# 1 MEMORANDUM

DATE: December 5, 2013

SUBJECT: Technology Review and Estimated Cost Impacts for the Amino/Phenolic Resin

Production Source Category

FROM: Nick Parsons, EPA/OAQPS/SPPD/RCG

TO: EPA Docket File (EPA

- HQ

- OAR

- 2012

– 0133 )

1.0 INTRODUCTION

Section 112 of the Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to

establish technology

- based standards for listed source categor ies as national emissions standards for

hazardous air pollutants (NESHAP). These technology

- based standards are often referred to as

maximum achievable control technology (MACT) standards. The Amino/Phenolic Resin Production

(APR) MACT standards (40 CFR pa rt 63, subpart OOO) apply to major sources of hazardous air

pollutant (HAP) emissions at existing and new facilities that manufacture amino and phenolic resins. For

existing sources, the rule requires the use of MACT to reduce HAP emissions from batch proc ess vents

(reactor and non

- reactor), heat exchange systems, and equipment leaks. 1



# Section 112 also contains provisions requiring the EPA to periodically revisit these standards.

Specifically, section 112(d)(6) states:

(6) REVIEW AND REVISION.

– The Administrator shall review, and revise as necessary

(taking into account developments in practices, processes, and control technologies), emissions

standards promulgated under this section no less often than every 8 years.

To comply with this CAA requirem ent, the EPA conducted a technology review for the APR MACT

standards for major sources. For the purposes of reviewing a MACT standard, the EPA considers a

“development” in practices, processes, and control technologies to be:

• 

# Any add

- on control technolog y or other equipment that was not identified and considered during

development of the original MACT standards.

• 

# Any improvements in add

- on control technology or other equipment (that were identified and

considered during development of the original MACT sta ndards) that could result in additional

emissions reduction.

• 

# Any work practice or operational procedure that was not identified or considered during

development of the original MACT standards.

1 

## The APR MACT standard also provides requirements for continuous process vents and storage vessels for new sources, but

these emissions sources are unregulated at existing sources and are therefore addressed separately under section 112(d)(2)

and (3) of th e CAA.

# 2 • 

# Any process change or pollution prevention alternative that cou ld be broadly applied to the

industry and that was not identified or considered during development of the original MACT

standards.

• 

# Any significant changes in the cost (including cost effectiveness) of applying controls (including

controls the EPA considere d during the development of the original MACT standards).

Section 2 of this memorandum presents background information about the APR source category. Section

3 presents a summary of the sources of data that were used to conduct the technology review. Sect ion 4

presents estimated cost impacts for identified developments in practices, processes, and control

technologies.

2.0 BACKGROUND FOR THE AMINO/PHENOLIC RESINS SOURCE CATEGORY

On December 14, 1998, the EPA proposed the NESHAP for Group III Polymers and Resins:

Amino/Phenolic Resins Production. The EPA promulgated the final APR MACT standards on January

20, 2000, at 40 CFR part 63, subpart OOO. The final rule combined the Amino Resins source category

and Phenolic Resins source category into a single sour ce category. The MACT standards of 40 CFR part

63, subpart OOO are intended to regulate facilities that produce phenol formaldehyde (phenolic),

melamine

- formaldehyde and urea

- formaldehyde resins (amino).

Amino resins are produced through the reaction of f ormaldehyde, or a formaldehyde containing solution

(e.g., aqueous formaldehyde), with compounds that contain the amino group (melamine, urea, and urea

derivatives). Phenolic resins are a condensation product of formaldehyde and phenol, or formaldehyde

or p henol substitutes. 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. Amino and phenolic resin s are produced in similar processes, which

typically use jacketed steel or stainless steel reaction vessels equipped with an agitator and a condenser. 2



# Amino and phenolic resins are used as (or in the manufacture of) coatings, adhesives, modifiers,

enamel s, laminates and binders. The primary feedstock in APR is formaldehyde. The major HAP

emitted by sources covered by the APR MACT standards include formaldehyde, methanol, phenol,

xylene and toluene. The APR MACT standards include a combination of equipment standards, work

practice standards, operational standards and performance standards for each of the emission sources

noted above.

Various other practices, processes, and control technologies were considered in the development of the

APR MACT standards

, which are summarized in Table 1.

At the time of the promulgation of the 1998 MACT rule, it was estimated that 40 facilities in the U.S.

produced APR and were major sources. The EPA has identified 18 currently operating facilities subject

to the APR MACT s tandards.

2 

## Basis and Purpose Document for Proposed Standards: Hazardous Air Pollutant Emissions from the Manufacture of Amino

and Phenolic Resins, EPA/OAQPS. May, 1998.

# 3 Table 1. Summary of Practices, Processes, and Control Technologies Identified and Considered

During APR MACT Standards Development

Emission Source Practices, Processes, and Control Technologies

Storage Vessels Fixed roof, internal floating roof, external floating roof, closed vent

system and control device

Batch and

Continuous

Process Vents Combustion devices, recovery devices, scrubbers/absorbers with

various control efficiencies

Equipment

Leaks Leak detection and repair (LDAR) program, specific equipment

modifications

Heat

Exchangers Work practices specifying monitoring and leak detection/repair

3.0 SOURCES OF AVAILABLE CONTROL TECHNOLOGY INFORMATION

To identify developments in practices, processes and control technologies since the MACT standards

were developed, the following sources of data were consulted:

• The EPA’s RACT/BACT/LAER clearinghouse

• Review of subsequent regulatory development efforts

3.1 RACT/BACT/LAER Clearinghouse Database

Under the EPA's New Source Review (NSR) program, if a company is planning to build a new plant or

modify an existing plant such that criteria air pollution emissions will increase by a certain amount, then

the com pany must obtain an NSR permit. The NSR permit is a construction permit which generally

requires the company to minimize air pollution emissions by changing the process to prevent air

pollution and/or installing air pollution control equipment.

