vvEPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle ParkNC 27711
EPA-450/3-82-0016
June 1990
Air
Air Oxidation
Processes in
Synthetic Organic
Chemical
Manufacturing
Industry--
Background
Information for
Promulgated
Standards
Final
EIS
5,Ubrtry . .^ ^_
7? We«t Jackson Boulevard, 12ttl rim
tt 60604-3590
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EPA-450/3-82-001b
Air Oxidation Processes in
Synthetic Organic Chemical
Manufacturing Industry —
Background Information
for Promulgated Standards
Emissions Standards Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
June 1990
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Final Environmental Impact Statement
for Volatile Organic Compound Emissions from
Air Oxidation Processes in
Synthetic Organic Chemical Manufacturing
Prepared by:
JapK R. Farmer t
Director, Emission Standards Division
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
1. The promulgated standards of performance will limit emissions of
volatile organic compounds from mew, modified, and reconstructed air
oxidation processes. Section 111 of the Clean Air Act (42 U S C
rlrfl'™*Lmef ' d1r?cts the Administrator to establish standards of
performance for any category of new stationary source of air pollution
that . . -causes or contributes significantly to air pollution which
may reasonably be anticipated to endanger public health or welfare."
2. Copies of this document have been sent to the following Federal
Departments: Labor, Health and Human Services, Defensl Transportation
Arty* 1 f*l| 1 f IIV* A F ntntnAvif* s\ T i * jf* «»^*y '|viw^swii*uuiuil*
Foundation;'state and'Territorial^ir Poir?JtioneprogramaAdministrators-
Sf^if"!1 Adm1n\strators; Local Air Pollution Control Official;
Office of Management and Budget; and other interested parties.
3. For additional information contact:
Mr. Doug Bell
Standards Development Branch (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, N. C. 27711
Telephone: (919) 541-5568
4. Copies of this document may be obtained from:
U. S. EPA Library (MD-35)
Research Triangle Park, N. C. 27711
Telephone: (919) 541-2777
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
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This report has been reviewed by the Emission Standards Division of the Office
of Air Quality Planning and Standards, EPA, and approved for publication.
Mention of trade names or commercial products is not intended to constitute
endorsement or recommendation for use. Copies of this report are available
through the Library Services Office (MD-35), U.S. Environmental Protection
Agency, Research Triangle Park, N.C. 27711, or from National Technical
Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.
ii
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TABLE OF CONTENTS
PAGE
TITLE PAGE : , . . i
DISCLAIMER ii
LIST OF TABLES v1
1.0 SUMMARY 1-1
1.1 SUMMARY OF CHANGES SINCE PROPOSAL 1-1
1.1.1 Applicability of the Standards 1-1
1.1.2 Flare Operating Specifications 1-2
1.1.3 Total Resource Effectiveness (TRE)
Coefficients 1-2
1.1.4 Treatment of Compounds with Negligible
Photochemical Reactivity 1-3
1.1.5 Monitoring Requirements 1-3
1.1.6 Net Heating Value Equation 1-4
1.1.7 Maximum TRE Index Value 1-4
1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION 1-5
1.2.1 Alternatives to Promulgated Action 1-5
1.2.2 Environmental Impacts of Promulgated Action. . . 1-5
1.2.3 Energy and Economic Impacts of Promulgated
Action 1-5
1.2.4 Other Considerations 1-6
1.2.4.1 Irreversible and Irretrievable
Commitment of Resources 1-6
1.2.4.2 Environmental and Energy Impacts
of Delayed Standards 1-6
2.0 SUMMARY OF PUBLIC COMMENTS 2-1
2.1 AFFECTED FACILITY AND APPLICABILITY OF THE STANDARDS ... 2-1
2.1.1 Designation of Affected Facility 2-1
2.1.2 Request to Limit Applicability of the
Standards 2-10
2.1.3 Request to Exclude Manufacture of Nitrogenous
Fertilizers from Ammoxidation Processes 2-12
2.2 SELECTION OF BEST DEMONSTRATED TECHNOLOGY 2-12
2.2.1 Consideration of Other Control Devices 2-12
2.2.2 Application of Technologies with Lower
Cost and Energy Requirements 2-15
2.2.3 Catalytic Oxidation 2-16
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TABLE OF CONTENTS (CONTINUED)
PAGE
2.3 MODIFICATION 2-19
2.3.1 Provision for Increased Emissions of
Pollutants Other than VOC 2-19
2.4 ECONOMIC IMPACT 2-19
2.4.1 Lowering Economic Feasibility Cutoff 2-19
2.4.2 Plant Data Accuracy 2-22
2.5 COST ESTIMATION 2-23
2.5.1 Change in Cost Procedure Base Year 2-23
2.5.2 Incinerator Cost Estimation Procedure 2-24
2.5.3 Discrepancies in Proposal BID Cost
Information 2-28
2.5.4 Brine Disposal Costs 2-30
2.6 COST EFFECTIVENESS 2-31
2.6.1 Cost-Effectiveness Cutoff 2-31
2.6.2 Incremental Cost and Energy Impacts of
Requiring 98 Percent Control 2-36
2.7 MONITORING AND MEASUREMENT METHODS 2-37
2.7.1 Monitoring During Start-up, Shutdown, or
Malfunction 2-37
2.7.2 Request to Waive Performance Tests and
Monitoring Requirements 2-38
2.7.3 Alternative Methods of Demonstrating
Compliance 2-40
2.7.4 Request to Define "Continuous" 2-40
2.7.5 Request to Consider Alternative Measurement
Methods 2-41
2.7.6 Verification of VOC Destruction Efficiency . . . 2-41
2.7.7 Catalytic Oxidation: Location of Sampling
Site and Inclusion in Regulation 2-42
2.8 EXEMPTIONS 2-43
2.8.1 Organic Pollutants with Negligible
Ozone-Producing Capability 2-43
2.9 GENERAL 2-45
2.9.1 Documentation of Contacts with OMB 2-45
IV
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TABLE OF CONTENTS (CONCLUDED)
PAGE
APPENDIX A: TRE EQUATION AND COEFFICIENT DEVELOPMENT FOR
THERMAL INCINERATORS A-1
A.I INTRODUCTION A-1
A.2 INCINERATOR TRE INDEX EQUATION A-1
A.2.1 Incinerator TRE Index Equation Development . . . A-1
A.2.2 Example Calculation of an Incinerator-based
TRE Index Value for a Facility A-4
APPENDIX B: CAPITAL COST COEFFICIENTS
APPENDIX C:
FEDERAL REGISTER NOTICES OF ORGANIC COMPOUNDS
DETERMINED TO HAVE NEGLIGIBLE PHOTOCHEMICAL
REACTIVITY
INTRODUCTION.
42 FR 35314 .
42 FR 32042 .
42 FR 48941 .
B-l
C-l
C-l
C-2
C-5
C-8
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LIST OF TABLES
TITLE PAGE
2-1 List of Commenters on the Proposed Standards of
Performance for Air Oxidation Processes in the
Synthetic Organic Chemical Manufacturing Industry .... 2-2
A-l Air Oxidation NSPS TRE Coefficients for Vent
Streams Controlled by an Incinerator A-3
A-2 Maximum Vent Stream Flowrates and Net Heating
Value Characteristics for Each Design Category A-5
B-l Total Installed Capital Cost Equations as a
Function of Offgas Flowrate B-2
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1.0 SUMMARY
On October 21, 1983, the Environmental Protection Agency (EPA) proposed
standards of performance for air oxidation processes in the synthetic organic
chemical manufacturing industry (SOCMI) (48 FR 48931) under the authority of
Section 111 of the Clean Air Act (CAA). Public comments were requested on
the proposal in the Federal Register. There were 11 commenters, most of whom
consisted of industry representatives. Comments were also received from a
vendor of equipment used to control emissions from air oxidation processes,
and from a representative of an environmental group. On May 16, 1985, EPA
reopened the period for receiving written comments on the proposed standards
(50 FR 20446) to allow public comment on the results of EPA's reanalysis of
the costing procedures, the total resource effectiveness (TRE) equation and
coefficients, and the designation of affected facility. The reanalysis
resulted from public comments on the proposed standards and the acquisition
of new information collected since proposal. The comments that were sub-
mitted, along with responses to these comments, are summarized in this
document. The comments and subsequent responses serve as the basis for the
revisions made to the regulation between proposal and promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
Several changes and clarifications were made in the regulation as a
result of the review of public comments. These changes and clarifications
were made in the following areas: (a) applicability of the standards,
(b) flare operating specifications, (c) TRE coefficients, (d) treatment of
compounds with negligible photochemical reactivity, (e) monitoring require-
ments, (f) net heating value equation, (g) maximum TRE index value, and
(h-) miscellaneous changes.
1.1.1 Applicability of the Standards
In order to clarify the applicability of the standards, a list of
chemicals has been added to the regulation. This list is contained in
Section 60.617, Chemicals Affected by Subpart III. The list consists of the
36 chemicals which were identified in the background information document
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(BID) as being entirely or partially produced by air oxidation processes. To
accommodate this change, Section 60.610(a) of the regulation has been amended
to read as follows: "The provisions of this subpart apply to each affected
facility...that produces any of the chemicals listed in Section 60.617 "
1.1.2 Flare Operating Specifications
Operating specifications for flares used to comply with requirements in
new source performance standards (NSPS) have been added to Section 60.18 of
the General Provisions (51 FR 2701, January 21, 1986) since proposal of the
air oxidation SOCMI NSPS. Therefore, the regulation has been revised to refer
all owners or operators of affected facilities which use flares to comply with
this NSPS to the requirements in that section.
1.1.3 TRE Coefficients
Table 1 of the regulation presents the coefficients associated with the
TRE index equation. Some of the coefficients in this table were corrected to
predict more accurately the TRE indexes (and associated cost-effectiveness
values) of facilities. The modifications to the coefficients in Table 1
resulted from changes in the costing procedures on which these coefficients
are based. The changes in costing procedures and TRE coefficients are
discussed in the Agency's notice on reopening the public comment period for
the proposed air oxidation standards (50 FR 20446).
Several modifications were also made in the format of Table 1 to provide
clarity to owners or operators of air oxidation facilities. These
modifications included: (a) the designation of Category Al and A2 streams was
changed from "chlorinated" to "halogenated"; (b) the designation for flow rate
was changed from "W" to Qs" so that the symbol would match the symbol in the
EPA Reference Methods discussion; (c) the term representing flow rate
intervals for selecting TRE coefficients was changed from "design standard
flow rate" to "vent stream flow rate" to indicate that actual operating flow
rate should be used in selecting TRE coefficients; (d) the first flow rate
interval was deleted because for all vent streams with flow rates below the
minimum incinerator size (500 scfm) [14.2 scm/min], a flow rate of 500 scfm
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(14.2 son/rain) is used for the purposes of calculating capital and annual
operating costs; and (e) the term representing flow rate for Category E
streams was changed from "design standard flow rate" to "dilution flow rate -
(Qs)(Hr)/3.6" to indicate that dilution flow rate should be used in selection
of TRE coefficients.
1'1-4 Treatment of Compounds with Negligible Photochemical Reactivity
Several changes have been made in the regulation to allow facilities to
subtract compounds with negligible photochemical reactivity in determining a
TRE index value. The Agency believes that it is appropriate to exclude those
compounds in the regulation since they do not contribute appreciably to the
formation of ozone.
To allow for subtraction of compounds with negligible photochemical
reactivity in determining a TRE index, the Agency has amended the definition
of total organic compounds (TOC's) in the regulation. The definition of TOC
in Section 60.611 has been amended to indicate that the definitin of "TOC"
means TOC less all compounds that have been determined by the Administrator to
possess negligible photochemical reactivity. This definition is used only
when applied to Sections 60.614(d)(2)(1), measuring molar composition;
60.614(d)(5), the hourly emission rate (E^); 60.614(e)(l) and (e)(2), the
TRE index calculation; and 60.615(b)(4) and 60.615(g)(4), the calculation of
absorber, condenser, or carbon adsorber TOC vent stream concentration. For
all other quantifications of TOC under these standards, VOC equals TOC less
methane and ethane as defined in Section 60.614. The Federal Register
citations for the list of negligibly photochemically reactive compounds that
may be subtracted are presented in Appendix C and have also been added to the
definition of TOC in Section 60.611 of the regulation.
1'1-S Monitoring Requirement*
The "continuous recording" requirements have been changed. All
measurements such as firebox temperature, absorber liquid specific gravity,
carbon adsorber steam mass flow rate and other methods for demonstrating
compliance with the standards are now required to be taken at least every
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15 minutes. There are several advantages to this change in monitoring
requirements: (1) computer-assisted monitors are allowed, (2) the parameter
measurement frequencies required for monitoring and continuous recording are
consistent with the frequencies required for compliance testing, and (3) the
same equipment may be used for both monitoring and compliance testing.
1.1.6 Net Heating Value Equation
To be sure that the net heating value is calculated on a wet basis, the
definition of symbol "C," in Section 60.614(c)(4) was amended to include "on a
wet basis." The net heating value must be calculated on a wet basis because
the entire vent stream, including water vapor, would be combusted, and
therefore this is the heating value used in calculating a TRE value.
The reference method for determining the concentration of carbon monoxide
in the vent stream was changed from the EPA Reference Method 10 to ASTM D1946-
82. Section 60.614(d)(2)(ii) has been amended accordingly.
1.1.7 Maximum TRE Index Value
Several changes were made in the regulation to provide for inclusion of a
maximum TRE index value. The maximum TRE index value of 4.0 represents the
value above which monitoring and recordkeeping requirements would not be
imposed on a facility attempting to comply with the standards. It is the
judgement of the Agency that facilities with TRE index values above the
maximum could not lower the TRE index value below the cutoff without making a
process change. Thus, the Agency believes that the monitoring and
recordkeeping burden should not be imposed on such facilities. However, if a
process change occurs, the facility should recalculate the TRE index value as
required in Section 60.614(e). If the recalculated TRE index value is less
than or equal to 1.0, the owner or operator shall notify the Administrator
within 1 week of the recalculation and shall conduct a performance test
according to the methods and procedures required by Section 60.614 to
determine compliance with Section 60.612(a). If the recalculated TRE index
value is less than or equal to 4.0, but greater than 1.0, the owner or
operator shall conduct a performance test according to the methods and
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procedures required by Section 60.614 and shall comply with Sections 60.613,
60.614, and 60.615. Sections 60.610, 60.614, and 60.615 of the regulation
have been amended to incorporate the requirements associated with the maximum
TRE index value. If the TRE index value remains above 4.0, the owner or
operator need only keep a record of the recalculation.
1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION
1.2.1 Alternatives to Promulgated Action
The regulatory alternatives are discussed in Chapter 6 of the proposal
BID. These regulatory alternatives reflect the different estimated
percentages of facilities required to reduce emissions by 98 weight-percent
or to 20 parts per million by volume (ppmv) under a particular cost-
effectiveness cutoff. These regulatory alternatives were used in selection
of the best demonstrated technology (BDT), considering the estimated cost
impacts,, nonair quality health impacts, environmental impacts, and economic
impacts associated with each alternative. These alternatives have not been
changed.
1.2.2 Environmental Impacts of Promulgated Action
The changes in the regulation described above will have a minor effect
on the estimated air quality impacts attributed to the standards as originally
proposed. The new estimated air quality impacts of the standards are pre-
sented in the Agency's notice reopening the public comment period for the
proposed air oxidation standards (50 FR 20446). The changes in the regulation
will have a negligible impact on the water quality and solid waste impacts
attributed to the standards as originally proposed. These impacts are
described in Chapter 7 of the proposal BID. That analysis of environmental
impacts along with the new air quality impacts presented at 50 FR 20446 now
constitute the final Environmental Impact Statement for the promulgated
standards.
1.2.3 Energy and Economic Impacts of Promulgated Action
Section 7.4 of the proposal BID describes the energy impacts and
Chapter 9 describes the economic impacts of the proposed standards. The
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changes In the regulation described above will have a negligible effect on
these Impacts.
