Hazardous Air Pollutant

Emissions from the

Manufacture of Amino

and Phenolic Resins

Basis and Purpose Document

for Proposed Standards

United States

Environmental Protection

Agency

Office of Air Quality

Planning and Standards

Research Triangle Park, NC 27711

Air

May 1998
Hazardous Air Pollutant Emissions

From the Manufacture

Of Amino and

Phenolic Resins

Basis and Purpose Document

for Proposed Standards

Emission Standards Division

U.S. Environmental Protection Agency

Office of Air And Radiation

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711

May 1998
iii

DISCLAIMER

This report has been reviewed by the Emission Standards Division

of the Office of Air Quality Planning and Standards, EPA, and

approved for publication. Mention of trade names or commercial

products is not intended to constitute endorsement or

recommendation for use.
iv

ENVIRONMENTAL PROTECTION AGENCY

Manufacture of Amino/Phenolic Resins -- 

Basis and Purpose Document for Proposed Standards

1. The standards regulate organic hazardous air pollutant (HAP)

emissions from the manufacture of amino and phenolic resins. 

Only those resin process units that are part of major

sources under section 112(d) of the Clean Air Act (Act) will

be regulated.

2. For additional information contact:

Mr. John Schaefer

Organic Chemicals Group

U.S. environmental Protection Agency (MD-13)

Research Triangle Park, NC 27711

Telephone: (919) 541-0296

E-MAIL: SCHAEFER.JOHN@EPAMAIL.EPA.GOV

3. Paper copies of this document may be obtained from:

U.S. Environmental Protection Agency Library (MD-36)

Research Triangle Park, NC 27711

Telephone: (919) 541-2777

National Technical Information Service (NTIS)

5285 Port Royal Road

Springfield, VA 22161

Telephone: (703) 487-4650

4. Electronic copies of this document may be obtained from the

EPA Technology Transfer Network (TTN) over the internet by

going to the following address:

http://www.epa.gov/ttncaaa1/t3bid.html

5. Electronic copies of this document may be obtained from the

EPA TTN electronic bulletin board system which is free,

except for the normal long distance charges. To access the

Basis and Purpose Document:

• Set software communication setting to 8 bits, no

parity, and 1 stop bit

• Set a terminal emulation of either VT100, VT102, or

ANSI

• Baud rates of 1200, 2400, 9600, 14,400 are accepted

• Use access number (919) 541-5742; access problems
v

should be directed to the system operator at (919) 541-

5384

• Register online by providing a personal name and

password

• Specify TTN Bulletin Board: Clean Air Act Amendments

• Select menu item: Recently Signed Rules
vi

TABLE OF CONTENTS

Page

1.0 PURPOSE OF DOCUMENT ................ 1-1

2.0 INTRODUCTION ................... 2-1

3.0 DESCRIPTION OF THE AFFECTED INDUSTRY ....... 3-1

3.1 General ................... 3-1

3.2 Amino Resins Production ........... 3-6

3.3 Phenolic Resins Production ........ 3-10

3.4 Emissions ................. 3-16

3.5 References ................. 3-20

4.0 SELECTION OF SOURCE CATEGORY ........... 4-1

5.0 BASELINE EMISSIONS ................ 5-1

6.0 MACT FLOORS AND REGULATORY ALTERNATIVES ...... 6-1

6.1 Clean Air Act Requirements .......... 6-1

6.2 General Approach for MACT Floors and

Regulatory Alternatives Beyond the MACT Floor 6-3

6.3 Determination of MACT Floors for 

Storage Vessels ............... 6-8

6.4 Determination of MACT Floors for Continuous

Process Vents ............... 6-16

6.5 Determination of MACT Floors for Reactor Batch

Process Vents ............... 6-19

6.6 Determination of MACT Floors for Non-Reactor Batch

Process Vents ............... 6-24

6.7 Determination of MACT Floors for Wastewater 6-31

6.8 Determination of MACT Floors for Equipment 

Leaks ................... 6-32

6.9 Regulatory Alternatives Beyond the MACT Floor 6-34
vii

TABLE OF CONTENTS (concluded)

Page

7.0 SUMMARY OF ENVIRONMENTAL, ENERGY, COST

AND ECONOMIC IMPACTS ............... 7-1

7.1 Facilities Affected by this NESHAP ...... 7-1

7.2 Primary Air Impacts ............. 7-2

7.3 Non-air Environmental Impacts ........ 7-3

7.4 Energy Impacts ................ 7-5

7.5 Cost Impacts ................. 7-7

7.6 Economic Impacts .............. 7-14

8.0 SUMMARY OF THE PROPOSED STANDARDS ......... 8-1

8.1 Source Category to be Regulated and

 Definition of Affected Source ....... 8-1

8.2 Relationship to Other Rules ......... 8-3

8.3 Pollutants to be Regulated .......... 8-5

8.4 Affected Emission Points ........... 8-6

8.5 Format of the Standard ............ 8-6

8.6 Summary of the Proposed Standards ...... 8-9
viii

LIST OF TABLES

Table Title Page

3-1 Amino and Phenolic Resin Production 

Facilities .................... 3-2

5-1 Baseline Organic HAP Emissions by Emission

Point for Major Existing Sources ......... 5-1

5-2 Predominant HAP Emitted by Emission Point ..... 5-2

6-1 MACT Floor and Regulatory Alternatives Beyond the MACT 

Floor Analysis for Existing and New Affected

Sources ...................... 6-5

6-2 Amino/Phenolic Resin Storage Vessels Raw

Material Tanks from Top 5 Facilities ....... 6-9

6-3 HON Analysis of Raw Material Tanks ....... 6-12

6-4 Continuous Process Vent Controls at

Major Sources .................. 6-17

6-5 Top Facilities for Reactor Batch Process Vents

Based on Applied Secondary Controls ....... 6-20

6-6 Top 5 Facilities for Non-Reactor Batch Process

Vents Based on Overall Percent Reduction .... 6-26

6-7 TRE Analysis for Continuous Process Vents at

Existing Affected Sources ............ 6-37

6-8 TRE Analysis for Continuous Process Vents at

New Affected Sources .............. 6-37
ix

LIST OF TABLES (concluded)

Table Title Page

6-9 Wastewater Flow and Concentration Data ..... 6-43

6-10 Emission Reductions and Cost Effectiveness

for Selected Wastewater Streams ......... 6-46

6-11 Summary of LDAR Regulatory Alternatives .... 6-49

6-12 Summary of Regulatory Analysis for Equipment

Leaks ...................... 6-54

7-1 Organic HAP Emission Reductions by Emission

Point for Existing Sources ............ 7-3

7-2 Summary of Cost Impacts .............. 7-9

8-1 Proposed Standards for New Affected Sources ... 8-10

8-1 Proposed Standards for Existing Affected Sources 8-12
x

LIST OF FIGURES

Figure Title Page

3-1 Amino Resins Manufacturing Process ...... 3-9

3-2 Phenolic Resins Manufacturing Process ... 3-12
1-1

1.0 PURPOSE OF DOCUMENT

The draft Basis and Purpose Document provides background

information on, and rationale for, decisions by the Environmental

Protection Agency (EPA) related to the proposed standards for the

reduction of hazardous air pollutants (HAP) emitted through the

manufacture of amino/phenolic resins. This document is intended

to supplement the preamble for the proposed standards.

This document is separated into eight chapters providing a

combination of background information and EPA rationale for

decisions made in the standards development process. Chapters 2,

3, 5, and 7 provide background information; chapter 2 is an

introduction, chapter 3 describes the affected industry, chapter

5 presents the baseline HAP emissions, and chapter 7 presents the

predicted impacts associated with the regulatory alternatives. 

Chapters 4, 6, and 8 provide the EPA’s rationale for the

selection of the source category, the determination of MACT

“floors” and development of regulatory alternatives beyond the

MACT Floor, and a summary of the proposed standards,

respectively.

Supporting information and more detailed descriptions for

technical and rationale chapters are contained in the memorandum

referenced in this document and contained in the project docket.
2-1

2.0 INTRODUCTION

Section 112 of the Clean Air Act (CAA), as amended in 1990

(1990 Amendments) provides the EPA with the authority to

establish national standards to reduce air emissions from sources

that emit one or more of 188 hazardous air pollutants (HAP). 

Section 112(b) of the Clean Air Act contains a list of HAP to be

regulated by National Emission Standards for Hazardous Air

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

this pollutant list to develop and publish a list of source

categories for which NESHAP will be developed. The EPA must list

all known source categories and subcategories of “major sources”

that emit one or more of the listed HAP. A major source is

defined in Section 112(a) as any stationary source or group of

stationary sources located within a contiguous area and under

common control that emits, or has the potential to emit

considering controls, in the aggregate, 10 tons per year of any

one HAP or 25 tons per year of any combination of HAP. This list

of source categories was published in the Federal Register on

July 16, 1992 (57 FR 31576).

The published list of source categories included the amino

resins production source category and the phenolic resins

production source category. These two products can broadly be

classified as formaldehyde-based thermosetting resins. Because

of similarities in the production process, HAP emissions,

emission profiles, and applicable control technology, the
2-2

proposed regulation combines the amino and phenolic resins

production categories into a single source category called

amino/phenolic resins production.
Table 3-1. AMINO/PHENOLIC RESIN PRODUCTION FACILITIES

3-1

3.0 DESCRIPTION OF THE AFFECTED INDUSTRY

This chapter presents a brief description of the industry

affected by this rule. This chapter is divided into five separate

sections: Section 3.1 provides a basic description of the

amino/phenolic resins industry, Section 3.2 describes of the

amino resins production process, Section 3.3 describes the

phenolic resins production process, Section 3.4 describes

emission points for the amino/phenolic resins production

processes, and Section 3.5 lists references for this chapter.

3.1 GENERAL

The EPA has identified a total of 99 plant sites producing

either amino or phenolic resins. The majority of these

facilities are either area sources or synthetic area sources.1

Table 3-1 identifies the known producers of amino/phenolic

resins, along with their facility locations. The amino/phenolic

resin manufacturing facilities covered in the scope of this

NESHAP are located in 30 states. The largest number of

facilities are located in Oregon, followed by: North Carolina,

Alabama, Ohio, Texas, Illinois, and South Carolina. 

Amino resins are produced by reacting formaldehyde (CH2O)

with an amino compound [a compound with an amino group (NH2)]. 

Company Location

3M Cottage Grove, MN

3M Hartford City, IN
Table 3-1. AMINO/PHENOLIC RESIN PRODUCTION FACILITIES

Company Location

3-2

3M North Cordova, IL

Akzo Louisville, KY

AMETEK Wilmington, DE

Ashland Calumet City, IL

Ashland Cleveland, OH

Auralax Norwich, CT

BASF Greenville, OH

Bendix Green Island, NJ

Borden Alexandria, LA

Borden Demopolis, AL

Borden Diboll, TX

Borden Fayetteville, NC

Borden Forest Park, OH

Borden Fremont, CA

Borden Island City, OR

Borden Louisville, KY

Borden Missoula, MT

Borden Morganton, NC

Borden Mt. Jewett, PA

Borden North Kent, WA

Borden Sheboygan, WI

Borden Springfield, OR

BTL Toledo, OH

Capital Resins Columbus, OH

Cargill Carpentersville, IL

CNC International Woonsocket, RI

Cook Composites Houston, TX

Cytec Kalamazoo, MI

Cytec Mobile, AL

Cytec (A.C. Molding) Wallingford, CT

Cytec (Negron) Wallingford, CT

Delta Resins Detroit, MI

Delta Resins Milwaukee, WI

Dexter Birmingham, AL

Dexter Waukegan, IL
Table 3-1. AMINO/PHENOLIC RESIN PRODUCTION FACILITIES

Company Location

3-3

Dock Resins Linden, NJ

Dynachem Georgetown, IL

Exxon Chemical Houston, TX

Freedom Textile Charlotte, NC

Georgia-Pacific Albany, OR

Georgia-Pacific Columbus, OH

Georgia-Pacific Conway, NC

Georgia-Pacific Crossett, AR

Georgia-Pacific Elk Grove, CA

Georgia-Pacific Eugene, OR

Georgia-Pacific Grayling, MI

Georgia-Pacific Louisville, MS

Georgia-Pacific Lufkin, TX

Georgia-Pacific Peachtree City, GA

Georgia-Pacific Port Wentworth, GA

Georgia-Pacific Russellville, SC

Georgia-Pacific Taylorsville, MS

Georgia-Pacific Ukiah, CA

Georgia-Pacific Vienna, GA

Georgia-Pacific Virginia, MN

Georgia-Pacific White City, OR

Heresite Protective Coatings Manitowoc, WI

Hickson Danville, VA

Hoechst Celanese Mount Holly, NC

Insulating Materials Schenectady, NY

International Paper Hampton, SC

IVAX Industries Rock Hill, SC

Lawter International Moundville, AL

National Starch Salisbury, NC

Neste Andalusia, AL

Neste Moncure, NC

Neste North Winnfield, LA

Neste Spokane, WA

Neste Springfield, OR

Neste Toledo, OH
Table 3-1. AMINO/PHENOLIC RESIN PRODUCTION FACILITIES

Company Location

3-4

NM Adhesives Las Vegas, NM

Occidental Niagara Falls, NY

Occidental North Tonawanda, NY

Occidental South Kenton, OH

Perstorp Florence, MA

Pioneer Florence, ME

Plastics Engineering Sheboygan, WI

PMC Specialties Fords, NJ

P.D. George St. Louis, MO

Ranbar Manor, PA

Reichold Newark, NJ

Rhone-Polenc Louisville, KY

Schenectady Rotterdam Junction, NY

Schenectady Schenectady, NY

Sequa Chester, SC

Simpson Timber Portland, OR

Solutia Addyston, OH

Solutia Springfield, MA

Southeastern Adhesives Lenoir, NC

Southeastern Adhesives Ridgeway, VA

Spaulding Composites Dekalb, IL

Spurlock Adhesives East Waverly, VA

Stuart-Ironsides, Inc. Chicago, IL

Sun Coast Dallas, TX

Sybron Chemicals Birmingham, NJ

Synthron, Inc. Morganton, NC

Valentine Sugars Lockport, LA
N

H

H

N C

H

H

O

(2)H C

O

H HO CH2 N C

H

N CH2 OH

O H

+ =

(Urea) (Formaldehyde) Dimethylol Urea (DMU)

3-5

In general, amino resins use urea (NH2CONH2), a urea derivative,

or melamine (C3N3(NH2)3) to form methylol monomer units, which are

subsequently condensed to form a polymer. 

Amino resin means a resin produced through the reaction of

formaldehyde, or a formaldehyde containing solution (e.g.,

aqueous formaldehyde), with compound(s) that contain the

amino group; these compounds include melamine, urea, and

urea derivatives. 

Phenolic resins are formed by reacting phenol (C6H11OH) with

formaldehyde. 

Phenolic resin means a resin that is a condensation product

of formaldehyde and phenol, or a formaldehyde substitute

and/or a phenol substitute. Substitutes for formaldehyde

include acetaldehyde or furfuraldehyde. Substitutes for

phenol include other phenolic starting compounds such as

cresol, xylenols, p-tert-butylphenol, p-phenylphenol, and

nonylphenol.

Both phenolic and amino resins are produced in processes

that are very similar to one another. Jacketed steel or

stainless steel reaction vessels equipped with an agitator and a

condenser are generally used.

3.2 AMINO RESINS PRODUCTION

The overall reaction for amino resins formation is similar

to that for phenol-formaldehyde resol formation. The first step 2

is the addition of formaldehyde to the amino compound and is

known as methylation or hydroxymethylation. This step is shown

for the urea-formaldehyde process in the following reaction:
H N

O C

HO CH2 N H

CH2

N H

C O

H N 2

CH HO

+ H2O H C H

O

+

(Initial U-F Polymer) (Water) (Formaldehyde)

H N CH2 OH

O C

HO CH2N H

HO CH2 N H

C O

CH OH 2 H N

+

3-6

This step is usually catalyzed by a base compound since the

compounds are more stable under alkaline conditions.2

The second step is known as condensation, methylene bridge

formation, polymerization, or simply cure. During condensation,

water is removed from the monomer units. Amino units are then

joined with the methylene links. The reaction process for the

urea-formaldehyde process is as follows:

This step

is cata

lyze d by

acid s

and ofte

n by heat

.

2

The processes that produce urea or melamine formaldehyde

resins are very similar. Often the same equipment is used to

produce both melamine and urea formaldehyde resins. This section

will discuss a general amino resins process production process.
3-7

Amino resins are manufactured in a simple batch process. 

The initial product is a concentrated syrup which is then sold or

further processed into solids. Figure 3-1 is a schematic

representation of the batch process.

Aqueous formaldehyde solution (usually 37% or 50%) is drawn

from storage and fed to a resin reactor (typically 2,000 to

10,000 gallons). Amino compounds, catalysts, and additives are

added and mixed. An additive used in large quantities for 8

melamine resins is methanol, which helps stabilize the compound.2

The reactor is agitated continuously and the mixture is heated to

the desired temperature by steam in the reactor jacket. The

progress of the reaction is measured periodically by sampling for

viscosity. When the desired viscosity has been reached, the

batch is cooled in the reactor and the syrup is concentrated by

evaporation of water with a vacuum. The pH is adjusted and the

syrup is pumped through a filter and into a syrup storage tank. 

