Basis and Purpose Document
PESTICIDE ACTIVE INGREDIENT
PRODUCTION NESHAP
Emission Standards Division
U. S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
July 1997
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BASIS AND PURPOSE DOCUMENT
PESTICIDE ACTIVE INGREDIENT PRODUCTION NESHAP
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TABLE OF CONTENTS
Pace
1.0 PURPOSE OF DOCUMENT ... . 1-1
2.0 INTRODUCTION . 2-1
3.0 DESCRIPTION OF THE PESTICIDE ACTIVE INGREDIENT
PRODUCTION INDUSTRY 3-1
3.1 PESTICIDE MANUFACTURING INDUSTRY 3-1
3.1.1 Source Category . . . 3-1
3.1.2 Definition of Pesticide 3-3
3.1.3 Registered Pesticides 3-3
3.1.4 Information Collection 3-5
3.1.5 Number of Major Source Pesticide
Active Ingredient Manufacturers 3-5
3.1.6 Location of Pesticide Active
Ingredient Manufacturers . . 3-7
3.1.7 Production Level and Usage of
Pesticide Active Ingredients . . 3-7
3.1.8 Growth Projections for Pesticide
Active Ingredient Industry 3-10
3.1.9 Typical facility . 3-10
3.2 PROCESS DESCRIPTION 3-12
3.2.1 Overview of Pesticide Active
Ingredient Processes ... 3-13
3.2.2 Generic process description 3-13
3.2.3 Batch versus Continuous Flow 3-16
3.2.4 HAP Emissions . 3-17
3.3 REFERENCES FOR CHAPTER 3 3-25
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
4.1.1 Source Categories 4-1
4.1.2 Addition of Other Pesticide Active
Ingredients 4-2
4.1.3 Change of the Source Category Name 4-2
4.^ RATIONALE FOR SUBCATEGORIZATION 4-3
4.2.1 Single Source Category . . 4-3
4.3 RATIONALE FOR EMISSIONS AVERAGING 4-4
5.0 BASELINE EMISSIONS 5-1
5.1 PROCESS VENTS . 5-2
5.2 EQUIPMENT LEAKS 5-4
5.3 STORAGE TANKS . . . 5-5
5.4 WASTEWATER SYSTEMS 5-7
5.5 BAG DUMP AND PRODUCT DRYERS 5-9
5.6 REFERENCES FOR CHAPTER 5 5-10
iii
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TABLE OF CONTENTS (continued)
Page
6.0 MACT FLOORS AND REGULATORY ALTERNATIVES 6-1
6.1 CLEAN AIR ACT REQUIREMENTS 6-1
6.2 EXISTING SOURCE MACT FLOOR AND REGULATORY
ALTERNATIVES 6-2
6.2.1 Overview of Approach . . 6-2
6.2.2 Process Vents . 6-6
6.2.3 Storage Tanks . . . 6-11
6.2.4 Wastewater Systems 6-13
6.2.5 Equipment Leaks 6-15
6.2.6 Bag Dumps and Product Dryers 6-16
6.3 NEW SOURCE MACT FLOOR . . . . 6-16
6.3.1 Process Vents 6-16
6.3.2 Storage Tanks . . 6-18
6.3.3 Wastewater Systems 6-18
6.3.4 Equipment Leaks 6-20
6.3.5 Bag Dumps and Product Dryers 6-21
6.4 REFERENCES FOR CHAPTER 6 6-21
7.0 SUMMARY OF ENVIRONMENTAL, ENERGY, COST, AND
ECONOMIC IMPACTS . . . 7-1
7.1 BASIS FOR IMPACTS ANALYSIS 7-1
7.2 PRIMARY AIR IMPACTS 7-2
7.3 SECONDARY ENVIRONMENTAL IMPACTS 7-2
7.3.1 Secondary Air Impacts 7-3
7.3.2 Secondary Water Impacts 7-4
7.3.3 Secondary Solid Waste Impacts 7-5
/.4 ENERGY IMPACTS . 7-5
7.4.1 Electricity 7-5
7.4.2 Fuel . . 7-7
7.5 COST IMPACTS .... 7-7
7.6 REFERENCES FOR CHAPTER 7 7-9
8.0 SELECTION OF THE STANDARDS 8-1
8.1 SUMMARY OF THE PROPOSED STANDARDS . 8-1
8.1.1 Relationship to Other Rules 8-3
8.1.2 Regulated Emission Points . 8-3
8.1.3 Pollutants to be Regulated 8-3
8.1.4 Proposed Standards 8-3
8.1.5 Alternative Pollution Prevention
Standard 8-13
8.2 RATIONALE FOR THE SELECTION OF THE PROPOSED
STANDARDS 8-13
8.2.1 Existing Sources . . 8-14
8.2.2 New Sources 8-15
8.2.3 Pollution Prevention Alternative 8-17
8.3 SELECTION OF THE FORMAT OF THE PROPOSED
STANDARDS 8-17
iv
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TABLE OF CONTENTS (continued)
Page
8.4 RATIONALE FOR THE SELECTION OF COMPLIANCE AND
PERFORMANCE TESTING PROVISIONS AND MONITORING
REQUIREMENTS 8-20
8.4.1 Testing and Monitoring 8-20
8.4.2 Selection of Test Methods and Criteria
for Performance Testing 8-23
8.4.3 Consideration of Control Devices in
Monitoring and Performance Test
Requirements . 8-24
8.4.4 Averaging Times 8-29
8.5 SELECTION OF REPORTING AND RECORDKEEPING
REQUIREMENTS .... 8-31
8.6 OPERATING PERMIT PROGRAM 8-31
8.7 REFERENCE FOR CHAPTER 8 8-31
v
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LIST OF FIGURES
Figure j-i.
Figure 3-2.
Figure 3-3.
Figure 8-1.
Figure »-2.
Figure 8-3.
Figure 8-4.
Figure 8-5.
Generic process flow diagram
Wastewater flow schematic for an indirect
discharge facility
Wastewater flow schematic for a direct
discharge facility
General applicability
Storage tank standards
Process vent standards
Wastewater standards
Initial compliance determination--process
vents
Figure 8-6. Monitoring provisions—process vents
Page
3-14
3-22
3-24
8-6
8-7
8-8
8-9
8-21
8-30
VI
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TABLE 3-1.
TABLE 3-2.
TABLE 3-3.
TABLE 3-4.
TABLE 3-5.
TABLE 3-6.
TABLE 3-7.
TABLE 3-8.
TABLE 3-».
TABLE 3-10.
TABLE 3-11.
TABLE 5-1.
TABLE 5-2.
TABLE 5-3.
TABLE 5-4.
TABLE 5-5.
TABLE 5-6.
LIST OF TABLES
SIC CODES FOR PAI SOURCE CATEGORY
PESTICIDE CATEGORIES
ACTIVE INGREDIENT LIST [IN DEVELOPMENT]
HAP COMPOUNDS THAT ARE PESTICIDE ACTIVE
INGREDIENTS
SUBSET OF MAJOR SOURCES INCLUDED IN THE
PESTICIDE ACTIVE INGREDIENT MANUFACTURING
INDUSTRY
U.S. PESTICIDE ACTIVE INGREDIENT
PRODUCTION BY CATEGORY
U.S. PESTICIDE ACTIVE INGREDIENT
USAGE BY INDUSTRIAL SECTOR
1993 USAGE OF PESTICIDES FOR AGRICULTURAL
CROPS
PERCENTAGE OF FACILITIES BY NUMBER OF ACTIVE
INGREDIENTS PRODUCED .
PERCENT OF FACILITIES BY QUANTITY OF ACTIVE
INGREDIENT PRODUCTION
EMISSION STREAM DATA FOR PROCESS VENTS
SUMMARY OF UNCONTROLLED AND BASELINE
EMISSIONS
UNCONTROLLED AND BASELINE HAP EMISSIONS AND
EMISSION REDUCTIONS FROM PROCESS VENTS AT
SURVEYED PLANTS
UNCONTROLLED AND BASELINE EMISSIONS FROM
MODEL PROCESS VENTS
UNCONTROLLED AND BASELINE EMISSIONS FROM
MODEL EQUIPMENT LEAKS
UNCONTROLLED AND BASELINE HAP EMISSIONS AND
EMISSION REDUCTIONS FROM STORAGE TANKS AT
SURVEYED PLANTS .
UNCONTROLLED AND BASELINE HAP EMISSIONS
AND EMISSION REDUCTIONS FROM MODEL STORAGE
TANKS
Page
3-2
3-3
J-«
3-8
3-9
3-9
3-11
3-12
3-12
j-17
3-19
5-1
5-4
5-5
5-6
5-7
VI l
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LIST OF TABLES (continued)
TABLE 5-7.
TABLE 5-8.
TABLE 6-1.
TABLE 6-2.
TABLE 6-J.
TABLE 6-4.
TABLE 6-5.
TABLE 7-1.
TABLE 7-2.
TABLE 7-3.
TABLE /-4.
TABLE 8-1.
TABLE 8-2.
ANNUAL HAP LOADINGS AND UNCONTROLLED AND
BASELINE HAP EMISSIONS FROM WASTEWATER
STREAMS AT SURVEYED PLANTS
UNCONTROLLED AND BASELINE HAP EMISSIONS AND
EMISSION REDUCTIONS FROM BAG DUMPS AND
PRODUCT DRYERS AT SURVEYED PLANTS
OVERALL CONTROL EFFICIENCY OF HAP EMISSIONS
FROM PAI PLANTS
SUMMARY OF PROCESS VENT EMISSIONS
STORAGE TANK CHARACTERISTICS AT MACT FLOOR
PLANTS
CONTROL EFFICIENCIES FOR EQUIPMENT LEAKS
AT MACT FLOOR PLANTS
CONTROL EFFICIENCIES FOR WASTEWATER SYSTEMS
AT MACT FLOOR PLANTS
SUMMARY OF PRIMARY AIR IMPACTS
SUMMARY OF SECONDARY AIR IMPACTS
SUMMARY OF ENERGY IMPACTS
SUMMARY OF TOTAL CAPITAL INVESTMENT AND TOTAL
ANNUAL COST IMPACTS
PROPOSED STANDARDS FOR EXISTING SOURCES
PROPOSED STANDARDS FOR NEW SOURCES
5-8
5-10
6-4
6-7
6-12
6-14
6-15
/-2
7-4
7-6
8-4
8-5
Vlll
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1.0 PURPOSE OF DOCUMENT
The Basis and Purpose Document provides background
information on, and the rationale for, decisions made by the
u. S. Environmental Protection Agency (EPA) related to the
proposed standards for the reduction of hazardous air pollutants
(HAP) emitted through the manufacture of pesticide active
ingredients covered by the source category. This document is
intended to supplement the preamble for the proposed standards.
This document is separated into eight 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. Chapters 4, 6, and 8 provide rationale for
regulatory decisions; Chapter 4 provides rationale for the
selection of source categories, subcategorization, and emissions
averaging; Chapter 6 presents rationale for determination of MACT
"floors" and development of regulatory alternatives, and
Chapter 8 provides rationale for the selection of the proposed
standards.
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.
1-1
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2.0 INTRODUCTION
Section 112 of the Clean Air 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's 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's. A major source is defined in
section 112(a) as any stationary source or group of stationary
sources located within a. contiguous area under common control
that emits, or has the potential to emit, in 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's. This list
of source categories was published in the Federal Register on
July 16, 1992 (57 FR 31576), and includes the following 10 source
categories in the Agricultural Chemicals Production industry
group:
1. 2,4-D Salts and Esters Production;
2. 4-Chloro-2-Methylphenoxyacetic Acid Production;
3. 4,6-Dinitro-o-Cresol Production;
4. Captafol Production;
5. Captan Production;
6. Chloroneb Production;
7. Chlorothalonil Production;
8. Dacthal™ Production;
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9. Sodium Pentachlorophenate Production; and
10. Tordon™ Acid Production.
A notice of revisions to the initial list of categories was
published in the Federal Register on June 4, 1996 (61 FR 28197)
that moved the Butadiene furfural cotrimer (R-ll) from the
•Polymers and Resins Production" industry group to the
"Agricultural Chemicals Production" industry group.
All of the products in these 11 source categories are
pesticide active ingredients (PAI's) that are used in the
production of insecticide, herbicide, or fungicide pesticide
products. Because of similarities in the production processes
and HAP emissions, the proposed regulation adds production of all
PAI's that are used in insecticide, herbicide, or fungicide
products to the source category list.
2-2
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3.0 DESCRIPTION OF THE PESTICIDE ACTIVE INGREDIENT
PRODUCTION INDUSTRY
This chapter discusses the source categories in the
pesticide active ingredient (PAD production industry group.
Section 3.1 provides a discussion of the PAI production industry.
Section 3.2 presents the process description and identifies
sources of hazardous air pollutants (HAP) emissions. Section 3.3
contains references for this section.
3.1 PESTICIDE MANUFACTURING INDUSTRY
3.1.1 Source Category
The PAI manufacturing source categories include those
facilities with process operations that (1) manufacture PAI's,
including intermediates; and (2) use, produce, or emit one of the
189 HAP listed in the 1990 Clean Air Act Amendments. A process
that manufactures a. compound for both nonpesticidal and
pesticidal uses is covered by these proposed regulations unless
the process is covered by an existing regulation, such as the
Hazardous Organic NESHAP (40 CFR part 63, subparts r, G, H, and
I) .
Facilities in the PAI production source categories are
included in a variety of Standard Industrial Classification (SIC)
codes. Many facilities have more than one SIC code because they
produce multiple types of products. Facilities manufacturing
PAI's and intermediates may be included in SIC groups 2831, 2833,
2834, 2842, 2843, 2861, 2865, 2869, 2879, and 2899.1 Table 3-1
identifies the industry titles for each of these groups. Other
types of manufacturing performed at these facilities are not
included in the PAI production source categories.
3-1
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TABLE 3-1. SIC CODES FOR PAI SOURCE CATEGORY
SIC code
2831*
2833
2834
2842
2843
2861
286S
2869
2879
2899
Industry title
...
Medicinal chemicals and botanical products
Pharmaceutical preparations
Specialty cleaning, polishing, and sanitation preparations
Surface active agents, finishing agents, sulfonated oils, and assistants
Gum and wood chemicals
Cyclic organic crudes and intermediates, and organic dyes and
pigments
Industrial organic chemicals, NEC
Pesticides and agricultural chemicals. NEC
Chemicals and chemical preparations. NEC
*SIC code 2831 was listed in the SIC Manual as "Biological products" until 1987; following 1987, SIC
code 2831 was changed to 2836, Biological products, except diagnostics. Note: NEC = not elsewhere
classified.
Active ingredients that (1) are regulated under the
Hazardous Organic NESHAP; (2) are only produced outside the
United States; and (3) require no HAP to be used, produced, or
emitted during manufacturing are excluded from the PAI production
source categories.
The source categories include intermediate manufacturing
only when the intermediate is manufactured at the same source
(i.e., onsite) as the active ingredients. Facilities that
manufacture only pesticide intermediates on site but do not
manufacture active ingredients are not included in the source
categories.2
Pesticide formulation (i.e., pesticide end-use products) and
production of fertilizers are specifically excluded from the
source categories. The HAP used in and emissions from pesticide
formulation processes are low relative to the PAI's manufacturing
processes. Because fertilizer production is included as a
separate source category on the source category list, fertilizer
products were omitted from the PAI production source categories.
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3.1.2 Definition of Pesticide
A pesticide, as defined by the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA), includes "any substance
or mixture of substances intended for preventing, destroying,
repelling, or mitigating any pest, and any substance or mixture
of substances intended for use as a plant regulator, defoliant,
or desiccant." A pesticide is used for treating insects,
rodents, nematodes, fungi, weeds, or any other forms of life
declared to be pests.* Pesticides are categorized into several
types, as shown in Table 3-2.5 Under FIFRA, a pesticide must be
formally registered with the EPA prior to its being sold or
distributed in the United States.
TABLE 3-2. PESTICIDE CATEGORIES5
Category
Insecticides
Herbicides
Fungicide
Rodenticide
Antimicrobial
Biocides
Acarictdes Miucide
Insect repellent Molluscicide
Insect growth Ovicide
regulator Piscicide
Larvicide
Microbial
insecticide
Algaecide
Plant growth regulator
Nematicide
Wood preservative
Bird repellent
Repellent
Bactencide
Microbicide
Nitrification inhibitor
Soil microbicide
—
3.1.3 Registered Pesticides
In 1988, 45,000 pesticide end-use products were registered
with EPA. Each formulation, or pesticide end-use product, has a
distinct registration.7 By 1994, the number of registered end-
use products was down to approximately 20,000 to 25,000. In
1988, there were approximately 600 active ingredient groups, or
"cases," that represented 1,150 PAI's. These PAI are used to
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formulate registered pesticide end-use products. A case or group
consists of related PAI compounds, e.g., a compound and specific
related salts and esters.6 By 1994, there were only 400 active
ingredient cases.6 (The number of PAI's is not known for 1994.)
Pesticide active ingredients are scheduled to be
reregistered by the Special Review and Reregistration Division,
Office of Pesticide Programs (SRRD/OPP). The EPA is required to
reregister existing PAI's that originally were registered when
the standards for government approval were less stringent than
they are today. The SRRD/OPP publishes an annual report (Rainbow
Report) that lists the current registration status of PAI's. In
the 1994 Rainbow Report, approximately 43 of the 189 HAP
compounds are identified as PAI's.8 Table 3-3 lists the PAI HAP
compounds.
TABLE 3-3.
HAP COMPOUNDS THAT ARE PESTICIDE
ACTIVE INGREDIENTS
Acrolein
Biphenyl
Bis(2-Ethy(hexyl)phthalate (DEHP))
Calcium cyanamide
Chloramben
Chlorine
Chlorobenzilaie
Cresol
Cresylic acid
Captan
Carbaryl
Chlordane
2-4-D, salts & esters
DDE
Dibutyl phthalate
1,4-Dichlorobenzene
Dimethyl phthalate
4,6-Dinitro-o-cresol. and salts
2.4-Dinitrophenol
1,3-DichJoropropene
Dichlorvos
Ethylene glycol
Formaldehyde
Heptachlor
Lindane
Methoxyclor
Methyl bromide
Methyl chloroform
MEK
Methylene chloride
Napthalene
4-NitrophenoI
Parathion
Pentachlorophenol
Phenol
Phosphorus
Propoxor
Propylene oxide
Tetrachloroethylene
2,4.5-Trichlorophenol
Toxaphene
Trifluralin
Xylenes
3-4
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3.1.4 Information Collection
Background information on the PAI production industry was
obtained from two sources: the 1986 effluent guidelines study on
PAI manufacturing that was conducted by the Office of Water (OH)
and the 1995 Section 114 information collection request conducted
by the Office of Air Quality Planning and Standards (OAQPS).
Some differences between the two studies exist; the OW study
focused on a large portion of the industry, and the Section 114
information collection request focused on a subset of facilities.
The 1986 OW study for developing effluent guidelines for PAI
manufacturing surveyed all facilities that were manufacturing
specific PAI's in 1984-1985. This study identified
75 facilities.^ Characteristics about the PAI production
industry based on this study are more likely to represent the
industry as a whole.
From the 1995 Section 114 information collection request for
the PAI production industry, OAQPS collected information from
nine companies on HAP emissions from the manufacture of PAI's and
intermediates. The Section 114 survey focused on sources that
(1) are major sources, (2) manufacture a variety of PAI's,
(3) use a variety of production processes, and (4) implement air
pollution control technology. Based on this survey,
20 facilities were identified that produce one or more PAI's
covered under the PAI production industry.10 All of these
facilities are believed to be major sources based on HAP
emissions generated by PAI manufacturing operations, or because
the PAI manufacturing operations are collocated with other
production processes at a facility whose entire plant site is a
major source. Characterizations made about the PAI production
industry that are based on the Section 114 responses are not
intended to represent the entire industry because they are based
on a subset of the industry.
3.1.5 Number of Major Source Pesticide Active Ingredient
Manufacturers
The number of major source PAI manufacturers in the PAI
production industry was based on two lists of facilities: the
3-5
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EPA's Section Seven Tracking System (SSTS) list and the list from
the 1986 OW study. In evaluating the impacts of the proposed
rule, the number of major source PAI manufacturers must be
determined. This section describes the procedures used to make
this determination.
Information about the production of pesticide products is
tracked by the EPA in a database called the SSTS. The EPA
requires all producers of pesticide products (technical grade and
formulated product) to report annually the amount of pesticides
produced at that facility. The data base identifies the name and
location of each producer and lists the name and amount of each
pesticide product the facility made in a particular year. The
SSTS data base identified 316 facilities in 1991.n
A list of facilities compiled in the 1986 OW study for
developing effluent guidelines for PAI manufacturing was also
used to identify facilities. In this study, the OW identified
75 facilities, which in 1986 comprised the total number of
sources generating wastewater from the production of select
active ingredients. Eleven of these facilities were not on the
SSTS list, so ct total of 327 facilities were identified as
possible producers of PAI from the SSTS and OW lists.11
Both the SSTS list and the OW list have shortcomings or
deficiencies in identifying facilities included in the PAI
production industry. The SSTS data base reported formulated end-
use products as active ingredients, and it also included research
facilities in the category of active ingredient manufacturers.