1.2.4 Other Considerations
1.2.4.1 Irreversible and Irretrievable Commitment of Resources.
Chapter 7 of the proposal BID concludes that other than fuels required for
the operation of volatile organic compounds (VOC's) control equipment, there
is no apparent irreversible or irretrievable commitment of resources
associated with the standards. The use of the TRE concept encourages the use
of recovery techniques or process changes to recover pollutants as products.
The control of VOC emissions using recovery techniques or process changes
might be an alternative to adding combustion controls for some air oxidation
facilities. This would result in the conservation of both chemicals and
fuels. The changes in the regulation described above will have no impact on
the commitment of resources.
1.2.4.2 Environmental and Energy Impacts of Delayed Standards.
Table 1-1 in the proposal BID summarizes the estimated environmental and
energy impacts associated with promulgation of the standards. If the
standards were delayed, adverse impacts on air quality could result. A delay
in promulgation would mean that affected facilities would be controlled to
the level specified in the appropriate State implementation plan (SIP).
Emission levels would consequently be higher than would be the case were the
standards in effect.
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2.0 SUMMARY OF PUBLIC COMMENTS
/
A total of 12 letters commenting on the proposed standards were
received. In addition, one speaker appeared at the public hearing to comment
on the proposed standards. The transcript from the public hearing, comments
on the proposed standards made at the public hearing, and the 12 letters
commenting on the proposed standards have been recorded and placed in the
docket. The list of commenters, their affiliation, and-the EPA docket item
number for each of the comments are shown in Table 2-1. The docket reference
is indicated in parentheses in each comment. Unless otherwise noted, all
docket references are part of Docket Number A-81-22, Category IV. The
comments have been organized into the following nine categories:
2.1 Affected Facility and Applicability of the Standards
2.2 Selection of BDT
2.3 Modification
2.4 Economic Impact
2.5 Cost Estimation
2.6 Cost Effectiveness
2.7 Monitoring and Measurement Methods
2.8 Exemptions
2.9 General
2.1 AFFECTED FACILITY AND APPLICABILITY OF THE STANDARDS
2.1.1 COMMENT: One commenter (D-6, D-6a) stated that the definition of
affected facility contained in the proposed regulation does not conform with
the requirements of the CAA insofar as it allows two or more air oxidation
reactors which are joined to a common product recovery system to be inter-
preted as one affected facility. As an example, the commenter pointed out
that if an existing facility consists of a single reactor, any changes in
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TABLE 2-1
List of Commenters on the Proposed Standards of Performance for
Air Oxidation Processes in the Synthetic Organic Chemical
Manufacturing Industry
Docket Number A-81-22, IV
Public Hearing
Commenter Docket Reference
Mr. A. W. Byer F-l
Process Engineering Consultant
Union Carbide Corporation
Post Office Box 8361
South Charleston, West Virginia 25303
Letters
Mr. H. Neal Troy . D-l
Manager, Environmental Control
Owens-Illinois, Incorporated
One SeaGate
Toledo, Ohio 43666
Mr. A. H. Nickolaus D-2
Chairman, CTG Subcommittee
Air Conservation Committee
Texas Chemical Council
1000 Brazos, Suite 200
Austin, Texas 78701
Mr. D. C. Macauley D-3
Environmental Affairs Manager
Union Carbide Corporation
Post Office Box 8361
South Charleston, West Virginia 25303
Mr. William T. McShea, D-4
Manager, TORVEX Environmental Products
Engelhard Industries Division
2555 U.S. Route 22
Union, New Jersey 07083
Mr. Mark Urbassik D-5
Manager, Environmental Regulatory Programs
Koppers Company, Inc.
Pittsburgh, Pennsylvania 15219
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Commenter Docket Reference
Dr. David D. Doniger D-6
Senior Staff Attorney
Natural Resources Defense Council, Inc.
1725 I Street, N.W., Suite 600
Washington, D.C. 20006
Geraldine V. Cox, Ph.D. D-7
Vice President
Technical Director
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, D.C. 20037
Mr. Gary D. Myers D-8
President
The Fertilizer Institute
1015 18th Street, N.W.
Washington, D.C. 20036
Mr. A. G. Smith D-9
Manager, Environmental Affairs
Shell Chemical Company
One Shell Plaza
Post Office Box 2463
Houston, Texas 77001
Mr. J. D. Reed D-10
General Manager
Environmental Affairs and Safety
Standard Oil Company (Indiana)
200 East Randolph Drive
Chicago, Illinois 60601
Mr. Keith M. Bentley . D-ll
Senior Environmental Engineer
Georgia-Pacific Corporation
133 Peachtree Street, N.E.
Post Office Box 105605
Atlanta, Georgia 30348
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Commenter Docket Reference
Mr. R. F. Kelley D-12
Assistant Corporate Director
Environmental Affairs
Union Carbide Corporation
Old Ridgebury Road
Danbury, Connecticut 06817
Mr. D. C. Macauley D-13
Environmental Affairs Manager
Union Carbide Corporation
Post Office Box 8361
South Charleston, West Virginia 25303
Geraldine V. Cox, Ph.D. D-14
Vice President
Technical Director
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, D.C. 20037
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that reactor during a 2-year period which result in cumulative costs of over
50 percent of the capital cost of a new reactor would make that reactor an
affected facility. However, if two or more reactors are joined in an
existing facility, similar changes to one reactor may not make that facility
subject to the standards because the capital costs are not likely to exceed
50 percent of the capital cost of the entire facility (i.e., single reactor
plus combined reactors). Thus, allowing two or more reactors to be joined in
the same affected facility would cause more emissions from air oxidation
reactors to go uncontrolled than would be the case were each reactor treated
as a separate affected facility.
According to the commenter, this broad definition of affected facility
in effect legislates a mechanism by which certain facilities may avoid the
standards. The commenter stated that the broad definition is not consistent
with the holding in ASARCO v. EPA, 578 F.2d 319 (D.C. Cir. 1978), which held
that the Agency could not define affected facility in a way which would allow
major units of production to go unregulated under the new source performance
standards (NSPS) without offering justification for the differential
treatment of identical sources. In this instance, the commenter concluded,
the Agency has offered no justification for holding reactors to different
standards depending on whether they are or are not joined to a common product
recovery system.
The commenter offered several suggestions for rectifying the definition.
First, the commenter recommended that all reactors be defined as affected
facilities. Alternatively, the commenter suggested that for cases where
several reactors are joined to a common product recovery device the NSPS
require a partial reduction in the total VOC emissions from the group of
reactors. The partial reduction should be equivalent to the reduction that
would be required in the emissions from the single new reactor were it the
only one connected to the product recovery system. A third suggestion
recommended by the commenter is that the Agency lengthen the period of time
over which capital investments will be accumulated in order to determine
whether a reconstruction has occurred.
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RESPONSE: As the commenter suggests, EPA's definition of the "affected
facility" in NSPS must be consistent with the definition of the term
"stationary source" in Section 111 of the CAA, as interpreted by the U. S.
Court of Appeals of the D.C. Circuit in ASARCO v. EPA. 578 F.2d 319 (1978).
As the commenter notes, the Court in ASARCO discussed the scope of EPA's
discretion in choosing the affected facility. The Court stated:
The EPA's definition of a "facility", which this court accepts, is "any
apparatus to which a standard of performance is specifically
applicable." [Citation omitted.] This definition is clearly designed
to designate as "facilities" those units of equipment -- be they
individual machines, combinations of machines, or even entire plants --
that the Agency finds to be appropriate units for separate emission
standards. A cursory review of EPA's regulations indicates that the
units designated as "facilities" under this definition are usually
larger than individual machines or single pieces of equipment, and are
sometimes whole plants. [Citation omitted.] In designating what will
'constitute a facility in each particular industrial context, EPA is
guided by a reasoned application of the terms of the statute it is
charged to enforce, not by an abstract "dictionary" definition. This
court would not remove this appropriate exercise of the Agency's
discretion. [Citations omitted.] 578 F.2d at 324 n. 17.
Consistent with this statement, EPA has selected the affected facility in
the air oxidation standards by looking at the terms and purposes of Section
111, as well as the characteristics of air oxidation plants. As EPA stated
at proposal, the main purpose of Section 111 is to minimize emissions by
requiring the application of BDT at all new, modified, and reconstructed
sources (considering cost, nonair quality health and environmental effects,
and energy impacts). The EPA believes that in most cases a narrow affected
facility designation will best further this purpose, because in most cases a
narrow designation ensures that all new emission units will be brought under
the coverage of the standards. If, for example, an entire plant is
designated as the affected facility, no part of the plant would be covered by
the standards unless the replacement caused the plant as a whole to be
"modified" or "reconstructed." If each piece of equipment is designated as a
separate affected facility, then as each piece is replaced, the replacement
piece would be a new source subject to the standards. For this reason, EPA
uses a presumption that the narrow designation is appropriate.
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The EPA treats the narrow designation only as a presumption, however,
because in some cases a broader affected facility may be more consistent with
the purposes of Section 111. For example, the Agency might choose a broader
designation if it concluded that either: (a) it would result in greater
emissions reduction than would a narrow designation; or (b) the other
relevant statutory factors (technical feasibility, economic, cost, energy,
and nonair quality health and environmental impacts) point to a broader
designation.
The EPA analyzed several alternative affected facility definitions for
the air oxidation standards, including: (1) each individual reactor with its
recovery system, (2) the group of reactors whose streams are ducted together
through a single recovery system, and (3) the entire plant. Using the
presumption mentioned above, EPA defined as a single affected facility each
reactor whose stream is sent to its own recovery system. The EPA concluded,
however, that when reactor streams are joined and sent through a single
recovery system the group reactors and their recovery system, rather than
each reactor, should be a single affected facility.
The EPA estimates a greater reduction in national VOC emissions using
the broader designation of affected facility. Greater reduction in emissions
will occur with the broader designation because for facilities where the TRE
index is less than 1.0, emissions from existing air oxidation reactors will
also be controlled when new reactors are combined with existing reactors
sharing a common recovery system. Under a narrow designation, when a new
reactor is combined with existing reactors, the new reactor is treated
separately. Thus, only emissions from the new reactor could potentially be
controlled.
The commenter did not comment on this reasoning. Instead the commenter
contended that when more than one reactor is vented to the same recovery
device EPA's designation will permit reactor replacements to avoid coverage
under the standards and will therefore result in less emission reduction than
would occur if the comnenter's affected facility designation were used. The
EPA disagrees with the commenter's analysis and conclusion. The replacement
of air oxidation reactors or pieces of recovery equipment is rare within the
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industry. This is because reactors are expensive pieces of equipment which
are designed to last a long time. Moreover, the Agency has concluded that
those few replacements which do occur often result from process changes
(e.g., from chlorination to hydrochlorination) or catastrophic events that
would probably require replacement of most of the group of reactors joined to
a single recovery system. These changes would likely amount to a "recon-
struction" of the facility as it is defined in these standards. Thus, in the
small percentage of cases where reactor replacements occur, the facility
would most likely fall under the coverage of the standards.
Furthermore, as EPA stated at proposal, the other types of reactor
changes that source owners would most likely consider are substantial changes
in catalysts, reactor conditions, or product separation purification equip-
ment. The cost of these changes is so great, however, that most owners would
choose to build new groups of reactors rather than radically modify
individual existing reactors. Thus, few air oxidation reactors would undergo
process changes that would subject them to the standards under either the
commenter's or EPA's designation. Moreover, under EPA's designation, in the
event an owner added a reactor to an existing group of reactors ducted to the
same recovery system, it is unlikely the facility could avoid being con-
sidered a modification by offsetting the new reactor emissions somewhere else
within the reactor group. This is because it would likely be technologically
infeasible to reduce emissions sufficiently or at all from the other
reactors. Although some VOC reductions could occur through upgrading
recovery equipment, it is unlikely that this reduction would result in a full
offset of the new reactor emissions because the increased load on the
recovery device (i.e., increased flow and VOC) would make the needed increase
in VOC removal efficiency difficult to achieve. Thus, the likely result is
that addition of a reactor to a group of joined reactors would bring the
entire set under the coverage of the standards as a modified facility.
In short, the broad evasion of the modification and reconstruction
provisions that might generally occur under broad affected facility
designations would not occur under EPA's designation for the air oxidation
standards. As discussed above, under EPA's designation, the inability of
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owners or operators to offset emissions from new reactors added to a set of
existing reactors would likely cause the entire set of new and existing
reactors to come under the standards as a modified facility. This results in
a greater emission reduction potential than would be the case for these
reactors under a narrow designation. For these reasons, EPA disagrees with
the commenter's premise that the affected facility designation in these
standards would result in foregone emission reductions and would therefore be
inconsistent with Section 111. Rather, EPA's selection of the affected
facility represents a reasoned application of Section 111, consistent with
ASARCO, because it couples consideration of both the need to secure the
greatest emissions reductions from new and modified emission units with the
technological realities of the air oxidation process.
A second reason for selecting the broader designation of affected
facility is that it facilitates implementation of the standards. When
several reactors feed process vent streams into a common recovery system, the
characteristics of the emissions vented into the atmosphere from the recovery
system are determined by both the process vent streams from each of the
reactors and the efficiency of the recovery system. Determining accurately
the contribution of each individual reactor to these emissions (i.e., each
reactor's TRE index value) can be complex and, therefore, costly. It
requires a mass balance calculation using three sampling sites: two which are
located upstream and downstream of the recovery system and one located just
downstream of the reactor.
Under the broader designation EPA is promulgating, however, only one
sampling site located after the last recovery device is needed to yield an
accurate determination of the facility's TRE index value. No estimation of
the recovery device efficiency on individual reactors is required because the
standards cover the entire vent stream. Therefore, there is no need to
determine which portion of the final vent stream from a group of reactors is
attributable to new, modified, and reconstructed reactors and which portion
is attributable to reactors that have not been changed or added. This
results in a decrease in both the cost and complexity of performance testing
because fewer sampling sites and_a simpler analysis are needed.
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Finally, the Supreme Court recently upheld EPA's similar interpretation
of the same term, "stationary source", in a similar context. Chevron,
U. S. A.. Inc. v. NRDC. 467 U. S. 837, 104 S.Ct. 2778 (1984). In that case,
EPA had defined the term as an entire plant for the purpose of implementing
the Section 173 new source permit requirements. The Court deferred to the
Agency's interpretation because Congress had not indicated how it would define
the term and EPA's construction was rational in light of the purposes of the
new source review program.
In reaching the first conclusion, the Court noted that Congress has
defined "stationary source" in Section 111 as "any building, structure,
facility, or installation" that emits air pollution. The Court found this
definition unclear, however, and held:
To the extent any Congressional "intent" can be
discerned from tnis language, it would appear that the
listing of overlapping, illustrative terms, was
intended to enlarge, rather than confine, the scope of
the Agency's power to regulate particular sources in
order to effectuate the policies of the Act.
Id. at 2791. Thus, Chevron supports the view that Congress left EPA
significant discretion to interpret the definition of "stationary source" for
purposes of implementing Section 111, so long as the Agency's interpretation
is reasonable in light of the statute's purposes. The EPA has exercised this
discretion by defining the "affected facility" in the air oxidation NSPS as a
collection of equipment that is smaller than an entire plant but larger than
each individual reactor. As indicated above, that definition reflects
consideration of the complexity of reactor-specific emission measurement, as
well as the degree of emission reduction that would result under the available
alternative definitions -- two factors centrally relevant to the purposes of
Section 111. In light of Chevron. EPA feels that this represents a
reasonable exercise of its discretion in interpreting the statute.
2.1.2 COMMENT: Three commenters (D-7, D-10, and D-ll) requested
clarification on the applicability of the standards. One commenter (D-ll)
stated that the definition of affected facility contained in the proposed
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regulation does not specifically limit the applicability of the standards to
air oxidation processes in the SOCMI. Consequently, the proposed standards
could be interpreted as also applying to air oxidation reactors in other
industries such as asphalt roofing and kraft pulp mills. Three commenters
(D-7, D-10, and D-11) recommended that the applicability provisions of the
proposed regulation be amended to specify that the standards are applicable
only to air oxidation processes which are used in the manufacture of certain
listed chemicals. Two of the commenters (D-7 and D-10) specifically
recommended that this list include those which were included in the standards
for fugitive emissions from the SOCMI at 40 CFR 60.489. The third commenter
(D-11) recommended that the 36 chemicals which were evaluated in the BID for
air oxidation processes be incorporated into the proposed standards.
