v>EPA
United States Office of Air Quality EPA-450/3-91 -030
Environmental Protection Planning and Standards July 1992
Agency Research Triangle Park, NC 27711
Air
Documentation for
Developing the Initial
Source Category
Final
Report
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EPA-450/3-91-030
Documentation for Developing
the
Initial Source Category List
Emission Standards Division
Office of Air Quality Planning and Standards
United States Environmental Protection Agency
Research Triangle Park, North Carolina 27711
July 1992
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DISCLAIMER
This final report has been reviewed by the Emissions Standards
Division, Office of Air Quality Planning and Standards,
U.S. Environmental Protection Agency, and approved for publication
as received from Radian Corporation. Approval does not signify the
contents necessarily reflect the views and policies of the
U.S. Environmental Protection Agency, nor does mention of trade
names of commercial products constitute endorsement or
recommendation for use.
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TABLE OF CONTENTS
SECTION PAGE
LIST OF TABLES vi
1.0 OVERVIEW 1-1
2.0 TECHNICAL APPROACH 2-1
2.1 Introduction 2-1
2.2 Data Compilation 2-1
2.2.1 Emission Standards Division Approach . . . 2-2
2.2.2 National Emissions Data System 2-4
2.2.3 Other EPA Sources 2-5
2.3 Information Analysis 2-6
2.3.1 Review and Documentation of
Emission Source Data 2-6
2.3.2 Response to Comments on the Preliminary Draft
List of Source Categories 2-7
2.3.3 Development of the Initial List of Source
Categories 2-8
2.4 References 2-10
3.0 LISTING OF CATEGORIES OF MAJOR SOURCES AND ASSOCIATED
HAZARDOUS AIR POLLUTANTS BY INDUSTRY GROUP 3-1
3.1 Introduction 3-1
3.2 References 3-17
4.0 LISTING OF CATEGORIES OF AREA SOURCES AND ASSOCIATED
HAZARDOUS AIR POLLUTANTS 4-1
4.1 Introduction 4-1
4.2 References 4-3
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TABLE OF CONTENTS (CONTINUED)
APPENDICES
APPENDIX A: DESCRIPTIONS OF SOURCE CATEGORIES
Fuel Combustion A-3
Non-ferrous Metals Processing A-6
Ferrous Metals Processing A-10
Mineral Products Processing A-18
Petroleum and Natural Gas Production and Refining A-25
Liquids Distribution A-27
Surface Coating Processes A-28
Waste Treatment and Disposal A-35
Agricultural Chemicals Production A-40
Fibers Production Processes A-44
Food and Agriculture Processes A-46
Pharmaceutical Production Processes A-48
Polymers and Resins Production A-50
Production of Inorganic Chemicals A-66
Production of Organic Chemicals A-71
Miscellaneous Processes A-80
IV
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TABLE OF CONTENTS (CONTINUED)
APPENDIX B: PUBLIC COMMENT SUMMARIES AND RESPONSES TO
PRELIMINARY DRAFT LISTING
1.0 Fuel Combustion B-3
2.0 Nonferrous Metals B-22
3.0 Ferrous Metals B-32
4.0 Mineral Products Processing and Use .... B-42
5.0 Petroleum Refineries B-60
6.0 Petroleum and Gasoline Production
and Marketing B-66
7.0 Surface Coating Processes B-75
8.0 Waste Treatment and Disposal B-89
9.0 Agricultural Chemicals Production and Use . B-112
10.0 Fibers Production Processes B-122
11.0 Food and Agriculture Industry B-124
12.0 Pharmaceutical Production
Processes B-129
13.0 Polymers and Resins Production B-130
14.0 Production and Use of Inorganic Chemicals . B-147
15.0 Production of Synthetic Organic Chemicals . B-163
16.0 Radionuclide Emitters B-170
17.0 Miscellaneous B-172
18.0 Toxic Release Inventory System (TRIS)
Production and Use Activities B-201
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LIST OF TABLES
TABLE PAGE
3.1 Categories of Major Sources and Associated Hazardous Air
Pollutants Listed by Industry Group 3-3
4.1 Categories of Area Sources and Associated Hazardous Air
Pollutants 4-2
VI
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1.0 OVERVIEW
Section 112 of Title III (Air Toxics) of the Clean Air Act
(CAA) as amended in 1990 identifies a list of 189 hazardous air
pollutants (HAP's) and requires the U.S. Environmental Protection
Agency (EPA) to publish, within 1 year of enactment, an initial
list of all categories and subcategories of major and area
sources of HAP's. According to the CAA, a "major source" is any
stationary source (including all emission points and units
located within a contiguous area and under common control) of air
pollution that has the potential to emit, considering controls,
10 tons or more per year of any HAP or 25 tons or more per year
of any combination of HAP's. An "area source" is any stationary
source of HAP's that is not a major source. Only major sources
within a category shall be subject to emission standards under
Section 112 unless a finding is made that indicates a threat of
adverse effects to human health or the environment from area
sources within a category. Area sources identified through such
a finding will be subject to regulation under Section 112.
An initial list of categories of stationary sources that
emit one or more of the 189 listed HAP's will be published by EPA
in an upcoming Federal Register notice, and is presented in
Sections 3.0 and 4.0 of this document. The purpose of this
report is to (1) describe the methodology used to identify
sources that emit HAP's, (2) document the technical references
that support EPA's conclusion that one or more of the listed
HAP's is emitted from a specified source category, (3) provide
broad descriptions of the categories of major sources included on
the initial list, and (4) present the responses to public
comments received regarding a preliminary draft list of source
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categories that was published in the Federal Register on June 21,
1991 (56 FR 28548) .
The technical approach used to develop the list of source
categories is discussed in Section 2.0. Categories of major
sources and associated HAP's are cited in Section 3.0, and
Section 4.0 discusses categories of area sources and associated
HAP's. Categories of major sources are listed by industry
groups, which consist of source categories that have similar
industrial descriptions. Some industry groups (e.g.,
Pharmaceutical Production Processes) contain only a single, broad
source category that includes a number of subcategories, by
description, for the purposes of regulatory development.
Sections 3.0 and 4.0 also include reference lists indicating the
reference sources used for listing and describing each source
category. The references cited are contained in Docket
No. A-90-49 and are available for public review at EPA's Air
Docket Section, Room M-1500, Waterside Mall, 401 M Street SW,
Washington, DC 20460.
Descriptions of the source categories appearing in Table 3.1
are provided in Appendix A. These descriptions are meant to
identify, in a very brief and concise manner, what may be
included in each source category and do not represent a complete
delineation of all possible emission sources within a source
category. For purposes of applicability determinations, the
final descriptions for each source category will be developed as
part of the regulatory effort for each standard. Descriptions
for the categories of area sources can be found in the upcoming
Federal Register notice entitled "Initial List of Categories of
Sources Under Section 112(c)(l) of the Clean Air Act Amendments
of 1990."
A summary of public comments on the preliminary draft
listing of source categories, and EPA's responses to those
comments, is provided in Appendix B. The comment and response
summaries are arranged by industry group and then by individual
source categories.
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2.0 TECHNICAL APPROACH
2.1 INTRODUCTION
The purpose of this section is to present the various
technical approaches that were used by EPA to identify source
categories and to describe how the initial list was developed.
The first step in the approach for identifying source categories,
described in Section 2.2, involved the compilation of a large
quantity of emissions data from different references that related
emissions to specific types of sources. A preliminary draft list
of proposed source categories based on the collected data
appeared in the Federal Register on June 21, 1991 in which
comments were requested by EPA. The development of the initial
list, as described in Section 2.3, was based on an analysis of
all source-related information that had been collected, including
any new, substantiated information acquired through the review of
public comments.
2.2 DATA COMPILATION
The identification of source categories was dependent on the
availability of references that relate emissions information to
specific types of sources. Source categories that emit any of
the 189 listed HAP's were identified using a variety of emissions
information. More than one reference may have identified a
source category as emitting one or more of the 189 HAP's, but
only one reference may be cited in Sections 3.0 and 4.0.
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The following references were used to develop the initial
list of source categories:
» Published production and consumption data for the
chemical industry and emission factors developed by the
EPA's Emission Standards Division (ESD);
« Pollutant speciation profiles for Source Classification
Codes (SCC's) used in the National Emissions Data
System (NEDS) and the National Acid Precipitation
Assessment Program (NAPAP);
» EPA reports, studies, memoranda, and other emission
data sources.
The references used to develop the initial source category
list v/ere evaluated in a prioritized manner, so as to use all
available information to identify categories of major sources,
but to place greater emphasis on the most reliable information
sources. Also, categories of area sources were identified when
information from the above references indicated that these area
sources present a threat of adverse effects to human health or
the environment. Information derived from the reference sources
listed above is discussed in the following sections and is
presented in the order in which the reference sources were
evalucited. The specific references used for each source category
are cited in Tables 3.1 and 4.1.
2.2.1 Emission Standards Division Approach
The ESD approach assessed emissions from industrial
processes that produce or consume organic chemicals by using
published chemical production and consumption data and emission
factors developed by ESD from previous regulatory studies.
Source categories were identified for the production and use of
these organic chemicals where there were associated HAP
emissions. Where applicable, source categories identified from
previous regulatory assessments were maintained.
Chemical marketing publications were evaluated to identify
emission sources that produce or use one or more of the listed
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HAP's. For example, some chemical production data were verified
by the Stanford Research Institute's Directory of Chemical
Producers, while publications such as the Mannsville Chemical
Synopsis and the Chemical Marketing Reporter were used to
identify the consumption pattern for many of the chemicals. In
addition to these references, emission data developed through
existing regulatory efforts covering the synthetic organic
chemical manufacturing industry were also used to identify
processes that emit HAP's.
An example of a source category identifed through the ESD
approach is the "Styrene Butadiene Rubber and Latex Production"
category which involves the end use of 1,3-butadiene and styrene,
and is listed under the "Polymers and Resins Production" industry
group. Similiarly, the commercial and industrial dry cleaning
categories listed under the "Miscellaneous Processes" industry
group were identified as end users of tetrachloroethylene. Many
organic chemical production processes, such as the production of
1,3-butadiene, were identified through EPA's Hazardous Organics
National Emission Standards for Hazardous Air Pollutants project,
also referred to as HON. Information from this existing
regulatory effort provided emission data for many of the organic
chemical production processes included in the "Synthetic Organic
Chemical Manufacturing" source category listed under the
"Production of Organic Chemicals" industry group.
The ESD approach identified a large range of industrial
processes associated with HAP emissions from which source
categories were identified. Also, by recognizing emission
sources already established through existing regulatory efforts,
(e.g., the HON project), regulatory consistency could be better
maintained in identifying source categories.
The specific references used for each category of major and area
sources can be found in Sections 3.2 and 4.2, respectively, of
this document.
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2.2.2 National Emissions Data System
Many emission sources were characterized by SCC's contained
within EPA's NEDS.2 The NEDS data base contains emissions
reported by individual states for sources emitting 100 tons or
more per year of any criteria pollutant. An SCC is an eight-
digit code divided into four levels of identifiers: (1) the
category process (2) the major industry (3) the major product,
and (4) different operations within the category process. A list
of approximately 4,000 SCC's and descriptions may be found in
Criteria Pollutant Emission Factors for the 1985 NAPAP Emissions
Inventory. Provided within NEDS are emission estimates for
volatile organic compounds (VOC's) and particulate matter (PM),
but not for individual HAP's.
Speciation profiles developed by EPA '5 were assigned to each
SCC contained in NEDS. Speciation profiles distinguish the
chemical constituents within the total VOC or PM emissions. By
linking each speciation profile with an SCC, estimates of the HAP
constituents emitted from a source category were determined.
Each speciation profile has an associated data quality
rating ("A" through "E"). These ratings are based on the
following criteria.
Data Quality A: Data set is based on a composite of several
tests using analytical techniques such as gas
chromatography or mass spectrometry (GC/MS),
and can be considered representative of the
total population.
Data Quality B: Data set is based on a composite of several
tests using analytical techniques such as
GC/MS, and can be considered representative
of a large percentage of the total
population.
Data Quality C: Data set is based on a small number of tests
using analytical techniques such as GC/MS,
and can be considered reasonably
representative of the total population.
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Data Quality D: Data set is based on a single source using
analytical techniques such as GC/MS, or data
set is taken from a number of sources where
data are based on engineering calculations.
Data Quality E: Data set is based on engineering judgment
and/or has no documentation provided; may not
be considered representative of the total
population.
The uncertainty associated with the E-quality profiles is such
that they are substantially less reliable than the other profiles
and, therefore, were not used for determining HAP constituents.
The SCC identifiers from NEDS were used to describe source
categories, identify appropriate industry groups, and, for some
source categories, provided the actual name as it appears on the
list. For many of the source categories that are listed in
Table 3.1 and based on the NEDS approach, a range of SCC's are
covered by the listed source category. For more information
regarding the SCC ranges associated with each NEDS-identified
source category, the reader is referred to the document entitled
Documentation for Developing the Source Category List.
Preliminary Draft. (Document No. II-C-1) located in the Air
Docket identified in Section 1.0.
2.2.3 Other EPA Sources
Other EPA reports and documentation were used to identify
source categories in addition to the previously described
references. Many of these reports were prepared in support of
the rulemaking procedures for national emission standards for
hazardous air pollutants (NESHAP) and new source performance
standards (NSPS). Such documentation includes preliminary source
assessments and surveys for HAP's, background information for
proposed regulations, reports on control technologies, and
federal regulations and notices for proposed rulemakings.
The EPA's Toxic Release Inventory System (TRIS) data base
was used to identify a small number of HAP production source
categories not previously addressed by the ESD and NEDS
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approaches and to confirm the existence of major sources within
certain source categories. The TRIS data base contains emissions
data reported by individual industrial facilities as required by
the Sxiperfund Amendments and Reauthorization Act (SARA) , Section
313. The emissions data reported to the TRIS data base are
maintciined by EPA, and are available to the public through the
EPA's Office of Toxic Substances, Public Data Branch.
2.3 INFORMATION ANALYSIS
The data compilation effort described above produced a
significant amount of information relating listed HAP's to
emission sources. This information then had to be analyzed by
EPA to identify distinct source categories for the initial list.
This analysis consisted of both an internal review of the
collected emission source data and the consideration of public
comments on the preliminary draft list of source categories
published in the Federal Register on June 21, 1991. The
following sections describe the data review process, the
responses to comments, and how the initial list, which appears in
this document, was developed.
2.3.1 Review and Documentation of Emission Source Data
The listing approaches described in Section 2.2 resulted in
a larcje amount of emissions data from many different references.
Because there was no single comprehensive and complete source of
information regarding the emissions of HAP's from different
source types in the United States, the results of each approach
had to be carefully reviewed to identify distinct source
categories for the list.
The focus of EPA's review was to identify all source
categories, for which information had been collected and
documented, that emitted one or more of the listed HAP's. Many
source categories that had been identified through the various
approaches, but for which data was incomplete or insufficient for
listing purposes, were investigated further to locate additional
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supporting data. To avoid duplication, the data were also
reviewed to identify where different approaches might have
identified emissions from the same source category.
Based on a review of the available emissions data, a
preliminary draft list of proposed source categories was
developed by EPA and published for public comment in the Federal
Register on June 21, 1991.1 The response to comments is
discussed in the following section.
2.3.2 Response to Comments on the Preliminary Draft List of
Source Categories
Along with the preliminary draft list of source categories,
EPA reguested comments on the proposed source categories, and on
the procedures used to develop the list. Specific comments were
reguested on the division of categories and subcategories,
approaches for listing area sources, the scope and completeness
of the preliminary draft list, and the use of emission data
bases, as described above, for identifying source categories.
After evaluating and responding to comments, EPA made applicable
revisions to the proposed source category list. The Federal
Register notice included a reguest that all comments supporting
the addition, deletion, or definition of source categories be
accompanied by adequate supporting documentation. A summary of
comments and responses appears in Appendix B of this document.
Many of the comments received requested clarification of the
proposed source categories to better determine applicability. A
large number of comments also reguested the deletion of certain
categories because they were suspected of comprising solely area
sources. Other comments asked for the deletion or addition of
certain pollutants within a source category. All comments were
reviewed and evaluated by EPA as part of the process of
developing the initial list of source categories that appears in
this document.
While evaluating and responding to comments, EPA made
applicable revisions to the preliminary draft list of source
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categories where adequate supporting documentation was available.
Many of the comments that requested specific actions (e.g., the
deletion of a source category) lacked adequate supporting data to
justify the suggested action. In conjunction with EPA's internal
review of the proposed source categories, however, the comments
did provide significant information for refining the preliminary
draft list and for describing the source categories that appear
on this initial listing.
2.3.3 Development of the Initial List of Source Categories
The initial list of source categories, as it appears in
Tables 3.1 and 4.1 of this document, was developed according to
Section 112(c) of the CAA, based on the results of EPA's emission
data review and the consideration of comments that were received
on the preliminary draft list of source categories, as described
in the previous section. The list consists of categories of
major sources, which are shown in Table 3.1, and categories of
area sources, which are shown in Table 4.1.
As described in Section 1.0 (Overview), the categories of
major sources are categories for which EPA has identified
evidence of major sources. The term "major source" is defined in
the CAA to mean "any stationary source or group of stationary
sources located within a contiguous area and under common control
that emits or has the potential to emit considering controls, in
the eiggregate, 10 tons per year or more of any [HAP] or 25 tons
per year or more of any combination of [HAP's]." A category of
major sources is one that has at least one stationary source in
the category that is a major source or where sources in the
category are commonly located on the premises of major sources.
"Area sources," as defined in the CAA, are any stationary sources
that emit HAP's that are not major sources. The categories of
area sources that appear in Table 4.1 represent those area
sources that EPA has found, at this time, to present a threat of
adverse effects to human health or the environment warranting
regulation under Section 112 of the CAA.
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The changes to the preliminary draft list, since publication
in the Federal Register on June 21, 1991, reflect EPA's
dispositions on source categories as a result of the review of
emission data and the comment period that followed publication.
Many source categories were maintained unchanged from the
preliminary draft list. Some source category names were changed
to provide a more accurate description of emission sources
included in a particular category. Other source categories were
aggregated to reflect similar and associated emission sources or
disaggregated to better represent distinctly identified emission
sources. Additions to the draft list occurred when new emissions
data were available to adequately identify a source category.
Also, source categories were deleted when there was no documented
evidence of major sources within a category, when an area source
finding had not been made, or when current data were determined
to be inadequate for listing purposes.
The CAA provides specific listing requirements for certain
emission sources, which are reflected in the initial list. For
example, the CAA requires that boat manufacturing be listed as a
separate source category. There are also special provisions for
the listing of oil and gas wells, including pipeline facilities,
which are reflected in the source category listing for "Oil and
Natural Gas Production" in this document. For other specific
requirements and provisions that pertain to the listing of source
categories in this document, the reader is referred to the CAA
Amendments of 1990 as revised therein, and to the upcoming
Federal Register notice announcing the "Initial List of
Categories of Sources Under Section 112(c)(l) of the Clean Air
Act Amendments of 1990."
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2.4 REFERENCES
1. U.S. Environmental Protection Agency. Preliminary Draft
List of Categories and Subcategories Under Section 112 of
the Clean Air Act. Federal Register. Vol. 56, No. 120,
pp. 28548. Washington, D.C. Office of the Federal Register,
June 21, 1991.
2. U.S. Environmental Protection Agency. National Emissions
Data System (NEDS). Office of Air Quality Planning and
Standards, National Air Data Branch. Research Triangle
Park, NC. July 1988.
3. U.S. Environmental Protection Agency. Criteria Pollutant
Emission Factors for the 1985 NAPAP Emissions Inventory.
Office of Research and Development. Research Triangle Park,
NC. Publication No. EPA-600/7-87-015. 1987.
4. U.S. Environmental Protection Agency. Volatile Organic
Compound (VOC) Species Profiles. In: Air Emissions Species
Manual, Volume 1. Office of Air Quality Planning and
Standards, Research Triangle Park, NC. January 1990.
5. U.S. Environmental Protection Agency. Particulate Matter
(PM) Species Profiles. In: Air Emissions Species Manual,
Volume 2. Office of Air Quality Planning and Standards,
Research Triangle Park, NC. January 1990.
6. U.S. Environmental Protection Agency. Toxic Chemical
Release Inventory Reporting Package for 1989. Office of
Toxic Substances, Washington, D.C. Publication No.
EPA-560/4-90-001. January 1990.
7. United States Congress. Clean Air Act, as amended,
November 15, 1990. 42 U.S.C. 1857 et seq. Washington, DC.
U.S. Government Printing Office. November 1990. Sections
301 to 306. 123 pp.
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3.0 LISTING OF CATEGORIES OF MAJOR SOURCES AND ASSOCIATED
HAZARDOUS AIR POLLUTANTS BY INDUSTRY GROUP
3.1 INTRODUCTION
Categories of major sources are listed in Table 3.1 by
industry group. For example, the source categories Industrial
Boilers, Stationary Turbines, and Process Heaters are all listed
under the industry group labeled "Fuel Combustion." Source
categories that cannot be identified by a common industry type
appear in the "Miscellaneous Processes" industry group.
Associated HAP's and references used for emissions data
collection and description purposes are indicated for each source
category in Table 3.1. The HAP's are located in the column
labeled "Pollutant(s)." The pollutants listed are those for
which documentation was readily available. Additional HAP's may
also be emitted from a source category but are not listed in
Table 3.1. This situation will be considered during the
development of individual regulations, at which time additional
HAP's may be identified for a source category.
The specific references from the listing approach used to
identify and describe each source category are coded by number in
the last column of Table 3.1 to correspond to the list of
references in Section 3.2. At the end of each reference citation
in Section 3.2, the document number for that reference has been
provided in parentheses. This number corresponds to docket index
number for Docket No. A-90-49 as identified in Section 1.0 of
this document, and thus facilitates locating references within
the docket. Table 3.1 is arranged as follows:
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Industry Group
Fuel Combustion 3-3
Non-ferrous Metals Processing. 3-4
Ferrous Metals Processing 3-4
Mineral Products Processing 3-6
Petroleum and Natural Gas Production
cind Refining 3-7
Liquids Distribution 3-7
Surface Coating Processes 3-7
Waste Treatment and Disposal 3-9
Agricultural Chemicals Production 3-10
Fibers Production Processes 3-11
Food and Agriculture Processes 3-11
Pharmaceutical Production Processes 3-11
Polymers and Resins Production 3-11
Production of Inorganic Chemicals 3-13
Production of Organic Chemicals 3-13
Miscellaneous Processes 3-15
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Table 3.1 Categories of Major Sources and Associated Hazardous Air
Pollutants Listed by Industry Group
SOURCE CATEGORY HAKE
POLLUTABT(S)
REFERENCE
-INDUSTRY GROUP = FUEL COMBUSTION-
ENGINE TEST FACILITIES
1,3-BUTADIENE
ACETALDEHYDE
ACROLEIN
BENZENE
ETHYL BENZENE
FORMALDEHYDE
PHENOL
PROPIONALDEHYDE
STYRENE
TOLUENE
XYLENE (0-)
1, 18, 147
INDUSTRIAL BOILERS
ETHYL BENZENE
XYLENE (0-)
ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSINE)
BENZENE
CADMIUM COMPOUNDS
CHROMIUM COMPOUNDS
HEXANE
LEAD COMPOUNDS
MANGANESE COMPOUNDS
MERCURY COMPOUNDS
NICKEL COMPOUNDS
SELENIUM COMPOUNDS
TOLUENE
FORMALDEHYDE
BERYLLIUM COMPOUNDS
PHOSPHORUS
POLYCYCLIC ORGANIC MATTER
1, 18, 19, 64, 65
138, 139
INSTITUTIONAL/COMMERCIAL BOILERS
ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSINE)
CADMIUM COMPOUNDS
CHROMIUM COMPOUNDS
LEAD COMPOUNDS
MANGANESE COMPOUNDS
NICKEL COMPOUNDS
ELENIUM COMPOUNDS
HEXANE
FORMALDEHYDE
BENZENE
TOLUENE
BERYLLIUM COMPOUNDS
MERCURY COMPOUNDS
PHOSPHORUS
POLYCYCLIC ORGANIC MATTER
1, 18, 19, 64, 65
138, 141, 142
PROCESS HEATERS
ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSINE)
BENZENE
CADMIUM COMPOUNDS
CHROMIUM COMPOUNDS
ORMALDEHYDE
HEXANE
LEAD COMPOUNDS
MANGANESE COMPOUNDS
NICKEL COMPOUNDS
ELENIUM COMPOUNDS
TOLUENE
1, 18, 19, 140
STATIONARY INTERNAL COMBUSTION ENGINES
1,3-BUTADIENE
BENZENE
ACETALDEHYDE
:THYL BENZENE
1, 18, 144, 145,
146
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Table 3.1 (continued)
SOURCE CATEGORY BAKE
STATIONARY INTERNAL COMBUSTION ENGINES (continued)
STATIONARY TURBINES
POLLUTABT(S)
FORMALDEHYDE
HEXANE
TOLUENE
XYLENE (M-)
XYLENE (0-)
XYLENES (MIXED)
XYLENE (P-)
ACROLEIN
PROPIONALDEHYDE
1,3-BUTADIENE
ACETALDEHYDE
ACROLEIN
BENZENE
ETHYL BENZENE
FORMALDEHYDE
HEXANE
PHENOL
PROPIONALDEHYDE
STYRENE
TOLUENE
XYLENE (M-)
XYLENES (MIXED)
XYLENE (O-)
REFERENCE
1, 18, 144, 143,
146
1, 18, 143
-INDUSTRY GROUP = NON-FERROUS HETALS PROCESSING-
PRIMARY ALUMINUM PRODUCTION
2,2,4-TRIOMETHYLPENTANE
BENZENE
CHROMIUM COMPOUNDS
ETHYL BENZENE
HEXANE
LEAD COMPOUNDS
MANGANESE COMPOUNDS
NICKEL COMPOUNDS
PHENOL
TOLUENE
XYLENE (0-)
XYLENE (P-)
POLYCYCLIC ORGANIC MATTER
1, 18, 19, 148,
149
ECONDARY &LUMINUM PRODUCTION
ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSINE)
CADMIUM COMPOUNDS
CHLORINE
CHROMIUM COMPOUNDS
HYDROCHLORIC ACID
LEAD COMPOUNDS
MANGANESE COMPOUNDS
NICKEL COMPOUNDS
SELENIUM COMPOUNDS
1, 19, 82, 153
PRIMARY COPPER SMELTING
CADMIUM COMPOUNDS
81, 84, 155, 156
RIMARY LEAD SMELTING
CADMIUM COMPOUNDS
CHROMIUM COMPOUNDS
LEAD COMPOUNDS
MANGANESE COMPOUNDS
MERCURY COMPOUNDS
NICKEL COMPOUNDS
SELENIUM COMPOUNDS
1, 19, 150
ECONDARY LEAD SMELTING
LEAD COMPOUNDS
85, 154
3-4
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Table 3.1 (continued)
SOURCE CATEGORY BANE
LEAD ACID BATTERY MANUFACTURING
PRIMARY MAGNESIUM REFINING
~ INDUSTRY GROUP — FBRR
COKE BY-PRODUCT PLANTS
COKE OVENS: CHARGING, TOP SIDE, AND DOOR LEAKS
COKE OVENS: PUSHING, QUENCHING, AND BATTERY
STACKS
FERROALLOYS PRODUCTION
INTEGRATED IROH S, STEEL MANUFACTURING
NON-STAINLESS STEEL MANUFACTURING - ELECTRIC
ARC FURNACE (EAF) OPERATION
STAINLESS STEEL MANUFACTURING - ELECTRIC ARC
FURNACE (EAF) OPERATION
IRON FOUNDRIES
POLLUTAHT(S)
LEAD COMPOUNDS
CHLORINE
HYDROCHLORIC ACID
JUS METALS PROCESSING
BENZENE
POLYCYCLIC ORGANIC MATTER
TOLUENE
COKE OVEN EMISSIONS
COKE OVEN EMISSIONS
CHROMIUM COMPOUNDS
LEAD COMPOUNDS
MANGANESE COMPOUNDS
ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSINE)
CADMIUM COMPOUNDS
CHROMIUM COMPOUNDS
LEAD COMPOUNDS
MANGANESE COMPOUNDS
SELENIUM COMPOUNDS
ACROLEIN
BENZENE
FORMALDEHYDE
HEXANE
PHENOL
TOLUENE
XYLENE (M-)
XYLENE (O-)
POLYCYCLIC ORGANIC MATTER
ANTIMONY COMPOUNDS
ARSENIC COMPOUNDS
CADMIUM COMPOUNDS
CHROMIUM COMPOUNDS
COBALT COMPOUNDS
CYANIDES COMPOUNDS
LEAD COMPOUNDS
MANGANESE COMPOUNDS
MERCURY COMPOUNDS
NICKEL COMPOUNDS
CHLORINE
CHROMIUM COMPOUNDS
LEAD COMPOUNDS
ACROLEIN
ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSIHE)
BENZENE
CHROMIUM COMPOUNDS
COBALT COMPOUNDS
FORMALDEHYDE
LEAD COMPOUNDS
MANGANESE COMPOUNDS
ICKEL COMPOUNDS
PHENOL
ELENIUM COMPOUNDS
OLUENE
YLENE (M-)
YLENE (O-)
REFERENCE
77, 83
127, 151, 152
68, 109, 167
76
76
1, 19, 157, 158
1, 18, 19, 159
86, 160, 161
87, 160, 161
1, 18, 19, 162,
163, 164, 165
3-5
-------
Table 3.1 (continued)
SOURCE CATEGORY SAME
STEEL FOUNDRIES
STEEL PICKLING - HC1 PROCESS
INDUSTRY GROUP =
ALUMINA PROCESSING
ASPHALT/COAL TAR APPLICATION - METAL PIPES
ASPHALT CONCRETE MANUFACTURING
ASPHALT PROCESSING
ASPHALT ROOFING MANUFACTURING
CHROMIUM REFRACTORIES PRODUCTION
CLAY PRODUCTS MANUFACTURING
LIME MANUFACTURING
POLLUTABT(S)
ACROLEIN
BENZENE
CADMIUM COMPOUNDS
CHROMIUM COMPOUNDS
FORMALDEHYDE
HEXANE
LEAD COMPOUNDS
MANGANESE COMPOUNDS
MERCURY COMPOUNDS
NICKEL COMPOUNDS
PHENOL
SELENIUM COMPOUNDS
TOLUENE
XYLENE (M-)
XYLENE (0-)
POLYCYCLIC ORGANIC MATTER
HYDROCHLORIC ACID
POLYCYCLIC ORGANIC MATTER
MINERAL PRODUCTS PROCESSING
HEXANE
FORMALDEHYDE
BENZENE
HEXANE
TOLUENE
BENZENE
CHROMIUM COMPOUNDS
HEXANE
LEAD COMPOUNDS
MANGANESE COMPOUNDS
NICKEL COMPOUNDS
POLYCYCLIC ORGANIC MATTER
CHLORINE
BENZENE
CHLORINE
CHROMIUM COMPOUNDS
COBALT COMPOUNDS
HEXANE
MANGANESE COMPOUNDS
SELENIUM COMPOUNDS
TOLUENE
CHROMIUM COMPOUNDS
CHLORINE
FORMALDEHYDE
HEXANE
ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSINE)
CADMIUM COMPOUNDS
CHLORINE
CHROMIUM COMPOUNDS
LEAD COMPOUNDS
MANGANESE COMPOUNDS
MERCURY COMPOUNDS
NICKEL COMPOUNDS
SELENIUM COMPOUNDS
REFERENCE
1, 18, 19, 166
18, 39, 86, 168
92, 176
1, 18, 173
1, 18, 19, 169,
170
16, 88, 171, 172
1, 18, 19, 88,
171, 172
70, 137, 174
1, 18, 92, 175
89, 177, 178
3-6
-------
Table 3.1 (continued)
SOURCE CATEGORY NAME
POLLUTANT(S)
REFERENCE
MINERAL WOOL PRODUCTION
FORMALDEHYDE
FINE MINERAL FIBERS
PHENOL
27, 90, 181
PORTLAND CEMENT MANUFACTURING
ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSINE)
CADMIUM COMPOUNDS
CHROMIUM COMPOUNDS
LEAD COMPOUNDS
MANGANESE COMPOUNDS
MERCURY COMPOUNDS
BICKEL COMPOUNDS
SELENIUM COMPOUNDS
PHOSPHORUS
1, 19, 65, 179,
180
TACONITE IRON ORE PROCESSING
BENZENE
FORMALDEHYDE
HEXANE
TOLUENE
1, 18, 184
WOOL FIBERGLASS MANUFACTURING
FORMALDEHYDE
PHENOL
78, 182, 183, 320
-INDUSTRY GROUP = PETROLEUM AND NATURAL GAS PRODUCTION t REFINING -
OIL AND NATURAL GAS PRODUCTION
BENZENE
CARBONYL SULFIDE
ETHYL BENZENE
XYLENES (MIXED)
TOLUENE
93, 94
PETROLEUM REFINERIES - CATALYTIC CRACKING
(FLUID AND OTHER) UNITS, CATALYTIC
REFORMING UNITS, ADD SULFUR PLANT UNITS
ACETALDEHYDE
BENZENE
CADMIUM COMPOUNDS
FORMALDEHYDE
HEXANE
HYDROGEN FLUORIDE
LEAD COMPOUNDS
MERCURY COMPOUNDS
METHANOL
METHYL ETHYL KETONE
NICKEL COMPOUNDS
PROFYLEBE OXIDE
SELENIUM COMPOUNDS
TOLUENE
XYLENES (MIXED)
1, 18, 19, 40,
183, 186, 187,
188
PETROLEUM REFINERIES - OTHER SOURCES NOT
DISTINCTLY LISTED
ACETALDEHYDE
BENZENE
CADMIUM COMPOUNDS
FORMALDEHYDE
HEXANE
HYDROGEN FLUORIDE
LEAD COMPOUNDS
MERCURY COMPOUNDS
METHANOL
METHYL ETHYL KETONE
NICKEL COMPOUNDS
PROPYLENE OXIDE
SELENIUM COMPOUNDS
TOLUENE
XYLENES (MIXED)
1, 18, 19, 40,
185, 186, 187,
188
3-7
-------
Table 3.1 (continued)
SOURCE CATEGORY SAME
POLLUTABT(S)
REFERENCE
INDUSTRY GROUP = LIQUIDS DISTRIBUTION
GASOLINE DISTRIBUTION (STAGE 1)
ORGANIC LIQUIDS DISTRIBUTION (BON-GASOLINE)
BENZENE
CUMENE
ETHYL BENZENE
HEXANE
NAPHTHALENE
TOLUENE
2, 2, 4-TRIMETHYLPENTANE
XYLENES (MIXED)
BENZENE
115
1, 18, 95
INDUSTRY GROUP = SURFACE COATING PROCESSES
AEROSPACE INDUSTRIES
AUTO AND LIGHT DUTY TRUCK (SURFACE COATING)
FLAT WOOD PANELING (SURFACE COATING)
LARGE APPLIANCE (SURFACE COATING)
MAGNETIC TAPES (SURFACE COATING)
MANUFACTURE OF PAINTS, COATINGS AND ADHESIVES
METAL CAN (SURFACE COATING)
METAL COIL (SURFACE COATING)
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (0-)
XYLENES (MIXED)
BENZENE
BIPHENYL
DIBUTYLPHTHAIATE
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
PHTHALIC ANHYDRIDE
TOLUENE
XYLENE (O-)
XYLENES (MIXED)
POLYCYCLIC ORGANIC MATTER
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (O-)
XYLENES (MIXED)
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (0-)
XYLENES (MIXED)
METHYL ETHYL KETONE
TETRACHLOROETHYLESE
TRICHLOROETHYLENE
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (0-)
XYLENES (MIXED)
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (0-)
XYLESES (MIXED)
1, 18, 217, 218
1, 18, 198, 199,
200
1, 18, 211
1, 18, 196, 197
46, 96, 223, 224
97, 229
1, 18, 201, 202
1, 18, 203, 204,
205, 206
3-8
-------
Table 3.1 (continued)
SOURCE CATEGORY BAMK
METAL FURNITURE (SURFACE COATING)
MISCELLANEOUS METAL PARTS AND PRODUCTS
(SURFACE COATING)
PAPER AND OTHER WEBS (SURFACE COATING)
PLASTIC PARTS AND PRODUCTS (SURFACE COATING)
PRINTING, COATING, AND DYEING OF FABRICS
PRINTING/PUBLISHING (SURFACE COATING)
SHIPBUILDING AND SHIP REPAIR (SURFACE COATING)
WOOD FURNITURE (SURFACE COATING)
INDUSTRY GROUP = IMS
HAZARDOUS WASTE INCINERATION
POLLUTABT(S)
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (O-)
XYLENES (MIXED)
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL XETONE
TOLUENE
XYLENE (O-)
XYLENSS (MIXED)
ETHYL BENIENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (O-)
XYLENES (MIXED)
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (O-)
XYLENES (MIXED)
BIPHEHYL
DIBUTYLPHTHALATE
DIMETHYL PHTHALATE
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (0-)
XYLENES (MIXED)
POLYCYCLIC ORGANIC MATTER
DIBUTYLPHTHALATE
CYANIDE COMPOUNDS
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (O-)
XYLENES (MIXED)
ETHYL BENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
TOLUENE
XYLENE (O-)
XYLENES (MIXED)
TE TREATMENT AND DISPOSAL
ANTIMONY COMPOUNDS
ARSENIC COMPOUNDS
BENZENE
BERRYLLIUM COMPOUNDS
CADMIUM COMPOUNDS
REFERENCE
1, 18, 210
1, 18, 225, 226,
227, 228
1, 18, 191, 192,
193, 194, 195
1, 18, 212, 213,
214, 215
1, 18, 189, 190,
191
1, 18, 219, 220,
221
1, 18, 216
1, 18, 207, 208,
209
79, 98, 233, 234
3-9
-------
Table 3.1 (continued)
SOURCE CATEGORY BAKE
POLLUTA»T(S)
REFERENCE
HAZARDOUS WASTE INCINERATION
(continued)
CHROMIUM COMPOUNDS
HYDROCHLORIC ACID
LEAD COMPOUNDS
MERCURY COMPOUNDS
79, 98, 233, 234
MUNICIPAL LANDFILLS
PUBLICLY OWNED TREATMENT WORKS (POTW) EMISSIONS
ACETALDEHYDE
ACRYLONITRILE
BENZENE
ETHYL ACRYLATE
ETHYL CHLORIDE
ETHYLENE OXIDE
rORMALDEHYDE
METHANOL
METHYL CHLORIDE
PHENOL
PROPYLENE OXIDE
STYRENE
TOLUENE
VINYL CHLORIDE
XYLENES (MIXED)
ACRYLAMIDE
ACRYLONITRILE
CARBON TETRACHLORIDE
CHLORINE
CHLOROFORM
ETHYLENE DICHLORIDE
METHYLENE CHLORIDE
TETRACHLOROETHYLENE
TRICHLOROETHYLENE
1, 18, 231
34, 354, 355
SEWAGE SLUDGE INCINERATION
BENZENE
CADMIUM COMPOUNDS
CHROMIUM COMPOUNDS
LEAD COMPOUNDS
MANGANESE COMPOUNDS
SELENIUM COMPOUNDS
1, 18, 19, 128,
230
SITE REMEDIATION
BENZENE
CHLOROFORM
ETHYL CHLORIDE
ETHYLENE DICHLORIDE
ETHYLIDENE DICHLORIDE
METHYL CHLORIDE
METHYL CHLOROFORM
METHYL ETHYL XETONE
METHYLENE CHLORIDE
METHYL ISOBUTYL KETONE
1,1,2,2-TETRACHLOROETHANE
TETRACHLOROETHYLENE
TOLUENE
1,1,2-TRICHLOROETHANE
TRICHLOROETHYLENE
VINYL CHLORIDE
VINYLIDENE CHLORIDE
XYLENES (MIXED)
113, 232
SOLID WASTE TREATMENT, STORAGE AND DISPOSAL
FACILITIES (TSDF)
METHYLENE CHLORIDE
TRICHLOROETHYLENE
TETRACHLOROETHYLENE
99, 235
3-10
-------
Table 3.1 (continued)
SOURCE CATEGORY NAME
POtLUTABT(S)
REFERENCE
INDUSTRY GROUP - AGRICULTURAL CHEMICALS PRODUCTION
2,4-D SALTS AND ESTERS PRODUCTION
4, 6-DINITRO-O-CRESOL PRODUCTION
4-CHLORO-2-METHYLPHENOXYACETIC ACID PRODUCTION
CAPTAFOL PRODUCTION
CAPTAN PRODUCTION
CHLORONEB PRODUCTION
CHLOROTHALONIL PRODUCTION
DACTHAL (TM) PRODUCTION
SODIUM PENTACHLOROPHEHATE PRODUCTION
TORDON (TM) ACID PRODUCTION
2,4-D SALTS AND ESTERS
CHLOROACETIC ACID
CRESOLS/CRESYLIC ACID (MIXTURE)
CRESOLS/CRESYLIC ACID (MIXTURE)
1,3-BUTADIENK
1, 3-BUTADIENE
HYDROQUINONE
CARBON TETRACHLORIDE
CARBON TETRACHLORIDE
PENTACHLOROPHENOL
CARBON TETRACHLORIDE
14, 61, 236, 237
62, 238
62, 239
7, 240
7, 17, 242
41
4, 241
4, 236, 241
49
4, 100
ACRYLIC FIBERS/MODACRYLIC FIBERS PRODUCTION
RAYON PRODUCTION
SPANDEX PRODUCTION
ACRYLONITRILE
CARBON DISULFIDE
DIMETHYL FORMAMIDE
8, 22, 125, 243,
244, 245
33, 247, 248
9, 130, 243, 246,
249
INDUSTRY GROUP = FOOD AND AGRICULTURE PROCESSES
BAKER'S YEAST MANUFACTURING
CELLULOSE FOOD CASING MANUFACTURING
VEGETABLE OIL PRODUCTION
ACETALDEHYDE
CARBON DISULFIDE
HEXANE
75, 118, 119, 250,
251
102, 254
101, 252, 253
INDUSTRY GROUP = PHARMACEUTICAL PRODUCTION PROCESSES
PHARMACEUTICALS PRODUCTION
BENZENE
CARBON TBTRACHLORIDE
CHLOROBENZENE
CHLOROFORM
ETHYLENB DICHLORIDE
METHANOL
METHYLENE CHLORIDE
TOLUENE
2, 3, 4, 10, 11,
255, 256, 257
_—_ intifnf, _ mm nnf»Tmrr< rr*Mvmr
ACETAL RESINS PRODUCTION
ACRYLONITRILE-BUTADIENE-STYRENE PRODUCTION
ALKYD RESINS PRODUCTION
AMINO RESINS PRODUCTION
BOAT MANUFACTURING
FORMALDEHYDE
1, 3-BUTADIENE
ACRYLONITRILE
STYRENE
PHTHALIC ANHYDRIDE
FORMALDEHYDE
STYRENE
38, 258, 259, 260
6, 7, 24, 29, 60,
261, 262
53, 264
38, 103, 272, 273,
274
97, 122, 335
3-11
-------
Table 3.1 (continued)
SOURCE CATEGORY BANK
BUTADIENE-FURFURAL COTRIMER (R-ll) PRODUCTION
BUTYL RUBBER PRODUCTION
CARBOXYMETHYLCELLULOSE PRODUCTION
CELLOPHANE PRODUCTION
CELLULOSE ETHERS PRODUCTION
EPICHLOROHYDRIN ELASTOMERS PRODUCTION
EPOXY RESINS PRODUCTION
ETHYLENE-PROPYLENE ELASTOMERS PRODUCTION
FLEXIBLE POLYURETHANE FOAM PRODUCTION
HYPALON (TM) PRODUCTION
MALEIC ANHYDRIDE COPOLYMERS PRODUCTION
METHYL METHACRYLATE-ACRYLONITRILE-BUTADIENE-
STYRENE PRODUCTION
METHYL METHACRYLATE-BUTADIENE STYRENE
TERPOLYMERS PRODUCTION
METHYLCELLULOSE PRODUCTION
NEOPRENE PRODUCTION
NITRILE BUTADIENE RUBBER PRODUCTION
NON-NYLON POLYAMIDES PRODUCTION
NYLON 6 PRODUCTION
PHENOLIC RESINS PRODUCTION
POLYBUTADIENE RUBBER PRODUCTION
POLYCARBONATES PRODUCTION
POLYESTER RESINS PRODUCTION
POLYETHYLENE TEREPHTHALATE PRODUCTION
POLYMERIZED VINYLIDENE CHLORIDE PRODUCTION
POLYMETHYL METHACRYLATE RESINS PRODUCTION
POLYSTYRENE PRODUCTION -
POLI.UTAHT(S)
1,3 -BUTADIENE
METHYL CHLORIDE
CHLOROACETIC ACID
CARBON DISULFIDE
ETHYL CHLORIDE
EPICHLOROHYDRIN
EPICHLOROHYDRIN
1 , 3-BUTADIENE
METHYLENE CHLORIDE
CARBON TETRACHLORIDE
MALEIC ANHYDRIDE
1 , 3-BUTADIENE
ACRYLONITRILE
METHYL METHACRYLATE
STYRENE
1, 3-BUTADIENE
METHYL METHACRYLATE
STYRENE
METHYL CHLORIDE
CHLOROPRENE
1 , 3-BUTADIENE
ACRYLONITRILE
EPICHLOROHYDRIN
CAPROLACTAM
CRESOLS/CRESYLIC ACID (MIXTURE)
PHENOL
1 , 3-BUTADIENE
METHYLENE CHLORIDE
PHOSGENE
MALEIC ANHYDRIDE
PHTHALIC ANHYDRIDE
STYRENE
ETHYLENE GLYCOL
VINYLIDENE CHLORIDE
METHYL METHACRYLATE
STYRENE
REFERENCE
132
45, 265, 266
61, 268, 269
34, 267
5, 268
36, 222, 319
36, 270, 271
7, 314
3, 104, 301, 302
4, 129, 317
42, 275, 276
7, 131, 277
7, 132, 277
44, 278, 279, 280
25, 26, 136, 281
23, 24, 29, 60,
282, 283, 284
116, 117, 315,
316
32, 285, 286
43, 50, 287, 288
23, 24, 60, 289,
290
3, 51, 53, 54,
291
299, 318
37, 294, 295
72, 296, 297
47, 298
54, 299, 300
3-12
-------
Table 3.1 (continued)
SOURCE CATEGORY SAME
POLYSULFIDE RUBBER PRODUCTION
POLYVINYL ACETATE EMULSIONS PRODUCTION
POLYVINYL ALCOHOL PRODUCTION
POLYVINYL BUTYRAL PRODUCTION
POLYVINYL CHLORIDE AND COPOLYMERS PRODUCTION
REINFORCED PLASTIC COMPOSITES PRODUCTION
STYRENE-ACRYLONITRILE PRODUCTION
STYRENE-BUTADIENE RUBBER AND LATEX PRODUCTION
______ -f *r
AMMONIUM SULFATE PRODUCTION - CAPROLACTAM BY-
PRODUCT PLANTS
ANTIMONY OXIDES MANUFACTURING
CHLORINE PRODUCTION
CHROMIUM CHEMICALS MANUFACTURING
CYANURIC CHLORIDE PRODUCTION
FUME SILICA PRODUCTION
HYDROCHLORIC ACID PRODUCTION
HYDROGEN CYANIDE PRODUCTION
HYDROGEN FLUORIDE PRODUCTION
POLLUTABT(S)
1 , 3-BUTADIENE
2,4-TOLUENE DIISOCYANATE
ACRYLIC ACID
ETHYL ACRYLATE
ETHYLENE DICHLORIDE
ETHYLENE GLYCOL
ETHYLENE OXIDE
FORMALDEHYDE
GLYCOL ETHERS
HYDROCHLORIC ACID
MANGANESE COMPOUNDS
METHANOL
METHYL CHLORIDE
METHYL ETHYL KETONE
METHYL METHACRYLATE
METHYLENE CHLORIDE
PHENOL
STYRENE
TOLUENE
XYLENES (MIXED)
VINYL ACETATE
VINYL ACETATE
VINYL ACETATE
TRICHLOROETHYLENE
VINYL ACETATE
VINYL CHLORIDE
STYRENE
1, 3-BUTADIENE
ACRYLONITRILE
STYRENE
1, 3-BUTADIENE
STYRENE
fr^ „„„.-=•„ * r „
CAPROLACTAM
ANTIMONY COMPOUNDS
CARBON TETRACHLORIDE
CHLORINE
ETHYLIDENE DICHLORIDE
CHROMIUM COMPOUNDS
CYANIDE COMPOUNDS
CHLORINE
HYDROCHLORIC ACID
CYANIDE COMPOUNDS
HYDROGEN FLUORIDE
REFERENCE
97, 299
58, 303, 304
58, 305, 306, 307
58, 305
57, 58, 59, 308,
309
6, 126, 310
6, 7, 24, 29, 54,
60, 263
23, 24, 54, 60,
311, 312, 313
80, 108, 325
107, 326
4, 16, 34, 327,
328
70, 91
35, 329
106, 330
39
14
14
3-13
-------
Table 3.1 (continued)
SOURCE CATEGORY IAMB
PHOSPHATE FERTILIZERS PRODUCTION
PHOSPHORIC ACID MANUFACTURING
QUATERNARY AMMONIUM COMPOUNDS PRODUCTION
POLLUTABT(S)
HYDROGEN FLUORIDE
HYDROGEN FLUORIDE
BENZYL CHLORIDE
METHYL CHLORIDE
REFERENCE
66, 105
52, 105
31, 45, 321
SODIUM CYANIDE PRODUCTION
CYANIDE COMPOUNDS
35, 322
URANIUM HEXAFLUORIDE PRODUCTION
HYDROGEN FLUORIDE
40, 323, 324
-INDUSTRY GROUP = PRODUCTIOH OF ORGAHIC CHEHICALS-
SYNTHETIC ORGANIC CHEMICAL MANUFACTURING
ACETALDEHYDE
ACETAMIDE
ACETONITRILB
ACETOPHENONE
ACROLEIB
ACRYLAMIDE
ACRYLIC ACID
ACRYLONITRILE
AIXYL CHLORIDE
ANILINE
0-ANISIDINE
BENZENE
BEN ZOTRICHLORIDE
BENZYL CHLORIDE
BIPHENYL
BIS(CHLOROMETHYL)ETHER
BROMOFORM
1,3-BUTADIENE
CAPROLACTAM
CARBON DISULFIDE
CARBON TETRACHLORIDE
CHLOROACETIC ACID
CHLOROBENZENE
CHLOROFORM
CHLOROPRENE
CRESOLS/CRESYLIC ACID (ISOMERS t MIXTURE)
M-CRESOL
O-CRESOL
P-CRESOL
CUMENE
CYANIDE COMPOUNDS
1,4-DICHLOROBENZENE (P)
DICHLOROETHYL ETHER (BIS(2-CHLOROETHYL)ETHER)
1,3-DICHLOROPROPENE
DIETHANOLAMINE
DIETHYL SULFATE
N,H'-DIMETHYIANILINE
3,3'-DIMETHYL BENZIDINE
DIMETHYL FORMAMIDE
1,1-DIMETHYL HYDRAZINE
DIMETHYL PHTHALATE
DIMETHYL SULFATE
2,4-DINITROPHENOL
2,4-DINITROTOLUENE
1,4-DIOXANE
1, 2-DIPHENYLHYDRAZINE
EPICHLOROHYDRIN
ETHYL ACRYLATE
ETHYL BENZENE
ETHYL CHLORIDE
ETHYLENE DIBROMIDE
12, 13, 20, 21,
28
3-14
-------
Table 3.1 (continued)
SOURCE CATEGORY UAME
POLLUTABT(S)
SYNTHETIC ORGANIC CHEMICAL MANUFACTURING
(continued)
ETHYLENE BICHLORIDE
ETHYLENE GLYCOL
ETHYLENE OXIDE
ETHYLIDENE DICHLORIDE
FORMALDEHYDE
GLYCOL ETHERS
HEXACHLOROBENZENE
HEXACHLOROBUTADIENE
HEXACHLOROETHANE
HEXAKE
HYDROQUINONE
ISOPHORONE
MALE1C ANHYDRIDE
METHANOL
METHYL BROMIDE
METHYL CHLORIDE
METHYL CHLOROFORM
METHYL ETHYL KETONE
METHYL HYDRAZINE
METHYL ISOBUTYL KETONE
METHYL ISOCYANATE
METHYL METHACRYLATE
METHYL TERT BUTYL ETHER
METHYLENE CHLORIDE
METHYLENE DIPHENYL DIISOCYANATE (MDI)
4,4-METHYLENEDIANILINE
NAPHTHALENE
NITROBENZENE
4-NITROPHENOL
2-NITROPROPANE
PHENOL
P-PHENYLENEDIAMINE
PHOSGENE
PHTHALIC ANHYDRIDE
B-PROPIOLACTONE
PROPIONALDEHYDE
PROPYLENE DICHLORIDE
PROPYLENE OXIDE
QUINONE
STYRENE
1,1,2,2-TETRACHLOROETHANE
TETRACHLOROETHYLENE
TOLUENE
2,4-TOLUENE DIAMINE
2,4-TOLUENE DIISOCYANATE
0-TOLUIDINE
1,2,4-TRICHLOROBENZENE
1,1,2-TRICHLOROETHANE
TRICHLOROETHYLENE
2,4,5-TRICHLOROPHENOL
TRIETHYLAMINE
2,2,4-TRIMETHYLPEIITANE
VINYL ACETATE
VINYL CHLORIDE
VINYLIDENE CHLORIDE
XYLENES (ISOMERS AND MIXTURES)
M-XYLEHE
O-XYLENE
P-XYLEHE
12, 13, 20, 21,
28
3-15
-------
Table 3.1 (continued)
SOURCE CATEGORY HAMS
__._.„-, f.r r
AEROSOL CAN-FILLING FACILITIES
BEN ZYLTRIMETHYLAMMON IUM CHLORIDE PRODUCTION
BUTADIENE DIMERS PRODUCTION
CARBONYL SULFIDE PRODUCTION
CHELATING AGENTS PRODUCTION
CHLORINATED PARAFFINS PRODUCTION
CHROMIC ACID ANODIZING
COMMERCIAL DRY CLEANING ( PERCHLOROETHYLENE ) - TRANSFER
MACHINES
COMMERCIAL STERILIZATION FACILITIES
DECORATIVE CHROMIUM ELECTROPLATING
DODECANEDIOIC ACID PRODUCTION
DRY CLEANING (PETROLEUM SOLVENT)
ETHYLIDENE NORBORNENE PRODUCTION
EXPLOSIVES PRODUCTION
HALOGENATED SOLVENT CLEANERS
HARD CHROMIUM ELECTROPLATING
HYDRAZINE PRODUCTION
INDUSTRIAL DRY CLEANING (PERCHLOROETHYLENE) - DRY-TO-DRY
MACHINES
INDUSTRIAL DRY CLEANING (PERCHLOROETHYLENE) - TRANSFER
MACHINES
INDUSTRIAL PROCESS COOLING TOWERS
OXYBISPHENOXARSINE/I, 3-DIISOCYANATE PRODUCTION
PAINT STRIPPER USERS
PHOTOGRAPHIC CHEMICALS PRODUCTION
POLLUTAHT(S)
METHYL CHLOROFORM
METHYLENE CHLORIDE
TETRACHLOROETHYLENE
BENZYL CHLORIDE
1, 3-BUTADIENE
CARBONYL SULFIDE
CYANIDE COMPOUNDS
CARBON TETRACHLORIDE
CHROMIUM COMPOUNDS
TETRACHLOROETHYLENE
ETHYLENE OXIDE
CHROMIUM COMPOUNDS
1, 3-BUTADIENE
CHLOROBENZENE
CUMENE
ETHYL BENZENE
POLYCYCLIC ORGANIC MATTER
TOLUENE
XYLENE (O-)
1, 3-BUTADIENE
PHOSPHORUS
TOLUENE
METHYL CHLOROFORM
METHYLENE CHLORIDE
TETRACHLOROETHYLENE
TRICHLOROETHYLENE
CHROMIUM COMPOUNDS
HYDRAZINE
TETRACHLOROETHYLENE
TETRACHLOROETHYLENE
CHROMIUM COMPOUNDS
NICKEL COMPOUNDS
PHOSPHORUS
CHLOROFORM
METHYLENE CHLORIDE
BENZIDINE
BETA-PROPIOLACTONE
ETHYLIDENE DICHLORIDE
HYDROQUINONE
B-NITROSODIMETHYLAMINE
REFERENCE
45, 48, 55, 69,
111
31, 334
7, 314, 336
17, 343
35, 337
133
70, 71, 356
55, 114
15, 110
70, 71, 356
7, 67
1, 18, 344
7, 132
56, 65, 97, 123,
349
18, 352, 353
70, 71, 356
14, 338
55, 114
55, 114
65, 70, 71, 73,
120, 121
135
48, 124, 348
16, 41, 97, 339
3-16
-------
Table 3.1 (continued)
SOURCE CATEGORY SAME
PHTHALATE PLAS T I C I Z ERS PRODUCTION
PLYWOOD/PARTICLE BOARD MANUFACTURING
POLYETHER POLYOLS PRODUCTION
PULP I PAPER PRODUCTION
ROCKET ENGINE TEST FIRING
RUBBER CHEMICALS MANUFACTURING
SEMICONDUCTOR MANUFACTURING
SYMMETRICAL TETRACHLOROPYRIDINE PRODUCTION
TIRE PRODUCTION
WOOD TREATMENT
POLLUTAST(S)
PHTHALIC ANHYDRIDE
MANGANESE COMPOUNDS
POLYCYCLIC ORGANIC MATTER
PROPYLENE OXIDE
ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSINE)
CADMIUM COMPOUNDS
CHLORINE
CHLOROFORM
CHROMIUM COMPOUNDS
LEAD COMPOUNDS
MANGANESE COMPOUNDS
MERCURY COMPOUNDS
NICKEL COMPOUNDS
SELENIUM COMPOUNDS
HYDROGEN CHLORIDE
ANILINE
CARBON DISULFIDE
HYDROflUINONE
ETHYLIDENE DICHLORIDE
CARBON TETRACHLORIDE
BENZENE
HEXANE
TOLUENE
PENTACHLOROPHENOL
REFERENCE
53, 345, 346, 347
1, 18, 19, 351
63, 293
1, 2, 19, 34, 331
112, 350
30, 33, 41, 340
16, 97, 341, 342
134
1, 18, 332, 333
49, 74, 97
3-17
-------
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102. Letter from Teepak, Inc., to Rosensteel, B., Chemical
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104. Memorandum from Ajax, R.L., and Wyatt, S.R.,
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108. Memorandum from Maxwell, B., Industrial Studies Branch,
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111. Ref. 69, pp. 1 and 8.
