United States
Environmental
Office of Air Quality
Planning and Standards
EPA-453/R-02-006
February 2002
http://www.epa.gov/ttn/at
©EPA
National Emission Standards for
Hazardous Air Pollutants
(NESHAP) for Source Category:
Miscellaneous Metal Parts and
Products Surface Coating
Operations -- Technical Support
Document
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EPA-453/R-02-006
National Emission Standards for
Hazardous Air Pollutants (NESHAP) for Source Category:
Miscellaneous Metal Parts and Products Surface Coating Operations -
Technical Support Document
Emission Standards Division
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
February 2002
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Disclaimer
This report has been reviewed by the U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Emission Standards Division and approved for publication. Mention
of trade names of commercial products does not constitute endorsement or recommendation for use.
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ENVIRONMENTAL PROTECTION AGENCY
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR
POLLUTANTS (NESHAP) FOR SOURCE CATEGORY: MISCELLANEOUS
METAL PARTS AND PRODUCTS SURFACE COATING OPERATIONS - TECHNICAL
SUPPORT DOCUMENT
1. These standards regulate organic hazardous air pollutant (HAP) emissions from the surface
coating of miscellaneous metal parts and products. Only those miscellaneous metal parts and
products surface coating operations that are part of major sources under section 112(d) of the
Clean Air Act (Act) will be regulated.
2. For additional information contact:
Ms. Kim Teal
U.S. Environmental Protection Agency
Coatings and Consumer Products Group (C 5 3 9-03)
Research Triangle Park, NC 27711
Telephone: (919) 541-5580
E-MAIL: TEAL.KIM@EPAMAIL.EPA.GOV
3. Paper copies of this document may be obtained from:
U.S. Environmental Protection Agency Library (MD-35)
Research Triangle Park, NC 27711
Telephone: (919) 541-2777
National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Telephone: (703) 487-4650
4. Electronic copies of this document may be obtained from the EPA Technology Transfer
Network (TTN) over the internet by going to the following address:
http://www.epa.gov/ttn/atw/coat/misc/misc_met.html
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TABLE OF CONTENTS
Title Page
Purpose of Document 1-1
MACT Approach for Miscellaneous Metal Parts and Products 2-1
Development of Model Plants for the Miscellaneous Metal Parts and Products NESHAP 3-1
Available Add-on Control Devices for Use in the Miscellaneous Metal Parts and Products (MMPP)
NESHAP 4-1
HAP Emission Reductions, Non-Air Quality Health and Environmental Impacts, and Energy
Requirements for the Miscellaneous Metal Parts and Products NESHAP 5-1
Methodology for Estimation of Monitoring, Recordkeeping, and Reporting
(MR&R) Burden 6-1
Cost Impact Analysis for the Miscellaneous Metal Parts and Products NESHAP 7-1
Preliminary Industry Characterization: Miscellaneous Metal Parts & Products Surface Coating
Source Category 8-1
IV
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Purpose of Document
This Technical Support Document (TSD) provides background information to support the U.S.
Environmental Protection Agency's proposal of national emission standards for hazardous air pollutants
(NESHAP) for the miscellaneous metal parts and products (MMPP) surface coating source category.
It consists of a series of technical memoranda that were prepared during the development of the
proposed NESHAP. The memoranda that are presented here provide information on the approach
utilized to develop the MACT floors, the model plants, the projected impacts of the proposed
NESHAP, and a preliminary attempt to characterize the affected industries. The memoranda contained
in this TSD are intended to present the primary technical findings and analyses that the Agency used in
developing the rationale and decisions presented in the preamble to the proposed standards.
Additional supporting information, including the economic impact analysis for these standards, is also
provided in the project docket (Docket Number A-97-34).
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MACT Approach for Miscellaneous
Metal Parts and Products
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November 27, 2001
MACT Approach for Miscellaneous Metal Parts and Products
This document presents recommendations for the regulatory approach for the miscellaneous
metal parts and products (MMPP) surface coating source category, including the maximum achievable
control technology (MACT) floor and potential subcategorization. The intent of regulation of facilities
within the MMPP source category is to provide some level of emission reduction for a diverse
collection of sources not otherwise regulated under specific coating MACT source categories.
Because of the broad diversity of the products coated and the coating technologies and application
methods employed, identification of the top performing facilities in this category is inherently difficult,
especially since the control techniques that make these facilities top performers must be transferable to
other facilities in the category. Consequently, it has been necessary to employ innovation in developing
a regulatory approach for this category that provides significant emission reductions while being
applicable across the source category. The evolution of this innovative approach is explained below
through discussions of the various approaches pursued, the problems encountered, and the reasons for
their eventual abandonment. Finally, the document presents the project team's recommendations for
MACT floor determination, subcategorization, existing source MACT, and new source MACT
requirements that will be the framework for the eventual national emission standards for hazardous air
pollutants (NESHAP) for surface coating of MMPP.
Background
The MMPP surface coating source category includes facilities that coat metal parts and
products for which other specific surface coating MACT source categories are not applicable. This
source category comprises numerous diverse operations that apply surface coatings to metal parts and
products including, but not limited to, railroad cars, medical equipment, electronic equipment,
wheelbarrows, magnet wire, heavy duty trucks, hardware, power tools, pipes, structural steel, sporting
goods, lawn mowers, bicycles, auto parts, musical instruments, steel drums, army tanks, and industrial
machinery. The MMPP category is truly a "catch-all" source category. Although the industries in this
category generally fall into Standard Industrial Classification (SIC) codes 33 through 39, applicability
cannot be stated in terms of SIC codes, since SIC codes do not identify which facilities perform surface
coating. In addition, other coating MACT source categories (e.g., large appliances, metal furniture,
metal cans, metal coils, etc.) may cover portions of many of the same SIC categories, overlapping with
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MMPP. To complicate matters further, a wide variety of coating technologies and application methods
are employed across all these industry segments. Nationwide, there are thousands of facilities involved
in coating of MMPP, with an estimated 1500 or more being classified as major sources.
Add-on controls are relatively rare in the MMPP category. Only a handful of facilities
employing some sort of control device were identified through the data gathering effort. Therefore,
early on, it was anticipated that reduction of emissions of hazardous air pollutants (HAP) would be
achieved primarily through the use of low-HAP materials.
There are no existing federal or State regulations requiring control of HAP emissions from this
category. Reasonably available control technology (RACT) requirements have been in place for
reduction of volatile organic compound (VOC) emissions from this category since the late 1970s, and
may have resulted in some degree of coincidental reductions in HAP emissions. However, since the
RACT requirements generally apply only to facilities located in ozone nonattainment areas, and many
States have applicability thresholds for the RACT requirements, there are a great number of
unregulated MMPP facilities remaining.
Data Gathering Efforts
Data gathering involved industry surveys, site visits, consultation with State regulatory agencies,
and extensive interaction with stakeholder groups. Existing facility information available through the
Aerometric Information Retrieval System (AIRS) and the Toxic Release Inventory (TRI) database was
also useful in identifying facilities potentially falling within the MMPP source category.
In May 1998, a two-page screening survey was sent to approximately 3000 facilities tentatively
identified as MMPP operations. The results of the screening survey were used to identify major and
synthetic minor sources that perform coating operations on MMPP. This list was augmented with
names of facilities provided by trade associations and resulted in a list of 312 corporate owners to
whom a subsequent, more detailed survey was distributed.
The detailed survey was mailed in November 1998 to 312 corporations who operated major
or synthetic minor sources performing coating operations within the MMPP industry. This data
gathering resulted in responses from 639 major and synthetic minor sources. Of the
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facilities responding to the survey, only 332 submitted data of sufficient quality to perform some degree
of analysis on coating material usage.
In order to gain a better understanding of the processes and considerations associated with
surface coating of MMPP, the project team visited a number of manufacturing facilities. The team
made an effort to visit facilities representing a variety of industry segments. The industries visited
include heavy duty trucks, magnet wire, railroad cars, extruded aluminum, aerospace ground support
equipment, motorcycles, rubber-to-metal parts, steel drum recycling, defense equipment, and steel
joists. Reports documenting these visits will be part of the rule-making docket.
Previous Approaches Examined
The project team explored various approaches to determining the MACT floor and eventual
regulatory strategy based on the available information. These are summarized below, along with the
problems encountered and reasons for their eventual abandonment. From the outset, the industry
stakeholders and the various facilities were grouped into industry "segments" based on the type of
products coated. This was done to identify trends among the segments and to indicate whether one or
more segments were influencing the floor determination. It also enabled the stakeholders to more easily
check the results for their respective industry segments and give EPA feedback on the apparent
accuracy of the information reported. Furthermore, it provided a method of organizing meetings and
teleconferences for specific industry segments to provide more focused discussions.
Coating Scenario Approach
From the outset, the industry has stressed the importance of coating performance and how it
affects the functionality and appearance of the parts and products coated. Specifically these
considerations involve the specific performance characteristics (corrosion resistance, high gloss,
abrasion resistance, heat resistance, etc.) of the coatings. The project team believed that a reasonable
approach would be to organize the data by grouping similar coating operations based on the type of
product being produced, coating performance characteristics, and application methods, collectively
referred to as a "coating scenario."
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Although this approach was popular with the stakeholders, the data reported in the survey was
not sufficient for analysis on that basis. The survey results lacked specific data needed to link
performance requirements and application method with specific coatings used. Consequently, the
"coating scenario" approach was abandoned early on.
Detailed Coating Category Approach
One early attempt to minimize the effect of the extreme diversity of the MMPP source category
was to explore the feasibility of a "coating category" approach. In the coating category approach, the
specific industry and the part or product coated had no bearing on the analysis. For this analysis,
coatings would be grouped according to their type (primers, color coats, top coats, clear coats,
adhesives, etc.) along with the thinners and additives specified for their use. They could be further
categorized by resin type (acrylic, alkyd, epoxy, polyurethane, etc.). Then, the HAP content "as
applied" (i.e., after thinning and mixing of additives) could be determined and the average of the best
coatings in each category could represent the MACT floor for that coating category. This approach is
similar to the coating category approaches used in the Wood Furniture Manufacturing MACT and the
Shipbuilding and Repair MACT source categories. However, it is more complex than those since the
MMPP category comprises a vast array of coatings and is further broken down by resin type.
A serious drawback to the detailed coating category approach was that the analysis depended
on high quality survey responses that would allow EPA to correlate coating type with resin type and
HAP content for a multitude of combinations. The survey data did not provide the level of information
required to enable the team to perform a meaningful analysis. Therefore, the detailed coating category
approach was also abandoned.
"One Number" Approach Based on Facility Emissions
After abandoning the detailed coating category approach, the project team attempted an
analysis of each facility based on emissions reported from the various coating operations. In many
cases, respondents reported HAP emissions for individual coating lines and other emission points as
requested. In many others, however, such estimates were not provided. In those cases, the project
team used available survey information on materials used to derive emission estimates for the various
emission points at the facility. The combined reported and derived emission estimates were used in
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conjunction with material data reported to develop a facility-wide ratio of HAP emitted per volume of
solids used. This "one-number" approach accounted for all coating-related emissions (painting, mixing,
thinning, cleaning, etc.) and eliminated the need to separately account for thinning and cleaning solvents,
paint additives, etc.
Although the "one number" approach is relatively simple, allows flexibility, and accounts for
emissions from all operations within the boundaries of the coating operation, the project team
questioned the dependability of using a combination of bases to estimate emissions. In order to check
for potential problems, the team examined the emissions and materials data reported for several
facilities. In many cases, the emissions reported could not be reconciled with the HAP content of the
materials used. In some cases, the emissions were reported to be greater than the total HAP content of
all materials reported. In order to avoid basing the MACT floor and eventual regulations on
questionable, unreconcilable data, the team decided to abandon the "emissions" approach and rely
solely on materials reported to determine the overall "one number" ratio of pounds HAP to gallons
solids.
"One Number" Approach Based on Material Usage
To avoid inconsistencies and to avoid data that could not be verified, the "one number"
approach was modified to rely solely on materials used in the entire coating and coating-related
operations at a facility. Using material data reported in the survey, the volatile HAP content and the
solids content were both summed across all materials, and a ratio of pounds HAP used per gallon solids
used was calculated for each facility. This number was modified to reflect any reductions from add-on
controls or from waste materials collected and shipped offsite. It was anticipated that under the
eventual regulation, solvents recycled onsite would not be subtracted, since they would be reused within
the boundaries of the coating operation and would not affect the material balance. Recycled materials
coming into the operation from offsite would be counted the same as new materials purchased.
Once the overall HAP to solids ratio was determined for each facility, the facilities were ranked
in ascending order based on this ratio (i.e., ranked best performing to worst performing). The top 12%
of these facilities were identified and their average ratio represented the MACT floor for the entire
source category. A similar procedure was performed on the facilities in the 16 individual industry
segments, to determine the effect certain segments may have on the floor calculation and to qualitatively
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assess how individual segments may be affected by eventual regulations based on the floor. The floor
calculation based on all facilities (i.e., no segmentation) yielded an average ratio of less than 0.1 pound
HAP per gallon solids. The floor calculations for individual segments yielded averages ranging from
zero Ib HAP/gal solids (auto parts, structural steel) to very high averages of 13 Ib HAP/gal solids
(magnet wire) and 58 Ib HAP/gal solids (rubber to metal products). This variation from segment to
segment indicated that a single floor, with no subcategorization, would not be representative of similar
sources. A tentative decision was made to divide the source category into at least three subcategories
(magnet wire, rubber to metal, and a "general use" subcategory for all other segments).
In order for the floor (and eventual HAP/solids limit in the regulation) to be calculated based on
similar sources within a subcategory, the makeup of the subcategory must be homogeneous enough to
enable the vast majority of facilities to come into compliance by implementing controls or using materials
and processes similar to those of the top performing facilities. Too much diversity (with respect to
products coated, coating performance requirements, etc.) within a subcategory results in a meaningless
MACT floor, since the top performing facilities (and the specific products they coat) may not be
representative of the subcategory. After careful review of the survey results from individual facilities
and consultation with several stakeholder groups, the project team concluded that the diversity within
the general use subcategory remained extremely broad, and that some other means of disaggregating
the subcategory was needed.
Because of this lack of homogeneity, the project team attempted to regroup the products
coated into a different set of potential subcategories. For example, instead of "automobile parts," "large
trucks and buses," "recreational vehicles," "heavy equipment," and "rail transportation," the products
within these industry segments were regrouped as "vehicle finishing," "vehicle body parts," "vehicle
mechanical parts," "engines and engine parts,"and "electrical parts" in order to group more
homogeneous products and performance requirements within the subcategories. After meeting with
stakeholders associated with these existing segments and potential subcategories, the team concluded
that the top performing facilities within the newly regrouped subcategories were still unrepresentative.
In an effort to sort out the various products into meaningful groups, the project team shared a non-CBI
version of the database with the auto industry at their request. The auto industry stakeholders
themselves were unable to determine appropriate subcategories for their own products. After
approximately eight months of wrestling with various permutations of the industry segments and
subcategories without any resolution in sight, the project team abandoned this approach.
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Simplified Coating Category Approach
In an attempt to mitigate the effects of diversity within the general use subcategory and to
minimize the need for a large number of additional subcategories, the project team revisited the coating
category approach. This simplified approach, although similar to the detailed coating category
approach discussed earlier, was based on a limited number of coating types only (primers, color coats,
top coats, clear coats, adhesives, etc.) without regard to resin type used (acrylics, alkyds, epoxies,
etc.). The team felt that a limited number of coaling categories could be identified in a similar fashion as
the seven categories used in the Wood Furniture Manufacturing MACT. Of course, the number,
description, and HAP limits of the MMPP categories would be dependent on the data analysis. One
drawback was that there would be no quantitative limit on cleaning solvents used, leaving work
practices as the only means of HAP reduction from cleaning. The coating category approach, though
an attractive one due to its inherent simplicity, was abandoned because the survey responses failed to
provide the information needed to link specific coatings with the types and amounts of thinning solvents
used, thereby making calculation of "as applied" HAP content impossible. In fact, one stakeholders
group, the heavy duty truck industry, trying to provide input to EPA regarding coating categories by
analyzing survey responses from their own facilities could not determine "as applied" HAP content for
the coatings they use. This helped confirm the futility of this approach.
Current Approach
Modified "One-Number" Approach Using State VOC Limits as Surrogate for HAP
After exhaustive analysis of the various strategies discussed above, the project team realized
that some sort of innovative approach was needed to provide reasonable HAP emission reductions
from the MMPP general use subcategory while maintaining a realistic expectation that the control
measures imposed could, in fact, be applicable across this diverse collection of industries. Instead of
determining the MACT floor and eventual HAP limits directly from facility emissions or materials
information, the project team decided to use a combination of State VOC limits and locations of
specific MMPP facilities to establish the floor and eventual HAP limits for most industries using the
VOC limits as a modified surrogate. The MACT floor process and other features of this approach are
discussed below.
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MACT Floor Methodology and Determination for Most MMPP Industries ("General Use
Subcategory"^
The MMPP database contains 321 facilities (332 facilities with usable materials information,
minus the 11 magnet wire and rubber-to-metal facilities) that are major sources or synthetic minor
sources. Using information from the survey, the project team identified the State in which each facility is
located. A review of existing State and local VOC requirements showed that the most stringent limits
are those imposed by the various air quality management districts in California. For most coating types,
this limit is 2.8 pounds VOC per gallon of coating (as applied), less water and exempt (non-VOC)
solvents. The State of Louisiana imposes a VOC limit of 3.0 Ib VOC/gal coating as applied, less water
and exempt solvents. The remainder of the States require the 3.5 Ib VOC/gal coating limit presented in
the Federal Control Techniques Guidelines (CTG) document (Massachusetts and North Carolina
express their limits as 6.7 Ib VOC/gallon solids, which is equivalent to 3.5 Ib VOC/gallon coating, less
water and exempt solvents). State and local limits for specialty coatings are discussed later.
Knowing the State VOC limits and the locations of the MMPP facilities in the database, the
project team was able to determine what the average State VOC limit would be for the top 12 percent
of the industry. From a total of 321 facilities, 39 facilities comprised the top 12 percent as follows:
California - 9 facilities @ 2.8 Ib/gal; Louisiana - no facilities @ 3.0 Ib/gal; and other States - 30
facilities @ 3.5 Ib/gal. Using these limits and the facilities subject to them, the average State limit for the
top 12 percent was calculated to be 3.3 Ib VOC/gal coating, less water and exempt solvents, or 6.0 Ib
VOC/gal solids. Similarly, the best controlled similar sources would be those subject to the California
limit of 2.8 Ib VOC/gal coating, or 4.5 Ib VOC/gal solids.
In order to use the average VOC limit as a surrogate for FLAP emissions, the project team
developed a correction factor that relates VOC emissions to FLAP emissions within the MMPP
category. To develop this factor, the team calculated the average FLAP to VOC ratio for all material
usage reported by the facilities in the MMPP database. By dividing the total amount of FLAP reported
by the total amount of VOC reported across the entire MMPP category (except for magnet wire and
rubber-to-metal products), the team determined that the average FLAP to VOC ratio for all materials
used is 43 percent.
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Using this approach, the MACT floor for existing sources was determined by multiplying the
average of the top 12 percent (6.0 Ib VOC/gal solids) by the correction factor (43 Ib HAP/100 Ib
VOC). This results in an existing source MACT floor of 2.6 Ib HAP/gal solids. A similar calculation
using the California limit results in a new source MACT floor of 1.9 Ib HAP/gal solids. These floor
determinations apply to most sources (now referred to as the "general use subcategory") within the
MMPP category. The development of MACT floors for the "rubber-to-metal," and "magnet wire
subcategories" is discussed later in this paper.
For most industries within the general use subcategory, the coating type used will be defined as
"general use coatings" and will be represented by the MACT floor values described above. Certain
specialty coatings that are used by some facilities within the general use subcategory have been
identified as "high performance coatings". These coatings are not used in any one industry exclusively,
but may be used in varying amounts in many different industries. This coating type includes coatings
used in severe conditions such as high temperatures or exposure to a variety of harsh chemicals.
Certain architectural coatings are also included in this coating type. The proposed rule contains specific
definitions that must be met for coatings to be considered high performance coatings. The new and
existing source MACT floor for these types of coatings was developed from California's 6.20 Ibs VOC
per gallon of coating provisions for specialty coatings. This limit was used for both the new and existing
source MACT floors because it is the most stringent limit found specifically for these coating types and
because it is currently applicable to facilities in California. The HAP to VOC ratio of these coatings,
based on information received from industry, is on average about 70 percent. The MACT floor for
these coatings is, therefore, 27.54 Ibs HAP/gal coating solids (3.30 kg HAP/liter coating solids).
The rubber-to-metal products industry segment is considered as a separate subcategory
because acceptable low HAP coatings have not been demonstrated for many applications within this
industry. Because there are less than 30 facilities within this subcategory, the MACT floor was based
on data from the 5 best performing facilities for which we have data. An analysis of the HAP data
provided by the industry in the survey responses lead to the development of a new source floor of 6.80
Ibs HAP/gal coating solids (0.82 kg HAP/liter coating solids) and an existing source floor of 37.70 Ibs
HAP/gal coating solids (4.50 kg HAP/liter coating solids).
Magnet wire coating is also considered as a separate subcategory for which specific MACT
floor values were determined. The magnet wire industry is unique within the source category because
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of the design of the curing ovens used in the industry. These ovens are designed to utilize volatile
organics in the exhaust gas stream as a supplemental fuel. They typically operate at temperatures that
achieve high volatile organic destruction efficiencies. Based on the HAP data provided by the best
performing 5 of the 7 facilities for which we have data (there are less than 30 facilities in the
subcategory), the new source MACT floor is 0.44 Ibs HAP/gal coating solids (0.05 kg HAP/liter
coating solids). The MACT floor for existing facilities is 1.00 Ibs HAP/gal coating solids (0.12 kg
HAP/liter coating solids). These values include a factor of 0.27 Ibs HAP/gal coating solids (0.03 kg
HAP/liter coating solids) to account for emissions from cleaning operations. This factor was necessary
because the emissions from most cleaning operations that employ solvents containing HAP are not
captured and controlled by the ovens.
Compliance Demonstration and Averaging Period
The method of demonstrating compliance with the MMPP NESHAP will be based on quantity
of materials used (documented by usage records for each material used in the coating operation),
combined with HAP and solids content data for each material used (documented by product data
sheets or other formulation information). Of course, standard test methods could be used to verify
HAP and solids content of materials for enforcement purposes.
Material usage and coating facility activities could fluctuate from week to week and from month
to month. For example, a facility could coat varying types of products, shut down for cleaning from
time to time, and use coatings and solvents of varying types and HAP content, all of which could result
in production-related and/or seasonal fluctuations in material usage. Therefore, the project team
realized the need for an extended averaging period to account for these fluctuations. A 12-month
rolling average (i.e., compliance determined for the most recent 12 calendar months) would be long
enough to accommodate seasonal as well as operational fluctuations.
Credit for Reductions Due to the Use of Add-on Controls
In calculating the overall ratio of pounds HAP to gallons of solids for compliance determination,
allowance must be made for HAP emission reductions (i.e., HAP used at the facility but not emitted)
achieved by add-on control devices. In some cases, facilities have existing add-on controls in place; in
others, the need for very high-HAP coatings and solvents may make addition of new controls for at
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least part of the coating operation an acceptable option. In those cases, the facility would have to track
coating and solvent usage within the facility to determine what portion of the materials used were routed
to the controlled portion of the facility. In addition, the control efficiency of the device would have to
be documented. The amount of HAP to be subtracted from overall usage would be calculated by
taking into account the amount of HAP used in the controlled operation, capture efficiency, and
efficiency of the control device. The facility would be responsible for documenting this calculation using
procedures presented in the regulation.
Credit for Waste and Recycled Solvents
In addition to credit for add-on control devices, any documented amount of HAP in solvents
collected for treatment or disposal at a hazardous waste treatment, storage, and disposal facility (i.e.,
HAP that was used at the facility but not emitted), should also be subtracted from the overall HAP
usage figure. Under the Resource Conservation and Recovery Act (RCRA), hazardous waste
materials being shipped must be manifested. Therefore, the RCRA manifest should provide the
required information for accounting for HAP materials shipped offsite and subtracted from overall
usage. Solvents reclaimed and reused onsite would be treated similarly.
Prepared by:
Bruce Moore
Coatings and Consumer Products Group
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
(919)541-5460
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Development of Model Plants for the Miscellaneous
Metal Parts and Products NESHAP
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Development of Model Plants for the Miscellaneous Metal Parts and Products NESHAP
Five model plants were developed to represent the facilities in the database that have been
projected to be potential major sources, and thus, subject to this rulemaking. The following paragraphs
present the methodology used to develop the model plants and the rationale for the assumptions that
were made. A model plant does not represent any single actual facility, but rather it represents a range
of facilities with similar characteristics that may be impacted by a standard. Each model plant is
characterized in terms of facility size and other parameters that affect the estimates of emissions, control
costs, and secondary environmental impacts. The model plants developed for this source category
incorporate the baseline characteristics presented in this memorandum.
EXISTING SOURCES
The "final" database from which model plants and estimated impacts were determined contains
data from 332 facilities. Eleven of these facilities are in the magnet wire and rubber-metal industry
segments and were not included in the analysis because they have their own emission rates and
corresponding limits. Data from the remaining 321 facilities were grouped into 5 size ranges, with size
measured by coating solids usage. Each size range is represented by a "model plant", designated as
Model Plants 1 through 5. The data that were used for model plant development is presented in five
attachments to this memo, one attachment for each model plant. To estimate the nationwide impacts of
the NESHAP, the projected impacts on each of the model plants were scaled up to the estimated
number of affected facilities nationwide. It is currently estimated that there are 1500 existing, major
source facilities nationwide. The following table presents a breakdown of the 1500 facilities into the 5
model plant size categories.
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Table 1. Model Plant Size Ranges
Model
Plant
1
2
3
4
5
Size Range (gallons
of solids)
< 5,000
5,000- 15,000
15,001 -35,000
35,001 -75,000
> 75,000
No. of Database
Facilities
105
74
81
44
17
321
% of Database
Facilities
33
23
25
14
5
100
No. of Facilities
Nationwide (est.
total of 1,500)
495
345
375
210
75
1,500
Many facilities within the source category are currently operating at FtAP emission levels that
comply with the draft emission limitation of 0.31 Kg HAP/L solids (2.6 Ibs HAP/gallon of solids).
These facilities would not be required to reduce their FtAP emission levels. (Twelve synthetic minor
facilities that do not meet the emission limit were assumed to be complying facilities because they would
not have to reduce their emissions. These facilities are indicated in the attachments by shaded cells.)
Therefore, the number and percentage of the facilities within each size range that would not comply
with the draft standards for existing sources without emission reductions was determined. Model plant
parameters related to material usage and FtAP content were determined using data from only the non-
complying segment of the database population. Parameter values from all non-complying facilities
within each size range were averaged to determine the model plant value.
To estimate nationwide impacts, it was assumed that the population of facilities in the database
(321 facilities) was a representative sample of the nationwide population (estimated to be 1,500
facilities). Therefore, about 18 percent of the facilities nationwide would be represented by model
plant 1 (33% are in that size range and 53.3% are non-complying). With 1,500 existing facilities in the
source category, 264 (1,500*.33*.533 = 264) would be represented by model plant 1 and the impacts
determined for it.
