Hazardous Air Pollutant Emissions from
Magnetic Tape Manufacturing
Operations—Background Information
for Technology and Residual Risk
Review
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EPA-453/R-05-001
July 2005
Hazardous Air Pollutant Emissions from Magnetic Tape Manufacturing Operations-
Background Information for Technology and Residual Risk Review
By:
RTI International
Research Triangle Park, North Carolina
Prepared for:
H. Lynn Dail, Work Assignment Manager
Emission Standards Division
Contract No. 68-D-01-079
Work Assignment No. 3-06
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Standards Division
Research Triangle Park, North Carolina
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Disclaimer
The U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards,
Emission Standards Division has reviewed this report and has approved it for publication.
Mention of trade names or commercial products is not intended to constitute endorsement or
recommendation for use.
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Laee
TABLE OF CONTENTS
List of Tables iv
List of Acronyms and Units of Measure v
Chapter 1 Introduction and Summary 1-1
1.1 Statutory Authority and Mandate 1-1
1.2 NESHAP Source Category 1-2
1.3 References 1-2
Chapter 2 Magnetic Tape Manufacturing 2-1
2.1 Industry Description 2-1
2.1.1 Manufacturing Process Overview 2-1
2.1.2 SIC and NAICS Codes 2-1
2.1.3 Emission Points 2-2
2.1.4 Status of the Industry 2-6
2.2 Baseline Emissions 2-8
2.3 References 2-10
Chapter 3 Existing Regulations 3-1
3.1 Summary of New Source Performance Standards 3-1
3.2 Summary of State Regulations 3-2
3.3 Summary of Promulgated NESHAP 3-3
3.4 References 3-5
Chapter 4 Technology (MACT) Review 4-1
4.1 Status of Industry Technology 4-1
4.2 Identification and Measurement of HAP Used 4-2
Chapter 5 Residual Risk Analysis 5-1
5.1 Data Collection 5-2
5.1.1 Pollutants 5-2
5.1.2 Source Identification 5-3
5.1.3 Source Characterization 5-3
5.2 Risk Analyses 5-4
5.3 References 5-8
Chapter 6 Risk Reduction Options 6-1
6.1 EPA Decision of MACT Adequacy 6-1
6.2 Feasibility of Additional Controls to Reduce Risk 6-2
6.3 EPA Decision of No Rulemaking Action 6-3
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LIST OF TABLES
2-1 Magnetic Tape Manufacturing Facilities in the United States 2-7
2-2 Recent HAP Emissions from Magnetic Tape Manufacturing Facilities 2-9
2-3 Summary of Total HAP Emissions 2-10
3-1 Summary of the Magnetic Tape Manufacturing Standard 3-4
5-1 Summary of Residual Risk for Magnetic Tape Manufacturing Facilities 5-5
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LIST OF ACRONYMS AND UNITS OF MEASURE
ATSDR Agency for Toxic Substances and Disease Registry
CAS Chemical Abstracts Service
CD compact disc
CEM continuous emission monitor
CFR Code of Federal Regulations
CTG control techniques guideline
dL deciliter
DVD digital video disc
EPA U.S. Environmental Protection Agency
FR Federal Register
g gram(s)
gal gallon(s)
HAP hazardous air pollutant(s)
HEM Human Exposure Model
HI hazard index
IEUBK Integrated Exposure Uptake Biokinetic Model for Lead in Children
ISCST3 Industrial Source Complex-Short-Term
kg kilogram(s)
L liter(s)
Ib pound(s)
m3 cubic meter(s)
MACT maximum achievable control technology
MEK methyl ethyl ketone
Mg megagram(s)
mg milligram(s)
MIBK methyl isobutyl ketone
MIR maximum individual lifetime risk(s)
MRL minimum risk level
NAICS North American Industrial Classification System
NEI National Emissions Inventory
NESHAP national emission standards for hazardous air pollutants
NSPS new source performance standards
PB persistent and bioaccumulative
PbB blood lead concentration
ppmv part(s) per million by volume
RfC reference concentration
SIC Standard Industrial Classification
SSR solid state recording
ton tons
TRI Toxics Release Inventory
VOC volatile organic compound
yr year(s)
/ag microgram(s)
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Chapter 1
Introduction and Summary
1.1 STATUTORY AUTHORITY AND MANDATE
Under section 112(d) of the Clean Air Act as amended in 1990 (the Act), the
U.S. Environmental Protection Agency (EPA) promulgated national emission standards for
hazardous air pollutants (NESHAP) for the magnetic tape manufacturing operations source
category on December 15, 1994 (59 FR 64596). The final rule was codified as subpart EE to Part
63 of the Code of Federal Regulations (CFR). These national emission standards are technology-
based and are also known as maximum achievable control technology (MACT) standards. The
standards apply to new and existing sources of hazardous air pollutants (HAP) as listed in section
112(b) of the Act. Section 112(d)(6) of the Act requires EPA to review and revise, as necessary
(taking into account developments in practices, processes, and control technologies), emission
standards promulgated under this section no less often than every 8 years.
The NESHAP covers sources that are major sources of HAP. Major sources of HAP are
those that emit, or have the potential to emit, 9.1 megagrams per year (Mg/yr) (10 tons per year
[ton/yr]) or more of any one HAP or 22.7 Mg/yr (25 ton/yr) or more of any combination of HAP.
The NESHAP also applies to any magnetic tape manufacturing operations located at a major
source of HAP emissions (i.e., co-located emission sources), even if the magnetic tape
manufacturing operations, by themselves, are not major sources of HAP emissions.
Section 112(f)(2) of the Act directs EPA to assess the risk remaining (residual risk) after
the application of MACT standards developed under section 112(d). This section of the Act
states that:
...the Administrator shall, within 8 years after promulgation of standards for each category
or subcategory of sources pursuant to subsection (d), promulgate standards for such
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category of subcategory if promulgation of such standards is required in order to provide
an ample margin of safety to protect public health in accordance with this section (as in
effect before the date of enactment of the Clean Air Act Amendments of 1990) or to
prevent, taking into consideration costs, energy, safety, and other relevant factors, an
adverse environmental effect.
1.2 NESHAP SOURCE CATEGORY'2
The magnetic tape manufacturing industry uses a primary coating process in which a
mixture of magnetic (metal) particles, resins, and solvents (the coating mix) is applied to either a
plastic film (tape) or paper. The HAP that have been used in this industry include methyl ethyl
ketone (MEK), methyl isobutyl ketone (MIBK), toluene, toluene diisocyanate, ethylene glycol,
methanol, xylenes, chromium, cobalt, ethylbenzene, and acetaldehyde. The most common HAP
solvents are MEK and toluene. The non-HAP solvents that have been used in this industry
include cyclohexanone, acetone, and isopropyl alcohol. Some of the HAP and non-HAP
compounds listed above are no longer used in this industry.
Magnetic media on plastic film are used primarily for audio and video recording (audio-
and videotape cassettes) and computer information storage (datatape, diskettes). Other uses of
magnetic media on plastic film include magnetic cards, credit cards, bank transfer ribbons,
instrumentation tape, and dictation tape. Magnetic coatings on paper are used for toll tickets,
airline boarding passes, and security badges.
1.3 REFERENCES
1. U.S. Environmental Protection Agency. Hazardous Air Pollutant Emissions from
Magnetic Tape Manufacturing Operations - Background Information for Proposed
Standards. Research Triangle Park, NC. EPA-453/R-93-059. December 1993.
2. U.S. Environmental Protection Agency. Hazardous Air Pollutant Emissions from
Magnetic Tape Manufacturing Operations - Background Information for Promulgated
Standards. Research Triangle Park, NC. EPA-453/R-94-074b. December 1994.
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Chapter 2
Magnetic Tape Manufacturing
2.1 INDUSTRY DESCRIPTION'2
2.1.1 Manufacturing Process Overview
In the magnetic tape manufacturing process, a mixture of magnetic (metal) particles,
resins, and solvents (the coating mix) is applied to either a plastic film (tape) or paper. The HAP
emissions are predominantly from solvents used in the coating operation and in the cleaning of
equipment. The primary HAP currently associated with magnetic tape surface coating are MEK
(68 percent of reported emissions) and toluene (29 percent).
