United States Environmental Protection Agency Office Of The Administrator (A-101F6) EPA101/F-90/039 September 1990 vvEPA How Do State Agencies In Region 3 Determine Compliance With Volatile Organic Compound Regulations #90-1301 Printed on Recycled Paper ------- NNEMS RESEARCH REPORT "HOW DO STATE AGENCIES IN REGION III DETERMINE COMPLIANCE WITH VOLATILE ORGANIC COMPOUND REGULATIONS?" BY CARL MASTROPAOLO AUGUST 1990 US Environmental Protection Agency Region 5 Library (PL-12J) 77 West Jackson Blvd., 12th Floor Chicago, IL 60604-3590 ------- DISCLAIMER This report was furnished to the U.S. Environmental Protection Agency by the graduate student identified on the cover page, under a National Network for Environmental Management Studies fellowship. The contents are essentially as received from the author. The opinions, findings, and conclusions expressed are those of the author and not necessarily those of the U.S. Environmental Protection Agency. Mention, if any, of company, process, or product names is not to be considered as an endorsement by the U.S. Environmental Protection Agency. ADDITIONAL COPIES To order additional copies of How Do State Agencies in Region 3 Determine Compliance With Volatile Organic Compound Regulation please call the National Technical Information Service (NTIS) of the U.S. Commerce Department at (703) 487-4650. To order this report ask for report number PB91-100156. Both paper copy and microfiche are available. ------- CONTENTS INTRODUCTION 2 STUDY APPROACH 2 ANALYSIS ON A RECORDKEEPING BASIS 4 Coating formulation/analysis data 5 Coating consumption data 6 Control equipment 7 Spray application transfer efficiency 9 Process information 10 ANALYSIS ON A STATE/LOCAL AGENCY BASIS 11 AMS Phila 11 PA DER Region 1 12 PA DER Region 2 13 PA DER Region 3 15 PA DER Region 5 17 PA DER Region 6 17 MD DOE 18 Allegheny County Department of Health 19 CONCLUSIONS 20 RECOMMENDATIONS 21 APPENDIX A: SOURCES STUDIED LISTED BY CONTROL TECHNIQUE GUIDELINE (CTG) GROUPING Al APPENDIX B: DATA COMPARISON BY STATE/LOCAL REGULATORY AGENCY...Bl APPENDIX C: ACTUAL VOC EMISSIONS PER GALLON OF SOLIDS TRANSFERRED Cl APPENDIX D: REFERENCES Dl APPENDIX E: EXAMPLE OF STUDY QUESTIONNAIRE El APPENDIX F: DATA SPREAD SHEETS AMS Phila Fl PA DER Region 1 F5 PA DER Region 2 F9 PA DER Region 3 F13 PA DER Region 5 F17 PA DER Region 6 F21 MD DOE F25 ------- NNEMS RESEARCH REPORT HOW DO STATE AGENCIES IN REGION III DETERMINE COMPLIANCE WITH VOLATILE ORGANIC COMPOUND REGULATIONS? BY CARL MASTROPAOLO AUGUST 1990 It should be noted that references to all industrial facilities in this report have been coded to protect the business interests of these facilities. The researcher would like to thank all EPA Region III personnel whose assistance and support in conducting this study have made it a valuable and rewarding experience, Lisa Wild's expertise, good sense and good humor have been most especially appreciated. ------- INTRODUCTION This report details the results of a three month study authorized by the Environmental Protection Agency through the National Network for Environmental Management Studies (NNEMS) program which attempts to answer the question: "How do state agencies in Region III determine compliance with volatile organic compound regulations?". Emphasis in this report is placed upon surface coating and graphic arts volatile organic compound (VOC) sources in Pennsylvania and Maryland which are regulated by two state agencies: the Pennsylvania Department of Environmental Resources (PA DER) and the Maryland Department of the Environment (MD DOE), and two county agencies in Pennsylvania: the Allegheny County Department of Health, and Air Management Services (AMS) in Philadelphia. All sources analyzed in this report exist in geographic areas where ozone levels exceed the National Ambient Air Quality Standards (NAAQS), that is, ozone non-attainment areas. STUDY APPROACH To evaluate how the state/local regulatory agencies determine source compliance with VOC regulations a researcher ideally should accompany the inspectors and observe their procedure for compliance determination. This would permit a researcher the opportunity to directly observe the operation, how it is documented by the source, how it is documented by the state/local agency, and how compliance is determined by the state/local agency. This approach could not be taken for several reasons including those of safety, security and finance. V The next best study approach would be to directly review state/local regulatory agency files and interview inspectors. This approach would permit a researcher to directly ------- evaluate how the state/local agency documents the source operation and determines compliance, and would indirectly, i.e., through the inspector, provide information to evaluate the source's operation and how the source documents it. This second approach could only be pursued to the extent that on-site file reviews were performed at four state/local agency locations (AMS Philadelphia, MD DOE (Baltimore), PA DER Region 1 (Norristown), and PA DER Region 3 (Harrisburg)). Travel resource constraints precluded file reviews at other PA DER regional offices located beyond a reasonable "commute" from Philadelphia. For these other regions information for selected VOC sources was elicited by asking inspectors to complete questionnaires especially devised for this study (see Appendix E). For those offices where on-site file reviews were performed the researcher had the opportunity to directly evaluate how the state/local agency documents the source operation, gain insight into how compliance is determined, and conjecture as to how the source operates and how well it documents its operation. For those offices where inspector-completed questionnaires provided the data source, insight into all phases of source operation and documentation and state/local compliance determination and documentation is indirect in nature. The 52 sources reviewed during this study were selected because their Standard Industrial Code (SIC) in the Compliance Data System (CDS) indicated they would potentially be VOC emitters and that emissions actually or potentially exceed 100 tons per year. Such sources are denoted as Class A VOC sources. Appendix A lists the sources studied by Control Technique Guideline (CTG) grouping. Originally over 75 sources were selected including seven which are regulated by the Allegheny County Department of Health. Due to internal workload, however, Allegheny County could not forward their questionnaires in time to be included in this study. ------- ANALYSIS ON A RECORDKEEPING BASIS EPA has developed specific recordkeeping requirements for surface coating and graphic arts sources (Ref 7) and has recommended that the state/local regulatory agencies include such documentation requirements as part of their individual State Implementation Plans (SIPs)(Ref 8). The minimum recordkeeping information which EPA recommends be kept by surface coating and graphic arts sources are (per Ref 7): 1) coating formulation and analytical data 2) coating consumption data 3) capture and control equipment performance data 4) spray applicator transfer efficiency data 5) process information In addition EPA has devised six forms which sources can utilize to record this data in an organized and consistent manner: 1) general information 2) process information 3) coating data 4) coating consumption data 5) control equipment data 6) transfer efficiency data While EPA does not require sources to use the forms it does require them to record the data and make it available to a regulatory agency for compliance determination. The EPA stance is that accurate source documentation of this data provides a regulatory agency with the minimum amount of data necessary to truly determine whether