-------
OT
L_
JO
~o
a
co
en
3 -
co
ro
(A
c
o
U)
o
o
Cost Range
so
100
a c f m (x 1000)
ISO
FIGURE 3-4 ANNUAL COSTS OF THERMAL INCINERATION WITH HEAT RECOVERY
-------
also because some of the plants contacted by ETA were reluctant to
discuss equipment changes. Second, the use of water-borne coatings
would result in increased drying time, thus affecting plant production
rate. This effect on production rate can be offset by installing larger
drying chambers or by preheating the parts to be coated to enhance the
evaporation of water. The costs of implementing any of the above
options is again dependent upon the plant-specific operational
characteristics and therefore could not be estimated because of data
constraints. Since industrial input in the cost of conversion to water-
borne coatings was limited, CTG-derived cost estimates were assumed to
be representative of the cost impact on the affected sources in Ohio.
Table 3-7 presents the technical parameters used in developing the
compliance costs per plant and for the industry-wide cost of compliance.
Table 3-8 presents these compliance costs. For the purposes of develop-
ing costs for an incinerator, it was assumed that all the sources to be
controlled in an affected plant would be ducted to a single incinerator.
As Table 3-8 indicates, a cost range has been presented for the industry
groups covered under SIC 34, 35, 36, 37 and 384. Lower cost in the
range represents the compliance costs if the affected industries in
these SIC categories implemented water-borne coating technology. The
upper value in the cost range represents control costs if a thermal
incinerator was used for compliance with the regulation. Annualized
costs presented in the table include the incremental operating and
maintenance costs, material costs, cost of utilities for operating the
control equipment, and the fixed capital charges. Fixed capital charges
include a capital recovery factor for depreciation and interest charges
and a factor for insurances, taxes, and administrative overheads (four
percent of the capital cost). Capital recovery factor was estimated to
be 14.7 percent for conversion to water-borne coating and 17.7 percent
for incinerators. The total capital costs of compliance are estimated
to be approximately $14.2 million, if water-borne coatings are used for
compliance by the affected facilities in SIC 34 through 38. The
corresponding annualized costs are $5.9 million. However, if an
incinerator is used as a means of compliance by the facilities that are
3-23
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TABLE 3-7. TECHNICAL PARAMETERS USED IN ESTIMATING CONTROL COSTS
SIC Code
254
33
34
35
36
37
384
5085
Number of
Affected Plants
1
6
3
11
12
17
1
1
Average Number
of Sources
Per Plant
1
2
3
3
3
4
2
3
Average Exhaust
Flow Rate
Per Source
(acfm)
10,000
14,500
32,100
35,900
17,830
19,225
3,500
6,500
Average Exhaust
Flow Rate
Per Plant
10,000
29,000
96,300
107,700
53,490
36,900
7,000
19,500
Control Technique(s)
Powder coating
Thermal incineration
with heat recovery
Water-borne coating/
thermal incinerator
with heat recovery
Water-borne coating/
thermal incinerator
with heat recovery
Water-borne coating/
thermal incinerator
with heat recovery
Water-borne coating/
thermal incinerator
with heat recovery
Water-borne coating/
thermal incinerator
with heat recovery
Thermal incinerator
with heat recovery
-------
TABLE 3-8. COMPLIANCE COST ESTIMATES FOR AFFECTED MISCELLANEOUS METAL COATING PLANTS
SIC
Code
254
33
34
35
36
37
384
00
^ 5085
Ul
TOTAL
Number of
Affected Plants
1
6
38
11
12
17
1
1
Control
Capital
300
1,100
87-3,500
87-3,900
87-1,900
72-1,500
36-250
700
Costs Per Plant3
(x!03$)
Annual i zed"
100
350
48-1,100
48-1,300
48-650
28-500
14-100
250
Total Cost
of Compliance
(x!03$)
Captial
300
6,600
3,306-133,000
957-42,900
1,044-22,800
1,224-25,500
36-250
700
14,167-232,050
Annual i zed
100
2,100
1,824-41,800
528-14,300
576-7,800
476-8,500
14-100
250
5,868-74,950
VOC
Emission
Reductions
(tons/yr)
91
1,321
18,173
765
1,670
2,458
29
47
24,554
Cost-
Effectiveness
($/ton)
1,100
1,590
100-2,300
690-1,870
345-4,670
194-3,460
483-3,450
5,320
239-3,050
Wherever a cost range is given, the lower value represents the cost of converting to
water-borne coatings and the higher value represents the cost of using a thermal
incinerator with heat recovery.
The annualized costs included the operating and maintenance costs, material costs,
cost of utilities, and the fixed capital charges for depreciation, interest charges,
insurance, taxes, and administrative overheads.
-------
presently planning to use water-borne coatings, the estimated capital
costs of compliance would be approximately $232 million. The
corresponding annualized costs would be about $75 million. The cost-
effectiveness of control with the use of water-borne coatings is $239
per ton of reduction. The cost-effectiveness figure for an incinerator
as the compliance technology is $3,050 per ton of reduction in VOC
emissions.
3-26
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3.5 References
1. Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume VI: Surface Coating of Miscellaneous Metal Parts
and Products^EPA-450/2-78-015,D/iTEnvironmentalProtection
Agency, Research Triangle Park, North Carolina, June 1978.
2. PEDCO Environmental, Inc., Enforcement Aspects of Reasonably
Available Control Technology Applied to Surface Coating of
Miscellaneous Metal Parts and Products. EPA Contract No. 68-01-
4147,U.S.EnvironmentalProtection Agency, Washington, DC, May
1980.
3. "Chemical Engineering Plant Cost Index," Chemical Engineering,
McGraw-Hill Publications Company, New York, NY, September 21, 1981.
4. Producer Prices and Price Indexes Data, Bureau of Labor Statistics,
U.S. Department of Labor, Washington, DC
5. CARD, Inc., Capital and Operating Costs of Selected Air Pollution
Control Systems, U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina, December 1978.
3-27
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4.0 GASOLINE TANK TRUCKS
4.1 INTRODUCTION
The approach taken in the section of the Ohio RACT regulation for control
of VOC emissions from gasoline tank trucks is a tank certification
program of maintenance, monitoring, and reporting. The owner or operator
of a gasoline tank truck is required to have each tank and its vapor
collection system pass an annual leak tightness test. The regulation
requires repair and retesting of the tank if it fails to pass the
prescribed certification test for any reason. The regulation also
establishes test procedures, record-keeping, and reporting requirements
which demonstrate and document compliance.
Although the section of the regulation dealing with tank trucks is
applicable statewide, there are exemptions available which will allow
many of the state's smaller gasoline transporting vehicles to avoid
having to comply with the certification program. These exemptions are
available to vehicles which are operated in conjunction with certain
facilities with gasoline throughputs below specified maximum amounts.
The smaller tank trucks often deal only with such facilities.
Exempted from the requirments of the regulation are any tank trucks
that: (1) receive gasoline only from loading racks which do not have a
vapor balance or control system; and (2) deliver gasoline only to
stationary storage tanks not equipped with a vapor balance or control
system. In the 18 urban counties, other sections of the Ohio regulation
[3745-21-09(P), (Q), and (R)] require the installation of a vapor balance
or control system on gasoline loading racks at all terminals and at bulk
plants with an average daily throughput of 4,000 gallons or more. Vapor
balance or control systems are also required at gasoline dispensing
facilities (mainly retail gasoline stations) with an annual throughput of
240,000 gallons or more. Outside of these 18 urban counties, the
requirement for vapor balance or control systems applies only at existing
facilities having the potential to emit a total of 100 tons or more of
organic compounds per calendar year.
4-1
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4.2 CHARACTERIZATION OF AFFECTED SOURCES
The number of gasoline carrying tank trucks that are expected to be
covered by the truck tank certification program contained in the
Ohio RACT regulations was estimated by contacting representatives of
refineries, bulk gasoline terminals, bulk gasoline plants, independent
trucking companies and OEPA records and files.
From the discussions with industry representatives, it became apparent
that the vast majority of tank trucks covered by the regulation will
be associated with the operation of gasoline terminals. Typically, a
bulk terminal will receive gasoline by pipeline directly from a refinery
and will transport it by truck to a bulk plant for distribution or
directly to a large account buyer. The tank truck used for this purpose
has a capacity of between 8,000 and 9,000 gallons.
A telephone survey of terminal owners and the large trucking companies
that perform gasoline hauling for such facilities identified a total of
954 tanks which are expected to require certification. In addition
to these, there are smaller companies and independently owned tank trucks
that also provide gasoline hauling services which may be covered by the
certification regulation. An estimate of the number of these tank trucks
was prepared by the OEPA in the course of this project. The number of
regulated tank trucks was estimated to be 500.1 This estimate was
confirmed by contacting a representative of the Ohio Petroleum Marketers
Association.2
Another type of vehicle known as an account truck is commonly associated
with the operation of a bulk gasoline plant. A bulk plant normally
receives gasoline by tank truck and distributes it to smaller acount
buyers by account truck. The average capacity of such a vehicle normally
used in Ohio is 2,000 gallons. Many of these vehicles will either
qualify for exemptions as discussed in Section 4.1 or will be removed
from gasoline service. These vehicles commonly deliver fuel oil and can
avoid regulation by switching to this type of service.
4-2
-------
Only one company contacted, SOHIO, stated that they would be certifying
their account trucks for leak-tightness. Due to an unusual business
arrangement, SOHIO has 117 account trucks participating in the certifica-
tion program.3
To complete the inventory of account trucks requiring certification, an
estimate of the number of vehicles associated with bulk plants installing
vapor balance on their loading racks was made. The compliance deadline
for installing vapor collection systems on the loading racks of bulk
plants was July 1, 1981. As of this date, the OEPA records show only
seven bulk plants not owned by SOHIO as planning this type of system to
achieve compliance. Since they are covered by the RACT regulation, they
must have an average daily throughput of 4,000 gallons or more. It is
assumed that in order to be able economically to install vapor balance
systems, these bulk plants must have an average daily throughput quite a
bit higher than 4,000 gallons.
In a previous Ohio study concerning RACT regulations4, bulk plants
in Ohio were modeled in two size ranges by throughput, 2,500 and 13,000
gallons per day. It is assumed then, that these seven bulk plants are
all represented by the larger model bulk plant. Associated with the
large model plant are four account trucks per bulk plant. Using this
methodology, 28 account trucks are thus estimated to be covered by RACT
regulations. The total inventory of affected tank trucks is then 1,599;
1,454 of the 8,500 gallon average capacity and 145 of the 2,000 gallon
average capacity.
4.2.1 Development of Emission Calculation Methodology
In order to reduce VOC emissions during gasoline loading, unloading,
and transport, the affected delivery truck tanks must be vapor tight and
equipped with a vapor collection system. During unloading, the tank's
vapor collection system collects vapors displaced from storage tanks
equipped with vapor recovery systems. During tank filling, VOC vapors
are either recovered by the loading facility's vapor recovery system or
4-3
-------
enter the atmosphere. During transport, VOC emissions are dependent upon
the leak tightness of the tank and its vapor collection system.
The estimate of VOC emission reduction that will be obtained by the
implementation of Ohio's tank certification requirements was obtained by
combining estimated reductions during loading and during transit. Since
a tank may be loaded at a rack with vapor control and unloaded at a
facility without provisions for vapor control, an estimate was made of
VOC emissions that takes this into account. No estimate of emission
reduction during unloading was made since this is considered part of the
service station emissions.
Emissions during loading were taken from the background information
document for bulk terminals.5 it is assumed that loading racks at bulk
plants are identical and that therefore emission rates are identical.
It is estimated that an average of 30 percent of VOC vapors are lost
during loading without a certification program while only 10 percent
are lost during loading with a certification program. These figures
represent actual measurements and reflect the fact that a truck that
passes the certification test is not likely to remain at the prescribed
level of leak-tightness for a full year.
Estimated emissions during transport are based on information in a
California Air Resources Board (CARB) staff report.6 The estimates
assume a 2-hour round trip for delivery and are presented in Table 4-1.
Finally, the emission factors for emissions during loading were taken
from the U.S. EPA compilation of emission factors.'' This value is the
same for top or bottom loading in vapor balance service and is 8 Ib VOC
per 1000 gallons loaded. The emission rate for submerged loading without
vapor balance or control is 5 Ib VOC per 1000 gallons transferred. This
rate is also assumed to be representative of that occurring when loading
a tank using a vapor balance system that had been unloaded without the
use of a vapor balance system.
-------
TABLE 4-1
ESTIMATED VOC EMISSIONS FROM GASOLINE TANK TRUCKS
CJI
TANK CAPACITY
(gallons)
Unloading withb
Vapor Balance
8,500
2,000
Unloading without
Vapor Balance
8,500
2,000
EMISSIONS
WITH
CERTIFICATION
PROGRAM
(Ib VOC)
6.8
1.6
4.3
1.0
FROM LOADING
WITHOUT
CERTIFICATION
PROGRAM
(Ib VOC)
20.4
4.8
12.8
3.0
EMISSIONS DURING TRANSIT*
WITH
CERTIFICATION
PROGRAM
(Ib VOC)
6.22
1.47
5.21
1.23
WITHOUT
CERTIFICATION
PROGRAM
(Ib VOC)
7.21
1.70
5.83
1.37
TOTAL
WITH
CERTIFICATION
PROGRAM
(Ib VOC)
13.02
3.07
9.51
2.23
EMISSIONS
WITHOUT
CERTIFICATION
PROGRAM
(Ib VOC)
27.61
6.50
18.63
4.37
aAssumes a 2-hour round trip.
bVapor balance at the receiving facility.
-------
4.3 POTENTIAL VOC EMISSION REDUCTIONS
It is assumed in this study that any regulated tank truck will be
loaded on a loading rack equipped with a vapor balance system. The tank
may be unloaded, however, either with or without the use of a vapor
balance system. A tank truck returning to the loading rack after
unloading using vapor balance will contain a much higher concentration of
VOC vapors than one that was unloaded without vapor balance. The
VOC emissions and recovery during loading are dependent upon the
concentration of VOC vapors in the tank at the time of loading.
Since the routes and delivery practices for individual tank trucks
vary widely, emissions and reductions are calculated for a vehicle that
delivers only to facilities employing vapor balance and for a vehicle
that delivers only to facilities not employing a vapor balance system.
This represents the extremes, and all of Ohio's regulated tank trucks
should fall between them.
In order to compute the annual emissions and reductions from a tank
truck, an estimate of the average number of delivery trips must be made.
To obtain this estimate, it is assumed that all gasoline consumed in Ohio
passes through a bulk terminal in Ohio equipped with vapor balance on its
loading racks, and is delivered via 8500-gallon tank truck from the bulk
terminal to bulk plants or elsewhere. Then the total amount of gasoline
consumed divided by the capacity of the fleet of tank trucks gives an
average number of delivery trips per year per tank truck. The amount
of gasoline consumed in Ohio in 1980 was 4.983 billion gallons.8 Using
the previously determined fleet size of 1,454 tank trucks with an average
capacity of 8,500 gallons, an average of 403 delivery trips per vehicle
per year is calculated. The transportation capacity of the fleet of
2,000 gallon account trucks was not used to estimate the number delivery
trips per vehicle per year. It is assumed that only the larger tank
trucks are used in the initial distribution of gasoline and the smaller
tank trucks are involved in subsequent distribution activities. It is
assumed that this average figure of annual number of delivery trips is
representative of all gasoline delivery vehicles in Ohio regulated by
RACT.
4-6
-------
Table 4-1 presents the emissions that are estimated to occur from
the gasoline tank trucks in Ohio which are affected by the certification
program. Emission figures are developed for the two different tank sizes
for the case where the tank is unloaded with and without vapor balance.
In Table 4-2, these emission estimates are shown on an annual basis along
with the estimates of emissions reduced by the implementation of the
certification program.
In order to provide an estimate of the actual emission reduction that
will occur in Ohio as a result of the tank truck certification program,
assumptions were made concerning the useage of a vapor balance systems
when the tank trucks are unloading at the state's network of gasoline
dispensing facilities. It is assumed that 95% of the gasoline consumed
in the 18 urban counties is unloaded using a vapor balance system while
the rest of the gasoline consumed in the state is unloaded without the
use of a vapor balance system.
Using figures provided by the Ohio Department of Taxation9, 64.5 percent
of the gasoline consumed in 1979 is estimated as having been consumed in
the 18 urban counties. Assuming that this percentage is representative
of 1980, then approximately 3.053 billion gallons of gasoline was
delivered utilizing vapor balance in 1980.
Using figures shown in the preceding tables and the assumptions just
presented, Table 4-3 was developed. This table presents the estimated
VOC emission reductions that may be expected in Ohio by implementing
the tank truck certification program. The emission reductions for
individual tanks will fall in between the two extremes, depending upon
the percentage of their deliveries made to facilities without a vapor
balance system. In addition, the estimated statewide total reduction is
presented.
4.4 COST ANALYSIS AND SUMMARY
The costs of controlling VOC emissions from the affected tank trucks
consist of the cost of the certification test and the incremental cost of
4-7
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TABLE 4-2
ANNUAL ESTIMATED VOC EMISSIONS AND REDUCTIONS PER TANK
TANK CAPACITY
(gallons)
Unloading with
Vapor Balanceb
8,500
2,000
Unloading without
Vapor Balance
8,500
2,000
EMISSIONS
WITH
CERTIFICATION
PROGRAM
(Ib VOC)
13.02
3.07
9.51
2.23
PER TRIP
WITHOUT
CERTIFICATION
PROGRAM
(Ib VOC)
27.61
6.50
18.63
4.37
ANNUAL
WITH
CERTIFICATION
PROGRAM
(tons VOC)
2.62
0.62
1.92
0.45
EMISSIONS3
WITHOUT
CERTIFICATION
PROGRAM
(tons VOC)
5.56
1.31
3.75
0.88
ANNUAL EMISSIONS PREVENTED
WITH CERTIFICATION PROGRAM
(tons VOC)
2.94
0.69
1.83
0.43
aAssumes 403 round trips per year.
t>Vapor balance equipment at receiving facility.
-------
TABLE 4-3
ESTIMATED TOTAL VOC EMISSION REDUCTIONS
(TONS PER YEAR)
TANK CAPACITY
(gallons)
8,50Qb
2,000b
TOTAL
ALL TANKS
UNLOADED WITH
VAPOR BALANCE
4,275
100
4,375
ESTIMATED ACTUAL*
3,649
86
3,735
ALL TANKS
UNLOADED WITHOUT
VAPOR BALANCE
2,661
62
2,723
*This figure represents the estimated reductions based on the projected
volume of gasoline unloaded with and without the use of a vapor balance
system. The emission reduction is calculated from the following equation:
A = ac(64.5%)(95%) + bc[l-(64.5%)(95%)]
where: A = estimated actual emission reduction for each tank size;
a,b = appropriate annual emissions prevented with certification
program (tons VOC) from Table 4-2;
c = appropriate number of tank trucks (either 1454 or 145);
64.5% represents gasoline consumed in the 18 urban counties in 1979;
and
95% represents the portion of the gasoline consumed in the 18 urban
counties in 1979 that is unloaded using a vapor balance system.
4-9
-------
maintenance required to keep the tank leak-free. It is expected that
implementation of the certification requirement will increase the
frequency of maintenance on a tank to the level necessary to pass the
annual test, but will not require the implementation of an entirely new
program for tank maintenance.
Although for a tank to be covered by the certification rules it must have
a vapor balance or control system, the existence of such a system
is required by a different part of Ohio's regulations. Therefore, the
costs for providing hardware and maintenance for vapor balance or control
systems are not presented in this analysis. Similarly, the credit for
product recovery due to the operation of vapor recovery systems has been
included in the economic analysis of the regulations requiring these
systems. The certification requirement acts as insurance that the credit
will be available. Also, the product will normally be recovered by the
bulk plant or terminal owner, and this is not necessarily the owner of
the tank truck. Therefore, product recovery credits are not included in
this analysis either, although they are presented in Table 4-4. In some
cases, the value recovered will go directly to the truck owner (when
the truck owner is also the bulk terminal or bulk plant owner and
vapor recovery systems are in place). In such cases, the actual cost
effectiveness will likely be more favorable to these owners.
The estimated costs are presented below for maintaining a tank in
leak tight condition. These costs include labor and materials for
performing the required maintenance to reduce leakage to an acceptable
level and labor for performing the Ohio certification test.
LABOR LABOR3 MATERIALS TOTAL COST
(hrs) ($) [$} ($)
8 192 50 242
aLabor rate = $24 per hour.
4-10
-------
TABLE 4-4
CONTROL COST SUMMARY FOR GASOLINE TANK TRUCKS3
(DOLLARS PER TON REDUCED)
TANK CAPACITY
(gallons)
8,500
2,000
Overall Average**
Value of Product0
Recovered
UNLOADING WITH
VAPOR BALANCE
82.31
350.90
88.45
1,402
ESTIMATED
AVERAGE
96.43
408.02
103.60
1,197
UNLOADING WITHOUT
VAPOR BALANCE
132.23
565.97
142.11
872
aBased upon an annual cost per tank of $242 (total annual cost:
$386,958), 1454 large capacity tanks, 145 small capacity tanks,
and emission reductions from Table 4-3.
bBased upon all 1599 tank trucks.
cBased upon a 90% recovery of vapors and a value of $0.178 per
pound. Units are thousands of dollars.
4-11
-------
These costs are similar to those found necessary in the state of
California^ where a similar certification test requirement has been in
place for several years. The labor hours indicated have been increased
from the four hours deemed necessary in California because conversations
with firms in Ohio performing certification tests have indicated that
eight hours is the average time required. This may be due to the fact
that the Ohio firms have less experience than California firms in
performing the test and maintenance procedures. Another reason for the
difference may be that tank truck configurations differ between the
two states. The costs presented are an average and are independent of
tank capacity.
The same report10 notes that the effort required to bring a tank
to within specified limits of leak tightness can be greater than the
effort required to maintain this level of leak tightness. This would
happen if a large number of potential leak sources were found to be
leaking at the first certification test, since not every leak will
reappear at every succeeding vapor tightness test.
The certification test may be performed using equipment normally found at
the maintenance facilities of a terminal or bulk plant that owns and
maintains its own trucks. The maintenance facility may need to purchase
a manometer (approximately $50) to perform the test. For those truck
owners without maintenance facilities, the test and maintenance can be
performed by an independent tank truck maintenance facility set up to
conduct the test for a fee. One entrepreneur was found in Ohio who plans
to carry the testing and maintenance equipment in trucks and perform the
test wherever the truck owner desires.
The estimated cost effectiveness of implementing Ohio's tank truck
certification program is presented in Table 4-4. The value of the
recovered product is also shown in this table. This value is based upon
an assumed 90 percent recovery of vapors and the average wholesale price
of gasoline in Cincinnati at the end of 1980.8
4-12
-------
4.5 REFERENCES
1. Personal communication, W. Juris, OEPA to J. Formento, Dames &
Moore, May 27, 1981.
2. Personal communication, W. Host, OPMA to J. Formento, Dames & Moore,
September 8, 1981.
3. Personal communication, P. Kiraly, SOHIO to J. Formento, Dames &
Moore, September 3, 1981.
4. Economic Impact of Implementing RACT Guidelines in the State of
Ohio, 1978. EPA 905/5-78-003. U.S. EPA Region V, Chicago,
Illinois.
5. Bulk Gasoline Terminals - Background Information for Proposed
Standards. 1980. EPA-450/3-80-038a. U.S. EPA, Research
Triangle Park, North Carolina.
6. Staff Report 77-5-1. March 15, 1977, California Air Resources
Board, Sacramento, California.
7. Compilation of Air Pollutant Emission Factors. 1977. AP-42,
Third Edition. U.S. EPA, Research Triangle Park, North Carolina.
8. National Petroleum News, June 1981, McGraw-Hill Book Company, New
York, New York.
9. Personal communication, W. Juris, OEPA to J. Formento, Dames &
Moore, September 2, 1981.
10. Evaluation of Vapor Leaks and Development of Monitoring Procedures
for Gasoline Tank Trucks and Vapor Piping. 1979. EPA-450/
3-79-018. U.S. EPA, Research Triangle Park, North Carolina.
4-13
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5.0 SYNTHESIZED PHARMACEUTICAL MANUFACTURING
5.1 Introduction
The pharmaceutical manufacturing industry encompasses the manufacture,
purification, and packaging of medicinal chemical materials. Production
activities of this industry can be grouped into the following
categories:
Chemical synthesis - The manufacture of pharmaceutical products by
chemical synthesis.
Fermentation - The production and separation of medicinal chemicals
such as antibiotics and vitamins from microorganisms.
V.
Extraction - The manufacture of botanical and biological products
by the extraction of organic chemicals from vegetative materials or
animal tissues.
Formulation and packaging - The formulation of bulk Pharmaceuticals
into various dosage forms such as tablets, capsules, injectable
solutions, ointments, etc., that can be taken by the patient im-
mediately and in accurate amount.
The Ohio EPA regulation on the control of VOC emissions from synthe-
sized pharmaceutical manufacturing covers only one of the production
activities indicated above—chemical synthesis.1 Other production
activities (fermentation, extraction, and formulation and packaging) are
not affected by this regulation. Therefore, any further reference to
synthesized pharmaceutical manufacturing in this analysis will mean
essentially the chemical synthesis part of synthesized pharmaceutical
manufacturing.
Production of a chemically synthesized pharmaceutical product mainly
consists of one or more chemical reactions followed by a series of
purifying operations. Production lines may contain reactors, filters,
5-1
-------
centrifuges, stills, dryers, process tanks, and crystallizers piped
together in a specific arrangement. One or several pieces of this
process equipment can be used in a plant, depending upon its size.
Figure 5-1 gives the flow diagram for a typical batch synthesis opera-
tion in a synthesized pharmaceutical manufacturing plant. Solid re-
actants and solvents are charged to a batch reactor, which is usually
equipped with a condenser. However, some volatile compounds may still
be produced as a product or by-product. Any remaining unreacted VOC
(solvents) is distilled off. When the reaction and solvent removal are
complete, the product is transferred to a holding tank, in which it
undergoes three to four washes of either water or solvent to remove any
remaining reactants and by-products. The wash solvent may also be
evaporated from the reaction product. The crude product may then be
dissolved in another solvent and transferred to a crystallizer for puri-
fication. After crystallization, the solid material is centrifuged from
the remaining solvent. In the centrifuge, the product cake may be
washed several times with water or solvent. Tray, rotary, or fluid-bed
dryers may then be used for final product finishing.
Each operation of the chemical synthesis process may be a source of VOC
emissions. Because of the wide variation in the operations, manu-
facturing equipment and the size of operation, typical emission rates
cannot be established. But the Control Technique Guideline (CTG) docu-
ment published by the U.S. EPA3 gives the following equipment types as
the major sources of VOC emissions: (a) dryers, (b) reactors, (c)
distillation units, (d) storage and transfer, (e) filters, (f)
extractors, (g) centrifuges, and (h) crystal!izers.
The Ohio EPA regulation on the control of VOC emissions from synthesized
pharmaceutical manufacturing specifies controls for all the major
sources of VOC emissions. It requires that the discharge of VOC emis-
sions into the ambient air from any reactor, distillation operation,
crystallizer, centrifuge or vacuum dryer should be controlled to a
concentration of fifty thousand parts or below by using a surface con-
denser or any other equally effective control device. VOC emissions
5-2
-------
So
in
co
Ive
i
io
il
1 i
has
V.
.-nt
J
Reactor
1
Ver
t
)>
I
Holding
Tank
it
i
-&•
Solvent
Distillation
Me
i^-
fit
H2O
Solvent Vent
Solvent Solvent
Receiver 1
Crystallize
_^
Typical Cycle 1/24 hours
\
(
i
Batch
Centrifuge
i
Vent
< .
Dryer
H2O
Solvent
Product
FIGURE 5-1 TYPICAL SYNTHETIC ORGANIC MEDICINAL CHEMICAL PROCESS
> » •
SOURCE: Reference 2
-------
from any air dryer or a production equipment exhaust system is not to
exceed 33 pounds in any one day, unless the emissions have been reduced
by at least 90 percent. Similarly, any centrifuge, rotary vacuum fil-
ter, or any other filter having an exposed VOC liquid surface should be
enclosed if the VOC liquid has a vapor pressure greater than 0.5 psia at
68°F. Finally, any leak of volatile organic liquid should be repaired
as soon as possible.
With regard to storage tanks holding VOC liquids with vapor pressure
greater than 1.5 psia at 68°F, the regulation requires the use of a
conservation vent or any other equally effective device. For the trans-
fer of VOC liquids with vapor pressure greater than 4.1 psia at 68°F
from storage tanks with storage capacity greater than 2,000 gallons, a
vapor balance or a vapor control system should be used to control at
least 90 percent of the VOC emissions. Finally, a cover should be
provided for all in-process storage tanks which contain an organic
compound liquid. This cover should be kept closed except when produc-
tion sampling, maintenance, or inspection procedures require access to
the tank.
5.2 Inventory of Affected Facilities
The number of facilities affected by the regulation were identified by
reviewing the list of Ohio pharmaceutical manufacturers provided by the
Ohio EPA and the information given in an EPA report2 on the operating
synthetic pharmaceutical plants in the United States. This review
resulted in a list of 16 plants that could be potentially engaged in
pharmaceutical manufacturing. However, personal contact with each of
these plants indicated that only 2 of these 16 plants were actually
involved in the manufacturing of synthesized pharmaceutical products;
the other plants were engaged mainly in formulation and packaging opera-
tions, which are not covered under the regulation. The inventory data on
the two affected plants in Ohio are given in Table 5-1. This informa-
tion was collected during the visits to these plants by ETA engineers.
As the table indicates, total VOC emissions from uncontrolled sources in
5-4
-------
TABLE 5-1. OPERATING AND EMISSION DATA FOR AFFECTED
SYNTHESIZED PHARMACEUTICAL MANUFACTURING PLANTS IN OHIO
Plant
1
Uncontrolled
Source
Vacuum jets
Number of
Units
2
Rated
Capacity
1,700 IDS
Hours of
Operation
(hr/yr)
4,800
Total VOC
Emissions
(tons/yr)
9.7
connected to
receivers
Reactors
750 Ibs
4,800
11.0
2 Reactors
Centrifuge
Vacuum Dryer
Filters (with
2
2
2
8
20-300 gals
50-100 gals
132 Ibs
5 gals
3,000
50
1,600
200
0.07
0.13
0.09
0.11
Total
exposed organic
liquid surfaces)
21.1
5-5
-------
these plants are 21.1 tons/year. Most of the emissions are, however,
from one plant (20.7 tons/yr). The contribution from the other plant is
0.4 tons/yr.
5.3 Alternative VOC Control Measures
Control techniques that can potentially be used to control VOC emissions
from sources at synthesized pharmaceutical manufacturing plants include
condensers, scrubbers, carbon adsorption systems, incinerators, or a
combination of controls. The following paragraphs briefly describe
these controls.
5.3.1 Condensers
Condensers are widely used to recover solvents from reactors, distilla-
tion units, extractors, separators, and dryers. Surface condensers are
the most prevalent form of control for reactor emissions. In this type
of condenser, heat is transferred across a tube wall that separates the
vapor and coolant. The coolant is not contaminated with the condensed
VOC and, therefore, it may be directly reused. The type of coolant
depends on the degree of cooling required and is usually either water or
brine. The use of a brine-cooled condenser can usually provide a reduc-
tion of approximately 90 percent in VOC emissions.3
Condensers are an attractive control option, if the solvent vapor con-
centration is high. However, when the gas stream is dilute or far from
saturation, considerable cooling is required to condense the VOC. In
such cases, condensers may not be a cost-effective option.
5.3.2 Scrubbers
Scrubbers can be applied to reduce emissions from reactors, distillation
equipment, centrifuges, filters, crystal!izers and dryers. These are
designed to provide intimate contact between the scrubbing liquid and
the gaseous pollutant, which promotes mass transfer between the phases.
The liquid absorbs the gas because of the preferential solubility of the
gas or gases in the liquid.
5-6
-------
Scrubbers can be of the venturi, packed tower, plate or tray tower, and
spray tower types. The VOC concentration in a scrubber exhaust is
related to the equilibrium partial pressure of the pollutant(s) in the
scrubbing medium. For a given unit, overall scrubbing efficiencies are
influenced by intimacy of contact between gas and liquid, operating
temperature, concentration of the pollutant in the liquid scrubbing
medium, and gas and liquid flow rates.
5.3.3 Carbon Adsorbers
Carbon adsorption has been found effective in controlling VOC emissions
because many organics are easily adsorbed onto activated carbon. This
control technique is particularly effective in controlling gas streams
with low VOC concentrations.
The efficiency of adsorption (or removal) on a carbon bed depends on the
type of activated carbon used, the VOC characteristics, the VOC concen-
tration, and the temperature, pressure and humidity of the system.
Although the overall VOC removal efficiency depends on the system
design, units can be designed and operated at removal efficiencies well
over 90 percent.2
5.3.4 Incinerators
Both thermal and catalytic incinerators can be used to control VOC
emissions by oxidizing these to form carbon dioxide and water. However,
incinerators are not widely used to control VOC emissions from synthe-
sized dry production, mainly because of high operating costs, vari-
ability of waste gases that would be directed to an incinerator, and the
intermittent (batch) type of operations used. Fluctuating flows and VOC
concentrations may hamper efficient operation.
5.3.5 Applicability of Alternative VOC Emission Control Techniques
to Affected Plants
Applicability of alternative control measures to uncontrolled sources in
the affected plants was determined in consultation with the affected
plants. VOC emissions from a vacuum jet (connected to receivers) in one
5-7
-------
of the affected plants would be controlled by replacing the present
vacuum jet by a new wet ring vacuum pump. VOC emissions from the two
uncontrolled reactors in this plant would be controlled by installing a
pipe condenser. The planned control strategy for the other plant is to
duct VOC emissions from all the uncontrolled affected sources to a
single carbon adsorber. The anticipated VOC emission reductions based
on the application of the above discussed control techniques are pre-
sented in Table 5-2.
5.4 Cost Analysis
Estimation of the control costs to comply with the regulation on
synthesized pharmaceutical manufacturing was based on the cost data
provided by the affected plants. The annualized costs were derived by
adding fixed capital charges to the annual operating and maintenance
costs. Fixed capital charges include a capital recovery factor of 14.7
percent (15 year equipment life, 12 percent interest rate) for depreci-
ation and interest charges and a factor for insurance taxes and admini-
strative overheads (4 percent of the installed capital costs). The
capital and annualized costs of compliance are presented in Table 5-3.
The total capital costs are estimated to be approximately $84,000. The
corresponding annualized costs are about $28,000. The overall cost-
effectiveness of control is $1,403 per ton of reduction in VOC emis-
sions. As is evident from the table, the cost-effectiveness value for
one of the affected plants is extremely high ($55,500/ton of reduction)
because of the low anticipated reduction in VOC emissions. The cost-
effectiveness of control for the other affected plant is $305 per ton of
reduction in emissions.
5-8
-------
en
i
TABLE 5-2. ESTIMATES OF EMISSION REDUCTIONS FROM
AFFECTED PHARMACEUTICAL PLANTS IN OHIO
Plant
1
2
Uncontrolled
Source
Vacuum jet
connected to
receivers
Reactors
Reactors
Centrifuges
Vacuum Dryer
Ml 1" OK*C
1 Lc I 5>
Uncontrolled
VOC Emissions
(tons/yr)
9.7
11.0
0.4
21.1
Control
Efficiency
Anticipated Control Technique (%)
Replacement of present vacuum 95
jet by a new wet ring vacuum
pump
Pipe condenser 95
Carbon adsorber 95
Potential
VOC Emission
Reductions
(tons/yr)
9.2
10.5
0.4
20.1
-------
TABLE 5-3. CONTROL COST ESTIMATES FOR AFFECTED SYNTHESIZED
PHARMACEUTICAL MANUFACTURING PLANTS IN OHIO
en
t—"
O
Uncontrolled
Plant Source
1 Vacuum Jet
Reactors
2 Reactors
Centrifuges
Vacuum Dryer
Filters
Control Technique
Replacement of present
vacuum jet by a new wet
ring vacuum pump
Pipe Condensers
Carbon Adsorber
Control Costs (x 103 $)
Capital Annual i zed
17.0 4.4
1.6 1.6
65.0 22.2
83.6 28.2
VOC
Emission
Reduction
(tons/yr)
9.2
10.5
0.4
20.1
Cost-
Effectiveness
($/ton)
478
152
55,500
1,403
Annualized costs include the annual operating and maintenance costs and fixed capital charges for depreciation,
interest, insurance, taxes and administrative overheads.
-------
5.5 References
1. Personal communication with Mr. Bill Juris of Ohio EPA, October
1981.
2. PEDCo Environmental, Enforceability Aspects of RACT for the Chemi-
cal Synthesis Pharmaceutical Industry Preliminary Draft, prepared
for U.S. Environmental Protection Agency, Washington, D.C., October
1980.
3. Control of Volatile Organic Emissions from Manufacture of Synthe-
sized Pharmaceutical Products!EPA-450/2-78-029,December 1978.
5-11
-------
6.0 RUBBER TIRE MANUFACTURING
6.1 Introduction
Rubber tire manufacturing consists of the production of component parts,
their assembly into a raw "green" tire, and the curing and finishing
required to yield a complete tire. Several types of rubber tires are
mass produced. These include agricultural vehicle tires, airplane
tires, industrial vehicle tires, mobile home tires, truck tires, and
automobile tires.