The syrup is then stored for sale, concentrated further, or

processed into a powder. Solid powder is produced in a two-step

process and can consist of either an unfilled powder which is

manufactured by spray drying, or a filled powder in which a solid 
Melamine

Storage

Urea

Storage

Steam

Cold Water Syrup Storage

Filters

Drum Flaker

(Chilled)

Grinder

Resin Impregnator

(Mixer) Dryer Molding Powder To Packaging

Two-Step

Process

Additives

Acid or Base 

Catalyst

Formaldehyde

Solution

(37 or 50)%

Steam H O2

Scrubber

Reflux

Condensor

Cold

Water

Vacuum

Pump

FIGURE 3-1. AMINO RESINS MANUFACTURING PROCESS

Process Vent

 Emissions Equipment Leak Emissions

Dryer

 Emissions

3-8
3-9

is saturated with syrup. The powder is then dried and

pulverized. The powder can be sold as a powder or it can be

deaerated into granules.7

3.3 PHENOLIC RESINS PRODUCTION

Phenolic resins are condensation products of formaldehyde

and phenol. Besides formaldehyde, acetaldehyde or 2,3,4

furfuraldehyde is sometimes used but in much smaller quantities. 

In addition to phenol, other phenolic starting compounds include

alkyl-substituted phenols, such as cresols, xylenols, p-tertbutylphenol, p-phenylphenol, and nonylphenol.3

Resols and novolaks are two types of phenolic resins

produced. Resols are produced in a one-step process either as 2,3,4

an aqueous syrup (liquid resole) or as a varnish (solid resole

dissolved in an alcohol or organic solvent). Novolaks are

produced in a two-step process to form molding powders.2

3.3.1 Resols Process Description

In the production of resole resins, a mole ratio of 1 to 3,

formaldehyde to phenol respectively, is generally used with a

basic catalyst such as sodium, barium, calcium hydroxide, sodium

carbonate, or an organic amine. The conventional mechanism of 3,4

polymerization is shown in the following reactions:
3-10

Depending on the extent of the polymerization and the

functionality, which is the total number of unsubstituted

positions on the benzene ring that are specific to the

application, intended for the material, the materials can be high

in molecular weight and viscosity.

Resols resin production is conducted in a batch process

reactor. Figure 3-2 shows a diagram for a typical batch process

for resols and novolaks. The process for resols will produce 2

either liquid or solid resols. Liquid resols (aqueous syrup) can

be produced in large capacity reactors because their viscosities

can be controlled and they do not have to be discharged as

rapidly as solid resols.
Weigh

Tank

Weigh

Tank

Organic Solvents

(Methanol, Ethanol,

& Butanol)

Formaldehyde

Solution

(37 or 50)%

Steam

Phenol

Storage

Steam

Syrup

Storage

Varnish

Storage

Acid or Base

Catalyst

Additives

Steam

Cold Water

Drum Flaker

(Chilled)

Grinder

Ribbon Blenders

Filler

Catalyst

Additives

Pelletizer

Molding Powder

to Packaging

Reactor

H O2

Scrubber

Reflux

Condensor

Cold

Water

Vacuum

Pump

Filters

FIGURE 3-2. PHENOLIC RESINS MANUFACTURING PROCESS

3-11
3-12

Solid resols generally require a relatively small reactor

(10 cubic meters) to maintain thermal stablity and to allow rapid

discharge since near the end of the reaction the viscosity

increases rapidly. An agitator is used to prevent local gelation

and to provide power to circulate the viscous fluids. A batch 3

cycle normally takes eight hours.

Raw materials in the production of resoles are molten

phenol, formaldehyde (37 or 50 percent aqueous solution), and an

organic solvent. Molten phenol which is fed through a weigh tank

and the desired basic catalyst, such as sodium hydroxide, are

charged first to the reactor. Next the 37% or 50% aqueous

formaldehyde is fed through a weigh tank and added to the reactor

at a rate to maintain a temperature of 60 to 70EC (140 to 158EF). 

The desired reaction temperature, approximately 80 to 100EC (176

to 212EF), is achieved by heating the mixture in a reaction

vessel that has an internal coil or external, temperaturecontrolled jacket. In addition, agitation and a vacuum reflux

are used to maintain the desired temperature. The temperature is

maintained for 1 to 3 hours. The reaction is monitored at short

intervals by measuring the viscosity of a sample from the

reactor. When the desired end point is reached, the reaction

mixture is neutralized with an acid such as acetic, formic,

sulfuric, or phosphoric acid. Evaporation of the water

(distillation) is performed in the reactor under a vacuum until

the desired syrup concentration is achieved. The reaction
3-13

contents are then cooled as rapidly as possible by discharging

them to cooled engineered surfaces, such as air-cooled floors,

moving belts, or trays in racks. The aqueous syrup is then

filtered and stored, usually in a refrigerator for future use.

After the distillation step is completed, a solvent, such as

methanol, is added to the solid resole and the product is

recovered as a varnish solution. The varnish solution is then

stored for future use. In either liquid or solid resoles,

additives and modifiers may be introduced during different steps

of the process.

3.3.2 Novolaks Production

In the production of novolak resins, a mole ratio of

formaldehyde to phenol is normally between 0.70 and 0.85.3,4

Oxalic acid is normally the catalyst used in the process;

however, acid catalysts such as hydrochloric acid, sulfuric acid,

sulfonic acid, p-toluene and phosphoric acid are sometimes used.3

When an acid catalyst is used, phenol and formaldehyde react by

way of electrophilic substitution. The general mechanism for

polymerization is given in the following reactions.3,4
OH

+ CH2OH +

slow fast

OH

H

CH2OH

OH

CH2OH

+ H

+

+

OH

CH2OH

H

+

OH

CH2OH

+

H2O

+

OH OH

CH2

+

OH OH

CH2

H

+

+

3-14

For the batch process of novolak resin production, a twostep process is generally used. Figure 3-2 shows a diagram for a

typical batch process.2,3,4

Phenol, which is stored in alloyed steel tanks at

approximately 60EC (140EF), is weighed and transferred to the

reactor where it is heated to 95EC (203EF). The acidic catalyst,

which is usually oxalic acid, is then added to the reactor. 

After the acidic catalyst has been added, an aqueous formaldehyde

solution is stirred into the reactor. The solution is stirred at

a rate designed to maintain a gentle boiling of the mixture. The

temperature of the mixture is maintained until the reaction has

exhausted the supply of formaldehyde. Water and unreacted phenol

are removed from the reaction mixture by heating an external

heating jacket to approximately 132E (270EF) at atmospheric

pressure. The reaction mixture is heated further to 160EC
3-15

(320EF). By using a vacuum and injecting live steam into the

reaction mixture, the residual volatiles are removed from the

resin. When the desired melting point is achieved, the resin is

fed to a heated vessel. It is then flaked onto a continuous

cooling belt. To form a powder resin, the flake is fed to a

grinder. In some cases, the powder resin is blended with

additives in a ribbon blender and then sent to a pelletizer for

further processing.

3.4 EMISSIONS

The potential emission points for amino/phenolic resins are

the same. Potential emission points include the following:

reactor batch process vents, non-reactor batch process vents,

continuous process vents, equipment leaks, wastewater, and

storage vessels.

3.4.1 Reactor Batch Process Vent Emissions

The manufacture of amino/phenolic resins takes place in a

single batch reactor. Emissions associated with the batch

reactor include charging, cooking or reflux, and distillation. 

The primary HAP emitted from batch reactor process vents are

formaldehyde, methanol, and phenol. These HAP can potentially be

emitted during each of the above events.

During the initial charging phase of a typical batch, a

highly exothermic reaction takes place which produces the highest

emissions. During the cooking phase, the reactor is operated in

reflux with vapors being condensed and returned to the reactor. 
3-16

Very few emissions occur during this phase. Finally, emissions

can occur during the distillation phase when a vacuum is pulled

on the reactor and excess water is evaporated from the product.

3.4.2 Non-reactor Batch Process Vent Emissions

Potential emissions can also occur from a variety of

equipment located at the facility including, but is not limited

to, mix tanks, flakers, and filters. The primary HAP emitted

from batch non-reactor process vents are formaldehyde, methanol,

phenol, and xylene.

3.4.3 Continuous Process Vent Emissions

Potential emissions can occur from spray drying operations. 

Spray drying operations include belt dryers, continuous drum

dryers, and continuous screen dryers that are vented to the

atmosphere.8

3.4.4 Equipment Leak Emissions

Equipment leak emissions occur while valves, pumps, flanges,

and other equipment are in HAP service. The amount of emissions

emitted from these components depend on the number of leaking

components, the type of service (i.e., gas/vapor, light liquid,

or heavy liquid), the percent of HAP contained in the process

fluid contacting the components, and the amount of time the

components remains in contact with the process fluid. The type

of HAP emitted depends on the process fluid in contact with the

component. Typical HAP emitted are formaldehyde, phenol,

methanol, and other chemicals that are charged to the reactor. 
3-17

HAP emissions occur from these components only when they are in

contact with the process fluid and there is a leak. Facilities

may flush their process lines so that some of the components are

no longer in contact with process fluids. During those periods

of time, there would be no potential emissions from the

components.

3.4.5 Wastewater Emissions

HAP emissions from wastewater can occur when the resin is

distilled to remove excess water and during reactor cleaning. In

addition, wastewater can result from the use of scrubbers;

several facilities use scrubbers as control devices. The primary

HAP emitted from wastewater at amino/phenolic resin facilities

are formaldehyde and methanol.

3.4.6 Storage Vessel Emissions

HAP emissions from storage vessels occur when material is

added to the storage vessel (loading emissions), which displaces

HAP-containing air from the vessel. Emissions from storage

vessels also occur as the result of breathing (or standing)

losses, which are emissions from the tank that occur when there

is no displacement of vapor (i.e., no filling or emptying of the

storage vessel). The amount of HAP emissions that occur from

storage vessels depends on the type of organic liquid in the

storage vessel, the type of storage vessel (e.g., fixed roof

tank, floating roof tank), the methods used to fill and empty the

tank, and the number of turnovers per year. The primary HAP
3-18

emitted from storage vessels at amino/phenolic resin facilities

are formaldehyde, methanol, phenol, toluene, and xylene.
3-19

3.5 REFERENCES

1. U.S. Environmental Protection Agency. Office of Air Quality

Planning and Standards. Information Collection Request from the

Amino and Phenolic Resins Industry, 1992

2. Polymer Industry Ranking by VOC Emissions Reduction That

Would Occur From New Source Performance Standards, C.N. Click and

D.K. Webber, Pullman Kellogg Houston, TX, 1979.

3. “Phenolic Resins”, Kirk-Othmer Encyclopedia of Chemical

Technology, 3rd Edition, Vol. 17.

4. Phenolic Resins Chemistry Applications and Performance. 

Andre Knop, Louis A. Pilato, Springer-Verlay, 1985.

5. 1991 Directory of Chemical Producers. United States of

America. Menlo Park, California, Chemical Information Services,

Stanford Research Institute, 1991.

6. Hawley’s Condensed Chemical Dictionary, 11th Edition,

Revised by B. Irving Sax and Richard Lewis, Sr., Van Nostrand

Reinhold Company, New York, 1987.

7. “Urea Formaldehyde Resins”, Perter D. Wallace, Borden, Inc.,

Presented at Technical Association of Pulp & Paper Industry

(TAPPI), October 1983.

8. Wilkins, G.E. Industrial Process Profiles for Environmental

Use. Chapter 10--Plastics and Resins Industry. U.S.

Environmental Protection Agency. Cincinnati, OH. EPA-600/2-77-

023j. February 1977.
4-1

4.0 SELECTION OF SOURCE CATEGORY

The amino resins production and phenolic resins production

source categories are listed in the source category list

published on July 16, 1992 (57 FR 3156). As noted in Chapter 2,

these two source categories are being combined into a single

source category for the purposes of this rulemaking. This action

is being taken due to similarities in process operations,

emissions characteristics, and control device applicability.

As described in detail in Chapter 3, the amino resins

manufacturing process and the phenolic resins manufacturing

process are very similar. At many facilities, the same process

equipment is used to produce both amino and phenolic resins. For

such facilities, complying with two different sets of standards

would be difficult, if not impossible. In addition, the emission

points for facilities manufacturing amino and phenolic resins are

the same (reactor and non-reactor process vents, dryer vents,

storage vessels, wastewater, and equipment leaks) and the

resulting emission characteristics are very similar. Lastly,

amino and phenolic manufacturing facilities use the same types of

control devices to control HAP emissions from corresponding

emission points; that is, there are no significant differences in

the types of control technologies applicable to controlling

emissions from amino and phenolic resins manufacturing processes. 
4-2

Common HAP control technologies are applicable to all production

operations at all of the facilities.

Another consideration in treating amino and phenolic resin

facilities under a single set of standards is the cost involved

in developing the standards and in complying with the standards. 

For the EPA, it is more efficient and less costly to develop a

single standard than to develop separate standards for multiple

source categories that have similar emission characteristics and

applicable control technologies. A single set of standards will

ensure that process equipment with comparable HAP emissions and

control technologies are subject to consistent emission control

requirements. In addition, compliance and enforcement activities

would be more efficient and less costly.

In summary, the information obtained during the information

gathering phase of the project demonstrated that the

manufacturing processes, emission characteristics, and applicable

control technologies for facilities in these two source

categories are similar. Based on these factors, the EPA

concluded that these two source categories are to be treated as a

single source category for purposes of this rulemaking. For

purposes of the proposed rule, the term amino/phenolic resin, and

similar terms, will be used to indicate that the two source

categories of amino resins and phenolic resins have been treated

as a single source category for purposes of developing this rule. 

As shown in Table 3-1, a total of 99 facilities were
 In this memorandum, 44 major sources are identified. 1

After the original data were collected, several facilities have

closed or have been otherwise identified as not being in the

source category. Thus, the total number of sources identified as

“major” is estimated to be 40.

4-3

identified as being in the amino/phenolic resin source category. 

Information gathered during the development of the proposed rule

indicated that many of these facilities are area sources or

synthetic area sources. Of the identified facilities, 40 are

considered major sources (see “Major source population of amino

and phenolic resin facilities for purposes of MACT analysis,”

Docket Item II-B-10, for the procedures used to determine major

sources ). The proposed rule applies only to major sources. 1
5-1

5.0 BASELINE EMISSIONS

Baseline organic HAP emissions for the six emission points

for the Amino/Phenolic Resins Industry are presented in 

Table 5-1. As shown in the table, the total nationwide estimated

organic HAP emissions are over 644 megagrams per year (Mg/yr) for

the 40 major existing sources.

Table 5-1. BASELINE ORGANIC HAP EMISSIONS BY EMISSION POINT 

FOR MAJOR EXISTING SOURCES

Emission Point Emissions

(Mg/yr)

Reactor Batch 202.4

Process Vents

Non-reactor Batch 109.0

Process Vents

Continuous Process 116.4

Vents

Storage Vessels 65.4

Wastewater 6.1

Equipment Leaks 144.6

Total 643.9

The organic HAP emitted include formaldehyde, methanol,

phenol, xylene, and toluene. The quantity of emissions for each

individual organic HAP was not determined; however, formaldehyde,

methanol, and phenol are estimated to comprise the largest

quantity of emissions. The predominant organic HAP emitted by

each emission point are identified in Table 5-2.

TABLE 5-2. PREDOMINANT HAP EMITTED 

BY EMISSION POINT
5-2

Emission Point HAP Emitted

Reactor Batch Process Vents formaldehyde, methanol, phenol

Non-reactor Batch Process formaldehyde, methanol,

Vents phenol, xylene

Continuous Process Vents formaldehyde, methanol

Storage Vessels formaldehyde, phenol,

methanol, toluene, xylene

Wastewater formaldehyde, methanol

Equipment Leaks formaldehyde, methanol, phenol

As described in Chapter 3, organic HAP are emitted from

reactor batch process vents, non-reactor batch process vents,

continuous process vents, storage vessels, wastewater, and

equipment leaks. Reactor batch process vents comprise the

largest portion of these emissions (over 31%), followed by

equipment leaks, continuous process vents, and non-reactor batch

process vents.

Emission estimates were made for each of the 40 major

sources in active operation. Emissions for reactor batch process

vents, non-reactor batch process vents, continuous process vents,

storage vessels, and wastewater were based on information

submitted by each facility. For most of these emission points,

the emissions reported by the facility were used. However, for

some of the facilities, emissions had to be estimated. For

example, for a number of facilities, reactor and non-reactor

batch process vents emissions were estimated using an average
5-3

emission factor, which was derived from information provided by

the other facilities, and the production capacity reported by the

facility.

In some instances, the emissions provided for wastewater was

not used because it contained emissions from sewers, which were

not considered part of wastewater under the proposed rule.

For equipment leaks, baseline emissions were estimated using

equipment component counts, type of service (i.e., gas/vapor,

light liquid, heavy liquid), the percent HAP in contact with the

component, the time in HAP service, and uncontrolled or

controlled emission factors, as appropriate, for each component

type and service. Many facilities provided equipment component

counts. For those facilities that did not provide specific

component counts, equipment component counts were estimated using

information on the number and type (i.e., light liquid or heavy

liquid) of storage vessels and component count factors (e.g.,

number of valves in light liquid service per light liquid storage

vessel). Type of service was based on the facility’s

identification of whether or not the component was in gas/vapor,

light liquid, or heavy liquid service. Where this information

was not available, the type of service was based on the compounds

being used. For example, unless otherwise indicated, the

composition of formalin was assumed to be 37% formaldehyde and 7%

methanol component, which is a common formulation for formalin. 

