United States
        Environmental Protection
        Agency
                Office of Air Quality
                Planning and Standards
                Research Triangle Park, NC 27711
EPA-453/R-95-004a
March 1995
        Air
iEPA
Hazardous Air Pollutant
Emissions from Process
Units in the Thermoplastics
Manufacturing Industry--

Basis and Purpose Document
for Proposed Standards

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                                            EPA-453/R-95-Q04a
     Hazardous Air Pollutant Emissions
         From Process Units in the
              Thermoplastics
         Manufacturing Industry—

             and Purpose Document
          for Proposed Standards
        Emission          Division
    U.S. Environmental Protection Agency
        Office of Air And Radiation
 Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
                March 1995

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                           DISCLAIMER

This Report has been reviewed by the Emission Standards Division
of the Office of Air Quality Planning and Standards,  EPA,  and
approved for publication.  Mention of trade names or commercial
products is not intended to constitute endorsement or
recommendation for use.

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               ENVIRONMENTAL PROTECTION AGENCY
 Hazardous Air Pollutant Emissions from Process Units in the
 Thermoplastics Manufacturing Industry — Basis and  Purpose
               Document for Proposed Standards


1.   The standards regulate organic hazardous air pollutant
     (HAP) emissions from the production of acrylonitrile
     butadiene styrene  (ABS) resin, styrene acrylonitrile
     (SAN) resin, methyl methacrylate acrylonitrile
     butadiene styrene  (MABS) resin, methyl methacrylate
     butadiene styrene  (MBS) resin, polystyrene resin,
     poly(ethylene terephthalate)  (PET) resin, and nitrile
     resin.  Only those thermoplastic product process units
     that are part of major sources under section 112(d) of
     the Clean Air Act  (Act) will be regulated.

2.   For additional information contact:

     Mr. Leslie Evans
     Organic Chemicals Group
     U.S. Environmental Protection Agency
     Research Triangle Park, NC  27711
     Telephone: (919) 541-5410

3.   Paper copies of this document may obtained from:

     U.S. Environmental Protection Agency Library (MD-36)
     Research Triangle Park, NC  27711
     Telephone:  (919) 541-2777

     National Technical Information Service (NTIS)
     5285 Port Royal Road
     Springfield,  VA  22161
     Telephone: (703) 487-4650

4.   Electronic copies of this document may be obtained from
     the EPA Technology Transfer Network (TTN).  The TTN is
     an electronic bulletin board system which is free,
     except for the normal long distance charges.  To access
     the Basis and Purpose Document:

          Set software communication setting to 8 bits, no
          parity,  and 1 stop bit
          Set a terminal emulation of either VT100,  VT102,
          or ANSI
          Baud rates of 1200, 2400, 9600, and 14,400 are
          accepted
                             111

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Use access number (919) 541—5742; access problems
should be directed to the system operator at
(919) 541-5384
Register online by providing a personal name,
password, and company name, address, and phone
number
Specify TTN Bulletin Board:  CAAA (Clean Air Act
Amendments)
Select menu item:  Title III:  Hazardous Air Poll.
Select menu item:  Policy Guidance Documents
To download, type filename:  PR4_BSP.ZIP (3/20/95
Basis and Purpose - Polymers/Resins Group IV)
                   IV

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                         TABLE  OF  CONTENTS


                                                              Page

1.0  PURPOSE OF DOCUMENT	1-1

2.0  INTRODUCTION	2-1

3.0  DESCRIPTION OF THE  AFFECTED  INDUSTRY	3-1

     3.1  DESCRIPTION OF PROCESSES AND SOURCES OF
          HAP EMISSIONS	3-5

4.0  RATIONALE FOR THE SELECTION  OF SOURCE CATEGORIES,
     SUBCATEGORIZATION,  AND EMISSIONS AVERAGING  	  4-1

     4.1  RATIONALE FOR  THE SELECTION OF SOURCE
          CATEGORIES	4-1
     4.2  RATIONALE FOR  SUBCATEGORIZATION	4-1
     4.3  EMISSIONS AVERAGING	4-9

5.0  BASELINE EMISSIONS  	  5-1

6.0  MACT FLOORS AND REGULATORY ALTERNATIVES  	  6-1

     6.1  CLEAN AIR ACT  REQUIREMENTS	6-1
     6.2  DETERMINATION  OF MACT FLOORS	6-3
     6.3  RESULTS OF MACT FLOOR DETERMINATION	6-15

7.0  SUMMARY OF ENVIRONMENTAL, ENERGY, COST,
     AND ECONOMIC IMPACT	7-1

     7.1  FACILITIES AFFECTED BY THESE NESHAP 	  7-1
     7.2  PRIMARY AIR IMPACTS	7-3
     7.3  NON-AIR ENVIRONMENTAL	7-5
     7.4  ENERGY IMPACTS	7-5
     7.5  COST IMPACTS	  7-7
     7.6  ECONOMIC IMPACTS  	  7-9

8.0  SELECTION OF THE STANDARDS	8-1

     8.1  SUMMARY OF THE PROPOSED STANDARDS	8-1
     8.2  RATIONALE FOR THE SELECTION OF EMISSION
          POINTS TO BE COVERED BY THE PROPOSED STANDARDS   .   8-44
     8.3  RATIONALE FOR THE SELECTION OF THE PROPOSED
          STANDARDS	   8-44
     8.4  RATIONALE FOR THE SELECTION OF THE FORMAT OF
          THE PROPOSED STANDARDS  .  .  	 ..... 8-103

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                  TABLE OF  CONTENTS   (Concluded)
                                                             Page

     8.5  RATIONALE FOR THE SELECTION OF COMPLIANCE AND
          PERFORMANCE TEST PROVISIONS AND MONITORING
          REQUIREMENTS  	 8-107
     8.6  RATIONALE FOR THE SELECTION OF PARAMETER
          MONITORING AND COMPLIANCE CERTIFICATION
          PROVISIONS	8-116
     8.7  RATIONALE FOR THE SELECTION OF RECORDKEEPING
          AND REPORTING REQUIREMENTS  	 8-119
     8.8  OPERATING PERMIT PROGRAM  	 8-126

9.0  REFERENCES	9-1
                               VI

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                          LIST OF TABLES
TABLE 3-1
TABLE 3-2
TABLE 5-1

TABLE 5-2
TABLE 5-3
TABLE 6-1
TABLE 6-2
TABLE 6-3

TABLE 7-1
TABLE 7-2

TABLE 8-1
TABLE 8-2
TABLE 8-3

TABLE 8-4
TABLE 8-5
TABLE 8-6


TABLE 8-7

TABLE 8-8


TABLE 8-9

TABLE 8-10

TABLE 8-11

TABLE 8-12
                                               Page

THERMOPLASTIC PRODUCTION FACILITIES   .  .  .  .  .3-2
THERMOPLASTIC PRODUCTION PROCESSES BY
SUBCATEGORY	3-12

BASELINE ORGANIC HAP EMISSIONS FOR EXISTING
SOURCES	5-2
BASELINE ORGANIC HAP EMISSIONS FOR NEW  SOURCES 5-4
MAJOR HAZARDOUS AIR POLLUTANTS EMITTED
BY SUBCATEGORY	5-6

MACT FLOOR ANALYSIS FOR EXISTING SOURCES  .  .   6-17
MACT FLOOR ANALYSIS FOR NEW SOURCES   ....   6-19
SUMMARY OF MACT FLOOR STRINGENCY ......   6-22

ORGANIC HAP EMISSIONS AND EMISSION REDUCTIONS   7-4
SUMMARY OF COST IMPACTS	7-8

SUMMARY OF PROPOSED STANDARDS FOR
EXISTING SOURCES IN RELATIONSHIP TO
SUBPARTS G AND H OF 40 CFR PART 63
AND THE POLYMERS NSPS	  8-8
SUMMARY OF PROPOSED STANDARDS FOR
NEW SOURCES IN RELATIONSHIP TO SUBPARTS
G AND H OF 40 CFR PART 63
AND THE POLYMERS NSPS	8-11
PROPOSED STANDARDS FOR EXISTING STORAGE
VESSELS	8-15
PROPOSED STANDARDS FOR NEW STORAGE VESSELS  .   8-16
SUMMARY OF PROPOSED PROCESS VENT
APPLICABILITY CRITERIA FOR EXISTING
FACILITIES	   8-22
SUMMARY OF PROPOSED PROCESS VENT
APPLICABILITY CRITERIA FOR NEW
FACILITIES	8-23
PROPOSED WASTEWATER APPLICABILITY
CRITERIA	8-31
REGULATORY ALTERNATIVE IMPACTS FOR
EXISTING POLYSTYRENE CONTINUOUS
FACILITIES	  .  .   8-60
REGULATORY ALTERNATIVE IMPACTS FOR
EXISTING TPA CONTINUOUS FACILITIES .....   8-66
REGULATORY ALTERNATIVE IMPACTS FOR
EXISTING TPA BATCH FACILITIES  	   8-70
REGULATORY ALTERNATIVE IMPACTS FOR
EXISTING DMT BATCH FACILITIES  .  .  .   .  .  .  .   8-73
REGULATORY ALTERNATIVE IMPACTS FOR
EXISTING DMT BATCH FACILITIES  	   8-77
                               VI1

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                         LIST OF FIGURES

                                                             Page

FIGURE 3-1     SIMPLIFIED FLOW DIAGRAM FOR THE
               THERMOPLASTICS MANUFACTURING PROCESS 	 3-6

FIGURE 4-1     THERMOPLASTICS SUBCATEGORIZATION 	 4-6
                              Vlll

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                  1.0  PURPOSE OF DOCUMENT





     The Basis and Purpose Document provides background



information on, and rationale for, decisions made by the



Environmental Protection Agency  (EPA) related to the



proposed standards for the reduction of hazardous air



pollutants  (HAP) emitted through the production of seven



source categories of thermoplastics  (Group IV Polymers and



Resins).  These source categories include the production of



acrylonitrile butadiene styrene  (ABS) resin, styrene



acrylonitrile  (SAN) resin, methyl methacrylate acrylonitrile



butadiene styrene  (MABS) resin, methyl methacrylate



butadiene styrene  (MBS) resin, polystyrene resin,



poly(ethylene terephthalate)   (PET) resin, and nitrile resin.



This document is intended to supplement the preamble for the



proposed standards.



     This document is separated into 8 chapters providing a



combination of background information and rationale for



decisions made in the standards development process.



Chapters 2,  3, 5,  and 7 provide background information;



chapter 2 is an introduction, chapter 3 describes the



affected industry,  chapter 5 presents the baseline organic



HAP emissions, and chapter 7 presents the predicted impacts



associated with the selected regulatory alternatives.





                             1-1

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Chapters 4, 6, and 8 provide rationale for



subcategorization, determination of MACT "floors" and



development of regulatory alternatives,  and rationale for



the selection of the proposed standards,  respectively.



     Supporting information and more detailed descriptions



of certain analyses are contained in the memoranda



referenced in this document, the Supplementary Information



Document (SID), the preamble, and the project docket.
                             1-2

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                      2.0  INTRODUCTION





     Section 112 of the  Clean Air Act  (Act), as amended in



1990, gives the EPA the  authority to establish national



standards to reduce air  emissions from sources that emit one



or more HAP.  Section  112(b) contains a list of HAP to be



regulated by National  Emission Standards for Hazardous Air



Pollutants  (NESHAP), and Section 112 (c) directs the EPA to



use this pollutant list to develop and publish a list of



source categories for  which NESHAP will be developed.  The



EPA must list all known source categories and subcategories



of "major sources" that emit one or more of the listed HAP.



A major source is defined in section 112(a) as 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, in the aggregate,



considering controls,   10 tons per year or more of any one



HAP or 25 tons per year or more of any combination of HAP.



This list of source categories was published in the Federal



Register on July 16,  1992 (57 FR 31576),  and includes the



following six source categories:



          •    Acrylonitrile butadiene styrene resin,



          •    Styrene acrylonitrile resin,
                            2-1

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          •    Methyl methacrylate acrylonitrile butadiene

               styrene resin,

          •    Methyl methacrylate butadiene styrene resin,

          •    Polystyrene resin, and

          •    Poly(ethylene terephthalate) resin.

A seventh source category, nitrile resin is being proposed

as an addition to the source category list.

     The products manufactured by facilities in these seven

source categories are called thermoplastics.a  A

thermoplastic is a resin that softens with heat and

rehardens to a rigid material upon cooling, without

generally showing any change in the physical-properties of

the thermoplastic, even through repeated heating and

cooling.1  Thermoplastics are composed of high-molecular-

weight polymers which are synthesized from monomers; the

thermoplastics covered in these seven source categories,

with one exception, use styrene monomer as the basic

feedstock.

     The thermoplastics produced by the seven source

categories listed above are used in the manufacture of goods

such as packaging materials and containers, polyester

fibers, electrical insulation, automotive components,
     a  While the term "thermoplastic"  is  used throughout
this document and other background materials for the
proposed NESHAP to describe the products produced by the
seven source categories listed above, these products only
make up a subset of the wide range of polymers generally
referred to as thermoplastics.

                             2-2

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furniture, radio and television components, housewares,



appliances, wall tiles, and x-ray film.
                            2-3

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          3.0  DESCRIPTION OF THE AFFECTED INDUSTRY





     The seven source categories covered under the proposed



rule have been grouped together because of similarities in



process operations, emission characteristics, and control



device applicability and costs.  These seven thermoplastic



source categories are collectively referred to as the Group



IV polymers and resins or the Group IV thermoplastics.



     The EPA identified a total of 66 plant sites producing



one or more of the seven thermoplastics.  All of the



facilities considered in the analysis supporting the



proposed rule are believed to either be a major source or to



be located at a plant site that is a major source.



     Table 3-1 identifies the known producers of the seven



thermoplastics, along with their facility locations.  The



thermoplastics manufacturing facilities covered in the scope



of this NESHAP are located in 23 States, including South



Carolina,  North Carolina,  Ohio, Illinois,  Alabama,



Pennsylvania, Texas,  Tennessee, Massachusetts,  and



California.
                            3-1

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TABLE 3-1.   THERMOPLASTIC PRODUCTION FACILITIES
Source
Category
PET
PET
PET
PET
PET
PET
PET
PET
PET
PET
PET
PET
PET
PET
PET
PET
PET
PETa
PETa
PETa
PETa
PET3
PET,
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Company
We 11 man
YKK
Tennessee Eastman
3M
BASF
Hoechst Celanese
DuPont
DuPont
Hoechst Celanese
DuPont
DuPont
DuPont
DuPont
Allied Signal
DuPont
ICI Films
Hoechst Celanese
Carolina Eastman
Shell
Eastman Kodak
Hoechst Celanese
ICI Films
3M
Scott Polymers
Huntsman Chemical
Novacor Chemicals
Novacor Chemicals
Location
Darlington, SC
Macon , GA
Kingsport , TN
Greenville, SC
Lowland, TN
Greer, SC
Kins ton, NC
Old Hickory, TN
Spartanburg, SC
Cape Fear, NC
Brevard, NC
Florence, SC
Circleville, SC
Moncure , NC
Cooper River, SC
Hopewell, VA
Shelby, NC
Columbia, SC
Apple Grove, WV
Rochester, NY
Salisbury, NC
Fayetteville, NC
Decatur, AL
Saginaw-1, TX
Chesapeake , VA
Decatur- 1, AL
Decatur- 2, AL
                      3-2

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TABLE 3-1.  THERMOPLASTIC PRODUCTION FACILITIES  (Continued)
Source
Category
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
Polystyrene
ASA/AMSAN,
Polystyrene
Polystyrene,
ABS
Company
Novacor Chemicals
Huntsman Chemical
Huntsman Chemical
Scott Polymers
Rohm and Haas
Kama
Huntsman Chemical
Scott Polymers
Arco Chemical
BASF
BASF
BASF
Arco Chemical
Amoco Chemical
American Polymers
Amoco Chemical
Amoco Chemical
Fina Oil & Chemical
BASF
Dow Chemical
Dow Chemical
Chevron Chemical
Dart Container
Dart Container
GE Plastics
Dow Chemical
Location
Indian Orchard, MA
Belpre, OH
Peru, IL
Saginaw-2, TX
Philadelphia, PA
Hazel ton, PA
Rome , GA
Fort Worth, TX
Monaca , PA
Holyoke, MA
Santa Ana, CA
Joliet, IL
Painesville, OH
Willow Springs, IL
Oxford, MA
Joliet, IL
Torrance , CA
Carville, LA
South Brunswick, NJ
Joliet, IL
Riverside, MO
Marietta, OH
Owensboro , KY
Leola, PA
Selkirk, NY
Hanging Rock, OH
                            3-3

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TABLE 3-1.  THERMOPLASTIC PRODUCTION FACILITIES  (Continued)
Source
Category
Polystyrene,
ABS
Polystyrene,
ABS
Polystyrene ,
ABS
ABS
ABS
ABS, MABS
ABS, SAN
ABS, SAN,
Polystyrene
MBS
MBS
MBS 	
Nitrile
SAN
Company
Dow Chemical
Dow Chemical
Dow Chemical
BF Goodrich
GE Plastics
GE Plastics
Monsanto
Monsanto
Rohm and Haas
Elf Atochem
iCaneka Texas Corp.
BP Chemicals
GE Plastics
Location
Torrance , CA
Allyn's Point, CT
Midland, MI
Akron, OH
Ottawa, IL
Washington, WV
Muscatine, IA
Addyston, OH
Louisville, KY
Axis, AL
Pasadena, TX
Lima , OH
Bay St. Louis, MS
     These facilities also use a solid state process.
                            3-4

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3.1  DESCRIPTION OF PROCESSES AND SOURCES OF ORGANIC HAP



     EMISSIONS



     Polymerization processes are used to manufacture



thermoplastics.  A simplified process flow diagram of the



thermoplastics manufacturing process is provided in



Figure 3-1.  Subsequent paragraphs describe the



polymerization process in general and the typical emission



points.
                            3-5

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      1) Storage and Raw Material Preparation
             2) Polymerization
            3) Material Recovery
               4) Finishing
Figure  3-1.
Simplified  Flow Diagram
for  the Thermoplastics
Manufacturing Process
                    3-6

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 3.1.1  General  Process Description



     In polymerization, a large number  (hundreds to



 thousands) of relatively simple molecular units, or



 monomers, are chemically combined to form a macromolecule,



 or polymer.  Polymer manufacturing can be divided into



 four areas:   (1) raw material storage and preparation,  (2)



 polymer formation  in a reactor  (3) material recovery, and



 (4) finishing.  The basic raw materials for polymerization



 are monomers and either solvents or water.



     Four types of polymerization are generally used in the



 thermoplastics manufacturing industry: emulsion, suspension,



 mass, and solution.  In emulsion polymerization, monomers



 are dispersed in water using a soap solution or an



 emulsifier.  In suspension polymerization, the monomer is



 suspended in a water phase.  In mass polymerization,



 monomers are reacted without the use of emulsifiers,



 suspending agents, salts or waters,  although a solvent may



 be used.  In solution polymerization, monomers are dissolved



 in .an organic solvent.  The production of PET does not fall



 under any of these four types of polymerization (see the



 process description memo for PET in the SID in Category II-B



 of the docket).



     Following polymerization,  any unreacted monomer,



 solvent or other material is recovered/removed by stripping,



devolatilizing,  or through some other means.   Finally,



 finishing operations may consist of  blending,  aging,





                            3-7

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coagulation  (to produce solid polymers),  washing, and drying



processes, depending on the eventual use of the polymer.



3.1.2  Description of Emission Points



     Five types of organic HAP emission points are commonly



found at thermoplastic production facilities:  storage of



pure organic HAP used as raw materials, process-related



emissions (process vents and process fugitives),  waste and



wastewater collection and treatment operations, equipment



leaks (pumps, valves, connectors, etc), and heat exchange



systems to include process contact cooling towers.



Emissions from raw material atmospheric storage vessels



typically occur as working and breathing losses.   Residual



concentrations of organic HAP are usually very low in



intermediate and finished thermoplastics products and, as a



result,  emissions from product storage tanks are negligible.



     Process-related organic HAP emission points include



vents from raw material preparation, monomer polymerization,



material recovery, and finishing operations.  In addition,



significant fugitive emissions can occur during the



finishing and drying of solid polymer products.  Emissions



from the reactors in the polymerization area may occur



during initial charging of the reactants and/or during the



polymerization reaction.  These emissions may be steady or



sporadic, depending on the mode of process operation  (i.e.,



continuous or batch), and generally contain organic HAP



monomer(s) and/or solvent.  The organic HAP concentration in





                             3-8

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reactor vent emissions can be relatively high, due to the



high concentrations of unreacted monomer and solvent present



in the reactor.



     Process vent streams from stripping unit operations can



have high organic HAP concentrations, but they are usually



routed to a material recovery device that recovers the



valuable monomer or solvent for re-use.



     Finishing emissions can be associated with coagulation



tanks, slurry or blending tanks, and dewatering screens and



filters.  The organic HAP concentrations in finishing area



process vent streams are much less than the concentrations



in reactor or stripper vent streams.  Dryer vents are often



the largest source of process vent emissions from



thermoplastics production.  These process vents are



characterized by low concentrations of organic HAP, but very



large volumetric flowrates.



     The emissions from many of the finishing and drying



operations are not completely captured or vented to



traditional vent stacks.   This type of emission is referred



to as process fugitive emissions.  Finishing operations are



often located in large warehouse-type buildings,  and process



fugitive emissions are removed from the work space through



roof fans and other general building ventilation.



     Equipment leaks occur primarily at connections between



different equipment components.   The characteristics of



these emissions for the thermoplastics industry are similar





                            3-9

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to those associated with the synthetic organic chemical



manufacturing industry  (SOCMI),  which are discussed in



greater detail in the final preamble to the Hazardous



Organic NESHAP (HON)  (59 PR 19402; April 22, 1994) .



Emissions from equipment leaks associated with operations



downstream from coagulation equipment will be minimal, due



to the low residual organic HAP content in the streams.



     Wastewater streams containing organic compounds may be



generated during thermoplastic production.  Sources of



wastewater containing organic HAP include the monomer



refining, stripping, material recovery, and finishing



processes.  While the largest wastewater generation is



associated with the finishing process, the concentration of



organic HAP in finishing wastewater is usually very low,



because residual organic HAP have been removed during the



stripping of the raw product.  Heat exchange systems,



including process contact cooling towers, can be used in the



production of thermoplastics.  Heat exchange systems are



emission points if either (1)  a non-contact heat exchange



system develops a leak,  or (2) a process contact heat



exchange system,  typically a process contact cooling tower,



is used.  Both non-contact and process contact heat exchange



systems are known to be used by the industry.



3.1.3  Summary of Processes



     Table 3-2 shows the types of processes that were



identified to be in use at active facilities in each source





                            3-10

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category.  Although other types of processes that produce



these products were described in the literature,  no plants



were identified that actively used these other processes.
                           3-11

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 TABLE 3-2.
THERMOPLASTIC PRODUCTION PROCESSES BY
       SUBCATEGORY

Aery lonit rile
Butadiene Styrene
Production
Styrene
Acrylonitrile
Production
Methyl
Methacrylate
Acrylonitrile
Butadiene
Styrene Production
Methyl
Methacrylate
Butadiene Styrene
Production
Polystyrene
Production
Nitrile Production
Poly (ethyl ene
terephthalate
Production3
Emulsion
/
/
/
/
/
/

Suspension
/
/


/


Mass
/
/


/


Solution




/


Other






/
Poly(ethylene terephthalate)  production cannot be
classified under one of these four polymerization
types.  For more information on the Poly(ethylene
terephthalate) process, see the memo entitled "Process
Description for Poly(ethylene terephthalate) Resins"
contained in Docket A-92-45,  Category II-B and in the
SID.
                       3-12

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     A description of each manufacturing process, and of



organic HAP emission points for each of the seven



thermoplastics, with the exception of nitrile resins, is



contained in the process description memorandum found in the



docket (Docket No. A-92-45, Category II-B)  and is included



as part of the SID.
                            3-13

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   4.0  RATIONALE FOR THE SELECTION OF SOURCE CATEGORIES,
         SUBCATEGORIZATION, AND EMISSIONS AVERAGING
4 .1.  RATIONALE FOR THE SELECTION OF SOURCE CATEGORIES

     Six of the seven source categories selected for the

development of the proposed rule are listed in the source

category list published on July 16, 1992  (57 FR 3156) .

Information gathered during the development of the proposed

rule indicated that all of the facilities in these six

source categories are major sources.  The seventh source

category, nitrile resins, is included under the proposed

rule because information obtained during the information

gathering phase of the project demonstrated that it was

similar to the other source categories included in this

group, especially the styrene-based facilities.  In

addition, the one facility identified as producing nitrile

resins was also determined to be a major source.

4.2  RATIONALE FOR SUBCATEGORIZATION

4.2.1  Subcatecrorization Results

     In developing standards, the EPA has the discretion to

distinguish or segregate classes, types, and sizes of

sources within a source category and,  conversely, to

aggregate among similar source categories.  Criteria that

may be considered in defining categories of similar sources

include similarities in process operations (including

                             4-1

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differences between batch and continuous operations),



emissions characteristics, control device applicability and



costs, safety considerations, and pollution prevention



opportunities.



     How source categories are defined is important because



it dictates the basis upon which the "floor" is to be



determined for a maximum achievable control technology



(MACT) standard.  Put another way, the definition of source



category describes the "pool" of facilities that can be used



to define the MACT floor.  (Note:  Facility is the term used



in the 1990 Amendments definition of the MACT floor.)   This



means that the MACT floor must be determined on the same



basis upon which source category is defined.  The definition



of source category is also important in that it limits the



scope of emissions averaging; collocated emission points



cannot emissions average unless they belong to the same



source category.



     Within four of the seven listed thermoplastic



production source categories, significant variations in



production methods and/or raw material usage exist.



Therefore, for purposes of the proposed rule, the EPA has



split these four categories -- ABS, SAN, polystyrene,  and



PET -- into subcategories.



     The major distinction within most source categories is



that some facilities use a batch operation, while other



facilities use a continuous operation.  This difference





                             4-2

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often gives rise to very different process emission stream



characteristics, which can affect the type of control device



most suitable for control.  For example, process vents from



continuous operations are often characterized by fairly



consistent pollutant concentrations, while process vents



from batch operations are often characterized by widely



varying pollutant concentrations during the emission event.



Another distinction was made in the PET industry based on



whether dimethyl terephthalate  (DMT) or terephthalic acid



(TPA) is used as a raw material.  When DMT is used, a large



amount of methanol is generated as a by-product, mainly



during the esterification process step.  This methanol is



captured and recovered on-site.  The TPA process does not



generate methanol as a by-product.   The generation of



methanol, therefore, results in the presence of methanol



recovery equipment and greater esterification emissions at



DMT facilities.



     In determining the definition to select for source



category, the EPA considered the similarities and



dissimilarities discussed above, and,  to a much lesser



degree,  the amount of collocation of processes (i.e.,



subcategories)  at each facility and the potential for



emissions averaging.



     The EPA concluded that subcategorization was not



necessary in three of the thermoplastic source categories



(MABS,  MBS,  and nitrile resin).  Only three facilities were





                            4-3

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found to produce MBS and the process used did not vary

significantly.  Only one facility was found to produce MASS

and only one to produce nitrile.

     In summary, four of the seven thermoplastic source

categories were subcategorized creating a total of 18

separate subcategories.b  These subcategories  are:

   • PET resin using a continuous TPA process,

   • PET resin using a batch TPA process,

   • PET resin using a continuous DMT process,

   • PET resin using a batch DMT process,

   • polystyrene resin using a continuous process,

   • polystyrene resin using a batch process,

   • expandable polystyrene (EPS) resin,

   • ABS resin using a continuous emulsion process,

   • ABS resin using a continuous mass process,

   • ABS resin using a batch emulsion process,

   • ABS resin using a batch suspension process,

   • ABS latex resin,

   • SAN resin using a continuous process,

   • SAN resin using a batch process,
     b  For the  purposes  of  this  document,  the term
"subcategory" will be generally used to describe the group
of sources that were analyzed together.  In fact, these
groups of sources can be either sources belonging to a
single source category as defined in the EPA's original
list, sources belonging to a source category that is
proposed to be added to the EPA's list, (i.e., nitrile
sources) or sources belonging to a subcategory.