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Table 2. Non-complying Facilities for Each Model Plant
Model
Plant
1
2
3
4
5
# of Database
Facilities That Are
Non-complying
56
47
35
16
O
157
% of Database
Facilities That Are
Non-complying
53.3
63.5
43.2
36.4
17.6
48.9
No. of Facilities
Nationwide (est.
total of 1,500)
495
345
375
210
75
1,500
# of Non-complying
Facilities Nationwide
264
219
162
76
13
734
Table 3 presents the baseline, or "uncontrolled" FtAP emission levels for each of the model
plants, and the extrapolated nationwide levels. These baseline FLAP emission levels will be used to
determine the potential FLAP emission reductions achieved by the NESFIAP. Refer to the "FLAP
Emission Reductions" memo (presented on page 5-1 of this TSD) for details concerning how these
values were calculated.
5-3
-------
Table 3. Existing Source Nationwide Baseline Emissions by Model Plant
Model Plant
1
2
3
4
5
Baseline
Emissions From
Database
Facilities (Ibs)
1,600,527
4,481,434
5,468,793
6,988,913
4,674,992
Number of
Database
Facilities
105
74
81
44
17
Baseline
Emissions Per
Database
Facility (Ibs)
15,243
60,560
67,516
158,839
275,000
Nationwide
Population of
Facilities
495
345
375
210
75
1,500
Nationwide
Baseline
Emissions
(Ibs HAP)
7,545,342
20,893,172
25,318,486
33,356,176
20,624,965
107,738,140
NEW SOURCES
To project impacts from the estimated 45 new facilities that become affected sources each
year, the same method of distributing the facilities by model plant sizes and baseline compliant status
was used. The assumption was made that, in the absence of the NESHAP, new sources would follow
the same trends relative to size and FLAP emission levels as the existing facilities in the database. Tables
4 and 5 present the projected number of new facilities by model plant size and the expected number of
these facilities that would be "non-complying" in the absence of the NESFLAP. Impacts for new
sources were based on the projected number of facilities presented in tables 4 and 5.
5-4
-------
Table 4. Distribution of New Sources By Model Plant
Model Plant
1
2
O
4
5
Size Range (gallons
of solids)
< 5,000
5,000- 15,000
15,001 -35,000
35,001 -75,000
> 75,000
No. of Database
Facilities
105
74
81
44
17
321
% of Database
Facilities
33
23
25
14
5
100
No. of New
Facilities
Nationwide (est.
total of 45 )
15
11
11
6
2
45
Table 5. Distribution of "Non-Complying" New Facilities By Model Plant
Model
Plant
# of Database
Facilities That Are
Non-complying
% of Database
Facilities That Are
Non-complying
No. of New
Facilities
Nationwide (est.
total of 45)
# of Non-complying
Facilities Nationwide
3-5
-------
1
2
O
4
5
65
54
42
20
O
184
61.9
73.0
51.9
45.5
17.6
57.3
15
11
11
6
2
45
9
8
6
3
0
26
ATTACHMENT 1
DATA FOR MODEL PLANT NUMBER 1
-------
Facility ID
vlMPP-2120
\/IMPP-0026
vlMPP-2160
\/IMPP-0029
\/IMPP-2224
\/IMPP-2122
vlMPP-1092
\/IMPP-0408
\/IMPP-2147
vlMPP-1411
\/IMPP-0542
\/IMPP-2114
vlMPP-2124
\/IMPP-2299
\/IMPP-0139
\/IMPP-2115
\/IMPP-2330
\/IMPP-1525
vlMPP-1133
\/IMPP-0577
Coatings
HAP Clbsl
0
0
0
0
0
0
0
258
250
102
4
874
707
1,774
2,002
97
188
693
215
3,430
Solids Caal)
690
860
1,738
1,923
2,819
3,407
913
2,582
2,161
717
1,522
2,004
349
3,374
3,758
910
87
2,197
1,553
4,586
Adhesives
HAP Clbsl
25
18
702
310
Solids Caari
65
2,323
472
659
Other Materials
HAP Clbsl
0
0
0
0
108
0
0
Solids (da!)
20
0
0
15
747
1,335
223
Solvents
HAP Clbsl
0
0
177
374
138
0
0
1,003
939
Waste Coating
HAP Clbsl
0
0
0
0
60
0
0
Waste Solvent
HAP Clbsl
0
0
0
0
0
0
HAP
Controlled Clbs)
3-6
-------
V1MPP-2118
\/lMPP-0083
\/lMPP-0495
\/lMPP-0628
VIMPP-1005
\/lMPP-2253
\/lMPP-0609
\/lMPP-1399
\/lMPP-0282
\/lMPP-2140
\/lMPP-0072
\/lMPP-1068
\/lMPP-2100
\/IMPP-0287
\/lMPP-1396
\/lMPP-0456
Facility ID
\/IMPP-2120
\/IMPP-0026
\/IMPP-2160
\/IMPP-0029
\/IMPP-2224
\/IMPP-2122
MMPP-1092
\/IMPP-0408
\/IMPP-2147
\/IMPP-1411
\/IMPP-0542
\/IMPP-2114
\/IMPP-2124
\/IMPP-2299
\/IMPP-0139
MMPP-2115
\/IMPP-2330
\/IMPP-1525
\/IMPP-1133
\/IMPP-0577
1,287
40
4,473
2,575
1,422
5,218
8,345
5,616
7,198
85
69
3,650
5,175
7,660
7,541
436
Met HAPs
(Ibs)
0
0
0
0
0
0
25
453
250
102
486
874
845
1,774
2,002
738
498
1,696
1,154
3,430
1,601
45
2,583
1,420
1,883
2,571
4,987
4,694
4,189
48
37
4,064
2,612
3,812
3,630
230
Gross Solids
(gai)
710
860
1,738
1,923
2,819
3,422
978
4,905
2,161
717
2,269
2,004
1,684
3,374
3,758
1,382
746
2,420
1,553
4,586
Facil ty Ratio
(Ibs HAP/gal solids)
0.000
0.000
0.000
0.000
0.000
0.000
0.026
0.092
0.116
0.142
0.214
0.436
0.501
0.526
0.533
0.534
0.667
0.701
0.743
0.748
0
0
570
Baseline Emissions
-
-
-
-
-
-
25
453
250
102
486
874
845
1,774
2,002
738
498
1,696
1,154
3,430
1,452
0
2,381
0
4,410
122
MACT
2.6
0
0
0
0
0
0
25
453
250
102
486
874
845
1,774
2,002
738
498
1,696
1,154
3,430
41
1,786
431
157
61
0
52
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
15
MACT
1.9
-
-
-
-
-
-
25
453
250
102
486
874
845
1,774
2,002
738
498
1,696
1,154
3,430
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3-7
-------
vlMPP-2118
\/lMPP-0083
\/lMPP-0495
\/lMPP-0628
vlMPP-1005
\/lMPP-2253
\/lMPP-0609
\/lMPP-1399
\/lMPP-0282
\/lMPP-2140
\/IMPP-0072
\/lMPP-1068
\/lMPP-2100
\/lMPP-0287
\/lMPP-1396
\/lMPP-0456
Facility ID
\/IMPP-2254
vlMPP-2252
\/IMPP-0599
\/IMPP-0658
vlMPP-1491
vlMPP-2283
vlMPP-0351
vlMPP-2284
\/IMPP-2257
vlMPP-1499
vlMPP-2134
\/IMPP-2324
\/IMPP-1424
\/IMPP-2323
vlMPP-2181
vlMPP-1378
vlMPP-2280
\/IMPP-0337
\/IMPP-0430
\/IMPP-2144
1,246
40
2,686
2,144
2,874
5,218
8,345
7,997
7,198
85
69
7,903
5,175
7,599
7,541
491
1,601
45
2,583
1,420
1,883
3,141
4,987
4,694
4,189
48
37
4,064
2,612
3,812
3,630
230
Coatings
HAP (Ibs)
1,140
3,982
4,030
9,286
351
87
714
198
106
12,803
108
172
25,742
5,513
5,139
8,913
68
22,285
585
1 1 ,605
Solids (gal)
529
1,363
3,114
4,091
461
32
215
60
45
4,275
26
41
4,016
3,258
796
2,690
27
4,461
111
2,166
0.778
0.889
1.040
1.510
1.526
1.662
1.673
1.704
1.719
1.771
1.865
1.945
1.981
1.993
2.077
2.133
1,246
40
2,686
2,144
2,874
5,218
8,345
7,997
7,198
85
69
7,903
5,175
7,599
7,541
491
Adhesives
HAP (Ibs)
940
0
828
Solids (gal)
893
11
210
1,246
40
2,686
2,144
2,874
5,218
8,345
7,997
7,198
85
69
7,903
5,175
7,599
7,541
491
Other Materials
HAP (Ibs)
0
0
0
Solids (gal)
479
983
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Solvents
HAP (Ibs)
0
4,442
869
0
3,814
0
1,351
15,263
3,286
54
1,246
40
2,686
2,144
2,874
5,218
8,345
7,997
7,198
85
69
7,721
4,963
7,243
6,897
437
Waste Coating
HAP (Ibs)
714
35
274
0
1 0,224
0
1,710
365
0
0
0
0
0
0
0
0
0
0
0
0
182
211
356
644
54
Waste Solvent
HAP (Ibs)
0
19
0
95
0
0
2,745
0
HAP
Controlled (Ibs)
-------
\/lMPP-2254
VIMPP-2250
\/lMPP-2146
\/lMPP-1082
\/lMPP-0158
\/IMPP-1235
\/lMPP-1305
\/lMPP-0243
\/lMPP-2249
\/lMPP-2216
\/lMPP-0788
\/IMPP-0821
\/lMPP-2208
\/lMPP-0202
\/lMPP-2217
\/lMPP-1353
\/lMPP-1062
Facility ID
\/IMPP-2254
MMPP-2252
\/IMPP-0599
\/IMPP-0658
MMPP-1491
MMPP-2283
VIMPP-0351
VIMPP-2284
MMPP-2257
MMPP-1499
MMPP-2134
\/IMPP-2324
\/IMPP-1424
\/IMPP-2323
MMPP-2181
MMPP-1378
\/IMPP-2280
\/IMPP-0337
\/IMPP-0430
\/IMPP-2144
1,140
5,726
3,777
26,721
9,245
1 1 ,732
5,298
27,773
24,073
15,996
1,177
17,692
7,144
4,492
10,719
716
4,554
Met HAPs
(Ibs)
1,140
3,982
8,699
9,286
1,201
87
714
198
899
16,247
108
172
16,868
18,032
3,429
11,835
122
22,285
585
1 1 ,605
529
4,228
812
4,785
2,290
4,581
1,395
4,500
3,712
2,895
1,162
3,165
1,272
967
1,012
462
658
Gross Solids
(gai)
529
1,841
4,006
4,091
461
32
225
60
255
4,275
26
41
4,016
4,242
796
2,690
27
4,461
111
2,166
4,197
1 1 ,083
98
660
Facility Ratio
(Ibs HAP/gal solids)
2.156
2.163
2.171
2.270
2.607
2.719
3.170
3.300
3.528
3.801
4.154
4.195
4.201
4.251
4.309
4.400
4.519
4.995
5.257
5.358
0
0
16
705
0
1,800
0
586
50
0
0
Baseline Emissions
1,140
3,982
8,699
9,286
1,201
87
714
198
899
16,247
108
172
16,868
18,032
3,429
1 1 ,835
122
22,285
585
1 1 ,605
20,733
8,772
3,086
16,320
4,336
1,295
0
2,422
0
6,029
2,541
3,198
3,021
2,967
964
MACT
2.6
1,140
3,982
8,699
9,286
1,198
83
586
156
899
11,114
68
107
10,441
18,032
2,069
6,994
70
1 1 ,600
289
5,631
0
2,012
0
0
0
0
7,098
0
0
EMISSION
REDUCTIONS
0
0
0
0
3
4
128
42
0
5,133
40
65
6,428
0
1,360
4,841
52
10,685
296
5,973
0
7,750
386
0
206
0
0
0
391
0
232
MACT
1.9
1,005
3,498
7,612
7,772
876
61
428
114
899
8,122
49
78
7,630
18,032
1,512
5,111
51
8,477
211
4,115
776
EMISSION
REDUCTIONS
135
484
1,087
1,514
326
26
286
84
0
8,125
59
94
9,239
0
1,917
6,724
71
13,808
374
7,490
3-9
-------
vlMPP-2250
vlMPP-2146
\/IMPP-1082
\/IMPP-0158
vlMPP-1235
\/IMPP-1305
\/lMPP-0243
\/lMPP-2249
\/IMPP-2216
\/lMPP-0788
\/IMPP-0821
\/lMPP-2208
\/lMPP-0202
\/IMPP-2217
\/IMPP-1353
vlMPP-1062
Facility ID
\/IMPP-2274
vlMPP-0831
\/IMPP-1028
\/IMPP-2315
vlMPP-0187
vlMPP-051 1
vlMPP-0501
vlMPP-0475
\/IMPP-1496
vlMPP-0444
vlMPP-0044
\/IMPP-0780
\/IMPP-0513
\/IMPP-0499
vlMPP-0730
vlMPP-1449
vlMPP-0182
\/IMPP-0479
vlMPP-1426
\/IMPP-0347
26,458
4,800
26,721
14,129
28,052
8,875
29,068
24,073
18,917
12,260
23,720
9,685
7,690
8,051
3,684
5,286
4,814
862
4,785
2,388
4,581
1,395
4,500
3,712
2,895
1,822
3,165
1,272
967
1,012
462
658
Coatings
HAP (Ibs)
10,714
14,075
23,697
8,391
14,273
34,961
1,911
25,647
14,719
50,061
1,236
26,085
38
24,586
13,351
12,581
5,969
31 ,884
9,652
19,014
Solids (gal)
1,210
4,383
3,920
488
4,401
4,064
1,255
2,763
1,295
4,419
938
1,979
10
2,411
3,754
1,882
1,023
2,351
1,487
1,224
5.496
5.567
5.584
5.917
6.123
6.363
6.460
6.486
6.534
6.729
7.495
7.615
7.951
7.955
7.978
8.035
26,458
4,800
26,721
14,129
28,052
8,875
29,068
24,073
18,917
12,260
23,720
9,685
7,690
8,051
3,684
5,286
Adhesives
HAP (Ibs)
1,986
3,684
10,700
6,004
Solids (gal)
205
81
90
2,164
12,517
2,242
12,442
6,209
11,911
3,626
11,700
9,650
7,527
4,737
23,720
9,685
2,515
8,051
3,684
5,286
Other Materials
HAP (Ibs)
0
72
507
Solids (gal)
811
1
13,941
2,558
14,279
7,920
16,140
5,249
17,368
14,423
1 1 ,390
7,523
0
0
5,175
0
0
0
Solvents
HAP (Ibs)
23,384
10,006
23,011
29,704
3,001
9,918
4,122
2,437
19,310
2,161
162
9,216
43,442
17,901
51
34,207
21,679
618
9,147
1,638
9,092
4,537
8,704
2,650
8,550
7,052
5,501
3,461
23,720
9,685
1,838
8,051
3,684
5286
Waste Coating
HAP (Ibs)
443
0
3,631
0
2,675
0
3,036
0
1,969
0
2,884
17,311
3,162
17,629
9,592
19,347
6,225
20,518
17,021
13,416
8,798
0
0
5,852
0
0
0
Waste Solvent
HAP (Ibs)
20,211
799
122
421
8,656
1,515
0
2,542
265
0
1,248
4,301
152
HAP
Controlled (Ibs)
60
3-10
-------
V1MPP-0222
MMPP-2138
\/lMPP-0356
\/IMPP-2191
MMPP-1471
\/IMPP-0123
\/IMPP-1320
\/lMPP-0346
\/IMPP-2219
\/IMPP-1693
\/IMPP-2314
\/lMPP-0774
\/IMPP-1592
TOTALS
AVERAGES
Facility ID
MMPP-2274
VIMPP-0831
\/IMPP-1028
MMPP-2315
VIMPP-0187
VIMPP-0511
VIMPP-0501
VIMPP-0475
MMPP-1496
MMPP-0444
\/IMPP-0044
\/IMPP-0780
\/IMPP-0513
\/IMPP-0499
\/IMPP-0730
MMPP-1449
VIMPP-0182
\/IMPP-0479
MMPP-1426
\/IMPP-0347
30,571
9,720
625
2,154
1 1 ,045
22,817
826
30,130
7,958
941
17,933
48,783
3,214
800,783
12,320
Net HAPs
(Ibs)
10,272
37,459
33,703
11,191
39,548
37,839
1 1 ,829
29,349
14,482
52,047
1 1 ,890
27,379
140
33,802
54,250
28,248
16,720
70,918
24,146
19,987
2,186
425
506
767
1,280
3,032
238
822
669
271
437
2,371
281
119,118
1,833
10
6,000
1,464
38
45,994
708
Gross Solids
(gai)
1,210
4,383
3,920
1,299
4,401
4,064
1,255
2,763
1,295
4,624
938
2,060
10
2,411
3,754
1,882
1,114
4,516
1,487
1,224
15
181
145
36
3,897
60
Facility Ratio
(Ibs HAP/gal solids)
8.489
8.546
8.598
8.613
8.985
9.312
9.425
10.623
11.181
1 1 .256
12.673
13.291
14.000
14.018
14.452
15.010
15.012
15.703
16.235
16.326
18,052
0
228
0
6,605
27,985
431
0
70
2,501
38
Baseline Emissions
10,272
37,459
33,703
11,191
39,548
37,839
1 1 ,829
29,349
14,482
52,047
11,890
27,379
140
33,802
54,250
28,248
16,720
70,918
24,146
19,987
54,747
14,000
706
23,097
68,197
7,815
0
20,966
10,774
70,360
210,868
20,063
856,242
13,173
MACT
2.6
3,146
1 1 ,397
10,191
3,378
1 1 ,443
37,839
3,263
7,183
3,367
12,023
2,439
5,356
26
6,269
9,760
4,893
2,896
1 1 ,742
3,867
3,183
0
0
1,172
0
0
1,398
0
38,925
599
EMISSION
REDUCTIONS
7,126
26,062
23,511
7,813
28,104
0
8,566
22,166
11,114
40,025
9,451
22,024
114
27,533
44,491
23,355
13,824
59,176
20,279
16,804
40,852
3,763
396
258
0
0
2,968
18,024
48,022
166,339
2,559
MACT
1.9
2,299
8,329
7,447
2,469
8,362
37,839
2,384
5,249
2,461
8,786
1,783
3,914
19
4,581
7,132
3,576
2,116
8,581
2,826
2,326
862
27,563
29,260
450
EMISSION
REDUCTIONS
7,973
29,130
26,255
8,722
31,185
0
9,444
24,099
12,021
43,261
10,107
23,466
121
29,220
47,118
24,672
14,604
62,338
21,320
17,661
3-11
-------
\/IMPP-0222
\/IMPP-2138
\/IMPP-0356
VIMPP-2191
\/lMPP-1471
MMPP-0123
\/lMPP-1320
\/IMPP-0346
VIMPP-2219
VIMPP-1693
\/lMPP-2314
\/lMPP-0774
\/lMPP-1592
TOTALS
AVERAGES
44,466
8,858
10,862
19,344
33,884
91,014
8,879
30,130
25,956
17,715
42,772
21 1 ,628
29,920
1 ,496,481
23,023
2,186
425
506
767
1,280
3,102
253
822
669
452
582
2,371
318
125,516
1,931
20.337
20.828
21 .486
25.236
26.463
29.339
35.052
36.638
38.817
39.191
73.519
89.267
94.235
1 1 .923
1 1 .923
44,466
8,858
10,862
19,344
33,884
91,014
8,879
30,130
25,956
17,715
42,772
211,628
29,920
1,600,527
15,243
44,466
1,106
1,314
1,993
3,329
8,066
659
2,138
1,739
1,175
1,513
6,164
826
537,031
0
7,752
9,548
17,351
30,555
82,948
8,221
27,992
24,217
16,540
41,259
205,465
29,095
1 ,063,495
18,991
44,46*
80*
96-
1,45(
2,43C
5,89'
48'
1,56:
1.27C
85$
1.10J
4,50'
eo:
456,62'
4,34$
ATTACHMENT 2
DATA FOR MODEL PLANT NUMBER 2
-------
Facility ID
\/IMPP-2303
\/IMPP-0558
vlMPP-0718
\/IMPP-0508
\/IMPP-1387
\/IMPP-0191
\/IMPP-2241
\/IMPP-2242
\/IMPP-2209
\/IMPP-2113
\/IMPP-2275
\/IMPP-1175
\/IMPP-1560
\/IMPP-2329
vlMPP-0002
vlMPP-2247
\/IMPP-0460
\/IMPP-0330
\/IMPP-0744
\/IMPP-0016
vlMPP-2260
vlMPP-1266
vlMPP-221 1
vlMPP-0666
vlMPP-0979
vlMPP-2317
vlMPP-0171
\/IMPP-2334
\/IMPP-2328
\/IMPP-2207
vlMPP-2171
vlMPP-0438
\/IMPP-2193
\/IMPP-0583
\/IMPP-0963
\/IMPP-2251
Coatings
HAP (Ibs)
0
0
0
0
363
1,613
21,090
2,405
0
1,325
2,650
18,545
4,691
3,163
5,524
6,545
5,154
13,111
9,566
8,999
12,200
12,968
15,897
9,516
32,432
15,279
9,048
37,813
8,604
25,327
3,187
35,086
19,340
44,275
128,224
45,124
Solids (gal)
6,188
9,191
9,652
13,557
8,004
14,905
1 1 ,209
9,038
10,738
1 1 ,582
14,738
6,170
11,179
5,053
6,228
5,281
10,337
9,537
5,808
8,755
14,143
8,042
6,939
8,884
13,295
6,206
9,529
14,385
3,699
8,645
9,209
12,336
5,922
12,984
14,693
12,348
Adhesives
HAP (Ibs)
0
4,144
10,859
Solids (gal)
3,290
2,789
4,670
Other Materials
HAP (Ibs)
0
0
504
92
0
0
0
44
0
22,031
344
Solids (gal)
0
239
0
57
195
0
0
4,394
0
0
Solvents
HAP (Ibs)
0
801
3,631
7,645
8,400
58,795
4,522
1,311
1 1 ,220
3,920
13,174
21,777
6,213
27,977
337
15,825
14,753
11,761
276
42,642
0
Waste Coating
HAP (Ibs)
0
1
18,433
0
0
13,830
0
1,887
858
896
44
1,369
256
0
735
203
0
0
2,973
100,496
Waste Solvent
HAP (Ibs)
7
58,643
0
0
0
1,661
2,376
3,492
1,263
15,508
0
1 1 ,849
1,612
72
17,793
HAP
Controlled (Ibs)
3-12
-------
Facility ID
\/IMPP-2303
\/IMPP-0558
VIMPP-0718
\/IMPP-0508
\/IMPP-1387
\/IMPP-0191
\/IMPP-2241
\/IMPP-2242
\/IMPP-2209
\/IMPP-2113
\/IMPP-2275
\/IMPP-1175
\/IMPP-1560
\/IMPP-2329
\/IMPP-0002
\/IMPP-2247
\/IMPP-0460
\/IMPP-0330
\/IMPP-0744
\/IMPP-0016
\/IMPP-2260
\/IMPP-1266
\/IMPP-221 1
VIMPP-0666
VIMPP-0979
MMPP-2317
MMPP-0171
\/IMPP-2334
\/IMPP-2328
\/IMPP-2207
\/IMPP-2171
\/IMPP-0438
\/IMPP-2193
\/IMPP-0583
\/IMPP-0963
\/IMPP-2251
Net HAPs
(Ibs)
0
0
0
0
362
1,613
2,657
3,206
4,135
8,963
1 1 ,050
4,866
9,305
6,731
5,524
5,688
15,478
15,326
9,566
18,429
30,229
17,919
15,897
21,250
32,432
15,413
24,873
37,813
22,411
35,477
25,218
35,086
16,916
44,275
52,577
45,124
Gross Solids
faar)
6,188
9,191
9,652
13,557
8,004
14,905
1 1 ,209
9,038
10,977
14,872
14,738
6,170
11,179
7,842
6,228
5,339
10,337
9,732
5,808
8,755
14,143
8,042
6,939
8,884
13,295
6,206
9,529
14,385
8,369
13,039
9,209
12,336
5,922
12,984
14,693
12,348
Facility Ratio
(Ibs HAP/aal solids)
0.000
0.000
0.000
0.000
0.045
0.108
0.237
0.355
0.377
0.603
0.750
0.789
0.832
0.858
0.887
1.065
1.497
1.575
1.647
2.105
2.137
2.228
2.291
2.392
2.439
2.484
2.610
2.629
2.678
2.721
2.738
2.844
2.856
3.410
3.578
3.655
Baseline Emissions
-
-
-
-
362
1,613
2,657
3,206
4,135
8,963
1 1 ,050
4,866
9,305
6,731
5,524
5,688
15,478
15,326
9,566
18,429
30,229
17,919
15,897
21,250
32,432
15,413
24,873
37,813
22,411
35,477
25,218
35,086
16,916
44,275
52,577
45,124
MACT
2.6
0
0
0
0
362
1,613
2,657
3,206
4,135
8,963
1 1 ,050
4,866
9,305
6,731
5,524
5,688
15,478
15,326
9,566
18,429
30,229
17,919
15,897
21,250
32,432
15,413
24,776
37,402
21,759
35,477
23,943
32,073
15,398
33,758
38,203
32,104
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
97
411
652
0
1,275
3,013
1,518
10,517
14,374
13,021
MACT
1.9
-
-
-
-
362
1,613
2,657
3,206
4,135
8,963
1 1 ,050
4,866
9,305
6,731
5,524
5,688
15,478
15,326
9,566
16,635
26,872
15,280
13,184
16,879
25,261
11,791
18,105
27,332
15,901
35,477
17,497
23,438
1 1 ,252
24,669
27,918
23,460
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,794
3,358
2,639
2,713
4,371
7,171
3,622
6,767
10,481
6,510
0
7,721
1 1 ,648
5,663
19,605
24,659
21,664
3-13
-------
Facility ID
\/IMPP-1032
\/IMPP-0913
vlMPP-2285
\/IMPP-0829
\/IMPP-0485
\/IMPP-2190
\/IMPP-0899
\/IMPP-1535
\/IMPP-0218
\/IMPP-2177
\/IMPP-1288
\/IMPP-0413
\/IMPP-2149
\/IMPP-2322
vlMPP-1053
vlMPP-1383
\/IMPP-0186
\/IMPP-1341
\/IMPP-0799
\/IMPP-1131
vlMPP-0571
vlMPP-2179
vlMPP-1339
vlMPP-2214
vlMPP-1145
vlMPP-0532
vlMPP-2279
\/IMPP-1359
\/IMPP-0457
\/IMPP-0427
vlMPP-2288
vlMPP-0037
vlMPP-0520
\/IMPP-0178
\/IMPP-1369
\/IMPP-2153
Coatings
HAP (Ibs)
24,427
38,591
26,363
48,535
6,389
57
36,997
0
36,814
30,174
31,452
7,093
30,047
18,053
77,614
47,214
13,668
32,801
158,541
48,586
82,231
55,546
128,980
48,221
20,740
71,306
106,647
46,490
86,663
46,932
154,408
86,578
4,092
131,226
125,123
7,189
Solids (gal)
6,647
1 1 ,469
7,440
12,074
5,041
8,642
4,700
7,214
8,917
6,085
12,657
11,581
6,929
5,851
1 1 ,974
5,873
6,128
10,774
10,990
5,106
10,252
9,356
1 1 ,870
10,435
5,243
1 1 ,703
6,988
8,850
12,183
5,290
10,478
10,713
6,332
6,720
10,944
387
Adhesives
HAP (Ibs)
240
12,816
6,914
143
10,383
129,611
Solids (gal)
79
4,181
1,812
18
1,290
3,229
Other Materials
HAP (Ibs)
0
0
9,246
891
0
0
0
10
0
1,238
Solids (gal)
195
54
660
0
833
1,851
0
6,020
Solvents
HAP (Ibs)
24,373
1,640
15,107
14,783
50,021
1,119
34,646
9,933
38,628
51 ,636
12,915
23,405
0
0
44,506
75,141
2,851
18,022
39,591
226
104,612
45,298
64,315
128,129
60,092
83,282
58,776
119,523
133,744
120,421
213,630
134,382
Waste Coating
HAP (Ibs)
0
1,860
0
0
0
861
4,304
0
57,094
0
8,347
0
14,661
0
0
0
54
4,863
Waste Solvent
HAP (Ibs)
0
14,091
13,178
0
2,703
0
0
1,262
15,028
0
20,248
6,219
0
14,725
0
0
5,670
115,879
34,840
1,008
119,366
HAP
Controlled (Ibs)
19,939
9,677
1,338
123,850
75,782
3-14
-------
Facility ID
\/IMPP-1032
\/IMPP-0913
\/IMPP-2285
\/IMPP-0829
\/IMPP-0485
VIMPP-2190
\/IMPP-0899
\/IMPP-1535
MMPP-0218
\/IMPP-2177
\/IMPP-1288
VIMPP-0413
\/IMPP-2149
\/IMPP-2322
\/IMPP-1053
\/IMPP-1383
\/IMPP-0186
MMPP-1341
\/IMPP-0799
\/IMPP-1131
\/IMPP-0571
\/IMPP-2179
\/IMPP-1339
\/IMPP-2214
MMPP-1145
VIMPP-0532
VIMPP-2279
MMPP-1359
\/IMPP-0457
VIMPP-0427
MMPP-2288
\/IMPP-0037
\/IMPP-0520
\/IMPP-0178
\/IMPP-1369
\/IMPP-2153
Net HAPs
(Ibs)
24,427
43,025
28,243
47,690
21,172
36,901
41,255
34,646
44,043
30,174
70,081
74,890
42,516
41,458
76,753
47,214
52,609
92,914
104,298
48,586
100,253
95,136
129,206
124,239
59,818
135,620
81,540
106,582
169,945
100,191
158,052
185,482
133,834
131,226
214,524
196,638
Gross Solids
faar)
6,647
1 1 ,469
7,519
12,074
5,041
8,642
8,881
7,410
8,917
6,085
12,657
13,394
6,983
6,512
1 1 ,974
5,873
6,128
10,774
10,990
5,106
10,252
9,356
1 1 ,870
1 1 ,268
5,243
1 1 ,703
6,988
8,850
12,183
7,158
10,478
10,713
7,622
6,720
10,944
9,636
Facility Ratio
(Ibs HAP/aal solids)
3.675
3.752
3.756
3.950
4.200
4.270
4.645
4.676
4.939
4.959
5.537
5.591
6.089
6.367
6.410
8.040
8.585
8.624
9.490
9.516
9.779
10.168
10.885
1 1 .026
1 1 .409
1 1 .589
1 1 .669
12.043
13.949
13.997
15.084
17.313
17.559
19.528
19.602
20.408
Baseline Emissions
24,427
43,025
28,243
47,690
21,172
36,901
41,255
34,646
44,043
30,174
70,081
74,890
42,516
41,458
76,753
47,214
52,609
92,914
104,298
48,586
100,253
95,136
129,206
124,239
59,818
135,620
81,540
106,582
169,945
100,191
158,052
185,482
133,834
131,226
214,524
196,638
MACT
2.6
17,281
29,818
19,549
31,392
13,106
22,469
23,089
19,265
23,185
15,820
32,909
34,824
18,155
16,930
31,133
15,269
15,933
28,013
28,574
13,275
26,656
24,327
30,862
29,297
13,632
30,427
18,169
23,010
31 ,676
18,611
27,244
27,854