The solvent HAP emissions result from the evaporation of solvents from the (1) storage
tanks, (2) coating mix preparation area, (3) coating application/flashoff area, (4) drying oven,
(5) packaging and labeling operations, (6) waste handling area, (7) cleaning activities, and (8) pipe
fittings. The drying oven and the coating mix area are typically the largest solvent HAP emission
sources.
The magnetic particles are combinations of iron, chrome, and cobalt. Particulate HAP
emissions can result from handling of materials, cleaning of process equipment, and adding dry
media to mix tanks during coating mix preparation.
2.1.2 SIC and NAICS Codes
The magnetic tape manufacturing industry is predominantly included in Standard Industrial
Classification (SIC) codes 3695, "Magnetic and Optical Recording Media"; 2672, "Coated and
Laminated Paper, Not Elsewhere Classified"; and 3861, "Photographic Equipment and Supplies."
Those same industry groups are covered under North American Industrial Classification System
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(NAICS) codes 334613, "Magnetic and Optical Recording Media Manufacturing"; 322222,
"Coated and Laminated Paper Manufacturing"; and 325992, "Photographic Film, Paper, Plate,
and Chemical Manufacturing."
2.1.3 Emission Points
In the course of developing the NESHAP for magnetic tape manufacturing, EPA
examined for potential control all known HAP emission points associated with the manufacturing
process. These emission points are described in the following subsections.
2.1.3.1 Solvent Storage Tanks
Small tanks are generally used to store the solvent HAP, which may be virgin material,
spent solvent from cleaning or off-specification mixes, or solvent from any stage of the solvent
recovery process. The tanks operate at or slightly above atmospheric pressure. A facility
typically has from 1 to 12 storage tanks, with a total capacity ranging from 757 to 75,700 liters
(L) (200 to 20,000 gallons [gal]). As discussed in the MACT rule, storage tanks do not refer to
tanks that are part of the process (e.g., mix preparation equipment). The HAP emissions from
storage tanks occur through working losses during tank loading or through breathing losses due
to diurnal temperature changes.
2.1.3.2 Mix Preparation Equipment and Paniculate Transfer Operations
Mix preparation usually takes place in a room or rooms separated from the coating line.
The components of the mix are first blended and then transferred to a series of mills to disperse
the aggregates of magnetic particles without reducing particle size. The mix is circulated and
filtered in holding tanks to prevent binders from curing, to prevent metal particles from settling
out, and to remove any oversize contaminants. The coating mix is pumped to and from the
different pieces of mix preparation equipment through closed lines. The mix preparation
equipment controlled by the MACT standards includes all of the equipment used in preparing the
coating mix, including mixers, holding tanks, and polishing tanks. Mills are not included as mix
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preparation equipment, because they operate under pressure and, therefore, no emissions are
expected, nor could they be vented to a control device.
Particulate HAP can be either transferred through closed systems or manually poured
through hatches in the covers of the mix preparation equipment. A small amount of particulate
HAP is emitted while transferring particulate from the bag or storage bin to the mix tank.
2.1.3.3 Coating Operations
In the coater, the substrate to be used for the magnetic or leader tape passes over a
support roll while the coating mix is applied. The thickness and amount of coating applied vary
with the product. During the coating application step, some solvent HAP will volatilize. The
amount emitted depends on site-specific variables, such as the coating mix composition and the
type of coater. Immediately following the coater, the magnetic tape is guided through an
orientation field consisting of an electromagnet or permanent magnet, which aligns the individual
magnetic particles in the direction of the intended recording. (Leader tape does not go through
the orientation process, because magnetic particles are not used.) The magnetic or leader tape is
passed through a drying oven, where the remaining solvents in the coating mix evaporate. Any
solvents on the coated tape that are going to evaporate are expected to do so by this point in the
process; therefore, no solvent evaporation is expected in subsequent steps. After drying, the
finished product may be (1) calendered to compact the dry coating and smooth the surface; (2) slit
to the desired width; and (3) packaged and labeled, either in parts produced in-house or in
prepurchased plastic casings.
2.1.3.4 Cleaning Activities
Cleaning is performed differently at each plant. Some plants may clean equipment
between each batch of coating, while others may clean only between product changes. At some
plants, virgin solvent is used once and immediately treated as a waste. At other plants, cleaning
solvent may be used several times before it is considered "spent." Four basic categories of
cleaning activities have been identified for this industry: (1) flushing fixed lines; (2) cleaning
tanks; (3) cleaning fixed exterior surfaces; and (4) cleaning miscellaneous removable parts.
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The flushing of fixed lines involves flushing solvent through fixed lines not associated with
the cleaning of a tank (e.g., the line from the mix preparation equipment to the coaler). A fixed
line is one that is stationary during normal operation but can be removed from its original location
for cleaning. Emissions can occur if the solvent used for cleaning, or collected after cleaning, is
exposed to the air.
Tank cleaning may be either an open-top or closed-top process. Open-top tank cleaning is
the practice of cleaning a tank that either has no cover or whose cover has been removed.
Solvent may be added and drained via buckets or pipes. The interior of the tank may be manually
cleaned with brushes while the solvent is in it. Closed-top tank cleaning is the practice of cleaning
a tank while using a cover that seals the top of the tank. Solvent is added to and drained from the
tank via pipes. An automated brush inside the tank may scrub the sides while the solvent is in the
closed tank. Emissions occur when the solvent used in the cleaning process is exposed to the air.
In a closed system, equipment leak emissions also occur. Based on test data from industry,
emissions from both types of cleaning processes are approximately equal.
Cleaning fixed exterior surfaces involves cleaning the surface area of a fixed piece of
equipment with rags or brushes. The solvent on the rag or brush evaporates to the air. The
surfaces to be cleaned are typically on the coater. The ventilation system of the enclosure around
the coater draws these emissions to the outside air.
Cleaning removable parts involves cleaning parts that have been moved from their normal
position to a wash tank or a sink that contains solvent. The solvent is volatile and, thus,
evaporates into the air above the wash tank or sink. The sink is usually ventilated; consequently,
emissions are discharged to the atmosphere.
Rags used for miscellaneous cleaning activities will contain some residual solvent and will,
therefore, contribute to air emissions.
2.1.3.5 Waste Handling Devices
The two waste handling devices most commonly used in the magnetic tape manufacturing
industry are pot stills and filter dryers. Both devices recover solvents from waste materials. In a
pot still, liquid wastes are pumped through closed piping into the pot still and heated to evaporate
the solvent portion of the waste. A filter dryer is used to treat solid wastes, such as filters, rags,
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and brushes, which are manually placed in the dryer and heated to evaporate the solvent portion.
With both pot stills and filter dryers, the evaporated solvent is condensed, and the recovered
liquid is sent to a storage tank. Air emissions may occur through the condenser vent.
2.1.3.6 Wastewater Treatment
At magnetic tape manufacturing facilities, the only significant source of wastewater that
contains HAP results from steam desorption of the carbon adsorption system beds used to recover
HAP solvent from the air stream. After the steam desorbs the carbon adsorber bed, the
solvent/water mixture is condensed and separated by gravity into distinct solvent and water
phases.
The solvent phase is distilled to separate it into its individual components. Potential air
emissions could result from residual solvents in the water phase if the water phase is not further
treated prior to discharge to the publicly owned treatment works. At magnetic tape
manufacturing facilities, the water phase is treated through steam stripping to remove residual
solvent. The solvent compounds recovered through steam stripping are then purified into the
individual solvent components.
2.1.3.7 Condenser Vents in the Solvent Recovery Area
The solvent recovery area is that area in the plant that contains the equipment used to
(1) remove HAP solvent from the air stream, (2) recover the solvent, and (3) purify the solvent
for reuse in the process. At magnetic tape manufacturing facilities, this equipment would include
the control device (a carbon adsorption system or condenser), the wastewater treatment system
(in the case of carbon adsorbers), and distillation units. Emissions of HAP to the air occur in the
solvent recovery area from atmospheric condenser vents, including condenser vents on the steam
stripper distillation columns and condenser vents to condense steam from carbon adsorber
regeneration. The vent on a condenser that is used as a primary emission control device is not
considered part of this emission point.