The OW list only addresses manufacturers of a selected group of
active ingredients. Therefore, State agencies were contacted to
confirm (1) which facilities are PAI's manufacturers, and
(2) which facilities are major sources for HAP with respect to
potential to emit.
Facilities that meet both criteria were confirmed for
12 States. During these efforts to confirm the number of
affected sources for each State, two additional facilities were
identified for a total of 329 facilities. The results of the
confirmation efforts indicate that 33 of the 140 facilities in
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these 12 States, or approximately 24 percent, are major source
active ingredient manufacturers. The nationwide number of
affected facilities (i.e., the number of major source active
ingredient manufacturers) was estimated assuming 24 percent of
329 facilities (316 facilities from the SSTS list, 11 additional
facilities from the OW list, and 2 facilities identified by State
contacts) are confirmed major source manufacturers; therefore, a
total of 78 sources are included in the PAI production
industry.^ The 33 major source PAI manufacturing facilities
identified during the State contacts along with those identified
in the Section 114 responses are listed in Table 3-4.
3.1.6 Location of Pesticide Active Ingredient Manufacturers
According to the 1986 OW study, PAI manufacturing facilities
are located in 29 States.12 The SSTS identifies 39 States with
PAI manufacturers. Based on the responses to the Section 114
information collection request and on the efforts to contact
States, at least 17 States contain major source PAI
manufacturers; these States are shown in Table 3-4. Based on the
1986 OW study, the majority of PAI manufacturing facilities are
located in the eastern half of the United States, with a large
concentration in the southeast and Gulf Coast States.
Approximately 50 percent of all pesticide production occurs in
these areas. 2
3.1.7 Production Level and Usage of Pesticide Active Ingredients
Table 3-5 lists the total production of different categories
of PAI in 1984 and 1994. Pesticide active ingredient production
in the United States increased from 1.07 billion pounds in 1984
to the 1994 figure of 1.32 billion pounds at an approximate
increase of 2 percent annually.1^
Table 3-6 provides the amount of PAI used in the
agricultural, industrial/commercial/government, and home/garden
sectors in 1983 and 1993. Pesticide active ingredient usage in
the agricultural sector accounts for approximately 75 percent of
the total u.S. usage; usage in the industrial/commercial/
government and home/garden sectors accounts for 18 and 7 percent,
respectively.14
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TABLE 3-4. SUBSET OF MAJOR SOURCES INCLUDED IN THE PESTICIDE
ACTIVE INGREDIENT MANUFACTURING INDUSTRY
Company mine
CibaGdgy
Du Pont
Zeneca Inc.
ArkiDtts Eastman
Division
Ethyl Corporation
Great Lakes Chemical
Corp.
Dow Chemical
Zeneca Inc.
Ururoyal Chemical
Monsanto Co.
Abbott Labs
Lonza Inc.
Monsanto Co.
Morton International
Riverdale Chemical Co.
Vulcan Chemicals
Elf Atochem N.A.. Inc.
Ciba Geigy
Ururoyal
FMC Corp. Ag. Chem.
Group
. j n. •
Anderson Development
Company
Dow Chemical
Elf Atochem N.A.. Inc.
City
Mclntosh
Axis
Bucks
Magness
Magnolia
El Dorado
Pittsbuig
Richmond
Naugatuck
Muscatine
North Chicago
Mapleton
Sauget
Ringwood
Chicago Heights
Wichita
Carrollton
SLGabnel
Geismar
Baltimore
Adnan
Midland
Riverview
State
AL
AL
AL
AR
AR
AR
CA
CA
CT
IA
IL
IL
IL
JL
IL
KS
KY
LA
LA
MD
Ml
MI
MI
Company name
American Cynamid Co.
Buckman Laboratories
Inc.
Farmland Industries
FMC Corporation
Occidental Chemical
Zeneca Inc.
DuPbnt
Eastman Kodak-
Tennessee Eastman
Great Lakes Chemical
Corp.
Olin Corp.
Zeneca Inc.
Dow Chemical
Du Pont
ISK Biotech Corp.
Sandoz Agro Inc.
Schenectady International
Zeneca Inc.
Cytec Industries
DuPont
PPG Industries
Rbone-Poulenc Ag. Co.
Union Carbide
City
Hannibal
Cadet
St. Joseph
Dcsscind v.uy
Castle Hayne
Ferry
Manati
Kingsport
Newport
Charleston
Mt. Pleasant
Freeport
LaPorte
Houston
Beaumont
Freeport
Pasadena
Willow Island
Belle
New Martinsville
Institute
South Charleston
State
MO
MO
MO
NC
NC
OH
PR
TN
TN
TN
TN
TX
TX
TX
TX
TX
TX
WV
WV
WV
WV
WV
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TABLE 3-5. U.S. PESTICIDE ACTIVE INGREDIENT
PRODUCTION BY CATEGORY*'13
Category
Insecticide
Herbicide
Fungicide
TOTAL
1984
Production,
Ib x 106
211
696b
131b
1,074°
1994
Production,
Ib x 106
253
876b
158b
1,319°
?For pesticide active ingredient products.
"Does not include production intended for sale outside the
U.S., which is included in annual total.
cIncludes miscellaneous other PAI's and production intended
for sale outside the U.S., not reported by category.
TABLE 3-b.
U.S. PESTICIDE ACTIVE INGREDIENT USAGE
BY INDUSTRIAL SECTOR14
Sector
Agricultural
Indus trial /Commercial /Government
Home /Garden
TOTAL
1983
Production,
Ib x 106
733
165
65
963
1993
Production,
Ib x 106
811
197
73
1,081
3-9
-------
Pesticide active ingredient usage is recorded by the U.S.
Department of Agriculture's National Agricultural Statistics
Service for major agricultural crop categories, including field
crops (corn, cotton, potatoes, rice, soybeans, and wheat),
vegetable crops, fruit crops, and nut crops (almonds, hazelnuts,
pecans, and walnuts).15 Some of the most commonly used
pesticides for these crops include Atrazine, Metolachlor, and
Alachlor.16 Table 3-7 lists the top 25 pesticides used for U.S.
agricultural crop production and their total usage in 1993.
3.1.8 Growth Projections for Pesticide Active Ingredient
Industry
The number of new affected sources in the five years
following promulgation of the standards was estimated to be
8 sources. ' This number was based on an average increase of
2 percent per year in the amount of PAI production, and it was
assumed that the increase in production would be equivalent to
the increase in the number of sources. 3
3.1.9 Typical facility
The 1986 OW study (covers the entire industry) and the
Section 114 responses (covers 20 facilities) provided data for
analysis of a typical facility. The 1986 OW study indicated that
a typical facility manufactured one active ingredient, was the
only facility in the country producing that active ingredient,
and produced between 1 and 10 million pounds of the active
ingredient annually.1® Data from the Section 114 responses
indicate that a typical facility produces four PAI's and produces
approximately 7 million pounds of each.10 Based on the 1986 OW
study, facilities manufactured as few as one and as many as
16 PAI's.19 The Section 114 study indicated that facilities
manufacture 1 to 15 active ingredients.10 Table 3-8 shows the
percentage of facilities that manufacture a specific number of
active ingredients, based on both studies.10'20 Table 3-9
presents the percentage of facilities that produce a specific
quantity of active ingredient.10'21
3-10
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TABLE 3-7. 1993 USAGE OF PESTICIDE
ACTIVE INGREDIENTS FOR AGRICULTURAL
CROPS16
Pesticide
Atrazine
Metolachlor
Sulfur
Alachlor
Methyl -bromide
Cyanazine
Dichloropropene
2,4-D
Me tarn- sodium
Trifluralin
Petroleum Oil
Pendime thai in
Glyphosate
EPTC
Chlorpyrifos
Chlorothalonil
Propanil
Dicamba
Terbufos
Bentazone
Mancozeb
Copper Hydroxide
Parathion
Simazine
Butylate
Total usage, Ib x 106
70-75
60-75
45-50
45-50
30-35
30-35
30-35
25-30
25-30
20-25
20-25
20-25
15-20
10-15
10-15
10-15
7-12
6-10
5-8
4-7
4-7
4-7
4-7
3-6
3-6
3-11
-------
TABLE 3-8. PERCENTAGE OF FACILITIES BY NUMBER
OF ACTIVE INGREDIENTS PRODUCED
No. of active
One
Two
Three
Four
Five or more
TOTAL
Percent of facilities based
on 1986 OW study20
52
18
11
8
11
100
Percent of facilities based JKI
PAI Section 114 study10
33
10
4
10
43
100
TABLE 3-9. PERCENT OF FACILITIES BY QUANTITY OF
ACTIVE INGREDIENT PRODUCTION
Range of active
ingredient produced, Ib
>45.000.000
10,000.000-45.000.000
1.000.000-9.999.999
100.000-999.999
0-99.999
TOTAL
Percent of facilities based
on 1986 OW study21
8
21
42
20
9
100
Percent of facilities basedjm
PAI Section 1 14 study10
19
33
38
10
0
100
From the 1986 OW study, 91 percent of manufacturers produced
organic PAI's, 4.5 percent produced metallo-organic PAI's, and
jj
4.5 percent produce both organic and metallo-organic PAI's. ^
3.2 PROCESS DESCRIPTION AND SOURCES OF HAP EMISSIONS
The approximately 1,150 PAI's (400 groups of active
ingredients) are produced by a variety of processes. The
specific manufacturing process used by a facility to manufacture
a PAI depends on the type of active ingredient produced. This
section presents an overview of PAI manufacturing processes and
provides a general discussion of the varieties of PAI processes
that may be encountered and presents a generic process flow
diagram. A generic flow diagram is given because of the
proprietary nature of many PAI processes. This section also
identifies the sources of HAP emissions from PAI manufacturing
processes.
3-12
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3.2.1 Overview of Pesticide Active Ingredient Processes
There are two stages in the production process of pesticide
products: (1) manufacture of the PAX and pesticide intermediate,
and (2) formulation of the pesticide end-use product.
Active ingredients are defined as the substances that are
responsible for pesticidal effects.23 Based on data in the
Section 114 responses, PAI's and pesticide intermediates are
manufactured by chemical synthesis.10 Chemical synthesis is the
process of manufacturing pesticides using organic and inorganic
chemical reactions, often in the presence of solvents, catalysts,
and acidic or basic reagents.
The production of a PAI may include the manufacture at the
facility of one or more pesticide intermediate compounds. A
pesticide intermediate is a specific precursor compound formed in
the process of manufacturing a PAI. The intermediate may or may
not be a pesticide and is subsequently converted by further
chemical reactions to PAI (e.g., if chemical A and chemical B are
reacted to form chemical C, and chemical C is reacted further to
produce a PAI, then chemical C is a pesticide intermediate).
A pesticide end-use product is a formulated product, i.e.,
it is a mixture of an active ingredient and inert diluents.24
Inerts are substances contained in a formulation that are not
pesticidally active. ^ Formulation of pesticide end-use products
through the mixing, blending, or dilution of one or more PAI's,
without an intended chemical reaction, is distinct from PAI
manufacturing.24 Formulation processes using active ingredients
to produce pesticide end-use products are not included in the
source categories and are not included in the process discussion.
3.2.2 Generic process description
A generic process flow diagram is provided in Figure 3-1.
The process steps shown in this figure include mixing, reaction,
and separation/purification steps. Manufacturing processes for
active ingredients can be simple processes with one reactor and a
3-13
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RAW MATERIAL/
SOLVENT
STORAGE
I
RAW MATERIAL/
SOLVENT
STORAGE
WEIGH
I
RAW MATERIAL/
SOLVENT
STORAGE
WEIGH
U>
I
MIXING
I
REACTOR
(INTERMEDIATE)
PURIFICATION
RECYCLE
FINAL
PRODUCT
(INTERMEDIATE)
REACTOR
(PRODUCT)
PURIFICATION
1
WASTEWATER
RECYCLE
FINAL
„ PRODUCT
(ACTIVE
INGREDIENT)
WASTEWATER
Figure 3-1. Generic process flow diagram.
-------
single separation/purification step or can be more complicated
with multiple reactors and multiple purification steps.
Mixing may occur in a separate vessel prior to reactor
charge or within the reactor. In « separate mixing step,
reactants, catalysts, and solvents are transported from storage
tanks to the mix tank(s) and then to the reactor. In other
cases, mixing may be conducted within the reactor, especially in
semibatch reactions in which the catalysts, solvents, and one
reactant is charged first, and then another reactant is metered
in over a period of hours. Measuring of input materials can be
done manually, by piping to weigh tanks, or with flow meters. In
some instances, materials may not need to be mixed prior to the
reactor.
The reaction step may occur in one vessel, or it can be
carried out with multiple reactor vessels. For reactions in a
single vessel, inputs can include a one time charge of reactants,
catalysts, and solvents or staged additions of reactants. For
multiple reactor vessels, additional charges may be added after
transfer to the next vessel. A product from the previous reactor
is considered to be an intermediate if additional raw materials
for reaction are charged to the next reactor vessel. Prior to
charging, the reactor may be purged with nitrogen, and during the
reaction, a small purge flow may be maintained to prevent the
buildup of oxygen in the head space where flammable solvent
vapors are present. In some instances, reactor products are sent
to process tanks or holding tanks before being transferred to the
next reactor vessel or before the purification step.-
Following the reaction step, product separation/purification
is usually required and may involve unit operations such as
crystallization, filtration, distillation, extraction, and/or
drying. For more discussions on common unit operations, see EPA
draft document "Control of Volatile Organic Compound Emissions
from Batch Processes,* EPA No. EPA-453/R-93-017.
From some separation/purifications steps, a recycle stream
may be fed back to the reactors. These streams are routed to
storage vessels, mixing or weigh vessels, or directly to the
3-15
-------
reactors. The recycle stream usually contains unreacted raw
materials, solvents, or catalysts that may be reused.
Product recovery devices are integral to the actual process
and are not considered to be air pollution control devices; these
recovery devices include condensers and absorbers used to recover
products, reactants, or co-products for use in a subsequent
process, as recycle feed, or for sale.
The final product from a process may be an active ingredient
ready for sale/formulation, or the final product may be an
intermediate to be used as a reactant for a subsequent process.
An intermediate may be held temporarily in a process holding tank
or long term in a storage vessel between the intermediate process
and the active ingredient process.
3.2.3 Batch versus Continuous Flow
Both batch and continuous processes are used to manufacture
PAI's. The majority of processes in the PAI production industry
are batch. The 1986 OW study indicated that 79 percent of active
ingredient manufacturing processes are batch. 5 Seventy-one
percent of the active ingredients and intermediates reported in
the Section 114 study are batch.10 Batch processes are
characterized by nonsteady-state conditions that result in finite
emission periods during which the concentration, flowrate, and
stream conditions (temperature and pressure) fluctuate. Batch
processes are used when small amounts of product are to be
manufactured, when multiple products are to be manufactured in
the same equipment, and when the reaction rate is fairly slow.
In continuous processes, raw materials are continuously fed
into the process while product is continuously removed. These
processes operate under steady-state conditions and may operate
for weeks or months at a time. Continuous processes are
generally used when large quantities of product are to be
manufactured and when the reaction rate proceeds quickly.
According to both the 1986 OW study and the Section 114
responses, 21 percent of active ingredients are manufactured with
continuous processes.25'10
3-16
-------
In some instances, a single PAI is produced using a
combination of both batch and continuous processes.25 The
Section 114 data indicate that 8 percent of active ingredient
processes are both batch and continuous.10
3.2.4 HAP Emissions
Emissions from the PAI production industry include HAP
compounds, and some of these HAP are also VOC compounds. A list
of HAP emitted from pesticide intermediate and active ingredient
manufacturing is given in Table 3-10; these HAP were identified
?fi
in the Section 114 responses. ° These HAP are used as raw
materials and solvents or are produced as intermediates and
active ingredients. The HAP emissions occur from process vents,
storage tanks, equipment leaks, wastewater, and bag dumps and
product dryers. These emission sources are discussed in this
section.
TABLE 3-10. HAP COMPOUNDS EMITTED FROM FACILITIES
IN THE PAI PRODUCTION INDUSTRY THAT RESPONDED
TO THE SECTION 114 REQUESTS26
Acetomirile Ethylene dichloride Methylene chloride
Aniline Ethylene glycol Methyl ethyl ketone
1.3-Butadiene Formaldehyde Methyl isobutyl ketone
Benzene Glycol ethers Methyl isocyanatc
Benzyl chloride HC1 N.N-Dimeihylanilme
Captan Hexachlorocyclopentadiene Napthalene
Carbon disulfide Hexachlorobenzene Phenol
Carbon tetrachlonde Hexachloroethane Phosgene
Chlorine Hexane Tetrachloroethylene
Chloroacetic acid Hydrazine Toluene
Chloroform Hydroquinone 1.2,4-Trichlorobenzene
Cyanide compounds Maleic anhydride Tnchloroethylene
1.1-Dimethyl hydrazine Methanol Tnethylamine
Ethyl benzene Methyl chloride Xylenes
Ethyl chloride Methyl chloroform
3.2.4.1 Process Vents. Unit operations (reactors, filters,
dryers, distillation columns, extractors, crystallizers, and
evaporators) used to produce, separate, and prepare PAI's and
intermediates are often vented to the atmosphere; emissions from
3-17
-------
these unit operations are termed process vent emissions.
Flowrates from these units range from less than 1 to
7,700 standard cubic feet per minute (scfm), according to data
from the Section 114 responses.10 Emission stream data for
process vents are provided in Table 3-11. Emissions of HAP can
occur from events such as vapor space displacement during vessel
charging, purging of vessel headspace, vessel heatup, gas
evolution from reaction and processing, and vessel emptying.
Data in the Section 114 responses identified 40 HAP compounds
emitted from process vents. The predominant HAP emitted to the
atmosphere (controlled basis) are HC1, toluene, methanol, and
methyl chloride.26
3.2.4.2 Storage tanks. Storage tanks are used to contain
chemical raw materials, pesticide intermediates, and PAI's.
Based on the Section 114 responses, storage tanks used by
facilities in the PAI production industry are fixed roof tanks
with capacities ranging from 2,500 to 1,567,000 gallons.26
Approximately half of all storage tanks in these source
categories are less than 20,000 gallons.26
Data from the Section 114 responses indicate that there are
80 organic HAP and 2 inorganic HAP storage tanks that store a
variety of HAP compounds. Approximately 80 percent of the
industry uses organic HAP storage tanks. The predominant HAP
emitted to the atmosphere (controlled basis) are methanol,
toluene, xylene, trichloroethylene, and methylene chloride.26
Emissions of HAP occur during vapor expansion and contraction due
to diurnal temperature changes (breathing losses) and refilling
the tanks with virgin or recycled solvent or product (working
losses).
3.2.4.3 Equipment leaks. Emissions of HAP occur primarily
at the connections between different equipment components during
transfer of chemicals. Transfer of chemicals can be done through
permanent or temporary piping from storage tanks, between process
equipment, or by manual transfer of chemicals. Equipment leak
sources include pumps, compressors, process valves, pressure
relief devices, open-ended valves or lines, sampling connections,
3-18
-------
TABLE 3-11. EMISSION STREAM DATA FOR PROCESS VENTS10
Total
Active
ingredient*
Intermediate*
PROCESS VENTS - ALL (BATCH. CONTINUOUS. AND BATCH/CONTINUOUS)
No. processes reported
Uncontrolled emissions. Mg/yr
Controlled emissions. Mg/yr
Average HAP reduction. %
PROCESS VENTS - BATCH PROCESS ONLY
No. processes reported
Uncontrolled emissions. Mg/yr
Controlled emissions, Mg/yr
Average HAP reduction. %
93
8.S14
777
91
66
4.092
479.8
88
77
5,886
441
93
55
1.685
175.1
90
15
2,596
335.2
87
10
2,375
304.2
87
PROCESS VENTS - CONTINUOUS PROCESS ONLY
No. processes reported
Uncontrolled emissions. Mg/yr
Controlled emissions. Mg/yr
Average HAP reduction. %
19
4.075
206.5
95
14
3,854
175.5
95
5
221.6
3102
86
PROCESS VENTS - BATCH/CONTINUOUS PROCESS ONLY
No. processes reported
Uncontrolled emissions. Mg/yr
Controlled emissions, Mg/yr
Average HAP reduction. %
8
3470
90.57
74
8
347.0
90.57
74
0
0
0
0
"One process was not identified as an active ingredient or intermediate.