19,817
17,472
28,454
25,052
EMISSION
REDUCTIONS
7,145
13,207
8,694
16,297
8,067
14,432
18,165
15,381
20,859
14,354
37,172
40,066
24,360
24,528
45,620
31,945
36,676
64,901
75,724
35,310
73,597
70,810
98,344
94,942
46,187
105,193
63,371
83,573
138,269
81,580
130,809
157,628
114,017
113,754
186,070
171,585
MACT
1.9
12,629
21,790
14,286
22,941
9,577
16,420
16,873
14,079
16,943
11,561
24,049
25,448
13,267
12,372
22,751
11,158
1 1 ,643
20,471
20,881
9,701
19,479
17,777
22,553
21,409
9,962
22,235
13,277
16,815
23,148
13,601
19,909
20,355
14,482
12,768
20,794
18,307
EMISSION
REDUCTIONS
11,798
21,235
13,957
24,749
11,595
20,481
24,382
20,567
27,101
18,613
46,032
49,442
29,248
29,086
54,002
36,056
40,966
72,443
83,417
38,885
80,773
77,359
106,653
102,830
49,857
113,385
68,263
89,768
146,797
86,590
138,143
165,127
119,352
118,458
193,731
178,330
3-15
-------
Facility ID
\/IMPP-1342
\/IMPP-2300
TOTALS
AVERAGES
Coatings
HAP (Ibs)
133,852
39,154
2,444,821
50,934
Solids (gal)
9,366
7,382
424,333
8,840
Adhesives
HAP (Ibs)
170,966
3,562
Solids
15,279
318
Other Materials
HAP (Ibs)
33,804
704
Solids (gal)
14,008
292
Solvents
HAP (Ibs)
149,736
456,593
2,416,334
50,340
Waste Coating
HAP (Ibs)
0
10,820
206,333
4,299
Waste Solvent
HAP (Ibs)
8,071
403,612
8,409
HAP
Controlled
230,586
4,804
3-16
-------
Facility ID
\/IMPP-1342
\/IMPP-2300
TOTALS
AVERAGES
Net HAPs
(Ibs)
283,588
476,856
4,225,394
88,029
Gross Solids
(aal)
9,366
7,382
453,620
9,450
Facility Ratio
(Ibs HAP/aal solids)
30.277
64.597
9.315
Baseline
283,588
476,856
4,481,434
60,560
MACT
2.6
24,353
19,193
1,437,029
19,419
EMISSION
REDUCTIONS
259,235
457,663
3,044,406
64,775
MACT
1.9
17,796
14,026
1,102,952
14,905
EMISSION
REDUCTIONS
265,792
462,830
3,378,482
62,564
3-17
-------
ATTACHMENT 3
DATA FOR MODEL PLANT NUMBER 3
-------
racility ID
\/IMPP-1397
vlMPP-1265
vlMPP-1180
\/IMPP-2156
vlMPP-2142
vlMPP-1855
\/lMPP-0642
\/lMPP-1857
\/lMPP-2256
vlMPP-1905
vlMPP-2155
vlMPP-1398
\/lMPP-2165
\/lMPP-0570
\/lMPP-1252
\/lMPP-0502
vlMPP-1360
vlMPP-0472
\/IMPP-2154
\/lMPP-2230
\/lMPP-2117
\/lMPP-1289
vlMPP-0231
\/IMPP-1881
vlMPP-0999
\/lMPP-2184
vlMPP-1162
vlMPP-1633
\/lMPP-0561
\/lMPP-0088
\/lMPP-1214
vlMPP-1434
vlMPP-1338
\/lMPP-0286
\/lMPP-1642
Coatings
HAP (Ibs)
0
0
22
36
93
883
914
577
4,054
2,028
0
17,805
149
3,042
52,348
1,403
2,785
15,278
3,648
17,331
1 1 ,368
13,547
14,215
13,889
9,364
23,017
23,473
81,061
45,782
47,801
27,620
16,776
72,576
17,020
75,882
Solids (gal)
20,124
23,040
107
22,804
582
32,734
20,130
17,348
33,509
18,997
14,919
20,145
20,977
22,428
20,942
15,036
19,497
29,056
1,670
33,936
18,578
17,075
22,899
21 ,046
16,457
30,506
24,815
30,884
22,042
23,049
17,176
16,696
27,422
4,037
33,740
Adhesives
HAP (Ibs)
0
780
1,810
707
6,618
0
1,317
Solids (gal)
20,286
1,501
92
1,883
18,258
8,932
408
Other Materials
HAP (Ibs)
0
0
0
0
0
0
0
374
0
49
0
547
Solids (gal)
104
33,551
7,640
38
0
288
2,266
3,511
1 1 ,352
Solvents
HAP (Ibs)
0
0
14
0
0
656
0
122
6,000
0
1,154
118,215
2,242
4,804
1,360
2,396
0
46
2,753
28,329
0
9,355
10,678
59
18,341
17,462
2,688
4,920
17,530
Waste Coating
HAP (Ibs)
0
0
2
512
15,052
8
50,388
1,006
0
0
0
15,594
568
60,499
30,967
18,140
19,434
2,395
34,103
41,817
Waste Solvent
HAP (Ibs)
0
0
120
4,110
0
114,993
0
0
997
8,245
0
0
4,373
1,618
HAP
Controlled (Ibs)
0
138
1,174
2,032
3-18
-------
VIMPP-2259
racility ID
MMPP-1397
\/IMPP-1265
MMPP-1180
\/IMPP-2156
\/IMPP-2142
\/IMPP-1855
\/IMPP-0642
MMPP-1857
\/IMPP-2256
\/IMPP-1905
\/IMPP-2155
\/IMPP-1398
\/IMPP-2165
\/IMPP-0570
MMPP-1252
\/IMPP-0502
\/IMPP-1360
\/IMPP-0472
\/IMPP-2154
MMPP-2230
MMPP-2117
VIMPP-1289
VIMPP-0231
MMPP-1881
\/IMPP-0999
MMPP-2184
\/IMPP-1162
\/IMPP-1633
\/IMPP-0561
\/IMPP-0088
MMPP-1214
MMPP-1434
\/IMPP-1338
\/IMPP-0286
\/IMPP-1642
16,141| 15,133| |
Net HAPs
(Ibs)
0
0
22
34
107
883
914
1,233
3,543
2,030
2,670
2,616
3,112
3,740
4,008
3,646
7,590
14,272
10,266
17,331
1 1 ,070
15,942
14,215
13,935
11,121
27,555
22,905
29,917
25,493
29,719
22,155
30,226
41,162
23,805
51,595
Gross Solids
faar)
20,124
23,040
20,393
22,908
34,134
32,734
20,130
17,348
33,509
18,997
24,060
20,145
21 ,068
24,348
20,942
15,036
19,497
29,056
20,216
33,936
18,578
26,007
22,899
21 ,046
16,457
32,772
24,815
30,884
22,042
23,049
17,176
20,208
27,422
15,797
33,740
Facility Ratio
(Ibs HAP/aal solids)
0.000
0.000
0.001
0.001
0.003
0.027
0.045
0.071
0.106
0.107
0.111
0.130
0.148
0.154
0.191
0.242
0.389
0.491
0.508
0.511
0.596
0.613
0.621
0.662
0.676
0.841
0.923
0.969
1.157
1.289
1.290
1.496
1.501
1.507
1.529
| | 12,814| 2,036| 3,168| |
Baseline Emissions
-
-
22
34
107
883
914
1,233
3,543
2,030
2,670
2,616
3,112
3,740
4,008
3,646
7,590
14,272
10,266
17,331
1 1 ,070
15,942
14,215
13,935
11,121
27,555
22,905
29,917
25,493
29,719
22,155
30,226
41,162
23,805
51,595
MACT
2.6
0
0
22
34
107
883
914
1,233
3,543
2,030
2,670
2,616
3,112
3,740
4,008
3,646
7,590
14,272
10,266
17,331
1 1 ,070
15,942
14,215
13,935
11,121
27,555
22,905
29,917
25,493
29,719
22,155
30,226
41,162
23,805
51,595
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
MACT
1.9
-
-
22
34
107
883
914
1,233
3,543
2,030
2,670
2,616
3,112
3,740
4,008
3,646
7,590
14,272
10,266
17,331
1 1 ,070
15,942
14,215
13,935
11,121
27,555
22,905
29,917
25,493
29,719
22,155
30,226
41,162
23,805
51 ,595
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3-19
-------
vlMPP-2259
racility ID
vlMPP-2289
\/lMPP-0973
\/lMPP-0983
\/lMPP-0281
\/lMPP-0197
\/lMPP-1637
\/lMPP-1450
\/IMPP-0779
\/lMPP-0470
\/lMPP-2157
\/lMPP-0804
\/lMPP-1508
\/lMPP-0597
vlMPP-1495
vlMPP-0716
\/lMPP-0636
\/lMPP-0105
\/lMPP-0605
\/lMPP-1587
vlMPP-1572
vlMPP-2321
vlMPP-0081
vlMPP-0212
vlMPP-0826
vlMPP-0442
vlMPP-0585
\/lMPP-2246
\/lMPP-0770
\/lMPP-0500
vlMPP-0284
vlMPP-2198
vlMPP-0279
\/lMPP-0270
\/lMPP-1150
\/lMPP-2176
23,751 1 15,133| 1.570| 23,751 1 23,751| 0| 23,751| 0|
Coatings
HAP (Ibs)
16,073
20,699
52,060
49,206
77,192
33,569
52,418
119,844
17,394
81,705
17,166
45,720
50,153
28,245
57,336
46,900
92,558
121,006
64,664
16,642
65,961
99,593
63,730
120,614
71,179
102,756
72,965
147,041
27,606
84,311
121,974
35,702
51,903
132,849
98,103
Solids (gal)
1 1 ,606
17,249
26,892
19,883
27,543
16,063
20,653
28,378
5,282
29,139
33,496
16,762
17,362
18,780
18,738
25,063
28,660
28,851
33,333
28,573
20,733
25,123
17,045
14,288
16,163
25,539
25,959
32,040
16,135
15,923
22,548
22,380
15,998
33,968
16,687
Adhesives
HAP (Ibs)
3,909
107
125
439
293
2,436
15,242
Solids (gal)
208
109
440
38
163
376
1,780
Other Materials
HAP (Ibs)
0
0
0
0
830
0
723
0
0
0
0
0
0
0
Solids (gal)
12,586
116
1,287
113
10,425
3,091
0
0
2,395
820
Solvents
HAP (Ibs)
49,377
1 1 ,966
435
24,489
6,229
2,523
33,468
35,075
6,220
150,073
2,179
28,107
32,522
6,558
534
48,849
438,807
1 1 ,725
24,043
185,841
3,688
75,035
739
65,600
93,024
37,062
61,196
Waste Coating
HAP (Ibs)
0
0
8,898
16,968
0
238
30,217
0
1,669
0
0
0
7,034
25,513
0
4,059
0
7,469
28,116
0
16,058
0
0
0
355
Waste Solvent
HAP (Ibs)
24,969
0
20,875
0
0
17,108
0
0
0
0
0
353,792
4,783
23,988
110,813
1,072
28,853
0
62
HAP
Controlled (Ibs)
51 ,577
74,575
103,866
3-20
-------
VIMPP-0920
racility ID
MMPP-2289
\/IMPP-0973
\/IMPP-0983
\/IMPP-0281
\/IMPP-0197
\/IMPP-1637
\/IMPP-1450
MMPP-0779
\/IMPP-0470
\/IMPP-2157
\/IMPP-0804
\/IMPP-1508
\/IMPP-0597
MMPP-1495
\/IMPP-0716
\/IMPP-0636
\/IMPP-0105
\/IMPP-0605
\/IMPP-1587
MMPP-1572
MMPP-2321
VIMPP-0081
VIMPP-0212
\/IMPP-0826
MMPP-0442
\/IMPP-0585
\/IMPP-2246
\/IMPP-0770
\/IMPP-0500
\/IMPP-0284
MMPP-2198
MMPP-0279
\/IMPP-0270
\/IMPP-1150
\/IMPP-2176
88,996| 15,921 1 |
Net HAPs
(Ibs)
40,480
32,665
52,495
40,308
63,837
39,798
54,703
71,519
40,101
86,255
93,387
47,899
50,153
56,459
57,336
79,548
92,082
96,466
113,513
97,890
75,339
92,124
63,785
63,660
71,179
120,614
119,147
147,781
77,148
84,311
121,974
128,663
88,964
194,045
97,748
Gross Solids
faar)
24,193
17,364
26,892
19,883
27,543
16,063
21 ,940
28,491
15,915
32,230
33,496
16,762
17,362
18,888
18,738
25,503
28,660
28,888
33,333
28,736
21,109
25,123
17,045
16,683
16,163
27,319
25,959
32,040
16,135
15,923
22,548
23,200
15,998
33,968
16,687
Facility Ratio
(Ibs HAP/aal solids)
1.673
1.881
1.952
2.027
2.318
2.478
2.493
2.510
2.520
2.676
2.788
2.858
2.889
2.989
3.060
3.119
3.213
3.339
3.405
3.406
3.569
3.667
3.742
3.816
4.404
4.415
4.590
4.612
4.782
5.295
5.410
5.546
5.561
5.713
5.858
I I 5,996| | | |
Baseline Emissions
40,480
32,665
52,495
40,308
63,837
39,798
54,703
71,519
40,101
86,255
93,387
47,899
50,153
56,459
57,336
79,548
92,082
96,466
113,513
97,890
75,339
92,124
63,785
63,660
71,179
120,614
119,147
147,781
77,148
84,311
121,974
128,663
88,964
194,045
97,748
MACT
2.6
40,480
32,665
52,495
40,308
63,837
39,798
54,703
71,519
40,101
83,798
87,089
43,580
45,140
56,459
48,718
66,307
74,516
75,110
86,665
74,714
54,883
65,320
44,318
43,376
42,023
71 ,030
67,492
83,305
41 ,950
41 ,399
58,625
60,319
41 ,594
88,316
43,386
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
2,457
6,298
4,319
5,013
0
8,618
13,241
17,566
21 ,356
26,847
23,176
20,455
26,804
19,467
20,283
29,156
49,584
51 ,655
64,476
35,199
42,912
63,350
68,344
47,371
105,729
54,363
MACT
1.9
40,480
32,665
51,095
37,777
52,331
30,519
41,687
54,133
30,239
61,237
63,642
31,847
32,987
56,459
35,602
48,455
54,454
54,888
63,332
54,599
40,107
47,734
32,386
31,698
30,709
51,906
49,321
60,877
30,656
30,253
42,841
44,080
30,395
64,539
31,705
EMISSION
REDUCTIONS
0
0
1,399
2,531
1 1 ,506
9,279
13,016
17,385
9,862
25,018
29,745
16,052
17,166
0
21,734
31,093
37,628
41,578
50,180
43,291
35,231
44,390
31,398
31,962
40,470
68,708
69,826
86,904
46,493
54,058
79,133
84,584
58,569
129,506
66,043
3-21
-------
vlMPP-0920
racility ID
vlMPP-1405
vlMPP-0168
vlMPP-1702
vlMPP-1064
\/lMPP-0166
vlMPP-1149
\/lMPP-1232
vlMPP-0543
\/lMPP-0169
TOTALS
AVERAGES
94,992| 15,921 1 5.967
Coatings
HAP (Ibs)
20,483
165,556
147,049
90,493
160,731
29,199
57,142
225,965
423,496
3,327,493
92,430
Solids (gal)
17,343
23,608
24,748
21,944
26,920
15,608
24,685
15,954
26,052
812,066
22,557
Adhesives
HAP (Ibs)
39
70
18,751
521
Solids (gal)
236
1,119
4,261
118
94,992| 41,394| 53,598| 30,250| 64,742|
Other Materials
HAP (Ibs)
0
0
723
20
Solids (gal)
5,137
1 1 ,443
318
Solvents
HAP (Ibs)
84,959
1,154
35,378
113,168
65,794
102,804
252,434
24,916
267,773
2,226,178
61 ,838
Waste Coating
HAP (Ibs)
20,366
0
0
110,639
3,073
Waste Solvent
HAP (Ibs)
0
1,450
22,047
0
0
126,892
673,751
18,715
HAP
Controlled (Ibs)
50,008
228,449
6,346
3-22
-------
Facility ID
\/IMPP-1405
\/IMPP-0168
\/IMPP-1702
MMPP-1064
\/IMPP-0166
MMPP-1149
\/IMPP-1232
\/IMPP-0543
\/IMPP-0169
TOTALS
AVERAGES
Net HAPs
(Ibs)
105,442
166,710
181,017
161,248
226,525
132,003
259,638
250,882
564,377
4,560,305
126,675
Gross Solids
faal)
17,343
23,608
24,985
21,944
26,920
15,608
25,804
21,092
26,052
827,770
22,994
Facility Ratio
(Ibs HAP/aal solids)
6.080
7.062
7.245
7.348
8.415
8.457
10.062
1 1 .895
21.664
5.509
Baseline Emissions
105,442
166,710
181,017
161,248
226,525
132,003
259,638
250,882
564,377
5,468,793
67,516
MACT
2.6
45,093
61,380
64,960
57,054
69,992
40,581
67,091
54,838
67,734
3,068,040
EMISSION
REDUCTIONS
60,349
105,330
116,057
104,194
156,533
91 ,421
192,547
196,044
496,643
2,400,753
68,593
MACT
1.9
32,952
44,855
47,471
41,694
51,148
29,656
49,028
40,074
49,498
2,436,844
30,084
EMISSION
REDUCTIONS
72,490
121,855
133,546
119,555
175,377
102,347
210,610
210,808
514,879
3,031,949
72,189
3-23
-------
ATTACHMENT 4
DATA FOR MODEL PLANT NUMBER 4
-------
Facility ID
\/IMPP-2105
\/IMPP-0986
vlMPP-1161
vlMPP-1395
\/IMPP-1237
\/IMPP-1461
\/IMPP-0960
\/IMPP-1478
vlMPP-0245
\/IMPP-1588
\/IMPP-2258
\/IMPP-0340
\/IMPP-0596
vlMPP-2127
vlMPP-0645
vlMPP-1022
\/IMPP-2098
\/IMPP-1221
\/IMPP-0439
\/IMPP-1024
vlMPP-0076
vlMPP-0962
vlMPP-1656
vlMPP-1583
vlMPP-0496
vlMPP-2255
vlMPP-1329
\/IMPP-0173
\/IMPP-1635
\/IMPP-1281
vlMPP-0120
vlMPP-0537
vlMPP-0567
\/IMPP-0493
\/IMPP-1155
\/IMPP-2292
Coatings
HAP (Ibs)
0
0
5,327
5,965
5,854
6,372
16,052
30,067
20,865
79,850
16,125
31,776
9,032
33,040
18,340
25,615
39,317
106,489
74,053
63,572
54,511
146,939
86,367
66,032
139,026
77,836
27,167
113,042
141,203
66,683
132,820
147,002
89,985
113,867
57,792
253,006
Solids (gal)
57,873
45,521
62,147
56,182
54,170
56,898
30,941
53,638
43,646
36,029
52,734
67,038
55,501
42,312
26,834
64,032
36,268
39,034
50,566
47,273
69,791
38,314
56,823
45,242
63,952
33,856
7,307
46,466
53,695
57,781
38,430
51,037
54,551
36,900
36,496
48,234
Adhesives
HAP (Ibs)
123
568
12,009
967
0
796
53,265
8,962
41 ,621
8,641
0
Solids (gal)
80
127
15,771
529
62
5,039
30,022
1,841
7,685
1,211
1,790
Other Materials
HAP (Ibs)
0
0
0
306
292
912
0
0
29,341
0
0
26,666
14,983
Solids (gal)
7,906
1,105
0
13,547
1
0
437
Solvents
HAP (Ibs)
1,275
0
0
0
395
2,420
19,094
1 1 ,885
38,931
12,359
34,030
167
13,039
127,024
4,155
15,167
13,001
308,312
85,472
81 ,400
92,171
196
1,354
75,463
16,612
118,178
14,890
25,138
74,298
52,311
126,761
Waste Coating
HAP (Ibs)
0
233
54
84
8,512
18,019
73,050
414
0
1,028
65,566
10,247
0
0
90,608
3,059
14,988
0
0
22,698
3,514
0
0
10,805
Waste Solvent
HAP (Ibs)
0
815
13,101
22,608
4,608
87,986
1,038
238,882
37,385
45,677
70,820
55,531
0
0
0
HAP
Controlled (Ibs)
32,182
13,305
3-24
-------
Facility ID
\/IMPP-2105
\/IMPP-0986
VIMPP-1161
MMPP-1395
\/IMPP-1237
\/IMPP-1461
\/IMPP-0960
\/IMPP-1478
\/IMPP-0245
\/IMPP-1588
\/IMPP-2258
\/IMPP-0340
\/IMPP-0596
MMPP-2127
\/IMPP-0645
VIMPP-1022
\/IMPP-2098
\/IMPP-1221
\/IMPP-0439
\/IMPP-1024
\/IMPP-0076
\/IMPP-0962
VIMPP-1656
VIMPP-1583
\/IMPP-0496
MMPP-2255
MMPP-1329
\/IMPP-0173
\/IMPP-1635
\/IMPP-1281
VIMPP-0120
\/IMPP-0537
\/IMPP-0567
\/IMPP-0493
\/IMPP-1155
\/IMPP-2292
Net HAPs
(Ibs)
0
1,275
5,093
5,965
5,800
6,682
9,267
18,609
20,865
18,685
32,448
44,136
42,953
33,207
38,781
64,652
38,289
45,078
79,194
76,573
124,852
72,236
105,726
87,382
124,038
108,169
81,787
141,936
157,815
184,862
125,011
168,627
232,570
174,818
184,552
257,184
Gross Solids
faar)
57,873
45,521
62,147
56,182
54,170
56,898
38,927
53,765
43,646
36,029
52,734
67,038
55,501
42,312
42,605
64,032
36,268
39,034
51 ,095
47,273
69,854
39,419
56,823
45,242
63,952
52,441
37,330
48,307
53,695
57,781
38,430
51 ,037
62,673
38,111
36,496
50,024
Facility Ratio
(Ibs HAP/aal solids)
0.000
0.028
0.082
0.106
0.107
0.117
0.238
0.346
0.478
0.519
0.615
0.658
0.774
0.785
0.910
1.010
1.056
1.155
1.550
1.620
1.787
1.833
1.861
1.931
1.940
2.063
2.191
2.938
2.939
3.199
3.253
3.304
3.711
4.587
5.057
5.141
Baseline Emissions
-
1,275
5,093
5,965
5,800
6,682
9,267
18,609
20,865
18,685
32,448
44,136
42,953
33,207
38,781
64,652
38,289
45,078
79,194
76,573
124,852
72,236
105,726
87,382
124,038
108,169
81,787
141,936
157,815
184,862
125,011
168,627
232,570
174,818
184,552
257,184
MACT
2.6
0
1,275
5,093
5,965
5,800
6,682
9,267
18,609
20,865
18,685
32,448
44,136
42,953
33,207
38,781
64,652
38,289
45,078
79,194
76,573
124,852
72,236
105,726
87,382
124,038
108,169
81,787
125,599
139,607
150,231
99,919
132,697
162,950
99,088
94,890
130,063
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
16,338
18,207
34,630
25,093
35,930
69,620
75,730
89,662
127,121
MACT
1.9
-
1,275
5,093
5,965
5,800
6,682
9,267
18,609
20,865
18,685
32,448
44,136
42,953
33,207
38,781
64,652
38,289
45,078
79,194
76,573
124,852
72,236
105,726
85,959
121,509
99,638
70,927
91,784
102,021
109,784
73,017
96,971
119,079
72,410
69,343
95,046
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,424
2,529
8,531
10,860
50,153
55,794
75,077
51,994
71,656
113,491
102,408
115,210
162,138
3-25
-------
Facility ID
\/IMPP-0203
\/IMPP-0839
\/IMPP-1655
\/IMPP-1439
\/IMPP-0458
vlMPP-0170
vlMPP-0164
\/IMPP-0070
TOTALS
AVERAGES
Coatings
HAP (Ibs)
352,320
350,170
326,443
119,231
269,288
768,461
792,314
72,842
4,166,468
245,086
Solids
(gai)
60,239
71,172
43,182
53,731
36,073
47,344
40,576
44,424
820,334
48,255
Adhesives
HAP (Ibs)
122,204
0
181,428
10,672
Solids (gal)
12,967
103
25,597
1,506
Other Materials
HAP (Ibs)
0
0
705,295
746,944
43,938
Solids (gal)
0
878
1,315
77
Solvents
HAP (Ibs)
190,413
252,400
496,709
84,544
562,927
467,900
294,341
2,852,885
167,817
Waste Coating
HAP (Ibs)
37,566
6,992
82,817
0
0
164,391
9,670
Waste Solvent
HAP (Ibs)
1,962
165,963
290,455
0
348,913
60,129
215,012
1,137,964
66,939
HAP
Controlled (Ibs)
159,488
95,110
260,222
433,381
948,202
55,777
3-26
-------
Facility ID
\/IMPP-0203
\/IMPP-0839
\/IMPP-1655
MMPP-1439
\/IMPP-0458
VIMPP-0170
\/IMPP-0164
\/IMPP-0070
TOTALS
AVERAGES
Net HAPs
(Ibs)
314,754
372,140
234,954
447,690
353,831
722,253
766,705
857,466
5,697,168
335,128
Gross Solids
foal)
60,239
71,172
43,182
67,576
36,073
47,344
40,576
44,528
847,246
49,838
Facility Ratio
(Ibs HAP/aal solids)
5.225
5.229
5.441
6.625
9.809
15.255
18.896
19.257
6.724
Baseline Emissions
314,754
372,140
234,954
447,690
353,831
722,253
766,705
857,466
6,988,913
158,839
MACT
2.6
156,622
185,048
112,274
175,698
93,791
123,094
766,705
115,772
4,155,792
94,450
EMISSION
REDUCTIONS
158,132
187,092
122,680
271 ,992
260,041
599,159
0
741 ,694
2,833,121
177,070
MACT
1.9
114,455
135,227
82,046
128,395
68,539
89,953
766,705
84,603
3,567,779
81 ,086
EMISSION
REDUCTIONS
200,299
236,912
152,908
319,295
285,292
632,300
0
772,863
3,421,134
171,057
3-27
-------
ATTACHMENT 5
DATA FOR MODEL PLANT NUMBER 5
-------
Facility ID
\/IMPP-0469
\/IMPP-2112
vlMPP-0236
\/IMPP-0732
\/IMPP-1241
\/IMPP-1146
\/IMPP-0389
\/IMPP-0872
\/IMPP-0180
\/IMPP-1209
\/IMPP-0904
\/IMPP-0613
\/IMPP-2128
\/IMPP-0372
vlMPP-1247
vlMPP-1047
\/IMPP-2206
TOTALS
AVERAGES
Coatings
HAP (Ibs)
88
12,511
41,949
24,067
35,541
54,049
102,489
89,695
65,992
77,590
93,173
104,465
129,226
386,708
237,395
1 ,829,474
38,771
2,105,639
701.880
Solids (gal)
126,337
79,926
200,492
127,635
94,281
133,990
21,378
42,401
89,326
78,681
52,970
77,084
79,924
58,476
194,047
345,229
20,076
559,353
186.451
Adhesives
HAP (Ibs)
0
0
0
27,638
4,228
120
26,597
0
0
Solids (gal)
4,399
210,930
4,346
88,152
7,244
102
6,300
0
0
Other Materials
HAP
0
0
0
0
0
0
0
299
536
3,195
9,441
4
4
1
Solids (gal)
2,146
44,089
1,221
15
5,144
1,696
142,286
56,619
56,619
18.873
Solvents
HAP (Ibs)
0
4,600
0
260
0
7,988
30,488
3,485
22,093
51,331
44,127
981
462,837
791,125
926,973
1,718,098
572.699
Waste Coating
HAP (Ibs)
9
458
635
76,527
0
0
0
0
0
91 ,048
0
0
0
Waste Solvent
HAP (Ibs)
0
0
0
0
0
16,411
0
323,131
0
0
HAP
Controlled (Ibs)
14,677
34,889
103,776
404,980
404,980
134.993
3-28
-------
Facility ID
\/IMPP-0469
\/IMPP-2112
\/IMPP-0236
\/IMPP-0732
\/IMPP-1241
\/IMPP-1146
\/IMPP-0389
\/IMPP-0872
\/IMPP-0180
\/IMPP-1209
\/IMPP-0904
\/IMPP-0613
\/IMPP-2128
\/IMPP-0372
MMPP-1247
MMPP-1047
\/IMPP-2206
TOTALS
AVERAGES
Net HAPs
(Ibs)
79
12,053
31,237
24,067
35,801
54,049
110,477
43,656
69,478
64,794
172,441
136,946
133,523
367,629
623,540
1 ,829,474
965,748
3,418,761
1.139.587
Gross Solids
faar)
130,736
79,926
200,492
129,781
94,281
133,990
232,308
86,490
93,671
79,903
141,137
89,472
81 ,722
207,062
194,047
345,229
76,695
615,972
205.324
Facility Ratio
(Ibs HAP/aal solids)
0.001
0.151
0.156
0.185
0.380
0.403
0.476
0.505
0.742
0.811
1.222
1.531
1.634
1.775
3.213
5.299
12.592
5.550
Baseline Emissions
79
12,053
31,237
24,067
35,801
54,049
110,477
43,656
69,478
64,794
172,441
136,946
133,523
367,629
623,540
1 ,829,474
965,748
4,674,992
275.000
MACT
2.6
79
12,053
31 ,237
24,067
35,801
54,049
110,477
43,656
69,478
64,794
172,441
136,946
133,523
367,629
504,523
897,596
199,408
2,857,757
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
119,017
931,878
766,340
1,817,234
605.745
MACT
1.9
79
12,053
31 ,237
24,067
35,801
54,049
110,477
43,656
69,478
64,794
172,441
136,946
133,523
367,629
368,690
655,935
145,721
2,426,577
142.740
EMISSION
REDUCTIONS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
254,850
1,173,538
820,027
2,248,415
749.472
3-29
-------
Available Add-on Control Devices for
Use in the Miscellaneous Metal Parts
and Products (MMPP) NESHAP
-------
Available Add-on Control Devices for Use in the Miscellaneous Metal Parts and Products
(MMPP) NESHAP
This memorandum describes the types of add-on control devices that could be used to reduce
volatile HAP emissions from miscellaneous metal parts and products surface coating operations and
explains the associated monitoring requirements. The first section of this memorandum describes the
types of add-on control devices. The second section presents the monitoring requirements for these
devices and provides the rationale for selecting these monitoring parameters.
