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'  *            ,   + + + ', - . 8  9 : ; : +  * ) ) *  + /  0  1  '@ @ @  Q P O NNO P 'Q '@ @ @ @  @ +@ '@7@74  &3 %271 +1 '1 '2 %- '-  '8 (878 %8 %7&6 (6 +677 %8 &97@$@$5$4$3"2#2$27374757@7 07 /7 .7 -7 .7 /7 07@!@"@#@$%_!_"` H     , #2PP#DRAFT 4/22/96#XN\  PXP# ѝ #h%PQP#DRAFT#u\  PP#  Presumptive MACT for Amino and Phenolic Resin Production#XN\  PXP# Presumptive MACT Determination Document Guidance Document not a Rule #[\  PP# Table of Contents #XN\  PXP# Introduction P-MACT Definition Statutory Requirementshh# Industry Profile Roundtable Team Members MACT Floor Determinations Storage Tanks Process Vents Wastewater Equipment Leaks Summary of Open Issues Presumptive MACT Determinations Storage Tanks Process Vents Wastewater Equipment Leaks Reporting, Recordkeeping, Monitoring Floor and P-MACT Summary Implementation Issues Sample Calculations for Batch ACT #u\  PP#Introduction #XN\  P XP# #[\  P P#PMACT Definition#XN\  P XP# #XN\  P XP#In 1994, EPA had to postpone work on several of the MACT standards due in November 1997 and November 2000 (the 7year and 10year MACT standards) as a result of resource constraints. If the EPA fails to set MACT standards on time, Section 112(j) of the Clean Air Act (Act) requires the States to establish emission limitations using a casebycase determination of what the Federal standard would have been. Casebycase MACT determinations under 112(j) will require substantial information and resources from State and local agencies, industry, and environmental groups, and there appears to be a strong incentive for all parties involved to gather information for 112(j) determinations and to promulgate standards on time. The amount of work needed to complete all of the 7year and 10year standards on time is difficult to predict; however, the EPA believes that new approaches are needed to reduce the amount of work and time associated with standards development. To achieve this goal, the EPA has initiated a new standard setting process called MACT Partnerships, that involves a partnership with States, industry, and environmental organizations. This process is described in the March 29, 1995 Federal Register. The MACT Partnerships program involves two phases. The first phase involves the development of a presumptive MACT. A presumptive MACT is not an emission standard; it serves as a statement of current knowledge of maximum achievable control technologies and a basis for a decision on how to develop the emission standard for the source category involved. The second phase is the formal standard development process. For the second phase, the EPA envisions the use of one of three basic regulatory development paths: adoptaMACT, shareaMACT, or a streamlinedtraditional approach. In all cases, EPA would eventually propose and then promulgate the MACT standard. The adoptaMACT and shareaMACT paths involve agreements with States and industry to take primary or shared responsibility for developing the underlying data and analysis from which EPA would determine MACT. When no suitable partners can be found or a standard appears suitable for development by the traditional process, the EPA would go through a streamlinedtraditional process of rule development. #XN\  P XP# #[\  PP#Statutory Requirements #XN\  PXP# Section 112(d) of the CAA requires the promulgation of emissions standards (MACT standards) for listed source categories of the 189 HAPs identified in 112(b). If no MACT standard is promulgated within 18 months of the statutory deadline, Section 112(j)(2) of the CAA requires major sources to apply for a permit and comply with emission limitations equivalent to MACT. Section 112(g) of the CAA requires compliance with MACT on a case-by-case basis for major source modifications when no MACT standard has been promulgated by EPA. It is important to emphasize that "major source" means any stationary source or group of stationary  8H sources located within a contiguous area under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year of any HAP or 25 tons per year of any combination of HAP.  This standard is intended to regulate facilities that produce phenolformaldehyde (phenolic resins), melamineformaldehyde and ureaformaldehyde resins (amino resins). It will likely be expanded to regulate a small number of other specialty resins that are also based on formaldehyde polymers and produced in a similar manner to the listed source categories. In other words, applicability will be based on product verses feedstocks or process. These two source categories are part of a broader project to develop a MACT standard for all facilities that produce formaldehyde based resins. This project includes the acetal resin source category. This PMACT document only addresses the amino and phenolic resin sources categories. The acetal resin