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Memorandum

Subject: Technical Support Document: Information to Support New Source 

Performance Standards Advanced Notice of Proposed Rulemaking

From: Ms. Janice Godfrey, Policy and Strategies Group, OAQPS/SPPD

To: New Source Performance Standards Project Docket

Date: July 6, 2011

INTRODUCTION

This technical support document (TSD) provides additional information to accompany

the Advanced Notice of Proposed Rulemaking (ANPR) (76 FR 65653, Monday, October 24, 2011)

which requests public comment on EPA’s New Source Performance Standards (NSPS) 

Management Strategy. The intent of the NSPS Management Strategy is to comply with EPA’s 

statutory requirement to review and revise NSPS while focusing attention on those NSPS that 

have the potential for significant net positive environmental benefits. One of the strategies to 

achieve this goal is to prioritize the evaluation of NSPS which will result in net environmental 

benefits by identifying NSPS that remain effective, and thus do not need to be reviewed. 

The ANPR identifies three criteria which EPA believes are appropriate for consideration

in making a determination that a review of an existing NSPS would not result in any 

environmental benefit. These criteria are discussed in more detail in the ANPR, but may be 

summarized as follows:

1) The application of the best system of emission reduction from the current NSPS 

remains appropriate. (e.g., review of the NSPS would not result in a more stringent 

emissions limit through technology improvements.)

2) There is no anticipated applicability of the NSPS during the current review cycle. 

(e.g., no anticipated new, modified, or reconstructed sources are expected to trigger 

applicability under the NSPS over the next 8 years)
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3) There is another regulatory program which has rules in place that are applicable to 

the same pollutants and emission sources as the NSPS, with equivalent or greater 

stringency. (e.g., review of the NSPS would not result in more stringent emissions 

limits than another existing CAA requirement.)

Table 1 below (A copy of Table 2 from the ANPR) lists NSPS standards for which EPA 

believes the current NSPS sufficiently addresses pollutants of concern and thus remains

effective, and for which EPA believes revision of such NSPS will not provide net environmental 

benefits. The table also indicates which of the three criteria described above apply to each of 

the listed NSPS. 

The following section of this document provides brief summaries of the manner in 

which EPA believes the identified criteria establish that no revisions are required for each of 

these candidates, including citations for the NSPS and any other referenced rules. Attachment 1 

includes detailed assessments of these criteria for the three NSPS categories described in 

Section III.B.4 of the ANPR, Primary Zinc Production, Magnetic Tape Production, and Publication 

Rotogravure Printing.

Table 1: NSPS potentially meeting criteria to not be reviewed based on CAA 111(b) (1) (B) authority

Subpart NSPS 

No Review Criterion

BDT from 

current 

standard 

remains 

appropriate

No expected 

applicability 

of NSPS (No 

new/modified/ 

reconstructed

sources)

Equivalent/more 

stringent 

requirements in 

Other CAA 

actions

P Primary Copper 

Smelters x x x

Q Primary Zinc 

Smelters

x x x

T Phosphate Fertilizers 

- Wet-Process 

Phosphoric Acid 

Plants

x
Page 

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U Phosphate Fertilizers - Superphosphoric 

Acid Plants

x

V Phosphate Fertilizers - Diammonium 

Phosphate Plants

x

W Phosphate Fertilizers - Triple 

Superphosphate 

Plants

xx

X Phosphate Fertilizers - Granular Triple 

Superphosphate 

Storage Facilities

xx

EE Metal Furniture 

Surface Coating

x

MM Auto/Light Duty Truck 

Surface Coating

x

NN Phosphate Rock 

Plants

xx

QQ Graphic Arts 

Industry/Publication 

Rotogravure Printing

x

BBB Rubber Tire 

Manufacturing

x

HHH Synthetic Fibers

x

SSS Magnetic Tape 

Coating Facilities

x
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SUMMARY INFORMATION SUPPORTING THE APPLICATION OF CRITERIA FOR 

SELECTION OF NSPS AS POTENTIAL CANDIDATES FOR NO REVISION

Primary Copper Smelters1

An evaluation of currently available information indicates that the Administrator need 

not review the NSPS for Primary Copper Smelters affected facilities at this time. The primary 

reason is that a review of the currently available technologies would not result in a more 

stringent level of control. The best system of emission reduction for controlling sulfur dioxide 

(SO2) emissions from roasters, smelting furnaces, and copper converters at primary copper 

production facilities is a double-absorption sulfuric acid plant. This technology is still commonly 

employed to control SO2 emissions in the primary copper industry and other primary metals 

industries.

Additionally, there is no anticipated applicability of the NSPS during the current review 

cycle, because no new or modified affected facilities subject to the NSPS are expected in the 

next 8 years. This is primarily as a result of changes in the types of processes typically used by 

the industry, and closure of U.S. copper smelting facilities due to foreign competition. 