The terms "RACT," "BACT," and "LAER" are acronyms for different program requirements relevant to

the NSR program. RACT, or Reasonably Available Control Technology, is required on sources in areas

that are not meeting national ambient air quality standards (non

- atta inment areas). BACT, or Best

Available Control Technology, is required on new or modified major sources in clean areas (attainment

areas). LAER, or Lowest Achievable Emission Rate, is required on new or modified major sources in

non

- attainment areas.

BAC T and LAER (and sometimes RACT) are determined on a case

- by

- case basis, usually by State or

local permitting agencies. The EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to

provide a central data base of air pollution technology information (in cluding past BACT and LAER

decisions contained in NSR permits) to promote the sharing of information among permitting agencies

and to aid in future case

- by

- case determinations. However, data in the RBLC are not limited to sources

subject to RACT, BACT, and LAER requirements. Noteworthy prevention and control technology

# 4 decisions and information may be included even if they are not related to past RACT, BACT, or LAER

decisions. 3



# The RBLC contains over 5,000 air pollution control permit determinations that c an help identify

appropriate technologies to mitigate most air pollutant emission streams. It was designed to help permit

applicants and reviewers make pollution prevention and control technology decisions for stationary air

pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200

different air pollutants and 1,000 industrial processes.

The RBLC provides several options for searching the permit database on

- line to locate applicable

control technologies. Our search of the RBLC specified all Polymer and Resin Production subcategories

under the Chemicals Manufacturing category, with permits dating back to 2000. The search results

included the following data fields:

• RBLC ID;

• Facility Name, and State;

• Permit Dat e;

• Process name;

• Throughput;

• Pollutant;

• Control technology; and

• Percent efficiency of control.

The results of the search are presented in Attachment 1 for the APR source category. Table 2 presents a

summary of the search results where the facility identified has more stringent requirements than the

APR NESHAP. Because specific emission sources could not be determined from the RBLC search

results, Table 2 shows all control technologies that achieve an efficiency greater than 62 percent, as this

is th e lowest control efficiency required for any emission source (nonreactor batch process vents). The

practices, processes, and control technologies shown in Table 2 are all examples of the types of emission

reduction techniques that were considered in the de velopment of the APR MACT standard. Therefore,

this exercise did not reveal any developments in practices, processes, or control technologies.

3 

## Technology Transfer Network: Clean Air Technology Center. RACT/BACT/LAER Clearinghouse Basic Information.

http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html

.