source category is being analyzed under a separate PMACT project. All of these resins will be addressed in the MACT standard for formaldehyde based resins, also referred to as Polymers and Resins Group III. The EPA is required to develop a MACT standard for each of these source categories before November 15, 1997. #[\  PP#Industry Profile#XN\  PXP# There are over 100 facilities that produce amino or phenolic resins in the United States. Thirty two of these facilitites produce amino (melamine or urea) resin while thirty three facilities produce phenolic resins. In addition, there are thirty five facilities that produce both amino and phenolic resins. There are at least twenty three facilities that also produce one of the primary feedstocks, formaldehyde, onsite. The following is a sample of the information that the EPA collected from the industry during the fall of 1992 using a generic Information Collection Request (ICR) and the authority of section 114 of the CAA. 337As illustrated in the following chart, almost 1400 tons per year of HAPs are emitted by amino and phenolic resin production facilities. The types of HAPs emitted include: formaldehyde, methanolKKKK Figure 1 KKKK Figure 1  % V dd % Total HAP Emissions, xylenes, phenol, o-cresols, toluene, 26 other HAPs. As illustrated in the following graphs, the facilities in these two source categories range from very large to very small manufacturers with all levels inbetween. In addition, there is no clear correlation between the size of a facility and the effectiveness of its existing pollution controls.  dd Resin Production vs Emissionsڐ No apparent correlation between size of facility and overall emissions from resin production.  ?# dd ?!Resin Production vs Emission Rate No apparent correlation between the size of the facility and the emission rate for resin production. Roundtable Team Members The following tables summarize the people and organizations who participated in the amino and phenolic resin PMACT. All of these people provided comments on draft documents, participated in roundtable discussions or otherwise provided expertise and insight into the production of amino and phenolic resins. T ddd+ ddd+ T hh EPA Participants OAQPShhhhOAQPS, RTP, NCTitlePhone NumberhhPete HofmannProject Engineer9195413713/F3470hhJohn SchaeferEnvironmental Engineer9195410296/F3470hhBob RosensteelSenior Engineer9195415608/F3470hhSusan WyattGroup Leader9195415674/F3470hhLarry SorrelsEconomist9195415041/F0839hhJan KingEconomist9195415665/F0839hh T ddd* ddd* T hh State and Local Agencies hhhhState or Local AgencyParticipant NamePhone NumberhhNew York DECJack Lauber518-457-7688/F-0794hhNew York DEC Region 4Rick LeonehhNew York DEC Region 9Larry StillerhhAPCD of Jefferson City, KentuckyDick Everhart502-574-6000/F-5306hhDiv of Env Services, Toledo, OHKaren Granata419-697-5129/F-936-3016hh T ddd. ddd. T hh Industry/Other hhCompany/Trade Group/OrganizationParticipant NamePhone NumberPPUF Resins Mfg Ass'n (*)c/o Brock Landry, Jenner & Block202-639-6070/F-6066hh*Southeastern AdhesivesLarry Wasfaret704-754-3493/F-0052hh*Borden, Inc.Mark Gruenwald614-225-3459/F-7638hh*Borden, Inc.Diane Strayer2064625453/F5487hh*Georgia-Pacific Resins, Inc.Terry Liles404-593-6832/F-6801hh*GeorgiaPacific Resins, Inc.Rodney Canada4046528037/F2301676hh*Neste Resins Corp.Larry Lowenkron503-687-8840/F-484-6825hh*Spurlock AdhesivesNorman Spurlock804-834-3113/F-2860hh*D.B. Western, Inc.Dan Matthews503-756-0533/F-5911hh*BTL Specialty ResinsAndy Fairchild419-244-5856/F-9206hh*Tailored Chemical ProductsJack Temple, III704-322-6512/F-7688hhSchenectady International Inc.Tom Windish518-370-4200/F-887-2386hhSchenectady Int. Inc. (Radian)John Stelling9194611279/F1417hh3M Camillya Bryant612-778-4344/F-7203hhMonsantoNorman Phillibert413-730-2082/F-3299hhMonsantoDave Krawczyk314-694-3666/F-6262hhDexter PackagingAndrew Miles205-854-5121/F-520-0206hhSimpson TimberDavid Berg503-978-2817/F-2607hhP.D. George CompanyJeannine Kelly314-621-5700/F-436-1030hhOccidental Chemical CorpFrank Collis716-286-3589/F-3141hhNational Paints and Coatings AssnJim Sell202-462-6272/F-8549hhCytec IndustriesSteve Byrne908-862-6000/F-8023hhAshland ChemicalTara Lanier614-790-3214/F-6080 hhClean Air NetworkJohn Tallmadge2026249388/F7835917 #[\  PP# MACT Floor Determination#XN\  PXP# Storage Tanks  Analysis Little or no information was available on the sizes or typical contents of storage tanks at the 100 facilities in the amino and phenolic resin source category. Some limited assumptions were possible based on the calculations submitted by some companies in the ICR data, but no specific information related to tank size, contents or controls at each facility was collected. In addition, the primary stored reactants in these source categories are heavy liquids, i.e., liquids with vapor pressures < 0.04 psi. Facilities that use volatile solvents to create specialty resins typically use either very small quantities or use controls consistent with the HON and the majority of state regulations. The existing state regulations for storage tanks are very similar to the HON except for minor differences in vapor pressure cutoffs. The types of controls required are the same.  