EPA-450/2-77-033
December 1977
(OAQPS No. 1.2-087)
MAGNET WIRE
COATING
AP-42 Section
4.2.2.51
Reference Number
    1
                     GUIDELINE SERIES
        CONTROL OF VOLATILE
            ORGANIC EMISSIONS
                 FROM EXISTING
          STATIONARY SOURCES
          VOLUME IV:  SURFACE
     COATING FOR INSULATION
               OF MAGNET WIRE
  U.S. ENVIRONMENTAL PROTECTION AGENCY
      Office of Air and Waste Management
    Office of Air Quality Planning and Standards
   Research Triangle Park, North Carolina 27711

-------
                                  EPA-450/2-77-033
                                 (OAQPS No. 1.2-087)
         CONTROL OF VOLATILE
ORGANIC EMISSIONS FROM EXISTING
         STATIONARY SOURCES
   VOLUME IV:  SURFACE COATING
 FOR INSULATION OF MAGNET WIRE
             Emissions Standards and Engineering Division
                 Chemical and Petroleum Branch
            ( .S. ENVIRONMENTAL PROTECTION AGENCY
               Office of Air and Waste Management
             OH ice of Air Quality Planning and Standards
             Research Triangle Park, North Carolina 27711

                     Deeemher 1977

-------
                   OAQPS GUIDELINE SERIES

The guideline series of reports is being issued by the Office of Air Quality
Planning and Standards (OAQPS) to provide information to state and local
air pollution control agencies;  for example,  to provide guidance on the
acquisition and processing of air quality data and on the planning and
analysis requisite lor the maintenance of air quality.  Reports published in
this series will be available - as supplies permit - from the Library Services
Office (MD-35) .U.S. Environmental Protection Agency, Research Triangle
Park, North Carolina 27711;  or, for a nominal fee, from the National
Technical Information Service,  5285 Port Royal Road, Springfield,  Virginia
22161.
                   Publication No. EPA-450/2-77-033
                          (OAQPS No. 1.2-087)

-------
                             PREFACE







     This  report is one of a continuing series designed to assist State



and local  jurisdictions in the development of air pollution control



regulations for volatile organic compounds (VOC)  which contribute to the



formation  of photochemical nxidants.  This report deals with VOC emissions



from wire  coating ovens.



     Below are provided emission limitations that represent the presumptive



norm that  can be achieved through the application of reasonably available



control  technology (RACT).  Reasonable available control technology is



defined as the lowest emission limit that a particular source is capable



of meeting by the application of control technology that is reasonably



available considering technological  and economic feasibility.   It may require



technology that has been applied to  similar, but not necessarily identical



source categories.  It must be cautioned that the limits reported in this



Preface are based on capabilities and problems which are general to the



industry,  but may not be applicable  to every plant.



     The most common control technique used for wire coating ovens is



incineration.  Essentially, all solvent emissions from the oven can be



directed to an incinerator with a combustion efficiency of at least 90



percent,  This efficiency is reasonable to attain.  Thermal incinerators



have an efficiency range  from 90 to 99 percent,  Catalytic oxidizers have



an  efficiency range of  90 to 95 percent if not fouled.

-------
     Low polluting coatings are beginning  to  be  used  in the wire coating

industry.  It is reasonable to exempt  an oven from  the  incineration

requirement if the coatings used contain less than  the  recommended

limitation given below for low solvent coatings.
      Affected Facility                    Recommended  Limitation for
                                              Low Solvent  Coatings
                                       kg  solvent  per      Ibs  solvent  per
                                       liter of coating    gallon of  coating
                                         (minus water)       (minus water)
       Wire Coating Oven                    0.20                 1.7


     This emission limit can be met with  high-solids  coatings  having  greater

than 77 percent solids by volume.   Powder coatings  and hot  melt  coatings

will both achieve this.   This emission limit can  also be  met with  a water-

borne coating which contains 29 volume percent  solids, 8  volume  percent organic

solvent, and 63 volume percent water.   A  water-borne  emulsion  with no organic

solvent would, of course,meet the recommended limit.

     Approximately the same amount of solvent will  be emitted  from a  low

solvent coating meeting the above limitation as from  an equal  volume  of

solids applied as a conventional coating  with 90  percent  incineration of

solvent emissions from the conventional  coating.

     Many wire enameling ovens already have incinerators  which reduce

volatile organic compound (VOC) emissions.  Because of the  number  of  sources

already controlled, national emissions from wire  enameling  is  not  so  great  as

from some other sources.  But a wire enameling plant  with only a few

uncontrolled ovens could easily exceed 91 Mg/year (100 tons/year)  of  VOC
                                IV

-------
emissions.   Thus,  a wire enameling plant can be a  significant  source  in
a local  area.

-------
                            SUMMARY







     Wire enameling is the process of insulating  electrical wire by



applying varnish or enamel.   Organic solvent  is  driven  off  in  the wire



drying oven.  Incineration,  either thermal  or catalytic,  is the  most common



way to control these solvent emissions.   Control  efficiencies  of 90



to 95 percent are typical.  Because  of the high  oven  temperatures and



high solvent concentrations  in the exhaust, this  is  a favorable  situation



for heat recovery.   The fuel value of the waste  solvent may be used  to



supply much of the heating requirements  of the oven.
                                 VI

-------
               CONVERSION FACTORS FOR METRIC UNITS
                                                         Equivalent
Metric Unit                 Metric Name                 English  Unit
Kg                    kilogram (103grams)                 2.2046  Ib
liter                 liter                              0.0353  ft3
dscm                  dry standard cubic meter          35.31  ft
scmm                  standard cubic meter per min.      35.31  ft /min
Mg                    megagram (10 grams)                2,204.6  Ib
metric ton            metric ton (10 grams)             2,204.6  Ib
     In keeping with U.S.  Environmental  Protection Agency policy,metric
units are used in this report.  These units may be converted to common
English units by using the above conversion factors.
     Temperature in degrees Celsius (C°) can be converted to temperature
in degrees Farenheit (°F)  by the following formula:

     t°f = 1.8 (t° ) + 32
     t°  = temperature in  degrees Farenheit
     t°  = temperature in  degrees Celsius or degrees  Centigrade