This assumption makes formalin a heavy liquid.
5-4

If facilities did not provide specific information on the

percent HAP in contact with the components or the time in

contact, then default values of 100% HAP (except for formalin)

and 8,760 hours per year were used to estimate emissions. For

formalin, the default value was 44% HAP (37% formaldehyde and 7%

methanol).

The uncontrolled emission factors were largely based on

“Protocol for Equipment Leak Emission Estimates,” EPA-453/R-93-

026, June 1993. Controlled emission factors were used to reflect

the application of a leak detection and repair program based on

40 CFR part 60, subpart VV.

The specific calculation made to estimate baseline emissions

for the six emission points can be found in the following

memoranda:

C Batch Process Vents Analysis for Amino/Phenolic Resins

NESHAP, Docket Item II-B-12.

C Continuous Process Vents Analysis for Amino/Phenolic

Resins NESHAP, Docket Item II-B-15.

C Storage Vessels Analysis for Amino/Phenolic Resins

NESHAP, Docket Item II-B-13.

C Wastewater Analysis for Amino/Phenolic Resins NESHAP,

Docket Item II-B-14.

C Equipment Leak Analysis for Amino/Phenolic Resins

NESHAP, Docket Item II-B-11.
6-1

6.0 MACT FLOORS AND REGULATORY ALTERNATIVES

This chapter presents the approach used to determine maximum

achievable control technology (MACT) floors and regulatory

alternatives beyond the MACT floor for the amino/phenolic resin

production source category. The 1990 Clean Air Act (Act)

requirements for the determination of MACT floors are discussed

in 6.1. The general approach used to determine the MACT floors

and regulatory alternatives beyond the MACT floor for the

amino/phenolic resin source category is discussed in 6.2. The

MACT floors, regulatory alternatives beyond the MACT floor, and

selected standards are presented by emission point in 6.3 through

6.10. 

6.1 CLEAN AIR ACT REQUIREMENTS

The Clean Air Act as amended in 1990 requires EPA to

promulgate emission standards to reflect the maximum degree of

reduction in emissions of HAP that EPA determines is achievable

for new or existing sources. This control level is referred to

as MACT. The Act also states how to determine the least

stringent level allowed for a MACT standard; this level has come

to be known as the "MACT floor." Consideration of control levels

more stringent than the MACT floor must reflect consideration of

the cost of achieving the emission reduction, and any non-air

quality, health, and environmental impacts, and energy

requirements.
6-2

 For new sources, the standards for a source category or

subcategory "shall not be less stringent than the emission

control that is achieved in practice by the best controlled

similar source, as determined by the Administrator"

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

stringent than the average emission limitation achieved by the

best performing 12 percent of the existing sources (for which EPA

has emissions information) for source categories and

subcategories with 30 or more sources or the average emission

limitation achieved by the best performing 5 sources (for which

EPA has emissions information) for source categories or

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

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

floor for new and existing sources.

Two interpretations were previously evaluated by the EPA for

representing the MACT floor for existing sources. One

interpretation is that the MACT floor is represented by the worst

performing facility of the best 12 percent of performing sources. 

The second interpretation is that the MACT floor is represented

by the "average emission limitation achieved" by the best

performing sources, where the "average" is based on a measure of

central tendency, such as the arithmetic mean, median, or mode. 

This latter interpretation is referred to as the "higher floor

interpretation." In a June 6, 1994 Federal Register notice (59

FR 29196), the EPA presented its interpretation of the statutory
6-3

language concerning the MACT floor for existing sources. Based

on a review of the statute, legislative history, and public

comments, the EPA believes that the "higher floor interpretation"

is a better reading of the statutory language. The determination

of the MACT floor for existing sources under the proposed rule

followed the "higher floor interpretation."

6.2 GENERAL APPROACH FOR MACT FLOORS AND REGULATORY ALTERNATIVES

BEYOND THE MACT FLOOR

There are 40 facilities that are major sources in the

amino/phenolic resins production source category. MACT floors

were determined separately for each emission point. For existing

sources, the Clean Air Act requires the MACT floor to be set by

the average of the best performing 12 percent of existing

sources; 5 sources (40 sources x 0.12 = 5 sources) represent the

best performing 12 percent. Therefore, a separate MACT floor was

determined for each emission point and the “best performing” 5

sources for each emission point could be different. For new

sources, the MACT floor is set by the best controlled existing

source. The best controlled source may differ for each emission

point. For both existing and new sources, regulatory

alternatives beyond the MACT Floor were investigated. Regulatory

alternatives beyond the MACT floor were incorporated into the

proposal as appropriate after consideration of cost and any nonair quality, health, and environmental impacts, and energy

requirements. Table 6-1 provides the new and existing MACT
6-4

floors, regulatory alternatives beyond the MACT floor considered,

and selected standards for each of the following emission points:

storage vessels, continuous process vents, reactor batch process

vents, non-reactor batch process vents, heat exchange systems,

wastewater, and equipment leaks.
Table 6-1. MACT FLOOR AND REGULATORY ALTERNATIVES BEYOND THE MACT FLOOR

ANALYSIS FOR EXISTING AND NEW AFFECTED SOURCES

6-5

Emission

Point

MACT Floor Alternatives Selected Standard

Regulatory

Considered

Existing New Existing New Existing New

Storage Aqueous Aqueous None None Aqueous Aqueous

Vessels formaldehyde formaldehyde formaldehyde formaldehyde

vessels $10,000 vessels $10,000 vessels $10,000 vessels $10,000

gallons gallons gallons gallons

capacity with capacity with capacity with capacity with

vapor pressure vapor pressure vapor pressure vapor pressure

$0.47 psia; $0.47 psia; $0.47 psia; $0.47 psia;

Non-aqueous Non-aqueous Non-aqueous Non-aqueous

formaldehyde formaldehyde formaldehyde formaldehyde

vessels $10,160 vessels $10,160 vessels $10,160 vessels $10,160

gallons gallons gallons gallons

capacity with capacity with capacity with capacity with

vapor pressure vapor pressure vapor pressure vapor pressure

$2.45 psia; and $2.45 psia; and $2.45 psia; and $2.45 psia; and

$90,000 gallons $90,000 gallons $90,000 gallons $90,000 gallons

capacity with capacity with capacity with capacity with

vapor pressure vapor pressure vapor pressure vapor pressure

$0.45 psia; $0.45 psia; $0.45 psia; $0.45 psia;

Control level Control level Control level Control level

of 50% of 95% of 50% of 95%

Control level Control level

of 50% of 50%

Continuous No control 85% emission HON HON No control 85% control for

Process reduction some vents and

Vents the HON

provisions for

other vents
Table 6-1. MACT FLOOR AND REGULATORY ALTERNATIVES BEYOND THE MACT FLOOR

ANALYSIS FOR EXISTING AND NEW AFFECTED SOURCES

Emission

Point

MACT Floor Alternatives Selected Standard

Regulatory

Considered

Existing New Existing New Existing New

6-6

Reactor 93% emission 95% emission 95% None 93% emission 95% emission

Batch reduction with reduction with emission considered reduction with reduction with

Process an alternative an alternative reduction an alternative an alternative

Vents emission limit emission limit based on emission limit emission limit

of 0.017 of 0.01 combustion of 0.017 of 0.01

kilogram of HAP kilogram of HAP kilogram of HAP kilogram of HAP

per megagram of per megagram of per megagram of per megagram of

product product product product

Non- reduce overall reduce overall 95% 95% reduce overall reduce overall

Reactor emissions by emissions by emission emission emissions by emissions by

Batch 68% for 83% for reduction reduction 68% for 83% for

Process affected affected based on based on affected affected

Vents sources with sources with combustion combustion sources with sources with

uncontrolled uncontrolled . . uncontrolled uncontrolled

emissions from emissions from emissions from emissions from

the collection the collection the collection the collection

of non-reactor of non-reactor of non-reactor of non-reactor

batch process batch process batch process batch process

vents greater vents greater vents greater vents greater

than or equal than or equal than or equal than or equal

to 0.23 Mg/yr to 0.23 Mg/yr to 0.23 Mg/yr to 0.23 Mg/yr

Heat monitor for monitor for HON HON monitor for monitor for

exchange leaks leaks leaks according leaks according

systems to the HON to the HON

provisions provisions

Wastewater No control No control HON HON No control HON
Table 6-1. MACT FLOOR AND REGULATORY ALTERNATIVES BEYOND THE MACT FLOOR

ANALYSIS FOR EXISTING AND NEW AFFECTED SOURCES

Emission

Point

MACT Floor Alternatives Selected Standard

Regulatory

Considered

Existing New Existing New Existing New

6-7

Equipment No control LDAR program at (1) SOCMI (1)HON HON LDAR HON LDAR 

Leaks Solutia’s VV LDAR 

Springfield, MA (2) HON

facility (SOCMI LDAR 

VV)
6-8

6.3 DETERMINATION OF MACT FLOORS FOR STORAGE VESSELS

This section describes the approach taken for determining

the MACT floor for storage vessels at existing and new affected

sources. Table 6-2 presents the storage vessel data for those

facilities that had applied controls to any of their storage

vessels (i.e., the MACT floor facilities). The entire analysis

is limited to this data set. Applicability criteria and control

levels for the MACT floor were developed using the same approach

used for the development of the HON.

6.3.1 MACT Floors for Storage Vessels at Existing Sources

The MACT floor for existing sources is set by the average

performance for the best performing 12 percent of existing

sources for categories with 30 or more sources. In this proposed

rule, the category contains 40 facilities that are major sources. 

Therefore, the best performing 12 percent of existing sources is

represented by the best performing 5 facilities. The best

performing 5 facilities were selected based on the same approach

as used in developing the MACT floor for storage vessels under

the HON. Applicability criteria and control levels for the MACT

floor were also developed using the HON approach. Note that

there are only 4 facilities that control storage vessels at

baseline. The fifth facility of the best performing 5 could be 
Table 6-2. AMINO/PHENOLIC RESIN STORAGE VESSELS RAW MATERIAL TANKS 

FROM BEST PERFORMING 5 FACILITIES

6-9

No. Size

Tanks (gal) Company Location Chemical Pressure Control Efficiency

Vapor Control Device

(psia) Perce

 Emissions

Uncont. Cont.

Mg/yr Mg/yr

5 tks Borden Fayetteville, aqueous 0.47 55,000 Scrubber 50% 912 456

NC formaldehyde

15 tks Borden Fayetteville, aqueous 0.47 16,000 Scrubber 50% 812 406

NC formaldehyde

2 tks Borden Fayetteville, phenol <0.01 25,000 None 0% 260 260

NC

1 tk Borden Fayetteville, methanol 1.63 30,000 None 0% 73 73

NC distillate

1 tk Borden Fayetteville, methanol 1.63 20,000 None 0% 49 49

NC distillate

1 tk Borden Fayetteville, aqueous 0.47 10,000 Scrubber 50% 33 16

NC formaldehyde

8 tks Borden Louisville, KY aqueous 0.47 20,000 Scrubber 50% 704 352

formaldehyde

2 tks Borden Louisville, KY distillate 1.63 20,300 None 0% 695 695

3 tks Borden Louisville, KY phenol <0.01 20,300 None 0% 500 500

1 tk Borden Louisville, KY ethylene <0.01 20,000 None 0% 1 1

glycol

1 tk Borden Louisville, KY toluene 0.71 4,500 None 0% 1 1

1 tk Cytec Wallingford, CT methanol 1.63 20,000 None 0% 2981 2981

distillate

1 tk Cytec Wallingford, CT methanol 1.63 11,600 None 0% 2865 2865

distillate

1 tk Cytec Wallingford, CT methanol 1.63 15,000 None 0% 2865 2865

distillate

1 tk Cytec Wallingford, CT methanol 2.45 50,000 Scrubber 95% 946 47

1 tk Cytec Wallingford, CT methanol 2.45 50,000 Scrubber 95% 946 47

1 tk Cytec Wallingford, CT methanol wash 2.45 10,159 Scrubber 95% 625 31
Table 6-2. AMINO/PHENOLIC RESIN STORAGE VESSELS RAW MATERIAL TANKS 

FROM BEST PERFORMING 5 FACILITIES

No. Size

Tanks (gal) Company Location Chemical Pressure Control Efficiency

Vapor Control Device

(psia) Perce

 Emissions

Uncont. Cont.

Mg/yr Mg/yr

6-10

1 tk Cytec Wallingford, CT recovered 2.45 10,000 None 0% 600 600

methanol

1 tk Cytec Wallingford, CT methyl formcel 0.45 90,000 Scrubber 95% 452 23

1 tk Cytec Wallingford, CT methanol wash 2.45 10,159 Scrubber 95% 222 11

1 tk Cytec Wallingford, CT xylene <1.5 15,000 None 0% 70 70

1 tk Cytec Wallingford, CT aqueous 0.15 90,000 Scrubber 95% 32 2

formaldehyde

1 tk Simpson Portland, OR aqueous 0.47 47,972 Scrubber 85% 1420 213

Timber formaldehyde

1 tk Simpson Portland, OR methanol 1.93 80,926 None 0% 280 280

Timber

1 tk Simpson Portland, OR phenol <0.01 51,702 None 0% 160 160

Timber

Note: The capacity values (size in gallons) apply separately to each storage vessel, while

the uncontrolled and controlled emissions (lb/yr) apply collectively to the group of storage

vessels for that specific facility.
6-11

any one of the other uncontrolled facilities; the term “best

performing 5" is used even though there are only four facilities

that control storage vessels at baseline.

For existing sources, the HON approach determines whether or

not there is control at the MACT floor by considering the overall

control status of each facility independently, judging each

facility as controlled or uncontrolled based on a predominance of

controlled or uncontrolled storage vessels. For example, if 8

out of 10 storage vessels are controlled at a given facility, the

overall control status of that facility is “controlled.” Next,

the HON approach looks at a predominance of the best performing 5

facilities. If at least 3 out of the 5 facilities are considered

“controlled,” a MACT floor of control is considered to exist. 

Table 6-3 presents a summary of the number of uncontrolled and

controlled storage vessels at each of the four facilities that

controlled storage vessels at the baseline and presents the HON

approach finding that the existing source MACT floor is

“controlled.”
6-12

Table 6-3. HON ANALYSIS OF RAW MATERIAL TANKS

Facility Status - controlled Controlled or

out of total Uncontrolled a

Cytec, 

Wallingford, CT 6 out of 11 Controlled

Simpson Timber, 

Portland, OR 1 out of 3 Uncontrolled

Borden,

Fayetteville, NC 21 out of 25 Controlled

Borden,

Louisville, KY 8 out of 15 Controlled

Existing MACT Floor 3 facilities out of 4

Facility Average facilities Controlled

 The facility level controlled/uncontrolled decision is based on a

whether or not a majority of tanks are controlled.

The HON approach expresses applicability criteria in terms

of vapor pressure and vessel capacity cutoffs. Once a finding of

“controlled” is made for the MACT floor, the first step in

developing applicability criteria is to plot all the tanks in the

best performing 5 population on a graph of vapor pressure versus

capacity and identify them as controlled or uncontrolled. The

second step is the development of vapor pressure and capacity

cutoffs that would describe those tanks that are controlled and

exclude tanks that are uncontrolled. More than one set of vapor

pressure and storage vessel capacity cutoffs may be developed, as

was the case for this analysis for the existing source MACT

floor. The following applicability criteria were developed:
6-13

Aqueous formaldehyde $10,000 gallons capacity with

vapor pressure $0.47 psia

Non-aqueous formaldehyde $10,160 gallons capacity with

vapor pressure $2.45 psia; and

$90,000 gallons capacity with

vapor pressure $0.45 psia

Two sets of criteria were developed because the storage vessels

in the best performing 5 facility data set naturally lend

themselves to division based on the material stored (i.e.,

aqueous formaldehyde or other materials), and because the HON

approach requires that storage vessels that are not controlled be

excluded by the applicability criteria.

The control level for the MACT floor is established based on

the control levels at the baseline. Of the best performing 5

facilities, there are a total of 36 controlled storage vessels of

which 6 are controlled to 95 percent, 1 is controlled to 85

percent, and 29 are controlled to 50 percent. The median and

mode, which is 50 percent, was chosen to represent the MACT floor

control level.

6.3.2 MACT Floors for Storage Vessels at New Sources

The MACT floor for new sources is set by the best controlled

source. Using the HON approach for new sources, the best

controlled source (here, the best controlled amino/phenolic resin

facility) is identified based on the absolute number of storage

vessels controlled. 
6-14

The Borden, Fayetteville facility is the best controlled

source based on absolute number of storage vessels controlled. 

However, the only controlled storage vessels are aqueous

formaldehyde storage vessels and this leaves storage of other raw

materials (i.e., non-aqueous formaldehyde) unaddressed. The

Cytec, Wallingford facility is the next best controlled facility

based on the absolute number of storage vessels controlled and

includes other raw materials among the controlled vessels. The

Borden, Fayetteville facility is the best controlled facility for

aqueous formaldehyde storage vessels, and the Cytec, Wallingford

facility is the best controlled facility for non-aqueous

formaldehyde storage vessels. Therefore, separate floors were

set for aqueous formaldehyde and non-aqueous formaldehyde storage

vessels.