# 5 Table 2. Control Technologies Identified for APR Processes in the August 23, 2012, Query of the RBLC Database

RBLCID Facility name ST Process Name Control Method %

Efficiency

TX

- 0378 LA PORTE

POLYPROPYLENE

PLANT TX STANDBY

INCINERATOR INICINERATOR

99.99

TX

- 0378 LA PORTE

POLYPROPYLENE

PLANT TX REGENERATIVE GAS

HEATER REG. GAS HEATER

99.99

TX

- 0378 LA PORTE

POLYPROPYLENE

PLANT TX WASTE HEAT BOILER WASTE HEAT BOILER

99.99

OH

- 0256 LIMA CHEMICALS

COMPLEX OH BUTANEDIOL

RECOVERY AND

PURIFICATION PLANT PROCESS FLARE OR

SCRUBBER OFFGAS

INCINERATOR 98

IA

- 0084 ADM POLYMERS IA BIOMASS; POLYMER

DRYERS THERMAL OXIDIZER 98

OH

- 0256 LIMA CHEMICALS

COMPLEX OH BUTANE FEEDSTOCK

SUPPLY FLARE, SCRUBBER OFFGAS

INCINERATOR 98

OH

- 0256 LIMA CHEMICALS

COMPLEX OH MALEIC ACID

HYDROGENATION PLANT PROCESS FLARE OR

HYDROGEN PLANT

REFORMER FURNACE 98

OH

- 0256 LIMA CHEMICALS

COMPLEX OH BUTANEDIOL

RECOVERY AND

PURIFICATION PLANT PROCESS

FLARE SYSTEM OR

SCRUBBER OFFGAS

INCINERATOR 98

PA

- 0212 ROHM & HAAS CO.,

BRISTOL FACILITY PA ACRYLOID COATING

PROCESS REGENERATIVE THERMAL

OXIDIZER 98

SC

- 0051 NATIONAL STARCH &

CHEMICAL

- WOODRUFF FACILITY SC POLYMER AND RESIN

PRODUCTION THERMAL OXIDIZER

98

TX

- 0329 CHEVRON PHILLIPS

HOUSTON CHEMICAL

COMPANY TX (3) FLARES, (5) PE CAT

ACT FAC, (40) PE

PLANTS NONE INDICATED

98

# Table 2 (continued)

6 RBLCID Facility name ST Process Name Control Method %

Efficiency

TX

- 0378 LA PORTE

POLYPROPYLENE

PLANT TX TRAIN NO. 8 FLARE FLARE 98

TX

- 0378 LA PORTE

POLYPROPYLENE

PLANT TX ALKYL FLARE FLARE

98

TX

- 0589 PLASTICS

MANUFACTURING TX High Density Polyethylene

manufacturing Smokeless Flare with liquid

knockout system 98

MI

- 0304 BASF CORPORATION MI BULK LOADING, TDI

& MDI CARBON CANISTER, WITH

MONITORING 97

MI

- 0304 BASF CORPORATION MI TANKS CARBON CANISTER WITH

MONITORING 97

MI

- 0304 BASF CORPORATION MI REACTORS,

ISOCYANATES CARBON CANISTER 97

TX

- 0578 BASF FREEPORT SITE TX Sodium Acrylate polymer

Production Scrubber 95

TX

- 0578 BASF FREEPORT SITE TX Sodium Acrylate polymer

Production Scrubber System 95

NV

- 0043 LASCO BATHWARE NV OPEN MOLDING WITH

EMISSION CONTROL REGENERATIVE THERMAL

OXIDATION AND

ADSORPTION. 95

MS

- 0085 DART CONTAINER

CORPORATION LLC MS CUP

MANUFACTURING

PROCESS BOILERS

95

NV

- 0043 LASCO BATHWARE NV OPEN MOLDING WITH

EMISSION CONTROL REGENERATIVE THERMAL

OXIDATION AND

ADSORPTION. 95

MI

- 0322 FAGERDALA PAC

- LITE

INCORPORATED MI EXPANDABLE

POLYPROPYLENE

BEAD PRODUCTION THERMAL OXIDIZER 85

# 7 3.2 Subsequent Regulatory Development Efforts

The APR MACT standards were promulgated in 2000. Since that time, EPA has developed air

toxics regulations for a number of additional source categories that emit organic HAP from the

same type of emission sources that are present in the APR source category. In subsequent air

toxic regulatory actions, the EPA consistently evaluated any new practices, processes, and

control technologies. A review of these subsequent air toxics regulations, including supporting

documentation used in the rulemakings wa s conducted to determine if any practices, processes or

control technologies could be applied to the APR source category.

The technology review analyses for the National Uniform Emission Standards for Storage

Vessels and Transfer Operations, Equipment Leaks and Control Devices (“Uniform Standards”)

were considered in this review. Although these analyses are not based directly on operations in

the APR source category, they are based on representative chemical manufacturing processes

and refinery processe s with similar types of equipment and emissions sources. Thus, it is

expected that emissions control and compliance demonstration methods that have been

determined to be cost effective for a model chemical manufacturing facility in the Uniform

Standards an alyses could potentially be cost effective for the same regulated material at similar

emission points in the APR source category. No potential developments in practices to control

emissions were identified through the review of the National Uniform Emissio n Standards for

Storage Vessels and Transfer Operations, Equipment Leaks and Control Devices, that could be

applied to the APR source category.

Other MACT standards were examined for practices, processes or control technologies could be

applied to the A PR source category. This exercise revealed potential developments in practices,

processes, or control technologies that could be applied to the APR source category, which are

discussed further in Section 4.

4.0 IDENTIFIED DEVELOPMENTS IN PRACTICES, PROCE SSES AND

CONTROL TECHNOLOGIES AND ESTIMATED COST IMPACTS

For equipment leaks, continuous process vents, batch process vents and heat exchange systems,

beyond what is currently required in the rule or is being proposed, we did not identify : a ny add

on cont rol technology or other equipment that was not identified and considered during MACT

development; any improvements in add

- on control technology or other equipment (that was

identified and considered during MACT development) that could result in significant additional

HAP emission reduction; any work practice or operational procedure that was not identified and

considered during MACT development; any process change or pollution prevention alternative

that could be broadly applied that was not identified and considered during MACT development;

or any significant changes in the cost (including cost effectiveness) of applying controls

(including controls the EPA considered during MACT development). The identified

developments in practices for storage vessel emis sions control are discussed below.

# 8 4.1 Storage Vessels

The amount of HAP emissions from storage vessels depends on the type of organic liquid in the

storage vessel, the type of storage vessel (e.g., tanks open to the atmosphere, fixed roof tanks,

inte rnal floating roof tanks, external floating roof tanks), the methods used to fill and empty the

tank and the number of turnovers per year.

For open tanks, organic emissions result from the volatilization of organic materials placed in the

tank and subsequ ent release of these vapors to the atmosphere. Emissions of organic HAP from

fixed roof tanks and floating roof tanks are the result of working and breathing losses. Working

losses occur when vapors are displaced when the level of liquid in the tank rises. Breathing

losses occur as a result of liquid level changes due to fluctuations in ambient temperature or

pressure. The quantity of emissions from fixed roof tanks depends greatly on the volatility of the

organic material in the tanks and whether the tanks are vented to the atmosphere, equipped with

a pressure

- vacuum relief valves or vented to an air emission control device.

