Hazardous
Air
Pollutant
Emissions
from
Magnetic
Tape
Manufacturing
Operations
 
Background
Information
for
Technology
and
Residual
Risk
Review
This
page
intentionally
left
blank.
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
4
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.
5
TABLE
OF
CONTENTS
Page
List
of
Tables
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iv
List
of
Acronyms
and
Units
of
Measure
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v
Chapter
1
Introduction
and
Summary
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1­
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1.1
Statutory
Authority
and
Mandate
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1­
1
1.2
NESHAP
Source
Category
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1­
2
1.3
References
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1­
2
Chapter
2
Magnetic
Tape
Manufacturing
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2­
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2.1
Industry
Description
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2­
1
2.1.1
Manufacturing
Process
Overview
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2­
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2.1.2
SIC
and
NAICS
Codes
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2­
1
2.1.3
Emission
Points
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2­
2
2.1.4
Status
of
the
Industry
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2­
6
2.2
Baseline
Emissions
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2­
8
2.3
References
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2­
10
Chapter
3
Existing
Regulations
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3­
1
3.1
Summary
of
New
Source
Performance
Standards
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3­
1
3.2
Summary
of
State
Regulations
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3­
2
3.3
Summary
of
Promulgated
NESHAP
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3­
3
3.4
References
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3­
5
Chapter
4
Technology
(
MACT)
Review
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4­
1
4.1
Status
of
Industry
Technology
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4­
1
4.2
Identification
and
Measurement
of
HAP
Used
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4­
2
Chapter
5
Residual
Risk
Analysis
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5­
1
5.1
Data
Collection
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5­
2
5.1.1
Pollutants
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5­
2
5.1.2
Source
Identification
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5­
3
5.1.3
Source
Characterization
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5­
3
5.2
Risk
Analyses
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5­
4
5.3
References
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5­
8
Chapter
6
Risk
Reduction
Options
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6­
1
6.1
EPA
Decision
of
MACT
Adequacy
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6­
1
6.2
Feasibility
of
Additional
Controls
to
Reduce
Risk
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6­
2
6.3
EPA
Decision
of
No
Rulemaking
Action
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6­
3
6
LIST
OF
TABLES
Page
2­
1
Magnetic
Tape
Manufacturing
Facilities
in
the
United
States
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2­
7
2­
2
Recent
HAP
Emissions
from
Magnetic
Tape
Manufacturing
Facilities
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2­
9
2­
3
Summary
of
Total
HAP
Emissions
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2­
10
3­
1
Summary
of
the
Magnetic
Tape
Manufacturing
Standard
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3­
4
5­
1
Summary
of
Residual
Risk
for
Magnetic
Tape
Manufacturing
Facilities
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5­
5
7
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)
lb
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)


g
microgram(
s)
8
This
page
intentionally
left
blank.
1­
1
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
technologybased
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
1­
2
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.

1.2
NESHAP
SOURCE
CATEGORY
1,2
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
(

audioand
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.
2­
1
Chapter
2
Magnetic
Tape
Manufacturing
2.1
INDUSTRY
DESCRIPTION
1,2
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
2­
2
(
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
Particulate
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
2­
3
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.
2­
4
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
coater).
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,
2­
5
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.
2­
6
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.
2­
7
Table
2­
1.
Magnetic
Tape
Manufacturing
Facilities
in
the
United
States
Facility
name
and
address
County
Latitude
Longitude
SIC
code
NAICS
code
Magnetic
tape
products
Quantegy
Inc.
2230
Marvyn
Parkway
Opelika,
AL
36801
Lee
32

37'
28"
85

22'
24"
3695
334613
audio­,
video­,
and
datatape
JVC
Magnetics
America
Co.
#
1
JVC
Road
Tuscaloosa,
AL
35405
Tuscaloosa
33

10'
29"
87

27'
30"
3695
334613
audio­
and
videotape
Sony
Magnetic
Products
Inc.
of
America
4275
W.
Main
Street
Dothan,
AL
36305
Houston
31

13'
56"
85

27'
28"
3695
334613
audio­,
video­,
and
datatape
3M
Magnetic
Tape
Manufacturing
Division
905
­
915
Adam
Street
S.
E.
Hutchinson,
MN
55350
McLeod
44

52'
49"
94

21'
32"
3695;
2672
334613;
322222
audio­
and
videotape
Eastman
Kodak
Co.
­
Kodak
Park
Plant
1669
Lake
Avenue
Rochester,
NY
14652
Monroe
43

12'
10"
77

37'
45"
3861
325992
Advantix
film
Imation
Enterprises
Corp.
2700
East
Frontage
Road
Weatherford,
OK
73096
Custer
35