Floor Determination  Since we did not have enough information available to make an attempt to estimate the floor for storage tanks, the reg team decided that the HON is at least as stringent as the floor and therefore, assume the HON to be the floor. The industry members on the roundtable commented that this would aid in obtaining regulatory consistency where possible and practical. In addition, most of the storage tanks at the facilities in these source categories would not meet either the size or the vapor pressure cutoffs of the HON. Control will be directed at those facilities using large quantities of volatile materials. Per the HON, the applicability cutoffs for control are as follows: capacity >40,000 gal hh#and (-vapor pressure >0.75 psi 20,0001.9 psi  Open Issues  none #[\  PP# MACT Floor Determination #XN\  PXP# Batch Process Vents  Analysis  In an effort to ensure consistency in the analysis of batch process vent emissions, the roundtable agreed to consider the primary condenser on the reactor to be an integral part of the process and not a pollution control device. In addition, batch emissions from process reactors were the primary source of data for determining the floor. Batch emissions from other process equipment were assumed to be small compared to the reactor emissions. Therefore, only control devices used after the primary condenser on the process reactors were considered in determining the floor. The MACT floor was determined using the average emissions reductions for the best performing twelve percent of existing facilities. Since we had data on 100 facilities, we analyzed the best performing twelve facilities. The floor included two facilities that use thermal incinerators, seven that use catalytic incinerators and the remaining three facilities used wet scrubbers. The reported efficiencies for these devices ranged up to 99.6%. To determine the MACT floor, we assumed control device effectiveness based on existing EPA documentation. Therefore, 98% was used for thermal incineration, 95% for catalytic incineration and 50% for wet scrubbing. Further analysis of actual flow characteristics in these source categories could modify these control device efficiencies.  Floor Determination  Based on the ICR data, the floor is 84% control of batch emissions from process vents (numerical average). Alternatively, the floor could possibly be defined by some other measure (e.g., max ppmv) or an equivalent control technology.  Open Issues  The EPA agreed to determine actual efficiencies of control devices using technical input from industry. The industry participants agreed to determine the proportion of incinerated streams that are from resin production at facilities who incinerate process vent emissions as well as obtain data on flow characteristics to aid the EPAs control device efficiency analysis. #[\  PP# MACT Floor Determination #XN\  PXP#Continuous Process Vents  Analysis  In addition to the batch emissions present at most all of the facilities in this source category, some facilities have a significant number of continuous process vent emissions. These emissions are primarily located at larger facilities who continuously operate spray dryers, flaker belts and other equipment for drying finished resins. In general, these emission sources can be characterized as either high volume, low concentration flows (e.g., spray dryers) and low volume, low concentration flows (e.g., flaker belts).  Floor Determination  Due to these flow characteristics, no spray dryers and very few other continuous process vents in these source categories are controlled. There are some controls on isolated pieces of continuously operating process equipment. Based on the data available, the floor for continuous process vents is no control.  Open Issues  None #[\  PP# MACT Floor Determination #XN\  PXP# Wastewater  Analysis  There are five facilities that use wastewater controls. These controls include thermal incineration, air stripping, steam stripping and carbon absorption to meet effluent guidelines. The HAPs controlled per the ICR are mostly non-volatile and don't require control per Table 8 in the wastewater provisions in the HON. These controls appear to exist primarily to minimize water discharges. The actual control device efficiencies for reducing air emissions are difficult to determine due to the low volatility of primary HAPs in liquid emission streams. In addition, no state regulations require control of air emissions from wastewater at facilities in these source categories. In addition to formal pollution controls on air emissions from wastewater streams, several facilities in these source categories are zero discharge and recycle or resale all of their process wastewater. It is not clear at this point how this practice should best be used to determine a floor level of control for air emissions.  