ADD-ON CONTROL DEVICES
There are many types of emission control technologies that could be used to reduce emissions
from miscellaneous metal parts and products surface coating operations. While the most common
method of volatile HAP emission reduction utilized in surface coating operations is the reformulation of
coating materials, add-on control devices are another technique available for use in reducing HAP
emissions. This memorandum describes the types of add-on control devices that are available.
Organic Solvent Recovery
Recovery of organic solvent from air streams is not widely practiced in surface coating
operations since many organic solvents used in the coating industry are relatively inexpensive. Also,
coatings contain a mixture of several organic solvents in order to maximize gloss, transfer efficiency, and
other desirable coating properties. Organic solvent recovery is usually most effective economically and
technically when used with air streams containing a few, expensive organic solvents [1].
Carbon Adsorption with Steam Desorption
In a carbon adsorption system with steam desorption, carbon beds adsorb organic solvents
from the air stream passing through them. In most cases, one bed is in the adsorption phase while the
second bed is in the steam desorption phase. In the desorption phase, steam is passed through the
carbon to release the collected organic solvent. Once the steam has been passed through the carbon, it
is then condensed and the organic solvent is removed through the process of settling or distillation. The
carbon desorption phase can be performed on site or the spent carbon can be shipped off-site for
4-1
-------
regeneration. The efficiency of this type of system can be very high when there are low organic solvent
concentrations in the air exhausted from the application booths [1].
Advantages of the carbon adsorption/steam desorption system are that they are relatively
inexpensive and have been proven effective over the years. They can handle a relatively high volume of
air (about 30 to 1,400 cubic meters per minute) efficiently. Also, because the organic solvent is
reclaimed there are no carbon monoxide (CO), carbon dioxide (CO2), or nitrogen oxide (NOX)
emissions that are usually associated with the destruction of used organic solvent in air streams by
combustion. Also, if the recovered organic solvents can be re-used it reduces the demand for
production of additional organic solvent [1].
The disadvantages of these systems result from the difficulty of separating organic solvents from
each other for re-use. Also, if water soluble organic solvents (i.e., alcohols, etc.) are used, it may be
difficult to separate the organic solvents from water. In addition, carbon does not adsorb all organic
solvents. Therefore, the blend of organic solvents in use must be determined and considered before
choosing this type of system. Another problem with systems of this type is that organic solvent quality
can be degraded while the organic solvent is held on the carbon [1].
Low-Temperature Condensation
All organic solvents will condense to liquid form when reduced to a low enough temperature.
Using some newly developed equipment and heat recovery techniques borrowed from the Brayton
cycle, the condensation process can be used to recover organic solvent from waste air streams [1].
This system can be costly and requires air streams of 30 cubic meters per minute (1,060 cfm)
or less. It also requires humidity controls on the exhaust stream being treated because water vapor
condenses and freezes in pipes [1].
Once the organic solvent is recovered it can be used for non-production activities such as spray
gun cleaning, or it can be sent off site to be filtered and reconditioned [1].
Organic Solvent Destruction
The prevalent method of destruction of organic solvent emissions from coatings is thermal
oxidation or incineration. The organic solvent-containing exhaust air is heated to a very high
temperature, which converts it to carbon dioxide and water through the process of combustion. There
are several options for VOC and/or HAP control by incineration. They include: 1) direct, gas-fired,
thermal recuperative incineration; 2) direct, gas-fired, thermal regenerative incineration; 3) direct,
electrically heated, thermal regenerative incineration; 4) direct, electrically heated, catalytic incineration;
4-2
-------
and 5) direct, gas-fired, catalytic incineration [1].
Direct, gas-fired, thermal recuperative incinerators usually operate at temperatures of 760
• C (1400 • F) and use a natural gas burner. The residence time for organic solvent rich air is about 0.5
seconds. This type of unit is usually constructed solely of steel and utilizes heat exchangers to recover
heat. These incinerators can achieve a high VOC destruction (98 percent efficient or better), especially
when the VOC concentration in the inlet stream is high [1]. These devices are not the most efficient for
heat recovery, but it is possible to use waste heat to produce steam or heated air. Their all steel
construction becomes a problem when hydrochloric acid is produced as a product of the combustion of
chlorinated organic solvents [1].
Direct, gas-fired, thermal regenerative incinerators utilize ceramic towers in a 3-, 5- or 7-
chamber configuration to achieve heat recovery efficiencies in the 80-95 percent range. For this
reason, the unit produces less NOX emissions and uses very little natural gas. Regenerative incinerators
can be effective for airstreams with flow rates of 280 to 4,250 cubic meters per minute (10,000 to
150,000 cfm) [1]. Regenerative incinerators are capable of achieving high destruction efficiencies
similar to those of recuperative incinerators [1].
Direct, electrically heated, thermal regenerative incinerators are based on the principle that
if enough organic solvent emissions enter the unit at high concentrations then the combustion process
will maintain itself using only the heat of the organic solvent combustion. Electric coils within the unit are
used to bring the unit up to its operating temperature (760 • C) as well as to help maintain operating
temperature when the organic solvent concentrations in the effluent stream drop below critical levels
[1]. The unit itself creates no NOX, CO, or CO2 emissions because it operates on electricity instead of
the combustion of natural gas or other fuels [1]. Some problems with these types of units include a long
startup time and costly operation due to the electricity required to operate them properly. Another
problem with this type of incinerator is that hydrochloric acid from the incineration of chlorinated
organic solvents can destroy the electric coils in the unit [1].
Direct, electrically heated, catalytic incinerators use precious metal catalysts as an integral
part of the combustion chamber which allows for lower combustion temperatures in the range of 320 to
430 • C (versus 760 • C for non-catalytic incinerators). These units use electric coils for startup and
temperature maintenance [1]. These units are typically constructed completely of steel with integrated
catalyst units. They do not produce NOX or CO, nor do they require large amounts of electricity
because they run at relatively low temperatures and they use heat exchangers to pre-heat incoming air.
The catalyst must be cleaned periodically. Also, the catalyst effectiveness may be masked by halogens,
metals, non-organic solvent resins, and other materials. If appropriate materials are used in the
4-:
-------
combustion chamber and the electric coils, halogenated solvents can be incinerated [1].
Direct, gas-fired, catalytic incinerators are similar to the electric catalytic incinerators except
that they use gas fired burners, instead of electric coils, for makeup heat. They also use precious metal
catalysts. These incinerators utilize heat exchangers to pre-heat exhaust air, which reduces fuel
requirements to relatively small amounts. If their catalysts are contaminated by halogen resins or high
boiling organic solvents, the units may produce some NOX or CO emissions [1].
Catalytic Magnet Wire Oven?, are similar in nature to many of the previously mentioned
destruction technologies. However, these units combine the coating application, curing, and solvent
destruction into one unit. With the aid of a catalyst, the solvents released from the application of
coating to magnet wire are incinerated and the heat generated is used to cure the wire coating. These
units are unique to the wire coating industry. Destruction efficiencies from these types of units can range
from 85 to 99 percent. In general, newer units have a destruction efficiency closer to the 99 percent
while the older units have lower destruction efficiencies. While these units are not typically considered
"add-on" control devices because they are integrated into the application unit, the more typical "add-
on" control devices can be applied downstream from these units in order to achieve increased
reductions.
Organic Solvent Concentrators
In some cases it is necessary to concentrate organic solvents before incineration because they
are not present in high enough concentrations for incineration equipment to perform efficiently.
Increased organic solvent concentration can reduce the size, installation costs, and operating costs
required for incinerators [1].
There are two common types of organic solvent concentration: rotary carbon adsorption and
zeolite adsorption.
The rotary carbon adsorber consists of carbon blocks on a rotating carousel. These blocks
adsorb organic solvents, which are then released by passing a stream of hot air over a small area of the
rotating carbon. The hot air stream is sent to some type of control unit or organic solvent recovery
system [1]. Rotary carbon systems are not expensive because the carbon they use to adsorb organic
solvents is relatively inexpensive. They are also relatively easy to operate. Exhaust streams can be
concentrated from 10 to 100 times their original concentration. However, the exhaust streams need
some type of humidity control to prevent interference of water with the organic solvent adsorption.
Another potential pitfall of these systems is that carbon may not readily adsorb some organic
solvents [1].
4-4
-------
Zeolites are naturally formed materials that adsorb organic solvent readily. They can be
tailored to collect organic solvents selectively by molecular size. This tailoring process can eliminate the
need for humidity controls like those required for carbon systems. Zeolite systems are set up much like
the rotary carbon adsorbers. However, zeolites are more efficient than carbon at adsorbing low
concentrations of organic solvent [1]. The major problem with zeolites is their higher expense versus
carbon and the fact that some organic solvents produce exhaust fumes in zeolite systems [1].
Alternative Oxidation Technologies
In ultraviolet light, ozone oxidation (uv/ox) systems an organic solvent is exposed to
high-intensity ultraviolet light. It is then mixed with an ozone-rich water wash which converts the
organic solvent to carbon dioxide and water through an oxidation process. The water is then filtered
through activated carbon beds where more ozone is injected and further oxidation occurs on the
carbon. These systems can produce high destruction efficiencies with no CO or NOX emissions [1].
The disadvantages of these systems are that they have high costs, they are complex units, and they
produce a wastewater stream. Also, this technology has not been used extensively for coating finishing
applications [1].
Bioreactors (or biqfilters) are large, bacteria-charged chambers. When air laden with organic
solvent is passed through a bioreactor, organic solvent is captured in the packed medium and degraded
to CO2 and water (HCL is released if the solvent is chlorinated). Bioreactors consume little energy and
produce no NOX, but they are very sensitive to fluctuations in the supply of organic material they
receive, as well as to humidity and temperature. Early conventional or packed bed systems required
large amounts of space. However, more compact designs are becoming available. There has been
little past experience with bioreactor units in the context of the finishing industry [1].
MONITORING REQUIREMENTS AND RATIONALE
The proposed standards require continuous monitoring system installation, operation and
maintenance for control and recovery devices. The use of parameter monitoring can accurately
demonstrate proper operation and maintenance of the control or recovery device, without the expense
associated with CEMS. The monitoring parameters for the proposed standards were selected because
they are good indicators of control or recovery device performance, and instruments are readily
available at a reasonable cost to continuously monitor these parameters. The operating parameter
levels are established during performance tests. The continuous monitoring ensures that the operating
4-5
-------
parameter levels indicating proper performance during the performance test continue to be achieved
during the operation of the control device. The proposed standards contain monitoring requirements
for capture system bypass lines, thermal and catalytic oxidizers, magnet wire ovens, carbon adsorbers,
condensers, and emission capture systems.
Emission capture system that contains bypass lines
For each emission capture system that contains bypass lines that could divert emissions away
from the control device to the atmosphere, the proposed standards require the owner or operator to
monitor or secure the valve or closure mechanism in a nondiverting position. By ensuring that emissions
are not escaping through a bypass line, the emissions are properly routed to the control device for
destruction or recovery.
Thermal oxidizer
For a thermal oxidizer, the proposed standards require the owner or operator to install a gas
temperature monitor in the firebox of the thermal oxidizer or in the duct immediately downstream of the
firebox before any substantial heat exchange occurs. Thermal oxidizers can achieve high destruction
efficiencies when operated properly. Tests have indicated that lower temperature can cause significant
decreases in control device efficiencies, while temperature increases can adversely affect control device
efficiency by decreasing the thoroughness of mixing of offgas, burner gases, and combustion air. Given
the large effect of temperature on efficiency, monitoring the temperature in the firebox is an effective
parameter to monitor for a thermal oxidizer. In addition, temperature monitors are relatively
inexpensive to buy and operate.
Catalytic oxidizer
For a catalytic oxidizer, the proposed standards require the owner or operator to install gas
temperature monitors both upstream and downstream of the catalyst bed to measure the temperature
difference across the bed. The temperature rise across the bed is proportional to the VOC loading to
the system. By monitoring the temperature rise, system performance can be ensured.
Carbon adsorber
For a carbon adsorber used as an add-on control device, the proposed standards require the
4-6
-------
owner or operator to monitor the total regeneration desorbing gas (e.g., steam or nitrogen) mass flow
for each regeneration cycle and the carbon bed temperature after each regeneration and cooling cycle.
These parameters are indicative of carbon adsorber performance. Carbon bed temperature monitors
and steam flow meters, which indicate the quantity of steam used over a period of time, are available at
reasonable cost.
Condenser
For a condenser, the proposed standards require the owner or operator to monitor the
condenser outlet (product side) gas temperature. The outlet temperature of a condenser is correlated
to the performance of the device and, therefore, monitoring the condenser outlet gas temperature is a
good indicator of condenser performance. By ensuring that the outlet gas temperature of the condenser
stays within the range measured during the performance test, a correlation can be made that the desired
amount of recovery is being achieved. Condenser temperature monitors are available at a reasonable
cost.
Flow measurement device
For each flow measurement device, the proposed standards require the owner or operator to
install a flow sensor in the duct to measure flow from the emission capture system to the add-on control
device. For each pressure drop measurement device, the proposed standards require the owner or
operator to install a pressure sensor in a position that will measure the pressure drop across each
opening being monitored. The efficiency of an emission capture system is directly related to the amount
of air designed to flow through the enclosure. Monitoring the flow rate through the enclosure is the best
measure of the continued performance of the capture system. If the measurement devices indicate a
change in flow or pressure drop (compared to the design or tested values), then this is an indication that
the emission capture system may not be performing as it did during the compliance demonstration.
4-7
-------
REFERENCES
1. 1997 Organic Finishing Guidebook and Directory Issue. Volume 95, Number 5A, Metal
Finishing, Tarrytown, NY, May 1997.
4-8
-------
HAP Emission Reductions, Non-Air Quality Health and
Environmental Impacts, and Energy Requirements for the
Miscellaneous Metal Parts and Products NESHAP
-------
HAP Emission Reductions, Non-Air Quality Health and Environmental Impacts, and Energy
Requirements for the Miscellaneous Metal Parts and Products NESHAP
This memorandum presents the estimated HAP emission reductions and discusses the non-air
quality health and environmental impacts and energy requirements associated with implementing the
MACT level of control at existing and new facilities within the miscellaneous metal parts and products
(MMPP) source category. The projected HAP emission reductions were developed using a model
plant approach and were then scaled up to the expected number of affected facilities nationwide.
APPROACH
The HAP emission reductions associated with implementing the MACT standard for the
MMPP industry were analyzed for each of the five model plants that were identified in the
memorandum entitled "Development of Model Plants for the Mscellaneous Metal Parts and Products
NESHAP Project" (presented on page 3-1 of this TSD). The estimated HAP emission reductions for
each model plant were then multiplied by the number of existing facilities represented by each model to
project the impacts to a nationwide value.
Non-air quality health and environmental impacts and energy requirements resulting from the
implementation of the proposed standards were also considered. Sufficient information was not
available to allow these impacts to be quantified, but the potential impacts of proposed standards are
discussed below.
ESTIMATED HAP EMISSION REDUCTIONS
The estimated reduction in HAP emissions resulting from implementing the proposed standards
at existing facilities is presented in Tables la and Ib. Emission reductions for each of the model plants
were based on the existing source MACT floor of 0.31 kg HAP emitted per liter of coating solids (2.6
Ib HAP/gallon of solids). Estimates of the HAP reductions that would be achieved through
implementation of the draft standards were determined for existing sources based on a facility-by-
facility examination of the 321 facilities in the database. The HAP/solids ratio (corresponding to the
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units of the emission limitation in the draft standards) was determined for each facility in the database.
For those facilities where the HAP/solids ratio exceeded 2.6, it was assumed that the facility would
take the necessary actions to bring the ratio down to, but not beyond, this level. It was also assumed
that the amount of solids used by the facility would not change. Therefore, the compliant emission level
for these facilities was calculated by multiplying their solids usage by the compliant emission limitation of
2.6 Ibs HAP/gal solids. The resulting emission level, in pounds of HAP, was subtracted from their
current (non-complying) emission level (Ibs HAP) to yield their emission reductions. The emission
reductions to be achieved by each non-complying facility were summed to estimate the reductions from
all database facilities.
To extrapolate the emission reductions calculated for the database facilities to a nationwide
basis, the average reduction per facility in each size range was determined and the results multiplied by
the estimated number of non-complying facilities in that size range. The five resultant values (one for
each size range) were then summed to give a nationwide total. As shown in Tables la and Ib, total
nationwide HAP emission reductions from implementing the MACT level of control at existing facilities
are estimated to be about 23.4 million kg (51.6 million Ibs) per year. This represents a 48 percent
reduction in HAP emissions industrywide. In Tables la and Ib, each model plant was assumed to
comply with the standard by converting to non-HAP surface preparation materials, cleaning materials,
and adhesives as well as reduced-HAP coatings and thinners.
HAP emission reductions were calculated for new facilities in a similar manner as the existing
facilities. The reductions were for each of the model plants were based on the new source MACT
floor of 0.23 kg HAP emitted per liter of coating solids (1.94 Ib HAP/gallon of solids). As shown in
Tables 2a and 2b, total nationwide HAP emission reductions from implementing the MACT level of
control at new facilities are estimated to be about 728 thousand kg (1.6 million Ibs) per year. This
represents a 57 percent reduction in HAP emissions industry wide. Since there is no baseline emission
level for new facilities, it was assumed that new facilities would follow the same trends as existing
facilities in the absence of the standard. As a result, the emissions per model plant were calculated in
the same manner as for existing facilities using the new source limit.
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NON-AIR QUALITY HEALTH AND ENVIRONMENTAL IMPACTS
The compliance options expected to be used by the industry for this standard are not expected
to create significant adverse environmental impacts. Coating material reformulation is expected to be
used by most facilities to reduce their emissions of hazardous air pollutants (HAP) from their coaling
operations. The use of reformulated coating materials is expected to result in the generation of equal, or
smaller, amounts of solid waste, waste solvents, and wastewater. In addition, the reformulated coating
materials have the benefit of reduced percentages of HAP in the wastes that are generated. The
expected increase in the use of powder coatings will result in a decrease in the generation of waste
because most powder coating booths utilize dry filters to collect overspray. The dry powder that is
collected as overspray can often be recycled, thus reducing the overall amount of waste material.
Because of the many variables involved, and the lack of specific information on the control approach
that will be selected by the affected sources, these impacts could not be quantified.
ENERGY REQUIREMENTS
The impact of the standard on the amount of energy consumed by surface coating operations
within the affected industry could not be determined with the information available. Energy consumed is
extremely variable and depends on the type and formulation of coating materials used, the film thickness
needed for each product, the size and shape of the products being coated, curing oven capacity and
desired line speed, and the method of heating the curing oven. Increases in energy consumption by the
existing capture systems and add-on control devices is also variable and depends on whether increased
utilization of these devices will be a part of the control strategy used by the facilities that have these
devices. Because there is such a range of factors, and because some compliance options may result in
a decrease in energy consumption (for example, high solids coatings may require less energy to cure
than conventional coalings), it was assumed that on a nationwide basis there would be no quantifiable
change in energy consumption as a result of the standard.
5-:
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Table la. Summary of Estimated HAP Reductions
for Existing Sources (kg/yr)
Model
Plant
1
2
3
4
5
Total # of Non-complying
Facilities Nationwide
264
219
162
76
13
734
Average HAP
Reductions/ Facility
(kg/yr)
8,614
29,381
31,113
80,318
274,761
Nationwide HAP
Reduction (kg/yr)
2,274,142
6,434,494
5,040,344
6,104,135
3,571,897
23,425,012
Table Ib. Summary of Estimated HAP Reductions
for Existing Sources (Ibs/yr)
Model
Plant
1
2
3
4
5
Total # of Non-complying
Facilities Nationwide
264
219
162
76
13
734
Average HAP
Reductions/ Facility
18,991
64,775
68,593
177,070
605,745
Nationwide HAP
Reduction (Ibs/yr)
5,013,624
14,185,632
11,112,057
13,457,315
7,874,685
51,643,313
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Table 2a. Summary of Estimated HAP Reductions
for New Sources (kg/yr)
Model
Plant
1
2
3
4
5
Total # of Non-complying
Facilities Nationwide
9
8
6
3
0
26
Average HAP
Reductions/ Facility
(kg/yr)
7,983
28,379
32,744
77,590
339,955
Nationwide HAP
Reduction (kg/yr)
71,843
227,030
196,467
232,770
0
728,110
Table 2b. Summary of Estimated HAP Reductions
for New Sources (Ibs/yr)
Model
Plant
1
2
3
4
5
Total # of Non-complying
Facilities Nationwide
9
8
6
3
0
26
Average HAP
Reductions/ Facility
(Ibs/yr)
17,599
62,564
72,189
171,057
749,472
Nationwide HAP
Reduction (Ibs/yr)
158,387
500,516
433,136
513,170
0
1,605,209
5-5
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APPENDIX A
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MODEL PLANT DEVELOPMENT
The "final" database from which model plants and estimated impacts were determined contains
data from 332 facilities. Eleven of these facilities are in the magnet wire and rubber-metal
categories and were not included in the analysis because they will be in separate subcategories.