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2.1.3.8 Equipment Leaks
In magnetic tape manufacturing operations, solvent is pumped through piping and process
equipment as it travels to or from storage tanks and from the mix preparation equipment to the
coater. Facilities that perform onsite solvent recovery and wastewater treatment will also have
process piping and equipment within these areas. Volatile HAP will be emitted through leaks
from equipment such as pumps, compressors, pressure relief devices, sampling connection
systems, open-ended valves or lines, and flanges or any other connecter in volatile organic
compound (VOC) service.
2.1.3.9 Packaging and Labeling
The packaging and labeling process occurs after the product has been coated, rewound,
and slit into the desired width (or punched into diskettes). Whatever the final form of the
product, printed materials such as labels, boxes, and inserts are usually part of the final package.
Most facilities purchase these items preprinted. Some facilities use ink jet printers to print
product identification codes on boxes. This operation can involve small amounts of HAP solvents
(contained in the ink) that volatilize as the ink dries.
2.1.4 Status of the Industry
In March 1994, 25 existing magnetic recording media and magnetic stripe manufacturing
facilities were identified in the course of NESHAP development. Those 25 facilities were owned
by 21 companies, and 14 of those 25 facilities were estimated to be major sources of HAP and,
thus, would have been affected by the regulation. As of July 2005, 6 magnetic tape
manufacturing facilities are still in operation in the United States, with 3 of the 6 located in
Alabama. Four of the 6 facilities are considered major sources of HAP, based solely on the level
of HAP emissions from their magnetic tape manufacturing operations, while the other two
facilities can be considered major sources because they are located at major source facilities.
Table 2-1 lists the six facilities identified as having magnetic tape manufacturing operations and
presents verified information on their location.
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Table 2-1. Magnetic Tape Manufacturing Facilities in the United States
Facility name and address
Quantegy Inc.
2230 Marvyn Parkway
Opelika, AL 36801
JVC Magnetics America Co.
#1 JVC Road
Tuscaloosa, AL 35405
Sony Magnetic Products Inc. of America
4275 W. Main Street
Dothan, AL 36305
3M Magnetic Tape Manufacturing Division
905 -915 Adam Street S.E.
Hutchinson, MN 55350
Eastman Kodak Co. - Kodak Park Plant
1669 Lake Avenue
Rochester, NY 14652
Imation Enterprises Corp.
2700 East Frontage Road
Weatherford, OK 73096
County
Lee
Tuscaloosa
Houston
McLeod
Monroe
Custer
Latitude
32°3728"
33° lO^"
31°13'56"
44°52'49"
43°12'10"
35 "3203"
Longitude
85°2224"
87°27'30"
85°2728"
94°21'32"
77°37'45"
98040'25"
SIC
code
3695
3695
3695
3695;
2672
3861
3695
NAICS
code
334613
334613
334613
334613;
322222
325992
334613
Magnetic
tape products
audio-, video-,
and datatape
audio- and
videotape
audio-, video-,
and datatape
audio- and
videotape
Advantix film
diskettes,
datatape
The shrinkage of the domestic magnetic tape manufacturing industry, resulting in many of
the plants closing in the United States, has been ascribed to competition from foreign producers,
which have lower production costs (primarily labor costs) than domestic producers. Industry
contacts have also noted that both domestic and foreign competitors have been consolidating their
operations. In addition, compact discs (CDs) and digital video discs (DVDs) have replaced most
audio- and videotape cassettes in today's market.
Two new technologies may eventually supplant magnetic recording media: optical
recording media and solid state recording (SSR) media. Optical recording devices use lasers to
record electronically encoded information onto a reflective disk. Currently, optical disks are used
to store extremely large amounts of data, much like computer tape and cartridges. Optical
recording devices are generally much more expensive than current technologies for recording
purposes and, therefore, have not been used extensively. Solid state recording devices eliminate
the need for mechanical devices (to move tape or rotate a disk) by using other types of technology
(e.g., semiconductor memory). This technology is in the early to intermediate stage of
development.
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In the mid-1990s, production of magnetic tape products reached its peak. In the late-
1990s and early-2000s, magnetic tape products were increasingly replaced by optical recording
media, particularly in prerecorded applications (e.g., prerecorded music and movies). Market
value for tape products continues to fall as optical media and SSR media penetrate the market.
2.2 BASELINE EMISSIONS29
In 1994, EPA estimated that the NESHAP for the magnetic tape manufacturing source
category would reduce baseline HAP emissions (4,060 Mg/yr [4,470 ton/yr]) from the 14 major
source facilities by 2,080 Mg/yr (2,300 ton/yr). The major HAP emitted at that time were MEK
and toluene. Emissions of VOC that are both HAP and non-HAP were expected to be controlled
in the process of meeting the requirements for HAP removal. However, the quantity of those
non-HAP VOC that would be removed was not quantified.
The six major source facilities in operation in 2005 are estimated to have HAP emissions
ranging from 3.9 to 214 Mg/yr (4.3 to 236 ton/yr) from their magnetic tape manufacturing
operations; these HAP emission estimates were determined using data from the 1999 Review
Draft National Emissions Inventory (NEI) Version 3, the 2000 Toxics Release Inventory (TRI),
State offices, and the facilities involved. The total HAP emissions for the magnetic tape
manufacturing source category are currently estimated to be 468 Mg/yr (516 ton/yr). As in 1994,
the major HAP emitted are MEK and toluene. These two solvents currently comprise 97 percent
of all air emissions in this source category. Tables 2-2 and 2-3 summarize recently reported HAP
emissions from these six facilities.
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Table 2-2. Recent HAP Emissions from Magnetic Tape Manufacturing Facilities''
Facility name
Quantegy Inc.
Opelika, AL
JVC Magnetics America Co.
Tuscaloosa, AL
3M Magnetic Tape
Manufacturing Division
Hutchinson, MN
Eastman Kodak Co.
Kodak Park
Rochester, NY
Imation Enterprises Corp.
Weatherford, OK
Sony Magnetic Products Inc.
of America
Dothan, AL
Pollutant
Cobalt
MEK
Toluene
HAP subtotal
MEK
Toluene
HAP subtotal
Acrylic acid
Antimony
Ethylbenzene
Ethylene glycol
n-Hexane
Lead compounds
MEK
Methanol
MffiK
Toluene
Xylenes
HAP subtotal
Cobalt
Hydrogen chloride
MEK
Toluene
HAP subtotal
Acrylonitrile
MEK
Methanol
Toluene
HAP subtotal
Cobalt
Cobalt compounds
MEK
Toluene
HAP subtotal
Emissions
Mg/yr
0.005
27
17
44
76
50
126
2.0
0.003
0.04
0.006
2.4
0.003
35
11
0.1
24
0.2
74
< 0.001
0.03
1.1
2.8
3.9
0.004
4.9
0.02
0.4
5.3
0.3
0.003
172
42
214
ton/yr
0.005
30
19
49
84
55
139
2.2
0.003
0.05
0.007
2.6
0.004
39
12
0.2
26
0.2
82
< 0.001
0.04
1.2
3
4.3
0.004
5.4
0.02
0.4
5.8
0.3
0.004
190
46
236
Notes
Data from TRI (2000) and NEI (1999)
Data from TRI (2000)
Data from TRI (2000); estimated
emissions by applying 30 percent factor
to the total facility emissions for each
pollutant
Data from Eastman Kodak (2001);
estimated MEK and toluene emissions
by applying ratio of emissions from TRI
(2000) to total organic emissions from
Eastman Kodak
Data from NEI (1999)
Data from TRI (2000) and Sony (2000)
' Data were from 1999, 2000, or 2001, depending on the facility.