-------
                          TABLE OF CONTENTS


PREFACE	 ,  ,	ill
SUMMARY .  .  .  ,	   vi
CONVERSION FACTORS FOR METRIC UNITS 	  vii
1.0  SOURCES AND TYPES OF EMISSIONS	1-1
     1.1  General  Discussion	1-1
     1.2  Processes and Affected Facility  	  1-1
          1.2.1   Process,	1-1
          1,2.2  Types of Emissions	1-5
     1,3  References	1-7
2.0  APPLICABLE SYSTEMS OF EMISSION REDUCTION  	  2-1
     2.1  Incineration (Combustion Systems)  .  ,  	  .....  2-1
     2.2  Carbon Adsorption 	  2-7
     2.3  Low Solvent Coatings	,  .  .  2-7
     2.4  References	2-9
3.0  COST ANALYSIS	3-1
     3.1  Introduction	3-1
          3.1.1  Purpose	,	3-1
          3.1.2  Scope	3-1
          3.1.3  Use of Model  Emission Points	3-2
          3.1,4  Basis for Capital and Annualized
                   Cost. Estimates	3-2
     3.2  Control  of Solvent  Emissions from  Wire
            Coating  Operations	3-4
          3.2.1  Model Cost Parameters	3-4
          3.2.2  Control Cost	3-4
          3.2.3  Cost Effectiveness	3-8
     3.3  References	3-11
4.0  ADVERSE AND BENEFICIAL EFFECTS OF APPLYING  TECHNOLOGY	4-1
     4,1  Beneficial Effects	4-1
                                   viii

-------
     4.2  Adverse Effects .  ,	4-1
     4.3  References. ,	4-2
5.0  MONITORING TECHNIQUES AND ENFORCEMENT ASPECTS. ..........  5-1
     5.1  References. ,	,	,  .  ,  .   .  5-2

-------
                  1.0  SOURCES  AND TYPES  3F  EMISSIONS








1.1   GENERAL DISCUSSION



     Magnet wire coating is the process of applying  a  coating  of  electrically



insulating varnish or enamel  to aluminum  or  copper wire  for  use  in



electrical machinery,   """ho wire is called magnet  wire  because, in such



equipment as electrical motors, generators and transformers,  this wire




carries an electncrtl  current which creates  an electromagnetic field.  The



wire coating must rnee: rigid specifications  of electrical, thermal  and



abrasion resistance.



     Magnet wire is usually coated in large  plants which both  draw  and



insulate the wire.  Tne wire is then sold to manufacturers of electrical



equipment.  There are approximately 30 enameling  plants  in the United States.



These are located in several  States including New York,  Connecticut,  Illinois,



Virginia, Massacnusetts, North Carolina,  Georgia  and Louisiana.   The  largest



geographical concentration of wire coaters is Fort Wayne, Indiana.  Several



companies have wire enameling plants there.






1.2  PROCESSES AND AFFECTED FACILITY



1.2.1  Processes




     Figure 1 shows a typical wire coating operation.   The wire  is  unwound



from spools and passed through an annealing  furnace.  Annealing  softens



the wire to make it -nore pliable for its  trip over the pulley network and also



acts as a cleaning chamber to burn off oil and dirt  left from previous



operations.





                                  1 -1

-------
                                Q)

                                C
                                 O
                                 o

                                 (D
                                 
-------
     The wire is then ready for coating.   There  are  several  variations on



the method of application.   Typically,  at  the  coating  applicator  the



wire passes through a bath  of coating and  picks  up a thick  layer  of coating.



The wire then is drawn vertically through  an orifice or coating die as



shown in Figure 2.   The die scrapes off excess coating and  leaves  a thin



film of the desired thickness.



     After the wire passes  through the coating die,  it is  routed  through



the oven where the coating  dries and cures.   The exhaust from the oven is



the most important solvent emission source in  the wire coating plant.



     Most coating ovens consist of two zones.   Wire  enters  at the drying



zone which is held at about 200°C.  The second or curing zone and the



temperature here is around 430°C.



     At some plants there  is a noticeable  solvent odor near the coating



applicator indicating incomplete capture.   In others,  solvent from the



coating bath appears to be drawn into the  oven by its  indraft. At any rate,



the solvent emissions from the applicator  are low compared to the principal



emission source, the drying oven.



     The exhausts from typical ovens range from 11  dry standard cubic meters



(dscm)  per minute to 42 dscm per minute with the average being around 28.



The solvent concentration  in the exhaust will  typically range fromlOto  25



percent of the LEL (lower  explosive limit).   This would be equivalent to



about 12 kg solvent per hour emissions from the oven.   Each oven  usually



operates three shifts per  day for seven days a week.  It is not unusual  for



a  wire  coating plant to have 50 coating ovens.  An  uncontrolled plant could



easily  emit more than 90 f-lg (megagratns) per year of solvent which would make



it a significant source of VOC emissions.
                                   1-3

-------
     TO DRYING OVEN
           I
            1
                      COATED
                       WIRE
                            COATING
                              DIE
                      EXCESS
                     COATING
    FROM COATING BATH
Figure 2.  Wire coating die.
             1-4

-------
     After a wire passes  through  the  oven and  the coating  is cured, it

again passes through  the  coating  applicator  and oven to  receive another

layer of coating.   This may be repeated  four to 12  times so that the wire

receives a thick coating  of many  layers.  After a final  pass through the oven,

the wire is wound on  a spool for  shipment to the customer.


1.2.2  Types of Emissions

     The organic solvent  content  of wire coatings  range  from 67 to  85  percent

by weight.  Coating resins include the following compounds:

                       Polyester  amide imide
                       Polyester
                       Polyurethane
                       Epoxy
                       Polyvinyl  formal
                       Polyimide


     In addition to solvent, from 10  to  25  percent  of  the  coating  resins may

be volatilized in the drying ovens and emitted with oven exhaust.   Most

of the volatilized resin  condenses  in the  atmosphere  to form  a particulate,

but some breaks down to form VOC.

     Coating resins may be dissolved  in  a  variety  of solvents.  Cresylic

acid and various cresols  are major solvents.  Xylene and mixtures  of  Co  -  C1?

aromatics are widely used also.  The  following solvents  are  used  to some

degree.