A generalized tire manufacturing process consists of four steps: (a)
preparation and compounding of raw materials, (b) transformation of the
raw materials into tire components, (c) tire component assembly, and (d)
molding. Thes step? are shown in more detail in Figure 6-1.
The preparation and compounding of raw material involves combining raw
crumb rubber with a variety of fillers, extenders, accelerators, anti-
oxidants, carbon black, and oil in internal mixing devices. After
mixing, the rubber is transferred to roll mills and formed into sheets.
The sheeted rubber is then fed manually to a warmup roller mill where it
is made more flexible for further processing. From the warmup mill, the
heated rubber passes to a strip-feed mill for final mixing.
After preparation and compounding, the rubber stock is transformed into
components from which the tire is built—tire tread and sidewalls, tire
cords, tire belts, and tire beads. These are constructed by using
rubber stock and other raw materials, including cord and fabric. A
detailed description of their formation process is given in two U.S. EPA
documents.1'2
The tire components are assembled either by conventional tire building
technique or by emerging technologies such as the Orbitread Process or
Rotomolding. In the conventional tire building technique, the tires are
6-1
-------
COtlPOUNDER
HATIHIAL
nuuoEH
SYHTIIETICj
cr>
(SJ
V/IIIE
COMPLETED
TIKE
fillEfN Tint
SI'UAY
Figure 6-1. Tire Manufacturing Flow Diagram
TREAD I NO
CIMCNUNC.
CAHOOM OLACK,
OH.S. SULFUn.O.
ACCCLEIUTOII
COOLING
CONVEYOflS
IINI)CIUIIfAI>
QHtNlINd .
MIXED WAdM-UP MILLS
MILL COMPOUND .
COATED CORO STOCK CUTTING
COATING AND
rOHMINO
TlttE FINISMINO
. AND
. INSPECTION
Tine curiiNO
TIHE ASSEMOI.Y
OHEEN .Tine
-------
fabricated as cylinders on a collapsible, rotating drum. First the
inner lines, which make the finished tire airtight, are wrapped around
the drum, followed by the required layers of rubber impregnated fabric.
Next, the edges of the fabric and inner lines are wrapped around the
bead assemblies. This step is followed by a manual or automatic rolling
operation wherein pressure is applied from the tread centerline out to
the beads in order to expel air trapped between the assembled
components. Belts made of fabric, steel, or glass fiber are then laid
onto the cord. Finally, the tread and sidewalls are wrapped around the
assembled components and stitched to form an uncured "green" tire.
In the final step (before molding), the green tire is sprayed on the
inside with band-ply lubricants and on the outside with mold release
agents. Band-ply lubricants 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.
After this spraying, the tires are molded and cured in automatic
presses.
Table 1-1 lists rubber tire manufacturing operations that are sources of
VOC. The Table also gives the type of material emitted and the relative
contribution of various sources to the overall VOC emissions at a rubber
tire manufacturing plant.
The Ohio EPA regulation [Rule 3745-21-09(X)] to control volatile organic
compound (VOC) emissions from rubber tire manufacturing exempts the
following types of operations: (a) any operation with a maximum VOC
discharge of 100 pounds per day or less into the ambient air, (b) any
tread-end cementing operation in which the cement is manually applied
with a brush, (c) any green tire spraying operation in which the VOC
content of the material sprayed is a maximum daily weighted average of
six percent or less by weight for material sprayed on the inside of a
tire and eleven percent or less by weight for material sprayed on the
outside of the tire, and (d) the manufacture of tires with a bead
diameter in excess of 20 inches and a cross-sectional dimension greater
than 12.8 inches.
6-3
-------
TABLE 6-1. TIRE MANUFACTURING VOLATILE ORGANIC COMPOUNDS
SOURCES AND EMISSIONS
Operation
Green Tire Spraying
(inside)
(outside)
Undertread Cementing
Tire Building
Sidewall Cementing
Tread End Cementing
Bead Dipping
Finishing
Curing
Compounding
Milling
Extrusion
Calendering
Latex Dipping
Source
Spray
Cement
Solvent
Cement
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
44.8
(17.1)
(27.7)
25.0
11.9
6.1
5.4
3.0
2.1
0.7
0.4
0.2
0.2
0.2
Excluding latex dipping operation.
Source: Reference 2.
6-4
-------
The regulation requires that VOC emissions from each undertread cement-
ing, tread-end cementing, and bead dipping operation be controlled by at
least 76.5 percent (85 percent capture and 90 percent control effici-
ency). Similarly, VOC emissions from a green tire spraying system
should be controlled by at least 81 percent by weight based on at least
90 percent capture efficiency and at least 90 percent control efficien-
cy.
6.2 Inventory of Affected Sources
The affected rubber tire manufacturing plants were identified through
inventory information provided by the Ohio EPA, information provided in
a U.S. EPA report,2 and personal communication with rubber tire manu-
facturing plants in Ohio. A preliminary list of nine potentially
affected rubber tire manufacturing plants was prepared by reviewing the
information provided by the Ohio EPA and the U.S. EPA document. These
plants were (1) Firestone Tire and Rubber, Akron; (2) Dayton Tire and
Rubber, Barberton; (3) Goodyear Tire and Rubber, Akron; (4) Dayton Tire
and Rubber, Dayton; (5) General Tire and Rubber Company, Bryan; (6)
Cooper Tire and Rubber Company, Findlay; (7) Denman Rubber Manufacturing
Company, Warren; (8) General Tire and Rubber Company, Akron; and (9) B.
F. Goodrich Company, Akron. The list of potentially affected plants was
then verified by contacting the individual plants.
This plant investigation revealed that Firestone originally had two tire
manufacturing facilities in Akron. One of these facilities has been
closed and demolished, however, and the other performs only mixing and
compounding operations.3 This plant is therefore not affected by the
regulation on rubber tire manufacturing. Similarly, Dayton Tire and
Rubber had two facilities in Ohio manufacturing tires—one in Barberton
and the other in Akron, but both of these facilities have been shut
down.4 The General plant in Bryan produces only large off-the-road
tires (heavy construction tires, for example) and therefore is not
affected by the regulation based on size criterion.5 Similarly, the
Goodyear plant in Akron manufactures only race car tires and is not
affected by the regulation.6
6-5
-------
The Ohio EPA adopted regulation therefore affects only four rubber tire
manufacturing plants in Ohio, two plants in Summit County, and one each
in Hancock and Trumbull counties. The location and the tire production
capacities for these plants are presented in Table 6-2. The production
data were taken from the publication Modern Tire Dealer7 and are for
January 1981.
As Table 6-2 shows, the individual plant tire production capacities
range from 700 to 14,500 tires per day (tpd), with an average rate of
7,025 tpd. Two of the plants manufacture automobile tires, and their
production rates range from 200 to 10,000 tpd. The other tires produced
are principally truck tires, although one plant manufactures airplane
tires. The production rates for all other tires range from 700 to 8,500
tpd, the average being 4,475 tires per day per plant.
The affected plants were contacted to procure plant-specific data on
their sources of VOC emissions, present VOC emission levels, exhaust gas
flow rates, and VOC concentration in the exhaust gases. Other plant-
specific data obtained included hours of operation, present emission
controls, and additional controls required to comply with the adopted
regulation.8-11 Plant contacts indicated that only two of the four
affected plants use undertread cementing and bead dipping operations.
One of these plants reports zero VOC emissions from both processes due
to mechanical design. All of the affected plants perform the tread-end
cementing operation manually, so this operation is exempt from the
regulation. Green tire spraying is also done at all the affected
plants, using a water-base release agent on one side of a tire and a
solvent-base release agent on the other side. Ultimately, all four
plants will be switched to water-base release agents for both sides--
inside and out.8-11 Table 6-3 presents the total number of operations
in the affected plants that require additional controls for compliance
with the adopted regulation. The table also presents the uncontrolled
VOC emissions from these operations, which were calculated based on
actual solvent usage for various operations in the affected plants. A
total of 17 operations in the affected tire manufacturing plants emit-
6-6
-------
TABLE 6-2. AFFECTED PLANTS AND THEIR TIRE PRODUCTION CAPACITY3
Facility
Cooper Tire
& Rubber Co.
Denman Rubber
Manufacturing
Company
General Tire
& Rubber Co.
B.F. Goodrich
Company
City
Find! ay
Warren
Akron
Akron
Passenger Other
Tires Per Tires Per
County Day Day
Hancock 10,000 4,500
Trumbull 200 4,200
Summit - 8,500
Summit - 700
Total
Tires Per
Day
14,500
4,400
8,500
700
Tire production capacities based on information in Reference 7.
Other tires include truck tires and airplane tires.
6-7
-------
TABLE 6-3. OPERATIONS IN AFFECTED TIRE MANUFACTURING PLANTS
REQUIRING ADDITIONAL CONTROLS
Operation
Undertread Cementers
Bead Dippers
Green Tire Spraying
Total3
.Number of Operations
Requiring Control
2
1
14
17
VOC Emissionsb
(tons/year)
66
30
766
862
Represents total number of operations in 4 affected plants that need
additional controls to comply with the regulation.
Estimated based on emission data provided by the affected plants.
6-8
-------
ting 862 tons per year of VOC would require additional controls to
comply with the Ohio EPA adopted regulation. It may be noted that all
the undertread cementing and bead dipping operations requiring controls
are at one rubber manufacturing plant.
6.3 Alternative VOC Control Measures
Alternative VOC control measures available to the tire manufacturing
industry include add-on controls (incineration and vapor adsorption) and
the use of rubber cements and solvents with low VOC contents. The
applicability of these control measures to various affected tire manu-
facturing operations is presented in Table 6-4. The control options
listed in the table are briefly described in the following subsections.
6.3.1 Incineration
Both thermal incinerators and catalytic incinerators can be used for the
control of VOC emissions in the tire manufacturing industry. The
efficiency of an incinerator depends on the types of VOCs to be
incinerated and on such factors as temperature, residence time, mixing,
inlet concentration, and flow patterns. Incineration temperatures for a
thermal incinerator range from 880°F to 1800°F, and those for catalytic
incinerators range from 400°F to 1200°F. The control efficiency is
between 81 and 96 percent for a catalytic incinerator and can be above
98 percent for a thermal incinerator.2 Usually, catalytic incinerators
consume 40 to 60 percent less fuel than thermal incinerators, since the
catalyst requires lower temperatures to bring the vapor and fuel mixture
to its ignition point.
One of the main disadvantages associated with the use of incinerators is
the consumption of fuel when no VOCs are present. Incinerators require
continuous fuel burning, even though VOCs may not always be present in
the exhaust stream. For example, when a source such as an undertread
cementer is not operation, reduced solvent evaporation results. There-
fore, with an incinerator as the control option, additional fuel is
needed during periods of low solvent evaporation as gas streams with
minimal VOC content continue to be incinerated.
6-9
-------
TABLE 6-4. CONTROL TECHNOLOGY OPTIONS FOR RELEVANT TIRE
MANUFACTURING OPERATIONS
Operation
Capture
Efficiency
(wt%)
Control
Efficiency
(wt%)
Overall
Efficiency
(wt%)
Control Technique
Options
Undertread
Cementing
Bead Dipping
Green Tire
Spraying
85
85
90
90
90
90
Process Modification
76.5
76.5
81.0
Carbon Adsorption
Thermal Incineration
Catalytic Incineration
Carbon Adsorption
Thermal Incineration
Catalytic Incineration
Carbon Adsorption
Thermal Incineration
Catalytic Incineration
Low Solvent Spray3
VOC content:
Inside spray, 6% or less
Outside spray, 11% or less
6-10
-------
6.3.2 Carbon Adsorption
Carbon adsorption, an alternative to incineration, reduces VOC emissions
by collecting organic vapors on the external surface of activated carbon
adsorbent. The control efficiencies are reported to be around 95
percent,2 although humidity can adversely affect carbon adsorption
collection efficiency when the moisture content of the exhaust stream
exceeds 50 percent. Carbon adsorbers are capable of effectively treat-
ing low organic vapor concentrations, and typical design flow rates
range from less than 100 scfm to 80,000 scfm,* which covers exhaust flow
rates from the tire industry (210 scfm to 62,000 scfm/unit).2
Carbon adsorbers have an advantage over incinerators, since they can
remove low VOC concentrations (less than 100 ppm) from exhaust streams,
even in the presence of water. However, several disadvantages are also
associated with the use of carbon adsorbers. Any particulate matter in
the exhaust stream may plug the carbon beds, lowering their VOC collec-
tion efficiencies. Also, the required depth of a carbon bed increases
with the number of compounds in the exhaust stream. Further, VOCs are
adsorbed in an inverse relation to compound volatilities, with highly
volatile compounds 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 operation.
6.3.3 Application of Low VOC Content Compounds
One alternative to the use of add-on control devices for the reduction
of VOC emissions in tire manufacturing operations is the use of rubber
cements and solvents with low VOC content. At the present time,
however, green tire spraying is the only operation in the tire
manufacturing industry for which low VOC materials are well developed,
i.e., water-base solvents for inside and outside green tire spraying,
6.3.4 Application of VOC Control Technology to Tire Manufacturing
Operations
As shown in the foregoing discussion, the tire manufacturing operations
in Ohio that require additional control to comply with Ohio EPA
*Standard cubic feet per minute.
6-11
-------
regulation include some undercementing and bead dipping operations, and
several green tire spraying operations (see Table 6-3). All the tread-
end cementing operations are done manually and are thus exempted from
the control requirements of the regulation. The selection of the most
appropriate control technologies for various affected operations was
based on engineering judgement and discussions with the affected
facilities.
For undertread cementing and bead dipping operations, an add-on control
device is expected to be the most appropriate, since low VOC materials
for these operations are not yet available. Based on preliminary
discussions with the affected plant, a carbon adsorber was assumed to be
the preferred add-on control device. For green tire spraying opera-
tions, both add-on controls and low solvent materials can be used to
reduce VOC emissions. All the affected plants favored the use of water-
base (low VOC) release agents as a method for VOC reduction.
The potential VOC emission reductions available from the application of
alternative control measures are presented in Table 6-5. The control
efficiencies of various control options were derived from the provisions
of the regulation. For example, the overall control efficiency of an
add-on control device was assumed to be 81 percent based on 90 percent
capture and 90 percent control, as required under the regulation. The
control efficiency for the application of water-base release agents in
green tire spraying was based on (1) the solvent contents specified in
the regulation and (2) the assumption that the present solvent-based
release agent is 100 percent VOC. Based on the use of water-base
release agents in green tire spraying and add-on control devices for
other operations, the potential VOC emission reductions from the tire
manufacturing industry in Ohio is estimated to be approximately 775
tons/year. If add-on control devices are used for all the affected
operations, the potential VOC emission reduction would be approximately
694 tons/year, as shown in Table 6-5.
6-12
-------
TABLE 6-5. ESTIMATE OF POTENTIAL VOC EMISSION REDUCTION FROM TIRE MANUFACTURING INDUSTRY IN OHIO
Tire Building Operation
Green Tire Spraying
Undertread Cementing
Bead Dipping
»
Total A
Total B
CTi
t— •
CO
Uncontrolled
VOC
Emissions
(tons/yr)
766
66
30
862
862
Control Technique
Control device
Low solvent agent
Control device
Control device
Control devices
Low-solvent &
control devices
Reduction3
% t/yr
81.0 620
91. 5C 701
76.5 51
76.5 23
694
775
Controlled
Emission
Level (t/yr)
146
65
15
7
168
87
Percent reduction derived from the adopted regulation.
Control device is a carbon adsorber, thermal incinerator, or a catalytic incinerator.
°This control efficiency based on the average non-solvent concentration between inside and outside sprays.
I1-.06) * (l-.ll) =>gi5
-------
6.4 Cost Analysis
The costs of controlling VOC emissions from the affected tire manufac-
turing operations were estimated by reviewing the operational data for
the individual operations. Since all the affected undertread cementing
and bead dipping operations were in one tire manufacturing plant, it was
assumed that the emissions from all the sources would be combined and
ducted to one control device. Based on discussions with this affected
plant, the exhaust air flow rate for all the affected undertread cement-
ing and bead dipping operations was estimated to be 36,500 acfm.* Only
add-on controls were considered in the compliance cost analysis for
undertread cementing and bead dipping operations. This is because low
solvent content materials for these applications are not commercially
available at the present time.
With regard to green tire spraying operations, all affected facilities
are planning on or are in the process of converting their solvent-based
spraying booths to water-base sprays. From discussions with one of the
affected plants, two sets of costs were estimated for switching to
water-base sprays. One set of cost estimates was based on minor equip-
ment changes in existing spray booths to use water-base release agents.
The other set of cost estimates was based on the installation of a new,
larger oven conveyor system to increase the residence time of the
product sprayed with water-base agents. This modification would provide
the required additional drying time without slowing down production.
The cost estimates provided by two of the affected plants for the two
alternative process changes noted above were extrapolated to represent
the cost impact on all the affected green tire spraying operations in
the industry.
The costs of applying add-on control devices to green tire spraying
operations were also estimated so as to reflect the relative cost
impacts of applying different control options. To estimate the capital
and operating costs of applying add-on controls to green tire spraying
*Actual cubic feet per minute.
6-14
-------
operations, the actual exhaust gas flow rates for affected green tire
spraying operations were used in coordination with cost data in a U.S.
EPA cost manual.12 Further, it was assumed that a single control device
would be used in each of the affected plants. This would mean ducting
exhaust gases from all green tire spray booths in each plant by a single
control.
Similarly, for undertread cementing and bead dipping operations, the
costs of applying various add-on control devices were based on the
actual exhaust gases from the affected operations and cost data in the
EPA cost manual (Ref. 12). All the costs were updated to June 1981
dollars. Table 6-6 summarizes the capital costs, the annualized costs,
and the cost-effectiveness of applying various control measures to
affected operations in tire manufacturing facilities. As indicated in
the table, the costs of VOC control from one affected bead dipping
operation is included in those for undertread cementing. Since all
these affected operations are at one facility, they can be assumed to be
ducted to one single control device.
Table 6-7 presents an estimate of the total anticipated compl/tence costs
for the tire manufacturing industry in Ohio based on the preferred
control technologies for affected operations. Use of a water-based
release agent was judged to be the most preferred control measure for
green tire spraying. A carbon adsorber was used as the control measure
for controlling VOC emissions from undertread cementing and bead dip-
ping. Based on the use of these control technologies, the total compli-
ance captial costs were estimated to be $1,014,000. The corresponding
annualized costs were estimated to be $276,000. The overall cost-
effectiveness of control was determined to be $356 per ton of reduction
in VOC emissions.
6-15
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TABLE 6-6. COST ESTIMATES OF APPLYING DIFFERENT CONTROL OPTIONS TO AFFECTED TIRE MANUFACTURING OPERATIONS
a
CTi
I—'
CTl
Annuali zed Costs
Operation and
Control Options
Undertread Cementing6
- Thermal Incinerators .
- Catalytic Incinerators
- Carbon Adsorbers9
Bead Dipping
Green Tire Spraying
- Switch to Water-Base
Sprays f
- Thermal Incinerators .
- Catalytic Incinerators
- Carbon Adsorbers9 •
Number of Capital Operational &
Affected Costs Capital. Maintenance
Operations (x!03$) Charges0 Costsc
2
350
635
246
K
1 "
14
•
135-1, 4001
1,104
2,004
776
76
138
53
*
29-3041
240
435
168
18
32
7
55
100
123
(Xl03$)
Energy
Costs0
150
(10)
63
442
(30)
186
VOC
Emission
Reductions
Total (tons/yr)
244
160
109
•
29-3041
737
505
231
74
74
74
701
620
620
620
Cost-
Effectiveness
($/ton)
3,297
2,162
1,473
41-434
1,189
814
373
The costs are in June 1981 dollars.
Capital charge factor of 21.7 percent Includes 17.7 percent for depreciation and interest
(12 percent borrowing rate, 10 years equipment life) and 4 percent for taxes, insurance and
administration.
cAssumed to be 5 percent of the capital costs.
Natural gas assumed at @ $2.0/mcf.
-------
TABLE 6-6 (continued)
eCombined and ducted to a single control device.
35 percent heat recovery Included.
9Cost estimate includes fuel credit for recovered solvent. Toluene assumed with credit
at $0.94 per gallon. Derived from regional price of No. 2 distillate fuel oil (Bureau
of Labor Statistics).
Costs are included in figures for undertread cementers.
The lower value corresponds to minor modification in existing spray booths and upper value
is based on the installation of new larger conveyor lines In the ovens.
JThe incremental 0 & tfl and energy costs were assumed to be negligible.
CTl
I
-------
TABLE 6-7. ANTICIPATED COMPLIANCE COSTS FOR THE TIRE MANUFACTURING INDUSTRY IN OHIO
I
t—'
00
Operation and
Anticipated Control Option
Undertread Cementing
- Carbon Adsorber
Bead Dipping
- Carbon Adsorbers
Green Tire Spraying
- Switch to Water-Based Materials
Capital
Costs
(x!03$)
246
a
768b
Annual i zed
Costs
(x!03$)
109
a
167
VOC Emission
Reductions
(tons/yr)
74
a
701
Cost-
Effectiveness
($/ton)
1473
a
238
JCost included under undertread cementing, since bead dipper and undertread cementing
operations are ducted to the same control device.
3Based on the average of the cost range presented in Table 6-6.
-------
6.5 References
1. "Control of Volatile Organic Emissions from Manufacture of
Pneumatic Rubber Tires," EPA-450/2-78-030, U.S. EPA, Research
Triangle Park, North Carolina, December 1978.
2. "Rubber Tire Manufacturing Industry—Background Information for
Proposed Standards," Preliminary Draft, U.S. EPA, Research Triangle
Park, North Carolina, November, 1980.
3. Personal communication with Robert Walter, Firestone, October 1,
1981.
4. Personal communication with Carl Schaeffer, Dayton Tire & Rubber,
October 1, 1981.
5. Dames and Moore, personal communication with Mr. Townhill, General
Tire, Akron, Ohio, May 6, 1981.
6. Dames and Moore, personal communication with Mr. Standke, Goodyear,
Akron, Ohio, May 1, 1981.
7. Modern Tire Dealer.
8. Personal correspondence with Dave Pinney of Denman Rubber Manufac-
turing, Company, Warren, Ohio, July 1981.
9. Personal correspondence with Ronald Clark of B. F. Goodrich, Akron,
Ohio, July 1981.
10. Personal communication with Bill Zimmerman of Cooper Tire, Findlay,
Ohio, July 1981.
11. Personal correspondence with Fred Troppe of General Tire, Inc.,
Akron, Ohio, August 1981.
12. "Capital and Operating Costs of Selected Air Pollution Control
Systems," EPA-450/5-80-002, U.S. EPA, Research Triangle Park, North
Carolina, December 1978.
6-19
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7.0 FLEXOGRAPHIC, PACKAGING ROTOGRAVURE, AND
PUBLICATION ROTOGRAVURE PRINTING LINES
7.1 INTRODUCTION
Flexography is a form of letterpress that incorporates an image carrier
made of rubber and other elastomeric materials rather than metal
plates. The image areas are raised relative to the non-image areas.
Ink is applied to the image areas and then transferred directly to the
substrate. In rotogravure printing, the image areas are recessed
relative to the non-image "areas. The image carrier is normally a
copper plated cylinder, which may also be chrome plated to enhance wear
resistance. The image is in the form of cells or cups mechanically or
chemically etched in the cylinder's surface. Magazines, catalogues, and
brochures are among the products printed by the publication gravure
industry. Packaging items printed by rotogravure or flexography include
cartons, corrogated paper board, envelopes, paper and plastic bags, paper
and foil labels, and plastic and foil overwraps.
Publication gravure printing is done at large plants, numbering less than
fifty nationwide. Packaging gravure and flexographic printing is
done by a considerably larger number of firms, ranging in size from large
integrated companies with many presslines to small operations with only
one or two press lines. In the mid-19701s, there were an estimated
14,000 package gravure and 30,000 flexographic printing lines in the
nation.1
Gravure and flexography printing both require low viscosity inks that are
solvent or water-based. Solvent content in solvent-based inks ranges
from about 50 to over 90 percent, while water-based inks have solvent
contents of 25 percent or less. Typical solvents include these volatile
organic compound (VOC) categories: alcohols, aliphatic napthas, aromatic
hydrocarbons, esters, ethers, glycols, and ketones. The inks dry by
solvent absorption into the web and/or evaporation. The major sources of
VOC emissions from printing operations are the printing units and the ink
7-1
-------
dryers. The latter hasten solvent evaporation by passing high velocity
air over the substrate at temperatures sufficiently low to avoid damaging
the substrate.
Ohio's RACT regulation is applicable statewide to facilities having
rotogravure and/or flexographic printing lines with total annual VOC
emissions in excess of 100 tons. Exempt from the regulation are printing
lines which apply vinyl coatings and printing lines used solely to check
the quality of image formation of newly engraved or etched cylinders.
7.2 CHARACTERIZATION OF AFFECTED SOURCES
7.2.1 Publication Rotogravure
The three Ohio publication gravure plants in operation as of January
1978 are listed in Table 7-1. The Art Gravure Corporation of Ohio
will be the sole plant operating in the state by December 1982. The
plant is already equipped with solvent vapor recovery systems, which
company management believes are adequate for compliance with Ohio's RACT
regulation.2
7.2.2 Packaging Rotogravure
The inventory of packaging gravure plants potentially affected by the
RACT regulation is based on three sources of information: emission
inventory data compiled by the Ohio EPA; supplementary inquires made to
Ohio EPA District Engineers; and the 1980 Ohio Industrial Directory.
Firms identified by any of these sources were contacted to obtain
information regarding their printing operations. Due to requests
that detailed information regarding annual production, product mix,
and ink consumption be treated as confidential , survey questions and
responses are phrased in somewhat generalized terms. The following
questions were asked to determine if a particular plant is affected by
the RACT regulation:
7-2
-------
NAME
TABLE 7-1
PUBLICATION ROTOGRAVURE PLANTS IN OPERATION
AS OF JANUARY 1. 19783
LOCATION REMARKS
Art Gravure Corporation of Ohio
Dayton Press, Inc.
Springfield Gravure Corporation
Cleveland
Dayton
Springfield
Equipped with a carbon
adsorption system
In process of terminating
operations
No longer in operation
7-3
-------
0 Is packaging gravure printing done at the plant?
• Are inks currently used primarily solvent-based or water-based?
• Has estimated annual solvent consumption in packaging gravure
operations been at least 100 tons in recent years?
• What solvent vapor emission control equipment is presently
installed?
t What measures are being seriously considered or are being
taken to reduce solvent vapor emissions to comply with the
RACT regulations?
Management personnel at 11 Ohio plants supposedly engaged in packaging
gravure printing were contacted. This type of printing is not done
at 2 of the 11 plants. The remaining plants affected by the RACT
regulation are summarized in Table 7-2. The judgment that a plant is
affected is based on one or more of:
t Annual emissions data from the Ohio Emission Inventory Summary
(EIS);
• Request for a compliance extension from the Ohio EPA; and
• Plans or a commitment made to increase the use of water-based
ink, as a response to the RACT regulation.
From Table 7-2, the preferred compliance strategy at 6 of the 9 plants is
the increased use of water-based inks. Solvent vapor recovery systems
represent the preferred compliance strategy at two plants. In addition,
American Can Company plans to transfer its packaging rotogravure printing
operations out of state due, in part, to the RACT regulation.4
7.2.3 Flexographic Printing
The inventory of flexographic printing plants affected by the RACT
regulation is based on four sources of information: Ohio EIS data;
supplementary inquiries made to Ohio EPA District Engineers; the
Flexographic Technical Association (FTA); and the 1980 Ohio Industrial
Directory. Firms identified from these sources were contacted to
7-4
-------
TABLE 7-2
INVENTORY OF OHIO PACKAGING ROTOGRAVURE PRINTING PLANTS
AFFECTED BY THE RACT REGULATION3
PLANT NAME
LOCATION
(CITY)
TOTAL HYDROCARBON
EMISSIONS3
(tons/yr)
MEASURES CONSIDERED OR TAKEN TO
REDUCE SOLVENT VAPOR EMISSIONS
en
American Can Company
Colorpac Inc.
Georgia Pacific Companyb
Ludlow Packaging Company^
Ohio Match
Olinkraft Inc.
Packaging Corporation of America
St. Regis Paper
Specialty Paper Company
Cleveland
Franklin
Cincinnati
Mount Vernon
Wadsworth
Evandale
Rittman
Middletown
Dayton
372
776
854
951
101
436
215
1000
735
printing operations being discontinued
solvent recovery system
increased use of water-based inks
increased use of water-based inks
increased use of water-based inks
increased use of water-based inks
increased use of water-based inks
increased use of water-based inks
solvent recovery system
aBased on 1979 Ohio Emission Inventory Summary.
bBoth packaging gravure and flexographic printing done at this plant.
are presented.
Emissions from all printing operations
-------
obtain information regarding their printing operations. In contrast to
the gravure printing industry, the development of an inventory of
flexographic printing plants potentially affected by the RACT regulations
is complicated by:
• The inclusion of flexographic printing operations in Standard
Industrial Classification (SIC) codes 2641, 2643, 2649, 2751,
2754, 3079, and 3497.5
t The use of a number of inks, which may be solvent and/or water-
based, at most flexographic printing plants;
t The wide range of flexographic printing plant sizes, in terms of
number of presses, number of employees, product quantity, and ink
consumption; and
• The use of solvent and/or water-based inks in printing oper-
ations, such as letterpress or lithography, conducted at the same
premises as is flexographic printing.
Management personnel at 45 Ohio printing plants supposedly having
some involvement in flexographic printing were contacted. The following
questions were asked to determine if a particular plant is affected by
the RACT regulation:
• Is flexographic printing done at the plant?
• Are inks used primarily solvent or water-based?
• Has estimated annual solvent consumption in flexographic printing
operations been at least 100 tons in recent years?
• What solvent vapor emission control equipment is presently
installed?
• What measures are being seriously considered or are being taken
to reduce solvent vapor emissions to comply with the Ohio RACT
regulation?
Plants were eliminated from the inventory for one or both of the
following reasons:
t Flexographic printing is no longer done at the plant;
• The quantity of VOC emissions from flexographic and rotogravure
printing is well under 100 tons per year.
7-6
-------
The inventory of plants assumed to be affected by the RACT regulation
is presented in Table 7-3. The judgment that these plants are affected
is based on one or more of:
• Emission data from the Ohio EIS;
• Request for a compliance extension from the Ohio EPA; and
• Plans or a commitment made to increase the use of water-based
ink, as a response to the RACT regulation.
From Table 7-3, the preferred compliance strategy expressed for all the
affected plants is the increased use of water-based inks. Diamond
International has already submitted for Ohio EPA approval a plan to
achieve compliance by sufficiently extensive use of water-based inks.6
Several companies contacted have requested a compliance extension from
the Ohio EPA in order to better determine the degree to which water-based
inks can replace solvent-based inks used at their Ohio facilities.
7.3 ALTERNATIVE CONTROL MEASURES
Alternate methods of controlling VOC emissions from gravure and
flexographic printing operations are: capture systems with control
devices, the use of low solvent (water-based) inks, and high solids inks.
The following subsections describe these control strategies and their
applicability to the three regulated printing industries.
7.3.1 Capture Systems with Control Devices
A printing plant's VOC emission control system consists of two discrete
sections: the capture system which collects solvent vapors in the
pressroom, and a control device used to either recover or destroy
captured solvent. Carbon adsorbers and fume incinerators are considered
proven, high efficiency equipment for controlling solvent vapor emissions
from rotogravure and flexographic printing operations.1
Ohio RACT II regulations specify a minimum control device efficiency
of 90 percent for the three categories of printing operations addressed
7-7
-------
TABLE 7-3
INVENTORY OF OHIO FLEXOGRAPHIC PRINTING PLANTS
AFFECTED BY THE RACT REGULATION3
PLANT NAME
TOTAL HYDROCARBON
LOCATION EMISSION3
(CITY) (tons/yr)
MEASURES CONSIDERED OR TAKEN TO
REDUCE SOLVENT VAPOR EMISSIONS
Champion International b
Clouds ley Company
H.S. Crocker Company
Diamond International
Diamond International
as Georgia Pacific Company0
Jaite Packaging Company^
Ludlow Packaging Company0
Mead Paper Company b
Zumbiel Company
Olmstead Falls
Forest Park
Blue Ash
Lockl and
Norwood
Cincinnati
Akron
Mount Vernon
Chlllocothe
Norwood
367d
605
183
412
514
854
367d
951
36 7d
119
increased use of water-based Inks
Increased use of water-based inks
increased use of water-based Inks
increased use of water-based inks
Increased use of water-based inks
increased use of water-based Inks
Increased use of water-based Inks
increased use of water-based Inks
increased use of water-based inks
increased use of water-based inks
3Based on 1979 Ohio Emission Inventory Summary.
bIncluded in Inventory due to expressed concern over Impact of RACT regulation on printing operations.
CBoth packaging gravure and flexographic printing done at this plant. Emissions from all printing operations
are presented.
^Estimated annual emissions equal to the average of the annual emissions from the five facilities at which
only flexographic printing is performed.
-------
in the regulations. The regulations require a VOC capture system
efficiency of 60 percent for flexographic printing, 70 percent for
packaging rotogravure printing, and 75 percent for publication roto-
gravure printing. Since overall emission reduction efficiency is a
function of capture efficiency and control device efficiency, the
required overall VOC reductions are approximately 58.5, 63.0, and
72.0 percent for flexographic, packaging rotogravure, and publication
rotogravure, respectively. These values do not take into account
solvent retained in the printed product.
7.3.1.1 Capture System Efficiency
Most press lines have dryer enclosures and ductwork designed to capture
and convey VOC exhaust vapors away from the presses. Capture efficiency
is a function of drying temperature, operating speed of the press,
and air flow from the dryers. Capture systems at most plants collect
only the dryer exhaust. However, dryer exhaust is not the only solvent-
laden air that can be collected by a high efficiency capture system.
Fugitive vapors from solvent evaporation in the ink fountains, from
exposed portions of the printing cylinder, and from exposed portions of
the printed web ahead of the dryers can be reduced by enclosing ink
fountains and extending the dryer enclosure. However, these areas
may still be exposed during press shutdowns for web breaks, cylinder
changes, and maintenance. Fugitive solvent vapors will also be emitted
from the web during shutdowns. A few plants' vapor capture systems
incorporate floor and/or room vents near each press to collect fugitive
emissions from the pressroom. Since the final printed product may retain
up to seven percent of solvent used in the printing operation, the
product remains a source of fugitive VOC even after cutting and folding
operations.
7.3.1.2 Carbon Adsorption Systems
Carbon adsorption systems available in the United States may be
classified as fixed or fluidized bed systems. In either adsorption
7-9
-------
process, at least 95 percent of the solvent vapor molecules can be
removed from an airstream. Subsequent stripping of solvent molecules
from the carbon is called desorption or bed regeneration.
Fixed-bed adsorption systems are more commonly associated with publica-
tion gravure operations, since the principal solvent (toluene) can be
separated from the water with relative ease, and solvent cost makes
recovery and recyling economically desirable. As of 1977, 19 of the
nation's 27 publication gravure plants employed fixed bed adsorption
systems on at least one press line.3 As indicated in Table 7-1, the
only Ohio publication gravure plant which will remain operational beyond
1982 has carbon adsorption systems.
In contrast to the publication gravure industry, inks typically
used in packaging gravure and flexographic printing often contain
complex mixtures of solvents which are not equally soluable in water.
Nevertheless, there is growing interest in carbon adsorption systems from
the packaging gravure industry. A previous national study of the
flexible packaging industry indicated that 4 of the 154 plants surveyed
were equipped with fixed bed adsorption systems.7 As indicated in
Table 7-2, management at two Ohio package gravure plants presently
consider solvent recovery systems as their preferred RACT compliance
strategy.
A flow diagram of a fixed bed adsorption system is presented as Figure
7-1. During the adsorption cycle, solvent concentration in the
adsorber unit's exhaust remains relatively constant until breakthrough
occurs. After this bed saturation level is reached, the outlet solvent
concentration increases rapidly. A hydrocarbon analyzer can be used
to monitor solvent concentration in the adsorber unit exhaust. The
solvent-laden airstream can then be ,-e-routed to another adsorber
unit, while the saturated bed is desorbed. Regeneration is usually
accomplished by flushing with low pressure stream. The stream and
solvent vapor must then be condensed and separated.
7-10
-------
SOLVENT LADEN
AIR IN
STEAM
1H
COOLER-
FILTER
I NON-CONDENSABLE
FAN
ACTIVATED
CARBON \
ADSORBER
1
GAS RECYCLE
ACTIVATED
CARBON \
TREATED AIR TO ATMOSPHERE
(XJ °Pen
closed
CONDENSER
» COOLER DECANTER
FIGURE 7-1
FLOW DIAGRAM OF SOLVENT RECOVERY SYSTEM
(ADSORBER 1 REGENERATING)
-------
Fixed-bed carbon adsorption systems for the packaging gravure industry
are being marketed by at least three American firms. At least one
firm can install an emissions control system encompassing press area
capture systems, adsorber units, water/solvent distillation units,
solvent mixture separation equipment, and recovered solvent storage.