3-19
-------
flanges and other connectors, agitators, product accumulator
vessels, and instrumentation systems. Data from the Section 114
responses showed that leak detection and repair (LDAR) programs
were in place at 7 of the 20 facilities for some or all of their
processes; one of these facilities had a process subject to
40 CFR part 63, subpart H, National Emission Standards for
Organic Hazardous Air Pollutants for Equipment Leaks.26
3.2.4.4 Wastewater. The Section 114 responses include
wastewater data that quantify the wastewater stream flowrates,
the HAP loads, and the control techniques used; descriptive
wastewater information for the PAI production industry in the
responses is limited. Because of the similarities in processing
and feed materials, wastewater systems in PAI production are
assumed to be similar to the wastewater systems in other
industries, such as the pharmaceutical production industry and
SOCMI. Descriptions of wastewater systems in the following
discussion are based on the wastewater systems in these other
industries. Data in the following discussion that quantify
specific wastewater parameters are based on the Section 114
responses for the PAI production industry.
Wastewater streams containing HAP compounds may be generated
during PAI and intermediate production. Air emissions from
evaporative losses of HAP in wastewater are a source of HAP
emissions in the PAI production industry. Sources of wastewater
containing HAP include water used as a reactant in a process;
water used for equipment cleaning; water used to wash impurities
from products or reactants; condensed steam from vacuum vessels
containing HAP; pumps with once-through circulation of water; and
scrubber water discharging. '2 The point at which wastewater
exits a process (and after the decanter for separation
operations) is considered the point of determination (POD) for
wastewater. Responses to the Section 114 information requests
indicated that 45 of 93 processes generated wastewater streams.26
Air emissions of HAP from wastewater may occur from the
wastewater collection and treatment system. Based on the data
from the Section 114 responses, PAI manufacturing facilities are
3-20
-------
either indirect dischargers or direct dischargers. Based on the
responses, there are four wastewater streams with indirect
2fi
discharge and 39 wastewater streams with direct discharge.
(Two wastewater streams are disposed of by deep-well injection.)
The collection system and the types of wastewater treatment for
indirect and direct wastewater discharge are discussed below.
3.2.4.4.1 Collection systems.29 The collection systems
used to route wastewater to the treatment system can be hard
piped, i.e., not allowing evaporative losses, or can be composed
of covered or grated sewers; additionally, open sumps and drop
structures may be encountered. The evaporation of HAP to the
atmosphere occurs most readily from open or uncovered collection
components where the wind retards the saturation of the ambient
air, thus allowing organic HAP to evaporate. Potential sources
of HAP emissions associated with wastewater collection and
treatment systems include drains, manholes, trenches, surface
impoundments, oil/water separators, storage and treatment tanks,
57 9 ft
junction boxes, sumps, and basins. ""°
A total of 28 HAP compounds were reported to be in
wastewater streams according to the Section 114 responses. Based
on analyses performed during the development of the HON,
volatilization of a significant fraction is likely for 19 of the
28 HAP. Methanol, ethylene dichloride, and hydrogen chloride
5 fi
were the predominant HAP in the wastewater streams. °
3.2.4.4.2 Indirect dischargers. 9 Facilities that route
their wastewater streams to a publicly owned treatment works
(POTW) are indirect dischargers. Indirect discharges usually
have treatment systems that are not designed to fully destroy
wastes because waste destruction is accomplished in the POTW.
Indirect discharge treatment systems usually comprise one to two
open equalization basins, an open neutralization basin, and one
or more open aerated stabilization basins. Evaporation of HAP
compounds to the atmosphere occurs in these treatment basins.
Figure 3-2 contains a generalized process flow diagram for an
indirect discharge facility. However, both equalization and
neutralization generally have less HAP air emissions than aerated
3-21
-------
U)
(O
PROCESS
AREA A
WATERWATER
POD
STREAM 1
PROCESS
AREAS
WATERWATER
POD
STREAM 2
SUMP
WATERWATER
POD
STREAM 3
SUMP
MAIN
A
SEWER
t
WASTEWATER FLOW
EQUALIZATION
BASIN
TOPOTW
I
• EMISSION POINT
Figure 3-2. Wastewater flow schematic for an indirect discharge facility.
-------
basins because they are typically not agitated or sparged. The
sizes of these basins are quite large, depending on the
wastewater flowrate.
3.2.4.4.3 Direct dischargers.29 Facilities that allow the
treated wastewater exiting the plant to flow directly to a source
of surface water are referred to as direct discharging
facilities. These treatment components are generally similar in
size to treatment components for indirect dischargers. However,
these facilities generally provide more thorough treatment of the
wastewater streams generated at the plant than do indirect
dischargers. Figure 3-3 contains a wastewater flow schematic for
a direct discharge facility.
Direct discharging facilities typically have equalization
and neutralization, but the aerated basins contain higher
quantities of active biomass (i.e., 4 to 8 g/L), which provides
for more degradation of the organic pollutants in the wastewater.
Additionally, primary and secondary clarification may be present
as well as liquid incineration or steam-stripping of specific,
high concentration wastewater streams.
3.2.4.5 Baa dumps and product drvers. Bag dump operations
include the addition of dry solids, usually raw materials or
intermediates, to process equipment during the manufacture of
PAI. In product dryers, small amounts of liquid evaporate from
solid materials into a gas stream by application of heat, vacuum,
or circulating warm air. Particulate matter emissions occur when
the solids become entrained during the addition of the solids or
by the air flow during the drying operation. Data from the
Section 114 responses indicate that two plants emit PM HAP from
bag dumps and product dryers.
3-23
-------
Ul
i
to
PROCESS
AREA A
WATERWATEF
POD
STREAM 1
WATERWATER
POD
STREAM 2
SUMP
MAIN
SEWER
EQUALIZATION
BASIN
t
A
WASTEWATER FLOW
EMISSION POINT
PRIMARY
CLARIRER
SECONDARY
CLARIFIER
TO
SURFACE
WATER
Figure 3-3. Wastewater flow schematic for a direct discharge facility.
-------
3.3 REFERENCES FOR CHAPTER 3
1. U. S. Environmental Protection Agency. Development Document
for Best Available Technology: Pretreatment Technology, and
New Source Performance Technology for the Pesticide Chemical
Industry. Washington, DC, Office of Science and Technology.
EPA Publication No. EPA-821/R-92-005. April 1992. p. 3-43.
2. Reference 1, p. 3-77.
3. U. S. Environmental Protection Agency. Initial List of
Categories of Sources under Section 112(c)(l) of the Clean
Air Act Amendments of 1990. 57 FR 31576. Washington, D.C.
U.S. Government Printing Office. July 16, 1992.
4. Farm Chemicals Handbook 1993. Meister Publishing Company.
Willoughby, OH.
5. U. S. Environmental Protection Agency. Status of Pesticides
in Reregistration and Special Review. EPA Publication
No. EPA-738/R-94-008. June 1994. p. 57.
6. Reference 5, pp. 55-56.
7. Reference 1, p. 3-3.
8. Reference 5, pp. 331-381.
9. Reference 1, p. 3-4.
10. Memorandum from K. Schmidtke, MRI, to L. Banker,
EPA/ESD/OCG. November 11, 1996. Documentation of Data Base
Containing Information from Section 114 responses and Site
Visits for the Production of Pesticide Active Ingredients
NESHAP.
11. Memorandum from K. Schmidtke, MRI, to L. Banker,
EPA/ESD/OCG. November 27, 1996. Estimation of the Number
of Affected Sources in the Production of PAI Source
Category.
12. Reference 1, p. 3-41.
13. Chemical and Engineering News. June 24, 1996. y. 46.
14. U. S. Environmental Protection Agency. Pesticides Industry
Sales and usage: 1992 and 1993 Market Estimates.
Washington, DC, Office of Prevention, Pesticides, and Toxic
Substances. EPA Publication No. EPA-733/K-94-001.
pp. 26-29.
15. Reference 14, p. 4.
16. Reference 14, p. 19.
3-25
-------
17. Memorandum from Schmidtke, K., MRI, to L. Banker, EPA:BSD.
January 6, 1997. Growth Projections for the PAI Production
Industry.
18. Reference 1, pp. 3-48.
19. Reference 1, pp. 3-51.
20. Reference i, pp. 3-60.
21. Reference 1, pp. .5-61.
22. Reference 1, pp. 3-79.
23. Bovey, R. W. and A. L. Young. The Science of 2,«,5-T and
Associated Phenoxy Herbicides. New York, Wiley. 1980.
p. 44.
24. Reference 1, pp. J-63.
25. Reference 1, pp. 3-64.
26. Memorandum from D. Randall and K. Schmidtke, MRI to
L. Banker, EPA/ESD/OCG. April 15, 1997. Summary of Data
from Responses to Information Collection Requests and Site
Visits for Production of PAI NESHAP.
27. U. S. Environmental Protection Agency. Control of Volatile
Organic Compound Emissions from Batch Processes Control
Techniques Guidelines. Draft, p. 2-37.
28. U. S. Environmental Protection Agency. Hazardous Air
Pollutant Emissions from Process Units in the Synthetic
Organic Chemical Manufacturing Industry - Background
Information for Proposed Standards. Volume 1A, National
Impacts Analysis. EPA Publication No. EPA-453/D-92-016a.
November 1992. p. 3-15.
29. U. S. Environmental Protection Agency. Pharmaceutical
Production Basis and Purpose Document. January 1997.
Chapter 3.
3-26
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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
Section 112 of the 1990 Clean Air Act Amendments (the Act),
requires that EPA evaluate and control emissions of HAP. The
control of HAP is achieved through promulgation of emission
standards under sections 112(d) and 112(f) and work practice and
equipment standards under section 112(h) for categories of
sources that emit HAP. On July 16, 1992, EPA published the
initial list of major and area source categories to be regulated
(57 FR 31576).
4.1.1 Source Categories
The source category list published in 1992 included
10 source categories in the agricultural chemicals production
industry group. Each of these 10 categories of agricultural
chemicals are produced at major sources; each agricultural
chemical is also a pesticide active ingredient (PAD. One source
category that was included on the original source category list
under a different industry group was added to the agricultural
chemicals source category. Butadiene furfural cotrimer (R-ll)
production was moved from the polymers and resins industry group
to this industry group on June 4, 1996 (61 FR 28197) . Butadiene
furfural cotrimer (R-ll) is an insecticide commonly used for
delousing cows. The EPA decided to include butadiene furfural
cotrimer (R-ll) production with the agricultural chemicals source
categories because: (1) there are similarities in process
operations, emission characteristics, and control device
applicability and costs, and (2) it is a pesticide active
ingredient.
4-1
-------
4.1.2 Addition of Other Pesticide Active Ingredients
While developing the standards, the EPA identified a number
of other PAI production operations that were not on the original
source category list. It was determined that production of these
compounds is similar to the production of the compounds in the
11 initial agricultural chemical source categories. Production
of these other pesticide active ingredients are being added to
the source category list under section 112 (c) of the Act based on
information obtained during the gathering of HAP emissions data.
From this information, it was determined that: (1) there are
similarities in process operations, emission characteristics,
control device applicability and costs, and opportunities for
pollution prevention of these PAI's with the listed agricultural
chemicals, and (2) the production of these PAI's occurs at
facilities that are major sources. Like the original
agricultural chemicals, these PAI's are those that are used in
herbicides, insecticides, and fungicides that are registered as
end-use products under section 3 of Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA).
4.1.3 Change of the Source Category Name
Because other PAI's have been added to the source category
list and because they have been grouped with the 11 agricultural
chemicals, which are also PAI's, the EPA decided that it was
appropriate to change the title of the NESHAP source category.
The EPA revised the source category list published under
section 112(c) of the Act to add a source category called
"Pesticide Active Ingredient Production" and subsumed the
11 original, separate PAI production source categories into that
category, as well as included other identified PAI operations
which are major sources of HAP. All 11 agricultural chemicals on
the initial source category list are PAI's; all of the other
pesticide chemicals identified during data gathering and that
have been added to the list are also PAI's. The change in the
title of the source category to "pesticide active ingredient
production" was appropriate to avoid confusion regarding the
definition of the source category and to aid in distinguishing
4-2
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the types of air emission sources addressed by this source
category.
4.2 RATIONALE FOR SUBCATEGORIZATION
4.2.1 Single Source Category
In developing the standards, EPA decided not to set MACT for
each individual PAI chemical but, rather, to aggregate all PAI's
together under the same source category. Data gathered from the
PAI production industry indicate that the process equipment,
emission characteristics, and applicable control technologies are
sufficiently similar for the broad group of sources that EPA is
regulating under a single set of standards. There are no
significant differences in the types of control technologies
applicable to controlling emissions from the various PAI
processes. Common HAP control technologies are applicable to the
production operations at all of the facilities. Based on these
factors, EPA concluded that determining MACT for each individual
pesticide active ingredient was not warranted.
The EPA believed that it is technically feasible to regulate
emissions from a variety of PAI processes by a single set of
emission standards. Similar to the Hazardous Organic NESHAP
(HON) for the Synthetic Organic Chemical Manufacturing Industry
(SOCMI), separate requirements are proposed for process vents,
storage tanks, equipment leaks, and wastewater HAP emission
points (often referred to as planks). The set of standards also
establishes different control requirements based on distinctions
in the size of the emission points. Variability in the
characteristics of the production processes for each individual
pesticide active ingredient chemical may affect the quantity of
HAP emissions. This variability has been addressed by
incorporating cutoffs for uncontrolled emissions in the standards
for individual planks.
Several other reasons support the development of a single
set of emission standards for a group of PAI processes. Many of
these PAI's are only produced at a single facility or by a single
company. In addition, data indicate that many of the PAI
processes that EPA is proposing to regulate by this set of
4-3
-------
standards are co-located within individual facilities; at some
facilities, multiple PAI's are also produced in the same
equipment (i.e., non-dedicated equipment). Facilities with co-
located PAI manufacturing could more easily comply with a single
set of emission standards than with individual standards for each
of the co-located processes. Several industry representatives in
the partnership group also expressed interest in a generic
regulation that would specify consistent requirements for a wide
range of processes.
Another justification for developing a single set of
emission standards to regulate production of a variety of PAI's
is that it is more efficient and less costly for EPA to develop a
single standard than to develop separate standards for several
individually listed source categories which have similar emission
characteristics and applicable control technologies. Development
of A single set of standards would avoid the costs associated
with having to develop emission standards for separate source
categories of PAI's. A single set of standards for PAI
manufacturing will ensure that process equipment with comparable
HAP emissions and control technologies are subject to consistent
emission control requirements. In addition, compliance and
enforcement activities would be more efficient and less costly.
4.3 RATIONALE FOR EMISSIONS AVERAGING
Emissions averaging will be part of this rule. The
emissions averaging provisions in this rule are based on
provisions that were developed for the HON NESHAP. The emissions
averaging provisions also have incorporated the emissions
averaging constraints included in the HON rule. These
constraints are discussed in a supplementary Federal Register
notice published on October 15, 1993 (58 FR 53479), and include
consideration of: (1) State discretion on the use of emissions
averaging, (2) inclusion of risk in averaging determinations,
(3) compliance period for emissions averaging, and (4) limit on
the number of emission points allowed in an average. Another
important consideration is to not allow controls to be used for
averaging if those controls are required to meet other State or
4-4
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Federal regulatory requirements. This consideration has been
incorporated into the proposed averaging provisions for this
rule.
As in the HON rule, emissions averaging for this proposed
rule is not allowed as a compliance option for new sources. The
decision to limit emissions averaging to only existing sources is
based on the fact that new sources have historically been held to
stricter standards than existing sources. It is most cost
effective to integrate state-of-the-art controls into equipment
design and to install the 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.
4-5
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5.0 BASELINE EMISSIONS
Baseline hazardous air pollutant (HAP) emissions for the
pesticide active ingredient (PAD manufacturing industry are
defined as the emissions that would exist in the absence of
additional EPA standards. As described in Chapter 3, there are
an estimated 78 major sources in the PAI manufacturing source
category, and HAP's are emitted from four emission source types
(i.e., process vents, equipment leaks, storage tanks, and
wastewater systems). Table 5-1 presents both the uncontrolled
and baseline HAP emissions for the PAI source category; the
nationwide HAP baseline emissions were estimated to be
6,750 Megagrams per year (Mg/yr).
TABLE 5-1. SUMMARY OF UNCONTROLLED AND BASELINE EMISSIONS
Emission source type
Process vents
Equipment leaks
Storage tanks
Wastewater systems
Bag dumps and product
dryers
Total
Emissions, Mg/yr
Uncontrolled
16,500
3.700
219
2,490
846
23,800
Baseline
1,770
3,410
37.3
1,530
8.5
6,750
The estimated baseline emissions in Table 5-1 consist of
actual and estimated emissions from 20 surveyed plants and
emissions from model emission source types that were developed to
5-1
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characterize the 58 additional facilities. The remainder of this
chapter summarizes the approach used to develop the uncontrolled
and baseline HAP emissions from each of the four emission source
types. More detailed information on the approach is contained in
the data summary, model plants, and baseline emissions
memoranda.^ ~ ^
5.1 PROCESS VENTS
Table 5-2 presents a list of HAP's with the highest
uncontrolled and baseline emissions from process vents at the
surveyed plants. The HAP's are listed in descending order based
on the magnitude of the baseline emissions. The baseline and
uncontrolled emissions are based entirely on data provided by the
surveyed plants. Hydrochloric acid (HC1), toluene, methanol, and
methyl chloride were the four HAP emitted in the largest
quantities from process vents in this source category. .These
four HAP's constituted nearly 75 percent of the baseline
emissions from process vents at the surveyed plants.
Four model processes were developed to characterize organic
HAP and HC1 emissions from process vents at the 58 additional
plants. Table 5-3 presents the estimated emissions from the
model process vents. Uncontrolled emissions were estimated to be
equal to the average uncontrolled emissions from processes at the
surveyed plants that were used as the basis for each model.
Baseline emissions were estimated assuming a control efficiency
of 80 percent for organic HAP. Baseline emissions for HC1 were
estimated assuming that 69 percent of the models are controlled
to 99 percent and 31 percent are controlled to 80 percent for
HC1. These control efficiencies were equal to the arithmetic mean
of the control efficiencies for all processes at the surveyed
plants that emitted these HAP's. The control efficiencies for
HC1 differ from the 93 percent reduction shown in Table 5-2
k
because processes with high uncontrolled HC1 emissions were
better controlled than processes with low uncontrolled HC1
emissions.
As listed in Table 5-1, uncontrolled and baseline emissions
from process vents at all 78 facilities were estimated to be
5-2
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TABLE 5-2. UNCONTROLLED AND BASELINE HAP EMISSIONS
AND EMISSION REDUCTIONS FROM PROCESS VENTS
AT SURVEYED PLANTS
HAPa
HC1
Toluene
Methanol
Methyl chloride
Phosgene
Methyl isobutyl ketone
Xylene
Methylene chloride
Triethylaroine
Carbon tetrachloride
Carbon disulfide
Tetrachloroethylene
Ethylene dichloride
Ethyl chloride
Benzene
Hexane
Acetonitrile
Chlorine
Benzyl chloride
All others
TOTAL
Emissions, Mg/yr
Uncontrolled
4.050
496
405
115
2,350
59.4
135
41.1
56.2
66.0
29.1
59.7
167
27.1
92.7
24.7
86.3
95.9
1.39
152
8.510
Baseline
301
151
80.4
51.1
48.8
21.9
21.7
18.2
17.3
16.5
14.3
9.80
4.54
3.60
3.41
3.14
2.69
2.38
1.39
3.45
777
Emission
reduction, %
93
70
80
56
97
63
84
56
69
75
51
84
97
87
96
87
97
98
0
98
91
aA total of 39 HAP's were emitted
plants.
from process vents at the surveyed
5-3
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TABLE 5-3.
UNCONTROLLED AND BASELINE EMISSIONS
FROM MODEL PROCESS VENTS
Model
process
1
2
3
4
TOTAL
No. of
models
48
19
14
12
93
Typical organic
HAP
Toluene
Methylene chloride
Toluene
Methylene chloride
Type of
process
Batch
Batch
Continuous
Continuous
Emissions, Mg/yr
Uncontrolled
Organic
HAP
657.2
760.2
574.0
1,222
3.213
HC1
0
1.256
0
3,540
4,796
Baseline
Organic
HAP
131.4
152.0
114.8
244.3
642.5
HC1
0
87.90
0
259.6
347.5
16,500 and 1,770 Mg/yr, respectively. Baseline emissions from
process vents comprise 26 percent of the total nationwide
baseline emissions.
5.2 EQUIPMENT LEAKS
Equipment leak emissions were estimated using either actual
or model equipment counts and average SOCMI emission factors.