Data from the remaining 321 facilities were grouped into 5 size ranges, with size measured by
solids usage. Each size range is represented by a "model plant", designated as Model Plants 1
through 5. It is currently estimated that there are 1500 existing, major source facilities
nationwide. The following table presents a breakdown of the 1500 facilities into the 5 model
plant size categories.
Table al. Distribution of Existing Facilities by Model Plant
Model
Plant
1
2
3
4
5
Size Range (gallons
of solids)
< 5,000
5,000- 15,000
15,001 -35,000
35,001 -75,000
> 75,000
No. of Database
Facilities
105
74
81
44
17
321
% of Database
Facilities
33
23
25
14
5
100
No. of Facilities
Nationwide (est.
total of 1,500)
495
345
375
210
75
1,500
Many facilities within the source category are currently operating at HAP emission levels that
comply with the draft emission limitation (assumed to be 2.6 Ibs FtAP/gallon of solids). These
facilities would not be required to reduce their FtAP emission levels. (Twelve synthetic minor
facilities that do not meet the 2.6 Ibs FtAP/gallon limit were assumed to be complying facilities
5-6
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because they would not have to reduce their emissions.) Therefore, the number and percentage
of the facilities within each size range that would not comply with the draft standards for
existing sources without emission reductions was determined. Model plant parameters related
to material usage and HAP content were determined using data from only the non-complying
segment of the database population. Parameter values from all non-complying facilities within
each size range were averaged to determine the model plant value.
To estimate nationwide impacts, it was assumed that the population of facilities in the database
(321 facilities) was a representative sample of the nationwide population (estimated to be 1,500
facilities). Therefore, about 18 percent of the facilities nationwide would be represented by
model plant 1 (33% are in that size range and 53.3% are non-complying). With 1,500 existing
facilities in the source category, 264 (1,500*.33*.533 = 264) would be represented by model
plant 1 and the impacts determined for it.
Table a2. Summary of Non-Compliant Existing Facilities
Model
Plant
1
2
3
4
5
# of Database
Facilities That Are
Non-complying
56
47
35
16
3
157
% of Database
Facilities That Are
Non-complying
53.3
63.5
43.2
36.4
17.6
48.9
No. of Facilities
Nationwide (est.
total of 1,500)
495
345
375
210
75
1,500
# of Non-complying
Facilities Nationwide
264
219
162
76
13
734
To project impacts from the estimated 45 new facilities that become affected sources
each year, the same method of distributing the facilities by model plant sizes and
baseline compliant status was used.
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Table a3. Distribution of New Facilities by Model Plant
Model
Plant
1
2
3
4
5
Size Range (gallons
of solids)
< 5,000
5,000- 15,000
15,001 -35,000
35,001 -75,000
> 75,000
No. of Database
Facilities
105
74
81
44
17
321
% of Database
Facilities
33
23
25
14
5
100
No. of New
Facilities
Nationwide (est.
total of 45 )
15
11
11
6
2
45
Table a4. Summary of Non-Compliant New Facilities
Model
Plant
1
2
3
4
5
# of Database
Facilities That Are
Non-complying
65
54
42
20
O
% of Database
Facilities That Are
Non-complying
61.9
73.0
51.9
45.5
17.6
No. of New
Facilities
Nationwide (est.
total of 45)
15
11
11
6
2
# of Non-complying
Facilities Nationwide
9
8
6
3
0
5-i
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184
57.3
45
26
5-9
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Methodology for Estimation of Monitoring,
Recordkeeping, and Reporting (MR&R) Burden
-------
Methodology for Estimation of Monitoring, Recordkeeping, and Reporting (MR&R) Burden
The purpose of this memo is to present assumptions used to determine an estimate of the
burden, in terms of labor hours and costs, that will be imposed on affected sources by the monitoring,
recordkeeping, and reporting requirements of the NESHAP. The methodology and assumptions
presented here are based on the expectation that nearly all facilities in the source category will choose
to, and be able to, comply with the emission limits by using reformulated (low-HAP, or non-HAP)
coating materials. The use of add-on control devices to reduce HAP emissions from surface coating
operations in the source category is very rare, and no attempt has been made to estimate the costs
associated with monitoring these devices.
Attachment A presents a list of the burden items, and the estimated effort for those items, that are
included in the calculation of MR&R burden that is reported in the OMB 83-1 package. A draft of the
values that were estimated for these burden items was presented to industry stakeholders at a meeting
held on February 8, 2001. Several industry stakeholders commented that the MR&R burden faced by
industry is highly variable and that our approach to estimating these costs should account for the fact
that some facilities will incur significantly higher costs than others. In response to these comments, we
considered several methods whereby we could account for the range of anticipated burden. The
number of coating materials used by facilities responding to the industry questionnaire was selected as
the primary measure of the burden. We assumed that the burden of tracking coating material usage and
formulation would increase as the number of materials used at a facility increased. Facility size was
considered to be less accurate measure because very small facilities may use many different coating
materials and very large facilities may use only a few materials, depending on the products being
coated.
The facilities in the MACT database were ranked and divided into three ranges based on the
number of coating materials they reported in the questionnaire responses. In preparing this ranking, we
found that the responses often reported "groups" of similar materials as one entry. To generate a
reliable count of the total number of materials used by facilities, the number of materials included in
these groups had to be determined. Since it was not always noted how many materials were in each
group, an assumption was needed to determine how many materials were represented by the group. A
6-1
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random sampling of the materials contained in the groups of data was taken. The sample results
indicated that the average reported "group" of coatings represents 7 materials.
The following three ranges were developed, based on the number of coating materials reported:
Range I < 25 Materials (183 database facilities, 57% of the facilities in the
database)
Range H 25 to 100 Materials (114 facilities, 36%)
Range IE >100 Materials (23 facilities, 7%)
The maximum number of materials reported by any one facility in the database was 288.
We made the assumption that the Range n facilities would require two times the recordkeeping and
reporting effort that Range I facilities would require. In addition, it was assumed that Range HI facilities
would require three times the effort that Range I would require. This is based on the assumption that as
number of materials increase, automation and increased efficiency would allow the larger facilities to
perform tasks at a faster rate.
The number of facilities in each Range nationwide was then projected from the distribution (by
percentages) of facilities in the MACT database. This was based on our previous assumption of 1500
existing facilities and 45 new facilities per year. The projected number of facilities in each Range across
the MMPP industry is:
Range I 855 existing facilities; 26 new facilities
Range n 540 existing facilities; 16 new facilities
Range m 105 existing facilities; 3 new facilities
After reviewing the list of burden items attributed to the MR&R requirements (presented in
Attachment A), we concluded that burden items 5 (Gather Information, Monitor and Inspect) and 6
(Process/Compile Review) were the activities that would be affected by the number of materials used.
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In the draft presentation made at the February 8, 2001 stakeholders meeting, we had assumed that
for Item 5 all facilities would require 12 hours per month. For our current estimate we are assuming
that facilities in Range I (those using the fewest coating materials) would require 12 hours and that other
facilities would require more effort. Using the 12 hour value and the scaling factors developed above,
we calculated the following estimates for the number of hours to assign to Item 5:
Range I (12 hours effort per facility per month)
855 facilities X 12 hours per facility = 10,260 hours
Range n (2x the effort for Range I)
540 facilities X 24 hours per facility = 12,960 hours
Range HI (3x the effort for Range I)
105 facilities X 36 hours per facility = 3,780 hours
Total for all Ranges = 27,000 hours
Average burden (1500 facilities) =18 hours
For burden Item 6, our original assumption of 8 hours effort per month for all facilities was used
as the estimated effort for those facilities in Range I. The following is a summary of the estimated
burden for Item 6 for each of the three Ranges:
Range I (8 hours effort per facility per month)
855 facilities X 8 hours per facility = 6,840 hours
Range n (2x the effort for Range I)
540 facilities X 16 hours per facility = 8,640 hours
-------
Range m (3x the effort for Range I)
105 facilities X 24 hours per facility = 2,520 hours
Total for all Ranges = 18,000 hours
Average burden (1500 facilities) = 12 hours
The projected industry-wide average values of 18 hours for burden Item 5, and 12 hours for
burden Item 6 were used, along with the other burden item estimates and labor rates presented in
Attachment A, to generate the values reported in the OMB 83-1.
The industry-wide fifth year MR&R cost using these assumptions is estimated to be $44,758,958.
6-4
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ATTACHMENT A
ASSUMPTIONS USED IN BURDEN ESTIMATES
-------
Description of Respondent Activities (Burden Items)
(1) Read Rule and Instructions are the activities, less training, which involve comprehending the
provisions in the standard and understanding how they apply to the respective points at a facility.
(2) Plan Activities represents such burdens as design, redesign, scheduling, and selecting methods
of compliance.
(3) Training represents the portion of activities from (1) Read Rule and Instruction for which an
average facility would elect to provide classroom instruction. The standard does not require specific
training itself.
(4) Create. Test, and Research and Development are the activities involving testing, retesting,
establishing parameter monitoring levels and determining emission point applicability.
(5) Gather Information. Monitor, and Inspect are the activities involving collection of monitored
data and other related activities.
(6) Process/Compile and Review are the activities that involve analysis of the information collected
during the compliance period for accuracy and completeness, and include generation of appropriate
internal reports and records required as a result.
(7) Complete Reports represents the activities normally associated with filling out required forms.
Because the rule requires no standardized forms, these activities relate to the preparing of formal
reports and cover letters as appropriate.
(8) Record/Disclose are activities that are solely recordkeeping that occur once the appropriate
report information has been extracted. These activities involve software translation, duplication, or
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archival processes normally associated with data management and storage common to this industry.
(9) Store/File are again activities that are solely recordkeeping that occur once the appropriate
report information has been extracted. The activities involve the management life cycle of records, from
the time they are filed and stored, to the time they are disposed.
(10) LDAR Reporting and Recordkeeping is the burden that is associated with requirements to
develop and implement a leak detection and repair plan. (This rule has no LDAR requirements)
(11) Capital Costs of Monitoring and Recordkeeping Equipment is the cost for purchasing
automated monitoring and recording devices that are required by the standards.
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Assumptions Used in Burden Estimates
(m) There are 1500 major (or "affected") sources and all are assumed to come into
compliance three years after the effective date of the rule, as required by the rule.
(n) There are expected to be 135 new, modified, or reconstructed sources during the first
three years (45 in each year).
(o) A total of 40 hours were estimated for obtaining, reading, and understanding the
requirements of the standard. (Burden Item 1)
(p) An estimated 40 hours would be required for communication and coordination with
materials suppliers to ensure that all needed information relative to HAP and solids
content of materials is provided with each purchase or shipment.(Burden Item 2)
(q) A total of 76 hours were estimated for training an additional employee in the
preparation of records and reports, as well as creating a "template" for the
reports. (Burden Items 3 &4)
(r) A total of 30 hours per month were assumed for gathering or retrieving the inventory
data from which the monthly compliance determination will be made and for the
analysis of the data.(Burden Items 5&6)
(s) An estimated 8 hours would be required for each of the semi-annual compliance
reports submitted to EPA. (Burden Item 7)
(t) A total of 8 hours were estimated for managing (copying, distributing, storing, etc), each
of the semi-annual reports.(Burden Items 8&9)
(u) Average labor costs per hour are; technical - $54.92, management - $78.10, clerical -
$36.16.
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(v) In addition to the technical hours described above, management hours equal to 5
percent and clerical hours equal to 10 percent of the technical hours are included in the
total burden estimate.
For the second year (and subsequent years) after facilities begin complying with the rule, the
following estimates were included:
(a) A total of 20 hours were assumed annually for rereading portions of the standards,
coordination with suppliers, and training additional employees.
(b) A total of 30 hours per month were assumed for completing the compliance
determination.
(c) An estimated 8 hours were assumed for preparing each semi-annual compliance report.
(d) An estimated 8 hours were assumed for "managing" each semi-annual report.
(e) Average labor costs per hour are; technical - $54.92, management - $78.10, clerical -
$36.16.
(f) Management hours equal to 5 percent and clerical hours equal to 10 percent of the
technical hours are included in the total burden estimate.
-------
Cost Impact Analysis for the Miscellaneous
Parts and Products NESHAP
-------
Cost Impact Analysis for the Miscellaneous Metal Parts and Products NESHAP
This memorandum presents the approach developed to estimate the cost impacts of
implementing the MACT level of control at existing and new miscellaneous metal parts and products
surface coating operations. The cost impacts were developed using a model plant approach and were
then projected to a nationwide number of facilities. The first section of this memorandum describes the
approach that was used to estimate the compliance alternatives and the costing assumptions. The
second section presents the results of the cost analysis on a model plant and nationwide basis.
APPROACH
The basic approach used to estimate the cost impacts of the standards was to predict the
method of compliance to be used by each model plant and the costs associated with that method. The
model plants and estimated impacts were determined from the final MACT database of 321 facilities.
It was estimated that there are 1500 existing, major source facilities nationwide. The following table
presents a breakdown of the 1500 facilities into 5 model plant size categories.
Model
Plant
1
2
O
4
5
Size Range (gallons
of solids)
< 5,000
5,000- 15,000
15,001 -35,000
35,001 -75,000
> 75,000
No. of Database
Facilities
105
74
81
44
17
321
% of Database
Facilities
33
23
25
14
5
100
No. of Facilities
Nationwide (est.
total of 1,500)
495
345
375
210
75
1,500
7-1
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Many facilities within the source category are currently operating at HAP emission levels that
comply with the emission limitation of 0.23 kg HAP/L solids (1.9 Ib HAP/gal solids) for new sources,
and 0.31 kg HAP/L solids (2.6 Ib HAP/gal solids) for existing sources. These facilities were assumed
to already be in compliance, and therefore, would not have to reduce their emissions. The numbers and
percentage of facilities that would not comply with the draft standards for new and existing sources
without emission reductions was determined.
Model
Plant
1
2
3
4
5
# of Database
Facilities That Are
Non-complying
56
47
35
16
3
157
% of Database
Facilities That Are
Non-complying
53.3
63.5
43.2
36.4
17.6
48.9
No. of Facilities
Nationwide (est.
total of 1,500)
495
345
375
210
75
1,500
# of Non-complying
Facilities Nationwide
264
219
162
76
13
734
Because an affected source-wide average HAP limit approach was selected for the standard,
there is a wide variety of actions that a facility could take to lower its HAP emissions from coating-
related operations to a compliant level. Reductions in the HAP contents of adhesives, surface
preparation materials, thinning solvents, and cleaning materials as well as the coatings themselves, all
contribute toward compliance. Converting from HAP-containing liquid coatings to powder coatings
can essentially eliminate HAP emissions from the coating operation. Add-on control devices could be
installed to reduce HAP emissions from selected exhaust gas streams, such as a curing oven exhaust.
(Thermal incinerators can achieve HAP reductions in excess of ninety percent.) Various combinations
of the actions outlined above can also be implemented to achieve the necessary HAP emission
reductions.
It was estimated that no facility within the industry would install add-on control devices as a
result of the proposed standards. The capital costs and annual operating costs of add-on control
devices usually make them less desirable than other compliance options for reducing volatile organic
7-2
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emissions from coating operations. The data collected in the miscellaneous metal parts and products
survey indicate that there are a few add-on control devices in use in this industry. Even though these
facilities may consider the devices' HAP emission reductions when determining compliance with the
proposed standards, no additional cost was attributed to them in our analysis because they would be
operated even in the absence of the proposed standards.
For the reasons presented above, the option that would likely be selected by most facilities
within the industry is the use of a combination of lower HAP liquid coatings and non-HAP adhesives,
surface preparation materials, and cleaning materials. It was also assumed that the use of lower HAP
coatings would be accompanied by the use of lower HAP coating thinners.
Because the compliance option expected to be used by most facilities to comply with the
standard utilizes reformulated raw materials rather than a different coating technology or add-on
controls, no capital costs were estimated. Some facilities will, no doubt, encounter up-front costs
during a materials conversion. Some facilities may need to upgrade application equipment to be able to
apply reformulated lower HAP coatings that may have a higher viscosity. These costs will be site
specific, however, and will most likely be offset by increased efficiencies of the new equipment and by
reductions in the cost of handling and disposal of HAP-containing wastes. The impacts of variables
such as shelf life of coatings, curing requirements, or spray booth ventilation rates could also be positive
or negative depending on the specific facility being evaluated. No cost information was available for
these variables. It should also be noted that there will be some cost incurred for testing or qualifying
new coating materials. These costs are also very site specific depending on the products manufactured,
the relative usage of each type of material, and the availability of demonstrated reformulated materials.
For liquid coatings there exists a wide range of HAP contents, coating solids contents, and
prices. Because of the variability from one facility to another regarding coating needs, it was not
possible to estimate each of the variables that must be considered to determine the increase or decrease
in costs that would be encountered in converting to a lower HAP coating. During the development of
the Large Appliances NESHAP, several contacts were made with industry representatives in an
attempt to obtain data on the relative costs of lower HAP coatings versus higher HAP coatings (Docket
A-97-41, Item n-E-12). Most of these contacts did not result in useful cost data. Because the cost of
coatings is usually compared in terms of coating solids content ($/L coating solids) or actual coverage
capability ($/sq m), we found that cost data was not readily available in terms of HAP content. An
f-J
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assumption was made, therefore, that it was reasonable to expect that the higher percentage of solvent
in a low solids coating would result in a corresponding higher percentage of HAP. Likewise, the lower
percentage of solvent in a high solids coating would result in a lower percentage of HAP. This
assumption correlating high solids to lower-HAP and low solids to higher-HAP allowed us to use
available data comparing the costs of low solids and high solids coatings. In an article appearing in
Products Finishing Magazine, the costs of high solids coatings were reported to be about 30 percent
less than the costs of low solids coatings [1]. One industry representative supplied information
indicating that the costs of their new high solids coatings are about 10 percent higher than the costs of
low solids coatings [2]. Information from a third source indicated practically no difference in the costs
between low solids and high solids coatings [3]. Because of the many site specific variables, and the
lack of a trend in the cost information available, it was assumed that overall there would be no change
in annual costs for coatings and, therefore, no cost was estimated for this analysis. It is likely, however,
that the annual costs of coatings will increase for some facilities, will remain about the same for many
facilities, and may decrease for some when the reformulation to lower HAP coatings is accompanied by
an increase in coating solids content (and thus, greater coverage and less waste per a given volume).
For adhesives, as for other coatings, no change in costs was predicted for converting to non-
HAP materials. Individual facilities may experience cost increases or decreases depending on the types
and quantities of adhesives used. A telephone survey of several adhesives manufacturers conducted
during the development of the NESHAP for the Plastic Parts and Products Surface Coating Source
Category resulted in the collection of cost and HAP data for seventeen different adhesives. The data
showed no clear relationship between the costs of the adhesives and the HAP content, and it was
assumed that reformulating to non-HAP adhesives in miscellaneous metal parts and products would
result in no additional costs [4].
The surface preparation materials, thinning solvents, and cleaning materials used by the
miscellaneous metal parts and products surface coating industry in 1997 were evaluated to determine
the constituent compositions and the amount of product used. Xylene is a commonly used, inexpensive
HAP surface preparation/thinning/cleaning product and isopropyl alcohol is a commonly used, and
much more expensive, non-HAP solvent. The cost of non-HAP alternative solvents such as isopropyl
alcohol and acetone was estimated to be one hundred percent higher than the cost of higher-HAP
solvents. A summary of cost information for xylene and isopropyl alcohol is presented in Docket A-
97-41 Item II-B-12. The selection of acceptable non-HAP alternative solvents will be a case-by-case
7-4
-------
decision to be made by each facility, and the comparison of xylene to isopropyl alcohol is used here
only for the purpose of establishing a cost differential. Many types of solvent blends, which have much
reduced levels of HAP, may also be acceptable substitutes and may cost less than the non-HAP
materials. The one hundred percent increase in cost for these materials is believed to be a conservative
(worst-case) assumption, however, and also does not consider the savings that could result from
current waste solvent disposal costs [5].
For new sources it is projected that most, if not all, will use coating technologies that are
considered to be "state-of-the-art" coatings (e.g., powder coatings and low HAP liquid coatings) even
in the absence of the proposed standards. Powder coating technology has advanced rapidly in recent
years, and is gaining widespread acceptance in the miscellaneous metal parts and products industry.
Powder coatings are not only very cost effective, their use eliminates the problems associated with
worker exposure to organic solvents. Due to the cost and performance advantages of powder
coatings, it is expected that many facilities will want to convert to powder coatings if possible.
However, due to the complexity of many of the products within the miscellaneous metal parts and
products source category, many of the affected industries may not find it feasible to switch to powder
coatings. It is assumed that sufficient low HAP coatings, coating solvents, and cleaning solvents are
available to make the HAP reductions possible while maintaining similar costs. Costs for new facilities
were based on the same compliance costs as existing facilities. This is based on the assumption that
new facilities would use similar methods of compliance as existing facilities. However, it is expected
that new facilities will have the advantage of increased flexibility over existing operations. In addition,
new facilities are expected to incur monitoring, recordkeeping, and reporting costs and these have been
included in the analysis.
ESTIMATED COST IMPACTS
Tables 1 through 7 present the model plants and the estimated cost that each would incur as a
result of complying with the standard. All existing sources were assumed to come into compliance at
the end of the three-year compliance period in the proposed standards. New sources are assumed to
comply when initial operation begins. Each model plant would comply with the standards by switching
to non-HAP adhesives, surface preparation materials, and cleaning materials and reducing the HAP
content of the coating materials and thinners to meet the existing source emission limit of 0.31 kg HAP
/L of coating solids (2.6 Ib HAP per gallon of solids). The total nationwide annual cost for existing
7-5
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sources to comply with the standard is estimated to be approximately $8,943,813, the sum of the costs
for each of the five model plants. Costs were developed for existing affected facilities and for an
estimated 45 new sources each year after the proposed standards become final. The total nationwide
annual cost for new sources to comply with the standard is estimated to be approximately $716,771.
Therefore, the cost for new sources increases by $716,771 each year as each new set of 45 facilities is
added (ie. Year 1 = 1 X $716,771 for 45 facilities, and year 2 = 2 X $716,771 for 90 facilities).
In addition to the costs associated with complying with the proposed HAP emissions limitation,
affected facilities will incur costs associated with the monitoring, recordkeeping, and reporting (MR&R)
requirements of the proposed standards. The MR&R costs were developed for the first five years after
proposal, and are summarized in Table 6 [6]. Table 7 presents a summary of the estimated nationwide
costs for the proposed standards, including the costs to comply with the HAP emissions limit and the
monitoring, recordkeeping, and reporting requirements. The fifth-year nationwide total cost is
projected to be approximately $57,286,624.
7-6
-------
REFERENCES
1. G. Bocchi, The Powder Coating Institute. Products Finishing. "Powder Coating Advantages." June
1997. 5pp.
2. Telecon from K. Maw, PES, Inc., to B. Vogt, Whirlpool. Discussion of costs of lower HAP
coatings and thinners. July 29, 1999. 1 p. Docket No. A-97-41, Item No. II-E-10.
3. Facsimile from C. Profilet, Thermal Engineering Corporation, to J. Paumier, PES, Inc. Information
on costs and emissions for coatings and two spreadsheets dated January 18 and 27, 1997. 4 pp.
Docket No. A-97-41, Item No. II-D-433.
4. Letter from K. Teal, EPA:CCPG, to M. Serageldin, EPA:CCPG. Adhesive Cost Information
Prepared for the Plastic Parts and Products Surface Coating NESHAP. December 5, 2000. Docket
No. A-97-41, Item No. II-B-13.
5. Alternative Control Techniques Document - Industrial Cleaning Solvents. EPA-453/R-94-015.
U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research
Triangle Park, North Carolina, February 1994, pp. 5-8 and 5-9.
6. OMB 83-1 and Supporting Statement for the Miscellaneous Metal Parts and Products Surface
Coating Operations NESHAP. EPA Tracking Number 2056.01. Docket No. A-97-34, Item No. H-
F-l.
