United States
Environmental Protection
Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/3-81-008a
July 1981
Air
                        Draft
                        EIS
Rubber Tire
Manufacturing
Industry —
Background Information
for Proposed Standards

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                                   EPA-450/3-81-008a
Rubber Tire  Manufacturing Industry —
         Background  Information
         for Proposed Standards
             Emission Standards and Engineering Division
            U.S. ENVIRONMENTAL PROTECTION AGENCY
               Office of Air, Noise, and Radiation
             Office of Air Quality Planning and Standards
            Research Triangle Park, North Carolina 27711
                      July 1981

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This report has been reviewed by the Emission Standards and Engineering
Division of the Office of Air Quality Planning and Standards, EPA,
and approved for publication.  Mention of trade names or commercial
products is not intended to constitute endorsement or recommendation
for use.  Copies of this report are available through the Library Services
Office  (MD-35), U.S. Environmental Protection Agency, Research Triangle
Park, N.C. 27711, or from National Technical Information Services,
5285 Port Royal Road, Springfield, Virginia 22161.

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                     ENVIRONMENTAL PROTECTION AGENCY
                         Background Information
                                and Draft
                     Environmental  Impact Statement
                for  Rubber  Tire Manufacturing Industry

                              Prepared  by:
Don R. Goodwin^
Director, Emission Standards  and  Engineering  Division
U.S. Environmental Protection Agency
Research Triangle Park,  NC  27711
(Date)
1.  The proposed standards of  performance  would  limit emissions  of
    volatile organic compounds (VOC)  from  new, modified,  and  recon-
    structed facilities  in rubber  tire manufacturing  plants.
    Section 111 of the Clean Air Act  (42 U.S.C.  7411),  as amended,
    directs the Administrator  to establish standards  of performance
    for any category of  new stationary source of air  pollution that
    "... causes or contributes significantly to air pollution  which
    may reasonably be anticipated  to  endanger public  health or welfare."

2.  Copies of this document have been sent to the following Federal
    Departments:  Labor, Defense,  Transportation,  Commerce, Interior,
    and Energy; the Council on Environmental Quality; members of the
    State and Territorial Air  Pollution Program  Administrators;  the
    Association of Local Air Pollution Control Officials; EPA Regional
    Administrators; and  other  interested parties.

3.  The comment period for review  of this  document is 60  days.
    Ms. Susan R. Wyatt may be  contacted regarding.the date of the
    comment period.                              '

4.  For additional  information  contact:

    Ms. Susan R. Wyatt
    Standards Development Branch (MD-13)
    U.S.  Environmental Protection  Agency
    Research Triangle Park, NC  27711
    telephone:   (919) 541-5578

5.  A limited number of copies  of  this document  are available and may
    be obtained from:

    U.S.  EPA Library (MD-35)
    Research Triangle Park, NC  27711

    National  Technical  Information Service
    5285  Port Royal Road
    Springfield, VA  22161

                                  111

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                           TABLE OF CONTENTS
    e                                                             Page
1.0  SUMMARY .............  .  ..........       1_1
     1.1  Regulatory Alternatives   ......  .....  .         l-l
     1.2  Environmental Impacts   .........  ,  .  .  .  .       l-l
     1.3  Economic Impact ..................       1_2

2.0  INTRODUCTION .....................  .       2-1
     2.1  Background and Authority  for Standards  .  .....       2-1
     2.2  Selection of Categories of Stationary Sources.  .  .       2-5
     2.3  Procedure for Development of Standards  of
               Performance ............  .....       2-6
     2.4  Consideration of Costs ........  .  .....       2-8
     2.5  Consideration of Environmental Impacts  ......       2-9
     2.6  Impact on Existing Sources ......... ...     2-11
     2.7  Revision of Standards of Performance .......     2-11

3.0  THE TIRE MANUFACTURING INDUSTRY .... ........       3-1
     3.1    Introduction ........... .......       3_1
     3.1.1  Tire Manufacturing Plants.  ...........       3_2
     3.1.2  Industry Trends ..... ............       3,2
     3.1.3  Volatile Organic Compound Emissions .......       3-8
     3.2    Processes and Their Emissions. .... .....       3.9
     3.2.1  Preparation of Raw Materials ......... .     3-13
     3.2.2  Component Preparation. . ............     3.14
     3.2.3  Tire Building ................ .       3.21
     3.2.4  Producing the Finished Tire ...........     3-24
     3.2.5  Summary of VOC  Emissions From Tire
               Manufacturing   ........  ...  ...... 3-28
     3.3    Emissions Under Existing Regulations ......     3-28
     3.3.1  Applicable Federal  Standards and
               Regulations   ......  .  ..... '..,...   3-28
     3.3.2  Baseline  Emissions  ......  .........     3-30
     3.3.3  Applicable Occupational  Safety and
               Health Regulations  ...  ............   3.33
     3.4    References  ...................     3.35

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Title                                                            Page
4.0  EMISSION CONTROL TECHNIQUES 	      4-1
     4.1    Factors Affecting Emission Control
               Techniques	      4-2
     4.2    VOC Emission Controls Available to the Tire
               Manufacturing Industry	      4-3
     4.2.1  Incineration of VOCs	      4-4
     4.2.2  Adsorption of VOCs	     4-10
     4.2.3  Low Solvent Consumption Cement Application
            Activities	     4-14
     4.2.4  Low Solvent Content Materials	     4-14
     4.3    Applications of VOC Emission Reduction
               Technology	     4-14
     4.3.1  VOC Emission Reduction Systems for Undertread
               Cementing	     4-14
     4.3.2  VOC Emission Reduction Systems for Sidewall
               Cementing	     4-18
     4.3.3  VOC Emission Reduction Systems for Tread End
               Cementing . .	     4-19
     4'. 3.4  VOC Emission Reduction Systems for Bead
               Cementing	     4-24
     4.3.5  VOC Emission Reduction Techniques for Green
               Tire Spraying	     4-28
     4.3.6  Summary.	  .     4-2$
     4.4    References 	  .............     4-32

5.0  MODIFICATION AND RECONSTRUCTION	      5-1
     5.1    Background ....... 	      5-1
     5.2    40 CFR Part 60 Provisions  for Modification and
               and  Reconstruction	      5-1
     5.2.1  §60.14 Modification	  .      5-1
     5.2.2  §60.15 Reconstruction	      5-3
     5.3    Applicability to Rubber Tire Manufacturing
               Plants.	      5-3
     5.3.1  General.  .	      5-3
     5.3.2  Applicability to Major Sources  in Rubber
               Tire Manufacturing Plants	      5-5
     5.4    References	      5-8

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Title
                                                                  Page
6.0  MODEL PLANTS AND REGULATORY ALTERNATIVES	      6-1
     6.1    Model Plants  .  .  .  ;-„»  .  .  ... ........      6-1
     6.1.1  Model Plant Sizes	      6-1
     6.1.2  Operating Parameters	      6-5
     6.2    Basis for Regulatory Alternatives.  .  	      6-6
     6.2.1  Regulatory Alternative  I	      6-9
     6.2.2  Regulatory Alternative  II.  ...........      6-9
     6.3    References	

7,0  ENVIRONMENTAL IMPACT	      7-1
     7.1    Air Pollution Impact	      7.1
     7.1.1  Primary Air Pollution Impact ..... 	      7.1
     7.1.2  Secondary Air Pollution Impact 	      7_8
     7.2    Water Pollution Impact .............    7.13
     7.2.1  Characterization of Model  Plant Wastewater
               Discharges. ..........  . . .....    7.13
     7,2.2  Water Pollution Impact of the
               Regulatory Alternatives	    7-16
     7.2.3  Applicable Water Pollution Regulations .....    7-17
     7.2.4  Pollutant Discharge Treatment Techniques ....    7-20
     7.2.5  Projected Fifth-Year Water Quality  Impact  ...    7-20
     7.3    Solid Waste Disposal  Impapt. ..........    7.20
     7.4    Energy Impact	    7_25
     7.4.1  Total  Process and Non-Process Energy
               Consumption .....  	 .....    7-25
     7.4.2  Energy Requirements for VOC Emission
               Reduction  Systems  ......  	    7.37
     7.5    Other Impacts	    7-30
     7.5.1  Noise Impacts	    7-30
     7.5.2  Urban and  Community Impacts	    7.30
     7.5.3  Irreversible  and Irretrievable  Commitment
               of Resources.	    7.30
     7.5.4  Impact of  a Delayed Standard 	  .....    7-31
     7.6    References	,             7-32

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Title                                                            Page
8.0  COSTS	     8-1
     8.1    Cost Analysis of VOC Emission Reduction Systems  .     8-1
     8.1.1  Introduction	     8-1
     8.1.2  New Operations	:  .     8-4
     8.2    Other Cost Considerations	•>  .    8-66
     8.2.1  Costs Imposed by Water Pollution Control
               Regulations	    8-66
     8.2.2  Costs Imposed by Solid Waste Disposal     :
               Requirements	    8-67
     8.2.3  Costs Associated with OSHA Compliance  ......    8-68
     8.2.4  Costs Associated with Other Air Pollution
               Control Regulations	  . .  .    8-68
     8.2.5  Composite Costs of Environmental
               Regulatory Requirements	    8-71
     8.3    References	    8-75

9.0  ECONOMIC IMPACT	  .     9-1
     9.1    Industry Characterization	  .     9-1
     9.1.1  General Profile	  .     9-1
     9.1.2  Industry Trends	     9-6
     9.1.3  Industry Growth and Future Capacity
               Requirements 	    9-13
     9.2    Economic Impact Analysis	  .    9-16
     9.2.1  Introduction and Summary. . 	  ......    9-16
     9.2.2  Financial Profile and Market Structure	  .    9-17
     9.2.3  Economic Impact Methodology	,  .    9-23
     9.2.4  Economic Impacts	  .    9-30
     9.3    Socioeconomic and Inflationary  Impacts.  .....    9-34
     9.3.1  Fifth-Year Annual ized Costs	  .    9-34
     9.3.2  Inflationary Impacts	  .    9-34
     9.3.3  Employment Impacts	  .    9-35
     9.4    References	    9-36
                                   vn i

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APPENDIX A - EVOLUTION OF PROPOSED STANDARD;	
APPENDIX B - INDEX TO ENVIRONMENTAL CONSIDERATIONS	
APPENDIX C - EMISSION SOURCE TEST DATA. ..........
APPENDIX D - EMISSION MEASUREMENT AND CONTINUOUS MONITORING
A-l
B-l
C-l
D-l
                                   IX

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                            LIST OF TABLES
Table
Page
1-1  Assessment of Environmental and Ecbnom'ic  Impacts  for
          Each Regulatory Alternative Considered   .........     1-3
3-1  Estimated Tire Production  by Plant  as of  January  1, 1980  ...     3-3
3-2  Announced Plant Expansions, New Plants  and Plant  Closings
          Since 1976	     3-6
3-3  Annual Shipments  of  Passenger  Car and Truck Tires for
          Originial Equipment and Replacement  Markets	  .     3-7
3-4  Properties of Volatile  Organic Compounds  Emitted  from
          Rubber Tire  Manufacturing Operations	    3-10
3-5  Tire Manufacturing Volatile Organic Compounds
          Sources and  Emissions 	    3-12
3-6  Composition of Water-Based Inside and Outside Tire Sprays.  .  .    3-26
3-7  Calculation of Average  VOC Emission Factors for Tire
          Manufacturing Operations	«.  . ,	    3-29
3-8  VOC Emission Reduction  Technology Recommended in  the  CTG  .  .  .    3-31
3-9  Calculation of VOC Emissions from U.S.
          Tire Manufacturing for Year 1979	    3-32
3-10 OSHA Exposure Limits for Solvents Generally Used
          in Tire Manufacturing	    3-34
4-1  VOC Emission Reduction  Efficiencies Using Available Emission
               Reduction  Techniques 	  .....    4-30
6-1  Operating Parameters for a 15,000 Tires/Day Model
          Tire Manufacturing Plant	     6-2
6-2  Operating Parameters for a 30,000 Tires/Day Model
          Tire Manufacturing Plant. .  	     6-3
6-3  Operating Parameters for a 50,000 Tires/Day Model
          Tire Manufacturing Plant	 .  .	     6-4
6-4  Regulatory Alternatives for the Tire Manufacturing
          Industry	    6-10
7-1  Impact Summary of VOC  Emissions from Model Tire
          Manufacturing Plants	     7-5
7-2  1985 VOC Emissions Inventory for U.S. Tire
          Manufacturing Plants	  .	    .7-9
7-3  Annual Nitrogen Oxides  (NOX) Emissions  for  Boilers
          Used on Carbon  Adsorbers  in Model  Plants. .  .	    7-11

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labje.                                                                 Page

 7-4   Annual  Nitrogen Oxide (ML) Emissions Due to the Use
           of  Afterburners	   7-12
 7-5   Wastewater Characteristics  for a Tire Manufacturing
           Plant Not Employing VOC Controls.	   7.44
 7-6   Fifth-Year Model  Plant Wastewater Discharges Due to Carbon
           Adsorption Control  Components	   7.15
 7-7   Solvent Vapor Pressures and Solubility in Water	   7-18
 7-8   U.S.  Environmental  Protection  Agency Effluent Limitations
           for Rubber Processing	  .	   7.19
 7-9   Solid Wastes  Due  to Tire Manufacturing.  .  .  	   7_21
 7-10   Fifth-Year Activated  Carbon Requirements  for Model  Plants
           Under Regulatory  Alternatives I  and  II  	   7.23
 7-11   Fifth-Year Solid  Waste  Impacts  on Model Tire Manufacturing
           Plants Due to the Use of Carbon  Adsorption Control
           Components.	    	    7^24
7-12   1977 Tire  Industry  Energy Consumption  	    7.26
7-13   Projected  Annual  Energy  Requirements  for Model  Plant
           VOC  Emission  Reduction  Systems.  .  .  .	    7_2g
8-1    Cost Combinations Used  for  the  Cost  Analysis of Model
           Plant  VOC  Emission  Reduction  Systems.	    8-2
8-2    Uncontrolled  Exhaust  Gas Parameters  for Model  Rubber
          Tire Manufacturing  Plants	    8-3
8-3    Regulatory  Alternative$  and  VOC Emission Reduction
          Systems for Applicable  Rubber Tire Manufacturing
          Facilities.	    8-5
8-4   Assumptions Used  in Developing Cost Estimates  for
          Carbon Adsorbers	    8-6
8-5   Assumptions Used  in Developing Cost Estimates  for
          Direct  Flame Afterburners	.  .	    8-7
8-6   Assumptions Used  in Developing Cost Estimates  for
          Catalytic  Flame Afterburners.  ... 	    8-8
8-7   Component  Capital Cost Factors for a Model Tire
          Plant  as a Function of  Purchased Equipment Cost, Q  .  .  .    8-10
8-8   Captured Exhaust Gas  Parameters .  	  ........    8-13
8-9   Control  Device Costs	    8-23
8-10  Capital  Costs of VOC  Emission Reduction Systems for
          Rubber Tire Manufacturing Model Plants.  .  . 	    8-31
8-11  Annualized Cost Data for Regulatory Alternatives I and II  .  .    8-46
                                   xi

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Table
8-12  Cost-Effectiveness Data for Regulatory Alternatives I
          and II	   13-55
8-13  Annualized Water Pollution Control Costs Incurred by
          Tire Manufacturers	   8-67
8-14  Annualized Solid Waste Disposal Costs Incurred by
          Tire Manufacturers	   8-69
8-15  Annualized Costs Incurred by Tire Manufacturers in
          Order to Comply with OSHA Regulations 	 .....   8-70
8-16  Annualized Particulate Control Costs Incurred by Tire
        . Manufacturers  	 .....   8-72
8-17  Projected Annualized Costs of Compliance with Applicable
          Regulatory Requirements 	 	   8-73
9-1   Estimated Shares of Original Equipment Market	    9-4
9-2   Brand Shares of Replacement Passenger Tire Market . .  . ...    9-5
9-3   Industry Trend	    9-7
9-4   Passenger Tire Shipments by Market and Tire
          Construction for 1979	    9-9
9-5   Tire Exports and Imports	   9-10
9-6   Tire Price Indices and Current Retail Prices	  9-12
9-7   Profit Margins for Tire Manufacturers ...-.•	   9-18
9-8   Net Profits for Tire Manufacturers	   9-19
9-9   Return on Equity for Tire Manufacturers 	  ....   9-21
9-10  Investment Requirements for New Radial Tire
          Manufacturing Plants	 . .	   9-24
9-11  Annual Revenues for New Radial Tire Manufacturing Plants.  .  .   9-24
9-12  Revenue, Cost, Tax and Profit Summary for Model Tire
          Manufacturing Plants (Pre-NSPS) 	 	  .  .   9-28
9-13  Percent Increases  in Price Under Full Cost Pricing	   9-31
9-14  Return on Investment (ROI) Under Full Cost Absorption  ....   9-33
                                    xii

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                             LIST OF FIGURES
 Figure
 3-1  Tire Manufacturing Flow Diagram .  .  .    ..........      3-11
 3-2  Concentrations of Organic Vapors:  Median of
           Plant Arithmetic Averages. .  .  .......... f        3_35
 4-1  Typical Burner Arrangements Used in Direct
           Flame Afterburners . . . . ..........               4 6
 4-2  Schematic Diagram of a Catalytic Burner Using
           a Torch-Type Preheater ...... .   .......          4-g
 4-3  Three Carbon Adsorption Methods .•........"."."."""'    4.^
 4-4  Ventilation Enclosure for an Undertread or Sidewall
           Cementing Operation ........ .......             .  ,
 4-5  ^"^System for Portable Chipping  and Grinding
                  .............. ...........     4-20
 4-6  Capture System for a  Soldering  Table ..........  .         4_21
 4-7  Capture System for Straight Line Automatic
           Buff1"9 ...........  .......  .  .  .....     4.23
 4-8  Capture Systems for Small  Spray Booths.  .        .......     4_25
 4-9  Capture System for a  Dip Tank  ........  ...I'.'.""     4^27
 8-1  Undertread  Cementing  -  Cost-Effectiveness  of  75  percent  '
           Efficient VOC  Emission  Reduction Systems  ........     8-64
 8-2  Sidewall Cementing  -  Cost-Effectiveness of 75  percent
           Efficient VOC  Emission  Reduction Systems  ........     8-64
 8-3  Automatic Tread End Cementing - Cost-Effectiveness of  '  '
           75 percent Efficient VOC Emission  Reduction Systems.  .  .     8-64
 8-4  Manual Tread end Cementing - Cost-Effectiveness of
           75 percent Efficient VOC Emission Reduction Systems.  .  .     8-64
8-5  Bead Cementing - Cost-Effectiveness of
          75 percent Efficient VOC Emission Reduction Systems.         8-65
8-6  Organic Solvent-Based Green Tire Spraying - Cost-Effectiveness
          of 75 percent Efficient VOC Emission Reduction Systems .    8-65
                                   xi ii

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                              1.0  SUMMARY

      Background  information on proposed new source performance standards
 for the rubber tire manufacturing industry is contained in this document.
 New source performance standards are proposed under authority of
 Sections 111 and 301(a) of the Clean Air Act, as amended.
 1.1  REGULATORY  ALTERNATIVES
      Review of the  technical  support data (Chapters 2 through 5) led
 to  the  selection of two regulatory alternatives.  Chapter 6 presents a
 detailed description of and reasoning for the choice of these alter-
 natives.   Regulatory Alternative I represents the level  of control  of
 volatile organic compound  (VOC)  emissions that would be in effect in
 the absence of additional  regulation.   This  alternative would rely on
 State Implementation Plans (SIPs)  to regulate all  new,  modified, and
 reconstructed  rubber tire  manufacturing operations.   A  typical  SIP for
 rubber  tire manufacturing  operations would require an average reduction
 of  70 percent  for uncontrolled VOC emissions from undertread  cementing,
 tread end  cementing, bead  cementing, and organic solvent-based  green
 tire  spraying.   VOC  emission  reductions under Regulatory Alternative I
 are achievable using VOC capture/control  (emission reduction) systems.
      Regulatory  Alternative II would require that  uncontrolled  VOC
 emissions  from undertread  cementing, sidewall  cementing, tread  end
 cementing,  and bead  cementing  be reduced  by  at least 75  percent.   It
 is  based on  the  use  of  emission reduction systems  for each  operation.
 Under Regulatory  Alternative  II, emissions from organic  green tire
 spraying operations  would  be  reduced 90 percent from average  uncontrolled
 levels by  substitution with water-based sprays.
 1.2   ENVIRONMENTAL IMPACT
      No decrease  from baseline VpC emission  levels would result from
 Regulatory Alternative  I, since the  alternative  represents  no additional
 regulation.  Regulatory Alternative  II  would  result,in decrease  of
annual VOC emissions from rubber tire manufacturing  operations  by
                                1-1

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about 1,700 megagrams (Mg) (1,880 tons) during the fifth-year of the
standard:  this represents a 55 percent reduction from projected
baseline VOC emissions from new, modified, and reconstructed operations.
Secondary pollutant emissions from VOC control devices, water pollution,
solid waste disposal, energy consumption, and noise impacts are anti-
cipated to be insignificant.  Chapter 7 of this document presents an
in-depth analysis of fifth-year environmental impacts for Regulatory
Alternatives I and II.  The results of this analysis are summarized by
the matrix presented in Table 1-1.
1.3  ECONOMIC IMPACT
     No increase in capital costs to the  rubber tire manufacturing
industry would be incurred under Regulatory Alternative I, as the
alternative represents no additional regulation.  Regulatory Alter-
native II would require that an additional $7.8 million be spent by
the tire industry during the first five years of the standard for the
purchase and installation of emission reduction systems employing
carbon adsorbers.  If direct flame afterburners or catalytic afterburners
are installed, additional capital costs incurred by the tire industry
through the first five years of the standard would be approximately
$8.7 million and $13.1 million, respectively.
     Regulatory Alternative II would result  in additional fifth-year
annualized costs of $1.5 million if credits  are given for VOCs that
are recovered by emission reduction systems  using carbon adsorbersj
$2.3 million would be spent if no recovery credits are given.
Fifth-year annualized costs attributable  to  Regulatory Alternative  II
would be $6.3 million if direct flame afterburners are used and
$6.0 million if catalytic afterburners  are employed.
     In the worst case scenario (use of direct flame afterburners  in  a
VOC emission reduction system serving a single operation), pass-through
of costs attributable to Regulatory Alternative  I.I would result  in  an
increase of $0.11 in  the average price  of a  radial passenger tire  by
the fifth year of the standard.  Under  the worst case  presented  for
Regulatory Alternative II,  if the expected return on investment  (ROI)
in the fifth year were 5 percent, it would decrease  from a  5 percent
baseline level to about 4.86 percent.
                                 1-2

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     Chapters 8 and 9 of this document  present  an  analysis  of the cost
and economic impacts of Regulatory Alternatives I  and  II.   The results
of the analysis are summarized by the matrix  presented in Table 1-1.
                                 1-4
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                          2.0   INTRODUCTION

2.1  BACKGROUND AND AUTHORITY  FOR STANDARDS
     Before  standards  of  performance are proposed as a Federal  regula-
tion, air  pollution control methods  available to the affected industry
and  the associated costs  of installing  and maintaining the control
equipment  are examined in detail.  Various levels of control  based  on
different  technologies and degrees of efficiency are expressed  as
regulatory alternatives.  Each  of these alternatives is studied by  EPA
as a prospective basis for a standard.   The alternatives are  investi-
gated in terms of their impacts  on the  economics and well-being of  the
industry,  the impacts  on  the national economy,  and the impacts  on the
environment.  This document summarizes  the information obtained through
these studies so that  interested persons will  be able to see  the
information considered by EPA  in the development of the proposed
standard.
     Standards of performance  for new stationary sources are  established
under section 111 of the  Clean Air Act  (42 U.S.C 7411) as amended,
hereinafter referred to as the Act.   Section  111 directs the  Adminis-
trator to  establish standards of performance  for any category of new
stationary source of air  pollution which "... causes,  or contributes
significantly to air pollution which  may reasonably be anticipated  to
endanger public health  or welfare."
     The Act requires  that standards  of performance for stationary
sources reflect, "...  the degree of  emission  reduction achievable
which (taking into consideration the  cost  of  achieving such emission
reduction, and any non-air quality health  and environmental impact  and
energy requirements) the  Administrator  determines  has  been adequately
demonstrated for that  category of sources."   The  standards apply only
to stationary sources, the construction  or modification  of which
commences after regulations are  proposed by publication  in the  Federal
Register.
                                  2-1
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     The 1977 amendments to the Act altered or  added  numerous  provisions
that apply to the process of establishing  standards of  performance.
     1.   EPA is required to list the categories  of major  stationary
sources that have not already been listed  and regulated under  standards
of performance.  Regulations must be promulgated  for  these  new categories
on the following schedule:
     a.   25 percent of the listed categories by  August 7,  1980.
     b.   75 percent of the listed categories by  August 7,  1981.
     c.   100 percent of the listed categories  by August 1;> 1982.
A governor of a State may apply to the Administrator  to add a  category
not on the list or may apply to the Administrator to  have  a standard
of performance revised.
     2.   EPA is required to review the standards of  performance every
four years and, if appropriate, revise them.
     3.   EPA is authorized to promulgate  a standard  based on  design,
equipment, work practice, or operational procedures when a standard
based on emission levels is not feasible.
     4.   The term "standards of performance" is  redefined,, and a new
term "technological system of continuous emission reduction" is defined,,
The new definitions clarify that the control system must be continuous
and may include a low- or non-polluting process or operation.
     5.   The time between the proposal and promulgation of a  standard
under Section 111 of the Act may be extended to six months,,
     Standards of performance, by themselves, do  not  guarantee  pro-
tection of health or welfare because they  are not designed to  achieve
any specific air quality levels.  Rather,  they  are designed to  reflect
the degree of emission limitation achievable through  application of
the best adequately demonstrated technological  system of continuous
emission reduction, taking into consideration the cost of  achieving
such emission reduction, any non-air quality health and environmental
impacts, and energy requirements.
     Congress had several reasons for including these requirements.
First, standards with a degree of uniformity are  needed to avoid
situations where some States may attract industries by relaxing standards
relative to other States.  Second, stringent standards enhance  the
                                  2-2
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 potential  for  long-term growth.   Third,  stringent standards may help
 achieve  long-term  cost  savings  by avoiding the need for more
 retrofitting when  pollution  ceilings  may be reduced in the future.
 Fourth,  certain  types of standards for coal-burning sources can ad-
 versely  affect the coal  market  by driving up the price of low-sulfur
 coal or  effectively excluding certain coals from the reserve base
 because  their untreated  pollution potentials are high.  Congress does
 not intend that  new source performance standards contribute to these
 problems.  Fifth,  the standard-setting process should create incentives
 for improved technology.
     Promulgation  of standards of performance does  not prevent State or
 local agencies from adopting more stringent emission limitations for the
 same sources.  States are free under  section 116 of the Act to establish
 even more stringent emission limits than  those established  under section
 111 or those necessary to attain  or maintain the National Ambient Air
 Quality  Standards  (NAAQS) under section  110.   Thus,  new sources  may in
 some cases be subject to limitations  more stringent than  standards  of
 performance under  section 111, and prospective owners  and operators of
 new sources should  be aware of this possibility in  planning  for  such
 facilities.
     A similar situation may arise when a major emitting  facility is to
 be constructed in a geographic area that  falls  under  the  prevention of
 significant deterioration of air  quality  provisions  of Part  C  of the
Act.  These provisions require,  among  other  things,  that major emitting
facilities to be constructed in such  areas are  to be  subject to  best
available control technology.  The term Best  Available  Control Techno-
logy (BACT),  as defined in the Act, means
          ...  an emission limitation  based on  the maximum degree  of
          reduction of each pollutant  subject  to regulation under
          this  Act'emitted from, qr which results from, any major
          emitting  facility,  which the permitting authority, on  a
          case-by-case basis, taking  into account energy, environ-
          mental, and  economic impacts and other costs, determines
          .is  achievable for such facility through application of
          production processes and available methods,  systems, and
          techniques,  including  fuel  cleaning or treatment or
          innovative fuel combustion techniques for control of each
          such  pollutant.  In no event shall application of "best
                                  2-3
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          available control technology" result in emissions of any
          pollutants which will exceed the emissions allowed by any
          applicable standard established pursuant to section 111
          or 112 of this Act.  (Section 169(3))
     Although standards of performance are normally structured in terms
of numerical emission limits where feasible, alternative approaches are
sometimes necessary.  In some cases physical measurement of emissions
from a new source may be impractical or exorbitantly expensive.  Section
lll(h) provides that the Administrator may promulgate a design or
equipment standard in those cases where it is not feasible to prescribe
or enforce a standard of performance.  For examples emissions of hydro-
carbons from storage vessels for petroleum liquids are greatest during
tank filling.  The nature of the emissions, high concentrations for
short periods during filling and low concentrations for longer periods
during storage, and the configuration of  storage tanks make direct
emission measurement impractical.  Therefore, a more practical approach
to standards of performance for storage vessels has been equipment
specification.
     In addition, section lll(i) authorizes the Administrator to grant
waivers of compliance to permit a source  to use innovative continuous
emission control technology.   In order to grant the waiver,, the Adminis-
trator must find:   (1) a substantial likelihood that the technology will
produce greater emission reductions than  the standards require or an
equivalent reduction at lower  economic energy or environmental cost;  (2)
the proposed system has not been adequately demonstrated;  (3) the
technology will not cause or contribute to an unreasonable risk to  the
public health, welfare, or safety;  (4) the governor of the State where
the source is located consents; and  (5) the waiver will not prevent the
attainment or maintenance of any ambient  standard.  A waiver may have
conditions attached to assure  the source  will not prevent attainment of
any NAAQS.  Any such condition will have  the force of a performance
standard.  Finally, waivers have definite end dates and may be termi-
nated earlier if the conditions are not met or  if the system fails  to
perform as expected.   In such  a case, the source may be given up to three
years to meet the standards with a mandatory progress schedule.
                                   2-4
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2.2  SELECTION OF  CATEGORIES  OF  STATIONARY SOURCES
     Section  111 of  the  Act directs  the Administrator to list categories
of stationary sources.   The Administrator "...  shall  include a category
of sources  in such list  if in  his  judgment it causes, or contributes
significantly to, air pollution  which  may reasonably  be anticipated to
endanger public health or welfare."  Proposal  and promulgation of
standards of  performance are  to  follow.
     Since  passage of the Clean  Air  Amendments  of 197,0, considerable
attention has been given to the  development of  a system for assigning
priorities  to various source  categories.   The approach specifies  areas
Of interest by considering the broad strategy of the  Agency for imple-
menting the Clean Air Act.  Often, these  "areas" are  actually pollutants
emitted by  stationary sources.   Source categories that emit these
pollutants  are evaluated and  ranked  by a  process involving  such factors
as:  (1) the  level of emission control  (if any)  already required  by
State regulations, (2) estimated levels of control  that might be  re-
quired from standards of performance for  the source category,  (3) pro-
jections of growth and replacement of  existing  facilities for the
source category, and (4) the estimated incremental  amount of air
pollution that could be  prevented  in a preselected  future year by
standards of performance for the source category.   Sources  for which
new source  performance standards were  promulgated or  under  development
during 1977, or earlier, were selected  on  these  criteria.
     The Act amendments  of August  1977 establish specific criteria to
be used in  determining priorities for  all  major  source categories not
yet listed  by EPA.  These are:   (1)  the quantity of air pollutant
emissions that each such category will emit,  or  will  be designed  to
emit; (2) the extent to  which each such pollutant may  reasonably  be
anticipated to endanger  public health  or welfare; and  (3) the  mobility
and competitive nature of each such  category  of  sources  and  the consequent
need for nationally applicable new source  standards of performance.
     The Administrator is to promulgate standards for  these  categories
according to the schedule referred to  earlier.
     In some cases, it may not be feasible  immediately to develop a
standard for a source category with  a  high  priority.   This might
                                  2-5
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happen when a program of research  is  needed  to  develop  control  techniques
or because techniques for sampling and measuring  emissions  may  require
refinement.  In the developing of  standards, differences  in the time
required to complete the necessary investigation  for different  source
categories must also be considered.   For  example,  substantially more
time may be necessary if numerous  pollutants must  be investigated  from
a single source category.  Further, even  late in  the development
process the schedule for completion of a  standard  may change.   For
example, inability to obtain emission data from well-controlled sources
in time to pursue the development  process in a  systematic fashion  may
force a change in scheduling.  Nevertheless, priority ranking is,  and
will continue to be, used to establish the order  in which projects are
initiated and resources assigned.
     After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be
determined.  A source category may have several facilities  that cause
air pollution, and emissions from  some of these facilities  may  vary
from insignificant to very expensive  to control.   Economic  studies of
the source category and of applicable control technology maiy show  that
air pollution control is better served by applying standards to the
more severe pollution sources.  For this  reason, and because there is
no adequately demonstrated system  for controlling  emissions from
certain facilities, standards often do not apply  to all facilities at
a source.  For the same reasons, the  standards  may not  apply to all
air pollutants emitted.  Thus, although a source category may be
selected to be covered by a standard  of performance, not all pollutants
or facilities within that source category may be covered by the standards,
2.3  PROCEDURE FOR DEVELOPMENT OF  STANDARDS  OF  PERFORMANCE
     Standards of performance must (1) realistically reflect best
demonstrated control practice; (2) adequately consider  the  cost, the
non-air-quality health and environmental  impacts,  and the energy
requirements of such control; (3)  be  applicable to existing sources
that are modified or reconstructed as well as new  installations; and
(4) meet these conditions for all  variations of operating conditions
being considered anywhere in the country.
                                  2-6
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      The objective of a program for developing standards is to identify
 the best technological  system of continuous emission reduction that    ;
 has been adequately demonstrated.  The standard-setting process involves
 three principal  phases  of activity:  (1) information gathering, (2)
 analysis of the information, and (3) development of the standard of
 performance.
      During the information-gathering phase, industries are queried
 through  a telephone survey, letters of inquiry, and plant visits by
 EPA representatives.   Information is also gathered from many other
 sources, and  a  literature search is conducted.   From the knowledge
 acquired about  the industry, EPA selects certain plants at which
 emission tests  are conducted to provide reliable data that characterize
 the pollutant emissions from well-controlled existing facilities.
      In  the second phase of a project,  the information about the in-
 dustry and  the  pollutants emitted  is used in analytical studies.
 Hypothetical  "model plants" are defined to provide a common basis  for
 analysis.   The model  plant definitions, national  pollutant emission
 data, and existing State regulations governing  emissions from  the
 source category  are then used in establishing  "regulatory alternatives."
 These regulatory alternatives are  essentially different levels of
 emission control.
     EPA conducts  studies  to determine  the impact  of each  regulatory
 alternative on the economics of the industry and on  the national
 economy, on the  environment,  and on energy consumption.   From  several
 possibly applicable alternatives,  EPA selects the  single most  plausible
 regulatory  alternative  as  the basis for a  standard of  performance  for
 the source  category under  study.
     In  the third  phase  of  a  project, the  selected regulatory  alternative
 is translated into a standard  of performance, which, in  turn,  is
written  in  the form of a federal regulation.  The  federal regulation,
when applied to  newly constructed plants, will  limit emissions  to the
levels indicated in the  selected regulatory  alternative.
     As early as is practical  in each standard-setting  project, EPA
representatives discuss  the  possibilities of a  standard  and the form
it might take with members of  the National Air  Pollution Control
                                  2-7
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Techniques Advisory Committee.  Industry representatives and other
interested parties also participate in these meetings.
     The information acquired in the project is  summarized  in  the
Background Information Document (BID).  The BID,  the  standard,  and  a
preamble explaining the standard are widely circulated  to the  industry
being considered for control, environmental groups, other government
agencies, and offices within EPA.  Through this  extensive review
process, the points of view of expert reviewers  are taken into  consi-
deration as changes are made to the documentation.
     A "proposal package" is assembled and sent  through the offices of
EPA Assistant Administrators for concurrence before the proposed stan-
dard is officially endorsed by the EPA Administrator.   After being
approved by the EPA Administrator, the preamble  and the proposed regu-
lation are published in the Federal Register.
     As a part of the Federal Register announcement of  the  proposed
regulation, the public is invited to participate in the standard-setting
process.  EPA invites written comments on  the  proposal  and  also holds
a public hearing to discuss the proposed standard with  interested
parties.  All public comments .are summarized and incorporated  into  a
second volume of the BID.  All information reviewed and generated  in
studies in support of the standard of performance is  available to  the
public in a "docket" on file  in Washington,  D. C.
     Comments from the public are evaluated, and the  standard  of
performance may be altered in response to  the  comments.
     The significant comments and EPA's  position on  the issues raised
are included in the  "preamble" of a  "promulgation package," which  also
contains the draft of the final  regulation.  The regulation is then
subjected to another round of review and refinement  until  it is approved
by the EPA Administrator.  After  the Administrator signs the regulation,
it is published as a  "final rule" in the  Federal Register.
2.4  CONSIDERATION OF COSTS
     Section 317 of  the Act requires an  economic impact assessment
with respect to any  standard  of  performance  established under  section
111 of the Act.  The assessment  is  required  to contain  an analysis of:
                                   2-8
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 (1) the costs of compliance with the regulation,  including  the  extent
 to which the cost of compliance varies depending  on the effective  date
 of the regulation and the development of less expensive or  more efficient
 methods of compliance; (2) the potential inflationary or recessionary
 effects of the regulation; (3) the effects the regulation might have
 oh small  business with respect to competition; (4) the effects  of  the
 regulation on consumer costs; and (5) the effects of the regulation on
 energy use.  Section 317 also requires that the economic impact assess-
 ment be as extensive as practicable.
      The economic impact of a proposed standard upon an industry is
 usually addressed both in absolute terms and in terms of the control
 costs that would be incurred as a result of compliance with typical,
 existing  State control  regulations.   An incremental  approach Is  necessary
 because both new and existing plants would be required to comply with
 State regulations in the absence of  a federal  standard of performance.
 This approach requires  a detailed analysis of the economic impact from
 the cost  differential  that would exist between a proposed standard of
 performance and  the typical  State standard.
      Air  pollutant emissions  may cause water pollution problems, and
 captured  potential  air  pollutants may pose a solid waste disposal
 problem.   The total  environmental  impact of  an emission  source must,
 therefore,  be analyzed  and the costs determined  whenever possible.
      A thorough  study of the  profitability and price-setting mechanisms
 of  the  industry  is  essential  to the  analysis  so  that an  accurate esti-
 mate of potential  adverse  economic impacts can be made for proposed
 standards.   It is  also  essential  to  know the capital  requirements for
 pollution  control  systems  already placed on  plants so  that the addi-
 tional  capital requirements necessitated by  these federal  standards
 can  be  placed  in,proper  perspective.   Finally, it is necessary to
 assess  the  availability of capital to provide  the additional  control
 equipment  needed  to meet the  standards of  performance.
 2.5  CONSIDERATION OF ENVIRONMENTAL  IMPACTS
     Section  102(2)(C) of  the  National Environmental Policy  Act  (NEPA)
of 1969 requires federal agencies to prepare detailed  environmental
                                  2-9
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impact statements on proposals for legislation and other major  federal
actions significantly affecting the quality of the human environment.
The objective of NEPA is to build into the decision-making  process  of
federal agencies a careful consideration of all environmental aspects
of proposed actions.
     In a number of legal challenges  to standards of  performance  for
various industries, the United States Court of Appeals  for  the  District
of Columbia Circuit has held that environmental impact  statements need
not be prepared by the Agency for proposed actions under section  111
of the Clean Air Act.  Essentially, the Court of Appeals has  determined
that the best system of emission reduction requires the Administrator
to take into account counter-productive environmental effects of  a
proposed standard, as well as economic costs to the industry.  On this
basis, therefore, the Court established a  narrow exemption  from NEPA
for EPA determination under section 111.
     In addition to these judicial determinations, the  Energy Supply
and Environmental Coordination Act  (ESECA) of 1974  (PL-93-319)  specifically
exempted proposed actions under  the Clean  Air Act from  NEPA requirements.
According to section 7(c)(l),  "No action  taken under  the Clean  Air Act
shall  be deemed  a major  Federal  action  significantly  affecting  the
quality of  the human environment within  the meaning of  the  National
Environmental Policy Act  of 1969."   (15  U.S.C.  793(c)(l))
     Nevertheless,  the Agency  has concluded  that  the  preparation  of
environmental impact statements  could have beneficial effects on
certain regulatory  actions.   Consequently,  although not legally required
to do  so by section  102(2)(C)  of NEPA,  EPA has  adopted  a  policy requiring
that environmental  impact statements  be prepared  for  various' regulatory
actions,  including  standards  of  performance  developed under section
111 of the  Act.   This  voluntary  preparation  of  environmental  impact
statements, however,  in  no  way legally subjects  the Agency to NEPA
requirements.
     To  implement this  policy,  a separate section in  this  document is
devoted  solely  to an analysis  of the  potential  environmental impacts
associated  with  the proposed  standards.  Both adverse and beneficial
impacts  in  such  areas  as air  and water pollution, increased  solid
waste  disposal,  and increased energy consumption are discussed.

                                   2-10
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 2.6   IMPACT ON  EXISTING SOURCES
      Section 111  of the Act defines a new source as "... any stationary
 source,  the construction or modification of which is commenced..."
 after the  proposed  standards are published.  An existing source is
 redefined  as a  new  source if "modified" or "reconstructed" as defined
 in amendments to  the general  provisions of Subpart A of 40 CFR Part
 60, which  were  promulgated in the Federal  Register on December 16,
 1975  (40 FR 58416).
      Promulgation of a  standard of performance requires States to
 establish  standards  of  performance for existing sources in the same
 industry under  section  lll(d)  of the  Act if the standard for new
 sources  limits  emissions  of a designated pollutant (i.e.,  a pollutant
 for which  air quality criteria have not been issued under  section 108
 or which has  not  been listed  as a hazardous pollutant under section
 112).  If a State  does not act,  EPA must establish such standards.
 General  provisions outlining  procedures for control  of existing  sources
 under  section lll(d)  were promulgated  on November 17,  1975,  as Subpart
 B of 40  CFR  Part  60  (40  FR 53340).
 2.7  REVISION OF  STANDARDS  OF  PERFORMANCE
     Congress was aware that  the  level  of  air  pollution  control  achievable
 by an  industry may improve  with  technological  advances.  Accordingly,
 section  111 of the Act provides, that the Administrator "...  shall,  at
 least  every 4 years,  review and,  if appropriate,  revise..."  the  standards.
 Revisions are made to assure that  the  standards continue to  reflect
 the best systems  that become available  in  the  future.   Such  revisions
will  not be retroactive,  but will apply  to  stationary  sources  constructed
or modified after, the proposal of  the  revised  standards.
                                  2-11
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                  3.0  THE TIRE MANUFACTURING  INDUSTRY

 3.1  INTRODUCTION
      For the purposes of this document, rubber  tire manufacturing
 means the mass production of rubber tires in  an assembly-line  fashion.
 Types of tires produced in this manner to be  included  in the definition
 are any agricultural, airplane, industrial, mobile home, light-duty
 truck and passenger vehicle tires which have  a bead diameter up to and
 including 0.5 meter (19.7 inches) and cross section dimension  up to
 0.325 meter (12.8 inches).  Production of heavy-duty truck tires and
 other large tires requires specialized equipment and is on a much
 smaller scale than the tire types under consideration  in this  document.
 Consequently,  these larger tire types are not addressed in this document.
      Basically,  tire manufacturing consists of the production  of
 component parts,  assembly of these components into a raw "green" tire,
 curing,  and finishing to yield a complete tire.   Pneumatic rubber
 tires are constructed from relatively strong fibers,  such as nylon,
 polyester,  rayon, glass, aramid,  or steel.   The  fibers  are impregnated
 with  both natural  and synthetic  rubber and  overlaid with a tread of
 wear-resistant polymer,  such  as  styrene-butadiene rubber (SBR).  Tires
 are assembled  individually by skilled  builders and cured in a heated
 mold  under  pressure  into the  familiar  doughnut shape.
      Obviously, there  are  many different  tire  types and sizes.   Tire
 plants are  usually not dedicated  to  the production of one size  class
 or  "series."  Moreover,  the type  of  tire manufactured may vary  with
 the seasons:  during  summer and fall,  tire plants  may produce a larger
 proportion  of snow tires to build  up inventories  for the ensuing
winter months.  Plants may use the same line of  equipment to  manufac-
 ture more than one tire  type or series.  When  necessary,  the  appropriate
machinery is adjusted  in order to  accommodate  the  different tires.
                                  3-1
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                                                                        26
Most available tire manufacturing emissions data do not differentiate
                           1 9^
between various tire types.      For  illustrative  purposes,,  the  existing
emissions data are related to a representative  tire which  is based  on
an average weight.  Hence, the emission  information can be expressed
in units of mass per tire.  Total tire industry production presented
in Table 3-1 shows that approximately 80 percent of all tires manufactured
in the United States as of January  1980  were  designated for  passenger
car use.  Industry-supplied data indicate the mean weight  of a passenger
tire in 1977 to be about 11.5 kilograms  (25.3 pounds).1"14  One  tire
industry representative has reported  that the average  tire weight in
1979 has decreased to  11.0 kilograms  (24.3 pounds) and predicted
further weight reduction as the newer glass belted radials are produced
Although no tire type  produced may  weigh precisely 11.5 kilograms,  it
is useful to approximate the weight of the average tire manufactured
in the U.S. for comparison of emissions  from  different tire  production
steps.
3.1.1  Tire Manufacturing Plants
     Listed in Table 3-1 are the United  States  tire companies' manufacturing
                                                              ?7
plants and the estimated 1979 tire  production for  each plant.*    Daily
production for the entire industry  as! of January  1, 1980,  was 984,100  tires
                                                             ' O"7  OQ
per day, down approximately 4 percent from the  previous year. "  '
The Gates Rubber Company left the tire  industry in 1976.   Since  1978,
17 tire manufacturing  plants have closed or have  been  scheduled  to
close.
      27-34
              During  the period of 1977 to 1978, six plants were closed
 by Firestone,  Goodyear, Mansfield, Mohawk, and Uniroyal.   Armstrong,
 Firestone,  Goodyear, Mansfield, and Uniroyal  have announced that
                                                        ^2—34
 11 additional  plants will  be closed by the end of 1981.-   °
      Since  1976,  the plans for, or actual start-up of, six plants have
 been announced by General, Goodyear, and Michel in.
      Plant  expansions by Armstrong, Firestone, Goodrich,  and Goodyear
                                                               27-34
 had been announced or were in operation as of January 1,  1979,.
 Table 3-2 lists tire plant openings, closings, and expansions.
 3.1.2  Industry Trends
      Table  3-3 shows the number of passenger car and truck tires
 shipped for the original equipment and the replacement tire markets
                                  3-2
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          Table 3-1.   ESTIMATED TIRE PRODUCTION BY PLANT
                AS  OF JANUARY  1, 198027
Tires Produced
Thousands/Day9
Company
Armstrong Rubber
Company
Cooper Tire and
Rubber Company
Plant Location
Des Moines, IA
Hanford, CA
Natchez, MS
West Haven CT
Nashville, TN
Find! ay, QH
Texarkana, AR
Passenger
Tires
10.0
11.0
3.0
12.0
8.5
49.5
8.4
16.6
25.0
All
Other
4.5
5.5
9.0
19.0
6.0
4.5
10.5
Total
Ti res
14.5
11.0
13.5
12.0
17.5
68.5
14.4
21.1
353"
Denman Rubber
  Manufacturing
  Company

Dunlop Tire and
  Rubber Company
Firestone Tire and
  Rubber Company
Warren, OH
Buffalo, NY
Huntsville, AL
Akron, OH
Albany, GA
Bloomington, IL
Decatur, IL
Des Moines, IA
Los Angeles, CA
Memphis, TN
Nashville, TN
0.2
4.2
        4.0
	
25.0

23.5
17.0
1.0
14.5
4.5
1.5
0.1
3.8
5.0
2.0
6.2
4.4
                                                 1.9
                                 3-3
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Table 3-1.  ESTIMATED TIRE PRODUCTION BY PLANT
      AS OF JANUARY 1, 19802? (Continued)
Tires Produced
Thousands/Day3
Company
Firestone Tire and
Rubber Company
(Continued)

Passenger
Plant Location Tires
Pottstown, PA
Salinas, CA
Wilson, NC

21.0
16.3
15.8
T347T
All
Other
3.0
2.3
—
3073~
Total
Ti res
24.0
18.6
15.8
T6474
Firestone Subsidiaries
Dayton Tire and
Rubber Company
Sieberling Tire &
Rubber Company
General Tire and
Rubber Company

i
i


B.F. Goodrich
Company




Dayton, OH
Oklahoma City, OK
Barberton, OH

Akron, OH
Bryan, OH
Charlotte, NC
Mayfield, KY
Mt. Vernon, IL
Waco, TX

Akron, OH
Ft. Wayne, IN
Miami, OK
Oaks, PA
Tuscaloosa, AL

12: 5
19.2
6.5
38.2
_«.-.
	
19.0
25.0
12.5
15.7
7071
— — —
18.4
5.6
18.0
33.5
75.5
6.1
3.4
3.5
13.0
8.5
0.1
—
9.0
0.5
4.9
2O"
0.5
7.1
7.0
1.0
—
15.6
18.6
22.6
10.0
• 5TT?
8.5
0.1
19.0
34 ..0
13.0
20.6
HH
0.5
25.5
12.6
19.0
33.5 .
91.1
                        3-4
-------
        Table 3^1.  ESTIMATED TIRE  PRODUCTION BY PLANT
              AS OF JANUARY 1, 198027  (Concluded)
Tires Produced
Thousands/Day3
Company
Goodyear Tire and
Rubber Company





Passenger All
Plant Location Tires Other
Danville, VA
Gadsden, AL
Jackson, MI
Topeka, KS
Union City, TN
Lawton, OK


31.5
21.0
30.0
46.0
22.0
150.5
11.8
17.0
1.5
5.0
___
___
35.5
Total
Ti res
11.8
48.5
22.5
35.0
46.0
22.0
T8O"
Goodyear Subsidiaries
Kelly-Springfield
Tire Company



McCreary Tire and
Rubber Company
Michel in Tire
Corporation


Mohawk Rubber
Company
Uni royal,
Incorporated




TOTAL
Cumberland, MD
Fayetteville, NC
Freeport, IL
Tyler, TX

Indiana, PA

Greenville, SC
Spartanburg, SC
Dothan, AL

Salem, VA

Ardmore, OK
Chicopee Falls, MA
Detroit, MI
Eau Claire, WI
Opelika, AL


4.5
29.0
14.5
25.0
~73TO
— ._

25.0

—
25 -°
13.0

32.0
17.2
14.0
20.5
13.7
97.4
781.6
13.0
0.5
5.0
— _
nui
4.0


3.0
2.0
5.0
0.5


4.8
2.0
7.0
5.8
i -J • P
202.5
17.5
29.5
19.5
25.0
~9T75
4.0

25.0
3.0
2.0
30.0
13.5

32.0
22.0
16.0
27.5
19.5
117.0
984.1
Dashes indicate plant does  not produce type of tire listed.
                               3-5
-------
    Table 3-2.  ANNOUNCED PLANT EXPANSIONS, NEW PLANTS AND PLANT
                           CLOSINGS SINCE 19762/-34
Company
Expansions
Goodyear
Armstrong
Fi restone

Goodrich
New Plants
Goodyear
Michel in



General
Closings
Mansfield

Goodyear



Firestone







Uni royal


Mohawk
Armstrong
Location
' !
Gadsden, Alabama
Natchez, Mississippi
Nashville, Tennessee

Woodburn, Indiana

Lawton, Oklahoma
Dothan, Alabama
Spartanburg, South Carolina
Lexington, South Carolina
Lubbock, Texas
Akron, Ohi6

Mansfield, Ohio
Tupelo, Mississippi
Los Angeles, California
Akron, Ohio

Conshohocken, Pennsylvania
Akron, Ohio (Plant 1)
Akron, Ohio (Plant 2)
Los Angeles, California
Pottstown, Pennsylvania
Salinas, California
Barberton, Ohio
Dayton, Ohio
t
Los Angeles, California
Detroit, Michigan
Chicopee ... Fal Is, Massachusetts
Akron, Ohio
West Haven, Connecticut
Year

1979
1978
1978-
1982
1980

1979
1979
1976
1982
1982
a

1978
1980
1977
1977-
1978
1979
1981
1978
1980
1980
1980
1980
1980

1978
1980
1980
1978
1981
a
 Tentative
                               3-6
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                              35
for the years 1975 through 1979.27   During that period, total shipment
of truck tires has shown a compound growth rate of approximately
9 percent per year; the growth rate for passenger car tires during the
same period was approximately 3 percent per year.  Although the total
number of tire shipments during 1979 are higher than those for 1975 or
1976, total shipment of tires during 1979 fell approximately  4 percent
below 1977 levels and 8 percent below 1978 levels.  Declines  in tire
shipments are attributable to the decrease of automobile sales, a
decline in automotive travel and longer lifetime of radial tires.'
     Table 3-3 shows the proportions of passenger radial, bias, and
bias belted tires shipped to original equipment and replacement markets
between 1976 and  1979.  Radial tire shipments dominated the original
equipment market  by 1976 and comprised over half the replacement
market in 1979.27 Extended durability and lifetime, improved vehicle
handling, and increased gas mileage are characteristics which have
allowed radial tires to displace bias and bias-belted tire purchases.
Discussion of projected trends in radial  tire shipments  is
presented in Chapter 9.0.
3.1.3  Volatile Organic Compound Emissions
     Tire manufacturing plants constitute an  industrial  source  of
emissions of volatile  organic  compounds  (VOCs)  to  the ambient air.
Volatile organic  compounds  are added  to rubber  components  during tire
manufacturing  in  order to  aid  in mixing,  promote  elasticity,  produce
 "tack" or  stickiness,  and  "extend"  or replace a portion  of the  raw
material.   Volatile  organic compounds used  as solvents  are predominantly
white  gasoline  and  petroleum naphtha,  although  heptane,  hexane,  toluene,
xylene,  ketones,  and  esters find  some use in  the industry, generally
 in lesser  amounts.   Boiling points  of these non-polar organic solvents
 range  from 30° to 288°C (86° to  550°F).   Consequently,  most of these
 compounds  evaporate during the manufacturing  process:   tests performed
 by the industry have shown that  approximately 8 percent of the VOCs
 applied  to the rubber are absorbed.36'3   In  addition,  hydrocarbons
 from rubber materials are volatilized during  curing and other
 high-temperature operations.
3-8
-------
      The Lower Explosive Limits (LEL) for VOC used in rubber tire
 manufacturing plants, which aid in determining maximum concentrations
 of VOCs permitted for fire safety, range from i.O to 2.5 percent by
               O  O                                               - **
volume of air.
              OQ
                '
                                         .                         -
                      General fire safety pradtice is to provide a
 margin of protection by maintaining organic vapor cbncent rations below
 25 percent of the LEL.     When more than one organic compound is
 involved, it is common  practice to regard the mixture as consisting of
 the component with the  lowest LEL.40  Properties of VOCs emitted from
 rubber tire manufacturing operations are presented in Table 3-4.
 3.2  PROCESSES AND THEIR EMISSIONS
      A generalized tire manufacturing process consists of:   (1) preparation
 and compounding of raw  materials, (2) transformation of the raw materials
 into tire components, (3) tire component assembly, and (4)  molding,
 curing,  and finishing of the assembled components into the  marketable
 product.   Figure 3-1 is a pictorial  flow diagram which will facilitate
 better understanding of the tire manufacturing processes.   Each of the
 above production phases may include  one or more sources of  volatile
 organic  compound (VOC)  emissions.  Total  1977 VQC emissions from
 United States  tire manufacturing plants have been estimated to be in
 the range of 56,100 to  72,700 megagrams (61,800 to 80,100 tons)  with a
 mean  of  64,400  megagrams (71,000 tons);  Table C-l summarizes  1977
 tire  manufacturing VOC  emission  estimates.   The mean  accounts  for
 approximately 45  percent of the  140,000 Mg  of VOCs emitted  by  all
 rubber related  industries (Standard  Industrial  Classification  [SIC]
 group  30)  operating  in  the  U.S.  in 1977.
      Table  3-5  lists operations  which  are sources  of  volatile  organic
 compounds  and the  type  of material emitted.   The first  six  exhaust
 streams listed  in  Table  3-5  contribute  97 percent  of  all VOCs  emitted
 in  a  tire manufacturing  plant.   Green  tire  spraying,  undertread  cementing,
 and sidewall cementing are  the largest  sources  of  VOC emissions.  Tire
 building  is  the fourth most  significant source  of  VOC emissions.
 However, these emissions  are very dilute  (0.01-0.32 g/m3) due  to small
 releases of  VOCs from solvent application at many  tire  building machines,
which occupy a significant proportion of  the total floor space of a  typical
                                  3-9
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-------
           Table 3-5.   TIRE MANUFACTURING VOLATILE ORGANIC
              COMPOUNDS SOURCES AND EMISSIONS1"25
Operation
Organic Solvent-Based
Green Tire Spraying
(inside)
(outside)
Undertread Cementing
Sidewall Cementing
Tire Building
Tread End Cementing
Bead Cementing
Finishing
Curing
Compounding
Milling
Extrusion
Calendering
Latex Dipping
Source

Spray


Cement
Cement
Solvent
Cement
Cement
Ink, Paint,
Spray
Tire
Rubber Batch
Rubber Stock
Rubber Stock
Rubber Stock
Latex
Material Emitted

Solvent


Solvent
Solvent
Solvent
Solvent
Solvent
Solvent
Rubber Volatiles
Rubber Volatiles
Rubber Volatiles
Rubber Volatiles
Rubber Volatiles
Solvent
Percent of
Total VOC
Emissions'