RESPOND: In order to clarify the applicability of the standards
several changes have been made in the regulation. The Agency has amended
Section 60.610(a) of the regulation to read as follows: "The provisions of
this subpart apply to each affected facility...that produces any of the
chemicals listed in Section 60.617...." A list of affected chemicals has also
been added to Section 60.617. The Agency believes that this list will clarify
the applicability of the standards. The list consists of the 36 chemicals
which were identified in the BID as being entirely or partially produced ny
air oxidation processes. The list included in the standards for fugitive
emissions from SOCMI facilities includes many chemicals which are not produced
by air oxidation and thus is not appropriate for the air oxidation standards
To the Agency's knowledge, none of the listed chemicals are produced at
asphalt roofing plants and kraft pulp mills using air oxidation processes
Thus, air oxidation processes at asphalt roofing and kraft pulp mills would
not be covered by these standards. If any of the listed chemicals were
produced as intermediates or final products at asphalt roofing plants or kraft
pulp mills, the facility producing the listed chemical would be covered by the
standards.
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2.1.3 COMMENT: One commenter (D-8) stated that it should be made clear
that the provisions which specify that the standards apply to ammoxidation
processes refer to the production of synthetic organic chemicals such as
acrylonitrile, and not to processes for the manufacture of nitrogenous
fertilizers.
RESPONSE; As stated in the response to comments 2.1.2, applicability of
the standards is limited specifically to air oxidation processes (including
ammoxidation and oxychlorination) within the SOCMI. Only those chemicals
listed in Section 60.617 are subject to the proposed standards. This list
does not include any nitrogenous fertilizers. However, if any of the listed
chemicals were produced as intermediates or final products at a fertilizer
plant using an air oxidation process, the facility at that plant would be
covered by the standards.
2.2 SELECTION OF BDT
2.2.1 COMMENT; Three commenters (D-2, D-4, and D-7) indicated that the
selection of BDT was too restrictive in not allowing the use of other control
devices. One commenter (D-2) stated that catalytic oxidizers, boilers,
process heaters, and flares should be allowed as alternate combustion tech-
nologies. Another commenter (D-7) indicated that all of these technologies
have VOC destruction efficiencies comparable to those of thermal incinera-
tors. This commenter indicated that catalytic oxidation and flaring could be
more cost effective than thermal incineration for an individual plant.
Furthermore, the commenter stated that the regulation should allow the use of
other available technologies (e.g., membranes, wet air oxidation) that
achieve control efficiencies which are less than the 98 percent combustion
requirement, but which may be greater than those needed to meet the TRE
cutoff of 1.0. A third commenter (D-4) indicated that catalytic oxidation is
widely used within the industry and can be an attractive alternative to
thermal incineration.
Three commenters (D-2, D-4, and D-7) stated that in analyzing regulatory
alternatives inadequate consideration was given to control technologies other
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than thermal incineration. The commenters believe that the combustion
devices listed above should also have been analyzed.
RESPONSE: The regulation does not prohibit the use of any control
device that reduces VOC emissions by 98 weight-percent or to 20 ppmv (which-
ever is less stringent). These emissions reduction requirements represent
the capabilities of thermal oxidation which the Agency believes is BDT.
Based upon available data, the Agency believes that those combustion devices
mentioned by the commenters are capable of achieving 98 percent VOC
destruction efficiency in cases where they are applicable. Therefore, the
standards do allow the use of alternative control techniques, such as
boilers, process heaters, flares, and catalytic oxidizers, as long as the
owner or operator of a facility using one of these devices can demonstrate
that the emission reduction requirements and/or limits are achieved. The
control techniques (i.e., membranes, wet air oxidation) identified by the
commenter that do not achieve 98 weight-percent VOC reduction or 20 ppmv
outlet concentration are not allowed. If these techniques were found to be
capable of achieving these emission reduction requirements they would be
allowed. Under such circumstances, the owner or operator of an affected
facility using these devices would be required to demonstrate compliance as
indicated in Section 60.613(e). The owner or operator would also have to
provide information describing the operation of the control device and the
process parameter(s) which would indicate proper operation and maintenance of
the control device.
Several commenters were concerned that the Agency did not adequately
consider alternative control techniques in analyzing regulatory alternatives.
In order to analyze the impacts of this regulation upon all segments of the
industry, EPA first attempted to identify a technology or technologies that
would be available to all potentially affected SOCMI air oxidation
facilities. Thermal oxidation was the technology that best met this
qualification for the industry as a whole. Consequently, EPA focused on
thermal oxidation for the purposes of the impacts analysis. Thermal
oxidation is an expensive VOC control technique relative to other available
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control techniques. The use of thermal oxidation in the TRE equation
prevents an underestimation of the costs that may be incurred by facilities
since no facility will use a more expensive device and, in fact, some
facilities will use less expensive devices such as flares, boilers, process
heaters, and catalytic oxidizers. However, for these other control tech-
niques EPA was unable to identify any subcategory of air oxidation vent
streams where these devices would always be applicable.
The other available VOC control techniques (i.e., catalytic oxidizers,
boilers, process heaters, and flares) were examined, but were not included in
the impacts analysis for various reasons. Although catalytic oxidizers are
capable of achieving 98 percent destruction efficiency, some air oxidation
vent streams may have characteristics which would limit the applicability of
catalytic oxidizers. For example, vent streams with high heating values or
vent streams with compounds that may deactivate the catalyst may not be
suitable for applying catalytic oxidizers. Catalysts can be deactivated by
compounds sometimes present in the waste stream, such as sulfur, bismuth,
phosphorus, arsenic, antimony, mercury, lead, zinc, or tin. Deactivation of
the catalyst may also occur at high temperatures. Because of these
susceptibilities to individual waste stream characteristics, catalytic
oxidation has not been demonstrated to be universally applicable for VOC
emissions reduction from all air oxidation processes. The VOC destruction
efficiencies may vary among processes and among plants. Although catalytic
oxidation was not included in the impacts analysis, in many cases this device
may be able to meet the 98 percent VOC reduction requirement as stated above.
However, the Agency is unable with available information to identify sub-
categories of air oxidation processes for which these technologies would
always apply.
Other combustion devices, such as boilers, process heaters, and flares
were also examined and found not to be universally applicable. However, in
many cases, these devices can achieve 98 percent VOC reduction under various
operating conditions and thus are permitted as control devices subject to a
compliance demonstration (except for boilers greater than 44 MW
(150 million Btu/hr)), which are .exempted from the compliance demonstration
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requirement). The Agency, however, cannot identify those specific facilities
for which these technologies can always be used, and therefore, they cannot
form the basis for analysis of industry-wide impacts. Flares were not
considered before proposal because they are generally not used to control air
oxidation emissions in the SOCMI. Low heat content offgas streams such as
those found in air oxidation processes are typically not combusted in flares
before a substantial amount of supplemental fuel would be required to increase
the offgas heat content. However, the Agency does not intend to exclude the
use of flares. To facilitate their use, th« Agency has added operating
specifications, monitoring requirements, test methods, and a TRE equation to
the regulation for flares to provide guidance to those owners or operators of
an affected facility planning to comply with the standards by using a flare.
2.2.2 COMMENT: One commenter (D-6, D-6a) recommended that technologies
which involve lower costs and energy requirements than thermal incineration be
evaluated for application to reactors for which thermal incineration has been
determined to have too high a cost per ton of VOC destroyed. Specifically,
the commenter pointed to product recovery devices, such as carbon adsorption,
or other devices such as catalytic oxidation as technologies which should be
examined further by the Agency for application to sources which are currently
exempted from the thermal incineration requirement of the proposed regulation.
RESPONSE: Catalytic oxidizers and product/by-product recovery devices
(e.g., adsorbers, absorbers, and condensers) were examined but were not
considered as alternative BDT for facilities with a TRE index above 1.0. The
reason they were not considered is that the Agency was unable to identify
subcategories for which these devices would always apply. Section 11 of the
CAA requires the Agency to demonstrate that a technology is applicable in all
representative conditions. In the National Lime Association v. EPA. 627 F.2d
416 (D. C. Cir, 1980), the Court held that the Agency must account for the
factors that may contribute to the efficiency of the emission control system
or to the amount of emissions that would be discharged from the
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emission control system. The Agency recognizes that in some cases it may be
appropriate to develop subcategories for which different types or levels of
control would apply. However, in the case of the air oxidation NSPS this is
not feasible.
The performance of catalytic oxidizers is sensitive to many air
oxidation process vent stream characteristics such as those described in the
response to comment 2.2.1. The performance of product/by-product recovery
devices may be greatly affected by the vent stream flow rate, water content,
temperature, VOC concentration, and VOC properties such as solubility,
molecular weight, and liquid/vapor equilibrium. Since these characteristics
vary widely within the industry, it is not possible with available informa-
tion and resources to identify subcategories of air oxidation processes for
which these devices would always be applicable and to specify control
efficiencies under an industry-wide standard approach. Even with greater
resources, this approach would be infeasible because it would require a
stream-by-stream characterization, ultimately resulting in the need for a
separate standard for each individual air oxidation process used to produce a
listed chemical. The number of standards required to regulate the same
number of sources would increase significantly. The Agency feels that such
an approach to regulating the air oxidation industry would be
administratively infeasible and therefore environmentally counterproductive.
In any event, as the commenter recognizes, proceeding now with this generic
regulation based on thermal incineration at least represents an important
first step in regulating air oxidation emissions and does not preclude later
regulation of subcategories of air oxidation facilities should that become
feasible The EPA believes it has the authority to take this step-by-step
approach under Section 111. See, e^, fironp Against Smog and Pollution
v.-EPA, 665 F.2d 1284 (D. C. Cir. 1981).
2 2 3 COMMENT: Two commenters (D-3 and D-4) implied that the emission
reduction Squired in the regulation should be lowered to make provision for
catalytic oxidation as a resource-effective control method. One commenter
(D-3) indicated that catalytic oxidation could achieve a VOC destruction
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efficiency close to that of thermal incineration at a lower cost effective-
ness. However, the commenter indicated that to achieve 98 percent emissions
reduction his firm would have to install a thermal incinerator after the
catalytic oxidizer.
Another commenter (D-4) indicated that although catalytic oxidation can
be designed for VOC destruction efficiencies higher than 99.9 percent (i.e.,
comparable to efficiencies for thermal incineration), economic factors
dictate whether these levels are practical. The commenter added that the
98 percent destruction efficiencies associated with the proposed standards
would possibly require the use of uneconomically large catalyst volumes in
catalytic incinerators or the use of thermal incinerators. The commenter
pointed out that neither of these options may result in a measurable
improvement in the environment over the case of catalytic oxidation at an
efficiency slightly lower than 98 percent. Furthermore, the use of thermal
incineration instead of catalytic oxidation may possibly entail the following
detrimental effects: (a) higher energy usage by the affected plants, (b) an
increase in NO emissions from the affected plants using thermal
incineration, and (c) a decrease in the competitive position of domestic
chemical producers with respect to foreign competition.
RESPONSE: The Agency has decided to make no changes in the emission
reduction requirements of the standards. The standards require facilities to
achieve an emission reduction that reflects the capabilities of BDT, which
for certain facilities is reduction of VOC emissions by 98 weight-percent or
to 20 ppmv through incineration. The standards do not prohibit the
application of any devices, including catalytic oxidizers, which are used to
comply with the emission reduction requirements and/or emission limits. The
Agency believes, based upon available data, that catalytic oxidizers are
capable of achieving 98 percent destruction efficiency in all cases where
they are applicable. Since both types of units can meet the 98 weight-
percent reduction or 20 ppmv limit, the owner or operator would have the
flexibility to choose the device which he believes is best for the facility
in terms of cost or other technical considerations.
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Catalytic oxidizers do not, however, necessarily have the advantages
over thermal incinerators named by the commenters. Because of the potential
for greater heat recovery associated with recuperative heat exchangers used
in conjunction with thermal incinerators, thermal incinerators may in many
cases be less expensive and use less energy than catalytic oxidation units.
This has to be examined on a case-by-case basis by owners or operators with
facilities which can use catalytic oxidation. For these reasons, catalytic
oxidation does not necessarily have any advantage over thermal incineration
in terms of price impacts or competitive position of domestic producers
relative to foreign competition, as suggested by the commenters. The
potential impacts of domestic price increases associated with thermal
incineration were investigated and are not considered to be large enough to
significantly affect the competitive position of domestic producers relative
to foreign competition. Using conservative (high) control cost estimates,
chemical price increases are estimated to range from 0 to about 3 percent.
Further, the potential for increased NO emissions associated with thermal
^
incineration was also examined, but the rate of NO formation is expected to
A
be low due to relatively low combustion temperatures and relatively short
residence times.
One commenter stated that to achieve 98 percent emissions reduction with
a catalytic oxidizer his firm would have to install a thermal incinerator
after the catalytic oxidizer. In order to evaluate this statement, the
Agency requested information to determine the cost effectiveness of achieving
98 percent destruction efficiency with catalytic oxidation. However, the
commenter indicated that no data were available. Also, the Agency has
recently tested the destruction efficiency of catalytic incineration for
various VOC (see EPA-600/2-85-041). In this study, the Agency examined vent
streams similar in characteristics to the commenter's vent stream. The
results show that VOC destruction efficiencies greater than 98 percent were
achieved with temperatures ranging from 800°F to 900°F and residence times
ranging from 0.07 to 0.12 seconds. Thus, the Agency believes that catalytic
incinerators can achieve 98 percent VOC destruction efficiency and does not
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believe the commenter will need to Install a thermal incinerator after a
catalytic oxidizer.
2.3 MODIFICATION
2.3.1 COMMENT: One commenter (D-5) stated that the proposed regulation
would apply to any air oxidation reactor which is modified such that there is
an increase in the amount of any air pollutant emitted into the atmosphere.
The commenter pointed out that this could include a reactor which is modified
such that VOC emissions are decreased, but emissions of another pollutant are
increased. The commenter recommended that the modification provisions be
amended to include consideration of the following: (a) the specific pollutant
which causes the process change to become a modification, (b) the amount of
the increase in emissions, (c) the cost of the process change, and (d) the
level of control prior to the process change.
RESPONSE: The General Provisions, 40 CFR 60.14, define a modification
as "any physical or operational change to an existing facility which results
in an increase in the emission rate to the atmosphere of any pollutant to
which a standard applies" (emphasis added). In the case of the air oxidation
regulation, the only pollutant to which the standard applies is VOC; there-
fore, only increased VOC emissions would result in an existing facility
becoming subject to the NSPS modification provisions for air oxidation
processes. However, a modification which results in the increase of another
pollutant may cause a facility to have to comply with the provisions of
another part of the CAA such as prevention of significant deterioration (PSD)
or SIP requirements, or a different NSPS for a pollutant other than VOC.
2.4 ECONOMIC IMPACT
2.4.1 COMMENT: One commenter (D-7) stated that the economic feasibility
threshold of 20 percent of total plant capital cost used in the economic
analysis is too high. This commenter stated that the chemical industry is
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already devoting 10 to 15 percent of capital investment in new plants to
overall pollution control. This commenter pointed out that it is
unreasonable to set an economic feasibility threshold for one type of
pollution from one emission point at a level comparable to the total
environmental control costs. Specifically, this commenter recommended that
the cutoff figure be based on total capital costs for all forms of pollution
control at air oxidation facilities.
RESPONSE: The economic impact of air oxidation NSPS controls is a
function of the effects of the costs of compliance on the profitability of
air oxidation projects and on the availability of capital for those projects.
Profitability is the preferred measure of impact because of the profit
maximizing objectives of firms. Implicit in the profitability measure is the
likelihood that if a project meets profit objectives, the capital will become
available.