4.1.1 Summary of Existing MACT Level of Control for Storage Vessels

Currently, storage vessels at existing facilities in the APR so urce category are unregulated by the

APR MACT standards. These emissions sources are not being addressed in the technology

review but are being examined separately. The current requirements for storage vessels at new

sources are to maintain and operate eit her an internal or an external floating roof, or use a fixed

roof tank with emissions vented through a closed vent system to any combination of control

devices that achieve a 95 percent emissions reduction or reduce emissions to specified control

device ou tlet concentrations. These requirements apply to storage vessels having a capacity of

50,000 gallons (gal) or greater and a vapor pressure of 2.45 pounds per square inch absolute

(psia) or greater, or a capacity of 90,000 gallons or greater and a vapor pre ssure of 0.15 psia or

greater. Table 3 includes a summary of the tank size and vapor pressure thresholds currently

required for new sources.

4.1.2 Developments in Technology for Storage Vessels

The practices, processes, and control technologies considere d during MACT development for

storage vessels at APR facilities included internal or external floating roofs and fixed roof tanks

with emissions routed to a control device that would reduce emissions by 95 percent or to

specified control device outlet conc entrations. As part of the Uniform Standards development, in

2011, the EPA conducted a general review and analysis of emissions reduction techniques for

storage vessels that have been put in place at chemical production facilities and refineries. 4



# No new developments were identified for storage vessels with fixed roofs and with emissions

routed through a closed vent system to a control device, and it is estimated from available data

that these types of storage vessels comprise the majority, if not all, of the storage vessels meeting

the control thresholds at APR facilities.

4 

## Memorandum from Randall, D., RTI International, to Parsons, N., EPA/OAQPS. Survey of Control Technology

for Stor age Vessels and Analysis of Impacts for Storage Vessel Control Options. January 20, 2012. EPA Docket No.

EPA

- HQ

- OAR

- 2010

- 0871

- 0027.

# 9 Through review of other chemical production MACT standards, it was found that several of

these include the same general control requirements for storage vessels as that of the APR

MACT standards, but that the storage vessels the provisions apply to vary between standards,

depending on the capacity of the tanks and the vapor pressure of the stored material. Based on

this review, we evaluated revising the applicability of the APR new sourc e MACT requirements

to include smaller capacity storage vessels and/or storage vessels containing liquids with lower

vapor pressures (Option 1). Although the standards reviewed required the same emissions

control efficiency (95 percent) it is recognized th at many devices are capable of achieving 98

percent control or greater. Therefore, under Option 2 we considered the impacts of requiring a 98

percent emissions reduction for storage vessels along with the capacity and vapor pressure

thresholds of Option 1. Under Options 1 and 2, we evaluated the impacts of changing the

thresholds at which emissions controls are required to be consistent with other storage vessel

standards already required for the chemical industry regulated by the hazardous organic

NESHAP ( HON). Specifically, as shown in Table 3, under this option, we evaluated requiring

the new source level of emissions control for storage vessels of capacities greater than or equal to

20,000 gal, but less than 40,000 gal if the maximum true vapor pressure (MTVP) is 1.9 psia or

greater, and for storage vessels of capacities greater than or equal to 40,000 gal, but less than

90,000 gal if the MTVP is 0.75 psia or greater. Control would still be required for storage vessels

of 90,000 gal or greater, if the MTV P is 0.15 psia or greater, as currently required for storage

vessels at new sources in the APR source category, but which is not a requirement of the HON.

Since available data for the source category indicate most APR storage vessels have fixed

- roofs,

unde r Option 2, we considered the impacts of requiring a 98 percent emissions reduction for

storage vessels meeting the capacity and vapor pressure thresholds under Option 1, assuming a

regenerative thermal oxidizer would be used to attain this increased level of control. Table 3

presents a summary of the tank size and vapor pressure thresholds considered for new sources.

Table 3. Storage Tank Size and Vapor Pressure Thresholds Considered Under the

Technology Review for New Sources

Option Applicability Threshold

Tank Size

(gallons) Vapor Pressure

@25°C (psia)

Current MACT Requirements 50,000 ≤ capacity ≥ 2.45

90,000 ≤ capacity ≥ 0.15

Options 1 and 2 20,000 ≤ capacity < 40,000 ≥ 1.9

40,000 ≤ capacity < 90,000 ≥ 0.75

90,000 ≤ capacity ≥ 0.15

Table 4 presents the impacts of the options considered for storage vessels at a new source in the

APR source category under the technology review. Since there are currently no new sources in

the APR source category, this analysis was conducted based on a single model APR facility. As

shown in Table 4, for Option 1, we estimated the capital costs to be approximately $11,000, and

the total annualized costs are estimated to be approximately $2,500. The estimated HAP

emissions decrease is approximately 1.1 tp y, and the cost effectiveness is approximately

$2,400/ton. For Option 2, we estimated the capital costs to be approximately $590,000, and the

total annualized costs are estimated to be approximately $171,000. The estimated HAP emissions

# 10 decrease is approxi mately 1.2 tpy, and the incremental cost effectiveness between Option 1 and

Option 2 is approximately $1.4 million/ton.