Plant specific factors affecting the design and cost of solvent capture,
recovery, and recycling systems include:
• The required efficiency of the proposed or existing capture
system;
• The range of solvent concentrations in the airstream from
each capture system;
• The types and corrosiveness of the solvents;
t The desired quality of construction materials;
• The relative location of the press lines within the plant;
• The variability of individual press line usage; and
t The decision to separate solvent mixtures on-site or to sell
the mixture for subsequent separation and reuse.8'9
Operational problems associated with fixed-bed adsorption systems
include: carbon pellet erosion and disintegration due to mechanical
abrasion and thermal degradation, buildup of residue on the carbon
pellets, corrosion, valve leakage, and potential formation of azeotropes
of water and alcohol solvents. Replaceable valve seals and seats reduce
leakage problems, while carbon pellet replacement reduces the effects
of erosion, disintegration, and residue buildup. Fixed bed carbon
adsorption systems require multiple adsorption units so that printing
operations may continue during bed regeneration. The length of an
adsorption cycle is dependent on pressroom activity and system design.
The regeneration cycle may continue for several hours, depending on steam
generation capacity, steam flowrate in the bed, and cooling times
required.
Union Carbide Corporation is marketing a fluidized bed carbon adsorption
system, called Purasiv-HR, that was developed by the Kureha Chemical
Corporation of Japan. A flow diagram of the Purasiv-HR system is
7-12-;
-------
presented as Figure 7-2. In the fluidized bed process, adsorption
and desorption occur simultaneously in a single vertical vessel. The
adsorbant is activated carbon beads. Solvent laden air is introduced
into the bottom of the adsorption section and passes upward counter-
current to the fluidized activated carbon in a series of perforated
trays. Carbon on each tray gradually flows downward from tray to tray as
solvent adsorption increases. As it leaves the bottom tray of the
adsorption section, the activated carbon is no longer fluidized and flows
as a dense bed through the desorption section of the column. In the
desorber, the adsorbent passes through the tube side of a shell-and-tube
heat exchanger where indirect heating by steam or other heat transfer
media raises it to the desorption temperature. The heat transfer
media used for indirect heating is condensed and returned uncontaminated
to the boiler. Desorption of solvent from the hot activated carbon is
assisted by the introduction of direct contact stripping gas, usually
nitrogen. The direct contact stripping gas reduces the partial pressure
of the hydrocarbons and sweeps them from the bed in vapor form. The
stripping gas, together with the vaporized solvent, passes from the
desorber to a condenser where the solvent is recovered. The activated
carbon leaving the bottom of the hot desorption section is first cooled
and then air-conveyed to the top tray of the adsorption section. The
nitrogen gas is recycled from the condenser back into the system for
re-use. A secondary adsorber above the desorption section is used to
properly condition the recycled nitrogen stream.10
Claimed advantages of the fluidized bed over the fixed bed adsorbers
include:
• Continuous adsorption and desorption in a single vessel ;
• The countercurrent flow of solvent laden air past the fluidized
adsorbant allows maxmium adsorption capacity;
• The use of nitrogen stripping gas instead of steam minimizes
water content in the recovered solvent, resulting in fewer
vessel corrosion problems;
• Reduced installation costs;
7-13
-------
TREATED CAS
i
i—•
-e»
UNION CftRBIDE CORPORATION
PURASIV l« EllCIICERINC • TONflWflNOfl. NCU YOniC'
SOLVENT LAC£N
AIR
FROM CUSTOMER
FIGURE 7-2
PURASIV-HR FLOW DIAGRAM
AIR LIFT
BLOWER
flIR LIFT
NOZZLE
-------
• Reduced steam requirements;
• Reduced space requirements;
• Fewer moving parts; and
0 Longer adsorbant life versus pelletized or granular activated
carbon.10
Disadvantages of the fluidized bed system include:
t System air flow rate must remain relatively constant;
• Operating experience is less than that of fixed bed adsorbers;
and
• Capital investment costs may be higher than for fixed bed
systems.1
7.3.1.3 Incineration
Incineration destroys organic emissions by oxidizing them to carbon
dioxide and water. There are no incineration systems currently being
used on publication rotogravure plants in this country.3 A previous
survey of the flexible packaging industry indicated 5 of the 157 plants
surveyed were equipped with incinerators. However, these units were
either not operating or were associated with plant operations that did
not involve flexographic printing. The survey of Ohio packaging gravure
industry reveals a single plant having one of its presses equipped with
an incineration system.11 The type and operational status of the
incineration system were not determined.
Industry sources were asked to comment on the packaging gravure and
flexographic printing industries' apparent reluctance to install
incineration systems. A compilation of their comments regarding the
disadvantages of incineration system is:
• Capital and installation costs are high:
• Industry is concerned over long-term fuel availability and
costs;
t Operating costs are high due to the discontinuous nature of
printing operations and the length of time needed for incinerator
start-up;
7-15
-------
• For incineration systems configured for partial heat recovery,
there may be no use for recovered heat unless existing presses'
drying ovens are modified; and
• There are roof-top or ground-level installation problems
associated with incineration systems.12,13,14
For the aforementioned reasons, and the lack of expressed desire from
the Ohio packaging gravure and flexographic printing industries to
consider incineration systems as an acceptable RACT compliance strategy,
incineration systems are not further addressed in this study.
7.3.2 Water-Based Inks
The development of water-based inks used in packaging gravure and
flexographic printing has been accelerated by the publication of EPA
guideline documents and subsequent promulgation of regulations limiting
VOC emissions from these printing operations.14 Water-based inks now
constitute a potential VOC emission control strategy for printing
operations involving more types of substrates than was true three years
ago. Management personnel from the majority of printing plants listed in
Tables 7-2 and 7-3 indicate that the increased use of water-based inks
represents the preferred RACT compliance strategy at their plants.
The use of water-based inks is an attractive RACT compliance strategy
since it represents a lower capital investment compared to either
carbon adsorption or incineration systems.15 While ink manufacturers
and representatives of printing industry professional organizations can
identify potential problem areas or benefits resulting from a conversion
to water-based inks, the overall impact upon the packaging gravure and
flexographic printing industries is difficult to estimate for many
reasons, including:
• The multitude of solvent-based ink/substrate combinations
found in these industries;
• The continuing development of water-based inks potentially
suitable as alternatives to solvent-based inks; and
• The unavailability of cost and operational experience information
compiled and analyzed for a sufficient number of plants that have
already converted to water-based inks.
7-16
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The paucity of cost and operational experience information causes
industry sources to be reluctant to estimate industry average or even
ranges of cost savings or increases associated with a conversion to
water-based inks. Sources contacted agree that water-based inks are
currently more expensive than the solvent-based inks they may eventually
replace. However, the magnitude of the cost differential is highly
dependent on the associated substrate and the solvent-based inks being
compared. Current estimates are that water-based inks cost the printing
industry an average of 10 to 15 percent more than solvent-based inks, but
that this cost differential will decrease as solvent costs continue to
increase and development costs passed on to the consumer decrease. 16»17
There may be a crossover in comparative solvent and water-based ink
prices in the latter half of the decade. 16>18 For the purposes of this
study, it is assumed that the average cost of water-based inks is
presently 15 percent higher than that of the solvent-based inks replaced.
The desirability of converting to water-based inks cannot be judged
solely on the basis of ink costs. Several operational considerations
must also be evaluated. Gravure cylinders used with solvent-based inks
may not produce the same quality printing if used with water-based
inks.I9'20 In general, water-based inks transfer onto the substrate
more efficiently than solvent-based inks. Therefore, to avoid excessive
ink deposition on the substrate, the technique used to engrave the
cylinders must be modified. The cost of obtaining gravure cylinders
suitable for use with water-based inks should not differ significantly
from that for cylinders compatible with solvent-based inks. From an
operational standpoint, however, the impact of procuring new cylinders
for use with water-based inks will depend on the amount and nature of
repeat printing tasks performed at a given printing plant. Rather
than being able to replace cylinders only as they become damaged or
worn, a plant may have to replace the entire set of cylinders used
for a repeat customer's printing job, once the use of water-based inks
has been authorized. It is assumed that the cost of procuring cylinders
compatible with water-based inks is identical to that for cylinders used
with solvent-based inks.
7-17
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With respect to the flexographic printing, there is some concern that a
press1 ink metering system may require modification if printing done
with water-based inks is to be of equivalent quality to that done using
solvent-based inks.17 No additional information on this potential
problem area is available. Consequently, any costs associated with
modifying a flexographic press line's ink metering system due to a
conversion to water-based inks will not be considered in this study.
Another operational concern regarding a conversion to water-based
inks is drying time. The magnitude of the increase in drying times is
dependent upon the inks being compared, substrate absorbancy, and the
design and operational characteristics of the press line's dryers.
Improvements in drying time could be realized by increasing the quantity
of heated air contacting the substrate, increasing the temperature of the
drying air, or decreasing the press1 operating speed. The amount
of temperature increase is limited by the substrate. The amount of
press speed decrease is limited by the decrease in profit that can be
tolerated. In the absence of industry cost estimates for implementing
any of these alternatives, costs incurred in modifying press equipment or
operational procedures to improve ink drying characteristics are not be
addressed in this study.
7.3.3 High Solids Inks
High-solids inks have not more than 40 percent solvent content by
volume, excluding water. High-solids inks include resins, so that
less solvent is needed to reduce ink viscosity to levels required for
application. Coatings have been developed with a low-viscosity vehicle
that polymerizes rapidly by reaction with some other component or by
action of ultraviolet or electron-beam radiation. Such measures are
necessary to affix the ink to the substrate.-*
While high-solids inks have been tried in other segments of the printing
industry, their use is not yet feasible for gravure and flexographic
printing applications.15 There is, however, some future for high-solids
inks, particularly for non-absorbant substrates.16
7-18
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Due to the state of high-solids ink technology with respect to packaging
gravure and flexographic printing, this VOC emission control strategy is
not be further addressed in this study.
7.3.4 Model Plant Formulation
Model plant configurations are used in this study to develop estimated
costs to the Ohio flexible packaging industry for implementing acceptable
RACT compliance strategies.
Management at plants identified in Section 7.2 consider either the
installation of carbon adsorption systems or the increased use of
water-based inks to be the only acceptable compliance strategy for their
plants The extent to which either strategy is being investigated or
adopted at these plants is generally considered proprietary information.
Model plant parameters presented in this section are based on information
presented in U.S. EPA publications and general guidance from industry
sources.
7.3.4.1 Model Plant Parameters for Plants Converting to Water-Based Inks
The cost differential between water and sol vent-based inks is assumed to
be the only parameter required to estimate the cost of implementing
a compliance strategy based on the use of water-based inks. It is
assumed that costs to implement any equipment or operational changes
eventually determined necessary to produce a satisfactory product printed
with water-based inks will not be prohibitive. It is also assumed
that the average cost of water-based inks utilized as a RACT compliance
strategy is 15 percent higher than that of the sol vent-based inks they
replace.
7-19
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7.3.4.2 Model Plant Parameters For Plants Equipped
with Carbon Adsorption Systems
Suppliers of solvent recovery systems cite a number of plant-specific
variables that greatly affect control system design and, therefore,
total cost.
Some suppliers include the upgrading of existing or the design and
installation of new vapor capture systems in their scope of services. In
this study, it is assumed that a company selecting carbon adsorption
systems as their compliance strategy already has pressroom vapor capture
systems that meet the efficiency requirements of Ohio's RACT regulations.
Since complex mixtures of solvents are commonly used in flexible
packaging printing operations, a major decision is whether to install
solvent mixture separation, purification, and storage equipment onsite or
to arrange for solvent mixture disposal by another firm. The latter will
be assumed in this study.
Although the total cost of a solvent recovery system is a function
of many variables, system suppliers and a recent U.S. EPA publication
utilize capture system exhaust volumetric flow rate and VOC concentration
in the exhaust as the critical parameters in control system cost
estimations. The volumetric flow rate and concentration combinations
presented in Table 7-4 are assumed representative for the Ohio flexible
packaging industry plants affected by the RACT regulations. The average
actual press operating time is assumed to be 3430 hours per year, based
on 4900 scheduled operating hours per year and 30 percent press idle
time.5
7.3.5 Estimated VOC Emissions After Implementation of RACT
Ohio's RACT regulations apply to gravure and flexographic operations
capable of emitting at least 100 tons per year of VOC. The state's only
publication gravure plant remaining operational beyond 1982 has been
7-20
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TABLE 7-4
PROCESS PARAMETERS FOR MODEL PLANT
CONFIGURATIONS INCORPORATING CARBON ADSORPTION
SYSTEMS FOR VOC EMISSIONS CONTROL
TOTAL SOLVENT CONCENTRATION TOTAL EXHAUST FROM AVERAGE PRESS3 ANNUAL PLANT5
IN CAPTURE SYSTEMS EXHAUST CAPTURE SYSTEMS OPERATING TIME VOC EMISSIONS
(ppm) (scfm) (hrs/yr) (tons/yr)
250
500
750
20,000
50,000
100,000
20,000
50,000
100,000
20,000
50,000
100,000
3,430
3,430
3,430
3,430
3,430
3,430
3,430
3,430
3,430
131.7
329.3
658.6
263.4
658.6
1317.2
395.2
987.9
1975.8
au.S. EPA, 1981.
bVOC (ton/yr) = (ppm)(scfm)(3,430 hrs/yr)
(65100) (2000 Ib/ton)
7-21
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equipped with a solvent recovery system for some time. Therefore, the
economic impact of Ohio's RACT regulation on the publication gravure
industry is not addressed in this study. The estimation of total annual
VOC emission reductions due to the implementation of RACT is based on
emission reductions from plants satisfying the following criteria:
0 Packaging gravure or flexographic printing operations will
continue beyond 1982; and
• In reaction to the RACT regulation, plant management is now in
the process of investigating or implementing measures to reduce
VOC emissions.
As indicated in Tables 7-2 and 7-3, sixteen plants are determined to
satisfy these criteria. Both flexography and package gravure printing is
done at two of the affected plants. Annual emissions data are available
from the 1979 Ohio EIS for 13 of the 16 plants. For the remaining 3
plants, annual VOC emissions from each of these plants are estimated to
be 367 tons per year, which is the average of the 1979 annual emissions
from the 5 facilities listed in Table 7-3 at which only flexographic
printing is performed. Therefore, total VOC emissions from printing
plants subject to the RACT regulations are estimated to be 8002 tons per
year.
7.3.5.1 Estimated Annual VOC Emission Reductions
From Plants Converting to Water-Based Inks
Management at 14 affected facilities indicate that the increased use
of water-based inks is their present RACT compliance strategy. The
extent to which water-based inks can actually replace solvent-based inks
at all plants will not be known for some time. In this study, it is
assumed that all 14 facilities will comply with the RACT regulations by
totally converting to water-based inks.
The estimated annual VOC emissions from these 14 plants are 6,491
tons per year. Package gravure and flexography printing utilize a
variety of inks which contain different percentages of volatile solvents,
ranging from about 50 to 96 percent.1 For solvent-based inks, an
7-22
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average volatile solvent content of 75 percent is assumed in this
study.1*3 Per Ohio Rule 3745-21-09(Y), the volatile organic compound
content of a compliance ink cannot exceed 25 percent by volume of the
ink's volatile content. Therefore, assuming identical solvent and
water-based ink consumption (i.e., identical solids content) before
and after implementation of RACT and 100 percent plant conversion to
water-based inks having 18.75 percent volatile solvent content, the
estimated annual reduction in VOC emissions from these 14 plants is
4,868 tons per year.
7.3.5.2 Estimated Annual VOC Emission Reductions From
Plants Installing Solvent Recovery Systems
Management at two plants indicate that the installation of solvent
recovery systems is their present RACT compliance strategy. It is
assumed that this compliance strategy will be implemented at only these
two plants.
Suppliers of fixed or fluidized bed carbon adsorption systems claim
a solvent vapor removal efficiency from capture system exhaust of
about 96 to 97 percent.9>21 It is conservatively assumed that the
adsorber units will operate at an overall average 90 percent VOC removal
efficiency, as is required by the RACT regulation. Assuming the plant's
existing capture systems meet the regulations' 70 percent efficiency
requirement, the annual reduction in VOC emissions from these plants can
be estimated from the 1979 Ohio EIS data and an average 90 percent
solvent recovery per absorber unit. The 1979 VOC emissions from the two
plants totaled 1,511 tons per year. The estimated reduction in VOC
emissions from plants assumed to eventually install solvent recovery
systems is about 952 tons per year.
7.3.5.3 Estimated VOC Emissions After Implementation of RACT
The estimated annual VOC emissions before and after the implementation of
RACT are summarized in Table 7-5. Total VOC emission reduction is
estimated as 5,820 tons per year.
7-23
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TABLE 7-5
ESTIMATED ANNUAL VOC EMISSION
REDUCTIONS AFTER IMPLEMENTATION OF RACT
COMPLIANCE STRATEGY
CONVERSION TO3
INSTALLATION OFb
SOLVENT RECOVERY
PARAMETER
Number of Plants
Estimated Annual VOC Emissions
Before RACT (tons/yr)
Estimated Annual VOC Emissions
After RACT (tons/yr)
Estimated Annual Reduction in
VOC Emissions Due to RACT
(tons/yr)
WATER -BASED INKS
14
6,491
1,623
4,868
SYSTEM
2
1,511
559
952
TOTAL
16
8,002
2,182
5,820
aBased on average solvent contents of 75 percent in sol vent-based inks and
18.75 percent in water-based inks.
bBased on capture system efficiency of 70 percent and control system efficiency
of 90 percent.
7-24,
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7.4 COST ANALYSES
The costs of controlling VOC emissions from affected packaging gravure
and flexographic printing plants are estimated using model plant
parameters formulated for the currently preferred control strategies at
the affected plants.
7.4.1 Conversion to Water-based Inks
As indicated in Section 7.3, the total cost of complying with the
RACT regulation that is incurred by plants adopting a water-based ink
compliance strategy is assumed to be the cost difference between water
and solvent-based inks used at these facilities. In general, the
cost of the pigment is a more important factor than the cost of the
solvents in inks used by the packaging gravure and flexographic printing
industries. The most commonly used inks are white. The current cost of
sol vent-based, white inks used by these industries is about $1.00 per
pound. The costs for other colors are higher, due to higher pigment
costs.22 The estimated industry average price for solvent-based inks
used in Midwestern packaging gravure and flexographic printing is about
$1.30 per pound.23 This value, equivalent to $2600 per ton of ink, is
assumed representative of ink costs to Ohio packaging gravure and
flexographic printers. Assuming that water-based inks currently are an
average 15 percent more expensive than sol vent-based inks, the estimated
average cost of water-based inks is $1.50 per pound ($3000 per ton).
The estimated costs of achieving compliance for affected plants assumed
to convert to 100 percent water-based ink usage and summarized in
Table 7-6. These facilities will incur an estimated average cost
of $800 per ton ($0.88 per kilogram) reduction in VOC emissions, based
on estimated current ink costs. This cost of achieving compliance
should decrease as water-based ink costs decrease relative to those of
sol vent-based inks.
7-25
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TABLE 7-6
ESTIMATED COSTS FOR CONVERSION TO
WATER-BASED INKS
PARAMETER VALUE
Estimated VOC emissions 6,491
before RACT (tons/yr)
Average solvent content in 75.00
solvent-based inks (%)
Average solvent content in 18.75
water-based inks (%)
Average solvent retention in 3.5
substrates3 (%)
Estimated ink consumption15 (tons/yr) 8,655
Estimated increased cost for 400
water-based inks ($/ton)
Estimated increased ink cost ($/yr) 3,462,000
Estimated VOC reduction due to
implementation of RACT (tons/yr)
Cost effectiveness ($/ton VOC reduction) 800
($/kg VOC reduction) 0.88
aRange of solvent retention is negligible to about 7
percent.
^Solvent or water-based inks.
7-26
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7.4.2 Carbon Adsorption Systems
installation and operation costs for carbon adsorption systems can
be estimated using model plant parameters presented in Table 7-4 and
equations developed for the EPA.5 The installation cost for carbon
adsorption systems, including site preparation and system piping and duct
work, are primary functions of the vapor capture systems exhaust gas
volumetric flow rates (VFR) and the VOC concentration in the exhaust gas,
as indicated in the following equation:
I = [2.7][(8.1)(VFR) + 17800] [1 + (C/3500)]
where: I is the total estimated installation cost in dollars;
VFR is expressed in units of standard cubic feet per minute
(scfm); and
C is solvent vapor concentration in parts per million (ppm).
Equations developed for annual operating costs are summarized below:
Steam Cost (SC) = (3.5)($9/1,000 Ib steam)(V Ib/hr)
Water Cost (WC) = (VFR)(H)($0.30/1,000 gal)
Carbon Replacement (CR) = ($0.14)(VFR)
(based on 10% replacement/yr at $1.27/lb)
Condensate Treatment (CT) = ($0.22)(V Ib/hr)
(for contract disposal)
where:
V is amount of VOC contained in the capture systems' exhaust
gas;
VFR is volumetric flow rate (scfm); and
H is operating hours (hrs/yr).
Estimated adsorption system installation and annual operating costs
for the model plant configurations are presented in Table 7-7. The
largest operating cost is associated with recovered solvent mixture
treatment and disposal.
7-27
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TABLE 7-7
ESTIMATED INSTALLATION AND ANNUAL OPERATING COSTS FOR
SOLVENT RECOVERY SYSTEMS
MODEL
PLANT NO.
1
2
3
4
r 5
ro
00 6
7
8
9
TOTAL SOLVENT
CONCENTRATION TOTAL EXHAUST
IN CAPTURE SYSTEMS FROM CAPTURE
EXHAUST (ppm) SYSTEMS (scfm)
250
250
250
500
500
500
750
750
750
20,000
50,000
100,000
20,000
50,000
100,000
20,000
50,000
100,000
ESTIMATED
INSTALLATION
COSTS
(nearest $1,000) STEAM
520,000
1,223,000
2,395,000
555,000
1,305,000
2,554,000
589,000
1,386,000
2,714,000
8,297
20,746
41,492
16,594
41,492
82,984
24,898
62,238
124,475
ANNUAL
WATER
20,580
51,450
102,900
20,580
51,450
102,900
20,580
51,450
102,900
OPERATING COSTS ($)*
CARBON
REPLACEMENT
2,800
7,000
14,000
2,800
7,000
14,000
2,800
7,000
14,000
CONDENSATE
DISPOSAL
57,948
144,892
289,784
115,896
289,784
579,568
173,888
434,676
869,352
TOTAL
89,625
224,088
448,176
155,870
389,726
779,452
222,166
555,364
1,110,727
*Based on 3,430 operating hours per year.5
-------
Solvent recovery is the preferred control strategy at two Ohio package
gravure plants. Although 1979 annual VOC emissions data are available
for both plants, pressroom configuration, and press and capture system
design and operational information are not available. It is assumed
that recovered solvent mixtures will be disposed of by an independent
contractor, rather than being recycled onsite or sold for reprocessing
and subsequent resale by another firm.
Annual VOC emissions from the two plants at which solvent recovery
systems is the preferred control strategy are 1,511 tons per year. It
is assumed that model plants No. 5 and No. 8 provide representative cost
estimates for facilities capable of emitting roughly 750 tons of VOC
annually. Assuming presslines operate 3,430 hours per year, annual
emissions from model plants Nos. 5 and 8 bracket an emissions value of
about 750 tons per year. Annualized cost estimates for model plants Nos.
5 and 8, presented in Table 7-8, include capital charges and operating
and maintenance costs. Capital charges cover a capital recovery factor
to account for interest and depreciation and a 4 percent factor for
property taxes, insurance, and administrative costs. The capital
recovery factor (CRF), defined in Chapter 1 of this study, is 17.7
percent, based on an annual interest rate of 12 percent and an equipment
life of 10 years. The total capital charge factor is, therefore,
estimated as 21.7 percent of the installed capital costs.
Annual operating costs were estimated using equations developed for
the EPA.5 Contract disposal of solvent at a cost of $65 per drum is
assumed. From Table 7-7, this method of recovered solvent handling
represents 64.7 to 78.7 percent of the total estimated annual operating
costs. Depending on local market conditions, should recovered solvent be
sold for reuse rather than being disposed of at a cost to the printer,
overall annual operating costs could be reduced significantly.
7.5 OVERALL COST EFFECTIVENESS
The overall estimated cost effectiveness for the segments of the printing
industry affected by Ohio's RACT regulation is presented in Table 7-9.
7-29
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TABLE 7-8
ESTIMATED COSTS FOR SOLVENT RECOVERY SYSTEMS
FOR TWO MODEL PLANT CONFIGURATIONS
MODEL PLANT CONFIGURATIONS
PARAMETER
Installed Capital Cost ($103)
Annual Operating Cost ($103)
Annual i zed Capital Charges3 ($103)
Total Annual Cost ($103)
Solvent Recovered^ (tons/yr)d
Cost Effectiveness0
($/tons recovered)
($/kg recovered)
NO. 5
1305.0
389.7
283.2
672.9
415
1621.
1.79
NO. 8
1386.0
555.4
300.8
855.2
622
1375.
1.52
aBased on an estimated equipment life of 10 years and a capital
charge factor of 21.7 percent.
bBased on capture system efficiency of 70 percent and control
system efficiency of 90 percent.
cBased on a 90 percent VOC removal efficiency, the minimum
efficiency required by the RACT regulation.
credit for solvent recovery.
7-30
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TABLE 7-9
CONTROL COST SUMMARY FOR AFFECTED PLANTS
PARAMETER
Number of Plants
Installed Capital Cost ($103)
Annuall zed Capital Charges ($103)
Annual Operating Costs ($103)
Total Annual Costs ($103)
VOC Reduction*
(tons/yr)
(kg/yr)
Cost Effectiveness*
($/ton VOC reduction)
($/kg VOC reduction)
CONVERSION TO
WATER -BASED INKS
14
-
-
3631.2
3631.2
4,868
4,416,175
800.
0.88
CARBON ADSORPTION
SYSTEM
2
2691.0
583.9
945.1
1528.1
952
507,125
1605.
3.01
TOTAL
CONTROL
COSTS
2691.0
583.9
4576.3
5159.3
5,820
4,923,300
866.
1.05
*For plants equipped with carbon adsorption systems, based on actual emissions and 70
percent capture system efficiency and 90 percent control system efficiency.
7-31
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The overall cost effectiveness of controlling VOC emissions will be
improved when one or more of the following conditions occur:
• Water-based ink prices become more competitive to those of
solvent-based inks. As indicated in Section 7.3.2, there may
even be a crossover in comparative solvent and water-based ink
prices in the latter half of this decade. This possible price
crossover, in conjunction with the time extension allowed in Ohio
Rule 04(C)(32)(b) for water-based research programs, may result
in a net savings for those converting to water-based inks;
• Facilities equipped with carbon adsorption systems utilize inks
whose solvents are recyclable with minimal separation and other
reprocessing problems; and
• Facilities equipped with carbon adsorption systems successfully
market recovered solvent mixtures or otherwise minimize disposal
costs.
7-32
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7.6 REFERENCES
1. U.S. Environmental Protection Agency. Control of Volatile Organic
Emissions from Existing Stationary Sources - Volume VIII:
Graphic Arts - Rotogravure and Flexography. EPA-450/2-78-033,
Office of Air Quality Planning and Standards, Research Triangle
Park, North Carolina, 1978, 55 pp.
2. Telecon. Calaiacovo, W. - The Art Gravure Corporation of Ohio, with
Ploski, T. - Dames & Moore. July 31, 1981.
3. U.S. Environmental Protection Agency. Publication Rotogravure
Printing - Background Information for Proposed Standards.
EPA-450/3-80-031a, Office of Air Quality Planning and
Standards, Research Triangle Park, North Carolina, 1980,
273 pp.
4. Telecon. Rice, H. - American Can Co., with Ploski, T. - Dames &
Moore, August 21, 1981.
5. Boies, D.B., Schumann, E.L., and F.C. Scofield. Assessment of
Organic Emissions in the Flexible Packaging Industry.
EPA-600/2-81-009, Wapora, Inc., Chevy Chase, Maryland, 1981,
141 pp.
6. Telecon. Boone, K. - Diamond International Corp., with Patterson,
R. - Dames & Moore. May 29, 1981.
7. Ponder, T.C., Abraham, J.P., and E.A. Pfetzing. Enforceability
Aspects of RACT for the Rotogravure and Flexography Portion
of the Graphic Arts Industry. PEDCO Environmental, Inc.,
Cincinnati, Ohio, 1980. 47 pp.
8. Telecon. Spencer, R. - Ray-Solo Corp., with Ploski, T. - Dames &
Moore. August 28, 1981.
9. Telecon. Wyutz, R. - Simon Croftshaw Co., with Ploski, T. - Dames &
Moore. August 28, 1981.
10. Union Carbide Corp. PURASIV-HR Solvent Recovery System, Tonawanda,
New York, undated, 5 pp.
11. Telecon. Jones, R. - Olinkraft Corp., with Ploski, T. - Dames &
Moore. August 21, 1981.
12. Telecon. George, H. - Gravure Research Institute, with Ploski, T. -
Dames & Moore. August 21, 1981.
13. Telecon. Lillquist, R. - Flexible Packaging Association, with
Ploski, T. - Dames & Moore. August 27, 1981.
7-33
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14. Telecon. Rusterholz, W. - Sun-Chemical Corp., with Ploski, T. -
Dames & Moore. August 21, 1981.
15. Telecon. Bownes, K. - Inmont Ink Corp., with Ploski, T. - Dames &
Moore. August 25, 1981.
16. Telecon. Baker, D. - Henkel Corp., with Ploski, T. - Dames & Moore.
August 27, 1981.
17. Telecon. Dunn, T. - Print Pack Co., with Ploski, T. - Dames &
Moore. August 25, 1981.
18. Telecon. Platt, M. - Crown Zellerbach Corp., with Ploski, T. -
Dames & Moore. August 31, 1981.
19. Telecon. George, H. - Gravure Research Institute, with Ploski, T.
- Dames & Moore. August 27, 1981.
20. Telecon. Schaffer, W. - Graphic Arts Technical Foundation, with
Ploski, T. - Dames & Moore. August 25, 1981.
21. Telecon. Hurwitz, D. - Union Carbide Corporation, with Ploski, T.
- Dames & Moore. August 27, 1981.
22. Telecon. Baker, D. - Henkel Corp., with Ploski, T. - Dames & Moore.
October 2, 1981.
23. Telecon. Platt, M. - Crown Zellerbach Corp., with Ploski, T. -
Dames & Moore. October 2, 1981.
7-34
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8.0 STORAGE OF PETROLEUM LIQUID IN EXTERNAL FLOATING ROOF TANKS
8.1 Introduction
Storage tanks for petroleum liquids are a significant source of VOC
emissions. The Ohio EPA had earlier implemented a regulation to control
VOC emissions from fixed roof tanks by requiring a retrofit with
internal floating roofs or their equivalent. The analysis presented
here is to determine the economic impact of controlling VOC emissions
from external floating roof tanks storing petroleum liquids. The Ohio
EPA adopted a regulation for this source category that requires
installation of a rim-mounted secondary seal or any other seal, closure,
or device with equivalent effectiveness. Exempted from this control
requirement are those tanks which (a) have a storage capacity of less
than 40,000 gallons, (b) have a storage capacity of less than 420,000
gallons and which store produced crude oil or condensate prior to
custody transfer, (c) store petroleum liquids with true vapor pressure
less than 1.5 psia, and (d) contain crude oil with a pour point of 50°F
or higher.
8.2 Inventory of Affected Facilities
The number of affected external floating roof tanks was estimated by
reviewing the state inventory information. Since the regulation exempts
the storage of vapor pressure of less than 1.5 psia, only the storage of
gasoline, crude oil and naphtha petroleum liquids was considered in
identifying the affected tanks. All other petroleum liquids have vapor
pressures below 1.5 psia, as is evident from Table 8-1, which lists the
average vapor pressure values for different petroleum liquids. Similar-
ly, other exempted categories, as listed in Section 8.1, were also
considered while identifying the affected external floating roof tanks.
The list of affected external floating roof tanks, as developed from the
state inventory, was sent to the Ohio EPA for review and comments. The
storage capacities of the tanks were also included in the listed in-
formation so they could be verified. The comments received from the
Ohio EPA on the list of affected tanks and their storage capacities were
subsequently incorporated in the final inventory information.
8-1
-------
TABLE 8-1. VAPOR PRESSURE OF VARIOUS
PETROLEUM LIQUIDS
True Vapor Pressure
Petroleum Liquid at 289°k (psia)
Gasoline 5.2
Naphtha 3.5
Jet Fuel 1.3
Benzene 1.2
Kerosene 0.0085
Diesel Fuel 0.0074
Residual Fuel Oil 0.00004
Crude Oil 2.0a
aCrude oil vapor pressure varies over a wide
range depending on the crude oil source.
2.0 psia is an average value taken from
Reference 1.
8-2
-------
The total number of affected external floating roof tanks was estimated
to be 279, with 263 tanks storing gasoline, 12 tanks storing crude oil
and 4 tanks storing naphtha. Since not all tanks are registered in the
Ohio Air Permit System, the actual number of tanks affected by this
regulation is likely to be considerably higher. A geographical
distribution of the affected tanks is presented in Figure 8-1. The size
distribution of affected gasoline storage tanks in terms of storage
capacity is given in Table 8-2. The storage capacity information was
actually available for only 198 tanks (from the total of 263 gasoline
storage tanks), and the size distribution of these tanks was used to
project the size distribution of all the affected gasoline tanks.
The uncontrolled VOC emissions from the affected gasoline storage tanks
and the potential reduction in these emissions were estimated by formu-
lating eight model tanks representing each of the eight size classifi-
cations in Table 8-2. Table 8-3 gives the model tank parameters and the
emission data for the affected gasoline storage tanks. Model tank
dimensions (diameter, height) given in Table 8-3 were estimated by con-
tacting storage tank vendors. The uncontrolled VOC emission estimates
were made by using the relationship given in Table 8-4. Using this
relationship, uncontrolled VOC emissions from affected gasoline storage
tanks were estimated to be 2,337 tons/year.
For tanks storing crude oil and naphtha, one model tank was considered
for each of the two petroleum liquids. Table 8-5 gives the technical
parameters for these model plants. Uncontrolled VOC emissions from
these tanks were estimated to be approximately 78 tons/year. The total
uncontrolled VOC emissions from all the affected tanks storing volatile
petroleum liquids (gasoline, crude oil, and naphtha) were estimated to
be approximately 2,415 tons/year.
8.3 Alternative VOC Control Measures
VOC emissions from external floating roof tanks can be controlled by
retrofitting these tanks with a shoe-mounted secondary seal or a rim-
mounted secondary seal. A shoe-mounted secondary seal is commonly
8-3
-------
SCALE IN MILES
0 5 r 2O 30 40
KEY
Q - Gasoline Storage Tank
C - Crude Oil Storage Tank
N - Naphtha Storage Tank
Ex. 15 C * 15 Crude Oil Storage Tanks
FIGURE 8-1 GEOGRAPHICAL DISTRIBUTION OF AFFECTED EXTERNAL
FLOATING ROOF STORAGE TANKS IN OHIO
8-4
-------
TABLE 8-2. SIZE DISTRIBUTION OF AFFECTED
GASOLINE STORAGE TANKS
Storage Capacity Average Value Number of Tanks
(xlO3 gallons) (xlO3 gallons) Sample Population
aExtrapolated from the sample data.
a
Less than 950
950 -
1,900 -
2,850 -
3,800 -
4,750 -
5,700 -
6,650 -
1,900
2,850
3,800
4,750
5,700
6,650
7,600
475
1,425
2,375
3,325
4,275
5,225
6,175
7,125
56
50
19
30
10
9
23
1
198
74
67
25
40
13
12
31
1
263
8-5
-------
TABLE 8-3. MODEL TANK PARAMETERS AND EMISSION DATA FOR GASOLINE STORAGE TANKS
cr>
Storaqe Capacity
Model Tank (x!0s gallons)
#1
#2
#3
#4
#5
#6
#7
#8
Uncontrol
Potential
475
1,425
2,375
3,325
4,275
5,225
6,175
7,125
led emissions from the
reduction in emissions
Diameter
45
78
100
119
123
136
148
159
affected EFR
Heig
40
40
40
40
48
48
48
48
gasoli
from the affected
Number of
Storage
Tanks
ht Represented
74
67
25
40
13
12
31
1
ne storage tanks = 2
EFR gasoline storage
Uncontrolled
Emissions
(tons/yr/tank)
4.42
7.66
9.82
11.69
12.08
13.36
14.54
15.62
,337 tons/yr.
tanks = 1,753
Control
Efficiency3
75
75
75
75
75
75
75
75
tons/yr.
Emission
Reduction
(tons/yr/tank)
3.32
5.75
7.37
8.77
9.06
10.02
10.91
11.72
3Assuming welded tanks with rim-mounted secondary seals.
-------
TABLE 8-4. RELATIONSHIP TO ESTIMATE UNCONTROLLED VOC
EMISSIONS FROM EXTERNAL FLOATING ROOF TANKS3
E— T pq-
?f
?7 Y in 4 , , _,. vHvM
j/ x iu 1 + (1. 068P )o 5 ^ x uf x nf
KXS
Where
Ef = Emissions from the model tank
E = Emissions from test tank at 5.0 p.s.i., Ibs/day
(estimated to be 7.3 Ibs/day based on data in Reference
3 and an average wind speed of 10 m.p.h in ohio)
P- = Vapor pressure of product stored in the model tank
D- = Diameter of the model tank, feet
M. = Hydrocarbon vapor molecular weight = 65
aSource: Reference 3.