Like the process for existing sources, vapor pressure and

capacity cutoffs were developed that include those storage

vessels that are controlled at baseline and exclude storage

vessels that are uncontrolled at baseline. The storage vessels

at the Borden, Fayetteville facility were used to develop the

aqueous formaldehyde criteria, and the storage vessels at the

Cytec, Wallingford facility were used to develop the non-aqueous

formaldehyde criteria. The following storage vessel

applicability criteria were developed:
6-15

Aqueous formaldehyde $10,000 gallons capacity with

vapor pressure $0.47 psia

Non-aqueous formaldehyde $10,160 gallons capacity with

vapor pressure $2.45 psia; and

$90,000 gallons capacity with

vapor pressure $0.45 psia

The applicability criteria for existing and new sources are

coincidentally the same because of the large number of storage

vessels at the Borden, Fayetteville facility.

The control level for the new source MACT floor is

established based on the control levels at the best controlled

facility. For aqueous formaldehyde storage vessels, the best

controlled facility is the Borden, Fayetteville facility. For

non-aqueous formaldehyde storage vessels, the best controlled

facility is the Cytec, Wallingford facility.

The aqueous formaldehyde storage vessels at the Borden,

Fayetteville facility are all controlled to 50 percent. 

Therefore, the MACT floor for aqueous formaldehyde storage

vessels is 50 percent. At the Cytec, Wallingford facility some

non-aqueous formaldehyde storage vessels are controlled and some

are not controlled. The applicability criteria presented above

separate the controlled tanks from the uncontrolled tanks. All

of the controlled tanks are controlled to 95 percent. Therefore,

the MACT floor for non-aqueous formaldehyde storage vessels is 95

percent.
6-16

6.4 DETERMINATION OF MACT FLOORS FOR CONTINUOUS PROCESS VENTS

This section describes the approach taken for determining

the MACT floor for continuous process vents at existing and new

sources.

The first step in determining the MACT floor for continuous

process vents was to determine which major source facilities

control their continuous process vents. Eight facilities thought

to have continuous process vents that might have controls were

contacted by telephone. Of these 8 facilities, continuous

process vents at 3 facilities were discovered to be batch process

vents, one facility had closed, and 4 facilities were confirmed

to have continuous process vents. Of the 4 facilities with

continuous process vents, 1 facility had 2 continuous process

vents (dryers) that were each controlled with a scrubber with an

85 percent control efficiency. The three remaining facilities

with continuous process vents did not control their process

vents. Table 6-4 presents the data for these major source

facilities included in the analysis.

6.4.1 MACT Floors for Continuous Process Vents at Existing

Sources

The MACT floor for existing sources is set by the average

performance for the best performing 12 percent of existing

sources for categories with 30 or more sources. The best

performing 12 percent of existing sources is represented by the

best performing 5 facilities for this source category. Because
6-17

only one facility was identified as controlling its continuous

process vents, the MACT floor for existing sources is no control.

Table 6-4. CONTINUOUS PROCESS VENT CONTROLS AT MAJOR SOURCES

Facility Location Control Device

BTL Toledo, OH No Control

Cytec Industries Wallingford, CT Two Scrubbers - Each has 

85 percent efficiency

Georgia Pacific Crossett, AR No Control

Perstorp Florence, MA No Control

6.4.2 MACT Floors for Continuous Process Vents at New Sources

The MACT floor for new sources is set by the best controlled

amino/phenolic resin production facility. The best controlled

facility has a scrubber with an 85 percent control efficiency. 

The applicability criterion chosen to represent the specific

continuous process vents that were controlled at the MACT floor

is the HON total resource effectiveness (TRE) equation for a

thermal incinerator with 70 percent heat recovery. This

applicability criterion was selected because the HON process vent

provisions were relied upon for part of the standard and using

the same applicability criterion to define the MACT floor

provides a consistent approach for the rule. 

The expression of applicability criteria is limited to the

TRE equation for a thermal incinerator with 70 percent heat

recovery because there was only one set of vent stream data,

which did not allow the EPA to evaluate a range of stream
6-18

conditions that were controlled versus those that were not

controlled. This TRE value of 1.2 was calculated using the vent

stream data for the continuous process vents setting the 85

percent MACT floor.

6.5 DETERMINATION OF MACT FLOORS FOR REACTOR BATCH PROCESS VENTS

This section describes the approach taken for determining

the MACT floor for reactor batch process vents at existing and

new sources.

6.5.1 MACT Floors for Reactor Batch Process Vents at Existing

Sources

The MACT floor for reactor batch process vents at existing

sources is set by the average performance for the best performing

12 percent of existing sources. The best performing 12 percent

of existing sources is represented by the best performing

5 facilities. Each of the best peforming 5 facilities had

applied secondary controls to all of their reactor batch process

vents; this fact necessitates that the proposed rule require

control of all reactor batch process vents with no applicability

criteria. Table 6-5 presents the data for the best performing 5

facilities in terms of reactor batch process vent controls.

The data set used for setting the MACT floor was limited to

the 17 facilities for which the 1992 ICR responses indicated that

secondary controls had been applied to reactor batch process

vents. These facilities were contacted via telephone during 1997
6-19

and were asked a series of questions in order to clarify the data

that were reported in the 1992 ICR responses. Some of the topics 
6-20

Table 6-5. BEST PERFORMING 5 FACILITIES FOR REACTOR BATCH PROCESS VENTS 

BASED ON APPLIED SECONDARY CONTROLS a

Facility Type of Production Collocated Secondary Emission

Resin of with Controls Factor

Methylated Formaldehyde (kilograms

Resins Plant (Y/N) of HAP per

(N or %) megagram of

production)

Ranbar P N N thermal 0.84

incinerator

(95%)

Georgia Pacific, A/P N Y catalytic 0.01

Taylorsville, MS incinerator

(95%)

Georgia Pacific, A/P 5 - 10% N caustic 0.017

Port Wentworth, GA treatment

(93%)

Borden, P N Y scrubber (90%) CBI

Louisville, Ky

Solutia, A 100% N scrubber (85%) CBI

Addyston, OH

 The data on this table is restricted to the 17 facilities that were contacted during a

the recent data gathering effort.
6-21

that were covered during the teleconferences included the

presence and purpose of a primary condenser, emissions before and

after the primary condenser, efficiency of the primary condenser

and secondary control devices, whether the facility was

collocated with a formaldehyde plant, and whether the facility

produced methylated resins.

In considering the best performing 5 facilities based on

applied secondary controls, the data were evaluated to determine

if the collocation with formaldehyde plants or the production of

methylated resins influenced the application of secondary

controls, specifically the use of combustion devices. No

patterns emerged. One combustion device is at a phenolic 

producer (Ranbar) that does not produce any methylated resins and

is not collocated with a formaldehyde plant. The other

combustion device is at an amino/phenolic producer (Georgia

Pacific, Taylorsville) that does not produce any methylated

resins and is collocated with a formaldehyde plant.

In addition, the data were evaluated for patterns of applied

secondary controls versus the production capacity of facilities. 

Again, no patterns emerged. One combustion device is located at

a 816 Mg/yr (1.8 million lb/yr) producer (Ranbar), and the other

combustion device is located at a 69,851 Mg/yr (154 million

lb/yr) producer (Georgia Pacific, Taylorsville). These

production capacities are typical small and large facilities,

respectively.
6-22

In conclusion, because of the good distribution of

methylators and non-methylators, facilities collocated with

formaldehyde plants and those not, and amino only, phenolic only,

and amino/phenolic producers within the best performing 5

facilities, the best performing 5 facilities were considered

representative of the industry.

The EPA considered two options for the MACT floor. The

options considered included selecting the percent reduction for

the median facility or averaging the percent reduction values for

the best performing 5 facilities and determining the alternative

emission limit in a similar manner. The option selected uses the

median facility for establishing the percent reduction and the

alternate emission limit. The Georgia Pacific, Port Wentworth

facility represents the median facility of the best performing 5. 

Using the percent reduction value and the emission factor for

this facility, the MACT floor was selected as 93 percent emission

reduction with an alternative emission limit of 0.017 kilogram of

HAP per megagram of product. 

The option of averaging the percent reductions for the best

performing 5 facilities was not selected because providing the

corresponding alternate emissions limit would require averaging

the emissions factors for the best performing 5 facilities. 

Because of the exceptionally high emission factor for Ranbar

(0.84 kilogram of HAP per megagram of product), which is a

facility with a combustion device expected to have a low
6-23

emissions factor, the EPA judged that this approach would not

provide a reasonable alternative emissions limit.

6.5.2 MACT Floors for Reactor Batch Process Vents at New Sources

The MACT floor for reactor batch process vents at new

sources is set by the best controlled amino/phenolic resin

facility. Referring back to Table 6-5, a review of the best

performing facilities reveals two facilities with combustion

controls. In selecting the best controlled facility, the Ranbar

and Georgia Pacific, Taylorsville facilities were considered as

equally controlled. Because the emission factor for the Ranbar

facility is judged to be exceptionally high considering the

reported secondary controls, the Georgia Pacific, Taylorsville

facility was selected as the best controlled facility. 

Therefore, the first option that was chosen as the MACT floor is

95 percent emission reduction with an alternative standard of

0.01 kilogram of HAP per megagram of product.

6.6 DETERMINATION OF MACT FLOORS FOR NON-REACTOR BATCH PROCESS

VENTS

This section describes the approach taken for determining

the MACT floor for non-reactor batch process vents at existing

and new affected sources.

6.6.1 MACT Floors for Non-Reactor Batch Process Vents at

Existing Sources

The MACT floor for non-reactor batch process vents at

existing sources is set by the average performance for the best
6-24

performing 12 percent of existing sources. The best performing

12 percent of existing sources is represented by the best

performing 5 facilities. The best performing 5 facilities were

selected based on the overall emission reduction achieved by each

facility. All of the best performing 5 facilities had applied

controls to some of their non-reactor batch process vents, and

two of the best performing 5 facilities had applied controls to

all of their non-reactor batch process vents. This baseline

control situation, and the limited data set available for the

analysis, led the EPA to consider a single option for the

development of existing source MACT floor based on achieving a

specified emission reduction for the collection of non-reactor

batch process vents within the affected source. Table 6-6

presents the data for the best performing 5 facilities in terms

of non-reactor batch process vent controls and the overall

emission reduction achieved by each facility. The facility

average emission reduction ranged from 83.7 percent to 50

percent.
Table 6-6. BEST PERFORMING 5 FACILITIES FOR NON-REACTOR BATCH PROCESS VENTS BASED ON

OVERALL PERCENT REDUCTION

6-25

Company Location Emission Emission Uncont’d Cont’d Primary Primary Second. Second. Combined

Point Point Emis. Emis. Control Device Control Device Eff.%

Description (tpy) (tpy) Device Eff.% Device Eff. %

Schenectady Rotterdam E14 Weigh tank 0.247 0.247 None NR None

Junction, NY

Schenectady Rotterdam E5/E6 Separator 24.1 0.241 Condenser NR Scrubber NR 99.5

Junction, NY Tank 

Schenectady Rotterdam E7 Hold Tank 25.2 0.252 Condenser 99 None NR NR

Junction, NY

Schenectady Rotterdam E4 Holding Tank 12.1 12.1 None None

Junction, NY

Schenectady Rotterdam E15/E16 Mix Tank 7.31 0.3654 Condenser NR Scrubber NR 95

Junction, NY Unit

Schenectady Rotterdam E20 Separator 21.7 0.11 Condenser NR Scrubber 99.5

Junction, NY Unit

Schenectady Rotterdam E19 Hold Tank 6.76 0.879 Condenser 87 None

Junction, NY

Schenectady Rotterdam E21 Recycle 0.182 0.182 None None

Junction, NY System

Schenectady Rotterdam E22/E23 Recycle Tank 2.31 0.0231 Condenser 99 None

Junction, NY

Schenectady Rotterdam E24 Flaking belt 5.67 2.84 Scrubber NR None

Junction, NY

Overall Emission Reduction for non-reactor batch process vents is 83.7 percent
Table 6-6. BEST PERFORMING 5 FACILITIES FOR NON-REACTOR BATCH PROCESS VENTS BASED ON

OVERALL PERCENT REDUCTION

Company Location Emission Emission Uncont’d Cont’d Primary Primary Second. Second. Combined

Point Point Emis. Emis. Control Device Control Device Eff.%

Description (tpy) (tpy) Device Eff.% Device Eff. %

6-26

Borden Louisville, E1A Weigh Tank/ 0.25 0.12 Scrubber 90 None

KY Fixed Roof

Borden Louisville, E2A Weigh Tank/ 0.5 0.05 Scrubber 90 None

KY Fixed Roof

Borden Louisville, E8 Recovery 0.004 0.004 None None

KY (phenol)

Borden Louisville, E11 Cooling & 0.005 0.005 Scrubber 90 None

KY Flaking

Overall Emission Reduction for non-reactor batch process vents is 77 percent

Dynachem Georgetown, E9 Weigh Tank 0.25 0.075 Scrubber 72 None

IL

Overall Emission Reduction for non-reactor batch process vents is 70 percent

Solutia Addyston, OH E3 Methanol 0.81 0.81 Vapor NR None

weigh tank balance

Solutia Addyston, OH E4 Formaldehyde 0.014 0.014 None None

weigh tank

Solutia Addyston, OH E7 Distillation 1.44 0.22 Scrubber 85 None

Overhead

Tank

Solutia Addyston, OH E6 Distillation 0.261 0.039 Scrubber 85 None

Feed Tank

Solutia Addyston, OH E8 Distillation 0.352 0.053 Scrubber 85 None

Bottom Tank

Overall Emission Reduction for non-reactor batch process vents is 60.5 percent
Table 6-6. BEST PERFORMING 5 FACILITIES FOR NON-REACTOR BATCH PROCESS VENTS BASED ON

OVERALL PERCENT REDUCTION

Company Location Emission Emission Uncont’d Cont’d Primary Primary Second. Second. Combined

Point Point Emis. Emis. Control Device Control Device Eff.%

Description (tpy) (tpy) Device Eff.% Device Eff. %

6-27

Borden Fayetteville E2 Weigh Tank 0.084 0.042 Scrubber 50 None

, NC

Borden Fayetteville E2 Weigh Tank 0.264 0.132 Scrubber 50 None

, NC

Borden Fayetteville E2 Weigh Tank 0.209 0.1045 Scrubber 50 None

, NC

Overall Emission Reduction for non-reactor batch process vents is 50 percent
6-28

The first step in determining the MACT floor was to

establish the overall percent emission reduction for the best

performing 5 facilities. The average percent emissions reduction

was calculated from the best performing 5 facilities. 

Specifically, for each of the best performing 5 facilities, the

difference of uncontrolled emissions minus controlled emissions

was divided by uncontrolled emissions to establish the average

percent emissions reduction for the facility. Then, the average

percent emissions reductions for the best performing 5 facilities

were added together and then divided by 5. The resulting average

percent emissions reduction for the best performing 5 facilities

is 68 percent.

Facility-wide uncontrolled emissions from non-reactor batch

process vents were chosen as the applicability criteria, because

it was the only available data, and because the EPA judged that

the applicability criteria, like the control level, should be an

overall value as opposed to an individual process vent specific

value. The uncontrolled emissions cutoff of 0.23 Mg/yr (0.25

tpy) represents the smallest facility-wide uncontrolled emissions

from non-reactor batch process vents for a facility in the best

performing 5. The smallest value was selected to ensure that all

the facilities included in setting the MACT floor would be

represented by the applicability criteria.

Putting together the control level and applicability

criteria, the MACT floor for non-reactor batch process vents at
6-29

existing sources requires an overall emissions reduction of 68

percent for the collection of non-reactor batch process vents

within the source for sources with uncontrolled emissions from

the collection of non-reactor batch process vents greater than or

equal to 0.23 Mg/yr (0.25 tpy).

6.6.2 MACT Floors for Non-Reactor Batch Process Vents at New

Sources

The MACT floor for new sources is set by the best controlled

amino/phenolic resin production facility. Using the overall

emission reduction for a facility approach, the best controlled

facility achieves an overall emission reduction of 83.7 percent. 

For purposes of the rule, this value was rounded down to 83

percent.

In considering the uncontrolled emissions cutoff for the new

source MACT floor, the CAAA states that existing source standards

may be less stringent than new source standards. By implication,

new source standards may not be less stringent than existing

source standards. Based on this, the uncontrolled facility-wide

emissions cutoff of 0.23 Mg/yr (0.25 tpy) was used because the

uncontrolled emissions at the best controlled facility are 96

Mg/yr (106 tpy). If the value of 96 Mg/yr (106 tpy) was used,

the new source standard would be less stringent than the existing

source standard. Therefore, the MACT floor for non-reactor batch

process vents at new affected sources requires an overall

emissions reduction of 83 percent for the collection of non-
6-30

reactor batch process vents within the affected source for

affected sources with uncontrolled emissions from the collection

of non-reactor batch process vents greater than or equal to 0.23

Mg/yr (0.25 tpy).

6.7 DETERMINATION OF MACT FLOORS FOR WASTEWATER

This section describes the approach taken for determining

the MACT floor for wastewater at existing and new sources. The

MACT floor for existing and new sources is based on controls at

baseline. 