The profitability analysis showed that air oxidation NSPS controls would
not render projects economically infeasible that were otherwise economically
feasible. An explicit capital availability measure was also applied to see
if there might be circumstances where, regardless of expected profits, a firm
would find it hard to raise the necessary funds for a project. The capital
availability analysis showed that only one chemical might, under worst-case
cost assumptions, be produced under conditions where the capital control
costs exceed 20 percent of uncontrolled plant costs.
Unfortunately the Agency did not, and does not, have adequate, reliable
data on the costs of building uncontrolled plants for all air oxidation
processes. Reliance was placed on proprietary process economics data from
Stanford Research Institute (SRI), but it was not possible to fully match
SR'I's plant parameters with those in the national statistical profile data
base used to develop the air oxidation NSPS. Worst-case assumptions were
made to ensure conservative results. The results of the capital availability
analysis were used to identify chemicals and processes that warranted closer
examination.
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The analysis found only one chemical that might have capital control
costs in excess of 20 percent of uncontrolled plant costs. It is
1,3-butadiene. Over 85 percent of 1,3-butadiene capacity utilizes nonair
oxidation processes (extraction from ethylene plant by-product streams and
dehydrogenation of n-butane). New plants are expected to be all ethylene
by-product extraction plants. Only one air oxidation process is used today;
this is the oxidative dehydrogenation of n-butenes. The July, 1983
Mannsville Chemical Products Synopsis on butadiene, and the SRI 1983
Directory of Chemical Producers report that only two firms used this process
in 1982. One is the Firestone Synthetic Rubber and Latex Company, but it
recently closed the plant, which was in Orange, Texas. The only remaining
firm, Petro-Tex Chemical Corporation, operates a facility in Houston, Texas.
However, Report 7 of Organic Chemical Manufacturing, Volume 10: Selected
Processes (EPA-450/3-80-028e) states that the vent stream at this plant is
controlled by a thermal oxidizer. Thus, it appears that no new, modified, or
reconstructed 1,3-butadiene facility will have to install control equipment
as a result of this NSPS. The future facilities either will be nonair
oxidation, or will be in a situation where control would be installed even in
the absence of this NSPS.
With more complete process economics data EPA could look into possible
capital availability problems in more depth and for more of the air oxidation
chemicals. Unfortunately, the needed information was not provided by this or
any commenter.
The Agency also believes that the TRE cutoff will prevent situations
where capital control costs become unduly large. The capital cost of an
incinerator and associated equipment is mostly a function of the vent stream
flow rate and the presence of halogenated compounds, which necessitates
scrubbing. A high flow rate results in a high capital cost of control and a
high TRE. Other things remaining unchanged, as the flow rate increases, the
capital control costs as a percentage of the cost of an uncontrolled plant
will increase, but so will the TRE value until the TRE cutoff is reached and
control is no longer required. Because all other things do not remain
unchanged, it is not possible to establish an unambiguous relationship
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between the TRE cutoff and a corresponding cutoff percentage of plant costs
that must go toward control equipment. However, it is clear that the TRE
cutoff can, in rare instances where actual (not worst-case) capital control
costs may exceed 5 or so percent of uncontrolled plant costs, serve to limit
that percentage. Of course, one can postulate an extraordinarily cheap and
inefficient plant - one that produces more CO, C02, H20, and corrosive
waste, than product -- where the TRE cutoff will not serve as a check on
capital control costs as a percentage of uncontrolled plant cost. The EPA
does not consider such plants as likely.
The commenter also recommended that any criterion relating to capital
constraints be based on the total capital costs for all forms of environ-
mental pollution control. Section 8.2 of the BID (EPA-450/3-82-001a)
discusses the overall burden of environmental regulations on firms that may
be affected by the air oxidation NSPS. This discussion centers on total
annualized costs; that is, on capital and annual operating costs combined.
The EPA believes these annualized costs more accurately represent potential
burden on affected firms than do capital costs.
In short, EPA believes this NSPS will not impose unduly restrictive
capital problems on any segment of the chemical industry.
2 4.2 COMMENT: One commenter (D-9) stated that some plants have been
inaccurately recorded in the BID. This commenter listed Shell Chemical
Company plants that are either no longer producing an air oxidation chemical
or have changed to nonair oxidation processes. Finally, this commenter
stated that if these inaccuracies are widespread, a review of basic data may
be advisable to ensure that they support the NSPS.
- RESPONSE: Given that one of the earliest stages in the regulatory
standard-setting process involves data collection, it is not surprising that
some of the data are no longer current. Although the BID was published in
October 1983, many of the data go back to 1978. Continual updating is
expensive and can be unnecessarily burdensome to companies and trade groups
that participate in the cost updating procedure. For this reason, generally
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EPA only updates data considered essential to support the NSPS. For other
data, EPA relies on comments submitted by companies like Shell Chemical to
decide whether updating is necessary. It should be noted that Shell
submitted the only comment in this regard. Thus, although it would be nice
to have the list of producers of air oxidation chemicals current as of today,
the list of producers has minimal bearing on the economic impact analysis and
the standard itself. The EPA concludes that there is no need to update the
list of producers or the economic impact analysis.
2.5 COST ESTIMATION
2.5.1 COMMENT: One commenter (D-2) recommended that all costs discussed
in the preamble be inflated from 1978 dollars to fall 1983 dollars. This
commenter indicated that the cost-effectiveness cutoff would then become
$2,600/Mg instead of $l,900/Mg.
RESPONSE; The Agency agrees that the cost-effectiveness cutoff of
$l,900/Mg (December 1978 dollars) would be about $2,600/Mg in fall 1983
dollars. However, EPA maintains that this would not change the analysis or
the requirements of the standards. When the analysis for the air oxidation
NSPS was begun, it was decided that 1978 would be the appropriate base year
for costs because more recent data were not available. If the implicit price
deflator for the gross national product is applied, the cost-effectiveness
cutoff inflates 40 percent over the 5-year period. However, regardless of
whether it is expressed in 1978 or 1983 dollars, the cost-effectiveness
cutoff has the same impact. If a given facility cost effectiveness is
increased 40 percent by an inflation factor to $2,600/Mg, the cost-
effectiveness cutoff will also increase by 40 percent, since both values are
calculated using the same cost assumptions. Thus, the ratio will remain the
same, and the TRE index cutoff value will still be 1.0. Inflation does not
affect the validity of the TRE index. Furthermore, in considering an
inflated TRE cutoff, it should also be realized that the value of the
benefits associated with the standards are also inflated accordingly. Thus,
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EPA plans no change in the base year dollars for the costs discussed in the
preamble.
2.5.2 COMMENT: Two commenters (D-2 and D-7, D-14) stated that several
oversights and flawed assumptions exist in the cost estimation procedure.
Both commenters asserted that capital cost estimates allow for only 150 feet
of ductwork between the source and the thermal incinerator, although 300 to
500 feet would generally be required. Both commenters also indicated that
EPA failed to include in the capital cost component the total cost of siting,
bringing utilities to the site, and piping and instrumentation connections.
One commenter (D-2) stated that the capital cost estimate should be increased
by at least 10 percent to account for these oversights. In addition, both
commenters mentioned operating costs that were ignored include maintenance-
related labor costs, operating supplies, and laboratory costs. Both
commenters suggested that a factor'of 40 percent of maintenance and operating
labor be added to compensate for these oversights, as was done in the BID for
petroleum refining operations. One commenter (D-7, D-14) also asserted that
annualized costs should include an allowance of 15 percent of labor costs for
direct supervision, as listed in the BID for polymer manufacturing.
RESPONSE: In response to these statements claiming that the costing
procedures contain flawed assumptions, the Agency reviewed the procedures in
great detail. Revisions were made where determined to be.appropriate for
ensuring that the costing procedures result in representative costs.
Throughout the development of the air oxidation NSPS the Agency has made
efforts to ensure that the costing procedures result in estimates that
adequately represent control costs anticipated to be incurred by the majority
of facilities in the industry. Prior to proposal, industry members were
given the opportunity to provide substantial input into the development of
the costing procedures. Preliminary costing assumptions were reviewed by
industry and subsequently revised based upon industry input. After proposal,
costing assumption revisions were prepared and presented in a supplemental
Federal Register notice (50 FR 20446) on May 16, 1985. This notice solicited
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further comments on costing procedures. The bases for these revisions are
documented in Docket Item No. IV-B-8. As a result of the initial industry
involvement and the recent revisions based on industry public comments, the
Agency feels confident that the costing procedures result in accurate
estimates for typical air oxidation facilities. The specific assumptions
that are key for ensuring representative cost estimates are discussed below.
Certain assumptions were included in the procedures to avoid
underestimating costs incurred by facilities using combustion to control VOC.
These assumptions were made to ensure that control equipment sizes and
supplemental gas requirements were not underestimated. First, vent streams
were assumed to contain no oxygen to maximize estimated combustion air
requirements. Most streams, while not containing 21 percent oxygen, have
some smaller percentage of oxygen present. The assumption of no oxygen
ensures that no underestimate will occur for the equipment size, the combus-
tion air flow rate, and the amount of supplemental natural gas needed.
Second, actual offgas flow rate was increased by 5 percent in calculating
costs, which inflated gas consumption and equipment size by 5 percent.
Third, the temperatures and residence times assumed for cost estimation
purposes (l,600°F/.75 sec for nonhalogenated streams, 2,000°F/1 sec for
halogenated streams) are the highest temperature and residence time
conditions necessary to achieve a 98 percent VOC destruction efficiency for
air oxidation vent streams, as discussed in Appendix A of the proposal BID.
These higher temperatures and residence times would result in a larger
equipment size and higher gas consumption than the majority of air oxidation
facilities require. Fourth, the overall installation factors assumed for new
sources were 4.0, 2.5, and 3.5 for the combustion chamber, heat exchanger,
and waste heat boiler, respectively. These factors were all higher than the
EPA CARD Manual recommended factor of 2.17 (EPA-450/5-80-002) because they
incorporate contingencies recommended by the industry to account for
equipment that was not originally specified in the costing procedure.
Revisions were made where appropriate in the capital cost and the annual
operating cost assumptions used in the procedures. For example, in the
capital cost component of the procedures, the ductwork length was changed
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from 150 feet to 300 feet. The ductwork length increase is based on
specifications provided by the Industrial Risk Insurers (IRI) and the
National Fire Protection Association (NFPA). These organizations present
recommended distances for safely locating combustion sources from process
units in chemical plants. The recommended distance for locating a closed
combustion source such as an incinerator from a process unit is 200 feet. An
additional 100 feet was added to the IRI and NFPA recommendation to account
for routing the stream around process equipment before routing it away from
the process unit. The 300-foot figure is believed to be more representative
of industry conditions and is within the range recommended by the commenter.
In addition to the ductwork length change, the capital cost component of
the procedures also was modified to include 250 feet of pipe rack. The
Agency judged that since the standards will probably require the use of new
rather than existing incinerators and since newly constructed incinerators
would require about 300 feet of ductwork, it is reasonable to assume that
existing structures may not be available to support the piping. However, the
250 feet of pipe rack assumes that 50 feet of the 300 feet of ductwork would
be supported by existing structures.
Several revisions were also made in the annual operating cost component
of the procedures. These were revisions in the labor rate, in the calcula-
tion of total labor cost, and in the gas and electricity prices used. All
these annual operating cost revisions are discussed below and are explained
in more detail in a memorandum to the SOCMI air oxidation NSPS files (Docket
Item No. IV-B-8). The labor rate was changed to reflect more accurately the
actual value for 1978. The original incinerator labor costing was based on a
labor rate (including overhead) in 1979 dollars that was deescalated to 1978
dollars. The new labor rate is based on actual U. S. Bureau of Labor
Statistics for 1978 and does not include overhead and fringe benefits.
The revisions in the calculation of total labor cost were made to
explicitly calculate the cost attributable to overhead and fringe benefits.
The overall changes in the total labor cost calculation included:
(1) calculation of the supervisory labor cost as 15 percent of the operating
labor cost; (2) calculation of the overhead cost as 80 percent of the sum of
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operating, supervisory, and maintenance labor costs; and (3) calculation of
total labor cost as the sum of operating, supervisory, maintenance, and
overhead labor costs.
The natural gas price used in the costing procedures was revised to
represent more accurately the projected effects of natural gas deregulation
and account for regional variations in gas price. The previous estimate of
natural gas was based on prices projected through the first 5 years of the
regulation and then was deflated to 1978 dollars. This was done to reflect
the fact that gas prices have been rising more rapidly than inflation. The
previous estimate was made during a period of rapidly increasing energy
prices. However, the actual rate of increase has slowed since that original
estimate was made. Thus, to improve the accuracy and representativeness of
the gas price, a new projection was made. The gas price was derived by
projecting regional gas prices to 1990, taking a nationwide 1990 gas price
that was weighted geographically, and then deflating to 1978 dollars.
The price for electricity was modified to provide for a more accurate
estimate of 1978 costs. Although the electricity was originally based on
1978 costs, further examination showed that a more representative price could
be used.
Several of the commenters' suggestions were not incorporated in the
procedures because they were not justified. The recommended capital cost
items that were judged to be inappropriate included the costs for siting,
bringing utilities to the site, and piping and instrumentation connections.
The cost associated with bringing utilities to the site was not included
because the control device will be located in the proximity of the process
unit where utilities are readily accessible. It was not necessary to include
the cost for siting because this has already been included. An equipment
cost installation factor of 1.35, which increased equipment purchase price by
35 percent, was used to account for site development, fees, and general
contingencies. Neither was it necessary to include the cost associated with
piping and instrumentation connections, because these were already incor-
porated. An equipment cost installation factor of 1.20 was used to increase
the equipment purchase price by 20 percent to account for unspecified
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equipment. Also, an overall correction factor of 1.33 was used to increase
equipment purchase price by 33 percent to account for any miscellaneous items
associated with purchasing and installing control equipment that may have
been overlooked.
Some annual operating cost items recommended by the commenters were also
judged to be inappropriate. The items identified by the commenters included
maintenance-related labor costs, operating supplies, and laboratory costs.
It was not necessary to include maintenance-related labor costs because these
are already incorporated in the maintenance labor factor, which is calculated
as 3 percent of the total installed capital cost. Similarly, the cost
associated with operating supplies was not a missing item but was already
incorporated in the maintenance materials factor, which is calculated as
3 percent of the installed capital cost. Finally, it was determined that
laboratory expenses, such as those involved with testing scrubbing wastewater
effluent, are part of the normal operating and maintenance cost for an
incinerator/scrubber system that would be used to control vent streams with
halogenated compounds. Thus, factors for maintenance labor and maintenance
materials associated with such a system would incorporate laboratory
expenses.
In summary, the revised costing procedures do not result in annualized
costs that are significantly different from the costs estimated using the
procedures used at proposal. An examination of the data showed that
depending on the vent stream characteristics of a facility, the annualized
cost increased for some facilities and decreased for others. For the most
common type of air oxidation vent stream (Category B - nonhalogenated stream
with net heating value below 0.48 MJ/m3), the annualized cost increased by
about 3 percent.
2.5.3 COMMENT: Two commenters (D-2 and D-7) identified two
discrepancies in the cost information presented in the proposal BID. First,
for a given set of vent stream characteristics, the total capital cost
obtained from Figures 6-1, G-2, and G-4 does not agree with the total capital
cost obtained from Figure 6-9 (a_composite of Figures 6-1, G-2, and G-4).
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For example, the commenter refers to a case based on a 10,000 scfm,
10 Btu/scf, Category B stream with 70 percent recuperative heat recovery. In
this situation, the capital cost obtained from Figures G-l, G-2, and G-4 is
$922,000, while the capital cost obtained from Figure G-9 is $850,000. One
commenter (D-2) noted a second discrepancy between the annualized incinerator
cost components given in Tables 8-5 and 8-7 of the BID and those used in
Table E-2. This commenter said that the investment multiplier in Table E-2
is higher than the investment multiplier in Table 8-5. Although the
annualized costs listed in Table E-2 appear to be in mid-1980 dollars, the
hourly rate for labor is lower.