                             4-4

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   • acrylonitrile styrene acrylate/alpha methyl styrene



     acrylonitrile (ASA/AMSAN) resin,



   • MASS resin,



   • MBS resin,  and



   • nitrile resin.



Figure 4-1 contains a schematic of subcategorization for the



thermoplastic source categories.
                            4-5

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AcrylonKrile
 Butadiene
  Styrene
   (ABS)
  Styrene
Acryfonitrile
  (SAN)
         - Continuous, emulsion

         -Continuous, mass

         - Batch, wnulslon


         -Bat*, latex

         . Batch, suspension
  Methyl
Methacrylate
Acrylonitrile
 Butadiene
  Styrene
  (MASS)
  Methyl
Methacrylate
 Butadiene
  Styrene
  (MBS)
                                              Poly(ethylene
                                              terephthalate
                                                 (PET)
                    -Continuous
                    •Bald)
                    • EPS
                                                  Nitrite
                   - TPA, continuous


                   •TPA, batch


                   - DMT, continuous


                   . DMT. batch
             ASA     - aoylonitrile styrene acrylate
             AMSAN  - alpha methyl styrene acrylonitrile
             EPS     - expandable polystyrene
             TPA     - terephthalic acid
             DMT     - dimethyl terephthalate
                      Figure  4-1.    Thermoplastics Subcategorization
                                                4-6

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4.2.2  Options for Source Categories



     In determining how to aggregate or distinguish among



the seven source categories, the EPA considered four



options.  The four options considered were:   (1) the



subcategory  (e.g., ABS production using a continuous mass



process);   (2) the source category  (e.g., ABS production



regardless of the process);  (3) three groupings of source



categories  (styrene-based resin production, nitrile resin



production, and PET production); and (4) a single "super"



source category composed of all seven thermoplastic source



categories.  The EPA selected the subcategory option (Option



1) for the reasons discussed below.



     The "super" source category option (Option 4) was



rejected for two reasons.  First, creating a "super" source



category would have grouped too many dissimilar processes



together, which would have resulted in MACT floor



determinations inappropriate for/not representative of some



of the processes.  This is especially true when combining



the styrene-based resin processes with the PET processes.



In addition, only one facility was identified as having both



a styrene-based resin process and a PET process.  Thus, this



option offers minimal potential gain through emissions



averaging.   Second,  the "super" source category option was



not reasonable given the available data.  Using this option



would have discounted a large amount of data that showed



distinctions between the subcategories.   For these reasons,





                             4-7

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the EPA rejected this option for defining the source



categories.



     Option 3, which creates three groups of source



categories  (styrene-based resins, nitrile,  and PET), was



rejected primarily because the grouping of all of the



styrene-based resins has the potential, due to technological



differences, to result in inappropriate/not representative



MACT floors for some styrene-based resin processes.



Further, while there is significant collocation between ABS



and SAN facilities (both styrene-based resins),  the overall



amount of collocation within the styrene- based resins is



relatively small.  Less than 30 percent of    styrene-based



facilities produce thermoplastics using more than one of the



processes as defined by 18 subcategories.  For these



reasons, the EPA rejected this option for defining source



categories.



     The source category option  (Option 2)  would be



consistent with the source category listing, would provide



some facilities additional opportunity to emissions .average,



and would avoid some of the problems of Options 3 and 4 by



reducing the grouping of dissimilar processes.  However,



even within source categories,  there are different process



technologies and raw materials usage that make division of



source categories into subcategories more defensible for



determining MACT floors.  In addition, most facilities would



not have benefited from emissions averaging under Option 2.





                            4-8

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Therefore, the EPA determined that the subcategory option



 (Option 1) was the best option for defining the source



categories.



4.3  EMISSIONS AVERAGING



     The proposed standards include provisions for emissions



averaging that are essentially the same as those found in



the HON.  Under the proposed standards, emissions averaging



would be allowed among collocated emission points at



existing sources belonging to the same subcategory.



     In considering the use of emissions averaging, the EPA



agreed that emissions averages should achieve at least a



comparable hazard and risk benefit to point-by-point



compliance.  Affected sources who elect to use emissions



averaging must demonstrate, to the satisfaction of the



implementing agency, that compliance through averaging would



not result in greater hazard or risk than compliance without



averaging.  Further discussion of this topic may be found on



pages 19427 and 19428 of the preamble to the final HON rule



(59 FR 19402)  promulgated on April 22, 1994.



     As in the HON rule,  for this proposed rule emissions



averaging is not allowed as a compliance option for new



sources.  The decision to limit emissions averaging to only



existing sources was based on the fact that new sources have



historically been held to a stricter standard than existing



sources.  It is most cost effective to integrate state-of-



the-art controls into equipment design and to install the





                            4-9

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technology during construction of new sources.  By allowing
emissions averaging, existing sources have the flexibility
to achieve compliance at diverse points with varying degrees
of control already in place in the most economically and
technically reasonable fashion.  This concern does not apply
to new sources which can be designed and constructed with
compliance in mind.  Therefore, emissions averaging is only
allowed at existing sources.  Further discussion of this
topic may be found on pages 19426 and 19427 of the preamble
to the final HON rule (59 FR 19402) promulgated on April 22,
1994.
     While the EPA believes that there is limited potential
for emissions averaging in this rule, the EPA did not want
to exclude emissions averaging based on the available data
and welcomes comments on whether or not to include emissions
averaging for the Group IV thermoplastics.  Commenters
supporting emissions averaging are urged to submit specific
information on how emissions averaging would benefit their
facility.  In addition, the EPA requests comment on ways the
implementation of emissions averaging can be made more
flexible without reducing the emission reductions.  The EPA
will consider all comments.
     As stated previously, the emissions averaging
provisions of this rule are essentially identical to the
provisions contained in the HON.  This rule has incorporated
the emissions averaging constraints included in the HON that

                            4-10

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are based on concerns expressed during the HON public



comment period.  The concerns are discussed in a



supplementary Federal Register notice published on October



15, 1993; 58 FR 53479.  These constraints include



consideration of:   (1) State discretion on emissions



averaging,  (2) inclusion of risk in averaging



determinations, (3) compliance period for emissions



averaging,  (4) limit on number of emission points allowed in



an average, and (5) effect of missing monitoring



data/parameter exceedances on averaging.  The EPA requests



comment on whether  it is appropriate to include these



constraints in the  proposed rule.



     The EPA is including emissions from process contact



cooling towers and  vacuum system wastewater at existing PET



facilities in the emissions averaging procedures being



proposed under §63.510.  As discussed in Chapter 8, the



proposed standards  would: 1) prohibit existing PET



facilities from using cooling tower water in the contact



condensers associated with vacuum systems, and 2)  require



the control of any wastewater stream containing organic HAP



listed on Table 9 of the HON wastewater provisions,



generated by the vacuum system containing organic HAP listed



on Table 9 of the HON wastewater provisions,  to the levels



required for a Group l process wastewater stream.   Control



is required regardless of the organic HAP concentration and



flowrate of the stream.
                            4-11

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     The proposed prohibition for cooling tower water would



eliminate organic HAP emissions from the process contact



cooling towers since the cooling tower water would not come



in contact with the organic HAP generated by the process.



If an owner or operator elected to comply with the proposed



emissions averaging procedures, the owner or operator could



elect not to eliminate process contact cooling tower water



from the vacuum system.  This would create a debit; that is,



organic HAP emissions would now occur from the cooling



tower, whereas under the proposed rule no organic HAP



emissions would occur.  Thus, the proposed emissions



averaging procedures only include process contact cooling



towers in the equation for the calculation of debits.  On



the other hand, since the proposed rule would eliminate



organic HAP emissions from the cooling tower, there is no



opportunity for an owner or operator to control cooling



tower emissions to a level more stringent than the proposed



rule.  Thus, the proposed emissions averaging procedures for



calculating credits do not include process contact cooling



towers.



     Under the proposed rule, the organic HAP that would



otherwise have been contained in the cooling tower water and



released from the cooling tower would now be contained in



the vacuum system wastewater stream(s).  The wastewater



stream(s) would be required to be controlled regardless of



the organic HAP concentration or flowrate, provided the





                            4-12

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stream contains an organic HAP listed on Table 9 of the HON



wastewater provisions.  A group determination  (Group 1/2)



would not be made for these wastewater streams as would be



for other process wastewater streams.  The level of control



being proposed for the vacuum wastewater streams is the same



level of control required for Group 1 process wastewater



streams.



     As for other Group 1 process wastewater streams, the



opportunity exists for vacuum system wastewater streams to



be controlled either more stringently or less stringently



than required.  Thus, the opportunity exists for generating



either credits or debits.  The proposed emissions averaging



procedures explicitly incorporate vacuum system wastewater



streams into the credit and debit equations.  In addition,



since the proposed rule requires their control as if a group



determination was conducted and they were found to be Group



1 process wastewater streams, vacuum system wastewater



streams are classified as Group 1 for purposes of



calculating debits and credits.



     Emissions from batch process vents have been excluded



from emissions averaging because there is no acceptable and



satisfactory methodology available to quantify the emission



reduction that would be gained or lost in an emissions



averaging scheme.  While there are methods presented in the



proposed rule for determining emissions from batch process



vents, the EPA does not find them adequate for the purposes





                            4-13

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of emissions averaging.  The EPA has judged that the



accuracy and consistency needs of emission estimates for



emissions averaging are greater than the accuracy and



consistency needs for determining applicability of the batch



process vent provisions.  Further, the EPA has in the past



excluded emissions associated with batch process vents from



averaging schemes.  Equipment leaks have also been excluded



from emissions averaging because:  (1) the proposed standard



for equipment leaks has no fixed performance level; and (2)



no method currently exists for determining the magnitude of



allowable equipment leak emissions.  Without an acceptable



method to determine the magnitude of allowable emissions to



assign for batch process vents and equipment leaks, an



averaging approach that includes these two types of emission



points has been considered technically infeasible.



     Similar to the HON emissions averaging provisions, the



proposed rule limits the number of emission points allowed



in an emissions average.  The concept for limiting the



number of emission points is the same as the HON, but the



exact number is different.  The reasons for constraining the



number of points to be included in emissions averaging are



described on pages 19428 - 19429 of the preamble to the



final HON rule (59 FR 19402) promulgated on April 22, 1994.



In summary, there is a concern about the burden and cost to



implementing agencies of overseeing and enforcing large



numbers of emission points in averages.  In addition, it was





                            4-14

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noted that most affected sources will not find a large



number of opportunities to generate cost-effective credits;



thus, most averages were anticipated to involve a limited



number of emission points, and imposing a limit should not



affect most sources.



     In selecting the number of points to allow in an



emissions average for the proposed rule, differences in the



definition of source category for the HON and the proposed



rule were considered.  The difference in the breadth of this



definition is important because emissions averaging is on a



source category/subcategory basis.  The definition of source



category in the HON includes the production of any chemical



included on the HON list.  Typically, facilities covered by



the HON produce multiple chemicals in multiple process units



at one plant site.  The HON allows an affected source to



include no more than 20 points in an emissions average; this



is increased to 25 points where pollution prevention



measures are used to control emission points to be included



in an average.  The 20- to 25-point limit would apply to the



combination of all process units at a given facility.  As



discussed earlier in this chapter, the definition of source



category for the proposed rule is more limited.  The



proposed rule has 18 subcategories, and the emissions



averaging provisions apply to each subcategory separately.



Emissions averaging is limited to emission points from a



single subcategory within the facility.   Some facilities





                            4-15

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contain multiple subcategories; the maximum number of such
collocated subcategories at any one facility is 6.  Thus, if
the HON emission point limit were directly applied to this
rule, this plant site would be allowed to include 20 to 25
emission points per subcategory; combined, this would
potentially equal a total of 120 to 150 emission points
across six emissions averaging plans.  Under a similar
scenario under the HON, the same plant site could include
only 20 to 25 emission points in one emissions averaging
plan due to the breadth of the definition of source category
for the HON.  The EPA decided that the number of emission
points allowed in the emissions averaging for the proposed
rule needed to be made more in parity with the HON.
     In deriving the numerical limit to include in the
proposed rule, the EPA considered that the maximum number of
collocated subcategories at one plant site is 6.  In order
to make the provisions included in the proposed rule in
parity with the HON, the maximum-number of emission points
included in averaging for each subcategory (without
pollution prevention controls) would need to be
20 -5- 6 = 3 1/3.  This number seemed to be too small to allow
sufficient practical consideration of averaging; thus, it
was increased to 5.  In addition,  the proposed rule is
similar to the HON in that it allows additional emission
points to be included in the average if pollution prevention
measures are used to control some emission points included

                            4-16

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in the average.  The proposed rule allows three additional



emission points to be included in the average if pollution



prevention measures are used.  For example, if two points to



be included in an average are controlled by the use of a



pollution prevention measure, the facility can include up to



7 emission points in their emissions average for that



subcategory.



     In the preamble to the proposed rule, the EPA



specifically requested comments on the selection of the



limit (5, or 8 if pollution prevention measures are used) of



emission points to be allowed per subcategory for purposes



of emissions averaging in the proposed rule.  The EPA



inquired as to whether this limit will preclude known



opportunities within actual facilities to generate cost-



effective credits within a category or subcategory.  The EPA



requested that any comments on this issue address specifics



on the emission and cost quantities computed and include



detailed calculations and references to show how these



quantities were determined.
                            4-17

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                   5,0  BASELINE EMISSIONS





     Baseline organic HAP emissions for the thermoplastic



subcategories are presented in Tables 5-1 and 5-2.   As shown



in the table, the total nationwide estimated organic HAP



emissions are over 24,780 megagrams per year (Mg/yr)  for



existing sources and 14,920 Mg/yr for new sources.
                            5-1

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       TABLE  5-1.
           BASELINE ORGANIC HAP EMISSIONS  FOR EXISTING
                         SOURCES
            Baseline Organic HAP Emissions for Existing Sources
                                  (Mg/yr)
Summary
ABS, Be
ABS, Bl
ABS, Bs
ABS, Ce
ABS, Cm
MABS
Nitrile
SAN, B
SAN, C
ASA/
AMSAN
MBS
EPS
PS, B
PS, C
PET TPA,
C
PET TPA,
B
PET DMT,
C
PET DMT,
B
TOTALS
Process
Vents
430
1
4
630
20
80
20
8
7
0
50
15
70
260
1,090
570
535
1,290
5,060
Storage
Vessels
6
0
1
15
6
2
0
3
4
0
3
3
10
60
3
1
80
100
310
Equipment
Leaks (a)
50
2
9
80
220
3
10
10
70
90
130
430
110
1,120
2,030
90
2,150
1,190
7,790
Wastewater (b)
20
0
1
390
0
3
0
10
30
5
10
0
0
5
1,310
35
580
110
2,510
Cooling
Towers
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,660
620
1,140
5,690
9,110
Total
500
3
15
1,110
240
90
30
40
110
100
190
450
190
1,440
6,090
1,320
4,480
8,390
24,790
a These values were  determined by estimating equipment counts and applying
  SOCMI factors2 adjusted according  to LDAR programs.
Be
Bl
Bs
Ce
Cm
B
C
PS
batch emulsion
batch latex
batch suspension
continuous  emulsion
continuous  mass
batch
continuous
polystyrene
                                   5-2

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    TABLE  5-2. BASELINE  ORGANIC HAP EMISSIONS  FOR NEW SOURCES
                 BASELINE ORGANIC
HAP EMISSIONS FOR NEW SOURCES
   (Mg/yr)
Subcategory3
ABS, B
ABS, Bl
ABS, Bs
ABS, Ce
ABS, Cm
MABS
Nitrile
SAN, B
SAN, C
ASA/AMSAN
MBS
EPS
PS, B
PS, C
PET TPA, C
PET TPA, B
PET DMT, C
PET DMT, B

TOTALS
Process
Vents
10
0
5
120
0
0
0
5
0
0
15
0
0
30
1,090
570
300
360

2,510
Storage
Vessels
0
0
1
1
2
0
0
3
1
0
0
0
0
15
3
1
80
40

150
Equipment
Leaksb
20
0
6
40
90
0
0
10
40
0
4
0
0
280
2,030
90
1,690
690

5,000
Wastewater
1
0
1
240
0
0
0
3
0
0
1
0
0
0
1,310
35
270
20

1,880
Cooling
Towers
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,660
620
850
2,270

5,400
TOTAL
30
0
10
400
90
0
0
20
40
0
20
0
0
330
6,090
1,315
3,190
3,380

14,930
a  See abbreviations  from Table 5-1.
b  These values were  determined by estimating equipment counts and applying
  SOCMI factors2 adjusted according to LDAR programs.
                                  5-3

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     The organic HAP emitted include styrene,  butadiene,



acrylonitrile, acetaldehyde, dioxane,  methanol, and ethylene



glycol.  The quantity of emissions for each individual



organic HAP was not determined,  but acrylonitrile and



styrene are estimated to comprise the largest quantity of



emissions.  The organic HAP emitted by each subcategory are



identified in Table 5-3.
                            5-4

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TABLE 5-3.
MAJOR HAZARDOUS AIR POLLUTANTS EMITTED BY
         SUBCATEGORY
Subcategory
ABS
SAN
MABS
MBS
Polystyrene
PET
Nitrile
Major HAP
acrylonitrile, butadiene,
Emitted
styrene
acrylonitrile, styrene
acrylonitrile, butadiene,
styrene
butadiene , styrene
styrene
ethylene glycol, methanol
dioxane
, acetaldehyde,
acrylonitrile
                         5-5

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     As described in Chapter 3, organic HAP are emitted from



storage vessels, process vents and process fugitives,



wastewater operations, equipment leaks, and heat exchange



systems to include process contact cooling towers.  Process



vents and equipment leaks are the emission points that



comprise the largest portion of these emissions.



     Emission estimates were made for each facility in



active operation.  Emissions for storage,  process vents,



wastewater operations, and process contact cooling towers



were taken directly from information submitted by each



facility.  Baseline emissions from equipment leaks were



calculated by using component counts provided by facilities



and emission factors from the EPA's Equipment Leak Protocol



document.2   The  level  of  equipment leak control  assumed for



each facility was based either on information submitted



concerning leak detection and repair (LDAR)  programs or on



applicable State regulations.  More detailed information on



the calculation of baseline emissions for the proposed



NESHAP is contained in the memorandum "Baseline Emissions



Estimates for the Thermoplastics Industry,"   contained in



Docket No.  A-92-45,  Category II-D and in the SID.  More



detailed information on the calculation of equipment leak



emissions is contained in the memorandum "Determination of



MACT Floors for Equipment Leaks," also contained in Docket



No. A-92-45, Category II-B and in the SID.
                             5-6

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        6.0  MACT FLOORS AND REGULATORY ALTERNATIVES





     This chapter presents the approach used to determine



MACT floors and regulatory alternatives for the Group IV



thermoplastic subcategories.  The Clean Air Act requirements



for the determination of MACT floors are discussed, as well



as the general approach used to determine the MACT floors



and regulatory alternatives.  Then, the results of the



analyses are presented.



6.1  CLEAN AIR ACT REQUIREMENTS



     The amended Clean Air Act contains requirements for the



development of regulatory alternatives for sources of HAP



emissions.  The statute requires the standards to reflect



the maximum degree of reduction in emissions of HAP that is



achievable for new or existing sources.  This control level



is referred to as MACT.  The amended Clean Air Act also



provides guidance on determining the least stringent level



allowed for a MACT standard;  this level is termed the "MACT



floor."  Consideration of control levels more stringent than



the MACT floor must reflect consideration of the cost of



achieving the emission reduction, any non-air quality,



health, and environmental impacts,  and energy requirements.



     For new sources, the standards for a source category or



subcategory "shall not be less stringent than the emission





                            6-1

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control that is achieved in practice by the best controlled



similar source, as determined by the Administrator"



[section 112(d) (3)] .  Existing source standards shall be no



less stringent than the average emission limitation achieved



by the best performing 12 percent of the existing sources



for source categories and subcategories with 30 or more



sources or the average emission limitation achieved by the



best performing 5 sources for source categories or



subcategories with fewer than 30 sources [section 112(d)(3)



of the Act].   These two minimum levels of control define the



MACT floor for new and existing sources.



     Two interpretations have been evaluated by the EPA for



representing the MACT floor for existing sources.  One



interpretation is that the MACT floor is represented by the



worst performing facility of the best 12 percent performing



sources.  The second interpretation is that the MACT floor



is represented by the "average emission limitation achieved"



by the best performing sources, where the "average" is based



on a measure of central tendency,  such as the arithmetic



mean,  median, or mode.  This latter interpretation is



referred to as the "higher floor interpretation."  In a June



6, 1994 Federal Register notice (59 FR 29196), the EPA



presented its interpretation of the statutory language



concerning the MACT floor for existing sources.  Based on a



review of the statute, legislative history, and public



comments,  the EPA believes that the "higher floor





                             6-2

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interpretation" is a better reading of the statutory



language.  The determination of the MACT floor for existing



sources under the proposed rule followed the "higher floor



interpretation."



6.2  DETERMINATION OF MACT FLOORS



     This section describes the approach taken for



determining the MACT floor for existing and new sources



(Section 6.2.1 and 6.2.2).  The final section (Section



6.2.3) discusses the special consideration taken into



account for the requirements of the Polymers NSPS.



     For determining both existing and new source MACT



floors, each type of emission point (e.g.,  storage vessel,



process vent, etc.)  within a subcategory was evaluated



separately.  The MACT floor for the subcategory is the



composite of these individual types of emission point



specific determinations.



6.2.1  Existing Source MACT Floor



     For existing sources, the amended Clean Air Act



requires the standards to be no less stringent then the



average emission limitation achieved by the best performing



5 sources for source categories or subcategories with fewer



than 30 sources.   All of the 18 subcategories covered by the



proposed rule have less than 30 sources.



     The EPA developed a general approach for evaluating the



MACT floor and determining regulatory alternatives that were



equivalent to or more stringent that the MACT floor for





                            6-3

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existing sources.  This approach was applied to each type of



emission point within each subcategory.



     The first step in the general approach for evaluating



the MACT floor and determining regulatory alternatives for



existing sources was to identify the potential types of



emission points for each subcategory and determine which



types of emission points were being controlled at each



facility within the subcategory.



     The next step in the general approach was to determine



which facilities were the best performing facilities.  For



those subcategories with five or fewer facilities, all of



the facilities represented the "best performing" facilities.



However, for those subcategories with more than five



facilities, the five best performing facilities had to be



identified.  This was done by examining the types of control



and the level of emission reductions being achieved  (e.g.,



emission factors, percent reductions).   For storage vessels,



the EPA examined the level of control,  vapor pressure, and



tank capacity to determine which facilities were best



controlled.  For process vents,  the EPA used percent



emission reduction as the primary indicator of the best



controlled facilities.  The EPA evaluated the option of



using emission factors for process vents as the primary



indicator of the best controlled facilities.  However, after



considering the variability in the quality of emissions data



and the difficulty of working with confidential business





                             6-4

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information production rate information, the EPA decided not



to use emission  factors as the primary indicator.  For



equipment leaks, the EPA used percent reduction based on the



facilities actual LDAR program to identify the best



controlled facilities.  For wastewater, the level of control



being applied at each facility was examined.  None of the



process contact  cooling towers were controlled.



     The next step was to determine regulatory alternatives



equivalent to or more stringent than the MACT floor as



reflected in the existing level of control for the "best



performing" facilities.  Potential regulatory alternatives



were developed based on the HON, Polymers NSPS (40 CFR part



60, subpart DDD), and the Batch Processes ACT.  The HON was



selected because (l) the characteristics of the emissions



from storage vessels, continuous process vents, equipment



leaks, and wastewater at Group IV thermoplastic facilities



are similar or identical to those addressed by the HON and



(2) the levels of control required under the HON were



already determined through extensive analyses to be



reasonable from a cost and impact perspective.



     The Polymers NSPS,  which covers certain process



emissions at polystyrene and PET facilities using a



continuous process and cooling tower emissions at PET



facilities,  was selected for the same basic reasons as the



HON.   Although the Polymers NSPS was developed under section



111 of the Clean Air Act and was targeted to control





                            6-5

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volatile organic compounds  (VOC) emissions, the requirements



for setting standards under section 111 are very similar to



the requirements under section 112 of the 1990 Amendments



and all of the HAP identified from polystyrene and PET



facilities are also VOC.



     Finally, the Batch Processes ACT was selected to



identify regulatory alternatives for batch process vents,



which are not addressed by either the HON or Polymers NSPS.



As with the Polymers NSPS, the Batch Processes ACT covers



VOC emissions.  Again, all of the HAP emissions identified



for the Group IV thermoplastics facilities are also VOC.



Unlike the HON and Polymers NSPS, the Batch Processes ACT is



not a regulation and, therefore, does not specify a level of



control that must be met.  Instead, the Batch Processes ACT



provides information on potential levels of control, their



costs, etc.  Based on the review of the Batch Processes ACT,



the EPA selected a level of control equivalent to 90 percent



reduction for batch process vents.  This level of control



was selected for regulatory analysis purposes because it



represents, for the purposes of the proposed rule, a



reasonable level of control considering costs and other



impacts.



     For the reasons stated above, where the HON, Polymers



NSPS,  and the Batch Processes ACT are more stringent than



the MACT floor,  they represent "ready made" regulatory



alternatives.  Furthermore, for the HON and Polymers NSPS,





                             6-6

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determinations were already made during the development of



those  standards that going beyond their control levels was



not reasonable.  With regard to batch process vents, the EPA



determined, as noted above, that control above the  90



percent  level was not reasonable considering the amount of



additional emission reduction and the cost of achieving that



emission reduction.  Thus, the existing regulations and the



Batch  Processes ACT have  "built in" stopping points as well.



In other words, it was unnecessary to develop and analyze



more stringent regulatory alternatives.



     The EPA then determined whether the HON, Polymers NSPS,



or the Batch Processes ACT were more or less stringent than



or equivalent to the MACT floor for each subcategory.  This



was done by comparing the MACT floor (reflected in the



existing control level for the best performing 5 facilities)



to the appropriate HON or Polymers NSPS requirements or the



90 percent control level for batch process vents for that



type of  emission point for a given subcategory.



     To  determine the relationship of the MACT floor to the



HON/Batch Processes ACT/Polymers NSPS,  several techniques



were used.  In most cases, the EPA examined the control/no



control  decisions (Groups 1 and 2)  for a type of emission



point that resulted from applying the HON/Batch Processes



ACT/Polymers NSPS,  and compared the control/no control



results with the existing control level for each of the best



five performing facilities in the subcategory.





                            6-7

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     If the HON/Batch Processes ACT/Polymers NSPS could not



be demonstrated to be at least as stringent as the MACT



floor using this technique, emissions allowed under existing



control levels and emissions allowed under the HON/Batch



Processes ACT/Polymers NSPS were compared and/or the



percentage of uncontrolled emissions meeting the HON/Batch



Processes ACT/Polymers NSPS requirements were determined.



These more quantitative comparisons clarified the stringency



of the MACT floor in relation to the HON/Batch Processes



ACT/Polymers NSPS requirements.  (For the details of these



determinations, refer to the MACT floor memoranda in Docket



No. A-92-45, Category II-B and in the SID).



     If the applicable HON or Polymers NSPS requirements or



the 90 percent control level for batch process vents were



found to be equivalent to or more stringent than the MACT



floor, then they became part of the first regulatory



alternative for that type of emission point for that



subcategory.   (The first regulatory alternative is the least



stringent level of control considered that is more stringent



than,  or at least as stringent as,  the MACT floor across all



types of emission points.)  As noted above, the EPA did not



typically consider additional regulatory alternatives beyond



the HON, Polymers NSPS,  or the 90 percent control level for



batch process vents.  An exception to this involves process



contact cooling towers at PET facilities, and the rationale
                             6-8

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 for this decision  is  discussed  in Section  6.2.3 and  Chapter



 8.0.