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118. Facsimile. Williamson, M., MRI, to Svendsgaard, D.,
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129. Letter with attachment from Bell, A.E., Texas Air Control
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150. U.S. Environmental Protection Agency. Background
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271. Ref. 259, p. 140.
272. Chemical Products Synopsis - Formaldehyde. Mannsville
Chemical Products, Mannsville, New York. June 1983.
(II-I-8)
273. Ref. 164, pp. 897 and 1210.
274. Ref. 152, pp. 527 and 528.
275. Ref. 164, p. 490.
276. Ref. 152, pp. 316, 724 and 725, and 933.
277. Ref. 136, p. 99.
278. Ref. 164, p. 763.
279. Ref. 152, pp. 228 and 1022.
280. Chemical Products Synopsis - Methyl Chloride. Mannsville
Chemical Products, Mannsville, New York. August 1983.
(IV-J-10)
281. Austin, G.T. Shreve's Chemical Process Industries, Fifth
Edition. McGraw-Hill, Inc., New York, New York. 1984.
p. 702. (IV-J-12)
282. Ref. 164, p. 825.
283. Ref. 259, p. 30.
284. Ref. 281, pp. 272 and 273.
285. Ref. 152, pp. 918 and 919.
286. Ref. 281, p. 671.
287. Ref. 164, p. 897.
288. Ref. 281, p. 384.
3-41
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289. Ref. 164, p. 932.
290. Ref. 136, pp. 52 to 54.
291. Ref. 164, p. 933.
292. Ref. 281, p. 653.
293. Ref. 152, pp. 927 and 1211.
294. Ref. 164, p. 936.
295. U.S. Environmental Protection Agency. Polymer Manufacturing
Industry—Background Information for Proposed Standards.
EPA-450/3-83-019a. September 1985. p. 3-55. (IV-A-37)
296. Ref. 164, p. 946.
297. Ref. 152, pp. 1223 to 1225.
298. Ref. 152, pp. 756 and 757.
299. Ref. 164, p. 943.
300. Ref. 295, p. 3-40.
301. Ref. 164, p. 944.
302. Ref. 259, p. 147.
303. Ref. 152, p. 1227.
304. Ref. 281, pp. 465 and 466.
305. Ref. 164, p. 945.
306. Ref. 259, pp. 73 and 198.
307. Skeist, I., Editor. Handbook of Adhesives, Second Edition.
Van Nostrand Reinhold Company, New York, New York. 1977.
p. 472. (IV-J-3)
308. Ref. 164, pp. 945 and 946
309. Ref. 259, pp. 133 and 136.
310. Ref. 259, pp. 225 to 252.
311. Ref. 164, p. 1101.
312. Ref. 136, p. 44.
3-42
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313. Ref. 259, p. 104.
314. Ref. 136, p. 103.
315. Ref. 164, pp. 96 and 932.
316. Ref. 152, pp. 133, 134, and 915 to 917.
317. Ref. 164, p. 627.
318. Ref. 152, pp. 936 to 938 and 1031 to 1033.
319. Encyclopedia of Polymer Science and Engineering. Volume 6.
John Wiley and Sons, Inc., New York, New York. 1986.
pp. 308 to 315. (IV-J-15)
320. Memorandum from Maxwell, B., Industrial Studies Branch,
U.S. Environmental Protection Agency, to Source Category
List Docket No. A-90-49. October 1, 1991. Source Category
List Discussion: Wool Fiberglass Production. (IV-B-23)
321. Ref. 152, p. 984.
322. Ref. 152, pp. 334 and 335.
323. Ref. 152, p. 1208.
324. Ref. 151, p. 1072.
325. Chemical Products Synopsis of Ammonium Sulfate. Mannsville
Chemical Products, Asbury Park, New Jersey. June 1988.
(IV-J-21)
326. Chemical Products Synopsis of Antimony Oxides, Mannsville
Chemical Products, Asbury Park, New Jersey. March 1990.
(IV-J-26)
327. U.S. Environmental Protection Agency. Prevention Reference
Manual: Chemical Specific, Volume 9: Control of
Accidental Releases of Chlorine. Air and Energy Engineering
Research Laboratory, Research Triangle Park, North Carolina.
Publication No. EPA/600/8-87/034i. August 1987.
pp. 13 to 17. (IV-A-42)
328. Memorandum from Maxwell, W.H., Office of Air Quality
Planning and Standards, Emission Standards Division, to
Rosensteel, R., Chemicals and Petroleum Branch, Office of
Air Quality Planning and Standards. June 18, 1991. Title
III Source Category Ranking System—Clarification of Bases
for Identifying Source Categories. (IV-B-13)
329. Ref. 151, p. 295.
3-43
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330. Ref. 151, p. 920.
331. Ref. 2, pp. 3-1 and 3-2.
332. U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Manufacture of Pneumatic Rubber
Tires. Office of Air Quality and Planning Standards.
Guideline Series, Research Triangle Park, North Carolina.
EPA-450/2-78-030. December 1978. p. 2-5. (IV-A-13)
333. U.S. Environmental Protection Agency. RACT Enforceability
Aspects for Pneumatic Tire Manufacture. General
Enforcement, Washington, D.C. EPA-350/1-80-017. January
1981. p. 11. (IV-A-24)
334. Ref. 151, p. 138.
335. Scott, R.J. Fiberglass Boat Design and Construction.
John de Graff, Inc., Tuckahoe, New York. 1973.
pp. 19 to 29. (IV-J-1)
336. Ref. 151, p. 298.
337. Ref. 152, pp. 242 to 244.
338. Ref. 151, p. 899.
339. Ref. 281, pp. 410 to 420.
340. Radian Corporation. Rubber-Processing Chemicals
Manufacturing Industry Overview and Hazardous Waste
Assessment Study. U.S. Environmental Protection Agency.
Research Triangle Park, North Carolina.
Contract No. 68-02-3174. May 1984. pp. i to iii,
2-1 to 2-8, and 3-1 to 3-3. (IV-A-35)
341. Ref. 152, pp. 1043 to 1048.
342. Ref. 164, pp. 560, 1032, 1033, 1038, and 1039.
343. Ref. 152, p. 1131.
344. U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Petroleum Dry Cleaners, Preliminary
Draft. Office of Air Quality Planning and Standards,
Guideline Series. February 1981. pp. 2-1 to 2-6.
(IV-A-25)
345. Ref. 259, pp. 202 to 204.
346. Ref. 164, p. 925.
3-44
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347. Ref. 152, pp. 884, 885, 904, and 905.
348. Memorandum from Most, C. , Radian Corporation, to Paint
Stripping Facilities Project File. December 18, 1987.
Emissions, Controls, and HEM Inputs Memorandum for Paint
Stripping Users, pp. 1 and 2. (IV-B-8)
349. Ref. 152, pp. 446 to 448.
350. National Aeronautics and Space Administration Supplemental
Final Environmental Impact Statement, Space Shuttle Advanced
Solid Rocket Motor Program. August 1990. p. 4-21.
(IV-J-33)
351. Letters from Docket A-90-49, Items IV-D-21, IV-D-60,
IV-D-25, IV-D-26, IV-D-59, and IV-G-06, to Air Docket
(LE-131), U.S. Environmental Protection Agency. 1991.
Comments on Draft Preliminary List of Source Categories.
352. U.S. Environmental Protection Agency. Organic Solvent
Cleaners - Background Information for Proposed Standard
Draft EIS. Office of Air Quality Planning and Standards,
Research Triangle Park, North Carolina. EPA-450/2-78-045a.
October 1979. pp. 3-1 and 3-2. (IV-A-21)
353. U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Solvent Metal Cleaning. Office of
Air Quality Planning and Standards, Guidelines.
EPA-450/2-77-022. November 1977. pp. 2-1 to 2-12, 2-16,
2-17, 2-19, 2-33 to 2-34, and 2-39. (IV-A-7)
354. Chemical Product Synopsis—Acrylamide. Mannsville Chemical
Products, Mannsville, New York. January 1988. (II-I-57).
355. Memorandum from Lucas, R.B. Office of Air Quality Planning
and Standards, Chemicals and Petroleum Branch, to Padgett,
J., Associate Director for Intermedia and Intergovernmental
Programs, Office of Air Quality Planning and Standards.
July 20, 1988. New Study on the Air Toxics Problem in the
United States—POTW Emissions. (II-B-6)
356. Memorandum from Svendsgaard, D., Chemicals and Petroleum
Branch, to Tim Mohin, Pollutant Assessment Branch,
U. S. Environmental Protection Agency. June 19, 1992.
Addition of Chromium Electroplaters to the List of Major
Source Categories.
3-45
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4.0 LISTING OF CATEGORIES OF AREA SOURCES AND ASSOCIATED
HAZARDOUS AIR POLLUTANTS
4.1 INTRODUCTION
Categories of area sources are listed in Table 4.1 in
alphabetical order. These source categories identify area
sources that EPA has found to present a threat of adverse effects
to human health or the environment warranting regulation under
Section 112 of the CAA.
The associated HAP's and references used for emissions data
collection and description purposes are indicated for each source
category in Table 4.1. The HAP's are located in the column
labeled "Pollutant Name." The pollutants listed are those for
which documentation was readily available. Additional HAP's may
also be emitted from a source category that are not listed in
Table 4.1. This situation will be considered during the
development of individual regulations, at which time additional
HAP's may be identified for a source category. The specific
references from the listing approach used to identify and
describe each source category are coded by number in the last
column of Table 4.1 to correspond to the list of references in
Section 4.2.
For further information regarding the listing of categories
of area sources that appear in Table 4.1, the reader is referred
to the upcoming Federal Register notice entitled "Initital List
of Categories of Sources under Section 112(c)(l) of the Clean Air
Act Amendments of 1990," which will announce the listing of
source categories that appear in this document.
4-1
-------
Table 4.1 Categories of Area Sources and Associated
Hazardous Air Pollutants
SOURCE CATEGORY NAME *
ASBESTOS PROCESSING
CHROMIC ACID ANODIZING
COMMERCIAL DRYCLEANING (PERCHLOROETHYLENE) -
TRANSFER MACHINES
COMMERCIAL DRYCLEANING (PERCHLOROETHYLENE) -
DRY-TO-DRY MACHINES
COMMERCIAL STERILIZATION FACILITIES
DECORATIVE CHROMIUM ELECTROPLATING
HARD CHROMIUM ELECTROPLATING
HALOGENATED SOLVENT CLEANERS
POLLUTAHT(S)
ASBESTOS
CHROMIUM COMPOUNDS
TETRACHLOROETHYLENE
TETRACHLOROETHYLENE
( PERCHLOROETHYLENE }
( PERCHLOROETHYLENE )
ETHYLENE OXIDE
CHROMIUM COMPOUNDS
CHROMIUM COMPOUNDS
TRICHLOROETHYLENE
TETRACHLOROETHYLENE
METHYLENE CHLORIDE
METHYL CHLOROFORM
(PERCHLOROETHYLENE )
* THE READER IS REFERRED TO REFERENCE 1 IN SECTION 4.2 FOR FURTHER INFORMATION
REGARDING THE BASIS FOR LISTING THE CATEGORIES OF AREA SOURCES APPEARING IN
TABLE 4.1.
4-2
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4.2 REFERENCES
1. Memorandum from Shear, N., Pollutant Assessment Branch, U.S,
Environmental Protection Agency, to Source Category List
Docket No. A-90-49. June 26, 1992. Final References for
Area Source Findings—Post OMB Review.
4-3
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APPENDIX A
Descriptions of Categories of Major Sources
-------
The following descriptions are intended to provide
information on the types of operations, processes and equipment
included within each category of major sources. Because of
current data limitations, a comprehensive discussion of processes
and/or equipment in HAP service is not possible. More detailed
analyses may be conducted during regulatory development, and such
information that becomes available in the future may serve to
refine these descriptions.
The descriptions for categories of major sources frequently
use terminology like "...including, but not limited to..." which
is meant to encompass process steps such as recovering/purifying
HAP's or HAP-containing materials such as unreacted raw
materials, solvents, and other stream components that are not
otherwise mentioned specifically within the descriptions.
Descriptions for categories of area sources can be found in the
preamble to the upcoming Federal Register notice announcing the
initial list of categories of sources under Section 112(c)(l) of
the Clean Air Act as amended in 1990.
The descriptions in Appendix A are presented for each
category of major sources and are arranged by industry group
similar to Table 3.1, in Section 3.0. Where applicable for each
category described in this appendix, the following five types of
emission points will be considered upon development of
regulations: equipment leaks, process vents, transfer-
operations, storage tanks (raw material, intermediate, and final
product), and wastewater collection and treatment systems
associated with the source category.
A-2
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INDUSTRY GROUP - FUEL COMBUSTION
Source Category: Engine Test Facilities
The Engine Test Facilities source category includes any
facility engaged in the testing of stationary and mobile engines,
including turbines and reciprocating engines. Testing purposes
include determining conformity with applicable standards and/or
new product testing.
Source Category: Industrial Boilers
The Industrial Boilers source category includes boilers used
in manufacturing, processing, mining, and refining or any other
industry to provide steam, hot water, and/or electricity. The
category includes, but is not limited to, boilers fired by wood,
coal, oil, natural gas, waste-type fuel, and mixed or other fuel.
Boiler types include watertube and firetube. Firing methods
include pulverized dry bottom, pulverized wet bottom, underfeed
stoker, spreader stoker, and hand stoker.
Source Category: Institutional/Commercial Boilers
The Institutional/Commercial Boilers source category
includes, but is not limited to, boilers used in commercial
establishments, medical centers, research centers, institutions
of higher education, hotels, and laundries to provide
electricity, steam, and/or hot water. The category includes, but
is not limited to, boilers fired by wood, coal, oil, natural gas,
waste-type fuel, and mixed or other fuel. Firing methods include
pulverized dry bottom, pulverized wet bottom, underfeed stoker,
spreader stoker, and hand stoker. Boiler types include watertube
and firetube.
A-3
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INDUSTRY GROUP - FUEL COMBUSTION (CONTINUED)
Source Category: Process Heaters
The Process Heaters source category includes, but is not
limited to, secondary metals process heaters, petroleum and
chemical industry process heaters, and other process heaters. A
process heater is defined as a piece of equipment (usually a
furnace-type device) used to heat chemical process stream
materials (liquids, gases, or solids) in plant or on-site
operations. Heater types include, but are not limited to,
direct-fired, indirect-fired, and pebble heaters. The category
includes process heaters fired by natural gas, oil, coal, wood,
waste, mixed, and other types of fuel.
Source Category: Stationary Internal Combustion Engines
The Stationary Internal Combustion Engines source category
includes utility, industrial, and commercial reciprocating
internal combustion engines used for compressor and pump drives,
electricity generation, and other industrial processes. The
category includes, but is not limited to, internal combustion
engines that are fueled by gasoline, diesel fuel, natural gas,
sewage gas, and any other types of fuel.
A-4
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INDUSTRY GROUP - FUEL COMBUSTION (CONTINUED)
Source Category: Stationary Turbines
The Stationary Turbines source category includes combustion
turbines used by electric and gas utilities, industrial
establishments, and commercial/institutional operations to
provide electricity, gas compression, or other functions.
Included in the category are turbines fired by fuel oil, natural
gas, and mixed or other fuel. The Stationary Turbine source
category includes simple cycle and regenerative cycle turbines,
and the turbine portion of a combined cycle steam/electric
generating system.
A-5
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INDUSTRY GROUP - NON-FERROUS METALS PROCESSING
Source Category: Primary Aluminum Production
The Primary Aluminum Production source category includes any
facility engaged in producing primary aluminum by
electrolytically reducing alumina. The category includes, but is
not limited to, the following process units: carbon mix plants,
reduction plants, anode bake plants, holding furnaces in the
casting area, casting processes, and refining processes. The
reduction plant consists of electrically linked cells which can
be one of the following types: prebake, horizontal stud
Soderberg, and vertical stud Soderberg. Reduction plants using
prebake cells require a separate anode bake plant facility, which
utilizes either a ring furnace or tunnel kiln in anode
production.
A-6
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INDUSTRY GROUP - NON-FERROUS METALS PROCESSING (CONTINUED)
Source Category: Secondary Aluminum Production
The Secondary Aluminum Production source category includes
any facility engaged in the cleaning, melting, refining,
alloying, and pouring of aluminum recovered from scrap, foundry
returns, and dross, to form aluminum products such as alloy
ingots, billets, notched bars, shot, hot metals, and hardeners.
The category includes, but is not limited to, the following
process steps: inspection, sorting, pretreatment,
smelting/refining, and coating. The pretreatment of the aluminum
scrap, foundry returns, and dross can include the following
treatments: crushing/screening, bailing, shredding, burning,
drying, hot dross processing, dry milling, leaching, roasting,
and sweating. The smelting/refining of the treated aluminum
scrap includes, but is not limited to, the following steps:
charging, melting, fluxing, alloying, mixing, demagging,
degassing, skimming, and pouring. Smelting/refining incorporates
the following processes: reverberating (chlorine)
smelting/refining, reverberating (fluorine) smelting/refining,
crucible smelting/refining, and induction smelting/refining.
A-7
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INDUSTRY GROUP - NON-FERROUS METALS PROCESSING (CONTINUED)
Source Category: Primary Copper Smelting
The Primary Copper Smelting source category includes any
facility engaged in the pyrometallurgical process used for the
extraction of copper from sulfur oxides, native ore concentrates,
or other copper bearing minerals. The category includes, but is
not limited to, the following smelting process units: roaster,
smelting furnace, and converter. The roaster smelting process
unit can utilize a multiple-hearth roaster or a fluid-bed
roaster. The smelting furnace process unit can utilize a fossil-
fuel-fired reverberatory furnace, electric furnace, Outo-kumpu
flash furnace, Noranda continuous smelter, Inco flash smelting
furnace, or other furnace type. The converter process unit can
consist of a Smith, "siphon," or other type converter.
Source Category: Primary Lead Smelting
The Primary Lead Smelting source category includes any
facility engaged in producing lead metal from ore concentrates.
The category includes, but is not limited to, the following
smelting processes: sintering, reduction, preliminary treatment,
and refining operations. The sintering process includes an
updraft or downdraft sintering machine. The reduction process
includes the blast furnace, electric smelting furnace with a
converter or reverberatory furnace, and slag fuming furnace
process units. The preliminary treatment process includes the
dressing kettles and dross reverberatory furnace process units.
The refining process includes the refinery process unit.
A-8
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INDUSTRY GROUP - NON-FERROUS METALS PROCESSING (CONTINUED)
Source Category: Secondary Lead Smelting
The Secondary Lead Smelting source category includes any
facility engaged in the production of purified lead from lead
scrap by melting and separating lead from metal and nonmetallic
contaminants and by reducing lead compounds to elemental lead.
The category includes processes associated with secondary lead
smelting such as battery breaking, smelting in reverberatory,
blast, rotary and electric furnaces, refining, alloying and
casting.
Source Category: Lead Acid Battery Manufacturing
The Lead Acid Battery Manufacturing source category includes
any facility engaged in producing lead-acid or lead-acid storage
batteries, including, but not limited to, starting-lighting-
ignition (SLI) batteries and industrial storage batteries. The
category includes, but is not limited to, the following lead-acid
battery manufacturing steps: lead oxide production, grid
casting, paste mixing, and three-process operation (plate
stacking, burning, and assembly).
Source Category: Primary Magnesium Refining
The Primary Magnesium Refining source category includes any
facility engaged in producing metallic magnesium. The source
category includes, but is not limited to, metallic magnesium
produced using the Dow sea-water process or the Pidgeon process.
The Dow sea-water process involves the electrolysis of molten
magnesium chloride. The Pidgeon process involves the thermal
reduction of magnesium oxide with ferrosilicon.
A-9
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INDUSTRY GROUP - FERROUS METALS PROCESSING
Source Category: Coke By-Product Plants
The Coke By-Product Plant source category includes the by-
product recovery plant component of a by-product recovery coke
oven battery. A by-product coke oven battery manufactures
metallurgical coke by destructive distillation of coal in ovens.
Volatile compounds are driven from the coal, collected from each
oven, and processed in an adjacent plant (by-product plant) for
recovery of combustible gases and other coal by-products. The
coke by-product recovery plant includes, but is not limited to,
the following process units: flushing liquor decanter,
dehydrator primary cooler decanter, primary cooler, final tar
extractor, electrostatic precipitator, weak ammonia liquor
settling tank, phenol extractor, ammonia still, exhauster,
precipitator reheater, ammonia absorber, final cooler, light oil
scrubber, hydrogen sulfide scrubber, gas holder, and booster
station.
A-10
-------
INDUSTRY GROUP - FERROUS METALS PROCESSING (CONTINUED)
Source Category: Coke Ovens: Charging, Top Side, and Door Leaks
The Coke Ovens: Charging, Top Side, and Door Leaks source
category includes emissions occurring during the charging
process, from topside ports and offtake systems, and from oven
doors of a coke oven battery. A coke oven battery is defined as
a facility engaged in the manufacturing of metallurgical coke by
the destructive distillation of coal. The charging process
includes the following steps: transfer of coal from bunker into
larry car; positioning of larry car on wide-gauge railroad tracks
over an empty, hot oven; opening of the lids on the charging
ports; discharge of coal from the hoppers of the larry car
through the charging pots into the coke oven; and the closing of
the charging port lids. The top side leaks include emissions
from closed charge ports, ascension pipes, and the collector
main, which are located on the top of the coke oven. The door
leaks include emissions from the coke oven doors when they are
closed and the oven is in operation.
A-ll
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INDUSTRY GROUP - FERROUS METALS PROCESSING (CONTINUED)
Source Category: Coke Ovens: Pushing, Quenching, arid
Battery Stacks
The Coke Ovens: Pushing, Quenching, and Battery Stacks
source category includes emissions from pushing and quenching
operations, and battery stacks at a coke oven battery. A coke
oven battery is defined as a facility engaged in the
manufacturing of metallurgical coke by the destructive
distillation of coal. The pushing process includes the following
steps: opening of the doors at both ends of the coke oven;
positioning of the pusher machine by the open oven; removal of
the incandescent coke from the coke side of the oven by a ram
which is extended from the pusher machine; and the receiving of
incandescent coke by the rail quench car. The quenching process,
which follows the pushing process, includes the quench tower,
where several thousand gallons of water are sprayed onto the coke
mass to cool it. The battery stack component of the coke oven
includes, the underfire or combustion stack, which receives hot
gases from the oven flues.
A-12
-------
INDUSTRY GROUP - FERROUS METALS PROCESSING (CONTINUED)
Source Category: Ferroalloys Production
The Ferroalloys Production source category includes any
facility engaged in producing ferroalloys such as ferrosilicon,
ferromanganese, and ferrochrome. A ferroalloy is an alloy of
iron and one or more other elements, such as silicon, manganese,
or chromium. Ferroalloys are used as additives to impart unique
properties to steel and cast iron. Ferroalloys production
includes, but is not limited to, the following processes:
unloading, storage, sintering, crushing, weigh-feeding, smelting,
tapping, casting, and screening. The smelting process can be
performed in a variety of furnace types including, but not
limited to: submerged electric arc furnaces, induction furnaces,
vacuum furnaces, exothermic reaction furnaces, and electrolytic
cells.
Source Category: Integrated Iron and Steel Manufacturing
The Integrated Iron and Steel Manufacturing source category
includes any integrated iron and steel facility engaged in
producing steel. Integrated Iron and Steel Manufacturing
includes the following processes: sinter production, iron
production, iron preparation (hot metal desulfurization), steel
production, semifinished product preparation, finished product
preparation, and handling and treatment of raw, intermediate, and
waste materials.
The iron production process includes the production of iron
in blast furnaces by the reduction of iron-bearing materials with
a hot gas. The steel production process includes basic oxygen
furnaces and open hearth furnaces.
A-13
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INDUSTRY GROUP - FERROUS METALS PROCESSING (CONTINUED)
Source Category: Non-Stainless Steel Manufacturing - Electric
Arc Furnace (EAF) Operation
The Non-Stainless Steel Manufacturing - Electric-Arc Furnace
(EAF) Operation source category includes any facility that uses
electric arc furnaces to melt steel scrap and cast semifinished
non-stainless steel shapes that must be mechanically worked to
form final products. The steel may contain small amounts of
alloying elements such as vanadium, molybdenum, manganese,
silicon, and copper. The plant includes the following process
units: electric arc furnace, forming facilities, and rolling
facilities.
In steel production, the electric-arc furnace is used as a
metal melter and a refining vessel. In the production process,
additives are added either directly to the furnace or added to
the ladle during a tap. The electric arc furnace process steps
include charging, meltdown, refining, and tapping.
A-14
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INDUSTRY GROUP - FERROUS METALS PROCESSING (CONTINUED)
Source Category: Stainless Steel Manufacturing - Electric Arc
Furnace (EAF) Operation
The Stainless Steel Manufacturing - Electric Arc Furnace
(EAF) Operation source category includes any facility that uses
electric arc furnaces to melt steel scrap and cast semifinished
stainless steel shapes that must be mechanically worked to form
final products. Stainless steel, by definition, contains four
percent or more chromium.. Additional elements such as silicon
and manganese can be added to give the steel certain properties,
such as greater strength.
A stainless steel plant includes the following process
units: EAF, argon-oxygen decarburization (AOD) vessel, and
forming and rolling facilities. The EAF functions primarily as a
metal melter and the AOD vessel is used to refine the molten
metal. Electric arc furnace stainless steel production processes
include consumable-electrode melting and electroslag remelting.
The production process steps include charging to the EAF,
meltdown, tapping from the AOD vessel, and refining in the AOD
vessel.
Raw materials used to produce stainless steels include No. 1
grade scrap; stainless scrap; and alloys such as ferromanganese,
ferrochrome, high carbon chrome, nickel, molybdenum oxide,
aluminum, manganese, silicon, and others.
A-15
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INDUSTRY GROUP - FERROUS METALS PROCESSING (CONTINUED)
Source Category: Iron Foundries
The Iron Foundries source category includes any facility
engaged in producing final shape castings from grades of iron
that include, but are not limited to, gray iron (also known as
pig iron), malleable iron (also known as white cast iron), and
ductile iron (also known as nodular cast iron). Gray iron is a
high-carbon iron that serves as the basic raw material for steel
and cast iron. Malleable iron contains about three percent
carbon, in the form of cementite and fine pearlite, and contains
little or no graphite. Ductile iron is gray iron which has been
treated with magnesium (0.01 - 1.0 percent).
The Iron Foundries category includes the following four
major production steps: raw materials handling and preparation,
metal melting, mold and core production, and casting and
finishing.
Raw materials handling and preparation includes the
following processes: receiving, unloading, storing, and
conveying of all raw materials for both furnace charging and mold
and core preparation.
Metal melting includes, but is not limited to, the following
processes: furnace charging, melting, backcharging, refining and
treatment, slag removing, and tapping. Casting and finishing
includes the following steps: tapping of molten metal into
ladle, ductile iron inoculation, molten metal treatment with
magnesium, ladling into molds, transport to cooling area, removal
of unwanted appendages, and abrasive blast cleaning and/or
tumbling.
A-16
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INDUSTRY GROUP - FERROUS METALS PROCESSING (CONTINUED)
Source Category: Steel Foundries
The Steel Foundries source category includes any facility
engaged in producing final shape steel castings by the melting,
alloying, and molding of pig iron and steel scrap. The category
includes, but is not limited to, the following steel foundry
process operations: raw materials handling, metal melting, mold
and core production, and casting and finishing.
Source Category: Steel Pickling - HC1 Process
The Steel Pickling - HC1 Process source category includes
any facility engaged in the pickling of steel using hydrochloric
acid (HC1) as the pickling acid. Pickling is defined as a
process which chemically removes oxides and scale from the
surface of steel by the action of agueous solutions of inorganic
acids. Not included in this category are facilities which pickle
steel using other acids.
The category includes both batch and continuous pickling
operations. In the batch pickling process, the steel is immersed
in an acid solution until the scale or oxide film is removed,
lifted from the bath, allowed to drain, and then rinsed by
sequential immersion in rinse tanks. In the continuous pickling
process, pickling lines pass the steel through the pickler in a
countercurrent direction to the flow of the acid solution; next,
the steel is lifted from the acid, allowed to drain, and then
rinsed in a series of rinse tanks.
A-17
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INDUSTRY GROUP - MINERAL PRODUCTS PROCESSING
Source Category: Alumina Processing
The Alumina Processing source category includes any facility
engaged in processing of ores to produce alumina. The base ore
for alumina is bauxite. After the ores are purified to alumina,
the alumina is reduced to elemental aluminum. This source
category does not include the production of aluminum from
alumina.
This category includes, but is not limited to, facilities
which produce alumina by the Bayer process. In the Bayer
process, the ore is dried, ground in ball mills, and mixed with a
leaching solution of sodium hydroxide to produce a sodium
aluminate solution. The solution is separated from the bauxite
impurities and then cooled. As the solution cools, hydrated
aluminum oxide precipitates. After separation and washing to
remove impurities, the aluminum oxide is dried and is calcined to
produce a crystalline form of alumina.
Source Category: Asphalt/Coal Tar Application - Metal Pipes
The Asphalt/Coal Tar Application - Metal Pipes source
category includes any facility engaged in coating the surfaces of
metal pipes with asphalt or coal tar. The category includes all
process units associated with the coating of metal pipes.
A-18
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INDUSTRY GROUP - MINERAL PRODUCTS PROCESSING (CONTINUED)
Source Category: Asphalt Concrete Manufacturing
The Asphalt Concrete Manufacturing source category includes
any facility engaged in the manufacture of asphaltic concrete.
Asphaltic concrete is a mixture of well graded, high quality
aggregate and liquid asphaltic cement which is heated and mixed
in measured quantities to produce bituminous pavement material.
Manufacturing processes for asphaltic concrete include batch mix,
continuous mix, and drum mix operations. The category includes,
but is not limited to, the following process units: dryers;
systems for screening, handling, storing, and weighing hot
aggregate; systems for loading, transferring, and storing mineral
filler; systems for mixing and recycling hot mix asphalt; and the
loading, transfer, and storage systems associated with emission
control systems.
Source Category: Asphalt Processing
The Asphalt Processing source category includes any facility
engaged in the preparation of asphalt at asphalt processing
plants, petroleum refineries, and asphalt roofing plants.
Asphalt preparation, called "blowing," involves the oxidation of
asphalt flux by bubbling air through the liquid asphalt flux at
260°C for 1 to 4.5 hours, depending upon the desired
characteristics of the asphalt. The category includes, but is
not limited to, the following processes: asphalt heating,
blowing still, and asphalt storage tanks.
A-19
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INDUSTRY GROUP - MINERAL PRODUCTS PROCESSING (CONTINUED)
Source Category: Asphalt Roofing Manufacturing
The Asphalt Roofing Manufacturing source category includes
any facility engaged in the manufacturing of asphalt roofing
products such as asphalt saturated felt rolls, roll roofing with
mineral granules on the surface, and smooth roll roofing. The
category includes, but is not limited to, the following
processes: asphalt storage, felt saturation, coating, and
mineral surfacing. The asphalt preparation process (blowing) is
not included in this category.
A-20
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INDUSTRY GROUP - MINERAL PRODUCTS PROCESSING (CONTINUED)
Source Category: Chromium Refractories Production
The Chromium Refractories source category includes any
facility engaged in producing chromium-containing refractories.
Refractories are heat-resistant materials which are used to build
or line high-temperature industrial furnaces. Chromium-
containing refractories are produced from chrome ore or chromic
oxide along with other raw materials such as alumina, zirconia,
silica, and magnesia. This category includes, but is not limited
to, facilities which manufacture magnesia-chrome, chrome-
magnesite, chrome-alumina, and chromic oxide refractories. Also
included are facilities which manufacture either formed (bricks)
or unformed (mortar, castables) chromium-containing refractories.
The production of chromium refractory materials can contain
from one to four general operations, depending on the type being
produced. These operations include raw materials processing,
forming, firing, and final product preparation. Production
processes for producing chromium-containing refractories include
the fusion-casting, casting, and pressing processes. The
processes differ most prominently in the forming and firing
operations. In the fusion-casting process, the processed raw
materials are fusion-melted together in an electric arc furnace
and cast into molds. In the casting and pressing processes, the
raw materials are mixed, cast into molds or pressed into bricks,
and then fired in a kiln.
A-21
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INDUSTRY GROUP - MINERAL PRODUCTS PROCESSING (CONTINUED)
Source Category: Clay Products Manufacturing
The Clay Products manufacturing source category includes any
facility engaged in manufacturing of clay products such as brick,
vitrified clay pipe, structural clay tile, and clay refractories.
The category includes, but is not limited to, the following
processes: grinding; screening and blending of the raw
materials; cutting or forming; and drying, curing, and firing.
Source Category: Lime Manufacturing
The Lime Manufacturing source category includes any facility
engaged in producing high calcium lime, dolomitic lime, and dead
burned dolomitie. Lime is the high temperature product of the
calcination of limestone. The basic processes in the production
of lime are: quarrying raw limestone, preparing limestone for
the kilns by crushing and sizing, calcining limestone, processing
the lime further by hydrating, and miscellaneous transfer,
storage, and handling operations. This category includes, but is
not limited to, the following process units: crushing and sizing
units, rotary kilns, vertical/shaft kilns, rotary hearth kilns,
fluidized bed kilns, and hydrators. Also included in the lime
kiln category are a facility's associated lime storage and
handling.
A-22
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INDUSTRY GROUP - MINERAL PRODUCTS PROCESSING (CONTINUED)
Source Category: Mineral Wool Production
The Mineral Wool Production source category includes any
facility engaged in producing mineral wool fiber from slag or
rock. Mineral wool is a material used mainly for thermal and
acoustical insulation. This category includes, but is not
limited to, the following process units: a cupola furnace for
melting the mineral charge; a blow chamber in which air and, in
some cases, a binder is drawn over the fibers forming them to a
screen, a curing oven to bond the fibers, and a cooling
compartment.
Source Category: Portland Cement Manufacturing
The Portland Cement Manufacturing source category includes
any facility engaged in manufacturing portland cement by either
the wet or dry process. The category includes, but is not
limited to, the following process units: kiln, clinker cooker,
raw mill system, finish mill system, raw mill dryer, raw material
storage, clinker storage, finished product storage, conveyor
transfer points, bagging, and bulk loading and unloading systems.
A-23
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INDUSTRY GROUP - MINERAL PRODUCTS PROCESSING (CONTINUED)
Source Category: Taconite Iron Ore Processing
The Taconite Iron Ore Processing source category includes
any facility engaged in separating and concentrating iron ore
from taconite, a low grade iron ore. The category includes, but
is not limited to, the following processes: liberation of the
iron ore by wet or dry crushing and grinding in gyratory
crushers, cone crushers, rod mills, and ball mills; concentration
of the iron ore by magnetic separation or flotation;
pelletization by wet tumbling with a balling drum or balling
disc, and induration using a vertical shaft furnace, straight
grate, circular grate, or grate/kiln.
Source Category: Wool Fiberglass Manufacturing
The Wool Fiberglass Manufacturing source category includes
any facility engaged in producing wool fiberglass from sand,
feldspar, sodium sulfate, anhydrous borax, boric acid, or any
other materials. In the wool fiberglass manufacturing process,
molten glass is formed into fibers that are bonded with an
organic resin to create a wool-like material that is used as
thermal or acoustical insulation. The category includes, but is
not limited to the following processes: glass melting furnace,
marble forming, refining unit, forming the fibers into a mat,
adding the binder, oven curing, and cooling.
A-24
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INDUSTRY GROUP - PETROLEUM AND NATURAL GAS PRODUCTION AND
REFINING
Source Category: Oil and Natural Gas Production
The Oil and Natural Gas Production source category includes
the processing and upgrading of crude oil prior to entering the
petroleum refining process and natural gas prior to entering the
transmission line. This source category excludes the aggregation
of oil or gas exploration or production wells (and equipment
associated with individual wells) and emissions from any pipeline
compressor or pump stations.
The production and processing phases for crude oil include,
but are not limited to, the following: removal of water, salts,
and solids, and removal of entrained gases. The production and
processing phases for natural gas include, but are not limited
to, the following: removal of water, removal of natural gas
liquids, and removal of sulphur and other contaminants.
The emissions sources associated with these phases include,
but are not limited to, equipment leaks, storage tanks, power
generating equipment, wastewater treatment, and process vents.
Processes that may have vents include, but are not limited to,
dehydration, sour gas processing (sweetening), and dewatering.
A-25
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INDUSTRY GROUP - PETROLEUM AND NATURAL GAS PRODUCTION AND
REFINING (CONTINUED)
Source Category: Petroleum Refineries - Catalytic Cracking
(Fluid and Other) Units, Catalytic Reforming
Units, and Sulfur Plant Units
The Petroleum Refineries - Catalytic Cracking (Fluid and
Other) Units, Catalytic Reforming Units, and Sulfur Plant Units
source category includes any facility engaged in producing
gasoline, naphthas, kerosene, jet fuels, distillate fuel oils,
residual fuel oils, lubricants, or other products from crude oil
or unfinished petroleum derivatives. This category includes the
following refinery process units: catalytic cracking (fluid and
other) units, catalytic reforming units, and sulfur plant units.
Source Category: Petroleum Refineries - Other Sources Not
Distinctly Listed
The Petroleum Refineries - Other Sources Not Distinctly
Listed source category includes any facility engaged in producing
gasoline, naphthas, kerosene, jet fuels, distillate fuel oils,
residual fuel oils, lubricants, or other products from crude oil
or unfinished petroleum derivatives. The category includes
refinery process units not listed in the Petroleum Refineries -
Catalytic Cracking (Fluid and Other) Units, Catalytic Reforming
Units, and Sulfur Plant Units Source Category. The refinery
process units in this source category include, but are not
limited to, thermal cracking, vacuum distillation, crude
distillation, hydroheating/hydrorefining, isomerization,
polymerization, lube oil processing, and hydrogen production.
A-26
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INDUSTRY GROUP - LIQUIDS DISTRIBUTION
Source Category: Gasoline Distribution (Stage 1)
The Gasoline Distribution (Stage 1) source category includes
the storage and transfer facilities associated with the movement
of gasoline. This category includes, but is not limited to, the
gasoline vapor emissions associated with the loading of transport
trucks or rail cars, storage tank emissions, and equipment leaks
from leaking pumps, valves, and connections at bulk terminals,
bulk plants, and pipeline facilities. Also included in this
category are the storage tank filling operations that occur at
public and private gasoline dispensing facilities (e.g., service
stations, convenience stores, etc.).
Source Category: Organic Liquids Distribution (Non-Gasoline)
The Organic Liquids Distribution (Non-Gasoline) source
category includes, but is not limited to, those activities
associated with the storage and distribution of organic liquids
other than gasoline, at sites which serve as distribution points
from which organic liquids may be obtained for further use and
processing.
A-27
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INDUSTRY GROUP - SURFACE COATING PROCESSES
Source Category: Aerospace Industries
The Aerospace Industries source category includes any
facility engaged in the surface coating of aerospace vehicles and
plastic, metal, and other composites used as components of
aerospace aircraft and parts. This category includes, but is not
limited to, the following: any machine (military or commercial)
designed to travel through the air, whether heavier or lighter
than air, including airplanes, balloons, dirigibles, helicopters,
and missiles.
Source Category: Auto and Light Duty Truck (Surface Coating)
The Auto and Light Duty Truck source category includes any
facility engaged in the surface coating of automobile and light
duty truck bodies or body parts for inclusion in new veihicles.
Automobile means a motor vehicle capable of carrying no more than
12 passengers. Light-duty truck means any motor vehicle rated at
3,850 kilograms gross vehicle weight or less, designed mainly to
transport property. Excluded from this source category are auto
customizers, body shops, and refinishers.
A-28
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INDUSTRY GROUP - SURFACE COATING PROCESSES (CONTINUED)
Source Category: Flat Wood Paneling (Surface Coating)
The Flat Wood Paneling source category includes facilities
that coat flat wood construction products made from wood
materials such as plywood, particleboard, hardboard, and
waferboard. Coating types may include fillers, sealers, groove
coats, stains, inks, primers, basecoats, and topcoats. Typical
coating processes may include roll coating and curtain coaters.