RESPONSE; The Agency acknowledges the discrepancy noted by the
commenter concerning total installed capital costs obtained from Figures G-l,
G-2, G-4, and G-9. Upon checking the original data from which these graphs
were derived, the Agency has determined that the costs obtained from the
summation of the graphs showing individual component costs (i.e., G-l, G-2,
G-4) are correct. The composite graph (i.e., G-9), which should give the
aggregate of the total installed capital costs obtained from the individual
component graphs, is incorrect. However, even without correction, the
impacts of this error in the graph showing installed capital cost on the
total annualized cost would be relatively small. The impacts would be
relatively small because: (a) the error in the graph showing installed
capital cost is relatively small for most vent streams; and (b) the installed
capital cost, when annualized over the 10-year period, represents a small
fraction of the total annualized cost. Nevertheless, the Agency modified the
cost equations to correct the small discrepancy. The Agency has also revised
the table of TRE coefficients to make the TRE index equation reflect these
changes. A corrected copy of Table 8-5, which presents the capital cost
coefficients used in the cost equation, will be presented in Appendix B of
the promulgation BID.
The Agency also acknowledges the discrepancy noted by commenter (D-2>
concerning cost factors given in Tables 8-5, 8-7, and E-2. The cost factors
presented in Tables 8-5 and 8-7 are correct. The information presented in
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Appendix E comes from a similar appendix prepared for the air oxidation
Control Techniques Guideline (CTG) document. The cost factors from
Tables 8-5 and 8-7 were used in developing the TRE equation and coefficients
presented in the proposal regulation. However, it should be noted that some
of these factors have been revised. As indicated in the previous response
the gas, labor, and electricity factors were modified to improve the accuracy
and representativeness of the cost algorithm. These changes are explained
and documented in a memorandum to the SOCMI air oxidation NSPS docket (Item
No. IV-B-8). A corrected version of the appendix concerning TRE calculations
will be included in Appendix A of the promulgation BID. The cost factors
presented in the CTG have also been revised so that they are on a consistent
basis with the factors used in the air oxidation NSPS algorithm.
2.5.4 COMMENT: Two commenters (D-2 and D-7) disagreed with the
assertion in the preamble that annualized costs associated with the disposal
of sodium chloride from scrubbing incinerator flue gases containing halo-
genated compounds are insignificant and, therefore, are not included in the
cost estimates. Both commenters stated that disposal will be expensive
unless the plant is located near salt water and can get a permit to dump its
brine.
RESPONSE: Brine solutions are currently disposed of in a variety of
ways depending on site-specific conditions. These include direct discharge
to sewer systems and surface waters (fresh and salt water bodies or rivers),
discharge to evaporative lagoons, and injection into a disposal well.
Because it is not possible to determine which options will be selected by the
individual facilities analyzed, it would be impractical to represent all of
these types of brine disposal in the cost, analysis. Therefore, the costs
anticipated to occur at the majority of facilities handling halogenated
compounds were considered instead.
Data available to the Agency shows that most air oxidation plants
producing halogenated waste streams are located near the coast (see Table 3-6
of the Air Oxidation proposal BID,) where brine can be disposed of at a low
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cost either directly or indirectly into salt water (e.g., ocean or brackish
stream direct discharge). The Agency believes that most new, modified, and
reconstructed facilities will continue to use this relatively low cost
disposal option. For those few that may not, EPA believes the other
relatively low cost options will be used (e.g., fresh water or sewer
discharge) since available data show that industrial facilities with waste
streams similar to those from air oxidation plants are currently using these
disposal options extensively. Therefore, the Agency has no reason to believe
that any air oxidation facility will face a significant brine disposal cost
as a result of this NSPS (Docket Item No. IV-B-9).
2.6 COST EFFECTIVENESS
2.6.1 COMMENT; Three commenters (D-2, D-6, and D-7, D-14) indicated
that the $l,900/Mg cost effectiveness cutoff is unreasonable. One commenter
(D-6, D-6a) recommended that the cutoff be raised to a level higher than
$l,900/Mg so that the standards cover a greater number of emission sources
and, thus, a greater amount of emissions. This recommendation is based on
the commenter's perception that the inclusion of a greater number of sources
would reduce public exposure to pollutants emitted by air oxidation reactors,
including potentially hazardous pollutants. This commenter also stated that
cost effectiveness is inappropriate as the sole determinant for excluding
certain air oxidation reactors from the application of the proposed
standards. The commenter stated that cost effectiveness is an invalid basis
for deciding not to set standards on processes for which no perceptible
economic impacts have been shown. Two commenters (D-2 and D-7) stated that
the cost-effectiveness cutoff should be reduced to a lower level which is
more typical of VOC standards. Both commenters stated that the Agency has
not presented adequate justification for concluding that a $l,900/Mg cost-
effectiveness cutoff is a reasonable upper limit for application of the
standards. Specifically, these commenters assert that this higher figure
cannot be justified based on the presence of toxic constituents in the
discharge streams from air oxidation reactors. They point out that the
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control of toxic pollutants 1s the objective of standards developed under
Section 112 of the CAA [National Emission Standards for Hazardous Air
Pollutants (NESHAP)] and not standards such as these which are being proposed
pursuant to Section 111 of the Act (NSPS). The first commenter (D-7, D-14)
stated that the Agency: (1) has not presented data which quantifies the
presence of toxic pollutants in the emissions from air oxidation processes,
(2) has made no effort to correlate the costs of control with the degree to
which toxic pollutants are eliminated, and (3) has not shown that toxic
pollutants will be controlled to the same degree as other pollutants under the
proposed standards. The second commenter (D-2) contended that the preamble
does not adequately demonstrate that the presence of toxic pollutants in the
emissions from air oxidation reactors are sufficiently different from the
emissions from other VOC sources to justify a special consideration of their
hazards. Both commenters also state that although the cost of controlling VOC
emissions is analyzed as a "worst-case" situation, there are facilities which
will have to incur costs as high as $l,900/Mg. They contend that the Agency
has not justified costs this high as being either reasonable or appropriate
for these facilities.
RESPONSE; The EPA believes that its decision to consider cost-
effectiveness when determining the cutoff for applying the standards reflects
a reasonable interpretation of Section 111 of the CAA. In analyzing the
question whether the consideration of cost effectiveness is appropriate, EPA
looked to see whether Congress has "directly spoken to the precise question."
Chevron. U.S.A.. Inc. v. NRCD. 467 U.S. 837, 104 S.Ct. 2778, 2782 (1984).
Section 111 requires EPA to promulgate NSPS limiting emissions to the level
that reflects the best system of emissions reduction "which (taking into
consideration the cost of achieving such emission reduction, any nonair
quality health and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated."
Section lll(a)(l). Nothing in either Section 111 or elsewhere in the Act
defines "the cost of achieving such emission reduction." The plain meaning of
the phrase, however, is quite broad. This indicates that Congress implicitly
delegated to EPA the authority to interpret the phrase to encompass a range
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of Impacts, Including costs of control In relation to the emission reduction
achieved. Further, Congress did not specify any particular manner in which
EPA was to take these costs "into consideration." Thus, absent a clear
Congressional direction to the contrary discernible from the Act's history
Chevron, 104 S.Ct. at 2783, Section 111 gives EPA authority to reject NSPs'
control options on the ground that their costs are unreasonably high in light
of the emissions reductions they achieve. I/
The EPA has reviewed the legislative history of Section 111 and concluded
that no contrary intent is discernible. Most important, the history contains
no express repudiation of the use of cost effectiveness as one mechanism in
considering cost when setting an NSPS.
For these reasons, EPA believes that Congress implicitly delegated the
Agency the authority to decide how best to "take into consideration...cost" in
setting NSPS and, if the Agency concluded it was appropriate, to consider cost
effectiveness.
Further» 1n Portland Cemomt Association w T^I,, 513 F.2d 506> 508 (Q c
dr. 1975), cert, denied, 416 U. S. 1025 (1975) ("Portland if), the Court
stated that EPA may reject control options that result in a "gross
disproportion between achievable reduction in emissions and cost of the
control technique." Since the purpose of cost-effectiveness analysis is to
highlight such disproportion, this passage supports EPA's approach.
In selecting cutoffs related to applicability of NSPS, EPA looks at a
variety of factors including: (1) the technical feasibility of additional
control; (2) the economic feasibility associated with different control
alternatives; (3) the magnitude of emission reductions associated with a
control alternative (e.g., a slightly higher cutoff could be selected if it
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led to a substantial Increase In the emission reduction achieved by the NSPS);
(4) the cost effectiveness (C/E) of the control alternative in terms of annual
cost per megagram ($/Mg) of emissions reduced; (5) the quality of the cost
estimates (e.g., worst case versus realistic estimates); (6) potential
reductions in other air pollutants not specifically regulated by the NSPS
resulting from a control alternative; and (7) the location of the sources
(e.g., urban versus rural). Because these factors vary from industry to
industry and, in some cases, within the same industry, decisions on the
appropriate level of control are made on a category-by-category basis.
In evaluating the above factors, EPA found that the following
considerations were key to the selection of the appropriate cutoff for SOCMI
air oxidation processes: (1) the cost effectiveness of NSPS for VOC emissions
previously promulgated by the EPA; (2) the fact that air oxidation vent
streams contain compounds that are considered potentially toxic by EPA; and
(3) the likelihood that these maximum costs will not be incurred by industry.
A survey of the VOC standards for other source categories shows that the
cost effectiveness of those control requirements has sometimes ranged as high
as $2,000/Mg. (See Docket Item No. IV-B-14.) The Agency's experience in
implementing these standards reveals that NSPS requiring this level of control
have proved a useful tool in bringing about the installation of much emissions
control technology, significant reductions in emissions, and corresponding
improvements in air quality, yet have not imposed costs that appear "grossly
disproportionate" to the emission reduction achieved. Portland II. 513 F.2d
at 508. Such an approach simply makes this NSPS consistent (as to dollars
spent per metric ton of VOC removed) with the existing body of NSPS
regulations, all of which have either been promulgated without legal challenge
or have been judicially upheld.
EPA also considered available evidence that air oxidation streams include
compounds that may be toxic. 2/ Although that evidence has not yet resulted
2/ The Agency has adequately documented that this is the case. (See Wehrum,
W. et a"!., "Air Toxics Emission Patterns and Trends", Docket Item No. IV-A-3,
and Registry of Toxic Effects on Chemical Substances, Docket Item
No. IV-J-9). Moreover, it is apparent that combustion of those streams will
reduce those compounds proportionately. (See, e.g., "Thermal Incinerator
Performance for NSPS", Docket Item No. II-B-3). The Agency received no
comment questioning this documentation.
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in a determination that those compounds should be listed as hazardous under
Section 112, EPA considered this potential toxicity along with other relevant
factors when choosing the cutoff. As stated in EPA's Air Toxic Strategy
published in July 1985, the Agency will consider the likely toxic pollutant
control benefits in the course of carrying out its responsibilities under
Section 111. This strategy reduces emissions of potentially toxic compounds
from new sources and from industries as their facilities are reconstructed or
modified. This approach achieves significant reductions in these compounds of
concern while the Agency evaluates them for regulation under Section 112. The
Agency disagrees with the argument that EPA has no authority to do this. The
EPA is not attempting here to regulate streams based on a decision that they
contain hazardous air pollutants within the meaning of Section 112. Rather,
the Agency is simply considering all available evidence within the framework
of Section 111. Section 111 does not attempt to restrict EPA's discretion to
consider all relevant factors in making that decision, and certainly the
potential toxicity of a stream is relevant to the control requirement
selected. Many SOCMI facilities are located in urban areas and, as a result,
many people will be exposed to any hazardous air pollutants emitted from these
facilities,
A third consideration in setting the cutoff at $l,900/Mg is the
likelihood that no facility will actually have to incur the costs implied by
that cutoff. The reasons are: (a) less expensive combustion control may be
used, thus reducing the costs and cost effectiveness incurred by individual
facilities; (b) the cost estimates for thermal incinerators and natural gas
prices are overstated; and (c) the inherent flexibility within the regulation
encourages the use of product recovery modifications that will significantly
reduce the cost incurred by individual facilities that may have otherwise had
to add a combustion device. The regulatory analysis assumes that each air
oxidation process vent would have its own combustion device and would need
separate ducting and support structures. It is expected, however, that some
air oxidation processes will share control systems with other process vents.
The analysis also assumes that thermal incinerators or flares will be useful
to reduce VOC emissions by 98 weight-percent. Data on current capital costs
of thermal incinerators indicate that units are now available at substantially
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reduced costs compared to the costs used in developing these standards. Lower
capital costs would reduce the annualized costs estimates, also, but not as
significantly. This is an important consideration in selecting the
appropriate cost-effectiveness cutoff. Another consideration is the fact that
natural gas prices used to calculate the cost-effectiveness for each stream
are overstated by about 40 percent, even though they were updated after
proposal (see following section on "Costing Revisions"). These conservative
assumptions have resulted in higher cost and cost-effectiveness estimates than
will actually occur. Finally, the standard encourages pollution prevention by
not requiring 98 weight-percent reduction if a TRE index greater than 1.0 is
maintained. The EPA believes that many facilities having a TRE index just
below the 1.0 cutoff (equivalent to $l,900/Mg) will upgrade product recovery
to reduce VOC and raise their TRE index above 1.0. This will significantly
reduce the cost of control incurred by the industry while reducing emissions
and will also minimize the national energy impacts. A preliminary examination
of the national statistical profile shows that because many facilities have
the potential to reduce VOC emissions sufficiently to raise their TRE values
above 1.0, the highest cost effectiveness that a facility will actually incur
as a result of installing a combustion device is estimated to be approximately
$l,400/Mg.
The EPA believes that this process reflects a reasoned interpretation of
the phrase "taking into consideration the cost of achieving such emission
reduction," especially given the lack of clear Congressional guidance. The
commenters' arguments that EPA should have selected either a higher cutoff to
provide for a greater degree of protection of the public health, or a lower
cutoff because most VOC standards have lower costs in relation to the
resulting emission reduction, fail to provide a more reasoned methodology for
selecting the appropriate level. Instead, they merely reflect each of the
competing goals reflected in Section Ill's history, as described above.
Consideration of all of the above factors confirmed EPA's belief that a
TRE value of 1.0 (i.e., $l,900/Mg) represents an appropriate cutoff for
determining which facilities must reduce VOC emissions by 98 weight-percent or
to 20 ppmv. The cutoff is specific to the SOCMI air oxidation processes
sources category and would not necessarily be appropriate for other source
categories; therefore, it should not be viewed as a benchmark for other
standards.
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2.6.2 COMMENT: One commenter (D-5) stated that the incremental cost and
energy impacts of requiring 98 percent control versus 95 percent control of
VOC emissions from affected facilities should be investigated further.
Specifically, the commenter believes the Agency should consider that source-
specific conditions such as fuel value, temperature, and volume vary widely.
RESPONSE: The Agency has determined that 98 percent destruction
efficiency represents BDT. In determining the level of control which
represents BDT, the Agency examined emissions data from incinerators already
operating within the industry as well as incinerator tests conducted by the
Agency and by chemical companies. The data show that all the new, well
operated incinerators were achieving 98 percent destruction efficiency or
could achieve 98 percent after adjustment. The Agency also found that at the
lower temperature and shorter residence time required for lower efficiencies,
some VOC may not come into contact with sufficient oxygen at a high enough
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temperature to enable the oxidation of VOC to proceed to completion. As a
result, there is greater chance that partially oxidized organic compounds
(e.g., aldehydes) and carbon monoxide may be generated.
As indicated in the response to comment 2.2.3, the air oxidation
standards are structured in a way which prevents any facilities from
incurring an unreasonable cost effectiveness. The Agency has found that
because of the wide variation in vent stream characteristics, both the cost
and cost effectiveness of control may vary considerably depending on the
chemical and the process. Further, the Agency has determined that the cost
of control would be unreasonable for some facilities. Consequently, the
standards are structured with the TRE index cutoff to require only those
facilities that can control cost effectively to achieve a 98 weight-percent
reduction efficiency or reduction to 20 ppmv.