      If the MACT floor was found to be more stringent than



 the HON/Batch Processes ACT/Polymers NSPS, it was defined



 and became part of the first regulatory alternative  for  that



 subcategory.  For  these cases,  the EPA did not develop a



 second regulatory  alternative since the MACT floor was



 already more stringent than regulatory alternatives  already



 considered to be reasonable  (i.e., above the HON/Batch



 Processes ACT/Polymers NSPS control levels).



 6.2.2  New Source  MACT Floor



      For new sources, the 1990 Amendments  require that



 standards be set that are no less stringent than the level



 represented by the best controlled similar source.   As for



 existing sources,  the EPA determined regulatory alternatives



 that were equivalent to, or more stringent than the  MACT



 floor by comparing the MACT floor for each type of emission



point with the appropriate requirements from the HON, Batch



Processes ACT,  and Polymers NSPS (as appropriate).   If the



HON, Batch Processes ACT,  or Polymers NSPS were found to be



equivalent to or more stringent than the MACT floor  for  a



given type of emission point, then the HON, Batch Processes



ACT, or Polymers NSPS became part of the first regulatory



alternative (Regulatory Alternative 1).   However,  if the



MACT floor for a given type of emission point was found  to



be more stringent  than the HON,  Batch Processes ACT,  and





                             6-9

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Polymers NSPS, the EPA defined the MACT floor for new



sources for that type of emission point and it became part



of the first regulatory alternative.



     The EPA constructed the first regulatory alternative



for all subcategories by including in it the best level of



control identified for each type of emission point within



the subcategory using the procedure described above.  In a



single case, a more stringent regulatory alternative was



identified for one subcategory--storage tanks at facilities



producing ABS using a continuous mass process.  The



rationale for developing and accepting this regulatory



alternative is presented in Chapter 8.0.



6.2.3  Special Considerations



6.2.3.1  Polymers NSPS



     The Polymers NSPS affects some process emissions from



new polystyrene facilities using a continuous process and



some process emissions from new PET facilities using a



continuous process.  (It also affects emissions from process



contact cooling towers at new PET facilities using a



continuous process; this is discussed in more detail later.)



These process emission provisions have the potential to be



more stringent than the HON and were considered in



developing regulatory alternatives for both existing and new



polystyrene and PET facilities using a continuous process.



The applicability criteria for modified and reconstructed
                            6-10

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sources, which includes a threshold emission rate, was



considered for the analysis of existing facilities.



     Threshold emission rates were developed under the



Polymers NSPS to set a point at which it was not cost



effective to require an existing source (i.e., modified or



reconstructed) to meet the emission limits.  However,



analysis showed that with one exception, sources subject to



the proposed rule were meeting the Polymers NSPS emission



limits.  For those situations where affected sources are



meeting the Polymers NSPS emission limits,  the emission



limits became part of the MACT floor for existing sources,



and threshold emission rates are not required as part of



implementing the emission limits from the Polymers NSPS.



For those situations where affected sources are not meeting



the Polymers NSPS emission limits (i.e., process vents



associated with material recovery at PET facilities using a



continuous DMT process), the threshold emission rate



developed under Polymers NSPS is used in implementing these



emission limits.   The analysis of new facilities entailed



comparing the appropriate process vent emissions against the



emission limits.   In all cases,  the best performing affected



source was already meeting the polymers NSPS emission



limits.



6.2.3.2  Process  Contact Cooling Towers



     The Polymers NSPS limits the ethylene  glycol



concentration in  the cooling tower water as the means for





                            6-11

-------
controlling emissions from process contact cooling towers at



new PET facilities using a continuous process.  These



provisions are not included as a regulatory alternative,



because other techniques (which are described below)  were



identified for controlling emissions from process contact



cooling towers and were determined to be both more effective



and less costly.  The EPA used one of these alternatives,



the use of ethylene glycol jets in place of steam jets in



the vacuum system, to estimate costs for a regulatory



alternative that eliminates the use of cooling tower water



in vacuum system contact condensers for all PET facilities.



     With few exceptions,  large volumes of organic HAP-



contaminated wastewater (i.e., condensate) are generated at



PET facilities through the use of contact barometric



intercondensers in the steam jet vacuum system.  At most



facilities, this wastewater stream is recycled through a



process contact cooling tower, potentially making the



cooling tower a major emission source.  The EPA believes



there are several technically feasible methods for



eliminating/minimizing emissions from vacuum system



generated wastewater.  These methods are briefly discussed



in the following paragraphs.



     First, there is the technique of using ethylene glycol



jets in place of steam jets in the vacuum system.  Ethylene



glycol jets are considered a pollution prevention technique



in that they prevent the creation of the vacuum system





                            6-12

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wastewater stream.  Instead of using steam in the vacuum jet



as the motivating gas, ethylene glycol vapor is used.



Contaminated ethylene glycol is sent to the ethylene glycol



recovery system.



     Second, mechanical vacuum pumps can be used.  Like the



first technique, mechanical vacuum pumps are a pollution



prevention technique since it prevents the creation of the



vacuum system wastewater stream.



     Third, non-contact condensers can be used in place of



the typical contact barometric intercondensers with steam



jet vacuum systems.  This technique does not prevent the



creation of the vacuum system wastewater stream, but it



serves to minimize emissions since only the steam condensate



is HAP-contaminated and the condensed stream is not sent to



the cooling tower.  To achieve emission reductions



approximately equivalent to the previous two techniques,  the



vacuum system wastewater stream, if it contains any organic



HAP specified in Table 9 of the HON wastewater provisions,



would be required to meet the control level required for a



Group 1 wastewater stream,  regardless of the organic HAP



concentration or flowrate.



     As discussed later,  the EPA has based its decision to



prohibit the use of cooling tower water in contact



condensers on the level of emission reductions and costs



associated with the use of the ethylene glycol jet system.



The EPA believes the other techniques identified above can





                            6-13

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achieve equivalent control at less expense and, in some



cases, may be more technically feasible for retrofitting



existing facilities than the ethylene glycol jet system.  It



is also possible that other techniques exist (or could be



developed) that could substantially eliminate the emissions



of organic HAP from the vacuum system.  If such a system



could be demonstrated to be equivalent to the techniques



described above, it would not be necessary to prohibit the



use of cooling tower water in the vacuum system contact



condensers.



     In the preamble to the proposed rule, the EPA solicited



comments on the emission reduction potential, costs, and



technical feasibility of all control options for process



contact cooling towers at PET facilities.  The EPA requested



that .any comments on alternate control options address the



emissions from the cooling tower, the emissions from any



wastewater discharged from the equipment required by the



control option, and any "reactor process" or "distillation



column" vent emissions associated with the control option.



     As a means of complying with the proposed prohibition



of cooling tower water in contact condensers at PET



facilities, the EPA has identified three alternative vacuum



systems (as discussed above)  that will allow a facility to



meet its vacuum requirements without the need for a process



contact cooling tower.  One of the options -- use of non-



contact condensers in place of the contact barometric





                            6-14

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intercondensers -- will not eliminate the vacuum system



generated wastewater stream, but will minimize the volume of



the wastewater created to that of the steam condensate



alone.  Further, this option prohibits exposing the



wastewater stream to the atmosphere since it can no longer



be recycled through the cooling tower.   (The HON prohibits



exposing Group 1 wastewater stream to the atmosphere prior



to control,



     Applying the HON wastewater provisions applicability



criteria to this vacuum system generated wastewater stream



might result in some wastewater streams being uncontrolled.



For these instances, it is possible that emissions at these



facilities will be greater than the emissions that would be



emitted at facilities using ethylene glycol jets.  Thus, the



use of non-contact condensers by themselves would not result



in equivalent emission reductions.   Therefore,  the proposed



rule requires that all vacuum system generated wastewater



streams that contain any organic HAP specified in Table 9 of



the HON wastewater provisions be considered Group 1



wastewater streams,  regardless of the organic HAP



concentration and flowrate;  these streams would be required



to meet the wastewater control level required for Group 1



wastewater streams.



6.3  RESULTS OF MACT FLOOR DETERMINATION



     Tables 6-1 and 6-2 present the results of the MACT



floor analysis and identify the selected regulatory





                            6-15

-------
alternatives for storage vessels, process vents, and
wastewater.  The "MACT Floor Stringency" column on Tables 6-
1 and 6-2 reflect the comparison of the MACT floor to the
selected set of rules/guidances  (i.e., HON Batch Processes
ACT/Polymers NSPS).   If this column indicates "<", this
means that the MACT floor, as reflected in the existing
level of control, is less stringent than the selected set of
rules/guidances.  If this column indicates "=", this means
that the MACT floor is equivalent to the selected set of
rules/guidances, and a ">" means the MACT floor is more
stringent than the selected set of rules/guidances.
                            6-16

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TABLE 6-1.  MACT FLOOR ANALYSIS FOR EXISTING SOURCES3
Subcategory
ABS, Ce
ABS, Cm
ABS, Be
ABS, Bs
ABS, Bl
MASS
MBS
SAN, C
SAN, B
ASA/AMSAN
PS, C
Storage Vessels
MACT
Floor Regulatory
Stringency13 Alternative
HON
HON
= HON
HON
HON
a HON
HON
HON
HON
> MACT Floor
> MACT Floor
Process Vents
MACT Floor Regulatory
Stringency11 Alternative
a HON/ Batch
ACT
a HON/Batch
ACT
HON/Batch
ACT
a HON/Batch
ACT
a HON/Batch
ACT
HON/Batch
ACT
> MACT Floor
a HON/Batch
ACT
HON/Batch
ACT
> MACT Floor
HON/NSPS/
Batch ACT
Wastewater Streams
MACT
Floor Regulatory
Stringency* Alternative
HON
a HON
HON
a HON
a HON
a HON
a HON
a HON
** HON
< No control0
a HON
                         6-17

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                 TABLE 6-1.  MACT FLOOR ANALYSIS FOR EXISTING SOURCES*  (Concluded)
Subcategory
PS, B
EPS
PET, TPA, C
PET, TPA, B
PET, DMT, C
PET, DMT, B
Nitrile
Storage Vessels
MACT
Floor Regulatory
Stringency* Alternative
a HON
« HON
a HON
a HON
a HON
a HON
> MACT Floor
Process Vents
MACT Floor Regulatory
Stringency*5 Alternative
< HON/Batch
ACT
HON/Batch
ACT
HON/NSPS/
Batch ACT
= HON/Batch
ACT
HON/NSPS/
Batch ACT
HON/Batch
ACT
< HON/Batch
ACT
Wastewater Streams
MACT
Floor Regulatory
Stringency13 Alternative
a HON
a HON
a HON
a HON
a HON
=» HON
a HON
a In all cases, the MACT floor for equipment leaks was less stringent than the HON.

b As compared to the selected set of rules/guidances.

c It is a policy decision to not accept the control level from the selected set of rules/guidances
  The reasons for this decision are discussed in Chapter 8.0.
                                                6-18

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TABLE 6-2,  MACT FLOOR ANALYSIS FOR NEW SOURCES8
Subcategory
ABS, Ce
ABS, Cm
ABS, Be
ABS, Bs
ABS, Bl
MABS
MBS
SAN, C
SAN, B
ASA/AMSAN
Storage Vessels
MACT
Floor Regulatory
Stringency* Alternative
HON
> Regulatory
Alternative
HON
HON
HON
HON
HON
> MACT Floor
HON
> MACT Floor
Process Vents
MACT
Floor Regulatory
Stringency*3 Alternative
= HON/Batch
ACT
HON/Batch
ACT
HON/Batch
ACT
HON/Batch
ACT
= HON/Batch
ACT
= HON/Batch
ACT
MACT Floor
HON/Batch
Act
> MACT Floor
> MACT Floor
Wastewater Streams
MACT
Floor Regulatory
Stringency1* Alternative
sa HON
* HON
« HON
« HON
= HON
= HON
= HON
« HON
« HON
< No controlc
                      6-19

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                    TABLE 6-2.   MACT FLOOR ANALYSIS  FOR NEW  SOURCES3   (Concluded)
Subcategory
PS, C
PS, B
EPS
PET, TPA, C
PET, TPA, B
PET, DMT, C
PET, DMT, B
Nitrile
Storage Vessels
MACT
Floor Regulatory
Stringency*" Alternative
> MACT Floor
« HON
HON
HON
HON
HON
HON
> MACT Floor
Process Vents
MACT
Floor Regulatory
Stringency* Alternative
HON/NSPS/
Batch ACT
< HON/Batch
ACT
* HON/Batch
ACT
HON/NSPS/
Batch ACT
« HON/Batch
ACT
HON/NSPS/
Batch ACT
= HON/Batch
ACT
< HON/Batch
ACT
Wastewater Streams
MACT
Floor Regulatory
Stringency13 Alternative
= HON
« HON
a HON
a HON
a HON
HON
a HON
a HON
a In all cases,  the MACT floor for equipment leaks was less stringent than the HON.
b As compared to the selected set of rules/guidances.
b It is a policy decision to not accept the control level from the selected set of rules/guidances
  or to go beyond the MACT floor.  The reasons for this decision are discussed in Chapter 8.0.
                                                6-20

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      For existing storage  vessels,  the  analysis  found that
for 15 out of the 18 subcategories, the MACT floor was less
stringent than or equivalent to the selected set of
rules/guidances.  For the remaining three cases,  the MACT
floor was determined to be more stringent than the selected
set of rules/guidances.  This information,  along with the
same information for process vents and wastewater, is
presented in Table 6-3.  In all cases, the MACT floor for
equipment leaks was less stringent than the HON.
                            6-21

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   TABLE 6-3.   SUMMARY OF MACT  FLOOR  STRINGENCY
Existing Subcategories
c
Storage 0 15 3
Vessels
Process 2 14 2
Vents
Wastewater 1 17 0
Streams
New Subcategories
c
0 13 5
2 14 2

1 17 0

Number of Subcategories where MACT floor is less
stringent than selected set of rules/guidances

MACT floor equivalent to selected set of
rules/guidances.

MACT floor more stringent than selected set of
rules/guidances.
                       6-22

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      The MACT floor analysis for process contact cooling



towers associated with PET production followed the



methodology described in Section 6.2, however, quickly



deviated  from it due the availability of a more  stringent,



cost effective option.  The MACT floor for process contact



cooling towers at existing sources, as reflected in the



existing  control level, was qualitatively compared to the



cooling tower provisions of the Polymers NSPS and found to



be less stringent.   (Note:  None of the facilities that had



process contact cooling towers controlled emissions from



this emission point.)  For new sources, the MACT floor was



based on  a facility that used ethylene glycol jets, as



opposed to steam jets, and did not have a cooling tower.  In



addition  to eliminating the need for a cooling tower, the



use of ethylene glycol jets prevents the generation of the



vacuum system wastewater stream(s).  This level  of control



was compared to the Polymers NSPS cooling tower provisions



and found to be more  stringent.   Therefore,  the MACT floor



for new sources was informally defined (i.e., not defined in



regulatory terms)  as "no process contact cooling tower" and



"no vacuum system wastewater."  This option was then



considered as a regulatory alternative for existing sources



and was found to be a cost effective option.
                            6-23

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  7.0  SUMMARY OF ENVIRONMENTAL,  ENERGY,  COST,  AND ECONOMIC
                           IMPACT
     This section presents the air, non-air environmental

 (waste and solid waste), energy, cost, and economic impacts

resulting from the control of organic HAP emissions under

the proposed rule.

7.1  FACILITIES AFFECTED BY THESE NESHAP

     The proposed rule would affect ABS, SAN, MASS, MBS,

polystyrene, PET, and nitrile facilities that are major

sources in themselves, or that are located within a major

source.  Based on available information, all of the

facilities at which these thermoplastics are produced were

judged to be major sources for the purpose of developing

these standards.  (Final determination of major source

status occurs as part of the compliance determination

process undertaken by each individual source.)

     Impacts are presented relative to a baseline reflecting

the level of control in the absence of the rule.  The

current level of control was well understood since emissions

and control data were collected on each facility included in

the analysis.  The estimates of impacts include applying

control to:   (1)  existing facilities and (2)  new facilities

(i.e.,  those that are expected to begin operation through

1999).

                            7-1

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     The expected growth rate in each of the seven listed



source categories was analyzed  (see the impacts memorandum



in Docket No. A-92-45, Category II-B).  Based on this



analysis, the following average annual growth rates  (percent



per year) through 1999 were estimated:



     •  ABS  - 4  percent



     •  SAN  - 4  percent



     •  MABS - 3 percent



     •  MBS  - 3  percent



     •  polystyrene  -  3 percent



     •  PET  - 10 percent  for bottle-grade resins  and  4



        percent  for  other PET resins



     •  nitrile  - 3  percent.



     The impacts for existing sources were estimated by



bringing each facility's control level up to the proposed



standards.  For new sources, impacts were based on



identifying the number of new facilities required to meet



the expected growth within the source category, identifying



the types of facilities  (e.g., batch versus continuous) that



would be built,  and then selecting a subset of the existing



facilities to represent the expected growth.  The impacts on



these "new"  facilities were determined by applying the



proposed standards for new sources to the selected subset of



facilities assuming the existing level of control.  This



methodology is discussed in detail in the impacts memorandum
                             7-2

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contained in Docket No.  A-92-45,  Category II-B and in the



SID.



7.2  PRIMARY AIR IMPACTS



     The proposed standards are estimated to reduce organic



HAP emissions from all existing sources by 11,750 Mg/yr from



a baseline level of 24,780 Mg/yr.   This is a 47 percent



reduction.  For new facilities, the proposed standards are



estimated to reduce organic HAP emissions by 7,395 Mg/yr



from a baseline level of 14,920 Mg/yr,  for a 50 percent



reduction.  Table 7-1 summarizes the organic HAP emission



reductions for each individual subcategory.
                            7-3

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                    TABLE 7-1.   ORGANIC  HAP EMISSIONS AND EMISSION  REDUCTIONS
Subcategory
ABS, continuous mass
ABS, continuous emulsion'
ABS, batch emulsion
ABS, batch suspension
ABS, latex
SAN, continuous
SAN, batch
ASA/AKSAN
NABS*
MBS
Polystyrene, continuous
Polystyrene, batch
Expandable polystyrene
PET-TPA, continuous
PET-TPA, batch*
PET -DMT, continuous
PET-DMT, batch
Uitrile
Totals"
Existing Sources
Baseline,
Mg/yr
240
1,110
500
15
3
110
35
100
86
190
1,440
190
450
6,090
1,310
4,480
8,400
30
24,780
Emission
Reduction,
Mp/yr
190
>180
56
5
2
65
13
94
>38
130
1,060
130
92
2,400
>6
2,330
4,950
10
11,750
Percent
Reduction
SOX
>16%
11%
33%
67%
60%
37%
94%
>44%
68%
74%
68%
20%
40%
>1%
52%
59%
33%
47%
New Sources
Baseline,
Mg/yr
95
400
35
13
--
40
20
--
--
20
330
"
••
6,090
1,310
3,190
3,380
--
14,920
Emission
Reduction,
Ms/yr
87
>115
15
5
..
25
6
..
,.
16
240
--
,.
2,200
»6
1,810
2,870
--
7,395
Percent
Reduction
92%
>29%
43%
38%
--
63%
30%
--
--
80%
73%
--
--
36%
>1%
57%
85%
--
50%
--No new growth projected,
*  A portion of the emission
*  Total values are affected
therefore, no impacts expected.
reductions for this subcategory are confidential business information.
by the subcategories for which some data are confidential business information.
                                                          7-4

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 7.3  NON-AIR ENVIRONMENTAL  IMPACTS



     The proposed  standards are not expected to generate any



 adverse water  impacts.  Depending on the methods selected to



 comply with the proposed prohibition of cooling tower water



 in contact condensers, the  amount of wastewater generated at



 PET  facilities could decrease.



     The proposed  standards are not expected to increase the



 generation of  solid waste at any Group IV thermoplastic



 facility.



 7.4  ENERGY IMPACTS



     Energy impacts include increased energy use (fuel) for



 the  operation  of control equipment, energy credits



 attributable to the prevention of organic HAP emissions from



 equipment leaks, and emissions of particulates, sulfur



 dioxides (SOX) , and nitrogen oxide  (NOX)  (secondary air



 impacts) associated with increased energy use.   Under the



 proposed rule,  energy use is expected to increase by



 approximately 30,000 barrels of oil per year for existing



 sources and 44,000 for new sources.  The emissions of



 secondary air pollutants associated with this energy



 increase are 70 Mg/yr for existing sources and 80 Mg/yr for



new sources.   At the same time, energy credits attributable



to the prevention of organic HAP emissions from equipment



leaks are approximately 17,000 barrels of oil per year for



existing sources and 8,000 for new sources.   This results in
                             7-5

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a net increase of approximately 13,000 barrels of oil per


year for existing sources and 36,000 for new sources.


     These figures are related to the control of process


vents, wastewater operations, and equipment leaks.  Energy


impacts related to storage vessels were not estimated since


many storage vessels would be controlled through the use of


internal floating roofs which do not have any associated
                                                *

energy impacts.  Further, the estimates above do not include


the projected energy savings associated with control of


emissions from process contact cooling towers and vacuum


system wastewater associated with the manufacture of PET.


The majority of existing vacuum systems are operated with


steam jets, which are very energy intensive.  The precise


affect of the proposed rule on the use of steam jets cannot


be predicted with accuracy.  However, it is anticipated by


the EPA that compliance with the proposed rule will, in


almost all cases, decrease the energy demand of the vacuum


systems.


     Given the relatively small energy impacts projected for


the control of process vents, wastewater operations, and


equipment leaks and the projected energy savings associated


with control of vacuum system air emissions, the EPA has


judged the energy impacts associated with the proposed rule


to be acceptable.
                             7-6

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7.5  COST IMPACTS



     Cost impacts include the capital costs of new control



equipment, the cost of energy (supplemental fuel, steam, and



electricity)  required to operate control equipment,



operation and maintenance costs, and the cost savings



generated by reducing the loss of valuable product in the



form of emissions.  Also, cost impacts include the costs of



monitoring,  recordkeeping,  and reporting associated with the



proposed standards.  Average cost effectiveness  ($/Mg of



pollutant removed) is also presented as part of cost impacts



and is determined by dividing the annual cost by the annual



emission reduction.  Table 7-2 presents the estimated



capital and annual costs and average cost effectiveness by



subcategory.
                            7-7

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                                     TABLE  7-2.   SUMMARY OF  COST IMPACTS
Subcategory
ABS, continuous mass
ABS, continuous emulsion'
ABS, batch emulsion
ABS, batch suspension
ABS, latex
SAN, continuous
SAN, batch
ASA/AMSAN
MABS9
MBS
Polystyrene, continuous
Polystyrene, batch
Expandable polystyrene
PET-TPA, continuous
PET-TPA, batch"
PET -DMT, continuous
PET -DMT, batch
NitrUe
Totals"
Existing Sources
Total Capital
Cost, $1000
210
>3,540
430
28
0.5
450
SO
550
90
550
770
300
110
40,790
>30
28,250
22,080
9
98,270
Total Annual
Costs,
$1000/yr
100
»1,300
310
19
-0.5
160
33
200
>-2
360
280
160
50
2,970
>18
3,010
3,360
7
12,330
Average
Cost-
Effectiveness
CS/Mg)
550
<7, 160
5,550
3,170
-240
2,520
2,520
2,150
>-50
2,720
260
1,270
540
1,230
<3,180
1,300
680
660
1,050
New Sources
Total Capital
Cost, $1000
150
>3,490
18
28
--
180
1
--
--
440
200
--
--
2,160
>30
2,200
1,440
--
10,340
Total Annual
Costs,
$1000/yr
38
>1,73Q
14
19
,,
38
-1.3
..
--
234
90
..
..
-3,926
>18
-970
-38
..
-2,750
Average
Cost-
Effectiveness
($/Mg)
430
<14,970
960
3,760
--
1,490
-210
--
--
14,200
350
--
--
-1,770
<3,180
-540
-13
--
-370
--No new growth projected, therefore no impacts expected.
*  A portion of the costs and/or emission reductions for this subcategory are confidential  business information.
6  Total values are affected by the subcategories for which some data are confidential business information.
                                                             7-8

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     Under  the proposed rule, it is estimated that total



capital  costs for existing sources would be $98 million



 (1989 dollars),  and total annual costs would by $12.3



million  (1989 dollars) per year.  It is expected that the



actual compliance cost impacts of the proposed rule would be



less than presented because of the potential to use common



control  devices, upgrade existing control devices, use other



less expensive control technologies, implement pollution



prevention  technologies, or use emissions averaging. Since



the effect  of such practices is highly site-specific and



data were unavailable to estimate how often the lower cost



compliance  practices could be utilized, it is not possible



to quantify the  amount by which actual compliance costs



would be reduced.



7.6  ECONOMIC IMPACTS



     The economic impact analysis for the selected



regulatory  alternatives shows that the estimated price



increases for the affected chemicals range from 0.1 percent



for nitrile to 2.8 percent for SAN.   Estimated decreases in



output range from 0.1 percent for polystyrene to 4.6 percent



for SAN.   Net annual exports (exports minus imports)  are



predicted to decrease by an average of 2.5 percent.



     As many as  five PET facilities and one ABS facility are



at risk of discontinuing PET and ABS production,



respectively,  due to the burden of compliance with the



standard.  This does  not mean that the facilities affected





                            7-9

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face the risk of closure.  The facilities affected will
continue to produce other chemicals whose processes are not
affected by this standard.
     Three assumptions in the analysis likely lead to an
overestimate of the number of facilities at risk of
discontinuing production of affected chemicals.  First, the
economic analysis model assumes that all PET and ABS
facilities compete in a national market, though in reality
some facilities may be protected from some competitors by
regional or local trade barriers.
     Second, it is assumed that the facilities with the
highest control cost per unit of production also have the
highest baseline production costs per unit.  This assumption
may not always be true since the baseline production costs
per unit are not known, and thus the estimated number of
facilities that would discontinue production of affected
chemicals may be too high.
     Third, for the production of PET,  the selected
regulatory alternative includes the control of organic HAP
emissions from the vacuum system and process contact cooling
tower.   Control of these emissions is the highest cost item
in the selected regulatory alternative and is the biggest
contributor to the risk of facilities discontinuing PET
production.  The economic analysis is based on the use of
ethylene glycol jets to control these emissions.  There are
a number of potential control technologies for these

                            7-10

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emissions that are expected by the EPA to have lower costs,
but costs for these control technologies were not
calculated.  Ethylene glycol jets are being used by at least
two facilities and data were available from one facility.
The EPA has and will continue to investigate other control
technologies for control of these emissions.  The EPA
invites comment and data on other control technologies.
                            7-11

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               8.0  SELECTION OF THE STANDARDS





     The purpose  of this chapter is to provide the rationale



for the selection of the standards for the Group IV



thermoplastic  subcategories.  In order to provide background



for the subsequent discussions, the first section of this



chapter is a summary of the proposed rule.  This is followed



by a discussion of the rationale for the selection of the



level and format  of the standards and the compliance,



reporting, and recordkeeping provisions.



     The format,  reporting, recordkeeping, and compliance



provisions of  the proposed standards are primarily a result



of the method  used to determine MACT floors and regulatory



alternatives.  In other words, the decision to use the HON,



the Batch Processes Act, and the Polymers NSPS in



determining the MACT floors and regulatory alternatives



predetermined  that the proposed standards would resemble



these standards.  A description of the approach used to



determine MACT floors and regulatory alternatives is



provided in Chapter 6.



8.1  SUMMARY OF THE PROPOSED STANDARDS



     This section provides a summary of the proposed



standards.  The full regulatory text is available in Docket



No. A-92-45,  directly from the EPA,  or from the Technology





                             8-1

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Transfer Network (TTN) on the EPA's electronic bulletin

boards.  More information on how to obtain a copy of the

proposed standards are provided in the preamble.

8.1.1  Source Categories to be Regulated

     The proposed standards would regulate organic HAP

process emissions from facilities in one of the 18

thermoplastic subcategories listed below,  provided that a

facility is determined to be a major source.  For the

proposed rule, an affected source is defined as one of the

following:

     • All  organic HAP  emission points  at  a facility  using
       a  continuous emulsion process to produce ABS.

     • All  organic HAP  emission points  at  a facility  using
       a  continuous mass process to produce ABS.