7-7
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Table 1. Year 1 Compliance Costs
Model
Plant
1
2
3
4
5
Solvent
Usage
(pounds)
13,173
50,340
61,838
167,817
572,699
Incremental Cost of
Using No-HAP
Solvent ($/lb)
$0.20
$0.20
$0.20
$0.20
$0.20
Incremental
Cost Per
Facility ($)
2,634.60
10,068.00
12,367.60
33,563.40
114,539.80
Number of Non-
complying
Existing Facilities
0
0
0
0
0
0
Projected
Number of
New
Facilities
15
11
11
6
2
45
Nationwide
Incremental Cost ($)
39,519
110,748
136,044
201,380
229,080
716,771
Table 2. Year 2 Compliance Cost
-------
Model
Plant
1
2
O
4
5
Solvent
Usage
(pounds)
13,173
50,340
61,838
167,817
572,699
Incremental Cost of
Using No-HAP
Solvent ($/lb)
$0.20
$0.20
$0.20
$0.20
$0.20
Incremental
Cost Per
Facility ($)
2,634.60
10,068.00
12,367.60
33,563.40
114,539.80
Number of Non-
complying
Existing Facilities
0
0
0
0
0
0
Projected
Number of
New
Facilities
30
22
22
12
4
90
Nationwide
Incremental Cost ($)
79,038
221,496
272,087
402,761
458,159
1,433,541
Table 3. Year 3 Compliance Costs
7-9
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Model
Plant
1
2
O
4
5
Solvent
Usage
(pounds)
13,173
50,340
61,838
167,817
572,699
Incremental Cost of
Using No-HAP
Solvent ($/lb)
$0.20
$0.20
$0.20
$0.20
$0.20
Incremental
Cost Per
Facility ($)
2,634.60
10,068.00
12,367.60
33,563.40
114,539.80
Number of Non-
complying
Existing Facilities
0
0
0
0
0
0
Projected
Number of
New
Facilities
45
33
33
18
6
135
Nationwide
Incremental Cost ($)
118,557
332,244
408,131
604,141
687,239
2,150,312
Table 4. Year 4 Compliance Costs
7-10
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Model
Plant
1
2
O
4
5
Solvent
Usage
(pounds)
13,173
50,340
61,838
167,817
572,699
Incremental Cost of
Using No-HAP
Solvent ($/lb)
$0.20
$0.20
$0.20
$0.20
$0.20
Incremental
Cost Per
Facility ($)
2,634.60
10,068.00
12,367.60
33,563.40
114,539.80
Number of Non-
complying
Existing Facilities
264
219
162
76
13
734
Projected
Number of
New
Facilities
60
44
44
24
8
180
Nationwide
Incremental Cost ($)
853,610
2,647,884
2,547,726
3,356,340
2,405,336
11,810,896
Table 5. Year 5 Compliance Costs
7-11
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Model
Plant
1
2
O
4
5
Solvent
Usage
(pounds)
13,173
50,340
61,838
167,817
572,699
Incremental Cost of
Using No-HAP
Solvent ($/lb)
$0.20
$0.20
$0.20
$0.20
$0.20
Incremental
Cost Per
Facility ($)
2,634.60
10,068.00
12,367.60
33,563.40
114,539.80
Number of Non-
complying
Existing Facilities
264
219
162
76
13
734
Projected
Number of
New
Facilities
75
55
55
30
10
225
Nationwide
Incremental Cost ($)
893,129
2,758,632
2,683,769
3,557,720
2,634,415
12,527,666
Table 6. Summary of Estimated Monitoring, Recordkeeping, and Reporting Costs — Years 1-5
7-12
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YEAR
1
2
3
4
5
EXISTING
SOURCE
COSTS ($)
3,746,460
0
10,864,734
38,588,538
38,588,538
EXISTING
SOURCE
BURDEN (HRS)
69,000
0
200,100
710,700
710,700
NEW
SOURCE
COSTS ($)
1,539,795
2,697,451
3,855,107
5,012,763
6,170,420
NEW SOURCE
BURDEN (HRS)
28,359
49,680
71,001
92,322
113,643
TOTAL
NATIONWIDE
ANNUAL COST
($)
5,286,255
2,697,451
14,719,841
43,601,301
44,758,958
TOTAL
NATIONWIDE
BURDEN (HRS)
97,359
49,680
271,101
803,022
824,343
Table 7. Total Estimated Cost of Proposed Standards — Years 1-5
7-13
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YEAR
1
2
O
4
5
COST TO COMPLY
($)
716,771
1,433,541
2,150,312
11,810,896
12,527,666
MONITORING,
RECORDKEEPING,
REPORTING COSTS
($)
5,286,255
2,697,451
14,719,841
43,601,301
44,758,958
TOTAL ANNUAL
COSTS ($)
6,003,026
4,130,992
16,870,153
55,412,197
57,286,624
7-14
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PRELIMINARY INDUSTRY CHARACTERIZATION:
MISCELLANEOUS METAL PARTS & PRODUCTS
SURFACE COATING SOURCE CATEGORY
Coatings and Consumer Products Group
Emission Standards Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
September 30,1998
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
CONTENTS
Section Page
I. OVERVIEW OF THE DEVELOPMENT OF MACT STANDARDS 8-4
II. SUMMARY OF DATA SOURCES AND NEXT STEPS 8-8
IE. SOURCE CATEGORY OVERVIEW 8-10
Applicability 8-10
Emissions/Emission Reduction Techniques 8-13
Current Industry Control Status 8-14
Industry Sector Profiles 8-14
Aerospace Ground Support Equipment 8-15
Agricultural and Construction Machinery Industry 8-16
Aluminum Extrusion Industry 8-17
Automobile Parts Industry 8-20
Contract Coating Facilities 8-22
Heavy-Duty Trucks and Buses Industry 8-23
Magnet Wire Industry 8-25
Metal Shipping Containers Industry 8-29
Pipe and Foundry Industry 8-32
Rail Transportation Industry 8-34
Recreational Vehicle Industry 8-35
Rubber-to-Metal Bonded Part Manufacturing Industry 8-36
Structural Metal Industry 8-37
Resources 8-40
IV. SUMMARY OF COMMENTS AND EPA RESPONSES 8-42
V. REFERENCES 8-47
5-2
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
LIST OF TABLES
TABLE 1. MISCELLANEOUS METAL PARTS AND PRODUCTS
INDUSTRY ASSOCIATIONS 8-5
TABLE 2. LIST OF SIC CODES FOR MISCELLANEOUS METAL PARTS AND
PRODUCTS 8-11
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
I. OVERVIEW OF THE DEVELOPMENT OF MACT STANDARDS
Under Section 112(d) of the Clean Air Act (the Act), the U.S. Environmental Protection
Agency (EPA) is developing national emission standards for hazardous air pollutants (NESHAP) for
the Miscellaneous Metal Parts and Products Surface Coating source category. The EPA is required to
publish final emission standards for the Miscellaneous Metal Parts and Products source category by
November 15, 2000. For this category, national volatile organic compound (VOC) rules or control
techniques guidelines under Section 183(e) are being developed on a similar schedule.
The Act requires that the emission standards for new sources be no less stringent than the
emission control achieved in practice by the best controlled similar source. For existing sources, the
emission control can be less stringent than the emission control for new sources, but it must be no less
stringent than the average emission limitation achieved by the best performing 12 percent of existing
sources (for which the EPA has emissions information). In categories or subcategories with fewer than
30 sources, emission control for existing sources must be no less stringent than the average emission
limitation achieved by the best performing 5 sources. The NESFIAP are commonly known as
maximum achievable control technology (MACT) standards.
The MACT standards development for the Miscellaneous Metal Parts and Products industry
began with a Coating Regulations Workshop for representatives of EPA and interested stakeholders in
April 1997 and continues as a coordinated effort to promote consistency and joint resolution of issues
common across nine coating source categories.1 The first phase was one in which EPA gathered
readily available information about the industry with the help of representatives from the regulated
industry, State and local air pollution agencies, small business assistance providers, and environmental
groups. The goals of the first phase were to either fully or partially:
Understand the coating process;
• Identify typical emission points and the relative emissions from each coating process;
• Identify the range(s) of emission reduction techniques and their effectiveness;
1 The workshop covered eight categories: fabric printing, coating and dyeing; large appliances;
metal can; metal coil; metal furniture; miscellaneous metal parts; plastic parts; and wood building
products. The automobile and light-duty truck project was started subsequently.
8-4
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Preliminary Industry Characterization:
Miscellaneous Metal Parts & Products Surface Coating
September 30,1998
• Make an initial determination on the scope of each category;
Determine the relationships and overlaps of the categories;
• Locate as many facilities as possible, particularly major sources;
• Identify and involve representatives for each industry segment;
Complete informational site visits;
• Identify issues and data needs and develop a plan for addressing them;
Develop questionnaire(s) for additional data gathering; and
• Document results of the first phase of regulatory development for each category.
The industry associations that have been identified as representatives of miscellaneous metal
parts and products surface coaters are listed in Table 1.
TABLE 1. MISCELLANEOUS METAL PARTS AND PRODUCTS
INDUSTRY ASSOCIATIONS
Trade Association
Adhesive and Sealant Council
Aerospace Industries Association
Air-Conditioning and Refrigeration Institute
Air Transport Association
Aluminum Association
Aluminum Kxtniders Council
Aluminum Foil Container Manufacturers Association
American Automobile Manufacturers Association
American Klectroplaters and Surface Finishers Societv
American Foundryrnens Societv
American Gear Manufacturers Association
American Institute for International Steel
American Institute of Steel Construction
American Iron and Steel Institute
American Railwav Car Institute
Association of Container Reconditioners
Association of Home Appliance Manufacturers
Association of International Automobile Manufacturers
Automotive Parts and Accessories Association
Chemical Manufacturers Association
Cookware Manufacturers Association
Copper and Brass Fabricators Council
Active
X
X
X
X
X
X
X
X
X
X
X
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Preliminary Industry Characterization:
Miscellaneous Metal Parts & Products Surface Coating
September 30,1998
Trade Association
Ductile Iron Pipe Research Association
Electronic Industries Association
Equipment Manufacturers Institute
Federation of Societies for Coating Technology
Hearth Products Association
Industrial Heating Equipment Association
International Fabricators and Manufacturers Association
Iron and Steel Society
Metal Building Manufacturers Association
Metal Construction Association
Metal Finishing Association
Metal Finishing Suppliers' Association
Metal Powder Industries Federation
Motor Equipment Manufacturers Association
National Association of Chain Manufacturers
National Association of Manufacturers
National Association of Metal Finishers
National Electrical Manufacturers Association
National Paint and Coatings Association
National Screw Machine Products Association
Powder Coating Institute
Precision Machined Products Association
Precision Metalforming Association
Recreational Vehicle Industry Association
Rubber Manufacturers Association
Society For Protective Coatings
Specialty Steel Industry of North America
Soring Manufacturers Institute
Steel Deck Institute
Steel Founders Society of America
Steel Joist Institute
Steel Manufacturers Association
Steel Plate Fabricators Association
Steel Shipping Container Institute
Steel Structures Painting Council
Steel Tank Institute
Steel Tube Institute
Suppliers of Advance Composite Materials Association
Tube and Pipe Association International
Active
X
X
X
X
X
X
X
X
X
X
X
X
8-6
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
Trade Association
Valve Manufacturers Association
Wire Association International
Active
The States that have participated in the stakeholder process are California, Florida, Illinois,
Wisconsin, Oklahoma, North Carolina, Nebraska, West Virginia, New York, Georgia, Alabama,
Louisiana, Tennessee, Virginia, and Kentucky. The Air Pollution Control District of Jefferson County
(KY) and the Ventura County Air Pollution Control District (CA) have also participated. The U.S.
EPA has been represented by EPA Regions 4, 7, and 9, the EPA Office of Air Quality Planning and
Standards (EPA/OAQPS), and the EPA Office of Research and Development.
The information summarized in this document can be used by States that may have to make
case-by-case MACT determinations under Sections 112(g) or 112(j) of the Act. The initial phase of
the regulatory development focused primarily on characterizing the Miscellaneous Metal Parts and
Products industry and collecting preliminary emission information from facilities applicable to the
category. This document represents the conclusion of that phase of rule development.
This document includes a description of the emission control technologies, identified by EPA,
that are currently used in practice by the industry and that could serve as the basis of MACT. Within
the short time-frame intended for this initial phase, however, only limited data were collected. The
information summarized in this memorandum was collected prior to July 1, 1998. Additional
information will be collected and considered before the Miscellaneous Metal Parts and Products
standards are promulgated.
During the next phase, EPA will continue to build on the knowledge gained to date and
proceed with more focused investigation and data analyses. We will also continue our efforts to
coordinate cross-cutting issues. We will continue to identify technical and policy issues that need to be
addressed in the rule-making and enlist the help of the stakeholders in resolving those issues.
5-7
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
II. SUMMARY OF DATA SOURCES AND NEXT STEPS
Data sources considered in this analysis of the MMPP surface coating source category
included:
• EPA's Source Test Information Retrieval System (STIRS) database (which includes test
reports from facilities nationwide);
• EPA's Toxic Reporting Inventory (TRI) database;
• EPA's Aerometric Information Retrieval System (AIRS), which includes emission inventory
data nationwide;
• Data from individual States which was specifically requested for use in this and the other 10-
year MACT surface coating projects;
• Data provided by facilities at which site visits were conducted (including Title V permit
applications); and
• Input from State and industry stakeholders at Stakeholder meetings and Conference Calls.
EPA also considered coating emission limits included in current regulations for sources similar to
MMPP surface coating. During the course of this effort, the "Regulatory Subgroup", consisting of the
EPA project team and EPA Regional and State/Local Agency representatives, convened to discuss the
process and the potential approaches to identify data gaps.
This document provides summary information, including a summary of existing State and
Federal rules pertaining to this source category, that may be useful in making a 112(g) determination.
Information obtained by the EPA from site visits (aluminum extruders, defense contractors, magnet wire
facilities, large truck manufacturers, railcar manufacturers, curtain wall manufacturers, and NASA) and
information provided by industry associations is included in the Industry Sector Profiles. Future site
visits are planned to facilities that coat automobile parts, recreational vehicles, rubber-to-metal bonded
parts, steel joists, and structural metal parts.
The development of the final MACT standard for MMPP surface coating will require the
gathering of additional information specific to all segments represented within this source category. In
addition to the information gathering techniques outlined above, data has been collected via a Screening
Survey, which was sent to approximately 3,000 facilities in June 1998, and will be collected from a
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
subsequent Detailed Questionnaire, which is planned to be distributed in October 1998. This
information will be used to further characterize and understand the coating operations from the various
industry segments included in this source category. The information will then be used to calculate a
precise MACT floor, and will enable EPA to develop pollution prevention alternatives that are directly
applicable to industries within the MMPP Surface Coating source category.
8-9
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
HI. SOURCE CATEGORY OVERVIEW
Applicability
The MMPP Surface Coating source category encompasses all industries that coat metal parts
and products, but are not subject to other surface coating regulations. The Miscellaneous Metal Parts
and Products source category includes thousands of small, medium, and large size facilities that apply
coatings to a metal substrate to produce a wide range of parts and products generally found under
Standard Industrial Classification (SIC) codes 33 through 39 and others. Coating is defined as a
protective, decorative, or functional film applied as a thin layer to a substrate or surface which cures to
form a continuous solid film. This term applies to paints such as lacquers or enamels, but also is used to
refer to films applied to paper, plastics, or foil. Adhesives and caulks are also being treated as
coatings. In general, this source category is broad and includes all those metal parts and products that
are not covered by another coating source category, including original equipment manufacturers (OEM)
and refurbishment shops. Careful attention has been and will continue to be placed on the potential for
overlaps between this and other source categories including the following:
Aerospace Surface Coating
• Architectural and Industrial Maintenance Coatings (VOC)
Automobile and Light-Duty Truck Surface Coating
• Boat Manufacturing
Iron and Steel Foundry
• Large Appliance Surface Coating
Metal Can Surface Coating
• Metal Coil Surface Coating
Metal Furniture Surface Coating
Paint Stripping
• Plastic Parts and Products Surface Coating
Ship Building and Repair
Other operations associated with surface coating (e.g. cleaning, mixing, surface preparation, storage,
waste handling, etc.) are also being considered for regulation at facilities in the MMPP Surface Coating
source category.
8-10
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
Many of the problems associated with developing regulations for the MMPP Surface Coating
source category have been related to the many possible overlapping categories, and the uncertainty of
defining the universe of MMPP facilities. A condensed list of the SIC codes that are potentially useful
in identifying MMPP facilities for analysis are shown in Table 2. As of January 1, 1997, a new
numerical coding system for classifying industries has been implemented by the U.S. Department of
Commerce. This new system is called the North American Industrial Classification System (NAICS).
The MMPP project team intends to use the NAICS codes as well as SIC codes in identifying potential
facilities within this source category for analysis, although using NAICS/SIC codes alone does not
identify whether individual sources within that industry perform surface coating.
TABLE 2. LIST OF SIC CODES FOR MISCELLANEOUS METAL PARTS AND
PRODUCTS
Major Group 33 - Primary Metal Industries
33 Ix Steel Works, Blast Furnaces, and Rolling and Finishing Mills
332x Iron and Steel Foundries
3 3 5x Rolling, Drawing, and Extruding of Nonferrous Metals
336x Nonferrous Foundries (Castings)
3399 Primary Metal Products, Not Elsewhere Classified
Major Group 34 - Fabricated Metal Products. Except Machinery and Transportation Equipment
3412 Metal Shipping Barrels, Drums, Kegs, and Pails
342x Cutlery, Hand tools, and General Hardware
343x Heating Equipment, Except Electric and Warm Air; and Plumbing Fixtures
344x Fabricated Structural Metal Products
345x Screw Machine Products, and Bolts, Nuts, Screws, Rivets, and Washers
346x Metal Forgings and Stampings
347x Coating, Engraving, and Allied Services, Not Elsewhere Classified
348x Ordnance and Accessories, Except Vehicles and Guided Missiles
349x Miscellaneous Fabricated Metal Products
8-11
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
TABLE 2. LIST OF SIC CODES FOR MISCELLANEOUS METAL PARTS AND
PRODUCTS (CONTINUED)
Major Group 35 - Industrial and Commercial Machinery and Computer Equipment
3 51 x Engines and Turbines
3 52x Farm and Garden Machinery and Equipment
3 5 3 x Construction Machinery and Equipment
3 5 4x Metal working Machinery and Equipment
3 5 5x Special Industry Machinery, Except Metalworking Machinery
3 5 6x General Industrial Machinery and Equipment
3 5 7x Computer and Office Equipment
3 5 8x Refrigeration and Service Industry Machinery
359x Miscellaneous Industrial and Commercial Machinery and Equipment
Major Group 36 - Electronic and Other Electrical Equipment and Components. Except
Computer Equipment
3 61 x Electric Transmission and Distribution Equipment
362x Electrical Industrial Apparatus
3631 Household Cooking Equipment
3634 Electric Housewares and Fans
3635 Household Vacuum Cleaners
3639 Household Appliances, Not Elsewhere Classified
3 64x Electric Lighting and Wiring Equipment
3651 Household Audio and Video Equipment
366x Communications Equipment
367x Electronic Components and Accessories
369x Miscellaneous Electrical Machinery, Equipment, and Supplies
Major Group 37 - Transportation Equipment
3 71 x Motor Vehicles and Motor Vehicle Equipment
3 724 Aircraft Engines and Engine Parts
3728 Aircraft Parts and Auxiliary Equipment, Not Elsewhere Classified
374x Railroad Equipment
375x Motorcycles, Bicycles, and Parts
8-12
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Preliminary Industry Characterization: September 30,1998
Miscellaneous Metal Parts & Products Surface Coating
376x Guided Missiles and Space Vehicles and Parts
379x Miscellaneous Transport Equipment
TABLE 2. LIST OF SIC CODES FOR MISCELLANEOUS METAL PARTS AND
PRODUCTS (CONTINUED)
Major Group 38 - Measuring. Analyzing, and Controlling Instruments: Photographic. Medical
and Optical Goods: Watches and Clocks
(ENTIRE GROUP)
Major Group 39 - Miscellaneous Manufacturing Industries
3911 Jewelry, Precious Metal
3914 Silverware, Plated Ware, and Stainless Steel Ware
3931 Musical Instruments
3944 Games, Toys, and Children's Vehicles, Except Dolls and Bicycles
3949 Sporting and Athletic Goods, Not Elsewhere Classified
396x Costume Jewelry, Costume Novelties, Buttons, and Miscellaneous Notions, Except
Precious Metal
3 99x Miscellaneous Manufacturing Industries
Major Group 97 - National Security and International Affairs
9711 National Security
Another approach that has proven useful in limiting MMPP sources identified by NAICS/SIC
to those involved in surface coating is using the emissions inventory data that is stored in the EPA's
Aerometric Information Retrieval System (AIRS). In that system, Source Classification Codes (SCCs)
specify the type of process that emits pollutants. Figure 1 shows the locations of the facilities that were
identified from AIRS as being MMPP sources.
Emissions/Emission Reduction Techniques
Due to the broad scope of the Miscellaneous Metal Parts and Products category, there are a
variety of products coated and application techniques used by the different industry sectors.
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Emissions from Miscellaneous Metal Parts and Products surface coating facilities typically come from
surface preparation, coating application and flash-off, and curing.
Surface preparation is often performed to clean the substrate and improve adhesion. Types of
chemicals for pretreatment include aqueous caustic solutions, phosphate, chromate rinse, and organic
solvent cleansers. After cleaning, parts are usually dried in an oven prior to coating application steps.
Surface preparation can also involve paint stripping, blasting (with sand, shot, or other blast media), and
other methods to physically alter the surface prior to coating application.
There are several coating application techniques used in the different industry sectors.
Variations in emissions from the application of solvent-based coatings are most commonly attributed to
transfer efficiency, evaporation and flash-off. Possible emission reduction techniques for coating
application include the use of waterborne coatings, high-solids coatings, powder coatings, and add-on
control devices. Many sectors of the category, however, may have performance requirements for their
coatings that would not allow the use of many of these more innovative technologies.
Current Industry Control Status
One of the most critical pieces of information that will be used for the determination of the
MACT floor will be the analysis of the control level used in the top performing 12% of sources within
the source category or within any yet-to-be identified subcategories. However, using the information
that is available through AIRS, a summary of the control techniques used for the SCCs that have been
identified as at least being potentially associated with the MMPP Surface Coating source category was
developed. Information on control techniques will be collected via the Screening and Detailed
Questionnaires and will be used for further analysis of industries within the Miscellaneous Metal Parts
and Products Surface Coating category.
Industry Sector Profiles
The MMPP Surface Coating source category covers a wide variety of industry types; no single
description could cover all of these different industry sectors. The industry sectors that have been
individually studied thus far in the course of this project are listed below, followed by a description of
each.
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• Aerospace Ground Support Equipment
Agricultural and Construction Machinery
• Aluminum Extrusion
• Automobile Parts
Contract Coating Facilities
• Heavy-Duty Trucks and Buses
• Magnet Wire
• Metal Shipping Containers
Pipe and Foundry
• Rail Transportation
Recreational Vehicles
• Rubber-to-Metal Bonded Part Manufacturing
• Structural Steel
This list should not be misconstrued as being all-inclusive, and industries that may be subject to
future regulations being developed for this source category may not be listed here. This document is for
informational purposes only and an omission of an industry from the list does not mean it will not be
regulated within this source category.
Additionally, the discussion of industry segments here should not be misconstrued as being a
default subcategorization scheme. The purpose of identifying industry segments in this document is to
provide some framework for presenting the information collected thus far in the process of regulatory
development and to demonstrate the breadth of the source category. The information provided in this
document will be expanded upon as the project moves forward.
Aerospace Ground Support Equipment Industry
General. More than 12,000 part or equipment types can be considered ground support
equipment (GSE) in the aerospace industry. GSE is classified by the function of the equipment and by
the items the equipment is used to support. GSE is used for auxiliary purposes, testing and checkout,
handling of other equipment and cargo, mechanical site testing, packaging and transport, servicing, and
other miscellaneous purposes.
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Trade Associations. The following trade associations have been identified for this industry
sector:
• Aerospace Industries Association
• Air Transport Association
Process Description. Detailed information is not available at this time.
Coatings. Detailed information is not available at this time.
Emission Control Techniques. Detailed information is not available at this time.
Agricultural and Construction Machinery Industry
General. The Agricultural and Construction Machinery Industry is covered by NAICS code
series 3331 (Agricultural, Construction, and Mining Machinery Manufacturing) and series 33392
(Material Handling Equipment Manufacturing). This industry is also described using the 1987 Standard
Industrial Classification (SIC) code series 352 (Farm and Garden Machinery and Equipment) and 353
(Construction, Mining, and Materials Handling Machinery and Equipment). The Agricultural and
Construction Machinery Industry excludes corrals, stalls, and holding gates which are covered by SIC
code 3523 (Farm Machinery and Equipment). These products are included with NAICS code
332323 (Ornamental and Architectural Metal Work Manufacturing) and are categorized within the
Structural Metal Industry. Railway truck maintenance equipment, which is covered by SIC code 3531
(Construction Machinery and Equipment), is also excluded from this industry. These products are
included with NAICS code 33651 (Railroad Rolling Stock Manufacturing) and are categorized in the
Rail Transportation Industry. Hand-held clippers for shearing or grooming animals, covered by SIC
3523, are also excluded from the Agricultural and Construction Machinery Industry. A list of the
NAICS codes that describe this industry and corresponding SIC codes is provided below [1].
333111 Farm Machinery and Equipment Manufacturing
[includes SIC 3523 (Farm Machinery and Equipment), except corrals, stalls, and
holding gates; farm conveyors and farm elevators, stackers and bale throwers; and
hand hair clippers for animal use.]
333112 Lawn and Garden Tractor and Home Lawn and Garden Equipment Manufacturing
[includes SIC 3524 (Lawn and Garden Tractors and Home Lawn and Garden
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Equipment), except non-powered lawnmowers]
33312 Construction Machinery Manufacturing
[includes SIC 3531 (Construction Machinery and Equipment), except railway truck
maintenance equipment; and winches, aerial work platforms and automotive wrecker
hoists.]
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333131 Mining Machinery and Equipment Manufacturing
[includes SIC 3532 (Mining Machinery and Equipment, Except Oil and Gas Field
Machinery and Equipment)]
333132 Oil and Gas Field Machinery and Equipment Manufacturing
[includes SIC 3533 (Oil and Gas Field Machinery Equipment)]
3 3 3 921 Elevator and Moving Stairway Manufacturing
[includes SIC 3534 (Elevator and Moving Stairways)]
333 922 Conveyor and Conveying Equipment Manufacturing
[includes SIC 3535 (Conveyors and Conveying Equipment); and farm conveyors and
farm elevators, stackers and bale throwers from SIC 3523 (Farm Machinery and
Equipment)]
333923 Overhead Traveling Crane, Hoist, and Monorail System Manufacturing
[includes SIC 3536 (Overhead Traveling Cranes, Hoists, and Monorail Systems); and
winches, aerial work platforms, and automotive wrecker hoists from SIC 3531
(Construction Machinery and Equipment)]
333924 Industrial Truck, Tractor, Trailer, and Stacker Machinery Manufacturing
[includes SIC 3537 (Industrial Trucks, Tractors, Trailers, and Stackers), except metal
pallets, and metal air cargo containers]
Trade Associations. No trade associations have been identified for this industry sector.
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), and in coating application (including
flash-off areas and curing ovens). Detailed information, however, is not available at this time.
Coatings. Detailed information is not available at this time.
Emission Control Techniques. Detailed information is not available at this time.
Aluminum Extrusion Industry
General. The Aluminum Extrusion Industry is covered by the NAICS code 331316
(Aluminum Extruded Product Manufacturing), and by the SIC code 3354 (Aluminum Extruded
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Products). Under SIC 3354, the Aluminum Extrusion Industry is grouped with establishments primarily
engaged in extruding aluminum and aluminum-based alloy basic shapes, such as rod and bar, pipe and
tube, and tube blooms, including establishments producing tube by drawing [2].
The MMPP project team developed a census of aluminum extrusion facilities from the AIRS
database and from information supplied by the Aluminum Extruders Council. A search of the AIRS
database indicated 11 aluminum extrusion facilities with in-house coating capabilities [3]. The AEC's
1997 Buyers Guide gives a complete listing of all AEC members. This list showed 144 aluminum
extrusion facilities nationwide and 43 facilities abroad. Only 50 of the U.S. AEC member facilities
possess in-house coating capabilities [4]. These facilities are located in 25 States, with Ohio having the
largest number of facilities.
One of the key reasons for the continuous growth in popularity of extrusion applications is the
nominal cost of extrusion dies. Complex extruded shapes almost always cost less than they would if
formed, rolled, or machined [5], In addition, aluminum extrusions provide a high strength-to-weight
ratio, close tolerances, ease of joining, good machinability, excellent corrosion resistance, and high
electrical conductivity [6]. Aluminum extrusions also have remarkable thermal properties and are
excellent for use in highly flammable atmospheres or with explosive materials [7]. Extruded aluminum
will not burn, and does not emit any toxic, hazardous fumes when exposed to high temperatures.
Aluminum extrusions have substantial scrap value and can be recycled. Recycling aluminum takes only
five percent as much energy as producing new aluminum [6]. Aluminum extrusions have the capacity to
accommodate a variety of coatings and finishes. Coatings such as powder paint or traditional enamel
paints can be applied with a variety of finishes from rough to mirror smooth.