Table 4. Facility Emissions Reduction and Cost Impacts of Control Options for Storage

Vessels at a Model New APR Facility

Regulatory

a lternatives HAP

emissions

reduction

(tpy) Capital

cost

($) Annual

cost
($/yr) Cost effectiveness

($/ton HAP

removed) Incremental cost

effectiveness

($/ton HAP

removed)

Option 1 1.1 11,000 2,500 2,400

----- Option 2 1.2 590,000 171,000 146,000 1,430,000

# A

- 1 

# Attachment 1:

Results of RBLC Database QueriesRBLCID Facility name ST Permit Date Process Name Through

‐

put Throughput

Units Pollutant Control Method %

Efficiency

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 STANDBY

INCINERATOR Volatile Organic

Compounds (VOC) INICINERATOR 99.99

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 REGENERATIVE GAS

HEATER Volatile Organic

Compounds (VOC) REG. GAS HEATER 99.99

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 WASTE HEAT BOILER Volatile Organic

Compounds (VOC) WASTE HEAT BOILER 99.99

OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 BUTANEDIOL

RECOVERY AND

PURIFICATION 175 MMLB/YR

BUTANEDIOL Hazardous Air

Pollutants (HAP) PLANT PROCESS FLARE OR

SCRUBBER OFFGAS

INCINERATOR 98

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 BIOMASS &

POLYMER DRYERS 90 T/H Volatile Organic

Compounds (VOC) THERMAL OXIDIZER 98

OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 BUTANE FEEDSTOCK

SUPPLY 175 MMLB/YR

BUTANEDIOL Volatile Organic

Compounds (VOC) PLANT PROCESS FLARE

SYSTEM, SCRUBBER

OFFGAS

INCINERATOR 98

OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 MALEIC ACID

HYDROGENATION 175 MMLB/YR

BUTANEDIOL Volatile Organic

Compounds (VOC) PLANT PROCESS FLARE OR

HYDROGEN PLANT

REFORMER FURNACE 98

OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 BUTANEDIOL

RECOVERY AND

PURIFICATION 175 MMLB/YR

BUTANEDIOL Volatile Organic

Compounds (VOC) PLANT PROCESS FLARE

SYSTEM OR SCRUBBER

OFFGAS INCINERATOR 98

PA

‐ 0212 ROHM & HAAS CO.,

BRISTOL FACILITY PA 01/23/2002 ACRYLOID COATING

PROCESS Volatile Organic

Compounds (VOC) REGENERATIVE THERMAL

OXIDIZER 98

SC

‐ 0051 NATIONAL STARCH &

CHEMICAL

‐ WOODRUFF

FACILITY SC 05/15/2000 POLYMER AND RESIN

PRODUCTION Volatile Organic

Compounds (VOC) THERMAL OXIDIZER 98

TX

‐ 0329 CHEVRON PHILLIPS

HOUSTON CHEMICAL

COMPANY TX 02/23/2000 (3) FLARES, (5) PE CAT

ACT FAC, (40) PE

PLANTS Volatile Organic

Compounds (VOC) NONE INDICATED 98

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 TRAIN NO. 8 FLARE Volatile Organic

Compounds (VOC) FLARE 98

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 ALKYL FLARE Volatile Organic