44.5
(15.6)
(28.9)
20.5
13.3
10.7
4.9
2.7
1.8
0.7
0.3
0.2
0.2
0.2
-

Excluding latex dipping operation.
                                 3-12
-------
tire manufacturing plant.1"14  Emissions  from  tread  end  cementing
constitute approximately 5 percent of  total  VOC  emissions  in  a tire
manufacturing plant.  Bead cementing operations  contribute approximately
3 percent to total in-plant VOC emissions.
     Very little emission reduction technology has been  employed  in
the industry.  About 40 percent of the VOC emission  points in reporting
tire plants are hooded for general workroom  ventilation.   VOC-emission
reduction systems are known to be installed  on the undertread cementing
facilities of two plants: one as a retrofit, the other as  a part  of
the original equipment design.1   *4    Industry-supplied data indicate
many plants have converted green tire  spraying operations  to  accommodate
water-based sprays in 1979:  approximately 80  percent of all  tire
production employed water-based inside green tire sprays;  about 55  percent
                                15 25
used water-based outside sprays.
3.2.1  Preparation of Raw Materials
     3.2.1.1  Compoundinq.  During compounding,  raw  crumb  rubber  is
combined with a variety of fillers, extenders, accelerators,  anti-
oxidants and pigments, using internal  mixing devices.  Carbon black
and oil are also added during compounding, and baghouse  particulate
collectors are normally used to control airborne dust generated by
               42
this operation.    After mixing, the rubber  is transferred to roll
mills which form the material into sheets.   The  tacky sheets  of rubber
stock are then coated with a material  such as  soapstone to prevent
them from sticking together during storage.
     VOC emissions from compounding are due  to evaporation of curing
agents, extenders, accelerators, antioxidants, and unreacted  monomers
in the base rubber, brought about as a  result  of heat generated in  the
mixing process.  There are no quantitative data  relating materials
balance to VOC emissions from compounding; thus,  a temperature-weight
loss correlation ,is used as an alternate method  for  estimating  the  VOC
emission factor (Appendix C).  By using an equation  derived from  the
temperature-weight loss correlation for tire curing  which  was  proposed
by S.M. Rappaport,   an emission factor for  compounding of 0.1  g/kg is
estimated.  Therefore, the estimated average VOC  emission  factor  for
compounding the raw material used in an average  tire weighing  11.5  kg
                                  3-13
-------
is 1 gram (0.002 Ib) per tire.  It should be noted that the temperature-
weight loss factor is used only to illustrate the relative magnitude
of VOC emissions from compounding.
     3.2.1.2  Milling.  After compounding, sheeted rubber is fed
manually to a warmup roller mill in order to make the stock more flex-
ible for further processing.  From the warmup mill, the heated  rubber
passes to a strip-feed mill for final mixing.  The temperature  of the
rubber mixture leaving the mill is typically 70°C to 90°C.
     This is a potential VOC emission point as heat generated by sheet
rubber milling may evaporate curing agents, antioxidants, and unreacted
monomers from the material.  At an operating temperature of 80°C,
50 percent of the volatile organic compounds emitted during milling
                                                  43
are assumed to immediately condense to an aerosol.    Engineering
judgment and tire industry observations attribute this phenomenon to
milling temperatures being close to the rubber stock's zero weight
                                                  44
loss temperature (critical temperature) of 73.2°C.    Based on  the use
of the Rappaport temperature-weight loss correlation described  in
Appendix C, an average emission factor for milling is estimated to be
0.6 gram (0.001 Ib) per tire.  As with the compounding emission factor,
the Rappaport temperature-weight loss correlation is used for
illustrative purposes.
3.2.2  Component Preparation
     Once the rubber stock is compounded and milled, it must be
transformed into components from which the tire  is built.  Component
construction involves several parallel operations.  Rubber stock and
other raw materials, including cord and fabric,  are used to make the
following components:  tire tread and sidewalls,  tire cords, tire
belts, and tire beads.  The tire tread is the part of the tire  which
contacts the road surface; the design and composition depend on the
use of the tire.  Sidewalls help anchor the  tread and beads as  well as
provide some strength and  protection to the  materials which form the
tire's pneumatic cushioning.  Tire cords are woven synthetic fabrics
(rayon, nylon, polyester)  which are  impregnated  with rubber.  Tire
cords are the body  of the  tire and supply it with most of  its strength.
Tire belts stabilize the tires, thus preventing  the lateral scrubbing
                                   3-14
-------
or wiping  action  that is  responsible foritread Wear,  tire beads are
rubber-coated wires  that  are in contact with the rim of the wheel on
which  the  tire  is mounted.   These beads ensure that a proper air seal
is maintained around the  wheel  rim at all  times.
     3.2.2.1  Tread  and Sidewall  Preparation.   Tread and sidewall
components may  be formed  separately or as  a single piece, depending on
specifications  for a particular tire.   When treads and sidewalls are
formed as a single component,  the two types of rubber stock used to
make the treads and  sidewalls  are peeled from  the rollers of separate
strip-feed mills  and continuously fed to a tread/sidewall extruder.
Where white sidewall  tires  are  manufactured, the sidewall components
consist of extruded  white rubber  strips sheathed in a protective
coating of black  rubber.  The  tread/sidewall extruder laminates the
two strip types to form the tire  tread and two sidewalls.  Adhesion of
the strips is accomplished  through heat and pressure generated by a
rotating extruder screw.  After extrusion, a cushioning layer is added
to the underside  of  the tread/sidewall  combination.   The continuous
strip of rubber is then conveyed  to a  cementing station.
     If tread and sidewall  are  formed  as separate components, separate
production lines  are  used.   Production equipment used to manufacture
sidewall components  is similar  to equipment used for tread  production.
When treads and sidewalls are manufactured separately,  the  components
are not joined  until  the  green  tire is  constructed in tire  building.
     Quantitative information on  emissions from extrusion in  tire
manufacturing plants  is not available.   However,  depending  on the mass
of the extruded product,  temperatures  between  70°C and  90°C are attained
during extrusion  due  to heat generation by the rotating  screw.   The
rotating screw  constitutes  a potential  VOC emission  point as  the heat
produced during extrusion of the  continuous  rubber strips may volatilize
materials added during compounding.  Applying  the temperature-weight
loss correlation  described  in Appendix  C and employing  the  assumption
that 50 percent of the materials  condense  immediately after volatili-
zation yields an  estimated  average  emission  factor for  extrusion of
0.6 gram (0.001 Ib) per tire.43   This value  is  determined for illustrative
purposes only.
                                  3-15
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     3.2.2.1.1  Undertread cementing.  The underside of the tread
component (tread base) is tackified to aid in tire assembly.  After
extrusion, the continuous strip of tread is tackified, .usually by the
                                                  1*5-?5 45 46
felt roller application of a solvent-based cement.     '  "    Solvents
typically used for this purpose include:  naphtha, heptane,, hexane,
some isopropanol, and toluene.1"    After cement application, the tread
strip is cooled by air drying on a conveyor and/or by passing through  a
water bath.
     Evaporation of solvent from the line's cement holding tank,
application assembly, and tread component as it passes along a conveyor
after cement application contributes to tire plant VOC emissions.
Materials balance calculations and evaporation rate testing have shown
that about 70 percent of VOC emissions at undertread cementing originate
at the tank area and application equipment; approximately 30 percent
of undertread cementing VOC emissions result from solvent evaporating
off the cemented rubber.    Test results "supplied by the industry show
that about 90 percent of the solvent applied to the rubber evaporates
within 30 seconds.  After several minutes of drying, approximately
8 percent of the solvent applied to the rubber remains absorbed and may
not be emitted from the coated material for periods exceeding 24 hours.   »
It should be noted that the amount of VOC emitted from the cement tank
and application assembly, the solvent evaporation rate, and proportion
of absorbed solvent may vary from plant to plant, as these parameters
are dependent on equipment used, equipment dimensions, ventilation  rate,
cement type, solvent type, and other work practices.
     In order to maintain VOC concentrations in the workplace below
Occupational Safety and Health Administration  (OSHA) employee exposure
limits (Section 3.3.3), industry employs local and general ventilation
methods to remove air contaminated by undertread  cementing operations.
Tire industry-supplied data indicate that exhaust gas flow rates due
to ventilation of undertread cementing operations range from 0.6 to
4.4 m3/sec (1,271 to 9,323 scfm).      Consequently, VOC concentrations
in the undertread cementing exhaust stream vary from approximately
0.7 to 5.0 g/m3  (90.0 x 10"5 to 310.0 x 10"6 Ib/ft3).1"14  The number
of undertread cementing operations per plant,  the exit gas flow  rate,
                                   3-16
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 temperature,  and  pressure for those operations which have individual
 ventilation systems  are  shown in Appendix C.   The calculated annual
 mass  of  volatile  organic compounds emitted from the undertread cementing
 facility in each  plant is also included.   Based on industry-supplied
 solvent  consumption  data ~25»40 and mass-balance calculations included
 in Appendix C,  the mean  emission factor for undertread cementing is
 estimated  to  be 63.2 grams (0.139 Ib)  of solvent VOC per tire.
      3.2.2.1.2  Sidewall  cementing.  Where sidewall  components are
 processed  separately from undertread components, a continuous strip of
 sidewall  rubber may  be tackified to aid in tire assembly.   After
 extrusion, the  continuous strip can be tackified, usually by the felt
 roller application of a  solvent-based  cement.15"25'45"46  Solvents
 typically  used  for this  purpose include:  naphtha, heptane,  hexane,
 isopropanol,  and  toluene.15"25  After  cementing, the sidewall  component
 can be water-cooled  and  air  dried,  then rolled in fabric and transported
 to the appropriate tire  building area.
      Evaporation  of  solvent  from the line's cement holding  tank,
 application assembly, and cemented  rubber sidewall  component contributes
 to VOC emissions.  No information  is available,  but since  sidewall
 operations are  similar to undertread operations, it is assumed that
 about 70 percent  of  sidewall  cementing  VOC emissions  originate at the
 application area; approximately 30  percent of  the VOC emitted  is assumed
 to evaporate  off  the  rubber.   It is  also  assumed that about 90 percent
 of the solvent  applied to the  rubber evaporates  within 30  seconds;  after
 several minutes of drying, approximately  8 percent  of the  applied solvent
 is assumed to remain  absorbed  in the rubber material.
      In order to maintain  VOC  concentrations in  the workplace  below
 Occupational  Safety and Health  Administration  (OSHA)  employee  exposure
 limits (Section 3.3.3.),  industry employs  some  local  and general
 ventilation methods to remove  air contaminated by VOC  evaporation from
 sidewall cementing operations.   No  information  is available concerning
exhaust gas flow rates and VOC  concentrations  from  sidewall  cementing.
However, flow rates are expected to  be  similar to those  in  undertread
cementing.  Thus if solvent VOC  use  is  less at sidewall  cementing than
at undertread cementing,   the respective VOC concentrations  in  exhaust
gases should be lower.

                                  3-17
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     The calculated annual mass of VOCs emitted from sidewall cementing
operations in each plant is shown in Appendix C.  Based on industry-
supplied solvent consumption data "   and mass balance calculations
included in Appendix C, the mean emission factor for sidewall cementing
is estimated to be 41.1 grams (0.091 Ib) of solvent VOC per  tire.
     3.2.2.1.3  Tread end cementing.  After undertread cementing,  the
continuous rubber tread is cut to the specified length for each  tire
series.  The tread ends may be tackified by a solvent-based  cement,
which is usually applied by either of two methods.  The tread ends can
be automatically sprayed with cement after undertread cementing  and
prior to stacking in trays for transport to tire building.   Alterna-
tively, cement can be manually applied to the ends of the rubber,
either after undertread cementing and prior to stacking, or  as  the
tread is wrapped around the tire building drum.  Naphtha, white  gasoline,
hexane, and heptane are solvents typically used in cements for  tread
end cementing; isopropanol and toluene are used less frequently.
     Potential VOC emissions result from: excess sprayed cement,  the
manual cement holding tank; the manual cement brush, and from the
tread ends.  Materials balance calculations and evaporation  rate
testing have shown that about 80 percent of the automatic  tread  end
cementing VOC emissions originate from the application  equipment;
                                                     A O
approximately 20 percent  evaporates from the  rubber.    Approximately
75 percent of manual tread end cementing emissions come from the
cement pot and brush; about 25 percent result  from solvent  applied to
the  tread ends.    Test results  supplied by the  industry  show that
about 90  percent of the solvent  applied  to the  rubber  evaporates
within 30 seconds.  After several minutes  of  drying, approximately
8 percent of the  solvent  applied to the  rubber  remains  absorbed and
may  not be emitted  from the coated  material  for periods exceeding
24 hours.36'37
     The  tire  industry utilizes  local  and  general  ventilation methods
to maintain workplace  VOC concentrations  associated  with  tread end
cementing emission  points below  OSHA  employee exposure limits
 (Section  3.3.3).   Consequently,  exhaust  flow  rates  due to ventilation
                                                     o
of tread  end  cementing  lines  range  from  0.8 to 9.4 m /sec (1,695 to
19,920  scfm).   Resulting  VOC  concentrations  in the tread  end cementing
                                   3-18
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exhaust stream vary from 0.02 to 5.20  g/m3  (1.2  x  10"6  to  324.6 x
10"  Ib/ft ). "    Appendix C contains emission  data  for individual
tire plant tread end cementing lines.   Based  on  industry-supplied
solvent consumption data     and the mass-balance  calculations  described
in Appendix C, the estimated mean emission  factor  for automatic tread
end cementing is 23.8 grams (0.052 Ib) of solvent  VOC per  tire.  The
mean emission factor for manual processes is  estimated  to  be  9.9 grams
(0.022 Ib) of solvent VOC per tire.  The combined  tread end cementing
emission factor, which is calculated by weighting  the contribution of
VOCs by both cement application methods on  a  pi ant-by-plant basis, is
estimated to be 15.1 grams (0.033 Ib)  per average  tire.
     3.2.2.2  Latex Dipping.  Tire cords and  belts are  constructed
from woven synthetic fabrics, such as  nylon,  polyester,  and rayon, as
well as steel and glass fiber.  Upon arrival  at  a  tire  manufacturing
plant, a roll of fabric is first spliced, either by adhesive  or by a
high-speed sewing machine, onto the tail of the  previously processed
roll.  This continuous sheet of fabric is then fed under controlled
tension to a latex dip tank.  After latex dipping, the  fabric travels
past either rotating beater bars or vacuum  suction lines and  then
through a drying oven to remove excess  solvent.
     Tire manufacturers tend to be producing  less and purchasing more
fabric which has been dipped in latex  at a  textile mill.  Some  of the
                           42
reasons for this trend are:
     1) a small  dipping operation requires  disproportionately large
capital expenditures;
     2) latex dipping is a high-speed  process which can  readily
over-supply a tire plant with fabric;  and
     3) on a weight basis, shipping costs for dipped and undipped
fabric are nearly the same.
In accordance with the above, only one  tire plant has reported consumption
of solvent for on-site latex dipping.  Therefore, no VOC emissions
have been calculated for this process.
     3.2.2.3  Calendering.  The latex  dipped fabric is passed through
a calendering machine which impregnates the fabric with  rubber.   Both
sides of the fabric can be coated simultaneously by four-roll  calenders,
                                  3-19
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which are the most  commonly  used  type in the tire manufacturing industry;
three-roll calenders  are  used  less  frequently as  they can coat only
one side of the fabric  at a  time.   Before being sent to the tire
building facility,  the  rubberized fabric is  cooled and cut to the
proper angle and length for  the tires in which it will be used.
     No emissions data  are available  for this source.   However, as the
rubber stock is bonded  to fabric, steel  mesh, or  glass fiber, its
plasticity is maintained  by  steam-heating the calender rolls, typi-
cally to temperatures of  70°C  to 80°C.   Therefore, VOC emissions from
calendering should  be very similar  in character and magnitude to those
from milling or extrusion.   Consequently, the estimated average VOC
emission factor for calendering operations is 0.6 gram (0.001 Ib) per
tire.  This value is determined for illustrative  purposes only.
     3.2.2.4  Bead  Formation.  Tire beads are" rubber-covered  wires
which ensure a seal between  a  tire  and  the rim of the wheel on which
it is mounted.  In  general,  bead formation is accomplished by simul-
taneously extruding rubber onto several  strands of braided copper or
brass-plated steel  wire and  fashioning  several  layers  of this coated
wire into a ring.   The  rubber  material  may be tackified to ensure
proper adhesion of  the  bead  assembly  to the  sidewall  when the tire is
built, although not all companies follow this practice.
     To facilitate  tackification of the extruded  rubber,  the  bead
assembly may be dipped, sprayed, rolled,  or  swabbed with  a solvent-
based cement.  Cement application can occur  either before the strands
are wound into a bead or  after.  One  method  of applying cement after
bead formation, bead dipping,  consists  of manually immersing  bead
packages or bundles into  a cement vat.   The  dipped packages are raised
from the tank, the  excess  cement allowed  to  run off,  and  the  beads
manually racked for drying.  Another  dipping  method consists  of placing
individual  beads on conveyorized hooks,  which are designed to dip the
beads, allow excess cement to  run off,  and carry  the beads to a drying
area.   Spray application  of  bead cement may  be  performed  in a manner
similar to package  dipping of  beads.  Another tackification method
involves manual application  of solvent  to the assembled  bead.   In some
cases, a layer of rubber-coated fabric  is wrapped around  the  bead;
natural  tack may be relied on  for adhesion.   Another cement application

                                  3-20
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 method incorporates the tackifying agent into the rubberized fabric
 wrap.     Where cement is applied before bead formation, the extruded
 rubber wire is passed across a cement-laden roller or swab suspended
 in  a small  cement trough.   A bead is then fashioned out of the cemented
 material.
      Solvents  employed for bead cementing operations include: naphtha,
 white  gasoline,  hexane,  heptane; some isopropanol  and toluene.1"25
 Solvent evaporating from excess sprayed cement,  the dip tank, roller,
 swab,  or cement  trough,  and the bead material  once it is removed from
 the cement  application area constitute potential  VOC emission points.
 Local  and general' ventilation methods are employed by the tire industry
 to  maintain workplace VOC  concentrations associated with bead tackifi-
 cation  operations  below  OSHA employee exposure limits (Section 3.3.3).
 Industry-supplied  data indicate that exhaust gas  flow rates from bead
 cementing operations  vary  from 0.1 to 4.7 m3/sec  (212 to 9,960 scfm)
 and have VOC concentrations which  range from 0.21  to 3.7 g/m3
 (13.1 x 10'6 to  231.0 x  10"6 Ib/ft3).1"25  Appendix C contains  emission
 and operating  data  specifically for plant bead cementing operations.
 Based on the application of mass-balance calculations delineated in
 Appendix C,  a  nominal  70 percent/30 percent distribution of emissions
 from the cement  application apparatus  and cemented bead, and  an 8 percent
 absorption  factor for solvent applied  to the bead,40'41  the mean VOC
 emission factor  for all bead  cementing  methods is  estimated to  be
 8.3 grams (0.018 Ib)  of solvent VOC  per tire.  This  emission  factor is
 a combined  value, as  average  VOC emission  factors  for bead  dipping,
 rolling, and swabbing  differ  by approximately  1 gram  per tire.   Bead
 spraying emissions are higher than  bead  dipping, rolling, or  swabbing;
 however, in  1979, only one  plant reported using a  bead spraying
 operation.
 3.2.3  Tire Building
     3.2.3.1  Conventional Tire Building Techniques.   Passenger  car
and truck tires are built as cylinders on a  collapsible,  rotating
drum.  First the inner liner, which makes the finished tire airtight,
 is wrapped around the drum, followed by the  required  layers (plies) of
 rubber impregnated fabric.  Next the edges of the  fabric and  inner
liner are wrapped around the bead assemblies.  This step is followed

                                  3-21
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by a manual or automatic rolling operation  (stitching) where  pressure
is applied from the tread center!ine out to  the  beads in  order  to
expel air trapped between the assembled components.  Then the belts,
made of fabric, steel, or glass fiber, are  laid  onto the  cord.   Finally,
the tread and sidewall components are wrapped  around the  assembled
components and are stitched.  The product is an  uncured or "green"
tire.  There are three reported variations  in  the method  of assembling
tires.  In one-stage tire building, all components are assembled on
one machine.  Two-stage tire building consists of constructing  the
carcass at one site, and at a second site rechecking the  siubassembly,
and then applying and stitching the belts,  tread, and sidewall.
Three-stage tire building involves carcass  assembly, belt/tread
construction, and final tire assembly at different stations.
Single-stage construction is normally utilized to produce bias  and
bias-belted tires.  Two- and three-stage building methods are generally
employed for radial-ply tire construction.
     Organic solvents, such as naphtha, white  gasoline, heptane,
hexane, isopropanol, methanol, and toluene,  may  be used during  building
to tackify the rubberized tire components;       The  purpose of  tackifying
rubber components is to keep the green tire intact prior  to curing.
Solvent may be applied when tire components have lost natural tack  or
if the company tire building instructions specify the use of  solvent
for  a particular tire type.  Tire  builders  generally are  allowed
considerable discretion as to whether to apply solvent.
     Potential VOC emission points  at tire  building  stations  are the
solvent pot, applicator brush, and  tackified tire components.  VOC
emissions may  vary between tire  building machines, as  the quantity  of
solvent used for component assembly  can  be  directly  influenced  by the
machine operator.  Solvent use may vary  for one-, two-,  or three-stage
tire building  operations  and may differ  between  machines  used for each
step of two- or three-stage tire assembly  processes.
     Presently, most  of the tire industry  uses only  general ventilation
to  keep workplace organic  vapor  concentrations due  to evaporation of
solvents  applied during tire  building  below OSHA employee exposure limits
 (Section  3.3.3).  Consequently,  tire building exhaust flow rates range
from 3.3  to  10.6 m3/sec  (6,992 to  22,460 scfm),  and  VOC concentrations
                                   3-22
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 in the exhaust  stream  vary  from  0.01  to 0.32 g/m3 (0.6 x 10"6 to 20.0 x
 10"  Ib/ft  ). "    Based oh  data supplied  for existing tire plants and
 the mass-balance calculations  included  in  Appendix  C,  the average VOC
 emission factor for tire building  is  estimated to be  33.0 grams (0.073
 Ib) of solvent VOC per tire.
      3-2-3-2  Emerging Tire  Building  Technology;  Rotomolded Polyester
 Elastomer Pneumatic Tires.   A  new  concept  in  tire manufacturing involves
 casting, rather than constructing  tires.   Polyair Maschinenbau  GmbH
 has developed a liquid injection molding (LIM)  system  which has at its
 center a compact production  cell or module that forms  a  completely
 self-contained tire production unit.  The cast tire is produced by
 assembly of the core unit, mixing and injection of the liquid chemical
 system,  setting of the tire, and tempering.  The  entire  process  can be
 manual,  partially automated, or fully automated.52
      When fully developed,  rotomold tires are expected to offer  several
 advantages  over conventional  tires:  40 percent reduction in production
 cpsts,  improved uniformity,  and a 25 percent reduction in weight due
 to lower  material  density.   LIM tires  are expected to have run-flat
 capabilities,  thus  providing greater driving safety.   Energy savings
 are anticipated  as  the  cast  tires would  be  recyclable.53'54
      Problems  encountered with  LIM tires are heat  build-up, low
 coefficients of  friction, and a tendency to go out-of-round.  These
 problems  have  prevented the  cast  tire  from  meeting U.S. automotive
 specifications.  One American tire  manufacturer has  evaluated rotomolding
 technology and believes the  production of tires in this manner within
 the near  future  to be unlikely:   production  costs  are  not expected to
 decrease  due to high material costs; materials  needed  to  produce a
 uniform product are not available;  although  the urethane  used to make
 the tires would be 10 percent less  dense  than  rubber, no  weight
 reduction would be achieved as  the  lack of strength would require
 that more urethane be used; the economic  feasibility of recycling the
 tires has not been demonstrated.37
     Even with the problems,  development  of tire casting  methods for
aircraft,  trucks, and other highway vehicles has proceeded.52"54 The
                                  3-23
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Caterpillar Tractor Company is licensing technology for filament
                                                      53
winding closed-torus tires with detachable components.    Zedron,  Inc.,
(U.S.) is preparing to market unitized tire assemblies of polyester
                               54
for low-speed, off-highway use.    An international consortium
(LIM-Holding SA) has been formed to handle LIM tire production  patent
                                       52
rights and licensing of new technology.    Phoenix Gummiwerke AG  is
cooperating with Volkswagen to evaluate reinforced rotomolded auto
tires and to obtain licensing of technology for the production  of
                                   54
headless tires by filament winding.
3.2.4  Producing the Finished Tire
     3.2.4.1  Green Tire Spraying.  The green tire is removed from the
tire building drum and placed, either singly or in batches,,  in  a  booth
where each uncured tire is sprayed on the inside with band»ply  lubricants,
and on the outside with mold release agents.  Band-ply lubricants
reduce friction and allow air to be removed from the inside  of  the
tire as the molding/curing bladder expands.  Mold release agents
prevent the outside of the tire from sticking to the mold after curing.
     Solvents consumed at green tire spraying operations include  naphtha,
white gasoline, hexane, heptane, isopropanol, and toluene.   VOC emission
points due to the use of green tire sprays are solvent evaporation
from the coated green tires and solvent evaporation from overspray.
Materials balance calculations and evaporative rate testing  have  shown
that approximately 80 percent of the VOC emissions originate from the
application equipment; approximately 20 percent evaporates from the
green tire.    Test results supplied by industry indicate that  about
8 percent of the solvent that  is applied  to  the  green  tires  is  absorbed.
     In most plants, green tire spraying  is  enclosed to  reduce  working
                                     42
area contamination due to overspray.    Where  organic-based  green  tire
sprays are used, VOC concentrations  in  the working  area  are  maintained
below OSHA employee exposure limits  (Section 3.3.3) by venting  the
green tire spray booths to the atmosphere.   Exhaust gas  flow rates
                                                         3
from green tire spraying booths range from 0.7 to 29.3 m /sec (1,270
                                                                         36
to 62,080 scfm).
0.3 to 4.7 g/m3  (21 x  10"6  to  293  x  10"6  lb/ft3).
                  VOC concentrations in the exhaust stream vary from
                                                   The described
organic vapor concentrations in spray booth exhaust streams may not
                                   3-24
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 adequately reflect total VOC emissions from green tire spraying facilities:
 As the enclosures were primarily designed to capture overspray, green
 tires may be removed from the booths before all of the solvents have
 evaporated.   Appendix C, contains data provided by the tire manufacturing
 industry which pertains to the type of spray used, the number of spray
 booths,  and  exit gas properties.  Based on industry-supplied solvent
 use data "   and using the mass-balance calculations described in
 Appendix C,  mean VOC emission factors for green tire spraying in
 plants using inside and outside organic solvent-based sprays are
 estimated to be 48.2 and 89.0 grams (0.106 and 0.196 Ib)  of solvent
 VOC per  tire,  respectively.   Therefore, the total  organic solvent-based
 green tire spray emission factor is estimated to be 137.2 grams (0.302 Ib)
 of solvent VOC per tire.
      Alternately,  water-based sprays can be used for green tires.
 Approximately  82 percent of  reported 1979 tire production involved the
 use of water-based inside sprays,  and about 54 percent involved the use
 of water-based outside sprays.14"25  Depending on  the composition  of the
 water-based  formulation and  of the organic-based formulations previously
 used,  water-based  green tire spray application can result in VOC
 emissions  which  are 95 to 100 percent less  than the average  organic
 solvent-based  green tire  spray emission factor.1"25'55"69
      Water-based  inside tire sprays are commercially available from
 several  companies.   "  9  These sprays,  which  may contain  small
 amounts  of organic solvents,  are .basically  aqueous dispersions  of
 silicone  solids.   Specifications for water-based inside and  outside
 tire  sprays  are  summarized in  Table 3-6.  Percent  composition of
 organic  solvent  in  inside sprays ranges  between 0  and 6 percent, by
 weight;  outside water-based  green  tire  spray  VOC content  ranges  from
 0  to  11  percent, by weight.55"69   Industry-supplied  information
 indicates  that most  inside and  outside water-based  green  tire sprays
 have  no  VOCs.  "    Based on  industry-supplied  data,  the  average
water-based  inside  green tire  spray  emission  factor  is estimated to
 be 0.1 grams (0.0002 Ib) per tire;  the  average  water-based outside
                                  3-25
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Table 3-6.  COMPOSITION OF WATER-BASED INSIDE AND OUTSIDE TIRE SPRAYS
                                                                    55-69
Product Component
, Inside Tire Spray Solids9
Water
Volatile Organic
Solvents
Emulsifiersb
Amount
by
20
35
0
3
, Percent
Weight
1
-60 • .
- 60
-6
-4
Outside Tire Spray
BactericidesG
Corrosion Inhibitors

Solidsb
Water
Volatile Organic
   Solvents
   <1

20 -  40
60 -  80
 0 -  11
aPolydimethylsiloxane, other silicone compounds,  and/or mica.
 Composition not specified.
G6-Acetoxy-2,2-dimethyl-m-dioxane.
                                  3-26
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spray emission factor is estimated  to  be  1.4 grams  (0.003 Ib)  per
tire.  Therefore, the total average water-based  green  tire spray
emission factor is estimated  to be  1.5 grams (0.003 Ib)  per tire.
     3.2.4.2  Molding and Curing.   Passenger car tires are molded and
cured in automatic presses.   A rubber  bladder is inflated inside the
tire, causing it to assume the characteristic doughnut shape.   As the .
bladder inflates, the mold is closed.  Steam heat is applied to the
outside of the tire through the mold and  to  the  inside by the  bladder.
Excess rubber and trapped air are forced  put through weepholes in the
mold.  After a time, pressure, and  temperature-controlled cure, the
press is cooled, the bladder  is deflated, and the tire,  complete with
grooved tread and raised lettering, is removed from the  mold.   Curing
usually takes 20 to 60 minutes at a temperature  of100°C to 20Q°C*42
After removal from the mold,  cured  tires  are usually inflated  and
allowed to cool.  This last step ensures  product quality and uniformity
by al1 owing the tire to cure  completely under control!ed conditions.42
     Tire curing and molding  has two potential VOC  emission points.
The heated, VOC contaminated  air may be emitted  through  the curing
mold weepholes or as the mold opens.   Based  on the  use of mass-balance
calculations similar to those described in Appendix C, an average
emission factor for molding and curing is estimated to be 2.0  grams
(0.004 Ib) per tire.  This emission factor compares favorably  to the
value of 2.2 grams (0.005 Ib) of VOC per  tire calculated using the
temperature-weight loss equation in Appendix C and  the assumption that
a curing temperature of 150°C is applied  to  an average tire mass  of
11.5 kilograms.  Although the emission factor and temperature-weight
loss equation tend to agree,  the values must be  used with caution,  as
identification and measurement of VOC  emissions  from tire molding and
curing,operations pose a complex problem.  This  problem  has been
recognized, and a tire curing study has been undertaken  by the U.S.
EPA's Industrial Environmental Research Laboratories (IERL).
     3.2.4.3  Finishing.  After the tires have cooled, the rubber
whiskers formed from excess rubber, which has  cured in the weepholes
of the mold, are removed by a grinding machine.   Final buffing and
grinding of most tire treads  is performed to ensure proper balance.
                                  3-27
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The black protective strip is ground off  tires which  are  constructed
with a white sidewall strip.  The white sidewalls are given  a  water-based
protective coating to minimize scuffing during shipping or mounting on
rims.  Some tires may receive decals or other manufacturer markings
prior to inspection and shipping.  These  operations may involve  the
use of organic solvent-based inks, paints, or sprays.  Consequently,
markings applied with organic solvent-based coatings  constitute  VOC
emission points.                                               '
     Volatile organic compound emission calculations  for  finishing
operations are based on the mass-balance  calculations described  in
Appendix C and use data provided by the tire industry.       The  average
VOC emission factor for tire finishing was estimated  to be 5.7 grams
(0.013 Ib) per tire.  Calculated annual VOC emissions reported for
finishing operations at existing tire manufacturing plants are listed
in Appendix C.  Operational exhaust flow  rate ranges  and  ranges  of VOC
concentration in the exhaust stream are also included.
3.2.5  Summary of VOC Emissions from Tire Manufacturing
     The total uncontrolled VOC emission  factor is estimated to  be
308.4 grams (0.680 Ib) VOC per average tire produced; this value
assumes the use of organic solvent-based  green tire spraying.  Organic
solvent-based green tire spraying, undertread cementing,  sidewall
cementing, tire building, tread end cementing, and bead cementing con-
tribute 97 percent of the total VOCs emitted from tire production.
Average uncontrolled VOC emission factors associated  with tire
manufacturing operations are summarized in Table 3-7.
3.3  EMISSIONS UNDER EXISTING REGULATIONS                 ',
3.3.1  Applicable Federal Standards and Regulations
     As of January 1980, there were no Federal or State regulations
governing VOC emissions from tire manufacturing plants.   General
hydrocarbon regulations do exist, but are not specifically applicable
to VOC emissions from rubber tire manufacturing plants.   Connecticut
does use its general hydrocarbon regulations to reduce VOC emissions
from the undertread cementing and green tire spray facilities  of one
plant.  State Implementation Plans (SIPs) are being revised  to include
regulations for existing tire plants.  Regulations adopted will  be
                                  3-28
-------
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-------
based upon recommendations for VOC emission reduction as outlined in
the OAQPS Guidelines Series, Control of VOC Emissions from Manufacture
of Pneumatic Rubber Tires (CTG).70  Levels of control recommended as
Reasonably Available Control Technology (RACT) in the CTG are  presented
in Table 3-8.  The SIPs governing VOCs emitted from existing tire
plants are expected to be submitted to EPA for consideration by July  1,
I960.71*72  All SIPs are expected to be reviewed and approved  by EPA
by December 1981.  Once the SIPs for existing tire plant VOC emissions
are approved and promulgated, a schedule will be formulated, in which
each State would have 1 year to develop an enforcement  program for
compliance with VOC regulations.  EPA expects that the  installation of
VOC emission reduction equipment in existing tire plants will  take up
to 2 years after promulgation of the SIPs.  Therefore,  VOC emission
reduction for existing tire plants  probably will not be in effect
before late 1983.73
3.3.2  Bas eli ne Emission s.
     Year 1979 baseline VOC emissibns for tiife manufacturing plants  in
the U.S. are derived from the product of each operation's VOC  emission
factor, daily 1979 industry tire production  (984,100 tires per day),
and the average annual operating schedule  (269 days  per year). "   *  ' *
As there are no current VOC regulations which apply  directly to  tire
manufacturing, it is assumed that no VOC emission  reduction techniques
are employed unless otherwise specified.  Tire industry-supplied
information  indicates that  two  plants  (comprising  3  percent of total
production)  use VOC emission reduction  systems in  their undertread
cementing lines;1"25 emission reductions due  to  these  systems  are  not
included in  baseline VOC  emission calculations.   Differences  in  VOC
emissions due to the use  of organic solvent-based  and  water-based
green  tire sprays are  included  in baseline  emission  calculations,  as
industry-supplied data  indicate that 82 percent  of reported  1979  tire
production involved the  use of  inside water-based  green tire  sprays
and  54 percent  involved  the use of  outside  water-based green  tire
sprays.  Therefore, approximately  58,690 megagrams (64,690  tons)  of
VOCs were emitted from U.S. tire manufacturing  plants  during   1979.
Table  3-9 presents  the calculation  of  estimated  1979 VOC emissions
from U.S. tire  manufacturing  plants.

                                   3-30
-------













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3.3.3  Applicable Occupational Safety and Health  Regulations
     The Occupational Safety and Health Act of  197074 authorizes  the
Secretary of Labor to set standards which will  afford the highest
degree of health and safety protection to the employee.  Subsequently,
29 CFR Subpart Z 1910.1000 sets employee exposure limits for selected
air contaminants.    Table 3-10 lists exposure  limits for solvents
generally used in tire manufacturing.  An Occupational Health Study
Group (OHS6) study of rubber workers funded by  the United Rubber
Workers, Armstrong, Firestone, General, Goodrich, Goodyear, and Uniroyal
tire companies reported that working area vapor concentrations were
well below the limits set in 1910.1000.76  Figure 3-2 illustrates
OHSG's observation.  Existing OSHA regulations are not expected to
affect baseline emission values, though it is important that any
proposed VOC emission control  strategy must not conflict with OSHA
regulations.
                                  3-33
-------
I
                      Table 3-10.  OSHA EXPOSURE LIMITS FOR SOLVENTS GENERALLY
                                  USED IN TIRE MANUFACTURING 75
                      Substance
Employee Exposure Limit9
   ppm                mg/m3
                 Heptane (n-heptane)
                 Hexane (n-hexane)
                 Isopropyl  alcohol
                 Methyl alcohol
                 Naphtha
                 Pentane
                 To!uene
   500
   500
   400
   200
   100
 1,000
   200
2,000
1,800
  9QO
  260
  400
2,950
                 a8-hour time weighted average
                                                  3-34
-------
                ports per million parts of air by volume {ppm)
OCCUPATIONAL C
GROUP

CEMENT MIXING
EXTRUSION



CURING
PREPARATION
INSPECTION
AND REWIR
) 5.0 IO.O 15
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           Exposure Limit Values  (ppm)
   Pentane     600
                100
                400
                100
r "~i Hexane
     Heptane
     Toluene
     Benzene
                 10
Figure 3-2.   Concentrations of Organic Vapors:
     Median  of Plant Arithmetic Averages?6
                        3-35
-------
3.4  REFERENCES

 1.  Letter from R.O. Lewis, Armstrong Rubber Company, to D.R. Goodwin,
     ESED/OAQPS/EPA.  February 28, 1978.  Response to Section 114
     letter.

 2   Letter from E.J. Burkett, The Goodyear Tire and Rubber Company,
     to D.R. Goodwin, ESED/OAQPS/EPA.  May 17, 1978.  Response to
     Section 114 letter.

 3.  Letter from R.C. Niles, Uniroyal,  Inc., to D.R. Goodwin, ESED/ -.
     OAQPS/EPA.  July 13, 1978.  Response to Section 114 letter.

 4.  Letter from R.C. Niles, Uniroyal,  Inc., to D.R. Goodwin, ESED/
     OAQPS/EPA.  May 16, 1978.  Response to Section 114 letter.

 5.  Letter from R.C. Niles, Uniroyal,  Inc., to D.R. Goodwin, ESED/
     OAQPS/EPA.  May 24, 1978.  Response to Section 114 letter.

 6,  Letter from R.C. Niles, Uniroyal,  Inc., to D.R. Goodwin, ESED/
     OAQPS/EPA.  April  4, 1978.  Response to Section 114 letter.

 7.  Letter from N.  Onstott, Mohawk  Rubber Company, to K.J. Zobel,
     ESED/OAQPS/EPA.  March 21, 1978.   Response to  Section  114 letter.

 8  Letter from R.M. Walter,  The  Firestone Tire  and Rubber Company,
     to D.R.  Goodwin, ESED/OAQPS/EPA.   May  5,  1978.  Response to
     Section  114 letter.

 9.  Letter from R.M. Walter,  The  Firestone Tire  and Rubber Company,
     to D.R.  Goodwin, ESED/OAQPS/EPA.   June  7, 1978.   Response  to
     Section  114 letter.

 10.  Letter from J.W. Lewis,  The  B.F.  Goodrich Company,  to  R.T. Walsh,
     ESED/OAQPS/EPA.  May  24,  1978.   Response  to  Section 114  letter.
 11   Letter from L.B.  Cooper, Michelin Tire Corporation, to D.R.  Goodwin,
      ESED/OAQPS/EPA.   April  13, 1978.   Response to Section 114 letter.

 12   Letter from R.M.  Walter, The Firestone Tire and Rubber Company,
      to R.T. Walsh, ESED/OAQPS/EPA.  June 29, 1978.  Response to
      Section 114 letter.

 13.  Letter from L.B.  Cooper, Michelin Tire Corporation, to D.R.  Goodwin,
      ESED/OAQPS/EPA.   March 13, 1978.   Response to Section 114 letter.

 14   Letter from R.W.  Frase, General Tire and Rubber Company, to D.R.
      Goodwin, ESED/OAQPS/EPA.  May 16, 1978.  Response to Section 114
      letter.
                                   3-36
-------
15.  Letter from E.O. Burkett, The Goodyear Tire and Rubber Company,
     tp J.R. Farmer, CPB/ESED/OAQPS/EPA.  March 31, 1980.  Response to
     Section 114 follow-on letter.
16.  Letter from R.C. Niles, Uniroyal,  Inc., to .J.R. Farmer, CPB/ESED/
     OAQPS/EPA.  April 11, 1980.  Response to Section 114 follow-on
     letter.
17.  Letter from J.R. Laman, The Firestone Tire and Rubber Company, to
     D.R. Goodwin, ESED/OAQPS/EPA.  April 8, 1980.  Response to Section  114
     follow-on letter.
18.  Letter from J.R. Townhill, The General Tire and Rubber Company,
     to K.J. Zobel, CPB/ESED/OAQPS/EPA.  April 2,  1980.  Response to
     Section 114 follow-on letter.
19.  Letter from R.R. Clark, The B.F. Goodrich Company,  to D.R. Goodwin,
     ESED/OAQPS/EPA.  March 18, 1980.   Response to Section 114 follow-on
     letter.
20.  Letter from P.M. Luysterborghs, Armstrong Rubber Company, to D.R.
     Goodwin,  ESED/OAQPS/EPA.  March 5,  1980.  Response  to Section  114
     follow-on letter.
21.  Letter from E.J. Burkett, The Goodyear Tire and Rubber Company,  to
     J.R. Farmer, CPB/ESED/OAQPS/EPA.   March 21, 1980.   Response to
     Section 114 follow-on letter.
22.  Letter from L. Cooper, Michel in, to J.R. Farmer, CPB/ESED/OAQPS/EPA.
     February  19, 1980.  Response to Section 114 follow-on letter.
23.  Letter from R.C. Niles,  Uniroyal,  to J.R. Farmer, CPB/ESED/OAQPS/EPA.
     May  12, 1980.  Response  to Section 114 follow-on letter.
24.  Letter from J.R. Laman,  Firestone, to D.R. Goodwin, ESED/OAQPS/EPA.
     April  17, 1980.  Response  to Section  114 follow-on  letter.
25.  Letter from R.R. Clark,  B.F. Goodrich, to D.R.  Goodwin,  ESED/OAQPS/EPA.
     April  16, 1980.  Response  to Section  114 follow-on  letter.
26.  Aus, B.   Meeting Memorandum:  Tire Industry/EPA/PES Meeting on
     NSPS Draft BID,  Chapters 2 through 5  [3 through 6].  February  25,
     1980.
27.  1979 Tire Industry  Facts.  Modern  Tire Dealer.  6^(2):25-33.
     January 1980.
28.  A Tire Industry  Analysis:  MTD's  13th  Annual  Facts/Directory
     Issue.  Modern Tire Dealer.  60(7):25-50.  January  1979.
29.  Outlook 1976.   Rubber World.  T73J4):23-29.   January  1976.
                                   3-37
-------
30.  Mohawk Rubber Closes Akron Operations.  Rubber World.  179_(3):19
     December 1978.

31.  Firestone to Double Truck Tire Facility.  Rubber World, 178(5):16.
     August 1978.

32.  Durham Morning Herald, August 1979.   p. 15A.

33.  The Wall Street Journal, January 23,  1980.  p.  10.

34.  The Wall Street Journal, March 20,  1980.  p.  10.
                                                          i
35.  Modern Tire Dealer. February  1978.  p.  16.

36  Letter from F.M.  Luysterborghs, Armstrong Rubber  Company,  to  J.R.
     Farmer, CPB/ESED/OAQPS/EPA.   January  21,  1980.  Comments  on draft
     Background  Information Document Chapters  2  through  5 (3 through 6).

37.  Letter from R.R.  Clark,  The B.F.  Goodrich Company,  to J.R.  Farmer,
     CPB/ESED/OAQPS/EPA.   February 12,  1980.   Comments on draft Background
     Information Document  Chapters 2 through 5 (3 through 6).

38.  Juhola, A.J.   Package Sorption Device System Study. , U.S. Environmental
     Protection  Agency.  Research  Triangle Park, N.C.   Publication
     No.  EPA-RZ-73-202.  April  1973.   576 p.

39.  The Industrial Environment -  Its  Evaluation and Control.   U.S.
     Department  of Health, Education,  and Welfare.  Public Health
     Service.   Center for  Disease  Control.  National Institute for
     Occupational  Safety and  Health.   Washington, D.C.  1973.

 40  McDermott,  H.J.  Handbook of Ventilation for Contaminant Control.
     Ann Arbor Science Publishers, Incorporated.  Ann Arbor, Michigan.
      1976.  368 p.

 41   Letter from E.J. Burkett, Goodyear Tire and Rubber Company, to
      K.J. Zobel, EPA.  May 14, 1979.  Information on pollution control
      facilities at the new Goodyear plant  in Lawton, Oklahoma.

 42.  Development Document for Effluent  Limitation Guidelines and New
      Source Performance Standards for the  Tirce  and  Synthetic Segment
      of the Rubber Processing Point Source Category.  Publication  No.
      EPA-440/l-74-013a.   U.S. Environmental Protection  Agency.
      Washington, D.C.  1974.  193 p.

 43   Rappaport, S.M.  The Identification  of Effluents from Rubber
      Vulcanization.   Paper presented at the Conference  on  Environmental
      Aspects of Chemical  Use in Rubber  Processing,  Akron*,  Ohio.   March
      12-14, 1975.

 44.  Telecon.   Rinaldi, G.M., Monsanto  Research Corporation with  Aus,
      B.M., Pacific Environmental  Services, Inc.,  July 9, 1979.  Calculation
      of  temperature-weight loss correlation.
                                    3-38
-------
45.  McAdams, M.T.  Trip Report:  Firestone Tire and Rubber Company,
     Wilson, N.C.  September 13, 1979.

46.  McAdams, M.T.  Trip Report:  Armstrong Rubber Company, West
     Haven, Conn.  September 5, 1979.

47.  Kalika, P.W., Report to Armstrong Rubber Company on Tests for
     Solvent Evaporation and Emission Rates at the West Haven, Conn.
     Plant.  TRC Project No. 31243.  May 2, 1973.

48.  Ringquist, D.E., Volatile Organic Compound Emission Measurements
     for Tread End Cementing and Bead Dipping Operations at a Tire
     Manufacturing Plant.  Armstrong Rubber Company, West Haven,  Conn.
     U.S. Environmental Protection Agency.  EMB Report No. 79-RBM-6.
     June 1980.

49.  Ringquist, D.E., Volatile Organic Compound Emission Measurements
     for Tread End Cementing and Bead Cementing at a Tire Manufacturing
     Plant, Kelly-Springfield Tire Company, Fayetteville, North  Carolina.
     U.S. Environmental Protection Agency.  EMB Report No. 79-RBM-7.
     March  1980.

50.  Chi, C.T., T.W. Hughes, T.E. Ctvrtnicek, D.A. Horn, and R.W.
     Serth.  Source Assessment:  Rubber  Processing, State-of-the-Art.
     Publication No. EPA-600/2-78-004J.  U.S. Environmental Protection
     Agency. Cincinnati, Ohio.  1978.  133 pp.

51.  Letter from R.C. Niles, Uniroyal, Inc.,  to J.R. Farmer, CPB/ESED/
     QAQPS/EPA.  January 18, 1980.  Comments on draft Background  Information
     Document  Chapters  2 through 5  (3  through 6).

52.  Rubber and  Plastics News.  February 20,  1978.  p.  2.

53.  Modern Plastics.   September 1978.   p.  70-71.

54.  Modern Plastics  International.   October  1978.  p.  58-59.

55.  Telecon.   Nelson,  G.,  Dow Corning Corporation, with  Rinaldi,
     G.M.,  Monsanto Research Corporation.   August 22,  1978.   Composition
     of water-based sprays  used by  the tire  industry.
                         4
56.  Telecon.   Raleigh, W.  and A. Wotiz, General  Electric Company,
     with  Rinaldi,  G.M., Monsanto  Research  Corporation.   August 22,
      1978.   Composition of  water-based sprays used by  the tire industry.

57.  Telecon.   Wittekind, R.,  SWS  Silicones  Corporation,  with  Rinaldi,
     G.M.,  Monsanto Research Corporation.   August 22,  1978.   Composition
     of water-based sprays  used by  the tire industry.

 58.  Letter from Brooks,  H.L., SWS  Silicones  Corporation,  to Zobel,
      K.J.,  EPA.   July 3,  1979.  Comments on proposed  Guidance Document
      for the Group  II  Control  Techniques Guidelines for Volatile
     Organic Compounds.
                                   3-39
-------
59   Telecon   Brewer, R.M.  The C.P. Hall Company, with Aus, B.,
     Selfic Environmental Services, Inc.  September 29, 1980.  Composition
     of water based sprays used by the tire industry.

60.  Letter from R. Brewer, The C.P. Hall Company Jo B  Ag. Pacific
     Environmental Services, Incorporated.  October 3, 198U.  water
     based green tire spray composition  and use.

61   Telecon.  Thimineur,  R., General Electric Company, with
     McAdams, M.T., Pacific Environmental Services,  Incorporated.
     December 20,  1979.   Use of water-based green  tire sprays by the
     .tire industry.

62.  Telecon.  Martin,  D., Dow  Corning  Corporation,  with McAdams,  M.T.,
     Pacific Environmental Services,  Incorporated.   December 28,  1979.
     Use  of water-based green tire sprays by  the tire  industry.

63  Telecon.  Slinger, O.L., Harwick Chemical  Company, with
     McAdaSs  M.T.,  Pacific  Environmental Services,.Incorporated
     December 20,  1979.  Use  of water-based green tire sprays by the
     tire industry..                                       :

 64.  Telecon.  Wittekind, R.,  SWS Silicones Corporation,  with
     McAdams, M.T.,  Pacific Environmental Services,  Incorporated.
      December 19, i979.  Use of water-based green tire sprays by the
      tire industry.

 65.   Telecon.   Reynard, K., SWS Silicones Corp.,with McAdams, T  ,
      Pacific Environmental Services, Inc.  December 27, 1979.  uomposi-
      tion and Use of Water-Based Green Tire Sprays.       ,

 66   Telecon.  Brooks, H., SWS Silicones Corp., with Kent, D., Pacific
      Environmental Services, Inc., September 11,  1980.  Composition  and
      Use of Water-Based  Green Tire Sprays.

 67   Telecon.  Martin, D., Dow Corning  Corp., with  Kent,  D., Pacific
      Environmental Services, Inc.  September 11,  1980.  Composition
      and Use of Water-Based Green Tire  Sprays.

  68.  Telecon.  Slinger,  J., Harwick  Chemical Corp., with  Kent,  D  .
      Pacific Environmental Services,  Inc.   September  18,  1980.   Compo-
      sition and  Use  of Water-Based  Green Tire  Sprays.

  69   Telecon.  Corbin, J.,  Nalco Chemical  Co.,  with Aus,  B., Pacific
      Environmental  Services,  Inc.  October 1,  1980.  Composition and
      Use of Water-Based Green  Tire Sprays.

  70.  Zobel,  K.O., and N. Efird.   Control of Volatile Organic Emissions
      from Manufacture of Pneumatic Rubber  Tires.  U.S. Environmental
       Protection  Agency.  Research Triangle Park, N.C.  Publication
       No. EPA-450/2-78r030.   December 1978.  59 p.        ,
                                    3-40
-------
71.  Memorandum from Hawkins, D.G., ANR443, EPA, to Regional Administrator,
     EPA, Regions I-X.  June 15, 1979.  Impact of Clean Air Act Nonattain-
     ment Sanctions.

72.  Blum, Barbara. Failure to Meet July 1 SIP Deadline Will Not Cause
     Disruptions, Blum Says.  Environment Reporter.  Current Developments.
     p. 225.  Washington, D.C.  The Bureau of National Affairs, Inc.
     June 29, 1979.

73.  Aus, B.  Meeting Memorandum:  EPA/PES Discussion on Draft BID
     Section 2.3 [3.3].  February  19,  1980.

74.  United States  Congress.  Occupational Safety and Health Act of
     1970.  PL 91-596, Statute 2193.   Washington, D.C.  U.S. Government
     Printing Office.  December 1970.

75.  U.S. Department  of Labor.  Code  of Federal  Regulations.  Title
     29,  Chapter 17,  Part 1910.1000.   Washington, D.C.  Office of  the
     Federal Register.  July  1, 1978.