8-7
-------
TABLE 8-5. EMISSION DATA AND MODEL PLANT PARAMETERS
AFFECTED CRUDE OIL AND NAPHTHA STORAGE TANKS
Number of tanks
Model tank capacity (103 gallons)
True vapor pressure (psi)
Model tank dimensions
Crude Oil
12
3,275
2.0
Naphtha
4
3,051
3.5
Total
16
Diameter (feet) 118 114
Height (feet) 48 48
Model tank uncontrolled emissions (tons/yr) 4.1 7.3
Total uncontrolled emissions (tons/yr) 49.2 29.2 78.4
Control efficiency (%) 75 75
Emission reductions (tons/yr) 37 22 59
8-8
-------
installed on external floating roofs. It extends from the top of the
shoe to the tank wall. However, shoe-mounted secondary seals do not
provide any control for VOC emissions escaping through any opening in
the primary seal envelope.
A second type of secondary seal is a rim-mounted secondary seal. This
type of seal is continuous and extends from the floating roof to the
tank wall, covering the entire primary seal. This secondary seal can
effectively control VOC emissions escaping from the small vapor space
between the primary seal and the wall. It can also control VOC emis-
sions escaping through any openings or tears in the primary seal en-
velope that would permit direct contact with the atmosphere. A rim-
mounted secondary seal is therefore a more efficient control for ex-
ternal floating roof tanks. Figure 8-2 shows how a rim-mounted secon-
dary seal works when installed over various types of primary seals.
The proposed Ohio EPA regulation to control VOC emissions from external
floating roof tanks requires these tanks to be retrofitted with a rim
mounted secondary seal. The control efficiency of this secondary seal
depends on the tank construction and also on the type of primary seal in
the tank. The EPA Control Technique Guideline (CTG) document on the
control of VOC emissions from external floating roof tanks specifies the
following control efficiencies for rim-mounted secondary seals for three
combinations of tank construction and type of primary seal:
Case I - Welded tank with the following primary seals—shoe seal,
liquid-mounted foam seal, or liquid-mounted liquid-filled
seal - 75 percent control efficiency.
Case II - Welded tank with a vapor-mounted foam primary seal— 84 -
88 percent control efficiency.
Case III - Riveted tank with a metallic shoe primary seal -- 45 per-
cent control efficiency.
8-9
-------
RIM-MOUNTED
SECONDARY SEAL
a. Shoe seal with rim-mounted secondary seal
^
TANK
WALL
RIM-MOUNTED
SECONDARY SEAL
* • • • r % Y--• 4
2-.VK&?
-•i.V* !••»••
W'*: :'/»;•'
?r:vV/«.>Av
^
-------
Personal communication with a supplier of storage tanks4 indicated that
welded tanks were the most common type of tanks being erected and used
in the industry in the large-size range. Therefore, it was assumed that
the affected tanks are welded tanks with any of the following primary
seals—shoe seal, liquid-mounted foam seal or liquid-mounted liquid-
filled seal..
8.4 Cost Analysis
The .costs of controlling VOC emissions from the affected tanks were
estimated by formulating model tanks to represent the whole population.
As mentioned earlier, eight model tanks were developed for the affected
gasoline storage tanks and one each for the crude oil storage and
naphtha storage tanks. Technical parameters for these model tanks are
presented in Table 8-3 (for gasoline storage tanks) and in Table 8-5
(for crude oil and naphtha storage tanks). The capital costs of in-
stalling a rim-mounted secondary seal on these model tanks were esti-
mated by contacting a vendor of these seals (Chicago Bridge and Iron
Company).4 The installed capital costs basically depend on the linear
circumferential footage and thus on the diameter of the tank. The
capital cost per foot of tank diameter tends to decrease as tank dia-
meter increases. This is mainly because a significant fraction of the
capital costs are fixed costs, which are independent of tank size.
Therefore, the capital cost value per unit diameter tends to be smaller
for larger tanks.
The fixed cost components of the capital costs of installing a secondary
seal include (a) analyzing engineering aspects of the control equipment,
(b) reviewing the tank measurements prior to finalizing the secondary
seal, and (c) moving the project crew from one job site to the next.
Since the cost analysis had to be done for 10 model tanks with different
diameters, ETA Engineering developed a graphical relationship between
the tank diameter and the installed capital costs per unit tank dia-
meter. Cost data provided by the Chicago Bridge and Iron Company were
used in developing this relationship, which is shown in Figure 8-3. The
cost relationship presented in Figure 8-3 was based on the following
assumptions:
8-11
-------
2SO
« 200-
9
a
o
O
o
*-
ai
C
ISO-
10 O-
50 100
Tank Diameter (feet)
ISO
FIGURE 8-3 RELATIONSHIP BETWEEN TANK DIAMETER AND
INSTALLED COST OF SECONDARY SEAL
8-12
-------
a. Wage rates in the Cleveland locale were used to estimate the
installation costs.
b. It was assumed that the tank roof has eight inches of rim
space for installing the secondary seal.
c. It was assumed that a small angle would be attached to the
existing rim of the tank so that the secondary seal could be
attached with clips.
d. Finally, the installed cost estimates assume the retrofitting
of a single tank per site. If a group of tanks are to be
retrofitted with secondary seals at one particular site, the
installed cost value per tank would probably be reduced by 5
to 10 percent.
The cost relationship presented in Figure 8-3 was used to estimate the
model tank costs and the total installed capital costs for all the
affected tanks. These cost estimates are presented in Table 8-6 for
affected gasoline storage tanks and in Table 8-7 for affected crude oil
storage and naphtha storage tanks.
In addition to estimating the capital costs of installing secondary
seals on affected external floating roof tanks, the cost incidence was
also presented in terms of net annualized costs. The net annualized
costs include the annual operating and maintenance costs and the fixed
capital charges. Fixed capital charges consist of a capital recovery
factor for depreciation and interest charges and a factor for insurance,
taxes and administrative overheads (4 percent of capital costs). The
capital recovery factor was estimated to be 17.7 percent of the capital
costs based on 10 years useful equipment life and a 12 percent interest
rate. The annual operation and maintenance costs were estimated at 5
percent of the installed capital cost plus an annual inspection charge
of $200 per tank. The product credit considered in the net annualized
costs was estimated by using the following product values based on the
8-13
-------
TABLE 8-6. CAPITAL COST ESTIMATES FOR INSTALLING SECONDARY
SEALS ON AFFECTED GASOLINE STORAGE TANKS
Model Tank
#1
#2
#3
#4
#5
#6
#7
#8
Diameter
(feet)
45
78
100
119
123
136
148
159
Number of
Storage Tanks
Represented
74
67
25
40
13
12
31
1
263
Installed Capital
Cost Per Tank
(103 $/tank)
9.7
14.7
18.0
20.9
21.5
23.5
25.5
27.0
Total Installed
Capital Costs
(103$)
718
985
450
836
280
282
791
27
4,369
8-14
-------
TABLE 8-7. CAPITAL COST ESTIMATES FOR INSTALLING SECONDARY SEALS
ON AFFECTED NAPHTHA AND CRUDE OIL STORAGE TANKS
Crude Oil Naphtha Total
Model tank capacity (10s gallons) 3,275 3,051
Model tank diameter (feet) 118 1,141
Number of storage tanks represented 12 4 16
Model tank installed capital cost (103 $) 20.8 20.2
Total installed capital costs (103 $) 250 81 331
8-15
-------
data in the Wall Street Journal on the cash prices of commodities as of
January 1981:
Gasoline - $0.98/gallon
Crude oil - $32.0/barrel
Naphtha - $0.98/gallon
A summary of the control cost estimates for all the affected tanks is
given in Table 8-8. The total installed capital costs for all the 279
affected storage tanks were estimated to be approximately $4.7 million.
The corresponding net annualized costs after considering the annual
petroleum savings were estimated to be approximately $745,000. The
Table also gives a value for the cost-effectiveness of control in terms
of dollars per ton of reduction. Based on a total reduction of 1,812
tons of VOC per year (1,753 tons/yr for gasoline storage tanks and 59
tons/yr for crude oil and naphtha storage tanks), the cost-effectiveness
of control was estimated to be $411 per ton of reduction in emissions.
8-16
-------
TABLE 8-8. CONTROL COST SUMMARY FOR EXTERNAL FLOATING
ROOF PETROLEUM STORAGE TANKS
Number of affected tanks
Installed capital costs (103 $)
Annual i zed capital charges (103 $)a
Annual maintenance costs (103 $)
Annual petroleum savings (103 $)c
Net annual ized costs (103 $)
Gasoline
263
4,369
948
271
(547)
672
Crude Oil
12
250
54
15
(12)
57
Naphtha
4
81
18
5
(7)
16
Total
279
4,700
1,020
291
(566)
745
Cost-effectiveness ($ per ton of
reduction) 383 1,540 727 411
aBased on a capital charge factor of 21.1 percent of installed
capital costs for interest, depreciation, taxes, and insurance
(12 percent interest rate and seal replacement life of 10
years).
Five percent of installed capital cost plus annual inspection
charge of $200 per tank (source: Reference 5).
cBased on a reduction of 1,753 tons/yr in gasoline emissions
and 59 tons/yr in crude oil/naphtha emissions. The credit was
calculated at $0.98/gallon for gasoline and $32/barrel for
crude oil. Average densities were assumed to be 6.2 Ibs/gallon
and 7.2 Ibs/gallon for gasoline and crude oil, respectively.6
8-17
-------
8.5 References
1. Pacific Environmental Services, Inc., Evaluation of Hydrocarbon
Emissions from Petroleum Liquid Storage. EPA-450/3-78-012,U.S.
Environmental Protection Agency, Research Triangle Park, North
Carolina, March 1978.
2. Personal communication with Mr. W. Jures of Ohio EPA, Columbus,
Ohio, May 1981.
3. Control of Volatile Organic Emissions .from Petroleum Liquid Storage
in External Floating Roof Tanks"! EPA-450/2-78-047, (LS.Environ-
mental Protection Agency, Research Triangle Park, North Carolina,
December 1978.
4. Personal communication with Mr. Jay Wodarski of Chicago Bridge and
Iron Company, Chicago, Illinois, October 1981.
5. Hydrocarbon Control Strategies for Gasoline Marketing Operations,
EPA-450/3-78-017,U.S.EnvironmentalProtection Agency,Research
Triangle Park, North Carolina, April 1978.
6. Marks' Standard Handbook for Mechanical Engineers, Eighth Edition,
McGraw-Hill Book Company, New York, New York.
8-18
-------
9.0 DRY CLEANERS
9.1 INTRODUCTION
The dry cleaning industry provides both cleaning and rental services
for apparel and other fine goods. The industry is divided into
coin-operated, commercial, and industrial segments, based on the types of
services offered. Coin-operated dry cleaning facilities are usually part
of a laundromat and operate on either an independent or franchise basis.
They provide low cost, self-service dry cleaning without pressing,
spotting, or other associated services. Commercial dry cleaning plants
are the most familiar type of facilities, offering the normal services
associated with cleaning and preparing soiled apparel and other items for
re-use. They include small, independent neighborhood shops, franchised
dry cleaners, and specialty cleaners. Industrial dry cleaners are the
largest dry cleaning plants, predominantly supplying cleaning and rental
services for uniforms and treated dust control items to business,
industrial, or institutional customers.
Dry cleaning is essentially a waterless process in which items are
cleaned with a solvent rather than with detergent and water. The
solvents are catagorized as either petroleum or synthetic solvents. The
RACT regulation applies to certain dry cleaning plants that utilize the
synthetic solvent perchloroethylene (perc), which is considered a
volatile organic compound. Based on 1976 Bureau of Census data and
estimates from industry spokesmen, the nationwide numbers of commerical
and industrial perc dry cleaning establishments are 15,060 and 239,
respectively.1 National perc emissions are about 135,580 tons for
commercial and 14,990 tons for industrial dry cleaning plants.2
Ohio's RACT regulation applies to perc dry cleaning establishments
located in the 18 designated urbanized counties and those plants located
elsewhere in the state which have potential annual atmospheric emissions
of perc vapor exceeding 100 tons. Exempt from the regulation are:
dry cleaning plants that do not use perc; coin-operated dry cleaning
9-1
-------
facilities; and facilities at which it can be demonstrated to the Ohio
EPA that a carbon adsorber cannot be installed due to insufficient steam
capacity and/or inadequate space. The estimate of affected facilities
was not reduced due to the latter exemption possibility since it is
expected that very few establishments will seek an exemption for this
reason.
The regulation, presented in Appendix B, requires that:
t Dryer exhaust be vented through a carbon adsorber that emits no
more than 100 parts per million of perc by volume;
• Dryer exhaust be vented through a device which is, in the
judgment of the OEPA, at least as effective in controlling perc
emissions as the above-mentioned carbon adsorber;
t Waste from any diatomaceous earth filter used to filter perc
cannot contain more than 25 percent of perc by weight;
• Waste from any solvent still used to distill perc cannot contain
more than 60 percent of perc by weight;
• Any disposable filter cartridge used to filter perc be drained in
its filter housing at least 24 hours; and
• Any equipment leaking perc liquid not be operated until the leak
is repaired.
9.2 CHARACTERIZATION OF AFFECTED FACILITIES
9.2.1 Estimated Number of Ohio Commercial and
Industrial Dry Cleaning Plants
The total number of commercial and industrial dry cleaning establishments
in Ohio was taken from data contained in the Bureau of the Census
publication County Business Patterns 1978-Ohio. For the entire state,
a total of 871 plants is listed under Standard Industrial Classification
(SIC) code 7216, titled Dry Cleaning Plants, Except Rugcleaning. These
establishments include small independent neighborhood shops, franchised
shops, and specialty cleaners which clean leather and other fine goods.
9-2
-------
The same census publication lists 52 establishments under SIC code
7218, Industrial Launderers. The definition of SIC code 7218 is as
follows:
Establishments primarily engaged in supplying laundered or
dry-cleaned work uniforms; laundered wiping towels; safety
equipment (gloves, flame resistant clothing, etc.); dust
control items, such as treated mats or rugs, mops, dust tool
covers and clothes and other selected items to industrial or
commercial users. These items may belong to the industrial
launderers and be supplied to users on a rental basis, or they
may be the customer's own goods. Establishments included in
this industry may or may not operate their own laundry or
drycleaning facilities.3
Ohio regulations apply to all perchloroethylene (perc) dry cleaning
establishments, commercial and industrial, located in the eighteen
urbanized counties, and those establishments outside these counties that
have a potential to emit at least 100 tons per year of perc vapors. SIC
code 7216 facilities located in the eighteen Ohio counties are summarized
in Table 9-1. Four of the eighteen counties, Clermont, Greene, Medina,
and Wood each have less than fifty paid employees in the commercial dry
cleaning industry. For the purposes of this study, it is assumed that
these counties each have 49 paid employees in the commercial dry cleaning
industry. It is also assumed that each of the four counties have seven
commercial dry cleaning establishments, the same number as reported for
Portage and Warren counties, which have between 50 and 75 paid employees
in this industry category. Therefore, it is estimated that there are
5,425 paid employees working in 681 commerical dry cleaning plants in the
eighteen Ohio counties.
9-3
-------
TABLE 9-1
SIC CODE 7216-DRY CLEANING FACILITIES IN EIGHTEEN OHIO COUNTIES
NUMBER OF ANNUAL PAYROLL NUMBER
COUNTY
Butler
Clermont3
Cuyahoga
Franklin
Greene3
Hamilton
Lake
Lorain
Lucas
Mahoning
Medina3
Montgomery
Portage
Stark
Summi t
Trumbull
Warren
Wood3
Total
NOTE: Data
EMPLOYEES (thousands of dollars) 1-4
202
49b
1216
818
49b
755
114
147
381
232
49b
498
74
264
388
83
57
49b
5425
obtained
770
-
7176
5024
-
4065
466
785
1922
1360
-
2976
436
1362
1957
354
276
-
from County Business
7
-
79
32
-
56
7
9
18
18
-
16
2
14
32
12
4
-
Patterns-Ohio,
OF ESTABLISHMENTS BY EMPLOYMENT SIZE CLASS
5-9
5
-
35
35
-
29
6
6
6
3
-
23
3
14
15
2
1
-
1978.
10-19
2
-
24
21
-
14
3
3
13
5
-
7
-
6
13
1
1
-
20-49 50-99 100-249
1 1
_
10 2 -
^ 1
w A
_
5 1
1
2
5
3
_
5 1
2
2
2
1
1
_
TOTAL
16
7C
150
94
7C
105
17
20
42
29
7C
52
7
36
62
16
7
7C
681
3Data unavailable, indicating less than 50 salaried employees in the county.
bNumber of employees assumed to be 49.
cTotal number of establishments assumed to be 7, equaling that of either Portage or Warren county.
-------
In 1978, self-employed persons comprised about 8 percent of the nation's
paid civilian employment.4 There may be commercial dry cleaning
establishments in Ohio, not reported in the county business patterns
data, that are totally owned and operated by self-employed persons
on a family-owned or partnership basis. It is assumed that the
number of these establishments is negligible compared to the number
of establishments having paid employees. Therefore, cost estimates
presented in this study will be based on commercial dry cleaners having
one or more paid employees.
Table 9-2 summarizes the location and size of 41 of the 52 Ohio
industrial laundering facilities. The remaining 11 establishments have
location and employment characteristics such that no county has at least
50 paid workers in the industrial laundering industry. Thirty-eight of
the 41 industrial launderers are located in one of the 18 urban counties.
The definition of SIC code 7218 states that industrial laundering
plants may or may not have drycleaning equipment. In 1979, the Institute
of Industrial Launderers estimated that 40 to 45 percent of industrial
laundering plants had drycleaning equipment.1 In this study, it is
assumed that 42.5 percent, or 22 of the Ohio industrial laundering plants
also perform drycleaning. It is further assumed that the industrial
laundering and drycleaning operations are conducted by establishments
having at least one paid employee. Therefore, cost estimates presented
in this study will be based on the estimated 22 industrial drycleaning
facilities in the state of Ohio. Since the number of laundering plant
employees totally or partially involved in a facility's dry cleaning
operation is highly variable, state wide employement in industrial dry
cleaning is not estimated.
9.2.2 Estimated Number of Perchloroethylene Dry Cleaning Plants
There are an estimated 681 commercial dry cleaning plants in the 18
Ohio counties and an estimated 22 industrial laundering plants in the
state which perform dry cleaning. In 1979, the International Fabricare
9-5
-------
TABLE 9-2
SIC CODE 7218-INDUSTRIAL LAUNDERERS IN ALL OHIO COUNTIES
NUMBER
ANNUAL PAYROLL
NUMBER OF
ESTABLISHMENTS BY
EMPLOYMENT SIZE CLASS
COUNTY
Allen3
Auglaize3
Clark3
Cuyahoga
Franklin
Hamilton
Lorain
Lucas
Ma honing
Montgomery
Stark
Summit
Total
NOTE: Data
OF EMPLOYEES
b
b
b
647
b
401
b
313
b
b
91
b
obtained from
(thousands of
b
b
b
6953
b
3423
b
2975
b
b
923
b
County Business
dollars) 1-19 20-99
1
1
1
2 3
1 1
5
-
5 2
1
1 3
3
-
Patterns-Ohio, 1978.
> 100
-
-
-
2
2
2
1
1
-
2
-
1
TOTAL
1
1
1
7
4
7
1
8
1
6
3
1
41
aNot included among the 18 urban counties.
blnformation withheld by the Census Bureau to avoid disclosure of operations of
individual establishments.
9-6,
-------
Institute (IFI) estimated that approximately 73 percent of the nation's
commercial dry cleaning establishments use perc. In the same year, the
Institute of Industrial Launderers (III) estimated that 50 percent of the
industrial launderies providing dry cleaning services utilize perc.1
The IFI and III believe these estimates are still representative of their
respective industries.5»6
The Ohio Cleaners Association (OCA), which is comprised of approximately
350 member establishments, has never maintained records of the type of
solvent employed by its members.7 In this study, therefore, it is
assumed that the IFI and Ill's national estimates of the percentages of
commercial and industrial dry cleaners using perc are representative of
industry conditions in Ohio. Thus, the estimated number of commercial
perc dry cleaners in the 18 Ohio counties is 497, while an estimated 11
industrial dry cleaning plants in Ohio use this cleaning agent.
9.2.3 Estimated Number of Plants Affected by Ohio's RACT Regulation
Estimates of uncontrolled and controlled perc emissions from dry cleaning
plants are based on the weight of clothes processed and emission factors
for the various steps in the dry cleaning and solvent recovery processes.
Annual throughput of clothes and solvent mileage data were unavailable
from our research. The Ohio Cleaners Association (OCA) readily admits
that it has never attempted to keep records of perc emission control
equipment in service or records of weight of clothes processed and
solvent mileage of its member establishments.7 Therefore, the number
of dry cleaners outside the 18 counties affected by the regulation must
be estimated from published ranges of annual clothes throughput and
emission factors for "typical" dry cleaning operations.
Various ranges of annual clothes throughput are found in the literature
for both commercial and industrial dry cleaning operations. In a
1979 study, commercial dry cleaners are reported to process a weight
of clothes ranging from less than 9,000 to over 45,000 kg per year.3
According to the IFI, annual clothes throughput varies from less than
9-7
-------
23,000 to 113,000 kg.1 Model commercial plant throughput data used in
this study are within these ranges. For the industrial segment of the
dry cleaning industry, estimates of annual throughput range from 240,000
to 700,000 kg.2 Modeled Ohio industrial dry cleaning plant throughput
is well within this range.
Sources of perc emissions include: dryer exhaust; cooked or uncooked
filter muck; alternative drained or undrained filter cartridges; solvent
still waste; and miscellaneous losses (primarily liquid leaks). Perc
emission factors found in the literature for commercial or industrial dry
cleaning plants also exhibit variability, as indicated in Table 9-3. The
CTG document and Background Information Document (BID) for the proposed
New Source Performance Standard (NSPS) state that "well operated" plants
may lose about 3 to 23 kg of perc per 100 kg of clothes processed, with
industry average loss estimates of either 10.6 to 12.0 kg of perc.1'2
Both documents caution that these emission factors are for "well-operated
plants". Apparently the well operated plant may or may not have a
dryer exhaust vapor control system, but does have some capability for
solvent recovery from filtered materials. Another U.S. EPA publication,
Compilation of Air Pollutant Emission Factors - AP42, presents a range of
perc loss from a "typical" dry cleaning plant from 4.4 to 25.1 kg per 100
kg of clothes cleaned.8
In this study, the number of Ohio dry cleaning plants capable of
emitting 100 tons of perc annually are estimated from maximum clothes
throughput and perc emission rate data obtained from the aforementioned
publications. The resulting annual perc emission estimates, summarized
in Table 9-4, indicate that it is extremely unlikely that a commercial
dry cleaning plant could emit 100 tons of perc on an annual basis.
However, the 100 ton per year emission figure could be achieved at an
industrial dry cleaning operation. Therefore, it will oe assumed that
the set of perc dry cleaning plants affected by Ohio's RACT regulation
consists of:
9-8
-------
TABLE 9-3
PERCHLOROETHYLENE EMISSION FACTORS FROM COMMERCIAL OR
INDUSTRIAL DRY CLEANING ESTABLISHMENTS
EMISSION SOURCE
EMISSION FACTORS (KG/100 KG OF CLOTHING)
FOR WELL3FOR5
OPERATED PLANTS TYPICAL PLANTS
Dryer Exhaust:
without carbon adsorber 7.0
with carbon adsorber 0.3
Retention in Filter Muck:
without cooking or draining 14.0
rigid tube filter with muck cooker 1.6
regenerative filter with muck cooker 1.0
Retention in Drained Cartridge Filters 0.6
Retention in Still Residue 1.0°
Miscellaneous Leaks 1.0
Total Potential Emissions 2.9e-23f
8.0
0.3
14.0
1.6
1.0
1.1
1.5
4.4e-25.1f
References 1 and 2.
bReference 8.
CNO EPA test data. Value assumed by EPA.
dBased on IFI estimate.
eAssuming carbon adsorber unit and solvent recovery from filtered materials.
fAssuming no carbon adsorber unit and uncooked filter muck.
9-9
-------
TABLE 9-4
MAXIMUM ESTIMATED PERCHLOROETHYLENE EMISSIONS FROM TYPICAL
COMMERCIAL AND INDUSTRIAL DRY CLEANING PLANTS
TYPE OF
PLANT
Commercial
Industrial
MAXIMUM CLOTHES3
THROUGHPUT (kg/yr)
113,000
700,000
PERC EMISSION5
(kg/100 kg of clothes)
25.1
25.1
ESTIMATED MAXIMUM
PERC EMISSIONS
(kg/yr) (tons/yr)
28363.0 31.3
175700.0 193.7
model plants.
bWorst case perc emissions from Table 9-3.
9-10
-------
t All commercial perc dry cleaners in the 18 urban counties;
and
t All industrial perc dry cleaners located in the state.
9.2.4 Model Plant Formulation
Model plants are used as a basis for estimating the economic impact
of Ohio's RACT regulations on existing commercial and industrial perc dry
cleaning plants. Model plant parameters summarized in Table 9-5 are
based upon models already developed in previous U.S. EPA studies of
the perc dry cleaning industry.1*2 In the commercial sector of the
industry, about 25 percent of the machines are dry-to-dry type, and the
remainder are transfer machines. Two machine sizes, 11 and 23 kg (25
and 50 pound capacity), are considered to be representative of the sizes
of dryers generally found in the commercial plants. The representative
industrial dryer's 113 kg capacity is based on information obtained from
the Institute of Industrial Launderers.l
Annual throughput data are not compiled at many commercial and industrial
dry cleaning plants. Therefore, estimates of the weight of materials dry
cleaned annually at these facilities must be incorporated as model plant
parameters. Estimated throughput data used in this study are model plant
parameters utilized in the U.S. EPA's CT6 document.2
9.3 ALTERNATIVE CONTROL MEASURES
Dry cleaning is a process in which clothes are primarily cleaned with an
organic solvent rather than with soap and water. A small amount of water
and detergent may be added to the solvent to remove water soluble
materials from the clothes. The principal steps in the process are
analagous to those of laundering in water. Figure 9-1 is a schematic of
a perc dry cleaning process. First, clothes and solvent are agitated in
a washer. After washing is completed, the clothes are spun as in a
washer spun cycle to remove solvent. This is called the extraction step.
After extraction, solvent is filtered and distilled to remove impurities
9-11
-------
TABLE 9-5
MODEL PLANT PARAMETERS FOR OHIO COMMERCIAL AND INDUSTRIAL
PERCHLOROETHYLENE DRY CLEANING PLANTS
PARAMETER
COMMERCIAL PLANTS
INDUSTRIAL PLANTS
Machine Capacity (kg/load)
Machines per Plant
Annual Washer Loads
Annual Operation (days/yr)
Annual Throughput (kg/yr)
11 23
1 1
2210 2113
250 250
24310 48600
113
1
5007
250
565790
.9-12
-------
gjs/solviint
10
i
1
i
. washer/extractor . filter
^ '
charged pure
solvent solve
tank tank
'" '' i
detergent
- J-v- y- emissions
• desorptlon
^~K
nt
$— ^
>
1
-*±-) dryer —
1
filtered
solvent
^ solvent
1 separate
pc
[condense
/
' /'
heat >Hst1llat1on
distillation'
bottoms!
1
I
solvent
t
stfll
— 7 'esldue
itorage
rj ^ water
3~^-.^
1 Y
muck
cooker ^ heat
j-rt t
! filter
1 muck
storage
s
X
Xx
X .
^* disposal
— «n»4 1^
i
• — • ^4 Condenser | j
N'
1
separator I ' ]
JL
±
Mater
|steam
~ _ v carbon I
•^ adsorber c-1
f
* dl*P"il condenser
FIGURE 9-1
PERCHLOROETHYLENE DRY CLEANING PLANT FLOW DIAGRAM
-------
before being returned to the system. The filtered solids (muck) contain
solvent, some of which can be removed and returned to the system. After
solvent wash and extraction, the clothes are tumbled dry. During the
drying cycle, much of the evaporated solvent can be recovered and
returned to the system. Remaining solvent in the clothes is reduced by
venting air through the clothes. This final step is called aeration or
deodorization.
Ohio regulations for control of perc emissions from commercial and
industrial dry cleaning facilities specify that dryer exhaust is to be
vented through a carbon adsorber or another device capable of limiting
emissions to 100 ppm of perc by volume. There are several alternate
control devices, categorized as refrigeration or scrubbing systems, which
are claimed by their manufacturers to be equivalent to carbon adsorption
for perc emissions control. Several control alternatives are discussed
below.
9.3.1 Carbon Adsorption
Activated carbon has been used in a variety of applications for the
removal of organic compounds from gaseous streams by adsorption.
Adsorption is the property of a surface to retain molecules of a fluid
which have contacted the surface. Perc can be retained by activated
carbon very easily since the adsorptive capacity of carbon with respect
to perc is about 20 percent by weight. For example, a 100 kilogram
(kg) bed of activated carbon can adsorb about 20 kg of perc before
regeneration is required.
In the drying cycle, a blower forces solvent-laden air through the
carbon adsorption unit. A typical commercial adsorption unit has one
carbon cannister which is usually desorbed daily. A large industrial
adsorption unit may contain multiple canisters so that one carbon bed can
be used while another is being regenerated. Desorption is accomplished
by passing steam through the carbon bed. Vaporized solvent is picked up
by the steam, recovered downstream in a condenser, separated from the
water, and then returned to the perc storage tank.
9-14
-------
For a dry cleaning operation involving the manual transfer of clothes
from a washer to a dryer unit, the Occupational Safety and Health
Administration (OSHA) requires that a current of fresh air be provided
to reduce solvent vapor inhalation by the operator. The required
ventilation may be provided by a fan which draws air through a duct at
the dryer door lip or by venting directly through the dryer door. This
solvent-laden airstream is then vented to the carbon adsorber. Floor
vents may be installed around the dryers and next to perc storage tanks
in order to collect fugitive emissions and vapors from solvent spills.
These emissions can also be directed to the adsorber unit. Carbon
adsorption can result in better than 96 percent emission reduction for
all gas streams passed through the adsorber unit.1
The emission limitation of 100 ppm for the dryer exhaust from perc
dry cleaning systems can easily be achieved by venting solvent-laden
airstreams through a properly designed and operated activated carbon
adsorption system. Factors which can interfere with maintaining
compliance with the emission limitation include:
• Insufficient adsorptive capacity of the activated carbon bed due
to defects on the adsorbing material;
• Leakage in the piping, adsorption unit cannister, or ductwork;
• Variations in humidity of the airstream to the adsorber unit;
• Adsorption of contaminants that may be present in the air stream
during adsorption or in the steam used for desorption;
• Lint accumulation on the carbon particles; and
• Service life of the activated carbon, which is a function of the
number of adsorption/desorption cycles.1 While equipment vendors
claim a 10 to 15 year service life for the activated carbon in
similar applications service life may be as low as 3 to 5 years.9
9-15
-------
9.3.2 Refrigeration Systems
Two St. Louis based firms, Spencer America Corporation and Kleen-Rite
Incorporated, are manufacturers/distributors of refrigeration systems
that are claimed to be capable of reducing perc emissions from the
dryer exhaust to 100 ppm or less.
For the Spencer Resolver, sol vent-laden air from the aeration phase of
the cleaning cycle is ducted to a cold storage system which consists
of a bed of stones and refrigerant coils. Solvent condenses and drips
into a perc/water separator below the bed. In contrast to carbon
adsorption systems, air leaving the bed of the refrigeration system is
not vented to the atmosphere. Instead, the air is returned to the dryer
unit.
The Kleen-Rite models KR II and KR III refrigeration systems condense
solvent from perc-laden air streams during both the drying and aeration
phases of the cleaning cycle. These airstreams are passed through
finned-tube refrigerated condensers. Condensed solvent drips into a
perc/ water separator below the condensers. A portion of the cold air
exiting the condensers is recirculated, while the remainder is vented to
the atmosphere.
There are perc emission points that would normally be ducted to a carbon
adsorption unit that would not be controlled by either manufacturer's
refrigeration system. For example, floor vents that would be ducted to
a carbon adsorber could not be ducted to a refrigeration system without
adversely affecting system efficiency. During dry cleaning operations
involving the hand transfer of clothes from the washer to the dryer unit,
perc vapors are normally drawn into the dryer unit and then to the carbon
adsorber. The refrigeration systems would be operational only during the
drying and/or aeration phases of the cleaning cycle, and not during the
physical transfer phase.
9-16
-------
9.3.3 Scrubber System
Another alternative to carbon adsorption is the Solvation (registered
trademark) unit which was first patented in England and is sold by the
Diversitron Corporation in the United States. In 1979, this country's
first Solvation unit was installed. The Solvation unit operates during
the aeration phase of the dry cleaning process. Solvent-laden air passes
through a scrubber consisting of screens and baffles submerged in water.
Air bubbles are formed and mass transfer of perc occurs from the bubbles
to the water. The primary force for mass transfer of perc is claimed to
be the formation of a perc/water azeotrope. An azeotrope is a liquid
mixture having a constant boiling point and capable of distilling off in
a fixed ratio without decomposition. The solvent-rich azeotropic vapor
stream is passed over cooling coils where perc condensation occurs.
Separation of perc and water takes place in the unit's water separator.
The vapor stream, now having a relatively low perc concentration, is
returned to the Solvation Tank for renewed azeotropic conditioning. Like
the refrigeration systems, the Solvation unit cannot be used to control
perc emissions from floor vents or from the physical transfer of clothes
to the cleaning system's dryer unit. The manufacturer claims that
operation of the Solvation unit increases the average weight of clothes
cleaned per gallon of perc by at least 100 percent.10
9.3.4 Control of Perc Emissions From Sources Besides Dryers
The Ohio RACT II regulation for control of solvent emissions from
perc dry cleaning facilities addresses emission points other than dryer
exhaust. The regulation states that:
• Waste from diatomaceous earth filters used to filter perc may not
contain more than 25 percent by weight of perc;
• Disposable filter cartridges used to filter perc must be drained
in their filter housing for at least 24 hours before being
discarded;
• Waste from solvent stills used to distill perc may not contain
more than 60 percent by weight of perc; and
t Equipment leaking perc liquid cannot be operated until the leak
is repaired.
9-17
-------
Techniques for control of perc emissions from these emission points
are discussed in the following paragraphs.
Some of the soils removed from fabrics during the dry cleaning process
are not soluble and must be filtered from the solvent. Some filters
may contain activated carbon. The filter muck (diatomaceous earth,
carbon, lint, detergent) also contains solvent which is recovered in
some perc plants by cooking solvent out of filtered materials. One
alternative is the use of cartridge filters which the regulations state
must be drained in their housing for at least 24 hours prior to disposal.
The International Fabricare Institute (IFI) has suggested to the U.S. EPA
that cartridge draining may also be accomplished in another properly
sealed container. This is particularly beneficial for plants having only
one cartridge housing unit.^ Another alternative to muck cooking or
cartridge draining is solvent recovery offsite by a solvent disposal
vendor.
In addition to insoluble residue removed by filtration, a buildup
of soluble residue (oils, fats, and greases) occurs in the solvent.
These are eliminated from the solvent by distillation. In some perc
plants, the distillation unit is used to separate solvent from both
soluble and insoluble residue. Solvent losses from distillation bottom
disposal can be reduced in "oil cookers" to levels below 1 kg per 100 kg
of clothes cleaned if the distillation unit and oil cooker are properly
operated and not prematurely shutdown.2
The state's regulations require repair of liquid perc leaks prior to
resumption of dry cleaning operations. Liquid leaks are characterized by
a brown residue that can be detected during an equipment inspection. The
following inspection checklist can be used to facilitate liquid perc leak
detection.2
9-18
-------
Liquid leakage areas include:
• Hose connections, unions, couplings and valves;
• Machine door gasket and seating;
• Filter head gasket and seating;
• Pumps;
• Base tanks and storage containers;
• Water separators (lost in water due to poor separation);
• Filter sludge recovery (lost in sludge by improper recovery);
t Distillation unit;
• Divector valves;
• Saturated lint from lint basket; and
• Cartidge filters.
9.3.5 Estimated Annual Perch!oroethylene Emissions From Affected
Plants Before and After Implementation of RACT
Based on estimates developed in previous subsections, approximately
497 commercial and 11 industrial perc dry cleaning facilities in Ohio
will be subjected to the state's regulation. The total decrease in perc
emissions from affected facilities will in part depend on the types of
perc emission control equipment already installed and utilized at these
facilities and on the extent to which good housekeeping procedures are
followed to further reduce emissions through prompt detection of liquid
leaks.
Factors complicating the estimation of current perc emissions from
plants affected by the RACT regulation are: (1) the degree of utiliza-
tion and actual efficiency of installed carbon adsorber systems; (2)
the lack of national or Ohio estimates of the number of affected plants
equipped with refrigeration or scrubber systems in lieu of carbon
adsorbers; and (3) the fact that while these comparatively new control
technologies may be equivalent or superior to carbon adsorbers, their
performance has not been officially accepted as such by either the United
States or Ohio EPAs. It is assumed that national estimates of facilities
equipped with carbon adsorbers are representative of the percentages of
9-19
-------
Ohio plants affected by the RACT regulation which are also equipped with
dryer exhaust perc emission control devices. Solvent emissions from
dryer exhaust are already being controlled at approximately 35 percent of
the nation's commercial and 50 percent of the industrial perc dry
cleaning plants.2 Therefore, the estimated number of commercial plants
in the 18 counties having carbon adsorbers is 174, while an estimated
five industrial perc dry cleaners in the state have this control
equipment. It is also assumed that the adsorbers installed at these
plants are capable of routinely meeting the emission limitations imposed
by the Ohio regulations.