Component counts were available for 30 of the processes at the
surveyed plants; the equipment counts for the remaining processes
at those surveyed plants were modeled. Additionally, all
components were assumed to be in service 100 percent of the
process operating hours, and the process fluid in contact with
each component was assumed to contain 100 percent HAP. The model
counts consisted of 1,100 flanges, 14 light liquid pumps, 65 gas
valves, and 340 light liquid valves for batch processes and 1,500
flanges, 33 light liquid pumps, 240 gas valves, and 1,100 light
liquid valves for continuous processes.
Baseline emissions were assumed to be equal to the
uncontrolled emissions unless the plant instituted a leak
detection and repair (LDAR) program equivalent to either the CTG
requirements or the requirements in subpart H of 40 CFR
part 63.5'6 Seven of the surveyed plants implemented LDAR
programs for some or all of their PAI manufacturing processes.
The uncontrolled emissions from equipment leaks at the surveyed
plants are 1,480 Mg/yr, and the baseline emissions are
5-4
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1,180 Mg/yr. Because most of the processes at the surveyed
plants had no LDAR program, processes at the 58 additional plants
also were assumed to have no .LDAR programs. The uncontrolled and
baseline emissions for the modeled equipment leaks are provided
in Table 5-4.
TABLE 5-4. UNCONTROLLED AND BASELINE EMISSIONS FROM
EQUIPMENT LEAKS AT MODEL PLANTS
Model
1
2
No. of models*
90
26
Types of process
Batch
Continuous
Uncontrolled and
baseline emissions,
Ma/yr
1,021
1,205
°The uncontrolled and baseline emissions for the surveyed plants include
emissions from 48 batch and 11 continuous model processes (where
facilities did not provide equipment counts for some processes). The
uncontrolled and baseline emissions at modeled plants include emissions
from 90 batch and 26 continuous.model processes, for a nationwide total
of 138 batch and 37 continuous.
As listed in Table 5-1, the total uncontrolled and baseline
HAP emissions from equipment leaks at all 78 facilities were
estimated to be 3,700 and 3,410 Mg/yr, respectively. Baseline
.emissions from equipment leaks account for approximately half of
the total baseline emissions from this source category.
5.3 STORAGE TANKS
Table 5-5 presents a list of HAP's with the highest
uncontrolled and baseline emissions from storage tanks at the
20 surveyed plants. Uncontrolled emissions from these tanks were
calculated using EPA's TANKS3 program. To calculate the
emissions, the program uses characteristics of the stored
material, physical characteristics of the tank, and meteoro-
logical conditions for the city that is nearest to the plant.
Characteristics of the stored material were obtained from
standard references or calculated based on the composition of the
material, which was provided by the surveyed plants. Tank
dimensions were assumed based on the capacity and known height-
to-diameter ratios for some tanks. Default values in the program
were used for most of the other tank parameters.
5-5
-------
TABLE 5-5. UNCONTROLLED AND BASELINE HAP EMISSIONS AND
EMISSION REDUCTIONS FROM STORAGE TANKS AT SURVEYED PLANTS
HAPa
Methanol
Toluene
Xylene
Trichloroethvlene
Methvlene chloride
Dimethyl hydras ine
Hexane
Methyl ethvl ketone
Bthvlene dichloride
Carbon tetrachloride
Glvcol ether • unspecified
Tetrachloroethylene
All others
TOTAL
Emission*, kq/yr
Uncontrolled
4.370
37.600
2.210
752
582
356
381
269
4.590
2.720
2.000
418
620
56.900
Baseline
3.020
2.060
968
752
533
356
348
269
91.7
54.1
40.1
8.37
518
9.020
Emission
reduction. %
31
95
56
0
9
0
8
0
98
98
98
98
16
84
*A total of 30 organic HAP's were emitted from storage tanks at the
surveyed plants.
The three HAP's stored in the most tanks at the surveyed
plants were toluene, methanol, and xylene, which were stored in
23, 14, and 10 tanks, respectively. These three HAP's also made
up almost 70 percent of the baseline HAP emissions from storage
tanks at the surveyed plants. Other HAP's with significant
baseline emissions at the surveyed plants included trichlor-
ethylene, methylene chloride, dimethyl hydrazine, hexane, and
methyl ethyl ketone. Bach of these compounds, except hexane, was
stored in only a single tank or in tanks at only a single
facility, and emissions from these tanks received little or no
control. Tetrachloroethylene, ethylene dichloride, carbon
tetrachloride, and glycol ether had uncontrolled emissions that
were similar to those for the compounds described above, but
tanks containing these compounds were well controlled..
Nine model storage tanks were developed to characterize the
uncontrolled and baseline emissions from storage tanks at the
58 additional facilities. Table 5-6 presents the estimated
emissions from the model storage tanks. The characteristics used
5-6
-------
to classify the surveyed tanks into the nine groups represented
by the models were tank capacity, uncontrolled emissions rate,
and control device efficiency. Uncontrolled emissions for each
model tank were estimated to be equal to the average uncontrolled
emissions from surveyed tanks that were used as the basis for
each model. Control efficiencies for all models except 1, 4, and
7 were estimated in the same way. Control efficiencies for
models 1, 4, and 7 were based on surveyed tanks that had reported
efficiencies equal to or greater than 95 percent; however, the
models based on these tanks were all assumed to have control
efficiencies equal to 95 percent.
TABLE 5-6. UNCONTROLLED AND BASELINE HAP EMISSIONS
AND EMISSION REDUCTIONS FROM MODEL STORAGE TANKS
Model
storage
tanks
1
2
3
4
5
6
7
8
9
TOTAL
No. of
models
26
26
67
23
6
32
34
12
12
238
Emissions, Mg/yr
Uncontrolled
16.6
6.93
2.08
9.62
3.30
0.540
112
10.5
0.869
163
Baseline
0.832
6.17
1.14
0.481
3.30
0.442
5.60
9.88
0.435
28.3
Control
efficiency. %
95
11
45
95
0
18
95
6
50
83
As listed in Table s-i, the total uncontrolled and baseline
HAP emissions from storage tanks at all 78 facilities were
estimated to be 219 and 37.3 Mg/yr, respectively. Baseline
emissions from storage tanks account for less than one percent of
the total baseline emissions from PAI production plants.
5.4 WASTEWATER SYSTEMS
Table 5-7 presents the annual loadings and estimated
emissions for six HAP's present in wastewater streams at surveyed
plants. The three HAP's contained in the most streams were
toluene, methanol, and xylenes, which were contained in 21, 16,
and 9 streams, respectively. The HAP's with the highest annual
-------
loadings were methanol, ethylene dichloride, methylene chloride,
methyl isobutyl ketone, and toluene; all of these compounds were
present in the wastewater from one plant that had significantly
higher loadings than any other plant.
TABLE 5-7. ANNUAL HAP LOADINGS AND UNCONTROLLED AND
BASELINE HAP EMISSIONS FROM WASTEWATER STREAMS
AT SURVEYED PLANTS
HAP
Methanol
Toluene
Acetonitrile
Methyl ethyl ketone
Benzene
Xylene
N. N-Dimethylaniline
Ethylene dichloride
Methyl isobutyl
Xetone
Glycol ether
Methylene chloride
Chloroform
All others
TOTAL
HAP load,
Mg/yr
1.950
88.7
73.7
51.3
15.3
20.0
34.1
760
152
6.78
205
2.24
8.52
3,370
Emissions, Mg/yr
Uncontrolled
331
71.0
26.5
24.6
12.3
16.0
11.6
486
80.6
2.17
158
1.75
5.78
1,230
Baseline
133
28.3
26.5
24.6
12.3
13.7
11.6
4.86
2.62
2.17
1.77
1.75
2.01
264
Control
efficiency,
%
60
60
0
0
0
14
0
90
97
0
99
0
65
79
Uncontrolled emissions were estimated to be a fraction of
the loading because not all of the HAP's in the wastewater have
the potential to volatilize. Of the 28 HAP's reported as present
in wastewater streams at the surveyed plants, 19 are designated
as HAP's that have the potential for a significant fraction to
volatilize from wastewater (based on an analysis performed during
development of the HON). Uncontrolled emissions for these HAP's
were estimated to be equal to the HAP loadings times the
respective "fraction emitted" (Fe) values that are listed in
subpart G of 40 CFR part 63.7 Using this procedure for each of
the 19 HAP's, the uncontrolled HAP emissions from the surveyed
plants were estimated to be 1,230 Mg/yr.
5-8
-------
The baseline HAP emissions were assumed to be equal to the
uncontrolled emissions for facilities that had no controls other
than biotreatment. This assumption was used to reflect HAP
recovery potential with steam stripping. Also, existing
biotreatment systems possibly are not operated to achieve the
level of HAP destruction that would be suggested by modeling of
enhanced biotreatment systems.
Baseline emissions for three surveyed plants that controlled
emissions from wastewater streams with steam stripping, air
stripping, and incineration were estimated by different
procedures. To estimate baseline emissions from a steam stripper
at one plant, the load of each HAP was multiplied by the
respective "fraction removed" (Fr) value that is listed in
subpart G of 40 CFR part 63.8 For one plant with an air stripper
that was use to control carbon tetrachloride and tetra-
chloroethylene, the control efficiency was assumed to be
95 percent--midway between the Fe and e"r values for these
compounds--because the air stripper should remove more than would
volatilize from a typical wastewater biotreatment system but less
than the fraction that would be removed in a steam stripper. An
incinerator that was used to control emissions from wastewater
had an assumed control efficiency of 99 percent.9
Hastewater streams at the 58 additional plants were assumed
to receive only biotreatment because wastewater streams at 17 of
the surveyed plants received only biotreatment. Therefore, the
baseline emissions were assumed to be equal to the uncontrolled
emissions for all of the 58 additional plants. The uncontrolled
and baseline emissions for the wastewater model streams are each
1,260 Mg/yr.
As listed in Table 5-1, the uncontrolled and baseline HAP
emissions from wastewater systems at all 78 facilities were
estimated to be 2,490 and 1,530 Mg/yr, respectively. Emissions
from wastewater systems comprise 23 percent of the total baseline
emissions from PAI production facilities.
5-9
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b.b BAG DUMP AND PRODUCT DRYERS
Table 5-8 presents the two HAP's emitted from bag dumps and
product dryers at the surveyed plants. These HAP's constitute
less than 1 percent of the baseline emissions. No models were
developed for bag drums and product dryers. Few facilities are
expected to have this type of emission source, and HAP emissions
from this source are expected to be controlled. The uncontrolled
and baseline emissions were estimated at 846 Mg/yr and
8.45 Mg/yr. respectively.
TABLE 5-8. UNCONTROLLED AND BASELINE HAP EMISSIONS
AND EMISSION REDUCTIONS FROM BAG DUMPS
AND PRODUCT DRYERS AT SURVEYED PLANTS
HAP
Cap tan
Maleic anhydride
TOTAL
Emissions, Mg/yr
Uncontrolled
844
1.66
846
Baseline
8.44
0.00181
8.45
Emission
reduction, %
99
99.9
99
REFERENCES FOR CHAPTER 5
Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:ESD. April 15, 1996. Summary of Data from
Responses to Information Collection Requests and Site Visits
for the Production of Pesticide Active Ingredients NESHAP.
Memorandum from D. Randall, K. Schmidtke, and C. Hale, MRI,
to L. Banker, EPA:BSD. April 30, 1997. Baseline Emissions
for the Pesticide Active Ingredient Production Industry.
Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPArESD. April 30, 1997. Model Plants for the
Pesticide Active Ingredient Manufacturing Industry.
Protocol for Equipment Leak Emission Estimates. Office of
Air Quality Planning and Standards. U. S. Environmental
Protection Agency. EPA-453/R-95-017. November 1995.
p. 2-12.
5-10
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5. Control of VOC Fugitive Emissions from Synthetic Organic
Chemical, Polymer, and Resin Manufacturing Equipment.
EPA-450/3-83-006. Office of Air Quality Planning and
Standards. U. S. Environmental Protection Agency. Research
Triangle Park, NC. March 1984.
6. 40 CFR part 63, subpart ri, section 63.161.
7. 40 CFR part 63, subpart G, Table 34.
8. 40 CFR part 63, subpart G, Table 9.
9. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:ESD. December 16, 1996. Recommended Control
Levels for the Process Vent, Storage Tank, and Wastewater
Planks of the New Source MACT Floor.
5-11
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6.0 MACT FLOORS AND REGULATORY ALTERNATIVES
This chapter presents the approach used to develop the
Maximum Achievable Control Technology (MACT) floors and
regulatory alternatives for existing and new sources in the
pesticide active ingredient (PAD production source category.
The floors and regulatory alternatives were developed for five
types of emission points: process vents, equipment leaks,
storage tanks, wastewater systems, and bag dumps and product
dryers. Each type of emission point constitutes a "plank" in the
MACT floor for the source category.
The remainder of this chapter is divided into three
•sections. The Clean Air Act (CAA) requirements for the
determination of MACT floors and regulatory alternatives are
discussed in section 6.1. The MACT floor and regulatory
alternatives for existing sources are described in section 6.2,
and the MACT floor for new sources is described in section 6.3.
6.1 CLEAN AIR ACT REQUIREMENTS
The CAA requires that standards for sources of hazardous air
pollutant (HAP) emissions reflect the maximum degree of reduction
in HAP emissions that is achievable. This control level is
referred to as MACT. The CAA also provides requirements for
determining the least stringent level allowed for a MACT
standard; this level is termed the "MACT floor." The CAA
requires examination of alternatives more stringent than the
floor. However, the CAA specifies that evaluation of regulatory
alternatives that are more stringent than the floor consider the
cost of achieving the emission reduction, any nonair quality
health and environmental impacts, and energy requirements.
6-1
-------
Section 112(d)(3) of the CAA specifies that standards for
new sources in a source category or subcategory "shall not be
less stringent than the emission control that is achieved in
practice by the best controlled similar source, as determined by
the Administrator." Section 112(d)(3) also specifies that
standards for existing sources 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.
The EPA has evaluated two interpretations of the MACT floor
for existing sources. Under the first interpretation, EPA would
look at the average emission limits achieved by each of the best
performing 12 percent of existing sources, and the lowest would
be used to represent the MACT floor. 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 the 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 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 EXISTING SOURCE MACT FLOOR AND REGULATORY ALTERNATIVES
6.2.1 Overview of Approach
This section describes the approach taken for determining
the MACT floor for existing sources in the PAI production source
category.
The first step in the approach was to identify the potential
types of emission points within the source category. For the PAI
6-2
-------
production source category, the emission points were determined
to be process vents, equipment leaks, storage tanks, wastewater
systems, and bag dumps and product dryers.
The next step in the approach was to determine the best
performing 12 percent of the facilities. The best performing
12 percent in this case was determined based on the total
percentage reduction in HAP emissions from the affected source.
For the PAX production source category, the affected source is
the collection of all process equipment, storage tanks, and waste
management units involved in the production of PAI's at the
plant. As noted in Chapter j, there are an estimated 78 affected
facilities nationwide. Therefore, the best performing 12 percent
consists of nine facilities.
Identification of the best performing 12 percent was
accomplished by conducting a screening telephone survey followed
by sending a detailed written information request to selected
companies.* The screening telephone survey was conducted to
identify several facilities that achieve high emissions
reductions. The survey was also designed to identify plants that
each produce a variety of PAI's, use a variety of production
processes, and are major sources. Companies with multiple plants
that met the criteria were favored over those with only one
plant. A detailed information request was then sent to nine
companies. These companies provided data for a total of
20 plants, which are ranked in Table 6-1 according to their total
percentage reduction in HAP emissions. Because plants with good
emission controls were targeted to receive the information
request, EPA believes that the surveyed plants include the nine
plants that are the best performing 12 percent.
Table 6-1 shows plant 16 has an overall control efficiency
of 99.9 percent. The only HAP emissions from this plant consist
of particulate generated from a raw material bag dump. This is
not considered to be typical of sources in this source category.
As a result, this plant was not included among the best
performing 12 percent of sources.
6-3
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TABLE 6-1. OVERALL CONTROL EFFICIENCY OF HAP EMISSIONS FROM PAI PLANTS
Plant
I6a
9
7
22
6
17
12
II
20
8
IS
10
23
19
1
21
3
13
14
5
Uncontrolled HAP emissions, Mg/yr
Process
vents
1.66
549
890
5,720
16.5
224
388
394
82.1
253
2.87
32.7
282
34.3
171
178
61.8
18.9
9.96
52.8
Equipment
leaks
0
14.2
57.7
136
0.56
128
80.4
242
22.7
69.0
107
90.6
126
11.3
56.8
79.4
137
22.7
56.7
48.1
Storage
vessels
0
0
0
0.64
0
0
1.9
6.9
0.47
0.97
0.08
3.1
1.74
0
33.1
4.36
0.09
0.27
1.17
2.0
Wastewaler
0
0.03
0.835
43.1
0
29.4
1.26
931
0.0147"
42.5b
9.35
0.173
c
11.6
6.17
112
1.84
25.1
10.9
2.17
Controlled HAP emissions, Mg/yr
Process vents
0.002
0.540
21.9
343
1.65
8.30
10.8
95.1
1.04
17.8
2.84
23.3
31.8
0.17
100
71.4
2.96
0.67
0.20
51.9
Equipment
leaks
0
10.7
57.7
136
0.56
126
80.4
242
22.7
69.0
25.1
21.6
126
11.3
39.5
79.4
137
22.7
56.7
47.8
Storage
vessels
0
0
0
0.00006
0
0
I.I
1.77
0.47
0.94
0.08
0.003
1.74
0
1.66
0.47
0.011
0.27
0.023
0.04
Waslewaler
0
0.03
0.835
43.1
0
29.4
1.26
9.31
0"
0"
9.35
0.0117
c
11.6
6.17
112
1.84
24.7
10.9
2.17
Overall
control
efficiency,
%
99.9
98.0
91.5
91.2
87.0
86.8
80.2
77.9
77.0
76.0
68.7
64.6
61.1
59.7
44.8
29.5
29.4
27.8
13.9
3.0
o\
I
'This plant is not considered to be typical of the industry and. thus, is not included in the best performing 12 percent
"This plant disposes of wastewater using deepwell injection.
cNo data provided.
-------
After the nine best performing sources in the source
category were identified, the "average emission limitation
achieved" was determined for each of the four planks at these
plants. The arithmetic mean was evaluated first. When the
arithmetic mean was at a level that corresponded with the control
achieved by a known technology, it was selected as the MACT
floor. When the arithmetic mean did not correspond with the
control achieved by a known technology, the median was selected
as the MACT floor.
The next step was to determine regulatory alternatives more
stringent than the MACT floor. Potential regulatory alternatives
were developed based on the Hazardous Organic NESHAP (HON) and
the Alternative Control Techniques Document for Control of
Volatile Organic Compound Emissions from Batch Processes (Batch
Processes ACT). The HON was selected because (1) the
characteristics of the emissions from storage vessels, equipment
leaks, and wastewater systems in the PAI production industry 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 Batch Processes ACT document was selected to identify
regulatory alternatives for batch process vents, which are not
addressed by the HON. The Batch Processes ACT document covers
VOC emissions, and most of the HAP emitted from PAI production
facilities are also VOC. Unlike the HON, the Batch Processes ACT
document is not a regulation and, therefore, does not specify a
level of control that must be met. Instead, the Batch Processes
ACT document provides information on potential levels of control
and their costs. Using procedures in the Batch Processes ACT
document, the EPA developed a regulatory alternative that
requires 98 percent reduction of gaseous organic HAP emissions
from "large" process vents. This level of control was selected
because it was determined to be achievable, considering costs and
other impacts, for process vents that meet certain flow and HAP
load characteristics.
6-5
-------
Under the CAA, EPA can distinguish among classes, types, and
sizes of sources within a source category in establishing
standards; one way to make distinctions is to establish
applicability cutoffs. The PAI source category is comprised of
many different production processes. Variability in the
characteristics of these processes may affect the emission rates.
To address this variability, EPA determined a MACT floor (and
regulatory alternatives) that consist of applicability cutoffs as
well as control efficiencies for the emission points that exceed
the cutoffs. For this regulation, the cutoffs were based on
uncontrolled emission rates. The MACT floor and regulatory
alternatives for process vents, storage tanks, wastewater
systems, equipment leaks, and bag dumps and product dryers at
existing sources are described below; additional information
about the development of the MACT floor and regulatory
alternatives is presented in the MACT Floor and Regulatory
Alternatives memorandum in the Supplementary Information
Document.^
6.2.2 Process Vents
The MACT floor for process vents could be determined on a
plant basis or on a process basis. The EPA chose to determine
the MACT floor on a process basis to maintain consistency with
the Batch Processes ACT document. In addition, because many
processes have a dedicated control (or controls), application on
a process basis would be easier to implement, monitor, and
demonstrate compliance. A process-based MACT floor would also be
consistent with the pollution prevention option, which is
described in Chapter 8.