the source is meeting non-attainment area VOC emission standards. Source documentation and regulatory agency review of this data is necessary to determine compliance. ------- Conversely, insufficient source documentation of these data elements and/or lack of review of same by the regulatory agency creates an environment in which compliance is impossible to accurately determine. While the scope of this study did not allow for on-site observance of source processes and recordkeeping practices, the following analysis is offered based upon information furnished by state/local agencies on their completed questionnaires and the on-site file reviews performed by EPA staff. Coating formulation/analysis data EPA requires that Reference Method 24 (RM24) laboratory analysis be performed on coatings/inks used by VOC sources on an "as applied" basis. While material safety data sheets (MSDS) and manufacturer's specification sheets also depict the VOC content of coatings, EPA is of the opinion that such data is not always consistent and does not account for production variables which may result in varying VOC contents in different batches of the same coating/ink. Further, analysis is required on an "as applied" basis since some sources dilute coatings/inks to reduce viscosity and ease the application process. Our analysis indicates that agency files only occasionally document whether a source dilutes the coatings/inks it uses. The number of coatings/inks used by a source is quite variable as our analysis has discovered. Some facilities perform a narrow range of production processes and use a small number of ink colors. (A MD DOE regulated paper coating source, MD-4, uses only five coatings). Other facilities perform a broader range of processes and may use an extensive number of coatings/inks. (MD- 6, a miscellaneous metal coater also regulated by MD DOE, uses on the order of 150 coatings). Of these latter sources, a large percentage of production output may be dominated by a relatively small number of coatings/inks. (PA-28, a metal furniture coater regulated by PA DER, uses over 100 coatings of which 3 comprise about 75% of the total usage). ------- To quantitatively determine how extensively RM24 analysis is performed by regulatory agencies requires an accurate accounting of at least the number of dominant coatings used for all of the sources studied. Unfortunately our study was not able to clearly isolate this information since state/local regulatory agencies could only identify the number of coatings/inks used by each source for only 13 of the 52 sources studied (25%). The breakout by regulatory agency follows: AMS Philadelphia 1 of 6 17% PA DER Region 1 4 of 11 36% PA DER Region 2 3 of 6 50% PA DER Region 3 0 of 9 0% PA DER Region 5 0 of 1 0% PA DER Region 6 2 of 2 100% (PA subtotal) (9 of 29) (31%) MD DOE 3 of 17 18% What is clear, however, is that most of the regulatory agencies surveyed do not routinely perform RM24 analyses. State/local regulatory agency-initiated method 24 analysis during the period 1 Jan 88 to 1 June 90 is evident for coatings used by only 14 of the 52 sources studied (27%): AMS Philadelphia 1 of 6 17% PA DER Region 1 7 of 11 64% PA DER Region 2 0 of 6 0% PA DER Region 3 3 of 9 33% PA DER Region 5 1 of 1 100% PA DER Region 6 2 of 2 100% (PA subtotal) 13 of 29 (45%) MD DOE 0 of 17 0% Coating consumption data Only a small number of sources apparently report coating 6 ------- consumption data on a daily or a per-line basis. Much of the data reported is for a much wider time frame, such as for a week or month. EPA encourages regulatory agencies to compare coating consumption data against a source's purchase and inventory record with guidance that a discrepancy greater than 5% implies that recordkeeping data might be questionable (p 4-3, Ref 7). While some of the agencies indicated that comparisons are made, such detailed comparisons were not at all evident in agency source files inspected by EPA personnel for this study. Control equipment Control equipment refers to all ducts, ovens, fans and blowers, incinerators, compressors, carbon adsorbers, and other equipment which function to collect fugitive VOC emissions and prevent their dispersal into the atmosphere. Control equipment falls into two broad categories, that which captures the fugitive emissions, and that which destroys or recovers the emissions once they are captured. The true capability of a source to control its VOC emissions can only be known by accurate quantitative measurements of both its capture and destruction (or removal) efficiencies. Reference 7 cites that a "facility must provide estimated efficiency of its capture systemand the method used to determine that efficiency" (p 3-13). This documet further requires that sources document concentration and temperature gradients across control equipment, control device destruction/removal efficiency, and data for catalyst bed changes when catalytic incinerators are employed (p 3-13). As indicated in Appendix F (Source Data Spread Sheets), capture, destruction/removal, and overall control efficiency data are apparent in only some of the agency source files for sources that utilize add-on controls with method of efficiency determination rarely documented. While EPA Headquarters has recently (April 1990) disseminated a protocol for determination of control equipment capture efficiency (Ref 10), no plans to ------- perform such determinations were evident in any of the state/local agency files. This may be understandable since the protocol is so recent. In addition to actual testing EPA has encouraged both source and regulatory agency personnel to use hand-held analytical equipment, such as organic vapor analyzers (OVA) and anemometers, to quantitatively assess whether capture systems are performing properly (p 4-5, Ref 7). From the on- site reviews only one source was documented (PA-11 regulated by PA DER) which employs OVA techniques. If other sources or regulatory agencies are using such techniques they are not documenting it in their source files. While many sources apparently record control equipment operating temperatures on a continuing or, at least, periodic basis, it seems as if neither the sources nor the regulatory agencies are overly concerned with measuring concentration gradients or in documenting them if they do measure them. Due to the ease with which it can be measured, temperature has apparently surfaced as the major indicator which both sources and state/local regulatory agencies monitor to "determine" that incinerators are properly functioning to effectively remove VOCs from the influx stream. However temperature is only one of the three important factors in incinerator design, the other two being the residence time and velocity of the influx stream. EPA has specifically noted that deficiencies in any of these three can result in incomplete combustion, resulting in generating carbon monoxide, aldehydes, and other undesirable VOC products (p 25-26, Ref 3). Compliance with non-attainment area VOC standards is not necessarily guaranteed by only measuring control equipment temperatures. Catalytic incinerators require additional attention since catalysts are prone to erosion at high temperatures and can react with various metals including lead, arsenic, mercury, zinc, tin and bismuth, as well as non-metals such as phosphorus, sulfur and halogens (p 32, Ref 3). A properly maintained catalyst bed has a life expectancy of one to five years (p 34, Ref 3). As a result, 8 ------- regulatory agencies should be tracking when sources are renewing the catalyst bed, but this apparently is never done. Spray application transfer efficiency For certain control technique guideline (CTG) sources, such as metal furniture coaters, an accurate measurement of transfer efficiency (TE) is critical in determining whether a source complies with the CTG since the standard is based upon a baseline transfer efficiency. For these CTGs the source has the opportunity to comply with the VOC emission standard by using an applicator with a transfer efficiency greater than that of the baseline (transfer efficiency enhancement) even though the VOC content of the coating exceeds that of the standard. Of the six metal coating sources studied the appropriate agency has TE data on only four of them. For two of these four, however, it is unclear whether these are engineering measurements or merely target efficiencies. While an accurate measure of TE is not required by EPA to determine compliance with other CTG standards, less than optimal TE results in an absolute increase in actual VOC emissions. In order to observe the effects of TE upon absolute VOC emissions it is useful to compute the Ibs of VOC emitted per gallon of solids transferred. This analysis is presented in Appendix C and indicates that an inverse relationship exists between transfer efficiency and actual VOC emissions. A 20% decrease in transfer efficiency, for example, would result in a 25% increase in actual VOC emissions (see Appendix C). State/local agency files reflect transfer efficiency data for processes used at only eight of the 52 sources studied (15%). PA DER Region 2 cites the permit application as the origin of efficiency determination for three of these eight sources. It is not clear whether these are engineering measurements or target efficiencies. For another three of these sources (the only sources selected from PA DER Regions 5 and 6) the agencies cite the manufacturer's specifications as the origin of determination, ------- while information regarding the remaining two sources (PA-25 regulated by PA DER and MD-6 regulated by MD DOE) reflects no origin of determination. In no case is it apparent that the EPA Region III guidelines for transfer efficiency determination, as documented in Appendix 2.0 of Reference 11, have been employed. Process information Often times the agency files contain information regarding the source's processing. For some sources the files contain detailed drawings of the processing, sketches or descriptions (sometimes well detailed) on inspection reports, or detailed descriptions of a portion of the overall operation on a pertinent application for permit. On the other extreme, however, agency files for other sources contain practically no information regarding the process. There is a general lack of consistency in agency documentation of source processes. 10 ------- ANALYSIS ON A STATE/LOCAL AGENCY BASIS AMS Philadelphia The data for the six selected sources regulated by this agency were obtained during two file reviews at this office on 27 June 90 and 20 July 90. These six sources were inspected a total of 13 times by the agency between 1 Jan 88 and 1 June 90 (average of 2.2 times per source, range: 0-4). Two Al VOC sources which use compliant coatings/inks were not inspected at all in that period. Nothing in the agency's files indicates how many coating are used by five of the sources. The sixth source, a paint manufacturer, is not strictly speaking a coating/graphics source. The agency however is aware of the numbers of pigments and solvents used by the source. Over the period 1 Jan 88 to 1 June 90 only 5 coatings from one of the six sources had been analyzed by method 24. This source (AMS-1) is a facility with at least 28 coating/press lines. No transfer efficiency determinations are evident from the agency's files for any processes in any of the six sources studied. Since, however, none of these sources is claiming compliance with applicable VOC emissions standards by means of transfer efficiency enhancement, TE determinations are not required. Three of the five coating/graphics sources use compliant coatings/inks and the other two comply with VOC emission standards by using control technologies. One of these two controlled sources (AMS-2) uses a thermal incinerator with a destruction efficiency of 90% but the origin of the efficiency determination is not apparent from the files. In addition, no capture efficiency determination is apparent. The other source (AMS-1) uses at least seven individual capture systems. The installer was scheduled to determine their capture efficiency by 15 May 89 but no record regarding this determination, nor for destruction efficiency was apparent in the 1989 AMS-1 files. The 11 ------- 1990 files for this source could not be located by agency personnel during the 20 July 90 file review. For both of the controlled sources it is not apparent from agency files whether the sources keep a continuous record of pertinent control technology parameters such as inlet/outlet temperature and inlet/outlet VOC concentration. For all six sources there is no file evidence indicating that the agency compares source-reported VOC usage quantities against purchase/inventory records. PA PER Region 1 The data for the eleven selected sources regulated by this agency were obtained during two file reviews at this office on 13 June 90 and 21 July 90. One of the sources (PA-9) had been monitored by the state over a two year period indicating that annual VOC emissions were less than 20 tons. This source is probably improperly classified as an A2 source in the CDS. A total of 27 VOC sources regulated by this region were originally identified for inclusion in this study. Since agency preparations for file reviews consume considerable time the researcher decided not to burden the agency with more than two days of review during the study period. The eleven sources which we reviewed were inspected a total of 22 times by the state between 1 Jan 88 and 1 June 90 (average of 2.0 times per source, range: 1-5). The files indicate that the agency has an actual or estimated count of the number of coatings/inks used by only four of eleven sources. During the period 1 Jan 88 to 1 June 90 at least one coating used by eight of the eleven sources was subjected to RM24 analysis. No transfer efficiency determinations are evident from the agency's files for any processes in any of the eleven sources studied. Since, however, none of these sources is claiming compliance with applicable VOC emissions standards by means of transfer efficiency enhancement, TE determinations are not required. 12 ------- Nine of the eleven sources comply with VOC emission standards by using add-on control technologies, the other two (PA-3 and PA-9) comply by maintaining emissions under 50 tons/year or 500 Ibs/day. Agency files reflect capture, destruction, or overall control efficiency data for control equipment used at only six of the nine controlled sources, with data from only two of these six distinguishing between capture and destruction efficiencies. Control efficiency determinations at all six of these sources were either performed by an independent contractor or EPA. Only two of these determinations were made since 1/1/88. For only two of the controlled sources is it apparent that the source keeps some record regarding temperature gradient across the control device. One of these (PA-1) keeps gradient temperature measurements on a per coating basis. This degree of conscientiousness in recordkeeping however is an aberration when compared to how other sources apparently perform recordkeeping. None of the controlled sources apparently maintain records regarding VOC inlet/outlet concentration across the control equipment. At least two of the sources which use catalytic incinerators (PA-6 and PA-11) have apparently experienced problems in properly maintaining the catalyst beds, yet it appears as if the regulatory agency files have no record regarding catalyst bed renewal by the three sources using catalytic incinerators. For