This source category does not include facilities that apply
preservatives to wood products or facilities that coat assembled
wood furniture.
Source Category: Large Appliance (Surface Coating)
The Large Appliance source category includes any facility
engaged in the surface coating of any large appliance part or
product. The category includes, but is not limited to, coating
of the following large, metal appliance parts or products:
ranges, conventional ovens, microwave ovens, refrigerators,
freezers, washers, dryers, dishwashers, water heaters or trash
compactors manufactured for household, commercial, or
recreational use.
A-29
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INDUSTRY GROUP - SURFACE COATING PROCESSES (CONTINUED)
Source Category: Magnetic Tapes (Surface Coating)
The Magnetic Tapes source category includes any facility
engaged in the surface coating of magnetic tapes. The category
includes, but is not limited to, the following magnetic tape
products: audio and video recording tape, computer tape, the
magnetic stripes on media involved in credit cards and toll
tickets, bank transfer ribbons, instrumentation tape, and
dictation tape.
Source Category: Manufacture of Paints, Coatings, and Adhesives
The Manufacture of Paints, Coatings, and Adhesives source
category includes any facility engaged in their manufacture
without regard to the particular end-uses or consumers of such
products. The manufacturing of these products may occur in any
combination at any facility.
Source Category: Metal Can (Surface Coating)
The Metal Can source category includes any facility engaged
in the surface coating of two-piece or three-piece metal cans or
can parts. A two-piece can consists of a body manufactured and
formed from a single piece of metal and a separate top end. A
three-piece can consists of a cylindrical body formed from a
sheet of metal and separate top and bottom ends.
Source Category: Metal Coil (Surface Coating)
The Metal Coil source category includes any facility engaged
in the surface coating of metal coil. Metal coil is defined as
any continuous metal strip (with a thickness of 0.15 mm or more)
that is packaged in a roll or coil.
A-30
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INDUSTRY GROUP - SURFACE COATING PROCESSES (CONTINUED)
Source Category: Metal Furniture (Surface Coating)
The Metal Furniture source category includes any facility
engaged in the surface coating and manufacture of metal furniture
parts or products. Such products may include chairs, tables,
cabinets and bookcases.
Source Category: Miscellaneous Metal Parts and Products
(Surface Coating)
The Miscellaneous Metal Parts and Products source category
includes any facility engaged in the surface coating of
miscellaneous metal parts and products such as: magnet wire;
medium/heavy duty trucks; large farm machinery (tractors,
harvesting, fertilizing, and planting machines, combines, etc.);
small farm machinery (lawn and garden tractors, lawn mowers,
rototillers, etc.); small appliances (fans, mixers, blenders,
crock pots, dehumidifiers, vacuum cleaners, etc.); commercial
machinery (computer and auxiliary equipment, typewriters,
calculators, vending machines, etc.); industrial machinery
(pumps, compressors, conveyor components, fans, blowers,
transformers, etc.); railroad transportation; and fabricated
metal products (metal covered doors, frames, etc.). The source
category does not include the surface coating of metal parts
covered under other distinct source categories.
A-31
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INDUSTRY GROUP - SURFACE COATING PROCESSES (CONTINUED)
Source Category: Paper and Other Webs (Surface Coating)
The Paper and Other Webs source category includes any
facility engaged in the coating of paper, plastic film, metallic
foil, and other web surfaces. The category may include, but is
not limited to, decorative coatings on gift wraps or packaging.
This category does not include paper or other web printing
operations covered under the source category of
Printing/Publishing.
Source Category: Plastic Parts and Products (Surface Coating)
The Plastic Parts and Products source category includes any
facility engaged in the surface coating of plastic parts and
products, including panels, housings, bases, covers, and other
components formed of synthetic polymers. The category includes,
but is not limited to, the surface coating of the following
plastic parts and products: business machines (typewriters,
computers, calculators, telephones, telegraph equipment,
photocopy machines, etc.); entertainment equipment (radios,
recorders, televisions, etc.); automotive, truck and other
transportation parts (fascia, bumpers, dashboards, doors, etc.);
and miscellaneous plastic parts (gas pumps, toys, doors, window
frames, signs, etc.).
A-32
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INDUSTRY GROUP - SURFACE COATING PROCESSES (CONTINUED)
Source Category: Printing, Coating, and Dyeing of Fabrics
The Printing, Coating, and Dyeing of Fabrics includes any
facility engaged in those operations. In fabric printing, a
decorative pattern or design is applied to fabric by methods such
as roller, flat screen, or rotary screen. Fabric coating is an
operation that imparts to a textile substrate additional
properties such as strength, stability, water or acid repellency,
or other specific characteristics of appearance. Fabric dyeing
is the process in which color is added to a substrate. This
category includes, but is not limited to, coating of industrial
and electrical tapes, tire cord, utility meter seals, imitation
leathers, tarpaulins, shoe material, and upholstery fabrics.
Source Category: Printing/Publishing (Surface Coating)
The Printing/Publishing source category includes the
application of inks utilizing a graphics arts operation to any
substrate including, but not limited to, paper, plastic, metal
foil, wood, vinyl, metal, and glass. This category does not
include the printing of fabric. The source category includes
facilities which use lithography, rotogravure, and other methods
to print products such as magazines, newspaper supplements,
packaging, and wallpaper.
A-33
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INDUSTRY GROUP - SURFACE COATING PROCESSES (CONTINUED)
Source Category: Shipbuilding and Ship Repair (Surface
Coating)
The Shipbuilding and Ship Repair source category is the
surface coating of ships and ship assemblies in public and
private shipyards.
Source Category: Wood Furniture (Surface Coating)
The Wood Furniture source category includes any facility
engaged in the surface coating and manufacture of objects made of
solid wood, wood composition, or objects made of simulated wood
material used in combination with solid wood or wood composites.
This category includes, but is not limited to, facilities that
glue and coat the following types of objects: kitchen and bath
cabinets; household furniture; upholstered, household furniture;
cabinets or cases (televisions, radios, phonographs, and sewing
machines); other household furniture; office furniture; public
building and related furniture; office and store fixtures;
partitions; shelving; and lockers.
A-34
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INDUSTRY GROUP - WASTE TREATMENT AND DISPOSAL
Source Category: Hazardous Waste Incineration
The Hazardous Waste Incineration source category includes
the incineration of hazardous waste which is described as, but is
not limited to, a solid waste, or combination of solid wastes
which, because of its quantity, concentration, or physical,
chemical or infectious characteristics may (1) cause, or
significantly contribute to an increase in mortality or an
increase in serious irreversible, or incapacitating reversible,
illness; or (2) pose a substantial present or potential hazard to
human health or the environment when improperly treated, stored,
transported, or disposed of, or otherwise managed. An
incinerator is any furnace, or other device, used in the process
of burning waste for the primary purpose of reducing the volume
of the waste by removing combustible matter.
A-35
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INDUSTRY GROUP - WASTE TREATMENT AND DISPOSAL (CONTINUED)
Source Category: Municipal Landfills
The Municipal Landfills source category is described as an
entire disposal facility in a contiguous geographical space where
household waste is placed in or on land. A municipal landfill
may also receive commercial waste, sludges, and industrial waste.
Household waste means any solid waste (including, but not limited
to, garbage, trash, and sanitary waste in septic tanks) derived
from households (including, but not limited to, single and
multiple residences, hotels and motels, bunkhouses, ranger
stations, crew quarters, campgrounds, picnic grounds, and day-use
recreation areas). Commercial waste includes, but is not limited
to, solid waste generated by stores, offices, restaurants,
warehouses, and other non-manufacturing activities, excluding
residential and industrial wastes. Sludge includes, but is not
limited to, any solid, semi-solid, or liquid waste generated from
a municipal, commercial, or industrial wastewater treatment
plant, water supply treatment plant, or air pollution control
facility exclusive of the treated effluent from a wastewater
treatment plant. Industrial solid waste means solid waste
generated by manufacturing or industrial processes, that is not a
hazardous waste regulated under subtitle C of the Resource
Conservation and Recovery Act. Such waste may include, but is
not limited to, waste from the following manufacturing processes:
electric power generation; fertilizer/agricultural chemicals;
food and related products/by-products; inorganic chemicals; iron
and steel manufacturing; leather and leather products; nonferrous
metals manufacturing/foundries; organic chemicals; plastics and
resins manufacturing; pulp and paper industry; rubber and
miscellaneous plastic products; stone, glass, clay, and concrete
products; textile manufacturing; transportation equipment; and
A-36
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INDUSTRY GROUP - WASTE TREATMENT AND DISPOSAL (CONTINUED)
Source Category: Municipal Landfills (Continued)
water treatment. This term does not include mining waste or oil
and gas waste. Portions of an MSW landfill may be separated by
access roads. An MSW landfill may be publicly or privately
owned.
Source Category: Publicly Owned Treatment Works (POTW) Emissions
This source category includes emissions from wastewaters
which are treated at a POTW. These wastewaters are produced by
industrial, commercial, and domestic sources. Emissions from
these wastewaters can occur within the collection system (sewers)
as well as during treatment at the POTW. Control options
include, but are not limited to, reduction of HAP's at the source
before they enter the collection system, add-on emission controls
on the collection system and at the POTW, and/or treatment
process modifications/substitutions.
A-37
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INDUSTRY GROUP - WASTE TREATMENT AND DISPOSAL (CONTINUED)
Source Category: Sewage Sludge Incineration
The Sewage Sludge Incineration source category includes, but
is not limited to, facilities that combust wastes containing more
than 10 percent sewage sludge on a dry basis. An incinerator is
described as any furnace or other device used in the process of
burning waste for the primary purpose of reducing the volume of
the waste by removing combustible matter. Types of sewage sludge
incinerators include, but are not limited to, multiple hearth,
fluidized bed, and electric sludge incinerators.
Source Category: Site Remediation
The Site Remediation source category includes the cleanup of
sites that possess contaminated media. Sites undergoing
remediation of contaminated media include, but are not limited
to, National Priorities List Sites, Corrective Action Sites, and
underground storage tank sites. Units requiring cleanup can
include hazardous waste dumps, industrial surface impoundments,
leaking tanks, and municipal, industrial, and combined landfills.
Site remediation includes, but is not limited to, the following
activities: contaminated soils cleaning; soil vapor extraction
(SVE); groundwater cleanup; oil recovery from below ground;
surface flow control; waste material removal from the site;
treatment of waste material after removal; and cleansing of water
mains, sewers, wetlands, and water bodies that have been
contaminated by wastes. Site remediation does not include the
installation of controls to municipal solid waste landfills to
comply with the New Source Performance Standards (NSPS) or Clean
Air Act (CAA), Section III(d) emission guidelines.
A-38
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INDUSTRY GROUP - WASTE TREATMENT AND DISPOSAL (CONTINUED)
Source Category: Solid Waste Treatment, Storage, and Disposal
Facilities (TSDF)
The Solid Waste Treatment, Storage, and Disposal Facilities
(TSDF) source category includes commercial facilities that treat,
store, or dispose of any solid waste received from off-site, as
well as commercial facilities that recycle, recover, and re-
refine wastes received from off-site. Treatment is described as
any method, technique, or process designed to change the
physical, chemical, or biological character of the waste.
Storage means the holding of waste for a temporary period, at the
end of which the waste is treated, disposed of, or stored
elsewhere. Disposal is defined as the discharge, deposit,
injection, dumping, spilling, leaking, or placing of any solid
waste into or on any land or water so that such solid waste, or
constituent thereof, may enter the environment or be emitted into
the air or discharged into any waters, including ground waters.
Recovery is defined as the removal or recapture of a useable
product or products from waste. Recycling or re-refining is
defined as the processing of a waste either to regenerate or to
recover a useable product.
A-39
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INDUSTRY GROUP - AGRICULTURAL CHEMICALS PRODUCTION
Source Category: 2,4-D Salts and Esters Production
The 2,4-D Salts and Esters Production source category
includes any facility engaged in producing the phenoxy herbicide
2,4-D (2,4-dichlorophenoxyacetic acid) in both salt and ester
forms. Production includes any reaction processes of
2,4-dichlorophenol and chloroacetic acid in aqueous sodium
hydroxide. Representative chemicals in this category are the
sodium salt (60 - 85 percent acid), amine salt (10 - 60 percent
acid), and ester (10 - 45 percent acid) forms of 2,4-D. The
category also includes, but is not limited to, chlorination and
esterification processes.
Source Category: 4-Chloro-2-Methylphenoxyacetic Acid Production
The 4-Chloro-2-Methylphenoxyacetic Acid Production source
category includes any facility engaged in producing the herbicide
4-chloro-2-methylphenoxyacetic acid. The category includes, but
is not limited to, vapor phase methylation processes and
production process units.
Source Category: 4,6-Dinitro-o-cresol Production
The 4,6-Dinitro-o-cresol Production source category includes
any facility engaged in producing the pesticide
4,6-Dinitro-o-cresol (4,6-Dinitro-2-methylphenol). The category
includes, but is not limited to, vapor phase methylation
processes and associated production process units.
A-40
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INDUSTRY GROUP - AGRICULTURAL CHEMICALS PRODUCTION (CONTINUED)
Source Category: Captafol Production
The Captafol Production source category includes any
facility engaged in producing the fungicide Captafol
[cis-N(1,1,2,2-tetrachloroethyl)-thio]-4-cyclohexene-l,2-
dicarboximide). The category includes any production process
units that store, react, or otherwise process 1,3-butadiene or
other HAP in the production of captafol.
Source Category: Captan Production
The Captan production source category includes any facility
engaged in the production of the fungicide, Captan. The
production process typically includes, but is not limited to, the
reaction of tetrahydrophthalimide and perchloromethyl mercaptan
with caustic.
Source Category: Chloroneb Production
The Chloroneb production source category includes any
facility engaged in producing the systemic fungicide Chloroneb
(l,4-dichloro-2,5-dimethoxybenzene). The category includes, but
is not limited to, the processes of hydroperoxidation, akylation,
oxidation, reduction, and hydrogenation as well as associated
equipment.
A-41
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INDUSTRY GROUP - AGRICULTURAL CHEMICALS PRODUCTION (CONTINUED)
Source Category: Chlorothalonil Production
The Chlorothalonil Production source category includes any
facility engaged in producing the agricultural fungicide,
bactericide and nematocide Chlorothalonil (Daconil). The
category includes any process units utilized to dissolve
tetrachlorophthalic acid chloride in an organic solvent,
typically carbon tetrachloride, with the subsequent addition of
ammonia.
Source Category: Dacthal Production
The Dacthal™ Production source category includes any
facility engaged in producing the pre-emergent herbicide
Dacthal™, also known as DCPA, DAC, and dimethyl ester
2,3,5,6-tetrachloroterephthalic acid. The category includes, but
is not limited to, chlorination processes and the following
production process units: photochlorination reactors, thermal
chlorination reactors and condensers.
Source Category: Sodium Pentachlorophenate Production
The Sodium Pentachlorophenate Production source category
includes any facility engaged in producing the fungicide,
herbicide, and slimicide sodium pentachlorophenate. The category
includes, but is not limited to, chlorination and hydrolization
processes.
A-42
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INDUSTRY GROUP - AGRICULTURAL CHEMICALS PRODUCTION (CONTINUED)
Source Category: Tordon Acid Production
The Tordon Acid Production source category includes any
TM
facility engaged in producing the synthetic herbicide Tordon
acid (4-amino-3,5,6-trichloropicolinic acid, picloram). The
category includes, but is not limited to, chlorination processes
TM
utilized in Tordon acid production.
A-43
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INDUSTRY GROUP - FIBERS PRODUCTION PROCESSES
Source Category: Acrylic Fibers/Modacrylic Fibers Production
The Acrylic Fibers/Modacrylic Fibers Production source
category includes any facility engaged in manufacturing fibers in
which the fiber-forming substance is any long-chain, synthetic
polymer composed of at least 85 percent, by weight, of
acrylonitrile units. The category includes polymerization
reactions, wet solvent spinning, dry solvent spinning, solvent
recovery, washing, filtration, stretching, cutting (into staple),
crimping, twisting, baling, drying, and packaging processes.
Source Category: Rayon Production
The Rayon Production source category includes any facility
engaged in manufacturing fibers composed of regenerated cellulose
as well as manufactured fibers composed of regenerated cellulose
in which substituents have replaced not more than 15 percent of
the hydrogens of the hydroxyl groups. The source category
includes production of regular (conventional) rayon, modified
high tenacity rayon, high-wet-modulus rayon, and polyinosic rayon.
The category also includes polymerization reactions, washing,
stretching, cutting (into staple), crimping, twisting, drying and
packaging processes. The category includes, but is not limited
to the following production process units: mixers, filters,
reactors, finishing baths, polymer dryers, pelletizers,
stretching, cutting, crimping and twisting units, packaging and
transport systems.
A-44
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INDUSTRY GROUP - FIBERS PRODUCTION PROCESSES (CONTINUED)
Source Category: Spandex Production
The Spandex Production source category includes any facility
engaged in manufacturing fiber in which the fiber forming
substance is a long-chain, synthetic polymer comprised of at
least 85 percent of a segmented polyurethane. The category
includes polymerization reactions, dry solvent spinning, solvent
recovery washing, stretching, cutting (into staple), crimping,
twisting, drying and packaging processes. The category includes,
but is not limited to, the following production process units:
mixers, filter, reactors, dry spinning cabinets, solvent recovery
systems, finishing baths, polymer dryers, pelletizers,
stretching, cutting, crimping, twisting, and baling units,
packaging and transport systems.
A-45
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INDUSTRY GROUP - FOOD AND AGRICULTURE PROCESSES
Source Category: Baker's Yeast Manufacturing
The Baker's Yeast Manufacturing source category includes any
facility engaged in manufacturing baker's yeast by fermentation
(both active dry yeast and compressed yeast). The category
includes, but is not limited to, the following manufacturing
process units: fermentation vessel, and drying and packaging
system.
Source Category: Cellulose Food Casing Manufacturing
The Cellulose Food Casing Manufacturing source category
includes any facility engaged in manufacturing cellulose food
casing. The category includes any cellulose tubular production
used in stuffing and packaging of hotdogs, sausages, poultry, and
other meat products. The category includes, but is not limited
to viscose, polymerization, filtration, aeration, drying,
shredding, shirring and packaging processes. The category also
includes the following production process units: viscose spin
tank, viscose blender, vissolver, shredders, filters, deareators,
slurry units, dryers, and packaging systems.
A-46
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INDUSTRY GROUP - FOOD AND AGRICULTURE PROCESSES (CONTINUED)
Source Category: Vegetable Oil Production
The Vegetable Oil Production source category includes any
facility engaged in producing vegetable oils, which include, but
are not limited to soybean, corn, cottonseed, safflower, and
peanut oil. The category includes seed preparation, oil
extraction, oil refining, solvent extraction, bleaching,
hydrogeneration, and deodorization processes. Emissions of HAP's
have been associated with the solvent extraction processes that
often use hexane as the solvent. Residual HAP emissions can also
occur in the areas of the dryer, cooler, conveyor, etc. The
category includes, but is not limited to, the following
production process units: extractor, desolventizer-toaster,
dryer, solvent-water separator, cooler, pneumatic conveyor and
condensers.
A-47
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INDUSTRY GROUP - PHARMACEUTICAL PRODUCTION PROCESSES
Source Category: Pharmaceuticals Production
The Pharmaceutical Production source category includes any
facility engaged in manufacturing, fabricating or processing
Pharmaceuticals for either human or veterinary uses. The
category includes both bulk Pharmaceuticals (active ingredients)
and final pharmaceutical products. The main processes; and
operations used in pharmaceutical manufacture are chemical
synthesis, fermentation, biological extraction, fractionation,
botanical extraction, product coating, formulation, and
packaging. Processes using HAP reactants, producing FLAP'S (if
any) or using process aids that are HAP's are those that will be
subject to MACT standards. Example production activities are:
• Production of blood and blood derivatives, vaccines,
antitoxins, diagnostics, and other biological for human
or veterinary use.
• Production of synthetic organic and inorganic medicinal
chemicals, as well as botanicals produced and shipped
in bulk.
• Production of pharmaceutical preparations such as
ampuls, tablets, capsules, vials, ointments, medicinal
powders, solutions, and suspensions for human or
veterinary use.
• Production of cosmetic preparations which function
primarily as skin treatments.
• Production of products with multiple end uses, where at
least one use is as a component of a pharmaceutical
preparation (i.e., fillers, binders and capsules).
A-48
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Source Category: Pharmaceuticals Production (Continued)
• Pharmaceutical research which includes biological,
microbiological, and chemical research, product
development, clinical and pilot plant activities.
A-49
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION
Source Category: Acetal Resins Production
The Acetal Resin Production source category includes any
facility which manufactures homopolymers and/or copolymers of
alternating oxymethylene units. Acetal resins are also known as
polyoxymethylenes, polyacetals, and aldehyde resins. They are
generally produced by polymerizing formaldehyde and the CH2
functional group and are characterized by repeating CH2O
(oxymethylene) units in the polymer backbone.
Source Category: Acrylonitrile-Butadiene-Styrene Production
The Acrylonitrile-Butadiene-Styrene (ABS) Production source
category includes any facility which manufactures styrenic
terpolymers consisting primarily of acrylonitrile, 1,3-butadiene,
and styrene monomer units. Acrylonitrile-butadiene-styrene is
usually composed of a styrene-acrylonitrile copolymer continuous
phase with dispersed butadiene derived rubber and can be
manufactured by emulsion, continuous mass (bulk), or suspension
processes or a combination of more than one process.
Source Category: Alkyd Resins Production
The Alkyd Resins Production source category includes any
facility which polymerizes a dihydric or polyhydric alcohol and a
polybasic acid. Alkyd resins are conventionally produced by
condensation polymerization, although other reaction processes
may be used.
A-50
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Amino Resins Production
The Amino Resins Production source category includes any
facility engaged in the manufacturing of the amino resin, urea-
formaldehyde; the amino resin, melamine-formaldehyde; or any
other resin in which formaldehyde is a portion. The category
includes, but is not limited to, formaldehyde resins produced for
building and construction material, bonding adhesives, decorative
laminates, electrical moldings, flexible foams, coatings, textile
treatments, paper processing, and plastics. The category also
includes, but is not limited to, the following production process
units: reactors, distillation units, and condensation units.
The production process includes operation such as
dehydrogenation, oxidation, condensation, and polymerization
processes.
Source Category: Boat Manufacturing
The Boat Manufacturing source category includes any facility
which manufactures aquatic vessels using synthetic materials as
the primary component although other materials (i.e., wood,
metals, glass) may be used to provide structural reinforcement.
The typical synthetic material used to fabricate the body of
components of the vessel is styrene. This category includes, but
is not limited to, the following production areas: molding
material application, and mold preparation.
A-51
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Butadiene-Furfural Cotrimer (R-ll) Production
The Butadiene-Furfural Cotrimer (R-ll) Production source
category includes any facility engaged in the production of R-ll.
R-ll is usually used as an insect repellant and as a delousing
agent for cows in the dairy industry. This source category
includes, but is not limited to, the production processes in
which butadiene reacts with an excess furfural in a liquid phase
reactor.
Source Category: Butyl Rubber Production
The Butyl Rubber Production source category includes any
facility which manufactures copolymers of isobutylene and
isoprene. A typical composition of butyl rubber is approximately
97 percent isobutylene and three percent isoprene. Modified,
derivative, and halogenated copolymers and lattices are also
included in this source category. Butyl rubber is typically made
by a precipitation (slurry) polymerization process in which
isobutylene and a minor amount of isoprene are copolymerized in
methyl chloride diluent. Halogenated butyl rubbers are produced
commercially by dissolving butyl rubber in hydrocarbon solvent
and contacting the solution with gaseous or liquid elemental
halogens such as chlorine or bromine.
A-52
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Carboxymethylcellulose Production
The Carboxymethylcellulose (CMC) Production source category
includes any facility which manufactures a type of cellulose
ether polymer in which CH2OOH (carboxymethyl) groups are
substituted on the glucose units of the cellulose chain through
an ether linkage. CMC is commonly produced by reacting
monochloroacetic acid, ether acid of sodium salt, and alkali
cellulose although other methods may be used.
Source Category: Cellophane Production
The Cellophane Production source category includes, but is
not limited to, any facility which manufactures such film
produced from wood pulp by the viscose process. This process
includes the purifying of cotton and wood cellulose with carbon
disulfide, though other methods may be used. Production of
coated and noncoated films are included in this category.
Source Category: Cellulose Ethers Production
The Cellulose Ethers Production source category includes any
facility which manufactures polymers, based on cellulose, which
are comprised of linear chains of (beta)-anhydroglucose rings.
The manufacture of cellulose ethers typically involves the
treatment of alkalai cellulose with ethyl chloride and ethylene
oxide.
A-53
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Epichlorohydrin Elastomers Production
The Epichlorohydrin Elastomers Production source category
includes any facility which polymerizes or copolymerizes
epichlorohydrin (ECH) to form elastomers. The main products of
this source category are polyepichlorohydrin, epi-ethylene oxide
(EO) copolymer, epi-allyl glycidyl ether (AGE) copolymer, and
epi-EO-AGE terpolymer.
Source Category: Epoxy Resins Production
The Epoxy Resins Production source category includes any
facility which manufactures basic liquid epoxy resins or advanced
epoxy resins. An epoxy resin contains an epoxide functional
group.
A-54
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Ethylene-Propylene Elastomers Production
The Ethylene-Propylene Elastomers Production source category
includes any facility engaged in the production of ethylene-
propylene copolymers or ethylene-propylene terpolymers.
Ethylene-propylene copolymers (EPM) result from the
polymerization of ethylene and propylene and contain a saturated
chain of the polymethylene type. Ethylene-propylene terpolymers
(EPDM) are produced in a similar manner as EPM except that a
moderate amount of the third monomer is added to the reaction
sequence. The third monomer can be either ethylidene norbornene,
1,4-hexadiene, or dicyclopentadience, the most commonly used
being ethylidene norbornene. Uses for these elastomers include,
but are not limited to, the following sectors: automotive
(radiator and heater hoses, weather stripping, door and window
seals, gaskets, and various body and chassis parts); industrial
(single-ply roofing membranes); construction plastics blending;
wire and cable (insulating and jacketing); additives; or other
miscellaneous uses. The production process includes, but is not
limited to, polymerization, recycle, recovery, and packaging
operations. The polymerization reaction occurs under solution or
slurry conditions.
A-55
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INDUSTRY GROUP - POLYMERS AMD RESINS PRODUCTION (CONTINUED)
Source Category: Flexible Polyurethane Foam Production
The Flexible Polyurethane Foam Production source category
includes any facility which manufactures foam made from a polymer
containing a plurality of carbamate linkages in the chain
backbone (polyurethane). Polyurethane is commonly made by
reacting a polyisocyanate with an organic polyhydroxyl material
in the presence of water. Application of blowing agents,
catalysts, surfactants, and fillers transform the polyurethane
into a foam with specialized properties.
Source Category: Hypalon Production
TM
The Hypalon Production source category includes any
facility engaged in the production of Hypalon™. Hypalon is
produced by reacting polyethylene with chloric and sulfur
dioxide, transforming the thermoplastic polyethylene into a
vulcanizable elastomer. The reaction is conducted in a solvent
TM
(carbon tetrachloride) reaction medium. Hypalon
(chlorosulfonated polyethylene) is a synthetic rubber produced
for uses such as wire and cable insulation, shoe soles and heels,
automotive components, and building products.
A-56
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Maleic Anhydride Copolymers Production
The Maleic Anhydride Copolymers Production source category
includes any facility engaged in the manufacturing of maleic
anhydride copolymers. The category includes, but is not limited
to the copolymerization of maleic anhydride with one or more of
the following monomers: ethylene, styrene, methyl vinyl ether
and vinyl chloride (i.e., ethylene-maleic anhydride, and styrene-
maleic anhydride). Some of the uses of maleic anhydride
copolymers are for oil-well drilling muds, stabilizers and
thickeners. The production processes include operations such as
step-growth and chain-growth polymerization.
Source Category: Methylcellulose Production
The Methylcellulose Production source category includes any
facility engaged in the production of methylcellulose, a water-
soluble resin. The category includes, but is not limited to, any
facility that converts cellulose to alkali cellulose which is
then reacted with methyl chloride, dimethyl sulfate, or methanol
and dehydrating agents. Methylcellulose may be used as a
protective colloid; as a gum and thickener in Pharmaceuticals,
cosmetics, adhesives, paint, concrete, and gypsum; for film and
sheeting; for leather tanning, as a dispersing and sizing agent;
as a food additive; and as a binder in ceramic glazes. The
Methylcellulose Production processes include operations such as
polymerization and etherification.
A-57
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Methyl Methacrylate-Acrylonitrile-
Butadiene-Styrene Production
The Methyl Methacrylate-Acrylonitrile-Butadiene-Styrene
(MABS) Production source category includes any facility which
manufactures styrenic polymers containing methyl methacrylate,
acrylonitrile, 1,3-butadiene, and styrene. The MABS copolymers
are prepared by dissolving or dispersing polybutadiene rubber in
a mixture of methyl methacrylate-aerylonitrile-styrene and
butadiene monomer. The graft polymerization is carried out by a
bulk or a suspension process.
Source Category: Methyl Methacrylate-Butadiene-Styrene
Terpolymers Production
The Methyl Methacrylate-Butadiene-Styrene Terpolymers
Production source category includes any facility which
manufactures styrenic polymers containing methyl methacrylate,
1,3-butadiene, and styrene. Production of MBS terpolymers is
achieved using an emulsion process in which methyl methacrylate
and styrene are grafted on to a styrene-butadiene rubber.
Source Category: Neoprene Production
The Neoprene Production source category includes any
facility which polymerizes chloroprene (2-chloro-l,3-butadiene).
The free radical emulsion process is generally used to produce
neoprene, although other methods may be used.
A-58
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Nitrile Butadiene Rubber Production
The Nitrile Butadiene Rubber Production source category
includes any facility which manufactures copolymers of
unsaturated nitriles and dienes, usually acrylonitrile and 1,3-
butadiene. The emulsion, bulk, or solvent processes are
generally used to produce nitrile rubber, although other methods
may be used.
Source Category: Non-Nylon Polyamides Production
The Non-Nylon Polyamides Production source category includes
any facility engaged in manufacturing non-nylon polyamide
polymers. At least 85 percent of the recurring amide linkages in
non-nylon polyamides are aromatic in structure (aromatic
polyamides). The category includes, but is not limited to,
non-nylon polyamide polymers produced for use in flame resistant
clothing, dust-filter bags, tire cord, bullet-resistant
structures, electrical insulation, filtration, conveyor belts,
ironing board covers, carpets, upholstery, drapes, boat covers,
tents and parachutes. Non-Nylon Polyamide Production includes
operations such as direct amidation, polymerization, and
condensation.
A-59
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Nylon 6 Production
The Nylon 6 Production category includes any facility which
manufactures polyamides formed by the reaction of diamine and a
dibasic acid in which less than 85 percent by weight of the
repeating units are aliphatic, alicyclic or a mixture of aromatic
moieties. Nylon is a generic term for any long-chain synthetic,
polymeric amide in which recurring amide groups are integral to
the main polymer chain. Nylon 6 products may be in the forms of
fibers, plastics, or other forms. The hazardous air pollutant
emitted is caprolactam.
Source Category: Phenolic Resins Production
The Phenolic Resins Production source category includes any
facility which manufactures synthetic resin obtained by the
condensation polymerization of phenol and/or substituted phenols
with aldehydes such as formaldehyde, acetaldehyde, and furfural.
This source category includes, but is not limited to, phenol-
formaldehyde, phenol-furfural, and resorcinol-formaldehyde.
Source Category: Polybutadiene Rubber Production
The Polybutadiene Rubber Production source category includes
any facility which polymerizes 1,3-butadiene. Polybutadiene may
be produced by the solution or emulsion polymerization processes,
although other methods may be used.
A-60
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Polycarbonates Production
The Polycarbonates Production source category includes any
facility which manufactures a special class of polyester formed
from any dihydroxy compound and any carbonate diester or by ester
interchange. Polycarbonates may be produced by solution or
emulsion polymerization, although other methods may be used. A
typical method for the manufacture of polycarbonates includes the
reaction of bisphenol-A with phosgene in the presence of pyridine
to form a polycarbonate. Methylene chloride is used as a solvent
in this polymerization reaction.
Source Category: Polyester Resins Production
The Polyester Resins Production source category includes any
facility which manufactures homopolymers or copolymers formed
when a difunctional alcohol is reacted with a dibasic acid or
anhydride. Polyester resin is usually produced by condensation
polymerization, although other methods may be used. However,
only those processes emitting HAP's will be considered for the
application of standards.
A-61
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Polyethylene Terephthalate Production
The Polyethylene Terephthalate (PET) Production source
category includes any facility which manufactures a polyester
formed from ethylene glycol. Polyethylene terephthalatcs is
usually produced by the dimethyl terephthalate (DMT) process or
the terephthalic acid (TPA) process, although other methods may
be used.
Source Category: Polymerized Vinylidene Chloride Production
The Polymerized Vinylidene Chloride Production source
category includes any facility which manufactures a homopolymer
or copolymer using Vinylidene chloride as the principle monomer
unit. Polyvinylidene chloride may be produced by using the
solution, slurry, suspension, or emulsion polymerization process,
although other methods may be used.
Source Category: Polymethyl Methacrylate Resins Production
The Polymethyl Methacrylate Resins Production source
category includes any facility which manufactures homopolymers or
copolymers consisting of methyl methacrylate monomer units.
Other additions such as ultralight light absorbers, dyes,
pigments, etc., may also be included. Methods for polymerization
of methyl methacrylate include, but are not limited to, bulk,
solution, emulsion, and suspension processes.
A-62
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Polystyrene Production
The Polystyrene Production source category includes any
facility which manufactures homopolymers or copolymers consisting
of styrene units. Styrene may be copolymerized with elastomers
to form impact polystyrene or rubber-modified polystyrenes. The
styrene content of impact polystyrene (IPS) is approximately
88 to 97 percent, by weight. Polystyrene can be produced by bulk
(mass), solution, suspension, or emulsion polymerization.
Source Category: Polysulfide Rubber Production
The Polysulfide Rubber Production source category includes
any facility engaged in the production of polysulfide rubber, a
synthetic rubber. This rubber is resilient and has low
temperature flexibility. The polysulfide elastomers Thiokol FA™
TM
and Thiokol ST are compounded in standard rubber processing
equipment (i.e., rubber mills or sigmoid-bladed mixers). The
process steps involved in polysulfide rubber production include
the following: preparation of sodium sulfide from aqueous
caustic and aqueous sodium hydroxide sulfide in a polar solvent,
removal of water from this feedstock by disillation, production
of polymer from the sodium sulfide stream and p-dichlorobenzene
at elevated temperature in the polar solvent, polymer recovery,
washing to remove the sodium chloride produced as a by-product,
drying and packaging.
A-63
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Polyvinyl Acetate Emulsions Production
The Polyvinyl Acetate Emulsions Production source category
includes any facility which manufactures polymers of vinyl
acetate units dispersed in water. Polyvinyl acetate can be made
by bulk, solution, suspension, and emulsion polymerization
techniques.
Source Category: Polyvinyl Alcohol Production
The Polyvinyl Alcohol Production source category includes
any facility which manufactures polymers produced by replacing
the ester groups of polyvinyl acetate or other polyvinyl ester
with hydroxyl groups although other methods may be used.
Polyvinyl alcohol production usually involves alcoholysis in
methanol or ethanol using an acid catalyst.
Source Category: Polyvinyl Butyral Production
The Polyvinyl Butyral Production source category includes,
but is not limited to, any facility which manufactures polymers
produced by reacting polyvinyl alcohol with a butyraldehyde.
Polyvinyl butyral may be produced by condensation polymerization,
although other methods may be used.
Source Category: Polyvinyl Chloride and Copolymers Production
The Polyvinyl Chloride (PVC) and Copolymers Production
source category includes any facility which manufactures
polymerized vinyl chloride. Polyvinyl Chloride may be produced
by the suspension, mass emulsion/dispersion, and solution
processes, although other methods may be used.
A-64
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INDUSTRY GROUP - POLYMERS AND RESINS PRODUCTION (CONTINUED)
Source Category: Reinforced Plastic Composites Production
The Reinforced Plastic Composites Production source category
includes any facility engaged in the manufacturing of
homopolymers and/or copolymers which contain materials designed
to enhance the chemical, physical, and/or thermal properties of
the polymer. This category includes, but is not limited to,
processing techniques such as hard layup and spray layup of gel
coats that incorporate styrene.
Source Category: Styrene-Acrylonitrile Production
The Styrene-Acrylonitrile (SAN) Production source category
includes any facility which manufactures copolymers consisting
primarily of styrene and acrylonitrile monomer units. Styrene-
Acrylonitrile typically consists of approximately 70 percent
styrene and 30 percent acrylonitrile and can be made by emulsion,
solution, and continuous mass polymerization processes, although
other methods may be used.
Source Category: Styrene-Butadiene Rubber and Latex Production
The Styrene-Butadiene Rubber (SBR) and Latex Production
source category includes any facility which manufactures
copolymers consisting of styrene and butadiene monomer units.
Styrene-Butadiene Rubber and Latex may be produced by emulsion
and solution polymerization, although other methods may be used.
A-65
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INDUSTRY GROUP - PRODUCTION OF INORGANIC CHEMICALS
Source Category: Ammonium Sulfate Production - Caprolactam
By-Product Plants
The Ammonium Sulfate Production - Caprolactam By-Product
Plants source category includes the production of ammonium
sulfate as a by-product in the production of Caprolactam, which
is used as an intermediate for Nylon 6. The category includes,
but is not limited to, ammonium sulfate produced when sulfuric
acid is used to rearrange cyclohexanone oxime to Caprolactam
sulfate, which is then reacted with ammonia to yield ammonium
sulfate and Caprolactam.
Source Category: Antimony Oxides Manufacturing
The Antimony Oxides Manufacturing source category includes
any facility engaged in the production of antimony oxides,
typically white, odorless, crystalline powders, mainly used as a
synergistic flame retardant in plastics and textiles. The
category includes antimony oxides produced from sulfide ores
containing antimony or as a by-product of the treatment of
sulfide ores of base metals and silver. The production of
antimony oxides from sulfide ores containing antimony includes
operations such as roasting, smelting in a blast furnace, and
melting in a crucible or reverberatory furnace with a reducing
atmosphere.
A-66
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INDUSTRY GROUP - PRODUCTION OF INORGANIC CHEMICALS (CONTINUED)
Source Category: Chlorine Production
The Chlorine Production source category includes any
facility engaged in the production of chlorine. The category
includes, but is not limited to facilities producing chlorine by
the following production methods: diaphragm cell, mercury cell,
membrane cell, hybrid fuel cell, Downs cell, potash manufacture,
hydrochloric acid decomposition, nitrosyl chloride process,
nitric acid/salt process, Kel-Chlor process, and sodium
chloride/sulfuric acid process.
Source Category: Chromium Chemicals Manufacturing
The Chromium Chemicals Manufacturing source category
includes any facility engaged in the production of chromium-based
chemicals. The category includes, but is not limited to,
production of: sodium chromate, produced by roasting chromate
ore with soda ash or with soda ash and lime in a kiln; sodium
dichromate, produced by converting sodium chromate by treatment
with sulfuric acid; and secondary chromium chemicals derived from
sodium dichromate, such as potassium chromate and dichromate,
ammonium dichromate, chromic acid, basic chromic sulfate, chromic
oxide, and chrome pigments.
Source Category: Cyanuric Chloride Production
The Cyanuric Chloride Production source category includes
any facility engaged in the production of cyanuric chloride, a
crystalline compound used in chemical synthesis, dyestuffs,
herbicides, and optical brighteners. The category includes, but
is not limited to, production of cyanuric chloride by the
reaction of sodium cyanide with chlorine to produce cyanogen
chloride, which then trimerizes to yield cyanuric chloride.
A-67
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INDUSTRY GROUP - PRODUCTION OF INORGANIC CHEMICALS (CONTINUED)
Source Category: Fume Silica Production
The Fume Silica Production source category includes any
facility engaged in the production of fume silica. Fume silica
is a fine white powder used as a thickener, thixotropic, or
reinforcing agent in inks, resins, rubber, paints, and cosmetics.
The category includes the production of fume silica by the
combustion of silicon tetrachloride in hydrogen-oxygen furnaces.
Source Category: Hydrochloric Acid Production
The Hydrochloric Acid Production source category includes
any facility engaged in the production of hydrochloric acid. The
category includes, but is not limited to, production of
hydrochloric acid via any of the following methods:
(1) production of hydrochloric acid as a by-product in the
manufacture of organic chemicals; (2) direct reaction of salts
and sulfuric acid (Mannheim process); (3) reaction of a salt,
sulfur dioxide, oxygen, and water (Hargreaves process) ; or
(4) burning chlorine in the presence of hydrogen gas.
Source Category: Hydrogen Cyanide Production
The Hydrogen Cyanide Production source category includes any
facility engaged in the production of hydrogen cyanide. The
category includes, but is not limited to, production of hydrogen
cyanide using any of the following methods: reaction of methane
and ammonia over a platinum catalyst; reaction of methane and
ammonia over a platinum-rhodium catalyst; co-production with
acrylonitrile (via Sohio process); and pyrolysis of formamide.
A-68
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INDUSTRY GROUP - PRODUCTION OP INORGANIC CHEMICALS (CONTINUED)
Source Category: Hydrogen Fluoride Production
The Hydrogen Fluoride Production source category includes
any facility engaged in the production of hydrogen fluoride. The
category includes, but is not limited to, production of hydrogen
fluoride by reacting calcium fluoride with sulfuric acid.
Source Category: Phosphate Fertilizers Production
The Phosphate Fertilizers Production source category
includes any facility engaged in the production of phosphate-
based fertilizers including, but not limited to, plants with
bulk-blend processes, fluid-mix processes, or ammonia granulation
processes. Examples of phosphate fertilizers are: ammonium
phosphates, triple superphosphates, and diammonium phosphates.
Source Category: Phosphoric Acid Manufacturing
The Phosphoric Acid Manufacturing source category includes
any facility engaged in the production of phosphoric acid. The
category includes, but is not limited to, production of wet-
process phosphoric acid and superphosphoric acid.
Source Category: Quaternary Ammonium Compounds Production
The Quaternary Ammonium Compounds Production source category
includes any facility engaged in the production of quaternary
ammonium compounds, which are usually tetra-substituted ammonium
salts. Quaternary ammonium compounds are produced by the
reaction of a tertiary amine with an alkylating agent, usually an
alkyl ester; other methods can be used depending on the desired
product.
A-69
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INDUSTRY GROUP - PRODUCTION OP INORGANIC CHEMICALS (CONTINUED)
Source Category: Sodium Cyanide Production
The Sodium Cyanide Production source category includes any
facility engaged in the production of sodium cyanide, a white
crystalline solid commonly called white cyanide. The category
includes, but is not limited to, production of sodium cyanide via
the neutralization process, or so-called wet process, in which
hydrogen cyanide reacts with sodium hydroxide solution xasually in
a unit system that embodies evaporation of water and
crystallization of the product.
Source Category: Uranium Hexafluoride Production
The Uranium Hexafluoride Production source category includes
any facility engaged in the production of uranium hexafluoride, a
colorless, volatile crystal, usually used in the gaseous;
diffusion process for separating isotopes of uranium. The
category includes, but is not limited to, the following
production methods: (1) the direct fluorination of uranium
tetrafluoride; and (2) the conversion of triuranium octoxide
directly to uranium hexafluoride with hydrogen fluoride and
fluorine.
A-70
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INDUSTRY GROUP - PRODUCTION OF ORGANIC CHEMICALS
Source Category: Synthetic Organic Chemical Manufacturing
The Synthetic Organic Chemical Manufacturing source category
includes, but is not limited to, manufacturing processes that
produce one or more of the chemicals listed below and that either
(1) use an organic HAP as a reactant or (2) produce an organic
HAP as a product, co-product, by-product, or isolated
intermediate. A list of organic HAP's for this source category
is located in Table 3.1 of Section 3.0 of this document. The
five types of emission points to be considered in the development
of regulations are: equipment leaks, process vents, transfer
operations, storage tanks (raw material, intermediate, and final
product), and wastewater collection and treatment systems
associated with this source category.