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Table 2-3. Summary of Total HAP Emissions2
Pollutant
Acrylic acid
Acrylonitrile
Antimony
Cobalt
Cobalt compounds
Ethylbenzene
Ethylene glycol
n-Hexane
Hydrogen chloride
Lead compounds
MEK
Methanol
MffiK
Toluene
Xylenes
Total
Mg/yr
2.0
0.004
0.003
0.3
0.003
0.04
0.006
2.4
0.03
0.003
317
11
0.1
136
0.2
468
ton/yr
2.2
0.004
0.003
0.3
0.004
0.05
0.007
2.6
0.04
0.004
349
12
0.2
150
0.2
516
Percent of
total
0.4
<0.01
<0.01
0.06
<0.01
<0.01
<0.01
0.5
<0.01
<0.01
68
2.3
0.03
29
0.03
100
" Summed across facilities using recent emission data presented in Table 2-2.
2.3 REFERENCES
1. U.S. Environmental Protection Agency. Hazardous Air Pollutant Emissions from
Magnetic Tape Manufacturing Operations - Background Information for Proposed
Standards. Research Triangle Park, NC. EPA-453/R-93-059. December 1993.
2. U.S. Environmental Protection Agency. Hazardous Air Pollutant Emissions from
Magnetic Tape Manufacturing Operations - Background Information for Promulgated
Standards. Research Triangle Park, NC. EPA-453/R-94-074b. December 1994.
3. Memorandum from Holloway, T., RTI, to the project files. January 3, 2003. Toxics
Release Inventory data for magnetic tape manufacturing facilities.
4. Memorandum from Holloway, T., RTI, to the project files. December 21, 2004.
Additional Toxics Release Inventory data for one magnetic tape manufacturing facility.
5. Telecon. Hellwig, V., EPA/CCPG, with Sidig, K., 3M Corp. June 19, 2002. Hutchinson
mag tape HAP emissions.
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6. E-mail and attachment from Holloway, T., RTI, to Dail, H., EPA/CCPG. June 17, 2003.
Mag tape NEI data.
7. E-mail and attachment from Palma, T., EPA/REAG, to Dail, H., EPA/CCPG. June 17,
2003. NEI data.
8. E-mail and attachment from Moeller, G., Eastman Kodak Co., to Holloway, T., RTI.
September 26, 2002. Re: Mag tape risk info.
9. E-mail and attachment from Farmer, M., Sony Magnetic Products Inc. of America, to
Reeves, D., RTI. November 20, 2003. Re: Word vs. Word Perfect.
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Chapter 3
Existing Regulations
3.1 SUMMARY OF NEW SOURCE PERFORMANCE STANDARDS'
Magnetic tape manufacturing operations have previously been regulated by the EPA. The
new source performance standards (NSPS) for the magnetic tape manufacturing industry were
promulgated on October 3, 1988 (53 FR 38914). The NSPS are national standards that limit
VOC emissions from the coating operation and the mix preparation steps at new magnetic tape
manufacturing facilities.
The NSPS include control requirements for new coating operations using greater than or
equal to 38 cubic meters (m3) (10,000 gal) of solvent per year and for modified or reconstructed
coating operations using greater than or equal to 370 m3 (98,000 gal) of solvent per year.
Coating operations that fall below these solvent usages are subject only to reporting and
recordkeeping requirements.
The NSPS require new coating operations to recover or destroy 93 percent of the VOC
content of the solvent applied at the coater. This same requirement applies to any modified or
reconstructed coating operation that was achieving less than 90 percent control when it was
modified or reconstructed. However, an existing coating operation that demonstrates an overall
VOC control efficiency greater than or equal to 90 percent before modification or reconstruction
is not required to add additional controls but must maintain an overall control level greater than or
equal to the previously demonstrated control level (up to an overall VOC control efficiency of
93 percent).
The NSPS also require new mix preparation equipment to be covered and vented to a
95 percent-efficient control device, if the equipment is constructed concurrently with any control
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device other than a condenser. For other cases, at a minimum, mix preparation equipment has to
be equipped with a cover meeting particular specifications.
Under the NSPS, sources can also comply with the rule by using coatings that contain less
than 0.2 kilograms per liter (kg/L) (1.67 pounds per gallon [lb/gal]) of coating solids as calculated
on a weighted-average basis for each nominal 1 -month period. As of the date of proposal of the
NSPS (January 22, 1986), any new, modified, or reconstructed lines in any State were subject to
the NSPS.
3.2 SUMMARY OF STATE REGULATIONS'
In addition to the NSPS, several State regulations that apply to the magnetic tape
manufacturing industry have been developed. Twenty-eight States limit VOC emissions by
requiring that the coatings used contain less than 347 grams per liter (g/L) (2.9 lb/gal) of coating
applied, excluding water. This requirement originally applied to 12 operating facilities and was
recommended by a 1977 Federal control techniques guideline (CTG) for existing stationary
sources ("Control of Volatile Organic Emissions from Existing Stationary Sources—Volume II:
Surface Coatings of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks,"
Document No. EPA-450/2-77-008). Based on the average VOC content of the coatings used by
the magnetic tape manufacturing industry, this requirement was equal to approximately 83 percent
control. Two States limited VOC emissions by requiring that the coatings used contain less than
359 g/L (3.0 lb/gal) of VOC. One magnetic tape manufacturing facility was located in one of
those States and was, therefore, subject to this requirement. Five facilities in California were
subject to rules that limit the VOC content of their coatings to either 120 or 264 g/L (1.0 or
2.2 lb/gal) of VOC, depending upon local district regulations. All of the aforementioned coating
limits could also be met through the use of add-on controls, which is the method all known
magnetic tape manufacturing facilities have chosen for compliance.
There has also been some regulation of VOC emissions from cleaning activities in the
magnetic tape manufacturing industry. In California, the Bay Area Air Quality Management
District requires that owners or operators either maintain a minimum freeboard ratio in their wash
sinks or vent wash sink emissions to a control device. Four facilities were located in the
California Bay Area. Illinois requires facilities with VOC emissions greater than 90.7 Mg/yr
3-2
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(100 ton/yr) that are located in ozone nonattainment areas to cover vessels during cleaning.
However, there have been no known magnetic tape manufacturing sources with VOC emissions
above this level located in Illinois.
3.3 SUMMARY OF PROMULGATED NESHAP2 3
The NESHAP for the magnetic tape manufacturing operations source category was
promulgated on December 15, 1994 (59 FR 64596) and amended on April 9, 1999 (64 FR
17464). The Magnetic Tape Manufacturing NESHAP defines MACT and limits emissions of
HAP from surface coatings used at new and existing major sources in the manufacture of
magnetic and optical recording media used in audio, video, computer, and magnetic stripe tape
and disks. In general, an overall HAP control efficiency of at least 95 percent is required for
emissions from each solvent storage tank, piece of mix preparation equipment, coating operation,
waste handling device, or condenser vent in solvent recovery. Most facilities were expected to
meet this requirement with solvent recovery devices, such as carbon adsorbers or condensers.
Some were expected to use incinerators. If a facility uses an incinerator to control these emission
points, it could choose to meet an outlet HAP concentration of no greater than 20 parts per
million by volume (ppmv) by compound rather than achieve 95 percent control, as long as the
efficiency of the capture system is 100 percent. The standards provide procedures for establishing
an alternate concentration limit for the control device when the coating operations are not
running. If a facility uses a coating with a HAP content no greater than 0.18 kg/L (1.5 Ib/gal) of
coatings solids, that facility's coating operation does not require further control.
The final NESHAP applies to major sources performing magnetic tape manufacturing
operations, which is the affected source subject to these standards. The standards do not apply to
research or laboratory facilities, or to owners or operators whose magnetic tape production on a
coating line is 1 percent or less of total production from that coating line (in terms of square
footage coated) in any 12-month period. Table 3-1 summarizes the standards for magnetic tape
manufacturing operations in the final NESHAP.