all eleven sources there is no file evidence indicating that the agency compares source-reported VOC usage quantities against purchase/inventory records. PA PER Region 2 The data for the six selected sources regulated by this agency were obtained by questionnaires completed and returned by agency personnel. Information regarding a seventh source, a pulp mill and paper products manufacturer, was also obtained. Analysis of this data however indicated this latter facility is 13 ------- not a VOC source. These six sources were inspected a total of 18 times by the state between 1 Jan 88 and 1 June 90 (average of 3.0 times per source, range: 2-4). Information provided by the sources indicates that the agency has an actual or estimated count of the number of coatings/inks used by only three of the six sources. During the period 1 Jan 88 to 1 June 90 none of the coatings/inks used by any of the six sources was subjected to RH24 analysis. The agency reports transfer efficiencies for processes used by three of the six sources "per permit application". It is not clear whether these are engineering measurements or merely permit required target efficiencies. Since, however, none of these sources is claiming compliance with applicable VOC emissions standards by means of transfer efficiency enhancement, TE determinations are not required. One of the six sources uses compliant coatings and four others comply with VOC emission standards by using control technologies. The sixth source (PA-15) is a metal furniture coater. It is not apparent from the information provided by the agency whether this source complies by using compliant coatings or control technology. The monthly usage reports for this source apparently provide no background regarding coating content information such as % water, % VOC, etc., raising the question "How is compliance determined?". The agency has provided control efficiency data for all sources using control technologies but it is not clear whether these figures represent capture, destruction, or overall control efficiencies, and how efficiency was determined. For only one of these sources is it clear that the source keeps a continuous record of temperature in the control device (PA-13 maintains a continuous chart recorder). None of the sources apparently maintain records regarding VOC inlet/outlet concentration across the control equipment. The agency indicates it compares source VOC usage data against purchase/inventory records for three of the six sources. 14 ------- The most recent inspection report (June 89) for one source (PA-17) indicates the inspector did not have access to the locked control room for the carbon adsorption system yet still deemed the source in compliance. The most recent inspection report (Nov 89) for another source (PA-12) cites solvent-laden soil piles which the inspector indicates is not a problem for residents in the area. It is possible that evaporation of this solvent into the atmosphere is not in compliance with applicable VOC regulations. There is no agency documentation however that the problem was referred to agency water pollution personnel in an attempt to determine whether the potential exists for groundwater contamination and subsequent dispersion. PA PER Region 3 The data for the nine selected sources regulated by this agency were obtained during a file review at this office on 25 July 90. Eleven sources were initially explored. One however had been shutdown since at least August 89 and analysis of the other revealed it was not a VOC source. These nine sources were state inspected a total of 44 times between 1 Jan 88 and 1 June 90 (average of 4.9 times per source, range: 3-7). Nothing in the agency's files indicates how many coatings/inks are used by any of these sources. During the period 1 Jan 88 to 1 June 90 coatings/inks from only three of the nine sources were subject to method 24 analysis. Transfer efficiency is indicated for only one of the processes used by the nine sources (100% for PA-25's roller coaters) but the origin of this determination is not evident from the files. This is a reasonable estimate of roller coater transfer efficiency. Since, however, none of these sources is claiming compliance with applicable VOC emissions standards by means of transfer efficiency enhancement, TE determinations are not required. Two of the nine sources comply with VOC emission standards 15 ------- by using compliant coatings, six by control technologies, and one by a combination of both. The agency files reflect efficiency data for all seven sources using control technologies. Both the capture and destruction efficiencies are indicated however for only two of the seven (PA-18 and PA-26), overall control efficiency for two (PA-20 and only one of PA-19's two incinerator's), and removal efficiency for another (PA-25's carbon adsorber, with no capture efficiency for the line nor any data at all for the source's two incinerators). PEDS efficiency data is listed for two of PA-21's seven incinerators but it is unclear what type of efficiency this is. Furthermore for only one of the pieces of control equipment (PA-18's catalytic incinerator) is the origin for efficiency determination indicated (in this case a contractor was hired by the source who performed the testing in October 88). For only two of the controlled sources is it clear that the source keeps a record of temperature in the control device (PA- 19 uses a chart recorder). One of the two (PA-19) has some method of recording the % formulation of the applied coating continuously on tape. None of the other controlled sources apparently maintain records regarding VOC inlet/outlet concentration across the control equipment. It appears as if the agency compares source VOC usage against purchase/inventory records for only two of the nine sources. This agency uses a well designed computerized report form which is customized for each source and clearly documents how the inspections are conducted. A 1988 destruction efficiency determination of 71% for one source's (PA-18) catalytic incinerator was determined by a contractor while EPA has noted that catalytic incinerators are usually about 90% efficient for can coating operations (Ref 2, p 2-1,2-2). In this case the source attributed the low efficiency to the fact that only two of nine end seal lines were in operation at the time of testing and that catalytic incinerators 16 ------- are more efficient at higher input concentrations. While there is no hard evidence for this speculation, this low destruction efficiency determination points to the degree of efficiency variability which may exist at any point in time in real time processing, which can not be predicted by applying manufacturer efficiency figures determined during idealized controlled testing. It also displays how difficult it is to truly determine compliance on a continuous basis. PA PER Region 5 The data for the one selected source regulated by this agency were obtained by a questionnaire completed and returned by agency personnel. This Al source was state inspected six times between 1 Jan 88 and 1 June 90. The agency did not indicate how many inks are used by this printing facility. Three inks were tested in Dec 88 using RM24. Ninety-five percent transfer efficiency is claimed based upon manufacturer's specifications. This source complies with VOC emission standards by choosing to produce less than 100 tons per year to avoid using compliant coatings and control equipment. The agency claims it compares source VOC usage against source purchase/inventory records. VOC emissions are calculated by material balance based upon known quantities of ink used minus VOC recovered from waste ink at the source's recycling plant. CDS lists this source as standard industrial code (SIC) 3069 (fabricated rubber products, NEC). DER, however list it as SIC 2754 (gravure printing). PA DER Region 6 The data for the two selected sources regulated by this agency were obtained by questionnaires completed and returned by agency personnel. 