Acenaphthene
Acetal
Acetaldehyde
Acetaldol
Acetamide
Acetanilide
Acetic acid
Acetic anhydride
Acetoacetanilide
Acetone
Acetone cyanohydrin
Acetonitrile
Acetophenone
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Adiponitrile
Alizarin
Alkyl anthraquinones
Allyl alcohol
Allyl chloride
Allyl cyanide
Aminophenol sulfonic acid
Aminophenol (p-)
Aniline
A-71
-------
Source Category: Synthetic Organic Chemical Manufacturing
(Continued)
Aniline hydrochloride
Anisidine (o-)
Anthracene
Anthraquinone
Azobenzene
Benzaldehyde
Benzene
Benzenedisulfonic acid
Benzenesulfonic acid
Benzil
Benzilic acid
Benzoic acid
Benzoin
Benzonitrile
Benzophenone
Benzotrichloride
Benzoyl chloride
Benzyl acetate
Benzyl alcohol
Benzyl benzoate
Benzyl chloride
Benzyl dichloride
Biphenyl
Bisphenol A
Bis(Chloromethyl)Ether
Bromobenz ene
Bromoform
Bromonaphthalene
Butadiene (1,3-)
Butanediol (1,4-)
Butyl acrylate (n-)
Butylbenzyl phthalate
Butylene glycol (1,3-)
Butyrolacetone
Caprolactam
Carbaryl
Carbazole
Carbon disulfide
Carbon tetrabromide
Carbon tetrachloride
Carbon tetrafluoride
Chloral
Chloroacetic acid
Chloroacetophenone (2-)
Chloroaniline (p-)
Chlorobenzene
Chlorodifluoroethane
Chlorodifluoromethane
A-72
-------
Source Category: Synthetic Organic Chemical Manufacturing
(Continued)
Chloroform
Ch1oronaphtha1ene
Chloronitrobenzene (m-)
Chloronitrobenzene (o-)
Chloronitrobenzene (p-)
Chlorophenol (m-)
Chlorophenol (o-)
Chlorophenol (p-)
Chloroprene
Chlorotoluene (m-)
Chlorotoluene (o-)
Chlorotoluene (p-)
Chlorotrifluoromethane
Chrysene
Cresol (m-)
Cresol (o-)
Cresol (p-)
Cresol/cresylic acid (mixed)
CrotonaIdehyde
Cumene
Cumene hydroperoxide
Cyanoacetic acid
Cyanoformamide
Cyclohexane
Cyclohexanol
Cyclohexanone
Cyclohexylamine
Cyclooctadiene (mixture)
Cyclooctadiene (1,5-)
Decahydronaphthalene
Diacetoxy-2-Butene (1,4-)
Diallyl phthalate
Diaminophenol hydrochloride
Dibromomethane
Dibutoxyethyl phthalate
Dichloroaniline (all isomers)
Dichlorobenzene (m-)
Dichlorobenzene (o-)
Dichlorobenzene (p-)
Dichlorobenzidine (3,3'-)
Dichlorodifluoromethane
Dichloroethane (1,2-)
Dichloroethyl ether
Dichloroethylene (1,2-)
Dichlorophenol (2,4-)
Dichloropropene (1,3-)
Dichlorotetrafluoroethane
Dichloro-1-butene (3,4-)
A-73
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Source Category: Synthetic Organic Chemical Manufacturing
(Continued)
Dichloro-2-butene (1,4-)
Diethanolamine
Diethyl phthalate
Diethyl sulfate
Diethylamine
Diethylaniline (2,6-)
Diethylene glycol
Diethylene glycol dibutyl ether
Diethylene glycol diethyl ether
Diethylene glycol dimethyl ether
Diethylene glycol monobutyl ether acetate
Diethylene glycol monobutyl ether
Diethylene glycol monoethyl ether acetate
Diethylene glycol monoethyl ether
Diethylene glycol monohexyl ether
Diethylene glycol monomethyl ether acetate
Diethylene glycol monomethyl ether
Diisodecyl phthalate
Diisooctyl phthalate
Dimethylbenzidine (3,3'-)
Dimethyl ether
Dimethyl formamide (N,N-)
Dimethylhydrazine (1,1-)
Dimethyl phthalate
Dimethyl sulfate
Dimethyl terephthalate
Dimethylamine
Dimethylaminoethanol (2-)
Dimethylaniline (N,N-)
Dinitrobenzenes
Dinitrophenol (2,4-)
Dinitrotoluene (2,4-)
Dioxane
Dioxolane
Diphenyl methane
Diphenyl oxide
Diphenyl thiourea
Diphenylamine
Dipropylene glycol
Di(2-methoxyethyl) phthalate
Di-o-tolyguanidine
Dodecylbenzene (all branched isomers)
Dodecylbenzene (n-)
Dodecylphenol (all branched isomers)
Dodecylaniline
Dodecylphenol
Epichlorohydrin
Ethane
A-74
-------
Source Category:
(Continued)
Synthetic Organic Chemical Manufacturing
Ethanolamines (all isomers)
Ethyl acrylate
Ethylbenzene
Ethyl chloride
Ethyl chloroacetate
Ethylamine
Ethylaniline (N-)
Ethylaniline (o-)
Ethylcellulose
Ethylcyanoacetate
Ethylene carbonate
Ethylene dibromide
Ethylene glycol
Ethylene glycol diacetate
Ethylene glycol dibutyl ether
Ethylene glycol diethyl ether
Ethylene glycol dimethyl ether
Ethylene glycol monoacetate
Ethylene glycol monobutyl ether acetate
Ethylene glycol monobutyl ether
Ethylene glycol monoethyl ether acetate
Ethylene glycol monoethyl ether
Ethylene glycol monohexyl ether
Ethylene glycol monomethyl ether acetate
Ethylene glycol monomethyl ether
Ethylene glycol monooctyl ether
Ethylene glycol monophenyl ether
Ethylene glycol monopropyl ether
Ethylene oxide
Ethylenediamine
Ethylenediamine tetracetic acid
Ethylhexyl acrylate (2-)
Fluoranthene
FormaIdehyde
Formamide
Formic acid
Fumaric acid
GlutaraIdehyde
GlyceraIdehyde
Glycerol
Glycerol dichlorohydrin
Glycine
Glycol ethers
Glyoxal
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Hexadiene (1,4-)
A-75
-------
Source Category: Synthetic Organic Chemical Manufacturing
(Continued)
Hexamethylene 1,6-diisocyanate
Hexamethylenetetramine
Hexane
Hexanetriol (1,2,6-)
Hydroqu inone
Hydroxyad ipaIdehyde
Iminodiethanol (2,2-)
Isobutyl acrylate
Isobutylene
Isophorone
Isophorone nitrile
Isophthalic acid
Isopropylphenol
Lead phthalate
Linear alkylbenzene
Maleic anhydride
Maleic hydrazide
Malic acid
Metanilic acid
Methacrylic acid
Methanol
Methionine
Methyl acetate
Methyl acrylate
Methyl bromide
Methyl chloride
Methyl ethyl ketone
Methyl formate
Methyl hydrazine
Methyl isobutyl carbinol
Methyl isobutyl ketone
Methyl isocyanate
Methyl mercaptan
Methyl methacrylate
Methyl phenyl carbinol
Methyl tert-butyl ether
Methylamine
Methylaniline (N-)
MethyIcyc1ohexane
Methylcyclohexanol
Methylcyclohexanone
Methylene chloride
Methylene dianiline (4,4-)
Methylene diphenyl diisocyanate
Methylionones (a-)
Methylpentynol
Methylstyrene (a-)
Naphthalene
A-76
-------
Source Category: Synthetic Organic Chemical Manufacturing
(Continued)
Naphthalene sulfonic acid (a-)
Naphthalene sulfonic acid (/?-)
Naphthol (a-)
Naphthol (/3-)
Naphtholsulfonic acid (1-)
Naphthylamine sulfonic acid (1,4-)
Naphthylamine sulfonic acid (2,1-)
Naphthylamine (1-)
Naphthylamine (2-)
Nitroaniline (m-)
Nitroaniline (o-)
Nitroanisole (o-)
Nitroanisole (p-)
Nitrobenzene
Nitronaphthalene (1-)
Nitrophenol (p-)
Nitrophenol (o-)
Nitropropane (2-)
Nitrotoluene
Nitrotoluene (o-)
Nitrotoluene (m-)
Nitrotoluene (p-)
Nitroxylene
Nonylbenzene (all branched isomers)
Nonylphenol
Octene-1
Octylphenol
Paraformaldehyde
Paraldehyde
Pentachlorophenol
Pentaerythritol
Peracetic acid
Perchloroethylene
Perchloromethyl mercaptan
Phenanthrene
Phenetidine (p-)
Phenol
Phenolphthalein
Phenolsulfonic acids (all isomers)
Phenylenediamine (p-)
Phloroglucinol
Phosgene
Phthalic acid
Phthalic anhydride
Phthalimide
Phthalonitrile
Picoline (0-)
Piperazine
A-77
-------
Source Category: Synthetic Organic Chemical Manufacturing
(Continued)
Polyethylene glycol
Polypropylene glycol
Propiolactone (/?-)
Propionaldehyde
Propionic acid
Propylene carbonate
Propylene dichloride
Propylene glycol
Propylene glycol monomethyl ether
Propylene oxide
Pyrene
Pyridine
p-tert-Butyl toluene
Quinone
Resorcinol
Salicylic acid
Sodium chloroacetate
Sodium Methoxide
Sodium phenate
Stilbene
Styrene
Succinic acid
Succinonitrile
Sulfanilic acid
Sulfolane
Tartaric Acid
Terephthalic acid
Tetrabromophthalic anhydride
Tetrachlorobenzene (1,2,4,5-)
Tetrachloroethane (1,1,2,2-)
Tetrachlorophthalic anhydride
Tetraethyl lead
Tetraethylene glycol
Tetraethylenepentamine
Tetrahydronapthalene
Tetrahydrophthalic anhydride
Tetramethylenediamine
Tetramethylethylenediamine
Tetramethyllead
Thiocarbanilide
Toluene
Toluene 2,4-diamine
Toluene 2,4-diisocyanate
Toluene diisocyanates (mixture)
Toluene sulfonic acids
Toluenesulfonyl chloride
Toluidine (o-)
Trichloroaniline (2,4,6-)
A-78
-------
Source Category: Synthetic Organic Chemical Manufacturing
(Continued)
Trichlorobenzene (1,2,3-)
Trichlorobenzene (1,2,4-)
Trichloroethane (1,1,1-)
Trichloroethane (1,1,2-)
Trichloroethylene
Trichlorofluoromethane
Trichlorophenol (2,4,5-)
Trichlorotrifluoroethane [(1,2,2-) (1,1,2-)]
Triethanolamine
Tr i ethy1amine
Triethylene glycol
Triethylene glycol dimethyl ether
Triethylene glycol monoethyl ether
Triethylene glycol monomethyl ether
Trimethylamine
Tr imethy1cyclohexano1
Trimethylcyclohexanone
TrimethyIcyclohexylamine
Trimethylolpropane
Tr imethyIpentane (2,2,4-)
Tripropylene glycol
Vinyl acetate
Vinyl chloride
Vinyl toluene
Vinylcyclohexene (4-)
Vinylidene chloride
Vinyl(N)-pyrrolidone(2-)
Xanthates
Xylene Sulfonic Acid
Xylene (m-)
Xylene (mixtures)
Xylene (o-)
Xylene (p-)
Xylenol
A-79
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES
Source Category: Aerosol Can-Filling Facilities
The Aerosol Can-Filling facilities source category includes
any facility engaged in the filling of aerosol cans. The aerosol
can-filling process includes mixing of the product ingredients,
dispensing of the product into aerosol cans, insertion of the
valve stem and valve, propellant charging, and sealing the
product in the can. The category includes facilities which add
hazardous air pollutants (HAP's), primarily chlorinated solvents
(e.g., methylene chloride), to the product in the mixing tank and
facilities which add the HAP's directly to the aerosol can.
Types of aerosol products include, but are not limited to, spray
paints, insecticides, lubricants, cleaners, adhesives, and paint
strippers.
Source Category: Benzyltrimethylammonium Chloride Production
The Benzyltrimethylammonium Chloride production ceitegory is
defined to include any facility which manufactures this;
quaternary ammonium salt. Benzyltrimethylammonium chloride can
be produced from benzyl chloride and trimethylamine, although
other methods may be used.
A-80
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Butadiene Dimers Production
The Butadiene Dimers Production source category includes any
facility engaged in the production of butadiene dimers.
Butadiene dimers include, but are not limited to,
tetrahydrobenzaIdehyde (THBA), a liquid used to improve the water
resistance of textiles. TetrahydrobenzaIdehyde is produced by
the reaction of acrolein and cyclohexane either at high
temperature, or in the presence of an aluminum-titanium catalyst,
although other methods can be used. The category includes the
following production units: feed pots, reactors, and recovery
stills.
Source Category: Carbonyl Sulfide Production
The Carbonyl Sulfide Production source category includes any
facility engaged in the production of carbonyl sulfide, a
colorless, odorless gas, used in the production of certain
thiocarbamate herbicides. This category includes, but is not
limited to, carbonyl sulfide formed by high temperature reactions
with chemical donors of oxygen and sulfur or carbonyl sulfide
resulting as a by-product in the production of carbon disulfide.
A-81
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Chelating Agents Production
The Chelating Agents Production source category includes any
facility engaged in the production of chelating agents, which are
compounds usually used in cleansing operations. The category
includes, but is not limited to, the following chelating agents:
phosphoric acids, polyphosphates, aminocarboxylic acids, 1,3-
diketones, hydrocarboxylic acids, polyamines, and amino acids.
Source Category: Chlorinated Paraffins Production
The Chlorinated Paraffins Production source category
includes any facility engaged in the production of dry
chlorinated paraffins, which are mainly straight-chain, saturated
hydrocarbons. The category includes, but is not limited to,
production of chlorinated paraffins by passing gaseous chlorine
into a paraffin hydrocarbon or by chlorination by using solvents,
such as carbon tetrachloride, under reflux.
Source Category: Chromic Acid Anodizing
The Chromic Acid Anodizing source category includes any
facility which uses chromic acid to form an oxide layer on
aluminum to provide corrosion resistance. Chromic acid anodizing
is used primarily on aircraft parts and architectural structures
that are subject to high stress and corrosive conditions,
although other parts or structures may be so treated. Although
other types of operations performed at metal finishing plants
involve chromium in some form, this source category includes only
those chromic acid anodizing processes that use chromic acid in
an electrolytic cell to deposit chromium metal or to form an
oxide film on a product.
A-82
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Commercial Dry Cleaning (Perchloroethylene)
Transfer Machines
The Commercial Dry Cleaning (Perchloroethylene) - Transfer
Machines source category includes facilities engaged in cleaning
soiled apparel, leather and other fine goods, which are usually
small independently operated neighborhood shops, franchise shops
and small specialty shops. This category includes facilities
that use perchloroethylene (PCE) as a cleaning agent. Facilities
that use petroleum solvents or 1,1,1-trichloroethane as cleaning
agents are not included in this source category. The category
includes transfer cleaning operations, a washing unit and a
drying unit, which are separate machines.
Source Category: Commercial Sterilization Facilities
The Commercial Sterilization Facilities source category
includes facilities which use ethylene oxide in any equipment
which destroys bacteria, viruses, fungi, insects, or other
unwanted microorganisms or materials when such facilities are
engaged in the growth, manufacture, construction, transportation,
retail or wholesale trade, or storage of commercial products, or
when such facilities are engaged in the operation of museums, art
galleries, arboreta, or botanical or zoological gardens or
exhibits. Not included in this category are hospitals, doctor
offices, veterinary offices, clinics and other facilities where
medical services are rendered.
A-83
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Decorative Chromium Electroplating
The Decorative Chromium Electroplating source category
includes any facility which plates a base material (e.g.,
aluminum, brass, plastic or steel), generally with a layer of
nickel, followed by a relatively thin layer of chromium to
provide a bright surface with wear and tarnish resistance.
Decorative plating is used for items such as automotive trim,
metal furniture, bicycles, hand tools, and plumbing fixtures,
although other items may be plated. Although other types of
operations performed at metal finishing plants involve chromium
in some form, this source category includes only those decorative
chromium electroplating processes that use chromic acid in an
electrolytic cell to deposit chromium metal or to form an oxide
film on a product.
Source Category: Dodecanedioic Acid Production
The Dodecanedioic Acid production source category includes
any facility engaged in producing dodecanedioic acid by using
butadiene which can be converted into several different cyclic or
open chain dimers and trimers depending upon the reaction
conditions and catalysts. Dodecanedioic acid is an intermediate
in the production of 1,5,9-cyclodecatriene, although it can be
produced by another method.
A-84
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Dry Cleaning (Petroleum Solvent)
The Dry Cleaning (Petroleum Solvent) source category
includes any facility engaged in the cleaning of apparel using
petroleum solvents, and includes both commercial (i.e. suits,
coats, dresses) and industrial (i.e. uniforms, shop towels, rugs)
dry cleaners. The category includes, but is not limited to,
petroleum solvents with the following structures: aliphatic,
alicyclic, and aromatic. The category also includes, but is not
limited, to the following process units: washers, centrifugal
extractors, and dryers. Emission sources in the Dry Cleaning
(Petroleum Solvent) category include, but are not limited to,
dryers, and solvent filtration and distillation systems.
Source Category: Ethylidene Norbornene Production
The Ethylidene Norbornene Production (END) source category
includes any facility engaged in the production of the diene,
ethylidene norbornene, which is typically used as a monomer in
the production of ethylene-propylene rubber products. The
associated HAP emissions from the production processes include
1,3-butadiene.
Source Category: Explosives Production
The Explosives Production source category includes any
facility engaged in the production of explosives. Explosives are
chemical compounds or their mixtures that rapidly produce large
volumes of hot gases when properly initiated. The category
includes, but is not limited to, facilities that produce primary
explosives, such as lead azide, and secondary explosives, such as
trinitrotoluene (TNT).
A-85
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Halogenated Solvent Cleaners
The Halogenated Solvent Cleaners source category includes
any facility engaged in any type of solvent cleaning activity
occurring within a solvent cleaning unit; it does not include
wipe cleaning or other cleaning occurring outside the confines of
a cleaning unit. This source category includes, but is not
limited to, the following solvents or solvent blends: 1,1,1-
trichloroethane (TCA), trichloroethylene (TCE), perchloroethylene
(PCE) and methylene chloride (MC). These activities include, but
are not limited to, open top vapor cleaning, cold batch cleaning,
and conveyorized (cold and vapor) cleaning. The sizes of the
units range from bench-top units to large, industrial units. The
emission points to be considered for regulation in this source
category include process emissions.
Source Category: Hard Chromium Electroplating
The Hard Chromium Electroplating source category includes
any facility which deposits a relatively thick layer of chromium
directly onto a base metal (usually steel) to provide a surface
with wear resistance, a low coefficient of friction, hardness,
and corrosion resistance. Hard plating is used for items such as
hydraulic cylinders and rods, industrial rolls, zinc die
castings, plastic molds, engine components, and marine hardware,
or other items or devices. Although other types of operations
performed at metal finishing plants involve chromium in some
form, this source category includes only those hard chromium
electroplating processes that use chromic acid in a electrolytic
cell to deposit chromium metal or to form an oxide file on a
product.
A-86
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Hydrazine Production
The Hydrazine Production source category includes any
facility engaged in the production of hydrazine, a colorless,
fuming, hygroscopic liquid used in rocket engine fuel,
agricultural chemicals, and Pharmaceuticals. The category
includes, but is not limited to, hydrazine produced by the
Rasching process or the ketazine process.
Source Category: Industrial Dry Cleaning (Perchloroethylene) -
Dry-to-Dry Machines
The Industrial Dry Cleaning (Perchloroethylene) - Dry-to-Dry
Machines source category includes facilities engaged in cleaning
rental uniforms, and other items (such as cleaning rags) used by
business, industrial, and institutional customers. The category
includes facilities that use perchloroethylene (PCE) as a
cleaning agent. Not included in this source category are
facilities that use petroleum solvents or 1,1,1-trichloroethane
(TCA) as cleaning agents. This category includes dry-to-dry
cleaning operations (one single unit) only.
A-87
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Industrial Dry Cleaning (Perchloroethylene) -
Transfer Machines
The Industrial Dry Cleaning (Perchloroethylene) - Transfer
Machines source category includes facilities engaged in cleaning
rental uniforms, and other items (such as cleaning rags;) used by
business, industrial, and institutional customers. The category
includes facilities that use perchloroethylene (PCE) as; a
cleaning agent. Not included in this source category cire
facilities that use petroleum solvents or 1,1,1-trichloroethane
(TCA) as cleaning agents. This category includes transfer
cleaning operations and separate washing and drying units which
are separate machines.
Source Category: Industrial Process Cooling Towers
The Industrial Process Cooling Towers source category
includes cooling towers located at any industrial site. In
addition to industrial cooling towers which are major s;ource
emitters of HAP's, this category includes industrial cooling
towers co-located at the individual facilities covered under
other categories of major sources.
Source Category: Oxybisphenoxarsine (OBPA)/I,3-Diisocyanate
Production
The OBPA/1,3-Diisocyanate Production source category
includes any facility engaged in the production of
Oxybisphenoxarsine (OBPA) or 1,3-Diisocyanate.
Oxybisphenoxarsine is a fungicide combined with rubber to prevent
mold growth on gaskets and seals, and 1,3-diisocyanate is an
intermediate in the production of polyurethane resins. Both
production processes use chloroform as a solvent.
A-88
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Paint Stripper Users
The Paint Strippers Users source category includes any
facility engaged in commercial or industrial paint stripping.
The paint stripping process involves four basic steps. First,
paint stripper is applied to the surface to be stripped. Second,
the stripper is allowed to penetrate or dissolve the coating.
Third, the paint and residual stripper are removed from the
treated surface. Finally, the stripped paint is cleaned up and
disposed. The category includes, but is not limited to, original
equipment manufacturing and maintenance facilities engaged in the
paint stripping of paint spray booths, paint stripping in large
open areas, and paint stripping in dip tanks, and other high
volume/high usage activities that use methylene chloride, or
other HAP's in the removal of paints or other coatings.
Source Category: Photographic Chemicals Production
The Photographic Chemicals Production source category
includes any facility engaged in the production of photographic
chemicals, including, but not limited to, chemicals for black and
white photo processing, color photo processing, and film, plate
and paper manufacturing. The category includes the process units
involved in the manufacture of the following chemicals:
developing agents, activators, preservatives, restrainers,
calcium precipitants, wetting agents, neutralizers, fixatives,
hardeners, intensifiers, and reducers.
A-89
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Phthalate Plasticizers Production
The Phthalate Plasticizers Production source category
includes any facility engaged in the manufacture of phthalate
plasticizers using phthalic anhydride as a reactant.
Plasticizers are additives that soften and increase flexibility
of inherently rigid, and even brittle, polymers such as polyvinyl
chloride (PVC). Phthalate plasticizers are a family of monomeric
plasticizers.
Source Category: Plywood/Particle Board Manufacturing
The Plywood/Particle Board Manufacturing source category
includes any facility engaged in the manufacturing of plywood
and/or particle boards. This category includes, but is not
limited to, manufacturing of chip waferboard, strandboard,
waferboard, hardboard/cellulosic fiber board, oriented
strandboard (OSB), hardwood plywood, medium density fiberboard,
particle board, softwood plywood, or other process using wood and
binder systems. Emissions of HAP's have been associated with,
but are not limited to, the drying of binders.
A-90
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Polyether Polyols Production
The Polyether Polyols Production source category includes
any facility which manufactures these polymers by starting with
cyclic ethers (e.g., oxides, epoxides, etc.) and initiating
polymerization by adding ethylene oxide, butylene oxide,
propylene oxide or other chemicals which would result in the
potential emission of HAP's. The reaction is base-catalyzed,
with potassium hydroxide being the most commonly used catalyst.
The physical properties of the polyols are influenced primarily
by the functionality of the initiator molecules and by the type
and quantity of alkylene oxide and hydroxyl groups present in the
polyol.
Source Category: Pulp and Paper Production
The Pulp and Paper Production source category includes any
facility engaged in the production of pulp and/or paper. This
category includes, but is not limited to, integrated mills (where
pulp alone or pulp and paper or paperboard are manufactured on-
site), non-integrated mills (where paper or paperboard are
manufactured, but no pulp is manufactured on-site), and secondary
fiber mills (where waste paper is used as the primary raw
material). Examples of pulping methods include Kraft, soda,
sulfite, semi-chemical, and mechanical. The pulp and paper
production process units include operations such as pulping,
bleaching, and chemical recovery.
A-91
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Rocket Engine Test Firing
The Rocket Engine Test Firing source category includes any
facility engaged in the test firing of rocket engines. The
category includes facilities which test fire rocket engines to
determine performance specifications or compliance with other
functional standards. The category includes, but is not limited
to, test firing of solid and liquid fuel rocket engines.
Source Category: Rubber Chemicals Manufacturing
The Rubber Chemicals Manufacturing source category includes
any facility engaged in the manufacturing of rubber-processing
chemicals. Rubber-processing chemicals are synthetic organic
compounds that are added to natural or synthetic rubber to
produce or enhance specific properties in the final product. The
category includes, but is not limited to, the manufacturing of
rubber-processing chemicals such as vulcanizing agents,,
accelerators, antioxidants, antiozonants, peptizing agents,
tackifying agents, vulcanizing retarders, bonding agents, and
lubricants.
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Semiconductor Manufacturing
The Semiconductor Manufacturing source category includes any
facility engaged in the manufacturing of p-type and n-type
semiconductors. Semiconductors may be crystalline (e.g., GaAs,
GaP, GaSb), amorphous, or organic. The source category
encompasses the manufacture of any class of materials that
exhibit electrical conductivities between those of conductors
(metals) and non-conductors (insulation). The category includes
production processes such as crystal growth, synthesis, doping,
chemical modification, diffusion, metathesis and electrolysis
processes.
Source Category: Symmetrical Tetrachloropyridine Production
The Symmetrical Tetrachloropyridine Production source
category includes any facility engaged in the production of
symmetrical tetrachloropyridine, by using carbon tetrachloride or
other HAP's as part of the reaction of other production process.
Source Category: Tire Production
The Tire Production source category includes, but is not
limited to, any facility engaged in producing passenger car and
light duty truck tires, heavy duty truck tires, off-the-road
tires, aircraft tires, and miscellaneous other tires. The
category includes the following processes: rubber compounding;
tread rubber, cord and bead production; tire building; green tire
spraying; and tire curing and finishing.
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INDUSTRY GROUP - MISCELLANEOUS PROCESSES (CONTINUED)
Source Category: Wood Treatment
The Wood Treatment source category includes any fcicility
engaged in the treatment of wood products for preservation or
other purposes. Wood treatment is accomplished by impregnating
or treating the wood with creosote or other chemicals such as
pentachlorophenol. Wood treatment using waterborne preservatives
will not be covered by this source category.
Wood treatment is performed using either pressure or non-
pressure processes. To initiate either process, wood products
are debarked and conditioned. Conditioning, primarily moisture
removal, is performed by air seasoning or kiln drying. Depending
on the particular preservative to be applied, conditioning may
also be performed by steaming the wood in the treatment retort,
heating the wood in oil under reduced pressure, or exposing it to
hot vapors of organic solvents (vapor drying).
Typical treated wood products include crossties, switch
ties, utility poles, crossarms, foundation pilings, and lumber.
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APPENDIX B
Public Comment Summaries and
Responses to Preliminary Draft Listing
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The following is a summary of public comments and responses
to the "Preliminary Draft List of Categories and Subcategories
Under Section 112 of the Clean Air Act," which was published in
the Federal Register on June 21, 1991 (56 FR 28548). The
reference numbers provided correspond to the original comment
letters in Docket No. A-90-49. The comments and responses are
presented for each source category by industry group, as it
appeared in the preliminary draft list.
Final dispositions provided for each category reflect
decisions made in the preparation of the initial list of
categories as it appears in this document. In many instances,
the final disposition states that a category was removed from the
list becuase no evidence was found to document a major source
within the category. The deletion from this initial list does
not preclude re-establishing the category on the list if a major
source is identified, nor does it preclude listing the area
sources within the category if a finding is made of threat of
adverse effects warranting regulation under Section 112 as a
category of area sources.
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1.0 FUEL COMBUSTION
General Comments
Comment: One commenter (#18) requested that two pollutants be
added to the Fuel Combustion industry group list: polycyclic
organic materials and 1,3-butadiene.
Response: When a source category is identified as one that is
emitting hazardous air pollutants (HAP's) and it is determined
that it contains a major source, it is placed on the list. Once
on the list, the source category will be regulated for any HAP's
that it is later identified as emitting. Therefore, addition of
another pollutant at this time has no impact on the listing
action.
Comment; Three commenters (IV-D-66, IV-D-90, IV-D-89) requested
that EPA create a subcategory for each listed category that
identifies the use of natural gas fuel. The second commenter
requested that EPA remove subcategories that use natural gas
because no source exclusively burning natural gas fuel will be a
source of HAP's and therefore warrant regulation under Title III.
The third commenter requested that EPA remove all natural gas
combustion sources that lack technical data supporting the
existence of major sources.
Response; The purpose of this list is to identify categories of
major sources for which standards will be established, not to
provide the final determination upon which standards will be
based. Only the major sources within the categories on this list
will be regulated. The source categories under the Fuel
Combustion industry group are not based on combustion of fuel
types but on process units, because there is great potential for
co-firing of fuels at a given process unit; traditionally,
potential fuels have been examined when considering a process
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unit. During standards development, classes, types, and sizes of
process units will be specified. Clarification of fuel type used
with a specific process unit will also be made during the
standards development process.
Comment: One commenter (IV-D-32) requested that the list be
limited to major sources and sufficiently well characterized area
sources to allow EPA and concerned parties to concentrate their
efforts in the areas where near-term results will be most
effective.
Response: After considering public comments and performing
additional evaluations of emissions data, EPA has developed a
list of categories of major sources under the Fuel Combustion
industry group that are well characterized.
Comment: One commenter (IV-D-119) requested that the following
source categories be added to this industry group: Residential
Furnaces - Oil, Gas, Wood, and Coal; Commercial Furnaces - Oil,
Gas, Wood and Coal; and Commercial Boilers - oil, Gas, Wood, and
Coal.
Response: The source categories under Fuel Combustion are not
based on combustion of fuel types but on process units, because
there is great potential for co-firing of fuels at a given
process unit; traditionally, potential fuels have been examined
when considering a process unit. During standards development,
classes, types, and sizes of process units will be specified.
Clarification of fuel type used with a specific process unit will
also be made during the standard development process.
Additionally, commercial boilers have been included on the list.
Comment: Four commenters (IV-D-33, IV-D-45, IV-D-74, IV-D-89)
requested that the categories be subcategorized by the type of
fuel combusted. For example, Turbines, Internal Combustion
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Engines, Industrial Boilers, and Commercial Boilers that burn
natural gas would be separate subcategories. In addition, the
commenters requested that EPA (1) evaluate whether such
subcategories potentially include major sources, and (2) not list
these subcategories unless they can be expected to trigger the
major source definition.
Response: The source categories under Fuel Combustion are not
based on combustion of fuel types but on process units, because
there is great potential for co-firing of fuels at a given
process unit; traditionally, potential fuels have been examined
when considering a process unit. During standards development,
classes, types, and sizes of process units will be specified.
Clarification of fuel type used with a specific process unit will
also be made during the standards development process.
Comment; One commenter (IV-D-135) requested that a category for
combustion of waste fuels be created under the Fuel Combustion
industry group.
Response; The Fuel Combustion industry group is categorized by
process unit, not by fuel combusted. Any process unit that has
the potential to combust waste fuel has been described as such.
Comment; One commenter (IV-D-27) noted that if the source
category Test Engine Aircraft constitutes a major source, then
municipal airports should also be included as a major source
under the Fuel Combustion industry group. The commenter included
volatile organic compound estimates as documentation.
Response: This listing includes only those categories that
contain stationary sources that exceed the major source cutoff.
Other types of sources are not subject to the requirements of
this list.
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Comment; One commenter (IV-D-41) requested clarification
regarding whether used oil-fired space heaters fall within the
source category Industrial External Combustion Boilers or
External Combustion Space Heaters. The commenter also stated
that used oil-fired space heaters should not appear on the list
for three reasons: (1) these space heaters are not operated by
industrial users; (2) these space heaters generate heat by
internal combustion; and (3) emissions generated by these space
heaters are extremely small.
Response; Source categories are not defined by combustion fuel
types, but by process units. The units may potentially be fired
by any type of fuel. The category of Space Heaters has been
deleted; however, any major sources fitting within the
description of boilers may be regulated in those categories.
Comment: One commenter (IV-D-59) noted that EPA should provide
more detail about how it intends to classify specific industries
under broad categories. The commenter said it appears that EPA
intends to develop some maximum achievable control technology
(MACT) standards across industries. Examples of such ceitegories
include but are not limited to Process Heaters, Oil and Gas Steam
Generation, Industrial In-Situ Fuel Use, and Prescribed Burning.
Response; Nothing precludes further clarification of classes,
types, and sizes of operations during development of the
regulations. Regarding the examples provided by the commenter,
EPA determined, after additional review of available delta that
Oil and Gas Steam Generation was duplicative with categories of
boilers using any fuel type; Industrial In-Situ Fuel Use was too
vague to define; and Prescribed Burning had no documentation of
major sources, but Process Heaters, because it included major
sources, has been retained on the list.
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Comment; One commenter (IV-D-89) stated that EPA has not
adequately reviewed its data base on fuel combustion sources to
be able to rely on speciation profiles. The commenter also noted
that EPA has combined profiles for a source category without
regard to the fuel being used.
Response: The approach taken to develop this list was the best
one due to the large amount of data necessary to fulfill the
requirements of the Clean Air Act (CAA). In addition, the list
was developed based on process units, not on the type of fuel
combusted, because there is a great potential for co-firing at
many facilities. Thus, the use of several profiles within a
category is warranted.
Comment: One commenter (IV-D-108) requested that source
categories related to electric utility steam-generating units
(e.g., Industrial or Institutional External Combustion Boilers)
should not be listed pending the results of the Section 112
(n)(1) study.
Response: Available information supports that industrial and
institutional/commercial boilers contain major sources or are
commonly located on the premises of major sources, and therefore
they have been listed. Categories that lack documentation of
major sources have not been listed. Section 112(n)(l) refers
specifically to electric utility boilers and provides no basis
for not including other boiler categories on the list.
Comment; One commenter (IV-G-03) requested that the combustion
of refuse-derived fuel (RDF) in external combustion boilers (both
electric utility and industrial) be added to the list. The
commenter noted that the type of emissions from combustion of RDF
are undetermined and potentially pose a threat to public health.
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Response: Source categories are not determined by combustion of
fuel types but by process units. Categories have been described
to include any potential fuel type; these fuels will be assessed
during regulatory development.
1.1 Industrial External Combustion Boilers
Comment; Five commenters (IV-D-62, IV-D-67, IV-D-75, IV-D-116,
IV-D-120) stated that Industrial Boilers should not be considered
for listing until after the study of utility boilers has been
completed. The first and third commenters pointed out that if
EPA is uncertain about the need to regulate larger utility
boilers, then the same uncertainty should apply to small
industrial boilers. The commenters believed that if Industrial
Boilers are listed at this time, it should be limited to major
sources. The second commenter (IV-D-67) requested that EPA
exclude Industrial External Combustion Boilers from the source
category listing until it is determined that their emission
sources are major or present a threat of adverse health effects.
The commenter also stated that this issue should be considered in
the context of other area source emissions, such as during
domestic heating and cooking, when use of these same fuels may
present greater exposure to the population. The fourth commenter
(IV-D-116) requested that Industrial External Combustion Boilers
not be listed because the potential for these units to release
air toxics is dependent on the fuels combusted. The commenter
stated that EPA should evaluate the release potential for these
units and, if regulation is warranted, a narrow source category
should be defined to cover only those areas of concern. The
fifth commenter (IV-D-120) stated that there is no basis for
including Industrial External Combustion Boilers that combust
natural gas. The commenter noted that this source category, when
specifying the use of natural gas, is not well characterized.
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Response; Available information supports that industrial and
institutional/commercial boilers contain major sources or are
commonly located on the premises of major sources, and therefore
they have been listed. Determining whether a source poses a
threat of adverse health effects is not necessary to list
categories of major sources. Categories that lack documentation
of major sources have not been listed. Categories have been
described to include any potential fuel type; these fuels will be
assessed during regulatory development.
Final Disposition; Because major sources have been documented,
this source category will remain on the list, but has been
renamed Industrial Boilers.
1.2 Institutional External Combustion Boilers
Comment; Three commenters (IV-D-67, IV-D-70, IV-D-120) requested
that EPA exclude Institutional External Combustion Boilers from
the source category listings until it is determined that their
emissions are major or present a threat of adverse health
effects. The commenter also stated that this issue should be
considered in the context of other area source emissions such as
domestic heating and cooking when the use of these same fuels may
present greater exposure to the population. The second commenter
noted that it is unclear why Institutional External Combustion
Boilers is listed as a source category, since no HAP emissions
are readily identified. The third commenter (IV-D-120) stated
that there is no basis for including Institutional External
Combustion Boilers that use natural gas fuel. The commenter
noted that this source category, when specifying the use of
natural gas, is not well characterized.
Response; Available information supports that commercial/
institutional boilers contain major sources or are commonly
located on the premises of major sources and therefore they have
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been listed. Determining whether a source poses a threat of
adverse health effects is not necessary for major sources.
Categories that lack documentation of major sources have not been
listed. Categories have been described to include any potential
fuel type; these fuels will be assessed during regulatory
development.
Comment: One commenter (IV-D-97) requested that EPA perform a
study to determine if any incremental increase in public health
protection that results from the control of emissions from
institutional steam boilers is equal to or greater than the
decrement that will occur when institutions that are providing
public health services with limited resources must reallocate
funds to comply with the regulations.
Response: The purpose of this list is to identify categories for
which standards will be established and not to provide an
assessment of economic or other impacts. Such studies will be
performed during development of the regulations.
Final Disposition: This source category will remain on the list
and has been renamed Institutional/Commercial Boilers, for which
documentation of major sources exists.
1.3 External Combustion Space Heaters
Comment; One commenter (IV-D-120) stated that there is no basis
for including External Combustion Space Heaters that use natural
gas as fuel on the list. The commenter noted that this source
category, when specifying the use of natural gas, is not well- .
characterized.
Response; This source category was deleted from the list;
however, any process units fitting within the description of
boilers may be regulated within those categories.
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Final Disposition; External Space Combustion Heaters was deleted
from the list because available information was not sufficient to
support the listing of such a distinct and clear source category;
however, any units that fit within the description of boilers may
be regulated within those source categories.
1.4 Industrial Electric Generation Turbines
Comment; One commenter (IV-D-116) requested that Industrial
Electric Generation Turbines not be listed because the potential
for these units to release air toxics is dependent on the fuels
combusted. The commenter stated that EPA should evaluate the
release potential for these units and, if regulation is
warranted, a narrow source category should be defined to cover
only those areas of concern.
Response; Source categories are not determined by combustion of
fuel types but by process units. They have been described to
include any potential fuels used in those units. Additional
clarification of fuel types associated with those units will be
provided during standards development.
Comment; One commenter (IV-D-120) stated that there is no basis
for including Industrial Electric Generation Turbines that
combust natural gas. The commenter noted that this source
category, when specifying the use of natural gas, is not well
characterized.
Response; Available information supports that Industrial
Electric Generation Turbines contain major sources or are
commonly located on the premises of major sources, and, therefore
they have been listed. Categories that lack documentation of
major sources have not been listed. Categories have been
described to include any potential fuel type; these fuels will be
assessed during regulatory development.
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Final Disposition: Because major sources have been documented,
this source category will remain on the list but has been renamed
Stationary Turbines.
1.5 Industrial Reciprocating Internal Combustion Engines
Comment: One commenter (IV-D-90) noted that only 9 of the 15
HAP's for which the category is listed are potentially emitted by
natural gas-fired, industrial reciprocating, internal combustion
engines. The commenter noted that based on this data, the same
nine HAP's are potentially emitted by natural gas-fired sources
within the categories Utility Reciprocating Engines and
Commercial Reciprocating Engines. Therefore, it is necessary to
establish separate categories or subcategories in addition to, or
within, those cited in the preliminary draft list for engines and
turbines that are fired by natural gas. This will ensure that
EPA establishes appropriately tailored emission factors for such
sources, as compared with sources within the listed categories
that use different fuels.
Response: When a category is identified as one that is emitting
HAP's and it is determined that it contains a major source or is
commonly located on the premises of major sources, it is placed
on the list. Once on the list, it will be regulated for any HAP
that it is later identified as emitting. Furthermore, source
categories are not based on combustion of fuel types, but on
process units. Considerations regarding types of fuels used will
be made during development of the standards.
Final Disposition: Because major sources have been documented,
this category will remain on the list but has been renamed
Stationary Internal Combustion Engines.
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1.6 Commercial/Institutional Turbines
Comment; One commenter (IV-D-120) stated that there is no basis
for including Commercial/Institutional Turbines that combust
natural gas. The commenter noted that this source category, when
specifying the use of natural gas, is not well characterized.
Response; Available information supports that commercial/
institutional turbines contain major sources or are commonly
located on the premises of major sources, and therefore they have
been listed. Categories that lack documentation of major sources
have not been listed. Categories have been described to include
any potential fuel type; these fuels will be assessed during
regulatory development.
Final Disposition: Because major sources have been documented,
this source category will remain on the list but has been renamed
Stationary Turbines.
1.7 Commercial Reciprocating Internal Combustion Engines
Comment; Two commenters (IV-D-67, IV-D-120) requested that EPA
exclude this source category until it is determined that emission
sources are major or present a threat of adverse health effects.
The commenters also stated that this issue should be considered
in the context of other area source emissions, such as during
domestic heating and cooking, when the use of these same fuels
may present greater exposure to the population. The second
commenter (IV-D-120) stated that there is no basis for including
Commercial Reciprocating 1C Engines that combust natural gas.
The commenter noted that this source category, using natural gas,
is not well characterized.
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Response: Available information supports that internal
combustion engines contain major sources or are commonly located
on the premises of major sources, and therefore they have been
listed. Determining whether a source poses a threat of adverse
health effects is not necessary for major sources. Categories
that lack documentation of major sources have not been listed.
Categories have been described to include any potential fuel
type; these fuels will be assessed during regulatory development.
Final Disposition; Because major sources have been documented,
this source will remain on the list but has been renamed
Stationary Internal Combustion Engines.
1.8 Test Engine-Aircraft
Comment: None
Final Disposition; Because major sources have been documented,
this source will remain on the list but has been renamed Engine
Test Facilities.
1.9 Test Engines - Turbine
Comment; None
Final Disposition; Because major sources have been documented,
this source will remain on the list but has been renamed Engine
Test Facilities.
1.10 Test Engines - Reciprocating
Comment: None
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Final Disposition: Because major sources have been documented,
this source will remain on the list but has been renamed Engine
Test Facilities.
1.11 Process Heaters
Comment: None
Final Disposition; Because major sources have been documented,
this category will remain on the list.
1.12 Secondary Metals Process Heaters
Comment: One commenter (IV-D-120) stated that there is no basis
for including Secondary Metals Process Heaters that use natural
gas as fuel. The commenter noted that this source category, when
specifying the use of natural gas, is not well characterized.
Response; Source categories are not based on combustion of fuel
types but on the process unit. The effects of fuel will be
addressed during regulatory development. However, this category
was found to be overlapping with Process Heaters and is now
listed under that category.
Comment: Two commenters (IV-D-62, IV-D-67) noted that the
description of this source category in the draft background
documentation is significantly lacking. The first commenter (IV-
D-62) requested that it be deleted from the list because it is
either based on little or no available data or is not identified
with sufficient precision. The second commenter requested that
this source category be deleted due to the absence of factual
data.
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Response; Each category has been better and more fully
described regarding its coverage. This clarification does not
preclude further distinctions for classes, types, and sizes for
the purposes of MACT as allowed by the CAA. However, this
category was found to be overlapping with that of Process Heaters
and is now listed under that category.
Final Disposition; Because this source category was found to be
overlapping with Process Heaters, it is now listed under the
Process Heaters category, which is documented as containing major
sources.
1.13 Petroleum Industry Process Heaters
Comment; One commenter (IV-D-67) noted that definition of this
source category in the draft background documentation is
significantly lacking. The commenter requested that this source
category be deleted due to the absence of factual data.
Response; Each category has been better and more fully described
regarding its coverage. This clarification does not preclude
further distinctions for classes, types, and sizes for the
purposes of MACT as allowed by the CAA. However, this category
was found to be overlapping with that of Process Heaters and has
been listed under that category.
Comment; One commenter (IV-D-120) stated that there is no basis
for including Petroleum Industry Process Heaters that use natural
gas as fuel. The commenter noted that this source category, when
specifying the use of natural gas, is not well characterized.
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Response; Source categories are not based on combustion of fuel
types but on the process unit. The effects of fuel will be
addressed during regulatory development. However, this category
was found to be overlapping with that of Process Heaters and has
been listed under that category.
Final Disposition; Because this source category was found to be
overlapping with that of Process Heaters, it has been listed
under the category Process Heaters, which is documented as
containing major sources or having sources commonly located on
the premises of major sources.
1.14 Oil and Gas Steam Generation
Comment; One commenter (IV-D-70) noted that it is unclear why
Oil and Gas Steam Generation is listed as a source category,
since no HAP emissions are readily identified.
Response; Though preliminary information indicated that there
were HAP emissions from this source category, further review of
the information indicated an overlap with the category of
Boilers. Therefore, this source category has been deleted from
the list.
Comment; One commenter (IV-D-88) noted that if utility steam
generators are included on the list, there should be separate
categories for oil-fired steam generators, very low-sulfur, oil-
fired steam generators, and natural gas-dominated steam
generators. In addition, the commenter requested that Oil and
Gas Steam Generation be amended to read Non-Utility Steam
Generation or at least Steam Generation Other than Utility,
Natural-Gas-Dominated Steam Generation.
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Response; Source categories are not based on combustion of fuel
types but on process units. Furthermore, this source category
was found to be overlapping with the category of boilers.
Therefore, this source category has been deleted from the list.
Comment; Two commenters (IV-D-85, IV-D-108) requested that EPA
list the source classification code (SCC) and title for each
entry because, for example, the listed category of Oil and Gas
Steam Generation appears to cover all categories of sources that
burn oil and gas for steam generation. However, the background
document "Documentation for Developing the Source Category List"
indicates that this category covers only SCC category 310004,
"Oil and Gas Production - Fuel-Fired Equipment - Steam
Generators." The second commenter (IV-D-108) noted that it is
not clear what is included in this source category. Presumably,
this does not include gas- or oil-fired electric utility steam-
generating units.
Response: This source category was found to be overlcipping with
the category of Boilers, and therefore, has been deleted from the
list.
Final Disposition; Because additional review of available data
indicated that this source category overlapped with Boilers, Oil
and Gas Steam Generation has been deleted as an individual
category on the list.
1.15 Industrial In-Situ Fuel Use
Comment; Three commenters (IV-G-04, IV-D-62, IV-D-67) requested
that Industrial In-Situ Fuel Use be regulated as a subcategory of
the respective process category. The second commenter (IV-D-67)
specifically noted that the definition of this source category in
the draft background documentation is significantly lacking. The
commenter requested that this source category be deleted due to
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the absence of factual data. The third commenter (IV-D-62)
requested that Industrial In-Situ Fuel Use be dropped from the
list because the source category is either based on little or no
available data or is not identified with sufficient precision.
Response; Additional review of available information could not
support a clear definition of the intended coverage of this
category, and it has been deleted from the list.
Final Disposition; Because additional review of available
information could not support a clear description of the intended
coverage of this category, Industrial In-Situ Fuel Use was
deleted from the list.
1.16 Prescribed Burning
Comment; None
Final Disposition; This source category has been deleted from
the list since, upon review, no evidence was found to document a
major source within the category.
1.17 Residential Boilers
Comment; One commenter (IV-D-119) noted that based on the given
source description, residential size boilers and furnaces would
be classified as area sources, therefore this source category has
been deleted.
Response; This source category has been deleted from the list
since, upon review, no evidence was found to document a major
source within the category.
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Final Disposition; No documentation of major sources was found
for this source category; it subsequently has been removed from
the list.
1.18 Residential Wood Combustion - Fireplaces
Comment; One commenter (IV-D-63) noted that listing fireplaces
as area sources of HAP's is premature and probably unjustified.
The commenter urged EPA to defer any listing until the need for
regulation can be fully documented and a practical regulatory
approach can be developed.
Response: This source category has been deleted from the list
since, upon review, no evidence was found to document a major
source within the category. No determination has yet been made
as to whether it is a category of area sources.
Final Disposition: No documentation of major sources was found
for this source category; it subsequently has been removed from
the list.
1.19 Residential Wood Combustion - Woodstoves
Comment; One commenter (IV-D-63) noted that listing woodstoves
as area sources of HAP's is premature and probably unjustified.
The commenter urged EPA to defer any listing until the need for
regulation can be fully documented and a practical regulatory
approach can be developed.
Response: This source category has been deleted from the list
since, upon review, no evidence was found to document a major
source within the category. No determination has yet been made
as to whether it is category of area sources.
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Final Disposition: No documentation of major sources was found
for this source category; it has been removed from the list.
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2.0 NONFERROUS METALS
General Comments
Comment: Three commenters (IV-G-01, IV-D-104, IV-D-76) requested
that EPA more narrowly describe subcategories within the source
categories in the Nonferrous Metals industry group. The narrow
description would allow the regulated community to submit
constructive comments and assess the potential impacts of final
regulations. The second commenter also suggested considering the
following types of information when more narrowly describing the
subcategories: types of raw materials processed/used; types of
manufacturing/treatment processes; nature and composition of
principal products; and types of pollution control/treatment
technology used. The third commenter noted that refining and
smelting processes differ in the type of metal processed and, in
certain instances, more than one process exists for refining,
smelting, or further processing of specific metals or metal
compounds.
Response; As a result of comments received, many source
categories have been described more precisely. However, nothing
precludes further clarification during standards development,
since the Clean Air Act (CAA) allows distinction for classes,
types, and sizes within a category or subcategory where necessary
to meet the purposes of maximum achievable control technology
(MACT) .
Comment: One commenter (IV-D-76) stated that a category for
facilities that smelt and refine copper in an integrated
operation should be listed distinctly from Primary Copper
Smelters. The commenter noted the processes and emission
profiles of integrated facilities are significantly different
from those of free-standing copper smelters.
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Response; The source category Primary Copper Smelters has been
described such that it is clear that integrated operations are
distinct from nonintegrated ones. Such differences will be taken
into account during regulatory development.
Comment; One commenter (IV-D-75) noted that EPA's proposal to
list primary copper smelters only on the basis of cadmium
emissions appears to reflect an Agency conclusion that smelters
should not be regulated under Section 112 on the basis of other
emissions. The commenter agreed with this approach.
Response; In fact, the EPA has studies on arsenic emissions that
indicate that primary copper smelters are a major source for
arsenic emissions. In addition, when a source category is
identified as one that is emitting hazardous air pollutants
(HAP's), and it determined that it contains a major source, it is
placed on the list. Once on the list, it will be regulated for
any HAP's that it is later identified as emitting.
Comment; One commenter (IV-D-01) stated that metals product
manufacturing is being lumped into a category that is too broad
to adequately differentiate both process and emission
characteristics.
Response; At this time, there is no metals product manufacturing
source category; furthermore, the Primary Metals - Miscellaneous
and the Secondary Metals - Miscellaneous categories have been
deleted from the list. Even with the list being now clarified,
nothing precludes further clarification during standards
development, since the Clean Air Act allows distinction for
classes, types, and sizes within a category or subcategory where
necessary to meet the purposes of MACT.
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Comment: One commenter (IV-D-56) requested that the source
category Aluminum Rolling and Annealing be included under the
industry group Nonferrous Metals.
Response; Because no documentation was provided with the
comments, and EPA has not identified any information indicating
that the processes of aluminum rolling and annealing constitute
an individual category of major sources, these specific source
categories have not been included on the list at this time.
Comment: One commenter (IV-D-56) stated that Primary Aluminum
Production should be a separate source category under the
Nonferrous Metals industry group.
Response: Primary Aluminum Production and Secondary Aluminum
Production are listed as distinct categories and have been
clearly described to include processes and emission points that
potentially emit HAP's.
2.1 Aluminum Production
Comment: Five commenters (IV-D-01, IV-D-15, IV-D-37, IV-D-38,
IV-D-56) requested that reasonable and technically accurate
categories be developed under this industry group. Two
commenters suggested the following divisions: Material Handling,
Prebake Reduction Process, Bake Ovens, Vertical Stud Soderberg
Process, Horizontal Stud Soderberg Process, and Paste Mixing.
The commenters believed that this proposed subcategorization is
supported by the fundamental differences in each process. The
second commenter stated that individual aluminum processes must
be categorized separately from that of ferrous or other
nonferrous metals. The commenter felt this separation was
justified because of differences between metal manufacturing
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processes and the manufacture of aluminum products, such as trace
metals, molten metal temperatures, and fabrication, and
lubrication methods from the metal mining operations.
Response; As a result of comments received, many source
categories have been described more precisely. However, nothing
precludes further clarification during standards development,
since the Clean Air Act allows distinctions for classes, types,
and sizes within a category or subcategory where necessary to
meet the purposes of MACT.
Comment: Two commenters (IV-D-15, IV-D-38) provided a list of
proposed categories and subcategories for aluminum processes as
well as descriptions of process differences. The 11 proposed
categories were Bauxite Processing, Primary Aluminum Production,
Aluminum Melting and Ingot Casting, Secondary Melting and
Casting, Aluminum Rolling and Annealing, Aluminum Coating,
Aluminum Wire Manufacturing, Aluminum Extrusion Operations,
Aluminum Can Making, Aluminum Foundry Operations, and Aluminum
Forging Operations. The commenters also proposed multiple
subcategories for each suggested category. In addition, the
second commenter requested that Aluminum Powder and Pigment
Production be included as a source category.
Response; As a result of comments received, many source
categories have been described more precisely. However, nothing
precludes further clarification during standards development,
since the Clean Air Act allows distinctions for classes, types,
and sizes within a category or subcategory where necessary to
meet the purposes of MACT.
Final Disposition; Available information indicates that Aluminum
Production contains a major source. Therefore, this source
category will remain on the list, but has been renamed Primary
Aluminum Production.
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2.2 Primary Lead Smelting
Comment: One commenter (IV-D-76) stated that inclusion of
Primary Lead Smelting as a single category could potentially
cover facilities with significantly different production
processes. In addition, lead smelters can either be free-
standing facilities or can be integrated with lead refineries.
