MEMORANDUM
SUBJECT:
National
Emission
Standards
for
Magnetic
Tape
Manufacturing
Operations
(
Tier
3;
SAN
4669;
RIN
2060­
AK23)­­
ACTION
MEMORANDUM
FROM:
William
L.
Wehrum
Acting
Assistant
Administrator
(
6101)

THRU:
OEX
(
1105A)

TO:
Stephen
L.
Johnson
The
Administrator
(
1101A)

DEADLINE
The
court
ordered
deadline
for
the
final
action
for
the
magnetic
tape
manufacturing
operations
source
category
is
March
2006.

OVERVIEW
Attached
for
your
approval
is
a
proposed
action
(
1)
announcing
a
decision
to
take
no
further
action
at
this
time
to
revise
the
national
emission
standards
for
magnetic
tape
manufacturing
operations
(
40
CFR
part
63,
subpart
EE)
and
(
2)
requesting
public
comments
on
the
residual
risk
assessment
and
technology
review
for
the
standards.
We
developed
the
proposed
action
pursuant
to
the
requirements
of
section
112
of
the
Clean
Air
Act
(
CAA).
Section
112(
d)
of
the
CAA
requires
us
to
establish
national
emission
standards
based
on
the
maximum
achievable
control
technology
(
MACT)
for
major
and
area
sources
that
emit
hazardous
air
pollutants
(
HAP)
exceeding
specific
emission
thresholds.
Section
112(
d)(
6)
of
the
CAA
requires
us
to
review
the
standards
every
8
years
for
changes
in
technology
or
emission
control
practices.
The
residual
risk
provisions
in
section
112(
f)
of
the
CAA
require
us
to
determine
whether
the
MACT
standards
protect
public
health
with
an
ample
margin
of
safety
and
reasonably
prevent
any
adverse
environmental
effects.

The
primary
HAP
emitted
from
magnetic
tape
manufacturing
operations
are
methyl
ethyl
ketone
and
toluene,
which
are
solvents
used
in
the
magnetic
tape
coating
operation
and
cleaning
of
equipment.
Some
particulate
air
toxics
emissions
(
e.
g.,
cobalt)
can
occur
from
the
transfer
of
magnetic
particles
to
the
coating
mix.
We
conducted
a
detailed
risk
assessment
for
the
six
magnetic
tape
manufacturing
facilities
currently
operating
in
the
United
States.
The
estimated
maximum
lifetime
individual
cancer
risk
associated
with
the
facility
with
the
highest
cancer
risk
2
was
1­
in­
100
million,
or
0.01
excess
cancer
case
in
a
population
of
1
million.
Since
our
assessment
shows
that
the
maximum
lifetime
excess
cancer
risk
is
significantly
less
than
1­
in­
amillion
and
since
we
have
evaluated
the
potential
for
adverse
noncancer
human
health
effects
and
ecological
risks
and
found
them
to
be
insignificant
for
the
source
category,
we
conclude
that
no
further
emissions
reductions
should
be
required
under
section
112(
f).

As
part
of
the
technology
review
required
under
section
112(
d)(
6)
of
the
CAA,
we
reviewed
available
information
about
the
industry,
talked
with
industry
representatives,
and
contacted
several
facilities
in
the
industry
to
investigate
available
emission
control
technologies
and
the
potential
for
additional
emissions
reductions.
As
noted
above,
we
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
emissions
reductions.
The
only
major
technical
advances
we
discovered
were
the
development
of
two
new
technologies
(
optical
recording
media
and
solid
state
recording
(
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
national
emission
standards.
Because
the
existing
national
emission
standards
continue
to
represent
the
best
controls
that
can
be
implemented
nationally,
we
conclude
that
no
further
revisions
to
the
national
emission
standards
are
needed
under
section
112(
d)(
6)
of
the
CAA.