76.  Occupational  Health Studies  Group.  Occupational Health Studies.
     University  of North Carolina, School  of Public Health.  Chapel
     Hill,  N.C.  September  1978.   15  p.
                                   3-41
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                   4,0  EMISSION CONTROL TECHNIQUES

     This chapter identifies air pollution control technology  that  is
available for reducing volatile organic compound  (VOC) emissions  from
the following operations:
     (1)  undertread cementing;
     (2)  sidewall cementing;
     (3)  tread end cementing;
     (4)  bead cementing;
     (5)  green tire spraying.
Emission points for undertread and sidewall cementing operations  are
the cement application area and drying area conveyor.  Automatic  and
manual tread end cementing emission points are the cement  application
area, the attendant drying area conveyor, and temporary  storage area.
VOC-emitting portions of bead cementing and green tire spraying operations
include cement or solvent application areas and temporary  component
storage sites.  Emissions from these tire manufacturing  operations
represent approximately 85 percent of VOCs emitted from  rubber tire
                     1-25
manufacturing plants.                                                   '•
     Although conventional tire building, as defined in  Section 3.2.3.1,
is a major VOC-emitting activity accounting for approximately  11  percent
of total plant emissions, it will not be further  considered  in this
document.  Exhaust gas flow rates provided by general ventilation of
the tire building work area are high (3.3 to 10.6 m /sec/unit  [7,000 to
22,500 scfm/unit]) and contain low VOC concentrations (0.01  to 0.32 g/m
[0.6 x 10"6 to 20.0 x 10"6 Ib/ft3]).1"14  Consequently,  treatment of
the conventional tire building exhaust stream is difficult.  Technology
for VOC emission reduction systems which utilizes both a capture
component and a control component is available, but the  cost of
                                  4-1
-------
transferring this technology to conventional tire building, based upon
the designs considered, has been determined to be very high [$98,000
to $306,000 per Mg ($90,000 to $280,000 per ton) of VOC emissions
reduced] relative to the cost of regulating other facilities.    Tire
finishing will not be considered for regulation for similar reasons:
organic solvent is only used in small quantities and in open areas,
resulting in very low, widely dispersed VOC emissions.
     Compounding, milling, extrusion, calendering, curing, and finishing
are not addressed in this chapter as emissions from these  points are
estimated to contribute about 3 percent to a tire plant's  total VOC
emissions.1"25  Latex dipping will  not be considered for control as
the process is more frequently performed in textile mills
(Section 3.2.2.2).
4.1  FACTORS AFFECTING EMISSION CONTROL TECHNIQUES
     Methods of meeting Occupational Safety and  Health  Administration
(OSHA) employee exposure  limits for solvents used  in the five  operations
include:
     (1)   dilution of  air containing solvents  with  air  from  the  outside
atmosphere;
     (2)   containment  and removal  of solvents  at their  emission  point;
     (3)   elimination  or  reduction  of  solvent  use.
     In  order  to  meet  fire safety codes,  organic vapor  concentrations
in tire  plant  ventilation systems are  diluted  and maintained below
25 percent of  the Lower  Explosive Limit (LEL).27  Occupational Safety
and Health Administration employee exposure limits for  various rubber
industry related  chemical compounds require maintenance of lower work
area VOC concentrations  than those required under fire  safety codes.
Therefore, large  volumes of air may need to be drawn off the affected
work area in order to  facilitate compliance with OSHA limits.   Employee
exposure limits for solvents used in the rubber industry as of July 1,
 1978,  were presented in Tables 3-4 and 3-10.
     Whether due to safety or operational  factors, low VOC concentrations
 (in the range of 60 to 1,600 ppm) in an activity's exhaust stream
 limit  the type of equipment that may be used for emission control.
 Since  VOC pollutants are in the vapor state, particulate control
                                   4-2
-------
devices, such as mechanical separators, filters, and electrostatic
                              28                                     '
precipitators, cannot be used.    Absorption techniques may be used
for VOC control,27'29 but in operation these techniques prove deficient
as they cannot satisfactorily treat low VOC concentrations without
long contact times and large quantities of absorbant.  '    Conden-
sation is difficult for multiple component gas streams and is
especially difficult where concentrations are below 25 percent of the
LEU32  Further, the low temperatures required for condensing some
                                  32
VOCs would make costs prohibitive.    Incineration of vapors via
flaring is precluded, as the waste gas lacks sufficient heating value
for combustion.  Incineration may be accomplished using afterburners,
which are designed to treat exhaust streams with low VOC concentra-
tions.  Adsorption systems can also be designed to control diluted VOC
          :      07 OQ on
exhaust streams//»^>JU
4.2  VOC EMISSION CONTROL TECHNIQUES AVAILABLE TO THE TIRE MANUFACTURING
     INDUSTRY
     Three general methods of VOC emission  reduction are available to
the  rubber tire manufacturing industry:
      (1)  emission reduction  sytems  (capture and control);
      (2)  low  solvent consumption cement  application techniques;
      (3)  low  VOC content  materials.
     The  tire  manufacturing  industry  presently  employs means  of general
ventilation  and vapor capture for the  purpose of  reducing  VOC vapor
concentrations below OSHA  Employee  Exposure Limits  and  25  percent of
the LEL.  General ventilation (dilution  ventilation) employs  numerous
exhaust fans to move large volumes  of air,  thereby  diluting  the con-
centration  of contaminants released in the  workroom to  acceptable OSHA
employee exposure levels.33  Consequently,  exhaust  streams from  solvent
application facilities  exit the ventilation system  at  flow rates  that
are too high to be  treated by conventional  packaged air pollution
                 1-14
control  systems.
      In order to reduce the amount  of air to be treated,  capture  systems
may be installed on individual  tire manufacturing facilities to isolate
                                   4-3
-------
and remove VOCs emitted, thereby reducing the volume of air needed to
be treated.  Approximately 40 percent of the VOC emission points
reported by tire manufacturers are hooded.  These hoods function to
reduce VOC concentrations below OSHA employee exposure limits.
     In two plants, enclosures surrounding undertread cement .application
and cement drying areas are vented to carbon adsorbers:  one system  is
a retrofit, the other is part of the original equipment design. "  '
For the purposes of this document, an exhaust gas capture or containment
system used in conjunction with a VOC emission control device  is
referred to as a VOC emission reduction system.
     Due to the small number of VOC emission control devices employed
by the tire industry, VOC controls used by industries producing other
rubber products [Standard Industrial Classification  (SIC) Group 30]
were examined:  Incineration has been employed for VOC emission control
in the rubber hose industry.35"37  Hence, incineration and vapor
adsorption are general exhaust gas treatment techniques which  may  be
used by the tire manufacturing'industry to control VOC emissions.
     An alternate strategy may be .to reduce the  amount of organic
solvent used by the facility through increasing  the  efficiency of
cement or green tire spray application, or by employing cement
application methods which minimize cement use.   Another strategy for
the reduction of organic vapor emissions is the  use  of cements and
solvents which have low VOC contents.  VOC emission  reduction  techniques
are discussed in the following subsections.
4.2.1  Incineration of VOCs
     Incineration  is a technique used  for the control of  VOC emissions
by oxidizing the organic vapors into harmless products, such as  carbon
dioxide and water.  As a result of OSHA employee exposure  limits for
organic vapors and fire safety consideration, VOC concentrations  in
the exhaust gases  from solvent application facilities are  low:  VOC
concentrations in  the workplace due to OSHA  regulations in many  cases
are below  100 ppm; fire safety codes would dictate that VOC  concentra-
tions  be maintained below  25  percent of the  LEL.   Hence,  fuel  must be
added  to the diluted vapor before  it can  be  incinerated.  ;Devices
                                   4-4
-------
which add fuel to the diluted vapors and  incinerate  the  combined
stream are referred to as afterburners.   Two types of afterburners may
be used:  direct flame and catalytic.
     4.2.1.1  Direct Flame Afterburners.  Direct flame afterburners
use an open fire to oxidize VOC emissions.  Secondary disposal  problems
                            38
are not usually encountered.    VOC control efficiencies of  new direct
flame afterburners are above 98 percent.       The efficiency of  a
direct flame afterburner is affected by the types of VOCs  to be
incinerated, temperature, residence time, mixing, inlet  concentration,
and flow pattern.  Incineration temperatures range from  455° to 980°C
(850° to 1800°F); the precise temperature is a function  of the  vapor
residence time (0.3 to 1.8 seconds), mixing chamber  turbulence, effluent
type, and afterburner design.  *   '       The exhaust stream may  be
directly incinerated by one of two general methods:  either  b;  passing
exhaust gas through a burning fuel-gas jet; or by mixing a portion of
the exhaust with raw gas and igniting the mixture, which heats  the
remaining portion of the exhaust stream to ignition  temperature.  The
second method, premixing, generally uses  20 to 30 percent  less  fuel
                                  41
than the direct combustion method.    Figure 4-1 illustrates the
design and operation of the two typical burner arrangements  of  direct
flame afterburners.
     Typical design flow rates for direct-flame afterburner  packages
range from 0.1 to 23.6 m3/s/unit at 21°C  (250 to 50,000  scfm/unit),
though custom-built units, capable of handling larger flow rates, are
          45 46
available.  '    Industry-supplied data indicate that exhaust flow
rates from the solvent application facilities under  consideration
range from 0.1 to 29.3 m3/s/unit at 21°C  (210 to 62,080  scfm/unit).1"25
Thus direct flame afterburners can be used to control VOCs in the
exhaust gas streams of rubber tire manufacturing facilities.
     Several disadvantages can be identified in the  use  of direct
flame afterburners:  consumption of fuel when no VOCs are  present,
nitrogen oxide emissions, and emission of incomplete combustion products.
     Direct flame afterburners require continuous fuel burning, although
periodically, VOCs may not be present in the exhaust stream.  Fuel
                                  4-5
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                             ft
                                   GAS
                                   JL
                   FUME INLET
                  CONNECTION
     ADJUSTABLE
      CONTROL
      LOUVERS
         GAS
      CONNECTION
REMOVABLE
  PILOT
 ASSEMBLY
                                   PATH OF FUME FLOW (FUME ITSELF IS
                                   USED AS SOURCE OF BURNER COMBUSTION
                                   OXYGEN, ELIMINATING NEED FOR OUTSIDE
                                   AIR ADMISSION AND INCREASED Blu LOAD.)
                                                       r
                                                      r
                                                  .	I
                                                                  INCINERATION
                                                                    CHAMBER
     FUME INLET PLENUM
                     J
                                                        I
                                                    _ J
                                                        1	; _	
                                          REFRACTORY-LINED
                                           IGNITION CHAMBER .
                                          B
        A.  Raw gas burner and multiple jet grid.
        B.  Multijet burner with exhaust gas preheater.
                                                                           32 38 57
Figure 4-1.  Typical Burner Arrangements Used in Direct Flame Afterburners  '  *
                                         4-6
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 requirements for direct flame afterburners are highest at 0 percent
 of the LEL and decrease as the VOC concentrations in the exhaust
 stream increase.    Therefore, whenever the exhaust stream contains no
 VOCs, fuel is wasted.27»28,32,38,41,43,51
      Nitrogen oxide (NQX) emissions in the afterburner exhaust may
 contribute to air pollution problems.  Two potential sources of nitro-
 gen can be identified:   fuel-bound nitrogen and thermal fixation of
 nitrogen from the atmosphere.   Residual fuel  oil  is rich in fuel-bound
 nitrogen and can contribute to greater than half of all NO  being
 emitted from a source.5   If the afterburners employ natural  gas or
 distillate fuel  oil  for combustion, thermal nitrogen fixation is a
 problem.   '    Thermal  fixation of nitrogen from the atmosphere is a
 function of the temperature in the combustion chamber and available
 oxygen.     Consequently,  NO  emissions in the exhaust increase as
 i        '                   A               '                      .  ,
 incineration temperatures and  oxidation efficiencies increase.27'39*52
 Further,  emission levels  vary  considerably with  the type of unit used
 and the extent of loading.     Several  combustion  modifications can be
 employed  for NO  emission reduction:
                ^
      (1)   limited excess  air firing can reduce N0x  emissions  by 5 to
 30  percent,
and
(2)  staged combustion can reduce NOX emissions by 20 to 45 percent,

(3)  flue gas recirculation can reduce NO  emissions by 10 to
                                         A
45 percent.
A more in-depth discussion of NOX emission control  techniques  can  be
found in U.S. EPA's publication, Control Techniques  for Nitrogen
Oxide Emissions from Stationary Sources.52
     Incomplete combustion of VOCs in the exhaust gases may create a
larger nuisance than the original substance:  incompletely combusted
VOCs may be more potent smog precursors than the VOCs in the exhaust
stream; sulfur and halogens in exhaust gases can create problems by
the production of sulfur oxides and acid gases.27  It is recommended
that low-sulfur fuels, such as natural gas, distillate oil, low-sulfur
residual  oil or desulfurized oil, be used as afterburner fuel, although
it is recognized that the availability of these resources is limited.53
                                  4-7
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     4.2.1.2  Catalytic After-Burners.  The design of catalytic afterburners
is similar to direct flame types.  The major difference between the
types of incineration is that catalytic afterburners employ a solid,
active surface on which the combustion reaction takes place.  Exhaust
gas is incinerated as it passes through a heated (200° to 650°C)
catalyst; usually a noble metal, such as platinum or palladium, sus-
pendecl 1n a honeycomb fasMon.28,37,38,43,45,50,54,55,56  F,gure w
presents the general design and operation of a catalytic afterburner.
     Catalytic afterburners are reported to have VOC control efficiencies
between 81 and 96 percent.37'3-?'43'56'57'58  Efficiency of vapor incine-
ration is associated with the afterburner temperature, which is in
turn dependent on the vapor's ignition temperature, afterburner space
velocity, and catalyst type.  Typical design flow rates for catalytic
afterburners range from approximately 0.2 to 18.9 m /s at 21°C  (420 to
40,050 scfm).32'55'56  Industry-supplied data show exhaust flow rates
from VOC-emitting facilities to range from approximately 0.1 to
29.3 m3/s/unit at 21°C (210 to 62,080 scfm/unit). "    Therefore,
catalytic afterburners have the potential to be employed as a VOC
control component for the reduction  of VOCs from rubber tire
manufacturing.
     Usually catalytic afterburners  consume 40 to 60 percent less  fuel
than direct flame types, as the catalyst requires lower temperatures
to bring the vapor and fuel mixture  to its ignition point.    Catalytic
afterburner fuel use is constant from 0 to 15 percent of the LEL;  at
                                                       43
25 percent of the LEL, fuel requirements drop slightly.    However, as
with direct flame afterburners,  fuel is wasted as it is burned  during
periods when no  VOCs are emitted.
     Maintenance of catalytic afterburners is frequent.  Some VOC
mixtures cannot  be  properly incinerated, allowing particulates  to  foul
or deactivate the catalyst.27'29'38'55  High  temperatures  are known  to
shorten the catalyst life, thus  limiting the  VOC concentrations that
may  be  treated by catalytic afterburners to 25 percent or  less  of
the  LEL.43  Further, gas streams containing sulfur,  silicon,  tin,
phosphorus, halogens,  or heavy metals  are  known  to  poison  platinum and
palladium-type catalysts,  thereby  allowing the gas  stream  to  pass
                                   4-8
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                         CATALYST
                         ELEMENTS
                                               CLEAN, HOT
                                                 GASES
                                                            OVEN
                                                            FUMES
                                                        PREHEATER
Figure 4-2.  Schematic Diagram  of j. Catalytic Burner Using a. Torch-Type
  Preheater.  In Order to Promote Mixing,  Flow of She Preheated Waste
                    Stream is Pulled through  a Fan5!
                                      4-9
-------
                                                                  27 32 41 45
untreated through the catalyst and become an environmental hazard.  *   *  •
Consequently, quality of fuel used by the catalytic afterburner  is  of
importance.
     4.2.1.3  Heat Recovery.  Heat recovery offers a way to  reduce  the
energy consumption of incinerators.  The simplest method, primary heat
recovery, uses the hot cleaned gases exiting the incinerator to  preheat
the cooler incoming gases.  Depending on the design, primary heat
                                                                 50  56 57
recovery efficiencies range from 35 to 90 percent of heat input.  »  *
Secondary heat recovery employs incinerator exhaust from the primary
heat recovery stage (or directly from the incinerator  if there  is no
primary heat recovery) to replace energy usage  elsewhere  in  the  plant.
Usual efficiencies for secondary heat recovery  units are 70  to  80 percent
of heat input, though circumstances in the plant may affect  these
values.32*43  There is little use for secondary heat recovery in
tire manufacturing plants.
4.2.2  Adsorption of VOCs
     As an alternative to incineration,  organic vapors may  be collected
on external  surfaces of a solid adsorbant.   Commonly used  adsorbants
for vapor  collection are  activated  alumina,  silica  gel, and  activated
carbon.  Activated carbon is widely applied  to  organic vapor collection,
                                            27  38
due to its affinity for nonpolar  compounds.   '    Adsorption equipment
collects VOCs by passing  exhaust  stream  vapors  through either fixed,
moving, or fluidized beds containing  activated  carbon.  The simplest
adsorption equipment design is  a  vertical  cylinder  containing a fixed
adsorbant  bed sandwiched  between  screens.   A moving bed configuration
passes activated carbon  through an  adsorption  zone.   In fluidized  bed
adsorbers, vapors are  forced upward through a  stack of beds or trays,
thus  imparting  a fluid appearance to  the adsorbant.   Fresh  adsorbant
is  fed onto  the tray  furthest from the vapor stream inlet,  flows
across the bed,  over  a weir, and  drops to the  tray directly beneath.
The same  procedure occurs with each tray in the stack.  The effect of
a fluidized  bed configuration is  that the VOC load in the adsorbant
increases  as the adsorbant  progresses down the tray stack.  Figure 4-3
 illustrates  the three different methods for organic vapor adsorption.
                                    4-10
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VAPOR-LADEN
  AIR  IN
                                             CARBON
                            IN
                              CYLINDRICAL
                             SHELL HOUSING
                                  VAPOR-FREE
                                    AIR OUT
                                                            VAPOR-FREE AIR
f
ABSORBANT
   ZONE
t
VAPOk-LADEN AIR
                                                               B
                                                  VAPOR-FREE AIR
     A.  Fixed adsorbant bed.
     B.  Moving adsorbant bed.
     C.  Fluidized adsorbant bed.
                                                                       FRESH CARBON
                                                                        DISPENSER
                                                                      SPENT CARBON
                                                                        COLLECTOR
                                                          VAPOR-LADEN AIR

             Figure 4-3.  Three Carbon Adsorption Methods27,32,65-67
                                        4-11
-------
     Fixed bed carbon absorbers are reported to be able to continuously
reduce VOC emissions by 95 percent; peak emission reduction efficiencies
of 99 percent have also been reported.41'59"63  Carbon absorbers are
capable of treating organic vapor concentrations that are less ithan
100 ppm.27'63"68  Control efficiencies are a function of vapor-activated
carbon surface contact area (including bed depth, width, configuration)
and humidity in the vapor stream.  Fixed bed, cone-shaped, and vertical
adsorbers allow more surface contact area for organic vapors than flat
bed adsorbers:  This enables cone-shaped units to accommodate higher
air flows and lower pressure drops than would be experienced in a flat
bed using the same total weight of adsorbant.  Moving beds may use the
same amount of activated carbon as fixed beds but may have higher
control efficiencies due to fresh adsorbant being continually introduced
into the adsorbing zone.  The effective lifetime of moving bed adsorbers
can be shorter due to wear on moving parts, more rapid attrition of
adsorbant, and higher steam requirements for desorption due to shorter
carbon beds.58  Fluidized-bed absorbers can tolerate high VOC loading,
require less steam for desorption, and may avoid channeling problems
                              '           38 51
occasionally encountered with fixed beds.  •    Humidity can adversely
affect carbon adsorption collection efficiency when the moisture
                                                 32 33
content of the exhaust stream exceeds 50 percent.   '   '
     Adsorber units allow for either treatment or disposal of used
adsorbant material.  Units which  facilitate adsorbant  treatment  (desorp-
tion) are classified as  regenerative systems.  Spent adsorbant  is
reactivated by removing  adsorbed  VOCs via  steaming.  The desorbed VOCs
are recovered by  distillation or  water treatment equipment, either  for
                                   CO
reuse or disposal  by incineration.    Adsorption units which do  not
reuse spent adsorbant are non-regenerative systems.  Spent adsorbant
may be shipped out for  regeneration or  incineration.   For a continuous,
regenerative, fixed bed  adsorption  system, at  least two  adsorption
tanks are needed.   If the time  for regeneration  and cooling  is  longer
than the adsorption time, three beds may  be  used:   one bed adsorbing,
                                CQ
one desorbing, and one  cooling.     When  the  adsorbing  bed  reaches  the
point where higher boiling  point vapors  displace compounds with lower
                                   4-12
-------
boiling points, the bed which  has  been  desorbed  and  cooled  is  put on
stream, and the VOC-laden adsorbant  is  steamed.   In  cases of  solvents
with high boiling points, superheated steam may  be required for
           38 R8
desorption.  '    After desorption,  the activated carbon must  be
adequately cooled before it can again be placed  on stream:  Contact of
VOCs with the heated bed may cause partial decomposition of the vapor,
                                                           38
releasing odorous and irritating gases  into the  atmosphere.
     Carbon adsorbers have an  advantage over  afterburners since they
can remove low VOC concentrations  (less than  100 ppm)  from exhaust
streams, even in the presence  of water  vapor.  '*       However,
under conditions of low VOC concentrations, carbon adsorption  effi-
ciencies decline.  Unlike afterburners,  VOCs  that are  adsorbed may be
recovered from desorption steam and  reused.
     There are, however, certain disadvantages associated wit  carbon
adsorbers.  Any particulate matter in the exhaust stream may plug the
carbon beds, lowering their VOC collection efficiencies.  Also,  the
required depth of a carbon bed-increases with the number of compounds
                      51
in the exhaust stream.    Thus, even if the VOC  concentrations in two
exhaust streams are similar, the carbon bed depths required may  be
very different if one exhaust  stream contains several  compounds  while
the other contains only one.   Further,  VOCs are  adsorbed in an inverse
relation to compound volatilities, with  highly volatile compounds
               30
adsorbed first.    As a result, the composition  of reclaimed materials
may differ greatly from the virgin material,  possibly  precluding  its
reuse in a tire manufacturing  activity.
     Typical design flow rates for carbon adsorption package units
range from less than 0.05 m3/s to  37.76  m3/s  at  21°C (100 scfm to
80,000 scfm).58'65"68  Exhaust flow rate data from the tire industry
indicate a potential for application of  carbon adsorption to VOC
emission points, as flow rates range from approximately 0.1 to
29.3 m3/s/unit at 21°C (210 to 62,000 scfm/unit).1"14  One retrofit
carbon adsorber is currently employed on  the undertread cementing line
at one tire manufacturing plant.  Tests  performed on this carbon
adsorber indicate that the device has an  average continuous VOC  removal
efficiency of 90 to 95 percent;63 factors constraining higher  removal
                                  4-13
-------
efficiencies are outlined in Section 4.3.1.  Further, carbon adsorbers
used to control VOC emissions from other rubber products and pressure
sensitive tapes/labels manufacturing have been reported to have continuous
control efficiencies of at least 95 percent.
4.2.3  Low Solvent Consumption Cement Application Activities
     An alternative to the use of add-on emission reduction systems  is
to increase the effectiveness of cement or solvent application to the
rubber component, thereby reducing the amount of cement or solvent
used.  Consequently, VOC emissions are lower than similar, less effective
application operations.  Industry-supplied information indicates that
at least one tread end cementing operation and one bead cementing
operation from each reporting company consumes such low amounts of
cement that VOC emissions are equal to or less than 10 grams per
     i ?R
tire.      These low solvent consuming cement application activities
are further discussed in Sections 4.3.3 and 4.3.4.
4.2.4  Low VOC Content Materials
     An alternative strategy for reducing VOC emissions is to substitute
lower VOC content materials for materials with higher VOC contents.
Water-based inside and outside green tire sprays are currently the
only well developed low-VOC content materials available to the tire
                       1 25
manufacturing  industry.      Overall emission reductions resulting
from tire application of inside and outside water-based green tire
sprays range approximately 90 to 100 percent of the average organic
solvent-based  emission factors for inside and outside green tire
sprays      ; the extent of the emission reduction  is dependent on the
VOC content of the sprays used and the amounts applied.  Further
discussion of  water-based green tire sprays is included in Section 3.2.4.
4.3  APPLICATIONS OF VOC EMISSION REDUCTION TECHNOLOGY
4.3.1  VOC Emission Reduction Systems for Undertread Cementing
     Carbon adsorption is the only type of VOC control component
currently used in the  tire manufacturing industry.  A dual bed carbon
adsorber is part of a  retrofit VOC emission reduction system at one
plant's undertread cementing operation; the system was  installed  in
order  to help  the plant meet State regulations.    A second plant,
which  recently began production, has an enclosure  and carbon adsorption
                                   4-14
-------
unit incorporated into the original equipment of the undertread cementing
line design.34  The retrofit VOC emission reduction system consists  of
a 2.6 m3/sec at 21°C (5500 scfm) enclosure connected to a standard
                         4Q
dual-bed carbon adsorber;   the adsorber could be interchanged with  a
                                      68
direct flame or catalytic incinerator.    The retrofit enclosure, as
depicted in Figure 4-4, was designed to maintain VOC vapors at a
concentration less than 25 percent of the LEL, while capturing solvent
that evaporates from the cement applicator assembly and cemented tread
stock.  '    This enclosure design can only be applied in cases where
                                              33
workers are not exposed to the organic vapors.
     Pertinent design considerations for the retrofit emission reduction
system or any new undertread cementing VOC emission reduction system
include:
     (1)  maintenance of OSHA employee exposure limits where workers
are exposed to organic vapors and maintenance of VOC concentrations  at
25 percent or less of the LEL where workers are not exposed;
     (2)  operator accessibility to areas within the enclosure for
tread changes and scheduled maintenance;
     (3)  sufficient tread residence time in the enclosed conveyor to
ensure solvent capture during drying.
     The capture system can be constructed to enclose the undertread
cement tank/application area and some or all of the conveyors leading
away from the undertread cementing station.  The enclosure requirements
Vary depending on the amount of VOC that is previously captured  in the
tank/application area, the speed of the conveyor, the rate of organic
solvent evaporation, and the amount of solvent that is absorbed  in the
rubber.  In practice, information on the rate of organic solvent
evaporation could be used to determine the point on the conveyor where
the concentration of VOCs in the ambient air would be so low that
additional enclosure would not be practical for capturing these  VOCs.
     Tests performed to determine the capture efficiency of the
retrofitted undertread cement tank/application area enclosure and  the
attendant drying area enclosure have yielded mostly inconclusive
results.  However, in one case, long-term materials balance measure-
ments provided by the owner show that the retrofit capture and control
                                   4-15
-------
       CEMENT APPLICATOR
           ENCLOSURE
   DOORS FOR
OPERATOR ACCESS
                                TO ADSORPTION
                                    SYSTEM
TO ADSORPTION
   SYSTEM
                                                      CONVEYOR
                                                      ENCLOSURE
                                                                       PATH  OF TREAD
                                             (V       ^-v^
                                                     -PATH OF TREAD
        Figure 4-4.  Ventilation  Enclosure for an Undertread or Sidewall
                          Cementing  Operation*
                                   4-16
-------
 systems achieved an overall emission reduction efficiency of about
 63 percent.    Source testing of the retrofit carbon adsorber servicing
 the undertread cementing capture component shows the control component
 to have an average VOC control efficiency of 90 to 95 percent.63  Thus
 the quotient of the overall emission reduction efficiency and the
 carbon adsorber efficiency yields a crude capture efficiency between
 66 and 70 percent.   The tire company believed that the following
 factors limited the degree of VOC emission reduction efficiency:
      (1)  Approximately 8 percent of VOC applied to rubber component
 is absorbed by the  rubber and is not immediately available for capture
 (emissions from cemented rubber account for about 30 percent of total
 VOC emissions from  this line, thus, about 2.4 percent of VOC used is
 absorbed);
      (2)  Enclosure system access doors are open for a finite time
 span for periodic threading of new tread sizes;  and
      (3)  Length of the drying area conveyor and enclosure is limited
 by the configuration  of existing extrusion equipment;
      (4)  The switching damper installed for enclosure emergency
 situations is not equipped  with  vapor loss seals,  thereby allowing a
 negative pressure to  exist  on both  sides of the  damper;
      (5)  Operating practices do not provide  for containment of  VOC
 emissions  during weekend  shutdown,  either by  draining cement tanks or
 by equipping  tanks with  tight fitting covers;
      (6)  Operating practices  do  not provide  for air  drying  and  cooling
 of the  desorbed carbon  bed  prior  to  the next  adsorption cycle;
      (7)  The company can not account for vapor  losses from  cement
 mixing  churns, recirculating  cement  distribution system storage  tanks,
 recovered  solvent storage tanks,  pumping,  and venting from decanter.85
 EPA analysis  indicates that the design  of  the retrofit VOC emission
 reduction  system can be improved, thereby  increasing  system efficiency
 to at least 75 percent on a continuous  basis.  New capture systems
 could be designed to minimize VOC loss  during periods when access
doors are open by providing openings which are of sufficient size  to
 allow unhampered worker access while maintaining adequate air velocities
                                  4-17
-------
across the face of the openings for containment of emitted VOCs.
Enclosures on drying conveyors at many plants could be extended to
contain more of the VOCs emitted from the cemented rubber?, the length
of conveyor that is enclosed would depend upon conveyor speed and the
solvent evaporation rate.  Vapor loss seals can be employed on dampers
to improve emission reduction system efficiency.  CemeVit tanks for  the
applicator assembly can be covered or drained when not in use.  Carbon
adsorbers employed in the system would require designs that allow
proper cooling of desorbed beds before being returned to the adsorption
cycle.
      In addition, the EPA document, Control of Volatile Organic Emissions
from  Manufacture of Pneumatic Tires (CTG),25 presents values based  on
capture and  control technologies used  in  other industries,.  These
values indicate that  retrofit capture  components  of undertread  cementing
VOC emission reduction  systems may  be  65  to 85 percent efficient;  it
is expected  that most systems would achieve at least  75  percent efficiency.
EPA analysis indicates  that  capture systems for  new,  modified,  or
reconstructed operations  should  be  able  to  continuously  achieve at
least 80  percent efficiency.   Eighty-five percent capture  is  not
considered  achievable in  all  situations  because  of variation  in
undertread  cement  application  equipment configuration,  need for operator
access,  and chemical  characteristics  of the cements and  solvents.
Control  components  can  achieve efficiencies of 95 percent.   Therefore,
new,  modified, and  reconstructed undertread cementing operations  that
employ VOC  emission reduction systems should be able to continuously
 reduce VOC  emissions  by at least 75 percent.
 4.3.2  VOC  Emission Reduction Systems for Sidewall Cementing.
      Since  the type of equipment used to apply cement to sidewall   is
 similar to  that used for undertread cementing, VOC emission reduction
methods should be similar.  Figure 4-4 illustrates the type of ventilation
 enclosure that can be used on a sidewall cementing unit.
      The capture design should address the following considerations:
      1.   Maintenance of OSHA employee exposure  limits for organic
 vapors in cases where workers are exposed to VOCs and maintenance  of
 organic vapor concentrations at 25 percent or less of the LEL where
 workers are not exposed;

                                   4-18
-------
      2.   Operator accessibility  to  areas  within the enclosure;
      3.   Retention of cemented sidewall within  the enclosure for a
 sufficient amount of time to ensure  optimum  VOC  capture during drying.
 As explained for undertread cementing, capture components  on new,
 modified, or reconstructed lines  can be designed to achieve 80 percent
 efficiency or better.  As indicated  in previous  sections,  new control
 devices are capable of attaining  95 percent  control  efficiency.   New,
 modified, or reconstructed sidewall cementing operations that incorporate
 VOC capture and control components having  efficiencies  of  80 and
 95 percent would be able to reduce VOC emissions  by  at  least 75 percent
 on a continuous basis.
 4.3.3  VOC Emission Reduction Systems for  Tread  End  Cementing
      Important parameters of any tread end cementing-VOC emission
 reduction system include provisions for maintenance  of  VOC concen-
 trations at 25 percent  or less  of the LEL,  worker accessibility to the
 cementing area, and sufficient  tread residence time  in  the system to
 ensure  solvent capture  during dement drying.   In addition, maintenance
 of organic vapor concentrations below OSHA  employee exposure limits is
 a  requirement  for the design  of any VOC capture component to be utilized
 for manual  tread end  cementing  facilities.
      VOC emissions  from manual  tread  end  cementing facilities can be
 caught  by a modified  side draft or slot capture hood mounted upon an
 underflow capture table.   The capture hood  and table can be enclosed
 on both  sides  and the top, thereby leaving  working area access unre-
 stricted.  Such  capture units are  similar to  those used for other
 industrial applications.   Diagrams of a portable  chipping/grinding
 table and  a soldering table appear as  Figures 4-5 and 4-6.86  Modifi-
 cation of  these  capture units to accommodate  a conveyor belt should
 pose little problem.  Openings  cut through  the extended  sides of the
 hooding  to accommodate conveyors can  be designed  to  minimize pressure
 losses or changes in air flow distribution  that might be caused by
 such modifications.  Drying conveyors should  also be  enclosed to
 capture solvent  that is emitted from the coated tread ends.   The
 overall  efficiency of the capture  system will  be  dependent  on the
extent of solvent evaporation occurring in  the conveyor  enclosure.
                                  4-19
-------
                             Duct velocity 35OO ft/min
                                       Reflector type bulb
                                       1/4" safety glass with
                                       *I6 ga. Z retainer
                                      Opening to be sized to handle
                                      3/4 of total air @ (ZOO) ft/mln
                                      	•	velocity
           Opening to be sized to handle
           1/4 of total air @(2OO) ft/min
          	velocity
                                                                                       Baffle
                                                                                        •plate
      A.   FRONT VIEW.
   -Sliding gate



B.   SIDE VIEW
Figure 4-5.   Capture System  for  Portable  Chipping and Grinding Tables
                                                                                    86
                                         4-20
-------
                          45° Slope min.
                                     Slots - size
                                     for IOOOFPM.
                                              Grille bench top.
                                     Removable cleonouf
                                      drawer.
Figure  4'-6.  Capture System for a Soldering  Table
                                                       86
                           4-21
-------
Conveyor enclosure ends should be fitted with flexible flaps  to minimize
dispersion of VOCs from the tread end cementing area.
                                    26
     Estimates presented in the CTG,   indicate that retrofit capture
components of manual tread end cementing VOC emission reduction systems
may be 65 to 85 percent efficienct; it is expected  that most  systems
would achieve at least 75 percent efficiency.  EPA  analysis indicates
that capture systems for new, modified, or  reconstructed operations
should be able to continuously achieve 80 percent efficiency  or better.
Eighty-five percent capture is not considered achievable in all situations
because of variations in tread end cementing equipment configuration,
need for operator access, and chemical characteristics of  the cements
and solvents.
     Automatic tread end cementing operations can be enclosed.  Movable
panels can be provided to allow worker access to the machinery for
adjustment and maintenance.  One possible enclosure type is a modifi-
cation of the design used for straight line automatic buffing
             oc
(Figure 4-7).    Drying conveyors should also be enclosed  to  capture
solvent that is emitted from the coated tread ends.  The overall
efficiency of the capture system will be dependent  on the  extent  to
which the conveyors are enclosed and  is related to  the percentage of
total solvent evaporation that occurs under the attendant  conveyor
hooding.  Ends of the drying conveyor enclosures should be covered
with flexible flaps to minimize dispersion  of VOCs  from tread end
cementing facilities.
                           26
     The CTG estimates that   retrofit capture components  of  automatic
tread end cementing VOC emission reduction  systems  may achieve 65 to
85 percent efficiency, most capture systems are expected to achieve
about 75 percent efficiency.  EPA analysis  indicates that  capture
systems for new, modified, or reconstructed operations should be  able
to continuously achieve at least 80 percent efficiency.  Eighty-five
percent capture efficiency is not considered achievable  in all situations
because of variations in undertread cement  application equipment
configuration, need for operator access, and chemical characteristics
of the cements and  solvents.
                                   4-22
-------
                    •Use one branch duct
                       for each wheel.
                           •Hinged access doors for maintoinance,
                             normally closed.
                               Stow speed belt conveyor
                  A.  Overall  V.iew
                                45°    r!75-2OOfpm.
L
24"min. •* -* -
t

	 i/«/oer eiiu ua JOT
•^ as practical.
o
                                                              Flexible flap
                  B.  Enclosure  of Conveyor Hood  Ends by Cloth  Flaps
Figure 4-7.   Capture System for Straight  Line Automatic  Buffing
                                                                .    86
                                  4-23
-------
     Alternately, low levels of VOC emissions from  tread  end  cementing
may be achieved without the aid of add-on VOC capture  and control
components.  Industry-supplied information  indicates that the small
amounts of solvent used at many tread end cementing operations  result
in VOC emission rates which are below 10 grams  (0.022  Ib) per
     1 9^ R^ R4
tire.    '  '    VOC emissions from some tread  end  cementing  opera-
tions are as low as 2.0 grams (0.004 Ib) per tire,  which  is approximately
85 percent less than the average uncontrolled tread end cementing
emission factor.
     New, modified, and reconstructed tread end cementing operations
that employ emission reduction systems  should be able  to  continuously
reduce VOC emissions by at least 75 percent.  Tread end operations
employing low solvent use techniques can achieve average  emissions
below 10.0 grams per tire.
4.3.4  VOC Emission Reduction Systems for Bead  Cementing
     Several features are important to  the  design of a bead cementing
VOC emission control system:
     (1)  maintenance of OSHA employee  exposure limits for organic
vapors where workers are exposed to VOCs and maintenance  of organic
vapor concentrations at 25 percent or less  of the LEL  where workers
are not exposed;
     (2)  worker accessibility to the bead  cementing facility,
     (3)  sufficient residence time in  the  VOC  capture component to
ensure optimal solvent capture during cement or solvent drying.
     Bead spraying, rolling and swabbing, and dipping  require different
VOC capture methods.  These methods are described below.
     4.3.4.1  Spraying.  Solvent emissions  from bead spraying can be
reduced by controlling the quantity of  cement applied  and by  employment
of VOC emission reduction systems.  Booths, similar to those  shown  in
                                                            86
Figure 4-8, could be used to enclose the spraying equipment.     Spray
booth capture efficiencies can range around 80  to 90 percent, depending
on the extent of enclosure and length of time the tire component is
                      pe
retained in the booth.
     4.3.4.2  Rolling and Swabbing.  Approximately  60  percent of tire
manufacturing plants performing bead cementing  in 1979 were using
                                   4-24
-------
        *~\^45*m>
            >V
                                                 min.
A.  Solid Baffle
B.  Angular Baffle     C.   Split Baffle or
       •                      Filters
         Figure 4-8.  Capture Systems for Small Spray Booths
                                                            86
                               4-25
-------
roller or  swab  techniques.   VOC  emissions  from roller or swab application
can be reduced  through  emission  reduction  systems.   The cement trough,
roller, or swab  application  areas  could  be enclosed.  VOCs emitted
would be vented  through  a hose to  a low  air flow (less than 4.72 x
  -2  3
10   m /sec  [100 scfm])  carbon absorption  canister.   Estimates -presented
in the CT6 indicate that the average efficiency of  VOC emission reduction
systems installed on roller- or  swab-type  bead cementing operations
                                                    nc
would be at  least 75 percent on  a  continuous basis.     However, such a
system may be impractical since  it would significantly increase air
flow through the small  application area, thereby increasing VOC evaporation
rates and  solvent requirements.  Engineering judgment indicates that
flash-off  areas  could not practically be enclosed due to the arrangement
and location of  bead forming equipment.
     Many  roller bead cement applicators emit small  quantities of VOC,
                                                       1 25 87 88
as solvent consumption  is less than 10 grams per tire.    *  '    At
one plant, VOC emissions from roller application were calculated
through a  materials balance  to-be  1.2 grams VOC per  tire,  which is
approximately 85 percent less than the average uncontrolled bead
                          1  ?% 87  88
cementing  emission factor.    '»     These calculations are described
in Appendix C.   Similar  levels of  VOC emissions from swabbing have not
been demonstrated.
     4.3.4.3  Dipping.  A unit similar to  the dip tank illustrated in
Figure 4-9 may be useful in  controlling  VOCs from bead dipping operations.
The dip tank's capture component consists  of two slotted side draft
capture hoods:   one for the  dip  tank and one for the drainboard.   The
critical area of VOC emission control  in bead dipping iks solvent
evaporation off  the agitated cement and  coated beads as  they are
removed from the dip tank.   VOC  capture  can be augmented by equipping   '
the dip tank hooding with extended  skirts,  though enclosure of the
tank would result in higher  capture efficiencies.  A capture unit with
design features  similar to those presented  in Figure 4-9 would be con-
sidered less efficient than  total  enclosure of the bead  cement tank
and drying area, but would afford  less restricted worker access.
                                    2fi
     Estimates presented in  the  CT6   indicate that  retrofit capture
components for bead dipping  VOC  emission reduction systems  may be 75
                                  4-26
-------
       -45'min.siOfM
                                                  For best results enclose
                                                  drainboard as a drying
                                                  tunnel.
-Sht velocity
2 x max. plenum
   " velocity.
  Figure 4-9.   Capture System  for a  Dip Tank
                                                   86
                          4-27
-------
to 85 percent efficient; it is expected that most capture systems
would achieve at least 80 percent efficiency.  EPA analysis  indicates
that capture systems for new, modified, or reconstructed operations
should be able to continuously achieve at least 80 percent efficiency.
Eighty-five percent capture efficiency is not considered achievable  in
all situations because of variations in bead cementing equipment
configuration, need for operator access, and chemical characteristics
of the cements and solvents.  Thus, uncontrolled bead dipping emissions
can be reduced at least 75 percent on a continuous basis through the
use of an 85 percent efficient capture system and a 95 percent efficient
   *  i j  •   I5'25
control device.
     Automatic dipping conveyors can be enclosed by a unit similar to
the capture component illustrated in Figure 4-7.  Ends of the enclosures
can be covered with flexible flaps to reduce the dispersion  of VOCs
from bead cementing equipment.  For reasons similar to those given for
non-automatic bead dipping, automatic dipping equipment/attendant
conveyor-1ine enclosures should be at least 80 percent efficient.
Therefore, if 80 percent efficient capture components are employed in
conjunction with 95 percent efficient VOC control devices., VOC emissions
from automatic bead dipping operations could be reduced by at least
75 percent on a continuous basis.
     Industry-supplied information indicates that some bead  dipping
operations use such small amounts of solvent that VOC emission rates
below 10 grams (0.022 Ib) per tire can be achieved.1"25'87'88  In
certain cases, solvent use is so low that bead dipping operations emit
approximately 1.0 gram (0.002 Ib) of VOC per tire:  an emission rate
which is about 85 percent less than the average uncontrolled emission  ,
factor.1-25'87'88
4.3.5  VOC Emission Reduction Techniques for Green Tire Spraying
     VOC emissions from green tire spraying may be reduced by either
of two techniques:  substitution of water-based sprays, or use of
emission reduction systems.
     4.3.5.1  Materials Substitution.  The use of water-based green
tire sprays can reduce average organic solvent-based  inside  green tire
spray emissions by 95 to 100 percent and average organic solvent-based
                                  4-28
-------
                                 ,26
 outside sprays by 90 to 100 percent.1"25'69"74  The extent of emission
 reduction is dependent on the formulation and amount'of sprays used.
 It is estimated that VOC emissions from both inside and outside water-
 based sprays would be approximately 90 to 100 percent less than average
 VOC emission levels resulting from the use of both inside and outside
 organic-solvent based sprays.
      4.3.5.2  Emission Reduction System.  Neither carbon adsorbers nor
 afterburners have been employed by the industry as VOC control components,
 even though green tire spray booths (spray enclosures) can be vented
 to a retrofit VOC control  unit.  The design of a green tire spray
 booth is illustrated in Figure 4-8.  Estimates presented in the CTG*
 indicate that retrofit capture components of green tire spraying VOC
 emission reduction system^ may be 80 to 90 percent efficient; most
 plants  would be expected to achieve about 80 percent efficiency.   EPA
 analysis indicates that capture systems for new, modified, or
 reconstructed operations should be able to achieve 80 percent efficiency
 or better on a continuous  basis.   Ninety percent capture efficiency is
 not considered achievable  in all  situations because of variations in
 green tire spraying  equipment configuration,  need for operator access,
 and chemical  characteristics of the cements and  solvents.   The length
 of time the coated tire is allowed to  dry in  the enclosure will  also
 affect  the capture efficiency.66
      The application  and effectiveness of an  adsorber  as a VOC control
 component for green  tire spraying might be limited by  solids  in the
 sprays  which,  when suspended in exhaust stream gases,  could foul  the
 carbon  beds;  particulates  in the  capture  component exhaust stream
 could also  plug  catalytic  afterburners.   Pretreatment  of the  exhaust
 gas  by  mechanical  separators,  scrubbers,  or bag  filters  should eliminate
              28  51 8Q
 this  problem.  °>ai»°*   if  95  percent efficient carbon  absorbers or
                                   4
 afterburners  are used  in conjunction with  80  percent efficient green
 tire  spray  booths, VOC  emissions  from  green tire spraying  operations
 could be  reduced by at  least 75 percent on a  continuous  basis.
 4.3.6   Summary
     Table 4-1 presents  emission  reductions achievable using  available
capture and control emission  reduction techniques.  Information is
4-29
-------


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provided for undertread cementing, sidewall  cementing, tread  end
cementing, bead cementing, and green tire spraying operations.  EPA
analysis indicates that capture/control systems  installed  on  these
operations would be able to reduce VOC emissions by at least  75 percent
on a continuous basis.  Water-based green tire spraying, tread-end
cementing which employs low solvent use techniques, and bead  cementing
which employs low solvent use techniques involves reduced  organic
solvent consumption.  Consequently, VOC emissions may be so small that
further emission reduction through the use of capture/control systems
may not be warranted.
                                  4-31
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4.4  REFERENCES

 1.  Letter from Lewis, R.O.,  Armstrong Rubber Company, to Goodwin,
     D.R.,  ESED/OAQPS/EPA.  February 28, 1978.  Response to Section 114
     letter.

 2.  Letter from Burkett, E.J., The Goodyear Tire and Rubber Company,
     to Goodwin, D.R., ESED/OAQPS/EPA.  May 17, 1978.  Response to
     Section 114 letter.

 3.  Letter from Miles, R.C., Uniroyal, Inc., to Goodwin, D.R., ESED/
     OAQPS/EPA.  July 13, 1978.  Response to Section 114 letter.

 4.  Letter from Miles, R.C., Uniroyal, Inc., to Goodwin, D.R., ESED/
     OAQPS/EPA.  May 16, 1978.  Response to Section 114 letter.

 5.  Letter from Frase, R.W., General Tire and Rubber Company, to
     Goodwin, D.R., ESED/OAQPS/EPA.  May 16, 1978.  Response to Section 114
     letter.

 6.  Letter from Miles, R.C., Uniroyal, Inc., to Goodwin, D.R., ESED/
     OAQPS/EPA.  April 4, 1978.  Response to Section 114 letter.

 7.  Letter from Onstott, N., Mohawk Rubber Company, to Zobel, K.J.,
     ESED/OAQPS/EPA.  March 21, 1978.  Response to Section 114.letter.

 8.  Letter from Walter, R.M., The Firestone Tire and Rubber Company,
     to Goodwin, D.R., ESED/OAQPS/EPA.  May 5, 1978.  Response to
     Section 114 letter.

 9.  Letter from Walter, R.M., The Firestone Tire and Rubber Company,
     to Goodwin, D.R., ESED/OAQPS/EPA.  June 7, 1978.  Response to
     Section 114 letter.

10.  Letter from Lewis, J.W., The B.F. Goodrich Company, to Walsh,
     R.T., ESED/OAQPS/EPA.  May 24, 1978.  Response to Section 114
     letter.

11.  Letter from Cooper, L.B., Michel in Tire Corporation, to Goodwin,
     D.R., .ESED/OAQPS/EPA.  April 13, 1978.  Response to Section 114
     letter.

12.  Letter from Walter, R.M., The Firestone Tire and Rubber Company,
     to Walsh, R.T., ESED/OAQPS/EPA.  June 29, 1978.  Response to
     Section 114 letter.

13.  Letter from Cooper, L.B., Michel in Tire Corporation, to Goodwin,
     D.R., ESED/OAQPS/EPA.  March 13, 1978.  Response to Section 114
     letter.
                                  4-32
-------
 14.   Letter  from  Miles,  R.C.,  Uniroyal,  Inc.,  to Goodwin, D.R.,
      ESED/OAQPS/EPA.  May  24,  1978.   Response  to Section 114 letter.

 15.   Letter  from  Burkett,  E.J.,  The  Goodyear Tire and Rubber Company,
      to  Farmer, J.R., ESED/OAQPS/EPA.  March 31, 1980.   Response to
      Section  114  follow-on letter.

 16.   Letter  from  Burkett,  E.J.,  The  Goodyear Tire and Rubber Company,
      to  Farmer, J.R., ESED/OAQPS/EPA.  March 21, 1980.   Response to
      Section  114  follow-on letter.

 17.   Letter  from  Townhill,  J.R.,  The General Tire and Rubber Company,
      to  Zobel, K.J., ESED/OAQPS/EPA.   April  2,  1980.   Response to
      Section  114  follow-on letter.

 18.   Letter from  Clark,  R.R.,  The B.F. Goodrich  Company, to Goodwin,
      D.R., ESED/OAQPS/EPA.  March 18,  1980.  Response to Section 114
      follow-on letter.

 19.   Letter from  Clark,  R.R.,  The B.F. Goodrich  Company, to Goodwin,
      D.R., ESED/OAQPS/EPA.  April 16,  1980.  Response to Section 114
      follow-on letter.

 20.   Letter from  Miles,  R.C.,  Uniroyal,  Inc., to Farmer, J.R.,  ESED/
      OAQPS/EPA.   April 11,  1980.  Response to Section 114 follow-on
      letter.

 21.   Letter from  Luysterborghs,  P.M.,  Armstrong  Rubber Company,  to
      Goodwin, D.R., ESED/OAQPS/EPA.  March 5, 1980.   Response  to
      Section  114  follow-on  letter.

 22.   Letter from  Laman,  J.R.,  The Firestone Tire and  Rubber Company,
      to Goodwin,  D.R., ESED/OAQPS/EPA.   April 8,  1980.   Response to
      Section  114  follow-on  letter.

 23.   Letter from  Laman,  J.R.,  The Firestone Tire and  Rubber Company,
      to Goodwin,  D.R., ESED/OAQPS/EPA.   April 17,  1980.   Response to
      Section  114  follow-on  letter.,

24.   Letter from  Cooper, L.B., Michel in  Tire Corporation,  to Farmer
     J.R., ESED/OAQPS/EPA.   February 19, 1980.

25.  Letter from  Niles,  R.C.,  Uniroyal,  Inc., to Farmer,  J.R.,
     CPB/ESED/OAQPS/EPA.  May  12, 1980.  Response  to  Section 114
     follow-on letter.

26.  Zobel, K.J. and N.   Efird.  Control  of Volatile Organic  Emissions
     from Manufacture of Pneumatic Rubber Tires.   U.S. Environmental
     Protection Agency.   Research Triangle Park, N.C.  Publication
     No.  EPA-450/2-78-030.   December 1978.   59 p.
                                  4-33
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27.  Hydrocarbon Pollutant Systems Study, Volume I - Stationary Sources,
     Effects, and Control.  U.S. Environmental Protection Agency.
     Research Triangle Park, N.C.  Publication No. APTD-1499.  October
     1972.  377 p.

28.  The Industrial Environment - Its Evaluation and Control.  U.S.
     Department of Health, Education, and Welfare.  Public Health
     Service.  Center for Disease Control.  National Institute for-
     Occupational Safety and Health.  Washington, D.C.  1973.  p. 645.

29.  Telecon.  Rinaldi, G., Monsanto Research Corporation with Bronson,
     T., Fly Ash Anestor Corporation.  August 16, 1978.  Scrubbers for
     control of hydrocarbon emissions.

30.  Juhola, A.J.  Package Sorption Device System Study.  U.S. Environmental
     Protection Agency.  Research Triangle Park, N.C.  Publication No.
     EPA-RZ-73-202.  April 1973.  576 p.

31.  Telecon.  Rinaldi, G., Monsanto Research Corporation, with Peterson,
     P.D., Uniroyal, Incorporated.  August 15, 1978.  Control of green
     tire spraying emissions.

32.  Control of Volatile Organic Emissions from  Existing Stationary
     Sources—Volume 1: Control Methods  for Surface-Coating  Operations*
     U.S. Environmental Protection Agency.  Research Triangle Park,
     N.C.  Publication No. EPA-450/2-76-028.  November 1976.  166 p.

33.  McDermott, H.J.  Handbook  of Ventilation for Contaminant Control.
     Ann Arbor Science Publishers,  Incorporated.  Ann Arbor, Michigan.
     1976.  368 p.

34.  Letter from Burkett, E.J., Goodyear Tire and Rubber Company, to
     Zobel, K.J.,  EPA.  May 14, 1979.   Information  on pollution control
     facilities at new Goodyear plant  in Lawton, Oklahoma.

35.  Melchiori, E.A.  Supportive Documentation for  Air Pollution
     Permit Applications: Red Oak,  Iowa, Hose Plant.  Uniroyal,  Incorporated.
     Middlebury, Conn.  1973.

36.  Harris, H.D., Colorado" Department of Health Air  Contaminant
     Emissions Notice.  Gates Rubber Company.  Denver, Colo.   1976.

37.  Letter from Madden,  G.I.,  E.I.  DuPont de Nemours and Company,
     Incorporated, to  Karger, E., Gates  Rubber Company.  November 9,
     1976.   Performance of  catalytic  incinerator.

38.  Air  Pollution:  Control Techniques  for Hydrocarbon  and  Organic
     Solvent Emissions from Stationary Sources.   NATO Committee  on  the
     Challenges  of Modern Society.   Brussels,.Belgium.   October  1973.
                                   4-34
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 39.   Lukey,  M.E.  and M.D.  High.   Exhaust Gas Conversion Factors, Zurn
      Environmental  Engineers.   Engineering Science, Incorporated.
      Washington,  D.C.  (Presented to the Air Pollution Control Association
      Annual  Meeting.  Miami  Beach,  Fla.   June 18-22, 1972). 16 p.

 40.   Memorandum.   J.R.  Farmer,  EPA/CPB,  to EPA staff.   Efficiencies of
      Thermal  Incinerators  and  Flares.  August 22, 1980.

 41.   Danielson, J.A., ed.  Air  Pollution Engineering Manualj Second
      Edition.  U.S.  Environmental Protection Agency.  Research Triangle
      Park, N.C,   Publication No.  AP-40.   1973.   987 p.

 42.   Telecon.  Cooper,  R., Midwest  Research Institute, with Aus, B.,
      Pacific  Environmental Services, Incorporated.   October 8, 1979.
      Control  technology transfer  from  the asphalt roofing  industry.

 43.   CE Air  Preheater and  the Industrial  Gas Institute.  Report of
      Fuel Requirements,  Capital Cost and Operating  Expense for Catalytic
      and Thermal  Afterburners.  U.S. Environmental  Protection Agency.
      Research Triangle  Park, N.C.   Publication  No.  EPA-450/3-76-031.
      September 1976.

 44.   Telecon.  W. Erbe,  Trane Terminal Co., with B.  Aus,  Pacific
      Environmental Services, Inc.   December 14,  1979.   Discussion of
      operating and cost parameters  of  direct flame  afterburners.

 45.   Kinkley, M.L. and  R.B.  Neveril.   Capital and Operating Costs of
      Selected Air Pollution  Control  Systems.  U.S.  Environmental
      Protection Agency.  Research Triangle Park,  N.C.   Publication
      No. EPA-450/3-76-014.   May 1976.  208 p.

 46.   Letter from  Mueller, J.H., Regenerative Environmental  Equipment
      Company, Incorporated,  to McCarthey,  J., OAQPS/EPA.   October 1,
      1976.  Operation of direct flame  afterburners.

 47.   Sandomirsky, A.G., D.M. Benforado,  L.D.  Grames, C.E.  Pauletta.
      Fume Control  in  Rubber  Processing by  Direct-Flame Incineration.
      Journal  of the Air Pollution Control  Association.  11:673-676.
      December 1966.

48,   Van Lierop,   B., and P.W. Kalika.  Measurement of  Hydrocarbon
      Emissions and Process Ventilation Requirements  at a Tire  Plant.
      (Presented at the 68th Annual Meeting  of the Air  Pollution  Control
     Association.   Boston, Mass.  June 15-20, 1975).   23 p.

49.   Feiner,  B.   Industrial Air Contaminant  Control, In: Dangerous
      Properties of Industrial Materials,  Fourth Edition.  Sax, N.I.,
     ed.  Van Nostrand Reinhold Company.    Cincinnati,  Ohio.   1975.
     p. 40-65.

50.  Ross, R.D. Pollution Abatement: Incineration of Solvent-Air
     Mixtures. Chemical Engineering Progress, Vol 68.  No. 8, p.  63.
     August 1972.
                                  4-35
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51   Rolks, R.W., R.D. Hawthorne, C.R. Garbett, E.R. Slater, and T.T.
     Phillips.  Afterburner Systems Study.  U.S. Environmental Protection
     Agency.  Research Triangle Park, M.C.  Publication No. EPA-R2-72-062.
     August 1972.  512 p.

52   Control Techniques for Nitrogen Oxide Emissions From Stationary
  '  Sources.  National Air Pollution Control Administration.  Washington,
     D.C.  Publication No. AP-67.  March  1970.  p. 5-4,5.

53.  U.S. Environmental Protection Agency.  Code of  Federal Regulations.
     Title 40, Chapter 51.  Washington, D.C.  Office of the Federal
     Register.   November  25,  1971.

54.  Miller,  M.R., and H.J. Wilhoyte.   A  Study  of  Catalyst  Support
     Systems  for Fume Abatement  of Hydrocarbon  Solvents.  Journal  of
     4-u«  a-iv.  Dnii.rHnn r.nnt.rnl Association.   17:791-795.  December
 55.
 56.
 57.
 58.
 59.
 60.
 61.
  62.
the Air Pollution Control Association.
1967.

Letter from DeRosa, F.,  Engelhard Minerals and Chemicals Corporation,
to B. Aus, Pacific Environmental Services, Incorporated.  February  13,
1980.  Operating parameters and costs of catalytic afterburners.

Letter from R. Littman, Met Pro Corporation, to B. Aus,  Pacific
Environmental Services,  Incorp1 orated.   February 5, 1980.  Operating
parameters and costs of catalytic afterburners.

Telecon.  R. Litman, Met Pro  Corporation,  with B. Aus.   December 14,
1979.  Discussion  of operating and cost parameters of  catalytic
afterburners.

Radian Corporation.  Control  Techniques for  Volatile Organic
Emissions from Stationary Sources.   U.S.  Environmental•Protection
Agency.   Research  Triangle  Park,  N.C.   Publication  No.  EPA-450/2-78-022.
May  1978.  578 p.

Telecon.  R.  Karesh, Vulcan Cincinnati, with B.  Aus, Pacific
Environmental Services,  Inc.   December 14, 1979.   Discussion of
operating and cost parameters of carbon absorbers,.

Telecon.  Wilcox,  C.,  Dayco Corporation, with Aus!;  B.  Pacific
Environmental Services,  Incorporated.  April 22,  1981.  Carbon
adsorber performance.

Telecon. Uilkes,  J.,  Norton Company, with Aus, B,., Pacific
 Environmental  Services,  Incorporated.  April 21, 1981.  Carbon
 adsorber performance.

 Radian Corporation.  Pressure Sensitive Tape and Label  Surface
 Coating Industry-Background  Information for Proposed Standard.
 U.S. Environmental Protection Agency.  Office of Air Quality
 Planning and Standards.   Research Triangle Park, MC.  Publication
 No. EPA-450/3-80-003a.  September 1980.   Chapter 4.0.
                                    4-36
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 63.   Jongleux, R.F.   Volatile Organic Carbon Emission Testing at
      Armstrong Rubber Company, Eastern Division, West Haven, Conn.
      TRW, Environmental  Engineering Division.  Durham, N.C.  April
      1979.

 64.   Chass,  R.L.,  C.V.  Kanter, J.H. Elliott.  Contribution of Solvent
      to Air Pollution and Methods for Controlling Their Emissions.
      Journal  of the  Air Pollution Control Association.  13:64-72.
      February 1963.

 65.   Marrone, W.A.   Results of a Test Program on the Solvent Recovery
      System  for the  Undertread Cementer,  Armstrong Rubber Company,
      West Haven, Conn.   The Research Corporation of New England.
      Wethersfield, Conn.   March 1975.   55 p.

 66.   Kalika,  P.W., and  J.E. Yocum.   The Control  of Hydrocarbon Emissions
      from the West Haven  Plant of the Armstrong  Rubber Company.   (Pre-
      sented  at the Connecticut Department of Environmental  Protection
      Public  Hearing  on  Compliance Schedule.   February 28,  1973).

 67.   Control  Techniques  for Hydrocarbon and  Organic Solvent Emissions
      from Stationary Sources.   U.S.  Public Health Service.   Washington,
      D.C.  Publication  No.  AP-68.   March  1970.   114 p.

 68.   Telecon.   Oakes, D.,  Hoyt Manufacturing Corporation,  with Aus,
      B.,  Pacific Environmental  Services,  Incorporated.  December 18,
      1979.  Operating parameters  and costs of carbon adsorbers.

 69.   Telecon.   Nelson, G.,  Dow Corning  Corporation,  with  Rinaldi,
      G.M., Monsanto  Research Corporation.  August 22,  1978.   Com-
      position  of water-based sprays  used  by  the  tire industry.

 70.   Telecon.   Raleigh, W.  and  A. Wotiz,  General  Electric  Company,
      with Rinaldi, G.M., Monsanto Research Corporation.  August  22,
      1978.  Composition of  water-based  sprays used  by  the  tire
      industry.

 71.   Telecon.   Wittekind, R.,  SWS Silicones  Corporation, with  Rinaldi,
      G.M., Monsanto  Research Corporation.  August 22,  1978.  Composition
      of water-based  sprays  used by the  tire  industry.
72.
73.
74.
Letter from Brooks, H.L., SWS Silicones Corporation,  to  Zobel,
K.J., EPA.  July 3, 1979.  Comments on proposed Guidance Document
for the Group II Control Techniques Guidelines for Volatile
Organic Compounds.                                            '

Telecon.  Brewer, R.M.  The C.P. Hall Company, with Aus,  B.,
Pacific Environmental Services, Incorporated.  September 29,
1980.  Composition of water-based sprays used by the  tire
industry.

Letter from R. Brewer, The C.P. Hall Company to B. Aus,  Pacific
Environmental Services, Incorporated.  October 3, 1980.   Water-
based green tire spray composition and use.
                                  4-37
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75.  Telecon.  Thimineur, R., General Electric Company, with McAdams,
     M.T., Pacific Environmental Services, Incorporated.  December 20,
     1979.  Use of water-based green tire sprays by the tire industry.

76.  Telecon.  Martin, D., Dow Corning Corporation, with McAdams,
     M.T., Pacific Environmental Services, Incorporated.  December 28,
     1979.  Use of water-based green tire sprays by the tire industry.

77.  Telecon.  Slinger, J.L., Harwick Chemical Company, with McAdams,
     M.T., Pacific Environmental Services, Incorporated.  December 209
     1979.  Use of water-based green tire sprays by the tire industry.

78.  Telecon.  Wittekind, R., SWS Silicones Corporation, with  ,
     McAdams, M.T., Pacific Environmental Services, Incorporated.
     December 19, 1979.  Use of water-based green  tire sprays  by
     the tire industry.

79.  Telecon.  Reynard, K., SWS Silicones Corporation, with McAdams,  T.,
     Pacific Environmental Services, Incorporated.  December 27,  1979.
     Composition and use of water-based  green  tire sprays.

80.  Telecon.  Brooks, H., SWS Silicones  Corporation, with Kent,  D.,
     Pacific Environmental Services, Incorporated.  September  11,
     1980.  Composition and use of water-based green  tire sprays.