Finally, another regulatory program has rules in place that EPA believes are applicable to 

the same pollutants and emission sources as the NSPS, such that a revision of the NSPS would 

result in NSPS requirements of equal or lesser stringency. The controls and emission limits 

specified in the NESHAP for Primary Copper Smelting2and the Area Source NESHAP for Primary 

Copper Smelting 3result in emissions reductions that meet or exceed those which would be 

required by a reviewed and subsequently revised NSPS.

Primary Zinc Smelters4

An evaluation of currently available information indicates that the Administrator need 

not review at this time the NSPS for Primary Zinc Smelters, which lists roasters and sintering 

operations as the affected facilities. The primary reason for this recommendation is that EPA 

believes a review of the currently available technologies would not result in any increased 

stringency for emission limits. BDT for controlling sulfur dioxide (SO2) emissions from roasters 

at primary zinc production facilities is still employed to control SO2 emissions in the primary zinc 

industry and other primary metals industries. 

 

1

40 CFR Part 60 - Subpart P, 40 CFR 60.160 [41 FR 2338, Jan. 15, 1976]

2

40 CFR Part 63 - Subpart QQQ, 40 CFR 63.1440 [67 FR 40478, Wednesday June 12, 2002]

3

40 CFR Part 63 - Subpart EEEEEE, 40 CFR 63.11146 [72 FR 2929, Tuesday, Jan 23, 2007]

4

40 CFR 60 Subpart Q, 40 CFR 60.170 [41 FR 2340, Jan. 15, 1976]
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Additionally, there is no anticipated applicability of the NSPS during the current review 

cycle, because no new or modified affected facilities that would be subject to the NSPS are 

expected in the next 8 years. This is primarily as a result of changes in the types of processes 

typically used by the industry, and an overall decline in the number of operational facilities in 

recent decades. 

Finally, under section 112 of the CAA, requirements are in place which would apply to 

any new or modified facility with provisions which are effectively at least as stringent as what 

would likely be considered BDT under an NSPS BDT review. The controls and emissions limits 

specified in the NESHAP for Primary Nonferrous Metals Area Sources - Zinc, Cadmium, and 

Beryllium5result in reductions of SO2 and PM that meet or exceed those which would be 

required by a reviewed and subsequently revised NSPS.

Phosphate Fertilizers - Wet-Process Phosphoric Acid Plants6

An evaluation of currently available information indicates that the Administrator need 

not revise the NSPS for Phosphate Fertilizers - Wet-Process Phosphoric Acid affected facilities at 

this time. Another regulatory program has rules in place that EPA believes are applicable to the 

same pollutants and emission sources as the NSPS, such that a revision of the NSPS would 

result in NSPS requirements of equal or lesser stringency. The controls and emission limits 

specified in the NESHAP for Phosphoric Acid Manufacturing Plants7and the NESHAP for 

Phosphate Fertilizers Production Plants8result in emissions reductions that meet or exceed 

those which would be required by a revised NSPS. We anticipate new sources in this industry 

and we expect this particular production process to dominate the Phosphate Fertilizer 

production industry.

Phosphate Fertilizers - Superphosphoric Acid Plants9

An evaluation of currently available information indicates that the Administrator need 

not revise the NSPS for Phosphate Fertilizers - Superphosphoric Acid affected facilities at this 

time. Another regulatory program has rules in place that EPA believes are applicable to the 

same pollutants and emission sources as the NSPS, such that a revision of the NSPS would 

result in NSPS requirements of equal or lesser stringency. The controls and emission limits 

 

5

40 CFR 63 Subpart GGGGGG, 40 CFR 63.1440 [72 FR 2930, Tuesday, January 23, 2007]

6

40 CFR Part 60 - Subpart T, 40 CFR 60.200 [42 FR 37937, July 25, 1977]

7

40 CFR Part 63 - Subpart AA, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]

8

40 CFR Part 63 - Subpart BB, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]

9

40 CFR Part 60 - Subpart U, 40 CFR 60.210 [42 FR 37937, July 25, 1977]
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specified in the NESHAP for Phosphoric Acid Manufacturing Plants10 and the NESHAP for 

Phosphate Fertilizers Production Plants11 result in emissions reductions that meet or exceed 

those which would be required by a revised NSPS. We anticipate new sources in this industry 

and think it is likely that the at least two new sources using this particular production process 

will start up within the next 8 years. 