Compounds (VOC) FLARE 98

TX

‐ 0589 PLASTICS

MANUFACTURING TX 01/18/2011 High Density

Polyethylene

manufacturing 5020 LB/H Volatile Organic

Compounds (VOC) Smokeless Flare with liquid

knockout system 98

MI

‐ 0304 BASF CORPORATION MI 10/23/2001 BULK LOADING, TDI

& MDI Methylene diphenyl

diisocyanate CARBON CANISTER, WITH

MONITORING 97

MI

‐ 0304 BASF CORPORATION MI 10/23/2001 TANKS 107800 GALLON Methylene diphenyl

diisocyanate CARBON CANISTER WITH

MONITORING 97

MI

‐ 0304 BASF CORPORATION MI 10/23/2001 REACTORS,

ISOCYANATES 153167 LB Methylene diphenyl

diisocyanate CARBON CANISTER 97

TX

‐ 0578 BASF FREEPORT SITE TX 01/07/2011 Sodium Acrylate

polymer Production 240000 Metric Tons

per year Acrylic Acid Scrubber 95

TX

‐ 0578 BASF FREEPORT SITE TX 01/07/2011 Sodium Acrylate

polymer Production 240000 Metric Tons

per year Isopropyl Alcohol Scrubber System 95

NV

‐ 0043 LASCO BATHWARE NV 10/25/2006 OPEN MOLDING

WITH EMISSION

CONTROL 1290 LB/H Styrene REGENERATIVE THERMAL

OXIDATION. STYRENE

EMISSIONS ARE CAPTURED

WITHIN THE BUILDING BY

THE TWO THE

CONCENTRATORS BY

ADSORPTION, AND THEN

DESORBED BY HEAT AND

INCINERATED BY THE

THERMAL OXIDIZER. 95

MS

‐ 0085 DART CONTAINER

CORPORATION LLC MS 01/31/2007 CUP

MANUFACTURING

PROCESS 5 tons/h Volatile Organic

Compounds (VOC) PENTANE EMISSIONS ARE

GATHERED AND ROUTED

TO BOILERS FOR

DESTRUCTION. 95NV

‐ 0043 LASCO BATHWARE NV 10/25/2006 OPEN MOLDING

WITH EMISSION

CONTROL 1290 LB/H Volatile Organic

Compounds (VOC) REGENERATIVE THERMAL

OXIDATION. VOC

EMISSIONS ARE CAPTURED

WITHIN THE BUILDING BY

THE TWO

CONCENTRATORS BY

ADSORPTION, AND THEN

DESORBED BY HEAT AND

INCINERATED BY THE

THERMAL OXIDIZER. 95

MI

‐ 0322 FAGERDALA PAC

‐ LITE

INCORPORATED MI 02/01/2001 EXPANDABLE

POLYPROPYLENE

BEAD PRODUCTION Volatile Organic

Compounds (VOC) THERMAL OXIDIZER 85

MI

‐ 0322 FAGERDALA PAC

‐ LITE

INCORPORATED MI 02/01/2001 EXTRUSION,

POLYPROPYLENE Volatile Organic

Compounds (VOC) HOODED DIE AREAS

CONTROLLED BY THERMAL

OXIDIZER 37

MI

‐ 0322 FAGERDALA PAC

‐ LITE

INCORPORATED MI 02/01/2001 EXTRUSION,

POLYETHYLENE Volatile Organic

Compounds (VOC) HOODED DIE AREAS

CONTROLLED BY THERMAL

OXIDIZER 12

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 INCINERATOR/SCRUB

BERS Chlorine / Chlorine

Compounds 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 DRYER 1A/B Ethyl Alcohol 0

TX

‐ 0329 CHEVRON PHILLIPS

HOUSTON CHEMICAL

COMPANY TX 02/23/2000 (3) FLARES, (15) PE

PLANTS,

HYDROCARBON

LOAD/UNL Hexene NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 STANDBY

INCINERATOR Hydrochloric Acid NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 WASTE HEAT BOILER Hydrochloric Acid NONE INDICATED 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 INCINERATOR/SCRUB

BERS Hydrochloric Acid 0

MI

‐ 0304 BASF CORPORATION MI 10/23/2001 BLENDING TANKS,

RESIN 262363 LB Hydrochlorofluorocar

bons (HCFC) 4000 T/YR THROUGHPUT

LIMIT 0

MI

‐ 0304 BASF CORPORATION MI 10/23/2001 DRUMMING Methylene diphenyl

diisocyanate THROUGHPUT LIMIT 50000

T/YR, MDI. 0

IL

‐ 0078 OASIS INDUSTRIES INC. IL 04/25/2003 FIBERGLASS RESIN

SPRAY BOOTHS, 4

EACH Styrene 0

NV

‐ 0043 LASCO BATHWARE NV 10/25/2006 FUEL BURNING FOR

THERMOSETTING 6.3 MMBTU/H Styrene N/A 0

MI

‐ 0304 BASF CORPORATION MI 10/23/2001 BLENDING TANKS,

RESIN 262363 LB Triethylamine 3179 LB/MONTH

THROUGHPUT LIMIT 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 INCINERATOR/SCRUB

BERS Vinyl Chloride 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 DRYER 1A/B Vinyl Chloride 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 TRAIN 2 DRYER Vinyl Chloride 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 TRAIN 3 DRYER Vinyl Chloride 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 FURNACE, HOT OIL,

20 MMBTU/H 20 MMBTU/H Volatile Organic

Compounds (VOC) GOOD COMBUSTION

PRACTICES 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 BISPHENOL ACETONE

(BPA) PRODUCTION

UNIT 799 MMLB/YR Volatile Organic

Compounds (VOC) 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 BRINE RECOVERY

UNIT 31 MMLB/YR Volatile Organic

Compounds (VOC) STRIPPER 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 FURNACE, HOT OIL,

10 MMBTU/H 10 MMBTU/H Volatile Organic

Compounds (VOC) GOOD COMBUSTION

PRACTICES 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 RESIN PRODUCTION

UNIT, ABSORBER 920 MMLB/YR Volatile Organic

Compounds (VOC) ABSORBER P84 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 PHOSGENE

PRODUCTION UNIT,

SCRUBBERS 463 MMLB/YR Volatile Organic

Compounds (VOC) SCRUBBERS 1 & 2 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 RESIN PRODUCTION

UNIT, BAGHOUSE 920 MMLB/YR Volatile Organic

Compounds (VOC) 0CA

‐ 1106 JACUZZI WHIRLPOOL BATH CA 10/15/2002 RESIN

MANUFACTURING:

POLYESTER RESIN

OPERATIONS

‐ HAND

AND SPRAY LAYUP 0 EACH BOOTH,

14 W X 1 Volatile Organic

Compounds (VOC) CONCENTRATOR AND

CATALYTIC OXIDIZER 0

CA

‐ 1107 SPARTECH PLASTICS CA 03/24/2000 PLASTIC AND RESIN

EXTRUSION 21.9 MM LB/YR

FOR ONE EXT Volatile Organic

Compounds (VOC) AFTER BURNER 0

CA

‐ 1161 LATEX TECHNOLOGY CA 05/07/2002 FLOW COATER, DIP

TANK AND ROLLER

COATER 48 48L X 18.5 H,

650 GA Volatile Organic

Compounds (VOC) 4,000 SCFM THERMAL

OXIDIZER 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 LAIDIG TANKS 3 T/H Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 POLYMER POWDER

CONVEYING 5 T/H Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 EXTRUDER VACUUM

PUMP 300 ACFM Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 PELLETIZER &

DRYER 3.15 T/H Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 PELLET BLENDING