     • All  organic HAP  emission points  at  a facility  using
       a  batch  emulsion process to produce ABS.

     • All  organic HAP  emission points  at  a facility  using
       a  batch  suspension process to produce ABS.

     • All  organic HAP  emission points  at  a facility  using
       a  batch  latex  process to produce ABS.

     • All  organic HAP  emission points  at  a facility
       producing MABS,

     • All  organic HAP  emission points  at  a facility
       producing MBS.

     • All  organic HAP  emission points  at  a facility  using
       a  continuous process to produce  SAN.

     • All  organic HAP  emission points  at  a facility  using
       a  batch  process  to produce SAN.

     • All  organic HAP  emission points  at  a facility
       producing ASA/AMSAN.

     • All  organic HAP  emission points  at  a facility  using
       a  continuous process to produce  polystyrene.

                            8-2

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      •  All organic HAP emission points at a facility using
        a batch process to produce polystyrene.

      •  All organic HAP emission points at a facility
        producing EPS.

      •  All organic HAP emission points at a facility using
        a continuous TPA process to produce PET  and any
        collocated solid state processes.

      •  All organic HAP emission points at a facility using
        a batch TPA process to produce PET and any
        collocated solid state processes.

      •  All organic HAP emission points at a facility using
        a continuous DMT process to produce PET  and any
        collocated solid state processes

      •  All organic HAP emission points at a facility using
        a batch DMT process to produce PET and any
        collocated solid state processes.

      •  All organic HAP emission points at a facility
        producing nitrile resins.

      The proposed rule regulates emissions from solid state

PET processes if they are collocated with a TPA or DMT fed

PET process, but does not regulate emissions from

independently located solid state PET processes (i.e., those

that  purchase low molecular weight PET from an off-site

source).  As part of the rulemaking, information was

submitted by the industry for collocated solid state PET

processes, but none was submitted for independently located

solid state PET processes.  (Note:  the data request did not

distinguish solid state as a separate process which might

have precipitated companies not submitting data concerning

PET produced by this process.)  In addition, the EPA

believes that independently located solid state PET

processes are likely to be non-major sources because there

                            8-3

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is not a significant source of organic HAP emissions from



the solid state process.  The emissions from a solid state



process are typically the result of release of residual



monomer in the low molecular weight PET.  For these reasons,



the EPA chose not to include independently located solid



state PET processes in the proposed rule.



8.1.2  Relationship to Other Rules



     Sources subject to the proposed rule are also subject



to other existing rules.  In some cases, the proposed rule



supersedes existing rules and affected sources are no longer



required to comply with the existing rule.  In other cases,



there is no conflict between the existing rule and the



proposed rule, and in these cases, the affected source must



comply with both rules.



     Sources subject to the proposed rule and subject to the



NESHAP for Certain Processes Subject to the Negotiated



Regulation for Equipment Leaks (40 CFR part 63,  subpart I)



are required to continue to comply with subpart I until the



compliance date of the proposed rule.   After the compliance



date of the proposed rule,  compliance  with the proposed rule



will constitute compliance with subpart I.



      Sources subject to the proposed rule may have storage



vessels subject to the NSPS for Volatile Organic Liquid



Storage Vessels (40 CFR part 60,  subpart Kb).   After the



compliance date for the proposed rule, such storage vessels
                            8-4

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are only subject to the proposed rule and are no longer



required to comply with subpart Kb.



     Some sources subject to the proposed rule that produce



PET polymers or polystyrene are also subject to the NSPS  (40



CFR part 60, subpart DDD).  After the compliance date for



the proposed rule, such affected sources are only subject to



the proposed rule and are no longer required to comply with



the Polymers NSPS.  As part of this rulemaking, it is



proposed to modify subpart DDD to exclude reference to the



manufacture of polystyrene and PET.



      Sources subject to the proposed rule may have cooling



towers subject to the NESHAP for Industrial Cooling Towers



(40 CFR part 63, subpart Q).  There is no conflict between



the requirements of subpart Q and the proposed rule.



Therefore, sources subject to both rules must comply with



both rules.



8.1.3  Pollutants to be Regulated



     The subcategories covered by the proposed rule emit a



variety of organic HAP.  Among the most significant



emissions of organic HAP are the following:   styrene,



acrylonitrile,  and butadiene from styrene-based resin



production,  which includes the production of ABS,  SAN, MABS,



MBS,  and polystyrene;  acrylonitrile from nitrile resin



production;  and ethylene glycol,  methanol,  acetaldehyde,  and



dioxane from PET production.   The proposed standards would
                             8-5

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regulate emissions of these compounds, as well as a variety



of other organic HAP that are emitted.



8.1.4  Affected Emission Points



     Emissions from the following types of emission points



are being covered by the proposed rule:  storage vessels,



process vents, equipment leaks, wastewater operations, and



heat exchange systems to include process contact cooling



towers.



8.1.5  Proposed Standards



     With relatively few exceptions, the standards being



proposed for storage vessels, continuous process vents,



equipment leaks, wastewater operations, and heat exchange



systems are the same as those promulgated for the



corresponding type of emission point at facilities subject



to the HON  (40 CFR 63, subparts F, G, H, and I).  The



proposed standards also require emissions from batch process



vents to be reduced by at least 90 percent or to be



controlled in a flare that meets the requirements of



§63.1Kb) of subpart A of 40 CFR part 63.  (The criteria



used to determine which batch process vents require control



was based on the approach described in the Batch Processes



ACT.)  The standards being proposed today for certain



continuous process vents from polystyrene facilities and



from PET facilities using a continuous process require the



same levels of control as were promulgated for these



facilities under the Polymers NSPS.  Finally, for PET





                             8-6

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 facilities, the proposed standards would prohibit the use of



 cooling tower water in contact condensers in the vacuum



 systems and would require that all vacuum system wastewater



 containing any of the organic HAP identified in Table 9 of



 the HON wastewater provisions be controlled to the same



 level of control as required under the HON, regardless of



 the wastewater streams organic HAP content or flowrate.



     Under the proposed standards, emissions from existing



 or new batch process vents, heat exchange systems excluding



 process contact cooling towers, and equipment leaks are



 required to be controlled to the levels specified in the



 proposed standards.  Emissions from existing storage



 vessels, continuous process vents, process wastewater



 streams, and process contact cooling towers are required to



 be controlled to the levels specified in the proposed



 standards or alternatively, the emissions averaging



 compliance approach specified in the rule may be used.



 Emissions from new storage vessels,  continuous process



 vents, process wastewater streams, and process contact



 cooling towers are required to be controlled to the levels



 specified in the proposed standards.   The emissions



 averaging compliance approach may not be used for new



 sources.



     Tables 8-1 and 8-2 summarize the level of control being



proposed.   For those types of emission points where the



 level of control is the same as the  HON,  this is indicated





                            8-7

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TABLE 8-1.
SUMMARY OF PROPOSED STANDARDS FOR EXISTING SOURCES IN RELATIONSHIP TO
SUB PARTS  G AND H of 40 CFR PART  63 AND THE POLYMERS NSPS
Subcategory
ABS, continuous
emulsion
ABS, continuous mass
ABS, batch emulsion
ABS, batch suspension
ABS, latex
MABS
MBS
SAN, continuous
SAN, batch
ASA/AMSAN
Type of Emission Point
Storage vessels
HON
HON
HON
HON
HON
HON
HON
HON
HON
HACT Floor
Process Vents
HON
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90X reduction or
compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents: MACT Floor
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents: NON
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
compliant flare
MACT Floor
Equipment
Leaks
HON
HON
HON
HON
HON
HON
HON
HON
HON
HON
Wastewater
HON
HON
HON
HON
HON
HON
HON
HON
HON
No control
Heat Exchange
Systems
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
                                       8-8

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TABLE 8-1.  SUMMARY OF PROPOSED STANDARDS FOR EXISTING SOURCES IN RELATIONSHIP TO
      SUBPARTS  G  AND H of  40 CFR  PART  63 AND  THE  POLYMERS  NSPS  (Continued)
Subcategory
Polystyrene,
continuous
Polystyrene, batch
Expandable polystyrene
PET-TPA, continuous
PET - TPA, batch
- DMT, batch
Type of Emission Point
Storage vessels
MACT Floor
HON
HON
NON
HON
Process Vents
Continuous Process Vents from material
recovery: same as subpart ODD
Other Continuous Process vents: HON
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents: NON
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents from raw
material preparation and polymerization
reaction sections: same as subpart ODD
Other Continuous Process vents: HON
Batch Process Vents: 9QX reduction or
compliant flare
Continuous Process Vents: NON
Batch Process Vents: 90S reduction or
compliant flare
Equipment
Leaks
HON
HON
HON
HON
HON
Wastewater
HON
HON
HON
HON for
wastewater
(including all
vacuum system
generated
wastewater). "
HON for
wasteuater
(including all
vacuum system
generated
wastewater ).b
Heat Exchange
Systems
HON for heat
exchange
systems .
HON for heat
exchange
systems.
HON for heat
exchange
systems.
No cooling
tower Mater
allowed in
vacuum system
contact
condensers. HON
for heat
exchange
systems.
No cooling
toner uater
allowed in
vacuum system
contact
condensers.
HON for heat
exchange
systems.
                                       8-9

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 TABLE 8-1.   SUMMARY OF PROPOSED  STANDARDS FOR EXISTING SOURCES  IN RELATIONSHIP TO
         SUBPARTS G AND H  of 40  CPR  PART 63 AND THE POLYMERS NSPS  (Continued)
Subcategory
PET - DHT, continuous
Nitrile
Type of Emission Point
Storage vessels
HON
HACT Floor
Process Vents
Continuous Process Vents from material
recovery and polymerization reaction
sections: same as subpart ODD
Other Continuous Process vents: HON
Batch Process Vents: 90% reduction or
compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
compliant flare
Equipment
Leaks
HON
HON
Wastewater
HON for
wastewater
(including all
vacuum system
generated
uastewater).
HON
Heat Exchange
Systems
No cooling
tower water
allowed in
vacuum system
contact
condensers.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
Vacuum System wastewater streams containing any organic
considered Group 1 and are required to be controlled.
HAP identified in Table 9 of the HON wastewater provisions (subpart G) shall be
                                                8-10

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TABLE 8-2.
SUMMARY OF PROPOSED STANDARDS FOR NEW SOURCES IN RELATIONSHIP TO SUBPARTS
        G & H of 40 CFR PART 63 AND THE POLYMERS NSPS

Subcategory
ABS, continuous
emulsion
ABS, continuous mass
ABS. batch emulsion
ABS. batch suspension
ABS, latex
MASS
MBS
SAN, continuous
SAN, batch
ASA/AMSAN
Type of Emission Point
Storage vessels
HON
Regulatory
Alternative 2a
HON
KON
HON
HON
HON
MACT Floor
HON
MACT Floor
Process Vents
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents; HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents; HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90X reduction or
a compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
a compliant flare
MACT Floor
MACT Floor
Equipment
Leaks
HON
HON
HON
HON
HON
HON
HON
HON
HON
HON
Uastewater
HON
HON
HON
HON
HON
HON
KON
HON
HON
No control
Heat Exchange
Systems
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HOH for heat
exchange
systems .
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
                                         8-11

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TABLE 8-2.
SUMMARY OF PROPOSED STANDARDS FOR NEW SOURCES IN RELATIONSHIP TO SUBPARTS
        G & H of 40 CFR PART 63 AND THE POLYMERS NSPS
                         (Continued)
Subcategory
Polystyrene,
continuous
Polystyrene, batch
Expandable
polystyrene
PET - TPA, continuous
PET - TPA, batch
- DMT, batch
Type of Emission Point
Storage vessels
MACT Floor
HON
HQN
HON
HON
Process Vents
Continuous Process Vents from material
recovery; Same as subpart ODD
Other Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents from raw
material preparation and
polymerization reaction sections: same
as subpart DOO
Other Continuous Process Vents; HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents: HOtt
Batch Process Vents: 90% reduction or
a compliant flare
Equipment
Leaks
HON
HON
HON
HON
HON
Uastewater
HON
HON
HON
HON for
wastewater
(including all
vacuum system
generated
wastewater). b
HON for
wastewater
(including all
vacuum system
generated
wastewater). b
Heat Exchange
Systems
HON for heat
exchange
systems.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
No cooling
tower water
allowed in
vacuum system
contact
condensers.
HON for heat
exchange
systems.
No cooling
tower water
allowed in
vacuum system
contact
condensers.
HON for heat
exchange
systems.
                                         8-12

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TABLE  8-2.
SUMMARY OF PROPOSED  STANDARDS  FOR  NEW SOURCES IN RELATIONSHIP TO  SUBPARTS
          G  & H of  40  CFR PART 63 AND THE  POLYMERS NSPS
                                 (Concluded)

Subcategory
PET - DMT, continuous
Nitrite
Type of Emission Point
Storage vessels
HON
MACT Floor
Process Vents
Continuous Process Vents from material
recovery and polymerization reaction
sections: same as subpart ODD
Other Continuous Process Vents: HON
Batch Process Vents: 90% reduction or
a compliant flare
Continuous Process Vents: HOM
Batch Process Vents: 90% reduction or
a compliant flare
Equipment
Leaks
HON
HON
Uastewater
KON for
wastewater
(including all
vacuum system
generated
wastewater) .*
HON
Heat Exchange
Systems
No cooling
tower water
• Honed in
vacuum system
contact
condensers.
HON for heat
exchange
systems.
HON for heat
exchange
systems.
  The proposed standard is more stringent than the MACT floor, which is more stringent than the HON.
  Vacuum system wastewater streams containing any organic HAP identified in Table 9 of the KON wastewater provisions (subpart o> shall be
  considered Group 1 and are required to be controlled.
                                                     8-13

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in the table by the acronym "HON."  Similarly,  where the



proposed level of control is the same as promulgated under



the Polymers NSPS, this is indicated by the use of the words



"same as under subpart DDD."  Finally, where the proposed



level of control is more stringent than the level of control



in the HON or in subpart DDD for that type of emission



point, the words "MACT floor" are used.



8.1.5.1  Storage Vessels.  Tables 8-3 and 8-4 summarize the



proposed standards for existing and new storage vessels,



respectively.  The proposed standards would require owners



and operators to first determine whether or not a storage



vessel was required to be controlled.  This^is  done through



the application of certain criteria to each storage vessel.



For those storage vessels determined to require control, the



proposed rule then specifies the level of control required.
                            8-14

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 TABLE  8-3.      PROPOSED  STANDARDS  FOR  EXISTING  STORAGE  VESSELS
    Subcategory
       Applicabih'ty Criteria*
                                                                     Level  of Control"
  All ABS
  SAN, continuous
  SAN. batch
  MABS
  MBS
  Polystyrene
    batch
  All PET
  Nitrite (except
  as noted below)
vapor pressure 20.75  psia  and
capacity 240,000 gallons0

vapor pressure 21.9 psia and
capacity £20,000 gallons0
 If vapor pressure is <11.1  psia:d
  1.     fixed roof and internal
         floating roof; or
  2.     external floating roof; or
  3.     an external floating roof
         converted to an internal
         floating roof; or
  it.     a closed vent system and
         control device

 If vapor pressure >11.1 psia:
a closed vent system and  control
device*1
  ASA/AHSAN         ANST for capacities £10,200 gallons

                    styrene/acrylonitrile for  capacities
                    ^1,000 gallons

                    acrylonitrile for capacities &20,000
                    gallons

                    any other chemical:

                           vapor pressure 20.75 psia
                           and capacity 240,000
                           gallons0

                           vapor pressure 21.9 psia and
                           capacity =20,000 gallons0
                                      98 percent reduction

                                      98 percent reduction


                                      98 percent reduction


                                      If vapor pressure  is <11.1 psia:
                                        1.    fixed roof and internal
                                              floating roof; or
                                        2.    external floating roof; or
                                        3.    an external floating roof
                                              converted to an internal
                                              floating roof; or
                                        4.    a closed vent  system and
                                              control device

                                      If vapor pressure  >11.1 psia:
                                      a closed vent  system and control
                                      device"
  Nitrite
Control all  acrylonitrile storage
vessels 2 3,500 gallons
(same as the NON  level of control)
  Polystyrene,      vapor pressure 2 0.28 psia and
  continuous        capacity 2 20,000 gallons

                   vapor pressure 2 2.08 psia and
                   capacity 2 10,000 but less than
 	20,000 gallons.	
                                      (same as the  HON  level of control).
'  Storage vessels  that meet the criteria are defined as Group 1 storage vessels and control of
   their emissions  would be required.  Storage vessels that do not meet the criteria are defined as
   Group 2 storage  vessels and control  of their emissions is not required.

b  Required for Group 1 storage vessels only.

0  The applicability criteria for these subcategories are the same as in the HON.

"  The level  of control is the same as  the HON.

KEY:  AMST = alpha methyl styrene
                                             8-15

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    TABLE  8-4.      PROPOSED STANDARDS FOR  NEW STORAGE VESSELS
    Subcategory
     Applicability Criteria'
            Level of Control"
 All ABS (except   vapor pressure *0.1 psia and
 CM)
 SAN, batch
 MABS
 MBS
 Polystyrene,
   batch
 All PET
 Nitrile (except
 as noted below)
capacity 240,000  gallons0

vapor pressure M.9 psia and
capacity 210,000  gallonsc
If vapor pressure  is <11.1 psia:11
  1.  fixed roof and internal floating
      roof; or
  2.  external floating roof; or
  3.  an external  floating roof converted
      to an internal floating roof; or
  4.  a closed vent system and control
      device

If vapor pressure  >11.1 psia:
a closed vent system and control device"
 ABS, continuous
 mass
VP a 1.9 psia and capacity
£10,000 gallons and <12,000
gallons

styrene for capacities z12,000
gallons

VP a 0.0782 psia and *12,000
gallons	
(same as the HON  level of control)
 SAN, continuous   VP 2 0.0735  to <0.1 psia and
                   capacity £600,000 gallons

                   VP a 0.1  to  <1.45 psia and
                   ^40,000  gallons

                   VP a 1.45 to <14.7 psia and
                   capacity 28,000 to <40,000
	gallons	
                                 90 percent reduction
                                 (same "as the HON level of control)
                                 98 percent reduction
 ASA/AMSAN         AMST for  capacities *10,200
                   gallons

                   styrene/acrylonitrile for
                   capacities 21,000 gallons

                   acrylonitrile for capacities
                   220,000 gallons

                   any other chemical:

                      vapor  pressure *0.1 psia and
                      capacity ^40,000 gallons0

                      vapor  pressure &1.9 psia and
	capacity £10,000 gallons0
                                 98 percent reduction
                                 98 percent reduction
                                 98 percent reduction
                                 (same as the HON  level of control)
 Nitrile
Control all  acrylonitrile
storage vessels a 3,500 gallons
(same as the HON  level of control)
 Polystyrene,       vapor pressure * 0.78 psia and
 continuous         capacity * 29,000 gallons

                   vapor pressure 2 0.09 psia and
                   capacity a 12,000 but less than
                   29,000 gallons.

                   vapor pressure 2 1.1  psia and
                   capacity * 5,170 but  less than
	12,000 gallons.	
                                 (same as the HON  level of control)
                                             8-16

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Footnotes to TABLE 8-4.

"   Storage vessels that meet the criteria are defined as Group 1  storage vessels and control of
   their emissions would be required.  Storage vessels that do not meet the criteria are defined as
   Group 2 storage vessels and control of their emissions is not  required.

b   Required for Group 1 storage vessels only.

c   The applicability criteria for these subcategories are the same as those in the HON.

d   The level of control is the same as in the HON.

KEY:   VP = vapor pressure; ANST = alpha methyl styrene
                                              8-17

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8.1.5.1.1  Applicability Criteria.  For most existing and



new storage vessels, the proposed criteria for determining



which storage vessels are to be controlled are identical to



the criteria from the HON storage vessel provisions and are



based on storage vessel capacity and vapor pressure of the



stored material.  Typically, vapor pressures and storage



vessel capacity criteria that determine Group 1 or Group 2



status are different for existing and new sources.  As in



the HON, if a storage vessel meets the applicability



criteria and is required to be controlled under the proposed



rule, it is referred to as a Group 1 storage vessel.  If a



storage vessel is not required to apply controls, it is



referred to as a Group 2 storage vessel.



     For new ABS,  continuous mass facilities,  the



applicability criteria also rely on vapor pressure and



storage vessel capacity, but use different levels of each



for defining a Group 1 storage vessel (see Table 8-4).



     For new continuous  SAN facilities, the  proposed



standards for storage vessels rely on five different



combinations of vapor pressure and storage vessel capacity



to determine Group 1 storage vessels.  These combinations of



vapor pressure and storage vessel capacity are shown in



Table 8-4.



     For existing  continuous polystyrene  facilities,  the



proposed standards for storage vessels rely on two



combinations of vapor pressure and storage vessel capacity





                            8-18

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to determine Group 1 storage vessels.  These combination of



vapor pressure and storage vessel capacity are shown in



Table 8-3.



     For new continuous polystyrene facilities,  the proposed



standards  for storage vessels rely on three combinations of



vapor pressure and storage vessel capacity to determine



Group 1 storage vessels.  These combinations of vapor



pressure and storage vessel capacity are shown in Table 8-4.



     For existing and new ASA/AMSAN facilities,  the proposed



standards  for storage vessels have two parts to the



applicability criteria.  The first part identifies specific



chemical and storage vessel capacity combinations.  The



second part applies vapor pressure and storage vessel



criteria for storage vessels containing chemicals not



specifically identified.



     For existing and new nitrile  facilities,  all



acrylonitrile storage vessels with capacities greater than



or equal to 3,500 gallons are required to be controlled.



For all other chemicals, the applicability criteria are the



same as in the HON.



8.1.5.1.2  Level of Control.  Except for the subcategories



discussed below,  the level of control required for storage



vessels determined to be Group 1 storage vessels under the



appropriate applicability criteria in the proposed rule is



either technical modification to the tank (e.g.,  the



installation of an internal floating roof)  or the use of a





                            8-19

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closed vent system and control device that is generally



required to achieve at least 95 percent emission reduction.



(This is the same level of control as required under the



HON.)  For all subcategories, storage vessels determined to



be Group 2 are not required to be controlled.



     For new continuous SAN facilities,  different  levels of



control for two of the five applicability criteria



combinations are being proposed.  For the applicability



combination of vapor pressure greater than 0.0735 but less



than 0.1 pounds per square inch absolute (psia)  and storage



vessel capacity greater than or equal to 600,000 gallons,



the proposed standards would require an emission reduction



of 90 percent or more.  For the applicability combination of



vapor pressure greater than or equal to 1.45 but less than



14.7 psia and storage vessel capacity greater than or equal



to 8,000 gallons but less than 40,000 gallons,  the proposed



standard would require an emission reduction of 98 percent



or more.



     For ASA/AMSAN facilities,  different levels  of control



for storage vessels determined to be Group 1 based on the



specific chemical/storage vessel capacity combination



criteria are being proposed.  For these storage vessels, the



proposed standard would require an emission reduction of 98



percent or more.



8.1.5.2  Process Vents.  As for storage vessels, the



proposed standards for process vents require owners and





                            8-20

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operators to first determine whether or not a process vent



(or set of process vents) requires control and, if so, then



specifies the level of control required.



8.1.5.2.1  Applicability Criteria.  Tables 8-5 and 8-6



summarize the proposed applicability criteria for continuous



and batch process vents at existing and new facilities,



respectively.  As for storage vessels,  process vents that



meet the applicability criteria are referred to as Group 1



process vents and those that do not are referred to as Group



2 process vents.  With the exceptions discussed below, the



proposed rule would require control of only those process



vents determined to be Group 1 process vents under the



appropriate criteria.
                            8-21

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TABLE  8-5.
SUMMARY OF  PROPOSED PROCESS  VENT  APPLICABILITY
 CRITERIA FOR EXISTING FACILITIES
  Process Vents
           Subcategory
    Applicability Criteria
Continuous Unit
Operations
    All  (except as
    specified below)

    MBS

    ASA/AMSAN
                   Polystyrene,
                   continuous:
                   material recovery

                   PET/DMT, continuous:
                   material recovery

                   PET/DMT, continuous:
                   polymerization reaction

                   PET/TPA, continuous:
                   raw material
                   preparation and
                   polymerization reaction
TRE"
TRE3 s  3.7

None.  All vents are required
to be controlled

None. Must meet standard
                              0.12  kg TOC per Mg product"
                              None.  Must meet  standard
                              None. Must meet  standard
Batch Unit
Operations
    All
    Stream
  Volatility
                                            Low
                                            Moderate
                                            High
 Flowrate
Regression
 Equation0
                                               (0.00437)  AE
                                               -  51.6d
                                               (0.00187)  AE
                                               -  14. Od
                                               (0.00081)  AE
                                               -  8.5d
 The total resource effectiveness  (TRE) value is a reflection of the
 cost effectiveness of controlling an individual process vent.  There
 are different TRE coefficients  for existing and new process vents.
 If emissions from the described process vents are greater than the
 applicability criteria,  control is required.
 If actual stream flowrate  (standard cubic meters per minute) is less
 than the flowrate calculated by the regression equation, the process
 vent is required to be controlled.
 AE = annual emissions in kilograms per year.
                                8-22

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        TABLE  8-6.   SUMMARY  OF PROPOSED  PROCESS VENT
         APPLICABILITY  CRITERIA FOR NEW FACILITIES
Process Vents
Continuous Unit
Operations













Batch Unit
Operations




Subcategory
All (except as
specified below)
SAN, batch
ASA/AMSAN

Polystyrene,
continuous : material
recovery
PET/DMT, continuous:
material recovery and
polymerization reaction
PET/TPA, continuous :
Raw material
preparation and
polymerization reaction
All (except as
specified below)



SAN, batch
Applicability Criteria
TREa s 1

None . Must


meet standard.
None. All vents are required to
be controlled.
None . Must


None. Must


None . Must



Stream
Volatility
Low
Moderate
High
None. Must
meet standard.


meet standard.


meet standard .



Flowrate Regression
Equation*"
(0.00437) AE - 51. 6C
(0.00187) AE - 14.0°
(0.00081) AE - 8.5C
meet standard.
The total resource  effectiveness (TRE)  value  is a reflection of the
cost effectiveness  of controlling an individual process vent.  There
are different TRE coefficients for existing and new process vents.
If actual stream flowrate  (standard cubic meters per minute) is less
than the flowrate calculated by the regression equation, the process
vent is required to be controlled.
AE = annual  emissions in kilograms per  year.
                              8-23

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     Except for certain PET and polystyrene continuous



process vents, Group I continuous process vents are



determined by comparing each process vent's total resource



effectiveness  (THE) value to a THE value of unity.  The TRE



is a reflection of the costs and other associated impacts of



controlling an individual process vent.  It is determined



based on process vent stream characteristics such as



emissions  (mass per hour), heat content, and flowrate.  The



procedure in the proposed rule for determining Group l



process vents is the same procedure as in the HON.



     Except for continuous process vents at existing MBS



facilities, continuous process vents with a TRE value of 1



or less would be classified as a Group 1 process vent.  For



continuous process vents at existing MBS facilities, a TRE



value of 3.7 or less defines a Group 1 process vent.



     As seen in Tables 8-5 and 8-6, there are no



applicability criteria specified for several subcategories.



At these facilities, a Group I/Group 2 status determination



does not need to be made and all process vents are required



to be controlled.



     For process vents associated with the material recovery



section from existing PET facilities using a continuous DMT



process, Group 1 process vents are determined by comparing



uncontrolled emission rates with threshold emission rates.



Process vents associated with the material recovery section



at an existing PET facility using a continuous DMT





                            8-24

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process would be considered Group 1 process vents if the



uncontrolled emission rate is greater than 0.12 kg TOG



per Mg of product  (see Table 8-5).  For other process vents



at existing and new polystyrene and PET facilities  (see



Tables 8-5 and 8-6) , there are no applicability criteria.



These process vents must meet the proposed standards.



     For process vents from batch unit operations, the



process vent is first characterized as to its volatility -



low, medium, or high.  Next, the estimate of the stream's



annual emissions is entered in the appropriate flowrate



regression equation.  If the actual flowrate is less than



the calculated flowrate, then the batch process vent is a



Group 1 vent under these standards, and control is required.