Phosphate Fertilizers - Diammonium Phosphate Plants12

An evaluation of currently available information indicates that the Administrator need 

not revise the NSPS for Phosphate Fertilizers - Diammonium Phosphate (DAP) affected facilities 

at this time. Another regulatory program has rules in place that EPA believes are applicable to 

the same pollutants and emission sources as the NSPS, such that a revision of the NSPS would 

result in NSPS requirements of equal or lesser stringency. The controls and emission limits 

specified in the NESHAP for Phosphoric Acid Manufacturing Plants13 and the NESHAP for 

Phosphate Fertilizers Production Plants14 result in emissions reductions that meet or exceed 

those which would be required by a revised NSPS. Because DAP is produced from wet-process 

phosphoric acid plants, we anticipate new sources in this industry and we expect this particular 

production process to dominate the Phosphate Fertilizer production industry.

Phosphate Fertilizers - Triple Superphosphate Plants15

An evaluation of currently available information indicates that the Administrator need 

not review the NSPS for Phosphate Fertilizers - Triple Superphosphate facilities at this time. 

Another regulatory program has rules in place that EPA believes are applicable to the same 

pollutants and emission sources as the NSPS, such that a revision of the NSPS would result in 

NSPS requirements of equal or lesser stringency. The controls and emission limits specified in

the NESHAP for Phosphoric Acid Manufacturing Plants16 and the NESHAP for Phosphate 

Fertilizers Production Plants17 result in emissions reductions that meet or exceed those which 

would be required by a revised NSPS. Furthermore, triple superphosphate is used to produce 

Granular Triple Superphosphate (GTSP), discussed below. Because demand for GTSP has 

ceased, the production of triple superphosphate has likewise ceased. We do not anticipate 

new sources in this source category within the next 8 years. 

 

10 40 CFR Part 63 - Subpart AA, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]

11 40 CFR Part 63 - Subpart BB, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]

12 40 CFR Part 60 - Subpart V, 40 CFR 60.220 [42 FR 37938, July 25, 1977]

13 40 CFR Part 63 - Subpart AA, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]

14 40 CFR Part 63 - Subpart BB, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]

15 40 CFR Part 60 - Subpart W, 40 CFR 60.230 [42 FR 37938, July 25, 1977]

16 40 CFR Part 63 - Subpart AA, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]

17 40 CFR Part 63 - Subpart BB, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]
Page 7 of 20

Phosphate Fertilizers - Granular Triple Superphosphate Plants18

An evaluation of currently available information indicates that the Administrator need 

not revise the NSPS for Phosphate Fertilizers - Granular Triple Superphosphate affected 

facilities at this time. Another regulatory program has rules in place that EPA believes are 

applicable to the same pollutants and emission sources as the NSPS, such that a revision of the 

NSPS would result in NSPS requirements of equal or lesser stringency. The controls and 

emission limits specified in the NESHAP for Phosphoric Acid Manufacturing Plants19 and the 

NESHAP for Phosphate Fertilizers Production Plants20 result in emissions reductions that meet 

or exceed those which would be required by a revised NSPS. Additionally, demand for and 

production of GTSP have ceased over the last 20 years. We therefore anticipate no new 

sources in this industry over the next 8 years.

Metal Furniture Surface Coating21

An evaluation of currently available information indicates that the Administrator need 

not revise the NSPS for Metal Furniture Surface Coating Facilities at this time because there is 

no anticipated applicability for the NSPS for Metal Furniture Surface Coating Facilities during 

the current review cycle. This is primarily due to the continual decline of the industry over the 

last decade, largely as a result of increased foreign production. As a result, there is no growth 

anticipated in the industry over the next 8 years, and there are no anticipated reconstruction or 

modification events which would trigger NSPS applicability.

Auto/Light Duty Truck Surface Coating22

An evaluation of currently available information indicates that the Administrator need 

not review the NSPS for Auto/Light Duty Truck Surface Coating affected facilities at this time. 

Another regulatory program has rules in place which EPA believes would apply to any new or 

modified facility with provisions which, while they do not provide a one-to one matching with 

those of the NSPS, are effectively at least as stringent as what would likely be considered BDT 

under an NSPS BDT review. The controls and emission limits specified in the NESHAP for 

Surface Coating of Automobiles and Light-Duty Trucks23 result in emissions reductions that 

meet or exceed those which would be required by a revised NSPS.

 

18 40 CFR Part 60 - Subpart X, 40 CFR 60.240 [42 FR 37938, July 25, 1977]

19 40 CFR Part 63 - Subpart AA, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]

20 40 CFR Part 63 - Subpart BB, 40 CFR 63.620 [64 FR 31358, Thursday, June 10, 1999]

21 40 CFR Part 60 - Subpart EE, 40 CFR 60.310 [47 FR 49287, Oct. 29, 1982]

22 40 CFR Part 60 - Subpart MM, 40 CFR 60.390 [45 FR 85415, Dec. 24, 1980]

23 40 CFR Part 63 - Subpart IIII, 40 CFR 63.3080 [69 FR 22601, Monday, April 26, 2004]
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Phosphate Rock Plants24 

An evaluation of currently available information indicates that there is no need at this 

time for revision of the NSPS for Phosphate Rock Plants consisting of dryers, calciners, grinders, 

and handling and storage facilities affected facilities. The primary reason is that a review of the 

currently available technologies would not result in a more stringent level of control. A second 

reason is that no new or modified affected facilities are expected in the next 8 years due to 

continual decline in the industry over the last 20 years with no indication of a future reversal of 

this trend. 