From the data presented in Table 9-3, it is evident that the two greatest
sources of perc vapor emissions are the dryer exhaust and the filter
muck or filter cartridges. No national or state statistics are available
regarding the number of dry cleaning plants equipped to recover solvent
from either filter muck or cartridges. However, a well-run commercial
or industrial plant will have a muck cooker.1 Cartridge filters,
originally introduced in the coin-operated segment of the dry cleaning
industry, are also increasing in use at commercial plants.2 It is
possible that a dry cleaning establishment may have a muck ooker or
equipment to recover solvent from cartridge filters, while not having
equipment to recover solvent from dryer exhaust. The opposite situation
may also exist. For the purposes of estimating perc emissions from
establishments affected by the regulation, it is assumed that only
those plants already equipped with dryer exhaust vapor control devices
also have equipment to recover solvent from materials trapped by filters.
Losses associated with poor maintenance of dry cleaning equipment are
difficult to quantify.2 Fugitive emission points include leaks from
valves, flanges, seals, etc. There are two types of perc losses (liquid
and vapor) from miscellaneous point and fugitive emission sources. One
solvent manufacturer estimates that a leak of one drip per second is
equivalent to about 4 litres of perc loss per day.2 Vapor leaks usually
occur at evaporative points and tears in ductwork, and can be detected by
smell or application of soap and water to suspect areas.
9-20
-------
These assumptions resulted in average values of emission rates being
utilized in calculations concerning these items. The figures used in
estimating controlled emissions after the implementation of RACT are
shown in Table 9-6 and are mainly the result of controlling dryer
emissions.
9.4 COST ANALYSIS
The costs of controlling VOC emissions from the affected dry cleaning
establishments were estimated by formulating three model plants to
represent the varying facilities in Ohio. Technical parameters of these
model plants are shown in Tables 9-5 and 9-6. The capital costs of
purchasing and installing carbon adsorbers and the annual cost of
operating such equipment were estimated by contacting four vendors to the
dry cleaning industry (VIC, Hoyt, Diversitron, Kleen-Rite). The costs
estimated for the model plants are presented in Table 9-7.
Annual operation and maintenance costs were estimated from discussions
with the previously mentioned vendors. Operating costs include the costs
of electricity, water, and boiler fuel. Electricity is consumed in
powering the fan which draws solvent-laden air over the carbon bed during
the adsorption cycle and provides airflow to dry the bed following
desorption. Recommended desorption time is typically one hour. For
commercial-sized carbon adsorption units, several hundred gallons of
water must be heated and then utilized to steam strip the carbon bed.
The value of perc used in this study was $3.85 per gallon or $0.63 per
kilogram. The estimates of perc cost obtained from various sources
ranged from a low of $3.50 per gallonll to as high as $4.15 per gallon.12
The value assumed applicable in Ohio is approximately the center of this
range.
The calculations of cost effectiveness per kilogram of recovered solvent
were performed for each of the model plants since the effectiveness of
the carbon adsorber perc recovery system varied for each size of plant,
becoming more cost effective with increasing plant size. The overall
9-21
-------
TABLE 9-6
ESTIMATED PERCHLOROETHYLENE EMISSIONS FROM DRY CLEANING
PLANTS AFFECTED BY THE OHIO RACT REGULATION
SMALL COMMERCIAL LARGE COMMERCIAL INDUSTRIAL
PLANT PLANT PLANT
Annual Clothes Throughput 24,310 48,600 565,790
(kg/yr)
Uncontrolled Emission Rate*
(kg/100 kg clothes) 12 12 12
Controlled Emission Rate*
(kg/100 kg clothes) 5 55
Emission Reduction
(kg/yr) 1,702 3,402 39,605
*Reference 2.
9-22
-------
TABLE 9-7
COSTS FOR CARBON ADSORPTION FOR PERCHLOROETHYLENE SOLVENT MODEL PLANTS
UNIT SIZE (kg)
PLANT TYPE
Model Existing Facilities
Installed capital cost
Annual Operating Costs
Annuali zed capital charges*
Total annual costs
Annual credit from perc recoveryb
9 $.63/kg
Cost effectiveness
($/kg removed)
($/ton removed)
11
Commercial
$4
$1
$
$2
$1
,760
,200
957
,157
,072
0.64
578.36
23
Commercial
$5
$1
$1
$2
$2
,960
,300
,198
,498
,143
0.10
94.67
113
Industrial
$13
$ 1
$ 2
$ 4
$24
,500
,500
,714
,214
,951
(0.
(475.
52)
00)
aBased on a capital charge factor of 20.1 percent of installed capital costs
for interest, depreciation, taxes and insurance (12 percent interest rate and
equipment life of 12 years).
bBased on the emission reductions shown in Table 9-6.
9-23 4
-------
cost effectiveness for the entire industry of affected facilities is
provided in Table 9-8. Emission reductions realized by performing proper
operating techniques as applied to existing equipment were not included
in the cost analysis since it is expected that plant operators will apply
these techniques on their own accord as they learn the cost advantages of
doing so. The controlled and uncontrolled emission rates demonstrating
the effect of applying air pollution control techniques required by the
Ohio regulations on the model plants were taken from the CT6 document,
and were intended to show average emission reductions available at the
model plants, and not the actual total emissions of any one plant.
9-24
-------
TABLE 9-8
I
ro
en
CONTROL COST SUMMARY FOR CARBON ADSORPTION
PERCHLOROETHYLENE SOLVENT PLANTS*
Number of Affected Facilities
Installed Capital Costs ($1,000)
Annual ized Capital Charges ($1,000)
Annual Operating Costs ($1,000)
Annual Perc Recovery Credit ($1,000)
Net Annual ized Costs ($1,000)
Total Annual Emission Reduction (10^ kg)
Cost Effectiveness ($/kg of reduction)
SMALL
COMMERCIAL
PLANT
162
771.12
155.04
194.40
173.66
175.78
275.72
0.64
LARGE
COMMERCIAL
PLANT
161
959.56
192.88
209.30
345.02
57.16
547.72
0.10
INDUSTRIAL
PLANT
6
81.00
16.28
9.00
149.71
(124.43)b
237.63
(0.52)b
TOTAL
329
1811.68
364.20
412.70
668.39
108.51
1061.08
0.10
aBased on figures provided for model plants in Tables 9-6 and 9-7.
bParentheses indicate a net savings.
-------
9.5 REFERENCES
1. U.S. Environmental Protection Agency. Perchloroethylene Dry
Cleaners - Background Information for Proposed Standards.
EPA-450/3-79-029a, Office of Air Quality Planning and
Standards, Research Triangle Park, North Carolina, 1980. 165
pp.
2. U.S. Environmental Protection Agency. Control of Volatile Organic
Emissions from Perchloroethylene Dry Cleaning Systems.
EPA-450/2-78-050. Research Triangle Park, North Carolina,
1978. 68 pp.
3. Ponder, T.C., and M.Y. Anastas. Overview Survey of the Dry Cleaning
Industry. PEDCo Environmental, Inc., Cincinnati, Ohio, 1979.
67 pp.
4. U.S. Bureau of the Census, County Business Patterns, 1978-Ohio. No.
49-45747. Washington, D.C., 1980. 215 pp.
5. Telecon. Fisher, W. - International Fabricare Institute, with
Patterson, R. - Dames & Moore. April 28, 1981.
6. Telecon. Sluizer, M. - Institute of Industrial Launderers, with
Ploski, T. - Dames & Moore. July 13, 1981.
7. Letter from Field, D. - Ohio Cleaners Association, to Formento, J. -
Dames & Moore. May 12, 1981.
8. U.S. Environmental Protection Agency. Compilation of Air Pollution
Emission Factors - AP-42, Third Edition. Research Triangle
Park, North Carolina, 1977.
9. PEDCo Environmental, Inc. Certification of Control Equipment for
VOC Control of Dry Cleaning Industry, Phase I. Cincinnati,
Ohio, 1980. 43 pp.
10. Diversitron Corp. Solvation. Fresh Meadows, New York, undated.
4 PP.
11. Telecon. Mr. Pappas - Spencer American, with Krzysiak, P. - Dames &
Moore. April 27, 1981.
12. Illinois Institute of Natural Resources. Effect of RACT II Environ-
mental Controls in Illinois R80-5. Document No. 81/28,
Environmental Management Division. Chicago, Illinois, 1981.
222 pp.
9-26
-------
10.0 SECONDARY ECONOMIC IMPACTS OF COMPLIANCE
10.1 Classification of Industries
The impact of compliance costs on Ohio industry is shown through the
development of several economic indices. To determine these indices, it
was necessary to first assign the industries considered in this study to
industrial source categories. Each industry was assigned to a category
according to its Standard Industrial Classification (SIC) code, as shown
in Table 10-1. The use of SIC codes facilitates the development of
economic impact indices because most of the economic data for the indus-
trial/commercial sector is classified according to these codes.
10.2 Methodology for Data Collection
The industrial parameters of each SIC assigned to the industrial source
categories are presented in Table 10-2. The table indicates the rela-
tive importance of each SIC within the assigned category. The table
also shows the relative size of each industry as represented by number
of firms, number of employees, sales, value added, capital expenditures,
material cost, and payroll.
In Table 10-2, the term "value added" is a measure of manufacturing
activity derived by subtracting the cost of materials, supplies,
containers, fuel, electricity, and contract work from the value of
shipments. The result of this computation is adjusted by the addition
of value added by merchandising operations (difference between sales
value and the cost of merchandise sold without further manufacture or
processing) plus the net change in inventories between the beginning and
end of the year. Capital expenditures include expenditures for
permanent additions and major alterations to manufacturing establish-
ments, including machinery and equipment for which depreciation accounts
are maintained. Excluded from capital expenditures are items leased
from nonmanufacturing concerns, government-owned facilities operated
under contract by private companies, items furnished to the manufacturer
by communities and nonprofit organizations, expenditures for land, and
current operatng expenses. Cost of materials refers to direct charges
10-1
-------
TABLE 10-1. INDUSTRIAL SOURCE CATEGORY AND ASSOCIATED STANDARD
INDUSTRIAL CLASSIFICATION
Industrial Source
Category
Petroleum Refineries
Surface Coating of Miscellaneous
Metal Parts
Gasoline Tank Trucks
Synthesized Pharmaceutical
Manufacturing
Rubber Tire Manufacturing
Graphic Arts
External Floating Roof Tanks
Dry Cleaning
Standard Industrial Classification
(SIC)
2911 Petroleum refining
254 Partitions, shelving, lockers,
and office and store fixtures
33 Primary metal industries
34 Fabricated metal products, except
machinery and transportation
equipment
35 Machinery, except electrical
36 Electrical and electronic machinery,
equipment, and supplies
37 Transportation equipment
384 Surgical, medical, and dental
instruments and supplies
5085 Industrial supplies
5171 Petroleum bulk stations and terminals
2833 Medicinal chemicals and botanical
products
3011 Tires and inner tubes
2751 Commercial printing, letterpress,
and screen
2754 Commercial printing, gravure
2911 Petroleum refineries
5171 Petroleum bulk stations and terminals
7216 Dry cleaning plants, except rug
cleaning
7218 Industrial launderers
10-2
-------
TABLE 10-2. COMPARATIVE PARAMETERS OF COMPONENT INDUSTRIES OF INDUSTRIAL SOURCE CATEGORIES
Industry Establishments
Employees
(thousands)
Sales
(million $)
Value Added
(million 11
Capital
Expenditures
{mil lion $)
Material
Cost
(million $)
Payroll
(million $)
PETROLEUM REFINERIES
2911
petroleum refining
6a
2.
3
3,034.
2
401.
3
31.8
2,653.2
61.5
SURFACE COATING - MISCELLANEOUS
METAL PARTS
254
33
5 34
i
CO
35
36
37
384
5085
partitions, shelving,
lockers
primary metal
industries
fabricated metal
products
machinery, except
electrical
electrical & electronic
machi nery
transportation
equipment
surgical, medical, and
dental instruments
industrial supplies
105
659
2,376
3,683
647
468
110
810C
4.
142.
164.
197.
. 110.
158.
4.
10.
0
6
5
3
0
9
2
0C
202.
13,281.
11,035.
10,766.
6,624.
16,568.
167.
2,360.
7
0
8
5
3
9
0
2C
110.
5,505.
5,398.
5,989.
3,654.
6,376.
91.
n.a.
4
7
6
2
0
5
1
b
2.1
389.6
318.8
333.0
185.0
494.1
3.6
n.a.
95.0
7,799.2
5,701.4
4,889.7
3,060.3
10,259.6
76.9
n.a.
58.6
2,548.6
2,483.3
2,945.0
1,496.8
3,061.2
44.8
149. Oc
GASOLINE TANK TRUCKS
5171 petroleum bulk stations
and terminals 50 5.2 6,188.0 456.6 93.2 3,015.2 110.1
-------
TABLE 10-2. (Continued)
Capital Material
Employees Sales Value Added Expenditures Cost Payroll
Industry Establishments (thousands) (million $) (million $) (million $) (million $) (million $)
PHARMACEUTICAL MANUFACTURERS
2833 medicinal chemicals
RUBBER TIRE MANUFACTURERS
3011 tires & inner tubes
GRAPHIC ARTS
2751 commercial printing,
letterpress & screen
2754 commercial printing,
gravure
EXTERNAL FLOATING ROOF TANKS
5171 petroleum bulk stations
& terminals
DRY CLEANING
7216 dry cleaning plants
7218 industrial launderers
2
5
268
9
44
871d
52d
n.a.b 397.9 52.0 15.4
6.2 651.1 294.7 27.1
8.7 375.3 194.0 20.5
0.5 58.6 29.0 1.7
4.4 2,740.0 n.a. n.a.
6.7d 89. Oe n.a. n.a.
3.1d 80. 3e n.a. n.a.
345.9 n.a.b
388.6 159.6
180.7 127.5
29.9 6.9
n.a. 54.5
n.a. 36. ld
n.a. 29. 8d
Sources: 1977 Census of Manufactures - Ohio, unless otherwise noted.
aOhio EPA
n.a. = not available
C1977 Census of Wholesale Trade - Ohio
1978 County Business Patterns - Ohio
e!977 Census of Service Industries - Ohio
-------
paid or payable for items consumed or put into production, including
freight charges and cost of materials or fuel consumed during manufactur-
ing operations.
Most statistics are presented as 1977 values and were taken directly
from the 1977 Census of Manufactures for Ohio. There are a few excep-
tions, and these are either noted in Table 10-2 or explained in the
following section. Other sources used for collecting the industry
statistics include (1) communications with the Ohio EPA, (2) the Annual
Survey of Manufacturers, 1975-1976, (3) the 1977 Census of Wholesale
Trade for Ohio, (4) the 1978 County Business Patterns for Ohio, and (5)
the 1977 Census of Service Industries for Ohio. In some cases census
data were not available. For instance, census data were withheld by
certain industries to avoid disclosure and were unavailable for others
because of the service nature of their business.
10.3 Industrial Statistics for Source Categories
Industrial parameters, estimated pollution control costs, and economic
impact indices are presented for each individual industrial source
category in Tables 10-3 through 10-10. These tables indicate what each
industry would have to spend to comply with RACT II guidelines. The
indices were derived by dividing either total or annualized control cost
values by the appropriate parameter.
Several limitations to the computed economic indices should be re-
organized. Whenever possible, the economic parameters for only the
affected portion of the industry were included in Table 10-2. When such
information could not be isolated, statistics for the industry as a
whole were used. Although control costs are expressed in terms of 1981
dollars, economic statistics summarized in Table 10-2 and categorized as
industrial parameters in Tables 10-3 through 10-10 are largely taken
from 1977 census data. These data are the most recent available, as
economic censuses are taken at 5-year intervals. No adjustments to
these 1977 statistics were made to account for inflation. Although
national inflation factors are available for SIC codes, their relevance
10-5
-------
TABLE 10-3. ECONOMIC STATISTICS FOR PETROLEUM
REFINING FACILITIES IN OHIO
INDUSTRIAL PARAMETERS
Number of Firms (potentially affected) 6
Employment 2,300
Sales ($) 3,034,240,000
Value Added ($) 401,280,000
Capital Expenditure ($) 31,768,000
Material Cost ($) 2,653,200,000
Payroll ($) 61,490,000
CONTROL COSTS
Number of Firms (actually affected) 6
Capital ($) 55,000
0 & M ($) (1,784,000)
Annualized Capital ($) 16,000
Total Annualized ($) (1,768,000)
ECONOMIC IMPACT INDICES
Capital Control Costs as a Percentage
of Annual Capital Expenditure (%) 0.173
Total Annual Control Cost as a
Percentage of Sales (%) (0.058)
Total Annual Control Cost as a
Percentage of Value Added (%) (0.44)
Note: Parentheses enclosing dollar amounts indicate a net savings.
10-6
-------
TABLE 10-4. ECONOMIC STATISTICS FOR MISCELLANEOUS
METAL COATING FACILITIES IN OHIO
INDUSTRIAL PARAMETERS
Number of Firms (potentially affected) 8,846
Employment 791,553
Sales ($) 61,006,400,000
Value Added ($) 27,125,500,000
Capital Expenditure ($) 1,726,200,000
Material Cost ($) 31,882,100,000
Payroll ($) 12,787,300,000
CONTROL COSTS
Number of Firms (actually affected) 87
Capital ($) 14,100,000-232,050,000
0 & M ($) 2,999,000- 24,558,000
Annualized Capital ($) 2,813,000- 50,256,000
Total Annualized ($) 5,814,000- 74,820,000
ECONOMIC IMPACT INDICES
Capital Control Costs as a Percentage
of Annual Capital Expenditure (%) 0.8 - 13.4
Total Annual Control Cost as a
Percentage of Sales (%) 0.01 - 0.123
Total Annual Control Cost as a
Percentage of Value Added (%) 0.02 - 0.276
10-7
-------
TABLE 10-5. ECONOMIC STATISTICS FOR MISCELLANEOUS
METAL COATING FACILITIES IN OHIO BY SIC CODE
o
i
CO
INDUSTRIAL PARAMETERS
Number of Firms (potentially affected)
Employment
Sales ($ 106)
Value Added ($ 106)
Capital Expenditure ($ 106)
Material Cost ($ 106)
Payroll ($ 106)
CONTROL COSTS
Number of Firms (actually affected)
Capital ($ 106)
0 & M ($ 106)
Annuali zed Capital ($ 106)
Total Annual i zed ($ 106)
ECONOMIC IMPACT INDICES
Capital Control Costs as a Percentage
of Annual Capital Expenditure (%)
Total Annual Control Cost as a
Percentage of Sales (%)
Total Annual Control Cost as a
Percentage of Value Added (%)
SIC
254
105
3,962
202.
110.
2.
95.
58.
1
0.
0.
0.
0.
14.
0.
0.
7
4
1
0
6
3
044
056
1
3
05
09
SIC 33
659
142,600
13,281.0
5,505.7
389.6
7,799.2
2,548.6
6
6.6
0.64
1.43
2.07
1.7
0.02
0.04
SIC 34
2,376
164,500
11,035.8
5,398.6
318.8
5,701.4
2,483.3
38
3.3-133.0
1.2-12.9
0.6-28.9
1.8-41.8
1.0-41.7
0.02-0.38
0.03-0.8
SIC 35
3,683
197,300
10,766.5
5,989.2
333.0
4,889.7
2,945.0
11
0.96-42.9
0.35-5.0
0.18-9.3
0.53-14.3
0.29-12.9
0.005-0.13
0.009-0.24
SIC 36
647
110,000
6,
3,
3,
1,
1.
0.
0.
0.
0.
0.
0.
624.3
654.0
185.0
060.3
496.8
12
0-22.8
38-2.8
19-4.9
57-7.7
54-12.3
009-0.12
016-0.21
SIC 37
468
158,900
16,568.9
6,376.5
494.1
10,259.6
3,061.2
17
1.2-25.5
0.25-3.0
0.23-5.5
0.48-8.5
0.24-5.2
0.003-0.05
0.007-0.13
SIC 384 SIC 5085
110
4,200
798
10,091
167.0 2,360.2
0.
0.
0.
0.
1.
0.
0.
91.1
3.6
76.9
44.8
1
04-0.25
007-0.046
007-0.05
014-0.1
11-6.9
008-0.06
015-0.11
-
-
-
149.0
1
0.7
0.098
0.15
0.25
-
0.01
-
-------
TABLE 10-6. ECONOMIC STATISTICS FOR FACILITIES IN OHIO
OPERATING GASOLINE TANK TRUCKS
INDUSTRIAL PARAMETERS
Number of Firms (potentially affected) 50
Employment 5,225
Sales ($) 6,188,000,000
Value Added ($) 456,600,000
Capital Expenditure ($) 93,200,000
Material Cost ($) 3,015,200,000
Payroll ($) 110,100,000
CONTROL COSTS
Number of Firms (actually affected) 50
Capital ($)
0 & M ($) 387,000
Annualized Capital ($)
Total Annualized ($) 387,000
ECONOMIC IMPACT INDICES
Capital Control Costs as a Percentage
of Annual Capital Expenditure (%) 0
Total Annual Control Cost as a
Percentage of Sales (%) 0.006
Total Annual Control Cost as a
Percentage of Value Added (%) 0.09
Note: Dash indicates that information is not applicable in this case.
10-9
-------
TABLE 10-7. ECONOMIC STATISTICS FOR PHARMACEUTICAL MANUFACTURING
FACILITIES IN OHIO
INDUSTRIAL PARAMETERS
Number of Firms (potentially affected) 2
Employment n.a.
Sales ($) 397,916,000
Value Added ($) 51,995,000
Capital Expenditure ($) 15,376,000
Material Cost ($) 345,921,000
Payroll ($) n.a.
CONTROL COSTS
Number of Firms (actually affected) 2
Capital ($) 83,600
0 & M ($) 12,500
Annualized Capital ($) 15,700
Total Annualized ($) 28,200
ECONOMIC IMPACT INDICES
Capital Control Costs as a Percentage
of Annual Capital Expenditure (%) 0.54
Total Annual Control Cost as a
Percentage of Sales (%) 0.007
Total Annual Control Cost as a
Percentage of Value Added (%) 0.054
Note: n.a. indicates that the information is not available.
10-10
-------
TABLE 10-8. ECONOMIC STATISTICS FOR RUBBER TIRE
MANUFACTURING FACILITIES IN OHIO
INDUSTRIAL PARAMETERS
Number of Firms (potentially affected) 5
Employment 6,210
Sales ($) 651,100,000
Value Added ($) 294,700,000
Capital Expenditure ($) 27,100,000
Material Cost ($) 388,600,000
Payroll ($) 159,600,000
CONTROL COSTS
Number of Firms (actually affected) 4
Capital ($) 1,014,000
0 & M ($) 33,000
Annualized Capital ($) 243,000
Total Annualized ($) 276,000
ECONOMIC IMPACT INDICES
Capital Control Costs as a Percentage
of Annual Capital Expenditure (%) 3.74
Total Annual Control Cost as a
Percentage of Sales (%) 0.042
Total Annual Control Cost as a
Percentage of Value Added (%) 0.094
10-11
-------
TABLE 10-9. ECONOMIC STATISTICS FOR ROTOGRAVURE AND
FLEXOGRAPHIC PRINTING FACILITIES IN OHIO
INDUSTRIAL PARAMETERS
Number of Firms (potentially affected) 277
Employment 9,223
Sales ($) 433,900,000
Value Added ($) 223,000,000
Capital Expenditure ($) 22,200,000
Material Cost ($) 210,600,000
Payroll ($) 134,400,000
CONTROL COSTS
Number of Firms (actually affected) 16
Capital ($) 2,691,000
0 & M ($) 4,576,000
Annualized Capital ($) 584,000
Total Annualized ($) 5,160,000
ECONOMIC IMPACT INDICES
Capital Control Costs as a Percentage
of Annual Capital Expenditure (%) 12.1
Total Annual Control Cost as a
Percentage of Sales ($) 1.19
Total Annual Control Cost as a
Percentage of Value Added ($) 2.3
10-12
-------
TABLE 10-10. ECONOMIC STATISTICS FOR FACILITIES IN OHIO WITH
EXTERNAL FLOATING ROOF STORAGE TANKS
INDUSTRIAL PARAMETERS
Number of Firms (potentially affected) 44
Employment 4,436
Sales ($) 2,740,000,000
Value Added ($)
Capital Expenditure ($) n.a.
Material Cost ($)
Payroll ($) 54,500,000
CONTROL COSTS
Number of Firms (actually affected) 44
Capital ($) 4,700,000
0 & M ($) (275,000)
Annualized Capital ($) 1,020,000
Total Annualized ($) 745,000
ECONOMIC IMPACT INDICES
Capital Control Costs as a Percentage
of Annual Capital Expenditure (%) n.a.
Total Annual Control Cost as a
Percentage of Sales (%) 0.027
Total Annual Control Cost as a
Percentage of Value Added (%)
Note: n.a. indicates that the information is unavailable. Dash indicates
that the information is not applicable in this case. Parentheses
enclosing dollar amounts indicate a net savings.
10-13
-------
for all affected Ohio industries is unclear, particularly where the
affected industrial category is comprised of several SIC codes.
Inaccuracies in the affected industry economic statistics would have too
easily been introduced had national inflation factors for SIC codes been
applied.
While the effects of inflation since the 1977 economic census are not
shown in the industrial cost parameters summarized in Table 10-2, it may
generally be assumed that the 1981 costs are higher. Thus, in Tables
10-3 through 10-10, those economic impact indices expressed as
percentages of capital expenditure or value added may be overstated.
10.3.1 Petroleum Refining
Petroleum refineries are primarily engaged in producing gasoline, kero-
sene, distillate and residual fuel oils, lubricants, and other products
from crude petroleum. In Ohio, the refining industry is concentrated in
five cities, Lima, Toledo, Canton, Findlay, and Cleveland. At present,
the larger refineries remain financially sound, but the smaller facili-
ties are closing as a result of decreasing petroleum sales. In 1977,
there were ten refineries in Ohio. This number has decreased to six.1
These refineries appear to be in no danger of closing, but only one,
Ashland-Canton, has made recent capital expenditures.2
The industrial parameters are proportional values derived from 1977 data
for ten refineries but scaled down for six refineries. These values are
shown in Table 10-3. Compliance with RACT II guidelines would actually
result in a net savings in operation and maintenance (0 & M) costs for
the refineries and, therefore, in total annualized control costs.
10.3.2 Surface Coating of Metal Parts
The types of end uses that involve surface coating of metal parts are
best shown in Table 10-1. The industrial parameters that are provided
in Table 10-4 were developed based on the assumption that the total
industry, 8846 firms, has the potential to be affected by the new guide-
lines. The firms that will actually be affected will number about 87,
because this is the number of firms that actually perform surface
coating of metal parts. Control costs and economic indices were
10-14
-------
developed for these 87 firms alone. Economic statistics by SIC code are
presented in Table 10-5.
10.3.3 Gasoline Tank Trucks
Gasoline tank trucks transport refinery products from the refineries to
terminals and dispensing facilities, and from terminals to bulk plants
and dispensing facilities. There are 6 refineries and 44 firms in Ohio
with storage tanks and they, together with independent truck owners,
operate a total of 1599 tank trucks which are likely to be affected by
RACT regulations. The operation of trucks is strictly an 0 & M
expenditure, and the control costs and economic indices presented in
Table 10-6 reflect this.
10.3.4 Pharmaceutical Manufacturing
There are 41 pharmaceutical manufacturing firms in Ohio, but only two
will be affected by the RACT II guidelines. Both of these firms are
located in Cincinnati and are involved in the manufacture of bulk
organic and inorganic medicinal chemicals and the processing of bulk
botanical drugs and herbs. The ethical pharmaceutical market is
growing, as reflected in the increased sales of both companies over the
past few years. The impact of additional pollution control costs on
these two companies is shown in Table 10-7.
10.3.5 Rubber Tire Manufacturing
Rubber tire manufacturing for cars and trucks is concentrated in the
urban areas of northern Ohio. There are five rubber tire manufacturing
facilities in this region, but only four will be affected by the RACT II
guidelines. The facilities tend to be older because new plants are not
being constructed in Ohio, and the industry is experiencing a general
downturn, which results in fewer capital expenditures. The larger firms
seem to be surviving the downturn, although they are losing money, but
the smaller companies are closing. The cost and economic impact of
complying with the new guidelines for the four firms are presented in
Table 10-8.
10-15
-------
10.3.6 Graphic Arts
The graphic arts industry provides printing services of various types to
end users. The industry is growing, and should continue to grow, as the
demand for this service increases. The most successful firms appear to
be smaller printers who specialize and the larger printers who deal in
volume orders and can afford the latest technology.
There are 277 printing firms in Ohio, but only 16 of these will actually
be affected by RACT II guidelines. Compliance costs and economic impact
indices for these 16 firms are presented in Table 10-9.
10.3.7 Floating Roof Tank Storage
The storage of petroleum products at bulk stations and terminals is the
function of this industrial category. Gasoline sales peaked in 1978 and
have been declining since that time owing to a decrease in demand. This
decrease in demand is the result of high prices and has caused an
increase in inventories and in the need for storage. As with other
sectors of the petroleum industry, the larger firms will be able to
survive while some of the smaller firms will be forced to close as a
result of the industry downturn. Approximately half of the Ohio facili-
ties are small, with less than five employees. As with the rest of the
industry, few capital expenditures for new facilities are being made,
although existing facilities are being modified.
Table 10-10 presents the compliance costs and economic impact for the 44
tank storage firms located in Ohio. Some of the indices could not be
computed because the necessary information was not available.
10.3.8 Dry Cleaning
The number of dry-cleaning establishments that launder clothes and other
items for retail, commercial, and industrial customers has been
decreasing slightly. Because these businesses are service-oriented,
they tend to follow the general trends of the overall economy. There
are 923 dry-cleaning establishments in Ohio and industrial parameters
are provided for all of these establishments in Table 10-11. Only 329
10-16
-------
TABLE 10-11. ECONOMIC STATISTICS FOR DRY-CLEANING
FACILITIES IN OHIO
INDUSTRIAL PARAMETERS
Number of Firms (potentially affected) 923
Employment 9,741
Sales ($) 169,331,000
Value Added ($)
Capital Expenditure ($)
Material Cost ($)
Payroll ($) 65,994,000
CONTROL COSTS
Number of Firms (actually affected) 329
Capital ($) 1,812,000
0 & M ($) (256,000)
Annualized Capital ($) 364,000
Total Annualized ($) 108,000
ECONOMIC IMPACT INDICES
Capital Control Costs as a Percentage
of Annual Capital Expenditure (%)
Total Annual Control Cost as a
Percentage of Sales (%) 0.06
Total Annual Control Cost as a
Percentage of Value Added (%)
Note: Dash indicates that the information is not applicable in this case.
Parentheses enclosing dollar amounts indicate a net savings.
10-17
-------
of these will be affected by the new guidelines, however, so the compli-
ance cost and economic impact values presented in Table 10-11 are for
the affected portion of the industry.
10.4 Discussion of Economic Impacts
The following discussion deals with the economic impact on the Ohio
economy of imposing the RACT II guidelines. To assess the relative
impact of additional compliance costs on Ohio industries, these costs
were first calculated. They are presented in Tables 10-3 through 10-11
for each of the industrial source categories. Compliance costs vary
from industry to industry depending on their projected response to the
new regulations. There were three possible responses considered: (1)
the addition of pollution control equipment, requiring additional
capital expenditures; (2) a change in the manufacturing process, which
also requires capital expenditures for equipment replacement; and (3) a
change in operating procedures, which affects operating and maintenance
(0 & M) costs.
Once the compliance costs were calculated, they were used to calculate
three economic impact indices for each of the industrial source
categories. These indices are presented in Table 10-12. The first
measure of economic impact considered in this study is the ratio of
capital control costs, resulting from the purchase of new equipment or
the replacement of existing equipment, to annual new capital expendi-
tures. This index reflects the impact of compliance costs on each
category's capital requirements. If an industry is spending a
percentage of its capital budget on environmental protection, that
amount may no.t be available for equipment replacement or plant expansion
and, thus for increased production. For example, petroleum refineries
would spend less than one percent of their capital budget for compliance
costs, but the surface coating and graphic arts industries would have to
spend 13.4 and 12.1 percent, respectively. This expenditure, which
could decrease production for the surface coating and graphic arts
industries, may decrease as the water-based surface coatings become more
highly developed and their use more widespread. These two factors will
10-18
-------
TABLE 10-12. COMPARISON OF ECONOMIC IMPACT INDICES FOR THE EIGHT INDUSTRIES
Index
Capital Control
Costs as a % of
Annual Capital
Expenditure
Total Annual
Control Cost
as a % of Sales
Total Annual
Control Cost as
a % of Value Added
Petroleum Surface
Refinery Coating
0.173 13.4
(0.058) 0.123
(0.44) 0.276
Gasoline
Tank Trucks
0.006
0.09
Pharmaceutical
Manufacture
0.54
0.007
0.054
Floating
Rubber Tire Graphic Roof Tank Dry
Manufacture Arts Storage Cleaning
3.74
0.042
0.094
12.1
n.a.
1.19 0.027
2.3
0.06
Note: 1) n.a. indicates that the information is not available.
2) Parentheses indicate a net savings.
-------
tend to lower the cost of the coatings, and could result in lower pollu-
tion control expenses and more money available for product-related
equipment. However, it must be recognized that capital used for
pollution control does not necessarily result in decreased capital for
product-related expenditures. A firm may not be forced to compromise
production capital for pollution control capital, since capital avail-
ability depends upon the cost of capital as well as upon the financial
and market status of both the company and the specific plant. For
example, capital used to convert to a new technology (i.e., high solids
or water-based inks or coatings) could simultaneously result in both
pollution control and new, possibly improved, products.
The second measure of economic impact is the ratio of total annualized
control costs as a percentage of the annual value of the industry's
sales (or shipments). This index indicates the price impact from the
annualized compliance costs. These percentages could represent
potential price increases, assuming that the full cost of the additional
pollution control measures was passed on (without markup) to the
consumers of the affected products. The percentages represent only
potential price increases, since prices depend upon numerous market
factors which extend far beyond increased annualized compliance costs
for pollution control. Looking at Table 10-12, the impact of the new
guidelines would be greatest on the graphic arts industry. Purchasers
of petroleum products would benefit from a price decrease, assuming that
the net savings reflected in Table 10-12 are passed on to the consumer,
and all other market conditions remained the same.
The third measure of economic impact is the ratio of total annualized
control costs as a percentage of value added. This index could only be
computed for industrial source categories classified by SIC codes as
manufacturers. Value added is not recorded for service industries
(i.e., dry cleaning). Value added is defined as the value of shipments
less the total cost of materials, with an adjustment of the total for
changes in inventories. The value added criteria avoids the duplication
inherent in the value of sales measure due to inter-industry and intra-
10-20
-------
industry sales. It is considered the best measure for comparing the
relative economic impact among industries. As before, the graphic arts
industry will be affected the most, meaning that the new guidelines will
cause a substantial reduction (2.3%) in the amount of earnings available
after the cost of production is deducted. As indicated in Chapter 7,
the sale of recovered solvent (or the anticipated cross-over in solvent
and water-based ink prices) could significantly reduce the economic
impact of this regulation on affected segments of the industry. The
petroleum refining industry will actually experience a net savings of
0.44 percent.
Although these ratios are rough measures of the impact of the RACT II
guidelines on the industrial source categories, they yield some perspec-
tive with regard to the relative economic effects of additional compli-
ance costs. The economic significance of these costs to each category
varies with its size, whether it is capital or labor intensive, the
compliance costs required, and the specific market conditions under
which the individual firms and plants operate.
10-21
-------
10.5 References
1. OGJ Report, Oil and Gas Journal, Pennwell Publishing Company,
Tulsa, Oklahoma, March 30, 1981.
2. Worldwide Refining and Gas Processing Directory 36th Edition,
Petroleum Publishing Company, Tulsa, Oklahoma, 1978.
10-22
-------
APPENDIX A
AFFECTED SOURCE INVENTORY
-------
Table A-l
Affected Petroleum Refineries
Facility Cit
Standard Oil of Ohio Lima
Toledo
Sun Company Toledo
Ashland Petroleum Canton
Findlay
Gulf Oil Company Cleveland
-------
Table A-2
Affected Facilities Which Perform Surface Coating
of Miscellaneous Metal Parts
SIC Code
254
33
Facility
Kiechler Manufacturing
Erwin G. Smith
Republic Steel Corp.
Clow Corp Cast
Benada Aluminum Product
Alcan Aluminum Corp.
Dura Div. Dura Corp.
City
Cincinnati
Cambridge
Youngstown
Coshocton
Girard
Warren
Toledo
34
Williamson Company
Harvard Manufacturing
Youngstown Steel Door
Amweld Bldg. Prod.
Lake Shore Industries
Louisiana Pacific
Norandex Inc.
Goldsmith Metal Lath
Mel ben Products
Alside Inc.
American Building Company
Leslie-Locke Building
Midwest Industries
Manufacturers Enameling
Fisher Body GMC
Republic Steel Corp.
Brainard Div-Sharon Steel
Inland Steel Container
AM Multigraphics
Witt Company
Akron Sand Blast
U.S. Steel Products
Cleveland Steel Container Corp.
Cortland Container Corp.
Queen City Barrel Company
Astro Fibre Drum
Mosler Safe
Diebold Inc.
Lunkenheimer Company
William Powell Company
Jones & Laughlin Steel
Van Huffel Tube
Doehler-Jarvis Casting
Clecon Inc.
Cincinnati
Bedford Hts.