Floor Determination  Since there are only five facilities that have any controls for air emissions from wastewater streams in place, the remaining seven facilities that are considered when determining the floor have no controls in place. Therefore, the key measure of central tendency for this subcategory would be the most frequently occurring data point or mode. Since the mode for this subcategory is no control, then the floor could be defined as no control. However, since it is not clear how to integrate zero discharge facilities in the floor analysis, the floor for wastewater is unclear at this time.  Open Issues  The EPA will obtain detailed information on VOHAP reductions at facilities with wastewater controls in place to help identify the best controlled source for defining the new source performance standard. EPA will also determine which HAPs are actually controlled at these facilities and the criteria for control. Finally, the EPA will need to determine if zero discharge facilities need to be accounted for in the floor determination for wastewater. #[\  PP#MACT Floor Determination#XN\  PXP# Equipment Leaks  Analysis  Twenty three facilities reported some form of LDAR program was in place for reducing fugitive emissions in the ICR. Further investigation by the roundtable team members identified at least sixteen of those facilities did not have formal LDAR programs for their resin facilities. They either performed routine maintenance and visual checks or had formal LDAR programs elsewhere in their facilities. The facilities that had LDAR programs in place claimed reductions that 6190% control. The specific reductions appear to correspond to prior EPA estimates for monthly, 10,000 ppmv leak detection programs outlined in 40 CFR 60 Subpart VV. Floor Determination  The NSPS LDAR requirement defines the floor (40 CFR 60 Subpart VV) based on the information collected.  Open Issues  none #[\  PP#Presumptive MACT#XN\  PXP# Storage Tanks  Analysis  The following options beyond the floor were considered during the development of the HON and were reconsidered for this PMACT: small tanks (10,00040,000 gal capacity) - control all tanks, control tanks with VP > 1.9 psi Since these options were determined to not be cost effective for the HON as well as the stored materials in these source categories being predominately less volatile than those in the HON, the HON is a sound choice for presumptive MACT. This also keeps with the desire for regulatory consistency from both the regulator and regulated communities.  Presumptive MACT Determination  HON storage tanks rule small (<20,000 gallon) - no control medium (20,0001.9 psi large (>40,000 gallon) - control if stored liquid has VP > 0.75 psi HON control requirements  Open Issues  none #[\  PP# Presumptive MACT #XN\  PXP# Batch Process Vents Analysis Based on the limited amount of emissions data available, the primary batch vent streams in these source categories have very low flow rates (<200 scfm) with low concentrations (<50 ppmv). Given that the floor is 84% control of emissions (emissions after primary condenser for reactor vents), the primary challenge was to determine an effective regulatory approach for defining controls and applicability requirements for batch process emissions. The Batch ACT (EPA450/R94020) has 90, 95 and 98% control options as well as a series of calculations to determine applicability for control that consider the unique qualities of batch emissions. In general, control is required for high concentration, low flowrate streams. In addition, manifolding of emissions from adjacent reactor lines is also considered during applicability determination calculations. While all three levels of control were considered to be cost effective during the development of the Batch ACT, the 90% level was chosen for these source categories due to the predominance of low flow/ low concentration emissions.  Presumptive MACT Determination  Batch ACT at 90% control level. (Note: The control cutoff for low volatility streams in the Batch ACT is defined at 13 tpy of HAP emissions. This will be modified for these source categories to ensure all major sources have to comply with the MACT standard. For example, the control cutoff may be redefined as 10 tpy of a single HAP/ 13 tpy of combined HAP emissions. ) Federally enforceable limits on production shall be used to ensure compliance with cutoff requirements.  