6.7.1 MACT Floors for Wastewater at Existing Sources

The MACT floor for existing sources is set by the average of

the best performing 12 percent of existing amino/phenolic resin

production facilities. The best performing 12 percent of

existing amino/phenolic resin production facilities is

represented by the best performing 5 facilities. The MACT floor

for existing sources is based on controls at baseline. No

facilities that are major sources were identified as controlling

their wastewater. Therefore, the MACT floor for existing sources

is no control.

6.7.2 MACT Floors for Wastewater at New Sources

There are 40 facilities that are major sources in this

source category. The MACT floor for new sources is set by the

best controlled amino/phenolic resin production facility. 

Because no facilities are controlled, the MACT floor for new

sources is no control.
6-31

6.8 DETERMINATION OF MACT FLOORS FOR EQUIPMENT LEAKS

This section describes the approach taken for determining

the MACT floor and regulatory alternatives for existing and new

source equipment leaks. For a more detailed discussion, please

see “Equipment Leak Analysis for Amino/Phenolic Resins NESHAP,”

Docket Item II-B-11.

Based on data provided through surveys and follow-up

telephone conversations, two amino/phenolic resin facilities were

identified as having equipment leak programs subject to Federal,

State, or local regulations. These two facilities are: Georgia

Pacific's Elk Grove, California plant and Solutia's Springfield,

Massachusetts plant. However, only one facility -- Solutia's

Springfield, MA, plant -- was identified as a major source. This

facility is subject to the State of Massachusetts rule 310 CMR

718(19), which essentially requires the facility to implement a

leak detection and repair (LDAR) program equivalent to 40 CFR

part 60, subpart VV.

6.8.1 MACT Floors for Equipment Leaks at Existing Sources

The MACT floor for existing sources is set by the average

performance for the best performing 12 percent of existing

sources. The best performing 12 percent of existing sources is

represented by the best performing 5 amino/phenolic resin

production facilities. The only source identified as having a

LDAR program subject to local, State, or Federal regulations is

Solutia’s Springfield, MA, facility. A number of other
6-32

facilities have been identified as having a maintenance-type LDAR

program. These maintenance-type programs are likely to be less

effective at reducing emissions than the LDAR program in place at

the Solutia, Springfield facility. Unfortunately, no information

is available to quantify the emission reduction being achieved

from these maintenance-type programs. Therefore, the average of

the best performing 5 facilities cannot be defined at this time,

and the MACT floor for equipment leaks for existing sources is

considered to be no control.

6.8.2 MACT Floors for Equipment Leaks at New Sources

The MACT floor for new sources is set by the best controlled

amino/phenolic resin facility. As noted in the previous

paragraph, only one major source has been identified as having a

LDAR program subject to local, State, or Federal regulations,

while others have maintenance-type LDAR programs. A number of

facilities have been identified by the EPA as repairing leaks

when they are seen or otherwise identified (e.g., smell or

sound). However, these maintenance-type LDAR programs are

unlikely to be more stringent than the LDAR program being

implemented at Solutia’s Springfield, MA, facility. Therefore,

the MACT floor for equipment leaks at new sources is represented

by the LDAR program at the Solutia, Springfield facility.
6-33

6.9 REGULATORY ALTERNATIVES BEYOND THE MACT FLOOR

This section discusses the regulatory alternatives beyond

the MACT floor that were evaluated for each of the six emission

points where applicable.

The MACT floor for storage vessels at existing sources was

identified as 50 percent. The MACT floor for storage vessels at

new sources was identified as 50 percent for aqueous formaldehyde

storage vessels and 95 percent for non-aqueous formaldehyde

storage vessels. For those storage vessels with a 50 percent

emission reduction MACT floor, the EPA judged that the

incremental emission reductions and costs would result in an

incremental cost effectiveness value that was unacceptable. This

judgment was based on the small incremental emission reduction

that would be achieved versus the large incremental cost in

moving from a scrubber to a combustion device. Although the

change in percentage from 50 percent to 95 percent appears to be

significant, the low level of HAP emitted from the storage

vessels in this source category would yield a small incremental

emission reduction being achieved.

The HON process vent provisions were evaluated as a

regulatory alternative beyond the MACT floor for continuous

process vents. The applicability of the HON process vent

provisions (i.e., TRE value) for those continuous process vents

for which stream characteristics were the basis of the analysis

were evaluated. The results are presented in Table 6-7 for
6-34

existing sources and in Table 6-8 for new sources. These values

were developed based on those process vents for which stream data

are available; data were only available for the two process vents

at the MACT floor facility (i.e., Cytec Wallingford, CT). 

Evaluation of the available data indicated that none of the

continuous process vents for which data were available would meet

the HON TRE applicability criteria.

For existing sources, the TRE values ranged from 4.4 to

93.2. Based on the calculated TRE values, it is very unlikely

that any continuous process vents at an existing affected source

would meet the HON TRE applicability criteria. As the TRE values

show (i.e., 4.4 to 93.2), these types of continuous process vents

are not cost effective to control. Therefore, the HON process

vent provisions were not selected as the regulatory alternative

for existing sources.

For new sources, the TRE values range from 1.2 to 25.4.

While the TRE values show that none of the continuous process

vents considered in the analysis would meet the HON TRE

applicability for new sources, the EPA judged that if a new

source were to have a continuous process vent within the costeffectiveness accepted by the EPA (i.e., with a TRE of 1.0 or

less), it should be controlled. Therefore, a two-tiered

approach, utilizing the MACT floor level of control for some

continuous process vents and the HON provisions for other

continuous process vents, was chosen as the regulatory
6-35

alternative for new sources. The HON provisions were included in

the selected regulatory alternative because it has been proven 
6-36

Table 6-7. TRE ANALYSIS FOR CONTINUOUS PROCESS VENTS AT EXISTING AFFECTED SOURCES

Stream ID E(HAP) Qs(scfm) Ht(stream) TRE TRE TRE

tpy MJ/scm (flare) (T1,0%) (T1,70%)

1 11.75 10,900 0.040 93.2 16.9 5.1

2 14.98 12,700 0.033 85.0 15.3 4.4

Stream ID Information

1 is Cytec, Wallingford - process vent (E9)

2 is Cytec, Wallingford - process vent (E13)

Table 6-8. TRE ANALYSIS FOR CONTINUOUS PROCESS VENTS AT NEW AFFECTED SOURCES

Stream ID E(HAP) Qs(scfm) Ht(stream) TRE TRE TRE

tpy MJ/scm (flare) (T1,0%) (T1,70%)

1 11.75 10,900 0.040 25.4 4.6 1.4

2 14.98 12,700 0.033 23.2 4.2 1.2

Stream ID Information

1 is Cytec, Wallingford - process vent (E9)

2 is Cytec, Wallingford - process vent (E13)
6-37

through past analyses that the HON provisions are a cost

effective approach for controlling continuous process vents. 

A two-tiered approach was used because the MACT floor is more

stringent than the HON; the MACT floor controls continuous

process vents that the HON would not control.

The proposed standard for continuous process vents at new

sources utilizes the MACT floor level of control and the HON

process vent provisions to establish a two-tiered standard. For

continuous process vents with a TRE greater than 1.0 but less

than 1.2, 85 percent emission reduction is required (i.e., MACT

floor). For continuous process vents with a TRE value of 1.0 or

less, 98 percent emission reduction is required (i.e., HON). For

process vents with a TRE value greater than 1.2, controls are not

required. TRE values are estimated using the TRE equations from

the HON for a thermal incinerator with 70 percent heat recovery.

Because the MACT floor level of control for reactor batch

process vents at existing sources was based on scrubbers with 93

percent control, the next step was to consider combustion

controls as a regulatory alternative beyond the MACT floor. 

However, this option was not chosen, because the EPA judged that

the incremental emission reductions and costs would result in an

incremental cost effectiveness value that was unacceptable. This

judgment was based on the small incremental emission reduction

that would be achieved in moving from 93% emission reduction to
6-38

95% or 98% emission reduction versus the large incremental cost

in moving from a scrubber to a combustion device.

Not enough information on beyond the MACT floor options for

non-reactor batch process vents was available to justify

selecting a regulatory alternative beyond the MACT floor.

A monitoring program to detect leaks from the process into

the cooling water was selected as the standard for heat exchange

systems. This monitoring program is the same as the HON program

(subpart F). No MACT floor or regulatory alternatives analyses

were performed, due to lack of data. Because heat exchange

systems have been identified as a potential source of emissions,

the EPA judges that proposing a standard to cover this emission

point is warranted. However, the EPA is not aware if any heat

exchange systems exist in the amino/phenolic resin industry and

has solicited comments from interested persons on this subject.

The HON was considered as a regulatory alternative for both

existing and new sources for wastewater streams. The first step

in evaluating the HON as a regulatory alternative beyond the MACT

floor was to compare the available stream data contained in the

project database to the HON applicability criteria to determine

whether any wastewater streams would meet the HON applicability

criteria. No wastewater streams met the HON existing source or

new source applicability criteria. It should be noted that there

were very little data available for wastewater streams and that

for those streams for which data were available, the data were
6-39

partial (i.e., indicating either wastewater flow or HAP

concentration, but not both). However, based on the little data,

it appeared unlikely that a wastewater stream would be covered by

the HON applicability criteria.

Table 6-9 shows those streams containing HAP regulated by

the HON wastewater provisions for which flow and/or concentration

data were known and compares the data to the HON applicability

criteria. It should be noted that the flow and concentration

numbers reported by industry in the ICR and used in this analysis

represent the maximum flow and concentration amounts during the

process; these numbers are not believed to be representative of

average flow and concentrations experienced during the process.

The HON has applicability criteria for the control of

Table 9 wastewater HAP for new and existing sources. The

criteria are based on the following annual concentrations and

flowrates: (1) a total VOHAP concentration greater than or equal

to 10,000 parts per million by weight (ppmw) (mg/l) at any

flowrate, or (2) a total VOHAP concentration greater than or

equal to 1,000 ppmw (mg/l) and a flowrate greater than or equal

to 10 lpm (37.9 gpm). The HON also has applicability criteria

for the determination for the control of Table 8 wastewater HAP

for new sources only based on a concentration of any Table 8 HAP

greater than or equal to 10 ppmw(mg/l) and a flowrate greater

than or equal to 0.02 lpm (0.00528 gpm).
6-40

 Table 6-9 shows that although several streams had either

flow or concentration data that met a part of the applicability

criteria, none of these streams would be covered by the HON

applicability criteria.

The second step in determining the regulatory alternatives

beyond the MACT floor for wastewater at existing and new sources

was to develop applicability criteria cut-off models (i.e.,

models that will just barely be affected by the HON applicability

criteria). These models were used to determine emission

reductions and cost effectiveness values for wastewater streams

that would just be affected by the HON. This analysis is

presented in Table 6-10. Streams of methanol, propionaldehyde,

and a stream with a 50/50 concentration of methanol and

ethylbenzene, at flow rates from 0.25 to 25 gallons per minute at

a concentration of 10,000 ppm and a stream with a flow rate of

37.9 gpm at a concentration of 1,000 ppm were chosen to be

modeled. Methanol was chosen because it is the most common Table

9 HAP found in the wastewater streams shown on 

Table 6-9. Propionaldehyde was one of two other pollutants found

in the reported wastewater streams that is a Table 9 HAP. A

combination stream of methanol and ethylbenzene was chosen

because methanol is the most common HAP found in the streams and

because ethylbenzene had the highest fraction emitted (Fe) number

and numbers equally as high as other HAP for fraction removed

(Fr) and fraction measured (Fm). Flow rates of 0.25 to 25
6-41

gallons per minute were chosen because this range of flow rates

is representative of the flow rate data provided by industry as

shown in Table 6-9. The concentrations represent concentrations

at the HON applicability criteria cutoffs.

Table 6-10 presents the results of the cost effectiveness

analysis for wastewater control at both new and existing

facilities. This analysis was based on steam stripping as the

control option. Based on this analysis, the cost effectiveness

of implementing the HON for methanol results in cost

effectiveness values of approximately $800/ton to $41,100/ton. 

The cost effectiveness of implementing the HON for

propionaldehyde results in cost effectiveness values of 
Table 6-9. WASTEWATER FLOW AND CONCENTRATION DATA

6-42

Facility Waste Table 8/9 Flow- Concentration New and Existing Sources New Sources

Name Water HAP rate (mg/l) HON Table 9 Criteria HON Table 8

 Stream (other (gpm) Criteria

ID pollutants) >0.00528 gpm

and >10 mg/l

$10,000 $1,000 $10 mg/L

(mg/l) (mg/l) and $

and any and 0.00528

flow $37.9 gpm

gpm

Borden, E2A methanol, 2.5 no data not not not NA

Louisville, (formaldehyde) caught caught caught

KY

Borden, E5 methanol, 2.5 no data not not not NA

Louisville, (formaldehyde) caught caught caught

KY

Cytec, E23,34, methanol, 1.5 no data not not not NA

Wallingford, 35,36 (formaldehyde) caught caught caught

CT

Cytec, E1 methanol, 3 no data not not not NA

Cottage (formaldehyde) caught caught caught

Grove, MN

Cytec, E9 methanol, 100 no data not not flow NA

Cottage (formaldehyde) caught caught

Grove, MN

c

Solutia, E3 methanol, 20 4 methanol, not not not NA

Springfield, (formaldehyde) 1,100 caught caught caught

MA formaldehyde

Solutia, E6 methanol, 3 60 methanol, not not not NA

Springfield, (formaldehyde) 900 caught caught caught

MA formaldehyde
Table 6-9. WASTEWATER FLOW AND CONCENTRATION DATA

Facility Waste Table 8/9 Flow- Concentration New and Existing Sources New Sources

Name Water HAP rate (mg/l) HON Table 9 Criteria HON Table 8

 Stream (other (gpm) Criteria

ID pollutants) >0.00528 gpm

and >10 mg/l

$10,000 $1,000 $10 mg/L

(mg/l) (mg/l) and $

and any and 0.00528

flow $37.9 gpm

gpm

6-43

Akzo, no data no data 0.013 no data not not not NA

Louisville, caught caught caught

KY

AVERAGE 11.6 5649

 Pollutants in parentheses are not Table 8/9 HAPs; these pollutants were included a

because they are present im the wastewater streams and affect the concentration of the

stream.

 The reported value is a maximum flow rate. The stream would be caught by the HON at b

this flow rate. However, since minimum flow rates were not reported it cannot be

ascertained for certain if the stream would be caught when averaged over a 24 hour period.

 “Flow” or “conc” means these streams meet the applicability criteria for flow (i.e. c

37.9 gpm) or concentration (i.e. 1,000 mg/l), respectively.

 This wastewater stream does not contain any Table 8 HAP. d
6-44

approximately $300/ton to $15,200/ton. The cost effectiveness of

implementing the HON for the combination stream results in cost

effectiveness values of approximately $400/ton to $21,500/ton. 

Table 6-10 shows that for a concentration of 10,000 mg/l, the

higher the flow rate, the more cost effective it is to control

that stream.

The MACT floor for wastewater for existing sources is no

control. Based on the regulatory alternatives beyond the MACT

floor analysis, the EPA judged that implementing the HON would be

cost effective. However, as shown in Table 6-10, the best

available data do not indicate that any wastewater streams at

existing facilities will definitely require control. Without an

indication that imposition of the HON wastewater standards would

achieve any amount of emission reductions at existing sources,

the EPA did not find the cost of the applicability analysis and

recordkeeping and reporting requirements of the regulatory

alternative beyond the MACT floor option to industry to be

justified. Therefore, the standard selected for existing sources

was no control. 
Table 6-10. EMISSION REDUCTIONS AND COST EFFECTIVENESS 

FOR SELECTED WASTEWATER STREAMS

6-45

Methanol

Model Flow Mass Cost

Stream Rate WW Effectiveness

ID (gpm) (lb/min) ($ per ton)

Concentration

(parts per

million)

(tons per year) Total

Annual

Cost

($)f

Total Emissions

Mass Reduction c Emissionsd

Method e

305a Absoluteb

1 0.25 2.1 10,000 11,765 6.5 1.1 2.0 $82,330 $41,149 

2 1 8.4 10,000 11,765 25.8 4.4 8.0 $92,590 $11,569 

3 2 16.7 10,000 11,765 51.6 8.8 16.0 $99,760 $6,233 

4 3 25.1 10,000 11,765 77.4 13.2 24.0 $104,770 $4,364 

5 5 41.8 10,000 11,765 129.1 21.9 40.0 $112,390 $2,809 

6 10 83.5 10,000 11,765 258.2 43.9 80.0 $128,320 $1,603 

7 15 125.3 10,000 11,765 387.2 65.8 120.0 $140,920 $1,174 

8 20 167.0 10,000 11,765 516.3 87.8 160.1 $152,110 $950 

9 25 208.8 10,000 11,765 645.4 109.7 200.1 $162,450 $812 

10 37.9 316.5 1,000 1,176 97.8 16.6 30.3 $186,700 $6,155 

Propionaldehyde

1 0.25 2.1 10,000 10,000 5.5 2.2 5.4 $82,330 $15,159 

2 1 8.4 10,000 10,000 21.9 9.0 21.7 $92,590 $4,262 

3 2 16.7 10,000 10,000 43.9 18.0 43.4 $99,760 $2,296 

4 3 25.1 10,000 10,000 65.8 27.0 65.2 $104,770 $1,608 

5 5 41.8 10,000 10,000 109.7 45.0 108.6 $112,390 $1,035 

6 10 83.5 10,000 10,000 219.4 90.0 217.2 $128,3200 $591 

7 15 125.3 10,000 10,000 329.2 135.0 325.9 $140,920 $432 

8 20 167.0 10,000 10,000 438.9 179.9 434.5 $152,110 $350 

9 25 208.8 10,000 10,000 548.6 224.9 543.1 $162,450 $299 

10 37.9 316.5 1,000 1,000 83.2 34.1 82.3 $186,700 $2,268 
Table 6-10. EMISSION REDUCTIONS AND COST EFFECTIVENESS 

FOR SELECTED WASTEWATER STREAMS

6-46

Methanol/EthylBenzene

Model Flow Mass Concentration (tons per year) Total Cost

Stream Rate WW (parts per Total Emissions Emissions Annual Effectiveness

ID (gpm) (lb/min) million) Mass Reduction Cost ($ per ton) c

d

e

Method Absolute ($)

305a

b f

1 0.25 2.1 10,000 10,753 5.9 2.9 3.8 $82,330 $21,472 

2 1 8.4 10,000 10,753 23.6 11.8 15.3 $92,590 $6,037 

3 2 16.7 10,000 10,753 47.2 23.6 30.7 $99,760 $3,252 

4 3 25.1 10,000 10,753 70.8 35.4 46.0 $104,770 $2,277 

5 5 41.8 10,000 10,753 118.0 59.0 76.7 $112,390 $1,466 

6 10 83.5 10,000 10,753 236.0 118.0 153.4 $128,320 $837 

7 15 125.3 10,000 10,753 353.9 177.0 230.1 $140,920 $613 

8 20 167.0 10,000 10,753 471.9 236.0 306.7 $152,110 $496 

9 25 208.8 10,000 10,753 589.9 294.9 383.4 $162,450 $424 

10 37.9 316.5 1,000 1,075 89.4 44.7 58.1 $186,700 $3,212 

 Concentration as measured using Method 305. The value measured using Method 305 is the a

value to be compared with the HON applicability criteria for concentration. Dividing a

concentration measured using Method 305 by the Fm (fraction measured) value yields the

absolute concentration.