Graphic Arts Industry/Publication Rotogravure Printing25

An evaluation of currently available information indicates that the Administrator need 

not revise the NSPS for Graphic Arts Industry/Publication Rotogravure Printing at this time. 

Another regulatory program has rules in place that EPA believes are applicable to the same 

pollutants and emission sources as the NSPS, such that a revision of the NSPS would result in 

NSPS requirements of equal or lesser stringency. The controls and emission limits specified in 

the NESHAP for Printing and Publishing26 is significantly more stringent than the NSPS under 

subpart QQ.

Rubber Tire Manufacturing27

An evaluation of currently available information indicates that the Administrator need 

not revise the NSPS for Rubber Tire Manufacturing affected facilities at this time. Another 

regulatory program has rules in place which EPA believes would apply to any new or modified 

facility with provisions which are effectively at least as stringent as what would likely be 

considered BDT under an NSPS BDT review. The controls and emission limits specified in the 

NESHAP for Tire Manufacturing28 likely result in emissions reductions that meet or exceed 

those which would be required by a reviewed and subsequently revised NSPS.

Synthetic Fiber Production Facilities29

An evaluation of currently available information indicates that the Administrator need 

not revise the NSPS for Synthetic Fiber Production facilities at this time. The primary reason is 

that EPA believes that a review of the currently available technologies would not result in any 

 

24 40 CFR Part 60 – Subpart NN, 40 CFR 60.400 [47 FR 16589, Apr. 16, 1982]

25 40 CFR Part 60 - Subpart QQ, 40 CFR 60.430 [47 FR 50649, Nov. 8, 1982]

26 40 CFR Part 63 - Subpart KK, 40 CFR 63.820 [61 FR 27140, May 30, 1996]

27 40 CFR Part 60 - Subpart BBB, 40 CFR 60.540 [52 FR 34874, Sept. 15, 1987]

28 40 CFR Part 63 - Subpart XXXX, 40 CFR 63.5980 [67 FR 45598, Tuesday, July 9, 2002]

29 40 CFR Part 60 - Subpart HHH, 40 CFR 60.600 [49 FR 13651, Apr. 5, 1984]
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increased stringency for emission limits, since EPA is unaware of any new emission control 

technologies for the industry. 

Magnetic Tape Production30 

An evaluation of currently available information indicates that the Administrator need 

not revise the NSPS for Magnetic Tape Coating Facilities at this time because there is no 

anticipated applicability for the NSPS for Magnetic Tape Coating Facilities during the current 

review cycle. This is primarily due to the continual decline of the industry over the past 20 years 

resulting from foreign competition and changes in the marketplace since the emergence of 

alternative technologies (e.g., optical recording media.) As a result, there is no growth 

anticipated in the industry over the next 8 years, and there are no anticipated reconstruction or 

modification events which would trigger NSPS applicability.

 

30 40 CFR 60 Subpart SSS, 40 CFR 60.710 [53 FR 38914, Oct. 3, 1988]
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ATTACHMENT 1 

Detailed Assessments of NSPS Categories Described in ANPR:

Primary Zinc Smelters (40 CFR Part 60, Subpart Q),

Magnetic Tape Production (40 CFR Part 60, Subpart SSS)

Graphic Arts Industry/Publication Rotogravure Printing (40 CFR Part 60, Subpart QQ)
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Primary Zinc Smelters (40 CFR Part 60, Subpart Q)

An evaluation of currently available information indicates that there is no need at this 

time for revision of the NSPS for Primary Zinc Smelters consisting of roaster and sintering 

operation affected facilities. The primary reason is that a review of the currently available 

technologies would not result in a more stringent level of control. A second reason is that no 

new or modified affected facilities are expected in the next 8 years due to changes in the types 

of processes typically used. Finally, another Clean Air Act (CAA) requirement would apply to any 

new or modified facility with provisions which are effectively at least as stringent as what would 

likely be considered Best Demonstrated Technology (BDT) under an NSPS BDT review. 