81.  Telecon.  Martin, D., Dow Corning Corporation, with Kent, D.,
     Pacific Environmental Services, Incorporated.  September  11,
     1980.  Composition and use of water-based green  tire sprays.

82.  Telecon.  Slinger, J., Harwick  Chemical  Corporation, with
     Kent, D., Pacific Environmental Services, Incorporated.
     September 18,  1980.  Composition  and use of water-based green
     tire sprays.

83.  Telecon.  Corbin, J.,  Nalco  Chemical Company, with  Aus, Bi.,
     Pacific Environmental  Services, Incorporated.  October  1,
     1980.   Composition  and use of water-based green  tire sprays.

84.  McAdams, M.T.  Trip  Report:  Armstrong  Rubber Company, West
     Haven,  Conn.   September  5, 1979.

85.  Letter  from P.M.  Luysterborghs, Armstrong Rubber Co.,,  to  J.R.
     Farmer, CPB/ESED/OAQPS/EPA.  July 21,  1980.   Comments  on  Rubber
     Tire Manufacturing  draft NSPS  Preamble  and  Regulation,  June 30,
     1980.

86.  Industrial  Ventilation:   A Manual  of Recommended Practice, Twelfth
     Edition.  American  Conference  of  Governmental Industrial  Hygienists.
     Committee on Industrial  Ventilation.  Lansing,  Mich.   1972.
     337 p.'
                                   4-38
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87.  Ringquist, D.E., and R.T. Harrison.  Volatile Organic Compound
     Emission Measurements for Tread End Cementing and Bead Cementing
     at a Tire Manufacturing Plant, Kelly-Springfield Tire Company,
     Fayetteville, North Carolina.  U.S. Environmental Protection
     Agency.  Research Triangle Park, North Carolina.  March 1980.

88.  Ringquist, D.E., and R.T. Harrison.  Volatile Organic Compound
     Emission Measurements for Tread End Cementing and Bead Dipping
     Operations at a Tire Manufacturing Plant.  Armstrong Rubber
     Company, West Haven, Connecticut.  U.S. Environmental Protection
     Agency.  Research Triangle Park, N.C.  June 1980.

89.  Benzene Emissions from Maleic Anhydride Industry — Background
     Information for Proposed Standards.  Office of Air Quality Planning
     and Standards.  U.S. Environmental Protection Agency.  Research
     Triangle Park, N.C.  Publication No. EPA-450/3-80-001a.
                                  4-39
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                  5.0  MODIFICATION AND RECONSTRUCTION

5.1  BACKGROUND
     Emission limitation standards promulgated under Section lll(b) of
the Clean Air Act apply to all facilities within the regulated source
category that are constructed, modified, or reconstructed after the
date of proposal of the standards.  Uncertainties may arise as to the
determination of whether any existing facility has been "modified" or
"reconstructed."  These issues are addressed in Sections 60.14 and
60.15, respectively, of Title 40 of the Code of Federal Regulations,
which defines conditions under which an "existing facility" may become'
                                    1 2
subject to standards of performance. '   An "existing facility,"
defined in 40 CFR 60.2(aa), is an apparatus of the type for which a
standard of performance is promulgated and the construction or modifi-
cation of which was commenced prior to the date of proposal of that
standard.
     The following discussion examines the applicability of the
modification/reconstruction provisions to any facilities for undertread
cementing, sidewall cementing, tread end cementing, bead cementing,
and green tire spraying in an existing rubber tire manufacturing plant
and details conditions under which existing facilities could become
subject to standards of performance for new stationary sources.  The
enforcement division of the appropriate EPA regional office should be
contacted regarding any questions on modification or reconstruction
applicability.
5.2  40 CFR PART 60 PROVISIONS FOR MODIFICATION AND RECONSTRUCTION
5.2.1  §60.14 Modification
     §60.14 states:
     ". . . any physical or operational change to an existing facility
     which results in an increase in the emission rate to the
     atmosphere of any pollutant to which a standard applies shall be
                                5-1
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     considered a modification within the meaning of Section 111 of
     the Act.  Upon modification, an existing facility shall become an
     affected facility for each pollutant to,which a standard applies
     and for which there is an increase in tn"e emission rate to the
     atmosphere."
     Paragraph (e) lists certain physical or operational changes which
by themselves are not considered modifications.  These changes include:
     a.   Facility maintenance, repair, and replacement which are
determined by the Administrator to be routine;,
     b.   An increase in the production rate not requiring a capital
expenditure as defined in §60.2(bb).
     c.   An increase in the hours of operation.
     d.   Use of an alternative fuel or raw material if prior to the
standard, the existing facility was designed to accommodate that
alternate fuel or raw material.  (Conversion to coal, as specified in
§111(a)(8) of the Clean Air Act, is also exempted.)
     e.   The addition or use of any system or device whose primary
function is the reduction of air pollutants, except when an emission
control system is removed or replaced by a system considered to be
less efficient.
     f.   The relocation or change in ownership of an existing facility.
     An increase in the production rate of an existing facility is
designated as a modification only if there is an increase in the
emission rate and the total cost necessary to accomplish the change
constitutes a "capital expenditure."  Capital expenditure is the
product of the facility's original cost, as defined by Section 1012 of
the Internal Revenue Code, and the appropriate "annual asset guideline
repair allowance percentage" (AA6RAP).  The 1978 edition of Internal
                               3
Revenue Service Publication 534  sets the AAGRAP for the tire manu-
facturing industry at 5 percent.  Therefore, if the total cost of
increasing the production rate of an existing tire manufacturing
facility exceeds 5 percent of the facility's original cost, and if
this change causes increased emissions, the facility would be considered
to have been modified.
                                5-2
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      Paragraph (b) clarifies what constitutes an increase in emissions
 in kilograms per hour and the procedures for determining the increase
 including the use of emission factors, material balances, continuous
 monitoring system and manual emission tests.  Paragraph (c) affirms
 that the addition of a facility subject to performance standards to a
 stationary source does not make any other facility within that source
 subject to standards of performance.  Paragraph (f) simply provides
 for superseding any conflicting provisions.
 5.2.2  §60.15 Reconstruction
      §60.15 states:
      "An existing facility, upon reconstruction,  becomes an affected
      facility,  irrespective of any change in emission rate.   'Recon-
      struction1  means the replacement of components of an existing
      facility to such an  extent that:  (1) the  fixed capital  cost of
      the new components exceeds 50 percent of the fixed capital  cost
      that would  be required to construct a comparable entirely new
      facility,  and (2)  it is technologically and  economically feasible
      to meet the applicable standards set forth in  this part."2
      The purpose of  this  provision is to ensure that an owner or
 operator does not perpetuate the lifetime of an existing facility by
 replacing all but vestigial  components,  support structures,  frames,
 housing,  etc., rather than  totally replacing it in  order to  avoid
 subjugation  to applicable standards  of performance.
 5.3  APPLICABILITY TO RUBBER TIRE  MANUFACTURING PLANTS
 5.3.1   General
      Investigation of facilities for undertread cementing, sidewall
 cementing, tread  end  cementing,  bead  cementing, and  green tire spraying
 shows that there  are  no specific practices by the industry which  can
 readily  be classified as modifications or reconstructions.  The following
 sections  are concerned with  alteration and replacement  practices
 common to these process facilities which limit the application of the
modification and  reconstruction provisions.   In Section 5.3.2 other
 practices specific to each process facility are discussed.
                                5-3
-------
     5.3.1.1  Modifications.  The emission of VOCs from the five VOC
source process facilities is the result of application of solvent-based
materials to tire components to improve adhesion during tire assembly
or of application of solvent-based sprays to green tires to facilitate
release from curing molds.  Consequently, for rubber tire manufacturing
any physical or operational change resulting in an increased emission
rate to the atmosphere would be due to one or more of the folTowing:
(1) a production rate increase; (2) an increase in the VOC content of
cement, solvent, or sprays; (3) an increase in the quantity of solvent
applied per unit area of product.                             !
     5.3.1.1.1  Production rate increases.  Any tire manufacturing
plant is designed for a maximum production capacity, which is usually
directly related to the maximum capacity of the tire building jprocess
facilities or the curing process facilities.   Facilities for other
processes, such as those for undertread cementing, sidewall cementing,
tread end cementing, bead cementing, and green tire spraying, ;may have
capacities which exceed the total plant capacity  for finished ;tires.
An increase in the production capacity of a plant is possible ;with a
capital expenditure only for those facilities which limit finished
tire production.  For example* an increase in the plant  production
capacity could be met by the addition of a tire building machine or
curing  press.  Any production rate increase which would  exceed the
capacity of existing process facilities would likely be  met by the
installation  of new facilities to accommodate the production rate
increase.5'6   If the additional facility were one for which NSPS are
established,  it would be  subject to  NSPS if the addition caused  an
increase in VOC emissions  and  if the capital expenditure criteria were
met.
      5.3.1.1.2 Sol vent-re!ated VOC  emission increases.  Changes in
solvent use practices may  result in  a  rise of the VOC emission rate
from  tire manufacturing  facilities.   One  possible change would be an
increase in the VOC content of  solvent,  resulting in an  increase in
the  quantity  of VOCs emitted  per unit of  product.  Such  changes  in
solvent formulations are not common  in  the  industry.  *        '•
                                 5-4
-------
      Another possible change would be to increase the quantity of
 solvent or cement applied per unit of product.  There is little incentive
 to do so since maximum bonding power is best effected by application
 of the thinnest complete layer of adhesive material.  More solvent or
 cement applied per unit area of rubber would only reduce bonding power
 and increase costs.
      Either change would be classified as a modification if VOC emissions
 were to increase, causing the facility in question to become subject
 to standards of performance.
      5.3.1.2  Reconstruction.  Repair or rebuilding of an existing
 facility at a cost exceeding 50 percent of the cost of an entirely new
 facility is unusual.   There are no general  conditions which can be
 classified as a reconstruction.   As stated  in Section 5.3.1.1.1,
 production rate increases are usually met by adding to facilities
 rather than reconstructing existing facilities.   Determination of
 whether any repair or rebuilding  activities constitute reconstruction
 must be made on a case-by-case basis.
      If a previously  closed plant were to reopen,  it would  not be
 subject to NSPS unless  one or more of the facilities for which standards
 had  been promulgated  were altered sufficiently to  meet reconstruction
 criteria.   Then,  only those facilities  which  had been altered  and  for
 which  standards exist would be subject to NSPS.
 5.3.2   Applicability  to  Ma.ior Sources  in  Rubber Tire
       Plants
Manufacturing
     5.3.2.1  Undertread Cementing.  The equipment used  to  cement
undertread is simple, and little maintenance is required  for most
types of cement application systems.  Cement applicator  rolls,  belts,
or other conveyor system parts would only infrequently require  replacement.
Cement applicator brushes, where used, may require more  frequent,
though routine replacement.  None of these cases should have an effect
on VOC emissions, consequently, none is considered a modification.
     Only a large-scale replacement of conveyor parts and cement
applicator parts, either of which is considered an unusual circumstance,
would approach 50 percent of the cost of replacing an entire undertread
cementing facility.  The determination of whether any rebuilding
constitutes a reconstruction should be made on a case-by-case basis.

                                5-5
-------
     5.3.2.2  Sidewall Cementing.  The equipment used to cement
sidewalls is similar to that used to cement undertread.  It is;simple,
and little maintenance is generally required.  Parts would occasionally
need routine replacement; but having no effect on VOC emissions, such
replacement would not be considered a modification.  Only in unusual
circumstances would parts replacement approach 50 percent of the cost
of replacing an entire sidewall cementing facility.  The determination
of whether any rebuilding constitutes a reconstruction should be made
on a case-by-case basis.
     5.3.2.3  Tread End Cementing.  The equipment used to perform
manual tread end cementing is very simple, including little specialized
equipment other than a conveyor.  Spray tread end cementing equipment
is more complex, with sensors, spray arms, and nozzles requiring
periodic adjustment or repair.  For either cementing method, conveyor
parts or cement application components would only rarely require
replacement.  Routine maintenance, repair, or replacement activities
should not affect VOC emissions.
     Replacement costs exceeding 50 percent of the cost of an entirely
new facility would be incurred only in a very unusual situation, such
as replacement of a major part .of a spray cement application system
and a large part of the conveyor system.  Any determination of;whether
any rebuilding constitutes a reconstruction must be made on a case-by-case
basis.
     5.3.2.4  Bead Cementing.  Bead cementing equipment, whether the
cement is applied with a roller or swab, by dipping or by spraying, is
very simple and requires little maintenance.  The trough or dip tank
containing cement must periodically be cleaned to remove rubber
particles accumulated at the bottom or dried cement caked around the
edges.  Sponges, rollers, and nozzles must be periodically cleaned or
replaced.  These activities should not increase VOC emissions.
     Repair or replacement costs exceeding 50 percent of the cost of
an entirely new facility would be unusual.  Any determination must be
made on a case-by-case basis.
     5.3.2.5  Green Tire Spraying.  In a green tire spraying operation
where solvent-based formulations are used, spray nozzles must be
                                5-6
-------
 routinely cleaned or replaced due to abrasion; this should have no
 effect on VOC emissions.   Other activities considered to be routine
 are clean-out of spray booths and mechanical  maintenance of motorized
 rollers used in  some operations to support green tires.
      As with other processes, the primary determinants of VOC emissions
 from any green tire spraying  facility are the VOC content of solvent-
 based sprays and quantity sprayed.  Whether any changes in VOC content
 of  sprays constitute a modification must be determined on a case-by-case
 basis.
      Switching from solvent-based to water-based sprays requires
 several  physical  changes  to a spraying unit.   Piping,  pumps,  and
 nozzles used to  convey solvent-based sprays must be replaced  with
 corrosion-resistant material.8'9   The booth itself may require
 replacement  as the useful  life of a carbon steel  spray booth  is
 lessened  by  the  use of water-based sprays.9  Additional  conveyors may
 be  necessary as  use of water-based sprays  requires  longer drying
 time.   Whether  the replacement of any of  these  components  would
 constitute a  reconstruction should be  determined  on a  case-by-case
 basis.  Replacement of an existing facility used  for solvent-based
 sprays  with  a  new  facility used for water-based  sprays  would  cause  the
 new facility to  be  subject to  standards  of  performance.
     Switching from water-based to solvent-based  sprays  would  be
considered a modification since VOC  emissions would  increase.   The
change would be  considered a  reconstruction if appurtenant  equipment
alterations or replacements were to exceed  50 percent of the cost of
an entirely new facility.
                                5-7
-------
5.4  REFERENCES

1.   U.S. Environmental Protection Agency,  Code of Federal Regulations.
     Title 40, Protection of Environment, Section 60.2(h), Definitions.
     Washington, D.C.  Office of the Federal Register.  Revised as of
     July 1, 1977.  p. 6.

2.   U.S. Environmental Protection Agency.  Code of Federal Regulations.
     Title 40, Protection of Environment, Section 60.15, Reconstruction.
     Washington, D.C.  Office of the Federal Register.  July 1, 1977.
     p. 18.                                                    :

3.   Tax Information on Depreciation.  U.S.1Department of the Treasury.
     Internal Revenue Service.  Washington, D.C.  Publication 534.
     1978.  p. 29.

4.   Letter from R.R. Clark, The B.F. Goodrich Company to J.R. farmer,
     CPB/ESED/EPA.  February 12, 1980.  Comments on draft background
     information document.

5.   Telecon.  McAdams, M.T., Pacific Environmental Services, Inc.,
     with Burnett, E.H., and Taylor, T.L., The Firestone Tire and
     Rubber Company.  September 6, 1979.  Production rate increases.

6.   Telecon.  McAdams, M.T., Pacific Environmental Services, Inc.,
     with Lewis, R., Armstrong Rubber Company.  September 21, 1979.
     Equipment alterations, changes in solvent use practices.

7.   Telecon.  McAdams, M.T., Pacific Environmental Services, Inc.,
     with Daigle, N.A., The Firestone Tire and Rubber Company.
     September 12, 1979.  Changes in solvent use practices.

8.   Telecon.  Rinaldi, 6.M., Monsanto Research Corporation,* with
     Alessandro, P., Armstrong Rubber Company.  September 29, 1978.
     Maintenance, repair, and replacement of tire manufacturing
     facilities.

9.   Control of Volatile Organic Emissions from Existing Stationary
     Sources —Volume II:  Surface Coating of Cans, Coils, Paper,
     Fabrics, Automobiles and Light-Duty Trucks.  U.S. Environmental
     Protection Agency.  Research Triangle Park, N.C.  Publication
     No. EPA 450/2-77-008.  May 1977.  p. 6-38.
                                 5-8
-------
             6.0  MODEL PLANTS AND REGULATORY ALTERNATIVES

     The purpose of this chapter is to define model plants and  to
identify regulatory alternatives.  Model plants are parametric  descrip-
tions of the types of plants and VOC-emitting facilities  that are
expected to be constructed by the tire manufacturing  industry.  They
also represent the characteristics of existing plants where new,
modified, or reconstructed VOC-emitting operations may be located.
The regulatory alternatives are levels of emission reduction \.hich  EPA
could use to limit the amount of VOCs released from tire  plants.  The
model plant parameters are used as a basis for estimating the environ-
mental, economic, emission reduction cost, and energy impacts associated
with the application of the regulatory alternatives to the tire industry,.
6.1  MODEL PLANTS
     Parameters for undertread cementing, sidewall cementing, tread
end cementing, bead cementing, and green tire spraying operations
compose the model plants.  Basic parameters for the model plants are
shown in Tables 6-1, 6-2, and 6-3.
6.1.1  Model Plant Sizes
     Analysis of the plant production rates that were presented in
Table 3-1 indicates that no single model plant size based on production
rate can adequately characterize existing plants and  facilities or  new
ones likely to be built.  Although manufacturing methods  in small and
large plants may be similar, VOC emission reduction cost  factors may
vary considerably.  As a result, three model plant sizes  are used for
the environmental, energy, emission reduction cost, and economic
impact analyses:  model plants with production rates  of 15,000  tires
per day, 30,000 tires per day, and 50,000 tires per day.  A distri-
bution analysis of existing plant production rates indicates clustering
around the production rates of 15,000 and 30,000 tires per day.
                                6-1
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 Further, daily  production  rates  for tire plants constructed since 1968
                                                 p*7 OQ
 fall  in a  similar  daily  production  distribution.  '    Two existing
 plants produce  48,000  or more tires per day.29  In order to represent
 such  large plants,  a 50,000 tires per day model plant is included.
 Together,  these three  model plants  should characterize the spectrum of
 tire  manufacturing plant sizes likely to be constructed by the tire
 industry by 1985.
 6.1.2 Operating Parameters
      The average annual  operating time for plants in the industry is
 about 269  days  per year.      Assuming a 24-hour work day, plants
 operate  approximately  6,456 hours per year.
      The numbers of operations employed for solvent application activities,
 the unit production rates, the VOC emission rates, and the exhaust gas
 temperatures are based on  industry-supplied information presented in
 Appendix  C.  Exhaust gas flow rates are based on maintenance of a
>150 feet  per minute face"velocity in the capture system with all
 cement application equipment access doors open.  A 100 feet-per-minute
 face velocity should be adequate; however, the  150 feet-per-minute
 face velocity assumes a 50 percent margin of  safety.
      Minimum capture system openings are based  on  industry-supplied
 information and observations at  tire plants.30"35  Allowances are
 given for air flow through permanent openings.   For each operation,
 exhaust gas flow rates are sufficient  to maintain  VOC concentrations
 in the emission reduction  system at 25  percent  or  less of  the Lower
 Explosive Limit (LEL) of n-heptane, the compound with the  lowest LEL
 of the major exhaust gas constituents.  The need for unrestricted
 operator  access requires a sizable opening in the  capture  system
 installed on certain operations.   For  example,  tread end cementing and
 bead dipping operations may  require larger openings  in  their  capture
 systems than undertread or sidewall cementing.   In the  case of  the
 model plant manual  tread  end  cementing  and bead dipping operations,
 large permanent openings  in  the  capture system are included as  the
 operator  continually  requires a  comfortable and safe working  area,
 while adequate  face velocities are maintained.   The  capture system for
 the  model  plant automatic  tread  end  cementing operation simply  consists
                                  6-5
-------
of an enclosure with two large detachable side panels for periodic
operator access.  Consequently, larger openings will increase the
quantity of air which must be transported in order to capture and
remove the pollutants.                                         !
     The model plant flow rates reflect an approach to removal of VOCs
which is a departure from current methods described in Chapters  3
and 4.  Current methods rely on general or local ventilation for
dilution and removal of VOCs.  The capture systems used  in the model
plants are relied upon to contain VOC emissions at their source  for
transport to a control device.  The lower model plant flow rates made
possible by the capture systems may permit the use of fewer control
devices in a plant since more operations could be connected to a
single device.                                                 ;
     Control technology useful for reduction of VOC emissions from
solvent application operations in each model plant includes carbon
adsorbers, thermal afterburners, and catalytic afterburners; of  equal
importance to the use of a control system is the use of  an effective
capture system.  In many cases, tread end cementing and  bead cementing
are performed with techniques designed to minimize solvent use.  VOC
emission rates for such techniques are 10 grams or less  per tire.
Consequently, when used in conjunction with good work practices, these
techniques could be used instead of emission reduction  systems  to
minimize VOC  releases to the  ambient air.  Material substitution of
water-based sprays for organic solvent-based sprays can  be used  in
place of VOC  emission reduction systems  for green tire  spraying. The
emission reduction systems,  alternate methods  of  solvent application,
and material  substitution  are described  in Chapter  4.
6.2   BASIS FOR  REGULATORY  ALTERNATIVES                         ,
      The purpose of this section  is to  identify  regulatory  alternatives
for  limiting  VOC emissions from model  plant undertread  cementing,
sidewall cementing, tread  end cementing,  bead  cementing, and  green
tire  spraying operations similar  to  the  actual  operations  described  in
Chapter 3.  Testing has been  performed  on  one  of  the  two undertread
cementing VOC emission  reduction  systems currently  employed  within  the
tire  manufacturing  industry  (Chapter  4).   For  tire  manufacturing
                                 6-6
-------
operations where no emission reduction systems are  currently  employed,
the VOC emission capture components which meet the  requirements  of
each regulatory alternative were based on designs transferred from
applications in other industries; emission control  components which
are needed to meet the requirements of each regulatory  alternative are
substantiated by vendor quotations, literature references,  and actual
operating experiences where control components were used on exhaust
streams having characteristics similar to those of  the  model  plants.
Testing has been performed on different methods of  tread end  cement
and bead cement application in order to determine differences in VOC
emissions and whether certain application methods may be used to meet
the requirement of the regulatory alternatives.  Vendor-supplied and
tire industry-supplied information was used to compare  VOC  emissions
due to water-based and organic solvent-based green  tire spray technologies
(Chapter 4.0).
     VOCs from undertread cementing, sidewall cementing, tread end
cementing, bead cementing, and green tire spraying  can  be reduced by
the application of appropriate capture and control  components.   Due to
the various machine configurations and the availability of  different
vapor capture methods, the design of the capture component  must  be
adjusted to comply with physical limitations, such  as cement/spray
application apparatus dimensions, need for operator access, and  avail-
able space in modified or reconstructed operations.  Further,  chemical
characteristics of the solvent, such as evaporation rate and  absorption
by rubber materials, may affect capture component design.   Consequently,
physical limitations due to equipment or plant design and chemical
characteristics of the solvents employed will affect capture  efficiency.
Hence, a single capture component design may not be adequate  for all
operations.
     Based on the review of control technology in Chapter 4,  VOC
emissions captured from tire manufacturing operations are most effec-
tively reduced by adsorption or incineration.  Adsorption of  organic
vapors contained in exhaust gases is achieved by the use of activated
carbon.  Incineration of exhaust streams containing VOCs can  be  accom-
plished by two methods:   catalytic or direct-flame  afterburners.   It
                                6-7
-------
should be noted that the emission reduction systems presented in
Chapter 4 are used to delineate environmental, economic, emission
reduction cost, and energy impacts of the regulatory alternatives on
model plants:  it is not intended that any particular VOC emission
reduction/control strategy be specified.  Therefore, tire producers
would not be constrained from selecting the most appropriate method of
VOC emission reduction for their plants.
     Substitution of water for organic solvents is an alternative
method of reducing VOC emissions.  The only current application of
water-based technology is to green tire sprays, which are in wide use
throughout the tire industry.  There are no VOC emissions attributable
to many water-based green tire sprays; water-based sprays which contain
VOCs include them in such small amounts that  very low quantities are
emitted, and the use of emission reduction systems is not warranted.
     Two regulatory alternatives have been identified:
     1.  Regulatory Alternative 1-70 percent average  reduction for
VOC  emissions  from undertread cementing, tread end cementing,  bead
cementing, and green tire spraying operations (sidewall  cementing  is
not  included);
     2.  Regulatory Alternative II - 75 percent reduction of VOC
emissions from undertread cementing, sidewall cementing, tread. end
cementing, and bead cementing operations;  90  percent  reductionf of
emissions from green tire spraying operations.
      Regulatory  Alternative  I is  equivalent  to the  emission reduction
levels  recommended  in  the EPA document,  Control of  Volatile Organic
Emissions from Manufacture  of Pneumatic  Rubber Tires  (CTG).    Again,
it should be noted  that  the 70  percent  value  is the  midpoint for the
range  of emission  reductions available.   Thus, actual  emission reductions
could  deviate above or below this  value.   Regulatory Alternative II
represents  the level  of  emission  reduction achieved  with capture and
control  components  which  EPA believes  to be  adequately demonstrated while
allowing for variations  in  equipment configuration,  operator access,
 available space  in  modified or  reconstructed operations, and chemical
 characteristics  of the solvents employed.   The emission reductions to
 be met under each regulatory alternative apply to the exhaust streams
                                 6-8
-------
of the major VOC-emitting operations in tire manufacturing which  can  be
treated effectively.  Therefore, total emission reductions in  each model
plant would be less than the VOC emission reduction levels characterized
by the regulatory alternatives.  Regulatory Alternatives  I and II are
discussed in the following sections.
6.2.1  Regulatory Alternative I
     Regulatory Alternative I represents the use of emission reduction
systems to reduce VOC emissions from undertread cementing, tread  end
cementing, bead cementing, and green tire spraying operations.  Appli-
cation of these systems is detailed in the CTG.    Regulatory  Alternative  I
represents the level of control that would be in effect in the absence  .
of additional regulation.  Since few existing SIPs include regulations
which apply to rubber tire manufacturing, the regulatory  baseline for
1985 is assumed to be equivalent to recommendations in the CTQ.
     Average capture efficiencies prescribed by the CTG for operations
recommended for regulation range from approximately 65 to 85 percent:
specific capture efficiencies are dependent on the type of solvent
application activity on which the VOC emission reduction  system capture
component is installed.    It should be noted that sidewall cementing
is not affected by Regulatory Alternative I.  Expected capture effic-
iencies were reviewed in Table 3-8.  VOCs in the exhaust  stream of an
operation's capture system component could be controlled  by an after-
                                                                37
burner or carbon adsorber achieving 90 to 95 percent efficiency.
Thus, general VOC emission reductions for affected facilities  under
Regulatory Alternative I range from 59 to 76 percent.  Alternately,
green tire spraying emissions can be reduced under Regulatory
Alternative I (90 to 100 percent) by the substitution of  water-based
solvents for organic-based materials. VOC emission reductions  recommended
by Regulatory Alternative I are summarized in Table 6-4.
6.2.2  Regulatory Alternative II
     Regulatory Alternative II recommends 75 percent reduction of VOC
emissions from undertread cementing, sidewall cementing,  tread end
cementing, and bead cementing operations.  VOC emissions  from  green
tire spraying operations would be reduced by 90 percent.  Reduction of
VOC emissions from undertread cementing, sidewall cementing, tread end
                                6-9
-------
             Table 6-4.  REGULATORY ALTERNATIVES FOR THE
               TIRE MANUFACTURING INDUSTRY1"25'36*37
    Operation
Alternative I
Alternative II
Undertread Cementing
     70%
     75%
Sidewall Cementing
not applicable
     75%
Tread End Cementing
     70%
     75%
Bead Cementing
     70%
     75%
Green Tire Spraying
     70%
     90%°
 Water-based sprays used.
                                6-10
-------
cementing, and bead cementing operations  is  attainable  by  use  of
capture and control components similar to those discussed  in Chapter 4.
Water-based inside and outside green tire sprays have been  demonstrated
throughout the industry to be capable of reducing typical organic
green tire spraying emissions by 90 percent  or better.  VOC  emission
reductions recommended for Regulatory Alternative II are summarized  in
Table 6-4.
                               6-11
-------
6.3  REFERENCES

1.   Letter from R.O. Lewis, Armstrong Rubber Company, to
     D.R. Goodwin; ESED/OAQPS/EPA.  February 28, 1978.  Response to
     Section 114 letter.

2.   Letter from E.J. Burkett, The Goodyear Tire and Rubber   <
     Company, to D.R. Goodwin, ESED/OAQPS/EPA.  May 17, 1978.
     Response to Section 114 letter.

3.   Letter from R.C. Niles, Uniroyal, Inc., to D.R. Goodwin,
     ESED/OAQPS/EPA.  July 13, 1978.  Response to Section 114
     letter.

4.   Letter from R.C. Niles, Uniroyal, Inc., to D.R. Goodwin,
     ESED/OAQPS/EPA.  May 16, 1978.  Response to Section 114
     letter.

5.   Letter from R.C. Niles, Uniroyal, Inc., to D.R. Goodwin,
     ESED/OAQPS/EPA.  May 24, 1978.  Response to Section 114
     letter.

6.   Letter from R.C. Niles, Uniroyal, Inc., to D.R. Goodwin,
     ESED/OAQPS/EPA.  April 4,-1978.  Response to Section 114.
     letter.

7.   Letter from N. Onstott, Mohawk Rubber Company, to K.J. Zobel,
     ESED/OAQPS/EPA.  March 21, 1978.  Response to Section 114
     letter.

8.   Letter from R.M. Walter, The Firestone Tire and Rubber Company,
     to D.R. Goodwin, ESED/OAQPS/EPA.  May 5, 1978.  Response to
     Section 114 letter.

9.   Letter from R.M. Walter, The Firestone Tire and Rubber Company,
     to D.R. Goodwin, ESED/OAQPS/EPA.  June 7, 1978.  Response to
     Section 114 letter.

10.  Letter from J.W. Lewis, The B.F. Goodrich Company, to R.T. Walsh,
     ESED/OAQPS/EPA..  May 24, 1978.  Response to Section 114  letter.

11.  Letter from L.B. Cooper, Michel in Tire Corporation, to D;.R.
     Goodwin, ESED/OAQPS/EPA.  April 13, 1978.  Response to Section 114
     letter.

12.  Letter from R.M. Walter, The Firestone Tire and Rubber Company,
     to R.T. Walsh, ESED/OAQPS/EPA.  June 29, 1978.  Response to
     Section 114 letter.

13.  Letter from L.B. Cooper, Michel in Tire Corporation, to D.R.
     Goodwin, ESED/OAQPS/EPA.  March 13, 1978.  Response to   :
     Section 114 letter.
                                6-12
-------
14.  Letter from R.W. Frase, General Tire arid Rubber Company, to D.R.
     Goodwin, ESED/OAQPS/EPA.  May 16, 1978.  Response to Section  114
     letter.
                                    /
15.  Letter from E.J. Burkett, The Goodyear Tire and Rubber Company,
     to J.R. Farmer, CPB/ESED/OAQPS/EPA.  March 31, 1980.  Response to
     Section 114 follow-on letter.

16.  Letter from R*C. Miles, Uniroyal, Inc., to J.R. Farmer, CPB/ESED/
     OAQPS/EPA.  April 11, 1980.  Response to Section 114 follow-on
     letter.

17.  Letter from J.R. Laman, The Firestone Tire and Rubber Company, to
     D.R. Goodwin, ESED/OAQPS/EPA.  April 8, 1980.  Response to
     Section 114 follow-on letter.

18.  Letter from J.R. Townhill, The General Tire and Rubber Company,
     to K.J. Zobel, CPB/ESED/OAQPS/EPA.  April 2, 1980.  Response  to
     Section 114 follow-on letter.

19.  Letter from R.R. Clark, The B.F. Goodrich Company, to D.R. Goodwin,
     ESED/OAQPS/EPA.  March 18, 1980.  Response to Section 114 follow-on
     letter.     /          ,

20.  Letter from F.M. Luysterborghs, Armstrong Rubber Company, to  D.R.
     Goodwin, ESED/OAQPS/EPA.  March 5, 1980.  Response to Section 114
     follow-on letter.

21.  Letter from E.J. Burkett, The Goodyear Tire and Rubber Company,
     to J.R. Fanner, CPB/ESED/OAQPS/EPA.  March 21, 1980.  Response to
     Section 114 follow-on letter.

22.  Letter from L. Cooper, Michel in Tire Corporation, to J.R. Fanner,
     CPB/ESED/OAQPS/EPA.  February 19, 1980.  Response to Section  114
     follow-on letter.

23.  Letter from R.C. Miles, Uniroyal, Inc., to J.R. Farmer, CPB/ESED/
     OAQPS/EPA.  May 12, 1980.  Response to Section 114 follow-on
     letter.

24.  Letter from J.R. Laman, Firestone Tire and Rubber Company, to
     D.R. Goodwin, ESED/OAQPS/EPA.  April 17, 1980.  Response to
     Section 114 follow-on letter.

25.  Letter from R.R. Clark, B.F. Goodrich Company, to D.R. Goodwin,
     ESED/OAQPS/EPA.  April 16, 1980.  Response to Section 114 follow-on
     letter.

26.  Telecon.  Daigle, N.A., Firestone Tire and Rubber Company, with
     Aus, B., Pacific Environmental Services, Inc.  August 28, 1980.
     Procedure for estimating the quantity of sidewall cementing units
     required for model plants.
                                6-13
-------
27   A Tire Industry Analysis:  MTD's 13th Annual Facts/Directory
     Issue.  Modern Tire Dealer.  6p_(7):25-50.  January  1979.

28.  Year End Report:  Rubber in 1968 - A Complete Recovery.   Rubber
     World.  159(4):29-48.  January 1969.

29.  1979 Tire Industry Facts - Modern Tire Dealer. 61(2):25-33.
     January 1980.

30.  Letter from J.R. Laman, The Firestone Tire and Rubber  Company, to
     R.T. Walsh, ESED/OAQPS/EPA.  June 14, 1979.  Comments  onjcapture
     systems for the manufacturing facilities.

31.  Letter from E.J. Burkett, Goodyear Tire  and  Rubber  Company, to
     K.J. Zobel, CPB/ESED/EPA.  May 14, 1979.  Hydrocarbon  emission
     information related to future tire plants NSPS.

32.  Letter from F.M. Luysterborghs, Armstrong Rubber Company:, to  B.
     Aus, Pacific Environmental Services,  Inc.  January  9,  1980.
     Enclosure design of undertread cementer  operation.       ;

33.  McAdams, M.T.  Trip Report:  Armstrong Rubber Company, West
     Haven, Conn.   September  25, 1979.

34.  McAdams, M.T.  Trip Report:  Firestone Tire  and  Rubber Company,
     Wilson, North  Carolina.   September  13,  1979.

35.  McAdams, M.T.  Trip Report:  Kelly-Springfield Tire Company,
     Fayetteville,  North Carolina.  March  18, 1979.   (Confidential
     file.)                                                   ;
                                                              I   --  .'
36.  Fundamentals Governing  the Design  and Operation  of  Local Exhaust
     Systems.   American  National Standards Institute.  New Yqrk, New
     York.   Publication  No.  ANSI Z9.2-1971.   1972.   63 pp.

37.  Zobel,  K.J.  and  N.  Efird.   Control  of Volatile  Organic Emissions
     from Manufacture of Pneumatic  Rubber Tires.   U.S. Environmental
     Protection Agency.   Research Triangle Park,  North Carolina.
     Publication No.  EPA-450/2-78-020.   December 1978.  59 pp.
                                 6-14
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                        7.0  ENVIRONMENTAL IMPACT

     This chapter presents an environmental impact assessment of the
regulatory alternatives discussed in Chapter 6.  The assessment includes
primary, secondary, and incremental impacts associated with air quality,
water quality, energy use, and solid waste disposal.  Noise impacts,
urban and community impacts, irreversible and irretrievable commitment
of resources, and the impact of delaying implementation of the standard
are also discussed.
     Projected 1985 VOC emissions from operations to be included in
standards of performance in tire manufacturing plants under Regulatory
Alternative II are about 1,700-megagrams (1,880 tons), or about 50 percent
less than projected new plant VOC emission levels in the absence of
additional regulation (Regulatory Alternative I).  Secondary pollutant
emissions due to the use of afterburners or boilers for steam stripping
carbon adsorber beds are anticipated to be minimal.  Projected water
pollution and solid waste disposal impacts are minimal in comparison to
the large contribution of liquid and solid wastes from operations not
related to VOC emission reduction in tire plants.  The energy impact due
to the use of VOC emission reduction systems is anticipated to be minor.
Projected noise, urban, and community impacts due to implementation of
any regulatory alternative are expected to be minimal.  No irreversible
or irretrievable commitments of resources are expected to be incurred
under the regulatory alternatives.  Detailed discussion of the environmental
impacts is presented in the following sections.
7.1  AIR POLLUTION IMPACT
7.1.1  Primary Air Pollution Impact
     The primary air pollution impact of each regulatory alternative is
determined by comparison of projected VOC emissions from plants operating
under Regulatory Alternative II in 1985 to projected VOC emissions
                                  7-1
-------
from plants operating during 1985 with no additional regulations  (Regulatory
Alternative I).  In order to analyze the incremental primary air  quality
impact of Regulatory Alternative II over Regulatory Alternative I,  average
annual model plant VOC emission rates under each regulatory alternative were
determined and then used £o project fifth-year  (1985)  impacts  on  national
air quality.
     7.1.1.1  Determination of Annual Uncontrolled Model  Plant VOC
Emission Rates.  Annual uncontrolled VOC emission rates  for each  model
plant size were determined using the following  equation:
                  A1u -
                                   n
1 megagram
  <*
10  grams
(1)
     where A.  is the annual uncontrolled  VOC  emission  rate  of
               model plant  i in megagrams  (i = 15,000,  30,000; or
               50,000 tires per day);
           B-  represents the  daily  tire production  rate for model
               plant;
           C   is the number of days per year  that the  model  plant is
               expected  to  operate (269 days per year);1"14
           D   represents the..average total  uncontrolled emission factor
               per  completed tire (308.4 grams per tire).
Therefore, the annual uncontrolled emission  rates for a 15,000, 30,000
and  a  50,000  tire per day model plant are  1,244 Mg (1,372 tons), 2,489 Mg
(2,743 tons), and 4,148  Mg  (4,572 tons),  respectively.   The  daily model
plant  tire production rates and plant operating schedule in  equation
(1)  were  derived from industry-supplied  information and are  discussed in
detail  in Chapter  6.  The average uncontrolled emission factor of
308.4  grams  of VOC  per  tire represents the sum of the average;emission
factors for  all  VOC-emitting  operations  in a model tire manufacturing
plant; this  value  does  not  include emission  reduction contributions due
to  the use of water-based green  tire sprays.
     7.1.1.2 Determination of Annual Model  Plant VOC Emission Rates
Under  Each Regulatory Alternative.  Annual VOC emission rates for model
plants designed  to  comply with Regulatory Alternatives I or II are
calculated using the equation:
                                   7-2
-------
                  •
1 megagram
10  grams
                                                                    (2)
     where A., is the annual VOC emission rate from model plant  i
               in megagrams (i = 15,000, 30,000, or 50,000 tires per
               day), which uses an emission reduction system to meet
               the level of VOC emission reduction recommended under
               Regulatory Alternative j (j = I or II);
            B. represents the daily tire production rate for model
               plant i;
            C  is the number of days per year that the model plant
               is expected to operate  (269 days per year);
                                                          1-14
            D. represents total VOC emissions per completed tire
               under Regulatory Alternative j.
The total per-tire VOC emission factor for each regulatory alternative
was derived from the relationship:
            D. = z[grams of VOC per tire from each operation that  is
                  affected by Regulatory Alternative j]  (1-E.) + z[grams
                                                            J
                  of VOC per tire from operations not controlled under
                  Regulatory Alternative j]                           (3)
E. is the VOC emission reduction efficiency recommended  for Regulatory
Alternative j.  Ej represents an average reduction of 70 percent for  VOC
emissions from undertread cementing, tread end cementing, bead cementing,
and green tire spraying.  Sidewall cementing is not included in E,.   Ej,
represents a 75 percent reduction in VOC emissions from  undertread
cementing, sidewall cementing, tread end cementing, and  bead cementing;
green tire spraying emissions are reduced by 90 percent.  Therefore,
223.8 grams of VOC per tire are available from operations to be controlled
under Regulatory Alternative I; 264.9 grams of VOC per tire (of which
137.2 grams are from green tire spraying) are available  from operations
controlled under Regulatory Alternative II.
     The quantity of VOCs from operations that are not controlled  change
with each regulatory alternative.  Operations not controlled under
Regulatory Alternative I include sidewall cementing, tire building,
finishing, curing, compounding, milling, extrusion, and  calendering.
Operations whose emissions are not controlled under Regulatory
Alternative II include tire building, finishing, curing, compounding,
                                  7-3
-------
milling, extrusion, and calendering.   VOC  emissions  from  operations  that
are not controlled under each  regulatory alternative are  84.6 grams
per tire (Regulatory Alternative  I) and 43.5  grams per  tire  (Regulatory
Alternative  II).  Therefore, the  total per-tire  VOC  emission  factor
(including residual and uncontrolled  emissions)  for  Regulatory Alternative I
                                                                        1 OC
(D.) is 151.7 grams and 89.1 grams for Regulatory Alternative;II  (Dj,).
     Annual VOC emissions from 15,000, 30,000, and 50,000 tire per day
model plants operating under Regulatory Alternative  I are 612 Mg  (675 tons),
1,224 Mg (1,349 tons), and 2,040  Mg (2,249 tons), respectively; annual
VOC emissions from each size of model  plant operating under Regulatory
Alternative  II are 360 Mg (349 tons),  719  Mg  (793 tons),  and  1,198 Mg
(1,321 tons).  The annual VOC  emission rates  for each model plant size
are tabulated for each regulatory alternative and compared to :the respective
model plant's uncontrolled VOC emission rates in Table  7-1; VOC emission
reductions beyond uncontrolled emissions are  also presented.   ^Overall
emission reductions for model  plants  employing VOC emission reduction
                                                               i
systems on the appropriate operations  are  approximately 50 percent under
Regulatory Alternative I and 70 percent for Regulatory  Alternative II.
These values do not directly reflect  the percent VOC emission reduction
suggested for appropriate operations  under each  regulatory alternative,
as uncontrolled VOC emissions  from operations not affected by the regulatory
alternatives are included.                                     i
     7.1.1.3  Year 1985 Impact of Regulatory  Alternatives on  VOC  Emissions.
                                                               i         T-T---1-.—
In order to project the future impact  of the  regulatory alternatives on
air quality, two scenarios (Regulatory Alternatives  I and II) were
constructed.  Year 1985 baseline  emissions under Regulatory Alternative I
were then compared to emissions projected  for 1985 under  Regulatory
Alternative  II.  In order to estimate  annual  baseline VOC emissions  from
tire plants for 1985, the level of emission reduction for operations
affected by Regulatory Alternative I  in all plants was  assumed to be
equivalent to the average level of emission reduction recommended in the
EPA document, Control of Volatile Organic  Emissions  from  Manufactureof
                                                              __-
Pneumatic Rubber Tires (CT6).     Under Regulatory Alternative ;II, all
plants which have new, modified,  or reconstructed operations  in place
between 1980 and 1985 would reduce VOC emissions to  the extent recom-
mended by Regulatory Alternative  II;  the extent  of emission reduction in
                                  7-4
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all plants with.no new, modified, or reconstructed operations would  be
to the level described for Regulatory Alternative I.   For the purposes
of this primary air pollutant impact assessment, plants were assumed to
have either all new, modified, or reconstructed operations, or  existing
operations only.  Further, plants having  new, modified, or  reconstructed
affected operations will be referred to as  "new" plants and all  others
as "existing plants."
     VOC emissions for year 1985 were projected through the equation:
               Aj  = x
                                "xj
1 meg ag ram
10  grams
                                                                      (4)
       where:
               A-  is the total  amount of VOC emitted under Regulatory
               Alternative j (j - I or II)
               B  is the daily quantity of tires manufactured during
               1985 in plant type x (x = existing or new);
               C is the annual  average number of plant operating
               days (269 days/year);1"25
               D . is the total per tire VOC emission factor for plant
               type x under Regulatory Alternative j (j = I or II;
               x = existing or new).
The overall growth rate of tire production for the 5-year period,  1980
to 1985, was determined in order to calculate the 1985 daily production
rates of new and existing plants.  The overall annual growth rate  for
tire production was extrapolated from the annual growth rates for  original
equipment and replacement market tire production in  conjunction with  the
proportion of total production devoted to each market.  The annual
growth  rates of the original equipment and  replacement markets are
2 percent and 1 percent,  respectively; the  average  original equipment
share is 30 percent of  the  total market.  7   Thus, an average annual
growth  rate of  1.3  percent  is  projected  for the  domestic  tire  industry.
The average annual  growth rate is  then multiplied by the  January  1,
1980, daily tire  production  value  (984,100)  to  produce  the  total  1985
daily tire production rate.28   The apportioning  of  production :for existing
plants  and new  plants was determined  by  assuming that  3.78 x  10   radial
tires per year  (140,520 tires  per  day) will  be  produced  by  new'piants,
while older bias  plants are closed (refer to Chapter 9.0 for  further
                                    7-6
-------
discussion of the radial tire value).  Thus, daily  tire  production rates
for existing plants and all new plants are  projected  to  be  909,230 and
140,520 tires per day, respectively.
     Each total per-tire VOC emission factor (DX^)  calculated  using
equation (3) represents per^tire emissions  from  existing  and new plants.
All undertread cementing, tread end cementing, and  bead  cementing operations
of existing plants would have 70 percent efficient  VOC emission  reduction
systems installed; green tire spraying operations not using water-based
sprays would also use 70 percent efficient  VOC emission  reduction systems.
For the purposes of projecting primary air  pollution  impacts,  the proportion
of existing plants using water-based green  tire  sprays in 1985 is assumed
to be the same as year 1979 non-attainment  area  water-based green tire
spray consumption.  Under this assumption,  82 percent of  all existing
tire production would use inside water-based green  tire  sprays;  54 percent
of all existing tire production would use outside water-based  sprays.15"25
Therefore, the total per-tire VOC emission  factor for existing plants  is
134.2 grams (0.296 Ib) per tire.  Under Regulatory  Alternative I,  all
new plants would reduce VOC emissions to the extent recommended  in the
    26
CT6.    Further, the proportion of new production that uses water-based
green tire sprays in 1985 is assumed to be  equivalent to  the nationwide
proportion of tire production that used water-based sprays  in year 1979
(82 percent of all inside sprays, 54 percent of  all outside sprays
used).  Therefore, the total per-tire VOC emission  factor for new plants
under Regulatory Alternative I is 134.2 grams (0.296  Ib)  per tire.  Year
1985 annual VOC emissions from new plants under  Regulatory Alternative I
are projected to be 5,073 megagrams (5,592  tons); total annual emissions
for year 1985 are estimated to be 37,896 Mg (41,773 tons).
     The total  per-tire VOC emission rates  for all  existing plants
remain constant under Regulatory Alternative II; the  levels of VOC
emission reduction recommended under Regulatory  Alternative II yield a
new plant total per-tire emission factor of 89.1 grams (0.196 Ib)  per
tire.  Therefore, year 1985 annual VOC emissions from new plants  operating
under Regulatory Alternative II are projected to be 3,368 megagrams
(3,713 tons) per year; total annual  emissions for year 1985 are  estimated
to be 39,191 megagrams (39,899 tons).
                                  7-7
-------
     An inventory of estimated 1985 VOC emissions from existing plants
and new plants under Regulatory Alternatives I and  II is presented  in
Table 7-2.  Average VOC emission reductions attributable to Regulatory
Alternative II are 1,705 megagrams  (1,879 tons): this represents  a
50 percent decrease in emissions from  all new plants and a 5  percent
reduction from nationwide baseline  emissions.  The  small difference in
percent VOC reduction between  the nationwide baseline  (Regulatory
Alternative I) and Regulatory  Alternative II emissions  is due to  the
large proportion of VOC emissions contributed by existing plants  and  the
wide, voluntary use of water-based  green tire sprays.          :
7.1.2  Secondary Air Pollution Impact
     Secondary air pollutants  are those emissions  which are  not usually
associated with an uncontrolled facility, but which result  from the use
of  pollution  control equipment.  VOC  emission control  equipment which
may be  incorporated  into  model plant  VOC emission  reduction  sy$tems
include  carbon  adsorbers  or afterburners.                      ;
     Secondary  air  pollution problems  due to the use of carbon; adsorption
by  the  manufacturers  are  expected  to  be minimal.  Odorous and irritating
gases may be  emitted  if the VOC stream contacts the carbon bed before it
 is  adequately cooled  following desorption.29  Following proper procedures
while  regenerating  the carbon beds  should eliminate thermal  decomposition
 of VOCs.  Secondary air pollutants  generated by the boiler used  in
 producing steam for carbon bed desorption include particulates,  sulfur
 oxides (SO ), carbon monoxide, incomplete combustion products, and
 nitrogen oxides (NO ).  Particulate and sulfur  oxide emissions from fuel
 combustion are regulated by State  Implementation Plans  (SIPs) ;which
 follow the guidelines set  forth in EPA regulations on  the Preparation  of
 Implementation Plans [40 CFR  51].30   These guidelines  provide ifor  parti-
 culate and SO  emission reduction  through exhaust  gas  treatment.   An
 alternative method for S02 emission control is  the combustion  of low
 sulfur fuels.30  Provided  exhaust  gas treatment,  low  sulfur  fuels  oil,
 or  natural gas is used, the amount of particulate  and  S0x emissions
 generated during steam stripping of the carbon  beds should  be'minimal  in
 relation to  the magnitude  of  VOC emission  reductions.   Depending on the
 model plant  size and regulatory alternative  involved,  annual N0x emissions
 due to  steam stripping of  carbon beds are  estimated  to range from
                                    7-8
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approximately 0.3 megagrams (0.3 tbns) to 1.9 megagrams  (2..1 tons).  NOX
emissions are calculated by multiplying the annual fuel  requirements of
the boiler under each regulatory alternative  (Sections 7.4 and 8.1) by
the NO  emission factor of 2.8 kilograms per  1,000 liters of distillate
oil (22 pounds per 1,000 gallons).31  Annual  NOX emissions from boilers
used for steam stripping carbon adsorber beds in model plants are  presented
as Table 7-3.                                                  :
     Afterburner exhaust may contain  some secondary  pollutants.  Excessive
NO  emissions in the afterburner exhaust may  be due  to several factors,
but the problem can be mitigated.  A  discussion of NOX emissions associated
with afterburner use is presented  in  Chapter  4.  Annual  N0x emissions
from afterburner exhaust of model  plant VOC emission reduction systems
are estimated to range from 12.9 megagrams  (14.2 tons) to 44.0 megagrams
(48.5 tons); the amount depending  on  the model  plant size, afterburner
type, and regulatory alternative involved.3   Annual N0x anissions from
model plant  afterburner control components  are  presented as Table  7-4.
Incomplete combustion of VOCs  passing through the  afterburner may  create
a  larger nuisance than the original  substance:   incompletely  combusted
hydrocarbons may be more potent smog  precursors  than the VOCs used at
the tire plant.  If the afterburner  is  designed to achieve 95 percent
removal efficiencies and is maintained  properly,  partially combusted
VOCs should  not be emitted.   Sulfur  and  halogens  in  the  exhaust  stream
                                              32
can produce  SO  and noxious gases  when  burned.     Existing SIPs  should
require the  use of low sulfur fuels  or treatment of  afterburner
exhaust streams that are contaminated  with sulfur or halogen compounds,
thereby negating S0x pollution problems.
     Secondary  air pollutants from VOC emission reduction  systems  are
not expected to be significant,  especially when compared to  the  contri-
bution of  pollutants from  other operations in the plant.  Fuel;combustion
for VOC  emission  reduction systems represents less  than  1  percent of a
model  plant's  total  fuel  demand (Section 7.4).   If  all'combustion
facilities  in  a plant were to use similar fuels, secondary pollutant
emissions  from VOC emissions  reduction systems  would be expected to
 increase  total  plant emissions by less than 1 percent.   Secondary air
pollutant  impacts  are  also not expected to be significant when; considering
                                   7-10
-------
           Table 7-3.  ANNUAL NITROGEN OXIDES  (NO  ) EMISSIONS

        FOR BOILERS USED ON CARBON ADSORBERS IN MODEL PLANTS31
Model
Plant
Size
Tires/Day
15,000
30,000
50,000
Annual
Regulatory Fuel Requirement
Alternative liters (gallons)
I
II
I
II
I
II
217,000
132,000
433,000
264,000
721,000
439,000
(57,300)
(34,900)
(115,000)
(63,900)
(191,000)
(116,000)
Annual .
NO Emissions0
megagrams (tons)
0.6
0.4
1.2
0.7
2.J
1.2
(0.7)
(0.4)
(1.3)
(0.8)
(2.2)
(1.4)
aNo. 2 oil  heating value:  3.95 x 10"2 gigajoules/liter (141,850 Btu/gallon),

 NO  emission factor:   2.8 kilograms NO /1000 liters (22 pounds NO /
   x                   1000 gallons)   x                          x
                                  7-11
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the extent of VOC emission reduction achieved by the carbon  adsorbers  or
afterburners; on a mass basis, secondary air pollutant emissions  are
estimated to be 1 percent or less than emissions from uncontrolled
operations.
7.2  WATER POLLUTION IMPACT
     The impact of the VOC emission reduction systems on  water  quality
is presented in this section.  Afterburner components used  in the VOC
emission reduction systems are not expected to  use  or discharge water.
Therefore, the water impact of afterburners is  negligible.   The water
impacts of emission reduction systems useing carbon adsorbers are.
determined by quantifying the effluents  and constituent  pollutants  that
are discharged from the VOC reduction systems employed  in the model
plants under each regulatory alternative.  The  effluent  values  determined
for each alternative are  then compared to  the total process and nonprocess
wastewater characteristics in order to determine  the significance of  the
additional wastewater  streams.   Applicable water  pollution regulations
are reviewed to determine if pollutants  discharged  in  the adsorber
effluent will adversely affect plant  compliance with existing discharge
limits.  Where applicable, control  techniques which would mitigate  water
pollution  impacts are  discussed.  No  unavoidable  impacts due to discharge
of carbon  adsorber effluent could  be  characterized; consequently,
unavoidable  water impacts are not  discussed.   Finally,  pollutant  dis-
charges associated with each  regulatory  alternative are extrapolated  to
estimate their contribution  to  the tire  industry's  fifth-year water
pollution  impact.
7.2.1  Characterization of Model Plant Wastewater Discharges
      In order  to  assess the  water pollution  impact associated with
Regulatory Alternatives  I and  II,  data  pertaining to the quantity and
quality of wastewater  streams  generated  by an uncontrolled entire plant
were  collected.   Table 7-5  characterizes the baseline wastewater dis-
charges for plants  in  operation  since 1959.33~3   Values presented in
Table 7-6  were converted  from reported  values by assuming:
      •  1,055  kilograms  of  raw materials are used to manufacture
                                             34
         1,000  kilograms  of  finished product;
                                   7-13
-------
              Table 7-5.  WASTEWATER CHARACTERISTICS FOR

                     A TIRE MANUFACTURING PLANT NOT

                       EMPLOYING VOC CONTROLS33'3
Wastewater Flow

Pollutant Load:

  Chemical Oxygen Demand (COD)
  Suspended Solids (SS)
  Total Dissolved Solids (TDS)
  Oil and grease
126.3 liters (33.4 gallons) per tire
7.0 grams (0.015 pounds) per tire
3.7 grams (0.008 pounds) per tire
66.6 grams (0.147 pounds) per tire
0.5 grams (0.001 pounds) per tire
Includes utility wastewaters.
                                  7-14
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                                                1-14
     •  the representative tire mass is 11.5 kg.               :'
     A typical tire plant generates 126.3 liters  (33 gallons)  of wastewater
for each tire produced.33  Noncontact heating and codling  represent  the
                                  oo         !
majority of the water requirement.    Discharges  from  service  utilities
and other nonprocess facilities substantially contribute to  pollutant
loading.33  Intermittent process wastewater discharges include;production
equipment effluent, washdown of processing areas, runoff from  raw material
storage, and spills or leakage of organic solvents, lubricating oils,
and miscellaneous solutions used in tire manufacturing.
7.2.2  Water Pollution Impact of the Regulatory Alternatives
     Increased wastewater flows and pollutant loadings due to  the  use  of
carbon adsorbers and water-based solvent green tire sprays for VOC
emission reduction are discussed below.
     Total VOC emissions that are available from  operations  under  each
of the regulatory alternatives were previously estimated  to be: 223.8 grams
per tire for Regulatory Alternative  I and  127.7 grams  peSr  tire for
                          1 ?5
Regulatory Alternative II.     - The VOC emission  reduction system
efficiencies  are expected to be 70  percent  for Regulatory  Alternative I
and 75 percent for Regulatory Alternative  II;  green  tire  spray|ing  is not
included in this section of the Regulatory  Alternative II  impacts  as the
operation does not employ an emission  reduction  system.  Solvent recovery
from the carbon  adsorber control  component was  assumed to be approximately
99 percent  efficient.  Therefore,  overall  solvent recovery efficiencies
from the VOC  emission  point to  decanting  of recovered solvent are
approximately 70 percent for Regulatory Alternative I and 75 percent for
Regulatory  Alternative II.  Multiplying a steam requirement of 4.0 kilograms
of  steam per  kilogram  desorbed  VOCs (4 pounds of steam per pound of
desorbed VOCs)35 by  the  affected  facilities'  available VOC emission
factor and  the average VOC  emission reduction efficiency for each regulatory
 alternative yields  the average per-tire wastewater discharges associated
with each  level  of VOC emission reduction.  The wastewater discharges
due  to air pollution control  are converted from mass  values to volume
 using  the  density  of water (1.0 gram per cubic centimeter)  and are
 presented  in  Table 7-6.   Fifth-year water pollution impacts of Regulatory
 Alternative I appear to be greater than the impacts of Regulatory
 Alternative II:   emission  reduction systems are employed  for  organic
                                   7-16
-------
solvent-based green tire spray operations  under  Regulatory Alternative I;
no emission reduction systems are needed for  the water-based  sprays.
The additional wastewater generated by  the carbon adsorber component
under each regulatory alternative represents  less than  1.0 percent of
the total wastewater discharge attributable to tire  production  and
nohprocess operations.
     Pollutants contained in the carbon adsorber effluent following
solvent decanting are expected to be minimal  as  approximately 98 percent
by volume of the solvents used by the tire manufacturers  are  virtually
                   •IOC OC
insoluble in water. "  '    The vapor pressures  of the  specific solvents
used in tire production indicate that most of the solvent that  escapes
decanting will volatilize after discharge  from the adsorber.  Therefore,
the wastewater impact due to employment of a  carbon  adsorber  as the VOC
emission reduction system control component is minimal.   The  water
solubilities and vapor pressures of solvents  used for the facilities
recommended for regulation are summarized  in  Table 7-7.
     Water pollution impacts due to the use of water-based green tire
sprays are expected to be minimal:  all water applied to  the  tires
during spraying evaporates.    Most wastewater from  green tire  overspray
is expected to evaporate since small quantities  of green  tire spray
(less than 50 grams per tire) are applied.
7.2.3  Applicable Water Pollution Regulations
     The EPA Effluent Guidelines for Water Quality Standards  [40 CFR
428] apply limitations to total suspended  solids,  oil/grease, and pH
discharge in effluents from rubber tire manufacturing plants.     The
effluent limitations are presented as Table 7-8.   Since the use of
proposed VOC emission reduction systems is  anticipated  to have  only a
minimal  impact on the total plant process  and nonprocess  wastewater
burden, the regulatory alternatives probably  will  not be  affected to  a
great extent by 40 CFR 428.  In the event  that toxic or nonconventional  .
(nondegradable) substances are discharged  in  the, carbon adsorber effluent,
the Pretreatment Standards for New Sources  [40 CFR 128 and 403] will
      43 44
apply.   '    It is not expected that carbon adsorber wastewater will
contain toxic or nonconventional  substances;  therefore, the pretreatment
                                        1  /">'
standards will not be further discussed.
                                  7-17
-------
       Table  7-7.
SOLVENT VAPOR  PRESSURES
RILITY IN UATERl-l4»db
AND
                 SOLUBILITY IN  WATER
Solvent
Naphtha
n-Heptane
n-Hexane
Toluene
Isopropanol
Othersb
Proportion of Solvent
Used by the Tire Industry
(Percent by Volume) •
90
6
2
1
1
Vapor Pressure
(mm Hg)
40-100 @ 20°C (68°F)
40 @ 22°C (72°F)
100 @ 16°C (60°F)
20 @ 18"C (65°F)
40 @ 24°C (75°F)
Solubility
In 100 Parts Water
i ,
0.005 @ 15°C (60°F)
0.014 @ 15°C (60°F)
0.05 @ 15°C (60°F)
S
 i 3 insoluble
 S = totally soluble
bOther solvents used by the tire industry include:
   Trlchloroethene
   Tetrachloroethane
   Pentachloroethane
   Carbon tetrachloride
   Xylene
   Kerosene                               '
   Diethyl Ether
   Gasoline
                          7-18
-------
                   Table 7-8.  U.S.'ENVIRONMENTAL PROTECTION AGENCY
                    EFFLUENT LIMITATIONS FOR RUBBER PROCESSING4^
          EFFLUENT CHARACTERISTICS
                                                         EFFLUENT LIMITATIONS
                                              One-day maximum
                         Daily average
Total Suspended Solids
 Kilograms per megagram (pounds per 1000
 pounds of raw material
Oil/grease
 Kilograms per megagram  (pounds per 1000
 pounds) of raw material
PH
0.096
0.024
6.0-9,0
0.064
0.016
6.0-9.0
            a.  For 30 consecutive days.
                                              7-19
-------
     The use of carbon adsorbers as the control component  of  the VOC
emission reduction system is not anticipated to significantly increase
the discharge of waterborne pollutants into the environment.   The major
constituents of the model plant wastewater stream are contributed by
operations other than air pollution control.  Therefore,  if a new plant
is constructed with the Best Available Technology Economically, Achievable
(BATEA) to treat process and nonprocess wastewater  streams, the plant
should continue to meet water quality standards when wastewater increments
from the carbon adsorber control component of the VOC emission reduction
system are included.  .
7.2.4  Pollutant Discharge Treatment Techniques
     Pollutants recovered from the carbon adsorber  can  be  removed from
the condensed steam by using an aspirator or a mechanical  decanter.
Once the solvents are recovered to the fullest extent practical, the
water may be discharged into an oil-water wastewater separator; with
effluent from other portions of the plant.    Engineering  judgment
indicates that the few VOCs remaining in the decanting  water  will
volatilize or be removed by the wastewater separator.
7.2.5  Projected Fifth-Year Water Quality Impact               ,
     The small quantities of water from carbon adsorbers  and  low
solubility of the recovered compounds in the wastewater from  the carbon
adsorber control component is anticipated to have only  a minimal effect
when it is combined with the large volume of wastewater and mass of
pollutants generated by process and nonprocess operations  in  the tire
plant.  VOC emission reduction systems that employ  afterburner control
components are not expected to use or discharge water.  Therefore, the
fifth-year water pollution impact of the proposed regulatory  alternatives
is expected to be minimal.
7.3  SOLID WASTE DISPOSAL IMPACT
     The quantity of solid wastes generated by existing tire  manufacturing
practice amounts to approximately 5.5 percent of the total weight of
product or 167.4 megagrams (184.5 tons) per year for the  tire
industry.     '    The components of these wastes include  rubber, metal,
                                         34
textile material, and nonprocess rubbish.    The sources  and  relative
magnitudes of each solid waste component are listed in  Table  7-9.
                                   7-20
-------
          Table 7-9.   SOLID  WASTES  DUE TO TIRE MANUFACTURING34
            Weight
            Percent
Material    of Total
                             Source(s)
Rubber
Metal
20
20
Textiles       10

Rubbish        50
Tires rejected during quality control,  experi-
mental and test products,  in-process trimmings,
curing bladders, and molding waste

Defective material and trimming from wire  bead
preparation and steel cord and belt processing

Fabric cord and belt in reject tires  .