IMPACTS
The
proposed
action
will
not
have
an
economic
impact
on
any
of
the
magnetic
tape
manufacturing
operations
because
we
are
proposing
to
take
no
further
action
to
revise
the
national
emission
standards
for
the
industry.
The
risk
impacts
are
based
on
our
analyses
of
emissions
from
the
surface
coatings
used
in
the
manufacture
of
magnetic
tape.
Emissions
estimates
are
based
on
data
from
the
1999
National
Emissions
Inventory,
2000
Toxics
Release
Inventory,
State
offices,
and
the
facilities
involved.
The
methodology
for
the
multipathway
human
health
and
ecological
risk
assessments
follows
the
framework
established
in
the
EPA
"
Residual
Risk
Report
to
Congress"
(
1999)
and
"
Guidelines
for
Ecological
Risk
Assessment"
(
1998).

STAKEHOLDER
INVOLVEMENT
We
involved
stakeholders
throughout
the
development
of
the
proposed
action.
The
list
of
magnetic
tape
manufacturing
facilities
was
compiled
based
on
inventory
information
gathered
from
a
number
of
manufacturing
facilities
and
State
environmental
program
offices
(
e.
g.,
whether
these
facilities
were
still
operating
and
manufacturing
magnetic
tape).
We
continued
3
our
contacts
with
the
industry
in
gathering
information
for
the
residual
risk
assessment
and
technology
review.

INTERNAL
REVIEW
The
proposed
action
was
developed
under
Tier
3
and
was
reviewed
by
the
work
group,
which
consists
of
the
Office
of
General
Counsel;
Office
of
Enforcement
and
Compliance
Assurance;
and
Office
of
Policy,
Economics,
and
Innovation.
We
have
addressed
all
issues
raised
during
their
reviews.

PEER
REVIEW
There
were
no
influential
or
highly
influential
products
supporting
this
action
as
defined
by
the
Agency's
Peer
Review
Handbook.

PLAIN
LANGUAGE
The
elements
of
plain
language
have
been
addressed
in
the
proposed
action.

OMB
TRANSACTION
The
rulemaking
action
was
submitted
to
OMB
for
review
under
Executive
Order
12866.
OMB
cleared
the
rulemaking
action
on
September
27,
2005.
Discussions
with
OMB
focused
on
whether
EPA
could
use
the
residual
risk
assessment
to
justify
removing
all
or
a
portion
of
this
source
category
from
the
list
of
source
categories
subject
to
regulation
under
section
112
of
the
CAA.
While
EPA
did
not
develop
the
data
to
support
this
type
of
action,
we
nonetheless
agreed
to
take
comment
on
whether
such
an
approach
could
work
and
still
ensure
that
sources
in
the
category
continued
to
pose
negligible
health
risks
to
nearby
residents.

ANTICIPATED
EXTERNAL
REACTION
We
do
not
expect
opposition
from
industry.
Because
this
is
one
of
the
first
residual
risk
proposals
where
we
justify
no
further
emissions
reductions
based
on
our
determination
that
cancer,
noncancer,
and
ecological
risks
are
extremely
low,
environmental
groups
may
express
some
concern
on
the
risk
policy
decisions.
However,
we
feel
that
our
assessment
is
a
healthprotective
one
and,
therefore,
provides
a
strong
technical
basis
for
our
proposal.

STAFF
CONTACT
If
you
have
questions
about
this
regulatory
package,
please
contact
H.
Lynn
Dail
at
(
919)
541­
2363
or
Maria
Pimentel
at
(
919)
541­
5280.

RECOMMENDATION
4
I
recommend
that
you
sign
the
attached
proposed
action
for
publication
in
the
Federal
Register.

Attachment
cc:
Dennis
Leaf/
OA
Special
Assistant
OAR/
OAQPS/
ESD/
CCPG:
ldail/
jeck(
x7946):
RTP/
C539­
03:
9/
30/
05:
MagTapeProPkgOct05/
ActMemMagTapeRR30Sep05.
wpd