We believe that a review of the currently available technologies would not result in a 

more stringent level of control for the two processes controlled under the NSPS: roasters and 

sintering machines. The Background Information Document (BID) for the Primary Zinc 

Production NSPS31 contains EPA’s determination that BDT for controlling sulfur dioxide (SO2) 

emissions from roasters at primary zinc production facilities is a double-absorption sulfuric acid 

plant. This technology is still commonly employed to control SO2 emissions in the primary zinc 

industry and other primary metals industries. Average daily conversion rates of at least 99.7 –

99.9 % are achievable with the double contact process.32 We have not identified any other 

control technology that could achieve greater reductions, and we believe that a new BDT 

determination would not result in any change in the current level of control. 

The same BID described BDT for sintering machines as fabric filter control for particulate 

matter (PM) emissions. This technology, which can achieve emission reductions up to 99 %, still 

represents the most effective technology to capture these emissions. Therefore, we believe 

that a new BDT determination would not result in any change in the current level of control.

Changes in industry structure support a finding that there will be no new primary zinc 

production facilities in the U.S. in the next 8 years. World-wide, 70 percent of the zinc produced 

comes from mined ores and 30 percent from recycled or secondary zinc. The level of recycling is 

increasing each year, and over 80 percent of the zinc available for recycling is actually 

recycled.33 Twelve companies recycle zinc in the U.S., primarily in the form of electric arc 

furnace (EAF) dust, which is a hazardous waste produced by the steel mini-mill manufacturing 

 

31 Background Information for New Source Performance Standards: Primary Copper, Zinc, and Lead Smelters, 

EPA-450/2-74-002a, October 1974.

32 Integrated Pollution Prevention and Control Reference Document on Best Available Techniques for the 

Manufacture of Large Volume Inorganic Chemicals - Ammonia, Acids and Fertilisers, August 2007.

33 International Zinc Association, Zinc Recycling. Downloaded on 11/10/08 from 

http://www.iza.com/recycling.html.
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process.34 These recycling processes do not use a roaster, which is the primary source of 

emissions from a primary zinc smelting operation. 

The second affected facility in the NSPS is the sintering operation, which is subject to a 

PM emission limit and a visible emissions limit (opacity). Sintering only takes place at one of the 

two available processes for converting zinc sulfide concentrate to zinc metal. At present, there 

are no U.S. operations that use this process. It is unlikely that any sources would install such a 

process in the future. According to an overview of zinc smelting, the vast majority of zinc 

smelting plants in the western world use the electrolytic process (vs. sintering and retorting in 

the pyrometallurgical process alternative) because it is more energy efficient, has higher 

recovery rates, and is easier to automate, which improves productivity.35

Data from the US Geological Survey (USGS) 36 and EPA1show that the primary zinc 

industry has been in decline for over a decade. In 1974, when the NSPS was under 

development, there were eight primary zinc production facilities in the US. There were four 

primary zinc production facilities listed in the 1994 USGS Minerals Yearbook, and by 2007 only 

one was operational, the Nyrstar Clarkesville, TN refinery37. A second former primary producer, 

Horsehead Holding Corporation’s Monaca, PA plant, has converted its production facilities to 

secondary production only.38 According to the company website of a third former primary 

producer (Big River Zinc) in Illinois, there are plans to restart a suspended smelter operation in 

Illinois, but no details on timing are available. Instead, the company is focusing on converting 

the existing electrolytic operation to wash impure concentrates produced by a recycling plant in 

Ohio.39 Because any future use of the Illinois site as primary production facility would take 

place on an existing site, we do not believe it would trigger NSPS applicability. Because of this, 

we believe that no new or modified primary zinc smelter is expected to be constructed using 

existing technology in the next 8 years. 

 

34 Company profile of Horsehead Holding Corp. EAF recycling operations. Downloaded on 11/10/08 from 

http://www.reuters.com/finance/stocks/companyProfile?rpc=66&symbol=ZINC.O.

35 Zinc Smelting Process overview. Downloaded 11/10/08 from 

http://www.nyrstar.com/nyrstar/en/products/productionprocess/.

36 USGS Zinc Statistics and Information taken from http://minerals.usgs.gov/minerals/pubs/commodity/zinc/ 

Specific documents used include the Mineral Commodity Summaries (1996-2008), and the Minerals Yearbooks 

(1994-2006).

37 Jeryl Stewart of the TN Dept. of Environment & Conservation reports that the Clarkesville plant is subject to the 

NSPS, and is in fact the only primary zinc facility that has ever been subject to NSPS, since all the others were 

constructed prior to promulgation of the NSPS. Contact report, EC/R conversation with Mr. Jeryl Stewart of TN 

DE&C 11/18/08.