The MACT floor for process vents was developed from data on
all 41 processes at the nine MACT floor plants. Uncontrolled and
controlled emissions and the corresponding control efficiencies
for each process are shown in Table 6-2. The HAP emissions were
grouped into two categories for analysis (1) gaseous organic HAP
and (2) hydrochloric acid (HCl) and chlorine. The HC1 emissions
include both HCl from the process and HCl that was generated by
burning chlorinated organic HAP in combustion-based control
6-6
-------
TABLE 6-2. SUMMARY OF PROCESS VENT EMISSIONS*
PUni Process
No No
6 16
7 17
7 18
1 19
8 20
8 22
1 23
9 24
9 25
11 28
11 29
II 30
11 31
11 32
11 33
II 34
II 35
II 36
12 37
12 38
12 39
12 40
17 60
17 61
17 62
17 63
20 65
20 66
22 74
22 75
22 76
22 77
22 78
22 79
22 80
22 81
22 82
22 83
22 84
22 85
22 86
Uncontrolled emissions.
Mi/yr
Onuics HClb
165 0
33.0 0
128 0
202 132
153 6.80
1.41 e
0 14.5
0 356
18.2 191
161 0
595 0
483 0
92.2 19 8
110 770
647 453
0354 0
0154 0
0.399 0
459 110
243 0000
199 212
482 504
0337 029
819 0
153 0
200 0
0146 0
818 0
347 2 390
53 1 355
454 0
454 0
238 0
8 30 55 3
181 0
138 0
57.5 1 67
28 9 0 84
96 3 0 101
667 0
1.730 598
Controlled emissions, Mg/yr
Orflanies HCIb
1.65 0
0660 0
128 0
130 1.32
1.53 0680
0141 c
0 121
0 0356
0.364 0.191
533 0
197 0
160 0
400 0 198
892 0770
5 24 0.453
0007) 0
00031 0
00080 0
0.0918 0110
0504 0000
5 93 2 48
311 0 304
00067 029
0164 0
291 0
522 0
0146 0
0807 0
694 578
106 875
00907 0
00907 0
0475 0
0 166 1 38
00363 0
00276 0
MS 1 67
0579 084
193 0101
1.33 0
345 331
Control efficiencies. %
Organic! HCI
900
980
00
936 900
900 900
900
91.7
999
980 999
669
669
669
56.6 990
919 990
919 990
980
980
980
980 990
979 00
97 0 98.8
935 994
98 0 0 0
980
810
974
00
990
98 0 97 6
98 0 97 5
980
980
980
98 0 97 5
980
980
980 00
980 00
980 00
980
980 447
Averages4 90 2 93 5
"Includes all processes at the nine MACT floor plants. Some of the controlled emissions and control
efficiencies were changed for reasons that are described in the Recommended Control Levels for New
.Source MACT Floor memorandum in the Supplementary Information Document.
°The HCI emissions include HO and chlorine from the process and HCI created by burning chlorinated
organics in a combustion-based control device, assuming all of the chlorine in the chlorinated organic is
convened to HCI.
*jNp data provided.
°The average control efficiency for organic HAP emissions is based on the efficiencies for the
38 processes with uncontrolled organic HAP emissions greater than 0.15 Mg/yr. The average HCI
control efficiency is based on the efficiencies for the IS processes with uncontrolled HCI emissions
greater than 6.8 Mg/yr.
6-7
-------
devices; HC1 from the process was reported by the plants in
responses to the information requests, and HCl generated by
combustion in control devices was estimated assuming all of the
chlorine in the chlorinated organics that are burned is converted
to HCl. Thirty-nine of the processes had organic HAP emissions
and 19 had HCl and chlorine emissions. Additional details about
the data are presented in the Data Summary memorandum in the
Supplementary Information Document.1
In responses to the information request, several facilities
reported organic HAP control efficiencies for thermal oxidation
control devices of 99 percent or more. These reported control
efficiencies were based on the results of trial burns for
compliance with RCRA regulations or were based on the results of
emissions tests when burning either liquid waste alone or both
liquid waste and process vent emissions. No data are available
on the control level when burning only process vent emissions.
However, based on numerous incinerator emission tests, it is
reasonable to assume that the control level is at least
98 percent.4 Therefore, reported control levels above 98 percent
were changed to 98 percent for use in the MACT floor analysis.
As noted above, the MACT floor consists of both an
applicability cutoff and a control efficiency requirement for
processes that exceed the cutoff. Separate cutoffs were
determined for each of the three categories of HAP emissions from
process vents. These cutoffs were determined by first ranking
the processes by uncontrolled emission rates in each category and
then examining the list for an appropriate cutoff. For the
organic HAP emissions, process 65 had the lowest uncontrolled
emissions, and this process was uncontrolled. Process 35 had the
second lowest uncontrolled emissions (0.154 Mg/yr), and it was
controlled. A cutoff of 0.15 Mg/yr was selected because this is
the highest point below which the arithmetic mean control
efficiency is no control; for higher cutoffs, the arithmetic mean
control efficiency for processes below the cutoff would be at
least 49 percent. For the 38 processes with uncontrolled organic
HAP emissions above the 0.15 Mg/yr cutoff, the arithmetic mean
6-8
-------
control efficiency was 90 percent. Because this efficiency can
be achieved by various control devices, it was selected as the
MACT floor control level. Therefore, the MACT floor for organic
HAP emissions from process vents consists of « control efficiency
of 90 percent for processes with uncontrolled emissions greater
than or equal to 0.15 Mg/yr.
For the HC1 and chlorine emissions category, processes 60,
82, 83, and 84 have the lowest uncontrolled emissions, and each
is uncontrolled. All of the other 15 processes with HC1 and
chlorine emissions are controlled. A cutoff was established at
uncontrolled emissions of 6.8 Mg/yr, which is equal to the lowest
uncontrolled emissions from a controlled process (process 20).
This value was selected because it is the highest value below
which the arithmetic mean control efficiency is no control; for
higher cutoffs, the arithmetic mean control efficiency for
processes below the cutoff would be at least 18 percent. Above
the t>.« Mg/yr cutoff, the arithmetic mean control efficiency is
94 percent. Because this level can be achieved by control
technologies, it was selected as the MACT floor control level.
Therefore, the MACT floor for HC1 and chlorine emissions from
process vents consists of a control efficiency of 94 percent for
processes with uncontrolled emissions greater than or equal to
6.8 Mg/yr.
Two regulatory alternatives beyond (i.e., more stringent
than) the floor were also developed. The first regulatory
alternative beyond the floor would require 98 percent control of
gaseous organic HAP emissions from vents that meet certain flow
and uncontrolled HAP mass loading criteria and that currently are
not controlled to the MACT floor level of 90 percent. The
combination of all other vents within a process not meeting the
flow and mass loading criteria remain controlled to the MACT
floor level of 90 percent. For the first regulatory alternative.
HC1 and chlorine emissions would be controlled to the MACT floor
level (i.e., 94 percent for processes with uncontrolled HC1
emissions greater than or equal to 6.8 Mg/yr). The second
regulatory alternative beyond the floor would require 98 percent
6-9
-------
control of gaseous organic HAP and 99 percent control of HC1
emissions on a process basis. Cutoffs for both regulatory
alternatives would be the same as for the MACT floor.
The flow and HAP load criteria for the first regulatory
alternative are based on a linear equation relating flow and
load. Vents currently controlled to levels of less than
90 percent and having actual flowrates (in standard cubic feet
per minute) less than the flowrate calculated by multiplying
uncontrolled HAP emissions, in Ib/yr, by 0.02 and subtracting
1,000 would meet the criteria for required control of 98 percent.
This equation was developed using a method that approximates
boundaries for cost effective control of emission stream
characteristics--in this case, flow and load. The cost-
effectiveness target used in this analysis is $3,500/Mg. This
value is based on decisions in previously promulgated part 63
rules where the cost effectiveness was judged to be reasonable.
The approach used to develop the equation is identical to
the approach described in the Batch Processes ACT document,
except that no volatility ranges were considered. Instead, the
properties of methanol only were used to develop cost-
effectiveness curves describing control by thermal incineration
and condensation. Methanol was used in the analysis because it
is one of the most common HAP in process vent emissions and it
has a moderate volatility, which means the resulting cost
effectiveness should represent the average cost effectiveness for
the range of HAP emissions. These curves are available in the
project docket.5 As described in the Batch Processes ACT
document, the curves form the basis for setting up control
requirements based on annual emissions and flow rate. By
developing a number of curves for different annual emission
totals, flow rate values were obtained for an optimum cost-
effectiveness range, considered to be £$3,500/Mg. These annual
emissions, and corresponding flow rates were used as data points
in a simple regression analysis to define a line that represents
the limits of cost effective control to 98 percent.
6-10
-------
6.2.3 Storage Tanks
Storage tank emissions are a function of many factors,
including the size of the tank, the vapor pressure, throughputs,
and molecular weight of the stored material. Therefore, the
methodology used to develop the storage tank plank of the MACT
floor focused on the characteristics of individual tanks at the
MACT floor plants rather than the plant wide control
efficiencies. The characteristics for tanks at the MACT floor
facilities are shown in Table 6-3.
For storage tanks, the MACT floor consists of two
applicability cutoffs and a control efficiency requirement for
storage tanks that exceed the cutoffs. To determine the cutoffs,
the tanks were first ranked according to their uncontrolled
emissions, as shown in Table b-j. The list in Table 6-3 shows a
majority of the tanks with low uncontrolled emissions were not
controlled. Working up from the bottom of the list, the median
control efficiency is 0 percent for all tanks with uncontrolled
emissions below any cutoff up to 0.11 Mg/yr (240 Ib/yr). Above a
cutoff of 0.11 Mg/yr (240 Ib/yr) the median control efficiency is
41 percent. A second cutoff was established based on the
capacity of the tank. In the group of tanks with uncontrolled
emissions £0.11 Mg/hr (240 Ib/yr), the smallest tank has a
capacity of 6,540 gallons. The two next smallest tanks have
capacities of about 10,000 gallons, and both are controlled to
98 percent. The 38 m^ (10,000 gallons) capacity cutoff was
selected because this is the smallest tank in the group of tanks
with uncontrolled emissions of 0.11 Mg/yr (240 Ib/yr) that is
controlled to the median control efficiency of 41 percent or
better. Therefore, the MACT floor for storage tanks is
41 percent control for storage tanks with capacities greater than
or equal to 38 m3 (10,000 gallons) with uncontrolled emissions
greater than or equal to 0.11 Mg/yr (240 Ib/yr).
A regulatory alternative more stringent than the MACT floor
was also developed. This alternative would require 95 percent
control of storage tanks with capacities greater than or equal to
76 m3 (20,000 gallons) that have uncontrolled emissions that are
6-11
-------
TABLE 6-3. STORAGE TANK CHARACTERISTICS AT KACT FLOOR PLANTS
T«*
No
1
2
3
4
5
•
7
•
9
10
II
12
13
14
IS
16
17
IS
19
20
21
^^
23
24
25
26
•*^
21
29
30
31
32
33
34
35
36
T7
39
40
41
42
nw
Ntt
II
II
II
12
•
11
22
12
11
11
20
20
12
12
II
12
22
12
I
12
S
12
12
20
7
•
11
II
12
•
•
20
12
20
20
II
12
n
i«
1
•
I
17
HAP
tlHVI SVf PITH OHITF
FTHYtGMF WCIUQWI*
XYLENE
TRJCMJORQETHYLENE
METHANOL
METHYia* CM/MRF
MEIHANOL
HEXANE
MEIHANOL
TOLUENE
DIMETHYL HYDRAZINE
DIMETHYL HYDRAZBC
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
MK-TOLUENEJCYANOHYDR1N
TMCMJOtOBENZENE
METHANOL
TMCHLOItOBENZENE
MIX-/rOLUENE/METHYLEME CHLORIDE
TOLUENE
ACETONFTRLE
MALEIC ANHYDMDE
XYLENE
METHYL BOBUTYL KETONE
TOLUENE
MIX-tCXA!'¥/TTtlCHlJQPQVE>I7FMF
TOLUENE
METHANOL
HYDRAZINE HYDRATE
MIX-ETHYL BENZENE/XYLENE
HYDRAZINE HYDRATE
MALE1C ANYHYDRDE
MDC-PORMALOEHYDE/METHANOL
TRKHLOROBEMZENE
DTWUAI rmrwnc
LIHYLENE CLYCOL
ETHYLENEGLYOOL
ETHYLENEGLYOOL
ETHYLENEGLYOOL
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IJ67JOOO
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7S1
693
553
S2S
341
260
231
195
164
127
124
III
116
112
108
9U
76J
669
656
639
57 •
555
494
456
43J
344
34J
32-2
301
165
12.7
12.4
747
141
n<4
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004
001
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Wd» w
9f
25
0
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4
91
0
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13J2
0
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91
91
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91
91
91
0
9t
0
9S
91
0
99J
0
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91
90
0
0
9S
0
0
9S
0
9g
0
0
0
0
ft**
64J
27J
•09
751
693
SSI
103
34»
ISI
201
195
164
233
149
69.4
2J3
2-24
2.16
9U
134
66.9
1JI
111
57J
0-2S
494
502
OSS
069
343
3T2
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114
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341
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004
004
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far
Control Lcvd for New
MACTRoor
6-12
-------
greater than or equal to 0.11 Mg/yr (240 Ib/yr); tanks with
smaller capacities that meet the emissions cutoff for the MACT
floor would be required to control to the level of the MACT
floor. Floating roof technology has been demonstrated to achieve
95 percent control and is considerably less expensive than other
technologies, even technologies that achieve control levels of
less than 95 percent; therefore, it is the preferred method of
control for tanks with capacities of greater than 76 m3
(20.000 gallons). Regulatory alternative 1 takes advantage of
this fact for tanks that can be equipped with floating roof
technology and merely requires the level of control that has been
demonstrated to be cost effective and technically feasible to
achieve. Regulatory alternative 1 also requires no additional
control of any tank that is currently equipped with a control
device achieving at least 41 percent control. This provision was
included in the regulatory alternative because the cost
associated with the incremental reduction achieved by increasing
control from 41 percent to 95 percent is not reasonable.
6.2.4 Wastewater Svst
-------
efficiency of any control technology, the median (i
control) was determined to be the MACT floor.
TABLE 6-4. CONTROL EFFICIENCIES FOR
WASTEWATER SYSTEMS AT MACT
FLOOR PLANTS
no
Plant
6
7
8
9
11
12
17
20
22
Control efficiency,
percent
0.0
0.0
a
0.0
99. Ob
0.0
0.0
a
0.0
aThis plant disposes of wastewater
.using deepwell injection.
°Control based on incineration of
all wastewater.
A regulatory alternative more stringent than the floor was
developed. This alternative would be to implement the
requirements in the HON (i.e., §§ 63.131 through 63.149 of
subpart G of part 63). This alternative specifies certain design
and emission control requirements for waste management units and
a variety of control options for wastewater treatment units.
Unlike the HON, this regulatory alternative applies to
maintenance wastewater as well as process wastewater.
Maintenance wastewater was excluded under the HON because it is
generated in batches, whereas the process wastewater is generated
continuously. However, in the PAI production industry, batch
processes with batch discharges are common. Thus, the same
procedures used to determine process streams that are subject to
6-14
-------
control would be used to determine maintenance streams that are
subject to control.
6.2.5 Equipment Leaks
The MACT floor for equipment leaks was determined to be no
control. This determination was based on all equipment leak data
provided by the nine MACT floor plants and on the modeled
equipment counts for those plants that did not provide data. The
arithmetic mean of control efficiencies in Table 6-5 is
13 percent, and the median is 0 percent. The arithmetic mean
does not represent the performance of any known regulatory
program for equipment leaks. Therefore, the median (i.e., no
control) was determined to be the MACT floor.
TABLE 6-5. CONTROL EFFICIENCIES FOR
EQUIPMENT LEAKS AT MACT FLOOR PLANTS
Plant
6
7
8
9
11
12
17
20
22
Control efficiency,
percent
0.0
0.0
0.0
24.6
0.0
0.0
90.0
0.0
0.0
A regulatory alternative more stringent than the floor was
also developed. This alternative is the implementation of all of
the requirements in subpart H of 40 CFR part 63, except that it
does not cover receivers and surge control vessels. Receivers
and surge control vessels are process vessels that typically
operate in batch mode. They also have vents like other types of
process vessels. Therefore, it is more appropriate to regulate
emissions from these vessels as process vent emissions rather
than equipment leak emissions.
6-15
-------
6.2.6 Bag Dumps and Product Drvers
Only one of the MACT floor plants emits particulate HAP from
bag dumps or product dryers. The particulate emissions at this
plant are from a product dryer that is controlled with a fabric
filter. This fabric filter controls PM HAP emissions to a
concentration below 22.9 milligrams per dry standard cubic meter
(mg/dscm) (0.01 grains per dry standard cubic foot [gr/dscf]).
This level is typical for fabric filter controls and. thus, was
selected as the MACT floor for PM HAP emissions from bag dumps
and product dryers. No alternatives more stringent than the MACT
floor were developed because the MACT floor was based on the best
control at an existing plant and the level represents good
control.
6.3 NEW SOURCE MACT FLOOR
For new sources, the MACT floor shall be no less stringent
than the level of control achieved by the best performing similar
source. The MACT floor for new sources in the PAI production
industry represents a high level of control that is at the limit
of technical feasibility for three of the four planks.
Therefore, no options above the floor were developed for process
vents, storage tanks, or equipment leaks. Alternatives more
stringent than the MACT floor were developed only for wastewater
systems. The remainder of this section describes the five planks
of the new source MACT floor and the regulatory alternatives for
wastewater.
6.3.J. Process Vents
The MACT floor for process vents at new sources was
determined on a process basis using data for the best controlled
processes at the best performing plants. Data for the best
performing plants are shown in Table 6-2. The MACT floor for new
sources also consists of applicability cutoffs and control
efficiency requirements for the same two categories of "HAP
emissions described above for existing sources: (1) organic HAP
and (2) HC1 and chlorine.
To determine the MACT floor for organic HAP emissions, the
processes in Table 6-2 were first ranked by their uncontrolled
6-16
-------
organic HAP emissions. Process 35 is the controlled process with
the lowest uncontrolled emissions (0.154 Mg/yr [330 Ib/yr]).
This process is controlled to 98 percent, and this level
represents the best control that is being achieved. Therefore,
the MACT floor consists of 98 percent control for any process
with uncontrolled organic emissions greater than or equal to
0.15 Mg/yr (330 Ib/yr).
In responses to the information collection request, a
facility reported control efficiencies of 99.99 percent or higher
for HC1 using scrubbers. These reported control efficiencies
were based on design parameters of the scrubbers and were not
based on the results of an emission test. Without specific test
data to demonstrate the control efficiency actually achieved by
the facility in the PAI production industry, control efficiencies
demonstrated for similar control devices in another industry were
evaluated.^ Control efficiencies of 99.9 percent for HC1 have
been demonstrated with test data in another industry. Therefore,
the reported control efficiencies above 99.9 percent were changed
to 99.9 percent, as shown in Table 6-2.
To determine the MACT floor for HC1 and chlorine emissions,
the processes in Table 6-2 were first ranked by their total
uncontrolled HCl and chlorine emissions. Processes 24 and 25 are
both controlled to 99.9 percent. This level represents the best
control that is being achieved; therefore, the floor for control
device efficiency was determined to be 99.9 percent. The other
component of the floor is the applicability cutoff. To determine
the cutoff, EPA examined the uncontrolled HCl and chlorine
emissions from processes 24 and 25. The lowest value is the
191 Mg/yr (211 ton/yr) emissions from process 24. Therefore,
191 Mg/yr (211 ton/yr) is the cutoff associated with the
99.9 percent control level. For processes with uncontrolled HCl
and chlorine emissions less than 191 Mg/yr (211 ton/yr), the MACT
floor is the same as for existing sources. By definition, the
floor for new sources cannot be less stringent than for existing
sources. Therefore, the floor consists of a 94 percent control
level for processes with uncontrolled HCl and chlorine emissions
6-17
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greater than or equal to 6.8 Mg/yr (7.5 ton/yr) and less than
191 Mg/yr (211 ton/yr) (i.e., the existing source level of
control).
6.3.2 Storage Tanks
The MACT floor for storage tank emissions at new sources was
based on the best performing tanks at the nine MACT floor plants.
The best performing single tank would have the highest control
efficiency of these tanks. To determine the MACT floor, all of
the storage tanks at the best performing plants were first ranked
according to their uncontrolled emissions; the tanks are ranked
in Table 6-3. The best level of control being achieved is
98 percent. The data show that many tanks are controlled to
98 percent. A 0.45 kg/yr (1 Ib/yr) cutoff was determined from
tank 38, which is the tank with the lowest uncontrolled emissions
that are controlled to 98 percent. A 26 m3 (7,000 gallons)
capacity cutoff was selected because this is the smallest tank
with uncontrolled emissions of at least 0.45 kg/yr (1 Ib/yr) that
is controlled to 98 percent or better. The new source MACT floor
was determined to be 98 percent control for any storage tank with
uncontrolled emissions greater than or equal to 0.45 kg/yr
(1 Ib/yr) and with capacity greater than or equal to 26 m3
(7,000 gallons). (Tank number 25 is controlled to 99.5 percent,
but it is controlled with a scrubber. A scrubber efficiency is
related to the characteristics of the HAP being controlled;
although it may achieve a high control level for a soluble
compound, it would not achieve the same control level on other
compounds.)