The Agency recognizes that there are source-specific characteristics
(e.g., market conditions, process design, and geographic conditions) that may
impact the cost of VOC emissions control for individual facilities. To
address the source-specific characteristics would have required separate
standards for each facility reflecting the differences in source-specific
characteristics. The Agency is unable with the available information and
resources to evaluate all source-specific characteristics of each facility
that could potentially be affected by the air oxidation NSPS.
2.7 MONITORING AND MEASUREMENT METHODS
2.7.1 COMMENT: One commenter (D-7) stated that the requirements for
continuous monitoring of VOC are unclear. This commenter indicated that the
proposed NSPS could be read to require continuous monitoring even during
periods of start-up and shutdown. Specifically, this commenter pointed out
that this interpretation is arbitrary and inconsistent with the EPA general
enforcement policy. This commenter said that EPA regulations normally allow
for temporary excursions due to start-up and shutdown.
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RESPONSE: The General Provisions, at 40 CFR 60.8(c), do allow for
temporary excursions due to start-up and shutdown of the affected facility.
This means that emission levels during these periods are not counted as
violations if they exceed the levels specified in the regulation. This does
not mean that a facility is exempt from monitoring requirements during these
periods; on the contrary, Section 60.13(e) states that "except for system
breakdowns, repairs, calibration checks, and zero and span adjustments . . .,
all continuous monitoring systems shall be in continuous operation." In
addition, Section 60.11(d) states that any affected facility and associated
air pollution control equipment must, to the extent practicable, be main-
tained and operated at all times, including periods of start-up, shutdown, or
malfunction of the affected facility. Monitoring is necessary to determine
how often and for how long periods of start-up, shutdown, or malfunction
occur and to assure that the affected facility and control device are being
operated in a manner consistent with good air pollution control practice for
minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based, in part, on monitoring
results. Therefore, it is essential that monitoring be conducted
continuously.
2.7.2 COMMENT; .One commenter (D-ll) agreed with EPA and stated that it
is appropriate to waive performance tests and monitoring requirements for
sources incinerating process vent streams in steam generating devices that
have heat input capacities of 44 MW (150 million Btu/hr) or greater. This
commenter suggested that the following conditions be required for exemption
from performance testing and monitoring requirements: (a) boilers with heat
input capacity of 44 MW (150 million Btu/hr) or greater, (b) combustion
devices maintaining a combustion temperature of 1,100°C and 1 second
residence time, and (c) incineration devices maintaining a temperature of
870°C and 0.75 second residence time if no halogenated organic compounds are
present in the vent gas.
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RESPONSE; The EPA believes that condition (a) mentioned by the
commenter is sufficient for exemption from performance tests. However,
conditions (b) and (c) mentioned by the commenter are not sufficient. An
incineration device operated at temperatures greater than 1,100°C and
1 second residence time (870°C and 0.75 second residence time for non-
halogenated streams) will achieve a 98 percent VOC reduction providing that
proper mixing has been achieved. The reactor offgas, combustion gases, and
supplemental air must be well mixed in order to achieve complete combustion.
The EPA has determined that proper mixing is, in fact, as important as
temperature and residence time in determining incinerator efficiency. This
concept is explained in an EPA memorandum (Docket Item No. II-B-3).
Improperly mixed gases may actually offset the increases in efficiency
generated by raising the combustion temperature. This is due to the fact
that increases in temperature only increase the destruction efficiency for
VOC within the well-mixed portion of the waste gas. In an improperly mixed
stream, therefore, the increase in temperature does not greatly affect
combustion efficiency.
Unfortunately, mixing is a variable which cannot be measured. Proper
mixing is generally achieved through a trial-and-error process of adjusting
the incinerator after start-up. There is no practical method of ensuring
that proper mixing occurs except by conducting a performance test and making
the necessary adjustments. For this reason, incinerators operating at the
temperatures and residence times expressed by the commenter in conditions (b)
and (c) are not exempt from the performance test requirements.
The EPA has determined that steam generating units with heat input
capacities of 44 MW (150 million Btu/hr) or greater consistently achieve
proper mixing. These units have conditions of temperature and residence time
that generally are well in excess of the most severe conditions necessary to
achieve 98 percent efficiency. It is to the economic advantage of the owner
or operator to design and operate such devices with very good mixing of gases
to maximize the combustion efficiency and subsequent steam generation rate.
Thus, these steam generating units are exempt from the performance test
requirement of the standards.
2-39
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2.7.3 COMMENT; One commenter (D-ll) suggested that EPA provide for
alternative methods of demonstrating compliance when air oxidation process
emissions are combined with other emission sources within the plant. For
example, vent gases from air oxidation processes may be incinerated in
wood-fired boilers. Since wood-fired boilers inherently generate VOC
emissions, demonstration of compliance with the proposed regulation may be
difficult.
RESPONSE: The General Provisions, 40 CFR 60.8, state that the
Administrator may approve the use of "an alternative method [of demonstrating
compliance] the results of which [s]he has determined to be adequate for
indicating whether a specific source is in compliance" with -a standard. This
is applicable to all NSPS and need not be specified in the regulation.
When air oxidation streams are combined with nonair oxidation offgas
streams within the plant, compliance of the combined stream may be demon- •
strated using Reference Method 18 or an alternative method approved for the
particular facility by the Administrator. The EPA has determined that if
compliance is demonstrated with the combined stream, compliance would also be
achieved when routing the air oxidation stream alone.
In the commenter's example wherein a wood-fired boiler is used to
incinerate air oxidation vent gases, VOC will be generated by the combustion
device itself. In this case, the total VOC reduction would still have to be
98 percent. If the VOC generated by the wood-fired boiler prevents this, the
affected facility will not be considered in compliance with the standards.
2.7.4 COMMENT: One commenter (D-2) suggested that EPA define the term
"continuous" from Section 60.611 to represent a record with data sampled and
recorded at a frequency of at least 1 percent of the compliance period. This
commenter stated that such a definition would enable EPA to achieve its
purposes while still allowing industry to use a documentation system
compatible with existing computer-assisted control systems. This commenter
said that existing monitors record at a frequency varying from a few seconds
to several minutes. The commentej also stated that a separate analog system
with a continuous recorder Tvould be difficult to implement.
2-40
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RESPONSE; The EPA has agreed to clarify the meaning of "continuous" in
Section 60.611 as follows: "'Continuous recorder' means a data recording
device recording an instantaneous data value at least once every 15 minutes."
This definition will enable industry to use existing computerized data control
systems attached to a measurement device. Furthermore, this time interval has
been found to be an adequate time period for providing EPA with sufficient
data to ensure proper operation and maintenance of VOC control equipment.
2.7.5 COMMENT: One commenter (D-ll) stated that alternative measurement
methods should be considered for demonstrating compliance with the proposed
standards. This commenter stated that under the proposed regulation,
Method 18 is required for demonstrating compliance and would necessitate that
certain plants in the industry develop an analytical procedure with sufficient
sensitivity to demonstrate compliance with the standards. This commenter
indicated that other methods with sufficient sensitivity to determine
compliance are already available.
RESPONSE; As with comment 2.7.3, the General Provisions (40 CFR 60.8)
permit the Administrator to approve alternative means of demonstrating
compliance on a case-by-case basis, providing the proposed alternative method
is adequate for this purpose, or to waive compliance demonstration
requirements if the owner or operator has already adequately demonstrated
compliance. Since the General provisions are applicable to all NSPS,
provisions for approval of test methods need not be specifically stated in the
regulation.
2.7.6 COMMENT: One commenter (D-4) stated that the 98 percent VOC
destruction efficiency required for thermal incinerators should be verified by
analytical measurements and not just by operating temperature. The commenter
stated that this would provide a more accurate performance assessment and,
thus, enable both users and governmental monitoring authorities to judge the
relative merits of various control equipment designs against a consistent
standard.
2-41
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RESPONSE; The standards already require an initial performance test to
determine mass destruction efficiency using sampling and analytical methods,
as suggested by the commenter. During the initial performance test used to
demonstrate that the thermal incinerator is achieving 98 weight-percent
reduction of VOC emissions, the temperature is measured continuously. If the
efficiency is verified, then the temperature measured is used as a baseline
by which the owner or operator can determine proper operation and maintenance
of the control equipment, and it indicates that conditions have remained
unchanged from the initial performance test conditions. Deviations from this
"optimal" temperature can indicate significant decreases in control device
efficiency. Because of this, once initial performance testing has been
performed and a temperature baseline has been set, temperature monitoring
alone is sufficient to demonstrate proper operation and maintenance.
2.7.7 COMMENT: One commenter (D-3) stated that the sampling site for
TRE measurement should be located after a catalytic oxidizer when such a unit
is employed as an integral part of the system. The commenter also pointed to
an apparent inconsistency in the treatment of catalytic oxidation between the
BID and the proposed regulation. The commenter indicated that although the
in-process catalytic oxidizer is properly discussed in the BID, no rationale
is presented in either the BID or the preamble to the proposed regulation for
the exclusion.
RESPONSE: The CAA authorizes the Agency to minimize the emissions at
new, modified, and reconstructed sources by application of BDT. The
injunction does not constrain the Agency from regulating points that are an
integral part of the process (i.e., points other than the final emission vent
to'the atmosphere) for a facility within a particular industry. Certain
integral process points may be regulated when these points include devices
that are normally used as control units. The catalytic oxidation unit to
which the commenter refers is employed as an essential element in an inte-
grated air compression/energy recovery system. Although the unit is not used
as a terminal control device, itjs an efficient VOC destruction device and,
as such, performs the function of a control device. For the air oxidation
2-42
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NSPS, the use of a catalytic oxidizer is not excluded and the unit may be
employed as a control device when compliance testing shows a 98 percent VOC
destruction efficiency or 20 ppmv VOC emission limit (i.e., the control level
associated with BDT, thermal incineration). Based upon available data, the
Agency believes that catalytic oxidation units can achieve a 98 percent
destruction efficiency or 20 ppmv emission limit in cases where they are
applicable. The Agency has determined that for streams with a TRE index
below 1.0 (i.e., measured after the final recovery device but prior to a
control device), the cost of control would be reasonable. Thus, the Agency
believes it is proper to require the TRE measurement before the inlet to the
catalytic oxidation unit.
2.8 EXEMPTIONS
2.8.1 COMMENT: One commenter (D-5) stated that the regulation should
provide for an exemption in the case of organic pollutants which have been
demonstrated to possess a negligible ozone-producing capability (i.e., are
not photochemically reactive). This commenter indicated that no
consideration has been given to the ozone-producing potential of individual
VOC species.
RESPONSE: The air oxidation NSPS are intended to cover air oxidation
facilities that emit VOC (i.e., compounds which participate in atmospheric
photochemical reactions to produce ozone). Since compounds with negligible
photochemical reactivity do not contribute appreciably to the formation of
ozone, the Agency believes that it is appropriate to exclude these compounds
in determining a TRE index. Facilities should measure only VOC; rather than
TOC, when quantifying the hourly emissions rate for input into the TRE
equation. For example, if the vent stream of a facility contains 90 percent
negligibly reactive organic compounds and 10 percent reactive organic com-
pounds, only 10 percent of the organic compounds emitted from that facility
would be considered for calculating a TRE index. Although subtraction of
2-43
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negligibly reactive compounds is permitted, it is expected that no significant
change in national impacts will occur since very few air oxidation vent
streams contain these compounds.
To allow for the subtraction of compounds with negligible photochemical
reactivity in calculating a TRE index, several changes have been made in the
regulation. The definition of TOC's in Section 60.611 has been amended as
follows: "'TOC's means those compounds .... in Section 60.614. For the
purposes of measuring molar composition as required in Section
60.614(d)(2)(i), hourly emissions rate as required in Section 60.614(d)(5) and
60.614(e), and TOC concentration as required in Section 60.615(b)(4) and
60.615(g)(4), those compounds that the Administrator has determined do not
contribute appreciably to the formation of ozone are to be excluded. The
compounds to be excluded are identified in EPA statements on ozone abatement
policy for SIP revisions (42 FR 35314; 44 FR 32042; 45 FR 32424;
45 FR 48942)." These Federal Register notices are included in Appendix C of
this document.
Even though subtraction of compounds with negligible photochemical
reactivity is permitted in determining a TRE index value, the 98 weight-
percent reduction requirement and 20 ppmv emission limits in the standards are
based on the control of TOC's, minus methane and ethane. This is because the
Agency evaluated BDT based upon the control of TOC's, not just reactive
compounds. The Agency derived the weight percent emission reduction
requirement and emission limit for air oxidation processes from data gathered
using test procedures that measured TOC's, minus methane and ethane. No other
VOC species, including compounds with negligible photochemical reactivity,
were subtracted in evaluating BDT. Thus, to reflect accurately the
performance of the technologies selected as BDT and to make the emission
limits consistent with the data and test methods from which they were derived,
the Agency will continue to express the emission limits in terms of TOC's,
minus methane and ethane.
2-44.
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2.9 GENERAL
2.9.1 COMMENT: One commenter (D-6) requested better documentation of
contacts between EPA and the Office of Management and Budget (OMB),
especially in regard to the cost-effectiveness cutoff used in the proposed
standards. To substantiate this request, the commenter cited Sierra Club v.
Costle. 657 F.2d 298 (D.C. Cir. 1981), in which the court accepted the
practice of reducing oral communications to memoranda and inserting them in
the docket. This commenter also cited the CAA Section 307(d)(4)(B)(ii),
which requires written communications to be placed in the public docket.
RESPONSE: All correspondence between EPA and OMB directly related to
the proposed NSPS for SOCMI air oxidation processes is contained in Docket
No. A-81-22, which is available for public inspection. The correspondence
can be found under Docket Item Numbers II-C-24, II-F-1, and II-F-2. In
addition, EPA has identified three pieces of correspondence between the
Agency and OMB which discussed the development of a cost-effectiveness cutoff
as part of the preparation of the CTG for air oxidation processes. These
letters have been forwarded to the commenter and entered into Docket No.
A-81-22, Category IV-C.
The policy of how any communication between EPA and another Federal
agency should be treated by EPA has been clearly described in a letter from
the Administrator to the commenter's organization (Docket Item No. IV-C-3).
2-45
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APPENDIX A: TRE EQUATION AND COEFFICIENT DEVELOPMENT
FOR THERMAL INCINERATORS
-------
APPENDIX A: TRE EQUATION AND COEFFICIENT DEVELOPMENT
FOR THERMAL INCINERATORS
A.I INTRODUCTION
This appendix describes the development of the TRE index equations used
in the proposed standards for air oxidation processes. These equations can
be used to directly calculate the TRE index based on the vent stream flowrate
(scm/min), heating value (MJ/scm), and VOC emission rate (kg/hr).
A. 2 INCINERATOR TRE INDEX EQUATION
This section presents the method used to develop the incinerator TRE
index equation and an example calculation of the incinerator TRE index.
A. 2.1 Incinerator TRE Index Equation Development
The incinerator TRE index equation was developed in the following
manner. First, an equation for total annual ized cost was determined by
combining the equations for each component of the annual ized costs. The
equations for each annual ized cost component are shown in Docket Item
No. IV-B-14 and include annual ized capital costs, supplemental gas costs,
labor costs, electricity costs, quench water costs, scrubber water costs,
neutralization costs, and heat recovery credits.
The equation for total annual ized costs developed from the equations for
each annual ized cost component (Docket Item No. IV-B-14) was divided by the
amount of VOC removed and the reference cost effectiveness of $l,900/Mg of
VOC removed to generate the general TRE index equation. Collecting like
terms results in an equation with the following form:
TRE
s
f (Y)0'5]
where for a vent stream flowrate (scm/min) at a standard temperature of 20 C
is greater than or equal to 14.2 scm/min:
A-l
-------
TRE = TRE index value.
Q - Vent stream flowrate (scm/min), at a standard temperature of
s 20°C.
HT = Vent stream net heating value (MJ/scm), where the net enthalpy
per mole of vent stream is based on combustion at 25 C and
760 mm Hg, but the standard temperature for determining the
volume corresponding to one mole is 20 C, as in the definition
of Q$.