38 Horsehead Corporation website. Downloaded on 11/10/08 from http://www.horsehead.net.

39 ZincOx Resources plc website, parent company of Big River Zinc. Downloaded on 11/6/08 from 

http://www.zincox.com/pages/recycling/big_river.htm.
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Furthermore, there is another applicable CAA regulation whose requirements are at 

least as stringent as what would likely be considered BDT under an NSPS BDT review. As 

described below, the controls employed to comply with requirements of the NSPS for Primary 

Zinc Smelters and the NESHAP for Primary Nonferrous Metals Area Sources - Zinc, Cadmium, 

and Beryllium (40 CFR Part 63, Subpart GGGGGG)

40 are effectively the same. Table 1 

summarizes the requirements of the two rules. 

Control of emissions of SO2 and visible emissions (required by the NSPS) and air toxics 

PM (required by the NESHAP) from roasters are both achieved at all currently existing facilities 

by venting the emissions to a sulfuric acid plant. Under the NSPS, roasters are subject to SO2

emission limits. Meeting those limits requires the source to duct roaster emissions to a sulfuric 

acid plant to reduce SO2 emissions. In order for the sulfuric acid plant to operate properly, the 

roaster exhaust must first be cleaned of PM. The area source NESHAP codifies this step in the 

process by requiring a PM control device, with the goal of achieving control of air toxics PM. 

However, the NESHAP also specifically requires that off-gases from each roaster are vented to a 

sulfuric acid plant, including during the charging of the roaster. Thus, although the NESHAP has 

no specific emission limit for SO2, it effectively requires the same level of control as the NSPS. 

The preamble to the proposal of the Primary Nonferrous Metals Area Source NESHAP10, 

describes the effectiveness of the controls as follows: 

“While the sulfuric acid plants were originally installed to recover sulfuric acid as a byproduct and to control SO2 emissions, the inherent design and operating requirements 

of these plants also provide effective control of PM and metal HAP contained in roaster 

offgases. The sulfuric acid production process involves the catalytic conversion of the 

SO2 contained in the off-gases to produce liquid sulfuric acid. To optimize the process 

performance and prevent extensive damage to the catalysts and other critical process 

equipment, the first step of the process requires that the roaster off-gases be 

precleaned and conditioned. These operations involve first passing the gas stream 

through multiple control devices for the removal of PM and to reduce gas stream 

temperature. By using multiple PM control devices in series (multicyclones, electrostatic 

precipitators, and venturi scrubbers) to treat roaster exhaust gases before entering the 

sulfuric acid plant, very high overall PM and metal HAP removal efficiencies are 

achieved. Consequently, there is little or no PM or metal HAP emitted in the tail gas 

from the sulfuric acid plant.” 

 

40 40 CFR 63 Subpart GGGGGG, proposed October 6, 2006 and promulgated Jan 23, 2007
Page 14 of 20

“Because rigorous treatment of the roaster off-gases to remove PM and metal HAP is a 

necessary operating condition for the sulfuric acid plant, requiring that cleaned gases be 

vented to a sulfuric acid plant ensures that emissions of HAP metals are either 

nonexistent or limited to trace amounts.”

Although the NESHAP does not include any limitation on visible emissions (opacity) from 

the outlet of the acid plant (as the NSPS does), any new facilities would still be subject to the 

opacity limits imposed by the NSPS. 

Emissions from the second affected facility referenced in the NSPS, sintering machines, 

are addressed under the NESHAP through a direct reference to the existing NSPS provisions. As 

described above, sintering machines (and the pyrometallurgical process for primary zinc 

smelting) are no longer employed at any currently operational primary zinc facilities. Because 

the pyrometallurgical process is less energy efficient, has lower recovery rates, and is more 

difficult to automate, we do not believe that it is likely to be employed at any existing or new 

facilities. Because of this, and because currently available information does not indicate any 

improvements in technology which might affect emissions from this source type, we believe 

that the currently existing BDT for sintering machines at primary zinc facilities is unlikely to 

change.

Taking these factors into account, we believe that the design imperatives of the sulfuric 

acid plant combined with the NESHAP requirements will result in the installation of controls 

equivalent to BDT under the NSPS at any new primary zinc facility, were one to be constructed. 
Page 15 of 20

Table 1: Comparison of Requirements: The Primary Zinc NSPS (Part 60, Subpart Q) and 

the Primary Nonferrous Metals Area Source NESHAP (Part 63, Subpart GGGGGG)

Emission 

Source Pollutant NSPS Requirement NESHAP Requirement

Roaster SO2 0.065 % by volume. 

Sources meet this 

limit by cleaning the 

roaster exhaust 

using PM controls 

and then ducting 

emissions to a 

sulfuric acid plant. 

The NESHAP does not address SO2 emissions or 

sulfuric acid mist because they are not HAP. 

However, it does require existing and new 

sources to exhaust the off-gases from each 

roaster to a sulfuric acid plant, including during 

the charging of the roaster. Although there is 

no numeric emission limit specified, the 

effective level of control achieved is equivalent.

PM The NSPS does not 

directly address PM. 