             Cresylic acid                 Hi-Flash naptha
             Xylene                        Methyl  ethyl  ketone
             Alcohols                      N-methyl pyrrolidine
             Cresols, meta para            Ortho  cresol
             Diacetone alcohol             Phenol
                                 Toluene
                                   1-5

-------
     Cresols have a strong disagreeable  odor which  is  usually noticeable



inside a wire coating plant.   This  odor  has been one  incentive for many



operators to install  combustion systems  to avoid complaints.
                                   1-6

-------
1.3  REFERENCES

1.   Johnson,  W.  L.,  U.S.  Environmental  Protection Agency, Research Triangle
    Park,  North  Carolina.   Report  of Trip  to Westinghouse Wire  Division
    Plant  in  Abingdon,  Virginia.   Report dated  February  10,  1977.
                               1-7

-------
           2.0  APPLICABLE SYSTEMS  OF  EMISSION  REDUCTION



2.1  INCINERATION (COMBUSTION SYSTEMS)

     Incineration is the most common technique  used  to  control  emissions

from wire coating ovens.  Since these  ovens  operate  at  high temperature

(greater than 350°Cj and have moderate to  high  solvent  loads  (10  to  25

percent LEL) they provide a favorable  situation for  incinerator.   Because

the oven exhaust is relatively hot, little additional fuel  is needed to

reach the solvent combustion temperature.  Furthermore,  the fuel  value of

the exhausted solvent may be high  enough that  little extra  fuel is required

to heat the oven.  Combustion systems  have been variously referred to as

incinerators, afterburners and oxidizers.  For further  details  on the theory

of incineration, see Chapter 3 of "Control of  Volatile  Organic  Emissions

from Existing Stationary Sources -  Volume  I: Control Methods  for  Surface-

Coating Operations."

     The four basic types of incinerators  are:

                             Internal  catalytic
                             External  catalytic
                             Internal  thermal
                             External  thermal

     Figure 3 shows a diagram of an internal catalytic  incineration.  (This

drawing is  simplified for illustrative purpose; most ovens  have two drying

zones.)  The catalyst is built as an integral  part of the oven.   Hot

solvent-laden air from the drying chamber is circulated past  the  catalyst;

combustion  of solvents takes place in the presence of the catalyst at  260°C
                                 2-1

-------
                           EXHAUST
  SOLVENT
EVAPORATION'
   ZONE
   WIRE
  COATING
    DIE
                                     RECIRCULATING
                                         FAN
                                        FRESH AIR
                                     CATALYTIC
                                      ELEMENT
                                   BURNER
   Figure 3.  Wire coating oven with internal catalyst.
                              2-2

-------
to 320°C.   If the hot air from the  drying  chamber is  in  this  temperature



range, the oven operation may be self substainiruj.   If not, a supplementary



burner (electric or gas-fired) is used to  raise  the  solvent-laden  gases to



the combustion temperature.   The gases leave the catalyst  at  450°C,  and



are recirculated back through the curing zone.



     Internal catalytic incinerators were  first  introduced in the  late



1950's.   All  major wire oven designers now incorporate metal  catalysts  into



their new ovens.  A representative of one  major  manufacturer  stated  that


                                                                          2
every wire oven built by his firm since 1960 has had an internal  catalyst.



     There are three reasons why internal  catalysts  are so popular:



     1.   The internal catalyst burns solvent fumes and recirculates  the



heat back into the wire drying zone.  Fuel otherwise needed to operate



the oven is eliminated or greatly reduced.



     2.   Since the gases are cleaned and recirculated within  the oven,



less makeup air is required.  This results in further energy  savings.



     3.   Catalysts are reported to be to 95 percent efficient in destroying


         3 4
solvents. '   However, others report that catalysts are only  75 to 90  percent



efficiency, since efficiency drops off as  the catalyst gets dirty.  Air



pollution control has been of secondary importance to wire coaters;  energy



conservation is most important because of resultant cost savings.



     An oven equipped with an external catalyst  is shown in Figure 4.   This



type of modification is usually made to older wire coating ovens that  do



not have an  internal catalyst.   The external catalyst system is added primarily



for pollution control since the heat is not as easily recovered.
                                     2-3

-------
              HOT CLEAN
              EXHAUST
                                  WIRE
                                 COATING
                                  OVEN
Figure 4. Wire coating oven with add on catalytic incinerator.
                         2-4

-------
     A serious impediment to the future use of catalytic  incinerators



as air pollution devices for wire coating  ovens is  that some  of  the newer



wire coatings, primarily polyester amide-imides,  act  as a catalyst poison.



Ordinarily, a wire coating catalyst can be used for 10,000 hours, but  some

                                                         o

coatings reduce the useful life to as little as 60  hours.   However,



experimental  catalysts are being developed which  reportedly  operate for


                                                                9
3,000 hours and possibly much longer using amide-imide coatings.



     Polyester amide-imide coatings have superior temperature resistance



and allow electrical equipment to operate  at higher temperatures, a  very



desirable quality.  Wire coating plants which convert to  these coatings  will



be unable to use catalytic incinerators and will  likely use thermal



incinerators for air pollution control.



     A simplified drawing of an internal thermal  incinerator  (oxidizer)  is



shown in Figure 5.  Solvent-laden gases from the drying zone  are drawn past



the thermal oxidizer where they are combusted with 98 percent efficiency.



The hot clean gases are then recirculated back to the drying  zone.   This



type of incinerator has not been popular with wire coaters, reportedly



because of high fuel usage.



     External thermal incinerators are used mainly for air pollution control



Usually the discharge from 10 to 15 wire ovens are manifolded to each



incinerator such that the total volume is 250 to 450 dscm per minute.



Usually the inlet to the  incinerator is preheated by contact  with  the



incinerator exhaust gases (primary heat exchange).  Secondary heat  recovery



systems are also employed on many large existing installations,  principally


                  II 12
for space heating.   '
                                  2-5

-------
                            EXHAUST
  SOLVENT
EVAPORATION
   ZONE
      WIRE
                                      RECIRCULATING
                                           FAN
                                    FRESH AIR
                                   OXIDIZER
                                 BURNER
                       COATING DIE
       Figure 5.  Wire coating oven with internal
       thermal oxidizer.
                          2-6

-------
2.2  CARBON ADSORPTION



     Carbon adsorption is not used as  a  control  method  in this  industry



for several reasons:



     }.   Wire ovens  exhaust at 200°C to  380°C.   The  gases would have to



be cooled to 38°C before adsorption would be  effective.



     2.   Resins volatilized in the oven  would tend to foul  the  carbon bed



and create maintenance problems unless (or even  if)  prefilters  were employed.



     3.   Since collected solvent mixtures would  not  be  reused  in  the process,



the recovery credit  is relatively small.





2.3  LOW SOLVENT COATINGS



     Low solvent coatings offer only  a potential alternate  way  of reducing



solvent emissions.  Unfortunately, low solvent coatings have not  yet been



developed with the properties that will  meet  all wire coating  needs.