Contaminated raw material containers
                                  7-21
-------
     Rubber wastes from tire manufacturing are currently disposed  of  in
sanitary landfill, by shipment to reclaiming operations, or  recycled  for
use as raw material in low-quality goods; the latter  technique  is  limited
by product mix.34'45'46  Scrap metal is handled by general collection
measures and hauled to available dumping locations, as  is  the case for
paper and wood waste and textile material in reject tires.    Defective
textile fabric, trimmings, and uncured tire carcasses are  often sold  to
                                                                       34
scrap dealers for distribution to the mechanical  rubber goods industry.
     A potential adverse impact on solid waste disposal associated with
the proposed regulatory alternatives is the handling  of spent carbon
from adsorption systems.  Typically, the weight of the  carbon bed  can be
determined by the equation:
                              M.. =  (K.. • T)                   :       (5)
          where M.. is the carbon weight per bed  (in  megagrams)
                    for model plant  i and Regulatory  Alternative j
                    (i = 15,000, 30,000, or 50,000 tires per d^y)
                    (j = I or II);                             ;
                K.. is the exhaust gas flow rate  (in  cubic feet
                  IJ
                    per minute for model plant i  and           ;
                    Regulatory Alternative j;                  ;
                T   is the ratio of  carbon to flow rate, equal
                    to 0.5 pounds carbon per cubic feet per  minute of airflow.
Three carbon beds  are considered necessary to handle  the model! plant's
facilities exhaust flow while adequately treating VOC emissions throughout
the plants' operating hours.    Thus M.., the weight  of the  carbon bed,
is tripled in order to arrive at the total amount of  carbon  required  for
the VOC emission  reduction system used  in the model plants under each
regulatory alternative.  Activated carbon has an  average useful life  of
           or                                                  ;
five years,   thus M.. is divided by five to obtain annual carbon  disposal
                     • W                          ,               :
requirements for  each model  plant.   The  activated carbon disposal
requirements for  the model plants under  each regulatory alternative are
presented  in Table 7-10.
     Fifth-year impacts on solid waste  disposal  are expected to be
minimal.  The increase in model plant solid waste due to employment
of carbon  adsorption is expected to  be  insignificant  (less than
0.003 percent).   Table 7-11  summarizes  the waste  disposal  impacts  of  the
proposed regulatory alternatives.
                                  7-22
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      Spent  activated  carbon  can be disposed of in at least two ways:
 incineration  and  sanitary  landfill.47  Incineration has the ability to
 significantly reduce  the volume of solid waste generated, but may create
 potential air pollution problems through release of incomplete combustion
 products.   Liquid waste due  to  exhaust gas  scrubbers employed on the
 solid waste incinerators may also pose problems.     Sanitary landfill
 probably represents the most desirable method  for spent carbon disposal.
 Proper solid  waste disposal  procedures will  restrict water movement
 through the adsorbant and  migration of adsorbed materials into the
 groundwater,  thereby  mitigating potential groundwater pollution due to
 solid waste disposal.                             .
 7.4  ENERGY IMPACT
 7.4.1  Total  Process  and Nonprocess Energy  Consumption
     Tire manufacturing plants  consume energy  for tire production and
 nonprocess  applications in the  form of electricity,  fuel  oil,  natural
 gas, and occasionally, coal.  Mechanical  energy is  required for pro-
 cessing equipment such as  the compounders, mills,  calenders,  and extruders.
 Thermal energy is employed for  drying  dipped fabric,  as well  as molding
 and curing  tires.  Plant lighting  and  ventilation  represent nonprocess
 energy consumption.
     Industry-supplied information  was  used to  estimate total  1977
 energy consumption by tire manufacturing  plants.1"14  The total  annual
 energy consumption is presented  as  Table  7-12.  Average heating values
 used to convert the various  energy  sources to a standard  unit  include:
     natural gas - 3.14 x 10"5  gigajoules/meter3  (1,050 Btu/ft3);
     coal  (national  average) -  3.15 x  10   gigajoules/kilogram
          (13,530 Btu/lb);
     No.  2 fuel oil  - 3.95 x 10"2 gigajoules/liter  (141,850 Btu/gal);
     No.  5  fuel oil  - 4.13 x 10"2 gigajoules/liter  (148,100 Btu/gal);
     No.  6  fuel oil  - 4.22 x 10"2 gigajoules/liter  (151,350 Btu/gal);
     propane - 2.55 x 10"  gigajoules/liter (91,500 Btu/gal).34
Total  1977 energy consumption for reporting tire plants was 1.34 x  109
gigajoules per. year.   2.1 x  10  tires were produced by  these plants  in
     48
1977;   thus,  the average amount of energy consumed to  produce  a tire is
                                ,• 7-25
-------
           Table 7-12.   1977 TIRE  INDUSTRY
              ENERGY  CONSUMPTION
                                 ,1-14,48
Plant Code
A
B
C
' D
E
F
G
H
I
J
K
L
M
N
0
P
Q
R
S
T
U
V
w
1977 Energy
Consumption
(gigajoules per year)
2. 52x1 O6
2. 04x1 O6
1.17x106
l.SlxlO6
2. 40x1 O6
5.55xl05
7. 26x1 O5
1.65xl06
1.66x106
1.55xl06 •
6. 22x1 O8
9. 92x1 O5
2.56xl05
5.16xl05
5.67X105
2.35xl05
C
5.86X1011
C " , -•
5.33x10° '
l,57x!05
7.51xl04
1.63X106
1.06xl09
6.01xl05
Plant Code
X
Y
Z
AA . .
BB
CC
DD
EE
FF
GG
HH
II
JJ
KK
LL
MM
1977 Total3






1977 Energy :
Consumption |
(gigajoules per year)
l.lOxlO6
1.09xl06 '
1.43X106 ;
1.38xl06
7.01xl05
8. 77x1 05
l.OSxlO6
1.33xl06 :
4. 06x1 O5
l.SlxlO6 ,
1.75xl08
i.gixio5 ;..
2.73xl06 '!
1.46xl06
2.09xl05
1.47x1 O5
1.38xl09



1 •
;-.••-

Represents reporting tire plants only.
                           7-26
-------
6.7 gigajoules.  This value represents an average value  and does not
reflect the actual amount of energy consumed to produce  any specific
type or size of tire.  The energy required to produce a  tire  in 1980  is
not expected to change as most plants included in the 1977 energy  use
                                                 8
survey are still in operation.  Thus, if 2.7 x 10  tires  are  produced in
1980,   the total annual tire industry demand without air pollution
                                               9
controls installed is estimated to be 1.78 x 10  gigajoules.
7.4.2  Energy Requirements for VOC Emission Reduction Systems
     The energy requirements for the VOC emission reduction systems can
be divided into electrical and fuel demands.  Electricity demands  for
the emission reduction systems are due to the energy required to run
fans, pumps, and the control panel.  Fuel is required to produce steam
to regenerate carbon beds in the adsorber control component and to
incinerate VOCs in the afterburner control component.
     Electrical requirements of the VOC emission reduction systems were
                                                               34  49-51
calculated from System design parameters and vendor quotations.   '
In-depth discussion of the methods used to determine electrical require-
ments of the emission reduction system is presented in Section 8.1 and
in Capital and Operating Costs of Selected Air Pollution Control Systems.
     The fuel required to produce steam to regenerate carbon  adsorber
beds can be expressed as:
                       R,, - 0.,- S- [H/ER]-C                        (6)
                        lj    1J         D
     where R,. is the annual fuel requirement (in Btus)  for model
               plant i under Regulatory Alternative j (i  = 15,000,
               30,000, or 50,000 tires per day)  (j = I or II);
           Q.. represents the quantity of VOCs adsorbed  daily (in  pounds)
               for model plant i under Regulatory Alternative j;
           S   is the steam requirement of 4.0 pounds per pound of VOCs
               desorbed;
           H   is the Btu requirement to produce superheated  steam
               (40 pounds per square inch at 300°F) from 68°F water
                                               36 52
               (1186.6 Btu per pound of steam);  '
           E_  represents an average steam boiler efficiency  (80  percent);
           C   is the average number of days per year that a  model plant
                                                          35
                                                           52
is expected to operate (269 days per year).
                                           1-14
                   7-27
-------
     The  fuel  requirements  for the afterburner control  components are
determined  by  the  equation:
                                 •  Ti -
                                                                   V
where:
            F..  is  the  hourly  fuel  requirement (in Btus) for the afterburner
                control  component in  model  plant i under Regulatory
                Alternative  j  (i  =  15,000,  30,000, or 50,000 tires per
                day)  (j  =  I  or II);
            TI   is  the  afterburner  temperature in °F;          ,    •
            TQ   is  the  temperature  at zero  enthalpy (60°F);     ;
            V..  represents the flow rate  through the control  component
                in  model plant i  under Regulatory Alternative j (i =
                15,000,  30,000, or  50,000 tires  per day) (j  = I 'or II);
            U..  is  the  VOC emission rate  (pounds per hour) from the
             1 J
                capture  component in  model  plant i under Regulatory
                Alternative  j;
            W    represents the average heating value of the  VOCs  in the
                exhaust  stream (10,700 Btu  per pound of VOC);36
            X    is  the  heat  recovery  efficiency  of the control  component
                (40 percent  for thermal and catalytic afterburners).  '
                                                              . i
The value of 1.08  represents  a conversion  factor for changing  the units
of temperature  and flow into  units of Btus per  hour.   The emission
reduction system's operating  assumptions used in calculating afterburner
fuel requirements  are  further discussed  in Section 8.1.
     VOC emission  reduction system annual  energy requirements  are presented
for each model  plant and regulatory  alternative and compared tp  total
plant energy requirements in  Table 7-13.   The percentage of  energy
required to operate the VOC emission  reduction  system is small 'when
compared to the overall energy demands of  the model  plant.,   Energy
requirements for systems using carbon adsorber  control  components are
estimated to be less than 0.03 percent of  the total  plant energy demand.
Afterburners may require up to 1.0 percent of the plant's total  energy
demand.                                                        ;
     Energy consumption may be affected  by the  capture components used
to meet the recommended regulatory alternatives:   general ventilation
                                  7-28
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requirements may be reduced in some areas of a plant  as  the capture
component may keep workplace concentrations of VOCs within OSHA  employee
exposure limits.  However, the tremendous amounts  of  heat generated  by
tire production equipment may require that present general ventilation
practices be maintained in order to control the  temperature of'the
                    45
working environment.
7.5  OTHER IMPACTS
7.5.1  Noise Impacts
     The proposed regulatory alternatives are not  anticipated to have
significant noise impacts on the plant environment.   The emission reduction
systems should not produce excessive noise if they are  operating properly.
If noise problems persist following repair of the  emission reduction
system, acoustical damping may be  necessary.     Earplugs should  be worn
by employees only in areas where acoustical damping  is  not feasible.
7.5.2  Urban and Community Impacts
     The fifth-year annualized cost analysis described  in Section 9.3
indicates that the projected costs are well .below  the 100 million dollar
level, which according to Executive Order 12291,54 signifies  a major
regulation.  It is also anticipated in Section 9.3 that the cost of
implementing the regulatory alternatives would have  minimal  impacts  upon
new plant profitability.  Under these conditions,  the decision  to con-
struct new tire plants should be unaffected by the proposed regulatory
alternatives.  Consequently, none  of the regulatory  alternatives are
expected to have an adverse impact on tire industry  employment  trends,
thereby reducing the probability that adverse urban  and community impacts
will be experienced.                                           i  '          •
7.5.3  Irreversible and Irretrievable Commitment of  Resources
     The VOC emission  reduction systems  proposed for installation in new
tire plants represent  technology transfer from other industries. Therefore,
it is possible that the emission reduction systems presented  in  this
document are not the most effective that can  be  installed,,  The  VOC
emission reduction system designs  presented  in previous chapters are not
intended to be strictly adhered to; rather they  represent  basic  emission
reduction technology that can be applied to  VOC-emitting facilities  in
tire plants in order to meet the proposed regulatory alternatives.   New
                                   7-30
-------
technology that is demonstrated to  reduce  VOC  emissions  to levels
comparable to the model VOC reduction systems  can  be  used, thereby
allowing each company to develop the optimal system for  each  plant.
Therefore, the regulatory alternatives are not expected  to adversely
affect future VOC control options.
7.5.4  Impact of a Delayed Standard        .  .
     Assuming that emission factors for VOC-emitting  facilities  and
activities do not increase, the fifth-year impact  of  delaying  imple-
mentation of the standard for VOC emissions from tire manufacturing
plants is an increase in VOC emissions from new plants by  about
1,693 megagrams (1,866 tons) per year.  Consequently, a  delay  in
implementation of the standard would effectively increase  national VOC
emissions from tire manufacturing operations by about 5  percent.
                                  7-31
-------
7.6  REFERENCES                                               :

 1.  Letter from R.O. Louis, Armstrong Rubber Company, to D.R., Goodwin
     ESED/CPB/EPA.  February 28, 1978.  Response to Section 114 letter.

 2.  Letter from E.J. Burkett, The Goodyear Tire and Rubber Company,
     to D.R. Goodwin, ESED/OAQPS/EPA.  May 17, 1978.  Response; to
     Section 114. letter.                  .                    <

 3.  Letter from R.C. Niles, Uniroyal, Inc., to D.R. Goodwin, ESED/
     OAQPS/EPA.  July 13, 1978.  Response to Section 114 letter.

 4.  Letter from R.C. Niles, Uniroyal, Inc., to D.R. Goodwin, ESED/
     OAQPS/EPA.  May 16, 1978.  Response to Section 114 letter.

 5.  Letter from R.C. Niles, Uniroyal, to D.R. Goodwin, ESED/OAQPS/EPA.
     May 24, 1978.  Response to Section 114 letter.           :

 6.  Letter from R.C. Niles, Uniroyal, Inc., to D.R. Goodwin, ;ESED/
     OAQPS/EPA.  April 4, 1978.  Response to Section 114 letter.

 7.  Letter from N. Onstott, Mohawk Rubber Company, to K.J. Zobel ,
     ESED/OAQPS/EPA.  March 21, 1978.  Response to Section 114, letter.

 8.  Letter from R.M. Walter, The Firestone Tire and Rubber Company,
     to D.R. Goodwin, ESED/OAQPS/EPA.  May 5, 1978.  Response to
     Section 114 letter.                                      -1

 9.  Letter from R.M. Walter, The Firestone Tire and Rubber Company,
to D.R. Goodwin, ESED/OAQPS/EPA.
Section 114 letter.
                                       June 7, 1978.  Response to
10.  Letter from J.W. Lewis, The B.F. Goodrich Company, to R.T. Walsh,
     ESED/OAQPS/EPA.  May 24, 1978.  Response to Section 114 letter.

11.  Letter from L.B. Cooper, Michel in Tire Corporation, to D.R. Goodwin,
     ESED/OAQPS/EPA.  April 13, 1978.  Response to Section 114 letter.

12.  Letter from R.M. Walter, The Firestone Tire and Rubber Company,
     to R.T. Walsh, ESED/OAQPS/EPA.  June 29, 1978.  Response to
     Section 114 letter.                                      :

13.  Letter from L.B. Cooper, Michel in Tire Corporation, to D.R. Goodwin,
     ESED/OAQPS/EPA.  March 13, 1978.  Response to Section 114 letter.

14.  Letter from R.W. Frase, General Tire and Rubber Company, to
     D.R. Goodwin, ESED/OAQPS/EPA.  May 16, 1978.  Response to Section 114
     letter.

15.  Letter from E.J. Burkett, The Goodyear Tire and Rubber Company,
     to J.R. Farmer, CPB/ESED/OAQPS/EPA.  March 31, 1980.  Response
     to Section 114 follow-on letter.
                                  7-32
-------
 16.   Letter from R.C.  Miles,  Uniroyal, Inc., to J.R. Farmer, CPB/ESED/
      OAQPS/EPA.   April  11,  1980.   Response to Section 114 follow-on
      letter.

 17.   Letter from J.R.  Laman,  The  Firestone Tire and Rubber Companyj to
      D.R.  Goodwin,  ESED/OAQPS/EPA.   April  8, 1980.   Response to Section
      114 follow-on  letter.

 18.   Letter from J.R..Townhill, The General  Tire and Rubber Company, to
      K.J.  Zobel,  CPB/ESED/OAQPS/EPA.   April  2, 1980.  Response to Section
      114 follow-on  letter.

 19.   Letter from R.R.  Clark,  The  B.F.  Goodrich Company,  to D.R. Goodwin,
      ESED/OAQPS/EPA.  March  18, 1980.   Response to  Section 114 follow-on
      letter.

 20.   Letter from  F.M.  Luysterborghs, Armstrong Rubber Company,  to D.R.
      Goodwin, ESED/OAQPS/EPA.  March 5,  1980.   Response  to Section 114
      follow-on letter.

 21.   Letter from  J.R. Laman,  Firestone Tire  and Rubber Company, to D.R.
      Goodwin, ESED/OAQPS/EPA.  April 17, 1980.   Response to Section 114
      follow-on letter.

 22.   Letter from  R.C. Miles,  Uniroyal,  Inc.,  to J.R.  Farmer, CPB/ESED/
      OAQPS/EPA.   May 12,  1980.  Response to  Section 114  follow-on letter.

 23.   Letter from  L. Cooper, Michel in Tire  Corporation, to J.R.  Farmer,
      CPB/ESED/OAQPS/EPA.  February  19,  1980.   Response to Section 114
      follow-on letter.

 24.   Letter from  E.J. Burkett, The  Goodyear  Tire  and  Rubber Company,  to
      J.R.  Fanner, CPB/ESED/EPA.  March 21, 1980.  Response to Section
      114 follow-on letter.

 25.   Letter from  R.R. Clark, B.F.  Goodrich Company,  to D.R.  Goodwin,
      ESED/OAQPS/EPA.  April 16, 1980.  Response to  Section 114  follow-on
      request.

 26.   Zobel, K.J., and N. Efird.  Control of Volatile  Organic  Emissions
      from Manufacture of Pneumatic  Rubber Tires.  U.S. Environmental
      Protection Agency.  Research  Triangle Park,  N.C.  Publication  No.
      EPA-450/2-78-030.  December 1978.   59 p.

27.   Standard and Poor's.  Industry Surveys:  Rubber  Fabricating
     Basic Analysis.  June 28, 1979.  pp. R201-203.

28.   1979 Tire Industry Facts.  Modern Tire Dealer.    61 (2)-.25-33.
     January 1980.
                                  7-33
-------
29.  Air Pollution:  Control Techniques for Hydrocarbon and Organic
     Solvent Emissions from Stationary Sources, NATO Committee ion
     the Challenges of Modern Society.  Brussels, Belgium.  October 1973.

30.  U.S. Environmental Protection Agency.  Code of Federal Regulations.
     Title 40, Chapter 1, Part 51.  Washington, D.C.  Office of the
     Federal Register.  November 25, 1971.                     ;

31.  Compilation of Air Pollution Emission Factors, Second Edition.
     U.S. 'Environmental Protection Agency.  Research Triangle  Park,
     N.C.  Publication No. AP-42.  April 1977.  pp. 1.3-1 through
     1.3-5 and 1.4-1 through 1.4-3.

32.  Hydrocarbon Pollutant Systems Study, Volume I - Stationary
     Sources, Effects, and Control.  U.S. Environmental Protection
     Agency.  Research Triangle Park, N.C.  Publication No. APTD-1499.
     October 1972.  377 p.

33.  Development Document for Effluent Limitation Guidelines and New
     Source Performance Standards for the Tire and Synthetic Segment
     of the Rubber Processing Point Source Category.  U.S. Environmental
     Protection Agency.  Washington, D.C.  Publication No. EPA-440/l-74-013a.
     1974.  193 p.

34.  Pettigrew, R.J. and F.H. Roninger.  Rubber Reuse and Solid Waste
     Management, Part  I:  Solid Waste Management in the Fabricated
     Rubber Products Industry, 1968.  U.S. Environmental Protection
     Agency.  Washington, D.C.  Publication No. SW-22c.  1971.! pp. 8-13.

35.  Neveril, R.B.  Capital and Operating Costs of Selected Ailr Pollution
     Control System.   U.S. Environmental Protection Agency.  Research
     Triangle Park, N.C.  Publication No. EPA 450/5-80-002.  December  1978.

36.  Perry, R.H., and  C.H. Chilton.  Chemical Engineers' Handbook,
     Fifth Edition.  McGraw-Hill Book Company, Incorporated.   New York,
     New York.  1973.                                          j

37.  Telecon.  Thimineur, R., General Electric Company, with MfcAdams,  M.T.,
     Pacific Environmental Services,  Incorporated.  December 20, 1979.
     Use of water-based green tire sprays by the tire industry.

38.  Telecon.  Martin, D., Dow Corning Corporation, with McAdams, M.T.,
     Pacific Environmental Services,  Incorporated.  December 20, 1979.
     Use of water-based green tire sprays by the tire industry.

39.  Telecon.  Slinger, J.L., Harwick Chemical Company, with McAdams,
     M.T., Pacific Environmental Services,  Incorporated.  December  20,
     1979.  Use of water-based green  tire sprays by the tire industry.

40.  Telecon.  Wittekind, R., SWS Silicones Corporation, with  McAdams,
     M.T., Pacific Environmental Services,  Incorporated.  Decejnber  19,
     1979.  Use of water-based green  tire sprays by the tire industry.
                                   7-34
-------
 41.   Telecon.   Reynard, K., SWS Silicones Corporation, with McAdams,
      M.T.,  Pacific Environmental Services, Inc.  December 27, 1979.
      Composition and use of water-based green tire sprays.

 42.   U.S.  Environmental Protection Agency.  Code of Federal Regulations.
      Title  40,  Chapter 1, Part 428.  Washington, D.C.  Office of the
      Federal  Register.  February 21, 1974.

 43.   U.S.  Environmental Protection Agency.  Code of Federal Regulations.
      Title  40,  Chapter 1, Part 129.  Washington, D.C.  Office of the
      Federal  Register.  January 12, 1977.

 44.   U.S.  Environmental Protection Agency.  Code of Federal Regulations.
      Title  40,  Chapter 1, Part 403.  Washington, D.C. Office of the
      Federal  Register.  June 26, 1978.

 45.   McAdaras, M.T.   Trip Report:  Firestone Tire and Rubber Company,
      Wilson,  N.C.   September 13, 1979.

 46.   McAdams, M.T.   Trip Report:  Armstrong Rubber Company, West
      Haven, Conn.   September 5, 1979.

 47.   Chanlett,  E.T.   Environmental  Protection.   McGraw-Hill Book
      Company, Incorporated.   New York,  New York.  1973.  pp. 293-295.

.48.   A Tire Industry Analysis:   MTD's 13th Annual  Facts/Directory Issue.
      Modern Tire Dealer.   60_(7):25-50.   January 1979.

 49,   Letter from R.G.  Litman,  Met Pro Corporation, to B.  Aus,  Pacific
      Environmental  Services,  Incorporated.  February 5, 1980.   Catalytic
      Incineration  of Vent Streams.

 50.   Letter from F.  DeRosa,  Engelhard Mineral  and  Chemicals Corporation,
      to B. Aus,  Pacific Environmental Services,  Incorporated.   February
      13, 1980.   Catalytic Incineration  of VOCs.

 51.   Ross, R.D.   Pollution Abatement:  Incineration of Solvent-Air
      Mixtures.   Chemical  Engineering Progress.   68(8):59-64.  August
      1972.

 52.   Babcock and Wilcox,  Steam/Its  Generation  and  Use, Thirty-eighth
      edition.  The.Babcock and  Wilcox Company.   New York,  New  York.
      1975.  pp.  2-6,  2-7.

 53.   The Industrial  Environment-Its Evaluation  and Control.  U.S.
      Department  of Health,  Education, and Welfare.   Public Health
      Service.  Center  for Disease Control.   National  Institute for
      Occupational Safety  and Health.  Washington,  D.C.  1973.
      pp. 533-562.

 54.   Federal Register.   Executive Order 12291.   Vol.  46, No. 33.
      February 17, 1981.
                                  7-35
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                               8.0  COSTS

 8.1   COST  ANALYSIS  OF  VOC  EMISSION REDUCTION SYSTEMS
 8.1.1  Introduction
      This  section presents  an  analysis of the costs to design, purchase,
 install, and  operate VOC emission reduction systems which may be used
 by the  rubber tire  industry to meet the emission reduction levels
 recommended for  the regulatory alternatives.   Twenty-seven combinations
 of control devices  and  capture components servicing applicable
 VOC-emitting  operations are sized and  the costs  analyzed for each
 regulatory alternative, model  plant, and one-line retrofit situation.
 The general design  of these systems is discussed in Chapter 4.  The
 cost  combinations are summarized  in Table 8-1.   Analysis performed on
 these VOC  emission  reduction systems includes capital  costs,  annualized
 costs,  and cost  effectiveness.  The results of the analysis are used
 in .Section 9.2 to determine the economic impacts on the  tire  industry.
 A cost  analysis  was performed  for additional  emission  reduction systems
 where various combinations  of  operations were manifolded into the same
 control component.  The cost analysis  for these  additional  systems is
 not included  in  this section but  is  included  in  the docket.   The most
 likely  combinations of solvent application  operations  to be controlled
 under the regulatory alternatives  will  be discussed.
     The emission reduction systems are designed to remove  VOCs  from
 the exhaust gas  streams, as described  by the  model  plant parameters in
 Chapter 6,  to the extent suggested  by  Regulatory Alternatives  I  and
 II.  Table 8-2 summarizes the uncontrolled  exhaust  gas parameters  for
those tire manufacturing operations to  which  VOC  emission reduction
systems may be applied.
                                  8-1
-------
       Table 8-1.   COST COMBINATIONS USED FOR THE COST ANALYSIS
             OF MODEL PLANT VOC EMISSION REDUCTION SYSTEMS3
           Undertread cementing
           Sidewall  cementing
           Manual  tread end cementing3
           Automatic tread end cementing3
           Bead dipping3
           Organic green tire spraying0
           Water-based green tire spraying3
           Undertread cementing/manual tread end cementing
           Undertread cementing/automatic tread end cementing
alncluded in Regulatory Alternatives I and II for one-line retrofits
 and all model plant sizes.
bNot included in Regulatory Alternative I.                     ;
cNot included in Regulatory Alternative II.                    ;
     included in one-line retrofit cost analysis.
                                  8-2
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     Regulatory Alternatives I and  II are analyzed for  their  cost
impacts.  Both regulatory alternatives would affect VOC emissions  from
undertread cementing, tread end cementing, bead cementing, and lgreen
tire spraying operations.  Regulatory Alternative II would additionally
affect VOC emissions from sidewall  cementing.  An in-depth discussion
of the regulatory alternatives is presented in Chapter  6.  The regulatory
alternatives and VOC emission reduction systems for applicable ;rubber
tire manufacturing operations are summarized in Table 8-3.
     A number of operating assumptions are made in order  to estimate
capital expenditures, annualized costs, and cost effectiveness of
model plant emission reduction systems.  The noncorrosive character of
the VOC exhaust stream allows for the control components  to be'package
units.  The entire emission reduction system is assumed to operate
24 hours per day for 269 days per year:  the average number of days
                                                1-14           I
that a model plant would be expected to operate.      For the purpose
of sizing afterburners, exhausted gases are assumed to  contain ja
maximum VOC concentration that-is less than 25 percent  of the lower
explosive limit.  Intermittent use  of solvents in some  activities may
occasionally result in exhaust gas  VOC concentrations approaching
                     1 14
0 percent of the LEL.      Capture  component design and dimensions for
model plant solvent application areas are,derived from  measurements of
existing capture components, capture components planned for new plants,
dimensions of solvent application areas having no exhaust gas capture
                                                               i
apparatus, and technology transfer  from other industries.  Model VOC
emission rates, solvent evaporation  (flashoff rates, and  attendant
conveyor speeds) were established in order to determine the additional
conveyor enclosure required to capture VOCs under each  regulatory
alternative.  The cost of the additional conveyor needed  to extend
                                                               i
beneath the capture hoods is not included as the incremental  costs
incurred by installation of additional conveyor.in the  model  plants
would not significantly affect the  results of the cost  analysis.
Other assumptions applicable to the cost analysis are discussed in the
following sections and are summarized in Tables 8-4 through 8-6.
8.1.2  New Operations -
     All costs are based on the parameters of the three sizes of model
plants presented in Tables 6-1 through 6-3.  These model  plants are

                                  8-4
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            Table 8-4.  ASSUMPTIONS USED IN DEVELOPING COST
                    ESTIMATES FOR CARBON ADSORBERS
Packaged unit designated for new source installation.           :
Fixed, regenerative bed design.                                 :
Automatic and continuous operation.
                             1-14
Operating hours:  6456 hr/yr.
Operating temperature:  38°C (100°F).26                         ;
Gas stream constituents:  90% naphtha, 6% n-hexane or
     n-heptane, 2% toluene, 1% isopropyl alcohol, 1% other VOCs.
Maximum VOC concentration in exhaust stream:
     9.1 g/m3  (5.7xlO~4 Ib/ft3).1"14                            i
                                   44 45 51
Life of activated carbon:  5 years.  '  '
Electricity cost  (10/79):  $0.055/kWh.51                        '.
Activated carbon  cost (12/79):   $4.40/kg  ($2.00/lb).
Steam cost  (12/79):   $11.10/Mg  ($5.04/103 lb).51
Cooling water  cost:   $0.03/103 liters  ($0.116/103 gallons)
Waste disposal  cost  (12/79):   $ll/Mg  ($10/ton).51
Direct operating  labor cost  (12/79):
      $7.82/hr  x 0.5  hr/shift x 807 shifts/yr  = $3155/yr.   '
Supervisory operating labor cost (12/79):
      15% of direct operating labor cost =  $475/yr.  1>
Maintenance labor costs:                                        :
      $8.6Q/hr  x 0.5  hr/shift x 807 shifts/yer = $347051
                             1-14
 Maintenance material  costs:   100% of maintenance labor costs
                                                          5'i
 Operating  supply costs:   15% of annual  maintenance costs.
 Plant overhead:   8% of operating labor  and maintenance labor.
 Discount interest rate:   10%.
                                    51
 Capital  recovery period:   15 years.
 Capital  recovery factor:   13.15% of fixed capital costs.
                          51
                           51
51
    51
 Taxes:   1% of fixed capital  costs.
 Insurance:  1% of fixed capital costs.
 Administration and permits:   2% of fixed capital costs.
                                            r/i
 Market value of naphtha (1/80):  $1.21/gal.
 Market value of hexane (1/80):  $0.60/gal.5^
 Market value of heptane (1/80):  $0.59/gal.
 Market value of toluene (1/80):  $1.36/gal.
 Market value of isopropyl alcohol (1/80):  $1.33/gal.
                     51
         54
         54
         54
                   54
8-6
-------
Table 8-5.  ASSUMPTIONS USED IN DEVELOPING COST
    .ESTIMATES FOR DIRECT FLAME AFTERBURNERS
                 1-14
                                                    1-14
                          51
 Packaged  unit designated for new source installation.
 Multi-jet nozzle  burner arrangements with 45% efficient primary
      heat recovery.42"44
 Afterburner temperature:   760°C (1400°F).42"44
 Vapor residence time:   0.5 seconds51
 Fuel  used:   #2 oil.
 Operating hours:   6456  hr/yr.
 Exhaust stream constituents:   90% naphtha,  6% n-hexane  or
      n-heptane, 2% toluene,  1% isopropyl  alcohol,  1% other VOCs.
 Concentration  of  VOCs in  exhaust stream:   1% to  25% of  the LE! .
 Refractory  life:   5 years51
 Electricity cost  (10/79):   $0.055/kWh.
 Cost  of #2  fuel oil (1/80):   $4.77/GJ  ($5.03/106 Btu).55
 Direct operating  labor  cost  (12/79):
      $7.82/hr  x 0.5 hr/shift x  807 shifts/yr = $3155/yr.51'52
 Supervisory operating labor cost (12/79):
      15%  of direct operating labor costs  =  $475/yr.51'52
 Maintenance labor costs:
      $8.60/hr  x 0.5 hr/shift  x  807  shift/hr = $3470.51
 Maintenance material  costs:  100% of maintenance labor costs51
 Operating supply costs:   15% of  annual maintenance  costs.53
 Plant overhead:  80% of operating labor and  maintenance labor costs.
 Discount  interest rate:   10%.51
 Capital recovery period:  10 years.51
 Capital recovery factor:  16.27% of fixed capital costs.
Taxes:  1% of fixed capital costs.51
 Insurance:  1% of fixed capital costs.51
Administration and permits:  2% of fixed capital  costs.51
                                                        51
                     8-7
-------
          Table 8-6.  ASSUMPTIONS USED  IN DEVELOPING COST
               ESTIMATES FOR CATALYTIC  AFTERBURNERS
Packaged unit designated for new source installation.          :
Multifire or vortimetric burner arrangement.                   ;
Precious metal catalyst in honeycomb configuration; mounted on ica'rbon
     or ceramic supports.
                               40 41
Heat recovery efficiency:  45%.  '      40  41
Afterburner temperature:  480°C  (900°F).  '
                           i 40  41
Space velocity:  60,000 hr \  '                              . :
Fuel used:  #2 oil.                                     ^^    ',
Operating  hours:   24 hr/day  x  269 days/yr = 6456  hr/yr.  '      j
Exhaust stream constituents:   90% naphtha,  6% n-hexane or      i  ^^
     n-heptane, 2% toluene,  1% isopropyl  alcohol, 1% other VOCs.  "
Concentration of VOCs  in  exhaust stream:   1% to 25% of the LEL,
Refractory life:   5 years 1
Catalyst life:   5  years.51                                    '
Electricity cost (10/79):  $0.055/kWh.                        :
Cost of #2 fuel  oil (1/80):   $4.77/60 ($5.03/10  Btu).    .    ;
Direct operating labor cost (12/79):
      $7.82/hr x 0.5 hr/shift x 807 shifts/yr
 Supervisory operating labor cost (12/79):                     ;
      15% of direct operating labor cost =  $475/yr.   '         |
 Maintenance labor  costs:  $8.60/hr x  0.5 hr/shift x  807 shift/hr
 Maintenance material costs:   100% of-maintenance labor  costs
 Operating supply  costs:   15%  of annual maintenance  costs.     •
                                               $3155/yr.51'52
                                                                   3470'
Plant overhead:
                  80% of operating  labor  and maintenance  labor xosts.
 Discount  interest  rate:   10%.
 capital recovery period:   10 years.

                                  51
  Capital  recovery factor:   16.27%
  Taxes:   1% of fixed capital  costs.
  Insurance:  1% of fixed capital  costs.
  Administration and permits:   2% of fixed capital  costs.
                                      51
                                                        51
                                   8-8
-------
 used  in order to obtain complete and consistent cost information.
 Three model  plant sizes were used since no single model plant size can
 adequately describe existing plants or plants likely to be built.  In
 order to generate cost information for additions in existing plants,
 model  plant parameters of retrofit single units were chosen for each
 facility:  the parameters for each one-line retrofit were based on the
 parameters of single model  plant units having the highest production
 rates.
      These costs do not represent the actual  amounts of money spent
 for any particular plant.   Rather, the costs  relate to models which
 represent  estimates of additional  lines and plants likely to be built.
 The costs  of VOC emission  reduction systems will  vary according to
 production rate,  production equipment used, plant layout,  and geographic
         45  56
 location.   '     For example,  installation costs in different geographic
 regions have  been reported  to vary from 15 percent to 400  percent of
 the freight-on-board (f.o.b.)  cost of a carbon  adsorber.45
     Two categories of costs  are derived using  the model  plant parameters:
 capital  and  annualized costs.   The annualized costs,  in conjunction
 with  the model plant parameters,  are used to  generate information on
 the cost effectiveness of the VOC  emission reduction  systems.
     8.1.2.1   Capital  Costs.   Capital  costs represent the  financial
 resources  required  to  plan,  fabricate,  install,  and test  run (shakedown)
 the VOC  emission  reduction  system.   These costs  can be  divided into
 direct  and indirect capital  costs.   Direct capital  costs  represent the
 investment needed  to purchase  and  install  a VOC emission reduction
 system.  Indirect  capital costs  cover  engineering,  contractors'  fees,
 field overhead,  shipping, shakedown,  spares,  performance testing,  and
 taxes.   In addition  to direct  and  indirect capital  costs,  a  contingency
 factor  is  included  to  account  for  any  unforeseen  costs  encountered
during  planning, fabrication,  and  installation of  the equipment.47
Table 8-7 presents  the magnitudes  of the  component  capital cost  factors
described above.
     8.1.2.1.1  Determination  of capital  costs.   In order  to be  able
to arrive at the total  installed capital  cost of any emission  reduction
system using the capital cost  component factors, the cost  to purchase
                                  8-9
-------
   Table 8-7.   COMPONENT CAPITAL COST FACTORS FOR

          A MODEL TIRE PLANT AS A FUNCTION

          OF PURCHASED EQUIPMENT COST, Q51
Component
Cost Factor
Direct Costs
     Purchased equipment costs
          control device9     b
          auxilliary equipment
          instruments and controls
          taxes
          freight


     Total purchased equipment costs

     Installation Costs
    1.00 C

    0.30 C
    0.05 C
    0.05 C
PE

PE
PE
PE
    1.00 Q
foundations and- supports
erection and handling
electrical
piping
insulation
painting
site preparation
facilities and buildings
Total installation costs
Total Direct costs
Indirect Costs
engineering and supervision
construction and field expenses
construction fee
start up
performance test
model study
contingencies
Total Indirect costs
Total Capital Costs
0.08 Q
0.21 Q
0.04 Q
0.02 Q
0.01 Q
0.01 Q
0.00 Q
0.37 Q
1.37 Q
0.20 Q
0.05 Q
0.10 Q
0.01 Q
0.01 Q
none
0.30 Q
0.67 Q
(0.29 Q)c
(0.45 Q)c
(1.45 Q)C
2.04 Q (2.12 Q)c
 aincludes control  equipment, instrumentation,
  fan, electrical  equipment, and steam regenerator.
 includes hooding, ductwork, fans, motors, belts, stack,
  and fabrication labor.                             i
                                                     i
 cretrofit situation.
                         8-10
-------
 the  system  (Q)  mist be determined.  The component cost factor Q does
 not  include installation  costs,  but does include instrumentation,
 taxes,  and  freight.   VOC  emission reduction systems are divided into
 two  parts:

       1.   the exhaust gas  containment and transport system (capture
       system),
       2.   the VOC emission control  device.
       For  solvent application activities,  the  capture system  should be
 designed  to  remove VOC  emissions  from cement,, solvent,  or spray  appli-
 cation equipment and  VOCs  from evaporation  of solvent that is  applied
 to the cemented or sprayed material.   A  detailed discussion  of these
 principles is presented in Chapter 4.  The  dimensions of  model plant
 application  area exhaust  stream capture  components  are  derived from
 dimensions of existing and planned VOC emission capture components;
 dimensions of the solvent application apparatus or  stations  not having
 exhaust stream capture components; and transfer of  capture component
 designs from other industries.   Enclosures used on  conveyors following
 cement application areas are designed to compliment the application
 area  component:   the enclosure  is extended to allow 75 percent
 (Regulatory  Alternative I) or 80 percent (Regulatory Alternative II)
 of the total  emissions available from solvent application to be captured.
 The length of conveyor enclosure employed in the capture system is
 determined by the  solvent  flashoff rate and  conveyor speed (nominally
 0.46  meters  per  second [90 ft/min]).57"59  Conveyor enclosures  are not
 included  for organic  green tire  spraying  operations as the coated
 tires  would  reside  in the  spray  booths to facilitate the recommended
 level  of  VOC  capture.   Water-based green  tire  spray booths would  not
 require conveyors and conveyor enclosures, but would require  the
 installation  of  a particulate control  component with appurtenant
 ducting.   Since  both  green tire spraying  technologies  would be  expected
 to  require the use of  a  particulate control  device  in  the  absense  of
 VOC controls, the costs of  particulate control  equipment for  green
 tire spraying operations are not included  in the cost  analysis.57"59
The capital costs of exhaust stream pretreatment for operations other
than green tire spraying are not considered  since industry-supplied
                                  8-11
-------
information and plant visits indicate the use of
reduction system components is not usually necessary.
Once the capture components are sized, material costs are determined
by translating the dimensions (plate area) into the weight of  carbon
steel required.  Fabrication labor costs are based on capture  component
plate area, the weight of material required, and complexity  of construction.
The procedure used to develop material and fabrication  labor costs  is
outlined in Capital and Operating Costs of Selected Air Pollution
Control Systems  (GARD Manual).  1                                \
     The dimensions of the  capture .component,  along with the assumption
that the capture component  is designed to'operate  with  all  application
area access panels open  in  order  to  maintain  effective  capture jdurlng
line changes  and machinery  adjustment, are  used to establish the
captured exhaust flow  rates.  The flow rates  for the capture components
servicing  the different  solvent application activities  are presented
in Table 8-8.   The duct  diameters then are determined as a function of
the flow rate and  the  duct velocity to be maintained.  For volatile
 organic gases, a duct  velocity of about 10 m/sec (2,000 ft/min) should
 be maintained.51'61'62  The purchase cost per linear foot of duct is
 determined as a function of the duct diameter and the thickness of
 carbon steel  used,  which is 12.7 nm (0.5 in) for VOC capture  systems.
 The costs  of duct elbows, transitions, and "tees" are also  determined
 as a function of the duct diameters and material thickness  used (12.7 mm).
 Calculations of duct costs are presented in the GARD Manual.   ; Model
 plant duct lengths are determined using nominal distances between
 solvent application operations and  the location of the  VOC  emission
       ,         . 57-59,60                                     I
 control component.
      Capital  costs of fans  and motors used to transport exhausted
 gases for the  VOC emission  capture  system depend  on  the control system
 to  be used and  the length  of ducting  involved.   Pressure drop| due to
 ducting are  approximately  1/10"  W.G.  per  100 ft.  of  duct.   '   : Carbon
  adsorbers  experience pressure drops of 15" to 20" Water Gauge (W.G.),
  while afterburner pressure drops are approximately 6" (direct iflame)
                                                     *^ 1   .    _ ••    ^
                                                                       45,51
51
  to 10" W.G.  (catalytic) when heat recovery is used.    Therefore, fan
  sizes and motor horsepower requirements for a carbon adsorber'would,
                                    8-12
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 in general, be larger than for an afterburner component  servicing
 similar solvent application activities.  Further details  regarding
 sizing and capital costs of fans and motors are presented  in  the CARD
 Manual.51
      Exhaust stacks are provided downstream of the fans for dispersion
 of exhaust gases in the immediate vicinity of the plant.   The capital
 costs of stacks are included for the solvent application facilities
 under consideration, since these facilities do not have capture compo-
 nents through which exhaust gases are usually ducted to the atmosphere.
 Stack costs are determined by using GARD Manual  prices, which are a
 function of the weight of 6.3 mm (0.25 in) carbon steel used in fabri-
 cation.   The weight of carbon steel  is in turn related to  the stack
 diameter and stack height.   The stack diameter is a function of the
 stack exit velocity and the average wind velocity (nominally 64 kilometers
 [40 miles] per hour).     Through observations of ceiling heights in
 several  tire plants,  the stack height is assumed to be about 15 meters
           C "7 C rt
 (50  feet).
           57-59
      Cooling  towers  and basins  are used to remove heat from cooling
water servicing  the  carbon adsorber's condenser.   The capital  costs of
cooling  towers are based on tower cooling capacity (tons), which is a
function  of the  carbon  adsorber's steam requirements.  Capital  costs
include  the price of the cooling  tower, fans,  pumps,  motors, and
installation.  Basin area requirements  are calculated as a function of
cooling  tower price.  Methodologies  used for sizing cooling towers and
basins are presented in  the GARD  Manual.51
      All  capital costs  of capture components,  appurtenant fans,  motors,
stacks, and cooling  towers  are  derived  from the GARD  Manual.51   All
prices are updated to December  1979  values using  the  Chemical Engineering
indices.
      Once the flow rates  through  the model  capture components are
established, model plant  VOC control  component costs  can  be determined.
Capital costs of control  components  are  derived from  information
supplied by vendors of VOC  control components.  Carbon  adsorber units
are available for all flow  rates  involved,  whereas direct flame and
catalytic afterburner units can only  effectively  treat  up to 19 cubic
                                  8-21
-------
meters per second [m /sec]  (40,000 scfm).
                                         OQ C1
                                           '   '
                                                               •
                                                   In such case;s where
flow rates exceed 19 m /sec, more than one afterburner unit  is  included
in the design.  The capital costs of control components for  each
operation and model plant size are presented in Table 8-9.
     8.1.2.1.2  Capital costs of VOC emission reduction systems.
December 1979 total installed capital costs are calculated fonthe
different combinations of solvent application facilities, regulatory
alternatives, control systems, and model plant sizes.  Direct costs
include switches, hoods, ducts, fans, motors, stacks, fabrication
labor, freight taxes, and installation labor.  Indirect capital costs
include engineering and contractors fees, field overhead, test  runs,
parts, and performance testing:  No model studies  are known  toihave
been performed on VOC emission reduction systems.  Thus, capital costs
for model studies are not included, as the values  could not  be!determined.
The total installed capital costs of the VOC emission reduction systems
are summarized in Table 8-10.  Capital costs for cooling towers and
basins are presented in Table 8-10 as separate values for each  model
plant, as costs for this equipment are not directly  attributed  to  any
single operation.                                              '.
     Comparison of the total installed capital costs shows that model
VOC emission  reduction systems using thermal afterburners have'costs
which are generally in the  same range as costs for similar systems
that employ carbon adsorbers.  The capital cost difference for1VOC
emission  reduction systems  using carbon adsorbers  and direct flame
afterburners  varies about ±15 percent over the range of exhaust flow
rates studied.  Emission reduction systems employing carbon  adsorbers
tend to cost  less  than systems using direct  flame  afterburners  at  flow
rates below 4.72 m3/sec  (10,000 scfm).   Emission  reduction systems
using catalytic afterburners exhibit much higher  capital  costs: in the
cases studied, the capital  costs for systems employing  carbon adsorbers
are 15 to 50  percent less than the cost of comparable  systems yifhich
employ catalytic afterburners; the larger differences  in  costs|between
emission  reduction systems  employing carbon  adsorbers  and  catalytic
afterburners  are exhibited  at lower  air  flow rates.  The  capital  costs
of purchasing and  installing the VOC emission  reduction  equipment
                                   8-22
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which are above the cost of installing equipment  to meet  the  reduction
levels suggested by Regulatory Alternative  I  (total installed costs
attributable to Regulatory Alternative II)  are  presented  in Table 8-10.
Water-based green tire spray facilities  have  no capital costs attributable
to Regulatory Alternative II as the  same water-based  green tire  sprays
used to meet Regulatory Alternative  I can be  used  to  meet the VOC
emission levels recommended under Regulatory  Alternative  II.   With the
exception of green tire spraying activities,  the  total  installed
capital costs attributable to Regulatory Alternative  II increase with
the .size of the model plant.
     8.1.2.2  Annualized Costs.  Annualized costs  of  the  VOC  emission
reduction systems represent the total annual  expenditure  required to
operate and maintain the equipment.  The annualized cost  is the  sum  of
annual operating costs and annual capital charges  minus annual recovery
credits.  Operating costs are the day-to-day  expenditures necessary  to
operate the VOC emission reduction system.  Capital charges include
items associated with owning the equipment.   Recovery credits represent
the reduction in annual operating costs  and annual capital charges due
to reclamation of materials or energy by the  emission reduction  system.
     8.1.2.2.1  Operating costs.  Operating cost  estimates for the VOC
emission reduction systems include utilities, operating labor, maintenance,
supplies, replacement parts, and waste disposal.
     Annual costs for utilities are  divided into  four areas:   electricity,
fuel, steam charges, and cooling water charges.   The  amount of electricity
used annually by the VOC emission reduction systems is  determined by
adding the horsepower requirements of the capture  and control  components
for each facility and placing the sum into  the  following  equation:
                           a - C(0.746b)c]  1.1
          where:  a = the amount of  kilowatt  hours used,
                  b = horsepower requirements,  and
                                              1-14
                  c = annual operating hours.
All emission reduction equipment is  assumed to  operate  6,456  hours per
year (24 hours per day for 269 days a year).
                                             1-14
The 1.1 factor
included in the above equation represents an adjustment  for  10  percent
                                  8-39
-------
line losses due to inefficiency in power transmission  through  electrical
components of the VOC emission reduction system.    Once  the kiflowatt
hour value is determined, it is multiplied by the cost per  kilowatt
hour ($0.055/kWh).51                                           ;
     The amount of gas or oil consumed annually by  the afterburjner
component of the VOC emission reduction system is determined byf  the
following empirical relationship between the annual operating  hpurs,
exhaust gas flow rate, fuel credit of the exhaust stream, and  the
degree of heat recovery available to the control system:
([(TrTo)(V..)1.08] -
                                  .  (TrC(TrT0)(l.X)+T0]1.08
>,456 hr/yr)
where F.. is the annual energy requirement  for  the  VOC  emission  reduction
          system in model plant  i  (i  =  15,000,  30,000,  or 50,00,0 tires
          per day) under Regulatory Alternative j  (j  =  I  or II);
      T.  is the afterburner temperature  in °F;               i
      T   is the temperature at  zero  enthalpy  (60°F);
      V-. represents the gas flow  rate  through  the  capture comp|onentin
          model plant  i (i = 15,000,  30,000, or 50,000  tires pe;r day)
          under Regulatory Alternative  j  (j =  I or  II);
      U-- is the VOC emission rate (pounds  per  hour)  from the qapture
          component in model plant i  under  Regulatory Alternative j;
      W   represents the average heating  value  of  the VOCs in the
          exhaust stream (10,700 Btu  per  pound  of  VOC);65
      X   is the heat  recovery efficiency of the control  component
                                                 40-44         i
          (45 percent  for both afterburner  types)              :
The value of 1.08 represents a conversion factor for  changing the
units of temperature and flow into units  of Btus per  hour.  Exhaust
flow rates  are dependent on the  nature  of the  solvent application
activity involved.  The fuel credit of  the  exhaust  stream is a 'function
of the mass of VOCs in the exhaust stream and  the  heating value  of the
VOCs.  The  mass of VOCs in the exhaust  stream  is dependent on the
activity involved; the heating value  of the VOCs is derived from the
                                   8-40
-------
heating value of a representative VOC exhaust stream  consisting  of
90 percent naphtha , 6 percent n-hexane or n-heptane,  2  percent toluene,
1 percent isopropyl alcohol, and 1 percent other  organic  solvents.
Thus the average heating value of the VOCs, with  air, is  approximately
         /-                                            f\f\
5.12 x 10  joules per kilogram (10,700 Btu per  pound).     The output
of the mathematical relationship described above  is the quantity of
joules (Btus) required per year, which when multiplied  by the cost per
joule (Btu), yields the annual fuel charges.  The January 1980 average
cost of No. 2 fuel oil is estimated to be $4.77 per gigajoule  ($5.03
                 cc
per million Btu);   the actual cost per joule value can be as low as
50 percent of this value, depending on the fuel type  used and the
geographic area in which the fuel is purchased.
     Steam requirements for carbon adsorbers includes the quantity of
water and heat required to desorb the carbon beds.  The price of steam
has been obtained through vendor quotations and has been  established
at $8.80 per megagram of steam delivered  ($4.00 per 1,000 pounds).  '
Steam requirements were extrapolated from the relationship:
'ij
where d.. represents the annual steam  costs for  the  carbon  adsorber
          VOC control component installed  on  the facility in  model
plant i
          (i - 15,000, 30,000, or 50,000 tires per day)  under Regulatory
          Alternative j (j =  I or II);
          is the annual quantity of VOCs adsorbed from  a facility
          model plant i under Regulatory Alternative j,  which is  a
          function of the quantity of  VOCs emitted from solvent
          application facilities, the  capture efficiency suggested
          by each regulatory  alternative,  and the removal efficiency
          of the carbon adsorber;
          represents the quantity of steam required  to  desorb one
          pound of VOC (4 kilograms [pounds]  of  steam per kilogram
          [pound] of, VOCs);51
          is the cost of steam ($11.10 per Mg or $5.04  p'er  1,000  Ibs
          of steam).
                                   8-41
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Cooling water charges were estimated using the equation:
                                                                  51
where k-- represents the annual cooling water  charges  for  a  carbon
          adsorber installed on a facility's VOC  emission  reduction
          system in model plant i (i =  15,000,  30,000,  or  50,000
          tires per day) under Regulatory  Alternative  j (j = I:or II);
      g.. is the annual quantity of VOCs adsorbed from a facility
          (pounds) in model plant i under  Regulatory Alternative  j;
      h   is the quantity of steam required to desorb  one  pound of
          VOC  (4 pounds of steam per pound of  VOC);    (        !
      m   represents the annual cooling water  requirement  for the
          carbon adsorber  (12 gallons water/100 pounds of  steaiji);
      p   is the cost per 1000 gallons  of  cooling water ($0.116).
Sewerage charges were not calculated as the assumption is  made j that
all water used  is reci rcul ated .
     Annual operating labor costs are derived  from the sum of direct
and supervisory labor costs.  Direct labor costs  are  quantified by
taking the  product of the annual operating hours, the  amount of labor
per shift allocated to  operating the VOC emission reduction  sy$tem,
and the  average hourly  earnings of  rubber  production workers. jThe
model plant emission reduction system  runs 6,456 hours per year and
the average amount of labor allotted to operating the  system is
0.5 man-hours.1"14'51   The U.S. Department of  Labor 1978 average
hourly earnings per 8-hour shift for rubber  tire and  tube  production
workers  is  used in the  analysis:   hourly wages are estimated to be
      CO
$7.82.    Supervisory time allotted  to  operation of the VOC  emission
reduction system  is estimated  at  15  percent  of the direct laboj" cost.
The assumptions used to calculate  annual  operating labor costs; are
summarized  in  Tables 8-4 through  8-6.
     Annual maintenance,  replacement,  and  supply costs represent the
labor and material used for upkeep  of  the  emission reduction systems,
as well  as  the supplies required  to  operate  the system.  Included  in
maintenance costs would be  the  labor  and material costs to repair  or
install  motors, fans,  switches,  and  other  associated  equipment.
                                                                      51
                                   8-42
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Maintenance labor costs are determined from the product of  the  emission
reduction system's annual operating hours  (6,456 hours),  the  amount  of
labor that is allocated to system maintenance during  each shift (0.5 hours),
and the average hourly earnings of maintenance workers  ($8.60).     '
Maintenance material costs are estimated to be 100  percent  of maintenance
labor costs.51  The replacment cost value  for emission  reduction
systems using carbon adsorbers represents  the cost  to replace activated
carbon and screens; afterbuner costs  include the price  of new refractory.
Methodologies employed to determine the  replacement costs of  carbon,
screens, and refractory are outlined  in  the SARD Manual.    Replacement
costs of catalysts  for afterburners are  calculated  from cost  information
presented in the  EPA publication  Report  of Fuel  Requirements. Capital Cost
and Operating Expense for Catalytic and  Thermal  Afterburners.
Operating supplies  include materials  required  for  cleaning  an'1  other
janitorial services.  Annual  operating supply  costs are estimated to
be 15 percent of  the annual maintenance  costs.     The assumptions used
to generate  annual  maintenance,  operating  material, and replacement
costs are presented in Tables 8-4 through  8-6.
      8.1.2.2.2   Capital  charges.   Annual capital  charges for VOC
emission  reduction  equipment  comprise the  capital  recovery  factor
 (CRF),  overhead administration costs  related  to owning the  equipment,
 taxes,  and  insurance.
      The  CRF is a function  of the discount interest rate and useful
 equipment life.  The relationship is  expressed as:

                             CRF -Ml*  1)"
                                   (1  + i)n - 1
           where i = the discount interest rate
                 n = the capital  recovery  period, in years.