The commenter requested that lead smelting be listed as Primary
Lead Smelters Principally Processing Complex Ore Feedstocks and
Integrated Primary Lead Smelters Processing High Grade Ore
Feedstocks.
Response; The Primary Lead Smelting source category has been
clearly described regarding the processes and emission points
included under this source category. The description also
reflects the information supplied by the commenters; this
information will be supplemented during the development of
regulations to account for various types of operations.
Final Disposition; Available information indicates that Primary
Lead Smelting contains a major source. Therefore, this source
category will remain on the list.
2.3 Primary Metals - Miscellaneous
Comment: Three commenters (IV-D-62, IV-D-66, IV-D-76) noted that
the category Primary Metals - Miscellaneous is so general that it
is impossible to know which types of facilities are covered by
it. The commenters noted that such a category could include
facilities engaged in smelting and refining nonferrous metals as.
well as facilities engaged in manufacturing castings or other
basic metal products. In addition, the third commenter noted
that such a general source category makes it impossible to
develop MACT standards. The second and third commenters
requested that Primary Metals - Miscellaneous be dropped from the
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list because the category is too broad and is based on little or
no available data. In addition, the third commenter requested
that this source category be replaced by four source categories:
Primary Copper Smelters with Flash Furnaces, Primary Copper
Smelters with Reverberatory Furnaces, Primary Copper Smelters
using Other Processes, and Integrated Primary Copper Refineries
and Smelters.
Response: The EPA noted that many of the processes that could be
included in this source category already appear on the list.
Because Primary Metals - Miscellaneous is duplicative and
unclear, it has been deleted from the list.
Final Disposition; This source category has been deleted from
the list since, upon review, no evidence was found to document a
major source in this category.
2.4 Secondary Aluminum
Comment: None
Final Disposition: The EPA has information indicating that
Secondary Aluminum contains a major source. Therefore, Secondary
Aluminum will remain on the list, but has been renamed Secondary
Aluminum Production.
2.5 Secondary Copper
Comment: None
Final Disposition: This source category has been deleted from
the list since, upon review, no evidence was found to document a
major source in this category.
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2.6 Battery Manufacture: Non-Lead Types
Comment: None
Final Disposition: Because available information did not
indicate that Battery Manufacture: Non-Lead Types contains a
major source, this category will not be listed at this time.
2.7 Cadmium Refining
Comment: Two commenters (IV-D-62, IV-D-76) stated that cadmium
refining should not be listed as a major source. The commenters
stated that the Toxic Release Inventory System (TRIS) data base
reported cadmium emissions in 1989 for facilities with cadmium
refining operations ranging from 0.05 to 1.85 tons per year. In
addition, the commenters stated that aggregate emissions
associated with cadmium emission are also well below the 25 tons
per year threshold. Finally, the commenters noted that stand-
alone cadmium refineries are different facilities and have
different emission profiles from facilities that are primarily
zinc smelters or refineries, but also refine cadmium as a by-
product. Therefore, if EPA does not delete cadmium refining, it
should narrow the category to cadmium refining and identify a
separate category for cadmium refining as an auxiliary to primary
zinc smelting or refining operations.
Response; Available information does not indicate that cadmium
refining contains a major source nor are there refiners commonly
located on the premises of major sources. Therefore this source
category has been deleted.
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Final Disposition: This source category has been deleted from
the list at this time because available information does not
indicate that cadmium refining contains a major source nor are
refiners commonly located on the premises of major sources.
2.8 Lead Acid Battery Manufacturing
Comment: None
Final Disposition; Available information indicates that this
source category contains a major source. Therefore, Lead Acid
Battery Manufacturing will remain on the list.
2.9 Nonferrous Alloys Production
Comment: None
Final Disposition; Because of the prior ambiguity regarding the
coverage of this category, and because no major source is
documented in the source category, Nonferrous Alloys Production
has been deleted from the list.
2.10 Primary Copper Smelters
Comment; One commenter (IV-D-62) noted that copper refineries
should not be listed under the Primary Copper Smelters category.
The commenter stated that emissions data from the TRIS data base
indicate that copper refineries are not a major source.
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Response: The Primary Copper Smelters category includes only
those source categories that contain major sources. Area sources
will be added to the list after an area source finding has been
made. This addition could occur at any time up to and including
during standards development for the source category.
Additionally, this category has been described to clarify what is
included.
Comment; One commenter (IV-D-75) stated that copper smelters
should not be regulated on the basis of lead emissions. The
commenter noted that smelter lead emissions are already
controlled pursuant to the ambient air quality standards for lead
and fine particulate matter (PM10) and new State PM10 reductions
are expected to achieve even further lead emission reductions at
the commenters smelter.
Response; When a source category is identified as one that is
emitting HAP's, and it is determined that it contains a major
source, it is placed on the list. Once on the list, it will be
regulated for any HAP's that it is later identified as emitting.
The effect of current (or future) regulations may be. taken into
account in developing the standards.
Comment; One commenter (IV-D-75) asked that Primary Copper
Smelters be taken off the list, but if it remains on the list,
the commenter requested that low-risk smelters be excluded from
the category. The commenter noted that low-risk smelters are
those where carcinogenic risk is less than 1 in 1 million.
Response: Available data support the presence of a major source;
therefore, Primary Copper Smelters will remain on the list. Risk
is not a determining factor in establishing the list.
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Final Disposition; Available information indicates that Primary
Copper Smelters contain a major source of HAP's. Therefore,
Primary Copper Smelters will remain on the list, but has been
renamed Primary Copper Smelting.
2.11 Secondary Metals - Miscellaneous
Comment; Two commenters (IV-D-62, IV-D-76) requested that
Secondary Metals - Miscellaneous be dropped from the list because
the category is too broad and is based on little or no available
data or is not identified with sufficient precision.
Response: The EPA noted that some of the categories that could
be contained in this source category (e.g., Secondary Aluminum
Production) already appear on the list individually. Therefore,
Secondary Metals - Miscellaneous has been deleted from the list.
Final Disposition; This source category has been deleted from
the list because many of the processes it could contain are
already source categories. However, now that Secondary Metals -
Miscellaneous has been deleted from the list, EPA will add
Secondary Lead Smelting to the list due to available information
indicating that this category contains a major source.
2.12 Zinc Smelting
Comment; None
Final Disposition; Zinc Smelting has been deleted from the list
since, upon review, no evidence was found to document a major
source in this category.
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3.0 FERROUS METALS
Greneral Comments
Comment: One commenter (IV-D-104) requested that EPA more
narrowly describe the categories within the Ferrous Metals
industry group and the subcategories within each source category.
The commenter suggested that in doing so, EPA consider the
following information: types of raw material processed, or used at
the facility; types of manufacturing or treatment processes
involved; nature and composition of principal products from the
operation; and types of pollution control and treatment
technologies used in the operation. The commenter thought that
possession of this basic information would allow EPA to identify
more narrow and more logical subcategories within the Ferrous
Metals industry group.
Response: As a result of comments received, many source
categories have been described more precisely. However, nothing
precludes further clarification during standards development,
since the Clean Air Act (CAA) allows distinction for "classes,
types, and sizes within a category or subcategory..." where
necessary to meet purposes of maximum achievable control
technology (MACT). Therefore, clarification of the list has no
impact on the already listed categories or subcategories.
Comment: One commenter (IV-G-03) stated that the category of
Ductile Iron Foundries should be added to the Ferrous Metals
industry group because stack tests conducted in Wisconsin
indicated that these facilities have the potential to emit
benzene and formaldehyde from mold pouring, cooling, and shake-
out operations. The commenter thought these emissions were the
result of thermal breakdown of the organic binders used to make
the mold cores. The commenter included estimated benzene and
formaldehyde emission rates from two Wisconsin foundries.
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Response: The source category Iron Foundries will be described
to include the processes used at facilities that emit hazardous
air pollutants (HAP's). Ductile Iron Foundries will be included
in the source category Iron Foundries. Any further rulemaking
will include all specific sources within the category that are
major sources of HAP's.
3.1 Ferroalloys Production
Comment: None
Final Disposition; The EPA has information indicating that this
source category contains a major source. Therefore, Ferroalloys
Production remains on the list.
3.2 Iron and Steel Manufacturing
Comment: Four commenters (IV-D-30, IV-D-58, IV-D-59, IV-G-01)
stated that the listing of Iron and Steel Manufacturing as a
single category under the Ferrous Metal industry group is too
broad and that a number of more specific categories should be
identified. The first commenter pointed out that iron and steel
manufacturing plants typically consist of a collection of very
distinct processing units that utilize different processing
technologies and raw materials. One commenter (IV-D-30)
recommended that as a minimum the iron and steel manufacturing
category be replaced with four categories: Iron Sintering, Iron
Blast Furnaces, Basic Oxygen Steelmaking, and Electric Arc
Furnace Steelmaking. In addition, the commenter recommended that
several subcategories within each of these categories would need
to be identified. For example, because of differences in the
products and raw materials utilized, the commenter believed it
may be necessary to separate Electric Arc Furnace Steelmaking
into subcategories such as Carbon Steelmaking or Specialty
Steelmaking.
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The second commenter (IV-D-58) requested that EPA
subcategorize iron and steel manufacturing into four processes:
Sintering, Pickling, Basic Oxygen Furnaces, and Electric Arc
Furnaces. In addition, the commenter requested that EPA
subcategorize the various melting processes included in iron and
steel manufacturing in an analogous manner to the categorical
effluent standards under the Clean Water Act.
The third and fourth commenters (IV-D-59, IV-G-01) asked
that EPA specify the emission points, process, or equipment that
will be regulated under Iron and Steel Manufacturing because this
source category could include at least 20 different processes
that potentially emit regulated HAP's. The commenter felt that
many of these steel manufacturing processes (such as coke ovens
and sintering) do not occur at specialty steel facilities;
therefore, it would be difficult to assess whether the specific
iron and steel manufacturing processes at facilities are targeted
for regulations.
Response; As a result of comments received, many source
categories have been described more precisely. This source
category has been divided into seven distinct source categories
(Integrated Iron and Steel Manufacturing, Non-Stainless Steel
Manufacturing, Stainless Steel Manufacturing, Coke By-Product
Plants, three categories for coke ovens and one for steel
pickling), and has been described to include all processes that
potentially emit HAP's and are a major source. However, nothing
precludes further clarification during standards development,
since the Clean Air Act allows distinction for "classes, types,
and sizes within a category or subcategory..." where necessary to
meet the purposes of MACT. Therefore, clarification has no
impact on the already listed categories or subcategories.
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Final Disposition; The Iron and Steel Manufacturing source
category has been divided into three distinct source categories:
Integrated Iron and Steel Manufacturing, Non-Stainless Steel
Manufacturing - Electric Arc Furnace Operation; and Stainless
Steel Manufacturing - Electric Arc Furnace Operation. In
addition, the existing Steel Pickling and Coke Oven source
categories remain on the list.
3.3 Gray Iron Foundries
Comment; One commenter (IV-G-04) stated that a single category
for Gray Iron Foundries is too broad; the commenter also
supported and agreed with the comments of the American Foundryman
Society (IV-G-02) on the appropriate categories for gray iron
foundries.
Response: As a result of comments received, many source
categories have been described more precisely. However, nothing
precludes further clarification during standards development,
since the Clean Air Act allows distinction for "classes, types,
and sizes within a category or subcategory..." where necessary to
meet the purposes of MACT. Therefore, clarification has no
impact on the already listed categories or subcategories.
Comment: One commenter (IV-G-02) stated that Gray Iron Foundries
should be further subcategorized using source classification
codes (SCC's). This commenter also felt that subcategories for
thermal sand reclamation and mechanical sand reclamation should
be included in this foundry category. The commenter stated that
while quantitative information on emissions of HAP's from this
foundry category and subcategories is limited, sufficient
surrogate data (i.e., volatile organic compounds [VOC] emission
rates) exist to establish that this category for the most part is
B-35
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not a major source of HAP's and should be classified as an area
source. The commenter included some VOC emissions data as well
as SCC descriptions of Gray Iron Foundries.
Response; Because major sources have been documented, this
source category will remain on the list but has been renamed Iron
Foundries. It has been described to include all major sources of
HAP's. Those subcategories that are not found to be major
sources will be subject to an area source finding.
Comment: One commenter (IV-D-135) requested that the final
definitions of foundries not be described so as to exclude those
specialty foundries that may emit nickel compounds. The
commenter requested that the foundry source categories include
any source category that produces a risk greater than 1 in
1 million, regardless of the emission, and that the general
control of fugitive emissions that are generated during pouring
operations be more restrictive.
Response: This source category is described to include all
operations at a foundry that emit HAP's including nickel
compounds. In addition, EPA is mandated to regulate MACT by
emission magnitude and will address residual risks from emissions
at a later date. Risk is not a determining factor in
establishing the list.
Final Disposition; The EPA has information indicating that this
source category contains a major source. Therefore, it will
remain on the list but has been renamed Iron Foundries.
3.4 Steel Foundry
Comment; One commenter (IV-G-02) stated that Steel Foundries
should be further subcategorized using SCC's. This commenter
also felt that subcategories for thermal sand reclamation and
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mechanical sand reclamation should be given to this foundry
category. The commenter noted that while quantitative
information on emissions of HAP's from this foundry category and
subcategories is limited, sufficient surrogate data (i.e., VOC
emission rates) exist to establish that this category, for the
most part, is not a major source of HAP's and should be
classified as an area source. The commenter included some VOC
emissions data, as well as SCC descriptions of steel foundries.
Response: Because major sources have been documented, this
source category will be described to include all major sources of
HAP's. Those categories that are not found to contain major
sources will be subject to an area source finding.
Comment: One commenter (IV-D-135) requested that the final
definitions of foundries not be so rigidly described so as to
exclude those specialty foundries that may emit nickel compounds.
Also, for the same source category, the commenter requested that
the foundries source categories include any source categories
that produce a risk greater than 1 in 1 million, regardless of
the emission rate, and that general control of fugitive emissions
that are generated during pouring operations be more restrictive.
Response: This source category is described to include all
operations at a foundry that emit HAP's including nickel
compounds. In addition, the EPA is mandated to regulate MACT by
emission magnitude and will address residual risks from emissions
at a later date. Risk is not a determining factor in
establishing the list.
Comment: One commenter (IV-D-66) felt that the Steel Foundry
category should be clarified to include only facilities that are
producing steel by the component process and not simply melting
steel. Based on an evaluation of the commenter's facilities
which simply melt steel and could be included under this
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category, the commenter feels that regulation is not warranted.
Any emissions would fall far below those thresholds described for
major sources, as well as any level that posed a threat of
adverse effects to human health and the environment.
Response: As a result of comments received, many source
categories have been described more precisely. However, nothing
precludes further clarification during standards development,
since the CAA allows distinction for "classes, types, and sizes
within a category or subcategories..." where necessary to meet
the purposes of MACT. Therefore, clarification of the list has
no impact on the already listed categories or subcategories.
Furthermore, only those major sources of HAP's will be regulated.
Final Disposition: The EPA has information indicating that this
source category contains a major source. Therefore, Steel
Foundry will remain on the list, but has been renamed Steel
Foundries.
3.5 Coke By-Product Plants
Comment: One commenter (IV-D-66) stated that the category Coke
By-Product Plants should be described consistently with the
definition under historic national emission standards for
hazardous air pollutants (NESHAP) regulations and should exclude
form-coke plants.
Response: The description of this source category will include
only those sources that are major. Attempts to maintain
consistency between existing and current definitions will be made
as appropriate. Source categories/subcategories and process
units subject to regulation will be described specifically during
regulatory development.
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Final Disposition: The EPA has information indicating that this
source category contains a major source; therefore Coke By-
Product Plants will remain on the list.
3.6 Coke Ovens
Comment: One commenter (IV-D-66) felt that the category Coke
Ovens should be described consistently with the definition under
historic NESHAP regulations and should exclude form-coke plants.
Response: The description of this source category only includes
those sources that are major. Attempts to maintain consistency
between existing and current descriptions have been made as
appropriate. Source categories/subcategories and process units
subject to regulation will be described specifically during
regulatory development.
Comment; One commenter (IV-D-45) requested that EPA redescribe
Coke Ovens as Coke Production. The commenter pointed out that
this would include three categories of coke production: one each
for wet coal-charged by-product coke ovens, dry coal-charged
ovens, and nonrecovery ovens.
Response: The Coke Oven source category has been divided into
two source categories: Coke Ovens: Charging, Top Side, and Door
Leaks; and Coke Ovens: Pushing, Quenching, and Battery Stacks.
Documentation of major sources exists for both source categories,
Final Disposition; The Coke Oven source category has been
divided into two source categories: Coke Ovens: Charging, Top
Side, and Door Leaks; and Coke Ovens: Pushing, Quenching, and
Battery Stacks. Documentation of major sources exists for both
source categories.
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3.7 Metal Shredding (Recycling)
Comment; Two commenters (IV-D-78, IV-D-112) stated that Metal
Shredding (Recycling) is inappropriately listed because the basis
for originally listing this category is a letter with no
documentation that suggested that shredding iron and steel for
recycling may generate particles of these metals that could
become airborne. The first commenter noted that the metal
shredding process incorporates dust controls and is designed to
produce steel fragments of a diameter of approximately three
inches. The commenter requests that, in the absence of any
evidence that shredders are adding cadmium or chromium to the
ambient air, this source category be removed from the list. The
second commenter noted that scrap metal from the fabrication
process is collected and recycled through a scrap dealer. Other
wastes are collected for off-site disposal.
Response; This source category has been deleted from the list,
since, upon review, no evidence was found to document a major
source in this category, nor was it commonly found to be located
on the premises of major sources.
Final Disposition: In the absence of any information indicating
that this source category contains a major source or is commonly
located on the premises of major sources, Metal Shredding
(Recycling) was removed from the list.
3.8 Steel Pickling
Comment: One commenter (IV-D-58) requested that EPA clarify
steel pickling operations to refer to hydrochloric acid pickling
at integrated carbon steel facilities. The commenter felt that
this category should not apply to specialty steel pickling
operations that do not emit sulfuric or hydrochloric acid. The
commenter mentioned that pickling operations at specialty steel
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facilities may emit the regulated pollutant hydrogen fluoride,
but these emission most likely fall below the "major source"
thresholds, and consequently pickling operations at specialty
steel facilities should not be a regulated subcategory.
Response: Steel pickling operations have been described to
include hydrochloric acid pickling where they are major sources.
Final Disposition: The EPA has information indicating that this
source category contains a major source. Therefore, the category
will remain on the list, but has been renamed Steel Pickling-HCl
Process.
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4.0 MINERAL PRODUCTS PROCESSING AND USE
General Comments
Comment: One commenter (IV-D-76) noted that the list of
categories related to the mineral processing industry could be
improved by the creation of more distinct and accurate
categories.
Response: As a result of comments received, many source
categories have been described more precisely. However, nothing
precludes further clarification during standards development
since the Clean Air Act (CAA) allows distinction for classes,
types, and sizes within a category or subcategory where necessary
to meet the purposes of maximum achievable control technology
(MACT). Therefore, clarification will have no impact on the
listed categories or subcategories.
Comment; Two commenters (IV-D-62, IV-D-76) noted that EPA may
have used fugitive emissions when listing ore flotation, stone
quarries, and sand and gravel mining operations as major sources
because these categories produce mostly fugitive emissions. The
commenter also pointed out that EPA may only count fugitive
emissions from a source for purposes of determining whether it is
a major source after it has conducted a rulemaking pursuant to
Section 302(j) of the CAA.
Response; These source categories have been deleted from the
list since, upon review, no evidence was found to document a
major source in this category. Source categories are only
included on the list when they contain a major source or when
such sources are commonly found to be located on the premises of
major sources.
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Comment: One commenter (IV-D-62) noted that the unique
characteristics of the mining industry provide a prime example of
why careful scrutiny must be given to special factors associated
with each source, source category, and source subcategory. The
commenter requested that Section 112 decisions recognize that the
mining industry is unique. Their unique characteristics include
locations in remote areas; these remote locations mean public
health risks will be minimized.
Response: The EPA only lists those source categories that are
documented as containing major sources or which are commonly
located on the premises of major sources. Determination of major
sources includes close scrutiny of multiple parameters associated
with each category or subcategory. However, if one source is
considered major, the agency will regulate the source category.
Risk is not a determining factor in establishing the list.
Comment; One commenter (IV-D-62) noted that the mining industry
is already heavily regulated to address environmental concerns
and for many mining categories and subcategories, it is likely
that existing or planned controls will satisfy Section 112
requirements.
Response: The CAA requires EPA to list all categories of major
sources. Provisions will be made during standards development
for those categories already regulated to assess whether the
existing or planned controls reflect MACT.
Comment: One commenter (IV-D-75) requested that EPA not list
uranium mines and mill tailings, unless it can be determined that
additional air toxics regulations are necessary to protect public
health.
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Response; Uranium mines and mill tailings are not currently
listed. Only if the EPA finds that these categories contain
major sources, or contain sources that are commonly located on
the premises of major sources, or warrant regulation as area
sources would they be added to the list.
4.1 Taconite Iron Ore Processing
Comment: One commenter (IV-D-62) requested that Taconite Iron
Ore Processing be deleted from the list because it is listed
based on the National Emission Data System (NEDS) approach, "D-
quality" data. The commenter stated that this is an insufficient
basis for listing.
Response: The approach taken for listing source categories was
the best approach for obtaining the large amount of data
necessary to fulfill the requirements of the CAA. The EPA
contends that the Taconite Iron Ore Processing source category
contains a major source and must be listed. If during regulatory
development this category were found not to contain a major
source, it would be deleted from the list.
Final Disposition; The EPA has information indicating that this
source category contains a major source. Therefore, Tciconite
Iron Ore Processing will remain on the list.
4.2 Asphalt Concrete Manufacture
Comment; One commenter (IV-D-23) recommended that asphalt
concrete manufacture be deleted from the list when hazeirdous air
pollutant (HAP) emissions do not exceed defined de minimis levels
and public health risks do not exceed prescribed levels. The
commenter also requested that if asphalt concrete manufacture is
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retained on the list, EPA ensure that sources with de minimis
levels of HAP emissions or risk may be exempt from the federal
operating permit program.
Response: The Asphalt Concrete Manufacture source category has
been described so that only major sources will be listed and
regulated. Those sources that do not emit enough HAP's to
qualify as a major source will not be listed. Risk is not a
determining factor in establishing the list.
Final Disposition: The EPA has information indicating that this
source category contains a major source. Therefore, Asphalt
Concrete Manufacturing will remain on the list.
4.3 Brick Manufacturing
Comment; None.
Final Disposition; This category has been renamed Clay Products
Manufacturing and EPA has information indicating that this source
category contains a major source.
4.4 Cement Kilns
Comment: One commenter (IV-D-62) requested that Cement Kilns be
deleted from the list because this category is listed based on
the NEDS approach, D-quality data. The commenter stated that
this is an insufficient basis for listing.
Response; The approach taken for listing source categories was
the best approach for obtaining the large amount of data
necessary to fulfill the requirements of the CAA. The EPA
contends that this source category contains a major source and
must be listed.
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Final Disposition; The EPA has information indicating that this
source category contains a major source. Therefore, it will
remain on the list but has been renamed Portland Cement
Manufacturing.
4.5 Glass Manufacture
Comment: One commenter (IV-D-54) requested that Glass
Manufacture be deleted from the list because EPA's data indicate
that emissions of HAP's from glass furnaces are extremely low and
do not present a threat of adverse effect to human health or the
environment.
Response: Upon review, EPA found no evidence to document a major
source in this category nor is it commonly located on the
premises of major sources. This source category has been deleted
from the list.
Final Disposition: Glass Manufacture has been deleted from the
list since, upon review, no evidence was found to document a
major source in this category nor is it commonly located on the
premises of major sources.
4.6 Stone Quarries
Comment: Five commenters (IV-D-66, IV-D-98, IV-D-111, IV-D-122,
IV-D-125) requested that the source category Stone Quarries be
removed from the list. The second commenter noted that if the
source category is not removed, it should be amended to read
"stone quarries except limestone" because the commenter believes
that given the Occupational Safety and Health Administration's
(OSHA) permissible exposure limit of 15 ng/m for limestone and
the relatively low content of manganese and lead in typical
compounds, air emissions from limestone quarries likely do not
pose an adverse threat to human health and the environment.
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Commenters IV-D-66, IV-D-111, IV-D-122, and IV-D-125 requested
that Stone Quarries be removed from the list. The first
commenter noted that the basis for inclusion of this category is
a single study conducted in Montana that recorded the presence of
background or trace amounts of lead and manganese at a limestone
quarry. The commenter noted that to use this one study as the
basis for an industry-wide hazardous pollutant regulatory scheme
is unconscionable and irresponsible. The second commenter noted
that stone quarries have effective in-place controls and
nonhazardous air emissions. The third and fourth commenters
noted that the data used to list stone quarries is not
representative of the industry and the occupational health data
characteristics of the industry do not demonstrate any health
effect traceable to either lead or manganese.
Response: The EPA has no data indicating that the source
category Stone Quarries contains a major source nor is it
commonly located on the premises of major sources. Therefore,
this source category will not be listed at this time.
Final Disposition; This source category has been deleted from
the list since, upon review, no evidence was found to document a
major source in this category nor is it commonly located on the
premises of major sources.
4.7 Mining Operations - Sand/Gravel
Comment; Five commenters (IV-D-23, IV-D-62, IV-D-111, IV-D-122,
IV-D-125) requested that Mining Operations - Sand/Gravel be
removed from the list. The first commenter noted that the basis
for inclusion of this category is a single study conducted in
Montana which recorded the presence of background or trace
amounts of lead and manganese at a limestone quarry. The
commenter noted that to use this one study as the basis for an
industry wide hazardous pollutant regulatory scheme is
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unconscionable and irresponsible. The second commenter noted
that Mining Operations - Sand/Gravel have effective in place
controls and non-hazardous air emissions. The third comiaenter
noted that the data used the list sand and gravel mining is not
representative of the industry and the occupational health
characteristics of the industry do not demonstrate any health
effect traceable to either lead or manganese. The fourth
commenter noted that there is little or no data supporting
inclusion of this source category. The fifth commenter (IV-D-23)
recommended that Mining Operations - Sand/Gravel be deleted from
the list when HAP emissions do not exceed defined de minimis
levels and public health risks do not exceed prescribed levels.
The commenter also requested that if Mining Operations -
Sand/Gravel is retained on the list, to ensure that sources with
de minimis levels of HAP emissions or risk may be exempted from
the federal operating permit program.
Response; The EPA has no data indicating that the source
category Mining Operations - Sand/Gravel contains a major source.
Therefore, this source category will not be listed at this time.
Final Disposition; This source category has been deleted from
the list since, upon review, no evidence was found to document a
major source in this category.
4.8 Metal Pipe Coating-Asphalt/Coal Tar
Comment; None
Final Disposition; The EPA has information indicating that this
source category contains a major source. Therefore, Metal Pipe
Coating-Asphalt/Coal Tar will remain on the list, but has been
renamed Asphalt/Coal Tar Application - Metal Pipes.
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4.9 Asbestos Fabricating
Comment; None
Final Disposition: While emissions from sources within this
category have not justified listing it as a major source, a
finding of threat of adverse effects to human health or the
environment has been made. Therefore, EPA has listed Asbestos
Fabrication as a category of area sources.
4.10 Asbestos Manufacturing
Comment: None
Final Disposition: While emissions from sources within this
category have not justified listing it as a major source, a
finding of threat of adverse effects to human health or the
environment has been made. Therefore, EPA has listed Asbestos
Manufacturing as a category of area sources.
4.11 Asbestos Milling
Comment: None
Final Disposition; While emissions from sources within this
category have not justified listing it as a major source, a
finding of threat of adverse effects to human health or the
environment has been made. Therefore, EPA has listed Asbestos
Milling as a category of area sources.
4.12 Asbestos Removal: Demolitions
Comment: Four commenters (IV-D-45, IV-D-66, IV-D-114, IV-D-124)
noted that this source category appears to be based on little to
no available data and is sufficiently ill-defined so as to
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preclude meaningful investigation, evaluation, and comments. The
second commenter noted that determination of applicability would
be improved by better describing the category. Both commenters
requested further clarification and categorization of this
category. The third commenter (IV-D-45) questioned why Asbestos
Removal: Demolitions is listed as a source category if it would
still, presumably, be covered by the existing national emission
standard for hazardous air pollutants (NESHAP). The fourth
commenter (IV-D-114) noted that it appears impossible that
emissions from Asbestos Removal: Demolitions could approach 10
tons per year if the emission control and disposal practices
required by NESHAP Subpart M are employed. This category would
then comprise entirely area sources and would be regulated as
such.
Response: Because emissions from sources within this category do
not justify listing it as a category of major sources, a finding
of threat of adverse effects to human health or the environment
would have to be made. However, such a finding has not been made
at this time.
Final Disposition: This source category has been deleted from
the list.
4.13 Asbestos Removal: Renovations
Comment; Four commenters (IV-D-45, IV-D-66, IV-D-114, IV-D-124)
requested clarification of this category. Two commenters noted
that this source category appears to be based on little to no
available data and is sufficiently ill-defined so as to preclude
meaningful investigation, evaluation, and comment. They noted
that determination of applicability would be improved by better
defining the Asbestos Removal: Renovations category and requested
further clarification and categorization. One commenter
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(IV-D-45) questioned why Asbestos Removal: Renovations is listed
as a source category if it would still, presumably, be covered by
the existing NESHAP. Another commenter (IV-D-114) noted that it
appears impossible that emissions from Asbestos Removal:
Renovations could approach 10 tons per year if the emission
control and disposal practices required by NESHAP Subpart M are
employed. This category would then comprise entirely area
sources and would be regulated as such.
Response; Because emissions from sources within this category do
not justify listing it as a category of major sources, a finding
of threat of adverse effects to human health or the environment
would have to be made. However, such a finding has not been made
at this time.
Final Disposition: This source category has been deleted from
the list.
4.14 Asbestos Waste Disposal: Demolitions
Comment; Three commenters (IV-D-66, IV-D-114, IV-D-124)
requested further clarification of this source category. One
commenter noted that it appears impossible that emissions from
Asbestos Waste Disposal: Demolitions could approach 10 tons per
year if the emission control and disposal practices required by
NESHAP Subpart M are employed. This category would then be
comprise entirely area sources and would be regulated as such.
Two commenters (IV-D-66, IV-D-124) noted that this source
category appears to be based on little to no available data and
is sufficiently ill-defined so as to preclude meaningful
investigation, evaluation, and comment. The commenters requested
further clarification and categorization.
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Response; Because emissions from sources within this category do
not justify listing it as a category of major sources, a finding
of threat of adverse effects to human health or the environment
would have to be made. However, such a finding has not been made
at this time.
Final Disposition: This source category has been deleted from
the list .
4.15 Asbestos Waste Disposal: Renovations
Comment: Three commenters (IV-D-66, IV-D-114, IV-D-124)
requested further clarification of this source category. One
commenter noted that it appears impossible that emissions from
Asbestos Waste Disposal: Renovations could approach 10 tons per
year if the emission control and disposal practices required by
NESHAP Subpart M are employed. This category would then comprise
entirely area sources and would be regulated as such. Two
commenters (IV-D-66, IV-D-124) noted that this source category
appears to be based on little to no available data and is
sufficiently ill-defined so as to preclude meaningful ^
investigation, evaluation, and comment. The commenters requested
further clarification and categorization.
Response: Because emissions from sources within this category do
not justify listing it as a category of major sources, a finding
of threat of adverse effects to human health or the environment
would have to be made. However, such a finding has not been made
at this time.
Final Disposition: This source category has been deleted from
the list.
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4.16 Construction: Spraying and Insulation
Comment; None
Final Disposition: EPA has no information indicating that this
source category contains a major source. Therefore,
Construction: Spraying and Insulation has been deleted from the
list.
4.17 Asphalt Paving and Roofing Operations
Comment: One commenter (IV-G-04) requested that this source
category be split into Asphalt Paving Operations and Asphalt
Roofing Operations.
Response: Asphalt Paving and Roofing Operations is no longer
listed as a distinct source category since, upon review, no
evidence was found to document major sources within this
category.
Comment; One commenter (IV-D-23) recommended that Asphalt Paving
and Roofing Operations be deleted from the list when HAP
emissions do not exceed defined de minimis levels and public
health risks do not exceed prescribed levels. The commenter also
requested that if Asphalt Paving and Roofing Operations is
retained on the list, EPA ensure that sources with de minimis
levels of HAP emissions or risk be exempt from the federal
operating permit program.
Response; The EPA must list all source categories that contain a
major source. Only those sources emitting HAP's that qualify
them as a major source will be regulated. Risk is not a
determining factor in establishing categories of major sources.
Any listed categories of area sources consider risk as part of
the finding of threat or adverse effects.
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Final Disposition; Because there was a lack of evidence that
this category contained a major source, it was removed from the
list.
4.18 Asphalt Processing
Comment: None
Final Disposition; This source category will remain on the list
because it is known to be co-located with a major source and will
be regulated as such.
4.19 Auto Trans. Plates Manufacturing
Comment: None
Final Disposition: Upon review, EPA found no evidence to
document a major source in this category. Therefore, Auto Trans.
Plates Manufacturing has been deleted from the list.
4.20 Brake Parts Manufacturing
Comment: None
Final Disposition; Upon review, EPA found no evidence to
document a major source in this category. Therefore, Brake Parts
Manufacturing has been deleted from the list.
4.21 Ceiling Tile Manufacturing
Comment; One commenter (IV-D-61) requested that Ceiling Tile
Manufacture be deleted from the list because fine mineral fibers
are not produced in manufacturing ceiling tiles. The commenter
noted that only mineral fibers with an average diameter greater
than 1 ^m are emitted.
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Response: Upon review, EPA found no evidence to document a major
source in this category. Therefore, Ceiling Tile Manufacturing
has been deleted from the list.
Final Disposition; This source category has been deleted since
no evidence was found to document that the source category
contains a major source.
4.22 Friction Material Manufacturing
Comment; None
Final Disposition: Friction Material Manufacturing has been
deleted since no evidence was found to document that this source
category contains a major source.
4.23 Mineral Dryers/Calciners
Comment; One commenter (IV-D-66) noted that this source category
appears to be based on little to no available data and is
sufficiently ill-defined so as to preclude meaningful
investigation, evaluation, and comment. The commenter requested
further clarification and categorization.
Response: As a result of comments received, many source
categories have been described more precisely. However, nothing
precludes further clarification during standards development,
since the CAA allows distinction for "classes, types, and sizes
within a category or subcategory..." where necessary to meet the
purposes of MACT. Therefore, clarification will not have an
impact on the listed category or subcategory.
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Comment: One commenter (IV-D-75) requested that mineral dryers
at primary copper processing facilities be excluded from any
listing of mineral dryers/calciners because primary copper
processing is not discussed in the background document for new
source performance standards for dryers.
Response: This source category will be defined in order to
clarify the intended coverage of major sources within this
listing.
Final Disposition; Upon additional review of available
documentation this category was determined to comprise the source
categories Lime Manufacturing and Alumina Processing, each of
which has documentation of major sources.
4.24 Mineral Wool Production
Comment; One commenter (IV-D-61) requested that Mineral Wool
Production be deleted from the list because fine mineral fibers
are not produced in manufacturing mineral wool. The commenter
noted that only mineral fibers with an average diameter greater
than 1 urn are emitted.
Response: This source category has been identified as containing
a major source of formaldehyde and phenol emissions. It will be
listed based on emissions of these HAP's.
Final Disposition: Major sources have been confirmed in this
category; therefore, it will remain on the list.
4.25 Ore Flotation
Comment: Four commenters (IV-D-62, IV-D-66, IV-D-75, IV-D-76)
noted that this source category appears to have been listed based
on little data. Three of the commenters indicated that they are
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not aware of any ore flotation processes that result in emissions
of HAP's beyond the major source threshold levels. The first
commenter also noted that there is no information in the EPA
docket supporting identification of ore flotation as a Title III
major source. The second commenter pointed out that this lack of
data also indicates the relatively sparse and poorly reviewed
documentation provided by EPA in making its listing decisions and
they believe that ore flotation is not a major source of cresol
or cresylic acid. The fourth commenter (IV-D-76) noted that the
Ore Flotation category is too broad. Various metallurgical
facilities use ore flotation, yet depending on the elemental ore,
different chemicals and processes are used. Some of these
processes do not generate any HAP's; the HAP emissions of others
vary greatly.
Response; Upon review, EPA found no evidence to document that
the Ore Flotation category contains a major source. This source
category has been deleted from the list.
Final Disposition: This source category has been deleted from
the list since there is no evidence to document that it contains
a major source nor is it commonly located on the premises of
major sources.
4.26 Refractories Production
Comment; None.
Final Disposition; This source category has been renamed
Chromium Refractories Production and remains on the list due to
documented presence of major sources.
4.27 Talc Manufacturing
Comment: None.
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Final Disposition; This source category has been deleted since
no evidence was found to document that this category contains a
major source nor is it commonly located on the premises of major
sources.
4.28 Vermiculite Manufacturing
Comment: One commenter (IV-D-62) recommended that EPA drop
Vermiculite Manufacturing from the list because it was based on
little or no available data.
Response; Upon review, EPA found no evidence to document a major
source within this source category nor that it is commonly
located on the premises of major sources. Vermiculite
Manufacturing has been deleted from the list.
Final Disposition: This source category has been deleted from
the list.
4.29 Wool Fiberglass Manufacturing
Comment: One commenter (IV-D-73) requested that wool fiberglass
manufacturing be divided into the following four categories:
Wool Fiberglass Manufacturing by Rotary Process, Wool Fiberglass
Manufacturing by HERM Rotary Process, Fiberglass Manufacturing by
Flame Attenuation and Microfiber Manufacturing. The commenter
rioted that the reason for breaking the industry down by
manufacturing process is to ensure that MACT criteria are fully
considered in the context of unique factors present in each of
these four categories.
Response: As a result of comments received, many source
categories have been described more precisely. However, nothing
precludes further clarification during standards development,
since the CAA allows distinction for "classes, types, and sizes
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within a category or subcategory..." where necessary to meet the
purposes of MACT. Therefore, clarification will have no impact
on the listed category or subcategory.
Final Disposition; The EPA has information indicating that this
source category contains a major source. Therefore, Wool
Fiberglass Manufacturing will remain on the list.
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5.0 PETROLEUM REFINERIES
General Comments
Comment; One commenter (IV-D-127) stated that gasoline
production is included under the Petroleum Refineries ssource
category and therefore recommended that EPA should either not
include it under the industry group Petroleum and Gasoline
Production and Marketing or should delete "Gasoline Production"
from the title.
Response: The production of gasoline is intended to be covered
only under the Petroleum Refineries industry group, which has
been renamed Petroleum and Natural Gas Production and Refining.
Comment: Two commenters (IV-D-31, IV-D-64) stated that a
potential for overlap exists when using the three methods for
creating categories: sector-based, equipment-based, and
operation-based. The commenters indicated care must be taken in
the creation of categories and in the development of emission
standards so the facility is not faced with confusing or
contradictory requirements. For example, refineries in Petroleum
Refining are sector-based, storage tanks within the refinery are
equipment-based and listed under Gasoline/Petroleum Storage, and
wastewater discharges from refineries are listed under Wastewater
Treatment Systems. The first commenter (IV-D-31) suggested using
an API sector-based categorization and included a preliminary
list.
Response: The approach taken was the best one for obtaining the
large amount of data necessary to fulfill the requirements of the
Clean Air Act (CAA). In addition, each source category has been
described in a precise manner to preclude overlap. In developing
this description, EPA considered comments regarding the
appropriate description of processes and operations involved.
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Storage tanks and wastewater treatment systems that are
associated with the refinery facility are included under the
Petroleum Refineries source category and are no longer listed as
distinct categories.
Comment; One commenter (IV-D-64) stated that uncertainty exists
on how to write compliance plans. Petroleum Refineries is a
source category, and presumably maximum achievable control
technology (MACT) standards promulgated for this category would
apply to storage tanks, process heaters, wastewater treatment
systems, or other processes normally associated with refining
operations. However, each are listed as separate categories. The
commenter questioned whether emission standards proposed for
tanks under the Petroleum Refineries category differ from those
required under Gasoline/Petroleum Storage.
Response: The source category for Gasoline/Petroleum Storage has
been eliminated to avoid overlap regarding storage tanks. In
addition, each source category has been described in a precise
manner to indicate what associated processes should be included
in this category.
Comment; One commenter (IV-D-31) noted that EPA should include
compliance flexibility in the final source category rulemaking;
the commenter recommended that EPA list subcategories of process
units until adequate emissions data is available for evaluation.
Response: Only those categories or subcategories with emission
data that indicated that they contain a major source have been
listed. Adequate emissions information is not available to
support the listing of individual subcategories as suggested by
the commenter. The EPA recognizes that different process units
exist for this source category, and the CAA allows EPA to
distinguish among classes, types, and sizes of sources within a
category or subcategory in establishing emission standards.
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Comment; One cortunenter (IV-D-19) suggested that subcatego-
rization be based on type of process because some sources are
large or complex (hydrotreaters, catalytic cracking units, etc.).
Response: Even with the list now being clarified, nothing
precludes further clarification during standards development
since the Clean Air Act allows distinction for "classes, types,
and sizes within a category or subcategory...." where necessary
to meet the purposes of MACT.
Comment: One commenter (IV-D-19) stated that area sources should
be included as subcategories of the major source category if
possible. An example is Biological Waste Treatment, which should
be a subcategory under Petroleum Refineries.
Response: Area sources are only included on the list if an area
source finding indicates that the source presents significant
health risks. Area sources may be added to the list at any time,
iap to and including during standards development for the source
category.
Comment: One commenter (IV-D-19) noted that EPA should identify
categories and appropriate subcategories that will enable
eventual MACT controls to be imposed first on the process units
having the greatest potential public health benefits. In
addition, EPA should postpone controls on process units that will
have a lesser public health benefit at a later time in the
10-year MACT schedule by using the API-suggested subcategories.
Response: The CAA directs EPA to consider health effects, the
quantity and location of emissions, and the efficiency of
grouping categories or subcategories in setting priorities for
promulgating standards. The schedule for promulgation of
emission standards will reflect these considerations.
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Comment: One commenter (IV-D-31) noted that MACT requirements
and promulgation schedules for storage tanks in a refinery may
need to differ substantially from MACT requirements in other
sectors. In addition, the same commenter stated that if EPA uses
API's proposed list with 19 process units, individualized MACT
requirements may be necessary for some of the process units
because of differences in operational characteristics.
Response: Even with the list being clarified now, nothing
precludes further clarification during standards development,
since the CAA allows distinction for "classes, types, and sizes
within a category or subcategory...." where necessary to meet the
purposes of MACT.
Comment; One commenter (IV-D-39) noted that different MACT
requirements may be applicable within the same category. One
could apply to storage within a refinery as well as the storage
of much smaller quantities at a market outlet. It is not
practical or necessary to apply the same emission standards to
both storage facilities.
Response; For the current listing, EPA has only listed those
categories where a major source has been identified or which are
commonly located on the premises of major sources. In addition,
the CAA allows EPA to distinguish among classes, types, and sizes
of sources within a category or subcategory in establishing
emission standards.
Comment; One commenter (IV-D-31) stated that API's suggested
subcategories for Petroleum Refineries are based on types of
process units, some of which may not be majcr sources of HAP
emissions. Data are not readily available to show whether they
are or are not major sources of HAP emissions.
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Response; The EPA has only listed those categories and subca-
tegories for which emissions data exist indicating a major source
or which are commonly located on the premises of major sources.
Comment: One commenter (IV-D-46) stated that small refineries
should be subcategorized. The commenter noted that the status of
small refiners requires creation of a separate subcategory under
Section 112(c). Small refineries have less access to capital and
are less diversified than large refineries, thus the economic
requirements are greater on small refineries. Section 410(h)
recognizes the appropriateness of special treatment of small
refineries and provides special sulfur allowances.
Response; The source category Petroleum Refineries has been
described to clarify what subcategories are included in the
source category. In addition, the CAA allows EPA to distinguish
among classes, types, and sizes of sources within a category or
subcategory in establishing emission standards.
5.1 Petroleum Refineries
Comment; Four commenters (IV-D-19, IV-D-31, IV-D-44, IV-D-64)
noted that the API Process Unit Breakdown List should be used and
gave the list of subcategories suggested. In addition, the third
commenter (IV-D-44) noted that if EPA chooses to use the API
list, the following statement should be included: "Refinery
equipment leaks should not be broken down into process unit
subcategories if EPA is not inclined to allow pooling of fugitive
sources across process limits."
Response; The approach taken was the best approach for obtaining
the large amounts of data necessary to fulfill the requirements
of the CAA. Furthermore, the API process unit breakdown was used
in defining the source category of Petroleum Refineries.
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Comment; One conunenter (IV-D-31) recommended adding the
following paragraph: "If future MACT standards are written to
apply across all process subcategories at a facility, they will
include the flexibility to provide specific individual criteria
for certain subcategories and permit the facility the flexibility
to group subcategories where appropriate for compliance purposes
taking into consideration the cost of achieving such emission
reductions [Section 112(d)(2)], and the efficiencies of grouping
categories or subcategories [Section 112(e)(2)(C)]."
Response; The CAA states that emission standards developed
through Section 112 will require the maximum degree of reduction
in emissions of HAP's that the EPA, taking into consideration the
cost of achieving such a reduction, along with other non-air
quality impacts, determines is achievable. Also, within each
category or subcategory, EPA is allowed to distinguish among
classes, types, and sizes of sources in establishing MACT
standards.
Comment: One conunenter (IV-D-31) noted that EPA should add the
subcategories Storage Tanks, Wastewater Treatment, and Process
Heaters & Boilers. The commenter suggested that these be
included as subcategories when in HAP service. No other
references were given.
Response; The Petroleum Refining source category has been
described to clarify which processes will be regulated under the
source category, including wastewater treatment operations, etc.
Final Disposition; The EPA has information indicating that this
source category contains a major source. Therefore, Petroleum
Refining will remain on the list, but will be divided into two
source categories: Petroleum Refineries - Catalytic Cracking
(Fluid and Other) Units, Catalytic Reforming Units and Sulfur
Plant Units) and Petroleum Refineries - Other Sources Not
Distinctly Listed.
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6.0 PETROLEUM AND GASOLINE PRODUCTION AND MARKETING
General Comments
Comment; Two commenters (IV-D-127, IV-D-05) suggested that the
name of this industry group be definitive and consistent with the
source categories that are included in it. The commenters
pointed out that, for example, gasoline production is covered in
the Petroleum Refineries category. The commenters further
explained that the industry group name does not reflect the
natural gas industry source categories included in the group..
These commenters urged that the subcategories specified under
this industry group need to be clear and distinct to prevent
overregulation.
Response: The EPA has changed the names of the Petroleum
Refining and Petroleum and Gasoline Production and Marketing
industry groups to more accurately reflect the two source
categories contained in them. The new names are Petroleum and
Natural Gas Production and Refining, and Liquids Distribution.
Nothing precludes further clarification during standards
development, since the Clean Air Act (CAA) allows distinction for
classes, types, and sizes within a category or subcategory where
necessary to meet the purposes of maximum achievable control
technology (MACT).
Comment: Two commenters (IV-D-66, IV-D-05) stated that they
support limiting "Production and Marketing" sources so as to
completely exclude users and small quantity producers that do not
engage in marketing. The commenters stated that if EPA chooses
to regulate these "users," sufficient data should be provided to
prove that a threat of adverse health effects exists, and a
cutoff point would be necessary to exempt small sources. The
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coinmenters noted that costs for compliance due to overregulating
can approach a constitutional Fifth Amendment "takings" situation
(see Executive Order 12630).
Response: The EPA has listed only those source categories that
contain major sources or that are commonly located on the
premises of major sources. Area sources may be added to the list
after an adverse public health finding has been made. Additions
of area sources can occur at any time.
Comment: One commenter (IV-D-05) requested that EPA recognize
the difference between industrial plant operations and oil and
gas production operations. However, the commenter provided no
additional documentation to support this request.
Response: The Oil and Gas Production source category has been
further defined to clarify processes and emissions that will be
regulated under the source category. It has been renamed Oil and
Natural Gas Production (excluding the following: individual
wells and equipment specifically associated with individual
wells, pipeline compressors and pump stations).
Comment: One commenter (IV-D-05) stated that the definition of a
"major source" as worded violates Section 112(n)(4)(A) and (B) of
the CAA as to oil and gas production operations. This commenter
provided no additional documentation to support this statement.
Response; Sections 112 (n)(4)(A) and (B) of the CAA give special
provisions for determining what constitutes major sources and
area sources for oil and gas production wells. These provisions
do not conflict with the definition of "major source" as it
appears elsewhere in the CAA and in the draft Preamble, but give
EPA specific directions on procedures for listing these
facilities.
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Comment: Four commenters (IV-D-127, IV-D-31, IV-D-64, IV-D-95)
requested that several source categories be added under this
industry group. The first commenter requested the addition of
glycol dehydration units, which can be major sources of benzene,
and sour gas processing facilities, which can be major sources of
carbonyl sulfide and hydrogen sulfide.