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Table 3-1. Summary of the Magnetic Tape Manufacturing Standard
Emission point
Each solvent storage
tank
Each piece of mix
preparation
equipment
Each coating
operation
Each waste handling
device
Each condenser vent
in solvent recovery
Each paniculate
transfer operation
Standards
§ 63.703(c)(l):
§ 63.703(c)(2):
§ 63.704(c)(4):
§ 63.703(i):
§ 63.703(c)(l):
§ 63.703(c)(2):
§ 63.703(0:
§ 63.703(c)(l):
§ 63.703(c)(2):
§ 63.703(c)(4):
§ 63.703(c)(5):
§63.703(c)(l):
§ 63.703(c)(2):
§ 63.703(i):
§ 63.703(c)(l):
§ 63.703(c)(2):
§ 63.703(i):
§ 63.703(d)(l):
§ 63.703(d)(2):
Overall (i.e., capture x control device efficiency) HAP control
efficiency of >95 percent; or
For incinerators, an alternate outlet HAP concentration of
<20 ppmv; or
Do not control solvent storage tanks, but control coating
operations at higher efficiencies specified in rule; or
Establish an alternate maximum HAP outlet concentration
monitored with a continuous emission monitor (CEM) to
demonstrate compliance during periods when coalers are not
operating.
Overall HAP control efficiency of >95 percent; or
For incinerators, an alternate outlet HAP concentration of
<20 ppmv; or
Establish an alternate maximum HAP outlet concentration
monitored with a CEM to demonstrate compliance during
periods when coalers are not operating.
Overall HAP conlrol efficiency of >95 percent; or
For incinerators, an oullet HAP concentralion of <20 ppmv;
or
Control all coating operations al specified higher efficiencies
instead of conlrolling solvenl slorage lanks; or
Use coaling wilh HAP conlenl no greater than 0.18 kg/L
(1.5 Ib/gal) of coating solids.
Overall HAP control efficiency of >95 percenl; or
For incinerators, an alternate outlel HAP concenlralion of
<20 ppmv; or
Establish an alternate maximum HAP outlel concenlralion to
demonslrale compliance during periods when coalers are nol
operaling.
Overall HAP control efficiency of >95 percent; or
For incinerators, an alternate oullel HAP concenlralion of
<20 ppmv; or
Establish an alternate maximum HAP oullel concenlralion to
demonstrate compliance during periods when coalers are nol
operaling.
Use enclosed Iransfer; or
Venl to baghouse/fabric filler that exhibits no visible
emissions while conlrolling paniculate HAP Iransfer.
(continues)
3-4
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Table 3-1. (continued)
Emission point
Each wash sink for
cleaning removable
parts
Each piece of
equipment for
flushing fixed lines
Each wastewater
treatment operation
Standards
§ 63.703(e)(l)(i):
§ 63.703(e)(l)(ii):
§ 63.703(i):
§ 63.703(f)(l)(i):
§ 63.703(f)(i)(ii):
§ 63.703(i):
§ 63.703(g):
3.4 REFERENCES
1. U.S. Environmental Protection
Overall HAP control efficiency of >88 percent; or
Minimum freeboard ratio of 75 percent; or
Establish an alternate maximum HAP outlet concentration to
demonstrate compliance during periods when coalers are not
operating.
Overall HAP control efficiency of >95 percent; or
Use closed system; or
Establish an alternate maximum HAP outlet concentration to
demonstrate compliance during periods when coalers are not
operating.
Treal lo remove HAP by Ihe fraclion removed thai is
specified in Table 9 of 40 CFR part 63, subparl G;
Treal lo remove HAP so that total volatile organic HAP
concentralion al exil is <50 parts per million by weight.
Agency. National Emission Standards for Hazardous Air
Pollutants; Proposed Standards for Hazardous Air Pollutant Emissions From Magnetic
Tape Manufacturing Operations; Proposed Rule. 59'FR 11662. Washington, DC.
U.S. Government Printing Office. March 11, 1994.
U.S. Environmental Protection Agency. National Emission Standards for Hazardous Air
Pollutants; Final Standards for Hazardous Air Pollutant Emissions from Magnetic Tape
Manufacturing Operations; Final Rule. 59 FR 64596. Washington, DC.
U.S. Government Printing Office. December 15, 1994.
U.S. Environmental Protection Agency. National Emission Standards for Hazardous Air
Pollutants for Source Categories; Amendments for Hazardous Air Pollutant Emissions
from Magnetic Tape Manufacturing Operations; Direct Final Rule. 64 FR 17464.
Washington, DC. U.S. Government Printing Office. April 9, 1999.
3-5
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Chapter 4
Technology (MACT) Review
4.1 STATUS OF INDUSTRY TECHNOLOGY
Section 112 (d)(6) of the Act requires EPA to review and revise, as necessary (taking into
account developments in practices, processes, and control technologies), emission standards
promulgated under section 112 no less often than every 8 years. The Magnetic Tape
Manufacturing NESHAP was promulgated on December 15, 1994.
In 2002, as part of the data gathering effort for the residual risk analysis required under
section 112(f)(2), EPA reviewed available information about the industry, talked with industry
representatives, and contacted several facilities in the industry to discuss emission control
technologies available to the industry. The EPA did not identify any additional control
technologies beyond those that are already in widespread use within the source category (e.g.,
carbon adsorbers, condensers). The only developments identified involve improvements in the
performance of existing technologies or increased frequency of inspections and testing, which
would achieve only small incremental emission reductions that are often already being achieved
because facilities over-control to maintain a safe level of continuous compliance with the
NESHAP. The only major technical advances have been in the development of optical recording
media and SSR media, which may eventually supplant magnetic tape. However, optical recording
media and SSR media are not considered magnetic tape and would not be covered under the
Magnetic Tape Manufacturing NESHAP. Therefore, the investigation did not identify any
significant developments in practices, processes, or control technologies in the magnetic tape
manufacturing industry since promulgation of the original standard in 1994. Because the existing
4-1
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NESHAP continues to represent the best controls that can be implemented nationally, EPA
believes that no further revisions to this standard are needed under section 112(d)(6).
4.2 IDENTIFICATION AND MEASUREMENT OF HAP USED
As noted in the introductory discussion of the NESHAP source category in Chapter 1,
the HAP that have been used in the magnetic tape manufacturing industry include MEK, MIBK,
methanol, toluene, toluene diisocyanate, ethylene glycol, xylenes, chromium, cobalt, ethylbenzene,
and acetaldehyde. The non-HAP solvents that have been used in this industry include
cyclohexanone, acetone, and isopropyl alcohol. Some of the HAP and non-HAP compounds
listed above are no longer used in this industry.
Based on recent emission data reported by those U.S. facilities still manufacturing
magnetic tape products, the primary HAP currently associated with magnetic tape surface coating
operations are MEK (68 percent of reported emissions) and toluene (29 percent). A significant
reduction has been noted in the amount of chromium used in the manufacturing operations
compared to the 1994 data. Most facilities either have eliminated all chromium from their
processes or are working on ways to substitute alternative metals in their coating formulations.
In a Federal Register notice published on May 30, 2003 (68 FR 32606), EPA proposed to
amend the list of HAP contained in section 112(b)(l) of the Act by removing MEK (Chemical
Abstracts Service [CAS] No. 78-93-3). This action was taken in response to a petition to delete
MEK from the HAP list submitted by the Ketones Panel of the American Chemistry Council on
behalf of MEK producers and consumers. Petitions to remove a substance from the HAP list are
permitted under section 112(b)(3) of the Act.
To delete a substance from the HAP list, section 112(b)(3) provides that the Administrator
must determine that ".. .there is adequate data on the health and environmental effects of the
substance to determine that emissions, ambient concentrations, bioaccumulation or deposition of
the substance may not reasonably be anticipated to cause any adverse effects to the human health
or adverse environmental effects." The proposed delisting notice is open to public comment and
public hearing, and EPA will evaluate all substantive information prior to taking any final action
related to the proposal.
4-2
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If MEK were successfully delisted, it would have minimal impact on the regulation of
magnetic tape manufacturing facilities. As noted in the following chapters, there is not a
significant health risk associated with any of the facilities currently manufacturing magnetic tape in
the United States. The delisting of MEK will not change that conclusion.