32'
03"
98

40'
25"
3695
334613
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.
2­
8
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
EMISSIONS
2­
9
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.
2­
9
Table
2­
2.
Recent
HAP
Emissions
from
Magnetic
Tape
Manufacturing
Facilities
a
Facility
name
Pollutant
Emissions
Notes
Mg/
yr
ton/
yr
Quantegy
Inc.
Opelika,
AL
Cobalt
0.005
0.005
Data
from
TRI
(
2000)
and
NEI
(
1999)

MEK
27
30
Toluene
17
19
HAP
subtotal
44
49
JVC
Magnetics
America
Co.
Tuscaloosa,
AL
MEK
76
84
Data
from
TRI
(
2000)

Toluene
50
55
HAP
subtotal
126
139
3M
Magnetic
Tape
Manufacturing
Division
Hutchinson,
MN
Acrylic
acid
2.0
2.2
Data
from
TRI
(
2000);
estimated
emissions
by
applying
30
percent
factor
to
the
total
facility
emissions
for
each
pollutant
Antimony
0.003
0.003
Ethylbenzene
0.04
0.05
Ethylene
glycol
0.006
0.007
n­
Hexane
2.4
2.6
Lead
compounds
0.003
0.004
MEK
35
39
Methanol
11
12
MIBK
0.1
0.2
Toluene
24
26
Xylenes
0.2
0.2
HAP
subtotal
74
82
Eastman
Kodak
Co.
Kodak
Park
Rochester,
NY
Cobalt
<
0.001
<
0.001
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
Hydrogen
chloride
0.03
0.04
MEK
1.1
1.2
Toluene
2.8
3
HAP
subtotal
3.9
4.3
Imation
Enterprises
Corp.
Weatherford,
OK
Acrylonitrile
0.004
0.004
Data
from
NEI
(
1999)

MEK
4.9
5.4
Methanol
0.02
0.02
Toluene
0.4
0.4
HAP
subtotal
5.3
5.8
Sony
Magnetic
Products
Inc.
of
America
Dothan,
AL
Cobalt
0.3
0.3
Data
from
TRI
(
2000)
and
Sony
(
2000)

Cobalt
compounds
0.003
0.004
MEK
172
190
Toluene
42
46
HAP
subtotal
214
236
a
Data
were
from
1999,
2000,
or
2001,
depending
on
the
facility.
2­
10
Table
2­
3.
Summary
of
Total
HAP
Emissions
a
Pollutant
Emissions
Percent
of
total
Mg/
yr
ton/
yr
Acrylic
acid
2.0
2.2
0.4
Acrylonitrile
0.004
0.004
<
0.01
Antimony
0.003
0.003
<
0.01
Cobalt
0.3
0.3
0.06
Cobalt
compounds
0.003
0.004
<
0.01
Ethylbenzene
0.04
0.05
<
0.01
Ethylene
glycol
0.006
0.007
<
0.01
n­
Hexane
2.4
2.6
0.5
Hydrogen
chloride
0.03
0.04
<
0.01
Lead
compounds
0.003
0.004
<
0.01
MEK
317
349
68
Methanol
11
12
2.3
MIBK
0.1
0.2
0.03
Toluene
136
150
29
Xylenes
0.2
0.2
0.03
Total
468
516
100
a
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.
2­
11
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.
2­
12
This
page
intentionally
left
blank.
3­
1
Chapter
3
Existing
Regulations
3.1
SUMMARY
OF
NEW
SOURCE
PERFORMANCE
STANDARDS
1
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
3­
2
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
1
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
3
(
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
NESHAP
2,3
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
lb/
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.
3­
4
Table
3­
1.
Summary
of
the
Magnetic
Tape
Manufacturing
Standard
Emission
point
Standards
Each
solvent
storage
tank
§
63.703(
c)(
1):
Overall
(
i.
e.,
capture
×
control
device
efficiency)
HAP
control
efficiency
of
>
95
percent;
or
§
63.703(
c)(
2):
For
incinerators,
an
alternate
outlet
HAP
concentration
of
<
20
ppmv;
or
§
63.704(
c)(
4):
Do
not
control
solvent
storage
tanks,
but
control
coating
operations
at
higher
efficiencies
specified
in
rule;
or
§
63.703(
i):
Establish
an
alternate
maximum
HAP
outlet
concentration
monitored
with
a
continuous
emission
monitor
(
CEM)
to
demonstrate
compliance
during
periods
when
coaters
are
not
operating.

Each
piece
of
mix
preparation
equipment
§
63.703(
c)(
1):
Overall
HAP
control
efficiency
of
>
95
percent;
or
§
63.703(
c)(
2):
For
incinerators,
an
alternate
outlet
HAP
concentration
of
<
20
ppmv;
or
§
63.703(
i):
Establish
an
alternate
maximum
HAP
outlet
concentration
monitored
with
a
CEM
to
demonstrate
compliance
during
periods
when
coaters
are
not
operating.