17 ------- The one Al source was state inspected six times and the A2 source three times between 1 Jan 88 and 1 June 90. The agency has a very precise record regarding how many coatings are used by these sources and has subjected a reasonable number of the Al source's coatings three times and the A2 source's once to RM24 analysis during that same time frame. The agency is aware of the transfer efficiency of the processes employed by the two sources based upon manufacturer's specifications. Both sources maintain compliance by using compliant coatings. The agency indicates it compares both sources' VOC usage data against purchase/inventory records annually. MD DOE The data for the seventeen selected sources regulated by this agency were obtained during two file reviews at this office on 18 and 24 July 90. Two other sources originally explored turned out to be non-VOC sources. These seventeen sources were state inspected a total of 73 times between 1 Jan 88 and 1 June 90 (average of 4.3 times per source, range: 1-10). File information indicates the agency has an accurate or estimated count of the number of coatings/inks used by only three of the seventeen sources. During the subject period RM24 analysis was performed on coatings/inks used by only two of the sources, but these samples were taken by EPA personnel during EPA inspections. The state agency initiated no RM24 analyses during the period 1 Jan 88 to 1 June 90 for any of the coatings used by any of the processes in any of the 17 sources studied. Two of the facilities are paint manufacturers which are, strictly speaking, not surface coating/graphic arts sources. No transfer efficiency determinations are evident from the agency's files for any processes in any of the seventeen sources. Since, however, none of these sources is claiming compliance with applicable VOC emissions standards by means of transfer 18 ------- efficiency enhancement, TE determinations are not required. Six of the seventeen coating/graphics sources comply with VOC emission standards by using compliant coatings/inks, ten by using control technologies, and one by limiting VOC emission to less than 200 Ibs per day. Agency files reflect some type of efficiency data for seven of the ten controlled sources but none of the data clearly quantifies both capture and destruction efficiencies for any one source. The overall control efficiencies of only two of the sources (MD-10 and MD-17) has been determined (MD-17's thermal incinerator (95%) by a consultant in 1984; MD-10's carbon adsorber (95%) by the source itself by conducting a material balance of toluene). The destruction efficiency of one other source (MD-5) was determined by an EPA hired consultant. For all other control equipment efficiency data it is not clear how such determinations were made. Agency files indicate that at least two of the ten controlled sources (MD-6 and MD-1) keep a continuous record of temperature in the control device. It is not apparent from the files whether the sources keep any pertinent data regarding VOC concentration gradients across the control device. The agency apparently compares source-reported VOC usage figures against purchase/inventory records for three of the sources (MD-6, MD-14 and MD-16) and receives purchase records only for a fourth source (MD-4). Allegheny County This agency was requested to complete questionnaires for seven selected sources by our letter dated 12 July 1990. When no reply was received four weeks after this date subsequent telephone calls revealed that the agency was in the midst of reorganization and deeply involved with the review two permits for major sources. The researcher was informed that the agency hoped to respond over the next few weeks and that a reply might be forthcoming by the end of August. As of 31 August 1990 no 19 ------- reply had been received. CONCLUSIONS 1. State/local agencies are aware of the number of coating/inks used per source for only about 25% of the VOC sources they regulate. 2. PA Region 2 and MD DOE apparently never initiated RM24 coating analyses during the period 1 Jan 88 to 1 June 90. On the other extreme, PA Region 1 analyzed at least one coating for 64% of the VOC sources which we reviewed for this region. 3. Sources apparently report coating consumption data for relatively wide time frames (week or month), and rarely on a per-line basis. The state/local agencies rarely perform detailed comparisons between a source's coating consumption data and its purchase and inventory records. 4. Transfer efficiency data is known for perhaps 10% of the processes reviewed. The EPA Region III transfer efficiency determination guidelines have apparently not been exercised. Such determinations, however, may not be required since none of the sources studied is claiming transfer efficiency enhancement in order to comply with applicable VOC regulatory standards. 5. Capture efficiency data is known for approximately 10% of the processes reviewed. Hand-held methods to quantitatively evaluate capture efficiency are apparently rarely performed. The recently published headquarters EPA protocol for capture efficiency has yet to be implemented. 6. Destruction/removal efficiency data is known for approximately one-third of the processes reviewed. 7. Overall control efficiency data is known for approximately one-third to one-half of the processes reviewed. 20 ------- 8. State/local agencies almost never track catalyst bed renewals. 9. Sources and regulatory agencies are content that monitoring incinerator temperature is sufficient to determine that VOCs are properly combusted. 10. In general, control data is tracked more closely by PA DER Region 3 than by any other agency surveyed. 11. In certain cases, state/local agency files contain impeccably detailed information regarding source processes. Applications for permitting of source equipment are sometimes accompanied by detailed process flow drawings or information and therefore provide a major source of insight into source processes. Overall, however, there is a general lack of consistency in documentation of source processes. 12. All VOC sources reviewed during this study were state/local agency inspected at least once during the period 1 Jan 88 and 1 June 90 except for two Al sources regulated by AMS Philadelphia (AMS-4 andAMS-6). 13. PA DER Region 1 regulates approximately 27 Class A VOC sources, ten more than MD DOE. None of the other agencies surveyed regulate more than ten VOC sources. It is perhaps not coincident that PA DER Region 1 tends to inspect its sources less than the other agencies studied. 14. While computer generated inspection reports are prepared by some of the agencies surveyed (PA DER Regions 3, 5 and 6), those used by Region 3 are customized for each source and provide insight into the actual inspection process. RECOMMENDATIONS 1. State/local agencies should become aware of the number of coatings/inks used by sources they regulate and perform RM24 analyses for a reasonable number on a more regular basis. 21 ------- 2. State/local agencies should require the sources they regulate to record coating consumption data on a daily basis. 3. State/local agencies should compare each source's coating consumption data against its purchase and inventory record as a means of checking whether the source is properly documenting its VOC emissions. 4. State/local agency inspectors should familiarize themselves with the Headquarters EPA protocol for capture efficiency and implement testing at sources where such efficiency is not currently known, or reported figures are suspect. EPA guidance and support may be required for state/local inspectors to become familiar with the procedures. 