Aluminum extrusion manufacturers produce a wide array of products for several market
sectors. The major market categories serviced by aluminum extruders and included in the MMPP
source category are building and construction, transportation, and consumer durables. The building and
construction market category consists of doors, windows and shutters, mobile homes, curtain walls,
bridge rails and decks, street and highway construction, architectural shapes, patio and pool enclosures,
light and flag poles, louvers and vents, and conduits. Included in the transportation category are
aircrafts, trailers and semitrailers, passenger cars, trucks and buses, travel trailers, and recreational
vehicles. The consumer durables market covers products such as refrigerators and freezers, major
appliances, furniture, boats, outboard motors, sports and athletic equipment, and toys. Other major
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market categories serviced by the aluminum extrusion industry include electrical goods, machinery and
equipment, distributors and jobbers, and exports. Most aluminum extruders produce products for
multiple market sectors. Thirty-five percent of all extruded aluminum is produced for the building and
construction industry [8].
Trade Associations. The following trade association has been identified for this industry
sector:
• Aluminum Extruders Council
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), in coating application (including flash-
off areas and curing ovens), and in thermal filling of extruded aluminum products.
Pretreatment. The pretreatment of aluminum lays the foundation for the coating and allows the
film to properly adhere to the substrate. Typically, pretreatment is a 5 to 7 stage process of either
immersion or in-line spraying of the substrate with several cleaning solutions. After pretreatment, the
aluminum part is dried in an oven before it is coated [9].
Cladding. To increase the natural corrosion resistance of extruded aluminum, a process known
as cladding is used. In the cladding process, an additional layer of pure aluminum or an appropriate
alloy is applied to the surface of a strong aluminum alloy to increase corrosion resistance [6]. No HAP
or VOC emissions are known to be released from the cladding process.
Thermal Filling. Thermal filling is a common practice for aluminum extruders who manufacture
windows and doors. In this process, the cavity of a window or door is filled with
epoxy and allowed to dry. Then a portion of the metal and epoxy is removed creating a discontinuity of
the surfaces, thereby providing greater insulation potential for the parts [10].
Coating Application Aluminum extrusions are coated on two types of lines: vertical and
horizontal. Both processes offer quality coated products and can handle a variety of shapes and sizes
[9]. The vertical coating line can accommodate extruded profiles of more than 30 feet in length.
Vertical coating processes can be customized based on the shape and length of a part. It is used for
longer shapes such as pool edges. It produces less waste than the horizontal process. The horizontal
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coating line offers a higher efficiency than the vertical process, however, it coats extrusions up to four
times slower than the vertical line. Both horizontal and vertical systems share the same basic stages for
coating application: pretreatment, dry, coating application, curing, and unloading.
Electrostatic spray application is the most popular way to coat aluminum extrusions and is used
for virtually all aluminum extrusion coating processes. Rotary atomization is a variation of the
electrostatic coating method which is used to apply liquid enamels.
Coatings. Both organic solvent-borne liquid enamels and low-VOC powder coatings are used
to paint aluminum extrusions. Typical resins found in liquid and powder aluminum extrusion coatings
are polyester, acrylic, siliconized polyester, and fluoropolymer. Aluminum extrusion coatings must be
resistant to stresses caused by UV radiation, moisture, high temperatures and temperature fluctuations,
aggressive environments, and physical damage [9].
Specifications for aluminum extrusion coatings have been developed by the American
Architectural Manufacturers Association (AAMA) and the Architectural Spray Coaters Association
(ASCA). Coatings covered by these specifications are rated on their performance in the following
areas: ease of application, solvent resistance, chemical resistance, corrosion resistance, exterior
durability, hardness, adhesion, flexibility, mar resistance, and color/gloss retention.
Emission Control Techniques. Powder coatings and oxidizers are the primary means of
VOC/HAP emissions control in the aluminum extrusion industry. Powder coatings contain from 0 to 10
percent entrapped volatiles [11]. Oxidation, or incineration, is the most common method of controlling
VOC/HAP emissions produced during the aluminum extrusion manufacturing process and are present
in many areas associated with the coating process including pretreatment stations, coating booths,
curing ovens, and flash-off areas.
Automobile Parts Industry
General. The Automobile Parts Industry is covered by the NAICS codes 336211 (Motor
Vehicle Body Manufacturing) and the NAICS code series 3363 (Motor Vehicle Parts Manufacturing).
This industry is also described by SIC code 3714 (Motor Vehicle Parts and Accessories). Under SIC
code 3714, the Automobile Parts Industry includes establishments primarily engaged in manufacturing
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motor vehicle parts and accessories, but not engaged in manufacturing complete motor vehicles or
passenger car bodies [2]. NAICS code 336211 includes dump truck lifting mechanisms and fifth
wheels which are also covered by SIC code 3714. In accordance with NAICS code series 3363, this
industry sector includes automobile
parts that are covered by various SIC codes including 3714. A list of the NAICS codes in series 3363
and corresponding SIC codes (except SIC 3714) that are relevant to the miscellaneous metal parts and
products source category is provided below [1].
336311 Carburetor, Piston, Piston Rings, and Valve Manufacturing
[includes SIC 3592 (Carburetor, Pistons, Piston Rings, and Valve Manufacturing)]
336312 Gasoline Engine and Engine Parts Manufacturing
336321 Vehicular Lighting Equipment
[includes SIC 3647 (Vehicular Lighting Equipment)
3 3 63 22 Other Motor Vehicle Electrical and Electronic Equipment Manufacturing
[includes SIC 3694 (Electrical Equipment for Internal Combustion Engines)]
33633 Motor Vehicle Steering and Suspension Components (except Spring) Manufacturing
33634 Motor Vehicle Brake System Manufacturing
33635 Motor Vehicle Transmission and Power Train Parts Manufacturing
33636 Motor Vehicle Seating and Interior Trim Manufacturing
[includes metal motor vehicle seat frames SIC 3499 (Fabricated Metal Products, Not
Elsewhere Classified)]
33637 Motor Vehicle Stamping, Metal
[includes SIC 3465 (Automotive Stampings)]
336391 Motor Vehicle Air-Conditioning Manufacturing
[includes motor vehicle air-conditioning from SIC 3585 (Air-Conditioning and Warm
Air Heating Equipment and Commercial and Industrial Refrigeration Equipment)]
336399 All Other Motor Vehicle Parts Manufacturing
[includes luggage and utility racks from SIC 3429 (Hardware, Not Elsewhere
Classified); stationary engine radiators from SIC 3519 (Internal Combustion Engines,
Not Elsewhere Classified); gasoline, oil, and intake filters for internal combustion
engines from SIC 3599 (Industrial and Commercial Machinery and Equipment, Not
Elsewhere Classified); and trailer hitches from SIC 3799 (Transportation Equipment,
Not Elsewhere Classified)]
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The AIRS database indicates that there are approximately 263 facilities nationwide located in 23 States
that manufacture automobile parts [3].
Trade Associations. The following trade associations have been identified for this industry
sector:
• American Automobile Manufacturers Association
Association of International Automobile Manufacturers
• Automotive Parts and Accessories Association
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), and in coating application (including
flash-off areas and curing ovens). Detailed information on these processes, however, is not available at
this time.
Coatings. Detailed information is not available at this time.
Emission Control Techniques. Detailed information is not available at this time.
Contract Coating Facilities
General. Contract coating facilities, or "job shops", may be described as facilities that perform
surface coating operations for a variety of industries on a contract basis. These facilities may specialize
in coating products for one specific industry; or may coat several products for several different
industries. Job shops may be covered by several SIC codes and NAICS codes including SIC code
3479 (Coating, Engraving, and Allied Services) and NAICS code 332812 (Metal Coating, Engraving
(except Jewelry and Silverware) and Allied Services to Manufacturers). SIC code 3479 includes
establishments primarily engaged in performing enameling, lacquering, and varnishing services of metal
products for the trade. Also included in this industry are establishments which perform these types of
activities on their own account on purchased metals or formed products [2].
Job shops showed dramatic increases in numbers of facilities and in sales between 1996 and
1998 [12]. Job shops utilize a variety of coating techniques to apply coatings to virtually all types of
products and substrates.
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Preliminary Industry Characterization: September 30,1998
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Trade Associations. No trade associations have been identified for this industry sector.
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), and in coating application (including
flash-off areas and curing ovens). Detailed information, however, is not available at this time.
Coatings. Detailed information is not available at this time.
Emission Control Techniques. Detailed information is not available at this time.
Heavy-Duty Trucks and Buses Industry
General. The Heavy-Duty Trucks and Buses Industry is covered by the NAICS code
331316 (Motor Vehicle Body Manufacturing) and the SIC code 3713 (Truck and Bus Bodies).
Under SIC code 3713, the Heavy-Duty Truck and Buses Industry is grouped with establishments
primarily engaged in manufacturing large truck and bus bodies and cabs for sale separately or for
assembly on purchased chassis, or in assembling large truck and bus bodies on purchased chassis.
Also included in this industry sector are truck trailers which are covered by the NAICS code 336212
(Truck Trailer Manufacturing), and the SIC code 3715 (Truck Trailers). Under SIC code 3715, the
truck trailer industry is grouped with establishments primarily engaged in manufacturing truck trailers,
truck trailer chassis for sale separately, detachable trailer bodies (cargo containers) for sale separately,
and detachable trailer (cargo container) chassis, for sale separately.
The AIRS database indicates that there are approximately 81 heavy-duty truck, trailer, and bus
manufacturing facilities nationwide located in 18 States [3]. AAMA (American Automobile
Manufacturers Association) reports that 346,000 large trucks (14,000+ Ibs.) were sold in the United
States in 1996.
Trade Associations. The following trade associations have been identified for this industry
sector:
• Truck Manufacturers Association
American Automobile Manufacturers Association
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Process Description. Heavy-duty trucks consists of three major parts: chassis, cab, and
trailer. Most parts are coated separately and prior to assembly. The basic chassis is formed using
metal rails, axles, and cross beams. The chassis structure is completed by adding metallic brake lines,
plastic wiring harnesses, and other metal and plastic parts. Chassis components are usually primed
individually prior to assembly at the heavy-duty truck manufacturing facility. In some cases, chassis
components are primed off-site by the parts manufacturers before being shipped to truck manufacturing
facilities. Individual parts may be sanded and touched up, if necessary, before chassis assembly using a
solvent-borne or waterborne paint. HAP and VOC emissions are expected from pretreatment
processes (when organic solvents are involved in the pretreatment process), and in coating application
(including flash-off areas and curing ovens) [13,14,15].
The assembled chassis enters a paint booth where a top coat is applied. Heavy-duty truck
manufacturers use conventional, electrostatic, and HVLP spray guns for this coating application. Black
is the primary color used for chassis coating, however, some facilities use several other colors in
addition to black. Greater than eighty percent of all heavy-duty truck chassis are black. Both solvent-
borne and waterborne paints are used for chassis top coats. Solvent-borne top coats are likely to be
high-solids acrylic or polyurethane coatings.
Cabs and cab components are primed prior to cab assembly; this is done for both metal and
plastic parts. Following assembly, metal and plastic cab components are coated together. Cab
assemblies are pretreated to prevent corrosion and promote coating adhesion. After pretreatment, cab
seams are sealed with an emulsion caulk which may be water-based. Cabs are primed in a spray
booth, using either conventional, HVLP, or electrostatic spray application methods. Cabs are then sent
to a flash-off area, followed by a curing oven where they are dried under either "hi-bake" (3 SOT or
higher) or "lo-bake" (approximately 180°F) conditions, depending on whether plastic parts have been
assembled to the cab. Once dry, some manufacturers apply a low-VOC asphalt undercoat spray as a
rust preventative measure. Cab surfaces are then sanded in preparation for the base coat. The base
coat is applied in a spray booth, typically using HVLP application, followed by a flash-off area or lo-
bake convection oven. Some cabs require multiple base coats. Typically, only one base coat is
applied per day, with 24 hours allowed for the coating to cure. The final layer is a clear top coat which
is often applied using conventional, HVLP, or electrostatic spray guns. Finally, the hood of the cab is
removed and the interior parts (i.e. seats, dash) are inserted.
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Coatings. Both waterborne and solvent-borne coatings are used for a variety of applications
throughout the heavy-duty trucks and buses industry sector. Chassis are primed and coated with both
solvent-borne and waterborne coatings. Solvent-borne paints used for chassis coating may be high-
solids acrylics, polyurethanes, or other low-VOC coatings. Heavy-duty truck manufacturers use
several hundred colors for cab coating applications. The use of solvent-borne coatings may be
necessary for color matching, durability, and other coating requirements in this industry. However,
heavy-duty truck manufacturers work closely with coating suppliers to find low solvent and low-HAP
coating solutions, where feasible [13,14,15].
Emission Control Techniques. Add-on control devices were not observed in site visits to
three heavy-duty truck facilities. Reviews of Title V permit applications, likewise, indicated that no
add-on control devices are used in typical heavy-duty truck facilities.
Magnet Wire Industry
General. The Magnet Wire Industry is covered by the NAICS codes 331319 (Other
Aluminum Rolling and Drawing), 331421 (Copper Rolling, Drawing, and Extruding); 331422 (Copper
Wire [except mechanical] Drawing), 33149 (Nonferrous Metals [except copper and aluminum] Rolling,
Drawing, and Extruding), and 335929 (Other Communication and Energy Wire Manufacturing). This
industry is also described using the SIC code 3357 (Drawing and Insulating of Nonferrous Wire).
Under SIC code 3357, the Magnet Wire Industry is grouped with establishments primarily engaged in
drawing, drawing and insulating, and insulating wire and cable of nonferrous metals from purchased
wire bars, rods, or wire and includes establishments primarily engaged in manufacturing insulated fiber
optic cable [2]. SCCs identify facilities involved in the coating of magnet wire with the six-digit SCC 4-
02-015 covering the industrial processes associated with the surface coating of magnet wire.
Magnet wire is produced predominantly in large facilities which both draw and insulate the wire
and sell it for use in electrical and electronic products. The AIRS database indicates that there are
approximately 30 magnet wire manufacturing facilities in the US [3]. These facilities are located in
Arkansas, California, Connecticut, Georgia, Illinois, Indiana, Kentucky, Maryland, Massachusetts,
Missouri, New Hampshire, New York, North Carolina, Pennsylvania, Tennessee, Texas, Vermont,
and West Virginia. Fort Wayne, Indiana is home to the largest concentration of magnet wire
manufacturers.
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In magnet wire fabrication, a coating of electrically insulating enamel or varnish is applied to
bare wire, usually made of copper or aluminum. The term "magnet" is used to describe this wire
because it is usually formed into coils for the purpose of creating an electromagnetic field when an
electrical current is applied. Magnet wire is used in electrical equipment such as clocks, telephones,
electric motors, generators, and transformers [16]. It is usually classified by gauge which indicates the
thickness/diameter of the wire, with greater gauge numbers indicative of increasingly finer wire. Wire of
20 gauge or less is called heavy wire; medium wire ranges from 21 to 32 gauge; fine wire ranges from
33 to 39 gauge; and extra fine wire is greater than 40 gauge.
Trade Associations. The following trade association has been identified for this industry
sector:
• National Electrical Manufacturers Association (NEMA)
Process Description. Most magnet wire manufacturing facilities draw wire from bare metal
rod in addition to insulating the wire with coating. The drawing of wire from bare rod is a process of
elongating the rod and decreasing its diameter, using a series of dies, until wire of a desired thickness or
gauge is achieved. Many processes require wire to incur several drawings before it reaches the
specified gauge.
Once wire has been drawn to the desired gauge, it is passed several times through an annealing
oven. This process softens the wire, making it more pliable, and cleans the wire of oil and dirt [16].
The wire is then ready for coating application. Two methods are used in the magnet wire coating
application process dependent upon the gauge of the wire. Typically, wire coating is applied using a die
applicator for lower gauge (thicker) wire. In this process, wire passes through a bath where it picks up
a thick layer of coating. The wire is then drawn through a coating die which removes excess coating
and leaves a thin film of desired thickness. Die applicators typically coat wire of 30 gauge or lower
(larger diameter wire). For fine wire of 30 gauge or more, a felt applicator may be used. In the felt
application process, felt swabs, saturated with enamel, are used to transfer coating to the wire [17].
After the wire is coated, it is routed through a two-zone recirculating oven where the coating is dried
and cured. The size of the oven is generally larger for lower gauge wire. Wire may be subjected to as
many as 20 passes through the coating, baking, and curing processes before it is sufficiently coated.
Finally, the insulated wire is passed through a cooling zone and is wound onto a spool where it awaits
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packaging. In many facilities, magnet wire is coated with a lubricant just after it is cooled and before it
is wound onto a spool. This lubricant coatings helps to keep the wire in place as it is wound onto the
spool. It is also used to lubricate wire as it is removed from the spool at the same or another
manufacturing facility for use in high speed coil winding. HAP and VOC emissions are expected from
the coating application (including the curing ovens).
Coatings. The materials used to coat magnet wire must meet rigid electrical insulating, thermal
and abrasion specifications. Nyleze is a common insulator made from nylon and polyester. Other
coatings include armored poly amide, polyester with a nylon overcoat, and solderable polyester. A
bondable material may also be used to coat 40 to 46 gauge wire [17].
Insulation for magnet wire must be tough and flexible. The coating must be capable of
elongating from 15 to 40 percent. The coating must stretch at the same rate as the wire which it coats
to ensure its insulating properties when the wire is wound to its final form (e.g., in electrical motors). It
must also be resistant to high temperatures and have a high thermal conductivity. The base coat, which
is typically 6 to 9 layers, provides most of the electrical insulating properties of the wire. The top coat,
which may have as few as 1 to 3 layers, provides durability for winding, toughness, and chemical and/or
heat resistance. In some specialized applications, a single-layered bond coat may be used as a final
coat. This heat-activated coat is frequently used in the automotive industry and serves to bond each
winding of the coated wire in a coil to other windings, forming a bonded coil [17].
Organic solvent-borne enamels are the principal coatings used in the magnet wire industry. The
solvents in these enamels must not poison the catalyst used in oven operations, and must be compatible
with the application method. Different coating formulations are used for felt and die applications. Low-
solvent coatings have not yet been developed with properties that meet all wire coating requirements.
The organic solvent content of wire coatings typically range from 67 to 85 percent by weight. Solvents
used in enamels are selected because they are compatible with the polymer used to insulate the wire
and with the oven catalyst. Phenol, cresol, xylene, and cumene are common solvents used in magnet
wire coatings. Fine wire coatings have a higher solvent content than medium or heavy wire. Other
solvents that may be used to thin magnet wire coatings are cresylic acid, diacetone alcohol, toluene,
hiflash naptha, methyl ethyl ketone, n-methyl pyrrolidine, and ortho cresol [16,17].
The solids content of a coating is a function of the type of enamel needed for insulation and the
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capabilities of the oven used for baking and curing. Base coats tend to have higher solids contents than
top coats. Newer ovens are likely to process higher solids more efficiently than
older models. Common resins used in magnet wire coatings are polyester amine imide, polyester,
polyurethane, epoxy, polyvinyl formal, and polyimide [16].
In the magnet wire coating process, separate ovens are used for annealing, and for baking and
curing the coated product. Most drying ovens consist of two zones. The drying zone is held at about
200°C and the curing zone at about 430°C. Many ovens are equipped with an in-line system that
draws wire just before it is annealed. The number and type of ovens selected for a facility depends on
the production needs of that facility. Over 140 coated wires can be processed in a single oven.
Production in an oven may be limited to a specified range of wire gauges.
An oven's line speed capability may be expressed as a product of the diameter of the wire and
its velocity through the oven (DV). The capacity of an oven is often characterized by its DV number.
The DV range of an oven tends to decrease as the size of the wire increases. Heavy wire must move
through an oven at a slower speed than fine wire because as wire travels through the oven, it must
maintain a temperature that will insure a consistent cure of the enamel. Heavier wire takes longer to
reach the set temperature throughout the wire [17].
The magnitude of emissions from wire coating operations depends on composition of the
coating, thickness of the coat, and efficiency of the application [18]. The exhaust from the oven is the
most important source of solvent emissions in the wire coating plant. Organic solvent emissions vary
from line to line, by size and speed of wire, by number of wires per oven, and by number of passes
through the oven. The exhaust from typical ovens range from 11 dry standard cubic meters (dscm) per
minute to 42 dscm per minute, with the average being around 28 dscm per minute. The solvent
concentration in exhaust normally ranges from 10 to 25 percent of the lower explosive limit (LEL) for
that solvent. This is equivalent to about 12 kg of solvent per hour in a typical process. In addition to
solvent, 10 to 25 percent of the coating resins may be volatilized in the drying oven, and emitted with
oven exhaust. Most of the volatilized resin condenses in the atmosphere to form particles but some
breaks down to form VOC [16].
One of three different types of solvent-based, VOC-containing coatings may be used to
lubricate magnet wire. A waxy material is commonly used for this application. The lubricated magnet
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wire does not pass through the catalytic or thermal incineration systems used to control VOC emissions
in magnet wire processing. Emissions from this coating process are limited by restricting the VOC
content of the lubricant material [19].
Emission Control Techniques. Incineration is the most common add-on control technique
used to control emissions from wire coating ovens. The high temperatures at which magnet wire
coating ovens operate and the moderate to high solvent loads of these ovens create a suitable
environment for incineration. During thermal incineration, solvent-laden gas is passed through an
oxidizer where the solvent is combusted. Heated exhaust from the thermal incinerator is then
recirculated to the drying oven. This process typically yields a ninety-eight percent solvent destruction
efficiency [16].
Magnet wire manufacturers often include catalytic incineration as an integral part of their baking
ovens to minimize the cost of oven operation, with the added benefit of reducing the emissions of VOCs
and HAPs in the solvent prior to any add-on controls. The heat generated by the catalyst is
recirculated to the oven reducing or eliminating the need for fuel after reaching operational
temperatures. During internal catalytic combustion, hot solvent-laden air from the oven circulates past a
catalyst causing combustion of the solvent to take place. If air exits the drying oven at 260 to 320°C,
the oven may be self sustaining. However, a supplementary burner may be used to heat the solvent-
laden gases if they do not reach these temperatures. Exhaust gases leave the catalyst at about 450°C
and are recirculated to the curing zone. Energy is conserved because less low-temperature makeup air
is required due to recirculation, and less fuel is needed to heat the oven or to reach the solvent
combustion temperature in the catalyst. Also, internal catalysts yield a 75 to 90 percent solvent
destruction efficiency. Air that is not recirculated to the baking oven passes through a control device (if
present) for additional solvent reduction.
Metal Shipping Containers Industry
General. Metal shipping containers are classified by the NAICS code 332439 (Other Metal
Container Manufacturing) and the SIC code 3412 (Metal Shipping Barrels, Drums, Kegs, and Pails).
Under SIC 3412, the Metal Shipping Containers Industry consists of establishments primarily engaged
in manufacturing metal shipping barrels, drums, kegs, and pails, and includes the following products [2]:
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• Containers, shipping: barrels, kegs, drums, packages - liquid tight (metal)
Drums, shipping: metal
• Milk (fluid) shipping containers, metal
• Pails, shipping: metal - except tinned
This industry also includes the reconditioning of shipping containers which is classified by the NAICS
code 81131 (Commercial and Industry Machinery and Equipment (except Automotive and Electronic}
Repair and Maintenance) and the SIC code 7699 (Repair Shops and Related Services, Not Elsewhere
Classified). The six-digit SCC 4-02-026 identifies the surface coating of steel drums. This grouping
has the potential to overlap with the Metal Can and Metal Coil surface coating categories.
AIRS data indicates that there are approximately 71 metal shipping container manufacturing
facilities nationwide. Of those, only 29 facilities are equipped with the capability to coat both the
interior and exterior of products [3].
Metal shipping containers can be grouped according to size into two major categories: drums,
which include barrels and kegs and are 13 to 110 gallons (49 - 416 L); and pails, which are 1 to 12
gallons (4 - 45 L) [20]. They consist of a cylindrical body with a welded side seam and top and
bottom heads. The thickness of pails and small drums usually range from 0.0115 in (0.3 mm) to
0.0269 in (0.7 mm). Larger drums are usually 0.030 in (0.8 mm) to 0.0533 in (1.4 mm) in thickness.
Drums and pails are generally fabricated from commercial grade cold-rolled sheet steel; however,
stainless steel, nickel, and other alloys are used for special applications.
Drums are used to transport and store liquids, viscous materials, and dry products. About
seventy-five percent of all new drums are used for liquids. Pails are used to transport and store liquids,
viscous products, powders, and solids. Currently, about 73 million new steel pails are produced in the
United States each year. Almost eighty percent of all pails manufactured annually are the popular 5-
gallon pail.
All steel pails and drums used in the United States for the transport of hazardous materials must
comply with the Department of Transportation's (DOT) Hazardous Materials Regulations. For non-
hazardous products, these containers usually comply with the minimum requirements of the
specifications set forth by the railroads Uniform Classification Committee and the highway carriers
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National Classification Committee. Packagers must now provide their drum and pail suppliers with the
following information: Packing Group, product vapor pressure (if liquid), net mass (if solid), and
specific gravity (if liquid). The steel drum and pail manufacturer marks the container, after having
performed the following tests: drop, leakproofness, stacking, and hydrostatic pressure (if liquid). Steel
drums to be reconditioned and reused to transport hazardous materials must meet DOT specifications
for minimum and nominal thickness. Each year over 40 million drums are reconditioned [20].
Trade Associations. The following trade associations have been identified for this industry
sector:
• Association of Container Reconditioners
Steel Shipping Container Institute
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), and in coating application (including
flash-off areas and curing ovens).
Surface Preparation. During new metal shipping container fabrication, parts are pretreated to
protect against flash rust and to remove oil and dirt from the surfaces prior to surface coating. This is
generally achieved using a spray washer and zinc or iron phosphate solution. A pretreatment system
may have as many as six or seven stages. The following is an example of a typical pretreatment
process for new metal shipping containers:
1. Hot water or detergent, oil skimming
2. Rinse
3. Cleaner or phosphate
4. Rinse
5. Final rinse sealer (optional)
In some facilities, dry steel is used to manufacture new shipping containers. Dry steel is steel received
from the mill with no rust inhibiting oil on the surface. In cases where dry steel is used, the surface
preparation process may be eliminated [21].
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Spray washing is also the initial step in preparation of the reconditioning process. Alkaline-
sodium hydroxide solutions are generally used to remove residue of prior container contents. Shot
blasting is also used during reconditioning operations to clean the exterior of tight head drums and the
interior and exterior of open head drums. Other operations performed before surface coating may
include acid washing, chaining, dedenting, leak testing, and corrosion inhibiting [22].
Coating Application Metal shipping containers are coated using either roll coating or spray
application methods. Roll coating is used mostly for the coating of coil. Spray coating is performed
after metal has been formed into shells or parts. Shells and parts are coated in spray booths using
HVLP, airless, or conventional coating apparatus. Drum and pail parts usually receive one or two
coats and may be coated on both inside and outside surfaces. After coating, parts are given a brief
flash-off period to allow separation of solvents in the coating. Parts are typically cured in natural-gas
fired ovens. This curing takes place for 5 to 15 minutes at 300 to 500* F [21].
Coatings. Waterbased, high-solids, polyesters, alkyds, epoxy phenolics and phenolics are
typically used to coat metal shipping containers. The selection of interior coatings is based on several
factors. The most important considerations are the compatibility of a coating with the products to be
shipped or stored within the container and the performance of a coating under various tests (i.e.,
reverse impact and rubbing). Though solvent-borne paints are still used for exterior coating, there is a
trend in the industry toward low-VOC exterior coatings. The types of pigments used in exterior
coatings affect the color consistency, application thickness, and surface adhesion of that coating. Thus,
some colors may be more compatible with low-VOC coatings than others [21].