Each
coating
operation
§
63.703(
c)(
1):
Overall
HAP
control
efficiency
of
>
95
percent;
or
§
63.703(
c)(
2):
For
incinerators,
an
outlet
HAP
concentration
of
<
20
ppmv;
or
§
63.703(
c)(
4):
Control
all
coating
operations
at
specified
higher
efficiencies
instead
of
controlling
solvent
storage
tanks;
or
§
63.703(
c)(
5):
Use
coating
with
HAP
content
no
greater
than
0.18
kg/
L
(
1.5
lb/
gal)
of
coating
solids.

Each
waste
handling
device
§
63.703(
c)(
1):
Overall
HAP
control
efficiency
of
>
95
percent;
or
§
63.703(
c)(
2):
For
incinerators,
an
alternate
outlet
HAP
concentration
of
<
20
ppmv;
or
§
63.703(
i):
Establish
an
alternate
maximum
HAP
outlet
concentration
to
demonstrate
compliance
during
periods
when
coaters
are
not
operating.

Each
condenser
vent
in
solvent
recovery
§
63.703(
c)(
1):
Overall
HAP
control
efficiency
of
>
95
percent;
or
§
63.703(
c)(
2):
For
incinerators,
an
alternate
outlet
HAP
concentration
of
<
20
ppmv;
or
§
63.703(
i):
Establish
an
alternate
maximum
HAP
outlet
concentration
to
demonstrate
compliance
during
periods
when
coaters
are
not
operating.

Each
particulate
transfer
operation
§
63.703(
d)(
1):
Use
enclosed
transfer;
or
§
63.703(
d)(
2):
Vent
to
baghouse/
fabric
filter
that
exhibits
no
visible
emissions
while
controlling
particulate
HAP
transfer.

(
continues)
Table
3­
1.
(
continued)

Emission
point
Standards
3­
5
Each
wash
sink
for
cleaning
removable
parts
§
63.703(
e)(
1)(
i):
Overall
HAP
control
efficiency
of
>
88
percent;
or
§
63.703(
e)(
1)(
ii):
Minimum
freeboard
ratio
of
75
percent;
or
§
63.703(
i):
Establish
an
alternate
maximum
HAP
outlet
concentration
to
demonstrate
compliance
during
periods
when
coaters
are
not
operating.

Each
piece
of
equipment
for
flushing
fixed
lines
§
63.703(
f)(
1)(
i):
Overall
HAP
control
efficiency
of
>
95
percent;
or
§
63.703(
f)(
i)(
ii):
Use
closed
system;
or
§
63.703(
i):
Establish
an
alternate
maximum
HAP
outlet
concentration
to
demonstrate
compliance
during
periods
when
coaters
are
not
operating.

Each
wastewater
treatment
operation
§
63.703(
g):
Treat
to
remove
HAP
by
the
fraction
removed
that
is
specified
in
Table
9
of
40
CFR
part
63,
subpart
G;
Treat
to
remove
HAP
so
that
total
volatile
organic
HAP
concentration
at
exit
is
<
50
parts
per
million
by
weight.

3.4
REFERENCES
1.
U.
S.
Environmental
Protection
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.

2.
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.

3.
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
6
This
page
intentionally
left
blank.
4­
1
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
2
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)(
1)
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
3
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
4
This
page
intentionally
left
blank.
5­
1
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
2
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
COLLECTION
1,2
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
Pollutants
3
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
3
5.1.2
Source
Identification
4
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
Characterization
5
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
4
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
colocated
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
ANALYSES
6
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
5
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
Emissions
MIRa
Chronic
HI
Mg/
yr
ton/
yr
Quantegy
44
49
NA
0.008
JVC
Magnetics
America
126
139
NA
0.02
3M
Magnetic
Tape
74
82
NA
0.3
Eastman
Kodak
3.9
4.3
NA
0.0002
Imation
Enterprises
5.3
5.8
1x10­
8
0.0002
Sony
Magnetic
Products
214
236
NA
0.2
a
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
6
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
healthprotective
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
SCREEN3
air
dispersion
model
was
used
for
the
assessment
of
acute
exposures.

SCREEN3
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.
5­
7
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
colocated
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
8
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
9
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).
5­
10
This
page
intentionally
left
blank.
6­
1
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.
6­
2
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
6­
3
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).
6­
4
This
page
intentionally
left
blank.
TECHNICAL
REPORT
DATA
1.
REPORT
NO.

EPA­
453/
R­
05­
001
2.
3.
RECIPIENT'S
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
Office
of
Air
Quality
Planning
and
Standards
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
13.
TYPE
OF
REPORT
AND
PERIOD
COVERED
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
a.
DESCRIPTORS
b.
IDENTIFIERS/
OPEN
ENDED
TERMS
c.
COSATI
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
United
States
Office
of
Air
Quality
Planning
and
Standards
Publication
No.
EPA­
453/
R­
05­
001
Environmental
Protection
Emission
Standards
Division
July
2005
Agency
Research
Triangle
Park,
NC