Open Issues  process vent floor issues #[\  P P# Presumptive MACT #XN\  P!XP#Continuous Process Vents Analysis The most prevalent continuous process vents in these source categories are associated with spray drying operations and other drying equipment (e.g., flaker belts). Spray drying operations typically have very high flow rates (>30,000 scfm) with low concentrations (<30 ppmv) of HAP. The MACT floor is no control for spray dryer emissions. To ensure that continuous vents are objectively analyzed for control potential, a TRE will be calculated for each continuous vent as outlined in the HON. Control will be required for all vents with TRE less than or equal to 1. This control option above the floor was also selected in the HON and determined to be cost effective.  Presumptive MACT Determination  Calculate TRE per HONTRE <= 1 control per HON TRE > 1 no control  Open Issues  none #[\  P"P#Presumptive MACT#XN\  P#XP# Wastewater  Analysis  The predominate HAPs in these source categories have very low volatility as well as high water solubility. Some facilities control wastewater, but information in ICRs is inconclusive as to why low volatility HAPs are controlled and if air emissions are controlled. Additional information was provided to EPA by roundtable members and confirmed that there are some facilities in these source categories that will meet the applicability thresholds for the HON wastewater provisions. These applicability determinations were made using an average flowrate calculated using the guidance in the HON (total annual wastewater volume divided by 525,600 minutes). This calculation method averages wastewater discharges over all batch process steps and simulates the effect of a continuous process stream. The HON wastewater provisions (identified compounds only) were considered and selected as an option for control beyond the floor. In addition, requiring a level of control comparable to the level acheived by zero discharge facilities will still be analyzed, depending how the final floor determination is made.  Presumptive MACT Determination  HON wastewater applicability VOHAPs identified in Table 9 of Subpart G 1000 ppm concentration and 10 lpm flow ` `  or ` ` 10,000 ppm concentration HON control requirements recycle to a process reduce total HAP mass or concentration reduce HAP content to specific target values treat with design steam stripper  Open Issues  wastewater floor issues #[\  P$P#Presumptive MACT#XN\  P%XP# Equipment Leaks Č Analysis  There is a floor requirement for an LDAR program corresponding to a monthly monitoring program similar to the requirements of Subpart VV. The predominate reactants in these source categories are heavy liquids, however, there are a number of facilities that use large quantities of solvents during the production of their resins. These solvents are predominately light liquids. As an option beyond the floor, the HON negotiated regulation for equipment leaks was considered. Since heavy liquids are the primary reactants in these source categories, there didnt appear to be any tangible benefit to requiring the HON equipment leak provisions. Each facility will have the option to use the HON provisions in place of Subpart VV if this will reduce regulatory burdens.  Presumptive MACT Determination  LDAR program consistent with NSPS LDAR requirements 40 CFR 60 Subpart VV  Open Issues  The EPA will verify that the NSPS LDAR program is consistent with LDAR programs in floor facilities. #[\  P&P#Presumptive MACT#XN\  P'XP# Reporting, Recordkeeping and Monitoring  Reporting Requirements  Semi-annual compliance reports will be required in either hardcopy or electronic formats. The focus of all reporting requirements will be on certifying compliance and not the submission of large quantities of data.  Recordkeeping Requirements  Facilities will be required to keep hardcopy records for key monitors for a five year period. Production records and other analyses to document compliance with federally enforceable limits for cutoffs and synthetic area determinations will also be required to be maintained for a five year period. The owner/operators will also be required to develop startup, shutdown and malfunction provisions similar to those in the General Provisions outlined in 40 CFR Part 63, Subpart A.  Monitoring Requirements  The primary monitoring requirements will be for key control device parameters. The operating limits for these control devices will be determined by the owner/operator. The key parameters will be averaged, most likely on an hourly basis, and used to ensure compliance with the standard.  