Austintown Twp.
Niles
Toledo
Norton
Walton Hills
Cincinnati
Harrison
Northampton Twp.
Jamestown
Lodi
Willard
Toledo
Fairfield
Youngstown
Howl and
Cleveland
Euclid
Cincinnati
Barberton
Masury
Niles
Cleveland
Cincinnati
Evendale
Hamilton
Hamilton
Cincinnati
Cincinnati
Niles
Warren
Toledo
Cleveland
-------
Table A-2 (Continued)
SIC Code
35
36
37
Facility
Conn Corporation
Diebold Inc. - Plant 1
Matco Allied
Wheeling - Pittsburgh
Terex Div. - GMC
Euclid Inc.
Cincinnati Milacron
American Tool Works
Leblond Inc.
Queen City Barrel
Cincinnati Inc.
Huffman Manufacturing Company
Lau Incorporated
Foster Transformer
Schulte Corporation
Packard Electric Div.
Alliance Manufacturing Company
A. 0. Smith Corporation
Lincoln Electric
Siemans-Allis
Lincoln Electric
Mansfield Products
Whirlpool Corporation
Whirlpool Corporation
Hoover Company - Plant 1
Whiteway Manufacturing
Sybron Corporation
Ford Motor Co. - Lima Engine Plant
Fram Corporation
Delco Air Conditioning
Delco Products
Dayton Walther Corporation
Inland Div. - Plant 1
Delco Products
Delco Air Conditioning
Inland Div. - Plant 3
Anchor Industries Inc.
Fisher Body - GMC
Ford Motor - Cleveland
Ford Motor
Teledyne-Monarch Rubber
General Electric
General American Transport
MTD Products
City
Westlake
Canton
Medi na
Canfield
Brooklyn
Euclid
Cincinnati
Cincinnati
Norwood
Cincinnati
Harrison
Celina
Dayton
Cincinnati
Cincinnati
Warren
Alliance
Tipp City
Cleveland
Cincinnati
Cleveland
Mansfield
Marion Twp.
Clyde
North Canton
Cincinnati
Cincinnati
Lima
Greenville
Dayton
Dayton
Dayton
Dayton
Dayton
Moraine
Vandalia
Cleveland
Cleveland
Brookpark
Walton Hills
Hartville
Evendale
Masury
Liverpool Twp.
-------
Table A-2 (Continued)
SIC Code Facility City
384 Picker Corporation Highland Hts.
Cincinnati Drum Service Reading
-------
Table A-3
Affected Pharmaceutical Manufacturers
Facility City
Hilton-Davis Chemical Company Cincinnati
Merrell Dow Pharmaceuticals Inc. Cincinnati
-------
Table A-4
Affected Rubber Tire Manufacturers
Facility City
B. F. Goodrich Company Akron
Cooper Tire and Rubber Company Find!ay
Denman Rubber Manufacturing Company Warren
General Tire Inc. Akron
-------
TABLE A-5
AFFECTED FLEXOGRAPHIC AND ROTOGRAVURE
PRINTING ESTABLISHMENTS
Facility
American Can Company
Champion International
Cloudsley Company
Colorpac Inc.
H.S. Crocker Company
Diamond International
Diamond International
Georgia Pacific Company
Jaite Packaging Company
Ludlow Packaging Company
Mead Paper Company
Ohio Match
Olinkraft, Inc.
Packaging Corporation of America
St. Regis Paper
Specialty Paper Company
Zumbiel Company
City
Cleveland
01 instead Falls
Forest Park
Franklin
Blue Ash
Lockland
No rwood
Cincinnati
Akron
Mount Vernon
Chillicothe
Wadsworth
Evandale
Rittman
Middletown
Dayton
Norwood
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Table A-6
Facilities with Potentially Affected External Floating Roof Tanks
Facility
Union Oil of California
Sun Oil Company
Sunmark Industries Div. of Sun Oil
Laurel Pipeline Company
Texaco Inc.
Standard Oil - Bulk Plant
- Toledo Refinery
- Broadway Sta.
- Bradley Rd Term
Kateenberger Tank Farm
Marathon Oil Company
(MP)
Shell Oil Company
Petroleum Fuel and Terminal Company
Ashland Petroleum
Arco Pipeline
Global Energy
Mobil - Cleveland Term
- Lebanon Term
City
Ami i n
Oregon
Dayton
Cleveland
Boardman Twp
Oregon
Groudview
Dayton
Cleveland
Akron
Toledo
Ellsworth
Ellsworth
Cincinnati
Lima
Shawnee Twp
Toledo
Oregon
Dayton
Cleveland
Cleveland
Cuyahoga Hts.
Monroe Twp
Tiffia
Henry Twp
Oregon
Findlay
Oregon
Brecksville
Dayton
Toledo
Toledo
Cleveland
Toledo
Dayton
Cleveland
Lebanon
-------
Table A-6 (Continued)
Facility
City
Clark Oil & Refining Corp.
Defense Fuel Support Point
Gulf Oil Company
Aurora Term & Transport
Buckeye Pipeline Company
Texas Eastern Trans Corp.
Phillips Petroleum
Brecksville
Cincinnati
Whitewater
Aurora
Mantua
Middletown
Clearcreek Twp
Aurora
-------
APPENDIX B
RELEVANT PORTIONS OF OHIO ADMINISTRATIVE CODE
AMENDED RULES 3745-21-04, 09, AND 10
-------
3745-21-04 Attainment dates and compliance time schedules.
(A) Attainment of established air quality standards for carbon
monoxide and ozone, within the area, through the orderly application
of pollution control techniques, shall be accomplished as expeditiously
as practicable, but in no event shall such time be later than December
31, 1987.
(B) Certification and permit application requirements.
(1) EXCEPT AS OTHERWISE PROVIDED IN PARAGRAPHS (B)(2) TO (B)(4)
OF THIS RULE, BY NO Ne later than December 1, 1979 any-ewnep-ei-
eper»atei»-ef FOR any air contaminant source subject toT-and
Het-spee4f4ea**y-exemp%ed-^em-» PARAGRAPHS (C) TO (S) OF rule
3745-21-09 of the Administrative Code AND BY NO LATER THAN
APRIL 1, 1981 FOR ANY AIR CONTAMINANT SOURCE SUBJECT TO PARAGRAPHS
It) TO (AA) OF RULE 3745-21-09 OF THE ADMINISTRATIVE CODE, ANY
OWNER OR OPERATOR OF SAID AIR CONTAMINANT SOURCE(S) sFall
either:
(a) Certify in writing to the director that such
source is in compliance with all requirements of rule
3745-21-09 of the Administrative Code. Such certification
shall include: equipment description, Ohio environmental
protection agency permit application number (if assigned),
and all necessary data (consistent with the appropriate
permit application appendices) and calculations which
confirm the compliance status. The certification shall
also include an application for a permit to operate such
source in accordance with rule 3745-35-02 of the Administrative
Code if such source does not possess an effective permit;
or
(b) Submit an application for a permit to operate
or an application for a modification to a permit to operate
in accordance with rule 3745-35-02 of the Administrative
Code. Such application shall include a compliance program
which will bring the source into compliance with all the
requirements of rule 3745-21-09 of the Administrative Code
as expeditiously as practicable but in no event later than
the dates specified in paragraph (C) of this rule, and
shall identify all reasonable interim control measures.
zr-rt'.-l Protection A^
DOCTOR'S JOURNAL
FE8121981
16
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(2) The certification and/or permit to operate application
required by paragraph (B)_QJ_ of this rule may include multiple
facilities if such facilities are subject exclusively to paragraph
(R) of rule 3745-21-09 of the Administrative Code (pertaining
to gasoline dispensing facilities).
(3) THE CERTIFICATION AND/OR PERMIT TO OPERATE APPLICATION REQUIRED
BY PARAGRAPH (B)(l) OF THIS RULE SHALL NOT APPLY TO ANY AIR
CONTAMINANT SOURCES SUBJECT EXCLUSIVELY TO PARAGRAPH (N) OR (V)
OF RULE 3745-21-09 OF THE ADMINISTRATIVE CODE (PERTAINING TO
CUTBACK ASPHALTS AND GASOLINE TANK TRUCKSj.
(4) THE CERTIFICATION AND/OR PERMIT TO OPERATE APPLICATION REQUIRED
BY PARAGRAPH (B)(l) OF THIS RULE FOR ANY GASOLINE DISPENSING
FACILITY WHICH IS SUBJECT TO PARAGRAPH (R) OF RULE 3745-21-09
OF THE ADMINISTRATIVE CODE AND WHICH HAS A MAXIMUM ANNUAL
THROUGHPUT GREATER THAN ONE HUNDRED TWENTY THOUSAND GALLONS BUT
LESS THAN TWO HUNDRED FORTY THOUSAND GALLONS OF GASOLINE SHALL
BE FILED WITH THE DIRECTOR BY NO LATER THAN APRIL 1, 1981^
(C) Compliance time schedules.
(1) No owner or operator may cause, permit, or allow the operation
or other use of any air contaminant source in violation of the
limitations specified in rule 3745-21-07 of the Administrative
Code or rule 3745-21-08 of the Administrative Code beyond April
15, 1977.
(2) Except as otherwise provided in paragraphs (C)(21) to (C)(26)
of this rule, any owner or operator of an automobile or light-
duty truck assembly plant which is subject to the requirements
of paragraph (C) of rule 3745-21-09 of the Administrative Code
shall achieve compliance with said requirements as expeditiously
as practicable, but in no event later than the deadlines in the
following schedule:
(a) Submit final control plan by July 1, 1980;
(b) Award contracts for emission control systems or process
modifications; or, issue orders for the purchase of
component parts to accomplish emission control or process
modification by December 1, 1980;
(c) Initiate on-site construction or installation of emission
control equipment or process change by March 1, 1981;
(d) Complete on-site construction or installation of emission
control equipment or process change by September 1, 1982;
and
(e) Achieve final compliance by December 1, 1982.
ENTERED DOCTOR'S JOUSKAL
FEB 121981
17
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1271 ANY OWNER OR OPERATOR OF PETROLEUM REFINERY EQUIPMENT WHICH IS
SUBJECT TO THE REQUIREMENTS OF PARAGRAPH (T) OF RULE 3745-21-09
OF THE ADMINISTRATIVE CODE SHALL ACHIEVE COMPLIANCE WITH SAID
REQUIREMENTS AS EXPEDITIOUSLY AS PRACTICABLE, BUT IN NO EVENT
LATER THAN THE DEADLINES IN THE FOLLOWING SCHEDULE:
jjl SUBMIT TO THE DIRECTOR A MONITORING PROGRAM BY JULY 1 ,
1981. THIS PROGRAM SHALL CONTAIN, AT A MINIMUM,~A LIST OF
THE REFINERY UNITS AND THE CALENDAR QUARTER IN WHICH THEY
WILL BE MONITORED, A COPY OF THE LOG BOOK FORMAT, AND THE
MAKE AND MODEL OF THE MONITORING EQUIPMENT TO BE USED. IN
NO CASE SHALL A CONTRACT RELIEVE THE OWNER OR OPERATOR OF ,
•A PETROLEUM REFINERY FROM THE RESPONSIBILITY FOR COMPLIANCE
WITH THIS RULE.
(b) SUBMIT THE FIRST QUARTERLY MONITORING REPORT TO THE
DIRECTOR BY OCTOBER 15, 1981.
(28) ANY OWNER OR OPERATOR OF A MISCELLANEOUS METAL PART OR PRODUCT
COATING LINE WHICH IS SUBJECT TO THE REQUIREMENTS OF PARAGRAPH
(U) OF RULE 3745-21-09 OF THE ADMINISTRATIVE CODE SHALL ACHIEVE
COMPLIANCE WITH SAID REQUIREMENTS AS EXPEDITIOUSLY AS PRACTICABLE,
BUT IN NO EVENT LATER THAN THE DEADLINES IN THE FOLLOWING
SCHEDULE:
(a) SUBMIT FINAL CONTROL PLAN BY JULY 1, 1981;
(b) AWARD CONTRACTS FOR EMISSION CONTROL SYSTEMS OR PROCESS
MODIFICATIONS; OR, ISSUE ORDERS FOR THE PURCHASE OF
COMPONENT PARTS TO ACCOMPLISH EMISSION CONTROL OR PROCESS
MODIFICATION BY OCTOBER 1, 1981;
(c) INITIATE ONSITE CONSTRUCTION OR INSTALLATION OF THE
EMISSION CONTROL EQUIPMENT OR PROCESS CHANGE BY APRIL 1,
1982;
(d) COMPLETE ONSITE CONSTRUCTION OR INSTALLATION OF THE
EMISSION CONTROL EQUIPMENT OR PROCESS CHANGE BY
OCTOBER 1, 1982; AND
(e) ACHIEVE FINAL COMPLIANCE BY DECEMBER 31, 1982.
(29) ANY OWNER OR OPERATOR OF A GASOLINE TANK TRUCK WHICH IS SUBJECT
TO THE REQUIREMENTS OF PARAGRAPH (V) OF RULE 3745-21-09 OF THE
ADMINISTRATIVE CODE SHALL ACHIEVE COMPLIANCE WITH SAID REQUIREMENTS
ffS EXPEDITIOUSLY AS PRACTICABLE, BUT IN NO EVENT LATER THAN
JULY 1, 1981.
FEB 121981
34
-------
(30) ANY OWNER OR OPERATOR OF A SYNTHESIZED PHARMACEUTICAL MANUFACTURING
FACILITY WHICH IS SUBJECT TO THE REQUIREMENTS OF PARAGRAPH (W)
OF RULE 3745-21-09 OF THE ADMINISTRATIVE CODE SHALL ACHIEVE
COMPLIANCE WITH SAID REQUIREMENTS AS EXPEDITIOUSLY AS PRACTICABLE,
BUT IN NO EVENT LATER THAN THE FOLLOWING SCHEDULE:
(a) SUBMIT FINAL CONTROL PLANS BY JULY 1, 198T;
(b) AWARD CONTRACTS FOR EMISSION CONTROL SYSTEMS OR PROCESS
MODIFICATIONS; OR, ISSUE ORDERS FOR THE PURCHASE OF
COMPONENT PARTS TO ACCOMPLISH EMISSION CONTROL OR PROCESS
MODIFICATION BY OCTOBER 1, 1981;
(c) INITIATE ONSITE CONSTRUCTION OR INSTALLATION OF THE
EMISSION CONTROL EQUIPMENT OR PROCESS CHANGE BY
APRIL 1, 1982;
(d) COMPLETE ONSITE CONSTRUCTION OR INSTALLATION OF THE
EMISSION CONTROL EQUIPMENT OR PROCESS CHANGE BY OCTOBER 1,
1982; AND
(e) ACHIEVE FINAL COMPLIANCE BY (DECEMBER 31, 1982.
(31) ANY OWNER OR OPERATOR OF A PNEUMATIC RUBBER TIRE MANUFACTURING
FACILITY WHICH IS SUBJECT TO THE REQUIREMENTS OF PARAGRAPH (X)
OF RULE 3745-21-09 OF THE ADMINISTRATIVE CODE SHALL ACHIEVE
COMPLIANCE WITH SAID REQUIREMENTS AS EXPEDITIOUSLY AS PRACTICABLE,
BUT IN NO EVENT LATER THAN THE DEADLINES IN THE FOLLOWING
SCHEDULE:
(a) SUBMIT FINAL CONTROL PLANS BY JULY 1, 1981;
(b) AWARD CONTRACTS FOR EMISSION CONTROL SYSTEMS OR PROCESS
MODIFICATIONS; OR, ISSUE ORDERS FOR THE PURCHASE OF
COMPONENT PARTS TO ACCOMPLISH EMISSION CONTROL OR PROCESS
MODIFICATION BY OCTOBER 1, 1981;
(c) INITIATE ONSITE CONSTRUCTION OR INSTALLATION OF THE
EMISSION CONTROL EQUIPMENT OR PROCESS CHANGE BY
APRIL 1, 1982;
(d) COMPLETE ONSITE CONSTRUCTION OR INSTALLATION OF THE
EMISSION CONTROL EQUIPMENT OR PROCESS CHANGE BY OCTOBER 1,
1982; AND
(e) ACHIEVE FINAL COMPLIANCE BY DECEMBER 31, 1982.
fts Frfrrr-r^r pr
FEB 1 2 198t
35
-------
(32) PACKAGING ROTOGRAVURE PRINTING LINES, PUBLICATION ROTOGRAVURE
PRINTING LINES, AND FLEXOGRAPHIC PRINTING LINES.
(a) EXCEPT AS PROVIDED IN PARAGRAPH (C)(32)(b) OF THIS RULE,
ANY OWNER OR OPERATOR OF A PACKAGING ROTOGRAVURE PRINTING
LINE, PUBLICATION ROTOGRAVURE PRINTING LINE, OR FLEXOGRAPHIC
PRINTING LINE WHICH IS SUBJECT TO THE REQUIREMENTS OF
PARAGRAPH (Y) OF RULE 3745-21-09 OF THE ADMINISTRATIVE
CODE SHALL ACHIEVE COMPLIANCE WITH SAID REQUIREMENTS AS
EXPEDITIOUSLY AS PRACTICABLE, BUT IN NO EVENT LATER THAN
THE DEADLINES IN THE FOLLOWING SCHEDULE:
(i) SUBMIT FINAL CONTROL PLANS BY JULY 1, 1981;
(ii) AWARD CONTRACTS FOR EMISSION CONTROL SYSTEMS OR
PROCESS MODIFICATIONS; OR, ISSUE ORDERS FOR THE
PURCHASE OF COMPONENT PARTS TO ACCOMPLISH EMISSION
CONTROL OR PROCESS MODIFICATION BY OCTOBER 1, 1981;
(iii) INITIATE ONSITE CONTRUCTION OR INSTALLATION OF EMISSION
CONTROL EQUIPMENT OR PROCESS CHANGE BY APRIL 1, 1982;
(1v) COMPLETE ONSITE CONSTRUCTION OR INSTALLATION OF
EMISSION CONTROL EQUIPMENT OR PROCESS CHANGE BY
OCTOBER 1, 1982; AND
(v) ACHIEVE FINAL COMPLIANCE BY DECEMBER 31, 1982.
(b) THE DIRECTOR MAY ESTABLISH AN ALTERNATIVE COMPLIANCE
SCHEDULE FOR A PRINTING LINE IDENTIFIED IN PARAGRAPH
(C)(32)(a) OF THIS RULE WHICH REQUIRES SUCH PRINTING LINE
TO ACHIEVE COMPLIANCE WITH PARAGRAPH (Y) OF RULE 3745-21-
09 OF THE ADMINISTRATIVE CODE AS EXPEDITIOUSLY AS PRACTICABLE,
BUT IN NO EVENT LATER THAN DECEMBER 31, 1987, IF THE OWNER
OR OPERATOR OF THE PRINTING LINE DEMONSTRATES THE NECESSITY
OF AN ALTERNATIVE SCHEDULE, TO THE SATISFACTION OF THE
DIRECTOR, BY SUPPLYING THE FOLLOWING DOCUMENTATION:
(1) PROOF OF THE ECONOMIC BURDEN OF INSTALLING CONTROL
EQUIPMENT WHICH WOULD ACHIEVE COMPLIANCE;
(ii) AN IDENTIFICATION OF THE SPECIFIC LOW SOLVENT CONTROL
— STRATEGY TO BE EMPLOYED TO ACHIEVE COMPLIANCE AND AN
ENFORCEABLE SCHEDULE FOR IMPLEMENTATION OF SUCH
STRATEGY;
(iii) A COMMITTMENT EARLY IN THE COMPLIANCE SCHEDULE TO
PROVIDE SUBSTANTIAL REDUCTIONS OF VOLATILE ORGANIC
COMPOUND EMISSIONS FROM THE PRINTING LINE;
~rn:-*:! Prctecfisn teey
FG D'^OR'S .iniiBMAflv) A COMMITTMENT TO PROVIDE A GREATER REDUCTION IN
Uiilim~^ VOLATILE ORGANIC COMPOUND EMISSIONS FROM THE PRINTING
rcn 1 o1001 LINE THAN WOULD HAVE RESULTED FROM THE INSTALLATION
l-hd l^lbOl OF CONTROL EQUIPMENT; AND
36
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(v) A COMMITTMENT TO INSTALL CONTROL EQUIPMENT AS A MEANS
OF COMPLIANCE BY A SPECIFIED DATE (NOT LATER THAN
DECEMBER 1, 1987) IF THE LOW SOLVENT CONTROL STRATEGY
FAILS TO ACHIEVE COMPLIANCE BY A SPECIFIED DATE (NOT
LATER THAN DECEMBER 31, 1985).
(33) ANY OWNER OR OPERATOR OR AN EXTERNAL FLOATING ROOF TANK WHICH
IS SUBJECT TO THE REQUIREMENTS OF PARAGRAPH (Z) OF RULE 3745-
21-09 OF THE ADMINISTRATIVE CODE SHALL ACHIEVE COMPLIANCE WITH
SAID REQUIREMENTS AS EXPEDITIOUSLY AS PRACTICABLE, BUT IN NO
EVENT LATER THAN THE DEADLINES IN THE FOLLOWING SCHEDULE:
(a) SUBMIT FINAL CONTROL PLAN BY JULY 1, 1981;
(b) AWARD CONTRACTS FOR EMISSION CONTROL SYSTEMS OR PROCESS
MODIFICATIONS; OR, ISSUE ORDERS FOR THE PURCHASE OF
COMPONENT PARTS TO ACCOMPLISH EMISSION CONTROL OR PROCESS
MODIFICATION BY OCTOBER 1, 1981;
(c) INITIATE ONSITE CONSTRUCTION OR INSTALLATION OF EMISSION
CONTROL EQUIPMENT OR PROCESS CHANGE BY APRIL 1, 1982;
(d) COMPLETE ONSITE CONSTRUCTION OR INSTALLATION OF EMISSION
EQUIPMENT OR PROCESS CHANGE BY OCTOBER 1, 1982; AND
(e) ACHIEVE FINAL COMPLIANCE BY DECEMBER 31, 1982.
(34) ANY OWNER OR OPERATOR OF A DRY CLEANING FACILITY WHICH IS
SUBJECT TO THE REQUIREMENTS OF PARAGRAPH (AA) OF RULE 3745-21-
09 OF THE ADMINISTRATIVE CODE SHALL ACHIEVE COMPLIANCE WITH
SAID REQUIREMENTS AS EXPEDITIOUSLY AS PRACTICABLE, BUT IN NO
EVENT LATER THAN THE DEADLINES IN THE FOLLOWING SCHEDULE:
(a) SUBMIT FINAL CONTROL PLANS BY JULY 1, 1981;
(b) AWARD CONTRACTS FOR EMISSION CONTROL SYSTEMS OR PROCESS
MODIFICATIONS; OR, ISSUE ORDERS FOR THE PURCHASE OF COMPONENT
PARTS TO ACCOMPLISH EMISSION CONTROL OR PROCESS MODIFICATION
BY OCTOBER 1, 1981;
(c) INITIATE ONSITE CONSTRUCTION OR INSTALLATION OF EMISSION
CONTROL EQUIPMENT OR PROCESS CHANGE BY APRIL 1, 1982;
(d) COMPLETE ONSITE CONSTRUCTION OR INSTALLATION OF EMISSION
CONTROL EQUIPMENT OR PROCESS CHANGE BY OCTOBER 1, 1982; AND
(e) ACHIEVE FINAL COMPLIANCE BY DECEMBER 31, 1982^
C?i!3 fatar*"! Prctesficn
Eh'TEHED DOCTOR'S JOURNAL
FFR 1 2 1981
37
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3745-21-09 Control of emissions of organic compounds from stationary
sources.
(A) Applicability.
(1) In Butler, Clermont, Cuyahoga, Franklin, Greene, Hamilton,
Lake, Lorain, Lucas, Mahoning, Medina, Montgomery, Portage,
Stark, Summit, Trumbull, Warren and Wood counties, the require-
ments of pargraphs (C) to (M) and,. (0) to (R)^ (T)^ (U) AND (W)
TO (AA) of this rule shall apply to all existing sources of
organic compounds.
(2) In those counties of the state of Ohio not specified in
paragraph (A)(l) of this rule, the requirements of paragraphs
(C) to. (M) and, (0) to (R)A (T)A (U) AND (W) TO (AA) of this
rule shall appTy only to existing sources of organic compounds
which are located at a facility having the potential to emit a
total of one hundred tons or more of organic compounds per
calendar year.
(3) The requirements of paragraph PARAGRAPHS (N) AND (V) of this
rul e pep%a4fl4n§-%e-the-Hse-ef-eutbaek-asphaHs-4n-»'ead-pav4n§
shall apply state-wide.
(B) The emission limitations specified in paragraphs (C) to (K), and
(S)^ (U) AND (Y) of this rule are based upon a weighted average of
all coating materials, excluding water, delivered to the coating
applicator in any one day; and shall not apply to coating lines OR
PRINTING LINE WHICH HAVE w4th a maximum application of coating
materials less than, or equal to, three gallons in any one day.
(C) Surface coating of automobiles and light-duty trucks.
(1) No owner or operator of an automobile or light-duty truck
assembly plant may cause, allow or permit the discharge into
the ambient air of any volatile organic compounds after the
dates specified in rule 3745-21-04 of the Administrative Code
in excess of the following:
(a) For a prime coat coating line employing electrodeposition,
(i) 1.2 pounds per gallon of coating, excluding water,
from the electrodeposition coating line; and
(ii) 2.9 pounds per gallon of coating, excluding water,
from the guidecoat or surfacer coating line.
(b) For a prime coat coating line not employing electro-
deposition, 1.9 pounds per gallon of coating, excluding
water.
F»«G F;ri'r~"^ Prctssticn ft
"diEREDOECIOR'S JOURNAL
FEB 1 2 1981
39
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LEAKS FROM PETROLEUM REFINERY EQUIPMENT.
EACH OWNER OR OPERATOR OF A PETROLEUM REFINERY SHALL COMPLY
WITH THE FOLLOWING MONITORING, RECORD-KEEPING AND REPORTING REQUIREMENTS
NO LATER THAN THE DATE SPECIFIED IN PARAGRAPH (C)(27) OF RULE 3745-
21-04 OF THE ADMINISTRATIVE CODE:
(a) EXCEPT AS OTHERWISE INDICATED IN PARAGRAPH (T)(l)(b) OF THIS
RULE, A MONITORING PROGRAM SHALL BE DEVELOPED AND IMPLEMENTED
WHICH INCORPORATES THE FOLLOWING PROVISIONS:
(1) YEARLY MONITORING OF ALL PUMP SEALS, PIPELINE VALVES
IN LIQUID SERVICE AND PROCESS DRAINS IN ACCORDANCE WITH
THE METHOD SPECIFIED IN PARAGRAPH (F) OF RULE 3745-21-10
' OF THE ADMINISTRATIVE CODE;
(11) QUARTERLY MONITORING OF ALL COMPRESSOR SEALS, PIPELINE
VALVES IN GAS SERVICE AND PRESSURE RELIEF VALVES IN GAS
SERVICE IN ACCORDANCE WITH THE METHOD SPECIFIED IN PARAGRAPH
(F) OF RULE 3745-21-10 OF THE ADMINISTRATIVE CODE;
(111) MONTHLY MONITORING OF ALL PUMP SEALS BY VISUAL METHODS;
(iv) MONITORING OF ANY PUMP SEAL IN ACCORDANCE WITH THE
METHOD SPECIFIED IN PARAGRAPH (F) OF RULE 3745-21-10 OF
THE ADMINISTRATIVE CODE WITHIN FIVE WORKING DAYS AFTER ANY
LIQUIDS ARE OBSERVED DRIPPING FROM THE SEAL;
(v) MONITORING OF ANY RELIEF VALVE IN ACCORDANCE WITH THE
METHOD SPECIFIED IN PARAGRAPH (F) OF RULE 3745-21-10 OF
THE ADMINISTRATIVE CODE WITHIN FIVE WORKING DAYS AFTER THE
VALVE HAS VENTED TO THE ATMOSPHERE; AND
(vi) MONITORING OF ANY COMPONENT IN ACCORDANCE WITH THE
METHOD SPECIFIED IN PARAGRAPH (F) OF RULE 3745-21-10 OF
THE ADMINISTRATIVE CODE WITHIN FIVE WORKING DAYS AFTER THE
REPAIR OF A LEAK; ~
(b) PRESSURE RELIEF DEVICES WHICH ARE CONNECTED TO AN OPERATING
FLARE HEADER, VAPOR RECOVERY DEVICES, VALVES WHICH ARE NOT
•REASONABLY ACCESSIBLE, VALVES WHICH ARE LOCATED IN PIPELINES
CONTAINING KEROSENE OR HEAVIER LIQUIDS, STORAGE TANK VALVES AND
VALVES WHICH ARE NOT EXTERNALLY REGULATED ARE EXEMPT FROM THE
MONITORING REQUIREMENTS CONTAINED IN PARAGRAPH (T)(l)(a) OF
THIS RULE;
(c) ALL PIPELINE VALVES IN GAS SERVICE AND PRESSURE RELIEF
VALVES IN GAS SERVICE SHALL BE CLEARLY MARKED AND IDENTIFIED IN
SUCH A MANNER THAT THEY WILL BE OBVIOUS TO BOTH REFINERY
PERSONNEL PERFORMING MONITORING AND TO THE DIRECTOR;
FF3 1 2 1981
54
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IF A LEAK IS IDENTIFIED AS A RESULT OF THE MONITORING PROGRAM
REQUIRED BY PARAGRAPH (T)(l)(a) OF THIS RULE AND THE CONCENTRATION
OF ORGANIC COMPOUNDS EXCEEDS TEN THOUSAND PARTS PER MILLION, A
TAG SHALL IMMEDIATELY BE PLACED ON THE LEAKING COMPONENT. THE
TAG SHALL BE READILY VISIBLE AND WEATHERPROOF; IT SHALL BEAR AN
IDENTIFICATION NUMBER; AND IT SHALL CLEARLY INDICATE THE DATE
THE LEAK WAS DETECTED. THE TAG SHALL REMAIN IN PLACE UNTIL THE
LEAKING COMPONENT IS REPAIRED;
(e) A MONITORING LOG SHALL BE MAINTAINED FOR ALL LEAKING
COMPONENTS WHICH ARE TAGGED IN ACCORDANCE WITH PARAGRAPH (T)(l)(d)
OF THIS RULE. THE MONITORING LOG SHALL CONTAIN, AT A MINIMUM,
THE FOLLOWING DATA:
(1) THE NAME OF THE PROCESS UNIT WHERE THE LEAKING COMPONENT
IS LOCATED;
(11) THE TYPE OF LEAKING COMPONENT (SUCH AS VALVE, SEAL, OR
OTHER COMPONENT);
(111) THE TAG NUMBER OF THE LEAKING COMPONENT;
(iv) THE DATE ON WHICH THE LEAKING COMPONENT WAS DETECTED;
(v) THE DATE ON WHICH THE LEAKING COMPONENT WAS REPAIRED;
(v1) THE DATE AND RESULTS OF THE MONITORING PERFORMED
WITHIN TWENTY-FOUR HOURS AFTER THE LEAKING COMPONENT WAS
REPAIRED;
(vil) A RECORD OF THE CALIBRATION OF THE MONITORING INSTRUMENT;
(vi1i) A LIST OF THOSE LEAKING COMPONENTS WHICH CANNOT BE REPAIRED
UNTIL THE NEXT PROCESS UNIT TURNAROUND; AND
(ix) THE TOTAL NUMBER OF COMPONENTS MONITORED AND THE
TOTAL NUMBER OF COMPONENTS FOUND LEAKING DURING THE CALENDAR
YEAR;
(f) A COPY OF ANY MONITORING LOG SHALL BE RETAINED BY THE OWNER OR
OPERATOR FOR A MINIMUM OF TWO YEARS AFTER THE DATE ON WHICH THE
RECORD WAS MADE OR THE REPORT WAS PREPARED;
(g) A COPY OF ANY MONITORING LOG SHALL IMMEDIATELY BE MADE AVAILABLE
TO THE DIRECTOR OR AN AUTHORIZED REPRESENTATIVE OF THE DIRECTOR,
UPON VERBAL OR WRITTEN REQUEST, AT ANY REASONABLE TIME; AND
Cliio E:iv!iG"::t:i Protection A
ENTERED DIRECTOR'S JOURNAL
FEB 121981
55
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(h) A REPORT SHALL BE SUBMITTED TO THE DIRECTOR BY THE FIFTEENTH
DAY OF JANUARY, APRIL, JULY AND OCTOBER THAT GIVES THE TOTAL
NUMBER OF COMPONENTS MONITORED DURING THE PREVIOUS THREE
CALENDAR MONTHS, GIVES THE TOTAL NUMBER OF COMPONENTS FOUND
LEAKING DURING THE PREVIOUS THREE CALENDAR MONTHS, IDENTIFIES
ALL COMPONENTS WHICH WERE FOUND LEAKING DURING THE PREVIOUS
THREE CALENDAR MONTHS BUT WHICH WERE NOT REPAIRED WITHIN
FIFTEEN DAYS AND IDENTIFIES ALL LEAKING COMPONENTS WHICH
CANNOT BE REPAIRED UNTIL THE NEXT PROCESS UNIT TURNAROUND.
(2) ANY OWNER OR OPERATOR OF A PETROLEUM REFINERY SHALL MAKE EVERY
REASONABLE EFFORT TO REPAIR WITHIN FIFTEEN DAYS ANY LEAKING COMPONENT
WHICH IS TAGGED AND IDENTIFIED IN ACCORDANCE WITH PARAGRAPH (T)(l)(d)
OF THIS RULE, UNLESS THE LEAKING COMPONENT CANNOT BE REPAIRED UNTIL
A PROCESS UNIT TURNAROUND OCCURS.
(3) THE DIRECTOR MAY REQUIRE A PROCESS UNIT TURNAROUND TO OCCUR EARLIER
THAN THE NORMALLY SCHEDULED DATE IF THE NUMBER AND SEVERITY OF
LEAKING COMPONENTS AWAITING A TURNAROUND WARRANT SUCH ACTION. ANY
SUCH PROCESS UNIT TURNAROUND SHALL BE REQUIRED BY MEANS OF AN ORDER
ISSUED BY THE DIRECTOR TO THE OWNER OR OPERATOR OF THE PETROLEUM
REFINERY PURSUANT TO DIVISION (S) OF SECTION 3704.03 OF THE REVISED
CODE.
(4) THE DIRECTOR MAY ACCEPT AN ALTERNATIVE MONITORING, RECORD-KEEPING
AND REPORTING PROGRAM FOR THAT REQUIRED BY PARAGRAPH (T)(l) OF THIS
RULE IF THE OWNER OR OPERATOR OF A PETROLEUM REFINERY CAN DEMONSTRATE
TO THE SATISFACTION OF THE DIRECTOR THAT THE ALTERNATIVE PROGRAM IS
AT LEAST AS EFFECTIVE IN IDENTIFYING, DOCUMENTING AND REPORTING
LEAKS FROM PETROLEUM REFINERY EQUIPMENT AS THE PROGRAM OUTLINED IN
PARAGRAPH (T)(l) OF THIS RULE. ANY ALTERNATIVE PROGRAM WHICH IS
ACCEPTED BY THE DIRECTOR SHALL BE SPECIFIED IN THE TERMS AND CONDITIONS
OF AN ORDER ISSUED BY THE DIRECTOR TO THE OWNER OR OPERATOR OF THE
PETROLEUM REFINERY PURSUANT TO DIVISION (S) OF SECTION 3704.03 OF
THE REVISED CODE.
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(U) SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS.
(1) EXCEPT WHERE EXEMPTED UNDER PARAGRAPH (U)(2) OF THIS RULE, NO OWNER
OR OPERATOR OF A MISCELLANEOUS METAL PART OR PRODUCT COATING LINE
MAY CAUSE, ALLOW OR PERMIT THE DISCHARGE INTO THE AMBIENT AIR OF ANY
VOLATILE ORGANIC COMPOUNDS FROM SUCH COATING LINE AFTER THE DATE
SPECIFIED IN PARAGRAPH (C)(28) OF RULE 3745-21-04 OF THE ADMINISTRATIVE
CODE UNLESS THE REQUIREMENTS OF EITHER PARAGRAPH (U)(l)(aJOR
TU)(l)(b) OF THIS RULE ARE SATISFIED.
(a) THE VOLATILE ORGANIC COMPOUND CONTENT OF EACH COATING EMPLOYED
IN THE MISCELLANEOUS METAL PART OR PRODUCT COATING LINE, AS
DETERMINED UNDER PARAGRAPH (B) OF RULE 3745-21-10 OF THE
ADMINISTRATIVE CODE, DOES NOT EXCEED THE LEAST STRINGENT OF ANY
0~F THE FOLLOWING LIMITATIONS WHICH ARE APPLICABLE:
(1) 4.3 POUNDS PER GALLON OF COATING, EXCLUDING WATER, FOR A
CLEAR COATING;
(11). 4.0 POUNDS PER GALLON OF COATING, EXCLUDING WATER, FOR A
ZINC RICH PRIMER COATING;
(ill) 3.5 POUNDS PER GALLON OF COATING, EXCLUDING WATER, FOR AN
EXTREME PERFORMANCE COATING;
(1v) 3.5 POUNDS PER GALLON OF COATING, EXCLUDING WATER, FOR ANY
COATING THAT IS DRIED AT TEMPERATURES NOT EXCEEDING TWO
HUNDRED DEGREES FAHRENHEIT;
(v) 5.0 POUNDS PER GALLON OF COATING, EXCLUDING WATER, FOR THE
INTERIOR COATING OF A STEEL PAIL OR DRUM;
(yj) 3.5 POUNDS PER GALLON OF COATING, EXCLUDING WATER, FOR THE
EXTERIOR COATING OF A STEEL PAIL OR DRUM; OR
(vli) 3.0 POUNDS PER GALLON OF COATING, EXCLUDING WATER, FOR ANY
COATING THAT IS NOT REGULATED UNDER PARAGRAPHS (U)(l)(a)(1)
TO (U)(l)(a)(v1) OF THIS RULE.