     Water-borne wire coatings, the most advanced low solvent  technology,



are being used in small quantities.  One plant reportedly  coats 10 percent



of its production with water-borne coatings.   These  however, are  not



available with properties suitable for all wire coating applications.   High



temperature resistance is not as good with water-borne  wire coatings.



     Powder coatings have been applied to wire on an experimental basis.



A  powder coating  line at the Westinghouse Wire Division plant  (Abingdon,



Virginia) was  featured in Products Finishing magazine  in February 1975.



Westinghouse has  been experimenting with powder coatings since 1967.   Powder



coating applications have been limited for the following reasons:
                                   2-7

-------
     1.   Epoxy powders are the main type available;  unfortunately,



the upper temperature range for an epoxy coating  is  only  130°C whereas



many types of electrical  equipment must  operate at temperatures  up to


      14
220°C.



     2.   Powder can be used only on larger diameter  wires.   For  finer wire,



the powder particle approaches the wire  diameter  and will  not  adhere well



to the wire.



     Several other types  of low solvent  wire coatings are  in the experimental



stage.   Hot melt coatings, which are applied as a molten  mass  and have  no


                                                           15
solvents, have reportedly been used successfully  in  Europe.    Ultraviolet



cured coatings are now available for specialized  systems.   Electrodeposition



coatings are theoretically possible, but once a layer of coating is applied



to the wire, the surface  is insulated against further electrodeposition.



Thus, thick films cannot  be built up.
                                    2-8

-------
 2.4   REFERENCES

 1.   "Control of  Volatile Organic Emissions from Existing Stationary
     Sources  -  Volume  I: Control Methods for Surface-Coating Operations,"
     U.S.  Environmental  Protection Agency, EPA 45-/2-76-028, November 1976.

 2.   Richards,  R.D., General Electric  Industrial Heating Business Department,
     Shellyville,  Indiana.  Telephone  conversation with W. L. Johnson, EPA
     on  April 20,  1977.

 3.   Ruff,  R.J.,  Catalyst Application  to Continuous Strip Ovens, Wire and
     Wire  Products, October 1959.

 4.   Bolduck, M.J., and  Severs,  R.K.,  A Modified Total Combustion Analyzer
     for Use  in Source Testing Air Pollution, Air Engineering, August 1965.

 5.   Spires,  E.T.,  Westinghouse  Electric Corporation, Abingdon, Virginia.
     Letter to  W.L. Johnson, EPA.  Dated November 1,  1977.

 6.   Ruff,  R.J.,  Catalytic Combustion  in Wire Enameling. Wire, October 1951,
     Page  936-940.

 7.   Brewer,  Gerald L,,  Air Correction Division of UOP, Darien, Connecticut.
     Telephone  conversation with W.L.  Johnson, EPA on April  18, 1977.

 8.   Ibid

 9.   Brewer,  Gerald L.,  Air Correction Division of UOP, Darien, Connecticut.
     Letter to  W.L. Johnson, EPA, dated October 19, 1977.

10.   Acrometal  Products, Inc., Bulletin DTOO-874.

11.   Johnson, W.L., Environmental Protection Agency,  trip  report on
     Westinghouse Wire Division  plant  in Abingdon, Va.  Report dated
     February 10, 1977.

12.   Kloppenburg, W.B.,  Springborn Laboratories,  Inc.  Report of trip to
     Chicago Magnet Wire in Elk Grove Village,  Illinois,Dated April  9,  1976.

13.   Powder Coating Used as  Insulation for Magnet Wire, Products Finishing,
     February 1975, pages  94-95.

14.   Op. Cit.   Johnson,  Febraury 10,  1977.

15.   Owen, Jim, Sales  Manager,  Michigan Oven  Company,  Romulus, Michigan.
     Telephone  conversation with W.L.  Johnson,  EPA on April  20, 1977.
                                   2-9

-------
                           3-0   COST ANALYSIS

3.1  INTRODUCTION
3.1.1  Purpose
     The purpose of this chapter is to present estimated costs for control
of volatile organic compound (VOC) emissions from wire coating lines at
existing magnet wire coating plants.
3.1.2  Scope
     Estimates of capital and annualized costs are presented for controlling
solvent emissions from drying ovens of existing magnet wire coating lines using
external (add-on) catalytic and thermal incinerators.  Control costs are
developed for four model sizes - one, five, 10 and 15 ovens per incinerator.
Each oven is medium size with emission exhausts averaging 28 dscm per minute
and production averaging 690 Mg per year of wire coated.  Incinerators are
costed with and without solvent heat recovery.  Cost effectiveness ratios
(annualized costs per megagram of solvent emissions controlled) are shown for
the single and multiple model oven configurations.
     Most wire coating ovens built since the early 1960's have built-in
                        1 2
(internal) incinerators. '   Since this report is concerned with
existing facilities, control costs of internal catalytic and thermal
incinerators are not included.  Other techniques, such as carbon adsorption,
are not costed since they are not used as control methods in the wire coating
industry (see sections 2.2 and 2.3).
                                 3-1

-------
3.1.3  Use of Model Emission Points
     Wire coating plants vary considerably as to the number and type of
ovens; the size, type and speed of wire processed; the types of coatings
applied; and the number of ovens per incinerator. ' ' ' '   Since an actual
plant is likely to have significantly different control costs than another
actual plant and the wide variety of installations reduces the applicability
of a model plant, the use of model emission points becomes a necessity.
Therefore, the cost analyses in this chapter are based on model emission
points - single and multiple drying oven models.  The technical parameters
used for the model ovens have been selected to represent typical operating
conditions at actual wire coating plants and are listed in Table 3-1.
Although model oven control costs may differ with actual costs incurred,
they are the most convenient means of comparing the relative costs of control
options.
3.1.4  Bases for Capital and Annualized Cost Estimates
     Capital cost estimates represent the total investment required to
purchase and install a particular control system.  Cost estimates were
obtained from EPA contractor reports, equipment vendors and plant installa-
tions.  Retrofit installations are assumed.  Costs for research and
development, production losses during installation and start-up, and
other highly variable costs are not included in the estimates.  All capital
costs reflect second quarter 1977 dollars.
     Annualized control cost estimates include operating labor, maintenance,
utilities, and annualized capital charges.  Reduced fuel (utility) costs are
based on 35-501 primary heat recovery for the incinerators with heat exchangers.
                                  3-2

-------
                   Table  3-1.  TECHNICAL PARAMETERS USED  IN
                              DEVELOPING CONTROL COSTSa
   I.   VOC  Emission  Rate:           12  Kg/hr.