The second and third commenters suggested the following
disaggregation of source categories for this industry group:
Crude Oil Loading and Marine Loading of Petroleum Products, (each
with several subcategories); Oil and Gas Exploration and
Production, (to differentiate MACT requirements for storage
facilities for pipelines involved in crude handling and/or other
petroleum products); Pipeline Transportation - Crude Storage and
Pipeline Transportation - Product Storage (to differentiate MACT
requirements for those storage facilities with pipelines involved
in crude handling from storage facilities with pipeline
transporting various petroleum products); and Research Facilities
(to develop equitable separate MACT standards for new process and
product research and development operations). The fourth
commenter also requested the addition of Crude Oil Loading,
Marine Loading of Crude Oil, Pipeline Transportation - Crude
Storage and Pipeline Transportation - Product Storage for the
same reasons as the other commenters.
Response; The categories suggested by the first commenter have
been included under the Oil and Gas Production source category,
which has been renamed Oil and Natural Gas Production. At this
time, EPA has no information indicating whether the additional
source categories suggested by the second, third, and fc>urth
commenters contain major sources. If information becomes
available indicating the existence of a major source in any of
these suggested categories, such categories will be included in
the list.
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6.1 Oil and Gas Production
Comment; One commenter (IV-D-05) suggested that there are no
additional sources to add to this industry group. The commenter
further stated that it is not timely for the generic inclusion of
the Oil and Gas Production category under Section 112 of the CAA.
This commenter provided no additional documentation to support
this statement.
Response: The CAA requires EPA to list all source categories
with major sources or that are commonly located on the premises
of major sources. Section 112(n)(4) further states that EPA
shall not aggregate any wells, well head equipment, pipeline
compressors, or pump stations to determine whether such units are
major sources. EPA has determined that other non-wellhead
operations individually exceed the major source threshold.
Therefore, this source category will remain on the list, but has
been renamed Oil and Natural Gas Production.
Comment: One commenter (IV-D-05) stated that oil and gas wells
acidizing has a short duration and overall insignificant impact
on the environment, but must be considered according to the
stipulations of Section 112(n)(4)(A) and (B) of the CAA.
Therefore, this operation should be included under the Oil and
Gas Production source category.
Response; Certain non-wellhead related equipment have been
individually identified as major sources, and as such, must be
listed. No consideration of risk or hazard is necessary under
Section 112(n)(4)(A) for listing categories of major sources if
the major source threshold is exceeded.
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Comment; One coimenter (IV-D-31) was concerned that a standard
for the Oil and Gas Production source category would overlap with
standards for Oil and Gas Steam Generation, Natural Gas
Storage/Transmission, Enhanced Oil Recovery, and Oil/Gas Well
Acidizing.
Response: The Oil and Gas Production source category has been
described to include Enhanced Oil Recovery and Oil/Gas Well
Acidizing. Furthermore, the list has been reviewed to eliminate
duplications. This source category has been renamed Oil and
Natural Gas Production.
Comment: Three commenters (IV-D-120, IV-D-89, IV-D-36) stated
that the proposed source category notice gave no evidence to
support the addition of Natural Gas Production as a major source
under Title III. The first two commenters pointed out that
Section 112(n)(4) states that EPA shall not list gas production
wells as an area source category under Section 112(c), unless
this category is determined to present more than a negligible
risk. The commenters further suggested that if no negligible
risk is found, the source category Oil and Gas Production should
be deleted from the list. The third commenter requested that Oil
and Gas Production be deleted from the source category list
because wells are specifically excluded as an area source under
Title III of the CAA of 1990.
Response; This category is not listed as a category of area
sources, so no demonstration of risk is needed. This source
category will remain on the list as a category of major sources,
but has been renamed Oil and Natural Gas Production.
Final Disposition: The EPA has information indicating that
individual, non-wellhead operations in this source category are
major sources. Therefore, Oil and Gas Production will remain on
the list, but has been renamed Oil and Natural Gas Production.
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6.2 Gasoline/Petroleum Storage
Comment; One commenter (IV-D-23) requested that the source
category Gasoline/Petroleum Storage be deleted from the draft
list because hazardous air pollutant (HAP) emissions from this
source category do not exceed de minimis levels and public health
risks do not exceed prescribed levels. The commenter further
requested that if this source category is not deleted from the
source category list the EPA ensure that it is exempt from the
Federal operating permit program.
Response; Each source category retained on the list has been
determined to contain a major source. However, upon review, the
source category Gasoline/Petroleum Storage has not been
determined to contain a major source, and it has been
incorporated into the Gasoline Distribution (Stage I) source
category and the Organic Liquids Distribution source category.
Comment; Two commenters (IV-D-31, IV-D-39) stated that according
to the way the source category list is structured, there is
potential for overlapping standards and different MACT
requirements to apply within this source category. As an
example, the commenter pointed out that a source category for
Gasoline/Petroleum Storage is listed in addition to source
categories for Refineries, Marketing Terminals, Bulk Plants, and
Oil and Gas Production.
Response; Each source category has been further described to
clarify which major source it includes. In addition, the
Petroleum Marketing (with bulk terminals and plants) source
category has been deleted from the list.
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Comment; Three commenters (IV-D-39, IV-D-62, IV-D-75) suggested
that the Gasoline/Petroleum Storage source category be clarified
to include a cutoff point for smaller users/facilities that are
not major sources and pose no significant health or environmental
threat.
Response: This source category has been deleted from the list
since, upon review, no evidence was found to document a major
source within this category.
Final Disposition: The EPA has no information indicating that
the Gasoline/Petroleum Storage source category contains a major
source to warrant its being listed as a distinct source category.
Therefore, Gasoline/Petroleum Storage has been incorporated into
the Gasoline Distribution (Stage I) source category and the
Organic Liquids Distribution source category.
6.3 Petroleum Marketing (with Bulk Terminals and Plants)
Comment: One commenter (IV-D-31) requested that this category be
subcategorized into Petroleum Bulk Terminals and Petroleum Bulk
Plants due to differences in size, complexity, emission
potential, MACT timing, and standard setting.
Response; Descriptions have been developed to clarify each
source category; but even with the list being clarified now,
nothing precludes further clarification during standards
development since the CAA allows distinction for classes, types,
and sizes within a category or subcategory where necessary to
meet the purposes of MACT.
Final Disposition: This source category has been renamed Organic
Liquids Distribution (Nongasoline).
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6.4 Manganese Fuel Additives
Comment; None
Final Disposition: Upon review, EPA found no evidence to
document that this source category contains a major source or
that it is commonly located on the premises of major sources.
Therefore, Manganese Fuel Additives has been deleted from the
list.
6.5 Natural Gas Storage/Transmission
Comment: Four commenters (IV-D-74, IV-D-86, IV-D-120, IV-D-90)
suggested that this source category be deleted for the following
reasons: First, EPA did not distinguish clearly enough between
area and major sources in this category; second, the facilities
in this category are very low in trace contaminants; and third,
the reference to support EPA's listing of this source category
based on its emissions of 1,1-dichloroethane is unfounded.
The third commenter pointed out that storage facilities are part
of many natural gas transmission systems; however, these storage
facilities would generally be excluded by law (unless they are
located in highly populated areas). This commenter further noted
that acidizing is a process applied to individual wells, and
because individual wells are exempt from this category, itv is not
necessary to indicate acidizing.
Response: This source category has been deleted from the list
since, upon review, no evidence was found to document a major
source within this source category. Moreover, Section 112(n)(4)
(A) precludes aggregating emissions from pipeline compressors or
pump stations to determine if such units are major sources.
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Final Disposition: The EPA has no information indicating that
individual units within this source category are major sources.
Therefore, Natural Gas Storage/Transmission has been deleted from
the list as a distinct source category.
6.6 Oil Shale Retorting
Comment; None
Final Disposition: The EPA has no information indicating that
this source category contains a major source or that it is
commonly located on the premises of major sources. Therefore,
Oil Shale Retorting has been deleted from the list.
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7.0 SURFACE COATING PROCESSES
General Comments
Comment; One commenter (IV-G-15) stated that a source category
should be added for medium-to-heavy-duty trucks with the
hazardous air pollutants (HAP's) xylene, toluene, methyl isobutyl
ketone (MIBK), methanol, and methyl ethyl ketone (MEK). The
commenter believed this industry is sufficiently distinct, large,
and unique with respect to the high performance and durability
requirements of its coatings to be included on the final list of
source categories. The commenter provided details about the
industry's coating process and paint technology in support of its
inclusion as a source category.
Response; The listing procedures used did not identify adequate
emissions information concerning the coatings involved with
medium-heavy-duty trucks so as to properly identify a distinct
category for listing this as a source category. However, EPA
intends to investigate the coatings associated with medium-heavy-
duty trucks for inclusion within the category of Miscellaneous
Metal Parts (Surface Coating). If warranted, EPA can evaluate
medium-heavy- duty truck coatings separately during the
regulatory development process.
Comment; One commenter (IV-D-23) suggested the addition of two
source categories - Plasma Arc and Metallizing Spray Operations -
with HAP's such as chrome and nickel. The comment was based on
the commenter's State agency permitting and air toxics
experience.
Response; The listing procedures used did not indicate that
Plasma Arc and Metallizing Spray Operations are distinct
categories containing major source emissions, and therefore the
EPA does not intend to add these categories to the list at this
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time. These types of operations would be evaluated, as
applicable, during the standards development process for listed
categories.
Comment: One commenter (IV-D-96) made three general comments
about Surface Coating Processes. One comment was that EPA lacks
sufficient data and some categories are ill-defined. The
commenter was concerned that if these categories and
subcategories are not clarified in the final rulemaking then it
will not be known what to do if a source falls into two or more
categories and subcategories. The commenter also noted the
absence of a Miscellaneous Metal Parts category, which was
employed by the Federal Clean Air Program in the control of
volatile organic compounds (VOC's). The commenter did not
understand why this category was not included, when so many other
surface coating categories based on controlling VOC's have been
included. The third comment made by the commenter was that many
of the processes that are identified under Surface Coating
Processes would not emit the requisite critical threshold amounts
of HAP's so as to be classified as major stationary sources under
Section 112 of the Clean Air Act (CAA).
Response: The approach taken for listing source categories was
the best one possible due to the large amount of data necessary
to fulfill the requirements of the CAA. The EPA feels confident
that source categories listed under the Surface Coatings
Processes industry group contain major sources and must, be
listed. EPA agrees with the commenter that more clarification is
needed for applicability purposes and has prepared descriptions
for each source category on the final list. Based on a review of
the industry group, EPA has decided to list a category for
Miscellaneous Metal Parts (Surface Coating) to include applicable
major sources not covered under other source categories already
listed.
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Comment: One commenter (IV-G-07) requested that Locomotive and
Rail Car Production and Repair and Metal Windows be added as
source categories to the Surface Coating Processes industry
group.
Response: The EPA could find no evidence of major sources for
these source categories. Therefore, they are not included on the
list at this time.
7.1 Fabric Printing
Comment; One commenter (IV-D-188) requested that EPA remove
fabric printing from consideration as a major source of HAP's,
after reviewing the documentation presented in the Draft List
from the Air Species Manual. Vol. 1, VOC Species Profiles. The
commenter refuted the inclusion with two separate analyses of
mineral spirits, the solvent used in their paste formulations,
which showed emissions below the thresholds of a major source,
even at the maximum measured concentrations. In conclusion, they
proposed fabric printing be removed from the list of major
sources for HAP's because the solvent base used in fabric
printing contains only trace amounts of HAP's.
Response: As a result of the listing procedures used, EPA feels
confident that the Fabric Printing source category contains a
major source and must be listed. Facilities within this source
category that do not emit HAP's in quantities sufficient to be
considered major sources may still be listed as area sources,
according to Section 112(c)(3) of the CAA, if EPA finds these
emission sources to present a threat of adverse effects to human
health or the environment.
Comment; One commenter (IV-D-102) requested that EPA delete any
reference to textile screen printing within the source category
of Fabric Printing because it does not emit HAP's, as proven by a
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survey of their industry. They did not recommend deleting the
source category, unless the source category is redefined to
include only screen printing, because other fabric printing
operations may emit listed HAP's.
Response: The CAA allows EPA to distinguish among classes,
types, and sizes within a category or subcategory when
developing emission standards. The deletion of particular HAP's
related only to textile screen printing processes has no effect
on the current listing action.
Final Disposition: Fabric Printing has been deleted as a
distinct source category. Emission sources associated with
Fabric Printing have been included within the scope of the
Printing, Coating, and Dyeing of Fabrics source category.
7.2 Surface Coating Operations - General Solvent Uses
Comment: Four commenters (IV-D-96, IV-D-67, IV-D-124, IV-D-66)
suggested that the category is too poorly defined to determine
applicability by industry and regulations. The first commenter
(IV-D-96) suggested that examples of what is to be included be
specified in the proposed rulemaking, and also questioned whether
the category is too general for the purpose of defining emission
sources. The second commenter (IV-D-67) pointed out that this
category could be interpreted to be broad; that is, it may refer
to paint application on both domestic and commercial sealers.
The third commenter (IV-D-124) suggested that the determination
of applicability would be much improved by better defining and
clarifying the scope of this category. The commenter felt this
clarification is necessary to improve an industry's ability to
determine applicability and to limit EPA's involvement in having
to make determinations for them. The last commenter (IV-D-66)
thought the category is ill-defined and that it requires
additional defining to exclude small surface coating operations,
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and supported that statement with three reasons. First, many of
these sources will be regulated under Title I. Second, the
qualifier "general solvent uses" is redundant and ill-conceived;
this perception might lead to the inclusion of solvent usage not
having to do with surface coating operations, such as maintenance
degreasing at a plant that uses a dry, electrostatic powder
surface coating operation. Third, based on the industry
commenter's evaluations, the small quantity sources that remain
do not warrant regulation under this section of the CAA
amendments.
Response: Upon review of the source categories contained in the
Surface Coating Processes industry group, EPA agrees that the
source category Surface Coating Operations - General Solvent Uses
is potentially redundant and has deleted this category from the
list. Instead, specific surface coating processes are listed.
Comment: One commenter (IV-D-78) wanted EPA to create a
subcategory within this category for the "high-rise building
construction and bridge structural steel fabrication industry."
The commenter stated that differences unique to this industry
make it difficult to apply control technologies to this industry
in other surface coating operations, and thus it warrants a
separate subcategory. As a result of defining this new category
and developing control technologies, the commenter thought that
the subcategory's major sources should not be addressed in
maximum achievable control technology (MACT) standards until the
10-year bin.
Response: Emission sources associated with high rise building
construction and bridge structural steel fabrication are intended
to be included as part of a newly listed category entitled
Miscellaneous Metal Parts. The listing of these sources within a
broader category does not limit EPA's ability to evaluate
distinct operations associated with these sources. After
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listing, nothing precludes further clarification during standards
development, since the CAA allows distinction for classes, types,
and sizes within a category or subcategory where necessary to
develop appropriate emission standards.
Comment; One commenter (IV-G-04) suggested EPA change the title
to Surface Coating Operations - Other if their intent is to
regulate sources not mentioned specifically under this industry
group. If the intention is that "plastic part" surface coaters
meet both category standards, then this would represent
duplication by EPA and would not be fair, according to the
commenter.
Response; The source category Surface Coating Operations -
General Solvent Uses was determined to be duplicative with
respect to other listed categories in the Surface Coating
Processes industry group and it will be deleted from the list.
Final Disposition; Surface Coating Operations - Genereil Solvent
Uses has been deleted from the list due to redundancy with
existing source categories within the Surface Coating Processes
industry group.
7 . 3 Fabric Coating
Comment; One commenter (IV-D-102) surveyed the industry for
information and requested that EPA remove specific HAP's from the
Fabric Coating category. The results of the survey showed the
absence of these HAP's within the textile screen printing
industry.
Response; The approach used to list Fabric Coating as a source
category identified at least one major source based on its HAP
emissions. The deletion of particular HAP's related specifically
to textile screen printing processes has no impact on the listing
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of the category as a whole. However, Fabric Coating has been
deleted as a separate source category and is now included in The
Printing, Coating and Dyeing of Fabrics Source Category.
Final Disposition; Fabric Coating has been deleted as a separate
source category. Emission sources associated with Fabric Coating
have been included within the scope of the Printing, Coating, and
Dyeing of Fabrics source category.
7.4 Paper Coating
Comment: None
Final Disposition: This source category has been renamed Paper
and Other Webs (Surface Coating).
7.5 Large Appliance
Comment: None
Final Disposition; This source category has been renamed Large
Appliance (Surface Coating).
7 . 6 Magnet Wire
Comment: None
Final Disposition; This source category has been deleted as a
distinct category and will now be included within the scope of
Miscellaneous Metal Parts and Products (Surface Coating).
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7.7 Auto and Light Duty Truck
Comment: One commenter (IV-D-103) requested that EPA delete
benzene as a pollutant in this category because it is present in
only trace amounts, even though it would not change the listing
status of this category. This is an example of a problem that
the commenter wanted to point out, concerning HAP emisision levels
not being quantified and included in the rulemaking.
Response; The listing requirements of the CAA do not require
that emission levels for each HAP be quantified and included in
the listing procedure for each source category. Auto and Light
Duty Truck has been identified as a source category containing a
major source, and the deletion of benzene as a pollutamt does not
affect the listing.
Final Disposition; This source category has been renaimed Auto
and Light Duty Truck (Surface Coating).
7.8 Metal Can
Comment; One commenter (IV-D-53) had two comments regarding this
category: (1) There are criteria to justify subcategorizing the
broad matrix of manufacturing activities into one Metal Can
Surface Coating group with 10 distinct processes; and (2) EPA is
urged to adopt these subcategories already established by New
Source Performance Standards (NSPS) and Reasonably Available
Control Technology (RACT) in this industrial category, especially
where those subcategories are long-established and historically
have been relied on by facility operators and State air agencies.
The commenter provided supporting technical data and legislative
citations for the establishment of these subcategories under this
category by EPA.
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Response: Nothing precludes subcategorization during standards
development since the Clean Air Act allows distinction for
classes, types, and sizes within a category or subcategory where
necessary to develop the appropriate emission standards. The EPA
intends to refer to existing NSPS-and RACT-regulated activities,
to the extent practicable, for further describing this category
upon standards development.
Final Disposition: This source category has been renamed Metal
Can (Surface Coating).
7.9 Metal Coil
Comment: None
Final Disposition: This category has been renamed Metal Coil
(Surface Coating).
7.10 Wood Furniture
Comment: One commenter (IV-D-84) requested that EPA allow
submission of an independent study, completed in September 1991,
to help in the determination of categorization and
subcategorization for the furniture industry.
Response: Nothing precludes further subcategorization during
standards development, since the CAA allows distinction for
classes, types, and sizes within a category or subcategory where
necessary to develop the appropriate emission standards.
Therefore, EPA will maintain this source category on the list,
and use, upon review and acceptance, information submitted by the
furniture industry for further redefining of this category during
standards development.
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Final Disposition; This category has been renamed Wood Furniture
(Surface Coating).
7.11 Metal Furniture
Comment: One conunenter (IV-D-84) requested that EPA allow
submission of an independent study, completed in September 1991,
to help in the determination of categorization and
subcategorization for the furniture industry.
Response; Nothing precludes further subcategorization during
standards development, since the CAA allows distinction for
classes, types, and sizes within a category or subcategory where
necessary to develop the appropriate emission standards.
Therefore, EPA will maintain these source categories on the list,
arid use, upon review and acceptance, information submitted by the
furniture industry for further redefining of this category during
standards development.
Final Disposition; This category has been renamed Metal
Furniture (Surface Coating).
7.12 Flat Wood Products
Comment; One commenter (IV-D-84) requested that EPA allow
submission of an independent study, completed in September 1991,
to help in the determination of categorization and
subcategorization for the furniture industry.
Response: Nothing precludes further subcategorization during
standards development, since the CAA allows distinction for
classes, types, and sizes within a category or subcategory where
necessary to develop the appropriate emission standards.
Therefore, EPA will maintain these source categories on the list,
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and use, upon review and acceptance, information submitted by the
furniture industry for further redefining of this category during
standards development.
Final Disposition: This source category has been renamed Flat
Wood Paneling (Surface Coating).
7.13 Plastic Part
Comment; One commenter (IV-G-15) stated a concern about the lack
of definition in the Plastic Part category. They believed it
should be made clear that the rules are not intended to regulate
the coating of plastic or nonplastic parts in the same booth.
They cited a court decision in Ohio to substantiate their claim
on the subject. Another commenter (IV-D-103) was concerned about
the broadness and differences from one source to another. The
commenter thought a distinction needed to be made between the
types of parts being coated. To accomplish this, the commenter
suggested that EPA clearly stated how it will utilize
subcategories in the final rule.
Response; Precise descriptions for each source category and the
emission sources that are intended to be included in them are
part of the final rule establishing a standard for the category.
Sufficient information was not available to define appropriate
and consistent subcategories for most broad categories included
on the initial list. Nothing precludes further subcategorization
during standards development, since the CAA allows distinction
for classes, types, and sizes within a category or subcategory
where necessary to develop appropriate emissions standards. As a
result, the inclusion of emission sources within a broader source
category does not limit EPA's ability to evaluate distinct
operations and processes associated with these sources.
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Final Disposition; This source category has been renamed Plastic
Parts and Products (Surface Coating) to provide more description.
7.14 Large Ship
Comment: None
Final Disposition: This source category has been renamed
Shipbuilding and Ship Repair (Surface Coating) to provide more
description.
7.15 Large Aircraft
Comment: None
Final Disposition: This source category has been renamed
Aerospace Industries.
7.16 Printing/Publishing
Comment: Two commenters (IV-D-50, IV-D-70) gave input on the
category of Printing/Publishing. The first commenter (IV-D-50)
proposed two actions: (1) to create a separate industry group
named Graphic Arts, and (2) to include under this industry group
subcategories of all the major printing processes. The commenter
urged EPA to consider the chemicals, inks, and potential HAP's as
sufficiently distinct for the creation of a Graphic Arts category
with each printing process as a subcategory. This would reduce
confusion by providing uniformity with the applications of
Prevention of Significant Deterioration (PSD), NSPS, and
nonattainment regulations, in accordance with previous control
technology guidelines (CTG's) and RACT/LAER (Lowest Achievable
Emission Rate) guidance.
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The second commenter (IV-D-70) suggested Graphic Arts
Electroplating as a subcategory in the Printing/Publishing
category, and agreed with the first commenter's suggestion to
subcategorize the printing processes.
Response; Regarding appropriate disaggregation, EPA acknowledges
that there are different types of printing/publishing processes
within this source category. However, the CAA allows EPA to
distinguish between classes, types, and sizes within a category
or subcategory where necessary to develop appropriate emission
standards. Where applicable and to the extent practicable, EPA
will define categories and subcategories that conform to those
defined under existing regulations, such as those for the graphic
arts industries.
Final Disposition: This source category has been renamed
Printing/Publishing (Surface Coating).
7.17 Architectural
Comment; One commenter (IV-D-96) argued that applying
architectural paints and coatings to structures or products
should not be regulated as stationary sources (major or area), as
defined by the CAA. The commenter noted that "a stationary
source...is any building, structure, facility, or installation
which emits or may emit any air pollutant..." Consequently, it
would appear the CAA does not authorize the regulation of
Architectural paints and coatings as products under Section 112,
according to the commenters' interpretation. Therefore, the
commenter recommended deleting this as a source category.
Response: The EPA concurs with the commenter's recommendation
to delete Architectural coatings from the list of categories due
to the inconsistency the category has with the CAA definition for
stationary sources.
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Final Disposition; This source category has been deleted from
the list of source categories.
7.18 Magnetic Tapes
Comment: None
Final Disposition; This source category has been renamed
Magnetic Tapes (Surface Coating).
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8.0 WASTE TREATMENT AND DISPOSAL
General Comments
Comment; Four commenters (IV-D-28, IV-D-77, IV-D-107, IV-D-09)
agreed with the Agency's position that solid waste incinerators
should not be included on the list because of Congress1
determination that these sources should be regulated exclusively
under the authority of Section 129 of the Clean Air Act (CAA).
Two commenters (IV-D-77, IV-D-107) concurred with EPA for the
same reasons, that municipal waste combustors should not be
listed, and one commenter (IV-D-107) said that medical waste
incinerators should not be listed.
Response: The EPA has not listed most solid waste incineration
source categories, opting, after review, to preserve the
requirements established in existing regulatory activities under
Section 129 of the CAA involving these sources. The Section 129
standards are based on maximum achievable control technology
(MACT). The exceptions are sewage sludge incineration and
hazardous waste incineration units, which are listed because they
are not listed under Section 129 of the Clean Air Act, and
because they contain major sources.
Comment: One commenter (IV-D-43) requested clarification
regarding how this industry applies to pharmaceutical
manufacturing plants with on-site wastewater treatment systems.
Response; Each source category within this industry group has
been described to make it clear what processes and emissions are
intended to be regulated.
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Comment; One commenter (IV-D-66) stated that regulation under
Section 112 is not warranted because most of the Waste Treatment
and Disposal sources are regulated under separate EPA programs
that provide for extremely tight control of emissions.
Response: Where regulations exist for some source categories,
EPA has reviewed, and will continue to review that regulatory
activity to determine its applicability and consistency with
Section 112 of the CAA. However, in many cases it will be
appropriate to regulate a source under Section 112 to accomplish
the purpose of controlling hazardous air pollutant (HAP)
emissions to a level achievable using MACT. The same source may
also be regulated under other authorities (such as the Resource
Conservation and Recovery Act [RCRA]) for other concerns. EPA
has no general discretion not to list categories of waste treat-
ment and disposal that may be regulated under other authorities
than Section 112, except for categories covered under 129.
Comment; One commenter (IV-D-109) observed that chlorine is a
category within the industry group for Production and Use of
Inorganic Chemicals and also is utilized in several categories
within the Waste Treatment and Disposal industry group. The
commenter's concern was that even though the technology that is
or can be applied to regulating chlorine emissions in a chlorine
production facility is different from technology applied in a
chlorine use facility, the EPA may intend to regulate chlorine in
the same fashion, regardless of whether the facility uses or
produces chlorine.
Response: The CAA allows EPA to distinguish between classes,
types, and sizes within a category or subcategory where necessary
to meet the purposes of MACT. Also, each source category
appearing on the final list will be defined to make it clear what
processes and emissions are intended to be regulated. As each
source category (and each type or class of source within each
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category) is considered for regulation, EPA will assess the
applicability of potential control technologies. Also the
selected MACT may be different for different types or classes of
sources emitting the same pollutant.
Comment; One commenter (IV-D-110) argued that it is not
necessary to list commercial and industrial solid waste
incinerator facilities because they are hazardous waste
incinerators and subject to regulation under RCRA. Regulations
and standards already exist and additional regulation of the
facilities under the CAA is redundant.
Response: EPA is not listing commercial and industrial solid
waste incineration because of provisions in Section 129
precluding listing of categories subject to Section 129.
Hazardous Waste Incinerators are listed because they are not
subject to regulation under Section 129 and because of the
existence of major sources in the category. Also, EPA cannot
omit a category because it is subject to regulation under RCRA;
however, Section 112(n)(7) requires EPA to take into account and
be consistent with any regulations promulgated under RCRA when
establishing MACT.
8.1 Solid Waste Disposal - Open Burning
Comment; None
Final Disposition: This source category has been deleted from
the list since, upon review, no evidence was found to document a
major source within this category.
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8.2 Sewage Sludge Incineration
Comment: Three commenters (IV-D-101, IV-D-114, IV-D-77)
requested the removal of Sewage Sludge Incineration from the
Waste Treatment and Disposal industry group because emissions of
HAP's from sewage sludge incineration are already regulated under
the Clean Water Act (40 CFR 503), and new source performance
standards (NSPS) exist for sewage sludge incinerators [40 CFR 60
(O)]. One of the commenters also stated that national emissions
standards for hazardous air pollutants (NESHAP) for particulate,
beryllium, and total mercury have been established for Sewage
Sludge Incinerations under Section 112 of the CAA. By removing
this category from the list, duplication of effort will be
avoided.
Response: The EPA does not have the discretion to not list this
category even though standards exist, or are being established,
under the Clean Water Act or under NSPS. EPA will evaluate any
existing standards during regulation when determining MACT floors
for this category. In addition, NSPS regulatory activity applies
only to new sources, and under Section 112, EPA is required to
develop emission standards based on MACT for new and existing
sources.
Comment; One commenter (IV-D-77) requested that EPA postpone
listing sewage sludge incinerators as a regulated category until
sufficient data has been gathered to demonstrate that this
category warrants regulation as a major or area source under
Section 112(d). The data used as a basis for including this
source category on the draft source category list were based on
speciation profiles of poor quality, and it appears the data were
derived from a single facility. The commenter thought EPA should
also consider controls in evaluating whether a source emits or
has the potential to emit 10 tons per year (tpy) or more of a HAP
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or 25 tpy or more of a combination of HAP's, and also when
determining whether an area source warrants regulation under
Section 112(d).
The commenter also stated that EPA should collect
sufficient data to correctly distinguish among sewage sludge
incineration subcategories before listing or regulating HAP
emissions from these operations under Subsection 112(d). Sewage
sludge is incinerated at many different types of facilities,
which, in turn, employ various combustion technologies. For
example, an incinerator that will employ a Lurgi circulating
fluid bed boiler has substantially different operating parameters
and emissions compared to technologies used at many existing
sewage sludge incinerators, such as multiple hearth incinerators.
Response; While the listing of Sewage Sludge Incineration was
based, in part, on limited pollutant information using species
profiles, EPA has obtained additional data that support the
listing of this source category as a category of major sources.
Regarding the regulation of different types of facilities and
operations associated with sewage sludge incineration, Section
112(d)(l) of the CAA allows EPA to distinguish among classes,
types, and size of sources within a category or subcategory in
establishing emissions standards.
Final Disposition; The EPA has sufficient information indicating
that this source category contains a major source. Section 129
does not preclude the listing of this category under
Section 112(c). Therefore, Sewage Sludge Incineration will
remain on the list.
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8.3 Municipal Landfills
Comment: Three commenters (IV-D-09, IV-D-28, IV-D-8-77) stated
that municipal landfills should not be included in the Waste
Treatment and Disposal industry group. One commenter (IV-D-77)
thought that municipal landfills should not be included on the
list of major and area sources of HAP's until the Agency has
sufficient data to determine that they warrant regulation as
either a major or area source under Section 112(d). The draft
list states that the listing of municipal landfills "is based in
part on speciation profiles of relatively poor quality ranking"
(56 FR 28557) . The draft documentation appears to have only
considered emissions from two landfills. Additionally, the
emissions surveyed through EPA's National Emissions Data System
(NEDS) were not HAP's but rather criteria pollutants. Based on
this information, it is unclear that the HAP emissions from the
two facilities would qualify as major sources. The data
presented in the draft documentation also do not demonstrate that
emissions from municipal landfills present a threat of adverse
effects to human health or the environment, therefore the
criteria necessary to warrant an area source listing has not been
established.
Response: The CAA requires EPA to list categories of major
sources. The source category Municipal Landfills was identified
as a major source through the NEDS approach, as described in the
Supplementary Information Section of the June 21, 1991 Federal
Register notice. While the listing of Municipal Landfills was
based, in part, on speciation profiles of relatively poor
quality, EPA believes a profile need only be representative of
one or several sources within a category in order to qualify that
source category for inclusion on the list.
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Comment: Two commenters (IV-D-09, IV-D-28) stated that municipal
landfills should not be included in the Waste Treatment and
Disposal industry group because the Agency had proposed to
regulate municipal landfills under Section 111 (56 FR 24468) and
deliberately chose not to regulate municipal solid waste
landfills under Section 112 (53 FR 33314) or under RCRA. One
commenter stated that when this decision was made, EPA was
cognizant that Section 112 of the CAA (which can be used to
develop NESHAP) could have been used. However, given the
uncertainty and difficulty in setting standards under Section
112, EPA decided to proceed with standards development under
Section 111.
Another commenter (IV-D-77) stated that EPA should delay
listing municipal landfills on the Section 112(c) source category
list until after the impact of the recently proposed NSPS and the
Section lll(d) guidelines on HAP emissions from municipal solid
waste (MSW) landfills can be evaluated. The proposed NSPS
rulemaking and guidelines would establish controls on the
emissions of nonmethane organic compounds from MSW landfills. In
order to list municipal landfills, EPA must demonstrate that
municipal landfill HAP emissions remaining after imposition of
the NSPS warrant regulation as major or area sources under
Section 112(d) of the CAA.
Response; The CAA requires EPA to list categories of major
sources and, to the extent practicable, be consistent with the
listing of source categories pursuant to Section 111. The
decision not to regulate landfills under Section 112 had to be
recommended in light of the new NESHAP requirements as set forth
in the CAA Amendments of 1990. A review of existing and proposed
regulatory activity under Section 111 and NSPS rulemakings
involving municipal landfills indicated that all Section 112
listed HAP's and source identification requirements would not be
addressed by this activity; therefore, Municipal Landfills was
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included on the list. The EPA will, however, consider NSPS and
Section 111 regulatory activity upon the development of standards
for this category.
Comment: One commenter (IV-D-77) asked EPA to develop
appropriate subcategories based on the different types of solid
waste disposed at municipal landfills because HAP emissions from
landfills can vary depending on the types of solid waste that are
disposed in the landfill.
Response: Section 112 (d)(1) of the CAA allows EPA to
distinguish among classes, types, and sizes of sources within a
category or subcategory in establishing emission standards.
Final Disposition: Through the listing procedures, EPA has
identified that this source category contains a major source.
Therefore, Municipal Landfills will remain on the list.
8.4 Groundwater Cleaning
Comment: Three commenters (IV-D-09, IV-D-66, IV-D-77) suggested
further wording to define what the EPA intends to include in this
category. Commenter IV-D-09 posed concerns regarding water
treatment devices used in groundwater remediation projects.
These projects tend to be site-specific and unique for each
installation, and the constituent mix, amounts, and exposure
scenarios vary dramatically. The second commenter (IV-D-66)
thought that differentiation by class, type and size, quantity,
arid nature of influent or material treated is necessary so that
facilities that are not sources of HAP's are not included in the
category. The third commenter (IV-D-77) recommended that each
different type of groundwater cleaning activity be considered as
separate subcategories because each activity may have different
levels and types of emissions and different technologies to
control HAP's.
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Response: This source category has been deleted from the list as
a separate source category but will be included in the scope of
the Site Remediation source category. The source category will
be concisely described during rulemaking to clarify what
processes will be regulated.
Comment; Three conunenters (IV-D-62, IV-D-66, IV-D-77) stated
that groundwater cleaning operations should not be included on
the list of categories because EPA has not demonstrated that
groundwater cleaning operations warrant regulation as a major
source of air toxics. The Agency does not provide data in the
Draft Documentation showing that such operations emit greater
than the 10/25 tpy cutoff. Two of the commenters (IV-D-62,
IV-D-77) questioned whether groundwater cleaning is actually an
area source category because EPA has not demonstrated that
groundwater cleaning operations present an adverse threat to
human health or the environment. Further study of HAP emissions
from these operations is requested.
Response; Groundwater cleaning operations are to be included
under the description of the category Site Remediation, which
will be provided as part of the final listing action. An EPA
study report entitled "Air Stripping of Contaminated Water
Sources - Air Emissions and Controls" (EPA-450/3/87-017) was
used to identify major source emissions from these operations.
This study will be part of the supporting docket reference for
the listing of the Site Remediation category.
Comment; One commenter (IV-D-14) recommended that the category
Groundwater Cleaning be revised to Groundwater Remediation at
Federal or State Designated Hazardous Waste Sites.
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Response; Emission sources associated with groundwater cleaning
will be included in the scope of the category Site Remediation.
Within the description of this category, EPA has included
applicable groundwater remediation activities that are associated
with Federal- and State-designated hazardous waste sites.
Comment; One commenter (IV-D-66) observed that groundwater
cleaning is not a waste treatment operation. Groundwater is a
resource and if it is being cleaned to remove a contaminant,
cilthough this operation may generate a waste, it is the
beneficiation and improvement of this resource which is the
motivation. In situ groundwater cleaning frequently involves the
destruction of any contaminants that are present, and not their
release to the air. Even groundwater cleaning systems, which
involve the extraction of groundwater, treatment, and
reinjection, do not result in emissions of HAP's unless those
contaminants being cleaned are volatile.
Response: The CAA directs EPA to list major and area emission
sources of HAP's, and in doing so, major sources associated with
groundwater cleaning activities have been identified. There are
no further requirements of the CAA that would preclude the
listing of these sources.
Comment: One commenter (IV-D-75) noted that facilities at
mineral processing operations that may overlap the groundwater
cleaning category should be excluded from the list because they
do not emit the pollutant of concern. The EPA listed groundwater
cleaning for ethylidene dichloride, which is not present in
metals cleaning systems.
Response; The listing of groundwater cleaning for ethylidene
dichloride emissions does not limit EPA's ability to identify any
and all HAP's that are associated with emission sources within
the category of Site Remediation.
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Comment; One commenter (IV-D-124) requested a clearer definition
of the groundwater cleaning category so as to improve each
industries ability to determine applicability. Further
clarification of the scope of this category is also requested.
The duration of groundwater cleanup projects should be
considered, with an exemption for projects of less than 12
months, because remediation projects can be of short duration.
Response: Groundwater cleaning emission sources will be clearly
described and included in the category Site Remediation. Also,
upon standards development, the CAA allows EPA to distinguish
among classes, types, and sizes of sources within a category or
subcategory, and it is at that time that such considerations as
duration of cleanup projects will be considered.
Final Disposition: Groundwater cleaning has been deleted as a
separate source category and will be included in the scope of the
Site Remediation source category.
8.5 Hazardous Waste Incineration
Comment: Three commenters (IV-D-28, IV-D-66, IV-D-110) noted
that Hazardous Waste Incineration should not be included in the
Waste Treatment and Disposal industry group because of the
Agency's prior actions to regulate air emissions for this source
solely pursuant to RCRA (55 FR 17863). When standards were
proposed for the burning of hazardous waste in boilers and
industrial furnaces (56 FR 7134), EPA recognized the limitations
imposed upon it by Congress pursuant to Section 112(n)(7).
Response: The EPA has reviewed existing regulatory activity
involving the Hazardous Waste Incineration source category,
including the promulgated boiler and industrial furnace rule
(56 FR 7134) and concluded that it does not completely fulfill
the requirements of Section 112 so as to preclude the listing of
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the category here. During Section 112 regulatory development EPA
will, however, take into account any RCRA regulatory activity to
ensure consistency in regulating emissions for hazardous waste
incinerators.
Comment: Two commenters (IV-D-62, IV-D-66) recommend that EPA
delete the hazardous waste incineration category from the list
because there is either insufficient data available or the
category was not identified with sufficient precision to warrant
inclusion.
Response; The CAA requires EPA to list categories of major
sources. The EPA is confident that the Hazardous Waste
Incineration category contains a major source. Therefore, this
source category will remain on the list.
Comment; One commenter (IV-D-62) questioned whether Hazardous
Waste Incineration is actually an area source category.
Response; The EPA has information indicating that this source
category contains at least one major source.
Comment; One commenter (IV-D-114) stated that the Hazardous
Waste Incineration category should be further divided into groups
of incinerators that burn similar types of materials together
(e.g., polychlorinated biphenyls). The commenter claimed that
the creation of subcategories would facilitate the regulation of
emissions from incinerators that burn similar materials while
maintaining overall consistency within the categories.
Response; Section 112 (d)(1) of the CAA allows EPA to
distinguish among classes, types, and sizes of sources within a
category or subcategory in establishing emission standards.
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Where appropriate, EPA would make such distinctions in the
Hazardous Waste Incineration category during regulatory
development.
Final Disposition: This source category will remain on the list.
8.6 Tire Burning
Comment; One commenter (IV-D-45) requested that the Tire Burning
category be subdivided such that one category be specified for
facilities where tires represent more than 50% of the heating
load and a separate category where tires represent less than 50%
of the heating load, because MACT will be different for both
categories.
Response: Tire Burning has been deleted from the list since no
evidence was found to document that this source category contains
a major source.
Final Disposition; The EPA has no information indicating that
this source category contains a major source. Therefore, Tire
Burning has been deleted from the list.
8.7 Tire Pyrolysis
Comment; None
Final Disposition; Upon review, EPA found no evidence indicating
that this source category contains a major source. Therefore,
Tire Pyrolysis has been deleted from the list.
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8.8 Cooling Water Chlorination - Steam Electric Generators
Comment; Two commenters (IV-D-77, IV-D-88) recommended that the
EPA not list utility Cooling Water Chlorination as a category.
Commenter IV-D-77 asked the EPA not to list this source category
until there is sufficient data available to demonstrate that this
category warrants regulation, under Subsection 112(d), as a major
source emitting more than the 10/25 tpy cutoff of HAP's or area
sources that present a threat of adverse effects to human health
or the environment. In addition, the second commenter (IV-D-88)
stated that if this category is listed, then Municipal Drinking
Water Chlorination and Swimming Pool Chlorination should also be
categories. The commenter suggested that an EPA study include
the Chlorination of drinking water as one of the largest sources
of risk.
Response; Cooling Water Chlorination-Steam Electric Generators
has been deleted from the list due to the lack of information
indicating this source category contains a major source.
Final Disposition: Upon review, EPA found no evidence indicating
that this source category contains a major source. Therefore,
Cooling Water Chlorination-Steam Electric Generators has been
deleted from the list.
8.9 Wastewater Treatment Systems
Comment; Five commenters (IV-D-11, IV-D-77, IV-D-85, IV-D-101,
IV-D-130) requested that the EPA establish a subcategory for
Publicly Owned Treatment Works (POTW's). The concern is that the
EPA may not be consistent with provisions under the CAA, Section
112(e)(5) and Section 112(n)(3), if there is only one category
for wastewater treatment systems. These CAA sections provide
POTW's up to 5 years from the date of CAA enactment to quantify
air emissions, demonstrate new technology-based standards, and
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ensure adequate input from POTWs when control requirements are
developed. Commenter (IV-D-77) observed that Congress did not
intend for EPA to regulate POTWs in the same manner as other
wastewater treatment systems.
Response: The EPA agrees with these commenters and has limited
the Wastewater Treatment Systems source category to Publicly
Owned Treatment Works (POTW) emissions. The EPA will study
emissions from POTW's according to Section 112(n)(3) and
promulgate standards regulating such emissions not later than
5 years after the enactment of the CAA amendments of 1990. A
category named Publicly Owned Treatment Works (POTW) Emissions
has been added to the list.
Comment; One commenter (IV-D-33) thought that the Wastewater
Treatment Systems category is too broad and the applicable
emissions should be regulated under individual source categories
because this category is proposed as a separate emission point in
the synthetic organic chemical manufacturing industry (SOCMI).
Response; The commenter is correct in saying that wastewater
treatment of SOCMI facilities will be regulated as part of the
source categories associated with EPA's Hazardous Organic NESHAP
(HON) project. In addition, EPA has decided to limit Wastewater
Treatment Systems to POTW emissions.
Comment; Two commenters (IV-D-43, IV-D-83) requested
clarification regarding how this category applies to
pharmaceutical manufacturing plants with on-site wastewater
treatment systems. Such plants would be subject to MACT
standards for the pharmaceutical source category. Would a
pharmaceutical facility's wastewater treatment operation then be
classified under the wastewater standard, or as part of the
overall pharmaceutical standard, as in the case of HON?
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Response; Wastewater Treatment Systems has been limited to POTW
emissions; EPA intends to regulate wastewater treatment systems
through the applicable, listed source categories that contain
these systems. For example, a pharmaceutical facility's
wastewater treatment operation would be included and regulated
within the scope of that source category. In addition, EPA will
be conducting a study of emissions from POTWs according to the
direction given in Section 112 (n)(3) of the CAA.
Comment; Three commenters (IV-D-48, IV-D-66, IV-D-77) thought
that there is insufficient data available to warrant listing
Wastewater Treatment Systems as a source category. One commenter
(IV-D-77) urged EPA to conduct further studies before listing
the appropriate categories or establishing standards for POTW's.
Response: For the reasons described above, EPA has limited
Wastewater Treatment Systems as a source category to POTW
emissions.
Comment; One commenter (IV-D-66) felt that differentiation by
class, type and size, quantity, and the nature of the material
treated in the wastewater stream is necessary so that facilities
that are not sources of HAP's will not be included in the
category.
Response: For the reasons described above, EPA has limited
Wastewater Treatment Systems as a source category to POTW
emissions. In addition, the CAA allows EPA to distinguish
between classes, types, and sizes of emission sources within a
category or subcategory upon development of emission standards.
Therefore, differences in wastewater treatment operations will be
considered under the appropriate category during regulatory
development.
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Comment: Two commenters (IV-D-66, IV-D-75) noted that the EPA
has listed wastewater treatment systems for a number of
pollutants not present in systems used at their facilities. One
commenter (IV-D-66) operates small-batch wastewater pretreatment
systems to remove contaminants from metal finishing to comply
with effluent guidelines and says that these systems do not
result in the emissions of HAP's. The second commenter operates
wastewater treatment systems at mineral processing facilities.
The commenters believed the final listing should exclude plants
that do not emit the pollutants of concern.
Response; For the reasons described above, EPA has limited
Wastewater Treatment Systems as a source category to POTW
emissions.
Comment; One commenter (IV-D-77) also suggested that EPA
evaluate the AB 2588 data base of air toxics emissions when
assessing HAP emissions from POTWs located in California. AB
2588 is the data base that contains the air toxics information
gathered pursuant to the requirements of the Air Toxics Hot Spot
Information and Assessment Act of 1987. The commenter believes
that AB 2588 is a more reliable source of information on HAP
emissions from POTW's located in California than any of the
information sources referenced in the draft documentation.
Response: EPA will be conducting a study of emissions from
POTW's according to the direction given in Section 112(n)(3) of
the CAA.
Comment: Two commenters (IV-D-104, IV-D-114) suggested that the
EPA define how broad the wastewater treatment category is and
clarify whether the applicable emissions attributed to wastewater
treatment should be regulated under individual source categories
that are identified elsewhere on the preliminary list.
Otherwise, EPA should define how the overlap of categories that
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are defined in terms of a particular type of equipment or
activity that is common to a variety of different industrial
operations should be handled.
Response; For the reasons described above, EPA has limited
Wastewater Treatment Systems as a source category to POTW
emissions.
Comment: Two commenters (IV-D-77, IV-D-114) recommended that the
Wastewater Treatment Systems category be subdivided into
Industrial and Municipal Wastewater Treatment Operations to
reflect the variety of operations and types of discharges into
wastewater treatment facilities as well as the variety in the
character and the amount of hazardous emissions from the two
operations. Commenter IV-D-114 stated that further category
division will allow wastewater treatment sources that result in
large emissions, or emit particularly hazardous pollutants, to be
targeted for early regulation, while allowing less significant
emissions to be deferred for later regulation. The commenter
also recommended dividing Industrial Wastewater Treatment into
subcategories according to the applicable industry, or to
restrict the wastewater treatment category to municipal
wastewater treatment facilities and to regulate the hazardous
emissions from industrial wastewater treatment under the source
generating the waste water.
Response; For the reasons described above, EPA has limited
Wastewater Treatment Systems as a source category to POTW
emissions.
Final Disposition; Wastewater Treatment Systems has been deleted
as a separate source category; however, EPA will regulate POTW
emissions which will encompass all or part of this previously
listed category. Those systems not associated with specific
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facilities under listed source categories may be included within
the scope of a new source category: Solid Waste Treatment,
Storage, and Disposal Facilities.
8.10 Water Treatment Purification Category
Comment: One commenter (IV-D-11) requested that the EPA
establish a subcategory for Municipal Water Treatment
Purification in order to reflect the differences between
Municipal Waste Treatment Districts and commercial and industrial
water purification systems.
Response; Water Treatment Purification has been deleted from the
list since no evidence was found to document that this source
category contains a major source.
Comment; One commenter (IV-D-11) requested that the EPA
promulgate standards for Municipal Waste Treatment Purification
at the same pace as POTW's under the CAA, Section 112(e)(5) and
112(n)(5), because current knowledge is so limited.
Response; Water Treatment Purification has been deleted from the
list since no evidence was found that this source category
contains a major source.
Comment; One commenter (IV-D-14) recommended that the water
treatment purification category be deleted from the list because
water treatment plants are a relatively minor source contribution
to air pollution. Very few of these plants would be classified
as a major source due to the major source emissions cutoff of
less than 10 tpy of any HAP's or 25 tpy of any combination of
HAP's. The commenter presented, as an example, the modeling data
presented in the proposed radon rule for drinking water. The
proposed rule designates aeration towers as the Best Available
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Control Technology (BACT) for removal of radon from drinking
water. None of the models developed a radon concentration in the
off-gas that presented a risk to public health.
Response: Water Treatment Purification has been deleted from the
list since no evidence was found that this source category
contains a major source.
Comment; One commenter (IV-D-66) recommended that EPA drop the
Water Treatment Purification category from the list because there
is either insufficient data available or the category was not
identified with sufficient precision to warrant inclusion. The
commenter also observed that water treatment purification is not
a waste treatment operation.
Response: Water Treatment Purification has been deleted from the
list since no evidence was found that this source category
contains a major source.
Comment; One commenter (IV-D-66) felt that differentiation by
class, type and size, quantity, and the nature of the material
treated is necessary so that facilities that are not sources of
hazardous air pollutants will not be included in this category.
Response: Water Treatment Purification has been deleted from the
list since no evidence was found that this source category
contains a major source.
Comment; One commenter (IV-G-04) stated that the Water Treatment
Purification category should be located within a more
appropriately titled industry group: Water and Waste Treatment
and Disposal.
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Response; Water Treatment Purification has been deleted from the
list since no evidence was found that this source category
contains a major source.
Final Disposition: Upon review, EPA found no information
indicating that this source category contains a major source.