Open Issue  EPA will identify a reliable/acceptable method to determine initial compliance with the 90% emission reduction for process vents. #\  P(P#Summary of Floor and Presumptive MACT#u\  P)P# #XN\  P*XP# 9ddddZdd@ddddZdd@9 T TdT0( ( ( TdT0( ( ( T P (P ( # %P+QP#FLOOR#XN\  P,XP#  Applicability  Control Requirement P (P ( Storage Tanks >40k gal & VP>0.75 psi 20k1.9 psi <20k galHON HON noneP (P ( Process Vents Batch Process Vents Continuous Process Vents84% control noneP (P ( Wastewater unclearunclearP  -P  - Equipment Leaks based on equipment type and volatilityLDAR per 40 CFR 60 part VV T TdT0( ( ( TdT0( ( ( T P (P ( # %P-QP#PMACT#XN\  P.XP#  Applicability  Control Requirement P (P ( Storage Tanks >40k gal & VP>0.75 psi 20k1.9 psi <20k galHON HON noneP (P ( Process Vents Batch ACT regression equations >50 ppm, TRE<=1.090% control HONP (P ( Wastewater 10,000 ppmv or 1000 ppmv and 10 lpmHONP  -P  - Equipment Leaks based on equipment type and volatilityLDAR per 40 CFR 60 part VV #[\  P/P#Implementation Issues#XN\  P0XP# During the final roundtable meeting in December 1995, several issues were identified that will need to be resolved before a standard can be promulgated for the amino and phenolic resin source categories. Any state or local regulators that use this PMACT document for guidance on implementing a local standard need to consider the following issues and how they apply to the facilities under their jurisdiction. The issues identified at the roundtable and the most current information are provided below. As more information is obtained, updates will be provided through the draft standard on the TTN. J TdT0S% TdT0S% J P (P ( ISSUE  DISCUSSION P (P (Compliance dates for this standardEven though this standard makes use of existing guidance from the HON and the Batch ACT, the compliance dates will be based on the proposal and promulgation dates of this standard.P (P (Applicability to thinning tanksIt is unlikely that thinning tanks at painting and coating facilities will be covered by this standard. The primary challenge is to define the end point of resin production and the start point for paints and coatings.P (P (Wastewater flowratesGiven the batch nature of these source categories, it is unclear what the most effective method for determining wastewater flowrates. The HON currently identifies an annual average (total discharge/525,600 minutes) as the preferred method.P (P (Wastewater holding tanksWastewater holding tanks downstream of process lines will be covered by the storage wastewater provisions of the standard that is developed.P (P (Equipment leak cutoffsIt is likely that there will be a cutoff limit for the equipment leak provisions of the standard similar to those in Subpart VV.P (P (Source category definitionThis standard is intended to regulate facilities that produce phenolformaldehyde, melamineformaldehyde and ureaformaldehyde resins. It will likely be expanded to regulate a small number of other specialty resins that are also based on formaldehyde polymers and produced in a similar manner to the listed source categories. In other words, applicability will be based on product verses feedstocks or process.P (P (Research and development facilitiesIt is unlikely that research and development facilities will be regulated by this standard. As defined in the CAA (Sect 112 (c)(7)), these facilities will be regulated in a future standard.P (P (DistillateIt is likely that distillate that is recycled will not be considered wastewater. However, distillate that is discharged will most likely be considered when evaluating wastewater control applicability.P (P (Fugitives other than equipment leaksSince the EPA has determined that the fugitive emissions other than equipment leaks (e.g. transfer operations) are negligible for these source categories, we dont plan to address them in this standard.P (P (Noncontact cooling waterFor this standard, wastewater will not include noncontact cooling water. EPA will still explore the possibility for an LDAR requirement if VOHAP contamination occurs.P (P (Emissions averagingIt is likely that there will be emissions averaging provisions in this standard similar to those in the HON and other polymer and resin standards.P (P (Aggregating batch process ventsWhile ducting costs are integrated into the regression cutoff equations of the Batch ACT, there are likely to be instances where the ducting costs will become excessive. This costs can escalate significantly due to a number of site specific factors. These factors include the physical distance between reactors as well as the potential need for flame arresters and other equipment to prevent explosions with certain resin formulations. EPA will investigate methods for evaluating these types of facilities.P (P (Process equipment definition for process vents In general, all process equipment involved in resin formulation and finishing will be considered when performing emission calculations for this standard. It is likely that the standard will identify certain specific types of process equipment that are very minor emission sources and need not be considered when performing process vent cutoff