As seen in Tables 8-5 and 8-6, the batch process vent



applicability criteria are the same for existing and new



sources, except for new SAN batch facilities.



     For new SAN batch facilities,  there are no



applicability criteria for individual process vent streams;



all process vents are subject to control in that the



proposed standard for these facilities requires an overall



emission reduction of 84 percent from all process vents.



     A batch process vent that is combined with a continuous



process vent prior to a control or recovery device is not



required to comply with the batch process vent provisions if



there are no emissions to the atmosphere up until the point



the batch vent stream is combined with the continuous vent





                            8-25

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stream.  The combined vent would be required to comply with



the continuous process vent provisions.  The presence of a



batch process vent in a continuous process vent stream would



necessitate that all applicability tests and performance



tests be conducted while the batch process vent is emitting



(i.e. at maximum operating conditions).



8.1.5.2.2  Level of Control.  For continuous process vents,



most of the facilities are required to control Group 1



process vents by at least 98 percent.  If a flare is used,



it must meet the design and operating requirements of



§63.1Kb) of subpart A of 40 CFR part 63.  Exceptions to



this are discussed in the paragraphs below.



     For continuous process emissions from the material



recovery section of polystyrene plants using a continuous



process, the proposed standards would  (l) limit the



emissions of total organic compounds (TOO  (minus methane



and ethane) to 0.0036 kilograms (kg)  of TOC per megagram



(Mg) of product (0.0036 pounds (Ibs)  TOC/1,000 Ibs of



product) from each material recovery section,  or (2)  limit



the outlet gas temperature from each final condenser in each



material recovery section to -25°C  (-13°F) , or  (3) reduce



emissions from each material recovery section by 98 weight



percent or to 20 parts per million by volume (ppmv).   These



are the same requirements as in the Polymer NSPS.



     For PET facilities using a continuous TPA process, the



proposed standards would limit continuous process vent





                            8-26

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emissions from  (1) the raw material preparation section to



0.04 kg TOC/Mg of product and  (2) the polymerization



reaction section to 0.02 kg TOC/Mg of product.  Similarly,



for PET facilities using a continuous DMT process, the



proposed standards would limit continuous process vent



emissions from  (1) the material recovery section to 0.018 kg



TOC/Mg of product or the temperature to 37°F from each final



condenser in the material recovery section and (2) the



polymerization reaction section to 0.02 kg TOC/Mg of



product.  These are also the same requirements that are in



the Polymers NSPS, with the exception that cooling tower



emissions would not be considered as part of the



polymerization reaction section.



     For Group 1 continuous process emissions from other



process sections at polystyrene and PET facilities, the



proposed standards would require emission reduction by at



least 98 percent or control by a flare that meets the



requirements of §63.11(b)  of subpart A of 40 CFR part 63.



     For batch process vents,  the proposed standards would



require Group 1 process vents from batch unit operations to



be controlled by at least 90 percent.



     There are three subcategories where the proposed



standards are based on the MACT floor.  These subcategories



are existing MBS facilities,  existing and new ASA/AMSAN



facilities,  and new SAN,  batch facilities.
                            8-27

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     For existing MBS facilities, the proposed standards



require continuous process vents at facilities to either  (1)



meet an emission level of 0.000590 kg of emissions per



megagram of product for all continuous process vents or  (2)



control all continuous process vents with a TRE of 3.7 or



less by at least 98 percent.  The TRE is to be calculated



for each process vent using the same TRE coefficients as for



other existing sources.   The development of the MACT floor



and applicability criteria for MBS existing sources is



documented in Docket A-92-45, Category II-B and in the SID.



     For both existing and new ASA/AMSAN facilities, the



proposed rule requires all process vents (continuous and



batch) at both existing and new facilities to control



emissions by at least 98 percent.



     For new SAN, batch facilities, the proposed rule



requires an overall emission reduction of 84 percent of



process vent emissions.



8.1.5.3  Equipment Leaks.  For all the subcategories, both



existing and new facilities would be required to implement a



leak detection and repair (LDAR) program.  With a few



exceptions, the LDAR program being proposed is the same as



that specified in the HON (40 CFR part 63,  subpart H) and



the National Emission Standards for Organic HAP for Certain



Processes  Subject to the Negotiated Regulation for



Equipment Leaks (40 CFR part 63, subpart I).  Under the



proposed standards, work practice requirements to reduce





                            8-28

-------
emissions from equipment that are in volatile HAP service



for 300 or more hours per year are specified.  The proposed



standards define  "in volatile HAP service" as being in



contact with or containing process fluid that contains a



total of 5 percent or more total HAP.  Equipment subject to



the proposed standards are:  valves, pumps, compressors,



connectors, pressure relief devices, open-ended valves or



lines, sampling connection systems, instrumentation systems,



agitators, surge  control vessels, bottoms receivers, and



closed-vent systems and control devices.



     Affected sources currently complying with the NESHAP



for Certain Processes Subject to the Negotiated Regulation



for Equipment Leaks (40 CPR part 63, subpart I) are required



to continue to comply with subpart I until the compliance



date of the proposed rule.  Further, affected sources



complying with subpart I through a quality improvement



program shall be  allowed to continue these programs without



interruption as part of complying with the proposed rule.



In other words, becoming subject to the proposed rule does



not restart or reset the "compliance clock" as it relates to



reduced burden earned through a quality improvement program.



8.1.5.4  Wastewater.  Except for ASA/AMSAN facilities,  the



proposed standards require owners and operators to determine



for each wastewater stream at its point of generation



whether it is a Group 1 or Group 2 wastewater stream.   As



for process vents,  Group 1 wastewater streams are required





                            8-29

-------
to be controlled, while Group 2 wastewater streams are not



required to be controlled.  The wastewater stream



characteristics used to make the Group I/Group 2



applicability determination are flowrate and organic HAP



concentration.  The proposed criteria for determining



Group 1 wastewater streams are presented in Table 8-7 and



are the same as used in the HON.  The level of control



required for Group 1 wastewater streams is dependent upon



the organic HAP constituents in the wastewater stream.  The



levels of control proposed for these standards are the same



as those for the HON.  The proposed rule would not control



wastewater emissions from any existing or new ASA/AMSAN



facilities.
                            8-30

-------
  TABLE 8-7.  PROPOSED WASTEWATER APPLICABILITY CRITERIA3'*
   Existing Source Criteria
     New Source Criteria
 VOHAP0 concentration  2
 10,000 ppmw

              or
Same as existing criteria
             and
 VOHAPC concentration  2  1,000   for a subset of organic
 ppmw and flow rate a 10       HAP. . .VOHAP0 concentration
 liters per minute             alO ppmw and flowrate &0.02
	liters per minute	

a Wastewater streams meeting these criteria are considered
  Group  1 wastewater streams and  control is required.

b There  are exemptions  for minimal flowrates and
  concentrations.

0 VOHAP  = volatile organic HAP.
                            8-31

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     The proposed standards require owners and operators to



comply with the maintenance wastewater requirements in



§63.105 of subpart F of part 63.  These provisions require



owners and operators to include a description of procedures



for managing wastewaters generated during maintenance in



their start-up, shutdown and malfunction plan'.  The start-



up, shutdown, and malfunction plan is required under subpart



A of part 63.



8.1.5.5  Heat Exchange Systems and Process Contact Cooling



Towers.  The proposed standards would require a monitoring



program to detect leakage of organic HAP from the process



into the cooling water.  The proposed monitoring program is



the same as that in the HON (subpart F) .   The proposed rule



would also prohibit the use of cooling tower water in



contact condensers in the vacuum systems at PET facilities.



Further, if a wastewater stream is generated from the vacuum



system and it contains any of the organic HAP identified in



Table 9 of the HON wastewater provisions (subpart G),  the



proposed rule would require it to be controlled regardless



of its organic HAP concentration or flowrate.  The level of



control required is the same as that for a Group 1



wastewater stream.



     These provisions for control of emissions from process



contact cooling towers are independent of the provisions of



the NESHAP for Industrial Cooling Towers (40 CFR Part 63,
                            8-32

-------
Subpart Q) which may also be applicable to these cooling



towers.



8.1.5.6  Emissions Averaging.  The proposed standards would



apply essentially the same emissions averaging scheme as has



been adopted by the HON, although the emissions averaging



provisions of the proposed rule are entirely contained in



the proposed rule instead of referring to the subpart G



emissions averaging provisions.  Under the proposed rule,



emissions averaging would be allowed among five collocated



existing emission points belonging to the same subcategory.



This number may be increased by three additional points if



pollution prevention measures are to be used to control



emission points to be included in the average.  However,



emissions from batch process vents and equipment leaks,



would not be allowed to be averaged.  The owner or operator



must demonstrate that the averaging scheme will not result



in greater hazard or risk relative to strict compliance with



the standards in the absence of averaging.



8.1.5.7  Compliance and performance test provisions and



monitoring requirements.  Compliance and performance test



provisions and monitoring requirements contained in the



proposed rule are very similar to those found in the HON



(subpart G).   Each type of emission point is discussed



briefly in the paragraphs below.   Also,  significant



differences from the parameter monitoring requirements found



in subpart G are discussed.





                            8-33

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8.1.5.7.1  Continuous Process Vents.  The proposed



regulations for process vents from continuous unit



operations (continuous process vents) require the owner or



operator to either calculate a TRE index value to determine



whether each continuous process vent is a Group 1 or Group 2



vent, or the owner or operator can elect to comply with the



control requirements without calculating the TRE index.  The



TRE index value is determined after the last recovery device



in the process or prior to venting to the atmosphere.   The



TRE calculation involves an emissions test or engineering



assessment and use of the TRE equations in the proposed



rule.



     Performance test provisions are included for Group 1



continuous process vents to verify that the control device



achieves the required performance.  Monitoring provisions



necessary to demonstrate compliance are also included in the



proposed rule.



     Compliance provisions for continuous process vents at



polystyrene and PET facilities are included in the proposed



rule.  For owners or operators electing to comply with a



kg TOC/Mg of product limit,  procedures to demonstrate



compliance are provided.  Also,  procedures are included in



the proposed rule to demonstrate compliance with the



requirement to reduce overall process vent emissions



(continuous and batch)  by 84 percent for new SAN, batch



facilities.





                            8-34

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8.1.5.7.2  Batch Process Vents.  Similar to the provisions



for continuous process vents, there is a procedure for



determining which batch process vents are Group 1 and which



are Group 2.  This procedure is based on annual emissions



and annual average flowrate of the batch process vent.



Equations for estimating annual emissions and annual average



flowrates are provided in the proposed rule.



     Performance test provisions are included for Group 1



batch process vents to verify that the control or recovery



device achieves the required performance.  Monitoring



provisions necessary to demonstrate compliance are also



included in the proposed rule.



     For Group 2 batch process vents, the proposed rule



requires owners and operators to establish a batch cycle



limitation.  The batch cycle limitation limits the number of



batch cycles that can be accomplished for a given batch unit



operation per year (i.e., for the operations that feed a



single batch process vent).   This enforceable limitation



ensures that a Group 2 batch process vent does not become a



Group 1 batch process vent as a result of running more



batches than anticipated when the group determination was



made.  The determination of the batch cycle limitation is



not tied to any previous production amounts.  An affected



source may set the batch cycle limitation at any level it



desires as long as the batch process vent remains a Group 2



batch process vent.   Alternatively the proposed rule would





                            8-35

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allow owners and operators to declare any Group 2 batch



process vent to be a Group 1 batch process vent.  In such



cases, control of the batch process vent is required.



     As described in Section 8.1.5.2.1, procedures are



included in the proposed rule to demonstrate compliance with



the requirement to reduce overall process vent emissions



(continuous and batch) by 84 percent for new SAN,  batch



facilities.



8.1.5.7.3  Storage Vessels.   Monitoring and compliance



provisions include periodic visual inspections of vessels,



roof seals, and fittings, as well as internal inspections.



If a control device is used, the owner or operator must



identify the appropriate monitoring procedures to be



followed in order to demonstrate compliance.  Monitoring



parameters and procedures for many of the control devices



likely to be used are already identified in other parts of



the proposed rule.  Reports and records of inspections,



repairs,  and other information necessary to determine



compliance are also required by the proposed rule.



8.1.5.7.4  Wastewater.  For demonstrating compliance with



the various requirements, the proposed rule allows the



owners or operators to either conduct performance tests or



to document compliance using engineering calculations.



Appropriate compliance and monitoring provisions are



included in the regulation.
                            8-36

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8.1.5.7.5  Equipment Leaks.  The proposed rule retains the



use of Method 21 to detect leaks.  Method 21 requires a



portable organic vapor analyzer to monitor for leaks from



equipment  in use.  A "leak" is a concentration specified in



the regulation for the type of equipment being monitored and



is based on the instrument response to methane (the



calibration gas) in air.  The observed screening value may



require adjustment for response factor relative to methane



if the weighted response factor of the stream exceeds a



specified  multiplier.  The proposed rule requires the use of



Method 18  to determine the organic content of a process



stream.  Test procedures using either a gas or a liquid for



pressure testing the batch system are specified to test for



leaks.



8.1.5.7.6  Heat Exchange Systems.  Monitoring of cooling



water is required to detect leaks in noncontact heat



exchange systems.  If a leak is detected, the heat exchange



system must be repaired.



8.1.5.7.7  Process Contact Cooling Towers.   Owners and



operators  of sources subject to these provisions are



required to indicate in their Implementation Plan and



Notification of Compliance Status report that cooling tower



water will not be used in contact condensers associated with



vacuum systems.



8.1.5.7.8  Continuous Parameter Monitoring.   When compared



to the HON, the proposed rule contains two significant





                            8-37

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differences related to continuous parameter monitoring.



First, the proposed rule does not allow any excused



excursions.  The proposed rule, as did subpart G requires at



least 75 percent of monitoring data to constitute a valid



days worth of data for continuous and batch process vents.



Failure to have a valid day's worth of monitoring data is



considered an excursion.  The criteria for determining a



valid day's or hour's worth of data are provided in the



proposed rule.  Second, the procedure for determining the



parameter monitoring level for continuous and batch process



vents is both more specific and restrictive than the



procedure in the HON because it relies exclusively on



performance tests.



8.1.5.8  Recordkeeping and Reporting Requirements.   The



general recordkeeping and reporting requirements of this



subpart are very similar to those found in the HON.  The



proposed rule also relies on the provisions of subpart A of



part 63.  A table included in the proposed rule designates



which sections of subpart A apply to the proposed rule.



Specific recordkeeping and reporting requirements for each



type of emission point are also included in the proposed



rule.



     The proposed rule requires sources to keep records and



submit reports of information necessary to document



compliance.  Records must be kept for 5 years.  The



following six types of reports must be submitted to the





                            8-38

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Administrator as appropriate:   (1) Initial Notification,



 (2)  Implementation Plan  (if an operating permit application



has  not been submitted or, for new sources,  an application



for  approval of construction or reconstruction),  (3)



Emissions Averaging Plan,  (4) Notification of Compliance



Status,  (5) Periodic Reports, and  (6) other  reports.  The



requirements for each of the six types of reports are



summarized below.  In addition, affected sources complying



with the equipment leak requirements contained in subpart  H



must follow the recordkeeping and reporting  requirements of



subpart H.



8.1.5.8.1  Initial Notification.  The Initial Notification



is due 120 days after the date of promulgation for existing



sources.  For new sources, it is due 180 days before



commencement of construction or reconstruction, or 45 days



after promulgation, whichever is later.  The notification



must list the thermoplastic processes that are subject to



the  proposed rule,  and which provisions may apply



(e.g.,  continuous process vents, batch process vents,



storage vessels, wastewater,  and/or equipment leak



provisions).   A detailed identification of emission points



is not necessary for the Initial Notification.  The



notification,  however,  must include a statement of whether



the affected source expects that it can achieve compliance



by the specified compliance date.
                            8-39

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8.1.5.8.2  Implementation Plan.  The Implementation Plan



details how the affected source plans to comply.  An



Implementation Plan would be required only for affected



sources that have not yet submitted an operating permit



application or for new sources that have not yet submitted



the same information as part of their application for



approval of construction or reconstruction.



     The Implementation Plan would be due 12 months prior to



the date of compliance.  For new sources, Implementation



Plans would be submitted with the Notification of Compliance



Status.



     The information in the Implementation Plan should be



incorporated into the affected source's operating permit



application.  The terms and conditions of the plan, as



approved by the permit authority, would then be incorporated



into the operating permit.



     The Implementation Plan would include a list of



emission points subject to the continuous process vents,



batch process vents,  storage vessels,  wastewater, heat



exchange system,  process contact cooling tower, and



equipment leak provisions and, as applicable, whether each



emission point (e.g.,  storage vessel or process vent)  is



Group 1 or Group 2.   The control technology or method of



compliance planned for each Group 1 emission point must be



specified.
                            8-40

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     The plan must also certify that appropriate testing,



monitoring, reporting, and recordkeeping will be done for



each Group 1 emission point.  If an affected source requests



approval to monitor a unique parameter, a rationale must be



included.



8.1.5.8.3  Emissions Averaging Plan.  The Emissions



Averaging Plan would be due 18 months prior to the date of



compliance.  New sources are not allowed to comply through



the use of emissions averaging.



     For points included in emissions averaging, the



Emissions Averaging Plan would include:  an identification



of all points in the average and whether they are Group 1 or



Group 2 points/ the specific control technique or pollution



prevention measure that will be applied to each point; the



control efficiency for each control used in the average; the



projected credit or debit generated by each point; and the



overall expected credits and debits.  The plan must include



a demonstration that the emissions averaging scheme will not



result in greater hazard or risk than if the emission points



would comply with the standards in the absence of averaging.



The plan must also certify that the same types of testing,



monitoring,  reporting, and recordkeeping that are required



by the proposed rule for Group 1 points will be done for all



points (both Group 1 and Group 2)  included in an emissions



average.   If an affected source requests approval to monitor



a unique parameter or use a unique recordkeeping and





                            8-41

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reporting system, a rationale must be included in the



Emissions Averaging Plan.



8.1.5.8.4  Notification of Compliance Status.   The



Notification of Compliance Status would be required



150 days after the affected source's compliance date.  It



contains the information for Group l emission points and for



all emission points in emissions averages, necessary to



demonstrate that compliance has been achieved.  Such



information includes, but is not limited to, the results of



any performance tests for continuous and/or batch process



vents and wastewater emission points; one complete test



report for each test method used for a particular kind of



emission point; TRE determinations for continuous process



vents; group determinations for batch process vents; design



analyses for storage vessels and wastewater emission points;



monitored parameter levels for each emission point and



supporting data for the designated level; and values of all



parameters used to calculate emission credits and debits for



emissions averaging.



8.1.5.8.5  Periodic Reports.  Generally,  Periodic Reports



would be submitted semiannually.  However, there are two



exceptions.   First,  quarterly reports must be submitted for



all points included in an emissions average.  Second, if



monitoring results show that the parameter values for an



emission point are above the maximum or below the minimum



established levels for more than 1 percent of the operating





                            8-42

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time  in a reporting period, or the monitoring system is out



of service  for more than 5 percent of the time, the



regulatory  authority may request that the owner or operator



submit quarterly reports for that emission point.  After



1 year, semiannual reporting can be resumed, unless the



regulatory  authority requests continuation of quarterly



reports.



      All Periodic Reports would include information required



to be reported under the recordkeeping and reporting



provisions  for each emission point.  For emission points



involved in emissions averages, the report would include the



results of  the calculations of credits and debits for each



month and for the quarter.   For continuously monitored



parameters, the data on those periods when the parameters



are above the maximum or below the minimum established



levels are  included in the reports.  Periodic Reports would



also  include results of any performance tests conducted



during the  reporting period and instances when required



inspections revealed problems.   Additional information the



affected source is required to report under its operating



permit or Implementation Plan would also be described in



Periodic Reports.



8.1.5.8.6  Other reports.   Other reports required under the



proposed rule include:   reports of start-up,  shutdown,  and



malfunction; process changes that change the compliance



status of process vents;  and requests for extensions of





                            8-43

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repair and notifications of inspections for storage vessels



and wastewater.



     In addition, quarterly reporting of the number of batch



cycles accomplished for Group 2 batch process vents is



required.  Every fourth quarterly report would be required



to include the total batch cycles accomplished during the



previous 12 months, and a statement whether the owner or



operator is in compliance with the batch cycle limitation.



8.2  RATIONALE FOR THE SELECTION OF EMISSION POINTS TO BE



     COVERED BY THE PROPOSED STANDARDS



     Emissions from the production of Group IV



thermoplastics were identified as occurring from storage



vessels, process vents, equipment leaks, wastewater



operations, and heat exchange systems to include process



contact cooling towers.  The EPA is proposing standards for



all of these types of emission points in the proposed rule.



8.3  RATIONALE FOR THE SELECTION OF THE PROPOSED STANDARDS



     The approach for determining the MACT floor and



developing regulatory alternatives is discussed in Chapter



6.0.   Chapter 6.0 also presents in tabular form the results



of the MACT floor analysis and identifies the selected



regulatory alternative.  This chapter discusses the results



of the MACT floor analysis and provides the rationale for



the selection of the proposed standards.  Throughout



Sections 8.3.1 and 8.3.2, the use of the term "HON" in



reference to process vents is meant to include the Batch





                            8-44

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Processes ACT.  When a sentence states "the HON was
equivalent to the MACT floor for process vents," it should
be understood that the HON and Batch Processes ACT were
equivalent to the MACT floor for process vents.
      In some instances, the EPA has required control more
stringent than that required by the MACT floor.  In these
instances, the EPA has judged the impacts to be reasonable.
The EPA specifically solicits comments on these decisions.
8.3.1  Selection of the Standards for Existing Sources
      The following paragraphs discuss the selection of the
standards for existing sources for each subcategory.
     ABS. Continuous Emulsion Process
     Based on available information, there are two existing
facilities in the U.S. at which ABS is produced using a
continuous emulsion process.  The information on controls at
both  facilities was used to evaluate the MACT floor.  Based
on the analysis for determining the relationship between the
MACT floor and the HON, the EPA determined that the HON was
equivalent to the MACT floor for storage vessels, process
vents, and wastewater, and that the HON was more stringent
than the MACT floor for equipment leaks.
     The first regulatory alternative considered for
existing continuous emulsion ABS facilities consisted of
applying the HON to storage vessels, process vents,
equipment leaks,  and wastewater.  For storage vessels,
process vents,  and wastewater,  Regulatory Alternative 1 is

                            8-45

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equivalent to the MACT floor; thus, no emission reductions
or costs beyond those required to achieve the MACT floor
level of control would be incurred.  For equipment leaks,
the HON requirements are more stringent than the MACT floor,
and emission reductions and costs beyond those required to
achieve the MACT floor level of control would be incurred.
The EPA estimated the emission reductions and costs
associated with implementing the HON equipment leak
requirements compared to the existing levels of control.
These impacts are based on confidential information and
cannot be presented.  Considering these impacts, as well as
non-air environmental and energy impacts, the EPA judged
that this level of control was reasonable.  No additional
regulatory alternatives were identified.  Therefore, the
Administrator selected Regulatory Alternative 1 as the
proposed standard for existing continuous emulsion ABS
facilities.
     ABS. Continuous Mass Process
     Based on available information,  there are five existing
facilities in the U.S. at which ABS is produced using a
continuous mass process.  The information on controls at all
five facilities was used to evaluate the MACT floor.  Based
on the analysis for determining the relationship between the
MACT floor and the HON, the EPA determined that the HON was
equivalent to the MACT floor for storage vessels, process
                            8-46

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vents, and wastewater, and that the HON was more stringent
than the MACT floor for equipment leaks.
     The first regulatory alternative considered for
existing continuous mass ABS facilities consisted of
applying the HON to storage vessels, process vents,
equipment leaks, and wastewater.  For storage vessels,
process vents, and wastewater, Regulatory Alternative 1 is
equivalent to the MACT floor; thus, no emission reductions
or costs beyond those required to achieve the MACT floor
level of control would be incurred.  For equipment leaks,
the HON requirements are more stringent than the MACT floor,
and emission reductions and costs beyond those required to
achieve the MACT floor level of control would be incurred.
The EPA estimated the emission reductions (171 Mg/yr) and
costs  ($70,000/yr) associated with implementing the HON
equipment leak requirements compared to the existing levels
of control.  Considering these impacts, as well as non-air
environmental and energy impacts,  the EPA judged that this
level of control was reasonable.  No additional regulatory
alternatives were identified.  Therefore,  the Administrator
selected Regulatory Alternative 1 as the proposed standard
for existing continuous mass ABS facilities.
     ABS,  Batch Emulsion Process
     Based on available information, there are four existing
facilities in the U.S. at which ABS is produced using a
batch emulsion process.  The information on controls at all

                            8-47

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four facilities was used to evaluate the MACT floor.  Based



on the analysis for determining the relationship between the



MACT floor and the HON, the EPA determined that the HON was



equivalent to the MACT floor for storage vessels/ process



vents, and wastewater, and that the HON was more stringent



than the MACT floor for equipment leaks.



     The first regulatory alternative considered for



existing batch emulsion ABS facilities consisted of applying



the HON to storage vessels, process vents,  equipment leaks,



and wastewater.  For storage vessels, process vents, and



wastewater, Regulatory Alternative 1 is equivalent to the



MACT floor; thus, no emission reductions or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For equipment leaks, the HON



requirements are more stringent than the MACT floor, and



emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions (37 Mg/yr) and



costs ($28,000/yr) associated with implementing the HON



equipment leak requirements compared to the existing levels



of control.  Considering these impacts, as well as non-air



environmental and energy impacts, the EPA judged that this



level of control was reasonable.  No additional regulatory



alternatives were identified.  Therefore, the Administrator



selected Regulatory Alternative 1 as the proposed standard



for existing batch emulsion ABS facilities.





                            8-48

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     ABS. Batch Suspension Process



     Based on available information, there are two existing



facilities in the U.S. at which ABS is produced using a



batch suspension process.  The information on controls at



both facilities was used to evaluate the MACT floor.  Based



on the analysis for determining the relationship between the



MACT floor and the HON, the EPA determined that the HON was



equivalent to the MACT floor for storage vessels, process



vents, and wastewater, and that the HON was more stringent



than the MACT floor for equipment leaks.



     The first regulatory alternative considered for



existing batch suspension ABS facilities consisted of



applying the HON to storage vessels, process vents,



equipment leaks, and wastewater.  For storage vessels,



process vents, and wastewater, Regulatory Alternative 1 is



equivalent to the MACT floor; thus, no emission reductions



or costs beyond those required to achieve the MACT floor



level of control would be incurred.  For equipment leaks,



the HON requirements are more stringent than the MACT floor,



and emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions of 5 Mg/yr and a



very small cost savings associated with implementing the HON



equipment leak requirements compared to the existing levels



of control.  Considering these impacts, as well as non-air



environmental and energy impacts,  the EPA judged that this





                            8-49

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level of control was reasonable.  No additional regulatory



alternatives were identified.  Therefore, the Administrator



selected Regulatory Alternative 1 as the proposed standard



for existing batch suspension ABS facilities.



     ABS. Latex Process



     Based on available information, there is one existing



facility in the U.S. at which ABS is produced using a latex



process.  The information on controls at this facility was



used to evaluate the MACT floor.  Based on the analysis for



determining the relationship between the MACT floor and the



HON, the EPA determined that the HON was equivalent to the



MACT floor for storage vessels, process vents, and



wastewater, and that the HON was more stringent than the



MACT floor for equipment leaks.



     The first regulatory alternative considered for



existing ABS latex facilities consisted of applying the HON



to storage vessels, process vents, equipment leaks, and



wastewater.  For storage vessels, process vents, and



wastewater, Regulatory Alternative 1 is equivalent to the



MACT floor; thus, no emission reductions or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For equipment leaks, the HON



requirements are more stringent than the MACT floor, and



emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions of 2 Mg/yr and a





                            8-50

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cost savings of  $500/yr associated with implementing the HON



equipment leak requirements compared to the existing levels



of control.  Considering these impacts, as well as non-air



environmental and energy impacts, the EPA judged that this



level of control was reasonable.  No additional regulatory



alternatives were identified.  Therefore, the Administrator



selected Regulatory Alternative 1 as the proposed standard



for existing ABS latex facilities.