Therefore, the Water Treatment Purification source category has
been deleted from the list.
8.11 Water Treatment - Boilers
Comment; Two commenters (IV-D-14, IV-D-88) recommended that the
Water Treatment - Boilers category be deleted from the list
because these sources have a relatively minor contribution to air
pollution. One commenter stated that very few of these plants
would be classified as a major source due to the major source
emissions cutoff of less than 10 tpy of any HAP's or 25 tpy of
any combination of HAP's. The commenter raised as an example the
modeling data presented in the proposed radon rule for drinking
water. The proposed rule designates aeration towers as the BACT
for removal of radon from drinking water. None of the models
developed radon concentrations in the off-gas that presented a
risk to public health.
Response: Water Treatment-Boilers has been deleted from the list
since no evidence was found that this source category contains a
major source.
Comment: Two commenters (IV-D-77, IV-D-66) recommended that EPA
drop the Water Treatment - Boilers category from the list because
there is either insufficient data available or the category was
not identified with sufficient precision to warrant inclusion.
The second commenter (IV-D-66) also observed that Water Treatment
- Boilers is not a waste treatment operation. The first
commenter (IV-D-77) suggested, as an alternative to deleting this
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category, that EPA provide additional data to demonstrate that
this category warrants regulations as major or area source under
Subsection 112(d).
Response; Water Treatment - Boilers has been deleted from the
list since no evidence was found that this source category
contains a major source.
Comment: One commenter (IV-D-66) felt that differentiation by
class, type and size, quantity, and nature of the influent
treated is necessary so that facilities that are not sources of
hazardous air pollutants are not included in the category.
Response; Water Treatment - Boilers has been deleted from the
list since no evidence was found to document that this source
category contains a major source.
Comment: Two commenters (IV-D-75, IV-D-77) said that the EPA has
listed water treatment boilers for hydrazine, which is not
present in boilers at their facilities. The final listing should
be restricted to boilers that emit the pollutant of concern, or
the category should be defined to be inclusive of water treatment
boilers that use hydrazine as an oxygen scavenger.
Response; Water Treatment - Boilers has been deleted from the
list since no evidence was found to document that this source
category contains a major source.
Comment: One commenter (IV-G-04) said that the Water Treatment -
Boilers category should be located within a more appropriately
titled industry group: Water and Waste Treatment and Disposal.
Response; Water Treatment-Boilers has been deleted from the list
since no evidence was found to document that this source category
contains a major source.
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Final Disposition; Upon review, EPA found no evidence to
document that this source category contains a major source.
Therefore, the Water Treatment - Boilers category has been
deleted from the list as a category of major sources.
B-lll
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9.0 AGRICULTURAL CHEMICALS PRODUCTION AND USE
General Comments
Comment: One commenter (IV-D-93) suggested that inconsistent
interpretations can be made for the categories from the industry
group heading as to whether they qualify under production or
under use. To clarify this question, the commenter recommended
removing "Production" from the industry group heading and instead
listing the group as Agricultural Chemicals.
Response: This industry group has been renamed Agricultural
Chemicals Production to specify what processes will be included
as source categories.
Comment; One commenter (IV-D-66) noted a lack of definition
concerning "Production," "Use," and "Production and Use" within
the source categories included under this industry group. The
commenter suggested to EPA that all categories under this
industry group be separated into "Manufacture" and "Formulation"
and that all ultimate end-uses of these products should be
deleted as source categories. Also, the "Formulation" activities
that result in a category should be differentiated or
subcategorized according to the type of end product.
Response; End use of products in this industry group has been
deleted because it is an ill-defined application. This industry
group has been disaggregated into production type processes, not
use or formulation type processes. The industry group has been
renamed Agricultural Chemicals Production.
Comment: One commenter (IV-D-121) noted that pesticide and
herbicide manufacturing categories and subcategories should be
disaggregated by production and then by formulation of a liquid
B-112
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or solid product. Also, the same commenter (IV-D-121) suggested
adding Fugitive Emissions as a subcategory under the pesticides
manufacturing areas.
Response: As a result of comments received, this industry group
has been disaggregated into production type processes, not end
use applications. In addition, formulation is a distinct type of
process not usually associated with production and is therefore
not used to disaggregate source categories. However, nothing
precludes further clarification during standards development
since the Clean Air Act (CAA) allows distinction for classes,
types, and sizes within a category or subcategory where necessary
to meet the purposes of maximum achievable control technology
(MACT). Fugitive emissions are one of several emission source
types within a source category and will be addressed under
individual source categories.
9.1 2,4-D Salts and Esters Production
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
9.2 4,6-Dinitro-o-cresol Production
Comment: None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
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9.3 4-Chloro-2-Methylphenoxyacetic Acid Production
Comment: None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
TM
9.4 Baygon Production
Comment: None
Final Disposition; This source category has been deleted from
the list because no major source was confirmed in the source
category.
9.5 Captafol Production
Comment; None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
9.6 Captan Production
Comment: None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
9.7 Carbamate Insecticides Production
Comment; One commenter (IV-D-66) urged EPA to differentiate or
subcategorize among Carbamate Insecticides Production processes.
The commenter stated that this would exclude "neat" carbomylation
processes from the category list because they result in less than
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5 tons per year (tpy) of hazardous air pollutant (HAP) emissions,
thus making them area sources. Derivatives of Carbamate
Insecticide Production should also be excluded from the list
according to the commenter because the processes used to produce
them are sufficiently different.
Response: This source category has been deleted from the list
since, upon further review, no evidence was found to document
major sources within this category.
Final Disposition: This source category has been deleted from
the list because no major source was confirmed in the source
category.
9.8 Chlorothalonil Production
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
TM
9.9 Dacthal Production
TM
Comment: One commenter (IV-D-123) questioned why Dacthal
Production is on the draft list of source categories when it
does not appear to be one of the compounds on the CAA
Section 112 list. The commenter said it would be helpful for the
EPA to explain why these chemicals are included on the draft list
of source categories and subcategories. The commenter speculated
TM
that Dacthal Production was listed as a source category because
the production of this chemical requires ingredients or creates a
by-product that is a HAP on the Section 112 list.
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Response; This source category contains a major source emitting
carbon tetrachloride. Carbon tetrachloride is the particular
solvent used in the chlorination process for producing
TM
Dachthal .
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
9.10 Dichlorodiphenyltrichloroethane (DDT) Production
Comment: None
Final Disposition; This source category has been deleted from
the list because DDT production has been banned in the United
States so there is no reason to regulate production.
9.11 Fumigation Use
Comment; One commenter (IV-D-115) said the category Fumigation
Use should be deleted because it duplicated the categories Soil
Fumigant Use and Space Fumigant Use. Concerning the categories
Fumigation Use, Soil Fumigant Use, and Space Fumigant Use, the
commenter stated that the uses of these fumigants are already
regulated under the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA). Therefore, the commenter said that
fumigants should not be dually regulated both by FIFRA and the
CAA. According to the commenter, this dual regulation would
cause confusion to regulators and put unnecessary burden on
fumigant applicators.
Response: Fumigant Use is not included on the list as a source
category because it overlaps with several other source categories
in this industry group.
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Comment: One commenter (IV-D-123) urged EPA to be more specific
with respect to which HAP's produced by fumigation it intends to
designate as categories and subcategories in this industry group.
Response; No subcategorization or clarification is necessary in
this case, since this source category has been deleted from the
list. Furthermore, categorization has not been based on the
HAP's they emit.
Comment; One commenter (IV-D-123) questioned the term use when
describing the category Fumigation Use. The commenter's
confusion stemmed from what exactly is being used within the
category's name. The commenter urged EPA to be more specific in
this industry group with respect to which HAP's produced by
fumigation it intends to designate as categories and
subcategories within this industry group.
Response: This source category has been deleted from the list
because the end use is not anticipated to be regulated under
Title III of the CAA.
Final Disposition: This source category has been deleted from
the list due to overlap with other source categories in this
industry group.
9.12 Grain Fumigation Production
Comment; One commenter (IV-D-115) noted that the category Grain
Fumigation Production should be renamed Grain Fumigant
Production. Another commenter (IV-D-18) suggested that carbon
tetrachloride be added to this category as an emitted pollutant
based on the commenter's knowledge of the industry process.
Response: Although the recommended name change would have been
correct, this source category has been deleted from the list.
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Final Disposition; This source category has been deleted from
the list because no major source was confirmed in the source
category.
9.13 Metribuzin Production
Comment; None
Final Disposition; This source category has been deleted from
the list because no major source was confirmed in the source
category.
9.14 Parathion Use
Comment: None
Final Disposition; This source category has been deleted from
the list because production of parathion in the United States has
stopped; consequently, the EPA was unable to establish major
source documentation for this source category.
9.15 Pentachloronitrobenzene Production
Comment; None
Final Disposition; This source category has been deleted from
the list because no major source was confirmed in the source
category.
9.16 Pentachlorophenol Production
Comment: None
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Final Disposition: This source category has been deleted from
the list because it is a chemical regulated within the Synthetic
Organic Chemical Manufacturing industry group.
9.17 R-ll (Butadiene-Furfural-Cotrimer) Production
Comment; None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented. However,
it has been moved to the Polymers and Resins industry group and
has been renamed Butadiene-Furfural Cotrimer (R-ll).
9.18 Sodium Pentachlorophenate Manufacture
Comment; None
Final Disposition: This source category will remain on the list
but will be renamed Sodium Pentachlorophenate Production.
9.19 Soil Fumigant Use
Comment; One commenter (IV-D-115) noted that the use of
fumigants is already regulated under FIFRA. Therefore, the
commenter stated that fumigants should not be dually regulated
both by FIFRA and the CAA. According to the commenter, this dual
regulation would cause confusion to regulators and put
unnecessary burden on fumigant applicators.
Response: This source category has been deleted from the list
because, upon review, no evidence was found to document a major
source within this category.
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Comment; One commenter (IV-D-123) questioned the term "Use" when
discussing the category Soil Fumigant Use. The commenter's
confusion stemmed from what exactly is being used within the
category's name. The commenter urged EPA to be more specific in
this industry group with respect to which HAP's produced by
fumigation it intends to designate as categories and
subcategories within this industry group.
Response: This source category has been deleted from the list
because, upon review, no evidence was found to document a major
source within this category.
Final Disposition; This source category has been deleted from
the list because, upon review, no major source was confirmed in
the source category.
9.20 Space Fumigant Use
Comment: One commenter (IV-D-115) stated that the end uses of
fumigants are already regulated under FIFRA. Therefore, the
commenter stated that fumigants should not be dually regulated
both by FIFRA and the CAA. According to the commenter, this dual
regulation would cause confusion to regulators and put
unnecessary burden on fumigant applicators.
Response: This source category has been deleted from the list
because, upon review, no evidence was found to document major
sources within this catgeory.
Final Disposition; This source category has been deleted from
the list because no major source was confirmed in the source
category.
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9.21 Substituted Phenyl Ureas Production
Comment; None
Final Disposition; This source category has been deleted from
the list because no major source was confirmed in the source
category.
9.22 Thiocarbamates Production
Comment: None
Final Disposition; This source category has been deleted from
the list because no major source was confirmed in the source
category.
TM
9.23 Tordon Acid Production
Comment; None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
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10.0 FIBERS PRODUCTION PROCESSES
10.1 Acrylic Fibers/Modacrylic Fibers
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
10.2 Nylon Fibers
Comment: None
Final Disposition; This source category has been deleted from
the list because it was found to overlap with the Nylon 6
Production source category in the Polymers and Resins industry
group.
10.3 Rayon
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
10.4 Spandex
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
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10.5 Triacetate Fibers
Comment: None
Final Disposition; This source category has been deleted from
the list, because, upon review, no evidence was found to document
major sources within this category.
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11.0 FOOD AND AGRICULTURE INDUSTRY
Comment; One commenter (IV-D-13) requested that the Cellulose
Food Casing Industry be listed as a separate source category.
The commenter stated that there are only two companies in the
United States that use the Viscose process in the cellulose food
casing industry and that the Viscose process could be incorrectly
included under three different categories: (1) Fiber Production
Process - Rayon, (2) Polymers and Resin Production - Cellophane
Production, and (3) Production and Use of Inorganic Chemicals -
Carbon Bisulfide. The commenter added that significant
differences in the process/product quality requirements make the
effluent technology appropriate for the cellulose food casing
industry very different from the rayon, cellophane, and carbon
disulfide industries, thus justifying a separate category.
Response: Because evidence of a major source for this distinct
category has been documented, the category Cellulose Food Casing
Manufacturing has been added to the source category list, and
will be regulated under this industry group. The commenter
provided material that demonstrated differences in production
technology, characteristics of emissions, controls that may be
applied and the associated costs.
Comment: One commenter (IV-D-16) suggested using State Standard
Industrial Classification (SIC) codes rather than listing
industry groups for categories.
Response: Standard Industrial Classification codes are not
sufficiently detailed to identify distinct source categories.
For this reason, the EPA has not used them widely to implement
the CAA.
B-124
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Comment: One commenter (IV-D-133) suggested adding corn wet
milling and soybean processing to the list based on the hexane
emissions from these source categories.
Response; At this time, EPA has no information indicating that
Corn Wet Milling and Soybean Processing are major sources of
hexane emissions. For this reason, these two source categories
are not being added to the list.
11.1 Baker's Yeast Manufacturing
Comment; One commenter (IV-D-155) suggested broadening the
Baker's Yeast Manufacturing category to Yeast Manufacture and Use
or splitting the category into four categories: Bakers Yeast
Manufacturing, Brewers Yeast Manufacturing, Bakeries, and
Breweries.
Response: At this time, documentation of major sources exists
only for the Baker's Yeast Manufacturing category; the other
source categories cannot be listed without sufficient
documentation of such.
Final Disposition; The EPA has documentation indicating that
Baker's Yeast Manufacturing contains a major source. Therefore,
this source category will remain on the list.
11.2 Coffee Roasting
Comment: Two commenters (IV-D-10, IV-D-23) requested that Coffee
Roasting be deleted from the source category list. The first
commenter (IV-D-10) stated that emissions of hazardous air
pollutants (HAP's) from coffee roasting are not significant
enough to make this a major source category. This commenter
added that total aggregate HAP emissions in the U.S. from coffee
roasting do not pose a significant health risk which warrant
B-125
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listing coffee roasting as a category of area sources. The
second commenter (IV-D-23) requested that the source category
Coffee Roasting be deleted from the draft list because HAP
emissions do not exceed the defined de minimis levels and public
health risks do not exceed prescribed levels. The commenter
stated that alternatively, if the Coffee Roasting source category
is retained on the list, the EPA needs to include provisions in
the Federal operating permit program to exempt those sources with
de minimis levels of HAP emissions or public health risk.
Response: Coffee Roasting has been deleted from the list since
no evidence was found to document major sources within this
category.
Final Disposition; This source category has been deleted from
the list.
11.3 Cotton Ginning
Comment: The commenter (IV-D-129) requested that Cotton Ginning
be deleted from the source category list based on phosphorous
emissions because cotton ginning does not emit elemental
phosphorous. The commenter also requested that Cotton Ginning be
removed from the list of source categories for any listed
chemical because cotton gins are not a major source of any HAP's.
Response: This category has been documented as emitting arsenic
compounds; however, upon review, EPA found no information
documenting a major source within this category.
Final Disposition: This source category has been deleted from
the list since no evidence was found to document major sources in
this category.
B-126
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11.4 Prepared Food Manufacturing
Comment; One commenter (IV-D-16) requested that subcategories
under Prepared Food Manufacturing be developed to include other
support operation processes such as Can Manufacturing, Surface
Coating, Boilers, Wastewater Treatment Systems, Fumigation Use,
Chlorine Use, and Industrial Cooling Towers. As an alternative
to this request, the commenter suggested that subcategories
specific to the prepared food processing industry be created to
include these support operation processes under the appropriate
source category listed in the Federal Register. The commenter
added that this recategorization would eliminate the need for the
Prepared Food Manufacturing category.
Response; The Prepared Food Manufacturing source category has
been deleted from the list since, upon review, no evidence was
found to document a major source within this category.
Final Disposition; This source category has been deleted from
the list.
Comment; Two commenters (IV-D-23, IV-D-126) requested that the
source category Prepared Food Manufacturing be deleted from the
draft list. The first commenter (IV-D-23) noted that Prepared
Food Production should be deleted because HAP emissions do not
exceed the defined de minimis levels and public health risks do
not exceed prescribed levels. The commenter stated that
alternatively, if this source category is retained on the list,
the EPA needs to include provisions in the Federal operating
permit program to exempt those sources with de minimis levels of
HAP emissions or public health risk. The second commenter
(IV-D-126) noted that the average emissions of benzidine
(8.8 Ibs/yr) per facility are less than the amount required to be
considered a major source.
B-127
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Response; The Prepared Food manufacturing source category has
been deleted from the list due to lack of information indicating
that it contains a major source.
Final Disposition: This source category has been deleted from
the list because no major sources have been documented.
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12.0 PHARMACEUTICAL PRODUCTION PROCESSES
General Comments
Comment: Four commenters (IV-D-43, IV-D-66, IV-D-83,
IV-D-121) stated that EPA needs to further define and
differentiate the Pharmaceutical Production Processes industry
group. One commenter (IV-D-66) supported further differentiation
and definition by adding the qualifier "active ingredients" or by
adding other categories/subcategories. Another commenter (IV-D-
121) suggested that the Pharmaceutical Production Processes
industry group be divided into 11 categories: Fermentation,
Extraction, Chemical-Synthesis, Formulation, Animal Health
Product Manufacture, Animal Health Product Formulation,
Biosynthesis, Solvent Recovery Operations, Fugitive Emissions,
Product Coating, and Research Pilot Plants.
Response; As a result of comments received, the description of
Pharmaceutical Production Processes industry group source
category has been clarified.
Final Disposition; The Pharmaceutical Production Processes
industry group has one source category, Pharmaceuticals
Production, which will remain on the list.
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13.0 POLYMERS AND RESINS PRODUCTION
General Comments:
Comment; One commenter (IV-D-57) stated that there is a strong
basis for collecting the following source categories under a new
industry group with the heading: Rubber Manufacturing or Rubber
Compounds and Products: Acrylonitrile-Butadiene-Styrene/
Styrene-Acrylonitrile, Butyl Rubber Production, Neoprene
Production, Nitrile Butadiene Rubber Production, Polybutadiene
Rubber Production, Styrene Butadiene Rubber and Latex Production.
The rubber industry is well recognized as a separate industry
grouping, as illustrated by EPA's past regulatory practice
involving effluent guideline regulations issued under the Clean
Water Act and prior actions under Section 111 of the Clean Air
Act (CAA). The commenter (IV-D-57) also believed that if a new
Rubber Manufacturing industry group was created, a more refined
list would need to be established to promote development of
appropriate standards for the sources within the categories and
to reflect significant differences in processes.
Response; The industry groups used in the list are used for
convenience and do not limit EPA's ability to regulate source
categories in the most effective manner. Current groupings would
not preclude EPA from grouping the categories as suggested by the
commenter if that is determined to be the best method. As
reguired by Section 112(d)(7) of the CAA, EPA will develop
emission standards that are consistent with requirements
established pursuant to Section 111 and other parts of the CAA.
The CAA also allows EPA to distinguish among classes, types, and
sizes of sources within a category or subcategory to develop
appropriate emission standards.
B-130
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Comment: One commenter (IV-D-33) stated that additional
categories should be included in the Polymers and Resins
Production industry group for specific continuous and batch
production processes for vinyl chloride and polyester resins.
The commenter thought that the listed source categories are too
broad and do not recognize that many of the polymers and resins
are produced with different continuous or batch operations,
resulting in different emissions and control technologies.
Response: For the initial list, EPA has included only those
categories for which a major source has been identified. Other
categories will be added to the list at a later time, if
identified, Once a category is on the list, the CAA allows EPA
to distinguish among classes, types and sizes of sources within a
category or subcategory in establishing emission standards. This
would allow EPA to address situations where different sizes,
types, or classes or sources within a category warrant separate
consideration.
Comment: One commenter (IV-D-33) suggested that if a category or
a subcategory is overly broad, the best-performing top 12 percent
in terms of average emission limitation may represent production
technology that is fundamentally different from the remaining
sources in that category or subcategory. If this occurs, the top
performers may use emission control technology that is impossible
to apply to the remaining sources. Another possibility resulting
from categories that are too broad would be the development of
maximum achievable control technology (MACT) standards that do
not represent the true performance capabilities of subsets of the
category or subcategory.
Response: Within each category or subcategory, EPA is allowed to
distinguish among classes, types and sizes of sources in
establishing MACT standards. The CAA states that emission
standards developed through Section 112 will require the maximum
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degree of reduction in emissions of hazardous air pollutants
(HAP's) that the EPA, taking into consideration the cost of
achieving such reduction along with other nonair quality impacts,
determines is achievable.
Comment; One commenter (IV-D-47) wanted EPA to correct and
refine its category and subcategory approaches as it undertakes
the development of emission control standards in the future.
Another commenter (IV-D-35) would like to participate in the
subcategorization process.
Response; As the CAA allows EPA to distinguish among classes,
types and sizes of sources within a category or subcategory to
develop appropriate standards, the EPA will be evaluating the
potential of further refinement of those categories as the
rulemaking process proceeds. EPA will consider the commenter's
suggestions regarding subcategorization during the development of
the list and upon standards development. Public participation is
encouraged at all stages of regulatory development.
Comment: One commenter (IV-D-45) encouraged EPA to limit its
listing of categories and subcategories to those that truly
warrant regulation under Section 112 of CAA, because it will be
the basis for decisions about businesses, investments,
operations, and proactive/reactive programs aimed at emission
reductions for the current listing action.
Response; As directed by Section 112 of the CAA, and through the
listing procedures identified in the June 12, 1991 Federal
Register notice, EPA has listed those categories or subcategories
with emission data indicating they contain a major source(s) of
HAP's, or when a threat of adverse effect to human health or the
environment has been found.
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Comment; One commenter (IV-D-85) requested that EPA reorganize
the listed chemical production source types into a higher
grouping for the purpose of defining categories in the same way
as other industrial groupings. By doing so, it would obviate the
need to decide now on any proposals to establish specific
subcategories at this stage.
Response; Source categories have been listed within the Polymers
and Resins industry group for which EPA has identified major
source emissions and distinct production processes. The industry
groups used in the list are used for convenience and do not limit
the EPA's ability to regulate source categories in the most
effective manner.
Comment: One commenter (IV-D-106) suggested that clarification
be provided as to whether the term "production" includes further
polymerization processes of a given listed substance.
Response: Each source category has been described in a precise
manner for the initial listing action, in order to indicate what
associated processes are intended to be included in that
category.
Comment: One commenter (IV-D-106) suggested that
"polymerization" not be included in the definition of
"production." The.commenter noted that EPA implied this by
listing some polymerization activities separate from production
activities (e.g., polymerization of vinylidene chloride in the
Polymers and Resins Production industry group versus the listing
of vinylidene chloride production in the Production of Synthetic
Organic Chemicals industry group.
Response; Each source category has been described in a precise
manner to avoid overlap in the final listing action.
B-133
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Comment; One commenter (IV-D-93) noted that there are
inconsistencies in the titles of source categories by not using
the word "production" in all the source categories. The
commenter believed that "production" should be used in all
categories to prevent confusion during the regulatory process and
clarify the intent of the regulation process.
Response; The word "production" has been added to each source
category name within this industry group.
Comment; One commenter (IV-D-04) will submit information in the
future regarding the breakdown of categories and subcategories
affecting the composites segment of the plastics industry.
Response: Comments submitted by affected industries regarding
appropriate subcategorizations will be evaluated by EPA during
the standards development process and in making distinctions
between classes, types, and sizes within a category or
subcategory upon development of emission standards.
Comment; One commenter (IV-D-23) suggested that a Fiberglass/
Polyester Resin Products Manufacturing source category be added
to the draft list, subject to de minimis emissions and risk
criteria.
Response; Source categories have been listed based on
documentation of major source emissions data and identification
through the various EPA listing approaches. Fiberglass/Polyester
Resin Products Manufacturing was not identified as a distinct
source category through these listing procedures.
Comment; One commenter (IV-D-33) believed that a
subcategorization approach similar to that used in the
development of Water Effluent Guidelines should be used for the
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Polymers and Resins industry group. The commenter provided a
list of suggested subcategories based on batch and continuous
polymerization processes.
Response: Even with the list being clarified now, nothing
precludes further clarifications during standards development
since the CAA allows distinction for classes, types, and sizes
within a category or subcategory where necessary when developing
emission standards.
Comment; One commenter (IV-D-03) stated that their industry,
plastics fabrication, should be broken down into a sufficient
number of subcategories so that the significant and meaningful
differences in the respective operations are recognized. Factors
that must be included in the creation of reasonable subcategories
are laminate surface areas, product size, and the ability to
contain or capture pollutants.
Response: Even with the list being clarified now, nothing
precludes further clarifications during standards development
since the CAA allows distinction for classes, types, and sizes
within a category or subcategory where necessary to develop
appropriate emission standards. The types of evaluations
mentioned by the commenter would be conducted during standards
development, as appropriate.
13.1 Acetal Resins Production
Comment; None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
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13.2 Acrylonitrile-Butadiene-Styrene/Styrene-Acrylonitrile
Comment; Two commenters (IV-D-45, IV-D-106) suggested that the
EPA establish separate categories for Acrylonitrile-Butadiene-
Styrene/Styrene-Acrylonitrile (ABS/SAN) Polymers that distinguish
between the major types, the processes employed, the emissions
involved, and the products produced. The ABS polymers and SAN
polymers are produced using batch- and continuous-type processes.
One commenter (IV-D-106) pointed out that the resin materials are
inherently different. The characteristics of the resins vary
according to the type of polymerization process, as well as
whether they are made via batch or continuous manufacturing
methods. Each product/process combination utilizes a different
process stream with different emission levels. The commenter
gave examples of differences between batch and continuous
processes. Because emissions differ widely, the suggested
subcategories would not be susceptible to uniform pollution
control strategies.
Response; ABS/SAN has been split into two separate source
categories: Acrylonitrile-Butadiene-Styrene Production and
Styrene-Acrylonitrile Production. Also, nothing precludes
further clarifications during standards development, since the
CAA allows distinction for classes, types, and sizes within a
Ccitegory or subcategory where necessary to develop appropriate
emission standards.
Final Disposition; The source category Acrylonitrile-Butadiene-
Styrene/Styrene-Acrylonitrile has been split into two source
categories: Acrylonitrile-Butadiene-Styrene Production and
Styrene-Acrylonitrile Production.
13.3 Alkyd Resins Production
Comment: None
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Final Disposition; This source category will remain on the list
because no evidence of major sources has been documented.
13.4 Butyl Rubber Production
Comment; None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
13.5 Carboxymethylcellulose Production
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
13.6 Cellophane Production
Comment; None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
13.7 Cellulose Ethers
Comment: None
Final Disposition; This source category will remain on the list
but has been renamed Cellulose Ethers Production.
13.8 Epichlorohydrin Elastomers
Comment: None
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Final Disposition; This source category will remain on the list
but has been renamed Epichlorohydrin Elastomers Production.
13.9 Epoxy Resins
Comment: None
Final Disposition; This source category will remain on the list
but has been renamed Epoxy Resins Production.
13.10 Foamed Plastics
Comment: None
Final Disposition; This source category has been deleted from
the list due to duplication with existing production categories
already listed for this industry group.
13.11 Formaldehyde Resins Production
Comment: None
Final Disposition: This source category will remain on the list,
but has been renamed Amino Resins Production.
TM
13.12 Hypalon
Comment; None
Final Disposition; This source category will remain on the list
TM
and has been renamed Hypalon Production.
13.13 Maleic Copolymers Production
Comment; None
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Final Disposition: This source category will remain on the list
because evidence of major sources has been documented. However,
it has been renamed Maleic Anhydride Copolymers Production.
13.14 Methyl Methacrylate-Acrylonitrile-Butadiene-Styrene
Comment; None
Final Disposition: This source category will remain on the list
but has been renamed Methyl Methacrylate-Acrylonitrile-Butadiene-
Styrene Production.
13.15 Methyl Methacrylate-Butadiene-Styrene Terpolymers
Comment; None
Final Disposition: This source category will remain on the list
but has been renamed Methyl Methacrylate-Butadiene-Styrene
Terpolymers Production.
13.16 Methylcellulose Production
Comment; None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
13.17 Neoprene Production
Comment: None
Final Disposition: This source category will remain on the list,
because evidence of major sources has been documented.
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13.18 Nitrile Butadiene Rubber Production
Comment: None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
13.19 Nylon Plastics Production
Comment; None
Final Disposition: This source category will remain on the list,
but has been renamed Nylon 6 Production.
13.20 Phenolic Resins Production
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
13.21 Polybutadiene Rubber Production
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
13.22 Polycarbonates Production
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
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13.23 Polyester Plastics
Comment: None
Final Disposition; Polyester Plastics has been deleted from the
list due to duplication with existing production categories
already listed for this industry group.
13.24 Polyester Resins Production
Comment: None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
13.25 Polyether Polyols Production
Comment; None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented. However,
additional information obtained by EPA reveals that this category
should not be a part of the Polymers and Resins Industry Group.
Therefore, Polyether Polyols has been moved to the Miscellaneous
Industry Group.
13.26 Polyethylene Terephthalate Production
Comment; None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
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13.27 Polymerization of Vinylidene Chloride
Comment: None
Final Disposition: This source category will remain on the list
but has been renamed Polymerized Vinylidene Chloride Production.
13.28 Polymethyl Methacrylate Resins Production
Comment; None
Final Disposition: This source category will remain on the list,
because evidence of major sources has been documented.
13.29 Polystyrene Production
Comment: None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
13.30 Polyurethane Foam
Comment; None
Final Disposition: This source category will remain on the list
but has been renamed Flexible Polyurethane Foam Production.
13.31 Polyurethane Production
Comment: None
Final Disposition; This source category has been deleted from
the list due to duplication with existing categories in this
industry group.
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13.32 Polyvinyl Acetate Emulsions
Comment; None
Final Disposition: This source category will remain on the list
but has been renamed Polyvinyl Acetate Emulsions Production.
13.33 Polyvinyl Alcohol Production
Comment: None
Final Disposition; This source category will remain on the list,
because evidence of major sources has been documented.
13.34 Polyvinyl Butyral Production
Comment; One commenter (IV-D-45) believed Polyvinyl Butyral
Production should be split into two categories, with one based on
solvent process and the other on nonsolvent process due to
different starting materials and completely different HAP's use
and generation. The starting materials for the solvent process is
a vinyl acetate monomer (HAP), where the process generates
acetaldehyde. The nonsolvent process utilizes polyvinyl alcohol
resin as the staring material with no HAP's used or generated.
Response; The source category Polyvinyl Butyral Production has
been identified through EPA's listing procedures as containing
major source emissions. Even with the list being clarified now,
nothing precludes further clarification during standards
development, since the CAA allows distinction for classes, types,
and sizes within a category or subcategory where necessary to
develop appropriate emission standards.
Final Disposition; This source category will remain on the list.
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13.35 Polyvinyl Chloride and Copolymers Production
Comment: None
Final Disposition: This source category will remain on the list.
13.36 Reinforced Plastics
Comment: One commenter (IV-D-136) suggested that the subcategory
Field Manufacturing Facilities be added. The commenter
recommended that the definition include a permitted life span of
at least 5 years. The commenter believed that this subcategory
is very important because there are temporary facilities that
manufacture on or near a client's property if a product is too
large to be shipped. At these facilities, an emission control
system would not be cost effective.
Response: No documentation was included by the commenter to
support that Field Manufacturing Facilities be added as a
distinct category within this industry group. Upon standards
development, such facilities may be identified as emission
sources within existing source categories, at which time EPA may
consider the uniqueness of these types of operations.
Comment: One commenter (IV-D-136) suggested that Corrosion
Resistant and Fire Retardant subcategories be added along side
categories that include general purpose resins. Each branch
should then include a lower-tier subcategory for the custom
manufacturing of plastic products where variability in size and
shape of product is recognized. Each of these branches should
then include lower-tier subcategories for fixed facilities and
for temporary facilities.
B-144
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Response; No documentation was included by the commenter to
support that Corrosion Resistant and Fire Retardant Resins be
listed as a distinct source category. Information was not
submitted that would substantiate a separate listing of this
category. However, the source categories may be evaluated during
rulemaking.
Comment: One commenter (IV-D-47) suggested that a clarification
be made, despite the information in the docket, because there
still may be confusion between the scope of this category and
other categories on the Agency list. The Agency should expressly
define the scope of each category. At a minimum it should
confirm that, based on the information in the docket and in these
comments, sources in the Reinforced Plastics category do not fall
within the Polyester Plastics category.
Response; Each source category within the industry group will be
described to indicate what emission sources are intended to be
included in each category, and to avoid any potential overlaps in
terms of applicability.
Comment; One commenter (IV-D-47) suggested that emissions of
dimethyl formamide and 1,4-dichlorobenzene do not originate from
the thermoset process and, therefore, these emissions should be
regulated under a different source category. The commenter
continued by stating that EPA should clarify the scope of the
Reinforced Plastics source category to include only operations
using styrene cross-linked thermoset resins with reinforcement
such as glass fiber and inert fillers. In addition, this
commenter thought the EPA should establish a subcategory for
Closed Molding Operations and a subcategory for Open Molding
Operations. These should then be distinguished by their
potential to emit styrene and the nature of feasible emission
control techniques.
B-145
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Response: The Reinforced Plastics source category will be
described as part of the initial list to indicate what emission
sources are intended to be included in this category. Upon
emission standards development, the CAA also allows EPA to
distinguish between classes, types, and sizes within a category
or subcategory.
Comment; One commenter (IV-D-47) pointed out that based on a
review of styrene environmental fate and toxicity, industrial
emissions of styrene from this category do not pose a threat to
human health or the environment. Thus, the commenter believed
that styrene emissions from this source category should be
assigned a low priority and placed in the 10-year regulatory
cycle.
Response: The CAA directs EPA to develop a schedule for emission
standards promulgation based not only on health and environmental
effects, but also on exposure and the efficiency of grouping
categories. Thus, the health effects of styrene will be only one
criteria EPA uses in establishing the appropriate standards
promulgation schedule for this source category.
Final Disposition; This source category will remain on the list
but has been renamed Reinforced Plastic Composites Production.
13.37 Styrene Butadiene Rubber and Latex Production
Comment: None
Final Disposition; This source category will remain on the list,
because evidence of major sources has been documented.
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14.0 PRODUCTION AND USE OF INORGANIC CHEMICALS
General Comments
Comment: Twelve commenters (IV-D-32, IV-D-36, IV-D-43, IV-D-59,
IV-D-66, IV-D-67, IV-D-72, IV-D-76, IV-D-77, IV-D-83, IV-D-93 and
IV-D-94) suggested that, because the production and use of
certain substances release different pollutants and the control
technologies would likely differ, these two areas be separate
industry groups.
The last ten commenters (IV-D-36, IV-D-43, IV-D-59, IV-D-66, IV-
D-67, IV-D-72, IV-D-76, IV-D-77, IV-D-83, IV-D-93) suggested an
overall clarification and better definition of the name of this
industry group because it seemed to include only those sources
that both produce and use the identified inorganic chemicals. If
the name were to remain the same, facilities should not be
considered for listing based on only use or only production.
Commenter IV-D-93 suggested the industry group title Inorganic
Chemicals.
Response: The source categories within this industry group are
now comprise only production-type activities; this industry group
has been renamed Production of Inorganic Chemicals to reflect the
current situation.
Comment; One commenter (IV-D-17) requested the magnesium source
category be moved from this industry group and into the industry
group Nonferrous Metals. Its production facility is not a
producer of inorganic chemicals, but rather, a producer of
magnesium metal products with emissions of chlorine and
hydrofluoric acid.
B-147
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Response; No source category for magnesium compounds was
published in the draft list; however, Primary Magnesium Refining
contains a major source and has been listed within the Nonferrous
Metals Processing industry group.
Comment; Three commenters (IV-D-76, IV-D-104, IV-D-107)
suggested that EPA better define the categories to facilitate the
subsequent maximum achievable control technology (MACT)
determinations. The EPA's attempt to avoid excluding any
possible sources of hazardous air pollutants (HAP's) has resulted
in a potential to overlap source categories by the chemical,
industry, operation, and equipment specific natures of the
categories, potentially subjecting one source category to a
myriad of MACT standards. The possibility of overlap with
synthetic organic chemical manufacturing industry (SOCMI)
processes could also exist.
Response: The EPA has reviewed the list in an attempt to
eliminate duplicative listings. But even with the list being
clarified now, nothing precludes further clarification of
ceitegories by classes, types, and sizes for the purposes of MACT
determinations.
Comment: One commenter (IV-D-85) requested that EPA reorganize
the listed chemical production source types into larger groupings
for the purpose of listing categories, in the same way as EPA has
handled other industrial groupings in this notice. This comment
is; made for the following groups on the draft list:
(1) Production and Use of Inorganic Chemicals (first group), and
(2) Production and Use of Inorganic Chemicals (second group).
This reorganization would obviate the need to decide on any
proposals that may be made in comments to establish specific
subcategories at this stage. Claims regarding process
B-148
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differences should be deferred until the standards development
process, at which time EPA can obtain and analyze the appropriate
information or refute such claims.
Response; It appears that, due to typographical errors in the
draft Federal Register notice, the commenter misinterpreted the
listing; industry groups have not been classified as a Group 1,
Group 2, and such. Even with the list being clarified now,
nothing precludes further clarification of categories by classes,
types, and sizes for the purposes of MACT determinations.
Additionally, categories have been defined in order to clarify
their coverage.
14.1 Aluminum Chloride
Comment: None
Final Disposition; Due to questions regarding the applicability
of the data used in listing Aluminum Chloride, the category has
been deleted.
14.2 Aluminum Fluoride
Comment: None
Final Disposition; Due to questions regarding the applicability
of the data used in listing Aluminum Fluoride, the category has
been deleted.
14 . 3 Ammonium Phosphates
Comment; One commenter (IV-D-45) suggested that a distinction be
made between Ammonium Phosphate - Wet Process Phosphoric Acid,
and Ammonium Phosphate - Furnace Phosphoric Acid. If ammonium
B-149
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phosphates are produced from wet acid, or by some other
processing route that contains HAP impurities, then there should
be two ammonium phosphate categories.
Response: Categories on the list have been defined to include
multiple types of operations or processes; however, Ammonium
Phosphates is no longer listed as a distinct category.
Comment: Two commenters (IV-D-79, IV-D-80) suggested the
deletion of this source category due to its listing being based
solely on its suspected emissions of phosphorus. The fertilizer
industry emits phosphates, not phosphorus. The EPA has
erroneously interpreted its data base regarding such emissions.
Response; The category Ammonium Phosphates has also been
identified as emitting hydrogen fluoride in addition to
phosphates. However, this source category has been incorporated
into the Phosphate Fertilizers Production source category.
Comment; One commenter (IV-D-12) requested the deletion of this
source category because it does not emit elemental phosphorus.
Response: The category Ammonium Phosphates has also been
identified as emitting hydrogen fluoride in addition to
phosphates. However, this source category has been incorporated
into the Phosphate Fertilizers Production source category.
Final Disposition: Ammonium phosphate plants have also been
identified as emitting hydrogen fluoride; however, this source
category is no longer listed as a distinct category, but has been
incorporated into the Phosphate Fertilizers Production source
category.
B-150
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14.4 Ammonium Sulfate
Comment: None
Final Disposition: This category will remain on the list but has
been renamed Ammonium Sulfate Production - Caprolactam By-Product
Plants.
14.5 Calcium Oxide Production
Comment; Two commenters (IV-D-45, IV-D-98) suggested the
deletion of this source category. The commenter noted that Table
3-1 of "Documentation for Developing the Source Category List"
states that the pollutant of regulatory concern for calcium oxide
production plants is cadmium; the reference for this information
is an Office of Air Quality Planning and Standards (OAQPS) study
on the cadmium refining industry. This study, however, addresses
cadmium oxide manufacturing plants, not calcium oxide
manufacturing plants. Thus, it seems the listing of Calcium
Oxide Production was inadvertent; instead, Cadmium Oxide
Production facilities were the intended source for listing. The
first commenter (IV-D-45) recommended that if this source
category is to remain on the list, only the production of this
material be considered for regulation under the MACT concept.
Regulating the use of this item would be immense in scope, cost,
and base, and would be guestionably unbeneficial due to the wide
usage by consumers.
Response: The listing of calcium oxide production was an error;
the appropriate metal should have been cadmium. Furthermore,
only production-type activities have been listed; regulation of
end uses is not anticipated unless so noted.
B-151
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Final Disposition; Though the correct metal would have been
cadmium, this category was deleted because no major source was
documented from available data.
14.6 Carbon Black
Comment: None
Final Disposition: This category was deleted since, upon review,
no evidence was found to document major sources within this
category.
14.7 Charcoal
Comment: One commenter (IV-D-45) recommended that if this source
category is to remain on the list, only the production of this
material be considered for regulation under the MACT concept.
Regulating the use of this item would be immense in scope, cost,
and base, and would be questionably unbeneficial due to the wide
usage by consumers.
Response: The source categories within this industry group now
comprise only production-type activities.
Final Disposition; This category was deleted because no major
source was documented from available data.
14.8 Chemical Intermediates
Comment; One commenter (IV-D-45) recommended that if this source
category is to remain on the list, only the production of
chemical intermediates be considered for regulation under the
MACT concept. Regulating the use of this item would be immense
in scope, cost, and base, and would be questionably unbeneficial
to the wide usage by consumers.
B-152
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Response: The source categories within this industry group now
comprise only production-type activities.
Comment: One commenter (IV-D-93) requested the deletion of this
source category because the two apparent chemicals of interest,
hydrochloric acid and methyl ethyl ketone, will be included
elsewhere in the rule.
Response: Once a source category is identified as emitting a
HAP, it is on the list. Regulations will be set later for all
HAP's potentially being emitted.
Comment: Two commenters (IV-D-43, IV-D-83) requested the
deletion of this source category because it is too vague of a
description for a source category.
Response; Descriptions have been developed to clarify the scope
of listed source categories.
Final Disposition: This source category was deleted because no
major source was documented from available data.
14.9 Chlorine
Comment: One commenter (IV-D-91) suggested that this source
category be included as a subcategory under Semiconductor
Manufacturing Operations. The commenter stated that the draft
list of categories and subcategories are too broad and inclusive
to reflect different emission issues and would result in
conflicting sets of requirements and standards within the
semiconductor industry.
B-153
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Response; By definition, chloride production is distinctly
different than semiconductor manufacturing. But even with the
list being clarified now, nothing precludes further clarification
of categories by classes, types, and sizes for the purposes of
MACT determinations.
Comment: One commenter (IV-D-109) stated that within the draft
list Chlorine appears as a category under Production and Use of
Inorganic Chemicals. Other categories appear within other groups
that specifically list chemical production and use activities
that utilize chlorine. Some examples in the industry group
Production of Synthetic Organic Chemicals are Chloroform
Production, Perchloroethylene Production, and Vinyl Chloride
Production. Another group where chlorine is utilized in several
categories is Waste Treatment and Disposal.
Because of the listing of the category Chlorine per se, the
commenter is concerned that there may be some intent to regulate
chlorine in the same fashion, regardless of whether it is a
chlorine production or chlorine use facility. The technology
that is or can be applied to regulating chlorine emissions in a
chlorine production facility is different from technology applied
in a chlorine use facility. This difference is due to the vast
difference between the electrolytic cell technology used to
produce chlorine and the wide variety of chemical reaction
technologies involved in chlorine use.
Response; The categories within this industry group now comprise
only production-type activities. Additionally, this source
category will be defined to include various methods for chlorine
production.
Final Disposition; This category will remain on the list;
however, it has been renamed Chlorine Production.
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14.10 Chromium Chemicals Manufacture
Comment; None
Final Disposition: Because major sources have been documented,
Chromium Chemicals Manufacturing will remain on the list.
14.11 Cyanuric Chloride
Comment: One commenter (IV-D-12) noted that this source category
appears under two industry groupings—Production of Synthetic
Organic Chemicals and Production and Use of Inorganic Chemicals.
One of the listings should be deleted.
Response: This category is now only included within this
industry group.
Final Disposition; Because major sources have been documented,
Cyanuric Chloride Production will remain on the list in the
Production of Inorganic Chemicals industry group.
14.12 Detergents
Comment: One commenter (IV-D-48) suggested defining this source
category. Companies do not know what is meant by the term
Detergents.
Response: The categories within this industry group now comprise
only production-type activities and definitions have been
provided for all categories remaining on the list.
Comment; One commenter (IV-D-45) recommended that if this source
category is to remain on the list, only the production of this
material be considered for regulation under the MACT concept.
B-155
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Regulating the use of this item would be immense in scope, cost,
and base, and would be questionably unbeneficial due to the wide
usage by consumers.
Response; The categories within this industry group now comprise
only production-type activities.
Final Disposition: This source category was deleted because no
major source was documented from available data.
14.13 Fertilizer Formulation
Comment: One commenter (IV-D-45) recommended that if this source
category is to remain on the list, only the production of this
material be considered for regulation under the MACT concept.
Regulating the use of this item would be immense in scope, cost,
and base and would be questionably unbeneficial due to the under
usage by consumers.
Response: The categories within this industry group now comprise
only production-type activities.
Comment: Three commenters (IV-D-12, IV-D-79, IV-D-80) suggested
the deletion of this source category due to its listing being
based solely on its suspected emissions of phosphorus. The
fertilizer industry emits phosphates not phosphorus. The EPA has
erroneously interpreted its data base regarding such emissions.
Response: Fertilizer plants have also been identified as
emitting hydrogen fluoride in addition to phosphates. In
addition, a major source has been identified so this source
category will remain on the list.
Final Disposition; This category will remain on the list;
however, it has been renamed Phosphate Fertilizers Production.
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14.14 Fluorides
Comment; None
Final Disposition; This category has been deleted due to its
ambiguity and suspected overlap with other specific categories of
fluorides.
14.15 Hydrochloric Acid
Comment: One commenter (IV-D-91) suggested that this source
category be included as a subcategory under Semiconductor
Manufacturing Operations. The commenter stated that the draft
lists of categories and subcategories are too broad and inclusive
to reflect different emission issues and would result in
conflicting sets of requirements and standards within the
semiconductor industry.
Response; By definition, the category of Hydrochloric Acid
Production is distinctly different than semiconductor
manufacturing. But even with the list being clarified now,
nothing precludes further clarification of categories by classes,
types, and sizes for the purposes of MACT determinations.
Comment; One commenter (IV-D-45) requested the differentiation
between hydrochloric acid produced in a stand-alone facility
versus hydrochloric acid produced as a co-product for regulatory
purposes of MACT standards.
Response; Once a source category is identified as emitting a
HAP, it is on the list. Regulations will be set later for all
potential HAP emissions. But even with the list being clarified
now, nothing precludes further clarification of categories by
classes, types, and sizes for the purposes of MACT
determinations.
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Final Disposition; Because major sources have been documented,
this category will remain on the list and has been renamed as
Hydrochloric Acid Production.
14.16 Hydrogen Cyanide
Comment: None
Final Disposition; This category will remain on the list and has
been renamed Hydrogen Cyanide Production.
14.17 Hydrogen Fluoride
Comment; One commenter (IV-D-23) suggested adding this source
category to the draft list, subject to the de ninimis emissions
and risk criteria.
Response; This category was listed in the draft publication.
However, risk is not a determining factor in establishing
categories of major sources. Any listed categories of area
sources consider risk as part of the finding of threat of adverse
effects.
Final Disposition; Because major sources have been documented,
this category will remain on the list and has been renamed
Hydrogen Fluoride Production.
14.18 Isopropanolamines
Comment: One commenter (IV-D-70) requested that this category be
moved from the Inorganic industry group to the Organic Chemical
industry group. No additional information was given.
Response; This source category has been deleted since no
evidence was found to document major sources in this category.
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Final Disposition; Because no major sources were documented
within this category, it has been deleted from the list.
14.19 Manganese Chemicals
Comment: None
Final Disposition: Because no major sources were documented
within this category, it has been deleted from the list.
However, Primary Magnesium refining contains a major source and
has been listed within the Nonferrous Metals Processing industry
group.
14.20 Phosphate Fertilizers
Comment; Three commenters (IV-D-12, IV-D-79, IV-D-80) suggested
the deletion of this source category because there are no
phosphorus emissions from this category, and because there has
been no measurement or factual determination that such sources
emit significant quantities of hydrogen fluoride.
Response; Confirmation of a major source of hydrogen fluoride
has been made for this category.
Final Disposition: Because documentation provides evidence of
major sources within this source category, it will remain on the
list. However, the category will be renamed Phosphate
Fertilizers Production.
14.21 Phosphoric Acid
Comment: Three commenter (IV-D-12, IV-D-79, IV-D-80) asked for
the deletion of this source category because it does not emit
elemental phosphorus. The second and third commenters (IV-D-79,
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IV-D-80) stated that fertilizer industry emits phosphates not
phosphorus. The EPA has erroneously interpreted its deita base
regarding such emissions.
Response: This category has been determined to emit hydrogen
fluoride in addition to phosphates.
Comment: One commenter (IV-D-45) suggested that the distinction
be made between phosphoric acid-thermal, and phosphoric acid-wet
process. One is produced with high-purity phosphorus, the other
is not.
Response: This category has been described to include different
types of processes. But even with the list being clarified now,
nothing precludes further clarification of categories by classes,
types, and sizes for the purposes of MACT determinations.