ETQC - Hourly emissions of TOC's reported in kg/hr measured at full
operating flowrate.
Y = Q for all vent stream categories listed in Table A-l except for
s Citegory E vent streams where YS - (Q$)(HT)/3.6.
where for a vent stream flowrate (scm/min) at a standard temperature of 20°C
that is less than 14.2 scm/min:
TRE - TRE index value.
Q = 14.2 scm/min
HT= (FLOW)(HVAL)/14.2
where:
FLOW = Vent stream flowrate (scm/min), at a temperature of 20°C.
Hy.. = Vent stream net heating value (MJ/scm), where the net enthalpy
per mole of vent stream is based on combustion at 25 C and
760 mm Hg, but the standard temperature for determining the
volume corresponding to one mole is 20 C, as in the definition
of Qs.
ETnr = Hourly emissions of TOC's reported in kg/hr measured at full
operating flowrate.
Y » Q for all vent stream categories listed in Table A-l except for
s dtegory E vent streams where Y$ - (Q$)(HT)/3.6.
The coefficients a through f are functions of incinerator design
parameters, such as temperature, residence time, supplemental fuel
requirements, etc. As discussed in Chapter 8 of the Air Oxidation Processes
A-2
-------
TABLE A-l. AIR OXIDATION NSPS TRE COEFFICIENTS FOR VENT STREAMS CONTROLLED BY AN INCINERATOR
DESIGN CATEGORY Al. FOR HALOGENATED PROCESS VENT STREAMS, IF
Q - Vent Stream Flowrate (scm/mln) »
14.2 < Q < 18.8
18.8 < Q* < 699
699 < Q* < 1*00
1400 < Q* < 2100
2100 < Q* < 2800
2800 < Q* < 3500
19.18370
20.00563
39.87022
59.73481
79.59941
99.46400
DESIGN CATEGORY A2. FOR HALOGENATED PROCESS VENT STREAMS, IF
Q - Vent Stream Flovrate (san/min) a
14.2 < Q < 18.8
18.8 < Q* < 699
699 < Q* < 1400
1400 < Q* < 2100
2100 < Q* < 2800
2800 < Q* < 3500
DESIGN CATEGORY B. FOR NONBALOGEKATED PROCESS
Q - Vent Stream Flowrate (scm/min)
14.2 < Q < 1340
1340 < Q* < 2690
2690 < Q* < 4040
DESIGN CATEGORY C. FOR NONHALOGENATED PROCESS
Q - Vent Stream Flovrate (scm/mln)
14.2 < Q < 1340
1340 < Q* < 2690
2690 < Q* < 4040
DESIGN CATEGORY D. FOR NONHALOCENATED PROCESS
Q - Vent Stream Flowrate (scm/mln)
14.2 < Q < 1180
1180
-------
proposal BID, there are six different design categories of incinerators.
Table A-2 presents the updated heating values and flowrate intervals
associated with each category. Substituting the design values into the
general equation allows values for coefficients a through f to be derived for
each design category. This derivation is included in Docket Item
No. IV-B-14.
The results of this derivation are summarized in Table A-l. As shown,
the coefficients are divided into six incinerator design categories. Under
each design category listed in Table A-l, there are several intervals of vent
stream flowrate. Each flowrate interval is associated with a different set
of coefficients. The first flowrate interval in each design category applies
to vent streams with a flowrate corresponding to the smallest control
equipment system easily available without special custom design.
The remaining flowrate intervals in each design category apply to vent
streams which would be expected to use two, three, four, or five sets of
control equipment, respectively. These flowrate intervals are distinguished
from one another because of limits to prefabricated equipment sizes.
A.2.2 c^pio ra1r.nat1o- •»* » TnHnerator-ha
for a Facility
This section presents an example of use of the TRE index equation. The
example reactor process vent stream has the following characterises:
1. q * 284 scm/min
2. HT =0.37 MJ/scm
3. ETQC =76.1 kg/hr.
4. Y =284 scm/min.
5. No halogenated compounds in the vent stream.
Based on the stream heating value of 0.37 MJ/scm, Category B is the
applicable incinerator design category for this stream. The flowrat,, «-.-
2 scm/min, and therefore the coefficients for the first flowrate interval
under Category B are used. The coefficients for Category B, flow interval
are:
A-4
-------
TABLE A-2. MAXIMUM VENT STREAM FLOWRATES AND NET HEATING VALUE
CHARACTERISTICS FOR EACH DESIGN CATEGORY
Minimum Net
Heating Value
Category (MJ/scm)*
Al 0
A2 3.5
B 0
C 0.48
D 1.9
E 3.6
Maximum Net
Heating Value
(MJ/scm)*
3.5
-
0.48
1.9
3.6
-
Maximum Process Vent
Stream Flowrate at
Incinerator Inlet
(103 scm/min)
0.70
0.70
1.34
1.34
1.18
1.18
These values are based on process vent stream conditions.
A-5
-------
a = 8.54
b = 0.106
c = 0.090
d = -0.171
e = 0
f = 0.010
The TRE equation is:
0.88 . _/n \ . jin \/u \ . _ / n 0.88 \ / u 0.881
TRE = E [a + b(Qsr°° + c(Q$) + d(Qs)(HT) + e(Q$
f (Qs)0-5]
TRE = (.013)[8.54 + 0.106 (284)0'88 + (0.090)(284)"°-171
(284) (.37) + 0 + (0.010)(284)0'5]
TRE = 0.111 + 0.199 + 0.332 - 0.236 + 0 + 0.002
TRE = 0.408
Since the calculated TRE index value of 0.408 is less than the cutoff value
of 1.0, this facility would be required to reduce VOC emissions by 98 weight-
percent or to 20 ppmv because the cost of incineration is considered to be
reasonable. Because the TRE index is a ratio of two cost-effectiveness
values, it is possible to calculate cost effectiveness for controlling any
vent stream given its TRE index value. The TRE index value of the facility
is multiplied by the reference cost effectiveness $l,900/Mg as follows:
TRE = 0.408
Reference cost effectiveness » $l,900/Mg
Cost effectiveness for example stream - (0.408) (1,900) = $775/Mg of
VOC removed
A-6
-------
APPENDIX B: CAPITAL COST COEFFICIENTS
-------
APPENDIX B: CAPITAL COST COEFFICIENTS
One comment received after proposal of the standards noted a discrepancy
concerning graphs in the proposal BID showing total installed capital costs
The data presented in these graphs were used to develop coefficients for the
capital cost equation shown in Table 8-5 (proposal BID). As indicated in the
response to public comments, the Agency has modified the cost equations to
correct the small discrepancy noted by the commenter. A corrected copy of
Table 8-5, which presents the capital cost coefficients used in the cost
equation, is presented in Table B-l.
B-l
-------
TABLE B-l. TOTAL INSTALLED CAPITAL COST EQUATIONS AS A FUNCTION OF OFFGAS FLOWRATE
,29,30
Category
Al
A2
B
C
D
b
E
Maximum
Flowrate
Per Unit
(Thousand)
(scm/inin)
0.74
0.79
1.52
1.52
1.34
1.34
Fabricated
Equipment
Cost
Escalation
Factor
.900
.900
.900
.900
.900
.900
Design
Vent
Size
Factor
.95
.95
.95
.95
.95
.95
Cl
803.11
786.61
259.89
297.99
236.35
236.35
C2
12.83*
12.44*
4.91
2.84
3.23
3.23
C3
0.88
0.88
0.88
0.88
0.88
0.88
Total Installed Capital Cost ($1,000) - (* of Units) x (Escalation Factor) x (Cl + C2 x
((Flowrate (son) divided by Design Vent Size Factor)C3))°
min
Flowrate Correction Factor of 1.12 - (1.14)" Incorporated into Coefficient C2.
Dilution Flowrate is Used in Capital Cost Equation.
Dilution Flowrate - (Design Flowrate) x (Original Heating Value) divided by (3.6 MJ/scm)
Flowrate per equipment unit.
B-2
-------
APPENDIX C: FEDERAL REGISTER NOTICES OF
ORGANIC COMPOUNDS DETERMINED TO HAVE
NEGLIGIBLE PHOTOCHEMICAL REACTIVITY
-------
-------
APPENDIX C: FEDERAL REGISTER NOTICES OF ORGANIC
COMPOUNDS DETERMINED TO HAVE NEGLIGIBLE
PHOTOCHEMICAL REACTIVITY
INTRODUCTION
As indicated by the Federal Register notices included in this appendix,
the following chemicals have been determined to be negligibly photochemically
reactive compounds: methane; ethane; 1,1,1-trichloroethane; methylene chlo-
ride; trichlorofluoromethane; dichlorodifluoromethane; chlorodifluoromethane;
trifluoromethane; trichlorotrifluoroethane; dichlorotetrafluoroethane; and
chloropentaf1uoroethane.
C-l
-------
35314
ENVIRONMENTAL PROTECTION
AGENCY
l«U.73S-»|
AIM QUALITY
on Control of VetetHe
The purpose of this notice to to rec-
ommend a policy for States to follow on
thu i*nntml nf yqlifflq ^ry»Tri>i """ttpflrouli
(VOC). which art a constituent in the
formation of photochemical "^11"*^
(smog) . ibis notice doee not place any
requirement! on States; State implemen-
tation Plan (SIP) provisions which offer
reasonable altemattres to this policy will
be approvable. However, this policy will
be followed by EPA whenever it is re-
quired to draft State Implementation
Flans for the control- of photochemical
Photochemical ozldants result from.
sunlight acting on volatile organic com-
pounds (TOO and oxides of nitrogen.
Some VOC. by their nature, start to form
oxidant after only a chart period of ir-
radiation-la the atmosphere. Other VOC
may undergo irradiation for a longer
period- before they yield, measurable
Jnlts (uidance.to States tar the prep-
aration, adoption, snd submittal of State'
Implementation Plans published in 1971.
the Environmental Protection Agency
empnastonrt reduction of total organic
compound «mt««iq««T rather than sub-
stitution. (See 40 CFR Part'SI, Appendix
BJ However, in Appendix B, EPA stated
• that substitution of one compound for
.. mother might b*.useful where it would
result to a clearly evident decrease In
reactivity and thus tend to reduce photo-
chemical ozidant formation. Subse-
quently, many State. Implementation
Plans were promulgated with solvent
substitution provisions similar to Rule
M of the LOB Angeles County Air Pollu-
tion Control District. These regulations
allowed exemptions for many organic
solvents which have now been shown
to generate significant photochemical
oxidant.
On January 29, 1976, EPA published
Its "Policy Statement on Use of the Cen-
eept of Photochemical Reactivity of Or-
. ganlc Compounds in State Implementa-
-. tton Plans for Oxidant Control.'' The
notice of availability of this document
appeared to the Fnnuu RiCBzn on
February S. 197« (41 FR 3330).
The 1978 policy statement emphasized
that the reactivity concept was useful
..at an interim measure only, and would
not be considered a reduction in organic
emissions for purposes of estimating at-
tainment of the ambient air quality
standard for oxldants. The document
also Included the following statement:
Although the substitution portions of Rule
ee and similar rules repment a workable
uut acceptable program at th* present time.
better (abnttntten regulation! can be de-
veloped, baeed oa current knowledge of re-
NOTtCE*
activity and industrial eapaaflltr. XPA m
eaUBbanaoB with State and iadotry repre-
••MUM «oi formulate IB urc an la-
prond rule ror national u*e.
-SUMMARY
Analysis of available data and infor-
mation show that very few volatile or-
ganic compounds are of such low photo-
chemical reactivity that they can be
ignored in oxidant control programs.
For this reason, EPA's «^rnr»«n^ttt
PoUcy reiterates the need for positive
reduction techniques (such as the reduc-
tion of volatile organic compounds in
surface coatings, process, changes, and
the use of control equipment) rather
than the substitution of compounds of •
low (slow) reactivity in the place of
more highly (fast) reactive compounds.
There are three reasons for this. First.
many of the VOC that previously have
been-designated as having low reactivity-
are now known to be moderately or
highly reactive in urban atmosphere!
Second, even compounds, that an pres-
ently known to have low reactivity can
form appreciable amounts of oxidant-
under mulUday «*»gn«Ufrci i*«idtq.rM
such as occur during summer in many-
areas. Third, some compounds of low
'
JrYeon 114. and Freon 115. which are cur-
reatly used as aerosol propellants. The.-
*»aqr to planning to Investigate control
•nOrns and substitutes for nonpropel-
- lans-usee under TBCA. as announced oa •
May 13. Methyl chloroform is not a fully
halogenated chloronuoroalkaae. Rather
It is among the chlorine-containing com-
pounds for which the Agency has not
completed its analysis: EPA has not yet
concluded whether it is or is not a threat
to the stratospheric ozone. Therefore. It*
has been placed on this list as an accept-
able exempt compound. As new informa--'
Hon .becomes available on these com-.
.pounds. EPA will reconsider the recom-
• 15*7ai£t5!Lors!*nte compounds listed*
in Table 2. while more photochemically "
reactive than, those in Table 1. never-
thelesa do not contribute large quantities;
of oxidant under many atmospheric coo.-.
Orponic. Compound*
fhotaeatmleat AeacttMty nut-'
Impt
Plant
O2 the small'number of VOC which
•have only negligible- photochemical re-
activity, several. (benzene, .aeetonlteile.
chloroform, carbon tetrachlortde. ethyl-
ene dlchlortde. ethylene dibromide. and
methylene chloride) have been identified
or implicated as being carcinogenic, mu-
tagenlc. or teratogenic. An' additional
compound, benzaldehyde. while produc-
ing no appreciable ozone, nevertheless,
forms a strong eye irritant under Irradia-
tion. In view of these circumstances, it
would be Inappropriate for EPA to en-
courage or support increased utilization
of these compounds. Therefore, they are
not recommended for exclusion from
control. Only the four compounds listed
In Table 1 are recommended for exclu-
sion from SIP regulations and. therefore.
it is not necessary that they be inven-
toried or controlled. In determining re-
ductions required' to meet oxidant
NAAQS. these VOC should not be In-
cluded in the base line nor should reduc-
tions in their emission be credited toward
achievement of the HAAQS.
'.It is recognized that the two halo-"
genated compounds listed In Table I
(methyl chloroform and Freon 113) may
cause deterioration of the earth's ultra-
violet radiation shield since they are
nearly unreactive in the lower atmos-
phere and all contain appreciable frae-'
tlons of chlorine. The Agency has
reached conclusions on tht effects of only
the fully halogenated chlorofluoroal-
kanes. The Agency on May 13. 1977 (43
FR 24542), proposed rules under the
Toxic Substances Control Act (TSCA) to
prohibit the nonessentlal use of fully
halogenated chlorofluoroalkanes as aero-
sol propellants. The restrictions were ap-
plied to all members of this *i«««, in-
cluding Freon 113. since they are poten-
tial substitutes for Freon 11.. Freon 12.
:UJ-THehloroethane (Methyl Chloroform^.''
Wchlemrlfinoroethaae (Freon 113)'
•• -xTfc«c compound* have beea Implicate*^
- ee haTtng-deleterloue effect* on atratoiphtrlet
-•ennBd. therefore, may be subject to ~ •-
..tnrecoatrau. .. „
.-.t organic Compound,
tan fhotoehtmiett Rtactiaity "
Methyl Ethyl Ketone
Methanol '..
Xnptopaaoi
Methyl Benaoate * '
Tertiary Alley! Alcohols
Methyl Aoetaie ..