                                                       51
 The EPA discount interest estimate used is 10 percent.     The  capital
 recovery period, or the economic life of  carbon adsorbers  and  afterburners
 is 15 years and 10 years, respectively, as the emission  reduction
 systems are not expected to encounter extreme VOC  loading  or corrosive
 compounds.51  Therefore, the CRF for  carbon adsorbers  (i =0.10 and
                                   8-43
-------
n « 15) is 13.1 percent and the CRF for afterbuners  (i =  0..10  ajnd
n « 10) is 16.3 percent.  The CRF is applied to the  fixed capital
investment, the product being the VOC emission reduction  system's
annual capital recovery cost.
     Annual overhead costs are not charged  directly  to a  particular
process, but allocations are made to cover  costs  of  administration,
safety, engineering, legal services, medical services, payroll,,; employee
benefits, recreation, and public relations.68  Annual overhead charges
are 80 percent of total annual operating  and maintenance  labor 'costs.
These assumptions are included in Tables  8-4 through 8-6.      ;
     Annual administrative costs associated with  owning  the emission
reduction system and annual permit costs  are estimated to be 2 ;percent
of the fixed  capital costs.51  Taxes  involved  with ownership of the
emission reduction  system are calculated  at 1  percent of  the fixed
capital  investment.51   Insurance for  the  emission reduction system was
                                           51
1 percent of  the fixed  capital investment.
      8.1.2.2.3  Recovery credits.  Afterburner recovery  credits are
based  on the  amount of  heat derived  from  the  VOCs in the exhaust
stream and  the extent of heat  recovery applied to the afterburner.
The  recovery  credits for afterburners  are included as part of the
empirical  relationship  involved  in  the determination of  annual
afterburner fuel requirements  discussed in 8.1.2.2.1.  Carbon adsorber
recovery credits are expressed  as  a  product of the amount of adsorbed
solvent recovered  and  the market value of the recovered  material.  The
 amount of  solvent  recovered  annually is determined by the mass;of
 solvent emitted  from a  facility,  the efficiency of the capture;system,
 and  the removal  efficiency of the adsorber.
      The market value  of the recovered material  is estimated at $0.31 per
 liter ($1.17 per gallon).   This  value is arrived  at by taking  J;he
 percent by weight  of each solvent in the exhaust  stream  and multiplying
                                                 C A
 the  percentage by  the  January 1980 market value.    The  sum of the
 values resulted in the weighted average  price of  the recovered! solvent.
 In cases where the recovered solvent is  not used  entirely  or must  be
 treated before reuse,  the value of the recovery credit will be, diminished
 accordingly.   A discussion of problems that may be  encountered with
 using recovered solvents is presented in Chapter  4.
                                   8-44
-------
     The  recovery credit  allotted  to  VOC  emission reduction systems
using carbon adsorbtion is  subtracted from the sum of operating costs
and capital charges.   Certain  solvent application operations, such as
undertread cementing and  organic solvent-based green tire spraying,
may experience  recovery credits large enough  to offset direct operating
costs and capital charges.   Such cases appear as negative values in
the annualized  costs presented in  Table 8-11.   Annualized costs for
systems employing carbon  adsorbers with no credits given for reuse of
recovered solvent are  also  presented.
     8.1.2.2.4  Review of annualized  costs.   Annualized emission
reduction costs are calculated for 216 combinations  of model  plants
and one-line retrofits, solvent application operations, control  devices,
and regulatory  alternatives.  Annualized  costs for VOC emission reduction
systems using carbon adsorbers (without recovery credits) are estimated
to be approximately 50 to 65 percent  lower than annualized costs for
thermal afterburners;  carbon adsorbers are expected  to incur annualized
costs that are  about 45 to  60 percent less than catalytic afterburner
costs.  Lower annualized  costs incurred by emission  reduction systems
employing carbon adsorbers  can generally  be attributed to lower energy
requirements.   Annualized costs for VOC emission reduction systems
employing catalytic afterburners are  generally less  than the costs for
similar systems that use  direct flame  afterburners:   the exception
applies to one-line retrofits having  flow rates less than 2.6 m3/sec
(5,500 scfm), as lower fuel  requirements  due  to use  of catalytic
afterburners are not sufficient to offset their higher capital  recovery
costs.  Undertread cementing activities in 30,000 and  50,000 tire per
day model plants and all  exhibit annualized emission reduction credits
when carbon adsorbers  are used and recovery credits  are given.   Annualized
VOC emission reduction costs for all  cement and solvent application
activities increase with  the tire  production  rate, though in  general,
economies of scale are exhibited on an annualized emission reduction
cost-per-tire basis.   Further, the annualized  costs  incurred  by  systems
manifolding exhaust gas from undertread cementing and  tread  end  cementing
facilities into one VOC control device are 2  to 20 percent less  than
the cost of operating  and maintaining  separate control  device;  the
                                  8-45
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degree of cost savings is dependent on the model plant size, the
control device, used, the type of tread end cementing performed, and
regulatory alterantive involved.  Due to greater energy  requirements,
the incremental annualized costs of Regulatory  Alternative  II  over
Regulatory Alternative I costs are generally  higher  for  systems ;using
afterburners than for emission reduction systems using carbon  adsorbers.
Annualized and incremental emission reduction costs  are  presented as
Table  8-11.      ,                                               ;
     8.1.2.3   Cos;t  Effectiveness,  the  cost  effectiveness of each VOC
emission  reduction  system  is  calculated  as the quotient  of the annualized
emission  reduction  costs and  the mass  of VOCs removed  from an activity's
exhaust stream.  Therefore, cost effectiveness expresses the cost of
removing  a unit  mass of  pollutant.   Through  the review of cost effective-
ness values  presented as Table 8-12,  it is observed that emission
reduction systems  which  employ carbon adsorbers are more cost effective
than  either direct flame or catalytic afterburners.  Even when ho
 recovery credits are given for reclaimed solvent, the cost effectiveness
 of carbon adsorbers is,  in most cases, superior to that  of eithjer type
 afterburner.  For the air flow rate and VOC  concentrations studied,
 emission reduction systems using catalytic afterburners  were  generally
 more cost-effective than systems employing direct flame  afterburners.
 Credits realized in the annualized costs are reflected  in  the cost
 effectiveness values.                                          ;
       Incremental cost effectiveness values  for VOC  emission  reduction
 systems  are derived  from  the quotient  of  the incremental annualized
 emission  reduction  costs  and the  incremental reduction  of VOC emissions.
 Credits  received for incremental  annualized costs  are also reflected
 in the incremental  cost effectiveness  values.  Incremental cost  effec-
 tiveness credits  are calculated for  all  emission  reduction systems
 used  on  organic solvent-based green  tire spraying  at one-line retrofits,
 30,000 tire per day model  plants,  and 50,000 tire  per day mode)  plants.
 Each  organic solvent-based green  tire spraying operation receives
  incremental  cost  effectiveness credits because in each case, ope size of
  emission reduction system can be  used to meet both regulatory alternatives.
  The retention time of the coated green tire in the spray  booth  is
                                    8-54
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-------
 critical to the degree of emission reduction achieved, whereas  other
 operations require larger capture/control systems  to  achieve  the
 additional emission reduction required in moving from Regulatory
 Alternative I to Regulatory Alternative  II.  Incremental  cost effec-
 tiveness values for emission reduction systems employed on applicable
 solvent application operations are presented along with the cost
 effectiveness values in Table 8-12.
      Curves illustrating the cost-effectiveness of 75 percent efficient
 retrofit emission reduction systems over a range of uncontrolled VOC
 emission factors were constructed for undertread cementing, sidewall
 cementing, automatic tread end cementing, manual  tread end cementing,
 bead cementing, and organic solvent-based green tire spraying operations,
 Retrofit emission reduction systems were chosen as these devices
 generally incurred higher operating costs than original-equiprr»nt
 systems.   The highest value in the range of uncontrolled VOC emission
 factors used  for developing the curves for each applicable operation
 represents the highest industry-reported VOC emission factor1"25; the
 lowest  value  used for each operation  was  nominally 1 gram of VOC.per
 tire.   It was  assumed that the air flow rates  and  capital  costs  for
 each  operation remained  constant over the entire  range of VOC  emission
 factors used.   The cost  curves  are presented  as Figures  8-1 through 8-6.
      8.1.2.4   Base Cost  of a  Facility.   Base  costs  of facilities vary
 depending on  the  model plant's  production rate  and  geographic  location.
 An  industry survey indicated  that the likely  size  of  a new plant may
 range from 18,000 to  40,000 tires per day.69  Land  costs  ranged  from
 0.5 to  12 million dollars;  the  costs  depend on  the  acreage required,
 geographic  location,  and  possible land  improvements.   Building costs
 range from  14  to  110 million  dollars.   Process  equipment  costs were
 estimated  to be between  100 and  200 million dollars.   The  utilization
 rate was  expected  to be 85 percent.69'70  Total projected  investment
 required  for the  three model  plant sizes  is derived from the industry
 survey  and presented in Chapter 9.  Total capital costs for model tire
manufacturing plants, excluding VOC emission reduction systems,  are
estimated to be approximately $186 million (15,000 tire per day  plant),
                                  8-63
-------
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                                                                              8-64
-------
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                                                                           8-65
-------
                                  69
$308 million (30,000 tires per day plant), and $450 million  (50,,000
tires per day plant).' Annualized costs for model plants are projected
in Chapter 9 to be about $124 million, $254 million, and $429 million
dollars for a 15,000, 30,000, and 50,000 tires per day model plant,
respectively.
     All costs presented above are in 1979 dollars.  The costs rinclude
construction of storage areas and employee facilities  (cafeteria  and
restrooms).  The average building life was estimated to be 50 y|ears,
and the average process equipment life was estimated to be 30 years.
     8.1.2.5  Cost Comparison With Industry Analysis.  This  cos|t
analysis of VOC emission reduction systems that  may be used  by |the
tire industry represents the only known  in-depth analysis performed  as
of March 1981.  A tire company that  has  installed a VOC emission
reduction system, equipped with  a carbon adsorber, as  original  equipment
on one plant's undertread cementing  facility  has factored the  capital
costs for emission reduction equipment from  the  capital costs  of  the
plant.^  Comparison  of the company-supplied  capital costs with costs
presented in this chapter that are adjusted  for  plant  size  indicates
that the company-supplied costs  are  approximately 2  percent  higher.
8.2  OTHER COST CONSIDERATIONS
     Costs that are  not directly associated  with reduction  of VOC
                                                               !
emissions from tire  manufacturing  are presented  and  discussed in  this
section.   Included are the  costs incurred  by the tire  industry to
comply  with  water pollution  control  regulations, solid waste disposal
requirements, Occupational  Safety and Health (OSHA)  regulations,  and
other  air  pollution  control  regulations.   Where appropriate, projected
annualized VOC emission  reduction costs  are compared to the other
regulatory costs.
8.2.1   Costs Imposed By  Water Pollution  Control  Regulations
      Existing  and new plants that discharge into surface waters are
subject to  the  effluent  limitations  specified in their National Pollutant
Discharge  Elimination System permits, which reflect limits presented
in the EPA Effluent  Guidelines for Water Quality Standards [40|CFR
428].71  All  tire  plants  that discharge wastewater containing toxic or
nonconservative  substances  into publicly owned  treatment systems  are
8-66
-------
-------
                                 69
$308 million (30,000 tires per day plant), and $450 million (50,000
tires per day plant).  Annualized costs for model plants are projected
in Chapter 9 to be about $124 million, $254 million, and $429 million
dollars for a 15,000, 30,000, and 50,000 tires per day model plant,
respectively.
     All costs presented above are in 1979 dollars.  The costs  jinclude
construction of storage areas and employee facilities  (cafeterii  and
restrooms).  The average building life was estimated to be 50, years,
and the average process equipment life was estimated to be 30 years.
     8.1.2.5  Cost Comparison With Industry Analysis.  This cost
analysis of VOC emission reduction systems that  may be used by  the
tire industry represents the only known in-depth analysis performed as
of March 1981.  A tire company that  has installed a VOC emission
reduction system, equipped with  a carbon  adsorber, as  original  equipment
on one  plant's undertread cementing  facility  has factored the  capital
costs for emission reduction equipment  from the  capital costs  of  the
plant.60  Comparison of the company-supplied  capital costs with costs
presented in this chapter that are adjusted for  plant  size  indicates
that the company-supplied costs  are  approximately 2  percent  higher.
8.2  OTHER  COST CONSIDERATIONS
     Costs  that are  not directly associated with reduction  of  VOC
emissions from tire  manufacturing  are presented  and  discussed  in  this
section.   Included are the  costs incurred by  the tire  industry to
comply  with water  pollution  control  regulations, solid waste disposal
requirements,  Occupational  Safety and Health  (OSHA)  regulations,  and
other  air  pollution  control  regulations.   Where appropriate, projected
annualized  VOC  emission  reduction costs are compared to the other
regulatory  costs.                                               j
8.2.1   Costs Imposed By  Water Pollution Control  Regulations
      Existing  and  new plants that discharge into surface waters are
subject to the effluent  limitations specified in their National Pollutant
Discharge Elimination System permits, which reflect limits presented
 in the EPA Effluent Guidelines for Water Quality Standards [40|CFR
428].71  All tire  plants that discharge wastewater containing  toxic or
 nonconservative substances into publicly owned  treatment systems are
8-66
-------
governed by Sections 307, 301(b)(2)(A), and 304(b)(2) of the Federal
Water Pollution Control Act [33 U.S.C. 1251, et seq.]; new plants are
also subject to the Pretreatment Standards for New Sources [40 CFR  129
and 403].       Tire plant effluent limitations were discussed in
Chapter 7.
     Industry-supplied information is used to determine the annualized
cost of water pollution control for a model plant which has no VOC
emission reduction systems installed.  The average annualized cost  for
water pollution control in plants with no VOC emission reduction
                                                   15 25
systems is estimated to be $0.04 per tire produced.  "    Water pollution
control costs could not be correlated to plant production rates due to
the lack of data.  The annualized water pollution control costs for
reporting plants are presented as Table 8-13.
             Table 8-13.  ANNUALIZED WATER POLLUTION CONTROL
                 COSTS INCURRED BY TIRE MANUFACTURERS15"25
                    Plant
Cost per Tire
Produced (1979$)
• = • A .
B
C
D
Average
0.027
0.033
0.098
0.011
0.042

8.2.2  Costs Imposed By Solid Waste Disposal Requirements
     Solid wastes from tire manufacturing are currently disposed  of  in
sanitary landfill, by shipment to reclaiming operations, or  recycled
for use as raw material in low-quality goods.
                                             58,59,61,75
                  Sanitary
landfills used for solid waste disposal must meet  the minimal  requirements
detailed in the EPA Guidelines for the Thermal Processing of Solid
Wastes and for Land Disposal of Solid Wastes [40 CFR 241].76   Solid
waste disposal is further discussed in Chapter 7.
                                  8-67
-------
     Industry-supplied data are used to determine the annualized cost
for solid waste disposal in a model plant employing no VOC emission
reduction equipment.  The average annualized cost for solid waste
disposal is estimated to be $0.04 per tire produced.  "    Solid waste
disposal costs were compared to percent production rates and found to
have poor correlation (r = -0.22).  Consequently, annualized per tire
solid waste disposal costs are nof determined for each size .of model
plant.  The annualized solid waste disposal costs for reporting plants
are presented in Table 8-14.                                   ,
8.2.3  Costs Associated Mith OSHA Compliance                   j
     The cost of compliance with OSHA regulations for the  tire manufacturing
industry is incurred primarily for ventilation  of the workplace!.
Discussion of OSHA requirements is presented in Chapter  3.     ;
     Industry-supplied data indicate that the average annualized cost
per tire that can be attributed to OSHA regulations  is approximately
$0.08.  Correlation between OSHA costs and plant production  rates  is
poor  (r = -0.64).  Consequently, annualized per tire OSHA  compliance
costs are not determined for each model plant size.  "     The  average
annualized per tire cost for OSHA  regulations is presented as  Table
8-15.                                                          ,
8.2.4   Costs Associated With Other Air  Pollution Control  Regulations
      Storage and movement  of carbon  black  in a  tire  plant  can  result
in particulate emissions to the ambient  air.55'59'61 40 CFR 50  sets
the primary and secondary  NAAQS for  particulates at  60 micrograms  per
cubic meter for the annual  geometric mean  and  150  micrograms per cubic
meter for one 24-hour  period a year.77   The  EPA Regulations onjPreparation
of Implementation  Plans  [40 CFR 51]  discusses  particulate emission
reductions achievable  with reasonably  available control  technology.
Consequently, the  tire industry employs  controls to  suppress particulate
emissions  as well  as  reduce losses of  valuable  carbon  black.  '   '
      Industry-supplied information indicates  that  the  average annual
cost  of particulate control  is  approximately $0.08 per  tire.  Correlation
of particulate  control  costs  to  plant  production rates  is poor|(r = -0.51).
Consequently, annualized per  tire particulate  control  costs are not
78
                                   8-68
-------
Table 8-14.  ANNUALIZED SOLID WASTE DISPOSAL COSTS
         INCURRED BY TIRE MANUFACTURERS15"25

Plant
A
B
C
D
E
F
G
H
I
J
K
L
M
N
0
P
Cost per Tire
Produced (1979$)
0.024
0.040
0.011
0.060
0.037
0.230
0.021
0.023
0.090
0.006
0.084
0.017
0.027
0.020
0.000
0.001
   Average
0.043
                       8-69
-------
Table 8-15.  ANNUALIZED COSTS INCURRED BY TIRE
   MANUFACTURERS IN ORDER TO COMPLY WITH
             OSHA REGULATIONS15"25
Plant
A
B
C
D
E
F
G
H
I
J
K
L
M
N
*
Cost per Tire
Produced (1979$)
0.002
0.001
0.000
0.001
0.041
0.005
0.106
0.147
0.197
0.338
0.202
0.004
0.010
0.001
Average
0.075
                     8-70
-------
-------
Table 8-15.  ANNUALIZED COSTS INCURRED BY TIRE
   MANUFACTURERS IN ORDER TO COMPLY WITH
             OSHA REGULATIONS15"25
Plant
A
B
C
D
E
F
G
H
I
J
K
L
M
N
Cost per Tire
Produced (1979$)
0.002
0.001
0.000
0.001
0.041
0.005
0.106
0.147
0.197
0.338
0.202
0.004
0.010
0.001
Average
0.075
                     8-70
-------
 determined for each model plant size.15"25   The  average annualized per
 tire cost of participate control for  reporting plants  is presented as
 Table 8-16.
 8.2.5  Composite Costs of Environmental Regulatory  Requirements
      The annualized costs projected to be incurred  by  the tire  industry
 to meet the requirements of the regulatory alternatives  are  presented
 in this subsection and compared to the annualized costs  not  directly
 associated with reduction of VOC emissions.
      8.2.5.1  Water Pollution Control.  The  annualized cost  of water
 pollution control that is attributable to a  model plant  VOC  emission
 reduction system which employs a carbon adsorber control  component is
 estimated by taking the proportion of the total wastewater flow con-
 tributed by the adsorber under each regulatory alternative and multiplying
 the value by the average annualized per tire cost of process and
 nonprocess wastewater treatment.   Annualized water treatment costs
 attributable to the carbon adsorber effluent under each  regulatory
 alternative are estimated to be  less than 0.05 percent of the average
 total  wastewater control  costs.   Afterburner control components incur
 no wastewater control  costs.   The average annualized wastewater control
 costs  for a VOC emission reduction system using a carbon adsorber and
 the total  plant wastewater treatment costs are compared in Table 8-17.
      8.2.5.2  Solid Waste Disposal.   Activated carbon requirements for
 the adsorber control  components  under each regulatory alternative were
 determined in Chapter  7.   The  carbon requirements for the adsorbers
 are converted to  a  per tire  carbon  requirement and used to estimate
 the proportion  of solid waste  contributed  by  each regulatory alterna-
 tive to  the  plant total.   The  product  of  that proportion and the
 average  annualized  cost of total  plant solid  waste disposal  per tire
 produced yields  the average annualized cost of  solid waste disposal
 attributable  to  the regulatory alternatives.   Average annualized  costs
 due  to disposal of  solid  wastes from the carbon adsorber control
 components under  each  regulatory alternative  represent  less  than
 0.05 percent of total  solid waste disposal costs.  Afterburner  control
 components incur  no solid waste disposal costs.   Solid  waste  disposal
costs associated with  VOC emission reduction  are  presented and  compared
to total plant solid waste disposal costs In  Table 8-17.

                                  8-71
-------
Table 8-16.  ANNUALIZED PARTICULATE CONTROL COSTS
        INCURRED BY TIRE MANUFACTURERS15"25

Plant
A
B
C
D
E
F
G
H
I
J
K
L
M
N
0
P
Q
R
S
T
U
Cost per Tire
Produced (1979$)
0.051
0.142
0.032
0.025
0.016
0.009
0.007
0.015
0.017
0.187
0.000
0.034
0.064
0.011
0.057
0.004
0.261
0.145
0.139
0.255
0.138
  Average
0.077
                      8-72
-------






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     8.2.5.3   Comparison  of  VOC  Emission Reduction Costs  to Paftticulate
Pollution Control  Costs.   Annualized  costs  associated with the !regulatory
alternatives for the model plants  are presented  in Section 8.I.1   When
                                                               !
solvent  recovery credits  are included,  VOC  emission reduction systems
                                                               i
employing carbon adsorber control  components  are expected to irjcur
annualized costs which  are approximately 50 percent less  (under  Regulatory
Alternative I) and 5 percent higher  (under  Regulatory Alternative II)
                                                               i
than the costs incurred by tire  manufacturers  for particulate (carbon
black) pollution controls.   When recovery credits are excluded,  systems
employing carbon adsorbers may have annualized costs  that are 45 percent
(under Regulatory Alternative I) and  60 percent  (under Regulatory
Alternative II) higher  than  the  costs for particulate pollution  controls.
VOC emission reduction  systems that use afterburners  may  have annualized
costs which are 245 to  510 percent above the  costs to operate and
maintain particulate pollution controls, depending on the afterburner
type employed  and the regulatory alternative  involved.  The annualized
model plant costs for each regulatory alternative and each VOC control
component are  presented and  compared  to particulate pollution control
costs in Table 8-17.                                           !
     8.2.5.4   Comparison  of  Total  Costs of  Compliance With Applicable
Regulatory Requirements.  VOC emission  reduction  systems  using Icarbon
adsorbers are  expected  to  increase total  annualized costs for compliance
with all applicable regulations  by approximately  15 percent (under
Regulatory Alternative  I with recovery  credits)  to 50 percent (under
Regulatory Alternative  II with recovery credits),  or  by $0.04 to
$0.12 per tire.  Use of afterburner control components  is projected to
increase total  annualized costs  for compliance with all regulatory
requirements by 110 to  140 percent ($0.24 to $0.33 per  tire),  depending
on the afterburner type employed and  the regulatory alternative!  involved.
The average annualized costs  per tire for non-VOC  related regulatory
requirements are totaled and  compared to the projected  annualized
costs of the VOC emission reduction systems in Table  8-17.     ;
                                  8-74
-------
8.3

  1.



  2.




  3.


  4.


  5.


  6.


  7.


 8.



 9.



10.


11.


12.



13.


14.
 REFERENCES

 Letter from P.M.  Luysterborghs, Armstrong Rubber Company, to
 R.T.  Walsh, ESED/CPB/EPA.   October 26, 1978.   Response to
 Section 114 letter.

 Letter from E.J.  Burkett,  The Goodyear Tire and Rubber Company,
 to D.R. Goodwin,  ESED/OAQPS/EPA.   May 17, 1978.  Response to
 Section 114 letter.

 Letter from R.C.  Miles,  Uniroyal,  Inc., to D.R. Goodwin, ESED/
 OAQPS/EPA.   July  13,  1978.   Response to Section 114 letter.

 Letter from R.C.  Miles,  Uniroyal,  Inc., to D.R. Goodwin, ESED/
 OAQPS/EPA.   May 16,  1978.   Response to Section 114 letter.

 Letter from R.C.  Miles,  Uniroyal,  Inc., to D.R. Goodwin, ESED/
 OAQPS/EPA.   May 24,  1978.   Response to Section 114 letter.

 Letter from R.C.  Niles,  Uniroyal,  Inc., to D.R. Goodwin, ESED/
 OAQPS/EPA.   April  4,  1978.   Response to Section 114 letter.

 Letter from N. Onstott,  Mohawk Rubber Company,  to K.J.  Zobel,
 ESED/OAQPS/EPA.   March 21,  1978.   Response to  Section  114 letter.

 Letter from R.M.  Walter, The  Firestone Tire and Rubber  Company,
 to  D.R.  Goodwin,  ESED/OAQPS/EPA.   May 5,  1978.   Response to
 Section 114 letter.

 Letter from R.M.  Walter, The  Firestone Tire and Rubber  Company,
 to  D.R.  Goodwin,  ESED/OAQPS/EPA.   June 7,  1978.   Response to
 Section  114 letter.

 Letter from J.W.  Lewis, The B.F. Goodrich  Company,  to R.T. Walsh,
 ESED/OAQPS/EPA.   May 24, 1978.  Response  to Section  114  letter.

 Letter from L.B.  Cooper, Michel in  Tire  Corporation,  to D.R. Goodwin,
 ESED/OAQPS/EPA.  April 13, 1978.   Response  to Section 114 letter.

 Letter from  R.M. Walter, The  Firestone  Tire an.d  Rubber Company,
 to R.T. Walsh, ESED/OAQPS/EPA.  June  29,  1978.   Response  to
 Section 114  letter.

 Letter from L.B. Cooper, Michelin Tire  Corporation,  to D.R. Goodwin,
 ESED/OAQPS/EPA.  March 13, 1978.  Response  to Section 114 letter.

 Letter from R.W. Frase, General Tire and Rubber Company, to D.R.
Goodwin, ESED/OAQPS/EPA.   May 16, 1978.  Response to Section 114
letter.
                                  8-75
-------
15.  Letter from E.J. Burkett, The Goodyear Tire and Rubber Company,  to
     J.R. Farmer, CPB/ESED/OAQPS/EPA.  March 31, 1980.  Response  to
     Section 114 follow-on letter.

16.  Letter from R.C. Miles, Uniroyal, Inc., to O.R. Farmer,  CPfc/ESED/
     OAQPS/EPA.  April 11, 1980.  Response to Section  114 follow-on
     letter.

17.  Letter from J.R. Laman, The Firestone Tire and Rubber Company, to
     D.R. Goodwin, ESED/OAQPS/EPA.  April 8, 1980.  Response  to Section
     114 follow-on letter.

18.  Letter from J.R. Townhill, The General Tire and Rubber Company,  to
     K.J. Zobel, CPB/ESED/OAQPS/EPA,  April 2, 1980.   Response to Section
     114 follow-on letter.

19.  Letter from R.R. Clark, The BF Goodrich Company,  to D.R. Goodwin,
     ESED70AQPS/EPA.  March 18, 1980.  Response to Section 114 follow-on
     letter.

20.  Letter from F.M. Luysterborghs, Armstrong Rubber  Company, to D.R.
     Goodwin, ESED/OAQPS/EPA.  March 5, 1980.  Response to Sectjion 114
     follow-on Tetter.                                         i
                                                               i

21.  Letter from E.J Burkett, The Goodyear Tire and Rubber Company, to
     J.R. Farmer, CPB/ESED/OAQPS/EPA.  March 21, 1980.  Response  to
     Section 114 follow on letter.                             ;
           "                                                    i
                                                               i
22.  Letter from L. Cooper, Michel in Tire Corporation, to J.R. Farmer,
     CPB/ESED/OAQPS/EPA.  February 19, 1980;.  Response to Section 114
     follow on letter.
                                                               i
23.  Letter from R.C. Miles, Uniroyal, Inc., to J.R. Farmer,  CPB/ESED/
     OAQPS/EPA.  May 12, 1980.  Response to Section 114 follow on letter.

24.  Letter from J.R. Laman, Firestone Tire and Rubber Company, to D.R.
     Goodwin, ESED/OAQPS/EPA, April 17, 1980>  Response to Section 114
     follow on letter.                                         •

25.  Letter from R.R. Clark, The. B-.F. Goodrich Company, to D.R.1 Goodwin,
     ESED/OAQPS/EPA.  April 16, 1980.  Response to Section 114 follow on
     letter.

26.  Zobel, K.J., and N. Efird.  Control  of Volatile Organic  Emissions
     from Manufacture of Pneumatic Rubber Tires.  U.S. Environmental
     Protection Agency.  Research Triangle Park, N.C.  Publication No.
     EPA-450/2-78-030.  December 1978.  59 p.

27.  Telecon.  Nelson, G., Dow Corning Corporation, with Rinaldi, G.M.,
     Monsanto Research Corporation^  August 22, 1978.  Composition of
     water-based sprays used by the tire industry.
                                  8-76
-------
28.  Telecon.  Raleigh, W. and A. Wotiz, General Electric Company, with
     Rinaldi, 6.M., Monsanto Research Corporation.  August 22,  1978.
     Composition of water-based sprays used by the tire  industry.

29.  Telecon.  Wittekind, R., SWS Silicones Corporation, with Rinaldi,
     G.M., Monsanto Research Corporation.  August 22,  1978.  Composition
     of water-based sprays used by the tire industry.

30.  Letter from H.L. Brooks, SWS Silicones Corporation, to  K.J. Zobel,
     EPA.  July 3, 1979.  Comments on proposed Guidance  Document for  the
     Group II Control Techniques Guidelines for Volatile Organic,Compounds.

31.  Telecon.  Brewer, R.M., The C.P. Hall Company, with Aus, B., Pacific
     Environmental Services, Inc.  September 29, 1980.   Composition of
     water-based green tire sprays used by the tire industry.

32.  Basdekis, H.S., Emissions Control Options for the Synthetic Organic
     Chemicals Manufacturing Industry.  U.S. Environmental Protection
     Agency.   Research Triangle Park, N.C.  EPA Contract No. 68-02-2577.
     February 1980.  p. 11-33.

33.  Hydrocarbon Pollutant Systems Study, Volume I - Stationary Sources,
     Effects, and Control.  U.S. Environmental Protection Agency.
     Research Triangle Park, N.C.  Publication No. APTD-1499.  October
     1972.  377 p.

34.  Letter from G.I. Madden, E.I. DuPont de Nemours and Company, Incorporated,
     to E. Karger,  Gates Rubber Company.  November 9, 1976.  Performance
     of catalytic incinerator.

35.  Danielson, J.A., ed.  Air Pollution Engineering Manual, Second
     Edition.  U.S. Environmental Protection Agency.  Research Triangle
     Park, N.C.  Publication No. AP-40.  1973.  987 p.

36.  Lukey, M.E., and M.D. High.  Exhaust Gas Conversion Factors, Zurn
     Environmental Engineers.  Engineering Science, Incorporated.
     Washington, D.C.  (Presented to the Air Pollution Control Association
     Annual Meeting.  Miami Beach, FL.  June 18-22, 1972.) 16 p.              .

37.  Sandomirsky, A.G., D.M. Benforado, L.D. Grames, C.E. Pauletta.
     Fume Control in Rubber Processing by Direct-Flame Incineration.
     Journal  of the Air Pollution Control Association.  11:673-676.
     December 1966.

38.  Rolks, R.W., R.D. Hawthorne, C.R. Garbett, E.R. Slater, and T.T.
     Phillips.  Afterburner Systems Study.  U.S. Environmental Protection
     Agency.   Research Triangle Park, N.C.  Publication No.  EPA-R2-72-062.
     August 1972.  512 p.

39.  Miller,  M.R., and H.J. Wilhoyte.  A Study of Catalyst Support
     Systems  for Fume Abatement of Hydrocarbon Solvents.   Journal of the
     Air Pollution Control Association.  17:791-795.  December 1967.
                                  8-77
-------
40.  Letter from R.6. Litman, Met Pro Corporation, to B. Aus, Pjacific
     Environmental Services, Incorporated.  February 5, 1980.  Operating
     and cost information for catalytic afterburners.
                                                               i
41.  Letter from F. DeRosa, Engelhard Industries, to B. Aus, Pacific
     Environmental Services, Incorporated.  February 13, 1980. ; Operating
     and cost information for catalytic afterburners.

42.  Ross, R.D.  Pollution Abatement:  Incineration of Solvent-Air
     Mixtures.  Chemical Engineering Progress.  68:(8):62.

43.  Telecon.  Kirkland, J., Hirt Combustion Engineers, with Aus, B.,
     Pacific Environmental Services, Incorporated.  December 14,  1979.
     Operating and cost information for direct flame afterburners.

44.  Letter from J.J. Sudnick, Trane Thermal Company, to B. Ausi,  Pacific
     Environmental Services, Incorporated.  January 2, 1980.  Incineration.

45.  Telecon.  Oakes, D., Hoyt Manufacturing Corporation, with 'Aus, B.,
     Pacific Environmental Services, Incorporated.  December 18,  1979.
     Operating and cost information for carbon adsorbers.      ;

46.  Telecon.  Karish, R.L., Vulcan Cincinnati, with Aus, B., Pacific
     Environmental Services, Incorporated.  December 14, 1979. i
                                                               i
47.  Jongleux, R.F.  Volatile Organic Carbon Emission Testing at  Armstrong
     Rubber Company, Eastern Division, West Haven, Conn.  TRW, jEnvironmental
     Engineering Division.  Durham, N.C.   April 1979.          ;

48.  Telecon.  Byrum, R., The E.W. Buschman Company, with Aus, ;B.
     Pacific Environmental Services, Inp.  November 6, 1980.  Cost  of
     Conveyor Systems.

49.  Telecon.  Coe,  B., Litton Unit Handling Systems, with  Aus,; B.,
     Pacific Environmental Services, Inc.  November 20,  1980.  ;Cost of
     Conveyor Systems.                                         !

50.  Telecon.  Johnson, L., Stone Conveyor Division of Honeoye (Industries,
     Inc., with Aus, B.   Pacific Environmental Services,  Inc. November 20,
     1980.  Cost  of  Conveyor Systems.                          :

51.  Neveril, R.B.,  Capital and Operating Costs  of Selected Air  Pollution
     Control Systems.   U.S. Environmental  Protection Agency, Research
     Triangle  Park,  N.C.   Publication  No.  EPA  450/5-80-002  December
     1978.
52.  Standard & Poors Industry Surveys
     wage rise.
                                          Price boosts to help offset
                                                               i
 53.   Peters,  M.S.  and Timmerhaus,  K.D.   Plant Design and Economics for
      Chemical Engineers.   Second Edition.   McGraw-Hill  Book Company.
      New York,  New York.   pp.  90-156.
                                   8-78
-------
54.  Chemical Marketing Reporter. January 7, 1980.  pp 48-57.

55.  The Wall Street Journal. January 22,"1980.  p. 39.

56.  Parmele, C.S., W.L. O'Connel, and H.S. Basdekis.  Vapor-Phase
     Adsorption Cuts Pollution, Recovers Solvents.  Chemical  Engineering.
     December 31, 1979.  pp. 58-70.

57.  McAdams, M.T.  Trip Report:  Armstrong Rubber Company, West  Haven,
     Conn.  July 27, 1979.

58.  McAdams, M.T.  Trip Report:  Firestone Tire and Rubber Company,
     Wilson, North Carolina.  September 13, 1979.

59.  McAdams, M.T.  Trip Report:  Kelly-Springfield .Tire Company,
     Fayetteville, North Carolina.  March 18,  1979.  (Confidential
     file.)

60.  Letter from E.J. Burkett, The Goodyear Tire and Rubber Company,  to
     K.J. Zobel, ESED/OAQPS/EPA.  May 14, 1979.  Hydrocarbon  emission
     information related to  future tire plants NSPS.

61.  Industrial Ventilation:  A Manual of Recommended Practice, Twelfth
     Edition.  American Conference of Governmental Industrial  Hygienists.
     Committee on Industrial Ventilation.  Lansing, Mich.  1972.   337 p.

62.  McDermott, H.J.  Handbook of Ventilation  for Contaminant Control.
     Ann Arbor Science Publishers, Incorporated.  Ann Arbor,  Michigan.
     1976.  368 p.

63.  Chemical Engineering.   December 31,  1979.  p. 7.

64.  Telecon.  DeRosa, F., Engelhard Industries, with Aus, B., Pacific
     Environmental Services, Incorporated.  January 25,  1980.   Catalytic
     afterburner size constraints.

65.  Perry, R.H., and C.H. Chilton.  Chemical  Engineers  Handbook.   5th
     Edition.  McGraw-Hill Book Company.  New  York, New  York.   1973.

66.  Energy User News.  January 21, 1980, p. 15.

67.  CE Air  Preheater Industrial Gas Cleaning  Institute.   Report  of Fuel
     Requirements, Capital Cost and Operating  Expense for  Catalytic and
     Thermal Afterburners.   U.S. Environmental  Protection  Agency.
     Research Triangle Park, North Carolina.   EPA  Publication No.
     EPA-450/3-76-031.  September  1976.

68.  PEDCo Environmental,  Incorporated.   Cost  Analysis Manual  for
     Standards Support Document.  U.S. Environmental Protection Agency,
     Research Triangle Park, N.C.  Apirl  1979.  p. G-9.
                                   8-79
-------
69.  Letter from F.T. Ryan, Rubber Manufacturers Associations,  to A.B.
     Bacon, JACA Corporation.  January 16, 1980.  Capacitys  investment,
     and operating parameters for new tire plants.

70.  Letter from M.T. McAdams, Pacific Environmental Services,
     Incorporated, to K.J. Zobel and D. Patrick,  U.S. Environmental
     Protection Agency,  [date to be added later]  Operating  parameters
     for tire manufacturing plants.

71.  U.S. Environmental Protection Agency.  Code of Federal  Regulations.
     Title 40, Chapter I, Part 428.  Washington, D.C.  Office of the
     Federal Register.  February 21, 1974.                      ;

72.  United States Congress.  Federal Water Pollution Control Ajct, as
     amended by the Clean Water Act of 1977.  33 U.S.C.  1251  et; seq.
     Washington, D.C.  U.S. Government Printing Office.

73.  U.S. Environmental Protection Agency.  Code of Federal  Regulations.
     Title 40, Chapter I, Part 129.  Washington, D.C.  Office of the
     Federal Register.  January 12, 1977.                       ,

74.  U.S. Environmental Protection Agency.  Code of Federal  Regulations.
     Title 40, Chapter I, Part 403.  Washington, D.C.  Office of the
     Federal Register.  June 26, 1978.                          !

75.  Pettigrew, R.J. and F.H. Rom'nger.  Rubber Reuse and Solid Waste
     Management, Part I:  Solid Waste Management in the  Fabricated
     Rubber Products Industry, 1968.  U.S. Environmental Protection
     Agency.  Washington, D.C.  Publication No. SW-22c.  1971.  pp.
     8-13.

76.  U.S. Environmental Protection Agency.  Code of Federal  Regulations.
     Title 40, Chapter I, Part 241.  Washington, D.C.  Office of the
     Federal Register.  August 14, 1974.

77.  U.S. Environmental Protection Agency.  Code of Federal  Regulations.
     Title 40, Chapter I, Part 50.  Washington, D.C.  Office  ofj the
     Federal Register.  November 25, 1971.                      •

78.  U.S. Environmental Protection Agency.  Code of Federal  Regulations.
     Title 40, Chapter I, Part 51.  Washington, D.C.  Office  of; the
     Federal Register.  November 25, 1971.                      ;
                                  8-80
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                             9.0   ECONOMIC  IMPACT

 9.1   INDUSTRY CHARACTERIZATION
 9.1.1  General Profile
      9.1.1.1  Industry Structure.  Presently,  12 firms manufacture  tires  in
 the United States.1  A company's size  is based  on  its daily  production  rate
 of tires, with three size classifications existing within the  industry.
 Goodyear, Firestone, General, B. F. Goodrich, and  Uniroyal, dominate the
 industry and are generally referred to as the "Big Five".2   in 1979, the
 "Big Five" and their subsidiaries operated 35 of the 55 domestic tire plants,
 and manufactured 81 percent of all  tires produced domestically.  Armstrong,
 Cooper, Ounlop,  and Michel in are intermediate in size and produce in the
 range of 20,000  to 69,000 tires per day.  The Mohawk, Denman, and McCreary .
 firms are categorized as small companies and produce between 500 to 19,000
 tires per day.   Tire manufacturers, their locations, and 1979 daily produc-
 tion rates are listed in Table 3-1.
      9.1.1.2  Ownership.   Three domestic firms, Denman,  McCreary, and Dunlop,
 are privately held.   Michel in is a  privately held French-owned corporation
 that currently operates  three plants  within  the U.S., with  two additional
 plants  scheduled  to  come  on-stream  in  1982.1  Michel in  has  established  a
 strong  reputation  in  the  U.S.  market  since  its development  of the radial
 tire.   The remaining  firms are publicly owned.
      9.1.1.3  Diversification.   Company product  lines can  include nontire-
 related commodities.  The  larger  firms  are the  most  diversified, producing  a
 multitude  of  products and  manufactured  goods:  chemicals, plastics,  indus-
 trial and  aerospace products,  rubber goods,  flooring, packaging film, foot-
 wear, and  enriched uranium.3   The smaller companies  are typically undiver-
 sified firms  which primarily market tire-related  products.
     The major companies are predicted  to continue  expansion  into  nontire-
related operations.  The industry's trend toward diversification  has  a number
of contributing factors:1*4
                                     •9-1
-------
     •    The declining sales of new automobiles
     •    The accelerating labor problems associated with tire production
     •    The increasing number of imported tires
     •    The capital expenditures associated with operating  low-effjiciency
          pi ants                                                    :
     •    The capital costs for construction of new facilities for radial
          tire production.                                       .,jf-

     In 1978, the General Tire Company led the  industry  in  the percentage
of pre-tax profits obtained from nontire-related businesses,  receiving  67
percent of its pre-tax profits from diversified activities.   Goodyear,  the
front runner in tire production, has the least diversified  product line among
the Big Five tire producers.  The company has attributed 80 percent |of  its
pre-tax profits to tires and related products over the past 5 years.5
     The Big Five also produce tire fabricating materials.  All  produce
                                                                    i
the synthetic elastomer styrene-butadiene, which is used as a raw material
in tire production.  Three of the major firms,  Goodyear, Firestone, |and
Uniroyal, produce their own natural rubber.6  Firestone,  also  produces
steel, cord, and beadwire.
     Armstrong is virtually undiversified.   In  addition  to  tires and tubes,
Armstrong produces only wheels and some raw materials.7  Michel in al,so
limits its manufacturing operations to relatively few  product lines.
     Small and intermediate sized firms are not diversified beyond the
manufacture of tire  related products.  These firms have  product  lines  which
include:

     •    Tire repair materials - plugs, patches
     •    Mechanical goods - hoses, belts
     •    Rubber products - sporting goods, footwear
     •    Specialty  tires - race cars, antique  cars, and off-highway vehicles.

The McCreary Tire Company has taken an approach of product-line  specializa-
tion rather than product-line diversification.   Its  production  is aimed
toward specialty tire markets.8
                                      9-2
-------
       9.1.1.4  Market Concentration.  Tires are described and categorized
  according  to:

      •    Type of construction  (bias-ply,  bias-belted, or radial)
      •    Vehicle type  (passenger car,  truck,  farm equipment, off-the-road,
            other)
      •    Marketv(original  equipment  or replacement).

  The extent of  industry  concentration  is much greater  in  the  original  equip-
 ment market  than  in  the replacement market.  In  1979,  Michel in  and  the  Big
  Five supplied  automobile manufacturers  with approximately 61.2  million  tires,
 representing 100  percent of the original equipment  (O.E.) market  share. 1
 During the same year, these sane  six firms and their subsidiaries sold  only
 45.2 percent of all  passenger tires sold in the replacement market  under
 their own names.   Table 9-1 shows the distribution of original  equipment
 shares with respect  to  the firms.  Table 9-2 depicts replacement market
 shares for passenger car tires by brand name.
      9.1.1.5  Raw Materials.  The tire  industry is the leading consumer of
 natural and synthetic rubbers in the U.S.  Raw materials used to produce
 tires  and rubber related goods include,  but are not limited to:  synthetic
 rubber, natural rubber,  synthetic fibers, steel,  wire, carbon black and
 rubber  chemicals.   In 1978 synthetic rubber accounted  for approximately 76
 percent of  all  new rubber  consumed in  the U.S.   Styrene-butadiene rubber
 captured  58 percent of the synthetic rubber market in  1978.5  Synthetic
 rubbers other than styrene-butadiene include:   polybutadiene, butyl, ethylene-
 propylene,  polychloroprene,  nitrile  and  polyisoprene.   These  compounds are
 used more selectively in special  tire  or rubber applications.
     Presently,  a  higher ratio of  natural rubber  to  synthetic rubber is  being
 utilized  in tire fabrication than  was  used  5 years  ago.   This increase in  the
 use of  natural  rubber in tire production is associated  with the  increase in
 production of radial  tires.  Rubber composition of the  average radial  tire is
 5.5 pounds of natural rubber and 6 pounds of synthetic  rubber.   The  typical
bias-ply  tire uses  8  pounds of synthetic  rubber and 2 pounds  of  natural  rubber.5
     Prices for synthetic rubber fluctuate over a wider range  than the prices
of natural rubber.  Spiral ing costs for  oil and natural gas are  directly
                                     9-3
-------
Table 9-1.  ESTIMATED SHARES OF ORIGINAL  EQUIPMENT MARKET
                         (1979)9
Goodyear
Uhiroyal
Firestone
General
Goodrich
Michel in
 27.8%
 24.6%
 22.6%
 13.0%
  9.5%
  2.5%
100.0%
aReference
                            9-4
-------
Table 9-2.  BRAND SHARES OF REPLACEMENT PASSENGER TIRE MARKET*
Goodyear
Firestone
Sears
Michel in
Wards
B. F. Goodrich
Kelly-Springfield
K-Mart
Atlas
Uni royal
Penny's
General
Dunlop
Dayton
Delta
Copper
Armstrong
Remington
Multi-Mile
Hercules
Others
14.0%
10.5%
10.0%
5.0%
5.0%
4.5%
3.0%
3.0%
3.0%
3.0%
3.0%
3.0%
3.0%
2.2%
1.5%
1.3%
1.2%
1.0%
1.0%
1.0%
20.8%
aReference 1.
                              9-5
-------
responsible for the higher price of  synthetic  rubber  products,  which are
produced from these resources.  Tire  producers have been  faced  with  rising
costs for raw materials since the oil  embargo  of  1973.9  As  a resuTti the
cost increases incurred by the  industry's  purchase of raw materials  are
passed on to the consumer.
9.1.2  Industry Trends
     9.1.2.1  Demand  Determinants.   In 1979,  passenger and truck tire ship-
ments totaled to 228  million  units,  as shown  in Table 9-3.l  Estimates of
tire shipments  in  1979 varied  according to sources  from 215 million  tires to
237 million tires.3»5 An  increasing volume of tires  was shipped annually
between  1975  and 1978, although each year  the growth  in annual  shipments
was declining.   Fewer tires  were  shipped in 1979 than were shipped in 1978,
reflected by  an  8  percent  decrease  in shipments.   Tire manufacturers' com-
bined profits  in 1979 fell  approximately 21 percent from those in 1978,
reaching the  lowest  level  since 1971.3  Production  slowdowns and decreased
profit margins  are attributed to  higher direct decline in automobile! travel,
and the  longer  life-time  of radial  tires.10
      g.1.2.1.1  Replacement market.   Passenger tires are the dominant type  of
tire  sold  in  the replacement market.   In 1979, 72.6 percent of all passenger
tires  shipped were in the replacement market, while 81.6 percent of  :all  tire
shipments  were passenger  tires.  Passenger tires shipped  in the replacement
market represented 59.2 percent of all tire shipments  in  1979.  Demand  for
the passenger tire in the replacement market  declined  about 8.2 percent
between  1978 and 1979,  exemplified by  shipment figures of 147 million  units
 in 1978 and 135 million units  in 1979.  The increased  use of radial  'tires  and
their extended durability and  lifetime have contributed  to  the declining need
for replacement tires.  Demand for replacement tires  is  also influenced  by
the consumer's disposable income and  tire  preference.   In  1980, over] 50
 percent of passenger tires shipped  to  the  replacement  market are  predicted
 to be radials.l                                                      ;
      g.1.2.1.2  Original equipment market.   In  1979,  the original equipment
market received 26.8 percent of all  tire  shipments.   Passenger tires are the
major type of tire supplied  to the  original  equipment market,  capturing 83
 percent of the market share; while  truck  tires represent only  17 percent of
 all tires shipped to the original equipment market.   A decl ine in domestic
                                       9-6
-------
                       Table 9-3.  INDUSTRY TRENDe
                                (millions)

                               1975
Passenger Tires
  Replacement
  QE
  Total
129
 40
169
137
 50
187
139
 58
197
135
 51
186C
Truck Tires
Repl acement
OE
Total
Total Tires
21,4
ilil
29.7
198.7
23.4
JJ.2
32.6
219.6
28.5
11.2
39.7
236.7
32b
12
44
247.5
31.8
M-I
42. Od
228.0

^Includes 12 million imports*
bIncludes 3.1 million imports,
clncludes 14.3 million imports both captive and noncaptive.
^includes 5 million imports both captive and noncaptive.
^Reference 1..
                                     9-7
-------
car production has adversely affected the original equipment market,  as  the
demand for tires in this market is based on the demand  for new cars.j   Between
1978 and 1979, shipments to this market decreased  approximately  10  percent,
from 68.5 million to 61.2 million tires.
                                                                    I
     The Big Five and Michel in supply 100 percent  of  the  tires required  in
original equipment market.  As shown in Table  9-1, Goodyear  is the  largest
supplier of tires for new cars, with an estimated  27.8  percent of the market
share.  Goodyear supplies Chrysler and /"merican Motors  with  over half of
their tire needs, as well as roughly 22 percent of both Ford  and General
Motor's tire requirements.  Uniroyal has captured  24.6  percent of the ori-
ginal equipment market, primarily due to the large supply commitment  made
to General Motors.
     Firestone is the largest single tire supplier to the Ford Motor  Company
and is ranked third among original equipment suppliers, having 22.6 percent
of the market share.  General, Goodrich, and Michel in complete the  list  of
tire suppliers to the original equipment market.
     Radial tires are expected to be installed on  80  percent of  all new  cars
assembled  in 1980, as seen'  in Table 9-4.   In 1972, only 5 percent of  all  new
cars were  equipped with radial tires.   In  1979, radials accounted for 63.2
percent of all tires shipped  in the original equipment  market.     ;
     9.1.2.1.3   Imports and Foreign Producers. Tire  imports made a minimal
contribution to domestic tire supplies  until the  late 1960's.l°   In irecent
years, tire imports have increased steadily, as seen  in Table 9-5.U   The
Department of Commerce estimated that  in 1978, 15  percent of the tire market
was composed of  imports.10  Some analysts  have attributed the growth  of
imports to: 12

     •     The high quality  of imported  radial  tires
     •     A lag of innovation and production on behalf  of U.S. firms
     •     The U.S. labor strike of 1976  lowering domestic inventories.