(b) THE MISCELLANEOUS METAL PART OR PRODUCT COATING LINE IS EQUIPPED
WITH A CAPTURE SYSTEM AND ASSOCIATED CONTROL SYSTEM WHICH ARE
DESIGNED AND OPERATED TO ACHIEVE THE FOLLOWING EFFICIENCIES FOR
VOLATILE ORGANIC COMPOUNDS, AS DETERMINED UNDER PARAGRAPH (C)
OF RULE 3745-21-10 OF THE ADMINISTRATIVE CODE:
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(1) A CAPTURE EFFICIENCY WHICH IS, IN THE JUDGMENT OF THE
DIRECTOR, A MAXIMUM REASONABLE AMOUNT BASED UPON GOOD
ENGINEERING DESIGN AS CONTAINED WITHIN THE FOLLOWING
DOCUMENTS:
(a.) "INDUSTRIAL VENTILATION", A MANUAL OF RECOMMENDED
PRACTICES, FOURTEENTH EDITION, "AMERICAN FEDERATION
OF INDUSTRIAL HYGIENISTS"; AND
(b) "RECOMMENDED INDUSTRIAL VENTILATION GUIDELINES",
UNITED STATES DEPARTMENT OF HEALTH, EDUCATION AND
WELFARE, "NATIONAL INSTITUTE OF OCCUPATIONAL SAFETY
AND HEALTH11"; AND
(11) A CONTROL EFFICIENCY WHICH IS AT LEAST NINETY PER CENT BY
WEIGHT.
(2) THE REQUIREMENTS OF PARAGRAPH (U)(l) OF THIS RULE SHALL NOT APPLY TO
THE FOLLOWING OPERATIONS:
(a) THE APPLICATION OF AN EXTERIOR COATING TO MARINE VESSELS;
(b) THE APPLICATION OF AN EXTERIOR COATING TO AIRPLANES;
(c) THE APPLICATION OF A REFINISHING COATING TO MOTOR VEHICLES;
(d) THE APPLICATION OF A CUSTOMIZED TOPCOAT AND ANY RELATED CUSTOMIZED
SINGLE COAT TO MOTOR VEHICLES, IF THE MAXIMUM NUMBER OF MOTOR
VEHICLES IS LESS THAN THIRTY-FIVE PER DAY:
(e) ANY COATING LINE WHICH EMPLOYS A MAXIMUM AMOUNT OF TEN OR LESS
GALLONS OF COATINGS PER DAY; AND
(f) ANY COATING LINE WHICH IS SUBJECT TO PARAGRAPH (C), (D), (E),
(I), (J), (K) OR (S) OF THIS RULE.
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(V) GASOLINE TANK TRUCKS.
(1) EXCEPT WHERE EXEMPTED UNDER PARAGRAPH (V)(3) OF THIS RULE, EACH
OWNER OR OPERATOR OF A GASOLINE TANK TRUCK SHALL COMPLY WITH THE
FOLLOWING TESTING, RECORD-KEEPING AND REPORTING REQUIREMENTS BY THE
DATE SPECIFIED IN PARAGRAPH (C)(29) OF RULE 3745-21-04 OF THE
ADMINISTRATIVE CODE:
(a) NO GASOLINE TANK TRUCK IS TO BE USED FOR THE TRANSFER OF
GASOLINE, UNLESS WITHIN THE PREVIOUS TWELVE MONTHS IT WAS
TESTED FOR LEAKS IN ACCORDANCE WITH THE METHOD SPECIFIED IN
PARAGRAPH (G) OF RULE 3745-21-10 OF THE ADMINISTRATIVE CODE;
(b) ANY GASOLINE TANK TRUCK WHICH SUSTAINS EITHER A PRESSURE
DECREASE GREATER THAN 3.0 INCHES OF WATER FOR THE PRESSURE
TEST OR A PRESSURE INCREASE GREATER THAN 3.0 INCHES OF WATER
FOR THE VACUUM TEST WHEN LAST TESTED FOR LEAKS IN ACCORDANCE
WITH THE METHOD SPECIFIED IN PARAGRAPH (G) OF RULE 3745-21-10
OF THE ADMINISTRATIVE CODE IS NOT TO BE USED FOR THE TRANSFER
OF GASOLINE;
(c) A RECORD IS TO BE MAINTAINED OF ALL GASOLINE TANK TRUCKS WHICH
ARE TESTED IN ACCORDANCE WITH PARAGRAPHS (V)(l)(a) AND (V)(2)
OF THIS RULE, AND SUCH RECORD IS TO CONTAIN, AT A MINIMUM, THE
FOLLOWING DATA:
(1) THE TANK IDENTIFICATION NUMBER OF THE GASOLINE TANK
TRUCK;
(1i). THE DATE AND LOCATION OF THE TEST;
(111) THE NAME, TITLE AND TELEPHONE NUMBER OF THE PERSON WHO
CONDUCTED THE TEST, AND THE NAME AND ADDRESS OF THE
COMPANY WHERE THE PERSON IS EMPLOYED;
(1v) THE TANK PRESSURE AND TIME FOR EACH OF THE FOLLOWING:
(a) THE START OF THE PRESSURE TEST;
(b) THE END OF THE PRESSURE TEST;
(c) THE START OF THE VACUUM TEST; AND
(d) THE END OF THE VACUUM TEST; AND
(v) THE RESULTANT PRESSURE CHANGES FOR THE PRESSURE
~~ TEST AND THE VACUUM TEST;
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(d) A COPY OF THE TEST RECORD REQUIRED IN PARAGRAPH (V)(l)(c) OF
THIS RULE IS TO BE RETAINED BY THE OWNER OR OPERATOR OF THE
TANK TRUCK FOR A MINIMUM OF TWO YEARS AFTER THE DATE ON WHICH
THE TEST WAS CONDUCTED;
(e) A COPY OF THE TEST RECORD REQUIRED IN PARAGRAPH (V)(l)(c) OF
THIS RULE IS TO IMMEDIATELY BE MADE AVAILABLE TO THE DIRECTOR,
OR AN AUTHORIZED REPRESENTATIVE OF THE DIRECTOR, UPON VERBAL OR
WRITTEN REQUEST, AT ANY REASONABLE TIME; AND
(f) A WRITTEN STATEMENT, CERTIFYING COMPLIANCE WITH THE REQUIREMENTS
OF PARAGRAPHS (V)(l)(a) AND (V)(l)(b) OF THIS RULE, IS TO BE
SUBMITTED BY JULY FIRST OF EACH YEAR TO EACH OWNER OR OPERATOR
OF ANY BULK GASOLINE TERMINAL, BULK GASOLINE PLANT AND GASOLINE
DISPENSING FACILITY AT WHICH GASOLINE IS TRANSFERRED TO OR FROM
SUCH GASOLINE TANK TRUCK.
(2) THE DIRECTOR MAY REQUIRE ANY GASOLINE TANK TRUCK TO BE TESTED IN
ACCORDANCE WITH THE METHOD SPECIFIED IN PARAGRAPH (G) OF RULE 3745-
21-10 OF THE ADMINISTRATIVE CODE WITHIN A REASONABLE PERIOD OF TIME.
ANY SUCH TEST SHALL BE REQUIRED BY MEANS OF AN ORDER ISSUED BY THE
DIRECTOR TO THE OWNER OR OPERATOR OF THE GASOLINE TANK TRUCK PURSUANT
TO DIVISION (S) OF SECTION 3704.03 OF THE REVISED CODE.
(3) EXEMPTED FROM THE REQUIREMENTS OF PARAGRAPHS (V)(l) AND (V)(2) OF
THIS RULE IS ANY GASOLINE TANK TRUCK:
(a) WHICH DOES NOT RECEIVE GASOLINE FROM ANY LOADING RACK WHICH IS
EQUIPPED WITH A VAPOR BALANCE SYSTEM OR VAPOR CONTROL SYSTEM;
AND
(b) WHICH DOES NOT DELIVER GASOLINE TO ANY STATIONARY STORAGE TANK
WHICH IS EQUIPPED WITH A VAPOR BALANCE SYSTEM.
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(W) SYNTHESIZED PHARMACEUTICAL MANUFACTURING FACILITY.
(1) EXCEPT WHERE EXEMPTED UNDER PARAGRAPH (W)(2) OF THIS RULE, EACH
OWNER OR OPERATOR OF A SYNTHESIZED PHARMACEUTICAL MANUFACTURING
FACILITY SHALL COMPLY WITH THE FOLLOWING REQUIREMENTS NO LATER THAN
THE DATE SPECIFIED IN PARAGRAPH (C)(30) OF RULE 3745-21-04 OF THE
ADMINISTRATIVE CODE:
(a) EXCEPT FOR ANY ORGANIC COMPOUND EMISSIONS WHICH ARE COLLECTED
BY A PRODUCTION EQUIPMENT EXHAUST SYSTEM, THE DISCHARGE OF
ORGANIC COMPOUND EMISSIONS INTO THE AMBIENT AIR FROM ANY
REACTOR, DISTILLATION OPERATION, CRYSTALLIZER, CENTRIFUGE OR
VACUUM DRYER IS TO, BE CONTROLLED BY ONE OF THE FOLLOWING
DEVICES:
(i) A SURFACE CONDENSER WHICH HAS AN OUTLET GAS CONCENTRATION
OF ORGANIC COMPOUNDS NOT EXCEEDING FIFTY THOUSAND PARTS
PER MILLION; OR
(11) A DEVICE OR SYSTEM WHICH IS, IN THE JUDGMENT OF THE
DIRECTOR, AT LEAST AS EFFECTIVE IN CONTROLLING ORGANIC
COMPOUND EMISSIONS AS THE ABOVE-MENTIONED SURFACE CONDENSER;
(b) THE DISCHARGE OF ORGANIC COMPOUND EMISSIONS INTO THE AMBIENT
AIR FROM ANY AIR DRYER OR PRODUCTION EQUIPMENT EXHAUST SYSTEM
IS NOT TO EXCEED THIRTY-THREE POUNDS IN ANY ONE DAY, UNLESS
SAID DISCHARGE HAS BEEN REDUCED BY AT LEAST NINETY PER CENT ON
A WEIGHT BASIS BY CONTROL EQUIPMENT;
(c) ANY STORAGE TANK WHICH HOLDS AN ORGANIC COMPOUND LIQUID THAT
HAS A VAPOR PRESSURE GREATER THAN 1.5 POUNDS PER SQUARE INCH
ABSOLUTE AT SIXTY-EIGHT DEGREES FAHRENHEIT IS TO BE EQUIPPED
WITH ONE OF THE FOLLOWING DEVICES:
(j) A CONSERVATION VENT WHICH OPENS AT A PRESSURE OF 0.5
OUNCE PER SQUARE INCH OR HIGHER AND AT A VACUUM OF 0.5
OUNCE PER SQUARE INCH OR HIGHER; OR
(11) A DEVICE OR SYSTEM WHICH IS, IN THE JUDGMENT OF THE
DIRECTOR, AT LEAST AS EFFECTIVE IN CONTROLLING ORGANIC
COMPOUND EMISSIONS AS THE ABOVE-MENTIONED CONSERVATION
VENT;
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(d) DURING ANY TRANSFER OF AN ORGANIC COMPOUND LIQUID, WHICH HAS A
VAPOR PRESSURE GREATER THAN 4.1 POUNDS PER SQUARE INCH ABSOLUTE
AT SIXTY-EIGHT DEGREES fAHRENHEIT, FROM A TRUCK OR RAILCAR TO
A FIXED ROOF TANK WHICH HAS A CAPACITY GREATER THAN TWO THOUSAND
GALLONS, THE VAPORS DISPLACED FROM SAID TANK ARE TO BE PROCESSED
BY ONE OF THE FOLLOWING SYSTEMS:
(i) A VAPOR BALANCE SYSTEM WHICH IS DESIGNED AND OPERATED TO
ROUTE AT LEAST NINETY PER CENT BY WEIGHT OF THE ORGANIC
COMPOUNDS IN THE DISPLACED VAPORS TO THE TRUCK OR RAILCAR;
OR
(11) A VAPOR CONTROL SYSTEM WHICH IS DESIGNED AND OPERATED TO
. RECOVER AT LEAST NINETY PER CENT BY WEIGHT OF THE ORGANIC
COMPOUNDS IN THE DISPLACED VAPORS;
(e) ANY CENTRIFUGE CONTAINING AN ORGANIC COMPOUND LIQUID, ANY
ROTARY VACUUM FILTER PROCESSING AN ORGANIC COMPOUND LIQUID AND
ANY OTHER FILTER HAVING AN EXPOSED ORGANIC COMPOUND LIQUID
SURFACE, ARE TO BE ENCLOSED IF THE ORGANIC COMPOUND LIQUID HAS
A VAPOR PRESSURE GREATER THAN 0.5 POUNDS PER SQUARE INCH
ABSOLUTE AT SIXTY-EIGHT DEGREES FAHRENHEIT;
(f) ANY IN-PROCESS TANK WHICH CONTAINS AN ORGANIC COMPOUND LIQUID
IS TO BE EQUIPPED WITH A COVER WHICH REMAINS CLOSED, EXCEPT
WHEN PRODUCTION, SAMPLING, MAINTENANCE OR INSPECTION PROCEDURES
REQUIRE ACCESS TO SAID TANK; AND
(g) ANY LEAK IN WHICH AN ORGANIC COMPOUND LIQUID IS OBSERVED TO BE
RUNNING OR DRIPPING FROM A VESSEL OR OTHER EQUIPMENT IS TO BE
REPAIRED AS SOON AS POSSIBLE, BUT NO LATER THAN THE FIRST TIME
SAID EQUIPMENT IS OFFLINE FOR A PERIOD OF TIME LONG ENOUGH TO
COMPLETE THE REPAIR.
(2) EXEMPTED FROM THE REQUIREMENTS OF PARAGRAPH (W)(l) OF THIS RULE IS
ANY OPERATION OR EQUIPMENT NOT ASSOCIATED WITH THE PRODUCTION OF
DRUGS.
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(X) RUBBER TIRE MANUFACTURING FACILITY.
(1) EXCEPT WHERE EXEMPTED UNDER PARAGRAPH (X)(2) OF THIS RULE, EACH
OWNER OR OPERATOR OF A RUBBER TIRE MANUFACTURING FACILITY SHALL
COMPLY WITH THE FOLLOWING REQUIREMENTS NO LATER THAN THE DATE
SPECIFIED IN PARAGRAPH (C)(31) OF RULE 3745-21-04 OF THE ADMINIS-
TRATIVE CODE:
(a) EACH UNDERTREAD CEMENTING, TREAD END CEMENTING AND BEAD DIPPING
OPERATION IS TO BE EQUIPPED WITH A CAPTURE SYSTEM AND ASSOCIATED
CONTROL SYSTEM WHICH ARE DESIGNED AND OPERATED WITH THE FOLLOWING
EFFICIENCIES FOR VOLATILE ORGANIC COMPOUNDS, AS DETERMINED
UNDER. PARAGRAPH (C) OF RULE 3745-21-10 OF THE ADMINISTRATIVE
CODE:
(i) A CAPTURE EFFICIENCY WHICH IS EITHER:
(a.) AT LEAST EIGHTY-FIVE PER CENT BY WEIGHT; OR
(b.) IN THE JUDGMENT OF THE DIRECTOR, A MAXIMUM REASONABLE
AMOUNT BASED UPON GOOD ENGINEERING DESIGN AS CON-
TAINED WITHIN THE FOLLOWING DOCUMENTS:
(l) "INDUSTRIAL VENTILATION", A MANUAL OF RECOMMENDED
PRACTICES, FOURTEENTH EDITION, "AMERICAN FEDERATION
OF INDUSTRIAL HYGIENISTS"; AND
(11) "RECOMMENDED INDUSTRIAL VENTILATION GUIDELINES",
UNITED STATES DEPARTMENT OF HEALTH, EDUCATION
AND WELFARE, "NATIONAL .INSTITUTE OF OCCUPATIONAL
SAFETY AND ^EALTH"; AND
(Ij.) A CONTROL EFFICIENCY WHICH IS AT LEAST NINETY PER CENT BY
WEIGHT; AND
(b) EXCEPT AS OTHERWISE PROVIDED IN PARAGRAPH (X)(l)(c) OF THIS
RULE, EACH GREEN TIRE SPRAYING OPERATION IS TO BE EQUIPPED WITH
A CAPTURE SYSTEM AND ASSOCIATED CONTROL SYSTEM WHICH ARE
DESIGNED AND OPERATED WITH THE FOLLOWING EFFICIENCIES FOR
• VOLATILE ORGANIC COMPOUNDS, AS DETERMINED UNDER PARAGRAPH (C)
OF RULE 3745-21-10 OF THE ADMINISTRATIVE CODE:
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(i) A CAPTURE EFFICIENCY WHICH IS EITHER:
(a.) AT LEAST NINETY PER CENT BY WEIGHT; OR
(bj IN THE JUDGMENT OF THE DIRECTOR, A MAXIMUM REASONABLE
AMOUNT BASED UPON GOOD ENGINEERING DESIGN AS CONTAINED
WITHIN THE FOLLOWING DOCUMENTS:
(i) "INDUSTRIAL VENTILATION", A MANUAL OF RECOMMENDED
PRACTICES, FOURTEENTH EDITION, "AMERICAN FEDERATION
OF INDUSTRIAL WGIENISTS"; AND
(11) "RECOMMENDED INDUSTRIAL VENTILATION GUIDELINES",
UNITED STATES DEPARTMENT OF HEALTH, EDUCATION
AND WELFARE, "NATIONAL INSTITUTE OF OCCUPATIONAL
SAFETY AND F[EALTH"; AND
(1i) A CONTROL EFFICIENCY WHICH IS AT'LEAST NINETY PER CENT BY
WEIGHT;
(c) THE REQUIREMENTS OF PARAGRAPH (X)(l)(b) OF THIS RULE DO NOT
APPLY TO ANY GREEN TIRE SPRAYING OPERATION IN WHICH THE VOLATILE
ORGANIC COMPOUND CONTENT OF THE MATERIAL SPRAYED, AS DETERMINED
BY A METHOD ACCEPTABLE TO THE DIRECTOR, IS A MAXIMUM DAILY
WEIGHTED AVERAGE OF SIX PER CENT OR LESS BY WEIGHT FOR MATERIAL
SPRAYED ON THE INSIDE OF A TIRE AND ELEVEN PER CENT OR LESS BY
WEIGHT FOR MATERIAL SPRAYED ON THE OUTSIDE OF A TIRE.
(2) EXEMPTED FROM THE REQUIREMENTS OF PARAGRAPH (X)(l) OF THIS RULE ARE
THE FOLLOWING OPERATIONS:
(a) ANY OPERATION NOT ASSOCIATED WITH RUBBER TIRES OF THE FOLLOWING
SIZE:
(i) A BEAD DIAMETER LESS THAN OR EQUAL TO 20.0 INCHES; AND
(ii) A CROSS-SECTIONAL DIMENSION LESS THAN OR EQUAL TO 12.8
INCHES,;
(b) ANY OPERATION IN WHICH THE MAXIMUM DISCHARGE OF VOLATILE
ORGANIC COMPOUNDS INTO THE AMBIENT AIR IS ONE HUNDRED POUNDS
' PER DAY OR LESS; AND
(c) ANY TREAD END CEMENTING OPERATION IN WHICH THE CEMENT IS
APPLIED MANUALLY WITH A BRUSH.
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(Y) FLEXOGRAPHIC, PACKAGING ROTOGRAVURE AND PUBLICATION ROTOGRAVURE PRINTING
LINES.
(1) EXCEPT WHERE EXEMPTED UNDER PARAGRAPH (Y)(2) OF THIS RULE, NO OWNER
OR OPERATOR OF A FLEXOGRAPHIC PRINTING LINE, PACKAGING ROTOGRAVURE
PRINTING LINE OR PUBLICATION ROTOGRAVURE PRINTING LINE MAY CAUSE,
ALLOW OR PERMIT THE DISCHARGE INTO THE AMBIENT AIR OF ANY VOLATILE
ORGANIC COMPOUNDS FROM SUCH PRINTING LINE AFTER THE DATE SPECIFIED
IN PARAGRAPH (C)(32) OF RULE 3745-21-04 OF THE ADMINISTRATIVE CODE
UNLESS THE REQUIREMENTS OF EITHER PARAGRAPH (Y)TD(a) OR (Y)(lJ(b)
OF THIS RULE ARE SATISFIED.
THE VOLATILE ORGANIC COMPOUND CONTENT OF EACH COATING AND INK
EMPLOYED IN SAID PRINTING LINE, AS DETERMINED UNDER PARAGRAPH
(B) OF RULE 3745-21-10 OF THE ADMINISTRATIVE CODE, DOES NOT
EXCEED THE FOLLOWING LIMITATION:
(i) FORTY PER CENT BY VOLUME, EXCLUDING WATER; OR
(11) TWENTY-FIVE PER CENT BY VOLUME OF THE VOLATILE CONTENT.
(b) SAID PRINTING LINE IS EQUIPPED WITH A CAPTURE SYSTEM AND
ASSOCIATED CONTROL SYSTEM WHICH ARE DESIGNED AND OPERATED TO
ACHIEVE THE FOLLOWING EFFICIENCIES FOR VOLATILE ORGANIC COMPOUNDS,
AS DETERMINED UNDER PARAGRAPH (C) OF RULE 3745-21-10 OF THE
ADMINISTRATIVE CODE:
(i) A CAPTURE EFFICIENCY WHICH IS:
(a) AT LEAST SIXTY-FIVE PER CENT BY WEIGHT, FOR A FLEXOGRAPHIC
PRINTING LINE;
(b) AT LEAST SEVENTY PER CENT BY WEIGHT, FOR A PACKAGING
ROTOGRAVURE PRINTING LINE;
(c) AT LEAST EIGHTY PER CENT BY WEIGHT, FOR A PUBLICATION
-Z- ROTOGRAVURE PRINTING LINE; OR
(d) IN THE JUDGMENT OF THE DIRECTOR, A MAXIMUM REASONABLE
— AMOUNT BASED UPON GOOD ENGINEERING DESIGN AS CONTAINED
WITHIN THE FOLLOWING DOCUMENTS:
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(i) "INDUSTRIAL VENTILATION". A MANUAL OF RECOMMENDED
PRACTICES, FOURTHEENTH EDITION, "AMERICAN FEDERATION
OF INDUSTRIAL HYGIENISTS"; AND
(11) "RECOMMENDED INDUSTRIAL VENTILATION GUIDELINES",
UNITED STATES DEPARTMENT OF HEALTH, EDUCATION AND
WELFARE, "NATIONAL INSTITUTE OF OCCUPATIONAL SAFETY
AND HEALTH"; AND
(ii) A CONTROL EFFICIENCY WHICH IS AT LEAST NINETY PER CENT BY
WEIGHT.
THE REQUIREMENTS OF PARAGRAPH (Y)(l) OF THIS RULE SHALL NOT APPLY TO
THE FOLLOWING PRINTING LINES:
(a) ANY PRINTING LINE WHICH APPLIES A VINYL COATING;
(b) ANY PRINTING LINE WHICH IS LOCATED AT A FACILITY IN WHICH THE
TOTAL MAXIMUM DISCHARGE OF VOLATILE ORGANIC COMPOUNDS INTO THE
AMBIENT AIR FROM ALL FLEXOGRAPHIC, PACKAGING ROTOGRAVURE AND
PUBLICATION ROTOGRAVURE PRINTING LINES IS LESS THAN OR EQUAL TO
ONE HUNDRED TONS PER YEAR; AND
(c) ANY PRINTING LINE WHICH IS USED SOLELY TO CHECK THE QUALITY OF
THE IMAGE FORMATION OF NEWLY ENGRAVED OR ETCHED CYLINDERS.
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(Z) STORAGE OF PETROLEUM LIQUIDS IN EXTERNAL FLOATING ROOF TANKS.
(1) EXCEPT WHERE EXEMPTED UNDER PARAGRAPH (Z)(3) OF THIS RULE, NO OWNER
OR OPERATOR OF AN EXTERNAL FLOATING ROOF TANK SHALL PLACE, STORE OR
HOLD ANY PETROLEUM LIQUID IN ANY SUCH TANK AFTER THE DATE SPECIFIED
IN PARAGRAPH (C)(33) OF RULE 3745-21-04 OF THE ADMINISTRATIVE CODE,
UNLESS THE TANK IS DESIGNED OR EQUIPPED AS FOLLOWS:
(a) THE TANK IS EQUIPPED WITH ONE OF THE FOLLOWING:
(1) A LIQUID MOUNTED PRIMARY SEAL AND A RIM MOUNTED SECONDARY
SEAL;
(11) -A MECHANICAL SHOE PRIMARY SEAL AND A RIM MOUNTED SECONDARY
SEAL;
(111) A MECHANICAL SHOE PRIMARY SEAL AND A SHOE MOUNTED SECONDARY
SEAL, PROVIDED THE SHOE MOUNTED SECONDARY SEAL WAS INSTALLED
PRIOR TO JANUARY 1, 1981;
(1v) A VAPOR MOUNTED PRIMARY SEAL AND A RIM MOUNTED SECONDARY
SEAL, PROVIDED THE VAPOR MOUNTFD PRIMARY SEAL WAS INSTALLED
PRIOR TO JANUARY 1, 1981; OR
(y) A SEAL, CLOSURE OR DEVICE WHICH IS, IN THE JUDGMENT OF THE
DIRECTOR, EQUIVALENT TO THE FOLLOWING DUAL SEALS IN
CONTROLLING THE EMISSION OF ORGANIC COMPOUNDS INTO THE
AMBIENT AIR:
(a) THE DUAL SEALS SPECIFIED IN PARAGRAPH (Z)(l)(a)(i) OR
— (Z)(l)(a)(11) OF THIS RULE; OR
(b) THE DUAL SEALS SPECIFIED IN PARAGRAPH (Z)(l)(a)(1ii)
-=- OR (Z)(l)(a)(iv) OF THIS RULE, PROVIDED SAID SEAL,
CLOSURE OR DEVICE WAS INSTALLED PRIOR TO JANUARY 1,
1981;
EACH SEAL MEETS THE FOLLOWING REQUIREMENTS:
(1) THERE ARE NO VISIBLE HOLES, TEARS, OR OTHER OPENINGS IN
THE SEAL OR SEAL FABRIC;
(11) IF THE TANK IS OF WELDED CONSTRUCTION, THE TOTAL SEAL GAP
— AREA, AS DETERMINED UNDER PARAGRAPH (H) OF RULE 3745-21-10
OF THE ADMINISTRATIVE CODE, DOES NOT EXCEED:
C'lio F-T'frirnirtl Prctsstisn
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(a.) 10.0 SQUARE INCHES PER FOOT OF TANK DIAMETER FOR A
- LIQUID MOUNTED PRIMARY SEAL, VAPOR MOUNTED PRIMARY
SEAL OR MECHANICAL SHOE PRIMARY SEAL;
(b.) 1.0 SQUARE INCH PER FOOT OF TANK DIAMETER FOR A RIM
- MOUNTED SECONDARY SEAL OR SHOE MOUNTED SECONDARY
SEAL; OR
(c.) THE AMOUNT WHICH IS ASSIGNED BY THE DIRECTOR FOR ANY
- SEAL WHICH IS EQUIVALENT UNDER PARAGRAPH (Z)(l)(a)(v)
OF THIS RULE;
(111). IF THE TANK IS OF RIVITED CONSTRUCTION, THE MAXIMUM SEAL
GAP WIDTH, AS DETERMINED UNDER PARAGRAPH (H) OF RULE 3745-
21-10 OF THE ADMINISTRATIVE CODE, DOES NOT EXCEED:
(a.) 2.5 INCHES FOR A MECHANICAL SHOE PRIMARY SEAL;
(b.) 1.5 INCHES FOR A LIQUID MOUNTED PRIMARY SEAL, VAPOR
- MOUNTED PRIMARY SEAL, SHOE MOUNTED SECONDARY SEAL OR
RIM MOUNTED SECONDARY SEAL; OR
(c) THE AMOUNT WHICH IS ASSIGNED RY THE DIRECTOR FOR ANY
- SEAL WHICH IS EQUIVALENT UNDEi. PARAGRAPH (Z)(l)(a)(v)
OF THIS RULE;
(c) ANY OPENING IN THE EXTERNAL FLOATING ROOF, EXCEPT AUTOMATIC
BLEEDER VENTS, RIM SPACE VENTS, LEG SLEEVES, STUB DRAINS AND
SLOTTED GAUGING/SAMPLING WELLS, IS EQUIPPED WITH:
(i) A COVER, SEAL OR LID WHICH REMAINS IN THE CLOSED POSITION
AT ALL TIMES WITHOUT ANY VISIBLE GAPS, EXCEPT WHEN THE
OPENING IS IN ACTUAL USE; AND
(11) A PROJECTION INTO THE TANK BELOW THE LIQUID SURFACE;
(d) ANY AUTOMATIC BLEEDER VENT REMAINS IN THE CLOSED POSITION,
EXCEPT WHEN THE EXTERNAL FLOATING ROOF IS FLOATED OFF OR
LANDED ON THE ROOF LEG SUPPORTS;
(e) ANY RIM VENT IS SET TO OPEN ONLY AT THE MANUFACTURER'S RECOMMENDED
SETTING, EXCEPT WHEN THE EXTERNAL FLOATING ROOF IS BEING
FLOATED OFF THE ROOF LEG SUPPORTS;
(f) ANY EMERGENCY ROOF DRAIN IS EQUIPPED WITH A SLOTTED MEMBRANE
FABRIC COVER OR OTHER DEVICE WHICH COVERS AT LEAST NINETY PER
CENT OF THE AREA OF THE OPENING;
(g) ANY STUB DRAIN IS EQUIPPED WITH A PROJECTION INTO THE TANK
BELOW THE LIQUID SURFACE; AND
(h) ANY SLOTTED GAUGING/SAMPLING WELL IS EQUIPPED WITH AN OBJECT
WHICH FLOATS ON THE LIQUID SURFACE WITHIN THE WELL AND WHICH
COVERS AT LEAST NINETY PER CENT OF THE AREA OF THE WELL OPENING.
1 2 1981
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(2) EXCEPT WHERE EXEMPTED UNDER PARAGRAPH (Z)(3) OF THIS RULE, EACH
OWNER OR OPERATOR OF AN EXTERNAL FLOATING ROOF TANK WHICH CONTAINS
A PETROLEUM LIQUID SHALL MEET THE FOLLOWING INSPECTION AND RECORD-
KEEPING REQUIREMENTS:
(a) INSPECT ANNUALLY ANY SEAL AND SEAL FABRIC FOR COMPLIANCE WITH
PARAGRAPH (Z)(l)(b)(i) OF THIS'RULE;
(b) MEASURE ANNUALLY, IN ACCORDANCE WITH THE METHOD SPECIFIED IN
PARAGRAPH (H) OF RULE 3745-21-10 OF THE ADMINISTRATIVE CODE,
THE SECONDARY SEAL GAP OR THE PRIMARY SEAL GAP, IF THERE IS NO
SECONDARY SEAL, FOR COMPLIANCE WITH THE SEAL GAP REQUIREMENTS
OF PARAGRAPH (Z)(l)(b)(ii) OF THIS RULE;
(c) MEASURE AT LEAST ONCE EVERY FIVE YEARS, IN ACCORDANCE WITH THE
METHOD SPECIFIED IN PARAGRAPH (H) OF RULE 3745-21-10 OF THE
ADMINISTRATIVE CODE, THE PRIMARY SEAL GAP, IF THERE IS A
SECONDARY SEAL, FOR COMPLIANCE WITH THE SEAL GAP REQUIREMENTS
OF PARAGRAPH (Z)(l)(b)(ii);
_(d]_ MAINTAIN FOR AT LEAST TWO YEARS A RECORD OF THE FOLLOWING:
(i) THE DATES AND RESULTS OF ANY INSPECTIONS OR MEASUREMENTS
PERFORMED IN ACCORDANCE WITH PARAGRAPHS (Z)(2)(a) TO
(Z)(2)(c) OF THIS RULE; AND
(jj) THE ANNUAL THROUGHPUT OF ANY PETROLEUM LIQUID STORED IN
THE TANK; AND
(el PROVIDE IMMEDIATELY TO THE DIRECTOR OR AN AUTHORIZED REPRESEN-
TATIVE OF THE DIRECTOR, UPON WRITTEN OR VERBAL REQUEST AT ANY
REASONABLE TIME, A COPY OF THE RECORD REQUIRED UNDER PARAGRAPH
(Z)(2)(d) OF THIS RULE.
(3) THE FOLLOWING EXTERNAL FLOATING ROOF TANKS SHALL BE EXEMPTED FROM
THE REQUIREMENTS OF PARAGRAPHS (Z)(l) AND (Z)(2) OF THIS RULE:
r^S:! Prafertion RIS
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(a) ANY TANK WHICH HAS A CAPACITY OF LESS THAN FORTY THOUSAND
GALLONS;
(b) ANY TANK WHICH HAS A CAPACITY OF LESS THAN FOUR HUNDRED
TWENTY THOUSAND GALLONS AND WHICH IS USED TO STORE PRODUCED
CRUDE OIL OR CONDENSATE PRIOR TO CUSTODY TRANSFER;
(c) ANY TANK WHICH CONTAINS A PETROLEUM LIQUID WHICH, AS STORED,
HAS A MAXIMUM TRUE VAPOR PRESSURE LESS THAN 1.5 POUNDS PER
SQUARE INCH ABSOLUTE; AND
(d) ANY TANK WHICH CONTAINS CRUDE OIL:
(f) WHICH HAS A POUR POINT OF FIFTY DEGREES FAHRENHEIT OR
HIGHER, AS DETERMINED BY "ASTM D 97-66, TEST FOR POUR
POINT OF PETROLEUM OILS"; OR ~
(11) WHICH HAS BEEN DEMONSTRATED TO THE SATISFACTION OF THE
DIRECTOR TO PRODUCE A DEPOSIT THAT CAN POTENTIALLY
DAMAGE ANY OTHERWISE REQUIRED SEAL.
F-r1:rn;:r*:i PrMta /lnc
EC BIGOTS m
FEB 121981
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(AA) DRY CLEANING FACILITY.
(1) EXCEPT WHERE EXEMPTED UNDER PARAGRAPH (AA)(2), NO OWNER OR OPERATOR
OF A DRY CLEANING FACILITY MAY CAUSE, ALLOW OR PERMIT THE DISCHARGE
INTO THE AMBIENT AIR OF PERCHLOROETHYLENE AFTER THE DATE SPECIFIED
IN PARAGRAPH (C)(34) OF RULE 3745-21-04 OF THE ADMINISTRATIVE CODE,
UNLESS THE FOLLOWING REQUIREMENTS ARE MET:
(a) THE EXHAUST FROM ANY DRYER WHICH CONTAINS ARTICLES CLEANED IN
PERCHLOROETHYLENE IS TO BE VENTED THROUGH ONE OF THE FOLLOWING
DEVICES:
(i) 'A CARBON ADSORBER WHICH EMITS NO MORE THAN ONE HUNDRED
PARTS PER MILLION BY VOLUME OF PERCHLOROETHYLENE AT ANY
TIME; OR
(11) A DEVICE WHICH IS, IN THE JUDGMENT OF THE DIRECTOR, AT
LEAST AS EFFECTIVE IN CONTROLLING EMISSIONS OF PERCHLOROETHYLENE
AS THE ABOVE-MENTIONED CARBON ADSORBER;
(b) THE WASTE FROM ANY DIATOMACEOUS EARTH FILTER WHICH HAS BEEN
USED TO FILTER PERCHLOROETHYLENE IS TO CONTAIN NO MORE THAN
TWENTY-FIVE PER CENT BY WEIGHT VOLATILE ORGANIC COMPOUNDS, AS
DETERMINED UNDER PARAGRAPH (I) OF RULE 3745-21-10 OF THE
ADMINISTRATIVE CODE;
(c) THE WASTE FROM ANY DISTILLATION OPERATION (SOLVENT STILL)
WHICH HAS BEEN USED TO DISTILL PERCHLOROETHYLENE IS TO CONTAIN
NO MORE THAN SIXTY PER CENT BY WEIGHT VOLATILE ORGANIC COMPOUNDS,
AS DETERMINED UNDER PARAGRAPH (I) OF RULE 3745-21-10 OF THE
ADMINISTRATIVE CODE;
(d) ANY DISPOSABLE FILTER CARTRIDGE WHICH HAS BEEN USED TO FILTER
PERCHLOROETHYLENE IS TO BE DRAINED IN THE FILTER HOUSING FOR
AT LEAST TWENTY-FOUR HOURS BEFORE BEING DISCARDED; AND
(e) ANY EQUIPMENT WHICH IS LEAKING PERCHLOROETHYLENE LIQUID IS NOT
TO BE OPERATED UNTIL THE LEAK IS REPAIRED.