Emission Control Techniques. Low-VOC coatings, such as high-solids and waterborne
coatings, are commonly used to minimize emissions from surface coating operations [21].
Pipe and Foundry Industry
General. The Pipe and Foundry Industry is covered by the NAICS code 33121 (Iron and
Steel Pipe and Tube Manufacturing from Purchased Steel), and the NAICS code series 3315
(Foundries). This industry is also described using the SIC code 3317 (Steel Pipe and Tubes), and the
SIC code series 332 (Iron and Steel Foundries) and 336 (Nonferrous Foundries {Castings}). SIC
code 3317 covers establishments primarily engaged in the production of welded or seamless steel pipe
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and tubes and heavy riveted steel pipe from purchased materials. SIC code series 332 consists of
establishments primarily engaged in manufacturing iron and steel castings. SIC code series 336 includes
establishments primarily engaged in manufacturing castings and die-castings of aluminum, brass, bronze,
and other nonferrous metals and alloys [2]. A list of the NAICS codes used to describe this industry
and corresponding SIC codes is provided below [1].
33121 Iron and Steel Pipe and Tube Manufacturing from Purchased Steel
[includes SIC 3317 (Steel Pipe and Tubes)]
331511 Iron Foundries
[includes SIC 3321 (Gray and Ductile Iron Foundries) and 3322 (Malleable Iron
Foundries)]
331512 Steel Investment Foundries
[includes SIC 3324 (Steel Investment Foundries)]
331513 Steel Foundries (except Investment)
[includes SIC 3325 (Steel Foundries, Not Elsewhere Classified)]
331521 Aluminum Die-Casting Foundries
[includes SIC 3363 (Aluminum Die-Castings)]
331522 Nonferrous (except Aluminum) Die-Casting Foundries
[includes SIC 3364 (Nonferrous Dies-Castings, except Aluminum)]
331524 Aluminum Foundries (except Die-Casting)
[includes SIC 3365 (Aluminum Foundries)]
331525 Copper Foundries (except Die-Casting)
[includes SIC 3366 (Copper Foundries)]
331528 Other Nonferrous Foundries (except Die-Casting)
[includes SIC 3369 (Nonferrous Foundries, Except Aluminum and Copper)]
The AIRS database indicates that there are approximately 146 metal pipe and foundry facilities
nationwide [3], The largest concentration of these facilities is in the State of California.
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Trade Associations. The following trade associations have been identified for this industry
sector:
• American Foundrymens Society
• American Institute for International Steel
American Iron and Steel Institute
• Iron and Steel Society
Specialty Steel Industry of North America
• Steel Founders Society of America
Steel Manufacturers Association
• Steel Tube Institute
Tube and Pipe Association International
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), and in coating application (including
flash-off areas and curing ovens). Detailed information, however, is not available at this time.
Coatings. Detailed information is not available at this time.
Emission Control Techniques. Detailed information is not available at this time.
Rail Transportation Industry
General. The Rail Transportation Industry is covered by the NAICS code 33651 (Railroad
Rolling Stock Manufacturing). This industry is also described using the SIC code 3743 (Railroad
Equipment). Under SIC code 3743, the Rail Transportation Industry includes establishments primarily
engaged in building and rebuilding locomotives (including frames and parts, not elsewhere classified) of
any type or gauge; and railroad, street, and rapid transit cars and car equipment for operation on rails
for freight and passenger service [2]. Locomotive fuel lubricating pumps and cooling medium pumps,
also included in SIC code 3743, are covered by NAICS code 333911 (Pump and Pumping Equipment
Manufacturing). In accordance with NAICS code 33651, this industry sector also includes railway
truck maintenance equipment which is also covered by SIC code 3531 (Construction Machinery and
Equipment). Approximately 38 rail transportation manufacturing facilities nationwide located in 18
States have been identified from queries of the AIRS database [3].
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Trade Associations. The following trade association has been identified for this industry
sector:
• American Railway Car Institute
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), and in coating application (including
flash-off areas and curing ovens).
Surface Preparation. Surface preparation for railcars and most railway equipment typically
includes blasting of the surface using a non-metallic blast media, and/or grit [23]. This method may be
used to prep the interior and exterior surfaces of railcars and other equipment. Surface preparation for
locomotives may include blasting with glass and plastic bead media. Blast facilities usually contain
filtering systems to capture waste [19]. Dust collectors may be used to control dust emissions and to
recapture blast media. Felt floor coverings may also be used to recover paint and waste materials.
Blast material may be recycled for future uses.
Coating Application Railway transportation manufacturing facilities typically use airless spray
apparatus for application of interior and exterior coatings. In some cases, surface coating is performed
using HVLP spray systems [23]. Railcars and locomotives are painted in large enclosed paint booths.
Coatings may be cured in thermal reacting drying ovens. In some facilities, coatings are allowed to dry
in the paint booth at ambient temperature conditions, with the ventilation system in operation. Paint
shops usually contain exhaust stacks with filtering systems to control paniculate emissions. Stencils or
decals are applied to railcars and locomotives using brush or roller apparatus. Facilities may also have
smaller paint booths for coating of railcar and locomotive accessories and other rail transportation
associated equipment such as sideframes and bolsters, sheet and aluminum blue flags, wood projects,
steel lockers, racks, tables, logo panels, hopper outlets, air jacks, and for other miscellaneous coating
projects. Some facilities coat motor coils with varnish on-site using a vacuum pressure impregnation
process.
Coatings. The Rail Transportation Industry typically uses dual-component, waterborne paints
for surface coating of railcars and equipment [23]. The dual component paint is usually mixed on-site,
inside the paint booth. Once the paint is mixed the shelf life is very short. Locomotives are often
coated with dual-component, solvent-based surface coatings [19].
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Emission Control Techniques. No add-on control devices were observed in site visits or
reviews of the Title V Permit application for the Union Pacific Railroad's DeSoto Car Shop in DeSoto,
MO. In conversations with representatives of the American Railway Car Institute, it was also indicated
that add-on controls are not common in rail car facilities.
Recreational Vehicle Industry
General. The Recreational Vehicle Industry is covered by the NAICS codes 336213 (Motor
Home Manufacturing) and 336214 (Travel Trailer and Camper Manufacturing). This industry is also
described using the SIC codes 3716 (Motor Homes) and 3792 (Travel Trailers and Campers). Under
SIC code 3716, the industry includes establishments primarily engaged in manufacturing self-contained
motor homes on purchased chassis. SIC code 3792 contains establishments primarily engaged in
manufacturing travel trailers and campers for attachment to passenger cars or other vehicles, pickup
coaches (campers) and caps (covers) for mounting on pickup trucks [2]. NAICS code 336214 also
includes automobile, boat, utility, and light truck trailers, which are also covered by SIC code 3799
(Transportation Equipment, Not Elsewhere Classified). Approximately 37 recreational vehicle
manufacturing facilities were located in 10 States from a query of the AIRS database.
Trade Associations. The following trade association has been identified for this industry
sector:
Recreational Vehicle Industry Association
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), and in coating application (including
flash-off areas and curing ovens). Detailed information, however, is not available at this time.
Coatings. Detailed information is not available at this time.
Emission Control Techniques. Detailed information is not available at this time.
Rubber-to-Metal Bonded Part Manufacturing Industry
General. The Rubber-to-Metal Bonded Parts Manufacturing Industry is covered by the
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NAICS codes 326291 (Rubber Product Manufacturing for Mechanical Use) and 326299 (All Other
Rubber Products Manufacturing). This industry is also described using the SIC codes 3061 (Molded,
Extruded, and Lathe-Cut Mechanical Rubber Goods) and 3069 (Fabricated Rubber Products, Not
Elsewhere Classified). SIC code 3061 includes establishments primarily engaged in manufacturing
molded, extruded, and lathe-cut mechanical rubber goods, generally for machinery and equipment.
SIC code 3069 consists of establishments primarily engaged in manufacturing industrial rubber goods,
rubberized fabrics, and vulcanized rubber clothing, and miscellaneous rubber specialties and sundries,
not elsewhere classified [2]. Many of the products manufactured in this industry are fabricated for use
in the automotive industry. This grouping has the potential to overlap with the Automobile and Light-
Duty Truck Surface Coating source category.
Trade Associations. The following trade association has been identified for this industry
sector:
Rubber Manufacturers Association
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), and in coating application (including
flash-off areas and curing ovens). Detailed information, however, is not available at this time.
Coatings. The main coatings associated with this industry are adhesives used to bond rubber
to metal parts. More detailed information is not available at this time.
Emission Control Techniques. Detailed information is not available at this time.
Structural Metal Industry
General. The Structural Metal Industry is covered by the NAICS codes 332114 (Custom
Roll Forming), 332311 (Prefabricated Metal Building and Component Manufacturing), 332312
(Fabricated Structural Metal Manufacturing), 332321 (Metal Window and Door Manufacturing), and
332323 (Ornamental and Architectural Metal Work Manufacturing). This industry is also described
using the SIC codes 3441 (Fabricated Structural Metal), 3442 (Metal Doors, Sash, Frames, Molding,
and Trim), 3446 (Architectural and Ornamental Metal Work), 3448 (Prefabricated Metal Building and
Components), and 3449 (Miscellaneous Structural Metal Work). SIC code 3441 covers
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establishments primarily engaged in fabricating iron and steel or other metal for structural purposes,
such as bridges, buildings, and sections for ships, boats, and barges [2]. SIC code 3442 includes
establishments primarily engaged in manufacturing ferrous and nonferrous metal doors, sash, window
and door frames and screens, molding, and trim. SIC code 3446 contains establishments primarily
engaged in manufacturing architectural and ornamental metal work, such as stairs and staircases, open
steel flooring (grating), fire escapes, grilles, railings, and fences and gates, except those made from wire.
SIC code 3448 consists of establishments primarily engaged in manufacturing portable and other
prefabricated metal buildings and parts and prefabricated exterior metal panels. SIC code 3449 is
comprised of establishments primarily engaged in manufacturing miscellaneous structural metal work,
such as metal plaster bases, fabricated bar joists, and concrete reinforcing bars. Also included in this
SIC code are establishments primarily engaged in custom roll forming of metal. In accordance with
NAICS code 332323, the structural metal industry also consists of metal corrals, stalls, and holding
gates, which are covered by SIC code 3523 (Farm Machinery and Equipment).
Approximately 349 structural metal manufacturing facilities located in 31 States were identified
from queries of the AIRS database [3]. However, information provided by the American Institute of
Steel Construction (AISC) states that there are approximately 1,000 structural steel and bridge
fabricators in the United States [24]. Of the 540 members of AISC, nearly 80 percent are small
businesses and 90 percent produce less than 20,000 tons per year. A mid-sized AISC fabricator will
process 2,500 tons of steel per year, and will make $3 million in sales annually. A survey was
conducted by AISC of its members requesting paint usage for 1994. Of the 159 respondents,
approximately 50 percent of them used less than 3,000 gallons of paint; approximately 78 percent used
7,000 gallons or less; and 90 percent used less than 10,000 gallons of paint.
Trade Associations. The following trade associations have been identified for this industry
sector:
American Institute of Steel Construction
• Metal Building Manufacturers Association
• Metal Construction Association
• National Association of Metal Finishers
• Specialty Steel Industry of North America
Steel Deck Institute
• Steel Joists Institute
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• Steel Structures Painting Council
Process Description. HAP and VOC emissions are expected from pretreatment processes
(when organic solvents are involved in the pretreatment process), and in coating application (including
flash-off areas and curing ovens). It is important to note that this industry covers several products with
a wide variety of shapes and sizes. Parts may range from 8 inches to over 100 feet in any dimension
(depth, width, or length); and weigh from less than 50 pounds to several tons. Therefore, some of the
processes summarized in this industry description will not be feasible for all products covered by this
industry [25,26].
Surface Preparation. Surface preparation of structural metal aids in the bonding of the
substrate with adhesives or paints. Several methods are utilized to prepare structural metal parts for
surface coating. Parts may be sanded to a mill finish. Hand or mechanical brushing or abrasive shot
blasting may also be means of surface preparation [26]. Etching is another process used in preparing
structural metal for coaling. Etching is a chemical method that produces a silver-white surface, often
referred to as frosted or matte. In this process, the substrate passes through a warm chemical solution
(i.e. caustic soda) removing any natural oxidation. It is then rinsed and passed through a nitric acid bath
to remove undissolved surface alloy constituents or impurities, and rinsed again. Some substrates may
also require a chrome phosphate treatment. The following is an example of a chemical pretreatment
process for structural metal:
1. Phosphate cleaner
2. Rinse
3. Sulfuric acid with small amounts of aluminum bichloride
4. Rinse
5. Nitric acid, which is used as a second cleaner due to the alloy leaving smut on the metal
6. Water rinse
7. Chromate conversion coat
8. City water rinse
9. Deionized water rinse with a small amount of chromic acid. The chromic acid is used to
keep the system acidic. This allows the metal to retain a chrome/phosphate surface
which is preferable for bonding.
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Coating Application. After the pretreatment process, metal sheets or components are placed
on racks and sent through a coating line, if feasible. A coating line may consists of a paint booth, a
flash-off area, and a curing oven. Larger, heavier structures are not compatible with conveyor belt
methods; and the use of an assembly line or line coating process is not practical [26]. Due to weight
and size variability, most of these parts are processed in large open areas without enclosure. In these
cases, flash-off areas and curing ovens are likewise not a part of the coating process. Coatings are
applied using either HVLP or air atomized electrostatic spray application methods; or, for some larger
parts, dip tank application methods also are utilized. Many steel joist manufacturers use large overhead
cranes for the dip coating process [27]. Both manual and/or automated application systems can be
used. Parts may receive up to 4 coats of paint depending on the type of paint used and the use of the
substrate. Metallic or brightly colored parts may also require a clear coat. After coating,
approximately 10 minutes is allowed for flash-off, and parts are sent to curing ovens, where applicable.
Natural-gas fired ovens are used for curing in this industry. Ovens operate at between 400* F and
55OF.
Coatings. Multi-polymer, polyester, and acrylic based coatings are commonly used in the
Structural Metal Industry. A large percentage of paint applied to structural steel for buildings is a single
coat, red or grey oxide, alkyd primer [26]. A two-coat system, that may consist of a zinc rich paint or
an epoxy, is typically used where greater protection is needed. In cases where a three-coat system is
required, a polyurethane top-coat will be added. The main type of paint used in dip coating operations
is a high-solids alkyd [27]. Xylene and toluene are the most common HAPs found in structural metal
coatings.
Emission Control Techniques. Thermal oxidation (incineration) is the primary add-on
control method used for controlling emissions from paint booths and curing ovens in the Structural
Metal Industry. Thermal oxidizers can achieve up to ninety-nine percent destruction of VOC.
Information provided by AISC indicates that most fabricators of larger, heavier steel structures do not
operate any control devices in their facilities [26]. It is difficult to capture emissions generated from
coating processes that take place in large open areas. Many structural metal manufacturing facilities
operate systems to treat waste water from the pretreatment process. However, in facilities where hand
or mechanical methods of surface preparation are utilized, no pretreatment waste waters are produced.
Resources
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The MMPP Surface Coating source category is one of several source categories that will also
be subject to VOC regulations under Section 183(e) of the CAA as amended in 1990. Two resources
that will be used in that effort, and may prove useful in performing case-by-case MACT determinations
under Section 112(g), at least for emissions of volatile HAPs, are the CTG documents for the MMPP
and Magnet Wire source categories:
• Control of Volatile Organic Emissions from Existing Stationary Sources - Volume
VI: Surface Coating Of Miscellaneous Metal Parts and Products. US
Environmental Protection Agency. Office of Air Quality Planning and Standards.
Research Triangle Park, NC. June 1978.
• Control of Volatile Organic Emissions from Existing Stationary Sources - Volume
IV: Surface Coating of Magnet Wire. US EPA. Office of Air Quality Planning and
Standards. Research Triangle Park, NC. December 1977.
In addition, NESHAP and NSPS developed for other surface coating operations may help to
identify compliance options and/or control measures applicable to the MMPP Surface Coating industry.
These regulations are as follows:
Aerospace Manufacturing and Rework Facilities, 40 CFR Parts 9 and 63, Subpart GG
- National Emission Standards for Aerospace Manufacturing and Rework Facilities.
March 27, 1998.
• Ship Building and Repair Facilities, 40 CFR Part 63, Subpart U - National Emission
Standards for Ship Building and Ship Repair (Surface Coating) Facilities. June 18,
1996.
Information on sources of emissions may be obtained from the EPA's AIRS/AFS database and
can be accessed through the Internet (http://www.epa.gov/airsweb/sources.htm).
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September 30,1998
IV. SUMMARY OF COMMENTS AND EPA RESPONSES
This section presents the general comments submitted by MMPP stakeholders on the Draft
Preliminary Industry Characterization document and the responses to these comments from EPA.
Comment: Industry groups SIC 352 and SIC 353 have not been represented in the document. A
list of "unique considerations" for the groups was included with comment.
Response: Comments and information provided have been incorporated into the Final document
under the "Agricultural and Construction Machinery Industry" description.
Comment: A process description of the cast wheels manufacturing process at Reynolds Wheels
International was submitted for use in development of the Automotive Parts Industry
description.
Response: Comments and information provided have been incorporated into the Automotive Parts
Industry description in the Final document.
Comment: A MACT proposal discussed at a past Stakeholder Meeting was excluded from the
draft document. The proposal was to allow facilities to maintain their current level of
VOM pounds per gallon if they can demonstrate that their process as a whole reduces
overall VOM emissions.
Response: The initial phase of the regulatory development has focused on describing the industries
applicable to the Miscellaneous Metal Parts and Products source category, and does
not investigate options for the yet-to-be-proposed rule.
Comment: The industry group referred to as "Steel Pipe and Foundry" in the PIC document would
be better described as "Steel Pipe and Steel Foundry".
Response: Comment has been incorporated into the Final document as a change in the industry
name to "Pipe and Foundry," and the segment has been expanded to include other
metal pipe and foundry industries.
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Comment: The potential overlap with the Iron and Steel Foundry MACT category should be cited.
Response: Comment provided has been incorporated into the Final document.
Comment: The process description provided for the Structural Steel Industry is not representative
of the entire industry. A summary of processes used by the industry was included with
comment.
Response: Comments and information provided have been incorporated into the process
description of the Structural Metal Industry in the Final document.
Comment: The industry group referred to as "Large Trucks and Buses" in the PIC document
would be better described as "Heavy-Duty Trucks and Buses".
Response: Comment provided has been incorporated into the Final document under the
description of "Heavy-Duty Trucks and Buses".
Comment: The process description provided for the Heavy-Duty Trucks and Buses Industry is not
representative of the entire industry. A summary of processes used by the industry was
included with comment.
Response: Comments and information provided have been incorporated into the Final document
under the process description of "Heavy-Duty Trucks and Buses."
Comment: Need clarification on the use of SIC and NAICS Codes. The document currently
addresses groups as being "previously described using SIC Code 3417". Most
industries still use the SIC Code system and the language may be confusing.
Response: The language describing the classification of industries by SIC or NAICS Codes has
been modified to avoid this confusion.
Comment: The use of a VOC-containing lubricant commonly used in the Magnet Wire industry
was omitted from the process description. Emissions from this process are typically not
controlled by catalytic or thermal incinerators.
Response: The section on the Magnet Wire industry has been updated to include this information.
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Comment: The description for Railroad Transportation does not include locomotives and
locomotive parts.
Response: The section on the Rail Transportation Industry has been updated to include this
information.
Comment: The term "Job Shops" needs to be clarified.
Response: For the purposes of this document, the term "Job Shops" refers to surface coating
contract facilities. To avoid further confusion, we have changed the name of the
industry segment to "Contract Coating Facilities".
Comment: In the description of the Metal Shipping Container Industry eliminate references to
container thickness requirements. These requirements change frequently and are
irrelevant to surface coating.
Response: References to container thickness requirements have been removed from the Metal
Shipping Container Industry description in the Final document.
Comment: The Metal Shipping Container industry description includes a list of DOT tests for
containers. The vibration test, included on the list, is not required of manufacturers.
Response: The list of DOT tests for Metal Shipping Containers has been modified to exclude the
vibration test.
Comment: The Steel Shipping Container Institute was not included on the list of applicable
associations.
Response: The Steel Shipping Container Institute has been added to the association list.
Comment: The process description provided for the Metal Shipping Container Industry is not
representative of the entire industry. A summary of processes used by the industry was
included with comment.
Response: Comments and information provided have been incorporated into the Final document
under the process description of Metal Shipping Containers.
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Comment: Metal container reconditioning operations have been classified as SIC 7699 (NAICS
81131) by the U. S. Department of Commerce.
Response: SIC code 7699 has been added to the table of applicable industries.
Comment: Metal container reconditioning does not require the use of pretreatment processes using
organic solvents. Steel shot blasting or wire brushing are used to strip drums prior to
painting or lining.
Response: The process description for Metal Shipping Containers has been updated to include this
information in the Final document.
Comment: The Rubber Manufacturers Association was not included on the list of industry
members participating in the stakeholder process.
Response: The Rubber Manufacturers Association has been added to the stakeholder list in the
Final document.
Comment: Rubber Manufacturers Association member company operations are not reflected in
the SIC codes listed. Rubber-to-metal bonding operations are classified under either
SIC 3061 or SIC 3069.
Response: SIC codes 3061 and 3069 have been added to the table of applicable industries.
Comment: There is not a process description for the rubber-to-metal bonding industry.
Response: Information on this industry was not available for Final document, but has been
collected through other efforts and will be included in the Background Information
Document (BID).
Comment: The Steel Joist Institute was not included on the list of industry members participating in
the stakeholder process.
Response: The Steel Joist Institute has been added to the stakeholder list in the Final document.
Comment: The steel joist facilities are usually classified under SIC 3441, however, in the PIC
document they have been listed under SIC 3449.
Response: The 1987 Standard Industrial Classification Manual specifically lists "fabricated bar
joists" as one of the products included in SIC 3449. However, the manual also
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specifically lists "Steel joists, open web: long-span series" as a product under SIC
3441. Therefore, both SIC codes have been used to describe the steel joist industry.
Comment: According to the industries listed in the PIC document, the EPA is proposing to
characterize the Miscellaneous Metal Parts and Products category into 11
subcategories.
Response: There has not been any subcategorization of the MMPP category as of yet. The
industry sector profiles included in the PIC document are only those sectors which have
been individually studied thus far and in no way denote a subcategorization.
Furthermore, the industry segments listed in this document are not a definitive listing of
all industries covered within this source category.
Comment: The process description provided for the Structural Steel Industry is not representative
of the entire industry. A summary of processes used by the steel joist industry was
included with comment.
Response: Comments and information provided have been incorporated into the Final document
under the process description of Structural Metal.
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V. REFERENCES
1. U.S. Census Bureau Website, 1997 NAICS and 1987 SIC Correspondence Tables. 1998.
http://www.census.gov/epcd/www/naicstab.htm.
2. Standard Industrial Classification Manual. Executive Office of the President, Office of
Management and Budget. 1987.
3. U.S. EPA's Aerometric Information Retrieval System (AIRS).
4. The Shapemakers Buyers' Guide. Aluminum Extruders Council. 1997.
5. The Shapemakers Extrusion Showcase. Aluminum Extruders Council. 1993.
6. Aluminum Extruders Council Website. Aluminum Extruders Council. 1997.
http://www.aec.org.
7. Extrusion Technology Website. Extrusion Technology, http://www.extrutech.com.
8. Extrusion Industry Profile Survey 1995. Aluminum Extruders Council. 1996.
9. The Shapemakers - Extrusion Coatings Spotlight. Aluminum Extruders Council. 1997.
10. Kirsch, F. William and Gwen P. Loobey. Waste Minimization Assessment for a Manufacturer
of Aluminum Extrusions. U.S. EPA, Risk Reduction Engineering Laboratory. Cincinnati, Ohio.
April 1992.
11. Coatings Alternatives Guide (CAGE) Website. Research Triangle Institute in cooperation with
U.S. EPA, Air Pollution Prevention and Control Division. Research Triangle Park, North
Carolina. 1996. http://www.cage.rti.org.
12. Products Finishing Magazine, 1998 Large Coating Job Shop Survey.
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13. Summary of the Site Visit to the Freightliner Facility in Cleveland, North Carolina. July 1997.
14. Summary of the Site Visit to the Freightliner Facility in Mt. Holly, North Carolina. July 1997.
15. Summary of the Site Visit to the Volvo Facility in FAiblin, Virginia. June 1997.
16. Control of Volatile Organic Emissions from Existing Stationary Sources - Volume IV: Surface
Coating of Magnet Wire. U.S. EPA, Office of Air Quality Planning and Standards. Research
Triangle Park, North Carolina. December 1977.
17. Summary of the Site Visit to the Phelps Dodge Magnet Wire Company. Laurinburg, North
Carolina, August 1997.
18. Compilation of Air Pollutant Emission Factors - Volume I: Stationary Point and Area Sources.
(AP-42), 5th edition. U.S. EPA, Office of Air Quality Planning and Standards. January
1995.
19. Letter. Comments on MMPPSC Industry Characterization from Bob Schenker, General
Electric Company. September 18, 1998.
20. Brody, Aaron and Kenneth Marsh (ed). The Wiley Encyclopedia of Packaging Technology.
2nd edition. Washington, DC. 1997.
21. Letter. SSCI Comments on PIC from David Core, Steel Shipping Container Institute,
September 22, 1998.
22. Letter. Comments from Dana Worcester, The Association of Container Reconditioners.
September 21, 1998.
23. Summary of the Site Visit to the Union Pacific Railroad Facility in DeSoto, Missouri,
September 1997.
24. Summary of the Site Visit to the Cupples Products, Inc. Facility in Union, Missouri,
September 1997.
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25. Summary of the Site Visit to the Windsor Metal Specialties Facility in Kissimmee, Florida,
September 1997.
26. Letter. Comments from Kenneth G. Lee, American Institute of Steel Construction, September
21, 1998.
27. Letter. Comments from R. Donald Murphy, Steel Joist Institute, September 16, 1998.
In addition to the materials cited above, the following references were consulted for information
pertaining to this document.
• Almag Website. Almag Aluminum Inc. 1997. Http://www.almag.com.
• Alumax - Magnolia Division Website. Alumax. 1997. http://www.alumax.com.
• Control Of Volatile Organic Emissions From Existing Stationary Sources - Volume VI: Surface
Coating Of Miscellaneous Metal Parts and Products. U.S. EPA, Office of Air Quality Planning
and Standards. Research Triangle Park, NC. June 1978.
McMinn ,Beth, C.R. Newman, Robert C. McCrillis and Michael Kosusko. VOC Prevention
Options for Surface Coating. Alliance Technologies Corporation, Chapel Hill, NC. SAIC,
Durham, NC. U.S. EPA, Air and Energy Engineering Research Laboratory. Research
Triangle Park, NC. 1992.
• Shapemakers - Aluminum Extrusions: Where Innovations Take Shape. Aluminum Extruders
Council. 1991.
SAPAs WWW Server. SAPA Limited. Tibshelf, Alfreton, Derbyshire DE55 5NH, United
Kingdom, http://www.sapa-uk.com.
• The Shapemakers - Extrusion Design Spotlight. Aluminum Extruders Council. 1997.
• The Shapemakers Extrusion Showcase. Aluminum Extruders Council. 1993.
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• Steel Shipping Containers Institute Website, http://www.steelcontainers.com.
Summary of the Site Visit to the Alumax Extrusions Facility in Plant City, Florida. September
1997.
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