6.3.3 Wastewater Systems
The new source MACT floor for wastewater was determined to
be 99 percent control of all wastewater streams at plants that
have a total HAP mass flow rate (of Table 9 compounds in
subpart 6 of part 63) of 2,100 Mg/yr (2,300 tons/yr) or more in
wastewater from all POD's. For all other plants the floor was
determined to be no control.
As shown in Table 6-4, one of the best performing facilities
incinerates all of its wastewater, two dispose of wastewater
6-18
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using deepwell injection, and the others do not use treatment
technology that controls emissions. A facility using deepwell
injection cannot be considered a similar source because the
technology is not available to all sources. Therefore, the new
source MACT floor for wastewater is based on the practices of a
single facility that is burning all of its wastewater in RCRA
incinerators that burn a mixture of wastes. This facility is the
best performer due to the degree and extent to which it is
controlling wastewater streams containing HAP compounds that are
listed in Table 9 of subpart G of part 63. Wastewater streams
from nine processes are incinerated at this plant. Data for
these streams are presented in the Data Summary memorandum in the
Supplementary Information Document.
The control level for the best performing source was
determined as follows. Based on trial burns, the plant reported
in its response to the information collection request that the
incinerators have control efficiencies of 99.99 percent on
hazardous waste, but no wastewater-specific control efficiency
data are available. However, it is reasonable to assume, because
these are RCRA incinerators, that the control efficiency is at
least 99 percent, the same level achievable by steam stripping
for many compounds. Data are not available to EPA to conclude
that the incinerator is achieving a greater efficiency.
Therefore, the MACT floor control efficiency was determined to be
99 percent.3
To determine the cutoff for the floor, EPA examined the mass
flow rate of Table 9 compounds that are being incinerated at the
best performing facility. Collectively, the wastewater streams
contain more than 2,100 Mg/yr (2,300 tons/yr) of Table 9
compounds. Thus, 2,100 Mg/yr (2,300 tons/yr) is the floor cutoff
associated with the 99 percent control level.
Two regulatory alternatives more stringent than the floor
were developed. Both alternatives include the floor control
requirements for sources that have a total mass flow rate of
Table 9 compounds of 2,100 Mg/yr (2,300 tons/yr) or more, but
requirements for other sources differ. Regulatory alternative 1
6-19
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would require new sources below this mass flow rate cutoff to
implement the HON requirements for existing sources (i.e., the
requirements in §§ 63.131 through 63.149 of subpart G of
part 63) . This alternative would require owners and operators to
control Group 1 streams for Table 9 compounds. Regulatory
alternative 2 would require new sources below the mass flow rate
cutoff to implement the HON requirements for new sources (i.e.,
the same requirements as for existing sources except that Group 1
streams for Table o compounds and Group 1 streams for Table 9
compounds must be controlled) . Regulatory alternative 2 is more
stringent than regulatory alternative 1 because the applicability
cutoffs for Group 1 streams are lower for Table 8 compounds than
for Table y compounds. Both regulatory alternatives apply to
maintenance wastewater streams and process wastewater streams.
The requirements for sources with mass flow rates that
exceed the mass flow rate cutoff are more stringent than the HON
requirements for two reasons. First, these facilities would be
required to control all wastewater streams at the source, whereas
the HON only requires control of Group 1 streams. Second, these
facilities would be required to achieve 99 percent control for
each stream, whereas the HON requires control levels at least
equal to the Fr values, which, for many compounds, are less than
0.99. Additionally, as for sources that do not exceed the mass
flow rate cutoff, these requirements apply to maintenance
wastewater streams as well as process wastewater streams.
6.3.4 Equipment Leaks
The MACT floor for equipment leak emissions at new sources
was determined to be the LDAR requirements in subpart H of
40 CFR 63. This floor is based on the finding that two PAI
production facilities are implementing LDAR programs that are
consistent with the subpart H requirements. No facility is
controlling equipment leaks to a level above that achieved with
the subpart H requirements.
6-20
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6.3.5 Baa Dumps and Product Drvers
The best performing PAX production source uses a fabric
filter to control PM HAP emissions from a product dryer. Based
on emissions test data, PM HAP emissions at this source do not
exceed 22.9 mg/dscm (0.01 gr/dscf). Thus, the MACT floor for PM
HAP emissions from bag dumps and product dryer vents was
determined to be 22.9 mg/dscm (0.01 gr/dscf).
6.4 REFERENCES FOR CHAPTER 6
1. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:ESD. April 15, 1996. Summary of Data from
Responses to Information Requests and Site Visits for the
Production of Pesticide Active Ingredients NESHAP.
2. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPArESD. April 30, 1997. MACT Floor and
Regulatory Alternatives for the Pesticide Active Ingredient
Production Industry.
3. Memorandum from D. Randall and K. Schmidtke, MRI, to,
L. Banker, EPAtESD. December 16, 1996. Recommended Control
Levels for the Process Vent, Storage Tank, and Wastewater
Planks of the New Source MACT Floor.
4. Memorandum and attachments from Fanner, J., EPA:ESD, to
Ajax, B. et al. August 22, 1980. Thermal incinerators and
flares.
5. Memorandum from D. Randall, MRI, to L. Banker, EPAtESD.
June 30, 1997. Basis for Applicability Cutoff Equation for
Process Vents under Regulatory Alternatiave No. 1.
6-21
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7.0 SUMMARY OF ENVIRONMENTAL, ENERGY, COST,
AND ECONOMIC IMPACTS
This chapter presents primary air, secondary environmental
(air, water, and solid waste), energy, cost, and economic impacts
for existing sources resulting from the control of hazardous air
pollutant (HAP) emissions under the proposed standards for the
pesticide active ingredient (PAD production source category.
The impacts are presented for each of the five emission source
types (i.e., process vents, equipment leaks, storage tanks,
wastewater systems, and bag dumps and product dryers). More
detail on the approach and calculations is contained in the
baseline emissions, environmental impacts, and cost impact
memoranda.
7.1 BASIS FOR IMPACTS ANALYSIS
To comply with the proposed standards for gaseous organic
HAP emissions from process vents, this analysis assumes that PAI
facilities would use thermal incinerators to control emissions
from dilute streams; control of concentrated streams was assumed
to be achieved with refrigerated condensers. Water scrubbers
(gas absorbers) were assumed to be used to control hydrochloric
acid (HC1) emissions from process vents. Compliance with the
standards for storage tanks was assumed to be achieved with the
installation of internal floating roofs (IFR's) for tanks with
capacities greater than or equal to 76 cubic meters (m3)
(20,000 gallons) and condensers for tanks with smaller
capacities. For most wastewater streams, compliance with the
proposed wastewater standards was assumed to be achieved with
steam strippers; for small streams, compliance was assumed to be
achieved by shipping offsite for disposal as a hazardous waste.
7-1
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Compliance with the proposed standards for equipment leaks was
assumed to be achieved by implementing a leak detection and
repair (LDAR) program. Compliance with the proposed standards
for bag dumps and product dryers was assumed to be achieved with
fabric filters.
7.2 PRIMARY AIR IMPACTS
Primary air impacts consist of the reduction in HAP
emissions from the baseline level that is directly attributable
to the proposed standards. The proposed standards are expected
to reduce HAP emissions from existing PAI production facilities
by 5,150 megagrams per year (Mg/yr), or 76 percent, from a
baseline level of 6,750 Mg/yr. The reduction consists of
%,690 Mg/yr of organic HAP's and 458 Mg/yr of HC1. Particulate
matter (PM) HAP emissions were assumed to be unchanged because
only two of the surveyed facilities were found to emit PM HAP,
and both controlled it to the level of the standard. A summary
of the primary air impacts associated with implementation of the
proposed standards is shown in Table 7-1.
TABLE 7-1. SUMMARY OF PRIMARY AIR IMPACTS
Emission source
Process vents
-- Organic HAP's
-- HC1
Equipment leaks
Storage tanks
Wastewater systems
Bag dumps and product
dryers
Total
Emission reduction from baseline
Mg/yr
714
458
3,020
20.0
934
0
5,150
Percent
64
71
89
54
61
0
76
7.3 SECONDARY ENVIRONMENTAL IMPACTS
Secondary environmental impacts consist of any adverse or
beneficial environmental impacts other than the primary impacts
described in Section 7.2. The secondary impacts are indirect or
7-2
-------
induced impacts that result from the operation of the control
system that controls HAP emissions. To comply with the proposed
standard, it is anticipated that PAI production facilities will
use control systems that result in secondary air impacts.
However, secondary water and solid waste impacts are expected to
be minimal. The secondary air, water, and solid waste impacts
are discussed in the sections below.
7.3.1 Secondary Air Impacts
Secondary air impacts consist of: (1) generation of
byproducts from fuel combustion needed to operate control
devices, and (2) reduction of VOC compounds. Fuel combustion is
necessary to maintain operating temperatures in incinerators, to
produce steam for steam strippers, and to generate electricity
for operating fans, pumps, and refrigeration units. Byproducts
of fuel combustion include emissions of carbon monoxide (CO),
nitrogen oxides (NOX), sulfur dioxide (SO2), and PM less than
10 microns in diameter (PM^Q).
Steam was assumed to be generated in small, natural
gas-fired industrial boilers. Incinerator control devices also
use natural gas as the auxiliary fuel. The estimated natural gas
consumption rates are described in Section 7.4. Emissions from
combustion in both the boilers and incinerators were estimated
using AP-42 emission factors for small industrial boilers.
Electricity was assumed to be generated at coal-fired
utility plants built since 1978. The estimated electricity
requirements, and the fuel energy needed to generate this
electricity, are described in Section 7.4. Utility plants built
since 1978 are subject to the new source performance standards
(NSPS) in subpart Da of 40 CFR part 60.5 These NSPS were used to
estimate the PM^Q and SC>2 emissions from coal combustion. The
NOX emissions were estimated using the AP-42 emission factor
because the emission factor is lower than the level required by
the NSPS. The CO emissions were estimated using the AP-42
emission factor because CO emissions are not covered by the
NSPS. The sulfur content of the coal was assumed to be
1.8 percent.
7-3
-------
A summary of the estimated secondary air impacts for each of
the four emission source types is presented in Table 7-2. There
are no secondary air impacts associated with the use of floating
roofs to control emissions from storage tanks, with the
implementation of an LDAR program to control equipment leaks, or
with the control of bag dumps and product dryers.
TABLE 7-2. SUMMARY OF SECONDARY AIR IMPACTS
Emission source type
Process vents
Equipment leaks
Storage tanks6
Wastewater systems
Bag dumps and product
diyera
Total
Increased emissions, Mg/yr
CO*
107
0
0.00
2.85
0
110
N0*b
378
0
0.00
11.3
0
389
SOjC
274
0
0.00
0.85
0
275
PM10d
18.6
0
0.00
0.012
0
18.6
•TlieCO
is were estimated using AP-42 emission factors of 5 Ib CO/ton of coal and 35 Ib
of natural gas.
NO. emissions were estimated using AP-42 emission factors of 13.7 Ib NO^/ton of coal and 140 Ib
NOX/10* ft3 of natural gas.
eThe SO2 emissions were estimated using the NSPS for coal-fired utility boilers of 1.2 Ib SO^IO* Btu
and the AP-42 emission factor of 0.6 Ib SO2/106 ft3 of natural gas.
^The PM jo emissions were estimated using the NSPS for coal-fired utility boilers of 0.03 lb/106 Btu and
the AP-42 emission factor of 6.2 Ib PM10/106 ft3 of natural gas.
^creased emissions for storage tanks include 0.16 kg/yr CO, 0.43 kg/yr NOX, 0.03 kg PMjQ, and
1.89 kg SOj
In addition to the generation of by-product emissions from
fuel combustion, secondary air impacts also include the reduction
of VOC emissions. The VOC compounds are precursors to ozone.
Both non-HAP VOC compounds and VOC HAP compounds are reduced by
implementation of the standards, but the amount of VOC reduction
achieved by the standards is not known.
7.3.2 Secondary Water Impacts
Secondary water impacts consist of wastewater generated by
water scrubbers used to control HC1 emissions from process vents.
Wastewater from HC1 scrubbers is estimated to increase by
7-4
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10.8 million liters per year (2.9 million gallons per year). The
volume of wastewater generated would also increase at plants that
choose to use a water scrubber to control certain water soluble
organic HAP's; this volume was not estimated because the use of
water scrubbers is expected to be uncommon.
7.3.3 Secondary Solid Waste Impacts
Solid waste impacts are expected to be minimal. Captured PM
HAP emissions from bag dumps and product dryers are expected to
be either raw material or product that would be returned to the
process. At some plants, the overheads from a steam stripper
(i.e., the mixture of steam and volatilized organic compounds)
may be a waste that needs to be disposed of. At other plants,
however, it was assumed that the overheads can be condensed and
returned to the process as either raw material or fuel.
7.4 ENERGY IMPACTS
Energy impacts consist of the fuel usage and electricity
needed to operate control devices that are used to comply with
the proposed standards. The estimated electricity and fuel
impacts for each of the four emission source types are presented
in Table 7-3. In each case, the impacts are based on the total
amount of electricity or fuel needed to operate the control
devices; electricity and fuel needs for existing controls are
assumed to be negligible. The electricity and fuel impacts are
discussed in the sections below.
7.4.1 Electricity
Electricity would be needed to operate control devices used
to control emissions from process vents, small storage tanks, and
wastewater systems. Specifically, electricity would be needed to
operate the fans for incinerators, scrubbers, and condensers; the
refrigeration unit for condensers; and pumps for scrubbers,
condensers, and steam strippers. As noted above, electricity was
assumed to be generated in coal-fired boilers at utility plants.
The amount of fuel energy required to generate the electricity
was estimated using a heating value of 14,000 Btu/lb of coal and
a power plant efficiency of 35 percent. No additional
electricity would be needed to operate floating roofs for large
7-5
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TABLE 7-3. SUMMARY OF ENERGY IMPACTS
Emission source type
Process venls
Equipment leaks
Storage tanks
Wastewaler systems
Bag dumps and product
dryers
Total
Increase in
electricity
consumption,
kwh/yr
51.4 x I06
0
198
0.089 x I06
0
51.5 x I06
Increase in
steam
consumption,
Ih/yr
0
0
0
Il9x I06
0
I19x I06
Increase in fuel energy, Blu/yr
To generate
electricity
5.010 x I08
0
0.0193 x I08
8.63 x I08
0
5,020 x I08
Auxiliary fuel for
incinerators
42,000 x I08
0
0
0
0
42.000 x I08
To produce steam
0
0
0
1.750 x I08
0
1,750 x I08
Total
47.000 x I08
0
0.0193 x I08
l.760x I08
0
48.800 x I08
-------
storage tanks or to implement an LDAR program for equipment
leaks; electricity needs for control of bag dumps and product
dryers were not estimated.
7.4.2 Fuel
Fuel would be needed to operate incinerators and to generate
steam for steam strippers. In both cases, natural gas was
assumed to be the fuel of choice.
The amount of natural gas needed in incinerators was
estimated using mass and energy balances around the incinerators.
The operating temperature was assumed to be 1600°F. Energy
losses were assumed to be equal to 10 percent of the total energy
input. Additional details on the procedure are described in the
OAQPS Control Cost Manual.7
Steam strippers for wastewater streams were designed with an
assumed wastewater-to-steam ratio of 10.4:1. The steam was
assumed to be at 350°F and 100 psia. The enthalpy change was
estimated to be 1,180 Btu per pound of steam, assuming the feed
water to the boiler is at 50°F. The energy required to generate
the steam was estimated assuming a boiler efficiency of
80 percent. The quantity of natural gas needed to supply the
energy was estimated assuming the heating value of natural gas is
1,000 Btu per standard cubic foot.
No additional fuel would be needed to operate condensers for
process vents, condensers or floating roofs for storage tanks, to
implement an LDAR program for equipment leaks, or for control of
emissions from bag dumps and product dryers.
7.5 COST IMPACTS
Table 7-« presents the total capital investment (TCI) and
total annual cost (TAC) of the proposed standards for each of the
five emission source types at existing sources. The overall TCI
for all five emission source types is $70.3 million, and the
overall TAC is $39.0 million.
To comply with the proposed standards for process vents, the
estimated TCI is $56.2 million and the TAC is $33.9 million.3
The TCI included the purchased equipment and installation costs
for the control device, manifolding, and detonation arrestors.
7-7
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TABLE 7-4. SUMMARY OF TOTAL CAPITAL INVESTMENT
AND TOTAL ANNUAL COST IMPACTS
Emission source type
Process vents
Equipment leaks
Storage tanks
Wastewater systems
Bag dumps and product
dryers
Total
Total capital
investment, $
56,200,000
3,400,000
867,000
9,780,000
0
76,300,000
Total annual
cost, $/yr
33,900,000
1,650,000
607,000
2,870,000
0
38,900,000
The TAC consisted of capital recovery; electricity; labor;
maintenance materials; property taxes, insurance, and
administrative charges; and, for incinerators, natural gas.
To comply with the proposed standards for equipment leaks,
the estimated TCI is $3.40 million and the TAC is $1.65 million.3
The TCI included the cost of one monitoring instrument per
process and replacement parts. Initial monitoring and repair
costs were also treated as part of the TCI because the initial
leak frequency was estimated to be higher than the leak
frequencies once the LDAR program is in place. The TAC consisted
of capital recovery, monitoring and repair labor, maintenance,
and unspecified miscellaneous charges.
To comply with the proposed standards for storage tanks, the
estimated TCI is $867,000 and the TAC is $607,000.3 The TCI for
IFR included the installed capital cost for an aluminum
noncontact internal floating roof with vapor mounted primary seal
and a secondary seal. Initial costs for degassing and cleaning
the tank and for sludge disposal were also included in the TCI.
The TAC consisted of the capital recovery, property taxes,
insurance, administration, and operating costs. The TCI for
condensers included the purchased equipment and installation
costs for the control device. The TAC consisted of capital
7-8
-------
recovery; electricity; labor; and property taxes, insurance, and
administrative charges.
To comply with the proposed standards for wastewater
systems, the estimated TCI is $9.78 million and the TAG is
$2.87 million.3 The TCI included purchased equipment and
installation costs. The purchased equipment costs included
equipment costs for a packed column steam stripper, decanter,
feed and bottoms tanks, pumps, steam condenser, and flame
arrestor; piping; instrumentation; sales tax; and freight. The
TAG consisted of capital recovery, steam, electricity, cooling
water, labor, maintenance materials, overhead, property taxes,
insurance, and administrative charges. On a nationwide basis, it
was assumed that the cost for some facilities to dispose of
overheads is balanced by the savings in raw material or fuel
costs at other facilities. Wastewater disposal costs as
-------
8. Engineering Cost Model Documentation Report for the
Pharmaceutical Manufacturing Industry. Prepared by Radian
Corporation for U. S. Environmental Protection Agency, Office
of Water. February 28, 1995. pp. 2-8 and 4-29.
7-10
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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 pesticide active
ingredient (PAD production source category. 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.
8.1 SUMMARY OF THE PROPOSED STANDARDS
This section provides a summary of the proposed standards.
The full regulatory text and preamble is available in the
proposed Federal Register Notice, in Docket No. A-95-20, directly
from the EPA, or from the Technology Transfer Network (TTN) on
the EPA's electronic bulletin board.
The proposed standards would regulate HAP emissions from
facilities that manufacture PAI's that are formulated into
insecticide, herbicide, or fungicide products, provided that the
facility is a major source of hazardous air pollutant (HAP)
emissions.
For the proposed rule, an affected source is the facility-
wide collection of process vents, storage tanks, waste management
units and associated treatment residuals, equipment components
(pump, compressors, agitators, pressure relief devices, sampling
connection systems, open-end valves or lines, valves, connectors,
and instrumentation systems), bag dumps and product dryers, and
heat exchange systems in PAI manufacturing operations. The PAI
manufacturing operations include the production of integral
intermediates for which 50 percent or more of the annual
8-1
-------
production is used in the onsite production of PAI's. A PAX is
any material that is an active ingredient within the meaning of
FIFRA Section 2(a); that is used in an insecticide, herbicide, or
fungicide product; and that must be labeled in accordance with
40 CFR part 156 for transfer, sale, or distribution. These
materials are typically described by Standard Industrial
Classification (SIC) Codes 2869 and 2879. These materials are
identified by product classification codes 01, 02, 04, 07, 08,
16, 21, and 44 in block 19 on EPA form 3540-16, the Pesticides
Report for Pesticide-Producing Establishments.