Sales of tires produced by  foreign-owned companies are  expected  to  rise  when
the new Michel in plants begin operation.   Michel in's  production  increase
could intensify  price and market competition.5
     9.1.2.1.4   Exports.  Export levels  peaked in  1974  and  1975, and  subse-
quently declined.13  The industry's labor  strike'accounted  for decreased
                                      9-8
-------
 Table 9-4.  PASSENGER TIRE SHIPMENTS  BY MARKET ,AND TIRE CONTRUCTION FOR 19793

Original Equipment
Repl acement
Total
% of Total
Bias
7.7
44.6
52.3
28.1
Bias-Belt
4.6
25.7
30.3
16.3
Radial
38.7
64.7
103.4
55.6
Total
51
135
186
                           TREND FOR PASSENGER TIRES
              By Percent of Market Shares and Tire Construction

                                               Bias    mas-Belt    Radial
      Original  Equipment
        1980
        1979
        1978
        1977

     Replacement
14
15
13
10
 6
 9'
18
22
80
76
69
68
1980
1979
1978
1977
30
33
35
36
17
19
23
26
53
48
42
38

Reference 1.
                                     9-9
-------
         Table 9-5.  TIRE .EXPORTS AND  IMPORTS

                      (000 tires)
Year -'-""
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
Exports9
2,51,8
2,364
1,531
1,589
2,127
4,393
9,229
6,124
4,784
5,390
Import sb»c
N/A
N/A
5,300
6,800
8,700
9,500
10,400
9,600
14,600
15,800
Reference 13.

bReference 11.

cConsisting of import plus Michel in shipments.   Since
 Michel in's Spartanburg plant began operating  in the
 early third quarter, 1976, and  Greenville  plant began
 operating in the early second quarter,  1975, the
 estimates for 1975 and 1976 are overestimates.  The
 1977 estimate does not include  Michel in sales to  the
 original equipment market.  In  addition, the  import
 estimates are for truck and passenger tires only.
                           9-10
-------
 exports in 1976 because the domestic demand for tires had to be supplied by
 existing inventories.
      In 1977,  the value of export shipments was $310 million, approximately
 29 percent of  the $1.1 billion value of import shipments.1°  Tire exports
 contributed to only a minor share of 1977 domestic tire production and
 represented 3.6 percent of the total dollar value for domestic shipments.
      9.1.2.2  Tire Prices.  Goodyear and Firestone have generally led price
 increases  among the tire producing firms.  However, other companies (Uniroyal
 and Armstrong) have initiated industrywide price increases.  The industry is
 often  involved in a cost-price strategy aimed at capturing larger market
 shares.  Price cutting may occur in response to excess capacity, poor sales
 or competition.  Rising costs for raw materials and labor incurred by the
 tire industry  initiated four separate price increases followed by discounting
 in 1979.   The  list price of a replacement tire was raised by 19 percent as a
 result  of  the  increased production costs.14
      The  average price paid for  a tire has increased by more than 40 percent
 in the  last 10 years.  The most  dramatic increase occurred between 1973 and
 1974 when  the  price rose by 16 percent.   Table 9-6 lists the tire price index
 for  years  1968 through 1977 and  1978 median retail  tire prices.15* 1-6
     9.1.2.3  Expansions and Capacities.  The tire industry expanded rapidly
 during  the 1960's followed by a  slowdown in the early seventies.   Plant
 expansions since 1972 have been  to increase production of radial  or non-
 passenger  tires.14»17  A deteriorating business climate during  the late 1970's
 has  forced  numerous plant closures.   Presently, the tire industry is exper-
 iencing  a  deep recession.14  Current plant operations  are estimated  to be
 functioning  at 80 percent of capacity based on a 5-day work  week,8 while in
 1978, the  industry was  estimated  to  have utilized  85 to 90 percent of total
 capacity.i8  Twenty individual plant closures  have  occurred  since  1976
 (refer  to  Table  3-2 in  Chapter 3).   Eight  plant closures during  the  last 2
years have  cut the  industry's  production capacity by 9 percent.8   Addi-
tional  plant closures  have  recently  been announced  by Firestone,  Uniroyal,
and Armstrong.   Firestone  and  its  subsidiaries  closed  five tire  plants in
November 1980:   Dayton  and  Barberton, Ohio;  Los Angeles  and  Salinas,  Cali-
fornia; and  Pottstown,  Pennsylvania.^   Uniroyal announced  in  January 1980,
that it would  be closing  plants  in Detroit,  Michigan,  and  Chicopee  Falls,
                                     9-11
-------
     Table 9-6.  TIRE PRICE INDICES (1968.1978) AND CURRENT RETAIL PRICESa

Year
1968
1969
. 1970
1971
1972
1973
1974
1975
1976
1977
June 1978
1967 = 100
*December

Year
1979
1978
1977
1976

Passenger Cars
Overall Bias Ply 	 Belted-Bias Radial
102.8 -
102.3 - - -
109.0 -
109.2 -
109.2 -
111.4 -
133.4 , -
148.5 142.1 104.1* . 105.8*
161.5 153.3 112.3* 113.6*
169.3 165.5 117.5 117.4*
179.3 -
unless otherwise specified.
1974 = 100.
MEDIAN TIRE PRICES&
Bias Bias-Belted
37.57 44.94
32.50 47.50
32 . 50 42. 50
29.81 , 37.02


Truck
-
;
-
-
111.3 ,
115.7
141.6 ;
155.4 :
172.8 ;
181.7
_



Radial
69.87
62.5;0
62.50
58.48


Tractor
-
"
-
-
114.4
117.9
147.4
166.9
182.8
194.6
_









,aReferences  15 and 16.
 bReference 1.
                                      9-12
-------
 Massachusetts,20 while Armstrong has closed its West Haven, Connecticut
 plant.   The impact of industry's production decline is most evident in Akron
 and  Los  Angeles,  cities once considered as the nation's first and second
 largest  tire producers.  After the announced closings are completed, not a
 single passenger  tire will  be produced in either Akron or Los Angeles.21
 Over-capacity for bias-belt production and outdated facilities that were
 built  in the early 1900's have contributed to plant closures.20  Experts
 cite the closing  of older plants as "one of the penalties of progress."21
     The industry has constructed new facilities arid consolidated older, less
 efficient plants  to accommodate for the production of radial tires.  Capital
 expenditures for  the rubber industry in 1979 were estimated to be $2.05
 billion, up 17 percent from 1978.  This increase in capital expenditures
 reflects the industry's commitment~to diversification, and other markets
 where the business outlook  and growth potential  are more favorable.5
 9.1.3  Industry Growth-and  Future Capacity Requirements
     The market for passenger tires can be discussed in terms of .two distinct
 segments, that is, the original  equipment market and the replacement market.
 Since to a certain extent market and demand conditions affect these two
 segments differently,  the potential  growth of each segment should be analyzed
 separately.
     The strength  of the original  equipment market is virtually entirely
 dependent upon the volume production of new automobiles.  While year-to-year
 fluctuations in auto production  have been observed to be as wide as 20
 percent,  one manufacturer has estimated the long-term (1979-87)  growth rate
 of United  States  production  as an  average annual  rate of 2 percent.5
     With  regard  to tires sold in  the replacement market,  several  factors
 have combined  to  indicate slower growth in this  area.   Specifically, the
 increasing  popularity of higher  mileage radial  tires,  along with the decline
 in overall  driving rate,  due  to  increased  gasoline prices,  has  affected  the
 frequency of tire  replacement.   Most projections  indicate  that  the  growth in
 demand for  replacement  tires  should  approximate  1 percent  per year  into  the
mid-1980's.5
     While  the aggregate  growth  rates  for  original  equipment  and  replacement
market tires are low,  it  has  been  projected  that  radial  tires will  account
for increasingly larger  portions of  both markets  up to  1985.   It  has been
                                     9-13
-------
estimated that  in the original  equipment market  the  radial  portion  will
increase from 69 percent  in  1978,1 to  85 percent in  1985.22,23  jn  the
replacement tire market the  demand for radials  has been  projected  to  increase
from 42 percent in  1978^  to  60  percent in  1985.22,23  The  growth in demand
for radial tires, along with the  economic  and technical  difficulties  of
converting bias tire plants  to  radial  tire product ion,14,24 indicate  the
need for several new radial  tire  plants over  the forecast  period (1981-85).
The observation that new  plants will be constructed  for  radial  tire|produc-
tion, has been  supported  by  industry representatives.25
     The needed additions to radial tire productive  capacity,  in terms of new
plants, have been estimated  as  described below.   It  has  been  assumed  that no
portion of the  existing radial  tire productive  capacity  will  require  replace-
ment over the forecast period,  due to  its  relatively recent installation
(i.e., first commercial radial  produced in 1965),21  and  projected  life of
30 years.25  The projections of new plant  requirements are  based upon the
estimation of several key variables., including:                      '

     •    Total passenger tire  demand  (1985)
     •    Total radial tire  demand (1978)
     •    Total radial tire  demand (1985)                           '
     •    Total radial tire  capacity (1978)                    4
     •    Total radial tire  capacity (1985).
                                                                    i
New additions to capacity have  been estimated through  the  following procedure.
     (1)  Estimation of total passenger tire  demand  (1985).  Total  passenger
tire demand (1985)  has been  estimated  through observation  of  total  1978
passenger tire  shipments  (as an approximate of  sales), in  terms  of  both
original equipment  and replacement tires,  and applying the  growth rates  in
both market segments as noted above.   In 1978 total  (including  exports)
passenger tire  shipments  amounted to 193.9 million,  of which  approximately
56 million were original equipment and  137.9 million were  replacements.5
According to the growth rates noted above  1985 demand would require 64.4
million [i.e.,  56 x (1.02)7] original  equipment  tires  and  147.6  million
[i.e., 137.9 x  (1.01)7] replacement tires.
                                     9-14
-------
      (2)   Estimation of total radial tire demand (1978).  As noted above,
 radial  tires in 1978 accounted for 69 percent of the original equipment
 market  and 42 percent of the replacement market.  According to these per-
 centages  the total  demand levels noted in (1) above, can be expressed in
 terms of  radial tires.  Specifically, in the 19~78 original equipment market,
 radial  sales amounted to 38.6 million (i.e., 56 x .69) and replacement tires
 were about 57.9 million (i.e., 137.9 x .42).  Total  1978 radial demand is
 therefore estimated to be 96.5 million tires.
      (3)   Estimation of total radial tire demand (1985).  In 1985, radial
 tires should account for 85 and 60 percent of the original equipment and
 replacement markets, respectively.  Therefore,  1985 radial tire demand can
 be  estimated as 54.7 million (i.e.,  64.4 x .85) original equipment and 88.6
 million (i.e., 147.6 x .60) replacement radials.  Total  1985 radial demand
 is  therefore estimated as 143.3 million tires.
      (4)   Estimation of total radial tire capacity (1978).  The estimation of
 total 1978 radial tire capacity is based on  the assumption that radial  tire
 capacity  utilization for that year can be approximated by industry capacity
 utilization rates,  which for 1978 were about 91 percent.5  Accordingly,
 total 1978 radial tire capacity is estimated as 106  million  (i.e., 96.5/.91).
      (5)   Estimation of total required radial tire capacity (1985).  The
 estimation of total  required radial  tire capacity is based on a capacity
 utilization rate of 85 percent.   This rate was  determined to be typical  of
 passenger  tire utilization  rates  since it represents the average capacity
 utilizations of such facilities over the six years  1973-78,  approximately
 one  complete business  cycle.   Assuming future radial  tire capacity is  used
 at  a rate  of 85 percent,  the total radial  tire  capacity  needed  in  1985 would
 be  168.6 million (i.e.,  143.3/.85) tires.
      Total  required  additions to  radial  tire capacity (1978-85)  can therefore
 be approximated  as  required  1985  capacity (168.6 mill ion)  less  1978 capacity
 (106 million)  or 62.6  million radial  tires.   Assuming  this need  can be met
 through equal  annual  additions  to  capacity,  each  annual  increment  would  need
 to add 8.9 million  (i.e., 62.6/7 years)  tires.   However,  since  the additions
 to capacity required for  1979 and  1980 should,  theoretically, have already
been made,  the  net  additions  for the  forecast period  1981-85, are  44.5
million (i.e.,  8.9 x 5 years) radial  tires.
                                     9-15
-------
     Several assumptions have been made in the determination of the new capa-
city requirements noted above, and to the extent those assumptions may prove
invalid, the conclusions as presented will be affected.  The assumptions
include:

     •    The import/export levels over the forecast period will remain
          constant at 1978 proportions,
     •    Radial tire capacity utilization will, over the forecast period,
          be 85 percent,
     •    Additions to radial tire capacity will be made in equal annual
          increments, and
     •    Growth rates for original equipment and replacement market  radial
          tires will be consistent with those sources cited.

     The addition of radial tire  productive capacity of  44.5 million  tires
per year could be made  in a number of ways  including the construction of  new
plants, or  through the retrofit of existing tire production lines.  ;The con-
struction of new plants would, given the  capacity requirements  noted  above,
require either 3 large, 5 medium, or 9 small  plants.   Such requirements are
based upon  269 operating days per year and  capacities of 58,825,  35,300,  and
17,650 TPD  for the large, medium, and small plants, respectively.
      If capacity additions are made through the retrofit of existing  lines,
a total of  73 retrofits would be  required,  assuming capacity  utilization  of
85 percent  and output of 6,250 TPD for sidewall cementing  lines,  7,5;00  TPD
for tread end and undertread  cementing lines, and  12,500 TPD  for  bead dipping
lines.  In  terms of  specific  lines, 23 sidewall cementing  lines,  19  of  both
tread end and undertread cementing  lines, and  12 bead  dipping  lines1 would be
required.                                                           ,

9.2   ECONOMIC  IMPACT ANALYSIS                                      !
9.2.1   Introduction  and Summary
      In the sections  which follow, the economic  impacts  of the regulatory alter-
natives are detailed.   Economic  impacts  are discussed  in terms of the potential
price,  profitability,  and capital  availability  impacts  of  each alternative.
      With regard to maximum  tire  price  increases,  the  use  of  the most economi-
cal VOC control  systems could,  in the  worst case,  increase the wholesale  price
                                      9-16
-------
of radial tires by  .44  percent.   This  implies  a price increase of 15 cents
for a tire which  wholesales  for  $35.26
     In the event NSPS  costs  are not  passed  to consumers in the form of price
increases, but  instead  are absorbed by tire  manufacturers,  the estimated pro-
fitability of new facilities  would decline,  in the worst case, from a 5.00
percent return  on investment  (ROI) to  4.78 ROI.   The determination of profit-
ability reductions  are  explained in Section  9.2.3.3.
     These conclusions  are based upon  observations of current capital require-
ments for investment  in new  tire manufacturing plants, the  growth in demand
for radial tires, as  well as  the current market  structure and competitive
nature of the industry.   Specific estimates  with regard to  price and profit-
ability impacts,  have been made  by assessing the expected responses of indi-
vidual  model plants to  the capital control and annualized costs summarized in
Chapter 8.
9.2,2  Financial  Profile  and  Market Structure
     9.2.2.1  Financial Profile  of the Industry.  Several  factors have contri-
buted to the current depressed profit  levels in  the rubber  tire industry. Gas-
oline shortages and rapidly  increasing gasoline  prices have served to impact
the growth in demand for  new domestically  produced automobiles (see Section
9.1.3)  as well  as to restrict the use  of existing  autos.  The slump in new
car sales has affected  the production  of tires for the original  equipment
market, while the replacement market has felt  the  impact of reduced  driving.27
In the face of  sagging  demand, the industry  has  experienced extraordinary in-
put price pressure, due for  the  most part  to increased prices for oil  and na-
tural gas, which  are basic requirements in the manufacture  of synthetic  rubber.
     However, continued increases in gasoline  prices and trends toward energy
conservation have increased  the  demand for radial  tires, which offer distinct
fuel economy advantages.28   The  general decline  in tire sales .and the shift
in demand toward radial tires has recently forced  the  closing of numerous bias
tire pi ants.8  However, despite  the problems encountered due to the  profit-
ability of bias tire production,  the demand  for  radial  tires remains strong
and it  is generally recognized that new tire plants  will  be constructed  for
the production of radial  tires.25
     Tables 9-7 and 9-8 demonstrate the overall  decline in  both  gross and net
profits for several  tire manufacturing firms.  With  regard  to gross  profits
(Table  9-7), margins for  the most recent year  noted  (1978)  are the  lowest
                                     9-17
-------
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among the ten years listed, with the exception of  1976 during which!the  indus-
try experienced major strikes.  Industry analysts  have predicted only  small
improvements in profit levels for I960.5
     It should be noted, however, that the profit  summaries  presented  in
Tables 9-7 and 9-8 relate to the profitability of  tire manufacturing firms,
and not necessarily the profitability of producing specific  types of tires.
Therefore the margins noted are for all tires including bias ply, bias belted
and radials.  It is generally accepted however, that the production :of radial
tires typically generates higher profit margins than the manufacture of bias
tires.5»29  Accordingly, the trend toward the manufacture  and sale of
radial tires is often cited as the bright spot in  the future of those  tire
manufacturers who have established radial tire capacity.            i
     Table 9-9 summarizes the return on equity for tire manufacturing firms,
and in effect, demonstrates the declining profitability of ownership of such
firms.  The most recent data^O suggests that the return on equity for tire
and rubber companies was an industry composite of  7.8 percent, for the year
ending December 31, 1979.  As in the case of the profit summaries, return on
equity data is presented at the firm level.                         ;
     Profit and related information with regard to the Michel in Tire Corp. is
largely unavailable as noted in Tables 9-7 through 9-9.  The scarcity of such
data is due mainly to the fact that the French-owned company, which:started
domestic production in 1974, is essentially privately held,  with family mem-
bers owning most of Michel in's stock.31  However,  several  factors indicate
                                                                    i
that the profitability of this company is most likely greater than that of
those firms noted.  First, the company is a leading manufacturer of radial
tires, having invented the radial in the early 1940's.31   TO the extent
                                                                    [
that higher profit margins are typically associated with radial tire produc-
tion, 5»29 Michel in's margins should compare favorably with those producers
who manufacture tires of other types of construction, as well as radials.
Second, the company is currently undertaking a rapid expansion of its domes-
tic productive capacity, a fact which indicates that its future earnings
potential is viewed as favorable.
     9.2.2.2  Market Structure and Industry Pricing.  In its current state
the market for tires can best be described as an oligopoly, characterized by
the existence of two firms which act as "price leaders".   In most cases price
leaders exist either because their productive facilities are inherently more
                                     9-20
-------
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-------
efficient, and thus more profitable due to  lower  average costs, or  because
consumers display a strong preference for their products.   The existence  of
price leader(s), is usually  indicated if a  disproportionate share of  the
total market is controlled by one or two producers.
     The basic implication of price leadership  is  that  the  leader(s), due to
the disparity in average costs among firms, or  the preference of consumers for
the products of the leader(s), have the ability to set  prices with  the  inten-
tion of either increasing market shares or  increasing total  revenues.   However,
within limits, market shares of individual  producers will be unaffected.  This
is so since, in the face of  price reductions on- the part of price leaders, the
remaining industry participants will also lower prices, at  the expen'se  of their
own profitability, and thus  attempt to protect  their individual market  shares.
                                                                    !
On the other hand, when price leaders increase  prices,  the  remaining  firms will
often raise prices in order  to enhance the  profitability of their own operations,
     Goodyear and Firestone  are generally recognized as the tire and  rubber
industry price leaders.5  Evidence of their price  leadership is ample as  ob-
served in the numerous instances of major industry representatives  referring
to current pricing practices as "cutthroat", and  calling for major  producers
to "firm up prices" and institute "more rational  pricing".8,28  A more  basic
indicator of price leadership can be observed by  the fact that together,  Good-
year and Firestone share more than half of  the  total market for tires sold as
original equipment.
     The existence of price  leadership will have  direct implications  regarding
the full absorption or full  pass through of NSPS  control costs.  More specifi-
cally, the price leaders, by raising the prices of tires produced atj  new  plants,
in order to pass through NSPS costs and thus preserve pre-NSPS levels of  profit,
will allow other manufacturers to do likewise.  On the  other hand,  if current
levels of price competition  persist, the price  leaders may  choose to  absorb the
costs associated with NSPS,  therefore reducing  industrywide profits for new
plants.  In any event, if the price leaders choose to follow a full cost  pric-
ing policy, the maximum price increases which could result  are small  enough to
ensure that market shares among industry participants will  not be altered.
Therefore, within the range  of price change possible (see Table 9-13),  the
demand for tires is essentially price inelastic.   The consequences  of full
cost pricing and full absorption are estimated  in  the following sections.
                                     9-22
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9.2.3  Economic  Impact  Methodology
     9.2.3.1  Required  Investment  for  New Tire  Manufacturing Plants.   Table
9-10 provides a  summary of  the  total capital  investment requirements  for new
radial tire manufacturing facilities.   The estimates  as presented provide a
basis for determining both  return  on  investment (ROT) and capital availability
impacts  as detailed  in  the  following  sections.
     New plant  investment requirements are distinguished by plant size, accor-
ding to  the model  plant capacities and production rates discussed in  Section
6.1.1.   Investment totals are therefore presented for radial tire plants with
capacities of  17,650, 35,300, and  58,825 TPD, and producing, with 85 percent
capacity utilization, 15,000, 30,000,  and 50,000 TPD.  In addition, impacts
upon'a retrofit  situation are assessed, with an assumed total retrofit of
44,118 TPD and  output of  37,500 TPD for capacity utilization of 85 percent.
Output of  37,500 TPD therefore requires six sidewall  cementing Tines  (at
6,250 TPD each), five of  both tread end and undertread cementing lines (at
7,500 TPD each), and three  bead dipping lines (at 12,500 TPD each).
     Total  investment requirements are identified by three  individual compo-
nents:   plant  and equipment, land, and working capital.  Plant and equipment
 investment data are  based upon industry estimates?5 regarding the cost to
construct  and  equip  facilities of various sizes.  Estimates, of land costs have
also been made,25 however.because of the extreme variability of such costs,
due to  size,  location,  and  level of improvements needed, a  constant estimate
of such  costs  has been  employed for all plants.  Land costs have not been
 included in  the retrofit  situation.
      Estimates of working capital, that is, the required investment  in short-
. term assets  such as  cash, short-term securities, accounts receivable, and in-
 ventories,  are based upon observations of working capital requirements, as re-
 ported  in  the annual reports of tire manufacturing companies.  According to
 those  reports  the ratio of working capital to sales typically approaches 20
 percent.  Thus for purpose of the following  analysis, working capital require-
ments  are  estimated  as  20 percent of  annual  plant revenues.  The estimation
 of annual  revenues for  each model plant  is described  in  the following section.
      9.2.3.2  Annual Revenues of  New Tire Manufacturing  Plants.  Annual reve-
 nues,  expected to be generated through the manufacture  and  sale  of radial
 tires,  have been estimated for each model plant.  The estimation of  annual
 revenues allows the determination of maximum tire price  increases, as well
                                      9-23
-------
 Table  9-10.   INVESTMENT REQUIREMENTS FOR NEW RADIAL TIRE MANUFACTURING PLANTS
                                ($000 1979)
	 Model Plant Size
Investment Capacity (TPD)
Component Output (TPD)
Plant and Equipment
Land
Working Capital
Total Investment
17,650
15,000
149,800
8,000
28,200
186,000

35,300
30,000
243,300
8,000
56,500
307,800

58,825
50,000
347,800
8,000
94,200
450,000

Retrofit
; 44, 118
37,500
284,300
70,600
354,900

     Table 9-11.  ANNUAL REVENUES FOR NEW RADIAL TIRE MANUFACTURING PLANTS
                                ($000 1979)
                                         Plant Output  in Tires/Day
                               15,000
               30.000
50,000
37,500
Days/Year
$/Tire

Annual Revenue
     269          269          269        269
$  35.00     $  35.00     $  35.00   $  35.00

$141,200     $282,500     $470,800   $353,100
                                      9-24
-------
as maximum profit reduction, under the full  pass  through  and  full  absorption
assumptions employed below.
     The derivation of the annual revenues expected  of  each model  plant  is
summarized in Table 9-11.  The  levels of daily  production as  well  as  days of
operation per year are explained  in Section  6.1,  while  the average wholesale
value of radial tires is based  upon estimates made available  by the Department
of Commerce,26
     9.2.3.3  Return on Investment (ROI) for New  Tire Manufacturing Plants.  In
order to estimate the extent to which the profitability of new tire plants,
as well as the prices of tires  produced, could  be affected by the  full absorp-
tion or pass through of NSPS control costs,  it  is first necessary  to  identify
a reasonable ROI that can be expected of new tire production  facilities  in
the absence of NSPS.  However, the competitive  nature of  the  industry and the
proprietary status of profit related data, have eliminated the possibility of
identification of a "target" ROI, by industry representatives.  However,
publicly available data, in the form of recent  rates of return on  equity for
the tire and rubber industry, make possible  the estimation of the  minimum
acceptable ROI for new plant construction.
     Since ROI is the expression  of net profits (i.e.,  profit after depreci-
ation, interest payments, and taxes) as a percent of total  investment, a
measure of the overall profitability of a new investment  can  be obtained by:
                               net profit
     Return on Investment =
                            total  investment
                                        x 100
(1)
     However, a more appropriate measure of profitability,  from  the  owners'
(shareholders) point-of-view is the return on equity,  which recognizes  that
only a portion of the total investment has been financed  by the  owners  (share-
holders), with the remainder financed through debt  upon which  interest  payments
are made.  The return on equity therefore, recognizes  the  impact of  debt  lever-
age upon earnings.  Therefore since net profits are determined after the  pay-
ment of interest:
or:
Return on Equity .
     Return on Equity =
                                     x 100
                                  return on investment
                        % of total investment financed by equity
(2)


(3)
                                     9-25
-------
     The use of current rates of return on equity to estimate minimum  accept-
able new plant profitability (ROI), is based on the assumption that the
managers of tire manufacturing firms will not  approve the construction of new
tire plants which, due to  low projected ROI's, could lower  prevailing  rates
of return on equity, and thus dilute the  earning potential  of  the  firm.
Therefore, only those new  plants which can promise ROI  high enough to  insure
that the return on equity  (as estimated by equation (3)  above),  will  at  least
not decrease, will be considered as potential  investments.
     The most recent available data suggests that for  1979  the return  on
equity for major tire and  rubber manufacturers was  an  industry composite of
7.8,percent.30  Furthermore, the percentage of debt to  debt plus equity  has
been observed as an  industry average of  36 percent.5   This  data  indicates
that as an  absolute minimum, any new plant must show  an ROI (i.e., return
on total  investment  after  taxes, depreciation, and  interest) of  at least
5 percent  since, according to equation  (3):
                              7.8% =
                                       5.0%
                                     (1 - .36)
(3a)
 Therefore, for purpose of this analysis, a 5 percent baseline ROI is, assumed
 for new tire plants since the investment in new plants which would return
 less could result in the reduction of current levels of profitability of
 ownership (i.e., return on equity).
      This estimate is considered to be conservative since it is based upon
 industry-wide rates of return on equity and consequently, reflects the
 profitability of producing all types of tires including bias-belted, bias-
 ply, and radial tires.  However, since new plant construction will be under-
 taken in order to satisfy the demand for radial tires, and the manufacture of
 radials is generally recognized to yield higher profit margins,5*29 it  is
 most probable that an estimated return of 5 percent understates the ^actual
 ROI for new plants.   In addition, to the extent that the declining book value
 of total assets is not offset by increasing annual maintenance costs, the ROI
 for an individual new plant  should increase from year to year.
      The 5 percent ROI for new plants, as estimated above, in conjunction  -
 with the  investment and revenue estimates summarized  in Tables 9-10'and
 9-11, can be employed in the determination of the  absolute levels of costs,
                                       9-26
-------
 earnings before federal taxes, federal  taxes,  and  net profits for each model
 plant.  These estimates are summarized  in  Table  9-12 and are used in the
 approximation of the profitability,; price,  and capital  availability impacts
 as detailed in the following  sections.   For the  retrofit situation profit-
 ability impacts have been assessed  by treating the new lines as an individual
 profit center with ROI identical to  that for a new plant.
      9.2.3.4  Estimation of Price Impacts  Under  Full  Cost  Pricing.  In the
 event the actions of the price leaders  allow the pass through of control
 costs, the methodology detailed belo'w has  been employed  to estimate the
 increases in tire prices required to ensure that manufacturers will  maintain
 baseline levels of ROI.  The  estimation of  price impacts is  based upon the
 assumption that manufacturers will  price their products  so that all  costs  are
 covered and a minimum ROI is  achieved.   In  this  manner baseline prices are
 set by:                             '
              P = TC + (ROI x TI)/(1. ~ t)
                              ~     '
                                                                   (4)
 where;
           P = Price Per Unit ($/tire)
          TC = Total Costs ($)
          TI = Total Investment ($)
           Q,= Unit Production Per Year (tires/year)
v          t = Federal  Tax Rate (.46)
         ROI = Return on Total Investment (expressed as a decimal).

      When  data for any of the model  plants summarized in Table 9-12 is sub-
 stituted  into this equation, an  average wholesale price of $35 per tire is
 observed.   This result is based  upon an ROI of 5 percent and 269 operating
 days  each  year.
      As  a  consequence  of NSPS controls, new plants will  incur increased costs
 in the form of capital  changes  and operating and maintenance costs.  In
 addition,  a larger asset base will be required.   Therefore, maximum price
 increases  can  be traced  to both  cost increases as well  as to a return for the
additional  capital  investment in  controls.   Consequently, post-NSPS prices
maybe estimated through the following modification of equation (4):
                                      9-27
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 Table 9-12.  BASELINE REVENUE,  COST,  TAX  AND  PROFIT SUMMARY FOR MODEL TIRE

                         '  MANUFACTURING PLANTS

                                 ($000  1979)

Total Investmenta
Annual Revenue*3
Total Costsc
Capacity (TPD)
Output (TPD)



Earnings Before Federal Taxd
Federal Tax6
Net Profits^


Mode
17,650
15,000
186,000
141,200
123,978
17,222
7,922
9,300
T Plant
35,300
30,000
307,800
282,500
254,000
28, 500
13,110
15,390
Size
58,825
50,000
450,000
470,800
429,133
41,667
19,167
22,500
Retrofit
44,118
37,500
354,900
353, 100
320,239
32,861
15,116
17,745
a See Table 9-10.

b$ee Table 9-11.
CTotal Costs = Annual Revenue  -  Earnings  Before  Federal  Tax  (Total  Costs
 includes all operating costs, general  and  administrative expenses, local  and
 state taxes, depreciation, and  interest).

•^Earnings Before Federal Tax = Net  Prof it/(1-. 46)  (assumes Federal  tax rate
 of 46%).
eFederal Tax = Earnings Before Federal  Tax  x  .46.

     Profits = Total  Investment  x  .05.
                                      9-28
-------
 where;
          P- ^ (TC + ACC) + [ROI x (TI + CC)]/(1  - t)        ,,,
                                  Q                          *  '
         ACC = Annualized Control Costs
          CC = Capital Control Costs.
      The annualized control costs (ACC) include capital charges for the
 annual  repayment of principal and interest on a uniform basis, to finance a
 loan for the control  investment.  To be consistent with the method in which
 the ROI reported in this analysis was derived, capital changes as mentioned
 above are used as a surrogate for the normal depreciation and interest
 charges that a typical  firm may deduct as allowable expenses for tax pur-
 poses.   Since firms with 100 percent financing would probably benefit through
 the use of accelerated  depreciation, it is believed that the procedure used
 in  this analysis would  generate conservative results in the first few years
 of  a project, such  as the radial tire plants summarized in Table 9-12.
      The results of the comparison of baseline and post-NSPS prices,  under
 each regulatory alternative are summarized in Section 9.2.4.1.   In that sec-
 tion the implications of the full  pass through of control  costs  are expressed
 in  terms of  the percentage increase  in average wholesale tire prices  where:

      Percent Change =  Post-NSPS price -  baseline price   .       ,
                  3                baseline price         x  iuu    ^'

      9.2.3.5   Estimation  of Rate of  Return on Investment Impacts  Under Full
 Cost  Absorption.  If due  to market conditions, the cost of NSPS controls
cannot be  passed  to consumers  in the  form  of  increased  tire  prices, the
profitability of  new plants  will decline.   In order  to  judge the  extent of
profitability impacts, the  ROI before  and  after NSPS controls, have been
compared for  each model  plant, according to the method  detailed below.
      The baseline ROI for each model  plant  is essentially:
                   ROI = (1 - t)(AR. - TO

                                                                    (7)
                                     9-29
-------
where:
          t =  Federal  Tax  Rate  (.46)
         AR =  Annual  Revenue  ($)
         TC =  Total  Costs  ($)
         TI =  Total  Investment  ($)
        ROI =  Return  on  Total  Investment (expressed as decimal).

This equation  is  simply  a  restatement  of equation (1) noted above, and if used
in conjunction with  the  investment, cost, and  profit data of Table 9-12, an
ROI of 5 percent  for  each  model  plant  is observed.
     The full  absorption of control costs implies that the annualized costs
of control will  increase total  annual  costs, and thus decrease earnings
before federal tax for new plants.   In addition the need to install  control
equipment entails capital  control costs and  will therefore increase  the total
investment required  for  new plant construction.  Considering these additional
costs, the post-control  ROI for  each model  plant may be estimated  through the
following modification of  equation  (7):
                   ROI1
(1 - t)(AR - TC - ACC)
       TI + CC
(8)
where:
        ACC = Annualized  Control  Costs
         CC = Capital Control  Costs.

     It should be noted that the  approach  described  above assumes that both
the capacity utilization  rates  and marginal  tax  rates  will  remain constant
before and after NSPS.  The results of  the calculation of post-NSPS ROI for
each model plant are summarized  in Section 9.2.4.2.
9.2.4  Economic Impacts
     9.2.4.1  Price  Impacts.   Section 9.2.3.4 has  detailed  the methodology
used to estimate the level of  price increases required if the full  costs of
NSPS control are passed to consumers  in  the  form of  increased tire  prices.
     Percentage price increases are summarized in  Table 9-13 where  individual
percentage price increases are distinguished  according to model  plant size
and control system employed.
                                    • 9-30
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Table 9-13.  PERCENT CHANGES IN PRICE UNDER FULL COST PRICING

Model Plant
(TPD)
15,000
30,000
50,000
37,500 (retrofit)

Carbon
Adsorber
.14
.13
.11
.14
Control System
Thermal
Afterburner
.44
.36
.34
.41

Catalytic
Afterburner
.42
.35
.32
.42
                               9-31
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     Table 9-13 indicates that maximum  average  tire  percentage  price  increas-
es are generally low.   For example, the  table shows  that  in  the worst  case,
that is, the most costly control  system  for  the  small  plant,  would  increase
prices by  .44 percent.  Based on  an average  wholesale  radial  tire price  of
$35, the full pass through of control costs  would  add  15  cents  to the  whole-
sale price.
     It should be noted, however  that the  control  of VOC  emissions  through
carbon adsorption is significantly less  costly  under all  circumstances.
For example, the use of carbon adsorption  in the worst case  situation  noted
above would  increase prices by .14 percent,  or  5 cents for the  same $35
tire.
     It should also be  noted that the costs  used to  determine both  price
and profitability impacts are those related  to  the control of sidewall,
undertread, bead, and tread end cementing  facilities.
     The previously discussed price-cutting  activities of industry  price
leaders, may result in  conditions where  NSPS costs must be fully absorbed
by all firms operating  new plants.  Under  these  circumstances the level  of
profit reduction which  may result from the full  absorption of NSPS  control
costs are discussed below.
     9.2.4.2  Rate of Return on Investment Impacts.   If,  for  reasons detailed
previously, the full costs of NSPS controls  are  not  passed to consumers  in
the form of price increases, the  profitability of  new  tire manufacturing
facilities will be affected.  Estimates  of the  extent  to  which  profitability
may decline, have been  made according to the procedure detailed in  Section
9.2.3.5.  Accordingly,  the results summarized in Table 9-14  identify the
post-NSPS ROI resulting from the  full absorption of  NSPS  control costs.
     As might be expected, the severity  of profitability  impacts follow  the
same patterns observed  with regard to potential  price  increases.  More speci-
fically, the use of carbon adsorption for  VOC emission reduction, entails
significantly lower impacts in terms of  reductions in  ROI.   In  general,  the
retrofit situation entails slightly larger levels  of net  profit reduction.
     ROI reductions of  the magnitude noted above,  cannot  be  considered impedi-
ments to new plant construction or retrofit. This  is especially true in  light
of two important factors.  First, it may be  recalled that the 5 percent  base-
line ROI was estimated  in such a  way that  this base  ROI level must  be  consi-
dered conservative (see Section 9.2.3.3).  To the  extent  the  actual ROI  for
                                     9-32
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Table 9-14.  RETURN ON INVESTMENT (ROI) UNDER FULL COST ABSORPTION
                  (Baseline ROI * 5.00 percent)

Model Plant
(TPD)
15,000
30,000
50,000
37,500 (retrofit)

Carbon
Adsorber
4.94
4.94
4.94
4.93
Control System
Thermal
Afterburner
4.81
4.83
4.81
4.79

Catalytic
Afterburner
4.82
4.84
4.83
4.78
                              9-33
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new plants  is higher, the ROI changes may be  slightly  overstated.   Second,
the existence of price  leadership  in the  industry suggests  that  profitability
impacts could be altogether  avoided  if  price  leaders choose to follow a full
cost pricing policy.
     9.2.4.3  Capital Availability Impacts.   Since  each  of  the regulatory al-
ternatives  requires capital  expenditures for  VOC  control  equipment,  the need
for such equipment requires  that potential  investors  in  new tire manufacturing
facilities must obtain  additional  capital financing above that which would  be
required in the absence of regulation.  However,  capital  availability problems
will not result from the imposition of  NSPS for new or retrofitted  tire manu-
facturing plants.  This is so because in no case, do the  capital control  costs
represent more than 1 percent of the total  investment  requirements  summarized
in Table 9-10.

9.3  SOCIOECONOMIC AND  INFLATIONARY  IMPACTS
9.3.1  Fifth-Year Annualized Costs
     Fifth-year annualized costs have been estimated  in  order to determine  if
this NSPS qualifies a major  regulation  under  the  $100  million criteria speci-
fied by E.O. 12291.  Since higher  costs are generally  associated with the
retrofit of existing lines,  fifth-year  annualized costs  have been estimated
by adding the annualized costs of  NSPS for those  retrofitted lines  expected
to be affected by this  standard.
     As noted in Section 9.1.3, the growth  in demand for  radial  tires is  pro-
jected to be such that  73 retrofitted lines may be  required by 1985.   Specific
requirements are:  23 sidewall cementing lines, 19  tread  end cementing lines,
19 undertread cementing lines, and 12 bead dipping  lines.   According  to these
projections and the annualized costs presented in Table  8-11, the use of the
most expensive control  technology  would result in fifth-year annualized costs
of $4.8 million.  In reality, the  use of the most cost-efficient control
systems will reduce this sum to $1.2 million.
9.3.2  Inflationary Impacts
     For 1978, the sales of  6 major tire producers  amounted  to less  than  1
percent of that year's  GNP.4  This fact in conjunction with the  low (.4
percent) maximum price  increases (Table 9-13), ensures that the  imposition
of the regulatory alternative will cause virtually  no  increase in the rate
of inflation.
                                     9-34
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9.3.3  Employment  Impacts
     As noted  in Section 9.2 the  cost  of NSPS could have very minimal  impacts
upon new plant  profitability.   Under these  conditions the decision to  con-
struct new tire plants  will  be  unaffected by NSPS controls.   For this  reason
the standard will  have  no  impact  upon  employment  trends in the industry.
9.3.4  Small Business Impacts
     The Regulatory  Flexibility Act of 1980 requires  the identification  of
possible adverse impacts of  Federal regulations upon  small  entities including
small businesses.  Snail businesses are  defined as business  concerns that are
not dominant in their respective  fields.  Concerning  tire manufacturing,  the
Small Business  Administration has  identified  small  businesses  as those that
employ fewer than  1,000 persons.   This employment level  has  been defined  by
the Small Business Administration  for  purpose of  pollution control  guarantee
assistance under Public Law  94-305, and  is  noted  in Federal  Register 36052,
August 15, 1978.
     There are  currently three  tire manufacturers that  have  fewer than 1,000
employees, namely  Denman of  Warren, Ohio; McCreary of Indiana,  Pennsylvania;
and Ironside of Louisville,  Kentucky.32   since it is  most likely that  any
new plant would employ  at least 1,000  persons,25  the  companies  noted above
would probably not become subject  to NSPS through new plant  construction..  If
the small companies  are affected through modifications  and/or  reconstructions
of existing facilities, economic  impacts  will be  very small  as  estimated
through the analysis of retrofitted plants.
9.4
 1.

 2.
 3.

 4.

 5.

 6.
REFERENCES
1979 Tire Industry  Facts.  Modern  Tire  Dealer.   61(2):25-31.   January
28, 1980.
Rubber Match.  Forbes.  October  15,  1979.   p.  102.
Standard and Poor's.  Industry Surveys:  Rubber  Fabricating Current
Analysis.  December 13, 1979.  p.  R194.
Tire Makers Seek the Right Product Mix.  Chemical Week.   December  6,
1978.  p. 46-47.
Standard and Poor's.  Industry Surveys:  Rubber  Fabricating Basic  Ana-
lysis.  June 28, 1979.  p. R194-R207.
Meeting between Dominic Olivieri, Jr.,  Rubber Manufacturers Association,
and Abigail  Mumy and Agnes Timothy,  JACA Corporation.  January  4,  1979.
                                     9-35
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 7.

 8.

 9.

10.
11.

12.
13.

14.

15.


16.

17.
18.
19.
20.

21.

22.
23.
24.
25.


26.
Securities and Exchange Commission.  Armstrong Rubber  Company 10-K
Report.  September 1978.
A Blowout for the Small Tire Producers.   Business Week.   October  29,
1979.  p. 150.
Standard and Poor's.   Industry  Surveys:   Rubber  Fabricating  Basic Ana-
lysis.  June 22, 1978.  p.  R205.
Modern Tire Dealer'.  February  1978.  p.  16.
Rubber World, January  1979, p.  41; Rubber World, February 1978,  p. 40;
Non-RMA Shipments, consisting  of  import  plus  Michel in  shipments.
Modern Tire Dealer.  March  1978.   p. 42.
United States Department  of Commerce.   Bureau of Economic Analysis.
Survey of Current Business.
Tire  Industry Drops  Into  Deep  Recession:   Gasoline  Shortage,, Rising
Costs Take Toll.  The  Wall  Street Journal.  October 17,  1979.  p. 48.
The  Handbook of  Basic  Economic Statistics.  Bureau  of Economic Statis-
tics,  Inc. Economic  Statistics Bureau  of Washington, DC. Vol. XXXII.
No.  1.   January  1978.
United States Department  of Labor.  Bureau of Labor Statistics.   Pro-
ducer  Prices  and  Price Indexes.
Wall  Street  Journal. May  8, 1979, p.  4.
Goodyear's Solo  Strategy.  Business  Week.  August 28, 1978.  p.  66-68.
Raleigh  News  and Observer,  Raleigh,  NC,  March 20, 1980.
Uniroyal  Announces  Plant  Closings.  Modern Tire Dealer.  61(3):13.
February 7,  1980.
Bias-Ply Tire  Plants Face Uncertain  Future.  Modern Tire Dealer.
60(20):19.   October 5, 1979.
Modern  Tire  Dealer, May 1978,  p. 72.
The  Wall  Street  Transcript.  February 5,  1979.
The  Philadelphia Inquirer.   August 19, 1979.  p. 6-D.
Letter from  Ryan, Frank T., Rubber Manufacturers Association, to Bacon,
Abigail  R.,  JACA Corp., Janaury  16,  1980.  Capacity,  investment, and
operating parameters for new tire plants.
Telecon.  Blank, David, United States Department of Commerce, with
Costello, Thomas V., JACA Corp., March 7, 1980.  Estimates  of average
wholesale prices of domestically produced radial tires.
                                      9-36
-------
27.  Will There Ever Be Happiness  in  Tire  Land?   Modern Tire Dealer.
     62(2):14.  January 28, 1980.
28.  Tire Industry Heads Share Sobering  Outlook.   Modern Tire Dealer.
     62(2):19.  January 28, 1980.
29.  Beyond Today's Gloomy Headlines.  Modern  Tire Dealer.  62(2):12.
     January 28, 1980.
30.  Business Week's Corporate Scoreboard:  How 1,200 Companies Performed
     in  1979.  Business Week.  March  17, 1980.  p. 114.               .   .
31.  Michel in Goes /\merican.  Business Week.   July 16, 1976.  p. 58.
32.  Telecon.  Serumgard, John,  Rubber Manufacturers Association, with
     Cryer, Christopher B., JACA Corp.,  June  12,  1981.  Extent of small
     business 'in the tire manufacturing  industry.
                                      9-37
-------
-------
            APPENDIX A
EVOLUTION OF THE PROPOSED STANDARDS
                 A-l
-------
                        APPENDIX A  -  EVOLUTION  OF
                         THE  PROPOSED STANDARDS
A.I  INTRODUCTION
     In December 1974, the  Industrial  Environmental  Research  Laboratory
of the U.S. Environmental Protection Agency  initiated  a  Source  Assessment/
State-of-the-Art Study of rubber processing.   The  study  was authorized
under Section 313 of the Clean Air Act, which  charges  the Administrator of
EPA with the responsibility of establishing  Federal  standards of  perfor-
mance for new stationary sources which may significantly contribute  to
air pollution.  Concurrently, a screening study  of nine  segments  of  the
rubber industry was initiated for the  purpose  of identification and
control of hydrocarbon emissions.  As  a result of  the  screening study,
the tire and inner tube industry segment proved  to have  the highest
potential for reduction of hydrocarbon emissions through implementation
of NSPS.  The EPA Priority List (40 CFR 60.16, 44  FR 49222, August 21,
1979) shows tire manufacturing to be a division  under  the source  category
of synthetic rubber, which is ranked twentieth in  priority.   The  method
used to rank the source categories was based on  emissions, public
health/welfare, and source mobility.  These  criteria were set forth  by
Congress in the 1977 Clean Air Act Amendements.
     Standards development for the rubber tire industry  involved  collection
of solvent use data and performance of emission  measurement; tests to
quantify and identify source emissions.  Plant visits  were scheduled to
obtain information on process details and emission control equipment,
while literature surveys were conducted to determine plant operating
parameters and the extent of use of emission reduction techniques.   EPA
scheduled meetings with Rubber Manufacturing Association (RMA)  repre-
sentatives to discuss relevant issues which  pertained  to the  development
of the standards.  The significant events relating to  the effort  of
developing the new source performance standards  (NSPS) for the  rubber
tire industry are discussed in the chronology below.
A.2  CHRONOLOGY
     The following chronology lists important events which have
occurred in the development of background information  for the rubber
tire manufacturing NSPS.
                                   A-2
-------
    Date

August 1975



May 1976


July 7, 1976



July 20, 1976




August 2,  1976



December 20, 1976


December 21, 1976



December 22, 1976


January  13,  1977


February 8,  1977



November 23, 1977
 January 20, 1978
                   Activity

Preliminary report prepared by the Monsanto
Research Corporation entitled Source Assess-
ment, Rubber Processing, State-of-the-Art.

Screening study of nine segments of the
rubber industry initiated.

Meeting with Environmental Committee
representatives of RMA and EPA to discuss
the screening study.

Meeting with Environmental Committee of RMA
and Monsanto Research Corporation
representatives to schedule plant visits to
nine segments of the industry.

RMA's position regarding the development of
guidelines document for the rubber industry
is confirmed.

Information requests sent to rubber industry
regarding data for screening study.

Visit to Armstrong Rubber Company, West
Haven, Connecticut plant - rubber tire
manufacturing.

Visit to Uniroyal, Chieopee Falls, Massachusetts
plant - rubber tire manufacturing.

Plant visit to Uniroyal  Incorporated, Red
Oaks, Iowa plant - rubber hose manufacturing.

Visit to Gates Rubber Company, Denver,
Colorado plant - rubber  hose and belt
manufacturing.

Second draft  of the  screening  study entitled
 "Identification and  Control of Hydrocarbon
Emissions  from Rubber Processing Operations"
finalized.  Decision made to pursue develop-
ment of guidelines document and  NSPS for
rubber tires.

 Information  requests  for development of NSPS
sent to eight rubber tire manufacturers.
                                    A-3
-------
    Date

May 1978


May 9, 1978
September 13, 1978




October 6, 1978


December 1978




January 22-26, 1979


April 1979


June 6, 1979



July 19, 1979


July 27, 1979



August 21, 1979
August 27 -
September 4, 1979

November 5-9, 1979
                   Activity

NSPS contract awarded to Monsanto Research
Corporation.

Meeting with RMA Environmental Committee and
EPA to discuss research and development
activities for capture systems in the curing
areas.

Meeting with RMA Environmental Committee and
EPA to initiate work on the design of a
capture system to control emissions from
tire curing operations.

Follow-up information requests sent:to five
rubber tire manufacturers.

Final draft of guidelines document entitled
"Control of Volatile Organic Emissions from
Manufacture of Pneumatic Rubber Tires (CTG)"
released.

Emission tests and measurements performed at
Armstrong Rubber Company, West Haven, Connecticut.

NSPS contract awarded to Pacific Environmental
Services, Incorporated.

Visit to Firestone Tire and Rubber Company,
Wilson, North Carolina plant - rubber tire
manufacturing.

Model plant parameters for rubber tire NSPS
proposed.

Visit to Armstrong Rubber Company, West
Haven, Connecticut plant - rubber tire
manufacturing.

EPA Priority List 40 CFR 60.16, 44 FR 49222,
August 21, 1979, Synthetic Rubber ranked
twentieth in priority.

Emission measurements performed at Armstrong
Rubber Company, West Haven, Connecticut.

Emission measurements performed at Kelly-
Springfield, Fayetteville, North Carolina.
                                   A-4
-------
    Date

November 7, 1979
December 31, 1979
January 4, 1980
January 24, 1980


June, 1980



June 2, 1980


June 27, 1980



July 31, 1980



October 31, 1980



November 26, 1980


December 1980

December 2, 1980

January 14, 1981
                   Activity

Visit to Kelly-Springfield Tire Company*
Fayetteville, North Carolina plant - rubber
tire manufacturing]

Emission fheasureijients performed at Michel in
Tire Company, Greenville, South Carolina
plants

Follow-on information requests sent to eight
rubber tire manufacturers.

Preliminary tests to determine effects of
absorption on evaporation of VOCs from
rubber components.

EPA/CPB and EPA/SDB concurrence on regulatory
approach.

Draft BID, Chapters 2-8 and Appendices B-D,
distributed to EPA Working Group and to
industry members.

Meeting between  rubber tire manufacturing
industry representatives and EPA staff to
discuss draft BID.

Draft BID, Chapters 2-9 and Appendices A-D,
distributed to EPA National Air Pollution
Control Techniques Advisory Committee  (NAPCTAC),

Draft BID, Chapters 2-9 and Appendices A-D,
distributed to EPA Steering Committee.

EPA  Steering Committee review.

NAPCTAC meeting, all comments were  recorded.

NAPCTAC meeting  minutes released for
public review.
                                    A-5
-------
-------
                              APPENDIX B

                 INDEX TO ENVIRONMENTAL CONSIDERATIONS

     This appendix consists of a reference system which is cross
indexed with the October 21, 1974, Federal Register (39 FR 37419)
containing EPA guidelines for the preparation of Environmental Impact
Statements.  This index can be used to identify sections of the document
which contain data and information germane to any portion of the
Federal Register guidelines.
                                B-l
-------
                              APPENDIX B
             INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419}
  Location Within the Background
    Information Document (BID)
1. Background and Description
   of Emissions and Emission
   Controls

       Statutory Basis for Develop-
       ment of New Source Perfor-
       mance Standards (NSPS).

       Activities Affected
       Process Affected
       Availability of  Control
       Technology
        Existing  Regulations  at
        State  or  Local  Level
 2.  Regulatory  Alternatives

      Regulatory  Alternative I

        Environmental  Impacts




        Costs
The statutory basis for NSPS
is given in Chapter 2.
Descriptions of the activities
which emit pollutants to be
affected are given in Chapter 3,
Section 3.1.

The activities to be affected
are listed in Chapter 4,
Section 4.0.

Information on the availability
of control technology is given
in Chapter 4.

A discussion of existing regula-
tions or the industry to be
affected by the standards is
included in Chapter 3, Section 3.3.
The environmental  impacts associated
with Regulatory Alternative  I
emission control  systems are
considered  in  Chapter  7.

The cost impact of Regulatory
Alternative I  emission  control
systems is  considered  in
Chapter 8,  Section 8.2.
                                                          (Continued)
                                B-2
-------
        INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS  (Continued)
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
  Location Within the Background
    Information Document (BID)
       Health and Wei fare Impact
The impact of Regulatory Alter-
native I emission control
systems on health and welfare
is considered in Chapter 6.
     Regulatory Alternative II
       Environmental  Impacts
       Costs
        Health  and Welfare  Impact
      Regulatory  Alternative III
        Environmental  Impacts
        Costs
        Health and Welfare Impact
 3. Environmental Impact of
    Regulatory Alternatives

        Air Pollution
The environmental impacts associated
with Regulatory Alternative II
emission control systems are
considered in Chapter 7.

The cost impact of Regulatory
Alternative II emission control
systems is considered in
Chapter 8, Section 8.2.

The impact of Regulatory Alter-
native II emission control
systems on health and welfare
is considered in Chapter 6.
The  environmental  impacts  associated
with Regulatory  Alternative  III
emission  control  systems are
considered  in  Chapter  7.

The  cost  impact  of Regulatory
Alternative III  emission control
systems is  considered  in
Chapter 8,  Section 8.2.

The  impact  of  Regulatory Alter-
native III  emission control
systems on  health and  welfare
is considered  in Chapter 6.
 The air pollution impact of the
 regulatory alternatives is
 considered in Chapter 6,
 Section 6.1.
                                                          (Continued)
                                B-3
-------
        INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS  (Concluded)
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
  Location Within the Background
    Information Document (BID)
       Water Pollution
       Solid Waste Disposal
       Energy
        Costs
The impact of the regulatory
alternatives on water pollu-
tion is considered
-------
APPENDIX C - EMISSION DATA
           C-l
-------
C.I  SUMMARY OF ACTIVITY
     Methods and data used to calculate emissions from  rubber  tire
manufacturing plants are presented in this appendix.  Emission test
methods and data from tests at two rubber tire manufacturing plants
are also presented.  Information used to calculate  industry emission
rates and uncontrolled emission factors was obtained from  industry
responses to two U.S. Environment Protection Agency inquiries  conducted
under authority of Section 114 of the Clean Air Act.  Industry Survey  I
was a request for information which reported quantities  of VOCs used
and operating parameters for all solvent consuming  operations  within a
tire plant.  Survey I information reported data for the  most recent
year available:  some plants responded with data for 1976  while ;others
reported 1977 information.  Industry Survey II concentrated on acquisition
of VOC consumption data and process description data for selected
solvent-consuming plant processes.  Industry Survey II  data pertained
to tire manufacturing for the three year period, 1977-1979.
     Two stages of tests were performed at two rubber tire manufacturing
plants in order to assist in the development of emissions  data for the
industry.  The objectives of the first stage of tests performed at one
plant were:  (1) to determine VOC removal efficiency of  the carbon
adsorber used at the undertread cementing operation, (2) to determine
cement usage at the undertread operation, and  (3) to compare two test
methods for VOC measurement.  The second stage of tests  was conducted
at two plants; one was the same plant at which the  first stage of
tests was performed.  Test objectives at both plants were:  (1) to
determine evaporation rates for VOCs applied to rubber  components at
tread end cementing and bead cementing operations,  (2)  to  determine
cement usage at tread end cementing and bead cementing  operations,  (3)
to determine the mass of VOC to mass of cement used at  tread end
cementing operations, and (4) to compare any variations  in VOC emissions
between different tread end cement and bead cement  application methods.
C.2  PRESENTATION OF SOLVENT CONSUMPTION DATA AND OPERATING, PARAMETERS
     Section 114 requests for information were necessary on two occassions
to obtain solvent consumption data for tire manufacturing  plants.
                                   C-2
-------
Information requested in Industry Survey I was used for:  (1) determining
which tire producing processes would be considered for emission control
and (2) developing model plant parameters.   Information obtained from
Industry Survey II provided for: (1) expansion of the data base for
specific solvent-consuming processes to a three year period, and  (2)
detailed process descriptions of cement or spray application methods.
     Tables C-l through C-18 present solvent consumption  data  and/or
properties of the exit gas for all tire manufacturing plants that
responded to the surveys.
     Table C-l lists the total annual  consumption of volatile  organic
compounds at 42 tire manufacturing plants, representing eight  companies
that responded to Industry Survey  I.   Tables C-2 through  C-18  list
annual  solvent consumption data as reported  in  Industry Surveys  I  and
II.  Out of a total  of  thirty-six  plants,  representating  seven tire
companies reporting  Industry  Survey  II information,  only  thirty-two
plants  are listed in the tables, as  four  plants  that exclusively
produce tires other  than those  considered in development  of the  standard
were excluded.
     In order to  arrive at  solvent consumption  values  presented  in the
following  tables, densities  of  specific organic compounds were used  to
convert solvent  consumption,  reported  in  gallons,  to mass.  Assumptions
used  in the  conversions include:
          •    the  density  of naphtha  and any "rubber solvents" of
                unspecified  composition is 5.49  Ib/gal  (666 gm/1);
           •    the  density  of gasoline is equal to that of octane,
                5.87 Ib/gal  (703 gm/1);
 The density of heterogeneous solvents were  calculated by summing the
 weighted  densities  of individual  VOC constituents.   Solvent consumption
 data is used to generate emission factors.  These factors represent
 100 percent of solvent usage reported in the Section 114 responses,
 except in the case of water-based green tire sprays.  In the  case of
 water-based green tire sprays the organic solvent content, expressed
 as weight percent,   is incorporated into the calculation  in order  to
 report the mass of  VOCs used.
                                    C-3
-------
Table C-l.  TOTAL SOLVENT CONSUMPTION DATA
  FROM TIRE MANUFACTURING PLANTS IN 1977

            (Industry Survey I)
Plant
Code
A
B
c
D
E
I
K
L
M
0
P
Q
*\
R
T
V
W
X
Y
z
BB
DD
VOC
Mg
1,042
33
567
962
774
852
1,296
249
2,578
1,719
1,341
1,371
1,218
712
1,705
266
1,025
1,188
1,646
56
790
CONSUMPTION
Tons
1,149
36
625
1,061
853
939
1 ,429
275
2,842
1,895
1,478
1,512
1,343
785
1,880
293
1,130
1,310
1,815
62
871
Plant
Code
EE
FF
GG
HH
JJ
LL
NN
00
PP
QQ
RR
SS
TT
UU
ww
XX
YY
ZZ
AAA
' BBB
CCC
VOC
Mg
963
209
1,564
1,342
1,334
4,337
624
856
385
1,213
476
673
1,334
1,032
1,719
1,287
1,053
202
605
743
223
CONSUMPTION
Tpns^
1,062
230
1,724
1,480
1,471
4,837
688
944
424
1,337
525
742
1,471
1,138
1 ,895
1,419
1,166
223
667
819
246
                    C-4
-------
Table C-2.  OPERATING PARAMETERS FOR UNDERTREAD CEMENTING
                   (Industry Survey I)
Number of
undertread
Plant cementing
Code lines
a
"a
B
C 2
D 3
E 4
I 2
K 2
I -
h "a
M 'a
0
P*5
O_
Q
R -3
T 8
V 8
W 2
X 13
Y 1
ZQ "a
BB -,
DO . -I
EE -
CC.
FF 1
66 4,
HH -a
JJ 2
LL 5
NN . 2,
00 -
PP 4
nn ' a
QQ -
RR 2
SS 2
TT -

UU 4
WW 3
XX
YY 3a
LL ™g
AAA -\
BBB -,
CCC
*Not available.
°Not calculated
Ambient
Fxit. gas properties
Flow rate,
Average
b
~tj
1.5
2.0
2.8
2.6
3'b
"b
~_b

n
2.5
3.6
3.8
3.3
3.3
5.7
-bb
"b
~b

2.6
2.8
_b
, 2.4
1.4
1.5
-b
1.0
_b
2.0
3.2
-b

1.8
3.8
-
4'S
"b
"b
"b



m-i/s per line.
Range
_a
"a
0.6,2.4
-
1.2-4.4
— Q
Q
"a
"a
"a
Id
"a
Id
1.9g3.8
»
3.2-3.5
_d
_e
a
la
_a
a

- "J
""3
"d
d
"a
— j
a
a
1.4-2.6
_d
_a
a

"a

"a
"a
"a
"a

pAll units have
Only one value
Temperature,
°C
_a
"a
"c
"c

-c
~c
"c
"a
"a
~c
"a
"c
^
"c

c
^c
_
"a
~a
"a

c
"c
"a
~c
"c
~c
"a
25-30
_c
_c
27
_a
c

2a '
c
"c
"c
~a
"a

same exit gas- flow
reported .