     MASS Process



     Based on available information, there is one existing



facility in the  U.S. at which ABS is produced.  The



information on controls at this facility was used to



evaluate the MACT floor.  Based on the analysis for



determining the  relationship between the MACT floor and the



HON, the EPA determined that the HON was equivalent to the



MACT floor for storage vessels, process vents, and



wastewater, and  that the HON was more stringent than the



MACT floor for equipment leaks.



     The first regulatory alternative considered for



existing MABS facilities consisted of applying the HON to



storage vessels, process vents, equipment leaks, and



wastewater.  For storage vessels, process vents, and



wastewater, Regulatory Alternative 1 is equivalent to the



MACT floor; thus, no emission reductions or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For equipment leaks, the HON





                            8-51

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requirements are more stringent than the MACT floor, and



emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions and costs



associated with implementing the HON equipment leak



requirements compared to the existing levels of control.



These impacts are based on confidential information and



cannot be presented.  Considering these impacts, as well as



non-air environmental and energy impacts, the EPA judged



that this level of control was reasonable.  No additional



regulatory alternatives were identified.  Therefore, the



Administrator selected Regulatory Alternative 1 as the



proposed standard for existing MABS facilities.



     MBS Process



     Based on available information, there are three



existing facilities in the U.S. at which MBS is produced.



The information on controls at all three facilities was used



to evaluate the MACT floor.  Based on the analysis for



determining the relationship between the MACT floor and the



HON, the EPA determined that the HON was equivalent to the



MACT floor for storage vessels and wastewater, that the HON



was less stringent than the MACT floor for process vents,



and that the HON was more stringent than the MACT floor for



equipment leaks.



     Since the HON was determined to be less stringent than



the MACT floor for process vents, the EPA defined the MACT





                            8-52

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floor and included it as part of the first regulatory



alternative  (Regulatory Alternative 1).  The EPA analyzed



several options for defining the MACT  floor.  These options



were a TRE, an emission factor, a percent reduction, and



various combinations of these.  Based  on this analysis  (see



Docket A-92-45, Category II-B), the EPA determined that the



option of either complying with a TRE  or an emission factor



was the best representation of the MACT floor.



     The first regulatory alternative  considered for



existing MBS facilities consisted of applying the MACT floor



to process vents and the HON to storage vessels, equipment



leaks, and wastewater.  For storage vessels, process vents,



and wastewater, Regulatory Alternative 1 is equivalent to



the MACT floor; thus, no emission reductions or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For equipment leaks, the HON



requirements are more stringent than the MACT floor, and



emission reductions and costs Jseyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions (109 Mg/yr)  and



costs ($44,000/yr) associated with implementing the HON



equipment leak requirements compared to the existing levels



of control.  Considering these impacts, as well as non-air



environmental and energy impacts,  the EPA judged that this



level of control was reasonable.   No additional regulatory



alternatives were identified.   Therefore, the Administrator





                            8-53

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selected Regulatory Alternative 1 as the proposed standard



for existing MBS facilities.



     SAN. Continuous Process



     Based on available information, there are three



existing facilities in the U.S. at which SAN is produced



using a continuous process.  The information on controls at



all three facilities was used to evaluate the MACT floor.



Based on the analysis for determining the relationship



between the MACT floor and the HON, the EPA determined that



the HON was equivalent to the MACT floor for storage



vessels, wastewater, and process vents, and the HON was more



stringent than the MACT floor for equipment leaks.



     The first regulatory alternative  (Regulatory



Alternative 1) considered for existing SAN facilities using



a continuous process consisted of applying the HON to each



of the four types of emission points.  For storage vessels,



process vents, and wastewater, Regulatory Alternative 1 is



equivalent to the MACT floor; thus, no emission reductions



or costs beyond those required to achieve the MACT floor



level of control would be incurred.  For equipment leaks,



the HON requirements are more stringent than the MACT floor,



and emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions (46 Mg/yr) and



costs ($55,000/yr)  associated with implementing the HON



equipment leak requirements compared to the existing level





                            8-54

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of controls.  Considering these impacts, as well as non-air
environmental and energy impacts, the EPA judged that this
level of control was reasonable.  No additional regulatory
alternatives were identified.  Therefore, the EPA selected
Regulatory Alternative 1 as the proposed standard for
existing SAN facilities using a continuous process.
     SAN. Batch Processes
     Based on available information, there are two existing
facilities in the U.S. at which SAN is produced using a
batch process.  The information on controls at both
facilities was used to evaluate the MACT floor.  Based on
the analysis for determining the relationship between the
MACT floor and the HON, the EPA determined that the HON was
equivalent to the MACT floor for storage vessels,
wastewater, and process vents, and that the HON was more
stringent than the MACT floor for equipment leaks.
     The first regulatory alternative (Regulatory
Alternative 1) considered for existing SAN facilities using
a batch process consisted of applying the HON to each of the
four types of emission points.  For storage vessels, process
vents,  and wastewater, Regulatory Alternative 1 is
equivalent to the MACT floor; thus,  no emission reductions
or costs beyond those required to achieve the MACT floor
level of control would be incurred.   For equipment leaks,
the HON requirements are more stringent than the MACT floor,
and emission reductions and costs beyond those required to

                            8-55

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achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions (7 Mg/yr) and cost



savings ($l,200/yr) associated with implementing the HON



equipment leak requirements compared to the existing level



of controls.  Considering these impacts, as well as non-air



environmental and energy impacts,  the EPA judged that this



level of control was reasonable.  No additional regulatory



alternatives were identified.  Therefore, the Administrator



selected Regulatory Alternative 1 as the proposed standard



for existing SAN facilities using a batch process.



     ASA/AMSAN Process



     Based on available information, only one facility in



the U.S. produces ASA/AMSAN.  The information on the



controls used at this one facility was used to evaluate the



MACT floor.  Based on the analysis for determining the



relationship between the MACT floor and the HON, the EPA



determined that the HON was less stringent than the MACT



floor for storage vessels and process vents, and the HON was



more stringent than the MACT floor for equipment leaks and



wastewater emissions.



     Since the HON was determined to be less stringent than



the MACT floor for storage vessels and process vents, the



EPA defined the MACT floor and included it as part of the



first regulatory alternative (Regulatory Alternative 1).



Since there is only one facility in this subcategory, the



MACT floor is equivalent to the existing level of control.





                            8-56

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For storage vessels, the EPA evaluated three options for



defining the MACT floor.  These options were:   (1) define



vapor pressure and storage vessel capacity combinations;  (2)



define chemical type and storage vessel capacity



combinations; and (3) Option 2 supplemented by Option 1 for



chemicals not specified under Option 2.   Based on this



analysis (see Docket A-92-45, Category II-B), the EPA



determined that the best option for defining the MACT floor



was to use vapor pressure and storage vessel size



combinations.  For process vents, the one facility controls



all process vents.  Therefore, the best representation of



the MACT floor is the same - control of all process vents.



     The first regulatory alternative considered for the



existing ASA/AMSAN facility consisted of applying the MACT



floor to storage vessels and process vents and the HON to



equipment leaks and wastewater.  For storage vessels and



process vents, Regulatory Alternative 1  is equivalent to the



MACT floor; thus no emission reductions  or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For equipment leaks  and wastewater,  the



HON requirements are more stringent than the MACT floor, and



emission reductions and costs beyond those required to



achieve the MACT floor level of control  would be incurred.



The EPA estimated the emission reductions (89 Mg/yr)  and



costs ($74,000/yr) associated with implementing the HON



equipment leaks requirements compared to the existing level





                            8-57

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of control.  Considering these impacts, as well as non-air



environmental and energy impacts, the EPA judged that this



level of control was reasonable.  The EPA also estimated the



emission reductions (5 Mg/yr)  and costs ($127,000/yr)



associated with implementing the HON wastewater



requirements.  The EPA found these impacts were not



reasonable.  No additional regulatory alternatives were



identified.  Based on these considerations, the



Administrator selected Regulatory Alternative I for storage



vessels, process vents, and equipment leaks as the proposed



standard for existing ASA/AMSAN facilities.  No standards



are being proposed for wastewater emissions.



     Polystyrene. Continuous Processes



     Based on available information, there are 22 facilities



in the U.S. at which polystyrene is being produced using a



continuous process.  The information on controls for the



best performing five facilities was used to evaluate the



MACT floor.  Based on the analysis for determining the



relationship between the MACT floor, the HON, and the



Polymers NSPS, the EPA determined that the HON and Polymers



NSPS were equivalent to the MACT floor for process vents,



the HON was equivalent to the MACT floor for wastewater, the



HON was more stringent than the MACT floor for equipment



leaks,  and the HON was less stringent than the MACT floor



for storage vessels.
                            8-58

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     The first regulatory alternative  (Regulatory



Alternative 1) considered for existing polystyrene



facilities using a continuous process consisted of applying



1) the MACT floor to storage vessels, 2) the HON and



Polymers NSPS to process vents, and 3) the HON to



wastewater, and equipment leaks.  For storage vessels,



process vents, and wastewater, Regulatory Alternative 1 is



equivalent to the MACT floor; thus, no emission reductions



or costs beyond those required to achieve the MACT floor



level of control would be incurred.  For equipment leaks,



the HON requirements are more stringent than the MACT floor,



and emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



     The EPA estimated the emission reductions and costs



associated with implementing those requirements in



Regulatory Alternative 1 that are more stringent than the



MACT floor (see Table 8-8).   Considering these impacts, as



well as non-air environmental and energy impacts, the EPA



judged that those portions of Regulatory Alternative 1 more



stringent than the MACT floor were reasonable.  Therefore,



the Administrator selected Regulatory Alternative 1 as the



proposed standard for existing polystyrene facilities using



a continuous process.
                            8-59

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TABLE 8-8.  REGULATORY ALTERNATIVE IMPACTS FOR
  EXISTING POLYSTYRENE CONTINUOUS FACILITIES
Regulatory
Alternative
Existing
Control
1
Emission
Reduction
Mg/yr
--
897
Total Annual
Costs,
$l,000/yr
--
414
Cost-
Ef f ectiveness ,
$/Mg
Average
--
460
                     8-60

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     Polystyrene. Batch Processes



     Based on available information, there are 11 existing



facilities in the U.S. at which polystyrene is produced



using a batch process.  The information on controls for the



best performing five facilities was used to evaluate the



MACT floor.  Based on the analysis for determining the



relationship between the MACT floor and the HON, the EPA



determined that the HON was equivalent to the MACT floor for



storage vessels and wastewater, and that the HON was more



stringent than the MACT floor for equipment leaks and



process vents.



     The first regulatory alternative (Regulatory



Alternative 1) considered for existing polystyrene



facilities using a batch process consisted of applying the



HON to each of the four types of emission points.   For



storage vessels and wastewater, Regulatory Alternative 1 is



equivalent to the MACT floor; thus, no emission reductions



or costs beyond those required to achieve the MACT floor



level of control would be incurred.  For process vents and



equipment leaks, the HON requirements are more stringent



than the MACT floor,  and emission reductions and costs



beyond those required to achieve the MACT floor level of



control would be incurred.  The EPA estimated the emission



reductions (139 Mg/yr)  and cost savings ($119,000/yr)



associated with implementing the HON to process vents and



equipment leaks compared to the existing level of controls.





                            8-61

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Considering these impacts, as well as non-air environmental



and energy impacts, the EPA judged that this level of



control was reasonable.  No additional regulatory



alternatives were identified.  Therefore, the Administrator



selected Regulatory Alternative 1 as the proposed standard



for existing polystyrene facilities using a batch process.



     Expandable Polystyrene Processes



     Based on available information, there are 7 existing



facilities in the U.S. at which expandable polystyrene is



produced.  The information on controls for the best



performing five facilities was used to evaluate the MACT



floor.  Based on the analysis for determining the



relationship between the MACT floor and the HON, the EPA



determined that the HON was equivalent to the MACT floor for



storage vessels, wastewater, and process vents, and that the



HON was more stringent than the MACT floor for equipment



leaks.



     The first regulatory alternative (Regulatory



Alternative 1) considered for existing expandable



polystyrene facilities consisted of applying the HON to each



of the four types of emission points.  For storage vessels,



process vents, and wastewater, Regulatory Alternative 1 is



equivalent to the MACT floor; thus, no emission reductions



or costs beyond those required to achieve the MACT floor



level of control would be incurred.  For equipment leaks,



the HON requirements are more stringent than the MACT floor,





                            8-62

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and emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions  (92 Mg/yr) and



cost savings  ($49,000/yr) associated with implementing the



HON equipment leak requirements compared to the existing



level of controls.  Considering these impacts, as well as



non-air environmental and energy impacts, the EPA judged



that this level of control was reasonable.  No additional



regulatory alternatives were identified.  Therefore, the



Administrator selected Regulatory Alternative 1 as the



proposed standard for existing expandable polystyrene



facilities.



     PET - TPA. Continuous Processes



     Based on available information, there are 12 facilities



in the U.S. at which PET is being produced using the TPA



continuous process.  The information on controls for the



best performing five facilities was used to evaluate the



MACT floor.  Based on the analysis for determining the



relationship between the MACT floor, the HON, and the



Polymers NSPS, the EPA determined that the HON was



equivalent to the MACT floor for storage vessels and



wastewater, that the HON and Polymers NSPS were equivalent



to the MACT floor for process vents, and that the HON was



more stringent than the MACT floor for equipment leaks.



     As has been discussed earlier,  process contact cooling



towers are addressed by the Polymers NSPS.  Of those





                            8-63

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facilities with process contact cooling towers as a type of



emission point, none control the emissions from the cooling



towers.  Based on this information, the EPA determined that



the MACT floor for process contact cooling towers at



existing facilities using a TPA continuous process was no



control.  Thus, the Polymers NSPS is more stringent than the



MACT floor.  However, as discussed earlier, ethylene glycol



jets were determined to be more cost effective in reducing



emissions than the requirements of the Polymers NSPS.



     The first regulatory alternative (Regulatory



Alternative 1) considered for existing PET sources using a



continuous TPA process consisted of applying the HON to



storage vessels, equipment leaks, and wastewater and



applying the HON and Polymers NSPS to process vents.  In



addition, the HON wastewater applicability criteria were



applied to the vacuum system generated wastewater as part of



the first regulatory alternative.  For storage vessels,



process vents, and (non-vacuum system generated) wastewater,



Regulatory Alternative 1 is equivalent to the MACT floor;



thus, no emission reductions or costs beyond those required



to achieve the MACT floor level of control would be



incurred.  For equipment leaks and vacuum system generated



wastewater, Regulatory Alternative 1 is more stringent than



the MACT floor, and emission reductions and costs beyond



those required to achieve the MACT floor level of control



would be incurred.





                            8-64

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     A second regulatory alternative was developed for



existing PET facilities using a continuous TPA process.  In



the second regulatory alternative, control of emissions from



the process contact cooling tower, which result from the



vacuum system generated wastewater, was considered by



prohibiting the use of cooling tower water in the contact



condensers in the vacuum system.  For the purposes of this



analysis, this prohibition was assumed to be implemented by



replacing the existing steam jet vacuum systems with



ethylene glycol jet vacuum systems.  (Other methods for



achieving this prohibition were judged by the EPA to obtain



equivalent results at less cost.)  The requirements for



storage vessels, process vents, equipment leaks, and



wastewater remained the same.  No additional regulatory



alternatives were identified.



     The EPA estimated the emission reductions and costs



associated with implementing those requirements in



Regulatory Alternatives 1 and 2 that are more stringent than



the MACT floor  (see Table 8-9) .  Considering these impacts,



as well as non-air environmental and energy impacts,  the EPA



judged that those portions of Regulatory Alternative 2 more



stringent than the MACT floor were reasonable.  Therefore,



the Administrator selected Regulatory Alternative 2 as the



proposed standard for existing PET facilities using a



continuous TPA process.   The EPA solicits comment on this



decision to go beyond the MACT floor.





                            8-65

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TABLE 8-9.  REGULATORY ALTERNATIVE IMPACTS FOR
      EXISTING TPA CONTINUOUS FACILITIES
Regulatory
Alternative
Existing
Control
1
2
Emission
Reduction
Mg/yr
--
1,380
2,472
Total
Annual
Costs,
$l,000/yr
--
1,441
3,436
Cost -Effectiveness,
$/Mg
Average
--
1,040
1,390
Incremental
--
--
1,830
                     8-66

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     Based on the available data, the Polymers NSPS



requirements did not gain any additional control over and



above that which the HON would obtain.  Since there does not



appear to be any impact from the Polymers NSPS on existing



continuous TPA facilities, the EPA is specifically



requesting comments on whether to adopt a combination of the



Polymers NSPS and HON or only the HON for this subcategory.



In support of their position, commenters are specifically



requested to provide documentation on (1) which emission



streams would be required to be controlled or not controlled



and  (2) for each stream that would be required to be



controlled, which rule (HON or Polymers NSPS or both) would



require control, the emission reduction as the result of



control, and the costs of control.  The regulatory



alternative selected for the final standard could range from



the Polymers NSPS to the HON or a combination of both,



depending on the data submitted.



     PET - TPA. Batch Processes



     Only one facility in the U.S. has been identified as



producing PET using a batch TPA process.  The information on



the controls used at this facility was used to evaluate the



MACT floor.  Based on the analysis for determining the



relationship between the HON and the MACT floor,  the HON was



determined to be equivalent to the MACT floor for storage



vessels, wastewater, and process vents,  and the HON was
                            8-67

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determined to be more stringent than the MACT floor for



equipment leaks.



     The one facility using the batch TPA process does not



control emissions from the process contact cooling tower.



Therefore, the MACT floor for process contact cooling towers



is no control.  One potential regulatory alternative is to



apply the requirements for cooling towers from the Polymers



NSPS.  However, as discussed earlier, several methods,



including ethylene glycol jets, were determined to be more



cost effective in reducing emissions from process contact



cooling towers.



     The first regulatory alternative (Regulatory



Alternative 1) considered for the existing PET facility



using a batch TPA process consisted of applying the HON to



storage vessels,  process vents, equipment leaks, and



wastewater (including vacuum system generated wastewater).



For storage vessels, process vents, and wastewater,



Regulatory Alternative 1 is equivalent to the MACT floor;



thus, no emission reductions or costs beyond those required



to achieve the MACT floor level of control would be



incurred.  For equipment leaks and vacuum system generated



wastewater, Regulatory Alternative 1 is more stringent than



the MACT floor, and emission reductions and costs beyond



those required to achieve the MACT floor control level would



be incurred.
                            8-68

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     A second regulatory alternative was developed for batch



TPA processes.  As for continuous TPA processes, in the



second regulatory alternative, control of emissions from the



cooling tower was considered through the replacement of



existing steam jet vacuum systems with ethylene glycol jet



vacuum systems.  Requirements for the other types of



emission points remained the same.  No additional regulatory



alternatives were identified.



     The EPA estimated the emission reductions and costs



associated with implementing those requirements in



Regulatory Alternatives l and 2 that are more stringent than



the MACT floor (see Table 8-10}.   Considering these impacts,



as well as non-air environmental and energy impacts, the EPA



judged that those portions of Regulatory Alternative 2 more



stringent than the MACT floor were reasonable.  Therefore,



the Administrator selected Regulatory Alternative 2 as the



proposed standard for existing PET facilities using a batch



TPA process.
                            8-69

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       TABLE  8-10.   REGULATORY ALTERNATIVE  IMPACTS  FOR
                EXISTING TPA BATCH FACILITIES
Regulatory
Alternative
Existing
Control
1
2a
Emission
Reduction
Mg/yr
--
5.6
CBI
Total
Annual
Costs,
$l,000/yr
--
18
CBI
Cost-
Ef f ectiveness ,
$/Mg
Average
--
3,180
CBI
a Impacts  for the  control  included  in  this  regulatory
alternative are based on confidential information and cannot
be presented.
                            8-70

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     PET - DMT. Continuous Processes



     Based on available information, there are 10 facilities



in the U.S. at which PET is produced using a DMT continuous



process.  The information on controls for the best



performing five facilities was used to evaluate the MACT



floor.  Based on the analysis for determining the



relationship between the MACT floor, the HON, and the



Polymers NSPS, the EPA determined that the HON was



equivalent to the MACT floor for storage vessels, process



vents, and wastewater, and that the HON was more stringent



than the MACT floor for equipment leaks.



     As has been discussed earlier, process contact cooling



towers are addressed by the Polymers NSPS.  Of those



facilities with process contact cooling towers as a type of



emission point, none control the emissions from the cooling



towers.  Based on this information, the EPA determined that



the MACT floor for process contact cooling towers at



existing facilities using a continuous DMT process was no



control, and the Polymers NSPS is more stringent than the



MACT floor.  However,  also as noted earlier,  ethylene glycol



jets were determined to be more cost effective in reducing



emissions.



     The first regulatory alternative (Regulatory



Alternative 1) considered for existing PET sources using a



continuous DMT process consisted of applying the HON to



storage vessels,  process vents,  equipment leaks,  and





                            8-71

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wastewater  (including the vacuum system generated



wastewater).  For storage vessels,  process vents, and



wastewater, Regulatory Alternative 1 is equivalent to the



MACT floor; thus, no emission reductions or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For equipment leaks, the HON



requirements are more stringent than the MACT floor, and



emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



     A second regulatory alternative was developed for



continuous DMT processes.  The second regulatory alternative



also considered the application of the Polymers NSPS to



process emissions from the material recovery section and the



polymerization reaction section, in addition to the HON for



other process vents.  As for continuous TPA processes, in



the second regulatory alternative,  control of emissions from



the cooling tower was considered through the replacement of



existing steam jet vacuum systems with ethylene glycol jet



vacuum systems.  The requirements for storage vessels,



equipment leaks, and wastewater remained the same.  No



additional regulatory alternatives were identified.



     The EPA estimated the emission reductions and costs



associated with implementing those requirements in



Regulatory Alternatives 1 and 2 that are more stringent than



the MACT floor  (see Table 8-11).  Considering these impacts,



as well as non-air environmental and energy impacts, the EPA





                            8-72

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TABLE 8-11.  REGULATORY ALTERNATIVE IMPACTS FOR
         EXISTING DMT BATCH FACILITIES
Regulatory
Alternative
Existing
Control
1
2
Emission
Reduction
Mg/yr
--
1,190
1,881
Total
Annual
Costs,
$l,000/yr
--
1,489
2,909
Cost-
Ef f ectiveness ,
$/Mg
Average
--
1,250
1,546
Incremental
--
—
2,050
                     8-73

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judged that those portions of Regulatory Alternative 2 more



stringent than the MACT floor were reasonable.  Therefore,



the EPA selected Regulatory Alternative 2 as the proposed



standard for existing PET facilities using a continuous DMT



process.  The EPA solicits comment on this decision to go



beyond the MACT floor.



     Based on the available data,  the Polymers NSPS applied



to continuous DMT process sources was estimated to obtain



additional control from process vents in the material



recovery section over and above what the HON would obtain,



but not for the polymerization reaction section.  Since the



impact of the Polymers NSPS on existing facilities is



unclear, the EPA is specifically requesting comments on



whether to adopt a combination of the Polymers NSPS and HON



or only the HON for this subcategory.  In support of their



position, commenters are specifically requested to provide



documentation on which emission streams would be required to



be controlled or not controlled and, for each stream that



would be required to be controlled,  which rule  (HON or



Polymers NSPS or both) would require control, the emission



reduction as the result of control,  and the costs of



control.  The regulatory alternative selected for the final



standard could range from the Polymers NSPS to the HON or a



combination of both, depending on the data submitted.
                            8-74

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     PET  - DMT. Batch Processes



     Based on available information, there are 10 facilities



in the U.S. at which PET is produced using a batch DMT



process.  The information on controls for the best



performing five facilities was used to evaluate the MACT



floor.  Based on the analysis for determining the



relationship between the MACT floor and the HON, the EPA



determined that HON was equivalent to the MACT floor for



storage vessels, wastewater, and process vents, and that the



HON was more stringent than the MACT floor for equipment



leaks.



     Of those facilities with process contact cooling towers



as a type of emission point, none control the cooling tower



emissions.  Based on this information, the EPA determined



that the MACT floor for process contact cooling towers at



existing facilities using a batch DMT process was no



control.  One potential regulatory alternative is to apply



the requirements for cooling towers from the Polymers NSPS.



However, as noted earlier,  ethylene glycol jets were



determined to be more cost effective in reducing emissions



from process contact cooling towers than the requirements of



subpart DDD.



     The first regulatory alternative (Regulatory



Alternative l)  considered for existing PET sources using a



batch DMT process consisted of applying the HON to storage



vessels, process vents,  equipment leaks,  and wastewater.





                            8-75

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For storage vessels, process vents, and wastewater,



Regulatory Alternative 1 is equivalent to the MACT floor;



thus, no emission reductions or costs beyond those required



to achieve the MACT floor level of control would be



incurred.  For equipment leaks and vacuum system generated



wastewater, the HON is more stringent than the MACT floor,



and emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



     A second regulatory alternative was developed for batch



DMT processes.  As for continuous TPA processes, in the



second regulatory alternative, control of emissions from the



process contact cooling tower was considered through the



replacement of existing steam jet vacuum systems with



ethylene glycol jet vacuum systems.  The requirements for



the remaining types of emission points remained the same.



No additional regulatory alternatives were identified.



     The EPA estimated the emission reductions and costs



associated with implementing the requirements in Regulatory



Alternatives 1 and 2 that are more stringent than the MACT



floor (see Table 8-12).   Considering these impacts, as well



as non-air environmental and energy impacts, the EPA judged



that those portions of Regulatory Alternative 2 more



stringent than the MACT floor were reasonable.  Therefore,



the EPA selected Regulatory Alternative 2 as the proposed



standard for existing PET facilities using a batch DMT



process.





                            8-76

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TABLE 8-12.  REGULATORY ALTERNATIVE IMPACTS FOR
         EXISTING DMT BATCH FACILITIES
Regulatory
Alternative
Existing
Control
1
2
Emission
Reduction
Mg/yr
--
2,567
4,551
Total
Annual
Costs,
$l,000/yr
--
12,023
2,741
Cost-Effectiveness ,
$/Mg
Average
--
4,680
602
Incremental
--

-4,680
                     8-77

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      Nitrile Resin Process



     Based on available information,  only one facility in



the U.S. produces nitrile resin.  The information on the



controls used at this one facility was used to evaluate the



MACT floor.  Based on the analysis for determining the



relationship between the MACT floor and the HON, the EPA



determined that the HON was less stringent than the MACT



floor for storage vessels,  more stringent than the MACT



floor for process vents and equipment leaks, and equivalent



to the MACT floor for wastewater emissions.



     Since the HON was determined to be less stringent than



the MACT floor for storage vessels, the EPA defined the MACT



floor and included it as part of the first regulatory



alternative (Regulatory Alternative 1).  Since there is only



one facility in this subcategory, the MACT floor is



equivalent to the existing level of control.  The EPA



determined that the best representation of the current level



of control for storage vessels is the control of all



acrylonitrile tanks of at least 3,500 gallons capacity and



the application of the HON applicability criteria for all



other chemical storage vessels  (see Docket A-92-45,



Category II-B).



     The first regulatory alternative considered for the



existing nitrile resin facility consisted of applying the



MACT floor to storage vessels and the HON to process vents,



equipment leaks, and wastewater.  For storage vessels and





                            8-78

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wastewater, Regulatory Alternative 1 is equivalent to the



MACT floor/ thus no emission reductions or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For process vents and equipment leaks,



the HON requirements are more stringent than the MACT floor,



and emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA-estimated the emission reductions (10 Mg/yr) and



costs ($6,600/yr) associated with implementing the HON



process vents and equipment leaks requirements compared to



the existing level of control.  Considering these impacts,



as well as non-air environmental and energy impacts, the EPA



judged that this level of control was reasonable.  No



additional regulatory alternatives were identified.  Based



on these considerations, the Administrator selected



Regulatory Alternative 1 as the proposed standard for



existing nitrile resin facilities.