 Concentration as measured using a method other than Method 305. The absolute value is used b

as the basis for estimating emissions and emission reductions. Multiplying the absolute

concentration by the Fm (fraction measured) value yields the Method 305 concentration.

 Total mass of HAP in water. c

 HAP air emissions. d

 HAP air emission reductions. e

 Costs based on steam stripping. f
6-47

However, the HON was chosen by EPA as the standard for new

sources. The EPA believes that because new sources will already

be required to characterize their emissions for the Title V

permit application, the additional cost of the applicability

analysis associated with the wastewater provisions would be

acceptable given the potential for reducing emissions.

For equipment leaks at existing sources, two regulatory

alternatives were identified -- (1) 40 CFR part 60, subpart VV

and (2) the Hazardous Organic NESHAP (HON) LDAR program under 40

CFR part 63, subpart H (referred to hereafter as the HON LDAR

program). Table 6-11 provides a brief summary of subpart VV’s

and the HON’s LDAR program. For new sources, the regulatory

alternative evaluated was the application of the HON LDAR program

, because the MACT floor is equivalent to the subpart VV program.

In conducting the regulatory analysis, there are several

items that need to be identified to determine whether or not any

of the regulatory alternatives are cost effective. First,

component counts for each of the major sources need to be

determined. Second, estimates of emissions and emission

reductions need to be made. Third, the costs associated with the

LDAR programs need to be estimated. The following paragraphs

present the methods used in the regulatory alternative analysis.
6-48

Table 6-11. SUMMARY OF LDAR REGULATORY ALTERNATIVES

Component and Service 40 CFR Part 60, 40 CFR Part 63,

Subpart VV Subpart H

Valves, gas/vapor and Monthly monitoring with skip period Quarterly monitoring with

light liquid option for quarterly monitoring. Leak leak definition of 500 ppm

definition = 10,000 ppm. (Phase III).

Valves, heavy liquid If indication of leak (sight, sound, smell), monitor to confirm leak

Pumps, heavy liquid (leak definition = 10,000 ppm) and then repair.

Pumps, light liquid Monitor monthly with weekly visual Monitor monthly with

inspection. Leak definition = 10,000. weekly visual inspections.

 Leak definition = 5,000

(Phase III).

Compressors Use of barrier fluid system that prevents leakage of VOC to atmosphere.

Open Ended Lines Caps, blind flanges, etc.

Pressure Relief Devices, No detectable emissions

gas/vapor

Pressure Relief Devices, If indication of leak (sight, sound, smell), monitor to confirm leak

light or heavy liquid (leak definition = 10,000 ppm) and then repair.

Sampling Connections Closed purge system or closed vent system to control device

Flanges and other If indication of leak (sight, sound, Annual monitoring with leak

connectors, gas/vapor smell), monitor to confirm leak (leak definition of 10,000.

definition = 10,000 ppm) and then

Flanges and other repair.

connectors, light liquid

Flanges and other If indication of leak (sight, sound, smell), monitor to confirm leak

connectors, heavy liquid (leak definition = 10,000 ppm) and then repair.
6-49

A questionnaire was sent to companies requesting specific

information on component counts, the weight percent HAP

contacting the components, and time the component is in contact

with the HAP. Facilities were also given the option of providing

information on the number of storage vessels, from which the

number of components would be estimated. Facilities that use

only heavy liquids in their process were asked to provide

information on the number of storage vessels only.

Emissions for each facility were estimated using equipment

counts and emission factors for uncontrolled emissions. 

Equipment counts were either provided by the facility or

estimated based on the number and type of storage vessels. 

Emissions were estimated for each of the two basic LDAR programs

identified as regulatory alternatives. In addition, the level of

emissions were adjusted based on the percent HAP and time in

contact with HAP if this information was provided by the

facility. If facilities did not provide this information,

default values of 100 percent HAP and 8,760 hours per year of

contact time were used to estimate emissions.

Costs (1989 $) were estimated for each facility except for

those that use heavy liquids only. The following paragraphs

discuss selected aspects of the costing used for the LDAR

programs. Complete details can be found in “Equipment Leak

Analysis for Amino/Phenolic Resins NESHAP,” Docket Item II-B-11.
6-50

Type of Monitoring Program. Facilities may use in-house or

subcontractor personnel to conduct a LDAR program. Because of

the relatively low number of components at most amino/phenolic

resins facilities, it was assumed that each facility would elect

to use in-house personnel, which should reduce the cost of

implementation, in part, by avoiding travel to monitor pumps.

Monitoring Instrument. Facilities must decide whether to

purchase or rent a monitoring instrument. The cost of a basic

monitoring instrument and its annual maintenance are estimated to

be $6,500 and $4,260, respectively, while the cost to rent an

instrument (including shipping) is estimated to be range from

$164 for one day of monitoring up to $760 for a 15-day monitoring

period. Because of the relatively low number of components,

rental of a monitoring instrument was estimated to be always less

expensive than the purchase and maintenance of the instrument. 

Logging vs Tagging. In implementing a LDAR program, a

decision must be made as to whether to tag the components

initially or to enter them into a log. Again, because of the

relatively low number of components, it was assumed that all

facilities would log their components rather than tag them.

Database System. Another decision to be made at the outset

of implementing a LDAR program is whether to purchase a database

system or use other means (e.g., a log book) to track the

components subject to the LDAR and those components identified as

leaking. It was assumed that all facilities with 500 or fewer
6-51

components subject to monitoring would purchase a simple

spreadsheet to track the components, while those with facilities

with more than 500 components subject to monitoring would

purchase a more expensive database system.

Reporting, Recordkeeping, Training, Administration. These

activities are required for each facility to implement and

maintain a LDAR program. There are both initial costs (e.g.,

training of personnel) and annual costs (e.g., report

preparation) associated with the implementation of a LDAR

program. For the purposes of the cost analysis, the following

assumptions were made as to the number of technical hours

required to implement the LDAR programs. Because the SOCMI

program does not cover connectors, a slightly reduced level of

effort was assumed for that LDAR program.

Initial Hours Annual Hours

SOCMI LDAR: 44 183

HON LDAR: 60 200

Table 6-12 presents the results of the cost effectiveness

analysis for both new and existing facilities. Based on this

analysis, the average cost effectiveness of implementing the

SOCMI Subpart VV LDAR program from baseline at each of the

amino/phenolic resin facilities is approximately $4,207 per

megagram of emission reduction. The average incremental cost

effectiveness of implementing the HON LDAR program from baseline

is approximately $2,608 per megagram of emission reduction. The
6-52

average incremental cost effectiveness of going from the SOCMI

Subpart VV program to the HON program is approximately $1,343 per

megagram of emission reduction.

The EPA judged the incremental cost effectiveness of the HON

LDAR program to be reasonable and, therefore, selected the HON

LDAR program as the proposed standards for equipment leaks at

both existing and new sources.
6-53

Table 6-12. Summary of Regulatory Analysis

for Equipment Leaks

Item HON SOCMI,

subpart VV

Emission Reduction

from Baseline 52.6 119.0

(Mg/yr)

Costs ($) 221,313 310,465

Cost Effectiveness

($/Mg) 4,207 2,608

Incremental Emission

Reduction (Mg/yr) -- 66.4

Incremental Costs

($) -- 89,152

Incremental Cost

Effectiveness ($/Mg) -- 1,343
7-1

7.0 SUMMARY OF ENVIRONMENTAL, ENERGY, COST,

AND ECONOMIC IMPACTS

This chapter presents the air, non-air environmental (solid

waste and wastewater), energy, cost, and economic impacts

resulting from the control of organic HAP emissions under the

proposed rule. In addition, this chapter presents a summary of

the costing for batch process vents, storage vessels, and

equipment leaks.

7.1 FACILITIES AFFECTED BY THIS NESHAP

The proposed rule would affect amino/phenolic resin

facilities that are major sources in themselves, or that are

located within a major source. Based on available information,

40 amino/phenolic resins facilities were judged to be major

sources (see “Major source population of amino and phenolic resin

facilities for purposes of MACT analysis” memorandum, Docket Item

II-B-10).

Impacts are presented relative to a baseline reflecting the

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

impacts only includes applying controls to the 40 major existing

facilities because, as discussed in Section 7.6, no new

facilities are expected to be constructed.

The impacts for existing sources were estimated by applying

the controls necessary to bring each facility into compliance

with the proposed standards. For a facility or emission point

within a facility already in compliance with the proposed
7-2

standards, no impacts were estimated for that facility or

emission point.

7.2 PRIMARY AIR IMPACTS

The proposed standards are estimated to reduce organic HAP

emissions from all existing sources by 361 Mg/yr from a baseline

level of 644 Mg/yr. This is a 56 percent reduction. Table 7-1

summarizes the organic HAP emission reductions for each of the

emission points.

Table 7-1. ORGANIC HAP EMISSION REDUCTIONS BY EMISSION POINT

FOR EXISTING SOURCES

Emission Point Emissions Proposed Reduction Reduction

Baseline After Emission Percent

(Mg/yr) Rule (Mg/yr) (%)

Emissions

(Mg/yr)

Reactor Batch

Process Vents 202.4 20.0 182.4 90.1

Non-reactor Batch

Process Vents 109.0 49.1 59.9 55.0

Continuous Process

Vents 116.4 116.4 0 0

Storage Vessels 65.4 65.3 0.1 0.2

Wastewater 6.1 6.1 0 0

Equipment Leaks 144.6 25.6 119.0 82.3

Total 643.9 282.5 361.4 56.1

7.3 NON-AIR ENVIRONMENTAL IMPACTS

The proposed standards are not expected to increase the

generation of solid waste at any amino/phenolic resin facility.
7-3

The use of scrubbers to control emissions will increase

water consumption as a result of evaporation and bleed-off. 

Bleed-off is the release of a small percentage of the recirculated scrubber water to control buildup or accumulation of

scale, or other contaminates. Scrubbers designed to capture

emissions from reactor and non-reactor batch process vents are

small in size and should require less than 100 gallons of bleedoff per day per reactor.

Many of the HAP being controlled by scrubbers are water

soluble, with very low evaporation rates once in water. 

Therefore, the EPA does not expect the HAP to be released from

the scrubber wastewater at a point downstream from the scrubber.

In general, the EPA expects the adverse impact of the

wastewater generated by the scrubbers to be small to negligible.

First, the HAP contained in the wastewater from the scrubber are

very susceptible to being eaten by the various bacteria found in

wastewater treatment plants. Thus, for those facilities that

send or will send the scrubber wastewater to a wastewater

treatment facility, there should be minimal adverse impacts.

Some facilities may not be able to send their scrubber

wastewater to a treatment facility. These facilities may be able

to recycle all of the scrubber wastewater within the facility.

From information gathered through site visits and telephone

conversations with industry, the EPA determined that some

facilities recycle wastewater containing the predominant HAP
7-4

emitted by batch process vents (i.e., formaldehyde, methanol,

and phenol). Three resin plants visited by the EPA collected and

reused their wastewater. The recovered wastewater contains the

 raw materials used in the reactor process. Recycling wastewater

into the resin manufacturing process reduces the quantities of

raw materials required to be purchased, thereby reducing costs. 

Based on telephone conversations with industry, one resin

manufacturer uses a water pit to collect emissions from the

reactor. Water is removed from the pit when the formaldehyde

concentration reaches approximately three percent and is placed

in a storage tank. The stored water is added to raw materials in

the reactors to establish the proper viscosity at the beginning

of a resin batch.

In summary, the EPA expects that affected facilities will be

able to either send the scrubber wastewater to a treatment

facility or recycle the scrubber wastewater back into the

process. Therefore, the use of scrubbers will result in minimal,

if any, adverse wastewater impacts.

7.4 ENERGY IMPACTS

Energy impacts include changes in energy use, typically

increases, and secondary air impacts associated with increased

energy use. Increases in energy use are associated with fuel for

the operation of control equipment; in this case, the use of

scrubbers to control reactor vents. Energy credits are

attributable to the prevention of organic HAP emissions from
7-5

equipment leaks. Secondary air impacts associated with increased

energy use are the emission of particulates, sulfur dioxides

(SOx), and nitrogen oxide (NOx). These secondary impacts are

associated with power plants that would supply the increased

energy demand. (For more information on the calculation of the

estimated energy impacts, see the “Estimated Energy and Secondary

Air Impacts” memorandum, Docket Item II-B-16.)

As noted above, energy use is expected to increase due to

the use of scrubbers to control reactor vents which would be used

to comply with the proposed rule. The use of scrubbers is

estimated to increase energy use by approximately 2,340 barrels

of oil per year for the 40 existing major sources. The emissions

of secondary air pollutants from power plants supplying the power

for this energy increase are estimated to be 3 Mg/yr of

filterable particulate, 15 Mg/yr of SOx, and 0.3 Mg/yr of NOx.

At the same time, the prevention of organic HAP emissions

from equipment leaks generates energy credits. These energy

credits are expected to be relatively small and have not been

estimated.

Energy impacts related to the control of storage vessels

were estimated to be negligible (or zero) because many storage

vessels would be controlled through the use of internal floating

roofs, which do not have any associated energy impacts.

As stated above, the use of scrubbers results in an increase

of oil consumption per year for the 40 major existing affected
7-6

sources. The net increase will be smaller due to the energy

credits generated by the control of equipment leak emissions. 

Given the relatively small energy impact projected from the

control of batch process vents, the EPA has judged the energy

impacts associated with the proposed rule to be acceptable.

7.5 COST IMPACTS

Cost impacts include the capital costs of new control

equipment, the cost of energy (supplemental fuel and electricity)

required to operate control equipment, operation and maintenance

costs, and the cost savings generated by reducing the loss of

valuable product in the form of emissions. Also, cost impacts

include the costs of monitoring, recordkeeping, and reporting

associated with the proposed standards. Average cost

effectiveness ($/Mg of pollutant removed) is also presented as

part of cost impacts and is determined by dividing the annual

cost by the annual emission reduction. Table 7-2 presents the

estimated capital and annual costs and average cost effectiveness

for complying with the proposed rule by existing affected

sources. There are no estimated cost impacts for new facilities,

because no new facilities are expected to be constructed.

Under the proposed rule, it is estimated that total capital

costs for existing sources would be $2,157,400 (1989 dollars),

and total annual costs would be $1,597,800 (1989 dollars) per

year. The use of 1989 dollars in estimating the costs associated

with the proposed standards was done in order to be consistent
7-7

with the cost effectiveness decisions reached for setting the HON

standards, which form the basis for most of the standards being

proposed for the amino/phenolic source category. The actual

compliance cost impacts of the proposed rule may be less than

presented because of the potential to use common control devices,

to upgrade existing control devices, and to vent emissions

streams into current control devices. Because the effect of such

practices is highly site-specific and data were unavailable to

estimate how often the lower cost compliance practices could be

utilized, it is not possible to quantify the amount by which

actual compliance costs would be reduced.

The following paragraphs discuss the costing used to develop

the cost impacts for batch process vents, storage vessels, and

equipment leaks. Following these paragraphs is a brief

discussion on the monitoring, recordkeeping, and reporting costs

estimated for the proposed rule. These latter costs are included

in the cost estimates reported in Table 7-2. 