6auge Pressure
Pa
_a . •
"a
530-800

0
0
0
_a
_a
530,
a
0
130a
*•
n
0
0
_a
_a
"a
"a

530a
a
800,
a
530.
0
0
270-2,500
-3
_a


0
_a

0
0


.
_a

rate.

                           C-5
-------
    Table C-3.  SOLVENT CONSUMPTION DATA FOR UNDERTREAtf CEMENTING
                         (Industry Survey I)
Plant
Code
A
B
C
D
E
I
K
L
M
0
P
Q
R
T
V
W
X
Y
Z
BB
DD
VOC
Mg
b
b
203
296
494
189
305

D
b
586
197
361
641
b
230
472
511
b
26
b
CONSUMPTION
Tons
b

224
326
545
208
336
17
b
b
648
217
398
709
b
253
520
563
b

29
Plant
Code
EE
FF
GG
HH
JJ
LL
NN
00
PP
QQ
RR
SS
TT
UU
ww
XX
YY
zz;
AAA
BBB
CCC
VOC
Mg
248
177
968
b
416
236
195
b
84
.b
301
113,
479
459
804
470
758
b
94
297
31
CONSUMPTION
Tons
273
195
1,067
b,
459
260
215
b
93
b
332
125
528
506
886
518
836
b
104
327
34
 Not available.
 Not calculated.
cAmbient.  ,
 All units have same exit*gas flow rate.
eOnly one value reported.
                                 C-6
-------
 Table C-4.  SOLVENT CONSUMPTION DATA  FOR UNDERTREAD CEMENTING

                     (Industry  Survey  II)
Plant Code
A
B
C
E
F
G
H
I
J
K
L
N
P
R
S
T
• U .
V
W
X
z
AA
BE
CC
DD
EE
FF
GG
HH
II
JJ
VOC CONSUMPTION 1977
Mg Tons
a
a
464.9
482.3
229.7
591.6
54.0
440.2
a
390.4
7.00.6
191.0
352.0
501.7
37.2
505.3
373.0
846.1
476.2
802.4
241.0
53.9
490.9
a
258.2
858.1
422.5
a
180.3
274.7
1036.5
a
a
.512.5
531.6'
253.2
652.1
(59.6,
485. 2b
a
430. 3b
772. 2b
210.5
388.0
553.0
(41.0
556. 913
411.2
932. 6L
524. 913
884. 4b
265.6
59.4
541. lb
a
284.6
945.9
465.7
a
198.7
302.8
1142.6
VOC CONSUMPTION 1978
Mg Tons
a
17.0
409.2
418.4
231.6
669.7
48.8
468.6
a
999.0
650.1
256.5
351.5
277.3
29.8
505.3
372.7
279.8
560.5
847.8
683.6
66.8
290.9
845.1
241.9
388.9
410.6
a
a
256.7
904.6
a
15.8
451.0
461.2
255.3
738.2
53.8
516. 5b
a
1101 .Z?
716. 6b
.28-2.7
' 387.5
305.7
(32.8,
556.8°
410.9
308.4
617. 8&
934. 5b
753.5
(73. 6U
320. 7b
931.3
266.7
428.7
452.6
a
a
282.9
997.2
VOC CONSUMPTION 1979
Mg Tons
a
90.5
245.3
436.6
224.1
550.3
41.3
437.7
a
827.5
651.0
212.6
289.4
277.2
28.8
546.9
358.6
163.7
556.8
747.0
730.0
53.4
266.7
a
270.7
283.8
353.9
a
a
193.1
471.4
a
99.7
270.4
481 . 3
247.0
606.6
45 6
t V • V
482. 5b
a
912. 2b
717. 6b
234.4
319.0
305.5
31.7
602. 8b
395.3
180.4
613.7b
823. 4b
804.6
58.9
294. Ob
a
298.4
312.8
390.1
a
a
212.9
519.6
Blank indicates that annual mass of solvent consumption could not be
calculated.

Sidewall and undertread cementing were reported together in the same
number.
                             C-7
-------
   Table C-5.   SOLVENT CONSUMPTION DATA FOR TREAD END CEMENTING*

                        (Industry Survey I)
Plant
Code
A
B
C
D
E
• I
K
L
M
0
P
Q
R
T
V
W
X
Y
z
BB
DD
VOC
Mg
7
/
a
22
75
12
30
40
a
a
a
120
158
18
a
10
18
29
52
a
a
a
CONSUMPTION
Tons
8
i— i
a
24
83
13
33
44
a
a
a
132
174
20
a
11
20
32
57
a
a
a
Plant
Code
EE
FF
GG
HH
JJ
LL
NN
00
pp
QQ
RR
SS
TT
UU
WW
XX
YY
ZZ
AAA
BBB
CCC
VOC
Mg
31
21
28
a
135
22
57
36
a
a
33
210
89
167
18
46
22
a
4
31
9
CONSUMPTION
Tons
34
23
31
, a
149
24
63
40
a
a
36
232
'98
184
20
51
24
a
4
34
10
aBlank indicates that annual iiiass of VOC emissions could not be
 calculated.
-------
 Table  C-6.  SOLVENT CONSUMPTION  DATA FOR TREAD END CEMENTING
                    (Industry Survey II)
Plant
Code
A
B
C

F
G
H
I
J
K
L
M
N
0
P
R
. T
U
U
X
Y '
z .
AA
BB
CC
DD
EE
GG
HH
II
JJ
Solvent Consumption 1977
Mg Jons
15.2
39.7
5.2
21.2
15.1
5.6
22.8
112.4
16.8
43.8
5.8
23.4
16.6
6.1
25.1
123.9
43.0 j 47.4
a I a
150.8 166.3
15.7 i 17.3
97.7
7.5
a
a
109.9
107.7
8.3
a
a
120.6
18.6 • 20.5
28.8
9.7
47.5
47.7
a
171.5
29.8
0.9
5.4
25.3
31.7
10.7
52.3
52.6
a
189.0
32.9
1.0
6.0
27.9
51.2 • 56.4
54.0 : 59.6
308.2 339.7
Solvent Consumption 1978
Mg Tons
14.2
37.5
4.6
48.1
21.5
6.1
25.2
100.1
35.6
a
134.1
17.8
85.3
9.4
80,2
86.9
123.4
17.7
29.9
10.5
61.6
47.6
a
171.0
27.8
0.4
7.2
48.2
45.6
48.8
288.3
15.7
41.4
5.1
53.0
23.7
6.7
27.8
110.4
39.2
a
147.9
19. .6
94.0
10.4
88.4
95.8
136.0
19.6
32.9
11.6
67.9
52.5
a
188.6
30.8
0.4
7.9
53.2
50.3
53.8
317.8
Solvent Consumption 1979
Mg Tons
12.9
44.7.
3.2
39.9
20.4
5.2
17.0
92.5
27.2
, a
98.8
17.7
60.5
8.0
61.6
36.3
99.2
16.7
26.2
11.3
58.2
39.2
a
123.1
21.5
0.9
6.7
27.1
48.8
41.4
182.3
14.2
49.2
3.6
44.0
22.5
5.7
18.8
102.0
30.0
a
109.0
19.5
66.7
8.8
67.9
40.0
109.3
18.4
28.8
12.4
64.2
43.2
a
135.7
23.6
1.0
7.4
29.9
53.7
45.6
208.9
Blank indicates that annual mass of solvent consumption could not be calculated.
                              C-9
-------
Table C-7.  SOLVENT CONSUMTPION DATA FOR SIDEWALL CEMENTING
                  (Industry Survey II)
	 -
Plant Code

C

E
G
H
I
J
K
M
N
0
P
Q
T
U
V
X
Y
Z
AA
BB
CC
DD
EE
FF
GG
II
00
VOC CONSUMPTION 1977
Mg Tons
a
8.7 9.6
a
352.0 388.0
a
a
a
a
a
a
a
33.9 37-. 3
a
a
a
a
167.2 184.3
a
a
a
a
131.5 144.9
a
a
a
a
a
a
a
a
a
VOC CONSUMPTION 1978
Mg Tons
a
3.6 3.9
a
351.5 387.5
a
a
-

.
a
337. 4h 41.3
314. 9b 347.1
a
a
a
92.4 101.9
a
,
a

„
148,8 164.0
a

_




a
a
	 — 	 	 * 	
VOC CONSUMPTION 1979
Mg Tons
a
6.4 7.0
a
289.4 319.0
a '
a
a
a
a
a
a
40.3. 44.5
370. 6D 408.5
a
a
a
92.4 101.8
a
a
a
a
122.3 134.8
a
a
a
a
a
a
a
a
a
___ 	 — 	
 ....... indicates that annual mass of solvent consumption could not be
 calculated.
                   consumption  from  bead cementing.
                              C-10
-------
      Table C-8.  OPERATING PARAMETERS FOR BEAD  CEMENTING

                         (Industry Survey I)
Plant
Code
A
B
C
. D
E
I

K
L
M
o
P
q
R
T
V
w
X
Y
1
BB
' DO
EE
FF
GG
HH
JJ
LL
NN
00
PP
QQ
RR
SS
TT
UU
WW
XX
'YY
ZZ
AAA
8BB
CCC
Number of
bead dipping
operations
1
_c
1
c
~c
1

1
_c
1
_c
3
c
1
c
~c
_c
1
_c
_c
~c
"c
"c
1
4
_c
1
_c
1
2.
c
"c
1-
c
c
"c
4
1
_c
"c
"c
"c
"c
Exit gas properties
Flow rate, m-Vs
Average
3.0
Id
0.9

^d
4.7
j
-Q
d
"d
"d
2.4
-d
3 6
"9
"d
"d
"d
"d
"d
"d
"d
"d
"d
"d
~d
2.4
^3
2.4
3.3
d
"d
"d
"d
"d
~d

sis

"d
"d
"d
_d
jjer operation
Range
a
"c
"a
"c
"c
"a
"e

"c
"e
"c
~g
_c
"a
"c
~c
c
"e
^c
e
"e
"c :
"e
"e
"e
~c
_a
"c
"a
_a
c
"c
_e
_c
~e
"c
_g
"a
"c
"c
"c
"e
"d
Temperature,
°C
b
"c
"b
"c
"fa
^b
, "f

"c
"f
"c
"b
"c
"b
~c
_c
"c
. "f
"c
"f
"f
"c
. "f
"f
"f
"c
"b
"c
_b
21
_c
c
"^
f
"c
"f
^c
2i
_b
c
"c
"c
"f
"c
Gauge pressure
Pa
°c

4
-
0
"f

c

~c

4
-
0
-
"c
•f

. "f

~c
"f
"f
"'f
-
2,000
_c
1,470
.c
c

"f
~c
"f

-
0
0
-
-
~f

-
?0nly one value reported.
°Ambient.
cNot available.
 Not calculated.
?No invidivuals ventilation system(s).
 Not applicable.
3A11 units have same exit gas flow rate.
                                       C-11
-------
      Table C-9.   SOLVENT CONSUMPTION DATA FOR BEAD CEMENTING
                        (Industry Survey I)
Plant
Code
A
B
c
n
\j
E
T
j*
K
L
M
0
P
n
X
R
T
v
W
X
Y
Z
BB
DD
VOC
Mg
34
*5
73.6
d
7.7
17.9
9.3
a
2.1,
d
31.3
d
106.6
13.7
d
d
7.7
d


d
CONSUMPTION
tons
3.7
d
81.1
d
8.5
19.7
10.3
d
2.3
d
34.5
d
117.5
15.1
d
d
8.5
d
4.4
d
d
Plant
Code
EE
FF
GG
HH
JJ
LL
NN
00
PP
QQ
RR
SS
TT
UU
WW
XX
YY
II
AAA
BBB
CCC
VOC
Mg
2.4
1 -T

13.2
59.5

93.9
15.8
d

53.2
d
28.3
VI
36.6
59.9
H
VI
d
VI
2.2

CONSUMPTION
Tons
2.6
T -,2
.
14.6
65.d5

103.5
17.4
d
\Ji
587
VI
31.3
d
40.4
66 yO
d
u
d
u
^rf*

aOnly one value reported.
 Ambient.
cNot available.
dNot calculated.
eNo individualized ventilation system(s),
 Not applicable.
9A11 units have same exit gas flow rate.
                                 C-12
-------
  Table C-10.  SOLVENT CONSUMPTION DATA FOR BEAD CEMENTING
                   (Industry  Survey  II)
Plant Code
A .
B
c
D
E
F
G
H
I
J
K
L
N
0
P
Q
. R
S
T
U
V
• w
X
U
AA
CC
FF
GG
HH
II
JJ
VOC CONSUMPTION 1977
Mg Tons
a
21.8
22.7
68.6
31.2
a
a
15.6
10.2
a
a
9.3
a
32.9
4.3
3.3
a
8.8
a
14.1
33.4
28.8
88.3
2.0
a
a
a
78.5
7.9
47.9
61.3

24.0
25.0
45.6
34.4


17.2
11.2


10.0

36.3
4.7
3.6

9.7

15.5
36.8
31.7
97.4
2.2



86.6
8.7
'52.6
67.5
VOC CONSUMPTION 1978
Mg Tons
a
8.1
22.3
19.0
31.2
a
a
20.4
34.3
a
a
9.0
89.9
37.3
2.5
3.1
a
52.0
a.
15.2
33.7
29.9
a
2.0
a
a
a
83.5
65.5
49.7
46.2

8.9
24.6
21.0
34.4


22.5
37.8


9.9
99.1
41.1
2.8
3.4

57.3
,
16.8
37.1
32.9

2.2



92.1
72.2
54.8
51.0
VOC CONSUMPTION 1979
Mg Tons
a
10.3
14.9
15.8
25.7
a
a
18.7
7.5
a
a
5.5
98.3
38.5
0.6
2.9
a
28.4
a
16.4
31.5
26.2
a
2.0
a
a
a
77.9
47.9
46.7
43.9

11.3
16.5
17.4
28.3


20.6
8.3


6.0
108.3
42.5
0.7
3.2,

31.2

18.1
34.8
28.8

2.2



85.9
52.8
51.5
48.4
Blank indicates that annual mass of solvent consumption could not
be calculated.
                            C-13
-------
Table C-11.  OPERATING PARAMETERS FOR GREEN TIRE SPRAYING
                  (Industry Survey I)

Plant
Code
A
B
C
0
£
I
K
L
H
0
P
Q
R
T
V
W
X
Y
Z
BB
00
EE
FF
GG
HH
00
LL
NN
00
PP
QQ
RR
SS
TT
UU
WW
XX
YY
ZZ
AAA
8BB
CCC
Number of
spray
booths
_a
2
2
3a
_a
a
4.
a
10
7
6a

7.
a
8,
d
5
1
fa
a
8,
ct
8
3
4
13
2
4,
Cl
la
a
3
fa
9a
a
3
i.
a
4
3
?Not available.
"Not calculated.
Ambient.
Exit gas properties
Flow rate, m-Vs per booth Temperature,
Average Range
b a
"" ~^J
3.3 -d
„ 2.4 1.5-3.3
_b _a
_b a
-b _a
3.0 2.6-3.3
-b _a
8.4, 3.1-29.3
-b .a
4.0 1.5-5.7
-b -a
3,1 1.5-4.1
-b -a
3.5 -d
_b _a
0.9 -d
16.8 -f-
3,7 1.7-5.7
-b .a
-b _a
3.8 1.3-6.0
-b, -a
3.8 -d
3.9 -a
7.0 3.8-11.3
1.7 1.0-2.8
5.7 -d
3.0 2.4-3.3
-b _a
4.7 -f
_b .a
3.7 3.6-3.8
4.3 1.7-5.7
-b _a;
5.2 3.2-9.4
-b .a
.b _a
9.9 -f
_b _a
3.4 1.4-5.7
2.0 0.6-2.7
All units have same exit
^Maximum value.
Only one value reported.
°C
_c
27e
_c
_c
_a
"a
_c
_c
~_c.
"c
~_c_
_a
_c
_a
_c
_a
_c
_c
_c
_a
la
_c
-a •
3c
21-29
" _C
_c
_c
21-38
_a
c
^a
13-24
_c
_a
21
_a
_a
_c
_c
_c
^c
gas flow rate.
Gauge pressure
Pa
0
_a
530
n
\J
_a
_a
0
0
.a
_a
530-2,000
.a
0
.a
_a
_a
0
0
_a
.a
_a
_a
_a
_a
0
930-2,000
.a
1 ,470
_a
_a
0
' _a
.a
_a
.a
0
_a
_a
o
_a
_a
0
•
                           C-14  -
-------
   Table C-12.  SOLVENT CONSUMPTION  DATA FOR GREEN TIRE SPRAYING
                        (Industry  Survey I)
Plant
Code
A
B
C
D
E
I
K
L
M
0
P
Q
R
T
V
W
X
Y
Z
BB
DO
VOC
Mg
b
30
153
439
b
116
776
61
932
624
512
502
255
b
475
b
157
343
675
b

CONSUMPTION
Tons
b
33
174
484
b
128
855.5
67.3
1,028
683
564
553
281
• b
524
b
173
378
744
b
b
Plant
Code
EE
FF
GG
HH
JJ
LL
NN
00
PP
QQ
RR
SS
TT
UU
ww
XX
YY
II
AAA
BBB
CCC
VOC
Mg
433
b
457
78
499
157
230
428
b
h
u
h
U

444
D
864
b
76
b
28
382
130
CONSUMPTION
Tons
477
b-
504
' 86
550
173
254
472
b
!_
0
»_
0
b
490
b
953 '
b
83.8
b
31
421
198
aNot available.
bNot calculated.
cAmbient.
dAll units have same exit gas flow rate,
eflaximur, value.
fOnly one value reported.
                                 C-15
-------
 Table C-13.  SOLVENT CONSUMPTION DATA FOR INSIDE  ORGANIC
             SOLVENT-BASED GREEN TIRE SPRAYING

                    (Industry Survey II)
Plant Code
A
B
C
D
E
F
G
H
I
J
K
L
M
N
0
P
Q
T
V
W
Y
Z
AA
BB
CC
DD
EE
FF
GG
HH
II
VOC CONSUMPTION 1977
Mg Tons
63.8 70.3
a
a
12.7 14.0
a
a
b
b
b
b
a
b
443.6 489.0
362.6 400.0
a
b
b
180.9 199.4
b
b
6
b
' b
•"*• b
b
b
a
a
325.0 358.3
b
160.6 177.0
VOC CONSUMPTION 1978
Mg Tons
56.3 62.0
a
a
b
a
a
b
a
b
b
385.3 424.7
b
441.0 486.1
132.0 145.6
a
b
b
179.1 197.4
a
b
a
b
b
b
b
b
a
a
80.8 89.1
a
b
VOC CONSUMPTION 1979
Mg Tons
27.6 30.4
b
b
b
b
167.0 184.0
b
a
b'
b
506.6 558.4
b
436.0 480.6
60.0 66.2
b
b
b
175.6 a 193.6
a
b
a
b
b
b
b
b
b
a
b
a
b
aBlank indicates that annual mass of solvent consumption could not be
 calculated.
 The plant used  water-based  sprays only.
                            C-16
-------
        Table  C-14.  SOLVENT CONSUMPTION FOR OUTSIDE ORGANIC
                   SOLVENT-BASED GREEN TIRE SPRAYING

                          (Industry Survey II)
Plant
Code
A
B
C
. P
E
F
G
H
I
J
K
L
M
N
0
P
Q
R
S
T
U
V
u
X
Y
Z
AA
BB
CC
DD
EE,
VOC Consumption 1977
Mg Tons
93.8
207.7

264.1
341.0
553.7
214.2


503.1


. 297.9




303.6
601.3

520.6

511.3
749.7
496.1


69.1
363.3

714.6


a




a
a

a
b

b
b
a
a


a

a



a
b


a

103.4
229.0

291.1
375.8
610.4
236.1


554.6


328.4




334.6
662.8

573.9

563.6
826.4
546.9


76.2
400.5

787.7
VOC Consumption 1978
Mg Tons
91.5
235.9
121.6

298.2
550.3
234.9


447.2
59.0

206.3




222.6
525.5

404.7
269.2
596.5
763.6

882.1

64.0
38.4

809.5



a



a
a


b

b
b
a
a


a




a

b


a

100.9
260.0
134.0

328.7
606.6
260.0


493.0
•65.0

227.4




245.3
579.3

446.1
296.7
657.5
841.7

972.4

70.5
42.3

892.3
VOC Consumption 1979
Mg Tons
107.5
210.4
88.4

271 .9
545.7
185.8





192.1




31.2
365.6

441.8
492.3
576.4
740.6

422.4

35.8

371.8




a



b
b
a
b
b

b
b
b
b


a


* '»

a

b

b

a
118.5
231.9
97.4

299.7
601.5
204.8





211.7




34.4
402.9

487.0
542.7
635.4
816.3

465.6

39.5

409.8

 Blank Indicates that annual mass of solvent consumption could not be calculated.
HThe plant used water-based sprays only.
                                C-17
-------
          Table C-15.   SOLVENT CONSUMPTION  FOR INSIDE
                  WATER-BASED  GREEN TIRE SPRAYING

                        (Industry Survey II)
Plant
Code
A
B
c
D
E
F
G
H
I
0
K
L
H
N
0
P
Q
R
S
T
U
V
U
X
Y
Z
AA
BB
CC
DD
EE
VOC
Mg

5.8

0.0
0.0
0.0



0.0



0.0




0.0
0.0



3.3
0.0
0.0


0.0

0.0
Consumption 1977
Tons
a

a



b
a
a

a
b
b

a
a
a
b


a
b
a



a
a

a


6.5

0.0
0.0
0.0



0.0



0.0




0.0
0.0



3.7
o.o
0.0


0.0

0.0
VOC
Mg

5.6

0.0
0.0
0.0



0.0

0.0

0.0
1.2


5.5
D.O
0.0
0.0


2.3
0.0
0.0


0.0

0.0
Consumption 1978
Tons
a

a



a
a
a

a

b


a
a




b
a



a
a

a


6.2

0.0
0.0
0.0



0.0

0.0

0.0
1.3


6.0
0.0
0.0
0.0


2.5
0.0
0.0


0.0

0.0
VOC
Mg
0.0
4.5

0.0
0.0
0.0
0.0
0.0
0.0
0.0

0.0

0.0
8.6
0.0

0.0
0.0
0.0
0.0

0.0
2.4
0.0
0.0


0.0

0.0
Consumption 1979
Tons
0.0
4.9:
a
0.0
0.0
0.0
0.0
0.0
0.0
0.0
a
0.0
b
0.0
9.4
0.0
a
0.0
0.0
0.0
0.0
b
0.0
2.6
0.0
0.0
a
a
0.0
a
0.0
aBlank Indicates that annual mass of solvent consumption could not be calculated.
H'he plant used organic-based sprays only.  .
                                    C-18
-------
          Table C-16.  SOLVENT CONSUMPTION FOR  OUTSIDE
                  WATER-BASED GREEN TIRE  SPRAYING

                       (Industry  Survey II)
Plant
Code
A
B
C.
D
E
F
G
H
I
J
K
L
M
N
0
P
Q
R
S
T
U
V
w
X
Y
Z
AA
BB
CC
DO
EE
VOC Consumption 1977
Mg Tons
a
a
b
8.9 9.8
b
b
0.0 0.0
b
a
a
b
0.0 0.0
b
0.0 0.0
b
b
2.0 2.3
b
b
a
b
b
a
b
b
b
b
b
a
b
b
VOC
Mg



8.8


0.0




0.0

0.0


1.7
0.0









0.0



Consumption 1978
Tons
a
a
a
9.7
b
b
0.0
b
a
a
a
0.0
b
0.0
b
b
1.9
0.0
b
a
b
b
b
b
b
a
b
0.0
a
b
b
VOC
Mg

7.2

8.9

0.0
0.0
0.0
7.8
5.2

0.0
0.0
0.0


1.6
7-9

8.5




0.0

0.0
0.0



Consumption 1979
Tons
a

a

b





a



b
b


b

b
b
b
b

a


a
b
b

8.0

9.8

0.0
0.0
0.0
8.6
5.8

0.0
0.0
0.0


1.8
8.7

9.4




0.0

0.0
0.0



aBlank indicates that annual mass of solvent consumption could not be calculated.

 Tfce plant used organic-based sprays only.
                                   C-19
-------
Table C-17.  SOLVENT CONSUMPTION DATA AND OPERATING PARAMETERS
                      FOR TIRE BUILDING3


                      (Industry Survey I)
Plant
Code
A
B
C
D
E
I
K
L
M
0
P
Q
R
T
V
W
X
Y
Z
BB
DD
VOC
Mg
a
a
63
a
a
a
a
a
a
a
53
a
a
a
a
a
a
a
a
a
a
CONSUMPTION
Tons
148
a
100
74
153
a
a
163
645
295
76
280
a
a
a
20
n
a
112
9
a
Plant
Code
EE
FF
GG
HH
JJ
LL
NN
00
PP
QQ
RR
SS
TT
UU
WW
XX
YY
ZZ
AAA
BBB
CCC
VOC
Mg
a
33
a
a
61
a
50
a
a
a
67
a
a
42
a
a
a
a
a
a
i a
CONSUMPTION
Tons
281
a
a
13
120
a
24
29
238
a
72
9
88
62
a
488
a
a
a
25
2
aBlanks indicate that the number of machines was not available or that
 VOC emissions could not be calculated.
                               C-20
-------
       Table C-18.  SOLVENT CONSUMPTION DATA FOR FINISHING*
                        (Industry Survey  I)
Plant
Code
A
B
C
D
E •
I
K
L
M
0
P
Q
R
T
V
W
X
Y
Z
BB
DD
VOC
Mg
a
a
17.1
23.7
1.2
a
17.9
a
1.4
a
8.5
a
a
17.2
a
a
a
116.5
a
3.3
a
CONSUMPTION
Tons
a
a
18.8
26.1
1.3
a
19,7
a
1.5
a
9.4
a
a
19.0
a
a
a
128.4
a
3.6
a






















Plant
Code
EE
FF
GG
HH
JJ
LL
NN
00
PP
QQ
RR
SS
TT
uu
ww
XX
YY
II
AAA
BBB
CCC
VOC
Mg
0.7
1.1
31.4
3.0
99.1
a
12.8
8.6
a
a
9.8
11.3
16.0
14.9
a
a
a
a
1,1
a
2.6
CONSUMPTION
Tons
0.8
1.2
34.6 .
. 3.3
109.3
a
14.1
9.5
a
a
10.8
12.5
17.6
16.4
a
a
a
a
1.2
a
2.9
Blanks indicate that annual mass of VOC emissions could not be calculated.
                               C-21
-------
C.3  CALCULATION OF MEAN EMISSION FACTORS FOR SOLVENT-CONSUMING;
       FACILITIES
     Average gram-per-tire emission factors were developed in an
effort to illustrate the relative quantities of VOCs emitted from each
solvent-consuming process.  Three methods of calculation, each dependent
upon one of the data sets, were used to generate emission factors for
the various tire manufacturing operations.  Table C-19 shows the
resulting emission factors.
C.3.1  Calculation Methodology for Undertread. Tread-end. Sidewall,
          and Bead Cementing Operations
     Mean emission factors for undertread cementing, tread end cementing,
sidewall cementing, and bead cementing operations were calculated from
Industry Survey II data.  The industry mean gram-per-tire emission
factor for each of these four processes was calculated in the following
manner:
          (1)  Annual solvent consumption values, in grams, were totaled
for each reporting plant for 1977-1979;
          (2)  This sum was divided by the total number  of finished
tires produced at .the plant between 1977 and 1979;
          (3)  Resultant values represented individual plant gram-per-
tire emissions factors;
          (4)  Individual plant emission factors were totaled, and
divided by the total number of reporting plants.
C.3.2  Calculation Methodology for Tire Building and Finishing
     Mean emission factors for tire building and finishing processes
were calculated from Industry Survey  I data.  The industry mean gram-per-
tire emission factors for these operations were derived  in the following
manner:
          (1)  Solvent consumption, in grams, was established for each
plant;
          (2)  This value was divided by the total  number of finished
tires produced at  that same plant during the reported year;
                                  C-22
-------
          (3)  Resultant values, representing individual plant
gram-per-tire emission factors, are then summed, and divided by  the
total number of reporting plants.
C,3.3  Calculation Methodology for Inside and Outside Green Tire
          Spraying
     Mean emission factors for inside and outside green  tire spraying
processes were developed using Industry Survey  II data.  The industry
mean gram-per-tire emission factors for these processes  were calculated
in the following manner:
          (1)  Annual water-based green tire spray  consumption values
for each plant are converted from units of volume to units of mass
using vendor- and industry-supplied density values;
          (2)  Water-based green tire spray mass consumption values
are multiplied by the volume percent of VOCs contained  in the spray
and divided by the total number of finished tires produced;
          (3)  Solids contained in organic solvent-based green tire
sprays are assumed to be in solution; thus the  green tire spray  mass
consumption values are divided directly by the  total number  of finished
tires produced;
          (4)  Per-tire solvent consumption values  for  each  plant are
averaged over 3 years, weighted by tire production; then the 3-year
plant averages are totaled and divided by the  total number of plants
reporting data.   (Note:  Per-tire inside and outside organic green
tire spray values are calculated  in  a manner similar to that for
undertread, sidewall, tread end,  and bead cementing);
     Through comparison, gram-per-tire emission factors reflect  the
relative importance  of VOC emissions from each  tire processing operation.
The  emission factors are also  used  in  calculating  the  industry's total
VOC  emissions and aid in projecting  the percent reduction  of emissions
associated with  proposed regulatory  alternatives.   The  gram-per-tire
scheme  is also utilized to project  environmental,  economic,  and  cost
impacts  from the proposed levels  of  emission  reduction.
                                  C-23
-------
  TABLE C-19.  MEAN EMISSION FACTORS BASED ON SOLVENT CONSUMPTION DATA
                          (1977 through 1979)
          Operation
Solvent Use
 (gms/tire)
     Undertread Cementing
     Sidewall Cementing
     Automatic tread-end
       Cementing
     Manual tread-end
       Cementing
     Tread-end Cementing
       Aggregate
     Bead Cementing
     Inside Green Tire
       Spraying
          Organic Solvent-based
          Water based
     Outside Green Tire
       Spraying
          Organic Solvent-based
          Water-based
    63.2
    41.1

    23.8

     9.9

    15.1
     8.3
    48.2
     0.1
    89.0
     1.4
aWhere solvent consumption for undertread cementing facilities and
 sidewall cementing facilities were reported as one figure.
C.4  CALCULATION OF VOC EMISSIONS FROM HIGH-TEMPERATURE TIRE MANUFACTURING
     OPERATIONS
     A temperature-weight loss correlation proposed by S.M. Rappaport
has been used to estimate emissions from tire curing.  Emissions from
other high-temperature tire manufacturing processes are approximated
using the ratio of the operating temperature to 180°C (the temperature
at which curing emissions were measured) as a correction factor.  In
addition, the numerical constants must be reduced by a factor of 10
when estimating volatile organic compound emissions, because 90 percent
                                 C-24
-------
-------
  TABLE C-19.   MEAN EMISSION FACTORS BASED ON SOLVENT CONSUMPTION DATA
                          (1977 through 1979)
          Operation
Solvent Use
 (gms/tire)
     Undertread Cementing
     Sidewall Cementing
     Automatic tread-end
       Cementing
     Manual  tread-end
       Cementing
     Tread-end Cementing
       Aggregate
     Bead Cementing
     Inside Green Tire
       Spraying
          Organic Solvent-based
          Water based
     Outside Green Tire
       Spraying
          Organic Solvent-based
          Water-based
    63.2
    41.1

    23.8

     9.9

    15.1
     8.3
    48.2
     0.1
    89.0
     1.4
 Where solvent consumption for undertread cementing facilities and
 sidewall cementing facilities were reported as one figure.
C.4  CALCULATION OF VOC EMISSIONS FROM HIGH-TEMPERATURE TIRE MANUFACTURING
     OPERATIONS                             -                   !
     A temperature-weight loss correlation  proposed by S.M. Rappaport
has been used to estimate emissions from tire curing.  Emissions from
other high-temperature tire manufacturing processes are approximated
using the ratio of the operating temperature to 180°C (the temperature
at which curing emissions were measured) as a correction factor,.  In
addition, the numerical constants must be reduced by a factor of 10
when estimating volatile organic compound emissions, because 90 percent
                                 C-24
-------
of the weight losses that were observed coulti  b$  attributed  to evaporation
of water.*  Thus, the modified temperature-weight loss  equation is:
                      C = 1.24 x 10
                                   -3
(C-l)
where C = weight loss, grams per kilogram;
      T = operating temperature, °C.
     In compounding, the mechanical release of heat normally  raises
the temperature of the rubber stock to  100°C.  Twenty  percent of  the
volatile species emitted are assumed to be adsorbed on carbon black
particulate that are simultaneously released.  Therefore, the emission
factor fpr compounding is:
          (0.8)  (1.27 x 10"3)  (100) = 0.1 g/kg
(C-2)
     A representative tire mass is required to convert the emission
factor from equation C-2 to grams-per-tire.  A passenger car tire was
chosen for this purpose because it represents approximately 80 percent
of the total number of tires produced by the industry, according to
the information shown in Table 3-1.  Data supplied by three plants
that produce only passenger car tires were used to calculate an average
tire mass of 11.5 kilograms.  Using this value, the estimated emission
factor for compounding is one gram per tire.
C.5  EMISSION TEST ACTIVITIES
C.5.1  Stage 1 Emission Tests
     Emission tests were performed at the undertread cementing operation
at one plant in order to: (1) determine VOC removal efficiency of the carbon
*Presentation, R.C. Miles, Uniroyal, Incorporated, to K.J. Zobel,
 ESED, OAQPS, EPA.  September 8, 1977, Durham, North Carolina.
                                 C-25
-------
adsorber, (2) determine cement usage, and  (3) compare mass emissions
using flame ionization detection (FID) method and EPA Method 25*  The
operation is equipped with a capture system which encloses the cement
application area and conveyor leaving the  application area,,  Captured
VOCs are vented to a dual bed carbon adsorber.                 ;
     Carbon adsorber removal efficiency was tested using the flame
ionization detection (FID) method and EPA  Method 25.  The removal
efficiency agreed closely for both methods.  Three one-day tests  of
the carbon adsorption system removal efficiency were conducted using
the FID method.  Carbon adsorber inlet and outlet concentrations  were
measured and compared.  The mean inlet concentration was 8.7 x ,10 ppmv
and the mean outlet concentration was approximately 1.1 x 10  ppmv,
for a mean removal efficiency of 87.9 percent.  On a mass basis,  the
removal efficiency for VOC was about 88.7  percent, with a reduction in
the mean inlet quantity of 47.8 milligrams per square centimeter  (mg/cm  )
of undertread cemented to a mean outlet quantity of 5.39 mg/cnT.   See
Table'C-20 for a summary of data.  Five two-hour tests of the carbon
adsorption system were conducted using EPA Method 25.  The mean removal
efficiency for VOC was 86.7 percent.  See  Table C-21 for a summary of
the test results using EPA Method 25.
     Data scatter in the results was attributed to  two variables:  (1)
the type of tread being processed  (radial  versus non-radial), and (2)
variations in the effectiveness of the enclosure, due to length of
time the operator needed access to the cement  application equipment.
     Cement usage data was  collected over  a  two-day period.   As shown   ,
in Table C-22, there was a  wide variation  in cement usage  between
measurement periods.  The variation was  considered  reasonable based  on
potential process variations during  the  test  period  and  testing conditions.
For  example,  the  cement  usage  rate varied  with respect  to  the type of
tread  being processed  (radial  versus non-radial).   It was  concluded
that the measurement method would  be  reliable  for  estimating  average
cement usage  provided that  tests are conducted over a  sufficient
number of days.   However, because  of the limited  amount of  data collected
at this site,  any conclusions  about  cement usage  are limited.
                                  C-26
-------
C-27
-------
Table C-21.  CARBON  ADSORBER EFFICIENCY—EPA METHOD 25
RUN
S
1
2
3
4
5
AVERAGE'
INLET
(ppnw)
4314
8845
4623
5592
8614
—,—,
OUTLET
(ppmv)
774
917
534
779
702
— ,T-
" REMOVAL' " ;
EFFICIENCY :
(X)
82.1 . :
89.6
'88.5
86.1
91.9
87.6
                       C-28
-------
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1
                    C-29
-------
     For further detail about  these  tests  see  the final  test  report.**
C.5.2  Stage 2 Emission Tests
     Emission tests were performed at the  tread end cementing and  bead
cementing facilities of two plants.  The test  objectives were:   (1)  to
determine VOC evaporation rates from cemented  components,  (2) to
determine cement usage rates,  and  (3) to measure VOC mass  emissions
using FID analysis and EPA Method 25.
     C.5.2.1  Tread End Cementing.   The tread  end cementing operation
at Plant Number One was equipped with automatic spray arms, one  for
each tread end, which are triggered  by an  electric eye system as the
tread passes on a conveyor.  At Plant Number Two each tread passes a
cementing station on a conveyor belt where cement is manually applied
to both bevel-cut ends of the  tread.  An operator paints the  cement  on
the tread using a sponge which he dips into an open tray containing
the cement.  After cementing,  the treads are conveyed to "bopkers" who
place the treads onto a series of trays which  resemble the pages of  an
open book.
     Each test was performed by taking a freshly cemented  tread  off
the conveyor just after cement application and placing it  into a
ventilated enclosure as quickly as possible.   The ventilated  enclosure's
exhaust VOC concentration and  air volume was measured so a VOC mass
emitted from the cemented tread could be calculated.  Individual tests
were considered complete when  the test enclosure VOC concentration had
decayed to 5 percent of its peak initial concentration.  The.length  of
time required for 90 and 95 percent  reduction  of the peak  VOC "flash
off" concentration was also recorded at both plants.  The  length of
time required for 99 percent reduction of  the  peak VOC "flash off"
concentration was also recorded at Plant Number Two; however, due  to
high background concentrations, too  few results could be recorded  for
any conclusions to be drawn.   "Flash off"  times are shown  below:
**0ongleux, R.F., Volatile Organic Carbon Emission Testing at Armstrong
  Rubber Company, Eastern Division, West Haven, Connecticut,;TRW,
  Environmental Engineering Division.  Durham, North Carolina.  April  1979.
                                 C-30
-------
Time
Plant No. 1
Plant No. 2
 95
 gg
Number of
  Tests
                  34
                  28
   47
   33
    6
   Averaged
  Flash-Off
Time (Seconds)
                    82.7
                   112.0
    108
    125
    113
  Range
(Seconds)
                  58 to 148
                  69 to 204
68 to 218
77 to 185
94 to 147
Standard
Deviation
(Seconds)
                21.5
                33.1
  31
  29
  20
     Tread end cementing VOC emission  results  are  expressed  as mass  of
carbon emitted (in grams) per unit  area  (square  centimeters)  of  tread
cemented.  These results are divided into  six  categories;  VOC(FID)go,
Flash-Off VOC(FID)go, VOC(FID)g5, Flash-Off  VOC(FID)g5,  VOC(FID)gg,
and Flash-Off VOC(FID)gg.   VOC(FID) values represent  emissions recorded
from initial instrument response  (after  encosure)  to  time  tgQ, tg5,  or
tgg.  Flash-off VOC(FID) values represent  emissions from VOC(FID)  plus
an estimate  of emissions from cement application to initial  instrument
response after placement in the test enclosure.  Values  are  shown
below:
      VOC  Name
 Plant No.  1
 VOC(FID)g0
 Flash-off VOC(FID)g0
 VOC(FID)g5
 Flash-off VOC(FID)g5
Number
of
Tests
Averaged
VOC Mass
Per Area
(q/cm2)
Range
(q/cm2)
Standard
Deviation
(q/cm2)
33
33
26
26
0.0025
0,0027
0.0027
0.0030
                                0.0009  to 0.0043   0.0006
                                0.0010  to 0.0046   0.0007
                                0.0020  to 0.0048   0.0007
                                0.0022  to 0.0051   0.0008
                                      C-31
-------
Number
of
Tests
47
47
33
33
6
6
Averaged
VOC Mass
Per Area
(g/cm2)
0.0033
0.0035
0.0033
0.0035
0.0019
0.0020
Range
(g/cm2!
0.0011 to 0.0078
0.0011 to 0.0081
0.0011 to 0.0088
0.0011 to 0.0091
0.0015 to 0.0024
0.0016 to 0.0016
Standard
Deviation
(g/cm2)
0.0019
0.0019
0.0019
0.0020
0.0003
0.0004
       VOC Name

  Plant No.  2
  VOC(FID)go
  Flash-off  VOC(FID)go
  VOC(FID)95
  Flash-off VOC(FID)95
  VOC(FID)99
  Flash-off VOC(FID)gg

      During each tread end cementing material balance  test  run  at  both
 plants, the quantity of cement used over a selected time period  and
 the total surface area of treads cemented were measured.  Each  test
 period coincided with the duration of a production run for  treads  of
 common size and identification number.   Material balance test results
 are shown below:
Average
raent Usage
(g/cm2)
Range
(g/cm2)
Standard
Deviation
(g/cm2)
Plant No.  1         0.017             0.004 to 0.036         :0.002
Plant No.  2         0.016             Q.013 to 0.019          0.003
      VOC mass emitted per mass  of cement  applied  tests  were'performed
using FID analysis and EPA Method 25  in order to measure the 'VOC mass
content of tread end cements used at  Plant Number  1 and  Plant  Number 2.
Results are shown below:

               VOC mass (g voc as carbon emitted per g       '
                         of cement dried)
                              Tread End Cementing
               Plant Number 1
               Plant Number 2
0.95
0.84
                                 C-32
-------
For more details of the test methodology,  see  the  final  test results.***

     C.5.2.2  Bead Cementing.  Tests were  performed  at  the  bead  cementing
facility at one plant in order to quantify the VOC mass  which was
emitted by a freshly cemented bead or  group of beads, and to correlate
this mass with bead surface area upon  which the cement was  applied.
Tests were performed at the bead cementing facilities of the plant at
which Stage 1 emissions tests were conducted and at  an  additional
plant, in order to determine the quantity  (mass) of  cement  used  for
bead production over a selected period of  time.  This mass  was compared
to the total bead surface area cemented during the same  time period.
     The bead cementing facility at Plant  No.  1 was  composed of  two
cement-filled tanks which were covered when not in use.  Groups  of
about 50 beads were dipped into the tank at one time and placed  on a
rack above and behind the tank to dry.   Excess cement dripped onto a  '
splash board and dried or was returned to  the  tank.
     The bead cementing facility at Plant  No.  2 was  part of the  bead
formation apparatus.  An extruder fuses a  rubber coating onto continuous
strands of wire.  The wire/rubber combination  exits  the  extruder as
one flat strip.  This flat strip then  passes over  a  wheel which  is
partially submerged in a cement bath.   Contact with  the  wheel  causes
it to rotate, thereby coating one side of  the  passing wire/rubber
strip with cement.
     Bead cementing VOC emission tests were only performed  at Plant
No. 1, since there was no effective way to directly  measure VOC
emissions from the application equipment used  at Plant  No.  2.  At
plant No. 1, each test was performed by taking one or a  pair of
***Ringquist, D.E., and R.T.  Harrison.   Volatile  Organic  Compound
    Emission Measurements for  Tread  End  Cementing  and  Bead Cementing
    at  a Tire Manufacturing  Plant, Kelly-Springfield Tire  Company,
    Fayetteville,  North Carolina.  U.S.  Environmental  Protection
    Agency.  Research Triangle Park,  North  Carolina.
    Rinquist, D.E., and R.T. Harrison.   Volatile Organic Compound
    Emission Measurements for  Tread  End  Cementing  and  Bead Dipping
    Operations at  a Tire Manufacturing Plant.   Armstrong Rubber
    Company, West  Haven, Connecticut.  U.S. Environmental  Protection
    Agency.  Research Triangle Park,  North  Carolina.
                                 C-33
-------
uncetnented beads and manually dipping  them  into  the  cement, bath.
After dipping, beads were withdrawn  from the cement  bath  and  allowed
to drain for deliberately varied time  periods  of between  1.1  and
11.2 seconds.  The degree to which the beads were allowcsd to  drain
prior to being placed in the test enclosure directly affected the VOC
mass emitted from them during drying.   The  freshly cemented beads were
placed into the ventilated enclosure for drying  in the  same manner  as
for the tread end cementing tests.
     The length of time required for 90 and 95 percent  reduction of
the peak VOC "flash-off" concentration was  recorded.  A summary of  the
results is shown below:
Time
U90
b95
Number of
  Tests
   37
   37
Averaged Flash-off
  Time (Seconds)
        118
        161
Range
(Seconds)
83 to 149
111 to 213
Standard
Deviation
(Seconds)
15.1
24.3
     Bead cementing VOC emission results are expressed as mass  of
carbon emitted (in grams) per unit area (square centimeters) of tread
cemented.  These results are divided into four categories; VOC(FID)go,
Flash-off VOC(FID)go, VOC(FID)g5', and Flash-off VOC (FID) gy  VOC(FID)
values represent emissions recorded from initial instrument response
(after enclosure) to time tgQ, tg5,tg5, or tgg.  Flash-off V0C(FID)
values represent emissions from VOC(FID) plus an estimate of cement
application to initial instrument response after placement in the test
enclosure.  Values are shown below:
VOC Name              Tests

VOC(FID)gQ              21
Flash-off VOC(FID)go    21
VOC(FID)g5              21
Flash-off VOC(FID)g5    21
                      Number   Averaged VOC
                        of      Mass/Area
                              2
                        (gm/cm )
                         0.0347
                         0.0370
                         0.0390
                         0.0410
                           Range
                          (gm/cm )

                      0.2970 to 0.0413

                      0.0318 to 0.0432

                      0.0327 to 0.0466
                                      !
                      0.0348 to 0.0485
Standard
Deviation
       2
 (gm/cm )
   0.003
   0.003
   0.004
   0.004
                                 C-34
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     During each bead cementing material balance test run at the  two

plants, both the quantity of cement used over a selected time period

and the total bead surface area cemented were measured.  Tests were

run over a 4-day period at each plant.  Material balance test results
are shown below:
                    Average
                 Cement Usage

                    (q/cm2)
Plant Number 1

Plant Numer 2
0.036

0.0034
     Range

    (q/cm2)

0.024 to 0.053

0.0014 to 0.0079
 Standard
Deviation
 (g/cm2)

  0.009

  0.0020
     VOC mass emitted per mass of cement applied tests were performed

using FID analysis and EPA Method 25 to measure the VOC mass content
of bead cements used at Plants No. 1 and Plant No. 2.  Results are
shown below:


                VOC mass (g voc as carbon emitted per g
                           of cement dried)
                          Bead end cement
     Plant Number 1
                             0.77
     Plant Number 2
                             0.97
For more details of the test methodology, see the final test reports.***
***Ringquist, D.E., and R.T. Harrison.  Volatile Organic Compound
   Emission Measurements for Tread End Cementing and Bead Cementing
   at a Tire Manufacturing Plant, Kelly-Springfield Tire Company,
   Fayetteville, North Carolina.  U.S. Environmental Protection
   Agency.  Research Triangle Park, North Carolina.

   Rinquist, D.E., and R.T. Harrison.  Volatile Organic Compound
   Emission Measurements for Tread End Cementing and Bead Dipping
   Operations at a Tire Manufacturing Plant.  Armstrong Rubber
   Company, West Hanover, Connecticut.  U.S. Environmental Protection
   Agency.  Research Triangle Park, North Carolina.
                                 C-35
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                  APPENDIX D



EMISSION MEASUREMENT AND CONTINUOUS MONITORING
                      D-1
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                      Appendix D - Emission Measurement
                          and Continuous Monitoring
D-l  Emission Measurement Methods
     During the standard support study for the rubber tire manufacturing
industry, the U.S Environmental Protection Agency conducted tests at two
tire manufacturing plants.
     The purposes of this test program were:  (1) to determine the
amount of cement used at various types of operations within these plants
(2) to compare cement usage rates for different methods of cement
application for the same operation, (3) to determine the VOC removal
efficiency of a carbon adsorption system, and (4) to determine the rate
at which VOC emissions evaporated when applied at the various types of
operations at these plants.  The summary of the results of these tests is
described in Appendix C.
     To determine the rate of cement usage at each operation of interest,
a material balance test procedure was used.  The following is a general
description of the material balance test procedure; specific details :may
be obtained from the Emission Test Report Numbers 79-rRBM-l, 79-RBM-6 ;
and 79-RBM-7.
     The material  balance consisted of determining the weight of
cement used over a selected time period and the total  surface area
of the product to  which cement was applied during that same time
                                     D-2
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period.  The cement usage was determined by pre- and post-weighing the
container from which the cement was used.  For three operations - two
bead cementing and one undertread cementing operation - it was necessary
to determine the initial level in the container; and at the end of the
test run, refill the container to the initial level and weigh the cement
additions. The total surface area of the product cemented was determined
as follows: (a) For undertread cementing, the nominal line speed was
multiplied by the elapsed time for a tread run and the nominal booking
width of the tread. This surface area cemented per tread run was then
added together for all tread runs tested,  (b) For tread ends cementing,
the nominal tread width for each tread size was multiplied by the number
of treads of that size and the average tread cemented length.  The
average tread cemented length was determined from measurements made on
several treads.  For the manual cement application technique, this value
was determined for each tread size; for the spray application technique,
a single value was determined for all tread sizes.  The surface area
cemented per tread run was then added together for all tread runs tested.
(c) For bead cementing, the cemented surface area was determined from
the nominal wire size and number of turns per bead (obtained from factory
specifications) and multiplied by the total quantity of beads cemented.
     Cement usage results were reported per surface area cemented to allow
comparison of different methods of application.  Data were also obtained
to relate emission results in terms of nominal weight of the finished
tire.
     To determine the VOC removal efficiency of the carbon adsorption
system, simultaneous emission tests were performed on the inlet and
.exhaust of the carbon adsorption system using both EPA Method 25 and a
                                     D-3
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 flame ionization detector  (FID) procedure to determine the VOC concentration
 and following EPA Methods  1,2, and 4 to determine volumeteric flow
 rates. Sampling runs were  scheduled to correspond with the adsorption cycle
 of one of the carbon beds  of the two-bed system.  Some runs were performed
 on both beds.                        .„...                       ffr	     ,
                  ,.., ;' <•'•'"  . V ••"':''                       i » •  : -
     The rate a't which VOC emissions evaporated when cement was  applied
 was determined for two types of tread end cementing (one type at each of
 two plants) and for one type of bead cementing application technique-.
 For tread end cementing, each test was performed by taking a freshly
 cemented tread off the conveyor just after cement application and placing
 it in a ventilated enclosure as quickly as possible.  The ventilated
 enclosure exhaust VOC concentration was monitored with a flame ionization
 detector analyzer (FID), and the air volume was measured with a  positive
 displacement type meter so a mass of VOC could be calculated.  Propane
was used to calibrate the  FID.  The VOC concentration was monitored and
 recorded on a strip chart  recorder.  Records were maintained of  the
 elapsed time from cement application to tread enclosure, elapsed time to
 90 and 95 percent reduction of the peak VOC concentration.  It was
 assumed that the solvent had evaporated 90 and 95 percent within the
 time specified by the corresponding peak VOC concentration percent
reduction.
     The evaporation rate  for one method of bead cementing was similarly
determined; however, because of sampling equipment limitations,  the
normal  plant operation was simulated with a smaller number of beads.
This simulation appears to have increased the apparent cement usage per  -
                                                                    i
surface area cemented,  however it is not certain what effect this would
                                     D-4
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have on the evaporation rate.   However,  since the apparent cement usage
rate was increased, it would appear that the recorded time to  evaporate
a specified percentage would be greater  than normal  plant operations.
                                     D-5
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 D.2   PERFORMANCE TEST METHODS
      Performance test methods are needed to determine the VOC content of
 coating and to determine the overall control efficiency of an add-on'
 VOC control system.                                                 •
 D.2.1  Volatile Organic Compound Content of the Coating.
      The volatile organic content of the coating may be determined by
manufacturer's formulation or from Reference Method 24, "Determination
                       t
 of Volatile Organic Content (as Mass) of Paint, Varnish, Lacquer, or
 Related Products."
      Reference Method 24 combines several ASTM standard methods which
determine the volatile matter content, density, and water content of
 the coatings.  From this information, the mass of volatile organic compounds
 (VOC) per unit mass of coating is calculated.   The estimated cost of
 analysis per coating sample is $150.  For aqueous coatings,  there is an
additional $100 per sample for water content determination.   Because
 the testing equipment is standard laboratory apparatus, no additional
purchasing costs are expected.
D.2.2  Control Efficiency of VOC Add-on Control System           .   !
      If the VOC content of the coatings used exceeds the level  of the
recommended standard the efficiency of the add-on control  system must
 be determined.   This would be used in conjunction with the  mass of ;
solvent used to determine compliance with the  recommended standard.
      For those types of control  systems which  do not destroy or change the
nature of VOC emissions,  the recommended procedure is a material  balance
system where the mass of the VOC recovered by  the control  system is
determined and used in conjunction with the mass of VOC used over the
                                     D-6
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same period of time.  The length of time during which this material
balance is conducted will be dependent on the Agency's decision on whether
to require continual compliance or to demonstrate compliance during an
initial performance test.  Examples of control systems where this
procedure would be applicable are refrigeration and carbon adsorption
systems.
     For those control systems which alter the VOC emissions (such as
incinerators) a different approach is recommended.  Ideally, the procedure
would directly measure all VOC emitted to the atmosphere.  However, this
would require measurement of the VOC emissions which escape capture
prior to the incinerator (control system) by construction of a complex
ducting system and measurement of the VOC emissions exhausting to
atmosphere from the control system.
     The recommended procedure requires simultaneous measurement of the
mass of VOC (as carbon) entering the control system and exiting the control
system to the atmosphere.  Methods 1, 2, 3, and 4 are recommended to
determine the volumetric flow measurements.  Reference Method 25
is recommended to determine the VOC (as carbon) concentration.  These
results are then combined to give th.e mass of VOC (as carbon) entering
the control system and exiting the control system to the atmosphere.  The
control efficiency of the control system is determined from these data.
     The average of three runs should be adequate to characterize the control
efficiency of the control system.  The length of each, run would be dependent
on the operational cycle of the control system employed.  Minimum sampling
time would be in the range of 30 minutes and would be dependent on the
size of the evacuated tanks and the sampling rate employed to obtain a
                                     D-7
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sample.  The control agency should also consider the representativeness
of the solvents used during the test program.   Although the actual  testing
time using Reference Method 25 is only a minimum of 1  1/2 hours,  the total
time required for one complete performance test is estimated at 8 hours,  with
an estimated overall cost of $4,000.
D.3  MONITORING SYSTEMS AND DEVICES
     The purpose of monitoring is to ensure that the emission control
system is being properly operated and maintained after the performance
test.  One can either directly monitor the regulated pollutant, or instead,
monitor an operational parameter of the emission control  system.   The aim
is to select a relatively inexpensive and simple method which will  indicate
that the facility is properly operated and maintained.
     For carbon adsorption systems, the recommended monitoring test is
identical to the performance test.  A solvent inventory record is
maintained, and the control efficiency is calculated every month.  Excluding
reporting costs, this monitoring procedure should not incur any additional
costs for the affected facility because these process data are normally
recorded anyway and the liquid volume meters were already installed for
the earlier performance test.
     For incinerators, two monitoring approaches were considered:
(1) directly monitoring the VOC content of the inlet, outlet, and fugitive
vents so that the monitoring test would be similar to the performance tests;
(2) monitoring the operating temperature of the incinerator as an
indicator of compliance.  The first alternative would require at least
two continuous hydrocarbon monitors with recorders, (about $4,000 each),
and frequent calibration and maintenance.  Instead, it is recommended
that a record be kept of the incinerator temperature.   The temperature
                                     D-8
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level  for indication of compliance should be related to the average
temperature measured during the performance test.   The averaging time
for the temperature for monitoring purposes should be related to the
time period for the performance test, in this case 1 1/2 hours.   Since
a temperature monitor is usually included as a standard feature  for
incinerators, it is expected that this monitoring  requirement will  not
incur additional costs for the plant.  The cost of purchasing and
installing an accurate temperature measurement device and recorder
is estimated at $1,000.
                                     D-9
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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
 1, REPORT NO.

  EPA 450/3-81-008a
            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
  Rubber Tire Manufacturing Industry - Background
  Information for Proposed  Standards
            5. REPORT DATE
              July 1981
            6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS

  Office of Air Quality  Planning and Standards
  U.S.  Environmental Protection  Agency
  Research Triangle Park,  North  Carolina  27711
            10. PROGRAM ELEMENT NO.
            11. CONTRACT/GR^ANT NO.


               68-02-3060
12. SPONSORING AGENCY NAME AND ADDRESS
 Director for Air  Quality Planning and Standards
 Office of Air,  Noise,  and Radiation
 U.S. Environmental  Protection Agency
 Research Triangle Park,  North Carolina  27711
                                                            13. TYPE OF REPORT AND PERIOD COVERED
            14. SPONSORING AGENCY CODE
                EPA/200/04
16. SUPPLEMENTARY NOTES
                     This report discusses the regulatory alternatives considered  during
 development of the proposed  new source performance standards and the environmental
 and  economic impacts associated with each regulatory alternative.      	
16. ABSTRACT
 Standards of Performance for  the control of VOC emissions  from the rubber tire manu-

 facturing industry are being  proposed under Section ill  of the Clean1 Air Act.  These

 standards would apply to the  following cement application  operations:   undertread

 cementing, sidewall cementing,  tread end cementing, bead cementing, inside green tire

 spraying, and outside green tire spraying.  This document  contains background infor-

 mation and environmental and  economic impact assessments of the regulatory alternatives

 considered in developing the  proposed standards.
 7.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                                                                         c.  COSATI Field/Group
 Air Pollution               NSPS
 Pollution  Control
 Standards  of Performance
 Rubber Tire Manufacture
 Volatile Organic Compounds (VOC)
Air Pollution  Control
13 b
 8, DISTRIBUTION STATEMENT
      Unlimited
                                              19. SECURITY CLASS (This Report)

                                                 Unclassified
                                                                         21. NO. OF PAGES
                                              20. SECURITY CLASS (This page)
                                                  'Unclassified
                         22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE
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