SILOS 1800 CF Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 PELLET STORAGE BIN 7550 CF Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 LOADOUT SILOS 7550 CF Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 SOLVENT RECOVERY

SYSTEM Volatile Organic

Compounds (VOC) SCRUBBER 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 MAIN FERMENTERS 143700 GAL Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 ANTIFOAM STORAGE

TANK 13000 GAL Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 BDO STORAGE TANK 86000 GAL Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 FIRE PUMP ENGINE 460 HP Volatile Organic

Compounds (VOC) GOOD COMBUSTION

PRACTICES 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 EMERGENCY

GENERATOR 74.3 GAL/H Volatile Organic

Compounds (VOC) GOOD COMBUSTION

PRACTICES 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 SEED FERMENTERS 8100 GAL Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 BROTH HOLDING

TANKS 145000 GAL Volatile Organic

Compounds (VOC) 0

IA

‐ 0084 ADM POLYMERS IA 11/30/2006 LEAKS FROM

EQUIPMENT IN VOC

SERVICE Volatile Organic

Compounds (VOC) LDAR (LEAK DETECTION

AND REPAIR) 0

LA

‐ 0195 LAKE CHARLES FACILITY LA 07/30/2003 DRYING LINES 106000 LB/H Volatile Organic

Compounds (VOC) STEAM STRIPPING OF

SOLVENT FROM CRUMB

RUBBER. EMISSIONS

STREAM FROM STRIPPING

OPERATION IS COLLECTED

AND ROUTED TO FLARE. 0

LA

‐ 0195 LAKE CHARLES FACILITY LA 07/30/2003 PROCESS FUGITIVES Volatile Organic

Compounds (VOC) LDAR PROGRAM

‐ 40 CFR

63 SUBPART I 0

MS

‐ 0085 DART CONTAINER

CORPORATION LLC MS 01/31/2007 NATURAL GAS FIRED

BOILER 33.5 MMBTU/h Volatile Organic

Compounds (VOC) 0

NV

‐ 0043 LASCO BATHWARE NV 10/25/2006 FUEL BURNING FOR

THERMOSETTING 6.3 MMBTU/H Volatile Organic

Compounds (VOC) N/A 0

OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 HYDROGEN SUPPLY

SYSTEM 175 MMLB/YR

BUTANEDIOL Volatile Organic

Compounds (VOC) 0

OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 COOLING TOWER 175 MMLB/YR Volatile Organic

Compounds (VOC) DRIFT ELIMINATORS +

LDAR PROGRAM 0

OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 BUTANEDIOL

PRODUCT STORAGE 175 MMLB/YR

BUTANEDIOL Volatile Organic

Compounds (VOC) FIXED ROOF TANKS,

INTERNAL FLOATING ROOF

TANKS +

USE OF SUBMERGED FILL

AND LDAR PROGRAM. 0

OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 TETRAHYDROFURAN

BY

‐ PRODUCT

STORAGE Volatile Organic

Compounds (VOC) FIXED ROOF TANK WITH

INTERNAL FLOATING ROOF

AND LDAR PROGRAM 0OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 PRODUCT LOADING Volatile Organic

Compounds (VOC) SUBMERGED FILL AND

LDAR PROGRAM 0

OH

‐ 0256 LIMA CHEMICALS

COMPLEX OH 07/10/2003 MALEIC ANHYDRIDE

REACTOR 175 MMLB/YR Volatile Organic

Compounds (VOC) SCRUBBER OFFGAS

INCINERATOR 0

OK

‐ 0112 MUSKOGEE MILL OK 03/27/2006 PAPER MACHINE

COMBUSTION #11

‐ 14 Volatile Organic

Compounds (VOC) EXISTING CONTROL

‐

GOOD COMBUSTION

PRACTICES 0

OK

‐ 0112 MUSKOGEE MILL OK 03/27/2006 PAPER MACHINE Volatile Organic

Compounds (VOC) NEW SUBSTANCE REVIEW 0

OK

‐ 0112 MUSKOGEE MILL OK 03/27/2006 POLYETHYLENE

FLEXOGRAPHIC

PRINTING PRESS #2

‐ 4 Volatile Organic

Compounds (VOC) PERMANENT ENCLOSURE,

RTO 0

OK

‐ 0112 MUSKOGEE MILL OK 03/27/2006 POLYETHYLENE

EXTRUDERS #2

‐ 4 Volatile Organic

Compounds (VOC) 0

OK

‐ 0112 MUSKOGEE MILL OK 03/27/2006 NEW PLATE

WASHER/MAKING Volatile Organic

Compounds (VOC) WASHER INHERENT

DESIGN 0

OK

‐ 0112 MUSKOGEE MILL OK 03/27/2006 PULPING SYSTEM 5 Volatile Organic

Compounds (VOC) EXISTING CONTROL

‐ NO

USE OF CHLORINE OR

CHLORINE DIOXIDE 0

PA

‐ 0168 MARKEL CORPORATION PA 03/22/2000 HORIZONTAL

EXTRUDER 115 F/MIN Volatile Organic

Compounds (VOC) EXHAUST INTO EXISTING

CONTROL EQUIPMENT

(CATALYTIC OXIDIZER) 0

TN

‐ 0145 POLYONE ELASTOMERS

AND PERFORMANCE

ADDITIVES GROUP TN 12/14/2000 RUBBER

COMPOUNDING LINE 15000 LB/H Volatile Organic

Compounds (VOC) VOC CONTENT OF SLURRY

COATING NOT TO EXCEED

20% BY WEIGHT 0

TX

‐ 0278 FORMOSA PLASTICS

CORPORATION TX 01/01/2000 FINAL DEGASSER NO.