Table 7-2. SUMMARY OF COST IMPACTS

Emission Point Effectiveness

Total Total

Capital Annual

Costs Costs

($1,000) ($1,000)

Average Cost

($/Mg)

Reactor and Non-reactor

Batch Process Vents 1,687 1,279 5,280

Continuous Process Vents 0 0 NA

Storage Vessels 31.6 8.3 83,000
7-8

Wastewater 0 0 NA

Equipment Leaks 438.8 310.5 2,608

Total 2,157.4 1,597.8 4,420

For more detailed information on the costing procedures, please

refer to the following memoranda:

C Batch Process Vents Analysis for Amino/Phenolic Resins

NESHAP, Docket Item II-B-12.

C Storage Vessels Analysis for Amino/Phenolic Resins

NESHAP, Docket Item II-B-13.

C Equipment Leak Analysis for Amino/Phenolic Resins

NESHAP, Docket Item II-B-11.

7.5.1 Reactor and Non-reactor Batch Process Vent Costs

Industry currently uses scrubbers and thermal incinerators

to control emissions from amino/phenolic resin production. The

three largest HAP in the emission stream are formaldehyde,

methanol, and phenol. All three compounds are readily absorbed

in water. Therefore, control device costing was based on the

installation of a scrubber to control the plant emission stream

from reactor and non-reactor batch process vents.

HAPPRO was used to calculate the total capital costs, fixed

annual costs, and annual variable costs. The total annual cost

for control is the sum of annual variable cost, annual fixed

cost, and the variable annual electrical cost. HAPPRO is a U.S.

Environmental Protection Agency computer program used as an aid
7-9

in costing pollution control devices. It is based on the OAQPS

Control Cost Manual, EPA 453/B-96-001.

In order to use HAPPRO for this analysis, several

assumptions had to be made. One major assumption was reactor

size, which was assumed to be 20,000 gallons. A second major

assumption was the level of production, which was based on a

conservative assumption of 12 hours per day for each batch of

amino/phenolic resin. (A batch of resin can be produced in 8

hours if conditions are normal.) Annual hours of production were

assumed to be 24 hours per day and 300 days per year, totaling

7,200 hours per year production time for each reactor. Finally,

air stream flow rate was estimated to be 114 standard cubic feet

per minute (scfm) per 1,000 gallons of reactor capacity. Using

these assumptions and the annual reported production data, the

number of reactors per facility, the number of operating hours,

and the air stream flow rate to the scrubber were calculated. 

This information, along with other data, was used in the HAPPRO

program for calculating control equipment costing.

7.5.2 Storage Vessels Costs

Storage vessel costs were based on the application of

internal floating roofs. This technology is an over estimate of

the emission reduction required (i.e., 95 percent vs. the

required 50 percent); however, the technology is technically

feasible for storage vessels with these vapor pressures and costs

for this technology were readily available.
7-10

Control costs were estimated for those storage vessels that

did not already have controls applied but met the applicability

criteria described in Chapter 6. Only one storage vessel at an

existing affected source requires control under the standard at a

total annual cost of $8,300/yr. Total capital costs are $31,600.

7.5.3 Equipment Leak Costs

The proposed rule would require facilities to implement,

with some changes, the leak detection and repair (LDAR) found in

40 CFR part 63, subpart H. Differences in the proposed rule

compared to subpart H that may reduce the estimated costs, but

which were not included in the costing algorithms used in this

analysis, are (1) the option to group valves and (2) the

increased monitoring frequencies for facilities that demonstrate

lower leak frequencies (e.g., monitoring connectors once every 8

years rather than once every 4 years).

The basic costing algorithms used to develop the LDAR cost

estimates were derived from the work used to support the

hazardous organic NESHAP (HON) equipment leak standards, which

are found in 40 CFR part 63, subpart H. Major variations or

assumptions used in developing the LDAR costs for the

amino/phenolic resin facilities are as follows:

C In-house personnel rather than subcontracting personnel

were assumed to be responsible for implementing the

LDAR program.

C The monitoring instrument was assumed to be rented

rather than purchased.
7-11

C Facilities with fewer than 500 or fewer components

subject to Method 21 monitoring were assumed not to

require the purchase of a database system; those with

more than 500 components subject to Method 21

monitoring were assumed to purchase a spreadsheet

program for tracking components.

C Facilities would “locate and log” the components

subject to Method 21 monitoring rather than “locate and

tag” these components. 

Emission reduction credits were assigned based on the

specific compounds being reduced. This reduced the overall total

annual costs attributable to the proposed rule.

7.5.4 Monitoring, Recordkeeping, and Reporting Costs

Additional costs for monitoring, recordkeeping, and

reporting were developed for a typical amino/phenolic resin

facility. The typical facility was assumed to have reactor and

non-reactor batch process vents and an equipment leaks LDAR

program. Monitoring, recordkeeping, and reporting costs were not

developed for continuous process vents or wastewater because they

are not being regulated at existing facilities. Storage vessels

were not included because most facilities will not have to

control their storage vessels.

The estimated additional costs for monitoring,

recordkeeping, and reporting at a typical facility is estimated

to be 1,217 hours and $41,092 during the first year. This

estimate decreases to 600 hours and $19,310 per year afterward. 

Detailed assumptions used to derive these cost estimates can be

found in the OMB 83-1 Form and Supporting Statement. A copy of
7-12

the OMB 83-1 Form and Supporting Statement may be obtained by

sending written correspondence to the Director, OPPE Regulatory

Information Division; U. S. Environmental Protection

Agency (2136), 401 M St. S.W., Washington, DC 20460, and to the

Office of Information and Regulatory Affairs, Office of

Management and Budget, 725 17th St. N.W., Washington, DC 20503,

marked "Attention: Desk Officer for EPA." Include the ICR number

in any correspondence.

7.6 ECONOMIC IMPACTS

An economic impact analysis for the proposed rule estimated

the impacts to affected businesses in the amino/phenolic resins

source category. Prices for products from the 20 businesses

that operate the 40 facilities affected by this rule are

estimated to increase by 0.3 percent for amino resin businesses

and 0.2 percent for phenolic resin businesses. Output for these

products are estimated to decrease by 0.2 for amino resin

businesses and 0.1 percent for phenolic resin businesses. 

Revenues for the entire industry are estimated to increase by 0.2

percent, and this is due to the expected increase in product

prices resulting from the proposed rule that will be experienced

by amino/phenolic resin producers that are not affected by this

rule. The level of employment in these industries is estimated

to fall by about 5 percent based on estimates to adversely

affected businesses only. No facilities are estimated to be at

risk of closure from costs associated with this proposed rule. 
7-13

For more information, refer to the Economic Impact Analysis

of the Proposed National Emission Standard for Hazardous Air

Pollutants: Manufacture of Amino/Phenolic Resins (contained in

the docket for this rule).
8-1

8.0 SUMMARY OF PROPOSED STANDARDS

The purpose of this chapter is to present a summary of the

proposed standards. The rationale associated with the selection

of the proposed standards is provided in the preamble and in

Chapter 6 of this document. The full regulatory text is

available in Docket A-92-19, directly from the EPA. More

information on how to obtain a copy of the proposed standards is

provided in the preamble.

8.1 SOURCE CATEGORY TO BE REGULATED AND DEFINITION OF AFFECTED

SOURCE

The proposed rule would regulate organic HAP emissions from

facilities in the amino/phenolic resin source category, provided

that a facility is determined to be a major source. The proposed

rule defines amino/phenolic, amino, and phenolic resins as

follows:

Amino/Phenolic Resin means one or both of the following

types of resins:

(1) Amino resin, or

(2) Phenolic resin.

Amino resin means a resin produced through the reaction of

formaldehyde, or a formaldehyde containing solution (e.g.,

aqueous formaldehyde), with compound(s) that contain the

amino group; these compounds include melamine, urea, and

urea derivatives.

Phenolic resin means a resin that is a condensation product

of formaldehyde and phenol, or a formaldehyde substitute

and/or a phenol substitute. Substitutes for formaldehyde

include acetaldehyde or furfuraldehyde. Substitutes for

phenol include other phenolic starting compounds such as

cresols, xylenols, p-tert-butylphenol, p-phenylphenol, and

nonylphenol.
8-2

The proposed rule would regulate existing and new affected

sources. For this proposed rule, an affected source is defined

as each group of one or more amino/phenolic resin process units

(APPU) that is located at a plant site that is a major source. 

An APPU is defined as follows:

Amino/Phenolic Resin Process Unit (APPU) means a collection

of equipment assembled and connected by hard-piping or

ductwork used to process raw materials and to manufacture an

amino/phenolic resin as its primary product. This

collection of equipment includes process vents from process

vessels; equipment identified in §63.149; storage vessels,

as determined in §63.1400(g); and the equipment that is

subject to the equipment leak provisions as specified in

§63.1415. Utilities, lines and equipment not containing

process fluids, and other non-process lines, such as heating

and cooling systems which do not combine their materials

with those in the processes they serve, are not part of the

amino/phenolic resin process unit. An amino/phenolic resin

process unit consists of more than one unit operation.

In addition to the emission points and/or equipment included

in the definition of APPU, the affected source includes waste

management units, maintenance wastewater, heat exchange systems,

and equipment used to comply with this rule, including control

devices and recovery devices.
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8.2 RELATIONSHIP TO OTHER RULES

Affected sources subject to the proposed rule may also be

subject to other existing rules. The relationship between this

rule and three other rules is discussed below. See proposed

§63.1401(g)-(i).

Affected sources subject to the proposed rule may have

storage vessels subject to the NSPS for Volatile Organic Liquid

Storage Vessels (40 CFR part 60, subpart Kb). For storage

vessels subject to and complying with the NSPS, the proposed rule

requires that such storage vessels remain in compliance with the

NSPS because the NSPS level of control (i.e., 95%) is more

stringent than the control level for the proposed rule (i.e.,

50%). For storage vessels subject to the NSPS but that did not

have to apply controls (e.g., the storage vessels stores an

organic liquid but the vapor pressure of the stored material is

below the applicability criteria), the proposed rule states that

after the compliance date for the proposed rule, such storage

vessels are only required to comply with the proposed rule and

are no longer subject to subpart Kb.

Affected sources subject to the proposed rule may have

cooling towers subject to the NESHAP for Industrial Cooling

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

the requirements of subpart Q and the proposed rule. Subpart Q

prohibits the use of certain chemicals in the cooling tower

water, and the proposed rule implements a leak detection and
8-4

repair program for organic HAP. Therefore, affected sources

subject to both rules must comply with both rules.

Affected sources subject to the proposed rule may also be

subject to the Standards of Performance for Equipment Leaks of

VOC in the Synthetic Organic Chemicals Manufacturing Industry

(SOCMI LDAR) (40 CFR part 60, subpart VV) and/or the National

Emission Standards for Organic Hazardous Air Pollutants for

Equipment Leaks (HON NESHAP LDAR)(40 CFR part 63, subpart H). 

After the compliance date for the proposed rule, such affected

sources are only required to comply with the proposed rule and

are no longer subject to CFR part 60 subpart VV or to CFR part 63

subpart H. The proposed rule directly references the HON

provisions contained in subpart H, and therefore is equivalent to

the HON. The HON is more stringent than the subpart VV.

Another likely instance of interaction between the proposed

rule and other rules is related to storage vessels already

covered by the HON; this is likely to occur at amino/phenolic

resin facilities that are collocated with formaldehyde plants

subject to the HON. In such cases, a methanol storage vessel

supplying methanol to the amino/phenolic resin facility is likely

to be subject to the HON. The storage vessel assignment

procedures in the proposed rule address such situations. If a

storage vessel is already subject to another part 63 standard,

that storage vessel is considered to be assigned to the process
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unit subject to the part 63 standard and is not subject to the

proposed rule.

8.3 POLLUTANTS TO BE REGULATED

The facilities in the source category covered by the

proposed rule emit a variety of organic HAP. Among the most

significant emissions of organic HAP are the following: 

formaldehyde, methanol, phenol, xylene, and toluene. The

proposed rule would regulate emissions of these compounds, as

well as a variety of other organic HAP that are emitted.

8.4 AFFECTED EMISSION POINTS

Emissions from the following emission points are being

covered by the proposed rule: storage vessels, continuous

process vents, batch process vents, equipment leaks, wastewater,

and heat exchange systems.

8.5 FORMAT OF THE STANDARD

The Hazardous Organic NESHAP (HON) (subparts F, G, H, and I

of 40 CFR part 63) is relied on heavily and provides the basis

for selection of the proposed formats for the majority of

emission points. For those emission points relying on the HON

(i.e., storage vessels, continuous process vents, heat exchange

systems, wastewater, and equipment leaks), the format of the

proposed standards is the same as those found in the HON. The

following paragraphs summarize the selected formats.

For storage vessels, the format of the proposed standards is

dependent on the method selected to comply with the standards. 
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If tank improvements (e.g., internal or external floating roofs

with proper seals and fittings) are selected, the format is a

combination of design, equipment, work practice, and operational

standards. If a closed vent system and control device are

selected, the format is a combination of design and equipment

standards, and a percent reduction or outlet concentration. As

an alternate standard, the proposed rule allows emissions from

storage vessels to be vented to a control device continuously

achieving an outlet concentration of 20 ppmv of organic HAP. In

this case the format is an outlet concentration.

For continuous process vents, the format of the proposed

standards is also dependent on the method selected to comply with

the standards. If a control device other than a flare is used,

the formats are a percent reduction or an outlet concentration. 

If a flare is selected, the format is a combination of equipment

and operating specifications. Like storage vessels, the proposed

rule allows compliance by venting emissions to a control device

continuously achieving an outlet concentration of 20 ppmv of

organic HAP.

For batch process vents the format depends on the type of

batch process vent. For reactor batch process vents, a percent

reduction and an emission limit were selected. The standard

requires that emissions are reduced by a certain percent (i.e.,

93 percent at existing affected sources and 95 percent at new

affected sources) over the batch cycle. As an alternative, the
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standard allows a demonstration that emissions are limited to

0.017 kg of HAP per megagram of product at existing affected

sources or 0.01 kg of HAP per megagram of product at new affected

sources. For non-reactor batch process vents, the standard

requires that emissions for the collection of non-reactor batch

process vents within the affected source are reduced by 68

percent at existing affected sources and by 83 percent at new

affected sources. Like continuous process vents, if a flare is

selected, the format is a combination of equipment and operating

specifications. Like storage vessels and continuous process

vents, the proposed rule allows compliance by venting emissions

to a control device continuously achieving an outlet

concentration of 20 ppmv of organic HAP.

For heat exchange systems, a work practice standard is

proposed. This standard requires a leak detection and repair

program to detect and repair leaks of organic HAP into cooling

tower water.

For wastewater streams requiring control, the proposed

standards incorporate several formats: equipment, operational,

work practice, and emission standards. The particular format

selected depends on which portion of the wastewater stream is

involved. For transport and handling equipment, the selected

format is a combination of equipment standards and work

practices. For the reduction of organic HAP from the wastewater

stream itself, several alternative formats are included,
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including alternative numerical emission limit formats and

equipment design and operation standard for a steam stripper. 

For vapor recovery and destruction devices other than flares, the

format is a weight percent reduction. For flares, the format is

a combination of equipment and operating specifications.

For equipment leaks, the proposed standards incorporate

several formats: equipment, design, base performance levels

(e.g., maximum allowable percent leaking valves), work practices,

and operational practices. Different formats are necessary for

different types of equipment because of the nature of the

equipment, available control techniques, and applicability of the

measurement method.

8.6 SUMMARY OF THE PROPOSED STANDARDS

Detailed information describing the approach used to

determine MACT floors and the consideration of regulatory

alternatives is presented in Chapter 6 of this document and in

Section V of this preamble.