  II.   VOC  Concentration:           15% LEL

 III.   Average  Exhaust  Flowrate    28  dscm/min.      (990  dscfm)

  IV.   Exhaust  Temperatures:

           Catalytic Incineration:   260° C  to  450°C (500°F to 842°F)

           Thermal  Incineration:     760°C   (1400°F)

   V.   Incineration  Residence  Time:  0.5  sec.

  VI.   VOC  Control  Efficiencies:

           Catalytic Incineration:   90%

           Thermal  Incineration:     90%

 VII.   Heat Recovery Efficiencies:0

           Catalytic:                35-45%  (Primary)

           Thermal:                  35-50%  (Primary)

VIII.   Operating Factor:             7000 hours/year

  IX.   Average  Densities:

           Solvent:                  0.882  Kg/liter (7.36 Ib/gal.)

           Coatings:                1.138  Kg/liter (9.5  Ib/gal.)

   X.   Ratio of Uncontrolled Solvent Emissions to
       Wire Production:e

           Average Uncontrolled Solvent Emissions  _ 10.9  Kg
           Average Wire Production                    100  Kg
 Except as noted, values are taken from Chapter 2.

bEPA estimate.
cReferences  7 and 10.

 Reference 3.
Reference 9.
                                   3-3

-------
     The annualized capital  charges are sub-divided into capital  recovery
costs (depreciation and interest costs) and costs for property taxes,
insurance and administration.   Depreciation and interest costs have been
computed using a capital  recovery factor based on a 10 year depreciation
life of the control equipment and an interest rate of 10% per annum.  Costs
for property taxes, insurance and administration are computed at 4% of
the capital costs.  All annualized costs are for one year periods commencing
with the second quarter of 1977.

3.2  CONTROL OF SOLVENT EMISSIONS FROM WIRE COATING OPERATIONS
3.2.1  Model Cost Parameters
     Control costs have been developed for four model sizes using each of
the following incineration devices:  catalytic incinerator without heat
exchanger; catalytic incinerator with heat exchanger; thermal incinerator
without heat exchanger; and thermal incinerator with heat exchanger.  All
incinerators are external (add-on) units.  Table 3-2 presents the cost
parameters for each of the four model sizes.  These parameters are based
upon studies of the wire coating industry by contractors and the EPA.
3.2.2  Control Costs
     Table 3-3 presents control costs for the single oven model (one oven
per incinerator) using four different external control devices:  catalytic
incinerator with and without heat exchanger, and thermal incinerator with
and without heat exchanger.  Similarly, Tables 3-4, 3-5, and 3-6 present
control costs of the four control devices for the 5-oven, 10-oven and
15-oven models.  Very  high installation costs  (75-90% of equipment costs)  have
been allowed for all multiple oven models to provide for additional costs  of
                                3-4

-------
                               Table 3-2.   COST PARAMETERS USED IN COMPUTING ANNUALIZED  COSTS
I
en
Model
I
II
III
IV
Number of
Ovens per
Incinerator
1
5
10
15
Emission Flowrates
Before Control
dsnr/min.
28
140
280
420
(dscfm)
(990)
(4950)
(9900)
(14850)
Average Wire
Production
Mg/Yr.
690
3,450
6,900
10,350
(1000 Ib/yr.)
(1520)
(7600)
(15,200)
(22,800)
          Chapter 2.

         Average wire production  from References  8,  9,  and  11;  actual wire  production will vary and depends on the
          size and speed of the wire,  the  number of wires  per  oven and the number of passes through the oven.

-------
                                      Table  3-3.
 CONTROL  COSTS  FOR  MODEL  I  (one oven per  incinerator;
 28 dsm /min. emission flowrate before control)
 Installed Casual  Cost ($000)
 Direct Operating Cost ($000/yr)

 Annualized Capital  Charges ($000/yr)

 Total Annual ized Cost {SOOO/yr)03

 Solvent Emissions  Controlled  (Mg/yr) e

 Cost per Mq  Emissions Controlled  (S/Hg)


                                     Table 3-4
n
External Catalytic Incinerator
with Heat Exchanger
60.0
5.4
12.2
17.6
75.6
Without H. E.
39.6
12.2
8.0
20.2
75.6
235 265
i
External Thermal Incinerator
With Heat Exchanger
50.0
10.3
10.1
Without H.E.
30.0
24.5
6.1
20.4 ! 30.6
!
75.6 75.6
270
405
CONTROL COSTS FOR MODEL  II  (Five  ovens  per  incinerator;
140 dsm3/min. emission  flowrate before  control)


Installed Capital Cost ($000)h
Direct Operating Cost ($000/yr)
Annualized Capital Charges (S000/yr)c
Total Annualized Cost (S000/yr)d
Solvent Emissions Controlled (Mg/yr)
rf
Cost per Hg Emissions Controlled .($/Hg )'
External Catalytic
With Heat Exchanger
140.0
22.5
28.4
50.9
378.0
135
. Incinerator^
Without H.E.
105.0
45.0
21.3
66.3
378.0
175
External Thermal
With Heat Exchanger
135.0
40.0
27.4
67.4
378.0
180
ncinerator
Without H.E.
100.0
80.0
20.3
100.3
378.0
265
 References 2, 7, 8, 11, 12 and 13; high installation costs (65% to 70? of purchased equipment costs) have been allowed.

 Average annual operating and maintenance costs per References 7 and 10, assuming the use of natural  gas and electric
 energy.  The multiple oven model costs have been compared with References 14 and 15.

 Capital recovery costs (using capital recovery factor with 105, interest rate and 10 year equipment life)  plus 4% of capital
 costs for property taxes,  insurance and administration.
 Sum of Direct Operating Cost and Annualized Capital Charges.

'Product of Uncontrolled VOC Emission Rate times Operating Factor Times Control  Efficiency.
 Total Annualized Cost divided by the Solvent Emissions Controlled.

sCatalysts assumed to have  normal  replacement lives and will  not become prematurely  poisoned by metallic coatings.

Average installed capital  costs  per References 10, 14, 15, and 16;  very high installation costs (75% to 90% of purchased
 equipment costs) have been allowed to provide for additional  costs  of  ducting,  controls,  lines, auxiliary equipment and
 some supporting  structures.