Phenyl Acetate
Ethyl Amtna* •'• -
Acetylene
1C. N-dlaet&yl formaailde
Only during multlday stagnations dol
Table 2 VOC yield significant oxtdanta,'
Tlieiefuie. if resources are limited or : "
the sources are located in areas wbei..
prolonged atmospheric stagnations are*]
•uncommon, priority should be given ' "
conteofllng more reactive VOC first u—
Table 2 organics later. Table 2 VOC art}
to be Included in base line emission in-".,
^eateries and reductions hi them will b«r>|
credited toward achievement of the"
MAAQa Reasonably available control
technology should be applied to signlil--!
cant sources of Table 2 VOC where news- - -,
sary to attain the NAAQS for oxldants. «i
New sources of these compounds will also ^
be subject to new source renew require--.?
ments. ••"*'•§
• Perchloroethylene. the principal sola?,
vent employed in the dry cleaning indis-^ I
try. is also of low reactivity, comparable '
to VOC listed in Table 2. It was not la-
eluded to Table 2 because of reported ad- •
verse health effects. Uses, environmental • ,
distribution, and effects of perchloro-,-.l
ethylene currently are being studied is-..: I
tensively by occupational health author- '
ethylene currently are being studied in-
vestigations may have major impact aa
FtDERAl ttGISTH, VOl. «, NO. 131—WIOAY, JOIY I, l»7f , j»^ 3sJ» V - J"J J'fc.
C-2
-------
ttuiustrlal users, in designing control reg-.
for perchloroethyleni
particularly dry cleaners, eonsideratioa
should be given to these findings as well
as miliBlfy lequtieuients and the.eost of
applying controls. Available control tech-
nology Is highly cost effective for large
perfshloroethyiene dry cleaning* opera-
tions*. Howeveri for coin-operated and,
would represent a heavy "economic
burden.
As part of its continuing program, EPA
wfll review new information relative to '
NOTICES
Investigation showed that:
1. Solvent gnhst^tiffn tisagfl on Bute
or deletions win be T*JIF to *****
ll*t» of VOC in. Ttbeli 1 and 3. .
68 hat been dlncUonaOy correct
aggrente and probably effects some re-
ductions la peak ozldant level*. Bow*
ever, because of the relatively Ugh re-
aetMty of meet of tne substituted aol-
Tents. +J?ft ^^'MftlflTi Is small compared, to
that which ^*TI be f^^^nnUffrftl with
positive rffiinr***?!! tftfnrrtipiflB Bevisioa
of Rale S8 consistent with current knowl-
edge at reactivity would, flMflTi***t the
Solvent substitution option, for most
sources, In. which substitution la new em-
ployed. Many of toe organic solvent*
which have been categorized, a* having.
*1^ reactivl^ are. ln> fact*
y^i^sft «Eir poUutioB ffiuti'ni
of VOC
in t&tf Olittod
gate «t_cf tee I*m Angetoi Ownty Atr
I^oOottoB' QoirtFM Dtftrtcc. i&msBttf
Begatation 443 of to* Southern Cantor-
ate Air PoOutton Control Dlsaictt. Bate
«6 and similar regulations, incorporate
two basic strategies to reduce ambient
erately or. frfgfrfy reactive* +*»T yield.
Kiytiifli»aTifc oxldaat when, subjected, to
irradiation. In. smog chambers. designed to
simulate, the urban* atmosphere.
2. A few VOC yield, only negligible
ozone) whea <»*«*u*t*rf *** a
under beta urban, and. ru
al conditions.
to. fnfa
oth
'
tton. absorption, and the use' of low-sol-
veot coattags an acknowledged means of
reducing ambient oxidant levels: they
should be retained m future VOC control
programs. la contrast, the utfltty of sol-
vent substitution strategies has been
questioned as more information on pho-
to chemical reactivity ha* emerged.
EPA acknowledged the
of solvent substitution
based on Bute 66
reactivity criteria la a 1978 policy state-
meat (41 PR 53*0). Finding* were cited
which Indicated that almost aB VOC
eventually react m the atmosphere to
form some oxidant. Concurrently..EPA
initiated an investigation to consider im-
plications of revising the solvent substi-
tution aspects of Bate 66. Three separate
forms were conducted with repiBssntm
«*•*••• of State aad local air pollution
control agencies, university professors.
and industrial representatives with
knowledge and expertise ia-the fields of
Msaoapherte chemistry aad industrial
snlveat applications, to addition, nu-
merous dteraattons were held with ac-
knowledged experts la the Held. Topics
of particular concern were:
Bole M nttw.tta.leB, criteria
b» rertaed oonnitent wtttt available
data and yM be compaable with
pmcmti and wltfe product re-
""""•hetner torn* compound* am or «ufl-
H "<.tly low ""••"Bvlty taat tney-are not oxl-
•"reeunon and can be exempted from
under state Implementation Plan*.
teer tne imposition of naettvtty re-
ratettoo* in addition to porttln emlrtoa
f*«ueton« wm delay to* development or
or promiatag
• uee ot
and ethane, a. group
fans, and three other
bensaldehyde... and
afttnnltmn can ba- so-classified. Thaw
compounds react* vsry slowly yielding
llttla osan* during, .the, first few days.
(YlUlM! 'IIS, **<*<*• f»l*m»m ffft tfl^ ^frfywi'V^'^
Available data, suggest that none of the.
listed compounds. eoatrOmtst significant.
f.»
-------
35316
spread substitution of methyl chloroform
(U4 trtehloroethanel for the photo-
Fhemlcally reactive decreasing solvent
trJchloroethylene. Socb substitution un-
der Bole «« generation regulations has
already influenced industrial degreeslng
operations to the extent that methyl
chloroform production has surpassed
that of tnchloroethylene In the United
States. Any regulation in the area .win
have a marked effect on the production
and atmospheric •mln**""" -of both sol-
vents. Endorsing methyl chloroform sub-
stitution would Increase emissions, par-
ticularly in industrial States that have-
not, heretofore. Implemented Bute «8. On
the other hand, disallowing methyl cnlo-
roform as a substitute or banning it alto-
gether would significantly increase amis-''
sions of triehloroethylene even if de-
greasers were controlled to the limits of
available' technology. Presently.- teeh-
•nology is only able to reduce emissions by
approximately SO percent. In metropoli-
tan areas which- have already Imple-
mented Rule 88. a return to triehloro-
ethylene would have an advene effect
^*oo ambient oxldant Icvele. fit ad*flmfl»i to
;.bemg highly reactive, triehloroethylene
Alternative* to the abi
^would be (l)^devetopment and appllca-
.tton of h*f/***y efficient degreaser control
-•.systems'end -(2) 'replacement with an
NOTICES
ivttmntm^m.t^ solvent which is neither re*
•CUT* nor detrimental, to toe upper aw
mosphere. Major revision* would be
needed to degreaser "V^gr"* to improve
vapor capture above toe current best
level. Anticipated design ******tft could
add materiallr to degreaser costs. No. al-
ternative solvent is clearly acceptable
from ^f standpoints of photodi*1"1^*!
oxidant and stratospherie ozone deple-
tion. Neither methylene chloride nor
trtchlorotrtfluoroetaane are reactive, but,
like methyl chloroform, are suspected of *
causing damage to the stratospheric
none layer. In addition, methylene chlo-
ride 4» a suspect mutagen. Perchloro-
ethylene. the principal dry. cleaning sol-
Tent, does not present a hazard to the
stratosphere bat has been implicated as.
-being svcarcinogen and also reacts slowly
in the atmosphere to form oxidant.
7.- Organic solvents of low or negligible
p)^t««»hyn<««i,- • reactivity have only
chlorinated organics that find principal
applications as cleaners for metal* and
fabrics. A few nonhalogenated VOC such
as acetone, methyl ethyl ketone. and'
isopropanol are of low reactivity but
these, can't possibly satisfy afl the myriad
needs of the paint, plastics; pharmaceu-
tical, or many other-industries.. •While
users of reactive VOC usually can employ
' effective control equipment to recover or
destroy VOC emissions, they seldom have
the option of applying reactivity con-
siderations In choosing solvents. Applying
reactivity restrictions to the surface coat-
ing industry would be especially disad-
vantageous since it would greatly inhibit
the development of low-solvent coatings;
-essentially a*i of *h* organic solvents
wsffd to constitute high-solids coatings
and water-borne coatings are. in fact,.
highly reactive.
S. It Is recognized that smog chamber'
studies conducted to date are Incomplete
because many organic compounds have
not been examined and it ***** been lm-'
possible to duplicate all atmospheric sit-;
nations. Tor trample, there baa been.
ntily Htjiiffljf ygMtiitwfchm of OXidftnt fOT-.!
matlon under relatively high ratios of.*
VOC to NO, (30:1 and greater). compar-r
tre^ reactivity necessarily
to be open to revision as new information "
la developed which may show specific
organic compounds to be more or less.
DbotocnemlcaUy. reactive ^*MI indicated.'
by current data.: ' - • -
.Dated^JuneM, 1817.
. EDWABB P. Tuiax.
itant .Administrator
^-rrZ&mir tad Watt Uanoatmmt,,
[i D00.7T-H8M TOft 7-7-T7:8:4S *
uoisrn, VOL 42, NO. ui—fiioAt, JUIT t. 1*77
C-4
•M
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i. ft
32042
Federal Register / VoL 44. No. 108 / Monday. June 4. 1979 / Notices
Review under 42 U.S.C. I 719(b) (1977
Supp.) from an ordtr of the Secretary of
Energy.
. Copies of the petition for review have
been served on th« Secretary.
Department of Energy, and all
partfcipattts i
the Secretary.
Any person desiring to be heard with
reference to such filing thould on or
before June 12.1979. file a petition to
-intervene with the Federal Energy
Regulatory Commission. **? North
Capitol Street N-E> Washington. D.C
20438. in accordance with the
Cnmmissinn's rules of practice and
procedure (18 CFR L8). Any person
wishing to become a party or to
participate as a party must file a petition
to intervene. Such petition moat also be
served on the parties of record in this
proceeding and the Secretary of Energy
through Gaynell C. Methvin. Deputy
General Counsel for Enforcement and
Litigation, Department of Energy. 12th
and Femuyhreaia Ave, N.W,
Washington. D.C 20461. Copiw of the-
petition for review are on file with the
Commission and are available for public
inspection at Room 1000.023 North '
Capitol SUKE, Washington. D.C
204m
(Docket NO. mrvaei .
Triton 7fr4ai
•
ENVtRONMENTAL PROTECTION
AGENCY
detenmnannn the* it haa
PoOcyCo
htgO]
Area RateOptaiottNo. S9»Corr»tea ft.w.
<»Heiaed fc« certain sales
-------
Federal Register / VoL 44. No. 108 / Monday. June 4. 1979 / Notices
32043
chloroform and methylene chloride, do
not appreciably affect ambient ozone
levels. Hence. EPA will not disapprove
any state implementation plan or plan
revision for iti failure to contain
regulation* restricting emissions of these
Although these substances need not
be controlled under state
implementation plans for the purpose of
achieving ambient ozone «*»«"i*>>in*a
Ftutectluu Agencjr* 26 FeoenI Plszs«
Room 1008. New York, N.Y. 10007.
Attention; Coastal Plain Aquifer.
Information conCTf^^ff the QyastalE
Plain Aquifer System will be available
for inspection at the above address.
Dated: May ZL 1979.
BekanitCBwdc.
Adatinutntof,
pv Dec. rt-irat mw M-X M« «•)
ooti IMP «t M
[FRL 1239-3 OPP-OOMS]
Stete-FIFRA Issues) Research and
Evaluation Group (SFIREC); Working
Committee on Enforcement; Open
AQINCY: Environmental Protection
Agency (EPA). .Office of Pesticide
ACTiONe Notice of Open Meeting. _
SUMMARY: There will be a two-day
meeting of the Working Committee on
Enforcement of the State-FTFRA Issues
Research and Evaluation Croup
(SFIREC) on Tuesday and Wednesday,
June 5-8. 1979. beginning at 830 a.m.
each day, and concluding by 12 noon on
June 8th. The meeting will be held at the
Atlanta Town House. 100 Tenth Street
N.W, Atlanta. Georgia. Telephone: 404/
892 aaoq and will be open to the public.
KH rUMTMOl INKMMATION CONTACT:
Mr. William Buffalpe. North Carolina
Department of Agriculture. Raleigh.
North Carolina. Telephone: 919/733-
3558: or Mr. Anthony Dellaveccnia.
Pesticide ""^ Toxic Substances
Enforcement Division, EPA. 401 M
Street S.W, Washington, D.C,
telephone! 202/755-0014.
•UMtfJHMTAirf mpomiATiON; This the
second meeting of the Working
fnmmiHmm gg Enforcement The meeting
will be otucerued with the following
1. Plan for future recall and
uspension orders:
Section 28 and 27 of FIFRA:
3L Status of State-primacy use
— 4*Use of recommendations of
-pesticide sales representatives;
. 5. Discussion of definition of "non
uu|i lend;1* ° * •
8. FIFRA Section 7— producers of
active ingredients; end
7. Other enforcement matters which
may arise.
Dated: May 29.1970,
Dfputf Aniitant Adminutmtor for Pesticide
OM. i+xrm ntt M-m MI «^
C-6
-------
T^faj&ftii«. iffiiritu&tt^, NotiCM
:-. i •
lachicMwithmtfaedefiniUoaof >
»ontargetsitaa an areas of permanent-
human habitation inchiding permanent
residences, schools, churches, and anaa
u which substantial conmarcial -.
activities an condacied (*g_ aaoppfai
centers), domestic apiaries, and "':
pghllftyJ«.<««.<«^ BM^. ftj arf.flflp,^ .
aquatic habiiats such as critical -'
Aeries, municipal water supply "-
intakes aad other waters (which include
rivers, stnams. ponds, lakes, and . '.
ephemeral streams and ponds with .
flowing or standing water visible from
aa aircraft flying at an altitude of 1.000
feet above the terrain at the time of
treatment), are included within the
definition of a sensitive ana. The
»»•»« of «ny pesticide spray it not
permitted over a sensitive ana or in the
surrounding buffer zone. Buffer zones
are,defined aa anas intended to receive
only spray drift fallout from the
application sites.
The Agency recognizes diet some
seasonal dwellings, such as hunting and
fishing camps, may be located inor
adjacent to the treatment ana. These
dwellings an not considered to be
- permanent residences and thus will not
be buffered against direct application.
However, many of these dwellings an
"•"•qMMc sites listed in Table n
which will be buffered.
To minimize operational errors.
overflights of the treatment area prior to
the actual spray operation an
•nconraged. The purpose of these
overflights is to locate visually all
sensitive anas and buffer zones
designated on the spray block maps.
Particular attention should be given to
identifying ephemeral stream* and
ponds visible from an aircraft flying at
an altitude of looo feet or less above the
terrain at the time of treatment which
may not be designated on the spray
block, map due to their seaaonality.
consistent with tat purposes of thia
Act," . •.-,.-jt"- r-'.-: .„"' f.—"
Dated: May hUMi.'. .
»le
-------
1. REPORT NO.
EPA-450/3-82-QQlh
|«. TITLE AND SUBTITLE
fenufectZHM Pr°cefS6S 12 synthe«c Organic Chemical
Standards " Background Information for Final
• ""F.0"M'NO ORO'*NIZAT'0»' WAMl AND ADDRESS
Office of Air Quality Planning and Standards
L!' ST?™6?*31 Protection Agency
Research Triangle Park, North Carolina 27711
wiiu **uanuar U5
Office of Air and Radiation, U. S. EPA
Research Triangle Park. North Carolina 27711
'fort campittint)
iTRECIPIENT-S ACCESSION NO.
IEPOBT DATE
June 1990
>. i-cnroiiMINO ORGANIZATION COoT
. rsBPORMING ORGANIZATION REPORT NO.
68-02-3058
13. TYPE OP REPORT AND PERIOD COVEREo"
EPA/200/04
.nt.n»tio, use by
^^
-u rape
industry are being pramjlaated under Section
on
proposed
?r9a"'J.<:hen1cal manufacturing
.
DESCRIPTORS
Air pollution
Air oxidation processes
Pollution control
Standards of performance
Organic chemical industry
volatile organic compounds (VOC)
angle Park. N. C. 2771l
SPA Form 22JO-1 111-.
(R... 4-77) Mlv,0oi CD,TION „ OMOl.eTE
KEY WORDS AND DOCUMENT ANALYSIS
r.^T.,,EHS/OPENBNOtiDTEHMS . c^,——-
Air Pollution Control
'». ikCUH.TY CLAM OlntKw,,,
Unclassified f
Unclassified
'. IVO. OF PAGE
81
TZ2. PRICE '
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