The proposed standards for new and existing affected sources

are summarized in Table 8-1 and Table 8-2, respectively. The

sections below present the proposed standards by emission point.
Table 8-1. PROPOSED STANDARDS FOR NEW AFFECTED SOURCES

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Emission Point Applicability Criteria Standard

Storage Vessels for aqueous formaldehyde 50 percent control

vessels; vessels with OR

capacities of 10,000 alternative standard of

gallons or greater with venting to a control device

vapor pressures of 0.47 continuously achieving a 20

psia or greater ppmv outlet concentration

for non-aqueous 95 percent control

formaldehyde vessels; OR

vessels with capacities of alternative standard of

10,160 gallons or greater venting to a control device

with vapor pressures of continuously achieving a 20

2.45 psia or greater and ppmv outlet concentration

vessels with capacities of

90,000 gallons and greater

with vapor pressures of

0.45 psia and greater

OR

Continuous Process HON TRE value 85 percent control for vents

Vents calculations; two levels with TRE greater than 1.0

of control but less than or equal to

1.2 

and

98 percent control for vents

with TRE equal to or less

than 1.0 

OR

alternative standard of

venting to a control device

continuously achieving a 20

ppmv outlet concentration

Reactor Batch No applicability criteria, 95 percent control over the

Process Vents all reactor batch process batch cycle;

vents are subject to or

control 0.01 kilogram of HAP per

megagram of product; 

OR

alternative standard of

venting to a control device

continuously achieving a 20

ppmv outlet concentration
Table 8-1. PROPOSED STANDARDS FOR NEW AFFECTED SOURCES

Emission Point Applicability Criteria Standard

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Non-Reactor Batch Facility-wide emissions 83 percent control for the

Process Vents from the collection of collection of non-reactor

non-reactor batch process batch process vents within

vents greater than or the affected source;

equal to or

0.23 Mg alternative standard of

venting to a control device

continuously achieving a 20

ppmv outlet concentration

Heat Exchange No applicability criteria Monitor for leaks

Systems

Wastewater HON applicability criteria HON control level

Equipment Leaks HON applicability criteria HON leak detection and a

repair program

 The HON has an exemption for equipment components in organic HAP a

service less than 300 hours per year.
Table 8-2. PROPOSED STANDARDS FOR EXISTING AFFECTED SOURCES

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Emission Point Applicability Criteria Standard

Storage Vessels for aqueous formaldehyde 50 percent control

vessels; vessels with OR

capacities of 10,000 alternative standard of

gallons or greater with venting to a control

vapor pressures of 0.47 device continuously

psia or greater achieving a 20 ppmv

for non-aqueous

formaldehyde vessels;

vessels with capacities

of 10,160 gallons or

greater with vapor

pressures of 2.45 psia or

greater and tanks with

capacities of 90,000

gallons and greater with

vapor pressures of 0.45

psia and greater

outlet concentration

Continuous Process Not applicable No standard selected

Vents

Reactor Batch Process No applicability 93 percent control over

Vents criteria, all reactor the batch cycle; 

batch process vents are OR

subject to control 0.017 kilogram of HAP per

megagram of product; OR

alternative standard of

venting to a control

device continuously

achieving a 20 ppmv

outlet concentration

Non-Reactor Batch Facility-wide emissions 68 percent control for

Process Vents from non-reactor batch all non-reactor batch

process vents greater process vents within the

than or equal to 0.23 Mg affected source; 

OR

alternative standard of

venting to a control

device continuously

achieving a 20 ppmv

outlet concentration

Heat Exchange Systems No applicability criteria Monitor for leaks

Wastewater Not appliable No standard selected
Table 8-2. PROPOSED STANDARDS FOR EXISTING AFFECTED SOURCES

Emission Point Applicability Criteria Standard

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Equipment Leaks HON applicability HON leak detection and

criteria repair program a

 The HON has an exemption for equipment components in organic HAP a

service less than 300 hours per year.
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8.6.1 Storage Vessels

The proposed standard for storage vessels at existing

affected sources is 50 percent emission reduction for storage

vessels meeting the following applicability criteria:

Aqueous formaldehyde $10,000 gallons capacity with vapor

pressure $0.47 psia

Non-aqueous formaldehyde $10,160 gallons capacity with vapor

pressure $2.45 psia; and $90,000

gallons capacity with vapor

pressure $0.45 psia

For storage vessels at new affected sources, the applicability

criteria are the same but the control levels are different. For

aqueous formaldehyde storage vessels, the control level is 50

percent, and for non-aqueous formaldehyde storage vessels, the

control level is 95 percent.

8.6.2 Continuous Process Vents

The proposed standard for continuous process vents at new

affected sources utilizes the MACT floor level of control and the

HON process vent provisions to establish a two-tiered standard. 

For continuous process vents with total resource effectiveness

values(TRE) greater than 1.0 but less than equal to 1.2, 85

percent emission reduction is required (i.e., MACT floor). For

continuous process vents with a TRE value of 1.0 or less, 98

percent emission reduction is required (i.e., HON). For process

vents with a TRE value greater than 1.2, controls are not
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required. TRE values are determined using the TRE equations from

the HON for a thermal incinerator with 70 percent heat recovery. 

As an alternative to the percent reduction, an owner or operator

may demonstrate that the selected controls reduce the outlet

concentration to 20 ppmv.

The proposed rule does not contain any requirements for the

control of continuous process vents at existing affected sources.

8.6.3 Batch Process Vents

Batch process vents are distinguished as reactor batch

process vents or non-reactor batch process vents under the

proposed standards, and are discussed separately in this section.

8.6.3.1 Reactor Batch Process Vents The proposed standards

for reactor batch process vents at new affected sources are 95

percent emission reduction with an alternative emission limit of

0.01 kilogram of HAP per megagram of product. The proposed

standards for reactor batch process vents at existing affected

sources are 93 percent emission reduction with an alternative

emission limit of 0.017 kilogram of HAP per megagram of product. 

Because there are no applicability criteria for reactor batch

process vents, all vents require control.

8.6.3.2 Non-Reactor Batch Process Vents. The proposed

standard for non-reactor batch process vents at new affected

sources is an overall emissions reduction of 83 percent from all

non-reactor batch process vents within the affected source for

affected sources with emissions from non-reactor batch process
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vents greater than or equal to 0.25 tpy. The proposed standard

for existing affected sources is an overall emissions reduction

of 68 percent for the collection of non-reactor batch process

vents within the affected source for affected sources with

emissions from the collection of non-reactor batch process vents

greater than or equal to 0.23 Mg.

8.6.4 Heat Exchange Systems

A monitoring program to detect leaks from the process into

the cooling water is the proposed standard for heat exchange

systems at both new and existing affected sources. This

monitoring program is the same as the HON program (40 CFR part

63, subpart F).

8.6.5 Wastewater Streams

The proposed standard for wastewater streams at new affected

sources is the HON. No standard is being proposed for existing

affected sources.

8.6.6 Equipment Leaks

The proposed standard for equipment leaks at new and

existing affected sources is based on the HON (40 CFR part 63,

subpart H). Aspects of the proposed standards that are not found

in the HON are: (1) the option to group valves, (2) longer

monitoring frequencies for facilities that demonstrate lower leak

frequencies for valves and connectors, (3) delay of repair of

equipment for which leaks have been detected is also allowed if

the owner or operator determines that repair personnel would be
8-16

exposed to an immediate danger if attempting to repair without a

process shutdown, and (4) closed-vent systems designed to operate

at a pressure below atmospheric pressure may be used to comply.

8.6.7 Alternative Standard

As an alternative to the standards presented above for

storage vessels, continuous process vents, reactor batch process

vents, and non-reactor batch process vents, an owner or operator

may choose to meet an alternative emission limit. Under the

alternative emission limit, vent streams requiring control may be

vented to a control device continuously achieving an outlet

concentration of 20 ppmv of organic HAP. This alternative

emission limit differs from the 20 ppmv alternatives that

accompany the percent reduction requirements for storage vessels

and continuous process vents in that a performance test specific

to an individual emission point is not required. Instead, an

initial demonstration that the control device continuously

achieves an outlet concentration of 20 ppmv of organic HAP is

required. Continuous compliance is demonstrated through

continuous monitoring of the control device outlet concentration.

8.6.8 Compliance and performance test provisions

Compliance and performance test provisions, to include group

determination procedures, contained in the proposed rule are

based on the HON, but there are several important exceptions. 

First, test methods are different because of the specific HAP

emitted by amino/phenolic resin facilities. Second, the specific
8-17

provisions for batch process vents are based on the provisions

from the promulgated Group IV Polymers and Resins NESHAP.

Because of the specific HAP emitted by amino/phenolic resin

facilities, the test methods specified in the HON are not

completely adequate for the proposed rule. Specifically,

formaldehyde is not adequately detected using either Method 18 or

Method 25A of appendix A, 40 CFR part 60. Therefore, the

following test methods have been added specifically for

formaldehyde: Methods 316 and 320. Method 316 is a manual

method that was proposed with the Mineral Wool NESHAP and Method

320 is an FTIR-based method that was proposed with the Portland

Cement NESHAP. Further, Method 18 does not always adequately

detect methanol, and Method 308 has been included as an option

for testing for methanol.

Under the proposed rule, control devices receiving 9.1 Mg/yr

(10 tpy) or less of uncontrolled HAP emissions are not required

to conduct a performance test and instead may perform a design

evaluation to demonstrate compliance with the proposed rule.

Each type of emission point is discussed briefly in the

paragraphs below.

8.6.8.1 Storage Vessels

The proposed standards for storage vessels refer directly to

the HON storage vessel provisions. The group status of storage

vessels is determined based on the storage vessel capacity and

vapor pressure of the stored material. The proposed rule
8-18

includes a table specifying storage vessels that are Group 1 and

therefore require control. There is no requirement for an

emissions test or engineering assessment to determine the group

status of a storage vessel.

Compliance demonstration provisions include periodic visual

inspections of vessels, roof seals, and fittings, as well as

internal inspections.

8.6.8.2 Continuous Process Vents

The proposed standards for continuous process vents refer

directly to the HON process vent provisions. Under the

referenced provisions, an owner or operator is required to either

calculate a TRE index value to determine whether each continuous

process vent is a Group 1 or Group 2 vent, or the owner or

operator can elect to comply with the continuous process vent

control requirements without calculating the TRE index. The TRE

index value is determined after the last recovery device in the

process or prior to venting to the atmosphere. The TRE

calculation involves an emissions test or engineering assessment

and use of the TRE equations in the proposed rule.

Performance test provisions are included for Group 1

continuous process vents to verify that the control device

achieves the required performance.

8.6.8.3 Batch Process Vents

There are no group determination procedures for reactor

batch process vents because all reactor batch process vents are
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subject to control under the proposed rule. For non-reactor

batch process vents, control is required for affected sources

with 0.25 tons per year of uncontrolled emissions from the

collection of non-reactor batch process vents within the affected

source. Procedures for determining uncontrolled emissions from

non-reactor batch process vents are included in the proposed

rule. For those affected sources required to control non-reactor

batch process vents, an owner or operator can choose to not

control some non-reactor batch process vents, as long as

emissions from the collection of non-reactor batch process vents

are reduced by the specified percentage. Performance test

provisions are included to verify the efficiency achieved by the

control device.

Compliance is demonstrated by showing that for the batch

cycle, if an individual reactor batch process vent is being

controlled, or on an overall basis, if non-reactor batch process

vents are being controlled, the specified percent reduction is

achieved. To demonstrate this, an emissions profile must be

developed that identifies each batch emission episode included in

the batch process vent and characterizes emissions from each

batch emission episode on a mass emitted per unit time basis. 

Using this emissions profile, the owner or operator must show

that the periods of under-control and over-control of emissions

balance and the batch cycle percent reduction or the overall

percent reduction is achieved. The proposed rule contains
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procedures for estimating emissions from individual batch

emission episodes, estimating control device efficiency, and for

demonstrating that the required percent reduction is achieved.

Procedures for demonstrating compliance with the alternative

kilogram of HAP per megagram of product emission limit are also

included in the proposed rule.

8.6.8.4 Heat Exchange Systems

There are no performance test requirements for heat exchange

systems. Compliance is demonstrated through the monitoring of

cooling water to detect leaks in heat exchange systems. If a

leak is detected, the heat exchange system must be repaired.

8.6.8.5 Wastewater

The proposed standards for wastewater refer directly to the

HON wastewater provisions. For demonstrating compliance with the

various requirements (i.e., group determinations, demonstrations

of control device performance, or demonstrations of treatment

processes), the proposed rule allows the owners or operators to

either conduct performance tests or to document compliance using

engineering calculations.
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8.6.8.6 Equipment Leaks

The proposed standards for equipment leaks refer directly to

the HON equipment leak provisions. The proposed rule retains the

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

organic vapor analyzer to monitor for leaks from equipment in

use. A "leak" is a concentration specified in the regulation for

the type of equipment being monitored and is based on the

instrument response to methane (the calibration gas) in air. The

observed screening value may require adjustment for response

factor relative to methane if the weighted response factor of the

stream exceeds a specified multiplier. The proposed rule

requires the use of Method 18 to determine the organic content of

a process stream.

8.6.9 Monitoring Requirements

Continuous parameter monitoring is required for control

devices. Exceptions to this are that control devices controlling

less than 1 ton per year of uncontrolled emissions are exempt

from continuous monitoring but must conduct a daily or per batch

demonstration that the control device is operating properly. 

Second, control devices serving storage vessels are not required

to conduct parameter monitoring unless the owner or operator

specifies continuous monitoring in the monitoring plan required

by the referenced HON provisions. However, if a control device

is used, the owners or operator must identify the appropriate

monitoring procedures to be followed for compliance demonstration
8-22

purposes. Further, if a control device serves both a storage

vessel(s) and another emission point subject to the proposed

rule, the control device is subject to continuous parameter

monitoring if the other emission point is subject to continuous

parameter monitoring.

Parameters must be monitored when emissions are vented to

the control device. The proposed rule directly references the

HON monitoring requirements for continuous process vents, storage

vessels, and wastewater. However, there are general monitoring

requirements specified in the proposed rule (e.g., establishment

of parameter monitoring levels) that apply to all emission

points. 

The proposed rule identifies parameters to be monitored for

most control devices expected to be used for emission points

regulated by the proposed rule. Parameter monitoring levels are

established based on design evaluation for control devices with

uncontrolled emissions less than 10 tons per year. For all other

control devices required to conduct continuous parameter

monitoring, parameter monitoring levels are established based on

a performance test, but can be supplemented by manufacturer's

recommendations and/or an engineering assessment. If an owner or

operator chooses to supplement results of the performance test

using manufacturer’s recommendations and/or engineering

assessment, the established parameter monitoring level is subject

to review and approval by the Administrator.
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Parameter monitoring averages are determined based on all

recorded values, except for values recorded under certain

conditions, for example under conditions of start-up, shutdown,

or malfunction. Parameter averages must be daily averages for

control devices serving continuous process vents, waste

management units, storage vessels (if required), or equipment

leaks. Parameter averages may be either batch cycle daily

averages or block averages for batch process vents. Parameter

averages based on batch cycle daily averages cover a 24-hour

period, based on the defined operating day, and may or may not

cover multiple batch cycles for the batch process vent. A batch

cycle daily average may also cover partial batch cycles,

therefore the proposed rule requires that the information

required to calculate parameter monitoring compliance for partial

batch cycles be provided. Parameter averages based on block

averages cover the complete batch cycle, regardless of the length

of time for the batch cycle.

There are two types of violations under the proposed rule;

violations of the operating limit and violations of the emission

limit. Violations of the operating limit occur when not enough

monitoring data are available to constitute a valid days worth of

data or when the average is above the maximum or below the

minimum established value. The proposed rule requires that 75

percent of the possible data points are recorded and are valid

during a day. Violations of the emission limit occur when
8-24

parameter monitoring values that directly reflect the control

device performance, such as condenser outlet temperature or the

use of an organic monitoring device, are above the maximum or

below the minimum established value. Other violations of the

emission limit occur when a control device fails to meet the 20

ppmv alternative standard allowed for continuous process vents,

batch process vents, and storage vessels, or when a control

device fails to meet the kilogram of HAP per megagram of product

emission limits for batch process vents.

Provisions for alternate monitoring parameters are included

in the proposed rule. An owner or operator must apply for

approval to monitor an alternate parameter.

8.6.10 Recordkeeping and Reporting Requirements

The general recordkeeping and reporting requirements of this

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

rule also relies on the provisions of subpart A of 40 CFR part

63. A table included in the proposed rule designates which

sections of subpart A apply to the proposed rule. Specific

recordkeeping and reporting requirements for each type of

emission point are also included in the proposed rule. The

proposed rule references the recordkeeping and reporting

requirements for continuous process vents, storage vessels,

wastewater, and equipment leaks.

The proposed rule requires sources to keep records and

submit reports of information necessary to document compliance. 
8-25

Records must be kept for 5 years. The following reports must be

submitted to the Administrator as appropriate: (1) Precompliance

Report, (2) Notification of Compliance Status, (3) Periodic

Reports, and (4) Other Reports. The requirements for each of the

four reports are summarized below. In addition, sources

complying with the equipment leak requirements contained in

subpart H must follow the recordkeeping and reporting

requirements of subpart H.

8.6.10.1 Precompliance Report The Precompliance Report

would be due no later than 12 months prior to the compliance

date. The Precompliance Report includes the following, as

appropriate: compliance extension requests; requests to monitor

alternative parameters; intent to use alternative controls;

intent to use the alternative continuous monitoring and

recordkeeping allowed by the rule; demonstration that the

emissions estimation equations for batch process vents are not

appropriate; and information related to establishing parameter

monitoring levels, if required.

8.6.10.2 Notification of Compliance Status

The Notification of Compliance Status would be due 150 days

after the affected source's compliance date. It includes the

information necessary to demonstrate that compliance has been

achieved for emission points required to apply controls by the

proposed rule. Such information includes, but is not limited to,

the results of any performance tests; one complete test report
8-26

for each test method used for a particular kind of emission

point; TRE determinations for continuous process vents; design

analyses for storage vessels and wastewater emission points and

for certain batch process vents; and monitored parameter levels

for each emission point and supporting data for the designated

level.

8.6.10.3 Periodic Reports

Generally, Periodic Reports would be submitted semiannually. 

However, there is an exception. The Administrator may request

that the owner or operator submit quarterly reports for certain

emission points that the Administrator identifies. After 1 year,

semiannual reporting can be resumed, unless the Administrator

requests continuation of quarterly reports.

Periodic Reports would include information required to be

reported under the recordkeeping and reporting provisions for

each emission point. For continuously monitored parameters, the

data on those periods when the parameters are above the maximum

or below the minimum established levels are included in the

reports. Periodic Reports would also include results of any

performance tests conducted during the reporting period and

instances when required inspections revealed problems.

8.6.10.4 Other Reports

Other reports required under the proposed rule include: the

notification of inspections required for storage vessels; reports

of changes to the primary product for an APPU or process unit;
8-27

reports of addition of one or more APPUs, addition of one or more

emission points, or change in the group status of emission

points.