As part of the petition evaluation, EPA considered the fact that MEK is one of the top
compounds by volume reported in TRI. Under the proposed delisting notice, MEK would no
longer be regulated as a HAP, but it would continue to be reported in TRI and regulated under
EPA's criteria pollutant (ozone) program.
4-3
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4-4
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Chapter 5
Residual Risk Analysis
Section 112(f)(2) of the Act directs EPA to assess the risk remaining (residual risk) after
the application of MACT standards under section 112(d). This section states that:
...the Administrator shall, within 8 years after promulgation of standards for each category
or subcategory of sources pursuant to subsection (d), promulgate standards for such
category or subcategory if promulgation of such standards is required in order to provide
an ample margin of safety to protect public health in accordance with this section (as in
effect before the date of enactment of the Clean Air Act Amendments of 1990) or to
prevent, taking into consideration costs, energy, safety, and other relevant factors, an
adverse environmental effect.
The EPA's policy for defining and providing "an ample margin of safety" can be found in
the "National Emission Standards for Hazardous Air Pollutants (NESHAP): Benzene Emissions
from Maleic Anhydride Plants, Ethylbenzene/Styrene Plants, Benzene Storage Vessels, Benzene
Equipment Leaks, and Coke By-Product Recovery Plants," 54 FR 38044, September 14, 1989,
where EPA stated that:
[I]n protecting the public health with an ample margin of safety under section 112,
EPA strives to provide maximum feasible protection against risks to health from
hazardous air pollutants by (1) protecting the greatest number of persons possible
to an individual lifetime risk level no higher than approximately 1 in 1 million and
(2) limiting to no higher than approximately 1 in 10 thousand the estimated risk
that a person living near a plant would have if he or she were exposed to the
maximum pollutant concentrations for 70 years. Implementation of these goals is
by means of a two-step, standard-setting approach, with an analytical first step to
determine an "acceptable risk" that considers all health information, including risk
estimation uncertainty, and includes a presumptive limit on maximum individual
lifetime risk (MIR) of approximately 1 in 10 thousand. A second step follows in
which the actual standard is set at a level that provides "an ample margin of safety"
in consideration of all health information, including the number of persons at risk
levels higher than approximately 1 in 1 million, as well as other relevant factors
5-1
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including costs and economic impacts, technological feasibility, and other factors
relevant to each particular decision.
54 FR 38044-45. See also, 55 FR 8292 (March 7, 1990).
5.1 DATA COLLECTION12
To evaluate the residual risk from the magnetic tape manufacturing source category after
implementation of the Magnetic Tape Manufacturing NESHAP, it was necessary to identify those
facilities that are subject to the control requirements of the standard and also to accurately
describe their site locations, operations, and emissions. During the development of the Magnetic
Tape Manufacturing NESHAP, information was gathered from a variety of sources to describe
and characterize the industry, the HAP emitted, the emission sources, the control measures that
were in use or available, and the projected emission reductions and costs of implementing the
standards. Much of the information gathered during the development of the technology standards
was useful in understanding the source category's emissions and controls as well as determining
the identify and location of affected sources and some of the site-specific information necessary to
do a risk analysis. The following sections describe the data gathering activities conducted for this
residual risk study.
5.1.1 Pollutants3
The primary HAP emitted from magnetic tape manufacturing are MEK and toluene.
These organic compounds comprise 97 percent of the HAP emitted from magnetic tape surface
coating. The single biggest pollutant is MEK, which accounts for 68 percent of the total source
category HAP emissions reported. Toluene accounts for 29 percent of total source category
emissions. Three facilities reported metallic cobalt emissions ranging from less than 0.001 to
0.3 Mg/yr (0.001 to 0.3 ton/yr). One facility reported cobalt compound emissions of 0.1 Mg/yr
(0.1 ton/yr), with cobalt comprising 3 weight-percent of the mix. (See Tables 2-2 and 2-3.)
Some metals, such as iron and chromium compounds, are also found in trace amounts in many
magnetic tape coatings.
5-2
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5.1.2 Source Identification4
The list of sources subject to the Magnetic Tape Manufacturing NESHAP was compiled
by investigating the 1999 NEI and the 2000 TRI, and by contacting and collecting information
from State offices and from the facilities involved. Table 2-1 lists each of the six facilities
reportedly manufacturing magnetic tape products. As noted in Chapter 2, several of the facilities
identified in 1994 are no longer in business or are no longer manufacturing magnetic tape
products.
5.1.3 Source Characterization5
To assess the risk posed by HAP emissions from the magnetic tape manufacturing source
category, detailed site-specific information was needed. Modeling inputs, such as latitude and
longitude, HAP emission rates, stack parameters (for stack emission points), building volume (for
fugitive emission points), and operating hours, were used to perform the risk modeling.
The primary sources of site-specific modeling data used for this risk analysis were the
1999 NEI, 2000 TRI, State offices, and the facilities involved. The NEI provided data for each of
the six facilities on the list of sources subject to the Magnetic Tape Manufacturing NESHAP.
Although the NEI was used as the site-specific data source for the six facilities, there were
deficiencies in the inventory that EPA had to address.
First, not all of the data fields in the NEI were populated with actual data. For missing
key parameters (e.g., stack height, stack diameter, stack gas temperature and velocity), the NEI
used default entries based on industry average values. Rather than use these default entries, EPA
obtained actual parameter data from most of the facilities involved, including data on stack
parameters (for stack emission points) and building volume (for fugitive emission points).
Second, in most cases, the HAP emission data in the NEI were somewhat out-of-date and
did not reflect recent emission reductions achieved in the industry. Consequently, EPA
supplemented the NEI with emission data obtained from the more recent 2000 TRI and from
contacts with State offices and the facilities involved. Where possible, stakeholders provided
updated information on the facilities' HAP emissions and on the percentage of HAP emissions
that could be attributed to magnetic tape manufacturing operations.
5-3
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At three of the six facilities (Quantegy, JVC Magnetics America, and Sony Magnetic
Products), it was possible to attribute all of the facilities' TRI emissions to their magnetic tape
manufacturing operations because they manufacture only magnetic tape. At the remaining three
facilities (3M Magnetic Tape, Eastman Kodak, and Imation Enterprises), only a small fraction of
these facilities' emissions can be attributed to their magnetic tape manufacturing operations
because they manufacture more than just magnetic tape. At one of these facilities (Eastman
Kodak), EPA was able to obtain emission data from the facility that were specific to the facility's
magnetic tape manufacturing operation. At the second facility (Imation Enterprises), the SIC
codes provided in the NEI made it possible to segregate the NEI emissions attributable to the
magnetic tape manufacturing operation at the facility from the NEI emissions attributable to co-
located sources that are part of another source category at the facility. At the third facility (3M
Magnetic Tape), EPA obtained information from the facility indicating that up to 30 percent of
the facility's total HAP emissions from the TRI could be attributed to the magnetic tape
manufacturing operation.
It was not possible to determine exactly which pollutants from the TRI were emitted from
3M's magnetic tape manufacturing operation and which were emitted from co-located sources
that are part of other source categories at the facility. However, some assumptions can be made
based on the list of HAP typically used in the magnetic tape manufacturing industry. Using these
assumptions, seven pollutants from the TRI (ethylbenzene, ethylene glycol, MEK, methanol,
MIBK, toluene, and xylenes) are the most likely pollutants emitted from 3M's magnetic tape
manufacturing operation, and four pollutants from the TRI (acrylic acid, antimony, n-hexane, and
lead compounds) are most likely emitted from co-located sources that are part of another source
category at the 3M facility.
5.2 RISK ANALYSES6
As discussed previously in more detail, site-specific emissions and source characteristic
data were obtained directly from the NEI or from the TRI, or gathered from contacts with State
offices or with the facilities involved. Using this information, EPA modeled exposure
concentrations surrounding the six facilities in the magnetic tape manufacturing source category,
calculated the risk of possible chronic cancer and noncancer health effects, evaluated whether
5-4
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acute exposures might exceed relevant health thresholds, and investigated human health
multipathway and ecological risks.