Final Disposition: This category will remain on the list but has
been renamed Phosphoric Acid Manufacturing.
14.22 Phosphorus Pentasulfide Production
Comment: None
Final Disposition; Due to questions regarding the applicability
of the data used in listing this source category, it has been
deleted from the list.
14.23 Phosphorus Production
Comment: None
Final Disposition: Due to questions regarding the applicability
of the data used in listing this source category, it has been
deleted from the list.
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14.24 Phosphorus Trichloride/Oxychloride Production
Comment; None
Final Disposition; Due to questions regarding the applicability
of the data used in listing this source category, it has been
deleted from the list.
14.25 Quaternary Ammonium Compounds Production
Comment; None
Final Disposition; Because major sources have been documented,
this category will remain on the list.
14.26 Rocket Engine Fuels
Comments; One commenter (IV-D-32) requested the
subcategorization of Rocket Engine Fuels into liquid and solid
fuels. No additional information was given by the commenter.
Response: Each listed category has been defined to clarify its
intended coverage; however, even with the list being clarified
now, nothing precludes further clarification of categories by
classes, types, and sizes for the purposes of MACT
determinations.
Final Disposition; Rocket Engine Fuel Production has been
deleted from the list, since no evidence was found to document
major sources within this category.
14.27 Sodium Cyanide Production
Comment; None
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Final Disposition: Because major sources have been documented,
this category will remain on the list.
14.28 Uranium Hexafluoride Production
Comment: None
Final Disposition: Because major sources have been documented,
this category will remain on the list.
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15.0 PRODUCTION OF SYNTHETIC ORGANIC CHEMICALS
General Comments
Comment; One commenter (IV-D-93) suggested that the term
"production" be defined and addressed either in the final list of
categories or in the maximum control achievable control
technology (MACT) standard because it is a key issue in
determining which units will eventually be regulated. The term
"production" should refer to the production process that is
producing that chemical as a final product. Due to the complex
nature of the synthetic organic chemical industry (SOCMI),
complex situations occur with mixture streams containing a wide
range of chemical concentrations, making a consistent
interpretation difficult, if not impossible.
Response: Even if the term "production" is clarified now,
nothing precludes further clarifications during standards
development, since the Clean Air Act (CAA) allows distinction for
classes, types, and sizes within a category or subcategory where
necessary to meet the purposes of determining MACT. The coverage
of the specific regulations will describe the applicability of
the standards.
Comment; One commenter (IV-D-18) suggested that to reflect the
regulatory flexibility of categories and subcategories required
under the CAA there is a need to distinguish between types of
operations (batch versus continuous) and between size of
operations (small plants versus large plants).
Response: Even with the list being clarified now, nothing
precludes further clarifications during standards development,
since the CAA allows distinction for classes, types, and sizes
within a category or subcategory where necessary to meet the
purposes of determining MACT.
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Comment: One commenter (IV-D-18) recommended that EPA group
different batch processes together in the Production of Synthetic
Organic Chemicals industry group. This approach is consistent
with that of the product/process grouping currently being pursued
by the Agency in the development of the Hazardous Organic
National Emission Standard for Hazardous Air Pollutants (NESHAP),
also referred to as the HON rule, which will be proposed later
this year.
Response: The purpose of this list is to identify categories for
which standards will be established, but not to provide the final
determination upon which standards will be based. In situations
where multiple source categories or subcategories can be
regulated under a single rulemaking, this can be considered
during the process of developing the MACT standard. On the other
hand, it may be determined during regulatory development that the
MACT control level is different for different sizes, types, or
classes or sources. This process is consistent with provisions
in the CAA which allow for distinctions for classes, types, and
sizes within a category or subcategory where necessary to meet
the purposes of determining MACT.
Comment: One commenter (IV-D-23) asked that the use of propylene
oxide be added to the draft list as a source category, subject to
the de minimis emissions and risk criteria. No additional
information was given.
Response; Because no documentation of major sources was
provided, this source category has not been added to the list.
Comment: One commenter (IV-D-45) suggested a subcategorization
of Linear Alkylbenzene Production. This product is made by two
different processes—one using an aluminum catalyst, the other a
hydrogen fluoride catalyst. The commenter believed that because
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the two processes emit different HAP's EPA should set up two
categories—one based upon production via the aluminum catalyst
route, the other via the hydrogen fluoride catalyst route.
Response; The purpose of this list is to identify categories for
which standards will be established. Even with these processes
being identified now, nothing precludes further clarifications
during standards development, since the CAA allows distinction
for classes, types, and sizes within a category or subcategory
where necessary to meet the purposes of determining MACT.
Comment: One commenter (IV-D-59) assumed that as long as a
product is not produced for sale nor used as a primary catalyst
in the production process then presence in a facility would not
trigger the potential application of separate Section 112(d) MACT
standards.
Response: Major sources of HAP's within the listed categories
will be regulated. The term product is not necessarily intended
to connote or be limited to consumer products or marketable
products. Furthermore, regulation of HAP's is not limited to
products only. For example, some chemical processes are listed
not because their products are HAP's, but because a HAP is used
as a reactant in the chemical production process and is therefore
emitted from the process. Applicability of each standard will be
provided when the MACT standards are proposed.
Comment: Two commenters (IV-D-67, IV-D-128) requested that EPA
consider each of the processes under the SOCMI list as a separate
category, with the opportunity to make appropriate subcategory
distinctions where needed. The Production of Synthetic Organic
Chemicals list is so extensive that allowing time for appropriate
standard consideration, differentiation by process, and adequate
MACT implementation is necessary and critical.
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Response; Though the list of chemicals under this industry group
is very extensive, there are many similarities among the chemical
production processes and emission characteristics which will
allow them to be considered under one rulemaking effort.
Considerations for classes, types, and sizes within a category or
subcategory where necessary to meet the purposes of determining
MACT will be made during development of the standards and a
rationale will be presented at that time.
Comment: One commenter (IV-D-70) asked that Isopropanolamines be
moved from the Inorganic to Organic Chemical industry group. No
additional information was given.
Response: Though isopropanolamines are organic chemicals, there
is no documentation of major source HAP's at this time;
therefore, this source category is not currently included on the
list. A category may be added to the list at a later date if
further information becomes available.
Comment: One commenter (IV-D-76) stated that the inclusion of a
broad mixture of categories based on different premises will
complicate and confuse the process of developing MACT standards
for each category. One category has the potential of being
regulated under three of four different industry groups. For
example, a mineral processing facility could be in a number of
categories including flotation and solvent extraction as well as
the chemical specific categories. Therefore, EPA should define
the categories more narrowly to facilitate the subsequent MACT
determinations.
Response: Even with the list being clarified now, nothing
precludes further clarifications of the applicability of MACT
standards during standards development. In developing MACT
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standards, EPA will consider the potential for overlap and seek
to minimize the potential for conflicting regulations to apply to
the same source.
Comments: One commenter (IV-D-85) stated that counting the HON
as hundreds of categories for Section 112(e) scheduling purposes
would be inequitable. Therefore, EPA should list all SOCMI as
one category.
Response: The EPA is no longer listing several hundred
categories within this industry group. Rather SOCMI will be
listed as the only category. A description of this source
category has been provided in Appendix A of this document.
Comment; Two commenters (IV-D-107, IV-D-109) urged EPA to
consider possible overlaps in the applicability of categories to
prevent dual applicability and staggered compliance dates for the
same process unit. Some equipment units manufacture different
products from different industry groupings. Organic as well as
inorganic chemicals may be produced as finished products in the
same unit. For example, a chlorinated organic process that
produces carbon tetrachloride (Synthetic Organic Chemical
Manufacturing industry group) often produces hydrochloric acid
(Inorganic Chemicals industry group) as a by-product. Processes
such as these should not be subject to two different sets of
control standards since these units are often highly integrated
and often use common control devices. In addition to the
possible overlap of the eventual regulations for the control
standards, separate category standards should be avoided because
the phase-in of the standards over the next 10 years could
establish different schedules for compliance. Different
compliance schedules for the same process unit could very easily
result in an ineffective use of resources by requiring new
revisions to a recently installed control device.
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Response: The purpose of this list is to identify categories for
which standards will be established, not to provide the final
determination for the applicability of the standards. Additional
provisions for effective MACT standards will be made during
regulation development.
Comment; One commenter (IV-D-121) noted that Cyanuric Chloride
Production appears under two industry groups—Production of
Synthetic Organic Chemicals and Production and Use of Inorganic
Chemicals. One should be deleted.
Response: The draft publication contained duplicative listings
for cyanuric chloride. This source category is now listed only
within the Production of Inorganic Chemicals industry group.
Comment; One commenter (IV-D-128) suggested that Dodecylbenzene
Production is probably included in the Linear Alkylbenzene
Production category, and is unaware of a manufacturer producing
commercial quantities of pure dodecylbenzene. In order to avoid
future confusion, the commenter requested deletion of
dodecylbenzene as a category.
Response: Neither Dodecylbenzene Production nor Linear
Alkylbenzene Production is listed as a distinct source category.
Synthetic Organic Chemical Manufacturing is the only category
currently listed in this industry group. Within this singular
source category, any production process, whether it produces
dodecylbenzene or other linear alkylbenzenes, is anticipated to
be covered by the HON. For other source categories, those that
are distinctly listed, are excluded from more general source
categories.
Comment: One commenter (IV-D-128) asked EPA to delete specific
phthalate plasticizer production categories from the Synthetic
Organic Chemical Manufacturing industry group and allow all
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plasticizer production to be regulated under the generic
Miscellaneous industry group category. Phthalic anhydride
emissions will be similar for most phthalate plasticizer
production facilities.
Response; Synthetic Organic Chemical Manufacturing is the only
source category currently listed in the Production of Organic
Chemicals industry group. The category of Phthalate Plasticizers
Production has been described to include any potential
manufacturers of such products. Source categories listed
distinctly are not covered under other source categories.
Final Disposition: The numerous subcategories previously listed
within this industry group are no longer listed as distinct
categories. The current listing is for the source category
SOCMI.
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16.0 RADIONUCLIDE EMITTERS
General Comments
Comment; Two commenters (IV-D-85, IV-D-114) suggested that
additional categories are needed to address industrial processes
that have different intricacies to those listed, such as the
Department of Energy (DOE) facilities which have the potential to
emit radionuclides. Chemical or waste treatment processes
employed at DOE facilities are similar to commercial processes;
however, their emissions have the potential to be radioactive.
This may result in different emission control and monitoring
equipment, as well as additional safety concerns. Recognizing
these types of activities and placing them into a separate
category or subcategories is necessary to avoid potential
inconsistencies and problems involved in promulgating regulations
that were not necessarily designed to handle the special problems
associated with radionuclides.
The first commenter (IV-D-85) also questioned why
underground and surface uranium mines, uranium mills, mill
tailings, facilities licensed by the Nuclear Regulatory
Commission and other Federal facilities, and utility boilers are
riot included on the proposed list.
Response; At this time, no categories have been listed for
radionuclide emissions. However, once EPA has determined the
criteria for differentiating between area and major sources,
major emitters of radionuclides will be listed and will be
clearly defined based on comments received.
Comment: One commenter (IV-D-85) stated that with the Section
112 Subsection (q) (2) exceptions, radionuclide-emittirig source
categories (both those for which EPA has already issued standards
and other sources) must be included on the 112(c) list. The
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reasoning is that Section 112(c)(4) states that the Administrator
may list categories of sources that have previously been
regulated under §112, and the list does reflect many such source
categories (i.e., vinyl chloride production, asbestos milling,
and other existing National Emission Standards for Hazardous Air
Pollutants (NESHAP). Section 112(q)(2) exempts only three types
of radionuclide sources from the coverage of §112 as amended in
1990: elemental phosphorus plants, grate calcination elemental
phosphorus plants, and phosphogypsum stacks. (These stay under
§112 as previously in effect.)
Response; Radionuclides cannot be included on the list until EPA
can define the different criteria for differentiating between
area and major sources.
Final Disposition: Categories of major and area sources of
radionuclides emissions are not included on the list at this
time. The EPA has not defined the different criteria for
differentiating between area and major sources for radionuclides
emitters that are different than the 10 or 25 ton per year
thresholds established for other hazardous air pollutants
(HAP's).
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17.0 MISCELLANEOUS
General Comments
Comment: Two commenters (IV-D-23, IV-D-48) had deletion
recommendations to suggest to EPA. The first commenter
recommended that the following source categories be deleted from
the draft list when hazardous air pollutant (HAP) emissions do
not exceed defined de minimis levels and public health risks do
not exceed prescribed levels: Boat Building; Ion Exchange Resins
Production; Asphalt Roofing Manufacturing; Petroleum Dry
Cleaning; Halogenated Solvent Dry Cleaning; Paint Removers Use;
Paints, Coatings, and Adhesives Use; Photographic Film
Processing; Vapor Degreasing; Semiconductors Manufacturing; and
Comfort Cooling Towers (with no detectable levels of h€;xavalent
chrome in the cooling tower water). The commenter made this
suggestion based on experience that there are many small sources
in these categories or sources that do not typically present
significant public health risks. The commenter's main concern is
that these small sources may be subject to the Federal operating
permit program, which would result in significant and unnecessary
cost administrative burdens on these sources, on state and local
permitting agencies, and on EPA. The second commenter (IV-D-48)
suggested deletion of Comfort Cooling Towers and Electric Wiring
because of the possibility that insufficient data exist to
warrant listing.
Response; Ion Exchange Resins Production, Photographic Film
Processing, and Electric Wiring have been deleted from the list.
Petroleum Dry Cleaning and Semiconductor Manufacturing will
remain on the list because major sources exist in both source
categories. Boat Building will also remain on the list but will
be renamed Boat Manufacturing. Asphalt Roofing Manufacturing
will remain on the list but has been moved to the Mineral
Products Processing industry group. Halogenated Solvent Dry
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Cleaning has been disaggregated into Dry Cleaning (Chlorinated
Solvents) - Commercial, and Dry Cleaning (Chlorinated Solvents) -
Industrial. Paint Removers Use has been aggregated into a Paint
Stripper Use category. Paints, Coatings, and Adhesive Use will
remain on the list but has been moved into the Surface Coating
industry group. Vapor Degreasing has been aggregated into the
Degreasing/Cleaning Operations source category. Finally, Comfort
Cooling Towers is considered an area source under the Industrial
Process Cooling Towers area source category. For categories
remaining on the list, documentation of major sources exists.
However, risk is not a determining factor in establishing
categories of major sources. Any listed categories of area
sources consider risk as part of the finding of threat of adverse
effects.
Comment; Five coitvmenters (IV-G-07, IV-G-21, IV-D-29, IV-D-21,
IV-D-70) suggested additional categories for the Miscellaneous
industry group. Commenter IV-G-07 suggested the addition of
Activated Carbon Regeneration and cites toluene, benzene,
polychlorinated biphenyls (PCB's), and dioxins as pollutants.
The commenter supported this suggestion with emission rates for
criteria pollutants and limited emissions rate per toxics and
with specific plant information. The second commenter (IV-G-21)
requested that Waferboard/Oriented Strand Board be included under
the industry group Miscellaneous. Reasons given by the commenter
were that most factories are major sources and that waferboard
manufacturing is not similar to the process of plywood/
particleboard manufacturing, as once thought. The commenter
provided a study supporting this source inclusion. The third
commenter (IV-D-29) suggested that EPA add an additional
category—Cellulose Food Casings Manufacturing—with carbon
disulfide and hydrogen sulfide as pollutants. The commenter felt
this should be regulated as a separate category or subcategory
and provided technical information relative to the manufacturing
of cellulose casings and emissions control of carbon disulfide.
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The fourth commenter (IV-D-21) recommended EPA add Hardboard/
Fiberboard Manufacturing to the Miscellaneous group. The reason
given for its inclusion on the list is the manufacturing of these
products involves a different process than that of particleboard
manufacturing, yet due to the common use of formaldehyde-laden
resins, HAP emissions are expected. The last commenter (IV-D-70)
suggested the addition of the category Printing Ink Manufacture.
The commenter thought the category was worthy of independence
because of the relatively large number of related facilities and
the great diversity of chemicals employed in their manufacturing.
No documentation was supplied in support of this suggestion.
Response; The EPA has no information indicating that Activated
Carbon Regeneration contains a major source; therefore it is not
included on the list at this time. Waferboard/Oriented Strand
Board and Hardboard/Fiberboard Manufacturing will both be
regulated under the Plywood/Particle Board Manufacturing source
category. The Cellulose Food Casings Manufacturing source
category has been included under the Food and Agriculture
Processes industry group. Printing Ink Manufacture is addressed
in the Surface Coating industry group.
17.1 Asphalt Roofing Manufacture
Comment: None
Final Disposition: Asphalt Roofing Manufacturing will remain on
the list but has been moved to the Mineral Products Processing
industry group.
17.2 Pulp and Paper Production
Comment: One commenter (IV-D-59) suggested subcategorization or
replacement of the Pulp and Paper Production category in
recognition of the diversity of the pulping processes by the
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following categories: (1) Kraft Pulp Mills; (2) Soda Pulp Mills;
(3) Sulfite Pulp Mills; (4) Serai-Chemical Pulp Mills; (5)
Mechanical Pulp Mills; (6) Non-Wood Pulp Mills; (7) Secondary
Fiber Mills; and (8) Nonintegrated Paper and Paperboard Mills.
The first five categories are distinguished by differences in
the methods and chemicals used to manufacture the pulp. The
commenter based this suggestion on expert knowledge of the pulp
and paper production industry.
Response; This source category will remain on the list as Pulp
and Paper Production. It will be described to enumerate all
processes that are major sources of HAP's.
Final Disposition: This source category has been found to
contain a major source and will remain on the list.
17.3 Plywood/Particle Board
Comment: Two commenters (IV-D-21, IV-G-06) urged EPA to clarify
and expand the category to include strandboard and waferboard
Manufacturing under the category as subcategories. The second
commenter (IV-G-06) noted the category should include the
manufacture of any wood product that utilizes wood and some type
of binder. Also, the commenter (IV-G-06) is concerned with the
manufacture of chemically impregnated wood products, such as
railroad ties and telephone poles. The first commenter included
no supporting documentation, just professional judgement for this
claim. The second commenter (IV-G-06) provided documentation
consisting of a preliminary analysis for a waferboard plant
permit application.
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Response: This source category has been described to include
many manufactured wood products, including strandboard and
waferboard. A separate category for treating wood has been
listed. The process within Wood Treatment are notably different
than those within this source category.
Comment: Three commenters (IV-D-26, IV-D-25, IV-D-59) said this
category should be subcategorized or replaced with the different
wood panel industry processes as characterized by the U.S.
Commerce Department. They suggest the wood panel industry should
be classified by the following major process categories:
(1) Hardboard/Cellulose Fiberboard; (2) Hardwood Plywood;
(3) Medium- Density Fiberboard; (4) Oriented Strandboard. and
Wciferboard; (5) Particleboard; and (6) Softwood Plywood. The
first commenter (IV-D-26) agreed with these subcategories, but
separated the Hardboard and Cellulose Fiberboard subcategories,
thus making seven categories. This commenter felt
subcategorization is necessary because of significant differences
in additives, coatings, and processing methods within the wood
panel industry. Also, the commenter feels promulgation of a
single maximum achievable control technology (MACT) regulation
for the entire wood panel industry would be inequitable and
technically wrong. The second commenter (IV-D-25) also gives the
differences in processes as the reason for subcategorization,
whereas they can differ in size, age, and degree of automation.
This commenter also sent EPA the U.S. Department of Commerce
Lumber and Wood Products grouping list for support of their
process categories. The third commenter (IV-D-59) endorsed the
proposal of the second commenter.
Response; The source category has been described to enumerate
many potential processes within the source category. This
description recognizes the variety of processes that exists and
identifies them individually.
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Final Disposition; This source category has been found to
contain a major source and will remain on the list.
17.4 Sawmill Operations
Comment: None
Final Disposition; This source category has been deleted from
the list because it does not contain a major source.
17.5 Tire Production
Comment: One commenter (IV-D-33) noted that this category is too
broad because the manufacturing of different types of tires
results in different HAP's being emitted. The commenter said
that Tire Production needs to be expanded to include the
production of tires for (1) passenger cars and light-duty truck
cars; (2) heavy-duty truck tires; (3) off-the-road truck tires;
(4) aircraft tires; and (5) miscellaneous other pneumatic tires.
Thus, they believe tire production should be subcategorized based
on their expertise of this category.
Response; This source category will be described to
differentiate between production of types of tires that may emit
different HAP's.
Final Disposition; This source category has been found to
contain a major source and will remain on the list of categories
of major sources. Also, it is not listed as a category of area
sources.
17.6 Dry Cleaning (Petroleum Solvents)
Comment; None
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Final Disposition; This source category has been found to
contain a major source and, therefore, it will remain on the
list.
17.7 Dry Cleaning (Chlorinated Solvents) Coin-Operated - Plant
Comment; None
Final Disposition: This source category does not contain a major
source and, therefore, has been deleted from the list of
categories of major sources. Also, it is not listed as a
category of area sources.
17.8 Dry Cleaning (Chlorinated Solvents) Coin-Operated - Self
Comment: None
Final Disposition; This source category does not contain a major
source and therefore, has been deleted from the list.
17.9 Dry Cleaning (Chlorinated Solvents) - Commercial
Comment: None
Final Disposition; This source category contains a major source
and will remain on the list, but has been renamed Commercial Dry
Cleaning (Perchloroethylene) - Transfer Machines. Within
commercial dry cleaning operations, only some types of transfer
machines have the potential to emit in major source quatities.
17.10 Dry Cleaning (Chlorinated Solvents) - Industrial
Comment: None
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Final Disposition; This source category contains major sources
and will remain on the list, but has been divided into two new
source categories: Industrial Dry Cleaning (Perchloroethylene) -
Transfer Machines and Industrial Dry Cleaning (Perchloroethylene)
- Dry-to-Dry Machines.
17.11 Cold Degreasing
Comment; Four commenters (IV-G-04, IV-D-114, IV-D-68, IV-D-104)
requested that this source category be clarified and
subcategorized because of assumptions as to what the category
includes (i.e., should cold water/soap solution be included, and
which industries do the processes include?). One commenter
(IV-D-114) suggested dividing the Cold Degreasing category based
on size, capacity, and throughput of the operations. Thus,
smaller degreasers would fall under regulation of area sources.
Another commenter (IV-D-68) recommended subcategorizing because
the process cuts across many industrial sectors and there are
important process-related distinctions that would make the
setting of emission standards hard during the rulemaking process.
For example, the scale of the operation may impact feasibility of
control technologies that are considered by EPA, which was also
suggested by another commenter (IV-D-114). Commenter (IV-D-68)
suggested this would apply to the categories Conveyorized
Degreasing, Open-Top Vapor Degreasing, and Electric Wiring. The
commenter (IV-D-104) suggested the same approach should be used
for the Industrial Cooling Towers category.
Response; This source category has been combined with other
degreasing and cleaning operations to form the Halogenated
Solvent Cleaners source category. It has been described to
include all processes that are a major source of HAP's. Sources
that are not major will not be regulated without making a finding
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of threat of adverse effects from the area sources. Size,
capacity, and throughput of the operations that will be regulated
will be decided during the regulatory process.
Comment; One commenter (IV-D-66) noted that the Cold Degreasing
s;ource category is ill-defined, has insufficient supporting data,
and is not a major or area source.
Response: This source category has been combined with other
degreasing and cleaning operations to form the Halogeriated
Solvent Cleaners source category. This source category has been
described to make clear which processes and operations are
included in the source category.
Final Disposition: This source category will remain on the list,
but has been combined with other degreasing and cleaning
operations to form the Halogenated Solvent Cleaners source
category.
17.12 Fabric Dyeing
Comment; None
Final Disposition; This category has been removed from the list
as a distinct source category and is now combined with the
Printing, Coating, and Dyeing of Fabrics source category.
17.13 Solvent Extraction Processes
Comment: Three commenters (IV-D-76, IV-D-83, IV-D-43) requested
that EPA clarify and define this category based on how the MACT
standards from overlapping categories relate to each other. Two
of the commenters (IV-D-83, IV-D-43) want this clarification
because of the relationship of this process to the pharmaceutical
industry. The first commenter (IV-D-76) requested clarification
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so as not to include solvent extraction at metallurgical
operations. This commenter references EPA's background
documentation to support that the category is limited to solvent
extraction processes at inorganic chemical facilities and not at
metallurgical operations.
Response: The EPA agreed that this source category was very
overlapping and has consequently deleted it from the list.
Comment; Two commenters (IV-D-62, IV-D-76) stated that the EPA
may be counting fugitive emissions toward the major source
thresholds and that is why Solvent Extraction Processes appears
on the list. They argue that such an approach appears to be
inconsistent with the proposed operating permit rulemaking and
that fugitive emissions should only be counted toward major
source thresholds at rulemaking.
Response; After reviewing the available data for this category,
evidence of major sources was not found; however, the data did
indicate that this category was very overlapping with other
source categories.
Comment: Two commenters (IV-D-62, IV-D-66) requested that, due
to lack of available data, the Solvent Extraction Processes
source category be deleted from the list.
Response: Upon further review of the data that the EPA used for
listing this category, it was determined to be very overlapping
with other source categories.
Final Disposition: Because the EPA determined that Solvent
Extraction Processes overlapped with other source categories, it
was deleted from the list.
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17.14 Acrylic Sheeting Production
Comment; None
Final Disposition: This source category has been deleted from
the list due to lack of documentation of a major source.
17.15 Aerosols Production
Comment: One commenter (IV-D-62) requested that, due to lack of
available data, the Aerosols Production source category be
deleted from the list.
Response: The EPA had available data which, upon further review,
indicated that this category should have been entitled Aerosol
Can-Filling Facilities, and which does show evidence of major
sources.
Final Disposition: This category remains on the list, but it has
been renamed Aerosol Can-Filling Facilities.
17.16 Anesthetics
Comment: None
Final Disposition; This source category has been depleted from
the list because no evidence of major sources was documented.
17.17 Benzyltrimethylammoniumchloride Production
Comment: None
Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
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17.18 Boat Building
Comment: None
Final Disposition: This source category will remain on the list;
however, the name has been changed to Boat Manufacturing and has
been moved to the Polymers and Resins Production industry group.
17.19 Butadiene Cylinders, Lab testing
Comment; None
Final Disposition; This source category has been deleted from
the list because it was found to overlap with other source
categories.
17.20 Butadiene Dimers Production
Comment; None
Final Disposition: This source category will remain on the list,
because evidence of major sources has been documented.
17.21 Chelating Agents Production
Comment; None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
17.22 Chlorinated Paraffins Production
Comment: None
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Final Disposition; This source category will remain on the list
because evidence of major sources has been documented.
17.23 Chloroneb Production
Comment; None
Final Disposition: This source category will remain on the list,
but has been transferred to the Agricultural Chemical Production
industry group.
17.24 Chromium Electroplating
Comment: One commenter (IV-D-70) suggested differentiating the
Chromium Electroplating and Other Electroplating categories from
printing and industrial electroplating. They recommended a
subcategory of Graphic Arts Electroplating in the
Printing/Publishing category based on their expertise in the
field.
Response: This source category has been divided into three
distinct source categories: Hard Chromium Electroplating, Chromic
Acid Anodizing, and Decorative Chromium Electroplating. These
source categories are listed both as major sources and as area
sources, due to a potential threat of adverse health effects to
human health or the environment.
Final Disposition: This source category has been divided into
three distinct source categories: Hard Chromium Electroplating,
Chromic Acid Anodizing, and Decorative Chromium Electroplating.
These three source categories are listed as categories of major
and area sources.
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17.25 Comfort Cooling Towers
Comment; One commenter (IV-D-83) noted that comfort cooling
towers should be considered as area sources. The commenter
requested that EPA thoroughly study them before adding them to
the list. The commenter provided no documentation to support
this claim.
Response: No major sources have been documented for this source
category; therefore it has been deleted from the list.
Final Disposition: This source category has been deleted.
17.26 Commercial Sterilization Facilities
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented.
17.27 Conveyorized Degreasing
Comment; None
Final Disposition: This source category has been combined with
other degreasing and cleaning operations to form the Halogenated
Solvent Cleaners source category.
17.28 Deodorant Production
Comment: None
Final Disposition: This source category has been deleted from
the list since no evidence was found to document major sources
within this category.
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17.29 Disinfectants Production
Comment: One commenter (IV-D-66) noted that the Disinfectants
Production source category is ill-defined, has insufficient
supporting data, and is not a major or area source.
Response; This source has been deleted from the list since no
evidence was found to document major sources within this
category.
Final Disposition: This source category has been deleted from
the list.
17.30 Dodecanedioic Acid Production
Comment; None
Final Disposition; This source category will remain on the list
because it is co-located with a major source.
17.31 Dyes and Pigments Production
Comment; Two commenters (IV-D-24, IV-D-87) suggested separating
or subcategorizing this industry group into two distinct groups
or categories. The first commenter (IV-D-24) suggested the
categories Dyes Production and Pigments Productions because of
the confusion that sometimes exists between the two industries.
This confusion results because the two industries involve
different manufacturing processes, products, chemistry, raw
materials, markets, expertise, personnel, and concerns, according
to the commenter. The commenter cites submittal of official
definitions to government agencies in 1979 as supporting
documentation. The second commenter (IV-D-87) recommended the
categories be Dyes and Pigments. This commenter thought that
after a distinction is made between the two industries it is
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questionable whether Dyes Production is a "major source" as
defined by Section 112 of the CAA Amendments. Both commenters
made suggestions based on knowledge of these industries.
Response; This source category has been deleted from the list
since no evidence of major sources has been documented.
Final Disposition: Dyes and Pigments have been deleted from the
list.
17.32 Electric Wiring
Comment: Four commenters (IV-G-04, IV-D-114, IV-D-68, IV-D-104)
requested that this source category be clarified and
subcategorized because of assumptions as to what the category
includes.
Response: This source category has been deleted from the list
since no evidence of major sources has been documented for this
category.
Comment: One commenter (IV-D-108) requested clarification on
what the Electric Wiring category was intended to cover. It is
not clear to the commenter what pollutants would be emitted
either.
Response; This source category has been deleted from the list.
since no evidence has been found to document major sources in
this category.
Final Disposition; This source category has been deleted from
the list.
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17.33 Electronics Manufacture
Comment: One commenter (IV-D-68) stated that this category is
too broad to regulate under one heading because it and
Semiconductor Manufacturing both encompass a large number of
widely variant processes. The commenter thought EPA would be
hard-pressed to develop one set of emission standards for all
processes in a single rulemaking effort. The commenter
recommends that to avoid this problem EPA should (1) adopt more
limited categories and subcategories applicable to the
electronics industry; (2) continue to utilize broad categories
but make clear the emissions limitations; or (3) delete
electronics-related categories or subcategories until meaningful
and workable categories are developed. For documentation, the
commenter cites the Federal Register notice in which the Preamble
was printed for the listing of categories pertaining to
promulgation at the same time for all processes that fall within
a source category.
Response; No evidence of major sources within this category was
available.
Final Disposition; Electronics manufacture has been deleted from
the list.
17.34 Ethylidene Norbornene Production
Comment: None
Final Disposition; This source category will remain on the list.
17.35 Explosives Production
Comment: None
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Final Disposition: This source category will remain on the list.
17.36 Flame Retardant Production
Comment; One commenter (IV-D-66) noted that the Flame Retardants
Production source category is ill-defined, has insufficient
supporting data, and is not a major or area source.
Response: This source category has been deleted from the list
since no evidence was found to document major sources within this
category.
Comment: One commenter (IV-D-66) suggested an overlap exists
between the categories, Flame Retardants Production, Lube Oil
Additives, and Phosphate Esters, which at one of the commenter's
facilities represents one production process. They recommend
that EPA differentiate among the different types of flame
retardants, lube oil additives, and phosphate esters by the
solvolysis process from the listed categories, the alkoxide
process, and any others for which the commenter has no knowledge
of. Furthermore, the commenter noted that the emissions from
these processes are well below the thresholds that define a major
source.
Response; This source category has been deleted from the list
since no evidence was found to document a major sources within
this category.
Final Disposition: This source category has been deleted from
the list.
17.37 Hospital Sterilizers
Comment: None
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Final Disposition: This source category has been deleted from
the list.
17.38 Hydrazine Production
Comment: None
Final Disposition: This source category will remain on the list.
17.39 Industrial Cooling Towers
Comment; Two commenters (IV-D-66, IV-D-83) noted that the
Industrial Cooling Tower source category is ill-defined, has
insufficient supporting data, and is not a major or area source.
The second commenter (IV-D-83) noted that industrial cooling
tower should be considered as area sources. The commenter
requested that EPA thoroughly study them before adding this
source category to the list.
Response: Industrial Cooling Towers will remain on the list as a
category of major sources because they are co-located at major
sources, but it has been renamed Industrial Process Cooling
Towers.
Comment: Three commenters (IV-D-114, IV-D-116, IV-D-75)
requested that EPA designate or subdivide the category to include
those industrial cooling towers where chromium, nickel, or
phosphorus is emitted. The first commenter (IV-D-114) suggested
dividing the category into treatment options employed or deleting
the category and including the Targeted Treatment Chemicals as a
production/use category. They made this suggestion because they
believe HAP emissions are affected by specific cooling water
treatment chemicals used. The second commenter (IV-D-116) noted
that there is no basis for including all cooling towers as an air
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toxics source category. The commenter's use and knowledge of
cooling towers gives him reason to question the threat of adverse
effect on human health or the environment from all industrial
cooling towers. The commenter (IV-D-116) thought only those that
emit chromium should be regulated. The third commenter (IV-D-75)
made the same suggestion about excluding the industrial cooling
towers that do not use nickel, chromium compounds, and are not
major sources of phosphorus emissions. Also, they suggested that
facilities at mineral processing operations that may fall within
various other categories proposed for listing), (i.e., cooling
towers) be excluded because they do not emit the pollutant of
concern or otherwise fail to pose a significant threat to health
or the environment.
Response; Industrial Cooling Towers will remain on the list as a
category of major sources, because they are co-located at major
sources. They will be regulated for any HAP's that they emit;
adding or deleting pollutants at this time will have no impact on
the listing action.
Final Disposition: Industrial Cooling Towers will be listed as a
category of major sources. The name has been changed to
Industrial Process Cooling Towers.
17.40 Industrial Process Aids - Enhanced Oil Recovery
Comment; None
Final Disposition: This source category has been deleted from
the list because there was no evidence that is contained a major
source.
17.41 Ion Exchange Resins production
Comment: None
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Final Disposition: Due to lack of information indicating a major
source, this source category has been deleted from the list.
17.42 Jet Fuel Deicer Use
Comment: None
Final Disposition; This source category has been deleted from
the list, since no evidence was found to document major sources
within this category.
17.43 Leather Tanning
Comment: None
Final Disposition: This source category has been deleted from
the list, since no evidence was found to document major sources
within this category.
17.44 Lube Oil additives
Comment: One commenter (IV-D-66) noted that the Lube Oil
Additives source category is ill-defined, has insufficient
supporting data, and is not a major or area source.
Response; This source category has been deleted from the list,
since no evidence was found to document major sources within this
category.
Final Disposition; This source category has been deleted from
the list, since no evidence was found to document major sources
within this category.
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17.45 Lube Oil Dewaxing
Comment:; None
Final Disposition: This source category has been deleted from
the list; however, the processes and operations it encompasses
will be included in the Petroleum Refineries source category
under the Oil and Natural Gas Production and Refining industry
group.
17.46 Moth Repellent
Comment: None
Final Disposition; This source category has been deleted from
the list since no evidence was found to document major sources
within this category.
17.47 Oil/Gas Acidizing
Comment; The commenter (IV-D-74) noted that there is
insufficient data to list this source category and the emissions
from the category fall into the requirement of regulating as an
area source. The commenter makes this appeal to EPA based on
knowledge of the subject.
Response: This source category has been deleted from the list
since no evidence was found to document major sources within this
category.
Final Disposition; This source category has been deleted from
the list since no evidence was found to document major sources
within this category.
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17.48 Open-Top Vapor Degreasing
Comment: One commenter (IV-D-66) noted that the Open-Top Vapor
Degreasing source category is ill-defined, has insufficient
supporting data, and is not a major or area source.
Response; This source category has been combined with other
degreasing and cleaning operations to form the Halogenated
Solvent Cleaners source category. This source category has been
documented as containing a major -source and has been described to
make clear what processes and operations are included in the
source category.
Comment: One commenter (IV-G-04) requested the name of the
category be changed to Vapor Degreasing and that EPA clarify what
sources are involved with the category.
Response: This source category has been renamed Halogenated
Solvent Cleaners and has been clearly described to indicate what
processes and operations will be regulated.
Final Disposition: This source category has been renamed
Halogenated Solvent Cleaners.
17.49 Other Electroplating
Comment: One commenter (IV-D-66) noted that the Other
Electroplating source category is ill-defined, has insufficient
supporting data, and is not a major or area source.
Response; Electroplating operations are now covered only by the
three source categories: Hard Chromium Electroplating, Chromic
Acid Anodizing, and Decorative Chromium Electroplating. These
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have been listed as categories of major and area sources and have
been described according to what types of operations are
performed.
Final Disposition: This category has been deleted; however,
chromium electroplating operations and processes will be covered
by the three source categories: Hard Chromium Electroplating,
Chromic Acid Anodizing, and Decorative Chromium Electroplating.
17.50 Paint Removers Use
Comment: One commenter (IV-D-66) noted that the Paint Removers
Use source category is ill-defined, has insufficient supporting
data, and is not a major or area source.
Response: This source category has been found to contain a major
source and will remain on the list. It has been renamed Paint
Stripper Users.
Comment; One commenter (IV-D-83) noted that paint remover use
should be considered as an area source. The commenter requested
that EPA thoroughly study this source category before adding it
to the list.
Response: Because evidence of major sources has been documented,
Paint Strippers Users has been listed as a category of major
sources. Qualitative information is not adequate to list this
category as a category of area sources. Therefore, until
quantitative data are obtained that would warrant listing it as a
category of area sources, Paint Stripper Users cannot, be listed
as a category of area sources.
Final Disposition: This source category will remain on the list
of categories of major sources. It has been renamed Paint
Stripper Users.
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17.51 Paints, Coatings, and Adhesives: Manufacturing and Use
Comment; One commenter (IV-G-04) stated that the mixing of these
concepts is inappropriate and overlapping with operations that
should be considered as surface coating. The commenter believed
adhesives should be regulated as a separate category since they
are rarely used as a surface coating. Also, the commenter
suggested that EPA separate manufacture and use to help determine
applicability for industry, thus leaving EPA with two separate
categories.
Response: This source category will remain on the list but will
only address paints, coatings, and adhesives manufacturing. It
has been moved to the Surface Coating processing industry group.
Final Disposition; Paints, Coatings, and Adhesives Manufacture
will remain on the list but it has been moved to the Surface
Costing Processes industry group, and renamed Manufacture of
Paints, Coatings, and Adhesives.
17.52 Phosphate Esters Production
Comment: The commenter (IV-D-66) noted that the Phosphate Esters
Production source category is ill-defined, has insufficient
supporting data, and is not a major or area source.
Response: This source category has been deleted from the list
because it overlaps with other source categories in the
Agricultural Chemicals Production industry group.
Final Disposition; This source category has been deleted from
the list.
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17.53 Photographic Chemical Production
Comment; None
Final Disposition: This source category has been documented to
contain a major source and will remain on the list.
17.54 Photographic Film Processing
Comment: Three commenters (IV-D-40, IV-D-70, IV-D-99) urged EPA
to delete this category because the information in the background
document is incorrect. The commenter suggested this document
discusses methylene chloride emissions of 8100 Mg when referring
to another process and not film processing. Two of the
commenters (IV-D-40, IV-D-99) concur that these emissions are
from the film base. They requested that the category
Photographic Film Base Manufacture replace the source category
listed, with methylene chloride as a pollutant. The commenters
based their comments on knowledge of the industry and commenter
supporting documentation supplied by IV-D-40 on the processes in
question.
Response; This source category has been deleted from the list
since no evidence was found to document major sources within this
category.
Final Disposition: This source category has been deleted from
the list.
17.55 Phthalate Plasticizers Production
Comment: None
Final Disposition: This source category contains a major source
and will remain on the list.
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17.56 Polymerization Inhibitors Use
Comment: None
Final Disposition; Because there was no evidence of a major
source within this category, it has been deleted from the list,
17.57 Resins Catalyst Production
Comment: None
Final Disposition: This source category has been deleted from
the list because it overlaps with production processes in the
Synthetic Organic Chemical industry group.
17.58 Rubber Antioxidants Production
Comment: None
Final Disposition; This source category has been deleted as a
specific source category and combined in the Rubber Chemicals
Manufacturing source category.
17.59 Rubber Cement Manufacturing
Comment: None
Final Disposition; This source category has been deleted as a
specific source category and combined in the Rubber Chemicals
Manufacturing source category.
17.60 Rubber Chemicals Production
Comment: None
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Final Disposition: This source category will remain on the list,
but has been renamed Rubber Chemicals Manufacturing.
17.61 Semiconductor Manufacturing
Comment: One commenter (IV-D-91) suggested that the category is
too broad and overlapping with other source categories. The
commenter urged EPA to subcategorize the semiconductor industry
because requirements as standards for each of these subcategories
would potentially be regulated differently. The commenter based
this suggestion on engineering knowledge of the semiconductor
industry.
Response; This source category will remain on the list but has
been described to indicate which processes and operations occur
within this source category. It is difficult to be more specific
without more details on how the commenter believes the category
should be disaggregated. However, broad categories, like
semiconductor manufacturing, can always be disaggregated later.
Final Disposition: This source category will remain on the list.
17.62 Surface Active Agents Production
Comment: None
Final Disposition; Due to lack of information indicating a major
source, this source category has been deleted.
17.63 Symmetrical Tetrachloropyrldine Process
Comment: None
Final Disposition: This source category will remain on the list
because evidence of a major source is documented.
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17.. 64 Synthetic Tanning Agents Production
Comment; None
Final Disposition: Due to lack of information indicating a major
source, this source category has been deleted.
17.65 Vinylidene Chloride Copolymer Fabrication
Comment; None
Final Disposition; Due to lack of information indicating a major
source, this source category has been deleted.
17.66 Wood Preservation - Direct Use
Comment: None
Final Disposition: This source category will remain on the list
bxit has been renamed Wood Treatment.
17.67 Polyether Polyols Production
Comment: None
Final Disposition: This source category will remain on the list
because evidence of major sources has been documented. However,
additional information obtained by EPA reveals that this category
should not be a part of the Polymers and Resins Industry Group.
Therefore, Polyether Polyols has been moved to the Miscellaneous
Industry Group.
17.68 Chromic Acid Anodizing
Comment: None
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Final Disposition; For final disposition of this source category
see comment 17.24.
17.69 Decorative Chromium Electroplating
Comment; None
Final Disposition; For final disposition of this source category
see comment 17.24.
17.70 Hard Chromium Electroplating
Comment; None
Final Disposition; For final disposition of this source category
see comment 17.24.
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18.0 TOXIC RELEASE INVENTORY SYSTEM (TRIS) PRODUCTION AND USE
ACTIVITIES
General Comments
Comment; One commenter (IV-D-32) requested that TRIS Production
and Use Activities be listed as separate industry groups. This
commenter pointed out that a specific substance could release
different types of pollutants depending on the specific role of
that substance in a production or use activity. The commenter
also noted that the appropriate control technologies needed to
reduce emissions of the released pollutants could also vary
depending on pollutant type.
Response: Unless otherwise reflected in the revised list, it is
not generally the intent to regulate end uses under Title III of
the Clean Air Act (CAA). Furthermore the TRIS Production and Use
Activities industry group, along with all its associated source
categories (except Antimony Oxides Manufacturing and Carbonyl
iSulfide Production) , have been deleted from the list.
Comment; One commenter (IV-D-36) stated that the 1988 TRIS data
do not accurately reflect current industrial practices. The
information in the TRIS data base is for calendar year 1988. The
commenter added that because the TRIS information reporting
system was relatively new and not well understood at the time it
was compiled, some of the information is of questionable
validity. The commenter also noted that there is no direct
correlation between chemicals reported on the TRIS and the
specific operations identified by Standard Industrial
Classification (SIC) codes. For this reason, the commenter
stated that there is no way to match a particular SIC code to a
chemical released by a particular process at a facility.
B-202
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Finally, the commenter pointed out that the textile industry has
eliminated or significantly reduced the use of a number of
chemicals reported in the 1988 TRIS.
Response: The TRIS Production and Use Activities industry group,
along with its associated source categories (except Antimony
Oxides Manufacturing and Carbonyl Sulfide Production) have been
deleted from the list.
Comment: Two commenters (IV-D-69, IV-D-76) urged EPA to
establish a separate source category for Production of Antimony
Oxides. In addition, the commenter stated that production
processes involving antimony oxides should be regulated under
separate source categories from end uses of antimony oxides.
The circumstances surrounding use of antimony oxides are quite
different from those surrounding production. The most common end
uses for antimony oxides are fire retardant in plastics, ranging
from television cabinets, small appliances, and video cassette
cases to airplane interiors and vinyl upholstery. Concerning
production processes, antimony oxides are used to produce various
polymer compounds. The major resin systems in these processes
typically include polystyrene, polyvinyl chloride, polyethylene,
polypropylene, and acrylobutadiene styrene.
Response: Because evidence of a major source within Antimony
Oxides Manufacturing has been documented, this category has been
included on the list within the Inorganic Chemical Production
industry group. Unless otherwise reflected in the revised list,
it is not generally the intent to regulate end uses under
Title III of the CAA.
Comment: Four commenters (IV-D-04, IV-D-48, IV-D-62, IV-D-66)
recommended that only producers of and disposal operations for
polychlorinated biphenyls (PCB) should be included on the source
category list. The second commenter stated that with the current
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wording of the source category titles, it is not clear what will
be included in the potentially regulated community. The first
commenter (IV-D-04) pointed out that because the use of PCB in
closed systems (transformers and capacitors) is regulated under
the Toxic Substances Control Act (TSCA), there is no need to
regulate use of PCB in closed systems beyond what exists today.
The commenter stated that either the category should be limited
to production of PCB or it should somehow include open systems in
the title.
The third and fourth commenters (IV-D-66, IV-D-62)
requested that the "use" portion of the TRIS Production and Use
Activities industry group be deleted from these listings. These
commenters urged that a more careful characterization of the
source categories is needed to avoid an expensive and time-
consuming delisting process.
Response; Due to difficulty in identifying specific categories
of major sources, the TRIS Production and Use Activities industry
group, along with its associated source categories (except
Antimony Oxides Manufacturing and Carbonyl Sulfide Production),
have been deleted from the list.
Comment; Two commenters (IV-D-76, IV-D-124) requested that the
"Production and Use" wording in the title of this industry group
be clarified. The commenter maintains that only those sources
that both produce and use, not just use, the listed chemicals
should be regulated. This commenter suggested that EPA's listing
of categories is too general for this industry group and that a
potential overlap of source categories exists due to the
different approaches used for listing. The second commenter
(IV-D-121) stated that numerous listed categories appear to be
duplicative, especially those included in the TRIS Production and
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Use industry group. The commenter thought that some of these
items ought to appear as subcategories of pesticide/herbicide
manufacturing or organic chemicals manufacturing.
Response; The TRIS Production and Use Activities industry group,
along with its associated source categories (except Antimony
Oxides Manufacturing and Carbonyl Sulfide Production) have been
deleted from the list. This deletion action was due, in part, to
the potential for duplication created by source categories listed
in this industry group.
Final Disposition; The EPA has determined that the TRIS
Production and Use Activities industry group included source
categories that were duplicative with other listed categories or
that were not sufficiently distinct for the listing of specific
source categories. Therefore, EPA has deleted these source
categories (except for Antimony Oxides Manufacturing and Carbonyl
Sulfide Production).
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing]
REPORT NO.
EPA-450/91-030
3 RECIPIENT'S ACCESSION NO
4. TITLE ANDSUBTITLE
Documentation for Developing the Initial Source
Category List
5. REPORT DATE
July 1992
6 PERFORMING ORGANIZATION CODE
7 AUTHOR(S)
8 PERFORMING ORGANIZATION REPORT NO
9 PERFORMING ORGANIZATION NAME AND ADDRESS
Emission Standards Division
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
1C PROGRAM ELEMENT NO
11 CONTRACT/GRANT NO
68-D1-0117
12. SPONSORING AGENCY NAME AND ADDRESS
Director of Air Quality Planning and Standards
office of Air and Radiation
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13 TYPE OF REPORT AND PERIOD COVERED
Final
14, SPONSORING AGENCY CODE
EPA/2UG/04
15 SUPPLEMENTARY NOTES
16. ABSTRACT " ' —— . ___
Under the autnority of Section 112 of the Clean Air Act, the EPA has developed an
initial list of categories of all major sources and selected area sources which
emit one or more of tne 189 hazardous air pollutants identified in Section il2(o)
of the clean Air Act. This document summarizes the technical approach used to
develop the initial list, lists the categories by industry groups, provides a brief
description of each listed category, and includes a summary'of the public comments
received after publication of the preliminary draft list and the EPA responses to
these comments.
17.
a
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field'Group
Air pollution
Hazardous air pollutants
Source category
Major sources
Maximum achievable control technology
Hazardous air pollutants
18. DISTRIBUTION STATEMENT
Release unlimited
19 SECURITY CLASS (Tins Reporti
Unclassified
21 NO OF PAGES
368
20. SECURITY CLASS /This page/
Unclassified
22 PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
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