-------






,.
o
4-J
t_
QJ

II

I- 0
l/> S-
c o
QJ 4-
Q XI
O CJ
r— 4-J


D~« ^
*— 4 O

4— L

IU C
o o
O '•"
yr in
(X '•"
£ o
00 -
t- ^
1>O '»"
O E;

„> H
O ^
Cf^ "O
t~
CD CO
CJ CvJ


in
i
m .
CJ
••a
1 —
























7)
p

QJ
±
U
tr:


1

c:

a
X
LU












.




"
t t


.




•^
























0 0 r—
co Ln uj









O O kO
OO*3-
CM r-« *d~
CM
















O O ir
Ln r— If"
r^ co r--









O O •-£
to O u
OJ









u
! 1
J^ i

O "v-^ ••»
C3 O
C> C)
ty> C )

O in <.
CJ O
CJ r
rj CD
4-> t:
CX *->
o i-
OJ
XJ Ci.
QJ O

•— u
4~> QJ
t: -*~


C15
r - tO O
co m -^
r— r-- c\j








IO CJ
*^ to o
r— VT> LO f
r- r- r~ |
















in o
10 IQ in
» ,— IT> r—









3 UD O
•> in ia i^">
r ao LO '"







[
1
! ,--.
aj ^:>
^ ; ^ ?"-
3 XJ en -Tj
D — ac c.;
Z> S-. ----- r—
*> >> < —
o aj k
^ C? i — 4-'
u CD r— r:
y> *» o c;>
T3 4-'
j m 6 (
O CJ <.-
t-* X3 c: i-i
CJ 0
rx M -r-- f
nj ••— i/i U(
_> r- l/l
rO T- f • n
o T f :-
OJ C L.I
r- -'C •*-» «'
r — C~ . :•-
*O r— OJ

C -»-* *- - '-'
c: o o CP
tf ] — cy> ^ >







S_
o
i-
QJ
U O
C t-

t.:
i.. o
OJ U
o,
OJ
t/5 --
i.^ O
> "S
0 XI
i-n oj

— - nj
l~

»— • O


LU
O C

E. •'"•
ID:' tn
LU E
QJ
I— C
O £:

_J°K
O in
cr! XJ
K^
O CM
CJ *3"


UJ
1
r^
£1






I









-






V--
3
y

c

o
tz


i
QJ

c:
t-

x
LL











01

_;
'


*'
^






<3
"(0



lj-


,















c>

cl ° "^ '^ ?>
o o jar g r- ui
C\J OJ OJ i — OJ






0

° ° °I °I n
in oo 10 f^ *— "^
oj en VD U3 - «d-
n i— r— i— 1
















o
° ° ^ "^ s
O r^. O 10 •— L^
LO r- ID l£ ^- ^








0 |
•I
CD o en o\ ' «*•
n
uo LT> co oo r-— m
r— CO <.Q i — * CD
prj r^ r_ r—






•

1
^ '
1 CJt
Ol O' 2C .
1 t. ! "S ^
• O XJ C7» XI
x: "v* § ^ ^ •—
CD ~^ •*-* ^^, X> O
CD CD O OJ V-
CJ CD 10 O r- 4J
*x> cj cu o •— c:
^ 	  CJ> V> O O
	 J- •— 1, 0
4J AJ -4 *
o in CJ in o c,
(JO 0 CJ 0
l_J r— CJ •*-
, 	 . n\ m in
rts en 4-> X) c: *n
+_> c: -i- QJ o •£
-,- r- fX fvj **- E
cx -»_> «j •*- in LU
*O rtj O *" V)
CJ S_ 
QJ -o :•> ir: ^"
xj o- OJ L: L»J
QJ O 1st t^ t-
. — -r- *a; 4> cu
^.. <_» ^- c; o-
»O CJ nj « — QJ
*-> QJ n rtl >• 4-*
C -r- C O O O
v-* o -^: t— t/o cj

1







I
























































1


03

•r- TJ
CX C, XJ
«o i/i c:
CJ 1TJ fO
•»-«*- CJ 4-»
X- 0 U C
4J * ~i CJ
O »« tn cx B

cr cx oo
*O" O C~V >i
m oj o o its
en -i- f^ r^
f— ro in x

t- c: oj C^ 5
ra QJ E
4-> K VI "
«3 CX >, 4-» in
c i— JQ m o>
n o c:
«~ cr xj o -r-
O OJ • OJ > —
>» c c:
OJ t. O O 0 *
in rj c. vi -r- in

>> *r~ O rO O
OJ • O O- r— 1-

^j ,__ r_ i|__ ^ ^3 (--
4- f— 4-» O
cn xi t? UJ OJ  4-* E Cn-r~
ny m s~- o s- jc o
OJ O CX t3
- CJ 4-» >,XJ
O C in in QJ t_
»~ OJ OJ Q> E QJ **-
t_ V- E O > O
XT Q> OJ v- CJ
«y o* c xj xi 10 4->
CXI T-~ 5- flj r— V)
r-» o r— 4J o
_C Vt 4-> i — O XJ CJ
. *n 4-* CD O O C C
cj 3: vt u. 4-> •— «
c: x: o c: *— - c:
OJ I- 3z • 
4- to c: .c: 4J tn X3 »f-
O 4-> +J r— QJ -»- rtj
JL-CJOfdrOCXVlin "
OJ fO!L-4->CDV)rUOV.
oj v> o_ in E •*- H~
W1QJ >>••- (13 OJLiJr- in
VI CJ 1— -r- 4J 4J CJ XJ
o OJ > G xj +-* cz c d •»"-
O>OXJQ; OJCJQJ>
O> JZ O) •*•- 4-> i— - OJ CD V-
U *- "t3 *-- 
OJO4-Jaj c o_c o t-
4JO-r-CJ i- QJXJ
C CX C to CX QJ
"ra'aj 32^-^^*^ i/>§
E^ cn5^ ^LUXJ E"M<~
tJEEcz^c:^ OJOO^d
QJ 13-CJ^» > OJ »— OJ GJ
Cn > * — * in «f— >• 

nj p — V> -»J +J r— V) O <\J > 13
j-cxo ro o O-M cjtis-
oj •*- u >, i- j- o .c: 4->
CX 4-> 4-J CJ -M X) XJ in
Or— >» t- fX C XI QJ QJ — x
r» t-aio o QJ p, — men
i — F; QJ O- o M :a «~- 4~> c
rti > o " 4-> c: -t— tn rj  c; Q