calculations using the Batch ACT methodology.P (P (Applicability of more stringent requirement for new sourcesWere more stringent controls are required for new or reconstructed sources such as storage tanks in the HON the Clean Air Act specifies 2 compliance deadlines. If the source begins construction after the rule is promulgated the source must show it will comply with the standard before it begins construction or reconstruction. If the source begins construction or reconstruction after proposal of a rule and before promulgation the source has three years after the date of promulgation to comply with the rule. CAA Section 112(i)(1) and (2) P  -P  -Nonsignificant sources at major facilitiesThere are several phenolic resins facilities located at paints and coatings facilities that produce resins for very small periods during the year (5% for many of these facilities). Many of these facilities are major due to their paints and coatings operations. There is a concern about drawing these plants into the rule for equipment leaks and recordkeeping (other operations are minor enough to be exempted). #[\  P1P#Sample Calculations for Batch ACT #XN\  P2XP# Medium Facility #A\  P3P#  Entire facility is major due to collocation with a SOCMI process   6 Reactors are used to produce amino and phenolic resins   Four resin products (A, B, C & D) are made in any of the six reactors ` ` Product A 100 batches in previous year ` ` Product B 300 batches in previous year ` ` Product C 700 batches in previous year ` ` Product D 275 batches in previous year   Emission streams are all low volatility   Actual annual HAP emissions from process vents during resin production was 28,300 lbs #XN\  P4XP# Determine MACT Applicability #A\  P5P#  Entire facility is a major source (>10/25 tpy)   Entire facility cant qualify as a synthetic minor   Comply with MACT standard #XN\  P6XP# Compute average flowrate (FR) per batch using the following equation: 1dddd (1) 1dddd (1) 2<Tdd<TqeFR~=~{SUM FROM {i=1} TO n (FR_event_i)(Duration_event_i)} OVER {SUM FROM {i=1} TO n Duration_event_i}q  ې#A\  P7P#Product A FR = 33.8 scfm   Product B FR = 52.1 scfm   Product C FR = 42.6 scfm   Product D FR = 48.3 scfm #XN\  P8XP# <dd<xlf ~Average~FR~per~batch~=~{(100)(33.8)~+~(300)(52.1)~+~(700)(42.6)~+~(275)(48.6)} OVER {1375}~=~45.2~scfmxڐ #A\  P9P#  Since all six reactors can be used for resin production, the average FR for the facility is (6)(45.2) = 271.2   Manifolding of vents for all twelve reactors and parallel processing is assumed #XN\  P:XP# Determine if cutoffs are met #A\  P;P#  AE from vents = 28,300lbs > 26,014lbs (cutoff for low volatility streams in Table 61) ====> NO   From Table 61, for low volatility stream and 90% control, use the following: ` ` FRcalc = (0.07)(AE) 1821 ` ` FRcalc = (0.07)(28,300) 1821 ` ` FRcalc = 160 scfm  Since 160 < 271.2, no control is required for process vents   Commit to enforceable limits on annual emissions as well as average FR for the facility #XN\  P<XP# Large Facility  #A\  P=P#  Entire facility is major   12 Reactors are used to produce amino and phenolic resins   Eight resin products (A, B, C, D, E, F, G & H) are made in any of the twelve reactors Previous year production: ` ` Product A 150 Batcheshh#(Product B 220 Batches ` ` Product C 95 Batcheshh#(Product D 900 Batches ` ` Product E 850 Batcheshh#(Product F 640 Batches ` ` Product G 770 Batcheshh#(Product H 1100 Batches   Emission streams are all low volatility   Actual annual HAP emissions from process vents during resin production was 52,600 lbs #XN\  P>XP# Determine MACT Applicability #A\  P?P#  Entire facility is a major source (>10/25 tpy)   Entire facility cant qualify as a synthetic minor   Comply with MACT standard#XN\  P@XP# Compute average flowrate (FR) per batch using the following equation: 2<Tdd<TqeFR~=~{SUM FROM {i=1} TO n (FR_event_i)(Duration_event_i)} OVER {SUM FROM {i=1} TO n Duration_event_i}qڐ#A\  PAP#  Product A FR = 42.8 scfmhh#(Product B FR = 38.3 scfm   Product C FR = 52.5 scfmhh#(Product D FR = 24.1 scfm   Product E FR = 22.6 scfmhh#(Product F FR = 19.7 scfm   Product G FR = 18.3 scfm hh#(Product H FR = 20.3 scfm#XN\  PBXP#  <dd<qef ~Average~FR~per~batch~=~{(150)(42.8)~+~(220)(38.3)~+~...~+~(1100)(20.3)} OVER {4725}~=~23.2~scfmqڐ#A\  PCP#  Since all 12 reactors can be used for resin production, the average FR for the facility is (12)(23.2) = 278.4   Manifolding of vents for all twelve reactors and parallel processing is assumed#XN\  PDXP# Determine if cutoffs are met #A\  PEP#  AE from vents = 52,600lbs > 26,014lbs (cutoff for low volatility streams in Table 61) ====> NO   From Table 61, for low volatility stream and 90% control, use the following: ` ` FRcalc = (0.07)(AE) 1821 ` ` FRcalc = (0.07)(52,600) 1821 ` ` FRcalc = 1861 scfm   Since 1861 > 278.4, control is required for process vents to 90 % #XN\  PFXP#