8.3.2  Selection of the Standards for New Sources



     The following paragraphs discuss the selection of the



standards for new sources for each subcategory.



     ABS.  Continuous Emulsion Process



     As noted earlier,  the EPA identified two facilities in



the U.S. at which ABS is produced using a continuous



emulsion process.  The information on controls at both



facilities was used to identify the best level of control



(i.e.,  MACT floor)  for each type of emission point.  Based





                            8-79

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on the analysis for determining the relationship between the



MACT floor and the HON, the EPA determined that the HON was



equivalent to the MACT floor for storage vessels, process



vents, and wastewater, and the HON was more stringent than



the MACT floor for equipment leaks.



     The first regulatory alternative (Regulatory



Alternative 1) considered for new ABS facilities using a



continuous emulsion process was the HON for storage vessels,



process vents, equipment leaks, and wastewater.  For storage



vessels, process vents, and wastewater,  Regulatory



Alternative 1 is equivalent to the MACT floor; thus no



emission reductions or costs beyond those required to



achieve the MACT floor level of control would be incurred.



For equipment leaks, the HON requirements are more stringent



than the MACT floor, and emission reductions and costs



beyond those required to achieve the MACT floor level of



control would be incurred.  The EPA estimated the emission



reductions and costs associated with implementing the HON



equipment leak requirements.  These impacts are based on



confidential information and cannot be presented.



Considering these impacts, as well as non-air environmental



and energy impacts, the EPA judged that this level of



control was reasonable.  Therefore, the EPA selected



Regulatory Alternative 1 as the proposed standard for new



ABS facilities using a continuous emulsion process.
                            8-80

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     ABS, Continuous Mass Process
     As noted earlier, the EPA identified five facilities  in
the U.S. at which ABS is produced using a continuous mass
process.  The information on controls at all five facilities
was used to identify the best level of control  (i.e., MACT
floor) for each type of emission point.  Based on the
analysis for determining the relationship between the MACT
floor and the HON, the EPA determined that the HON was less
stringent than the MACT floor for storage vessels, the HON
was equivalent to the MACT floor for process vents and
wastewater, and the HON was more stringent than the MACT
floor for equipment leaks.
     Since the HON was less stringent than the MACT floor
for storage vessels, the EPA defined the MACT floor.  Three
options were considered for defining the MACT floor:
(l) define vapor pressure and storage vessel capacity
combinations; (2) define chemical type and storage vessel
capacity combinations/ and (3) Option 2 supplemented by
Option 1 for chemicals not specified under Option 2.  Based
on this analysis (see Docket A-92-45,  Category II-B), the
EPA determined that the best option for defining the MACT
floor was to use vapor pressure and storage vessel size
combinations.
     The first regulatory alternative (Regulatory
Alternative 1)  considered for new ABS facilities using a
continuous mass process was the MACT floor for storage

                            8-81

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vessels and the HON for process vents, equipment leaks, and
wastewater.  For storage vessels, process vents, and
wastewater, Regulatory Alternative 1 is equivalent to the
MACT floor; thus no emission reductions or costs beyond
those required to achieve the MACT floor level of control
would be incurred.  For equipment leaks, the HON
requirements are more stringent than the MACT floor, and
emission reductions and costs beyond those required to
achieve the MACT floor level of control would be incurred.
The EPA developed a second regulatory alternative, which
considered more stringent controls on storage tanks.
    The EPA estimated the emission reductions and costs
associated with implementing those requirements of
Regulatory Alternatives 1 and 2 that are more stringent than
the MACT floor.  For Regulatory Alternative 2, the EPA
estimated 86 Mg/yr of emission reduction at a cost of
$38,000.  These estimates, however,  do not reflect the cost
of the more stringent storage vessel requirements in
Regulatory Alternative 2, because the facility selected to
represent new growth would not be affected by the more
stringent requirements.  The EPA estimated the emission
reduction and costs of the more stringent storage vessel
requirement for the facility on which the storage vessel
MACT floor was based.  For this facility, the more stringent
storage vessels requirements would reduce emissions by 0.75
Mg/yr and a cost of $4,650/yr.   Considering these impacts,

                            8-82

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as well as non-air environmental and energy impacts, the EPA



judged that the level of control under Regulatory



Alternative 2 was reasonable.  Therefore, the Administrator



selected Regulatory Alternative 2 as the proposed standard



for new ABS facilities using a continuous mass process.



     ABS, Batch Emulsion Process



     As noted earlier, the EPA identified four facilities in



the U.S. at which ABS is produced using a batch emulsion



process.  The information on controls at all four facilities



was used to identify the best level of control (i.e., MACT



floor) for each type of emission point.   Based on the



analysis for determining the relationship between the MACT



floor and the HON, the EPA determined that the HON was



equivalent to the MACT floor for storage vessels, wastewater



and process vents, and the HON was more stringent than the



MACT floor for equipment leaks.



     The first regulatory alternative (Regulatory



Alternative 1) considered for new ABS facilities using a



batch emulsion process was the HON for storage vessels,



equipment leaks, process vents and wastewater.  For storage



vessels, process vents,  and wastewater,  Regulatory



Alternative 1 is equivalent to the MACT floor; thus no



emission reductions or costs beyond those required to



achieve the MACT floor level of control would be incurred.



For equipment leaks,  the HON requirements are more stringent



than the MACT floor,  and emission reductions and costs





                            8-83

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beyond those required to achieve the MACT floor level of



control would be incurred.  The EPA estimated the emission



reductions  (15 Mg/yr) and costs ($14,000/yr) associated with



implementing the HON equipment leak requirements.



Considering these impacts, as well as non-air environmental



and energy impacts, the EPA judged that this level of



control was reasonable.  Therefore, the EPA selected



Regulatory Alternative 1 as the proposed standard for new



ABS facilities using a batch emulsion process.



     ABS. Batch Suspension Process



     As noted earlier, the EPA identified two facilities in



the U.S. at which ABS is produced using a batch suspension



process.  The information on controls at both facilities was



used to identify the best level of control  (i.e., MACT



floor) for each type of emission point.  Based on the



analysis for determining the relationship between the MACT



floor and the HON, the EPA determined that the HON was



equivalent to the MACT floor for storage vessels,



wastewater, and process vents, and the HON was more



stringent than the MACT floor for equipment leaks.



     The first regulatory alternative (Regulatory



Alternative 1) considered for new ABS facilities using a



batch suspension process was the HON for storage vessels,



equipment leaks, process vents, and wastewater.  For storage



vessels, process vents, and wastewater, Regulatory



Alternative 1 is equivalent to the MACT floor; thus no





                            8-84

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emission reductions or costs beyond those required to



achieve the MACT floor level of control would be incurred.



For equipment leaks, the HON requirements are more stringent



than  the MACT floor, and emission reductions and costs



beyond those required to achieve the MACT floor level of



control would be incurred.  The EPA estimated the emission



reductions of 5 Mg/yr and a cost savings of $500/yr



associated with implementing the HON equipment leak



requirements.  Considering these impacts, as well as non-air



environmental and energy impacts, the EPA judged that this



level of control was reasonable.  Therefore, the EPA



selected Regulatory Alternative 1 as the proposed standard



for new ABS facilities using a batch suspension process.



     ABS, Latex Process



     As noted earlier, the EPA identified one facility in



the U.S. at which ABS is produced using a latex process.



The information on controls at this facility was used to



identify the best level of control (i.e., MACT floor) for



each type of emission point.  Based on the analysis for



determining the relationship between the MACT floor and the



HON, the EPA determined that the HON was equivalent to the



MACT floor for storage vessels, process vents,  and



wastewater, and the HON was more stringent than the MACT



floor for equipment leaks.



     The first regulatory alternative (Regulatory



Alternative 1)  considered for new ABS latex facilities was





                            8-85

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the HON for storage vessels, process vents, equipment leaks,



and wastewater.  For storage vessels, process vents, and



wastewater, Regulatory Alternative 1 is equivalent to the



MACT floor; thus no emission reductions or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For equipment leaks, the HON



requirements are more stringent than the MACT floor, and



emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions and costs



associated with implementing the HON equipment leak



requirements for any new facilities based on existing



facilities.  Considering these impacts, as well as non-air



environmental and energy impacts, the EPA judged that this



level of control was reasonable.  Therefore, the EPA



selected Regulatory Alternative 1 as the proposed standard



for new ABS latex facilities.



     MABS Process



     The EPA identified one facility in the U.S. at which



MABS is produced.  The information on controls at this



facility was used to identify the best levels of control



(i.e., MACT floor) for each type of emission point.  Based



on the analysis for determining the relationship between the



MACT floor and the HON, the EPA determined that the HON was



equivalent to the MACT floor for storage vessels, process
                            8-86

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vents, and wastewater, and more stringent than the MACT



floor  for equipment leaks.



     The first regulatory alternative  (Regulatory



Alternative 1) considered for new MABS facilities consisted



of applying the HON to all types of emission points.  For



storage vessels, process vents, and wastewater, Regulatory



Alternative 1 is equivalent to the MACT floor; thus, no



emission reductions or costs beyond those required to



achieve the MACT floor level of control would be incurred.



For equipment leaks, the HON requirements are more stringent



than the MACT floor, and emission reductions and costs



beyond those required to achieve the MACT floor level of



control would be incurred.  The EPA estimated the emission



reductions and costs associated with implementing the HON



equipment leak requirements for any new facilities based on



existing facilities.  These impacts are based on



confidential information and cannot be presented.



Considering these impacts, as well as non-air environmental



and energy impacts, the EPA judged that this level of



control was reasonable.  Therefore, the EPA selected



Regulatory Alternative 1 as the proposed standard for new



MABS facilities.



     MBS Process



     The EPA identified three facilities in the U.S. at



which MBS is produced.  The information on controls at all



three facilities was used to identify the best levels of





                            8-87

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control  (i.e., MACT floor)  for each type of emission point.



Based on the analysis for determining the relationship



between the MACT floor and the HON, the EPA determined that



the HON was equivalent to the MACT floor for storage



vessels, process vents,  equipment leaks, and wastewater.



     The first regulatory alternative (Regulatory



Alternative 1) considered for new MBS facilities consisted



of applying the HON to all types of emission points.  For



all types of emission points, Regulatory Alternative 1 is



equivalent to the MACT floor; thus, no emission reductions



or costs beyond those required to achieve the MACT floor



level of control would be incurred.  Therefore, the EPA



selected Regulatory Alternative 1 as the proposed standard



for new MBS facilities.



     SAN. Continuous Process



     As noted earlier, the EPA identified three facilities



in the U.S. at which SAN is produced using a continuous



process.  The information on controls at all three



facilities was used to identify the best level of control



(i.e., MACT floor)  for each type of emission point.  Based



on the analysis for determining the relationship between the



MACT floor and the HON,  the EPA determined that the HON was



less stringent than the MACT floor for storage vessels, the



HON was equivalent to the MACT floor for process vents and



wastewater, and the HON was more stringent than the MACT



floor for equipment leaks.





                            8-88

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     Since the HON was less stringent than the MACT floor



for storage vessels, the EPA defined the MACT floor.  Three



options were considered for defining the MACT floor:



 (1) define vapor pressure and storage vessel capacity



combinations;  (2) define chemical type and storage vessel



capacity combinations; and  (3) Option 2 supplemented by



Option 1 for chemicals not specified under Option 2.  Based



on this analysis  (see Docket A-92-45, Category II-B), the



EPA determined that the best option for defining the MACT



floor was to use vapor pressure and storage vessel size



combinations.



     The first regulatory alternative (Regulatory



Alternative 1) considered for new SAN facilities using a



continuous process was the MACT floor for storage vessels



and the HON for process vents, equipment leaks, and



wastewater.  For storage vessels,  process vents, and



wastewater, Regulatory Alternative 1 is equivalent to the



MACT floor; thus no emission reductions or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For equipment leaks, the HON



requirements are more stringent than the MACT floor, and



emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions (25 Mg/yr) and



costs ($38,000/yr) associated with implementing the HON



equipment leak requirements.  Considering these impacts, as





                            8-89

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well as non-air environmental and energy impacts, the EPA



judged that this level of control was reasonable.



Therefore, the EPA selected Regulatory Alternative 1 as the



proposed standard for new SAN facilities using a continuous



process.



     SAN. Batch Processes



     The EPA identified two existing facilities in the U.S.



at which SAN is produced using a batch process.  The



information on controls at both facilities was used to



identify the best level of control (i.e., MACT floor) for



each type of emission point.  Based on the analysis for



determining the relationship between the MACT floor and the



HON, the EPA determined that the HON was equivalent to the



MACT floor for storage vessels and wastewater, that the HON



was less stringent than the MACT floor for process vents,



and that the HON was more stringent than the MACT floor for



equipment leaks.



     Since the HON and Batch Processes ACT were less



stringent than the MACT floor for process vents, the EPA



defined the MACT floor.  The EPA considered an emission



factor and a percent reduction for defining the MACT floor.



Based on its analysis  (see Docket A-92-45, Category II-B),



the EPA determined that percent reduction was the best



option for defining the MACT floor.



     The first regulatory alternative (Regulatory



Alternative 1) considered for new SAN facilities using a





                            8-90

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batch process consisted of applying the HON to storage



vessels, equipment leaks, and wastewater, and the MACT floor



to process vents.  For storage vessels, process vents, and



wastewater, Regulatory Alternative 1 is equivalent to the



MACT floor; thus, no emission reductions or costs beyond



those required to achieve the MACT floor level of control



would be incurred.  For equipment leaks, the HON



requirements are more stringent than the MACT floor, and



emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



The EPA estimated the emission reductions (6.4 Mg/yr) and



costs ($l,300/yr) associated with implementing the HON



equipment leak requirements.  Considering these impacts, as



well as non-air environmental and energy impacts, the EPA



judged that this level of control was reasonable.



Therefore, the Administrator selected Regulatory Alternative



1 as the proposed standard for new SAN facilities using a



batch process.



     ASA/AMSAN Facilities



     As noted earlier,  only one facility in the U.S. was



identified as producing ASA/AMSAN resins.  Since there is



only one facility,  the MACT floor for new facilities is the



same as for existing facilities,  and the relationship of the



current level of control to the HON was found to be the same



as that for ASA/AMSAN existing facilities.   For these
                            8-91

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reasons, the EPA is proposing the same standards for new



ASA/AMSAN facilities as for existing ASA/AMSAN facilities.



     Polystyrene. Continuous Processes



     As noted earlier, the EPA identified 22 facilities in



the U.S. at which polystyrene is produced using a continuous



process.  The information on controls at all 22 facilities



was used to identify the best level of control (i.e., MACT



floor) for each type of emission point.  Based on the



analysis for determining the relationship between the MACT



floor, the HON,  and the Polymers NSPS, the EPA determined



that the HON was equivalent to the MACT floor for



wastewater, that the HON and Polymers NSPS were equivalent



to the MACT floor for process vents, that the HON was more



stringent than the MACT floor for equipment leaks and that



the HON was less stringent than the MACT floor for storage



vessels.



     The first regulatory alternative  (Regulatory



Alternative 1) considered for new polystyrene facilities



using a continuous process consisted of applying the MACT



floor to storage vessels,  applying the HON to process vents



from process sections other than the material recovery



section, equipment leaks,  and wastewater, and applying the .



Polymers NSPS to process vents from the material recovery



section.  For storage vessels, wastewater, and process



vents, Regulatory Alternative 1 is equivalent to the MACT



floor; thus no emission reductions or costs beyond those





                            8-92

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required to achieve the MACT floor level of control would be



incurred.  For equipment leaks, the HON requirements are



more stringent than the MACT floor, and emission reductions



and costs beyond those required to achieve the MACT floor



level of control would be incurred.  The EPA estimated the



emission reductions  (212 Mg/yr) and costs  ($85,600/yr)



associated with implementing the HON requirements for



equipment leaks.  Considering these impacts, as well as non-



air environmental and energy impacts, the EPA judged that



this level of control was reasonable.  Therefore, the EPA



selected Regulatory Alternative 1 as the proposed standard



for new polystyrene facilities using a continuous process.



     Polystyrene, Batch Processes



     The EPA identified 11 existing facilities in the U.S.



at which polystyrene is produced using a batch process.  The



information on controls at these 11 facilities was used to



identify the best level of control (i.e., MACT floor)  for



each type of emission point.  Based on the analysis for



determining the relationship between the MACT floor and the



HON, the EPA determined that the HON was equivalent to the



MACT floor for storage vessels and wastewater, and that the



HON was more stringent than the MACT floor for process vents



and equipment leaks.



     The first regulatory alternative (Regulatory



Alternative 1)  considered for new polystyrene facilities



using a batch process consisted of applying the HON to





                            8-93

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storage vessels, equipment leaks, process vents, and



wastewater.  For storage vessels and wastewater, Regulatory



Alternative 1 is equivalent to the MACT floor; thus, no



emission reductions or costs beyond those required to



achieve the MACT floor level of control would be incurred.



For process vents and equipment leaks,  the HON requirements,



are more stringent than the MACT floor, and emission



reductions and costs beyond those required to achieve the



MACT floor level of control would be incurred.  The EPA



estimated the emission reductions and costs associated with



implementing the HON equipment leak and process vent



requirements for any new facilities based on existing



facilities.  Considering these impacts, as well as non-air



environmental and energy impacts, the EPA judged that this



level of control was reasonable.  Therefore, the



Administrator selected Regulatory Alternative I as the



proposed standard for new polystyrene facilities using a



batch process.



     Expandable Polystyrene Processes



     The EPA identified 7 existing facilities in the U.S. at



which expandable polystyrene is produced.  The information



on controls at these 7 facilities was used to identify the



best level of control (i.e., MACT floor)  for each type of



emission point.  Based on the analysis for determining the



relationship between the MACT floor and the HON, the EPA



determined that the HON was equivalent to the MACT floor for





                            8-94

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storage vessels, process vents, and wastewater, and that the



HON was more stringent than the MACT floor for equipment



leaks.



     The first regulatory alternative (Regulatory



Alternative 1) considered for new expandable polystyrene



facilities consisted of applying the HON to storage vessels,



equipment leaks, process vents, and wastewater.  For storage



vessels, process vents, and wastewater,  Regulatory



Alternative 1 is equivalent to the MACT floor; thus, no



emission reductions or costs beyond those required to



achieve the MACT floor level of control would be incurred.



For equipment leaks, the HON requirements are more stringent



than the MACT floor, and emission reductions and costs



beyond those required to achieve the MACT floor level of



control would be incurred.  The EPA estimated the emission



reductions and costs associated with implementing the HON



equipment leak requirements for any new facility based on



existing facilities.  Considering these impacts, as well as



non-air environmental and energy impacts,  the EPA judged



that this level of control was reasonable.   Therefore,  the



Administrator selected Regulatory Alternative 1 as the



proposed standard for new expandable polystyrene facilities.



     PET - TPA.  Continuous Processes



     As noted earlier,  12 facilities in the U.S. were



identified at which PET is being produced using a continuous



TPA process.   The information on controls at all 12





                            8-95

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facilities was used to determine the best levels of controls
(i.e., MACT floor) for each type of emission point.  Based
on the analysis for determining the relationship between the
MACT floor, the HON, and Polymers NSPS the EPA determined
that the HON was equivalent to the MACT floor for storage
vessels, and wastewater, that the HON and Polymers NSPS were
equivalent to the MACT floor for process vents, and that the
HON was more stringent than the MACT floor for equipment
leaks.  In addition, it was determined that the best
controlled facility did not have a process contact cooling
tower and used ethylene glycol jets in its vacuum system.
Therefore, these emission reduction design aspects of a
continuous TPA facility were determined to be part of the
MACT floor for this subcategory.
     The first regulatory alternative (Regulatory
Alternative 1) considered for new PET facilities using a
continuous TPA process consisted of applying 1) the HON to
storage vessels, equipment leaks, and wastewater, 2) the HON
and Polymers NSPS to process vents, and 3) prohibiting the
use of cooling tower water in the contact condensers in the
vacuum system.  For all emission points other than equipment
leaks, Regulatory Alternative 1 is equivalent to the MACT
floor; thus, no emission reductions or costs beyond those
required to achieve the MACT floor level of control would be
incurred under Regulatory Alternative 1.  For equipment
leaks, the HON requirements are more stringent than the MACT

                            8-96

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floor, and emission reductions and costs beyond those



required to achieve the MACT floor level of control would be



incurred.



     The EPA estimated the emission reductions (473 Mg/yr)



and costs  ($744,000/yr) associated with implementing the HON



equipment leaks requirements.  Considering these impacts, as



well as non-air environmental and energy impacts, the EPA



judged that this level of control was reasonable.



Therefore, the EPA selected Regulatory Alternative 1 as the



proposed standard for new PET facilities using the



continuous TPA process.



     PET - TPA. Batch Processes



     Only one facility in the U.S. has been identified as



producing PET using a batch TPA process.  The information on



the controls used at this facility was used to determine the



best levels of control (i.e., MACT floor)  for storage



vessels, process vents, equipment leaks, and wastewater.



However, for process contact cooling towers,  the EPA



determined that it was appropriate to look to similar



sources outside the subcategory for determining the best



level of control.   As presented previously for continuous



TPA processes,  the best level of control is represented by



no process contact cooling tower and the use of ethylene



glycol jets in the vacuum system.  The EPA believes that



this level of control represents the MACT floor for



facilities using a batch TPA process.





                            8-97

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     Based on the analysis for determining the relationship



between the MACT floor and the HON, the EPA determined that



the HON was equivalent to the MACT floor for storage



vessels, process vents, and wastewater, and the HON is more



stringent than the MACT floor for equipment leaks.  Further,



the EPA judged that prohibiting the use of cooling tower



water in the contact condensers in the vacuum system is



equivalent to the MACT floor.



     The first regulatory alternative  (Regulatory



Alternative 1) considered for the new PET facilities using a



batch TPA process consisted of applying the HON to storage



vessels, equipment leaks, process vents, and wastewater, and



prohibiting the use of cooling tower water in the contact



condensers in the vacuum system.  For all emission points



other than equipment leaks,  Regulatory Alternative 1 is



equivalent to the MACT floor; thus no emission reductions or



costs beyond those required to achieve the MACT floor



control level would be incurred.  For equipment leaks, the



HON requirements are more stringent than the MACT floor, and



emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



     The EPA estimated the emission reductions (5.6 Mg/yr)



and costs ($17,700/yr)  associated with implementing the HON



equipment leak requirements.  Considering these impacts, as



well as non-air environmental and energy impacts, the EPA



judged that this level of control was reasonable.





                            8-98

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Therefore, the EPA selected Regulatory Alternative 1 as the



proposed standard for new PET facilities using a batch TPA



process.



     PET - DMT. Continuous Processes



     The EPA identified 10 facilities in the U.S. at which



PET is produced using a DMT continuous process.  The



information on controls at all 10 facilities was used to



determine the best level of control  (i.e., MACT floor) for



each emission source type.  Based on the analysis for



determining the relationship between the MACT floor, the



HON, and Polymers NSPS, the EPA determined that the HON was



equivalent to the MACT floor for storage vessels and



wastewater, the HON and Polymers NSPS were equivalent to the



MACT floor for process vents, and the HON was more stringent



than the MACT floor for equipment leaks.  In addition, it



was determined that the best controlled facility did not



have a process contact cooling tower and used ethylene



glycol jets in its vacuum system.  Therefore, these emission



reduction design aspects of a continuous DMT facility were



determined to be part of the MACT floor for this



subcategory.



     The first regulatory alternative (Regulatory



Alternative 1)  considered for new PET facilities using a



continuous DMT process consisted of applying 1) the HON to



storage vessels,  equipment leaks, and wastewater, 2) the HON



and Polymers NSPS to process vents,  and 3) prohibiting the





                            8-99

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use of cooling tower water in the contact condensers in the
vacuum system.  For all emission points other than equipment
leaks, Regulatory Alternative 1 is equivalent to the MACT
floor; thus no emission reductions or costs beyond those
required to achieve the MACT floor control level would be
incurred.  For equipment leaks, the HON requirements are
more stringent than the MACT floor, and emission reductions
and costs beyond those required to achieve the MACT floor
level of control would be incurred.
     The EPA estimated the emission reductions (903 Mg/yr)
and costs  ($988,000/yr) associated with implementing the HON
equipment leak requirements.  Considering these impacts, as
well as non-air environmental and energy impacts, the EPA
judged that this level of control was reasonable.
Therefore, the EPA selected Regulatory Alternative 1 as the
proposed standard for new PET facilities using a continuous
DMT process.
     PET - DMT. Batch Processes
     As noted earlier, the EPA identified 10 facilities in
the U.S. at which PET is produced using a DMT batch process.
The information on controls at all 10 facilities was used to
determine the best levels of controls (i.e., MACT floor) for
each type of emission point.  Based on the analysis for
determining the relationship between the MACT floor and the
HON, the EPA determined that the HON was equivalent to the
MACT floor for storage vessels, process vents, and

                            8-100

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wastewater, and the HON was more stringent than the MACT



floor for equipment leaks.  In addition, it was determined



that the best controlled facility did not have a process



contact cooling tower.  Therefore, the EPA has defined the



MACT floor for new batch DMT facilities as "no process



contact cooling towers".



     As for batch TPA facilities, the EPA determined that it



was appropriate to look to similar sources outside the



subcategory for determining the best level of control for



the control of emissions from the vacuum system generated



wastewater.  As presented previously for continuous TPA



processes, the best level of control is represented by no



process contact cooling tower and the use of ethylene glycol



jets in the vacuum system.  As discussed above, "no process



contact cooling towers" was determined to be part of the



MACT floor for new facilities using a batch DMT process.



The EPA believes that the use of ethylene glycol jets also



represents the MACT floor for new facilities using a batch



DMT process.



     The first regulatory alternative (Regulatory



Alternative 1) considered for new PET facilities using a



batch DMT process consisted of applying the HON to storage



vessels, equipment leaks,  process vents and wastewater,  and



prohibiting the use of cooling tower water in the contact



condensers in the vacuum system.   For all emission points



other than equipment leaks,  Regulatory Alternative 1 is





                           8-101

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equivalent to the MACT floor; thus, no emission reductions



or costs beyond those required to achieve the MACT floor



level of control would be incurred.  For equipment leaks,



the HON requirements are more stringent than the MACT floor,



and emission reductions and costs beyond those required to



achieve the MACT floor level of control would be incurred.



     The EPA estimated the emission reductions (408 Mg/yr)



and costs ($569,000/yr) associated with implementing the HON



equipment leak requirements.  Considering these impacts, as



well as non-air environmental and energy impacts,  the EPA



judged that this level of control was reasonable.



Therefore, the EPA selected Regulatory Alternative 1 as the



proposed standard for new PET facilities using a batch DMT



process.



     Nitrile Resin Process



     As noted earlier, only one facility in the U.S. was



identified as producing nitrile resins.  Since there is only



one facility, the MACT floor for new facilities is the same



as for existing facilities,  and the relationship of the



current level of control to the HON was found to be the same



as that for ASA/AMSAN existing nitrile resin facilities.



For these reasons, the EPA is proposing the same standards



for new nitrile resin facilities as for existing nitrile



resin facilities.
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8.4  RATIONALE FOR THE SELECTION OF THE FORMAT OF THE



     PROPOSED STANDARDS



     The proposed standards adopt the formats found in the



HON, the Batch Processes ACT, and Polymers NSPS.  The



Federal Register notice for the HON (57 FR 62608;



December 31, 1992) provides the rationale for the selection



of the specific formats used in the final rule for the HON.



The Batch Processes ACT document discusses the selection of



formats presented by the ACT.  The Federal Register notice



for the Polymers NSPS (57 FR 36678, September 30, 1987)



provides the rationale for the selection of the formats



associated with the process vent limits.  The EPA finds no



reason for changing those formats and, therefore, has



adopted the same formats for this rule as have been



promulgated for the HON and Polymers NSPS and as were



presented in the Batch Processes ACT.