However, in order to 

meet the SO2 

standard, sources 

must clean the 

roaster exhaust to 

avoid fouling the 

catalyst in the acid 

plant.

Existing and new sources must exhaust the offgases from each roaster to a PM control device, 

including during the charging of the roaster. 

Because rigorous treatment of the roaster offgases to remove PM and metal HAP is a 

necessary operating condition for the sulfuric 

acid plant, requiring that cleaned gases be 

vented to a sulfuric acid plant ensures that 

emissions of HAP metals are either nonexistent 

or limited to trace amounts. 

Opacity 20 % opacity (acid 

mist) from the 

sulfuric acid plant.

The NESHAP does not address sulfuric acid mist 

because it is not a HAP.
Page 16 of 20

Emission 

Source Pollutant NSPS Requirement NESHAP Requirement

Furnaces PM (No NSPS 

requirement for this 

emission source.)

(1) PM Emissions limits: 

Existing Sources 

(a) .93 lbs/hr. from the exhaust vent of a zinc 

cathode melting furnace; 

(b) 0.1 lb/hr from the exhaust vent of a furnace 

that melts zinc dust, zinc chips, and/or other 

materials containing zinc; 

(c) 0.228 lb/hr from the vent for the combined 

exhaust from a furnace melting zinc scrap and 

an alloy furnace; 

(d) 0.014 gr/dscf from the exhaust vent of an 

anode casting furnace; 

(e) 0.015 gr/dscf from the exhaust vent of a 

cadmium melting furnace; and 

(f) 0.005 gr/dscf as an alternative to the limits 

in lb/hr in (a)-(c); New Sources 

(a) 0.005 gr/dscf from the exhaust vent of a 

zinc cathode and melting furnace, furnace 

melting zinc dust, zinc chips, and/or other 

materials containing zinc, and alloy melting 

furnace; (b) 

0.014 gr/dscf from the exhaust of an anode 

casting furnace; and 

(c) 0.015 gr/dscf from the exhaust vent of a 

cadmium melting furnace; 

(2) Operating Parameters and Monitoring: 

Existing and new sources must establish and 

comply with operating parameters and 

monitoring requirements
Page 17 of 20

Emission 

Source Pollutant NSPS Requirement NESHAP Requirement

Sintering 

Machine

SO2 Any sintering 

machine which 

eliminates more 

than 10 percent of 

the sulfur initially 

contained in the zinc 

sulfide ore 

concentrates will be 

considered as a 

roaster.

The NESHAP does not address SO2.

PM 0.022 gr/dscf (50 

mg/dscm). Initial 

Method 5 test only. 

Existing and new sources must meet the PM 

emissions limit in 40 CFR 60.172 for any 

sintering machine operated. (This is a reference 

to Part 60, Subpart Q, the NSPS for Primary 

Zinc)

Opacity 20 % Opacity 

measured by COMS

Existing and new sources must meet the 

opacity limit in 40 CFR 60.174(a) for any 

sintering machine operated. (This is a reference 

to Part 60, Subpart Q, the NSPS for Primary 

Zinc)
Page 18 of 20

Magnetic Tape Production (40 CFR Part 60, Subpart SSS) 

An evaluation of currently available information indicates that the NSPS for Magnetic 

Tape Coating Facilities remains effective; therefore, we believe a revision of the standard would 

not be needed at this time. The primary basis for this assessment is the continual decline of the 

industry over the past 20 years. As a result, there is no growth anticipated in the industry over 

the next 8 years, and there are no anticipated reconstruction or modification events which 

would trigger NSPS applicability. Consequently, there would be no environmental benefit in 

reviewing, and subsequently revising emission limits based on what would be considered BDT 

for the magnetic tape production NSPS category at this time.

Information collected in 2005 by EPA during the initial development of the National 

Emissions Standards for Hazardous Air Pollutants (NESHAP) for the magnetic tape production 

industry41,42 clearly shows the industry has been in decline for decades. This has been due to 

foreign competition and changes in the marketplace resulting from the emergence of 

alternative technologies (e.g., optical recording media.) The NESHAP development process 

includes the development of the original NESHAP for magnetic tape production in 1994 and a 

MACT review and residual risk determination in 2005. During the NESHAP development 

process, EPA prepared facility counts for the industry, based on direct contact with industry 

representatives and State regulatory agencies. Discussion with industry representatives at the 

time of the residual risk analysis conducted in 2005 also revealed that none of the remaining 

facilities indicated any plans to add lines or modify their magnetic tape production operations.

A search for NAICS 334613 “Magnetic and Optical Recording Media Manufacturing,” 

performed via EPA’s RACT/BACT/LAER Clearinghouse (RBLC) database identified two facilities 

with any permit activity, both dating to the early 1990s. Both of the facilities are among the six 

facilities identified as being currently operational in EPA’s 2005 MACT review and residual risk 

determination. One of the two facilities identified was specifically cited as being subject to the 

magnetic tape production NSPS.