1 Volatile Organic

Compounds (VOC) 0

TX

‐ 0278 FORMOSA PLASTICS

CORPORATION TX 01/01/2000 PELLETIZERS NO. 1

& 2 Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0278 FORMOSA PLASTICS

CORPORATION TX 01/01/2000 CATALYST FILLING

VENT NO. 1 Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0278 FORMOSA PLASTICS

CORPORATION TX 01/01/2000 CATALYST FILLING

VENT NO. 2 Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0278 FORMOSA PLASTICS

CORPORATION TX 01/01/2000 PROCESS FUGITIVES Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 (2) PELLET DRYER

EXHAUST Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 COOLING WATER

ADDITIVE TANKS Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 BOILER WATER

ADDITIVE TANKS Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 (2) PELLET REFEED

BIN VENT Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 (2) INLINE BLENDER

VENT FILTER Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 COOLING TOWER Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 PACKAGE BOILER Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 PACKAGE BOILER BO

‐

4 60 MMBTU/H Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 (4) CARLOT SILO

BLENDERS Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 (4) PELLET LINE LOT

BLENDER Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 PELLET OFFSPEC BIN Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 BAGGING BIN VENT

FILTER Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 ALKYL SEAL POT Volatile Organic

Compounds (VOC) NONE INDICATED 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 MONUMENT NO. 2

FLARE Volatile Organic

Compounds (VOC) FLARE 0

TX

‐ 0378 LA PORTE POLYPROPYLENE

PLANT TX 11/05/2001 FUGITIVES Volatile Organic

Compounds (VOC) 28 MID 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 TRAIN 3 DRYER

EMISSIONS Volatile Organic

Compounds (VOC) 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 INCINERATOR/SCRUB

BERS Volatile Organic

Compounds (VOC) 0TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 DRYER 1A/B Volatile Organic

Compounds (VOC) 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 TRAIN 1A/B DRYER

EMISSIONS Volatile Organic

Compounds (VOC) 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 TRAIN 2 DRYER Volatile Organic

Compounds (VOC) 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 TRAIN 3 DRYER Volatile Organic

Compounds (VOC) 0

TX

‐ 0508 FORMOSA SPECIALTY PVC

PLANT TX 04/04/2006 TRAIN 2 DRYER

EMISSIONS Volatile Organic

Compounds (VOC) 0

TX

‐ 0510 OXY VINYLS

COGENERATION UNIT NOS

1 AND 2 TX 02/28/2006 NO. 1/2 HEAT

RECOVERY STEAM

GENERATION STACK Volatile Organic

Compounds (VOC) 0

TX

‐ 0510 OXY VINYLS

COGENERATION UNIT NOS

1 AND 2 TX 02/28/2006 NO. 3 HEAT

RECOVERY STEAM

GENERATION STACK Volatile Organic

Compounds (VOC) 0

# A

- 7 

# Attachment 2:

Analysis of Subsequent Regulations

# A

- 8 Regulatory Actions Where Practices, Processes, and Control Technologies Were Considered for Emission Sources Similar to

Those at APR Sources

Source Category Subpart Date of

Final

Rule Practices, Processes, and Control Techniques Evaluated

MACT Standards

Ethylene Processes YY 7/12/02 combustion devices, recovery devices, LDAR, equipment modifications, floating

roofs, steam stripping, biological treatment

Spandex Production YY 7/12/02 combustion devices, recovery devices,

equipment modifications, floating roofs

Miscellaneous

Organic Chemical

Production and

Processes (MON) FFFF 11/10/03 combustion devices, recovery devices, halogen reduction devices, LDAR,

equipment modifications, pollution prevention, floating roofs, steam stripping,

biological treatment

Area Source Standards

PVC & Copolymer

Production DDDDDD 1/23/07 recovery devices, steam stripping

Acrylic

Fibers/Modacrylic

Fibers LLLLLL 7/16/07 scrubbers, floating roofs, combustion devices, recovery devices, steam stripping,

biological treatment, LDAR, equipment modifications, pollution prevention

Chemical

Manufacturing VVVVVV 10/29/09 combustion devices, recovery devices, LDAR, equipment modifications, floating

roofs, steam stripping, biological treatment

Chemical

Preparations BBBBBBB 12/30/09 scrubbers, LDAR

# A

- 9 Residual Risk Standards

Hazardous Organic

NESHAP (HON) F, G, H 12/21/06 No significant development in practices,

processes or control technologies since promulgation of the MACT standards

Pharmaceuticals GGG 4/21/11 No significant development in practices,

processes or control technologies since promulgation of the MACT standards

Polymers and

Resins I U 4/21/11 No significant development in practices,

processes or control technologies since promulgation of the MACT standards

Hydrogen Fluoride YY 12/16/08 No significant development in practices,

processes or control technologies since promulgation of the MACT standards

Acetal Resins YY 12/16/08 No significant development in practices,

processes or control technologies since promulgation of the MACT standards