The EPA Human Exposure Model (HEM-Screen, 2003 Version) was used for the
assessment of chronic exposures. HEM-Screen contains an atmospheric dispersion model with
meteorological data and year 2000 population data at the census block level from the U.S. Bureau
of Census. For this assessment, EPA used HEM-Screen to estimate the average annual ambient
concentration at census block centroid locations for each facility. This concentration was then
used as a surrogate for exposure to estimate the maximum lifetime individual cancer risk (MIR)
and chronic noncancer hazard index (HI) for that facility. The MIR and HI estimates represent
upper-bound risks for individuals who actually live in the most impacted areas. The MIR and HI
results for the most exposed census blocks for each facility are summarized in Table 5-1. The
total HAP emission rates used in the risk analysis are also provided in Table 5-1 for reference.
Table 5-1. Summary of Residual Risk for Magnetic Tape Manufacturing Facilities
Facility
Quantegy
JVC Magnetics America
3M Magnetic Tape
Eastman Kodak
Imation Enterprises
Sony Magnetic Products
Emissions
Mg/yr
44
126
74
3.9
5.3
214
ton/yr
49
139
82
4.3
5.8
236
MIR"
NA
NA
NA
NA
IxlO'8
NA
Chronic HI
0.008
0.02
0.3
0.0002
0.0002
0.2
' NA = not applicable.
The results show that out of the six facilities modeled, none pose cancer risks that are
predicted to exceed 1 in 1 million, and none pose chronic noncancer risks that are predicted to
exceed an HI of 1. One of the six facilities in the magnetic tape manufacturing source category
(Imation Enterprises) was quantitatively assessed for potential cancer risks due to acrylonitrile
emissions from this facility. Acrylonitrile is classified as a probable human carcinogen by EPA.
The other five facilities did not emit any amount of known, probable, or possible carcinogens.
The estimated MIR associated with this facility was 1 in 100 million, or 0.01 excess cancer case in
5-5
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a population of 1 million. This is significantly less than the statutory limit of 1 excess cancer case
in a population of 1 million in section 112(f)(2) of the Act. Furthermore, because of the health-
protective assumptions used in the assessment, EPA believes that worst-case cancer risks from the
magnetic tape facilities are actually lower.
The maximum chronic noncancer His for all six of the modeled facilities were well below
1. This means that the total lifetime exposures to the HAP emitted by these sources did not
exceed the noncancer reference concentration (RfC) for any of the sources. For one of the
facilities with the highest HI (0.2), the primary noncancer risk driver was cobalt, responsible for
99 percent of the estimated risk. Chronic inhalation exposure to cobalt has been associated with a
variety of noncancer health effects in humans, including respiratory irritation, wheezing, asthma,
pneumonia, fibrosis, cardiac effects, congestion of the liver and kidneys, and immunological
effects. However, since all predicted cobalt exposures were well below the RfC, EPA does not
believe that chronic exposures from these facilities pose a public health concern.
The EPA SCREENS air dispersion model was used for the assessment of acute exposures.
SCREENS is a screening-level model that can be used to predict worst-case, 1-hour
concentrations for a source of air toxics. With one exception, all maximum 1 -hour exposure
concentrations were below available acute dose-response values. The predicted maximum 1-hour
concentration of toluene at one facility (JVC Magnetics America) slightly exceeded the acute
minimum risk level (MRL) developed by the Agency for Toxic Substances and Disease Registry
(ATSDR). Acute inhalation exposure to toluene has been associated with a variety of adverse
health effects in humans, including dysfunction of the central nervous system and narcosis.
Because ATSDR MRLs for acute exposures are derived assuming 1- to 14-day exposure
durations, they may not be appropriate for comparison to maximum 1-hour HAP concentrations.
A more suitable toluene MRL derived specifically for a 1-hour exposure period would likely be
higher than the MRL associated with a 1- to 14-day exposure duration and above the maximum
1-hour toluene exposure. Since no 1-hour acute dose-response values for toluene were exceeded
at any facility, EPA does not believe that acute exposures from these facilities pose a public health
concern. Overall, results of the acute exposure analysis indicate that significant acute effects
associated with HAP emissions from the six magnetic tape facilities are not expected.
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Some persistent and bioaccumulative (PB) HAP may pose human health risks via
exposure pathways other than inhalation and can also pose ecological risks by entering the wildlife
food chain. Based on emissions data obtained for the magnetic tape manufacturing source
category, lead is the only PB HAP reported as emitted by magnetic tape sources. Therefore, lead
was investigated for potential human health impacts via non-inhalation pathways (e.g., ingestion).
Lead was reported as emitted by one facility (3M Magnetic Tape) in the magnetic tape
manufacturing source category. Although lead is not typically emitted from magnetic tape
manufacturing processes, EPA nonetheless included those emissions in its analysis in an attempt
to capture the worst-case impacts for the facility. The lead may have been emitted from other co-
located processes at the facility. As noted in the previous section, up to 30 percent of the
facility's total HAP emissions can be attributed to the magnetic tape manufacturing process, with
the rest attributed to other co-located processes. To estimate the facility's magnetic tape
emissions, EPA applied the 30 percent to the facility's emissions for each HAP, including lead.
The facility's emissions were extracted from its 2000 TRI results.
The Industrial Source Complex-Short-Term (ISCST3) model was used to model the
deposition of lead into soil, and the Integrated Exposure Uptake Biokinetic Model for Lead in
Children (IEUBK) was used to predict blood lead concentrations (PbBs) for children exposed to
predicted concentrations of lead in soil as a result of emissions from this facility. The maximum
annual average air concentration of lead associated with this facility was estimated at 0.00032
microgram per cubic meter (//g/m3). The maximum soil concentration of lead due to deposition
over a 30-year time period at a census block centroid was estimated at 4.6 milligrams per gram
(mg/g). The PbBs for children 7 years old and younger were calculated using an assumed soil
lead concentration of 204.6 mg/g, which represents the IEUBK default of 200 mg/g plus the
maximum calculated soil lead concentration of 4.6 mg/g associated with this facility. All of the
PbBs associated with this facility were estimated at concentrations ranging from 2.5 to 4.2
micrograms per deciliter (/^g/dL) for the various age groups evaluated. The reference value
which represents a level of concern for children as specified by EPA and the Centers for Disease
Control and Prevention is 10 //g/dL. Thus, no significant human health multipathway are
expected.
5-7
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The EPA is also required to consider adverse impacts to the environment (e.g., ecological
risks) as a part of a residual risk assessment. Consequently, lead was also investigated for
potential ecological risks. Regarding the inhalation exposure pathway for terrestrial mammals,
EPA contends that human toxicity values for the inhalation pathway are generally protective of
terrestrial mammals. Because the maximum cancer and non-cancer hazards to humans from
inhalation exposure are relatively low, EPA expects there to be no significant or widespread
adverse effects to terrestrial mammals from inhalation exposure to HAP emitted from facilities in
this source category. To ensure that the potential for adverse effects to wildlife (including birds)
resulting from lead exposure is low, EPA carried out a screening-level assessment of ecological
effects. The predicted soil lead concentrations from the 3M facility are low compared to the
screening value for lead in soil and would not be expected to cause unacceptable risks to
ecological receptors.
Acrylic acid was also reported as emitted by the 3M facility. Although acrylic acid is not
typically emitted from magnetic tape manufacturing processes, EPA nonetheless included those
emissions in its analysis in an attempt to capture the worst-case impacts for the facility. The
acrylic acid may have been emitted from other co-located processes at the facility. When acrylic
acid was included in the residual risk assessment for this facility, cancer risks and acute noncancer
risks were unchanged, and the chronic noncancer HI rose to 0.3. Because this value is below 1,
EPA remains unconcerned about potential noncancer health risks.
Based on the results presented in this section, the potential for unacceptable chronic or
acute human health effects and ecological effects appears to be low for this source category.