     In addition to adopting various portions of existing



standards,  the proposed rule also contains standards for



controlling process contact cooling tower emissions at PET



facilities by prohibiting the use of cooling tower water in



contact condensers in the vacuum system and requiring any



vacuum system generated wastewater to be controlled,



regardless of its organic HAP content  or flowrate,  provided



the organic HAP present in the stream are specified on



Table 9 of the HON wastewater provisions.  In some cases/



the standards are a more stringent version of the HON,  yet





                           8-103

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the format of the standard remains the same as the HON
format.  In other cases,  a format found in the HON (i.e.,
percent reduction) is used with a slight variation.  All of
these situations are discussed in the following paragraphs.
     As has been discussed, the best controlled PET
facilities for process contact cooling towers are those that
an ethylene glycol jet vacuum system, which eliminates the
process contact cooling tower and other vacuum system
generated wastewater emissions.  Since there are no known
demonstrated techniques for eliminating organic HAP
emissions from process contact cooling towers, the only
format possible was a work practice/design standard.   Rather
than dictating the use of a specific type of vacuum system
(i.e., the use of ethylene glycol jets), the EPA is
proposing to (1) prohibit the use of cooling tower water in
contact condensers in the vacuum system and (2) since some
vacuum systems still may generate some wastewater, require
all vacuum system generated wastewater be controlled,
regardless of its organic HAP content or flowrate provided
the organic HAP present in the stream are specified on
Table 9 of the HON wastewater provisions.
     For the following types of emission points for the
indicated subcategories,  a more stringent version of the HON
is being proposed as the standard:   (1)  storage vessels at
existing and new ASA/AMSAN facilities, new SAN facilities
using a continuous process, new ABS facilities using a

                            8-104

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continuous mass process, existing and new nitrile resin



facilities, and existing and new polystyrene facilities and



 (2) process vents at existing MBS facilities, existing and



new ASA/AMSAN facilities, and new SAN facilities using a



batch process.  For most of these situations, the EPA finds



no reason for changing the HON formats and, therefore, have



adopted the HON formats for this rule.  The following



paragraphs discuss those situations where alternative



formats have been adopted for storage tanks and process



vents.



     For storage vessels at existing and new ASA/AMSAN



facilities and some storage vessels at new SAN continuous



facilities, the format of the standard is a percent



reduction.  In both cases, the choice of format was greatly



influenced by the uniqueness of the facilities in the



subcategory.  There is only one identified facility



producing ASA/AMSAN and the basis of the standard for new



SAN continuous facilities is the one "best controlled"



facility.  In each case, the available data for the facility



considered led the EPA to select a percent reduction format.



Other format options (e.g.,  design and equipment standards)



would not have accurately represented the level of control



being achieved at these facilities.



     For process vents at existing and new ASA/AMSAN



facilities,  the uniqueness of the subcategory greatly



influences the format of the proposed standard.  Only one





                            8-105

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facility in the U.S. that produces ASA/AMSAN was identified



and, based on the available data, every process vent is



controlled through combustion.  The most appropriate formats



for representing the performance capabilities of combustion



units is percent reduction or concentration (parts per



million).  These formats were therefore selected for the



proposed standards, which require these process vents to be



reduced by at least 98 percent or to 20 ppmv,  whichever is



less stringent.



     For process vents at new SAN batch facilities, a



percent reduction format was selected.  Three other options



that were considered were identifying specific process vents



to be controlled, a "TRE-like" approach, or an emission



factor.  Because of the possibility of different process



vent configurations between facilities and different



emission characteristics for process vents with the same



name (e.g., dryer vent), a format that identified specific



process vents for control was not accepted.  Because stream



characteristics of batch process vents are difficult to



describe and stream characteristic data were not available,



a "TRE-like" approach could not be used.  Finally, because



the MACT floor for new sources is based on a single facility



(i.e.,  the best controlled facility), use of an emission



factor would reveal confidential production data.  After



these considerations,  the EPA found a percent reduction



format to be the most widely applicable.





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8.5  RATIONALE FOR THE SELECTION OF COMPLIANCE AND



     PERFORMANCE TEST PROVISIONS AND MONITORING REQUIREMENTS



     For the most part, the level of control required by the



proposed rule are the same as those in the HON or Polymers



NSPS.  Further, the control devices likely to be used in



complying with the proposed requirements for batch process



vents were already considered as part of the HON.  As a



result, the EPA has determined that there is no need to



change performance testing provisions or the parameters



selected for monitoring.  Since the rationale for the



selected provisions has been presented in detail in the



proposal and promulgation preambles to the HON, it is not



repeated here in the same depth.  The paragraphs below



briefly discuss the rationale for the selected provisions



for each type of emission point.  Later in this section, the



rationales for the use of parameter monitoring and the



overall compliance certification provisions are presented.



8.5.1  Continuous Process Vents



     The proposed rule specifies the group determination



procedures,  performance tests,  monitoring requirements,  and



test methods necessary to determine whether a process vent



from a continuous unit operation is required to be



controlled and to demonstrate that the allowed emission



levels are achieved when controls are applied.   The



following paragraphs discuss each of these.
                           8-107

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8.5.1.1  Group determination procedures



     Except as discussed in the next paragraph,  the proposed



rule requires each owner or operator to determine for each



continuous process vent whether the vent is a Group 1 or



Group 2 process vent.  There are three group determination



procedures:  (1) process vent flowrate measurement,



(2) process vent organic HAP concentration measurement, and



(3) TRE index value determination.  A detailed discussion of



the rationale for these three procedures is found on pages



62636-62637 of Federal Register Vol. 57, No. 252,



December 31, 1992.



     An owner or operator may chose to comply directly with



the requirement to reduce organic HAP emissions by



98 weight-percent or to an outlet concentration of 20 ppmv



through use of a control device.



     Finally, for continuous process vents at some



subcategories (e.g., ASA/AMSAN), a Group I/Group 2



determination is not required.



8.5.1.2  Performance test



     Initial performance tests are required for all control



devices other than flares and certain boilers and process



heaters.  Specifically, testing would be required for:



(1) incinerators, (2) scrubbers used with combustion devices



to control halogenated vent streams, and (3) some boilers



and process heaters smaller than 44 megawatts (MW)



[150 million British thermal units  (Btu/hr)].  Performance





                            8-108

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tests are being required because they (1) ensure that a
control device achieves the required control level and  (2)
serve as the basis for establishing operating parameter
levels required for monitoring.
     Because their percent reduction and outlet
concentration cannot feasibly be measured, flares are not
required to be tested and instead must meet the requirements
in Section 63.11 for operating conditions.
8.5.1.3  Test methods
     The proposed process vent provisions would require the
use of approved test methods to ensure consistent and
verifiable results for group determination procedures,
initial performance tests, and compliance demonstrations.
8.5.1.4  Monitoring
     Control devices used to comply with the proposed rule
need to be maintained and operated properly if the required
level of control is to be achieved on a continuing basis.
Monitoring of the control device operating parameters can be
used to ensure that such proper operation and maintenance
are occurring.
     The proposed standard lists the parameters that can be
monitored for the common types of combustion devices:
firebox temperature for thermal incinerators;  temperature
upstream and downstream of the catalyst bed for catalytic
incinerators; firebox temperature for boilers and process
heaters/ and presence of a flame at the pilot light for

                           8-109

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flares.  These parameters were selected because they are
good indicators of combustion device performance,  and
instruments are readily available at a reasonable cost to
continuously monitor these parameters.  The proposed rule
also allows the owner or operator to request to monitor
other parameters on a site-specific basis.   The proposed
rule also specifies monitoring requirements for scrubbers
installed to remove halogens and hydrogen halides from the
combustor outlet.
     The proposed standard would require the owner or
operator to establish site-specific parameter levels through
the Notification of Compliance Status report and operating
permit.  Site-specific parameter levels accommodate site-
specific differences in control design and process vent
stream characteristics.
     For Group 2 continuous process vents that have TRE
index values greater than 1.0 but less than or equal to 4.0
(greater than 3.7 but less than 6.7 for continuous process
vents at existing MBS facilities),  monitoring of the final
recovery device would be required to ensure that it
continues to be operated as it was during the group
determination test when the initial TRE index value was
calculated.  Improper recovery device operation and
maintenance could lead to increased organic HAP
concentration, potentially reducing the TRE index value
below l.O, and causing the vent to become a Group 1 process

                            8-110

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vent.  Continuous monitoring will ensure continued good



performance of recovery devices.  The TRE index value



monitoring level of 4.0 is being proposed because the



variability of the process parameters established during



normal operating conditions are unlikely to vary to the



extent that a TRE value above 4.0 would be reduced to a TRE



level less than 1.0 and thus require control.



     The proposed rule specifies the parameters that can be



monitored for the three common types of recovery devices:



1) exit temperature of the absorbing liquid and exit



specific gravity for absorbers; 2) exit temperature for



condensers; and 3) total regeneration stream mass flow



during carbon bed regeneration cycle and temperature of the



carbon bed after regeneration for carbon adsorbers.  These



parameters were selected because they are good indicators of



recovery device performance, and instruments are readily



available at a reasonable cost to continuously monitor these



process parameters.  The proposed rule also allows the owner



or operator to request to monitor parameters on a site-



specific basis.  The owner or operator would establish a



site-specific level for the parameters through the



Notification of Compliance Status report and operating



permit.



8.5.2  Batch Process Vents



     As for continuous process vents,  some batch process



vents are more cost effective to control than others.





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Therefore, cost effectiveness is related to the procedures
that are being proposed for the group determination for
batch process vents.  These procedures are taken from the
Batch Processes Alternative Control Technologies (ACT)
document.  The Batch Processes ACT describes applicability
criteria  (i.e., annual emissions and annual average
flowrate) for distinguishing between batch process vents
that are cost effective to control and those that are not.
The rationale for these applicability criteria and
procedures is presented in depth in the Batch Processes ACT
document.
     For the same reasons the proposed rule requires a
performance test and continuous monitoring of a control
device for a continuous process vent, performance tests and
continuous monitoring are required for the control or
recovery device used by an affected source to comply with
the batch process vents control requirement.  Also, the
monitoring parameters selected for recovery devices were
presented and discussed as part of the continuous process
vent provisions and in the preamble to the proposed
subpart G.
     Because compliance with the batch process vent
standards is determined on an annual basis, the EPA
established the batch cycle limitation for Group 2 batch
process vents in an attempt to minimize the number of Group
2 batch process vents that would become non-compliant.  The

                            8-112

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purpose of the batch cycle limitation, and quarterly
reporting of the number of batch cycles accomplished, is to
ensure that a Group 2 batch process vent does not become a
Group 1 batch process vent simply due to accomplishing more
batch cycles in a year than were anticipated at the time the
initial group determination was made.  As mentioned earlier,
an affected source may set the batch cycle limitation at any
level it desires as long as the batch process vent remains a
Group 2 batch process vent.  Since this may prove too
"restrictive" for an owner or operator, the proposed rule
allows an owner or operator to declare any batch process
vent Group 1 and control as required by the proposed rule.
     Like continuous process vents, owners or operators are
not required to make a Group 1/Group 2 determination for all
batch process vents.  The proposed standards for process
vents, continuous and batch, at new SAN batch facilities
require an 84 percent emission reduction in overall process
vent emissions.  The proposed standards do not require a
Group I/Group 2 determination.
8.5.3  Storage Vessels
     The proposed storage vessel provisions require control
by tank improvements or a closed vent system and control
device;  however,  the choice of control technologies is
limited depending on the material stored.   For vessels
storing liquids with vapor pressures less  than
76.6 kilopascals (kPa),  either control option may be

                            8-113

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selected.  However, for vessels storing liquids with vapor



pressures greater than or equal to 76.6 kPa,  tank



improvements do not achieve the expected level of emission



reductions.  As a result, Group 1 storage vessels containing



liquids with a maximum true vapor pressure of organic HAP



greater than or equal to 76.6 kPa must be controlled with a



closed vent system and control device.



8.5.4  Wastewater



     Two important parameters must be quantified initially,



and whenever process changes are made, to determine whether



a process wastewater stream is a Group 1 or Group 2 stream.



These parameters are the annual wastewater quantity for a



stream and the volatile organic HAP (VOHAP) concentration in



the stream.  The VOHAP concentration can be quantified as a



flow-weighted annual average for total VOHAP or for



individually-speciated organic HAP.  Several methods are



allowed by the proposed rule for determining both of these



parameters.



     Initial performance tests for control of Group 1



wastewater streams are not required by the proposed rule.



For treatment processes and control devices,  facilities have



the choice of using either performance tests or engineering



calculations to demonstrate the compliance of those units



with the standards.  Engineering calculations, supported by



the appropriate documentation, have been allowed to provide



a less costly alternative to that of actual testing.





                            8-114

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     A performance test is not specified for the design



steam stripper.  Installation of the specified equipment,



along with monitoring to show attainment of the specified



operating parameter levels, demonstrates compliance with the



equipment design and operation provisions.  Thus, a



performance test is not necessary.



     The proposed process wastewater provisions include



requirements for periodic monitoring and inspections to



ensure proper operation and maintenance of the control



system and continued compliance.



8.5.5   Equipment Leaks



     The proposed rule retains the use of Method 21 to



detect leaks of organic compounds from equipment; however,



several modifications were made to the existing procedures.



These modifications consist of changes to the calibration



gases required, addition of procedures for response factor



correction,  and addition of procedures for pressure testing



of batch processes.   The bases for the changes to the



provisions are presented in the preamble to the proposed



subpart H.



8.5.6  Heat  Exchange Systems



     Periodic monitoring for leaks is required to



demonstrate  compliance for this type of emission point.  The



frequency of periodic monitoring becomes less frequent as



data show that leaks are not present.  This monitoring
                           8-115

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system is proposed to minimize the burden on the affected



source.



8.5.7  Process Contact Cooling Towers



     Since the proposed rule prohibits the use of cooling



tower water in contact condensers associated with vacuum



systems, there are no continual monitoring or compliance



activities.  Instead, owners or operators must initially



state that they will comply with the rule in their



Implementation Plan and Notification of Compliance Status.



8.6  RATIONALE FOR THE SELECTION OF PARAMETER MONITORING AND



     COMPLIANCE CERTIFICATION PROVISIONS



     The proposed rule requires monitoring of control and



recovery device operating parameters and reporting of



periods when parameter values are above maximum or below



minimum established levels.   Under the NSPS and NESHAP



programs, parameter monitoring has traditionally been used



as a. tool in determining whether control devices are being



maintained and operated properly.  However,



Section 114(a)(3) of the Act and Section 70.6(c) of the



operating permit rule (57 FR 32251) require the submission



of "compliance certifications" from sources subject to the



operating permit program.  Section 114(a)(3) of the amended



Act requires enhanced monitoring and compliance



certifications of all major stationary sources.  The annual



compliance certifications certify whether compliance has



been continuous or intermittent.  Enhanced monitoring shall





                            8-116

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be capable of detecting deviations from each applicable



emission limitation or standard with sufficient



representativeness, accuracy, precision, reliability,



frequency, and timeliness to determine if compliance is



continuous during a reporting period.  The monitoring in



this regulation satisfies the requirements of enhanced



monitoring.



     In light of these requirements, the EPA has considered



how sources subject to this rule would demonstrate



compliance.  The EPA has concluded that operating parameter



monitoring can be used for this purpose.



     For the proposed rule, the EPA is requiring affected



sources to establish site-specific parameter levels.



Although in previous NSPS and NESHAP, the EPA has specified



a pre-determined range of operating parameter values, such



values could be considered inadequate given the increased



importance of parameter monitoring in determining and



certifying compliance due to the new requirements in



Section 114 of the Act.  Allowing site-specific levels for



monitored parameters accommodates site-specific variation in



emission point characteristics and control device designs.



The proposed procedure for establishing operating parameter



levels for continuous and batch process vents is based on



performance tests.



     The proposed rule requires the affected source to



record daily average values for continuously monitored





                           8-117

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parameters.  The daily average is the average of all of the



15-minute values generated by the continuous recorder during



the operating day.  If the daily average value is outside



the established range, it must be reported.  The daily



averaging period was selected because the purpose of



monitoring data is to ensure proper operation and



maintenance of the control device.  Because it often takes



from 12 to 24 hours to correct a problem, this averaging



period was considered to best reflect operation and



maintenance practices.  This averaging period therefore



gives the owner or operator a reasonable period of time to



take action.  If a shorter averaging period (for example



3 hours) was selected, affected sources would be likely to



have multiple excursions caused by the same operational



problem because it would not be possible to correct problems



in one 3-hour reporting period.



     In the proposed rule, as in subpart G, at least 75



percent of monitoring data is required to constitute a valid



day's worth of data.  For example, for continuous process



vents an affected source needs to have valid monitoring data



for at least 75 percent of the operating hours in a given



operating day to have a valid day's worth of monitoring



data.



     Whereas the HON allows excused excursions to reflect



the uncertainty of parameter monitoring, the proposed rule



does not allow excused excursions.  Excused excursions are





                            8-118

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not  included in the proposed rule because most continuous



monitoring system problems can be dealt with in the context



of the  start-up, shutdown, and malfunction plan required



under subpart A.



8.7  RATIONALE FOR THE SELECTION OF RECORDKEEPING AND



     REPORTING REQUIREMENTS



     The general recordkeeping and reporting requirements of



this subpart are very similar to those found in subpart G of



part 63.  The proposed rule also relies on the provisions of



subpart A of part 63.  A table included in the proposed rule



designates which sections of subpart A apply to the proposed



rule.



     The proposed rule would require affected sources to



submit the following six types of reports:



     1.   Initial  Notification,



     2.   Implementation  Plan (if  an  operating  permit



          application  has not been submitted or,  for new



          sources,  an  application  for approval  of



          construction or reconstruction),



     3 .   Emissions Averaging Plan,



     4.   Notification of Compliance  Status,



     5.   Periodic  Reports, and



     6 .   Other  reports.



The purpose and contents of each of these reports are



described in this section.  The wording of the proposed rule



requires all draft reports to be submitted to the





                           8-119

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"Administrator".   The term Administrator means either the
Administrator of the EPA, an EPA regional office, a State
agency, or other authority that has been delegated the
authority to implement this rule.  In most cases, reports
will be sent to State agencies.  Addresses are provided in
subpart A of part 63.
     Records of reported information and other information
necessary to document compliance with the regulation are
generally required to be kept for 5 years.  A few records
pertaining to equipment design would be kept for the life of
the equipment.
8.7.1  Initial Notification
     The proposed rule would require owners or operators who
are subject to the proposed rule to submit an Initial
Notification.  This report will establish an early dialog
between the affected source and the regulatory agency,
allowing both to plan for compliance activities.  The
notification is due 120 days after the date of promulgation
for existing sources.   For new sources, it is due 180 days
before commencement of construction or reconstruction, or
45 days after promulgation, whichever is later.
     The notification must list the thermoplastic processes
at the source that are subject to the proposed rule, and
which provisions  may apply (e.g., continuous process vents,
batch process vents, etc.).  A detailed identification of
emission points is not required.  The Initial Notification

                           8-120

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must  include a statement of whether the affected source  can



achieve compliance by the specified compliance date.



8.7.2  Implementation Plan



      The  Implementation Plan details how the affected source



plans to  comply.  Implementation Plans are only required for



affected  sources that have not submitted an operating permit



application or application for approval of construction  or



reconstruction.  An operating permit application would



contain all the types of information required in the



Implementation Plan, so it would be redundant to require



affected  sources to submit both.



     Existing sources must submit the Implementation Plan



12 months prior to the compliance date.  For new sources,



Implementation Plans would be submitted with the



Notification of Compliance Status.  It is critical that



regulatory authorities have the Implementation Plans well



before the compliance date so they can plan their



implementation and enforcement activities.  The early



submission of these plans may also benefit regulated sources



by allowing them to receive any feedback on their control



plans prior to the actual compliance dates.



8.7.3  Emissions Averaging Plan



     The Emissions Averaging Plan is required 18 months



prior to the compliance date to allow time for review and



approval of the average.   Because of the complexities and



site-specific nature of emissions averaging,  an approval





                           8-121

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process is necessary to assure that compliance through
averaging would not result in greater hazard or risk than
compliance without averaging and that the specific averaging
plan will result in emissions credits outweighing debits.
The Emissions Averaging Plans must be more detailed and
thorough than an Implementation Plan.  The additional
information is necessary for the reviewing authority to make
an informed decision about approving the average.  The
projected credits and debits included in the Emissions
Averaging Plan may be based on calculations, design
analyses, or engineering assessments instead of measured
values.  This flexibility is provided because, in many
cases, control measures will not have been implemented at
the time the plan is due and actual measurements would not
be possible.
8.7.4  Notification of Compliance Status
     The Notification of Compliance Status would be
submitted 150 days after the affected source's compliance
date.  It contains the information necessary to demonstrate
that compliance has been achieved, such as the results of
performance tests, TRE determinations,  and design analyses.
     Affected sources with a large number of emission points
are likely to be submitting results of multiple performance
tests for each kind of emission point.   For each test method
used for a particular kind of emission point  (e.g., a
process vent),  one complete test report would be submitted.

                            8-122

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For additional tests performed for the same kind of emission



point using the same method, the results would be submitted,



but a complete test report is not required.  Results would



include values needed to determine compliance  (e.g., inlet



and outlet concentrations, flowrates, percent reduction) as



well as the values of monitored parameters averaged over the



period of the test.  The submission of one test report will



allow the regulatory authority to verify that the affected



source has followed the correct sampling and analytical



procedures and has done calculations correctly.  Complete



test reports for other emission points may be kept at the



plant rather than submitted.  This reporting system was



established to ensure that reviewing authorities have



sufficient information to evaluate the monitoring and



testing used to demonstrate compliance while minimizing the



reporting burden.



     Another type of information to be included in the



Notification of Compliance Status is the specific level for



each monitored parameter for each emission point, and the



rationale for why this level indicates proper operation of



the control device.  (If this level has already been



established in the operating permit,  it does not need to be



repeated in the Notification of Compliance Status).   As an



example,  for a process vent controlled by an incinerator,



the notification would include the site-specific minimum



firebox temperature that will ensure proper operation of the





                            8-123

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incinerator, and the data and rationale to support this



minimum temperature.



     For emission points included in an emissions average,



the notification would also include the measured or



calculated values of all parameters needed to calculate



emission credits and debits, and the result of the



calculation for the first quarter.  This information is



needed to ensure that the points in the average are being



controlled as described in the Emissions Averaging Plan and



that the average itself is balancing as planned.



8.7.5  Periodic Reports



     Periodic Reports are required to ensure that the



standards continue to be met and that control devices are



operated and maintained properly.  Generally, Periodic



Reports would be submitted semiannually, however, quarterly



reports must be submitted in some instances.



     Periodic Reports specify periods when the values of



monitored parameters are above the maximum or below the



minimum established level specified in the Notification of



Compliance Status or operating permit.  For continuously



monitored parameters, records must be kept of the parameter



value recorded once every 15 minutes.  If a parameter is



monitored more frequently than once every 15 minutes, the



15-minute averages may be kept instead of the individual



values.  This requirement ensures that there will be enough



monitoring values recorded to be representative of the





                            8-124

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monitoring period without requiring the affected source to



retain additional data on file and readily accessible.



     For some types of emission points and controls,



periodic (e.g., monthly, quarterly, or annual) inspections



or measurements are required instead of continuous



monitoring.  Records that such inspections or measurements



were done must be kept; but results are included in Periodic



Reports only if a problem is found.  This requirement is



designed to minimize the recordkeeping and reporting burden



of the proposed rule.



     For emission points included in an emissions average,



the results of the quarterly credit and debit calculation



are also included in the Periodic Reports, so the reviewing



authority can ensure that the quarterly requirements for the



average have been met.



8.7.6  Other Reports



     There are a very limited number of other reports.



Where possible, the proposed rule is structured to allow



information to be reported in the semiannual  (or quarterly)



Periodic Reports.  However,  in a few cases, it is necessary



for the affected source to provide information to the



regulatory authority shortly before or after a specific



event.   For example,  if a process change is made that causes



a continuous or batch process vent to change from Group 2 to



Group 1,  the affected source must report the change within



90 days.   For storage vessels,  notification prior to





                            8-125

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internal tank inspections is required to allow the
regulatory authority to have an observer present.  For
storage and wastewater, if an owner or operator requests an
extension of the repair period or a delay of repair, the
request needs to be submitted separately from the Periodic
Reports because the requests require a quick response from
the reviewing authority.  Certain notifications and reports
required by subpart A of part 63 must also be submitted.
8.7.7  Possible Alternative Recordkeepina Requirements
     The proposed rule requires affected sources to keep
readily accessible records of monitored parameters.  For
those control devices that must be monitored continuously,
records which include at least one monitored value for every
15 minutes of operation are considered sufficient.  These
monitoring records must be maintained for 5 years.  However,
there are some existing monitoring systems that might not
satisfy these requirements.  To comply with the proposed
rule, affected sources have the flexibility to request
approval for the use of alternative recordkeeping systems
under the proposed rule or under provisions of subpart A of
part 63 .
8.8  OPERATING PERMIT PROGRAM
     Under Title V of the 1990 Amendments, facilities
subject to this rule will be required to obtain an operating
permit.
                            8-126

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     Oftentimes, emission limits, monitoring, and reporting



and recordkeeping requirements are scattered among numerous



provisions of State implementation plans (SIP's) or Federal



regulations.  As discussed in the proposed rule for the



operating permit program published on May 10, 1991 (58 FR



21712), this new permit program would include in a single



document all of the requirements that pertain to a single



source.  Once a State's permit program has been approved,



each facility containing a source within that State must



apply for and obtain an operating permit.  If the State



wherein the source is located does not have an approved



operating permit program,  the owner or operator of a source



must submit the application under the General Provisions of



40 CFR part 63.
                           8-127

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                       9.0   REFERENCES

1.   Harper, Charles A. Handbook of Plastics. Elastomers.
     and Composites. McGraw-Hill, Inc., New York, 1992,
     p.10.5.

2.   Protocol for Equipment Leak Emission Estimates.  EPA-
     453-/R-93-026.  Environmental Protection Agency,
     Research Triangle Park, NC.  June 1993.
                            9-1

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                                   TECHNICAL REPORT DATA
                            ff lease read Instrucnom on tfie rtvtrte btforr completingl
1. REPORT NO.
  EPA-453/l-95-004a
                              2.
             3. RECIPIENT'S ACCESSION NO.
*. TITLE AND SUBTITLE
 Hazardous Air  Pollutant Emissions  from Process Units in
 the Thermoplastics Manufacturing Industry—
 Basis and Purpose Document for Proposed Standards
             S, REPORT DATE
              March 1995
             8. PERFORMING ORGANIZATION CODE
?. AUTHORISE
                                                             I. PERFORMING ORGANIZATION R6PQRT NO
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
 U.S.  Environmental Protection Agency
 Office of Air Quality Planning and  Standards
 Research Triaagle  Park,  ISC  27711
             ia. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.

               68D10116
12. SPONSORING AGENCY NAME ANO ADDRESS
  Director
  Office of Air Quality  Planning and  Standards
  Office of Air and  Radiation
  U.S.  Environmental Protection Agency
  Research Triangle  Park.  NC  27711	
             13. TYPE OP REPORT ANO PERIOD COVERED
             14. SPONSORING AGENCY CODE


               EPA/200/04
IS. SUPPLEMENTARY NOTES
16. ABSTRACT
  This  document provides  the background  information and rationale for the  decisions
  made  in the (proposed)  standards setting process for the  thermoplastics
  manufacturing industry.   The affected  industry is described,  the baseline  organic
  HAP emissions are presented as are the predicted impacts  associated with the
  selected regulatory alternatives.  The rational for the alternatives and the
  selected proposed standard is given.
 7.
                                KEY WORDS ANO DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIiflS/OPEN ENOED TERMS
                           c, COSATi Field. Croup
 Air Pollution
 Pollution Control
 Hazardous Air Pollutants
Air  Pollution Control
Thermoplastic polymer
manufacturing industry
18. DISTRIBUTION STATEMENT

  Release Unlimited
19. SECURITY CLASS i Tlits Repam
  Unclassified
                                                                          21. NO. Of 'AGES
211
                                               20. SECURITY CLASS tThtspuget
                                                 Unclassified
                                                                          22. PRICE
EPA f«t«> 2220-1 (R»». 4-?
                              EO«T»ON it o«soi-CTe

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