Table 2 is a summary of the magnetic tape industry facility count information collected 

during the magnetic tape NESHAP development process. It shows a decline in magnetic tape 

production facilities of approximately 85 percent since 1988, from 42 facilities to 6 (all 6 of 

which were major sources under the NESHAP). 

 

41 “National Emission Standards For Hazardous Air Pollutants; Proposed Standards For Hazardous Air Pollutant 

Emissions From Magnetic Tape Manufacturing Operations” US EPA, 03/11/94 59 FR 11662

42 “National Emission Standards For Magnetic Tape Manufacturing Operations” US EPA 10/24/05 70 FR 61417
Page 19 of 20

We also reviewed other data sources to confirm the industry growth trends identified in 

EPA’s research. The Census data for the NAICS primarily corresponding to the magnetic tape 

industry, NAICS 334613 (Magnetic and Optical Recording Media Manufacture), cannot be 

directly compared with the facility counts taken from the NESHAP development process, as 

many of the facilities in the category manufacture products that are not regulated by the MACT 

rule (e.g., recordable CD and DVD media, which are produced using an entirely different 

process from magnetic tape.) The census data include optical media manufacture and are not 

directly representative of the industry covered by the NSPS and NESHAP regulations. Data 

indicating the portion of the broader industry represented by magnetic tape were not available. 

However, the available census data43 shows a moderate (33 percent) decline in establishments 

in the broader sector represented by NAICS 334613 between 1997 and 2002, and a sharp (72 

percent) decline in employment, perhaps reflecting consolidation and automation. 

We believe that there is no need at this time for revision of the NSPS for Magnetic Tape 

Production operations, because there is no growth anticipated in the industry over the next 8 

years, and there are no anticipated reconstruction or modification events which would trigger 

NSPS applicability. The lack of expected growth is based on decades of decline in magnetic tape 

facilities reflected by the facility counts compiled during EPA regulatory development for the 

magnetic tape NESHAP in conjunction with the moderate decline in the entire magnetic and 

optical recording media manufacture industry shown by recent census data.

 Table 2: Estimated Facility Numbers in Magnetic Tape Industry, 1988-2005

Year

Number of Facilities in 

Magnetic Tape Industry

1988 42

1994 25

2005 6

Source Notes: 1988 number is taken from the preamble to the 1994 NESHAP. 

1994 and 2005 numbers are taken from 2005 MACT review & Residual Risk 

analysis.

 

43 “Magnetic and Optical Recording Media Manufacture: 2002”, 2002 Economic Census, Manufacturing Industry 

Series. U.S. Census Bureau, EC02-311-334613(RV), December 2004.
Page 20 of 20

Graphic Arts Industry/Publication Rotogravure Printing (40 CFR Part 60, Subpart 

QQ)

The third example of an NSPS category for which currently available information 

indicates that there is no need at this time for review of the applicable NSPS is Publication 

Rotogravure Printing (40 CFR 60 subpart QQ). In accordance with criteria 3, the NESHAP (40 CFR 

subpart KK) for Printing and Publishing is significantly more stringent than the NSPS under 

subpart QQ. The NESHAP recently went through EPA’s Risk and Technology Review (RTR) 

process and no additional technology standards were adopted pursuant to CAA section 112(d) 

(6). Furthermore, any new facility or new press would likely be subject to non-attainment New 

Source Review (NSR) or Prevention of Significant Deterioration (PSD), and consequently 

required to apply Lowest Achievable Emission Rate (LAER) or Best Available Control Technology 

(BACT). Only two new facilities have been built in the past 15 years since the NESHAP was 

promulgated in 1996. Both of these facilities placed their presses in permanent total enclosures 

using carbon adsorbers to achieve very efficient solvent recovery. As part of EPA’s Risk and 

Technology Review (RTR) it was determined that no new advancements in practices, processes 

or control technologies beyond those in place at the two new facilities were identified. The 

BACT level control at the two new facilities is representative of current industry practice and is 

state of the art technology, and a revised best system of emission reduction for the solvent 

recovery practice listed in the NSPS would not be more stringent. Under criteria 2, there has 

been almost no growth in the industry in the past decade. The number of publication 

rotogravure printing facilities has declined from 27 to under 20 in the last 10 years. Only two 

facilities have been built in the last 15 years. No new facilities are anticipated during the next 8 

year review cycle. Therefore, we do not expect applicability of the NSPS in the foreseeable 

future. Therefore, we believe no additional emission reductions would be achieved from a 

revision to the current standard. Thus the agency believes that the Publication Rotogravure 

Printing NSPS (subpart QQ) meets the criteria to not review as described in this document.