(2) EXEMPTIONS:
(a) PARAGRAPH (AA)(1) OF THIS RULE SHALL NOT APPLY TO ANY DRY
CLEANING OPERATION WHICH IS COIN-OPERATED; AND
(b) PARAGRAPH (AA)(l)(a) OF THIS RULE (PERTAINING TO CARBON ADSORBERS)
SHALL NOT APPLY TO ANY FACILITY IN WHICH THE OWNER OR OPERATOR
HAS, IN THE JUDGMENT OF THE DIRECTOR, SATISFACTORILY DEMONSTRATED
THAT A CARBON ADSORBER CANNOT BE INSTALLED BECAUSE OF INSUFFICIENT
STEAM CAPACITY AND/OR INADEQUATE SPACE.
S/o rT.ta;r?.*! Prctestfon /i^ncy
WISHED DOCTOR'S JO!T"J"
FEB 1 21981
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3745-21-10 Compliance test methods and procedures.
(A) General provisions.
(1) The methods and procedures of this rule apply to sources
governed by rule 3745-21-09 of the Administrative Code.
(2) Alternative methods and/or procedures may be used to
demonstrate compliance with rule 3745-21-09 of the Administrative
Code provided that such methods or procedures are in accordance
with good engineering practice and authorized in writing by the
director.
(3) The results of any compliance testing required by the
director, other than tests conducted pursuant to paragraph (B) of
this rule, shall not be accepted unless the Ohio environmental
protection agency has been notified of the intent to test in
accordance with paragraph (A)(4) of this rule not less than
thirty days before the proposed initiation of the testing.
(4) Any person notifying the Ohio environmental protection
agency of a proposed emissions compliance test shall include as
part of the notification the following information:
(a) A statement indicating the purpose of the proposed
test and the applicable paragraph of rule 3745-21-09 of the
Administrative Code;
(b) A detailed description of the facility to be tested;
(c) A detailed description of the test procedures, equipment
and sampling sites; and
(d) A timetable, setting forth the dates on which:
(i) The testing will be conducted;
(ii) The final test report will be submitted (not
later than thirty days after completion of onsite
sampling).
(5) For any source compliance determination, the owner or
operator of the source shall be responsible for providing:
(a) Sampling ports, pipes, lines, or appurtenances for
the collection of samples and data required by the test
procedures;
C& Eivi;c:"~t:i Protsstion n^
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(b) Safe access to the sample and data collection locations;
and
(c) Light, electricity, and other utilities required for
sample and data collection.
(B) Method for the determination of volatile organic compound content
of surface coatings.
(1) This method applies to the determination of the volatile
organic compound content of paint, varnish, lacquer, and
surface coatings which are air-dried or force-dried.
(2) This method does not apply to surface coatings employed
in the following coating lines:
(a) Coating lines employing exposure to ultraviolet light
to promote cross-linking; or
(b) Any other coating line employing a special curing process
as determined by the director.
(3) For the purpose of this method, the applicable surface
coatings are divided into the following three classes:
(a) Class I (general solvent type paints). This class
includes white linseed oil outside paint, white soya and
phthalic alkyd enamel, white linseed o-phthalic alkyd
enamel, red lead primer, zinc chromate primer, flat white
inside enamel, white epoxy enamel, white vinyl toluene
modified alkyd, white amino mocifisd baking enamel, and
other sol vent-type paints not included in class II or III.
(b) Class II (varnishes and lacquers). This class includes
clear and pigmented lacquers and varnishes.
(c) Class III (waterborne paints). This class includes
emulsion or latex paints and colored enamels.
(4) For the purposes of this method, a representative sample of
'the surface coating shall be obtained at the point of delivery
to the coater or any other point in the process that is acceptable
to the Ohio environmental protection agency.
(5) The volatile organic content of the sample shall be determined
as follows:
(a) Assign the coating to one of the three classes in
paragraph (B)('3) of this seetien RULE. Assign any coating
not clearly belonging to class II or III to class I.
Ft B 1 21281
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(b) Determine the density D™ (in grams per cubic centimeter)
of the paint, varnish, lacquer, or related product according
to the procedure outlined in "ASTM D 1475-60, Standard
Method of Test for Density of Paint, Varnish, Lacquer, and
Related Products". Then, depending on the class of the
coating, use one of the following specified procedures to
determine the volatile content:
(i) Class I. Use the procedure in "ASTM D 2369-73,
Standard Method of Test for Volatile Content of
Paints".
(a) Record the following information:
W-| = weight of dish and sample, grams
W2 = weight of dish and sample after heating,
grams
S = sample weight, grams
(b) Compute the volatile matter content Cv (in
grams per liter of paint) as follows:
Cv =
(Wj - W2)(Dm)(103)
(c_) To convert grams per liter to pounds per
gallon multiply Cv by 8.3455 x 10"3.
(ii) Class II. Use the procedure in "ASTM D 1644-59
Method A, Standard Methods of Ttst for Nonvolatile
Content of Varnishes".
(a_) Record the following information:
A = weight of dish, grams
B = weight of sample used, grams
C = weight of dish and contents after
heating, grams
Era Frivir fctoZfcl Mutfto fo
EtfEKD OirtECTOr
FEB 1 21981
75
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(bj Compute the volatile matter content Cv
(in grams per liter) as follows:
(A + B - C)(Dm)(lQ3)
B
(c_) To convert grams per liter to pounds per
gallon, multiply Cv by 8.3455 x 10'3.
(iii) Class III. Use the procedure in "ASTM D 2369-73,
Standard Method of Test for Volatile Content of
Paints".
(aj Record the same information as specified in
paragraph (B)(5)(b)(1) of this rule.
(b_) Determine the water content P (in per cent
water by weight) of the paint according to the
procedure outlined in "Federal Standard 141A,
Method 4082.1, Water in Paint and Varnishes
(Karl Fischer Titration Method)".
(c_) Compute the nonaqueous volatile matter content
Cv (in grams per liter, EXCLUDING WATER) as
follows:
(W-, - W2 - 0.01 P
S_ (1 - 0.01 PJ
(d_) To convert grams per liter^ EXCLUDING WATER_,_ to
pounds per gallon, EXCLUDING WATER_,_ multiply Cv
by 8.3455 x 10'3.
(C) Method for the determination of mass emission rate and/or control
equipment efficiency for a source equipped with control equipment
designed to reduce the emission of organic compounds or volatile
organic compounds.
(1) The provisions of this paragraph are generally applicable to
any test method employed to determine the collection or control
efficiency and/or mass emission rate for any control equipment
designed, installed, and operated for the purpose of reducing
the emission of organic compounds or volatile oruanic compounds,
FOR PURPOSES OF THIS PARAGRAPH "VAPOR COLLECTION"SYSTEM" ALSO
MEANS CAPTURE SYSTEM AND "VAPOR CONTROL SYSTEM" ALSO MEANS
CONTROL SYSTEM.
— P.-V - • ,_ .....
FEB 1 2 1981
76
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(2) The following procedures shall be included in any efficiency
determination and/or mass emission rate determination where
applicable:
(a) The source shall be operated at or near maximum
operating capacity during any testing and the measurement
of the operating rate shall be made in a manner acceptable
to the Ohio environmental protection agency.
(b) The organic compound containing material shall be
sampled and analyzed in a manner acceptable to the Ohio
environmental protection agency such that the quantity of
emissions of organic compounds or volatile organic compounds
that could result from the use of the material can be
quantified.
(c) The efficiency of any vapor collection system used to
transport the volatile organic compound emissions from
their point of origin to the vapor control equipment shall
be computed or measured in a manner based upon accepted
engineering practice and in a manner acceptable to the
Ohio environmental protection agency.
(d) Samples of the gas stream containing organic compounds
or volatile organic compounds shall be taken simultaneously
at the inlet and outlet of the vapor control system in a
manner acceptable to the Ohio environmental protection
agency.
(e) The total combustible carbon content of the samples
taken under paragraph (C)(2)(c) of this rule shall be
determined by a method acceptable to the Ohio environmental
protection agency.
(f) The efficiency of the vapor control system shall be
expressed as the per cent of total combustible carbon
content reduction achieved.
(g) The efficiency of the vapor collection system shall be
expressed as the per cent of total emissions of organic
compounds or volatile organic compounds emitted from the
source which are vented to the vapor control system.
(h) The mass emission rate of organic compounds or volatile
organic compounds shall be the sum of emissions from the
vapor control system, emissions not collected by the vapor
collection system and emissions from any losses associated
with the vapor collection system and vapor control system.
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(F) METHOD FOR THE DETECTION OF LEAKS OF ORGANIC COMPOUNDS FROM
PETROLEUM REFINERY EQUIPMENT.
Cl) THIS METHOD IS APPLICABLE TO THE DETECTION OF LEAKS OF
ORGANIC COMPOUNDS INTO THE AMBIENT AIR FROM PETROLEUM REFINERY
EQUIPMENT.
(2) THIS METHOD DESCRIBES THE PROCEDURES TO BE FOLLOWED FOR
DETECTING LEAKS OF ORGANIC COMPOUNDS FROM PETROLEUM REFINERY
EQUIPMENT DURING NORMAL OPERATION BY MEANS OF A PORTABLE GAS
DETECTOR. ALSO, THIS METHOD DESCRIBES THE PROCEDURES TO BE
FOLLOWED FOR CALIBRATION AND PERFORMANCE TESTING OF THE
PORTABLE GAS DETECTOR. (ALL MEASUREMENTS OF THE CONCENTRATION
OF ORGANIC COMPOUNDS ARE EXPRESSED IN PARTS PER MILLION BY
VOLUME AS HEXANE.)
_(3j_ ANY PORTABLE GAS DETECTOR SHALL:
(a) BE EQUIPPED WITH A PUMP FOR CONTINUOUS SAMPLING;
(b) HAVE THE CAPABILITY (OR OPTION) FOR MEASURING CONCENTRATIONS
IN THE RANGE OF TEN THOUSAND PARTS PER MILLION BY
VOLUME;
(c) BE EQUIPPED WITH A METER OR OTHER READOUT DEVICE WHICH
CAN BE READ TO PLUS OR MINUS FIVE PER CENT AT TEN
THOUSAND PARTS PER MILLION BY VOLUME; AND
(d) MEET THE FOLLOWING PERFORMANCE CRITERIA:
(i) THE ZERO DRIFT FOR A TWO-HOUR PERIOD DOES NOT
EXCEED FIVE PARTS PER MILLION BY VOLUME AS HEXANE;
(ii) THE CALIBRATION DRIFT FOR A TWO-HOUR PERIOD DOES
NOT EXCEED FIVE PER CENT OF THE CONCENTRATION OF
THE CALIBRATION GAS;
(iii) THE CALIBRATION ERROR DOES NOT EXCEED FIVE PER
CENT OF THE CONCENTRATION OF THE CALIBRATION GAS;
AND
(jy) THE RESPONSE TIME DOES NOT EXCEED FIVE SECONDS.
(4) THE FOLLOWING GAS MIXTURES SHALL BE EMPLOYED FOR THE CALIBRATION
AND PERFORMANCE TESTING OF THE PORTABLE GAS DETECTOR, EXCEPT
AS PROVIDED IN PARAGRAPH (F)(5) OF THIS RULE:
FFR 1 21931
86
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(a) A ZERO GAS WHICH CONTAINS LESS THAN THREE PARTS PER
MILLION BY VOLUME OF HEXANE IN AIR; AND
(b) A CALIBRATION GAS WHICH CONTAINS ABOUT TEN THOUSAND PARTS
PER MILLION BY VOLUME OF HEXANE IN AIR ACCURATE TO WITHIN
PLUS OR MINUS TWO PER CENT.
(5) AN ALTERNATIVE GAS MAY BE USED IN PLACE OF HEXANE IN PARAGRAPH
(F)(4) OF THIS RULE PROVIDED A RELATIVE RESPONSE FACTOR FOR
THE PORTABLE GAS DETECTOR IS DETERMINED SO THAT CALIBRATIONS
WITH THE ALTERNATIVE GAS MAY BE EXPRESSED AS HEXANE EQUIVALENTS
ON THE METER OR READOUT DEVICE.
(6) ANY PORTABLE GAS DETECTOR WHICH IS USED UNDER THIS METHOD
SHALL BE SUBJECT TO AND MUST PASS THE PERFORMANCE TEST SPECIFIED
IN PARAGRAPH (F}(7) OF THIS RULE AT THE FOLLOWING TIMES:
(a) PRIOR TO BEING PLACED INTO INITIAL SERVICE;
(b) PRIOR TO BEING PLACED INTO SERVICE AFTER ANY REPAIR OR
MODIFICATION; AND
(c) WITHIN SIX MONTHS AFTER THE MOST RECENT PERFORMANCE TEST.
(7) A PERFORMANCE TEST OF A PORTABLE GAS DETECTOR SHALL BE CONDUCTED
ACCORDING TO THE FOLLOWING PROCEDURES:
(a) ASSEMBLE AND START UP THE PORTABLE GAS DETECTOR IN ACCORDANCE
WITH THE MANUFACTURER'S INSTRUCTIONS FOR RECOMMENDED
WARMUP AND PRELIMINARY ADJUSTMENT;
(b) TEST THE ZERO DRIFT AND CALIBRATION DRIFT AS FOLLOWS:
(1) CALIBRATE THE PORTABLE GAS DETECTOR ACCORDING TO
THE MANUFACTURER'S INSTRUCTIONS WITH THE ZERO AND
CALIBRATION GASES SPECIFIED IN PARAGRAPH (F)(4) OF
THIS RULE AND RECORD THE TIME, THE INITIAL ZERO GAS
READING AND THE INITIAL CALIBRATION GAS READING;
(11) AFTER TWO HOURS OF CONTINUOUS OPERATION, INTRODUCE
THE ZERO AND CALIBRATION GASES INTO THE PORTABLE GAS
DETECTOR AND RECORD THE FINAL ZERO GAS READING AND
THE FINAL CALIBRATION GAS READING;
FFR 1 21981
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(111) REPEAT FOR THREE MORE RUNS THE PROCEDURES IN PARAGRAPHS
(F)(7)(b)(i) AND (F)(7)(b)(11) OF THIS RULE;
(1v) CALCULATE THE MEAN ZERO DRIFT BY ADDING THE ABSOLUTE
VALUES OF THE DIFFERENCES BETWEEN THE INITIAL AND FINAL
ZERO GAS READINGS FOR THE FOUR TWO-HOUR RUNS AND DIVIDING
BY FOUR;
(v) CALCULATE THE MEAN CALIBRATION DRIFT BY ADDING THE ABSOLUTE
VALUES OF THE DIFFERENCES BETWEEN THE INITIAL AND FINAL
CALIBRATION GAS READINGS FOR THE FOUR TWO-HOUR RUNS AND
DIVIDING BY FOUR; AND
(vi) IF THE MEAN ZERO DRIFT EXCEEDS FIVE PARTS PER MILLION BY
•VOLUME AS HEXANE OR IF THE MEAN CALIBRATION DRIFT EXCEEDS
FIVE PER CENT OF THE CONCENTRATION OF THE CALIBRATION GAS,
THE PORTABLE GAS DETECTOR HAS FAILED THE PERFORMANCE TEST;
(c) TEST THE CALIBRATION ERROR AS FOLLOWS:
(1) CALIBRATE THE PORTABLE GAS DETECTOR ACCORDING TO THE
MANUFACTURER'S INSTRUCTIONS WITH THE ZERO AND CALIBRATION
GASES SPECIFIED IN PARAGRAPH (F)(4) OF THIS RULE;
(11) OBTAIN AND RECORD NINE MEASUREMENTS OF THE CONCENTRATION
OF THE CALIBRATION GAS BY ALTERNATING BETWEEN THE ZERO GAS
AND THE CALIBRATION GAS;
(111) CALCULATE THE MEAN CALIBRATION ERROR BY ADDING THE ABSOLUTE
VALUES OF THE DIFFERENCES BETWEEN THE CALIBRATION GAS
CONCENTRATIONS AND THE RECORDED MEASUREMENTS FOR THE NINE
MEASUREMENTS AND DIVIDING BY NINE; AND
(1v) IF THE MEAN CALIBRATION ERROR EXCEEDS FIVE PER CENT OF
THE CONCENTRATION OF THE CALIBRATION GAS, THE PORTABLE GAS
DETECTOR HAS FAILED THE PERFORMANCE TEST;
(d) TEST THE RESPONSE TIME AS FOLLOWS:
(1) CALIBRATE THE PORTABLE GAS DETECTOR ACCORDING TO THE
MANUFACTURER'S INSTRUCTIONS WITH THE ZERO AND CALIBRATION
GASES SPECIFIED IN PARAGRAPH (F)(4) OF THIS RULE;
FFR 1 2 1981
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(ii) INTRODUCE ZERO GAS INTO THE PORTABLE GAS DETECTOR
THROUGH THE DETECTOR'S PROBE; WAIT FOR THE METER OR
READOUT DEVICE TO STABILIZE; SWITCH QUICKLY TO THE
CALIBRATION GAS; MEASURE THE TIME THE METER OR
READOUT DEVICE TAKES TO REACH NINETY-FIVE PER CENT
OF THE CALIBRATION READING AFTER THE SWITCH TO THE
CALIBRATION GAS (RESPONSE TIME); AND RECORD THE
RESPONSE TIME;
(111) PERFORM THE TEST SEQUENCE IN PARAGRAPH (F)(7)(d)(1i)
OF THIS RULE THREE TIMES;
(iv) CALCULATE THE MEAN RESPONSE TIME BY ADDING THE THREE
RESPONSE TIMES AND DIVIDING BY THREE; AND
(v) IF THE MEAN RESPONSE TIME EXCEEDS FIVE SECONDS, THE
PORTABLE GAS DETECTOR HAS FAILED THE PERFORMANCE
TEST.
(8) PETROLEUM REFINERY EQUIPMENT SHALL BE TESTED FOR LEAKS ACCORDING
TO THE FOLLOWING PROCEDURES:
(a) CALIBRATE THE PORTABLE GAS DETECTOR ACCORDING TO THE
MANUFACTURER'S INSTRUCTIONS WITH THE ZERO AND CALIBRATION
GASES SPECIFIED IN PARAGRAPH (F)(4) OF THIS RULE;
(b) OBTAIN A GAS SAMPLE FROM THE COMPONENT BY PLACING THE
PROBE AT AN INTERFACE OR EMISSION POINT IN THE FOLLOWING
MANNER:
(t) FOR BLOCK (GLOVE, PLUG, GATE, BALL, ETC.) AND CONTROL
VALVES, THE PROBE SHOULD BE PLACED AT THE INTERFACE
WHERE THE STEM EXITS THE SEAL, AND SAMPLES SHOULD BE
TAKEN ON ALL SIDES OF THE STEM;
(ii) FOR VALVES IN WHICH THE HOUSING IS A MULTIPART
ASSEMBLY OR IN WHICH LEAKS CAN OCCUR FROM POINTS
OTHER THAN THE STEM SEAL, THE PROBE SHOULD BE PLACED
AT THE INTERFACE OF THE HOUSING OR OTHER POSSIBLE
LEAKING POINT;
(111) FOR WELDED FLANGES, THE PROBE SHOULD BE PLACED AT
THE INTERFACE BETWEEN THE FLANGE AND GASKET, AND
SAMPLES SHOULD BE TAKEN FROM AROUND THE CIRCUMFERENCE
OF THE FLANGE;
FFR 1 21981
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(iv) FOR CONNECTIONS WHICH ARE NOT FLANGES (E.G., THREADED
CONNECTIONS), THE PROBE SHOULD BE PLACED AT THE INTERFACE
OF THE CONNECTION AND- SAMPLES SHOULD BE TAKEN FROM AROUND
THE CIRCUMFERENCE OF THE CONNECTION;
(v) FOR PUMPS AND COMPRESSORS, THE PROBE SHOULD BE PLACED AT
ALL ACCESSIBLE PORTIONS OF THE INTERFACE BETWEEN THE
HOUSING SEAL AH THE OUTER SURFACE 3F THE PUMP OR COMPRESSOR,
WITHIN 0.5 INCHES OF ANY SHAFT-SEAL INTERFACE IN WHICH THE
PROBE CANNOT BE PLACED IN CONTACT WITH A ROTATING SHAFT,
AT ALL OTHER JOINTS WHERE LEAKAGE COULD OCCUR, AND, IF
SEALING OIL IS USED, AT APPROXIMATELY THE CENTER OF THE
END OF THE VENT FROM THE SEAL OIL RESERVOIR;
(vi) FOR PRESSURE RELIEF VALVES WHICH HAVE AN ENCLOSED EXTENSION
• OR HORN, THE PROBE SHOULD BE PLACED AT APPROXIMATELY THE
CENTER OF THE EXHAUST AREA TO THE AMBIENT AIR;
(viil FOR OPEN PROCESS DRAINS, THE PROBE SHOULD BE PLACED AT
APPROXIMATELY THE CENTER OF THE AREA OPEN TO THE AMBIENT
AIR;
(viii) FOR COVERED PROCESS DRAINS, THE PROBE SHOULD BE PLACED AT
THE COVER'S CIRCUMFERENTIAL INTERFACE; AND
(ix) FOR OPEN-ENDED VALVES (E.G., SAMPLE TAPS OR DRAIN LINES),
THE PROBE SHOULD BE PLACED AT APPROXIMATELY THE CENTER OF
THE UNCAPPED OPENING TO THE AMBIENT AIR;
(c) WHEN SAMPLING AN INTERFACE ON A COMPONENT, MOVE THE
PROBE SLOWLY ALONG THE SURFACE OF THE INTERFACE WITH THE INLET
OF THE PROBE POSITIONED AT THE LOCAL UPWIND AND DOWNWIND SIDE
OF THE INTERFACE; AND
(d) FOR ANY SAMPLE WHICH HAS A CONCENTRATION EXCEEDING TEN THOUSAND
PARTS PER MILLION BY VOLUME AS HEXANE, RECORD THE DATE, TIME
AND COMPONENT'S IDENTIFICATION.
FFR121981
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(9) AN ALTERNATIVE METHOD OF LEAK DETECTION, BASED UPON THE MEASUREMENT
OF AMBIENT ORGANIC COMPOUND CONCENTRATIONS IN A PROCESS UNIT AREA,
MAY BE USED IN PLACE OF THE TESTING OF EACH COMPONENT BY THE METHOD
SPECIFIED IN PARAGRAPHS (F)(l) TO (F)(8) OF THIS RULE IF, IN THE
JUDGMENT OF THE DIRECTOR, SUCH ALTERNATIVE METHOD IS EFFECTIVE IN
LOCATING INDIVIDUAL EQUIPMENT LEAKS. ANY EQUIPMENT WHICH IS LOCATED
WITHIN A PROCESS UNIT AREA AND WHICH IS DETERMINED TO HAVE AN EXCESSIVE
LEAK BY SUCH ALTERNATIVE METHOD SHALL ALSO BE TESTED BY THE PROCEDURES
CONTAINED IN PARAGRAPHS (F)(l) TO (F)(8) OF THIS RULE.
FFfl 1 21981
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(G) METHOD FOR THE DETERMINATION OF THE LEAK TIGHTNESS OF GASOLINE TANK TRUCKS.
(1) THIS METHOD IS APPLICABLE TO DETERMINING THE LEAK TIGHTNESS OF GAS-
OLINE TANK TRUCKS WHICH ARE EQUIPPED WITH PIPING, HOSES AND OTHER
DEVICES FOR THE COLLECTION OR RETURN OF GASOLINE VAPORS DURING THE
TRANSFER OF GASOLINE AT A GASOLINE DISPENSING FACILITY, BULK GASOLINE
PLANT OR BULK GASOLINE TERMINAL.
(2) THIS METHOD DESCRIBES THE TEST CONDITIONS AND TEST PROCEDURES TO BE
FOLLOWED IN DETERMINING THE LEAK TIGHTNESS OF GASOLINE TANK TRUCKS.
UNDER THESE PROCEDURES THE CHANGE OF PRESSURE WITHIN THE COMPARTMENTS
OF A GASOLINE TANK TRUCK ARE RECORDED AT A SPECIFIED TIME AFTER THE
COMPARTMENTS ARE PRESSURIZED TO A SPECIFIED PRESSURE AND AFTER THE
COMPARTMENTS ARE EVACUATED TO A SPECIFIED PRESSURE.
(3) THE FOLLOWING EQUIPMENT ARE REQUIRED FOR THIS METHOD:
(a) A PUMP, BLOWER OR CYLINDER OF COMPRESSED AIR OR INERT GAS WHICH
IS CAPABLE OF PRESSURIZING THE GASOLINE TANK TRUCK TO TWENTY-
FIVE INCHES OF WATER ABOVE ATMOSPHERIC PRESSURE;
(b) A LOW PRESSURE REGULATOR WHICH IS USED TO CONTROL THE PRESSURI-
ZATION OF THE GASOLINE TANK TRUCK;
(c) A VACUUM PUMP WHICH IS CAPABLE OF EVACUATING THE GASOLINE TANK
TRUCK TO TEN INCHES OF WATER BELOW ATMOSPHERIC PRESSURE;
(d) A LIQUID MANOMETER (OR EQUIVALENT INSTRUMENT) WHICH IS CAPABLE
OF MEASURING UP TO TWENTY-FIVE INCHES OF WATER GAUGE PRESSURE
WITH A PRECISION OF PLUS OR MINUS 0.1 INCHES OF WATER;
(e) A TEST CAP WHICH HAS A FITTING FOR CONNECTION TO THE GASOLINE
TANK TRUCK'S VAPOR RECOVERY LINE, A PRESSURE TAP FOR CONNECTION
TO THE MANOMETER (OR EQUIVALENT INSTRUMENT), AND A SHUT-OFF
VALVE FOR CONNECTION TO THE PRESSURE/VACUUM SUPPLY LINE;
(f) AN IN-LINE PRESSURE/VACUUM RELIEF VALVE WHICH IS SET TO ACTIVATE
AT TWENTY-EIGHT INCHES OF WATER ABOVE ATMOSPHERIC PRESSURE OR
TWELVE INCHES OF WATER BELOW ATMOSPHERIC PRESSURE AND WHICH HAS
A CAPACITY EQUAL TO THE CAPACITY OF THE PRESSURE AND EVACUATION
.EQUIPMENT;
CAPS FOR THE LIQUID DELIVERY LINES; AND
A PRESSURE/VACUUM SUPPLY LINE.
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FFB 1 21981
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(4) THE PRE-TEST CONDITIONS ARE AS FOLLOWS:
(a) THE GASOLINE TANK TRUCK SHALL BE PURGED OF GASOLINE VAPORS IN
A SAFE MANNER (E.G., FLUSHING WITH DIESEL FUEL OR HEATING FUEL)
AND SHALL BE TESTED EMPTY; AND
(b) THE GASOLINE TANK TRUCK SHALL BE LOCATED AT A SITE WHICH IS
PROTECTED FROM DIRECT SUNLIGHT.
(5) THE TEST PROCEDURES ARE AS FOLLOWS:
(a) OPEN AND CLOSE THE DOME COVERS;
(b) CONNECT STATIC ELECTRICAL GROUND CONNECTIONS TO THE GASOLINE
TANK TRUCK, ATTACH THE DELIVERY AND VAPOR HOSES, REMOVE THE
DELIVERY ELBOWS AND ATTACH CAPS TO THE LIQUID DELIVERY LINES;
(c) CONNECT THE TEST CAP TO THE VAPOR RECOVERY LINE OF THE GASOLINE
TANK TRUCK, CONNECT THE PRESSURE/VACUUM SUPPLY LINE AND THE
PRESSURE/VACUUM RELIEF VALVE TO THE SHUT-OFF VALVE IN THE TEST
CAP, CONNECT THE MANOMETER (OR EQUIVALENT INSTRUMENT) TO THE
PRESSURE TAP IN THE TEST CAP;
(d) CONNECT THE COMPARTMENTS OF THE GASOLINE TANK TRUCK INTERNALLY
TO EACH OTHER, IF POSSIBLE (IF NOT POSSIBLE, EACH COMPARTMENT
MUST BE TESTED SEPARATELY);
(e) CONNECT THE PRESSURE SOURCE TO THE PRESSURE/VACUUM SUPPLY LINE;
(f) OPEN THE SHUT-OFF VALVE IN THE TEST CAP AND ALLOW THE PRESSURE
WITHIN THE GASOLINE TANK TRUCK (OR, ALTERNATIVELY, A COMPARTMENT
OF THE GASOLINE TANK TRUCK) TO SLOWLY REACH THIRTEEN INCHES OF
WATER GAUGE.PRESSURE;
(g) CLOSE THE SHUT-OFF VALVE IN THE TEST CAP, ALLOW THE PRESSURE TO
STABILIZE, AND ADJUST THE PRESSURE, IF NECESSARY, TO MAINTAIN
THIRTEEN INCHES OF WATER;
(h) RECORD THE TIME AND INITIAL PRESSURE WHEN THE PRESSURE IS
STABLE AT NO LESS THAN 18.0 INCHES OF WATER GAUGE PRESSURE,
WITH THE SHUT-OFF VALVE IN THE TEST CAP CLOSED;
(i) RECORD THE TIME AND FINAL PRESSURE AT THE END OF FIVE MINUTES
AFTER THE INITIAL PRESSURE READING;
\ 21981
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(j) DISCONNECT THE PRESSURE SOURCE FROM THE PRESSURE/VACUUM LINE
AND OPEN SLOWLY THE SHUT-OFF VALVE IN THE TEST CAP TO ALLOW THE
PRESSURE IN THE GASOLINE TANK TRUCK (OR, ALTERNATIVELY, A COM-
PARTMENT OF THE GASOLINE TANK TRUCK) TO REACH ATMOSPHERIC
PRESSURE;
(k) CONNECT THE VACUUM SOURCE TO THE PRESSURE/VACUUM SUPPLY LINE;
(1) OPEN THE SHUT-OFF VALVE IN THE TEST CAP AND ALLOW THE PRESSURE
WITHIN THE GASOLINE TANK TRUCK (OR, ALTERNATIVELY, A COMPARTMENT
OF THE GASOLINE TANK TRUCK) TO SLOWLY REACH MINUS SIX INCHES OF
WATER GAUGE PRESSURE;
(m) CLOSE THE SHUT-OFF VALVE IN THE TEST CAP, ALLOW THE PRESSURE TO
STABILIZE AND ADJUST THE PRESSURE, IF NECESSARY, TO MAINTAIN
MINUS SIX INCHES OF WATER GAUGE PRESSURE;
(n) RECORD THE TIME AND INITIAL PRESSURE WHEN THE PRESSURE IS
STABLE AT NO MORE THAN MINUS SIX INCHES OF WATER GAUGE PRESSURE,
WITH THE SHUT-OFF VALVE IN THE TEST CAP CLOSED;
(o) RECORD THE TIME AND FINAL PRESSURE AT THE END OF FIVE MINUTES
AFTER THE INITIAL PRESSURE READING;
(p) DISCONNECT THE VACUUM SOURCE FROM THE PRESSURE/VACUUM LINE AND
SLOWLY OPEN THE SHUT-OFF VALVE IN THE TEST CAP TO ALLOW THE
PRESSURE IN THE GASOLINE TANK TRUCK (OR, ALTERNATIVELY, A
COMPARTMENT OF THE GASOLINE TANK TRUCK) TO REACH ATMOSPHERIC
PRESSURE; AND
(£J.( REPEAT THE TEST PROCEDURES CONTAINED IN PARAGRAPHS (G)(5)(e) TO
(G)(5)(p) OF THIS RULE FOR EACH COMPARTMENT OF THE GASOLINE
TANK TRUCK IF THE COMPARTMENTS COULD NOT BE INTERCONNECTED AS
SPECIFIED IN PARAGRAPH (G)(5)(d) OF THIS RULE.
(6) AN ALTERNATIVE METHOD MAY BE USED FOR TESTING THE LEAK TIGHTNESS OF
THE GASOLINE TANK TRUCK PROVIDED SUCH ALTERNATIVE METHOD HAS BEEN
DEMONSTRATED TO THE SATISFACTION OF THE DIRECTOR AS EQUIVALENT TO
THIS METHOD AND HAS BEEN APPROVED BY THE DIRECTOR IN WRITING.
P'.
I ;
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(H) METHOD FOR THE DETERMINATION OF SEAL GAPS IN AN EXTERNAL FLOATING ROOF
TANK.
(1) THIS METHOD IS APPLICABLE TO DETERMINING THE WIDTH AND AREA OF ANY
GAPS BETWEEN THE WALL OF AN EXTERNAL FLOATING ROOF TANK AND A SEAL
WHICH IS AROUND THE CIRCUMFERENCE OF THE EXTERNAL FLOATING ROOF.
(2) THE WIDTH OF ANY SEAL GAP IS THE DISTANCE BETWEEN THE SEAL AND THE
TANK WALL. IT IS DETERMINED BY USING PROBES OF VARIOUS WIDTHS TO
ACCURATELY MEASURE THE ACTUAL DISTANCE FROM THE SEAL TO THE TANK
WALL.
(3) THE AREA 'OF ANY SEAL GAP IS DETERMINED BY MULTIPLYING THE WIDTH OF
THE SEAL GAP, AS DETERMINED IN PARAGRAPH (H)(2) OF THIS RULE, BY
THE CIRCUMFERENTIAL LENGTH Of THE GAP.
(4) THE TOTAL SEAL GAP AREA IS THE ACCUMULATED AREA OF ALL GAPS WHICH
ARE GREATER THAN 0.125 INCHES IN WIDTH.
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95
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(I) METHOD FOR THE DETERMINATION OF THE VOLATILE ORGANIC CONTENT OF WASTES AT
A DRY CLEANING FACILITY WHICH USES PERCHLOROETHYLENE.
ill THE METHOD IS APPLICABLE TO DETERMINING THE VOLATILE ORGANIC COMPOUND
CONTENT IN PER CENT BY WEIGHT FOR WASTE AT A DRY CLEANING FACILITY
FROM ANY DISTILLATION OPERATION WHICH DISTILLS PERCHLOROETHYLENE AND
FROM ANY DIATOMACEOUS EARTH FILTER WHICH FILTERS PERCHLOROETHYLENE.
(2) THE VOLATILE ORGANIC COMPOUND'CONTENT OF THE WASTE IN PER CENT BY
VOLUME IS DETERMINED IN ACCORDANCE WITH THE PROCEDURE IN "ASTM D 33-
67, STANDARD TEST METHOD FOR GASOLINE DILUENT IN USED GASOLINE
ENGINE OILS BY [DISTILLATION11 AND IS CALCULATED AS THE DILUENT
CONTENT IN THAT PROCEDURE.
(3) THE DENSITY OF THE WASTE IS DETERMINED BY WEIGHING A KNOWN VOLUME OF
THE WASTE AND IS CALCULATED AS THE NET WEIGHT OF THE WASTE IN
POUNDS DIVIDED BY THE VOLUME OF THE WASTE IN GALLONS.
(4) THE VOLATILE ORGANIC COMPOUND CONTENT OF THE WASTE IN PER CENT BY
WEIGHT IS CALCULATED AS THE PRODUCT OF ITS DILUENT CONTENT AND
13.55, DIVIDED BY ITS DENSITY.
Effective: March 27/3 1981
Certification:
Date
Promulgated under: RC Chapter 119
Rule amplifies: RC Chapter 3704
Amended: 10/19/79
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96
FFR 1 ?, 1981
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
. REPORT MO.
EPA-9Q575-81-002
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Economic Impact of Implementing Volatile Organic
Compound Group II Regulations in Ohio
5. REPORT DATE
December, 1981
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
John W. Formento - D&M Raj an Chaudhry - ETA
Thomas J. Ploski - D&M Matt Klickman - ETA
8. PERFORMING ORGANIZATION REPORT NO
9094-139-07
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Dames & Moore
1550 Northwest Highway
Park Ridge, Illinois 60068
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3508
Work Assignment 2
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency, Region V
Air Programs Branch
230 South Dearborn Street
Chicago, Illinois 60604
13. TYPE OF REPORT AND PERIOD COVERED
Final; Jun. - Dec.. 1981
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Project Officer: Mr. Barry A. Perlmutter
16. ABSTRACT ' '
The major objective of the contract effort was to determine the direct economic
impact of implementing Reasonably Available Control Technology (RACT) standards
in Ohio. The study is to be used primarily to assist EPA and Ohio decisions on
achieving the volatile organic compound (VOC) emission limitations of the RACT
standards.
The economic impact was assessed for the following eight RACT industrial
categories: petroleum refinery fugitive emissions; surface coating of miscellaneous
metal parts and products; gasoline tank trucks; synthesized pharmaceutical man-
ufacturing; rubber tire manufacture; graphic arts; petroleum liquid storage in
external floating roof tanks; and dry cleaners using perchloroethylene.
The scope of this project was to determine the costs and direct impact of control
to achieve RACT limitations for these eight VOC industrial categories in Ohio.
Direct economic costs and benefits from the implementation of Ract limitations were
identified and quantified. While secondary impacts (social, energy, employment,
etc.) are addressed, they were not a major emphasis in the study.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Air Pollution
Emission limits
Metal Coatings
Petroleum operations
Printing
b 'DENTIFIERS/OPEN ENDEQ TERMS
Air Pollution Control
Stationary Sources
Ohio
Economic Impact
Hydrocarbon emissions
COSATl Field/Group
13B
Unlimited
19. SECURITY CLASS /This Report/
! None
21. NO. OF PAGES
20. SECURITY CLASS /This page/
None
22. PRICE
2FA Form 2220—1 (Sev. 4-77) PREVIOUS EDITION is OBSOLETE
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