ft) CJ> 4-J (/> O ^1 i — r— ru CX
CJOJ* O-in C: O 4-» 4-» CJ^FS
>C «3O 13 5V- O rtl >CTO
•-C OJ CJ U IX) CX 1— CJ-
-------
ducting, controls, lines, auxiliary equipment and some supporting structures;
while high installation costs (65% to 70% of equipment costs) have been
allowed for the single oven model.  Wherever possible, the cost estimates
have been compared with industry costs.2,8,11,12,13,14,15,16  But, it is
recognized that control costs of actual installations may vary from the
estimates.
     The solvent emissions controlled per year are determined as the un-
controlled VOC emission rate times the operating factor times the control
efficiency.  For example, the single oven model solvent emissions controlled
are calculated as (12 Kg/hr) (7000 hrs/yr) (.90) = 75,600 Kg/Yr.  The cost
per Mg of controlled emissions is the total annualized cost divided by the
solvent emissions controlled, or $17,600/75.6 Mg = $235 per Mg for the single
oven model using catalytic incineration with heat recovery.
     As evidenced by the estimates, the catalytic incinerators, both with
and without heat exchangers, have lower operating costs than the corresponding
thermal devices.  The catalysts cause combustion to occur at lower temperatures,
thus requiring less fuel than the thermal devices.  These costs assume that
the catalysts will have normal replacement lives and will not become pre-
maturely poisoned by metallic coatings (see  Section 2.1).  Also, for each
model size, the incinerators with heat exchangers have higher capital costs
and lower operating costs than those without heat exchangers.  This relation-
ship is due to the additional capital cost of the heat exchangers  (and
auxiliary equipment) and the resulting fuel  savings obtained from 35 to  50%
primary heat recovery.
3.2.3  Cost Effectiveness
     Figure 3-1 graphically depicts the estimated cost-effectiveness of  the
four external control devices for the four model sizes.  For the convenience

-------
                                        Figure 3-1.  Cost-effectiveness of VOC Emission Control
                                                     of Wire Coating Ovens
           400
oo
I
     O)
     O
CO
c
O
•I —
LO
    €
    f>
           300
                     28


                    75.6


                     690
                                                      SYMBOLS:

                                                      External  thermal  incinerator without  heat  exchanger

                                                      External  thermal  incinerator with  heat  exchanger

                                                      External  catalytic  incinerator without  heat  exchanger

                                                      External  catalytic  incinerator with heat exchanger
                                                                     280
                                        Average Emission Flowrate (dsm /min.)
                                      378.0                         756.0

                                        Average Emissions Controlled (Mg/yr.)

                                      3,450                         6,900

                                        Average Wire Production (Mg wire coated/yr.)
   420


 1,134.0


10,350

-------
of the user, several  different measures (average emission flowrates,
average emissions controlled, and average wire production)  have been
plotted on the horizontal axis.
     It should be noted from the cost-effectiveness curves that, for  all
model sizes, the external catalytic incinerator with heat exchanger is
the most cost effective device.  Also, control costs per Mg of controlled
emissions are lower for multiple oven models and appear to level off  at
the 10 and 15 oven models.  Thus, the lowest cost emission control  system
is the 15-oven catalytic incinerator with heat exchanger; the costs of this
system are estimated to be $105 per Mg of emissions controlled.  If a
catalyst cannot be used because of poisoning or other reason, then  the
lowest cost system is the 15-oven thermal incinerator with heat recovery,
at an estimated cost of $145 per Mg of emissions controlled.  The highest
cost device is the single-oven model thermal incinerator without heat
exchanger at an estimated cost of $405 per Mg of emissions controlled.
                             3-10

-------
 3.3   REFERENCES

 1.   G.  L.  Brewer,  Air  Correction  Division  of UOP, Darien, Conn.  Letter
     to  W.  L.  Johnson,  U.S. EPA, dated April 19, 1977.

 2.   R.  D.  Richards,  General  Electric  Industrial Heating Business Dept.,
     Shelbyville,  Indiana.  Telephone  conversation with W. L. Johnson,
     U.S.  EPA, on  April 20, 1977.   Memo  to  file by R. A. Quaney, U.S. EPA
     dated August  31, 1977.

 3.   General  Electric Wire  Enameling Systems Bulletin GEA-10402, June 1977.

 4.   Kloppenburg,  W.  B., Springborn Labs.   Report of Trip to Chicago Magnet
     Wire  in  Elk   Grove Village,  Illinois,  dated April 9, 1976.

 5.   Kloppenburg,  W.  B., Springborn Labs.   Report of trip to General Electric
     Co.,  Schenectady,  New  York,  dated April 6, 1976.

 6.   Johnson,  W.  L.,  U.S.  EPA.   Report of trip  to Westinghouse Wire Division
     Plant, Abingdon, Virginia,  dated  February  10, 1977.

 7.   Kinkley,  M.  L. and Neveril,  R. B.,  Capital and Operating Costs of
     Selected  Air  Pollution Control Systems.  Prepared by GARD,  Inc. Niles,
     111.   for U.S. EPA, Contract  No.  68-02-2072, dated May, 1976.

 8.   Wire  Coating  Emission  Control  Costs, Section VIII.  Interim Report
     prepared  for  U.S.  EPA  by Springborn Labs., Enfield, Conn., dated
     November 12,  1976.

 9.   Wire  Coating  Organic Emissions Estimates,  Chapter IV.   Interim Report
     prepared  for  EPA by Springborn Labs, Enfield, Conn., dated January 13, 1977.

10.   Fuel  Requirements, Capital  Cost and Operating Expense For Catalytic
     and Thermal Afterburners.   Report prepared for U.S. EPA by CE Air
     Preheater, Industrial  Gas  Cleaning  Institute, Stamford, Conn., Contract
     No. 68-02-1473,  dated  September,  1976.

11.   Owens, J., Michigan Oven,  Romulus,  Michigan.  Memo to file by R. H.
     Schippers, U.S.  EPA, dated August,  1977.

12.   Kloppenburg,  W.  B., Springborn Labs.   Report of trip to Rea Magnet
     Wire  Co., Ft.  Wayne, Ind.,  dated  March 17, 1976.

13.   Kloppenburg,  W.  B., Springborn Labs.   Report of trip to Phelps Dodge
     Magnet Wire Co., Fort  Wayne,  Ind.,  dated April 7, 1976.
                                  3-11

-------
14.   E.  T.  Spires,  Westinghouse Electric  Corp.,  Abingdon, Va.  Letter to
     W.  L.  Johnson, U.S.  Environmental  Protection  Agency, dated November
     1,  1977.   Memo to file by R.  A.  Quaney,  U.S.  Environmental Protection
     Agency,  dated  December 1, 1977.