Existing affected sources are those facilities that
manufacture a PAI as defined above as of the proposal date of
this standard. Such existing affected sources will be required
to comply with the standards 3 years after the date of
promulgation. New affected sources constructed or reconstructed
after the effective date of this standard (promulgation date)
will be required to comply with the new source standards upon
startup. New affected sources constructed or reconstructed after
proposal but prior to promulgation are not required to comply
with the standards until 3 years after the date of promulgation
provided:
1. The promulgated standard is more stringent than the
proposed standard, and
2. The owner or operator complies with the standard as
proposed during the 3-year period following the promulgation
date.
Pesticide active ingredient production operations that are
added after the proposal date to an existing facility that is a
major source, as defined in Section 112(a) of the Act, will be
subject to the new source standards only if they meet the
definition of construction in § 63.2 of subpart A of 40 CFR 63
and have the potential to emit 10 tons per year or more of any
HAP or 25 tons per year or more of any combination of HAP.
8-2
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8.1.1 Relationship to Other Rules
The proposed standard requires that equipment leak emission
sources be regulated according to the procedures described in
40 CFR €3 subpart H, with some slight modifications. The
requirements proposed in this rule do not affect components
regulated under subpart I of 40 CFR 63.
8.1.2 Regulated Emission Points
Emissions from PAI production occur from the following
emission points: storage tanks, process vents, equipment leaks,
waste management units, bag dumps and product dryers, and heat
exchange systems. The EPA is proposing standards for all of
these emission points.
8.1.3 Pollutants to be Regulated
A variety of HAP emissions would be regulated by the
proposed rule. Among the most significant organic HAP emissions
from all types of emission points are toluene, methanol, methyl
chloride, and xylene. Hydrochloric acid (HC1) emissions from
process vents and particulate matter (PM) HAP (e.g., Captan)
emissions from bag dumps and product dryers would also be
regulated.
8.1.4 Proposed Standards
Tables 8-1 and 8-2 summarize the standards for existing and
new PAI production affected sources, respectively. Figures 8-1
through 8-4 present logic diagrams of applicability and
requirements for the standards.
8.1.4.1 Process Vents. For existing sources, the proposed
standards would require control of gaseous organic HAP and HC1
from process vents for most PAI production processes.
Specifically, existing sources would be required to reduce
gaseous organic HAP emissions by 90 percent from all processes
where the sum of uncontrolled gaseous organic HAP emissions from
all vents is greater than or equal to 0.15 Mg/yr (330 pounds per
year [lb/yr]). The proposed standards would also require
existing sources to reduce HC1 emissions by 94 percent from all
processes where the sum of uncontrolled HC1 emissions from all
vents is greater than or equal to 6.8 Mg/yr (7.5 tons/yr).
8-.S
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TABLE 8-1. PROPOSED STANDARDS FOR EXISTING SOURCES
Emission point
Applicability
• • »
Processes having uncontrolled organic
HAP emissions £0.15 Mg/yr
Requirement
Process vents
90% overall organic HAP control per
process
Processes having uncontrolled HC1
emissions 26.8 Mg/yr
94% overall HC1 control per process
Individual process vents meeting TRE
and gaseous organic HAP emissions
controlled to less than 90% as of
proposal date
98% organic HAP control per vent
or <20 ppmv at the control device
outlet
Storage tanks
20.11 Mg/yr uncontrolled HAP
emissions:
238 m3 capacity and <76 m3
capacity
276 m3 capacity
41% control per tank
95% control per tank
Wastewater3
Group 1 wastewater streams for
Table 9 compounds at facilities with
mass flow rate of 21 Mg/yr of Table 9
compounds, in the Group 1 wastewater
streams.
Overall reduction to <50 ppmw of
Table 9 compounds (or other control
options)
Equipment
leaks
All components in HAP service,
excluding components covered by
subpart I
LDAR program in subpart H with
minor changes
Bag dumps
and product
dryers
All
PM HAP control to <0.01 gr/dscf
Heat exchange
systems
Each heat exchange system used to
cool process equipment in PAI
production operations.
Monitoring and leak repair as in
HON
"Table 9 is listed in the appendix to subpart G of 40 CFR pan 63.
8-4
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TABLE 8-2. PROPOSED STANDARDS FOR NEW SOURCES
Emission point
Process vents
Storage tanks
Wastewater*
Equipment
leaks
Bag dumps
and product
dryers
Heat exchange
systems
Applicability
Processes having uncontrolled organic
HAP emissions 20.15 Mg/yr
Processes having uncontrolled HC1
emissions 26.8 Mg/yr and <191 Mg/yr
Processes having uncontrolled HC1
emissions 2191 Mg/yr
20.45 kg/yr uncontrolled HAP
emissions and 226 nr capacity
Total mass flow rate of Table 9
compounds 22,100 Mg/yr
Total mass flow rate of Table 9
compounds <2,100 Mg/yr, and mass
flow rate of Table 9 compounds
>} Mg/yr/stream for Group 1 streams
All components in HAP service,
excluding components covered by
subpart I
All
Each heat exchange system used to
cool process equipment in PAI
production operations
Requirement
98% overall gaseous organic HAP
control per process or <20 ppmv at
the control device outlet
94% overall HC1 control per process
99.9% overall HC1 control per
process
98% control per tank or <20 ppmv at
the control device outlet
99% overall control of Table 9
compounds from each stream
Overall reduction to <50 ppmw of
Table 9 compounds per stream (or
other options)
LDAR program in subpart H with
minor changes
PM HAP control to <0.01 gr/dscf
Monitoring and leak repair as in
HON
9 is listed in the appendix to subpart G or 40 CFR pan 63.
8-5
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major source (as defined in
seetaon 112(a) of the CAA)?
>10tons/yr each HAP
• >25tons/yr total HAP's
Facility it not subject
to Subpart MMM
Does the facility manufacture a
pesticide active ingredient?
Facility is subject to subpart MMM
Figure 8-1. General applicability.
8-6
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Determine uncontrolled
emission* fbf til vent*
Group by process
For each process
are on* or more of the
(ollowlng true?
1) Gaieou* organic HAP
emission >0 ISMp/yr
2) MCI emission* J6.8 Mg/yr
No oontroi requirement
Record keeping
per§e31M«(b)
Control requirement*
1) For gaaaous organic HAP
amlaaiona >015 Mgyyr. 98% overall
control
2) For HO enuaawna >1B1 IMg/yr.
99 8% overall oontroi
3) For HO emiaawnt »6 8 Mg/yr and
<191 Mg/yr. 94% overall control
Is the proces* pan of a
new
alfeded source?
Are tha flowrate*
of any venl(t) aqual to
or less than lha flowrate
calculatad by (0 02)(HL)-
1.000.wti«r*HL«tha
uncontrolled organic HAP
toad par van! in Ib/yr^
Wai the vent equipped with a
device achieving 90% control
of gaaeous organic HAP prior
to proposal dale'
Control requirement*
1) For gaaeou* organic HAP omitttona
>015 Mg/yr par prooaaa. 90% overall
control
2) For HO emission* >8 8 Mg/yr per
procea*. 94% overall control
Control requirement*
1) For vent(«) with flowrata greater
than that calculated by the above
equation, 96% control of gateout
organic HAP or «20 ppm
2) For other vent* 90% overall
control of gaseou* organic HAP
3) For HCI emiMton* >6 8 Mg/yr per
proceu 94% overall control
Figure 8-2. Process vent standards.
8-7
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Control to 95% per
§ 63 1362(c)(1)
l»the«toragatankparto»an«w
aoura?
20.11 Mgyyr (240 IbM)?
An tftoontrollM 6flfiiMron§
z04Sk»yr
-------
99H control oral
streams mm*rMm|63mavoupf6ai37r*quMto Oontrt of Ikes* 9 compounds •
«sr eompounds n tn*
tor compounds n tne
1 Rserjeseone*ntratmita<90ppnwua^arVranbdbgicallii*tmeni
2
•
Figure 8-4. Wastewater standards.
8-9
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Additionally, individual vents that meet specific annual
emissions and flowrate criteria, and are currently controlled to
less than 90 percent, are required to achieve 98 percent control
of organic HAP emissions from these vents; other vents from the
process are subject to the overall 90 percent requirement.
New sources would be required to meet various process-based
control levels. Specifically, the proposed standards would
require new sources to reduce gaseous organic HAP emissions by
98 percent from all processes where the sum of uncontrolled
gaseous organic HAP emissions from all vents is greater than or
equal to 0.15 Mg/yr (330 Ib/yr) . The proposed standards would
also require new sources to reduce HC1 emissions by
(1) 94 percent from all processes where the sum of uncontrolled
HCl emissions from all vents is greater than or equal to
6.8 Mg/yr (7.5 tons/yr) and less than 191 Mg/yr (211 tons/yr),
and (2) 99.9 percent from all processes where the sum of
uncontrolled HCl emissions from all vents is greater than or
equal to 191 Mg/yr (211 tons/yr).
8.1.4.2 Storage Tanks. For existing sources, the proposed
standards would require a minimum of 41 percent control of
emissions from storage tanks that (1) have uncontrolled emissions
greater than or equal to 110 kilograms per year (kg/yr)
(240 Ib/yr), and (2) have a design capacity greater than or equal
to 38 cubic meters (m3) (10,000 gallons [gal]) and less than
76 m3 (20,000 gal). The proposed standards would require a
minimum of 95 percent control of emissions from storage tanks
that (1) have uncontrolled emissions greater than or equal to
110 kg/yr (240 Ib/yr), (2) have a design capacity greater than or
equal to 76 m3 (20,000 gal), and (3) are currently controlled to
less than 41 percent.
Any of the following control systems may be applied to meet
these requirements: (1) an internal floating roof with proper
seals and fittings; (2) an external floating roof with proper
seals and fittings; (3) an external floating roof converted to an
internal floating roof with proper seals and fittings; or (4) a
closed vent system with a 95 percent efficient control device.
8-10
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For new sources, the proposed standards would require
98 percent control of HAP emissions from storage tanks with (1)
uncontrolled emissions greater than or equal to 0.45 kg/yr
(1 Ib/yr), and (2) a design capacity greater than or equal to
26 m3 (7,000 gal). This control level can be met with a closed
vent system with a 98 percent efficient control device.
0.1.4.3 Wastewater. The proposed standards require owners
and operators of existing sources to determine for each
wastewater stream at its point of determination whether it is a
Group 1 or Group 2 wastewater stream. Group 1 wastewater streams
are required 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 8-3 and are the same as used in the HON. The
level of control required for Group 1 wastewater streams depends
on 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 standards require new sources that meet an
applicability cutoff to reduce the HAP mass flow rate by
99 percent or more from each stream. The cutoff is an overall
mass flow rate of HAP compounds listed in Table 9 of subpart G of
the HON that is greater than or equal to 2,100 Mg/yr
(2,300 tons/yr) from all streams. New sources that do not exceed
this cutoff are required to implement the same provisions as
existing sources (i.e., the provisions for existing sources in
the HON), except that the requirements apply to maintenance
wastewater streams as well as process wastewater streams. The
applicability characteristics for new sources are also shown in
Table 8-3.
8.1.4.4 Equipment Leaks. With one exception, new and
existing affected sources would be required to implement the same
requirements that are specified in the National Emission
Standards for Organic Hazardous Air Pollutants for Equipment
8-11
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TABLE 8-3
PROPOSED WASTEWATER APPLICABILITY CRITERIA FOR
EXISTING AND NEW SOURCES*'b'c
Existing source criteria
New source criteria
Total concentration of Table 9 compounds
210,000 ppmw
21
Total concentration of Table 9 compounds
SI.OOP ppm and flow rate 210 liters per minute
Same as existing criteria for source with total
mass flow rate of Table 9 compounds
<2,100 Mg/yr
SL
All streams for sources with total mass flow rate
of Table 9 compounds 22,100 Mg/yr
*Wastewater streams meeting these criteria are considered Group 1 wastewater streams and control is
.required.
"There are exemptions for minimal flowrates and concentrations.
'Table 9 is in subpart G of 40 CFR part 63.
Leaks (40 CFR 63, subpart H). The primary requirements in
subpart H are specific equipment modifications and work practices
that reduce emissions from equipment leaks. The difference
between the proposed regulation and subpart H is that the
subpart H requirements for receivers and surge control vessels do
not apply; emissions from this equipment will be considered to be
process vent emissions.
8.1.4.5 Baa Dumps and Product Drvers. Under the proposed
standards, particulate HAP emissions from bag dumps and dryers
would not be allowed to exceed 0.01 gr/dscf.
8.1.4.6 Heat Exchange Systems. New and existing affected
sources would be required to implement « 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 (Section 63.104 of 40 CFR part 63 as proposed in
August 1996).
8.1.4.7 Emissions Averaging. The proposed standards would
apply essentially the same emissions averaging scheme as was
adopted under the HON. Emissions averaging is allowed among
*
process vent, storage tank, and wastewater emission points at an
existing affected source. Under emissions averaging, a system of
"credits" and "debits" is used to determine whether an affected
source is achieving the required emissions reductions. The owner
or operator must demonstrate that the averaging scheme will not
8-12
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result in greater hazard or risk relative to strict compliance
with the standards in the absence of averaging. New sources
would not be allowed to use emissions averaging.
8.1.5 Alternative Pollution Prevention Standard
Owners and operators of existing affected sources may also
choose a pollution prevention (P2) alternative that can be
implemented in lieu of the requirements described in
Section a.1.4. The P2 option was developed to provide a way for
proactive facilities to demonstrate compliance with the MACT
standard by demonstrating that they have effected reductions in
overall waste from their processes. In the P2 option, which is
applicable to existing affected sources, owners and operators can
satisfy the MACT requirements for all process vent, storage tank,
equipment leak, and wastewater system emission points associated
with each process by demonstrating that the production-indexed
consumption of HAP's has decreased by 85 percent from a baseline
set during the first year of operation of the process or the year
1987. The production-indexed consumption factor is expressed as
kg HAP consumed/kg product produced (kg/kg factor). The
numerator in the kg/kg factor is the total consumption of
material, which describes all the different areas where material
can be consumed, either through losses to the environment,
consumption in the process as a reactant, or otherwise destroyed.
0.2 RATIONALE FOR THE SELECTION OF THE PROPOSED STANDARDS
The approach for determining the MACT floors and developing
regulatory alternatives for new and existing sources is discussed
in Chapter 6. Chapter 6 also presents the resulting MACT floors
and regulatory alternatives for new and existing sources. This
section identifies the selected alternatives and provides the
rationale for their selection as the proposed standards. 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. More detailed information
on the calculation of impacts is contained in the cost impacts
memorandum.^
8-13
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8.2.1 Existing Sources
8.2.1.1 Process Vents. The Administrator selected
Regulatory Alternative 1 over the MACT floor regulatory option
because the incremental cost effectiveness to move from the floor
to a more stringent alternative was $2,900/Mg, and this value was
judged to be reasonable.1 Additionally, Regulatory Alternative 1
is more cost effective than the floor (when both are compared to
baseline conditions). In fact, few streams are expected to have
characteristics that would require emissions reductions of
98 percent under Regulatory Alternative 1. Many of those that
would be required to achieve such reductions are expected to
incur no additional cost because the least costly control device
to meet the MACT floor was found to be an incinerator.
Therefore, even at the MACT floor, these streams would already be
controlled to 98 percent.
The decision to not require 98 percent control of emission
sources meeting the flow and load applicability criteria that are
already controlled to the level of the MACT floor (90 percent) is
based on the rationale that the incremental 8 percent control
achieved in stepping up control from 90 percent to 98 percent may
be difficult for many facilities to achieve without great
expense. Because 98 percent control efficiency in many cases
cannot be achieved by retrofitting or modifying existing control
systems, there is a possibility that owners and operators that
have made a good faith effort to control their emission sources
to high levels (90 percent) would be required to scrap existing
controls and install completely new control systems.
Regulatory Alternative 2 was not selected because the
overall cost effectiveness and the incremental cost effectiveness
were determined to be unreasonable. The incremental cost
effectiveness relative to Regulatory Alternative 1 is $14,000/Mg,
*
and the overall cost effectiveness relative to baseline is
$25,600/Mg.1
8.2.1.2 Storage Tanks. The Administrator selected the MACT
floor regulatory alternative for storage tanks with a capacity
greater than or equal to 38 m3 (10,000 gal) and less than 76 m3
8-14
-------
(20,000 gal) because the incremental cost effectiveness to
implement Regulatory Alternative 1 was judged to be unreasonable.
The Administrator selected Regulatory Alternative 1 for storage
tanks with a capacity of £76 m3 (20,000 gal) because there was no
incremental cost incurred to control to the higher level. For
these storage tanks, floating roofs would be the least costly
control technology to achieve the MACT floor control level of
41 percent. Because the floating roofs actually achieve
95 percent control, there would be no incremental cost between
the MACT floor and Regulatory Alternative 1.
8.2.1.3 Wastewater Systems. The Administrator selected
Regulatory Alternative 1 because it was judged to be technically
feasible, and the incremental cost effectiveness between the MACT
floor and Regulatory Alternative 1 was judged to be acceptable.
The incremental cost effectiveness is $3,070/Mg. This value was
judged to be acceptable based on decisions in previously
promulgated Part 63 rules for sources with organic HAP emissions.
As noted in Chapter 6, the regulatory alternative is based
on the wastewater requirements in the HON. Another reason for
selecting the regulatory alternative is that the PAI industry is
familiar with the HON requirements (because many PAI facilities
also have HON sources on-site) and would prefer to have similar
wastewater requirements for PAI sources.
8.2.1.4 Equipment Leaks. The Administrator selected
Regulatory Alternative 1 over the MACT floor because the LDAR
program in Regulatory Alternative 1 was judged to be technically
feasible to implement for this industry, and the cost was
determined to be reasonable. The incremental cost effectiveness
from the floor to Regulatory Alternative 1 is $546/Mg.1
8.2.2 New Sources
For new sources, the MACT floor shall be no less stringent
than the level of control achieved by the best performing similar
source. As noted in Chapter 6, no regulatory alternatives more
stringent than the floor were developed for process vents,
storage tanks, and equipment leaks because the floor represents a
high level of control that is at the limit of technical
8-15
-------
feasibility for each of these three planks. Therefore, the
Administrator selected the MACT floor for process vents, storage
tanks, and equipment leaks.
The Administrator selected Regulatory Alternative 1 for
wastewater systems because it is technically feasible at a
reasonable cost. The MACT floor was considered to be
unacceptable because the control requirement would be less
stringent than the existing source requirement for facilities
that have a total mass flow rate of Table 9 compounds less than
^,100 Mg/yr (2,300 tons/yr). Regulatory alternative 1 was
determined to be technically feasible for new sources, just as
for existing sources. While the characteristics (i.e., flow,
load, and HAP compounds) of wastewater streams at new sources are
not known, the wastewater streams at new sources are likely to be
similar to wastewater streams at existing sources. Because
wastewater streams at both existing and new sources are expected
to be similar, the costs and cost effectiveness for existing
sources would be applicable to new wastewater streams with
similar control levels. Therefore, the incremental cost
effectiveness of Regulatory Alternative 1 was estimated to be
$3,070/Mg.^ This value was judged to be reasonable for the
reasons described above in the discussion of the cost
effectiveness for existing sources.
Regulatory Alternative 2 for wastewater was determined to be
unacceptable because the incremental cost was high. Just as for
Regulatory Alternative 1, the wastewater streams at new sources
are assumed to be similar to wastewater streams at existing
sources. Therefore, costs were determined for all of the streams
(10 streams) at the surveyed plants that meet the applicability
criteria for Regulatory Alternative 2 but do not meet the
criteria for Regulatory Alternative 1. Eight streams were from
processes that had no other streams subject to Regulatory
Alternative 1, and the cost effectiveness to treat these streams
ranged from $96,500/Mg to $2,170,000/Mg.1 The remaining two
streams subject to Regulatory Alternative 2 were from processes
that had other streams that would require control under
8-16
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Regulatory Alternative 1, and the cost effectiveness to treat
these streams was $3,200/Mg and SlS^OO/Mg.1 Assuming the
distribution of wastewater s.treams at new sources would be
similar to the distribution at existing sources, the average
incremental cost effectiveness of Regulatory Alternative 2
relative to Regulatory Alternative 1 would be $226,000/Mg.1
8.2.3 Pollution Prevention Alternative
Rationale for the P2 standard is that, typically, a
reduction in consumption of HAP material can be associated with a
reduction in losses to air, water, or solid waste. The first P2
option requires that 85 percent reduction in the production-
indexed consumption factor be achieved from the 1987 baseline
year. The second P2 option requires that the production-indexed
consumption factor be reduced by at least 50 percent, and that
actual mass reductions equivalent to 35 percent of the kg/kg
value be achieved using add-on controls. A total reduction of at
least 85 percent will be required under both P2 options. The
basis of the 85 percent is the reduction from uncontrolled
wastewater load and uncontrolled emissions from process vents,
storage tanks, and equipment leaks achieved by the standards.