5. EPA should issue guidance to state/local agencies regarding reasonably quantitative methods of determining capture efficiency. 6. State/local agencies should require sources to determine the destruction/removal efficiency of their equipment when such data is not available. 7. State/local agencies should require sources to keep records regarding catalyst bed changes and review them during compliance inspections. 8. EPA should issue guidance to state/local agencies regarding reasonably quantitative methods of determining whether incinerator inlet velocity and mixing are sufficient for complete combustion to carbon dioxide and water. 9. State/local agencies should clearly document source processes. 10. State/local agencies should explore the option of producing computerized inspection reports customized for each source. 22 ------- APPENDIX A SOURCES STUDIED LISTED BY CONTROL TECHNIQUE GUIDELINE (CTG) GROUPING ------- SOURCES STUDIED LISTED BY CONTROL TECHNOLOGY GUIDELINE fCTGl GROUPING Source Agency Can Coating AMS-1 PA-1 PA-18 PA-19 MD-1 MD-2 MD-3 AMS Phila PA DER Region 1 PA DER Region 3 PA DER Region 3 MD DOE MD DOE MD DOE Paper Coating AMS-2 PA-2 PA-12 PA-20 MD-4 AMS Phila PA DER Region 1 PA DER Region 2 PA DER Region 3 MD DOE Fabric Coating PA-3 PA-13 PA DER Region 1 PA DER Region 2 Coil Coating PA-4 PA-21 MD-5 PA DER Region 1 PA DER Region 3 MD DOE Metal Furniture Coating AMS-3 PA-14 PA-15 PA-22 PA-28 PA-29 AMS Phila PA DER Region 2 PA DER Region 2 PA DER Region 3 PA DER Region 6 PA DER Region 6 A - 1 ------- SOURCES STUDIED LISTED BY CONTROL TECHNOLOGY GUIDELINE (CTG\ GROUPING Source Agency Metal Furn/Misc AMS-4 Metal Parts Coating PA-5 AMS Phila PA DER Region 1 Misc Metal Parts Coating PA-6 PA-7 MD-6 PA DER Region 1 PA DER Region 1 MD DOE Wood Furniture Coating PA-23 PA DER Region 3 Adhesives PA-12 PA-24 PA-25 MD-7 PA DER Region 2 PA DER Region 3 PA DER Region 3 MD DOE Paint Manufacturers AMS—5 MD-8 MD-9 AMS Phila MD DOE MD DOE Glass Coating MD-10 MD DOE A - 2 ------- SOURCES STUDIED LISTED BY CONTROL TECHNOLOGY GUIDELINE (CTG\ GROUPING Source Agency Printing/ Graphic Arts AMS-2 AMS-6 PA-8 PA-9 PA-10 PA-11 PA-16 PA-17 PA-19 PA-25 PA-26 PA-27 MD-7 MD-11 MD-12 MD-13 MD-14 MD-15 MD-16 MD-17 AMS Phila AMS Phila PA DER Region 1 PA DER Region 1 PA DER Region 1 PA DER Region 1 PA DER Region 2 PA DER Region 2 PA DER Region 3 PA DER Region 3 PA DER Region 3 PA DER Region 5 MD DOE MD DOE MD DOE MD DOE MD DOE MD DOE MD DOE MD DOE A - 3 ------- APPENDIX B DATA COMPARISON BY STATE/LOCAL REGULATORY AGENCY ------- DATA COMPARISON BY STATE/LOCAL AGENCY VOC SOURCES REGULATED VOC SOURCES REVIEWED # INSPECTIONS OF VOC SOURCES REVIEWED AVERAGE INSPECTIONS PER SOURCE RANGE OF INSPECTIONS PER SOURCE KNOWLEDGE OF # COATINGS PER SOURCE SOURCES WHICH COATINGS ANALYZED BY RM24 SOURCES WHERE PROCESS T.E. IS KNOWN SOURCES WHERE USAGE AND INVENTORY CHECKED SOURCES USING CONTROLS SOURCES FOR WHICH CAPTURE EFF. KNOWN SOURCES FOR WHICH DESTRUCTION EFF. KNOWN SOURCES WHERE OVERALL CONTROL EFF. CAN BE DETERMINED SOURCES USING CATALYTIC INCINERATION AMS PHI LA 6 6 13 2.2 0-4 1 (17X) 1 (17X) 0 (0%) 0 (OX) 2 0 (OX) 1 (SOX) 0 (OX) 1 CATALYST RENEWAL DATA 0 KNOWN | (OX) REG 1 27 11 22 2.0 1-5 4 (36X) 7 (64X) 0 (OX) 0 (OX) 9 1 (11X) 2 (22X) 3-5 (33-56X) 3-5 0 (OX) REG 2 6 6 18 3.0 2-4 3 <50X) 0 (OX) 0-3 (0-50X) 3 (SOX) 4 0 (OX) 0 (OX) 0-4 (0-100X) 1-3 0 (OX) PENNSYLVANIA REG 3 REG 5 9 9 44 4.9 3-7 0 (OX) 3 (33X) 0 (OX) 2 (22X) 7 2 (29X) 3 (43X) 6 (86X) 5 1 (20X) 1 .1 6 6 6 0 (OX) 1 (100X) 1 (100X) 1 (100X) 0 - - • 0 - REG 6 2 2 9 4.5 3-6 2 (100X) 2 (100%) 2 (100X) 2 (100X) 0 - - 0 - MARYLAND DOE 17 17 73 4.3 1-10 3 (18X) 0 (OX) 1 (6X) 3 (18X) 10 0 (OX) 4 (40X) 3 (30X) 0 - TOTAL 68 52 185 3.6 0-10 13 (25X) 14 (27%) 4-7 (8-13X) 11 (21X) 32 3 (9X) 10 (31X) 12-18 (38-56X) 10-14 1 (7-10X) B - 1 ------- APPENDIX C ACTUAL VOC EMISSIONS PER GALLON OF SOLIDS TRANSFERRED ------- APPENDIX C: ACTUAL VOC EMISSIONS PER GALLON OF SOLIDS TRANSFERRED It is useful to compute the actual pounds of VOC emitted, E, as a result of transferring a gallon of solids to a substrate, especially in computing the effects of transfer efficiencies (TE) of less than 100%, or less than baseline when a baseline transfer efficiency has been used in establishing a VOC standard for a given CTG. Assuming a coating has S Ibs VOC per gallon coating(-)water, a standard VOC density of 7.36 Ibs per gallon, and a decimal transfer efficiency of TE gallon solids transferred per gallon solids, actual emissions can be calculated by: S Ib VOC X oal VOC = S gal VOC gal coat(-)water 7.36 Ib VOC 7.36 gal coat(-)water Since a gallon of coating(-)water consists solely of solids and VOC, then: gal solid = 1 - S = 7.36 - S gal coat(-)water 7.36 7.36 Therefore: E = S Ib VOC x 7.36 aal coatr-lwater X aal solid gal coat(-)water (7.36 - S) gal solid TE gal solid trns E = 7.36 S Ib VOC TE (7.36 - S) gal solids trnsfrd The ratio of emissions at an actual transfer efficiency other than 100% to emissions at 100% transfer efficiency can be computed: C - 1 ------- Efother than 100% TE1 = 7.36 S 1 (7.36 - S) E(100% TE) TE (7.36 - S) 7.36 S actual TE An inverse relationship therefore exists between emissions and transfer efficiency. For CTGs using a baseline transfer efficiency the same relationship holds: E(less than baseline TE) = baseline TE E(baseline TE) actual TE Substitution yields the following table: actual TE actual emissions baseline TE .95 .90 .85 .80 .75 .70 .65 .60 .55 .50 baseline emissions 1.05 1.11 1.18 1.25 1.33 1.43 1.54 1.67 1.82 2.00 For example, an actual transfer efficiency at 80% of baseline TE (i.e., 20% less than baseline) yields a 25% increase in actual VOC emissions. C - 2 ------- As another example, using the can coating end seal CTG standard of 3.7 Ib VOC per gal coating(-) water, and assuming 100% TE: E = 7.36 (3.71 = 7.4 Ib VOC 1 (7.36 - 3.7) gal solids transferred Whereas at 80% TE: E = 1.25 (7.4) = 9.3 Ib VOC gal solids transferred C - 3 ------- APPENDIX D REFERENCES ------- REFERENCES 1. Control of Volatile Organic Emissions From Existing Stationary Sources-Vol I 2. Control of Volatile Organic Emissions From Existing Stationary Sources-Vol II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, And Light-Duty Trucks, EPA- 450/2-77-008, May 1977 3. Control Techniques For Volatile Organic Emissions From Stationary Sources, EPA-450/2-78-022, May 1978 4. Control of Volatile Organic Emissions From Existing Stationary Sources-Vol VI: Surface Coating of Miscellaneous Metal Parts and Products, EPA-450/2-78-015,June 1978 5. Control of Volatile Organic Emissions From Existing Stationary Sources-Vol VIII: Graphic Arts-Rotogravure and Flexography, EPA-450/2-78-033, December 1978 6. RACT Air Regulation Handbook For Can Manufacturing, by Can Manufacturer's Institute, January 1983 7. Recordkeeping Guidance Document For Surface Coating Operations And the Graphic Arts Industry, EPA 340/1-88-003, July 1989 8. Letter from EPA Region III VOC Coordinator to Directors of State/Local Agencies in the Region, 25 September 1989 9. VOC Surface Coating Operations Inspection Guidance Manual by the Alliance Technologies Corporation through EPA contract f 68-02-4465, September 1989 10. Letter from EPA Headquarters Stationary Source Compliance Division regarding protocol for capture efficiency determination, 16 April 1990 11. State VOC Regulatory Review by EPA Region III Personnel, December 1987 D - 1 ------- APPENDIX E EXAMPLE OF STUDY QUESTIONNAIRE ------- STUDY TO ASCERTAIN HOW THE STATES DETERMINE VOC COMPLIANCE STATE CONTACT: CONTACT'S PHONE NUMBER: SOURCE NAME: SOURCE ADDRESS: SIC: TYPE OF OPERATION: 1. List dates of all state inspections of this source since 1 Jan 88, the nature of the inspection, and a copy of the most recent inspection report: List dates when samples of coatings were analyzed for VOC composition since 1 Jan 88, the number of coatings analyzed, and the origin of analysis (eg., the source, the state, lab subcontracted by the source, etc.)