15.   J.  L.  Phillips, Essex Group,  Inc.,  Ft. Wayne  Ind.   Letter to  W. L.
     Johnson,  U.S.  Environmental  Protection Agency,  dated November 2, 1977.
     Memo to  file by R.  A. Quaney, U.S.  Environmental  Protection Agency,
     dated  December 6, 1977.

16.   G.  L.  Brewer,  Air Correction  Division of U.O.P.,  Darien, Conn.;
     letter to W. L. Johnson,  U.S. Environmental Protection  Agency,
     dated  October 19, 1977.   S.  Olson,  Air Correction  Division of U.O.P.,
     Darien,  Conn.; memo to file by R.  A. Quaney,  U.S.  Environmental Protection
     Agency,  dated November 29, 1977.
                             3-12

-------
         4.0  ADVERSE AND BENEFICIAL EFFECTS OF APPLYING  TECHNOLOGY







4.1   BENEFICIAL EFFECTS



     About 29,500 metric tons of solvents are used in the insulation varnishes,



including wire coatings, each year.    Much of this is now burned within  drying



ovens sincemost wire coating ovens installed since 1960 have internal



catalytic incinerators.  This type of oven has grown in popularity because



it utilizes the heat of combustion of the exhaust gases,  eliminates



malodors and avoids buildup of flammable resins in the stack.   However,



the catalysts in many of these catalytic incinerators may have been  poisoned



or have lost reactivity.  Also, some older ovens have no  controls at all ,



so there is no way to know how much solvent is actually emitted.



Unquestionably, however, uniform application of control restrictions would



effect a reduction in emissions.





4.2  ADVERSE EFFECTS



     Wire coating ovens are generally built with a catalyst within the



oven thereby taking advantage of the heat of combustion of the coating



solvent to reduce fuel requirements.  Where an external afterburner must



be retrofitted, however, the oven system may not be designed to benefit



by the heat made available.  Conseqaently, the fuel requirements for



operating the line would increase.
                                4-1

-------
4.3  REFERENCES

1.   "Sources and Consumption of Chemical  Raw  Materials  in  Paints and Coatings
    by Type and End Use," 1974.   Prepared for National  Paint  and Coatings
    Association, Incorporated by Stanford Research  Institute, Menlo Park,
    California.
                                   4-2

-------
           5.0   MONITORING  TECHNIQUES AND  ENFORCEMENT ASPECTS


     The suggested emission limitations will  probably be met with an
incinerator.   Wire ovens  are enclosed and  hooding  should be designed to
capture and direct essentially all  solvent to the  incinerator.  The main
problem of the  control  official  is  determining that  the incinerator is
operating correctly.   A measurement of  combustion  efficiency across the
incinerator could be required when  the  unit is installed.   (One test may
be adequate when several  identical  units are installed.)
     A thermal  incinerator which shows  a high combustion efficiency will
probably continue to perform well  if operated under  the same temperature
conditions.  Normally,  a temperature indicator reading  in  the  combustion
chamber is sufficient to monitor proper operation.   For catalytic incinerators,
the temperature rise across the catalyst bed should  be measured during the
test for combustion efficiency.   This  temperature  rise  reflects the activity
of the catalyst.
     Wire oven  catalysts normally have  a  finite life of 6,000  to  14,000
hours.  The plant should be required to replace catalysts  after 10,000  hours
of operation unless the plant can document that the  catalysts  will operate
longer.  Catalysts which are exposed to polyester amide  imide  coatings  may
become deactivated in as little as  60 hours.  Thermal  incinerators should
be required to control  coatings which  poison catalysts.   Catalyst performance
can be monitored by temperature indicator.
     There are several  techniques for testing the efficiency  across an  incin-
erator.  For a more detailed discussion of organic compound test  methods,  see
Chapter 5, "Approaches to Determination of Total Nonmethane Hydrocarbons",
in Volume  I of this series.
                                   5-1

-------
5.11   REFERENCES

1.  "Control  of Volatile Organic Emissions from Existing Stationary Sources -
   Volume I: Control  Methods for Surface-Coating Operations," U.S. Environmental
   Protection Agency, EPA 450/2-76-028, November 1976.
                                  5-2

-------
                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
    °WAN°450/2-77-033
                                                            3 RECIPIENT'S ACCESSIOI*NO.
4. TITLE AND SUBTITLE
 Control of Volatile Organic Emissions from Existing
 Stationary Sources  - Volume IV:   Surface Coating  for
 Insulation of Magnet Wire
             5. REPORT DATE
               December  1977
             6. PERFORMING ORGANIZATION CODE
7 AUTHOR(S)
9 Pt HF (JRMING ORGANIZATION NAML AND ADDRESS
 U.S. Environmental  Protection  Agency
 Office of Air and  Waste Management
 Office of Air Quality Planning and Standards
 Research Triangle  Park, North  Carolina 2771]
                                                            8. PERFORMING ORGANIZATION REPORT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
                                                             OAQPS  No.  1 .2.087
                                                            10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.
                                                             13. TYPE OF REPORT AND PERIOD COVERED
                                                             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
           This  report provides  guidance for development of regulations to limit
      emissions  of volatile organic compounds  from magnet wire  coating operations,
      Coating  operations and  control  technology  are described.   Reasonably
      Available  Control Technology (RACT) is described for the  industry.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
      Air  Pollution
      Magnet Wire
      Wire Enameling
      Emission Limits
                                               b.IDENTIFIERS/OPEN ENDED TERMS  C.  COSATI Field/Group
  Air Pollution  Control
  Stationary Sources
  Organic Vapors
18. DISTRIBUTION STATEMENT

       Unlimited
19. SECURITY CLASS (This Report)
   Unclassified
                           21. NO. OF PAGES
42
                                               20. SECURITY CLASS (This page)
                                                  Unclassified
                                                                          22. PRICE
EPA Form 2220-1 (9-73)

-------
 ENVIRONMENTAL PROTECTION AGENCY
    General Services Division (MD-28)
        Office of Administration
Research Triangle Park, North Carolina 27711
     POSTAGE AND FEES PAID
ENVIRONMENTAL PROTECTION AGENCY
           EPA-335
           OFFICIAL BUSINESS
     AN EQUAL OPPORTUNITY EMPLOYER
                                Return this sheet if you do NOT wish to receive this material fll
                                or if change of address is needed [  |. (Indicate change, including
                                ZIP code.)
                              PUBLICATION NO. EPA-450/2-77-033
                                          (OAQPS No.  1.2-087)

-------