8.3 SELECTION OF THE FORMAT OF THE PROPOSED STANDARDS
Of the formats considered (mass emission limits, percent
concentration, percent reduction, equipment standards, work
practice standards), the percent reduction format was chosen for
the process vent and storage tank planks because it allows owners
and operators the most flexibility possible in achieving the
level of control required. For such diverse sources as batch
process vents, the percent reduction format, in conjunction with
strict definitions for the interpretation of the uncontrolled
baseline, allows for a consistent implementation of requirements
across the many types of process vent emission sources in the
industry. Because the majority of process vents result from
batch processing, characteristics of flow and concentration vary
with time; therefore, a concentration-based standard is not
feasible. Also, mass emission limits, which tend to encourage
facilities to reduce emissions through process changes, work
8-17
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practice changes, and other methods to avoid costly add-on
controls, cannot be universally applied to all process vents
because of the diversity in emission stream characteristics.
The proposed standards for wastewater adopt the formats
found in the HON. The formats include: (1) concentration limit,
(2) percent mass removal, (3) design and operation requirements,
or (4) mass flowrate limit. These alternative formats are
provided to sources for a maximum degree of flexibility in
complying with the wastewater provisions.
Concentration limits are provided as alternatives to allow
compliance flexibility for facilities required to treat
wastewater streams having low organic HAP concentrations. At
very low concentrations, it is technically more difficult and
costly to achieve a specific percent reduction.
The percent mass removal format is based on the organic HAP
removal efficiency of a steam stripper. However, any treatment
process that can achieve the control efficiency can be used to
comply with the standard.
An equipment design and operation format consists of either
(1) a steam stripper designed and operated at specific parameters
or (2) use of permitted RCRA hazardous waste incinerators,
permitted process heaters/boilers, or permitted underground
injection wells. Because the performance test and monitoring
requirements for these units are reduced or nonexistent, the
equipment standards provide an alternative with fewer monitoring
or performance test requirements.
The proposed LDAR program for equipment leaks is a
combination of an equipment standard/work practice format. Under
Section 112 of the Act, national emission standards must,
whenever possible, take the format of a numerical emission
standard. Typically, an emission standard is written in terms of
an allowable emission rate, performance level, or allowable
concentration. These types of standards require the direct
measurement of emissions to determine compliance. For some
emission points, emission standards cannot be prescribed because
it is not feasible to measure emissions. Section 112(h)(2)
8-18
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recognizes this situation by defining two conditions under which
it is not feasible to establish an emission standard. These
conditions are: (1) if the pollutants cannot be emitted through
a conveyance designed and constructed to emit or capture the
pollutant; or (2) if the application of measurement methodology
is not practicable due to technological and economic limitations.
If an emission standard cannot be established, EPA may instead
establish a design, equipment, work practice, or operational
standard or combination thereof.
The first condition is analogous to the situation involving
wastewater conveyance and collection systems for which a means of
demonstrating compliance with overall percent reduction is to
demonstrate that the system is completely closed to the
atmosphere.
For equipment leak emission points, such as pumps and
valves, EPA has previously determined that it is not feasible to
prescribe or enforce emission standards. Except for those items
of equipment for which standards can be set at a specific
concentration, the only method of measuring emissions is total
enclosure of individual items of equipment, collection of
emissions for a specified time period, and measurement of the
emissions. This procedure, known as bagging, is a time-consuming
and prohibitively expensive technique considering the great
number of individual items of equipment in a typical process
unit. Moreover, this procedure would not be useful for routine
monitoring and identification of leaking equipment for repair.
Therefore, EPA established a combination of work practice and
equipment standards for equipment leaks (although a percent
reduction format is also specified for equipment leak emissions
that are routed through a closed vent system to a control
device).
The P2 alternative standard is in the format of a process
specific production-indexed material consumption limit. This
unique format allows for tracking of material consumption, while
considering fluctuations in production rates. A very important
8-19
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facet of this format is that demonstration of compliance is
achieved through periodic tracking of production and consumption.
0.4 RATIONALE FOR THE SELECTION OF COMPLIANCE AND PERFORMANCE
TESTING PROVISIONS AND MONITORING REQUIREMENTS
The proposed regulation contains compliance provisions that
will require owners or operators to conduct an initial
performance test on control devices that handle greater than
10 tons/yr of HAP to demonstrate compliance with the proposed
standards. For devices controlling streams totaling less than
10 tons/yr, design evaluations or emission estimation
methodologies can be used to calculate reduction efficiencies and
make compliance demonstrations. As a means of demonstrating
compliance with the standards following the initial performance
test or other initial compliance demonstration, the owner or
operator must also establish source-specific parameters based on
the characteristics of the emission stream, process, or type of
control device used. The Administrator determined that these
provisions were necessary to meet the monitoring requirements of
the General Provisions (40 CFR 63, subpart A).
8.4.1 Testing and Monitoring
Compliance is comprised of (1) initial performance testing
or compliance determination and (2) continuous compliance
verification or monitoring. The proposed requirements for
initial compliance testing and any periodic or continuous
measurement to verify ongoing compliance are based on the
emission stream characteristics that would be encountered either
at the inlet and outlet of the control device or at the point of
release to the atmosphere for uncontrolled emission streams.
Figure 8-5 presents a logic diagram for the demonstration of
initial compliance. As shown in Figure 8-5, an initial
performance test would be required only if the total of
uncontrolled HAP routed to a control device is greater than
10 tons/yr. For condensers handling uncontrolled emissions in
excess of 10 tons/yr, no performance test is required, provided
the condenser is equipped with a temperature sensor and recorder.
8-20
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63.1364: Datermme yearty uncontrolled HAP
ermsskms from all procMi vents using.
(b) testing
(e)(1)(0 equations. H appropriate
(Od )(H) •nglnMrlng aMeaements, If
equations are not appropriate
Is total of uncontrolled HAP*
from all procaaa vatita to each control
device £lOtona/yr?
to control device a
bolter, proeaaa heater, hazardous
watte Incinerator, or flara that maata
(d)(3)(i*v). • condansarttiat maata
(0(5){V): or a control device for
which a pravtoua teat waa
Eondudad according
No performance tact
required for control
device, uaa a detign
evaluation, ammawn
calculatona. or previoue
last data to detarmna
controeed emtaaiona
Performance last
required to calculate
controlled amtaaions
Are any
enuitions from batch
procaaa(aa)?
Determine performance
tail condtwns according to
63 1364(c)(3)<*)
Batch test
provisions
Conduct test according to
63 l364(b)(9)(N) under absolute
peak-case, representative
peak-case hypothetical
peak-case o» normal conditions
Continuous last
provisions m
§63l364(b)(9)(i)
Flow and concentration
measurements required
Is control device
a condense^
Three 1-hour runs
Direct
measurement
of temperature
• atowed
Teat 1 run of
peek-case, not to
anouny
Figure 8-5. Initial compliance determination—process vents
8-21
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Initial performance tests would not be required for flares
because measurement of the percent reduction and outlet
concentration is not feasible, but flares must meet the
requirements in section 63.11. Performance tests also would not
be required if the device is a boiler, process heater, or
hazardous waste incinerator that meets certain criteria. In
addition, if a previous test was conducted at conditions that
meet test criteria, the results of the previous performance test
can be used to calculate controlled emissions. Uncontrolled and
controlled emissions are the only parameters needed to
demonstrate compliance with the percent reduction requirement.
The demonstration that emission points within various plants
meet emission limits (i.e., 330 Ib/process for process vents) is
based on the calculation or measurement of controlled emissions.
For batch performance testing, owners and operators have the
option of testing during peak conditions in addition to normal
conditions. Peak conditions are defined in three ways: absolute
peak-case, hypothetical peak-case, and representative peak-case.
Absolute peak-case conditions have been defined as the period of
time in which the pollutant stream entering the device will
contain any of the following: (1) at least 50 percent of the
total HAP load from the combination of processes that could
concurrently be emitted to the device, not to exceed 8 hours, (2)
the highest hourly HAP mass loading rate from the combination of
episodes that can concurrently be emitted to the device, or (3)
the highest hourly heat load from the combination of episodes
that can concurrently be emitted to the device if the device
being tested is a condenser. An option to simulate such
conditions is also available in the rule, if the owner or
operator cannot predictably produce peak-case conditions; this
option is referred to as hypothetical peak case.
The intent of testing under peak-case conditions is to
document the control efficiency of the device under its most
challenging conditions and thereby establish a lower limit of the
expected efficiency of the device for the purposes of documenting
initial and continuous compliance with the standard. Presumably,
8-22
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the device should function as well or better under conditions
that are not as challenging. Owners or operators have the option
to test all control devices under absolute or hypothetical test
conditions. Additionally, for incinerators, owners and operators
may conduct performance testing under representative peak-case
conditions provided that they operate the incinerator within
design constraints. Representative peak-case conditions must
include the highest HAP mass loading rate, in Ib/hr, from a
single process, as well as any other emission events that are
emitting to the control device during the test.
Testing under normal conditions is also allowed for all
control devices, provided that the conditions under which testing
is conducted are never exceeded during operation of the device.
w.4.2 Selection of Test Methods and Criteria for Performance
Testing
An important characteristic to consider when evaluating
measurement methods are whether the streams are from continuous
sources or whether they are from batch sources. Streams that are
from continuous sources would have minimal variation in
characteristics; the test measurement method therefore can be
intermittent in nature. For example, flowrate and concentration
can be sampled on an intermittent basis to obtain an average
emission value that presumably will not vary significantly.
Batch emission streams, however, are expected to have wide
variation in flowrate, composition, and conditions throughout the
course of a batch (i.e., with time). Often, proportional
sampling of flowrate and composition over the course of « batch
to arrive at a total emission number over the entire batch is
necessary (i.e., the sampling flowrate must be adjusted as needed
throughout the entire sampling time to be consistent with the
flow rate from the process). Alternatively, simultaneous
measurement of flowrate and composition must be made to arrive at
an instantaneous emission rate. Because these methods are
difficult, an initial compliance demonstration requiring testing
is required only for control devices that handle HAP emissions of
greater than 10 tons/yr. Rationale for this criterion is based
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on the application of the major source cutoffs. Specifically for
this NESHAP, equations are provided in the regulation to
determine HAP emissions from various PAI production process
vents.
A second important characteristic of the emission stream to
consider during selection of a test method is the composition.
If organic material other than HAP are contained in the stream,
it may be necessary to speciate the stream or at least identify
the HAP constituents in the stream. This identification limits
how continuously the stream can be sampled. The most common
technology that will be used in identification is gas
chromatography, specified in EPA Reference Method 18 of 40 CFR
part 60, appendix A. Gas chromatography, coupled with the
quantification of material typically done with a. flame-ionization
device (FID), EPA Reference Method 25A, can be done at sub-minute
intervals, but not continuously. However, if identification of
organic species is not necessary, an FID alone can be used. This
technology can provide a continuous reading of organic
concentration.
8.4.3 Consideration of Control Devices in Monitoring and
Performance Test Requirements
The devices used to abate HAP emissions will affect the
outlet stream composition and conditions and therefore affect the
degree of confidence of the initial and continuous compliance
methods. Devices that are commonly used in the PAI production
industry to control process vents and storage tank emissions are
condensers, gas absorbers (water scrubbers), carbon adsorbers,
and incinerators. These devices differ from one another in the
type of streams that they control and the outlet conditions of
the streams and should be considered in establishing monitoring
requirements. A discussion of specific control devices and
consideration for establishing monitoring parameters and-
performance test requirements is presented below.
8.4.3.1 Condensers. In the case of condensers, which are
usually applied to saturated emission streams and by design yield
saturated streams, it can be assumed that the components will be
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present at levels corresponding to their saturated values
(equilibrium) at the outlet conditions. This measure provides a
worst-case estimate of emissions. Therefore, the direct
measurement of concentration often may be foregone in lieu of the
measurement of stream temperature and flow rate and subsequent
calculation to yield mass emissions. For batch reactors in this
industry, this is the required measurement to determine HAP
concentration.
8.4.3.2 Gas Absorbers. Gas absorbers (water scrubbers),
however, differ in that there is no parameter that can be
measured and used to establish a limit of HAP concentration.
Often, the streams routed to scrubbers are more dilute, and the
control device functions in not only changing the conditions of
the gas temperature like a condenser would do, but in employing
concentration gradients to remove materials from gas streams. In
order to predict the performance of « gas absorber, information
must be known about the appropriate mass transfer coefficients
for the specific system. Most often, the mass transfer
coefficients are experimentally derived for specific applications
and are usually functions of the mass velocities and contacting
path variables. While it is possible to calculate the scrubber
outlet compositions without mass transfer information by assuming
that the amount of material transferred to the liquid is limited
by the equilibrium-defined composition, this information is not
indicative of the physical scrubber because it does not provide
for the evaluation of the contacting path. Therefore, a direct
measurement of composition is required during the initial
performance test.
Evaluation of continuous compliance need not be done by
continuous direct measurement of HAP concentration from the
scrubber effluent, however. Another parameter, the liquid to gas
molar ratio through the scrubber, can be monitored on a
continuous basis to ensure required removal. The L/G ratio,
which often reduces to the measurement of L, the liquid molar
flow rate, because G, the gas molar flow rate is often constant,
can be measured during the initial performance test to evaluate
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the sensitivity of the ratio with removal efficiency.
Thereafter, the L/6 ratio can be used to verify removal on a
continuous basis by comparison to the limits established during
the initial compliance test.
8.4.3.3 Carbon Adsorbers. Streams controlled by carbon
adsorption will usually be dilute, compared to those controlled
by condensers and scrubbers. No surrogate parameters have been
identified as measures of HAP concentration or removal
efficiencies. Therefore, a direct measurement of uncontrolled
and controlled emissions (i.e., concentration and flowrate) will
be required during the initial performance test as well as in
continuous compliance monitoring.
8.4.3.4 Incinerators. Incinerators are sometimes used in
this industry to control emission streams that have been
manifolded together from one or more processes. As such, they
often contain mixtures of HAP's and other organics. An initial
performance test of incinerator efficiency involving the direct
measurement of stream composition is required. The continuous
monitoring of incinerator operating parameter such as combustion
temperature is required for continuous compliance demonstrations.
8.4.3.5 Wastewater. The proposed testing and monitoring
requirements for wastewater are based on the requirements in the
HON. Further, the treatment systems and control devices likely
to be used in complying with the proposed requirements were
already considered as part of the HON. As a result, EPA has
determined that there is no need to change performance testing
provisions or the parameters selected for monitoring.
Performance testing provisions are specified in 40 CFR 63.145,
and monitoring requirements are specified in 40 CFR 63.143.
Rationale for the selected provisions was presented in detail in
the proposal and promulgation preambles to the HON, and in the
preamble for the proposed amendments to the final rule. The
discussion below summarizes the rationale for the selected
provisions.
Initial performance tests for control of Group 1 wastewater
streams are not required by the proposed rule for nonbiological
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or closed biological treatment processes. For these treatment
processes, facilities have the choice of using either performance
tests or design evaluations (i.e., engineering calculations) to
demonstrate the compliance of these units with the standards.
Engineering calculations, supported by the appropriate
documentation, were allowed to provide a less costly alternative
to that of testing.
The proposed rule requires performance tests for open
biological treatment processes because volatilization is an
important issue for these treatment processes. To demonstrate
compliance, the owner or operator must determine the mass of
Table 9 compounds that is removed by biodegradation rather than
volatilization. However, the proposed rule exempts a facility
from the performance test requirement if the open biological
treatment system meets the definition of an enhanced biological
treatment system, and it receives streams that contain only
compounds in List 1 on Table 36 of the final amendments to the
HON. The compounds on List 1 have fraction biodegraded (F^Q)
values approximately equal to or higher than their fraction
removed (Fr) values, and their fraction emitted (Fe) values are
in the middle to lower volatility range. In an enhanced
biological treatment system, the compounds on List 1 are more
readily biodegraded than the other HAP compounds, with minimal
volatilization. Therefore, the EPA believes that the proposed
exemption provides additional flexibility without sacrificing
emissions reductions.
If the design steam stripper option is selected to comply
with the control requirements, neither a design evaluation nor a
performance test is required. 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.
The proposed wastewater provisions include requirements for
periodic monitoring and inspections to ensure proper operation
and maintenance of the control system and continued compliance.
Waste management units are required to be visually inspected
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semiannually for improper work practices and control equipment
failures that potentially may be a source of emissions. For
biological treatment processes, the proposed rule requires the
owner or operator to submit a request for approval from the
permitting authority to monitor appropriate parameters. For
steam strippers, the proposed rule requires continuous monitoring
of the steam flow rate, the wastewater feed mass flow rate, and
the wastewater feed temperature. Continuous monitoring is
necessary to ensure proper operation of the stripper, thereby
maximizing emission reductions. The proposed rule also includes
monitoring requirements for control devices used with vapor
collection or closed vent systems. The monitoring equipment,
parameters, and frequency of monitoring for each control device
are given in the proposed rule. The parameters were selected
because they are good indicators of control device performance,
and instruments are available at a reasonable cost to monitor
these parameters.
8.4.3.6 Storage Tanks. Storage tank emissions vary greatly
over time, which precludes testing over reasonable periods of
time. Therefore, no initial compliance test is proposed for this
emission point, unless emissions are manifolded with process
vents, in which case the compliance tests specified for process
vents apply. For any tank that is not controlled with a floating
roof, the proposed rule requires an owner or operator to prepare
a design evaluation. The design evaluation consists of
documentation showing the control device achieves the required
control efficiency when the tank is filled at the reasonably
expected maximum rate. The needed documentation includes a
description of the gas stream entering the control device, and
the design and operating parameters for the control device.
Because storage tank emissions are not dependent on parameters
that can be controlled, no continuous monitoring requirements are
proposed for this emission point, except that facilities that
control storage tank emissions must certify that such control
devices are in proper working order.
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To determine that a storage tank is exempt from the control
requirements, existing and new sources must demonstrate that the
uncontrolled emissions are less than 240 Ib/yr and 1 Ib/yr,
respectively. The proposed rule specifies the methods to use to
calculate these emissions.
8.4.3.7 Equipment Leaks. Like wastewater emissions,
equipment leak emissions occur in open areas and in most cases
cannot feasibly be captured. Therefore, no performance test is
required for equipment leaks. Instead, facilities must
demonstrate that they have an LDAR program in place that meets
the proposed requirements. No monitoring requirements other than
those contained in the LDAR requirement are proposed for
equipment leaks, as the proposed standard for equipment leaks is
a work practice/equipment standard.
8-4.4 Averaging Times
8.4.4.1 Initial Compliance. For continuous processes, a
1-hour averaging time is specified for process vent compliance
tests; the emission rate would be the average of the results of
three 1-hour tests. For batch process vents, the uncontrolled
and controlled emission rates used to determine compliance would
be the average of three tests taken over three runs or one test
taken over a longer period of time.
Averaging times for wastewater treatment system control
efficiency determinations should be taken over three 1-hour runs.
as specified in 40 CFR 63.145(c).
8-4.4.2 Monitoring. Figure 8-6 presents a logic diagram
for monitoring requirements. For control devices handling over
0.91 Mg/yr (1 ton/yr) emissions from continuous processes,
monitoring systems measuring either emissions or an operating
parameter shall complete a minimum of one measurement cycle
(sampling, analyzing, and data recording) for each successive
15-minute period during which time the device is operating in
reducing emissions.
Owners and operators complying with the standard may be
determined to be out of compliance with the standard if, for any
24-hour period, the average operating parameter value exceeds or
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Nomontarin
mentorin
Figure 8-6. Monitoring provisions—process vents
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is less than the value established during the initial compliance
demonstration, as applicable.
For control devices handling emissions of less than
0.91 Mg/yr (1 ton/yr), only a periodic verification that the
device is operating properly is required. This verification is a
site-specific determination which requires approval from the
Administrator.
8.5 SELECTION OF REPORTING AND RECORDKEEPING REQUIREMENTS
The owner or operator of any PAI manufacturing facility
subject to these standards would be required to fulfill reporting
requirements outlined in the General Provisions of 40 CFR part 63
and in the rule.
8.6 OPERATING PERMIT PROGRAM
Under Title V of the CAA, all HAP-emitting facilities will
be required to obtain an operating permit. Often, 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 that 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 permitting program,
the owner or operator of a source must submit the application
under the proposed General Provisions of 40 CFR part 63.
8.7 REFERENCE FOR CHAPTER 8
1. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:ESD. April 30, 1997. Cost Impacts of
Regulatory Alternatives for the Pesticide Active Ingredient
Production NESHAP.
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