While this analysis is not exhaustive and is not intended to be, EPA has used (1) the best
emissions data currently available, (2) reasonable dispersion models, and (3) exposure locations
where receptor populations currently reside. The EPA has also made several health-protective
assumptions, meaning that the predicted risk estimates are likely higher than would be expected to
actually occur in the exposed population. On balance, based on EPA's scientific judgment and
risk assessment experience, EPA believes the results are protective.
5.3 REFERENCES
5-8
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1. U.S. Environmental Protection Agency. Hazardous Air Pollutant Emissions from
Magnetic Tape Manufacturing Operations - Background Information for Proposed
Standards. Research Triangle Park, NC. EPA-453/R-93-059. December 1993.
2. U.S. Environmental Protection Agency. Hazardous Air Pollutant Emissions from
Magnetic Tape Manufacturing Operations - Background Information for Promulgated
Standards. Research Triangle Park, NC. EPA-453/R-94-074b. December 1994.
3. E-mail and attachment from Holloway, T., RTI, to Pimentel, M., EPA/REAG.
November 25, 2003. Updated inputs for Sony.
4. Memorandum from Holloway, T., RTI, to the project files. March 28, 2005.
Documentation of magnetic tape manufacturing facility inventory.
5. E-mail and attachment from Holloway, T., RTI, to Dail, H., EPA/CCPG. June 17, 2003.
Mag tape NEI data.
6. Memorandum from Pimentel, M., EPA/REAG to Guinnup, D., EPA/REAG. October 15,
2004. Residual risk assessment for the magnetic tape manufacturing source category
(dated October 15, 2004); addendum (dated July 20, 2005); EPA internal peer review
(dated July 20, 2005).
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Chapter 6
Risk Reduction Options
6.1 EPA DECISION OF MACT ADEQUACY
The results of the residual risk analyses indicate that the development and promulgation of
additional standards for the magnetic tape manufacturing source category is not justified for a
number of reasons. Provided below is a discussion of those reasons, which draws from the
analyses and discussion presented previously.
The EPA used a two-step, standard-setting approach to determine if residual risk
standards were warranted. The first step was to determine an "acceptable risk" that considered all
health information, including risk estimation uncertainty, and included a presumptive limit on MIR
of approximately 100 in 1 million. The EPA modeled each of the six facilities with magnetic tape
manufacturing source category emission sources and found no facilities with a cancer MIR at or
above 100 in 1 million. The EPA also found the maximum noncancer HI from these facilities to
be well below 1 (see Table 5-1). The EPA believes that these six facilities constitute all of the
emissions from this source category and that the assessment is likely to overestimate rather than
underestimate risks. Therefore, EPA has determined that this source category currently presents
an acceptable level of cancer and noncancer risks.
The results of the residual risk analyses show that there is not a significant health risk
associated with any of the facilities currently manufacturing magnetic tape in the United States.
The major source facilities are complying with the MACT requirements, and overall HAP
emissions have been reduced on both an industry-wide and a facility-level basis. Therefore, EPA
believes that the existing MACT requirements for the magnetic tape manufacturing source
category are adequate and no additional changes or updates are needed.
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6.2 FEASIBILITY OF ADDITIONAL CONTROLS TO REDUCE RISK
The second step of the standard-setting approach was to set a standard at a level that
provided "an ample margin of safety" in consideration of all health information, including the
number of persons at risk levels higher than approximately 1 in 1 million, as well as other relevant
factors, including costs and economic impacts, technological feasibility, and other factors relevant
to each particular decision.
Facilities in the magnetic tape manufacturing source category typically emit HAP from
some combination of storage tanks, mixing operations, coating operations, and equipment leaks.
The EPA considered the technological feasibility of applying additional control measures to
reduce the emissions and risk at these facilities. In evaluating potential additional controls for
magnetic tape manufacturing facilities, EPA considered several recent MACT standards, including
the standards for Surface Coating of Plastic Parts and Products (subpart PPPP), Paper and Other
Web Coatings (subpart JJJJ), Organic Liquids Distribution (subpart EEEE), and Generic MACT
for Storage Vessels (subpart WW). These MACT standards generally require the same types of
controls found in most surface coating sectors, as well as the NSPS for storage tanks (subpart
Kb), except that the descriptions of the controls are more specific in the newer rules. Emission
reductions may have already been realized because some of the standards discussed above require
controls for surface coating operations and storage tanks that are new or have been modified or
reconstructed since 1984.
As discussed previously, EPA has not identified any additional control technologies
beyond those that are already in widespread use within the source category (e.g., carbon
adsorbers, condensers). The only additional control measures identified involve improvements in
the performance of existing technologies or increased frequency of inspections and testing, which
would not significantly reduce emissions (and, therefore, residual risk) within this source
category. The incremental emission reductions that could be achieved by the application of these
additional control measures would be small and are often already being achieved because facilities
over-control to maintain a safe level of continuous compliance with the NESHAP. Therefore,
EPA believes that any additional control requirements would achieve minimal risk reduction at a
very high cost. As a result, EPA has concluded that no additional control should be required
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because an ample margin of safety (considering cost, technical feasibility, and other factors) has
been achieved by the NESHAP.
6.3 EPA DECISION OF NO RULEMAKING ACTION
The residual risk analyses show that sufficient data are available to justify removing the
magnetic tape manufacturing source category from consideration for a residual risk rule. A
residual risk rule is not necessary, because the identifiable risk to the surrounding populations
living in neighborhoods close to the magnetic tape manufacturing facilities is below a lifetime
excess cancer risk of 1 in 1 million or a noncancer HI of 1.
Although EPA believes no further action is needed on this source category to reduce risk,
the residual risk from facilities that have emission sources covered by multiple, co-located source
categories will continue to be evaluated by EPA as each source category is reviewed. The
Printing and Publishing (subpart KK) and Paper and Other Web Coatings (subpart JJJJ) industries
are examples of sectors where the same facility may manufacture other products along with
magnetic tape and will be covered by a future residual risk standard for that source category.
Total HAP emissions and the associated risks from these facilities will be reduced as controls are
implemented to comply with the requirements of the future MACT standards, which will include
MACT review and residual risk analyses. The Plastic Parts Surface Coating NESHAP,
promulgated in September 2003, will also result in emission reductions from a couple of the same
facilities analyzed under the magnetic tape manufacturing source category. Furthermore, EPA
will also consider options to allow other co-located emission sources to increase control of
magnetic tape manufacturing emission sources in lieu of possible additional controls required
under a risk reduction strategy for the other source category (e.g., if risk reductions are necessary
for facilities regulated by the Paper and Other Web Coatings NESHAP).
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TECHNICAL REPORT DATA
. REPORT NO.
EPA-453/R-05-001
3. RECIPIENTS ACCESSION NO.
4. TITLE AND SUBTITLE
Hazardous Air Pollutant Emissions from Magnetic Tape
Manufacturing Operations-Background Information for Technical
and Residual Risk Review
5. REPORT DATE
July 2005
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
RTI International
3040 Cornwallis Road, P.O. Box 12194
Research Triangle Park, NC 27709-2194
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D-01-079
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
Final (2002-5)
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
National emission standards for hazardous air pollutants (NESHAP) were promulgated in 1994 for
magnetic tape manufacturing operations under the authority of Section 112(d) of the Clean Air Act as
amended in 1990. Section 112(d)(6) of the Act requires EPA to review and revise, as necessary (taking
into account developments in practices, processes, and control technologies), emission standards
promulgated no less often than every 8 years. Section 112(f)(2) directs EPA to assess the risk remaining
(residual risk) within 8 years after promulgation of standards and develop standards, if necessary, to provide
an ample margin of safety to protect public health or to prevent (taking into consideration costs, energy,
safety, and other relevant factors) an adverse environmental effect. This document contains background
information considered in EPA's decision to make no changes or updates to the NESHAP based on the
results of its technology review and residual risk assessment.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSAT1 Field/Group
Coating operation
Cobalt
Methyl ethyl ketone
Mix equipment
Toluene
Air pollution control
Hazardous air pollutants
MACT
Magnetic tape manufacturing
NESHAP
Residual risk
Technology review
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOLETE
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