- Indicate whether the coating is one which complies with existing emission limits: date # of coatings origin comments 3. What is the total number of coatings used by this source? E - 1 ------- 4. List the operational processes performed by this source (eg., airless spray coating, brush coating), the transfer efficiency and origin of efficiency determination (eg., manufacturer's specs, state analysis, source analysis), the control devices associated with each process, and the regulation governing the operational process (eg., permit, EPA approved bubble, state approved bubble, SIP). Indicate if the emissions from 2 or more line operations inflow to the same control device. As an example: line operation roller coating electrostatic spray coating airless spray coating roller coating efficiency & origin 95% manu specs 85% manu specs 75% manu specs 95% manu specs control devices hood #1,catalytic incinerator #1 hood #2,catalytic incinerator #2 hood #3,catalytic incinerator #2 none-only compliant coatings used regulation SIP provision XXX.XX 24 hr EPA approved bubble #1 24 hr EPA approved bubble #1 none The above example indicates the two spray coating operations vent through different hoods but to the same catalytic incinerator. In addition they are regulated together under a 24 hour bubble. line operation efficiency & origin control devices regulation E - 2 ------- 5. List all control devices used by the source, respective capture or destruction efficiencies, origin of efficiency determination (eg., manufacturer's specs, state analysis, etc.)/ date of determination, and whether the source keeps a record of input and output concentrations and temperatures. For catalytic incinerators indicate whether the source keeps a record of when the catalyst is renewed. For carbon adsorbers indicate whether the source keeps a record of when the adsorbent is renewed, whether the adsorbed solvent is recycled or disposed, and whether the source keeps a record on amounts disposed and method of disposal. capt/dest source control device efficiency origin date records comments E - 3 ------- List any compliant coatings being used without control devices and indicate the origin of compliance determination (eg., manufacturer's spec sheets, analysis by lab subcontracted by source, etc.), and when it was determined/ dated: coating origin date 7. Are the VOC usage figures reported by the source compared against the source's purchasing/inventory records? E - 4 ------- APPENDIX F DATA SPREAD SHEETS ------- COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET al Regulatory Agency:AMS Phila Set 1 of 1 # 1 OF 4 COATINGS # INSPCTNS # COATNGS METHOD 24 SINCE ANLYZD RCE VOC SIZE SINCE 1/1/88 IN USE 1/1/88 & # COATNGS BY -3 Al 3 ? none since '79-converted to water base paints by 10/79 Al none none-using compliant coatings by 1/87 Al none none-converted to water base inks by 12/88 A2 none-resumed using solvent based inks by 9/88 134 pigments none 35 solvents Al 2/89-5-consultant (Jaca) F - 1 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET Local Regulatory Agency:AMS_Phila Set 1 of 1 EVIDENCE OF DETERMINATION OF; COATING SOURCE PROCESS TE CNTRL/CAPT/DEST EFF AMS-3 electrostatic spray no no controls # 2 OF AMS-4 2 electrostatic disc spray booths; 1 hand spray booth no no no controls AMS-6 6 flexographic presses no no controls AMS-2 paper coating no ther incin:90% dest eff-who? AMS-5 paint manu no baghouses only AMS-1 Dept21:4 litho coaters 5 litho presses; Dept22:9 punch presses no capt eff of 7 individual syste due to be determined by instal by 15 May 89-could not locate Dept23:10 assmbly lines Dept39: 2 d/i lines files during 7/20/90 file revi F - 2 ------- COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 3 OF 4 al Regulatory Agency:AMS Phila Set 1 of 1 EVIDENCE OF SOURCE RECORDS RE: DISPOSITION RCE C/ T etc CATALYST RENEWAL ADSORPTION REGEN OF ADSORBATES _3 < not applicable > -4 < not applicable- -6 < not applicable- -2 no < not applicable- ;-5 < not applicable- ;-l no no < not applicable- F - 3 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 4 OF Local Regulatory Agency:AMS Phila Set 1 of 1 EVIDENCE THAT REG AGNCY COMPARES USAGE QTYS SOURCE & PURCH/INV RCRDS OTHER AMS-3 no out of business 4/90 AMS-4 no AMS-6 no AMS-2 no AMS-5 AMS rcvd pigment purchase data for CY 83-87, but not invento data; not sure if AMS compares this with anything AMS-lno F - 4 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 1 OF 4 ^al R< JRCE -3 -5 -8 -2 -9 -10 -11 -1 -4 ^gulatory Agency: PA DER Recrion 1 Set 1 of 1 # INSPCTNS VOC SIZE SINCE 1/1/88 Al 2 Al 3 1-EPA Al 1 Al 5 A2 1 Al 1 Al 3 1-EPA Al 2 A2 1 Al 1 COATINGS # COATNGS METHOD 24 SINCE ANLYZD IN USE 1/1/88 & # COATNGS BY 1 7/88-1 DER lab ? 10/89-2-DER lab; 10/88-2cntrctr -results not in file; 5/88-2DER lab; 3/8 8 -2 -EPA- DER disputes results on 1 of 2 ? none >50 4/90-6-cntrctr; 10/88-6-cntrctr in file ? none (Jaca) rslts not ab 30 1984-8-EPA-rslts not in file ? 2/90-2 DER lab 3/89-3-DER lab 2/88-2-DER lab 57 none ? 1986-1-DER lab ? 1989-2-cntrctr or cntrctr (Jaca) (Jaca) v-7 A2 1988-1-DER lab F - 5 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET Local Regulatory Agency;PA PER Region 1 Set 1 of 1 EVIDENCE OF DETERMINATION OF: # 2 OF COATING SOURCE PROCESS TE CNTRL/CAPT/DEST EFF PA-3 fabric no no controls-<500 Ibs/day PA-5 electrostatic disc spray no incinmo eff in file PA-8 rotogravure flexographic no no incin:98%-which eff?- cntrctr hired by source-6/86 ther vs cat? PA-2 2 paper coaters each consisting of adhesive/ primer/release coatings no ther incin:no eff in file carbon ads:91% capt, 96% dest- contractor-4/90 PA-9 no no controls PA-10 rotagravure no 8 carbon ads-"collection" eff: 84-87% (EPA 1984) PA-11 flexographic rotagravure no no cat incin:85% dest eff by src using OVA various times; 97% dest eff,74% capt-cntrctr(86) PA-1 spray roller no no cat inc:50%cntrl effcntrctr(86 cat inc:95%cntrl eff-cntrctr(8 PA-4 coil coating no incin (cat vs ther?)-no eff da PA-6 metal coating no 2 cat inc<75% eff (which?)-DEF (87); 1 of 2 (which?) >76.5% e (which?)-cntrctr (88) PA-7 no ther incin:no eff in file F - 6 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 3 OF 4 ;al Regulatory Agency:PA PER Region 1 Set 1 of 1 EVIDENCE OF SOURCE RECORDS RE; DISPOSITION JRCE C/ T etc CATALYST RENEWAL ADSORPTION REGEN OF ADSORBATES -3 < not applicable > -5 no < not applicable- -8 no cat vs ther? < not applicable- -2 T-yes not applicable no adsorbate recycld & reused in process -9 < not applicable > -10 T-not not applicable auto cycling 86-89% solvent applicable; system amongst C-? 8 adsorbers -11 no no < not applicable > -l _T on per no < not applicable- coating basis -4 no ther vs cat? < not applicable- no no < not applicable- no < not applicable- F - 7 ------- VOC COMPLIANCE STUDY - SUMMER 1990 Local Regulatory Agency;PA PER Region 1 SOURCE PA-3 EVIDENCE THAT REG AGNCY COMPARES USAGE QTYS & PURCH/INV RCRDS no DATA SPREAD SHEET Set 1 of 1 OTHER # 4 OF PA-5 no PA-8 no PA-2 no process well documented in at least DER inspection reports since 1/1/88 PA-9 no <20 tons/yr over a 2 yr monitoring period PA-10 no possibly did not have latest file-DER sent latest insp rp in mail after file review there PA-11 no 10/89:silica in a VOC coating found to be poisoning catalyst PA-1 no 3/88 permit rquirs testing 10% ctnc ea yr;rprtd data for spray line assumes 44% cntrl eff PA-4 no permit very specific re operating parameters for oven, blower, heat exchanger (heat exc no longer used) PA-6 PA-7 no no correspondence indicates source is not properly replacing catalyst; filed for bankruptcy 2/88 F - 8 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 1 OF 4 ;al Regulatory Agency:PA PER Region 2 Set 1 of 1 COATINGS # INSPCTNS # COATNGS METHOD 24 SINCE ANLYZD JRCE VOC SIZE SINCE 1/1/88 IN USE 1/1/88 & # COATNGS BY -13 A2 2 2 none -14 Al 3 9 none-all compliant coatings but CDS shows this with total source classification of A2 -15 Al 2 plus many >27 none due to odor complaints lieAl4?none -12 Al 4 ? none -17 Al 3 ? none but CDS shows this with total source classification of A2 F - 9 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 2 OF Local Regulatory Agency;PA PER Region 2 Set 1 of 1 EVIDENCE OF DETERMINATION OF: COATING SOURCE PROCESS TE CNTRL/CAPT/DEST EFF PA-13 3 roller coaters 96% per 5/84:99%-who, which eff? permit application? PA-14 hi volume/low pressure spray coating 65-70% per permit application none-only compliant coatings; control for particulates only PA-15 line 1 & 2 teach w/ 3 manu and 2 auto electrostatic sprayers manu:60% control for particulates only auto:80% per permit application PA-16 14 flexographic presses no 2 cat incin:98%-which eff? who determined it? PA-12 no incin:95%-which eff? who determined it? ther vs cat? PA-17 6 printing presses/ coaters no carbon ads:98%-which eff? who determined it? F - 10 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 3 OF 4 ;al Regulatory Agency;PA PER Region 2 Set 1 of 1 EVIDENCE OF SOURCE RECORDS RE: DISPOSITION JRCE C/ T etc CATALYST RENEWAL ADSORPTION REGEN OF ADSORBATES -13 T chart cat vs ther? < not applicable > paper kept by source -not applicable- -15 -not applicable- -16 not clear whether src keeps record if so, DER does <• not provide info -not applicable- -12 no cat vs ther? -not applicable- -17 no not applicable no recovered, then? F - 11 ------- VOC COMPLIANCE STUDY - SUMMER 1990 Local Regulatory Agency:PA PER Region 2 SOURCE PA-13 EVIDENCE THAT REG AGNCY COMPARES USAGE QTYS & PURCH/INV RCRDS DER indicates no DATA SPREAD SHEET Set 1 of 1 OTHER no VOC usage data provided- properly classified as A2? # 4 OF PA-14 DER indicates no uses only compliant coatings; cntrl particulates only; Al VOC source bu A2 overall in CDS?? PA-15 DER indicates no monthly usage rprt provides no bkgr re coating contents-how is complian determined? PA-16 DER indicates yes PA-12 DER indicates yes 11/89 insp rprt indicates solvent infested soil piles-inspctr notes r problem-groundwater analysis done? PA-17 DER indicates yes inspector did not have access to control room of carbon ads system k still determined compliance F - 12 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 1 OF 4 ;al Regulatory JRCE VOC SIZE -22 Al -23 Al -24 A2 -26 A2 -20 Al -25 Al Agency: PA DER Region 3 Set 1 of 1 COATINGS # INSPCTNS # COATNGS METHOD 24 SINCE ANLYZD SINCE 1/1/88 IN USE 1/1/88 & # COATNGS BY 4 ? 5/89-6 PA 1/89-5 PA 4 ? 2/89-4 PA 10/89-4 PA 6 ? none DER DER DER DER 5 ? none-only waste inks/solvents are required to be analyzed 4 ? none-though required by '84 consent order 7 ? none -18 Al 6 ? late 88-1-source/EPA/DER jointly during stack test -• — __ - _ -- -___-..... ..._ ----.__ -19 A2 3 ? none -21 Al 5 ? none F - 13 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 2 OF Local Regulatory Agency;PA PER Region 3 Set 1 of 1 SOURCE PA-22 COATING PROCESS line 1: 4 spray booths plus 1 touch up booth; line 2: 3 spray booths EVIDENCE OF DETERMINATION OF; TE no no stain spray booth sealer spray booth topcoat spray booth CNTRL/CAPT/DEST EFF no controls-using compliant coatings but 1/89 method 24 analysis indicated at least 1 coating was noncompliant PA-23 no no no only for particulates-using compliant coatings-but 2 of 8 sampled in 89 were noncomplian PA-2 4 8 coaters no 2 incin plus carbon ads; usage rprt shows 90.25% control achv who? which device? PA-26 7 flexographic presses no press #2/#5:93% capt;#6:55% ca #7:72% capt; cat inc #1:95% de cat inc #2:99% dest- who dtrmr these efficiencies? PA-20 paper coating line paper curing line no no cat inc:90% cntrl-manu specs; inc:90% cntrl-manu specs; no test for either PA-25 7 roto prs;5 roll ctrs 100%- 6 corlon lines;3 print 2 roll coat lines;3 finish coaters- lines; >1 tile prnt line who? ther inc:no eff data; cat inc: no eff data;carbon ads:96-99.E dest eff-no testing data for incinerators *** PA-18 6 inside spray 7 end seal no no none-compliant coatings cat inc:95% capt;71% dest- cntrctr hired by src-10/88 PA-19 3 sheet coating 3 print coating no no ther incin:>90% cntrl-manu sp* ther incin:no eff data PA-21 coil coating no 7 ther incin:#1:77% ? eff-5/8f #2:98% ? eff-5/88 (PEDS) *** source determines carbon adsorption destr eff periodically thru year by material balance per perm: F - 14 special condition ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET :al Regulatory Agency;PA PER Region 3 Set 1 of 1 EVIDENCE OF SOURCE RECORDS RE; JRCE C/ T etc CATALYST RENEWAL ADSORPTION REGEN -22 < not applicable # 3 OF 4 DISPOSITION OF ADSORBATES -23 -not applicable- •24 no no no no -26 yes yes < not applicable- -20 no no < not applicable- -25 no no no no -18 no no < not applicable- -19 yes-chart < recorder; ctngs contents continuously recorded •not applicable- -21 no -not applicable- F - 15 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET Local Recrulatory Aaency:PA DER Reaion 3 EVIDENCE THAT REG AGNCY COMPARES USAGE QTYS SOURCE & PURCH/INV RCRDS PA- 2 2 yes PA-23 no PA-24 no PA-26 yes PA- 20 no PA-25 no PA- 18 no PA- 19 no Set 1 of 1 OTHER 1/89 method 24 analysis: at least 1 coating noncompliant •87 emissions: 94 tons; no subsequen data well devised computerized report fo well devised computerized rprt fonr gtrly solvent emission data provide well devised computerized rprt font very large facility-hard to determi the processes from file 1988 destr eff determined while running 2 lines thru incin designed to handle 9-possible reason for lov destr eff wrong source name in CDS; well devised computerized rprt form PA-21 no 40% of coating is water based F - 16 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 1 OF 4 :al Regulatory Agency;PA PER Region 5 Set 1 of 1 COATINGS # INSPCTNS # COATNGS METHOD 24 SINCE ANLYZD fRCE VOC SIZE SINCE 1/1/88 IN USE 1/1/88 & # COATNGS BY 27 Al 6 ? 12/88-3-consultant (Jaca) F - 17 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 2 OF Local Regulatory Agency;PA PER Region 5 Set 1 of 1 EVIDENCE OF DETERMINATION OF; COATING SOURCE PROCESS TE CNTRL/CAPT/DEST EFF PA-27 rotogravure roller 95%-iaanu specs control for particulates onl VPC roller 95%-manu specs F - 18 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 3 OF 4 :al Regulatory Agency:PA PER Region 5 Set 1 of 1 EVIDENCE OF SOURCE RECORDS RE; DISPOSITION fRCE C/ T etc CATALYST RENEWAL ADSORPTION REGEN OF ADSORBATES 27 < not applicable > F -19 ------- VOC COMPLIANCE STUDY - SUMMER 199^ DATA SPREAD SHEET # 4 OF Local Regulatory Agency;PA PER Region 5 Set 1 of 1 EVIDENCE THAT REG AGNCY COMPARES USAGE QTYS SOURCE & PURCH/INV RCRDS OTHER PA-27 yes source opts to produce <100 tons/yr to avoid compliant coatings/control emissions computed by mass balance known Quantities of ink used minus VOC recovered at source's recycling plant; CDS lists this source as SIC 3069 (fabricated rubber prods,NEC) but PER shows 2754 (qravure print: F - 20 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 1 OF 4 :al Regulatory Agency:PA PER Region 6 Set 1 of 1 COATINGS # INSPCTNS # COATNGS ANALYSES SINCE ANLYZD IRCE VOC SIZE SINCE 1/1/88 IN USE 1/1/88 & # COATNGS BY -28 Al 6 3-75% of 2/90-2; 7/88-2; all by state usage; 6/88-2 air quality total:>100 lab-Hrsburg •29 A2 3 major 2/90-2 . state air usage:13 quality lab total:350 Harrisburg F - 21 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 2 OF Local Regulatory Agency:PA PER Region 6 Set 1 of 1 EVIDENCE OF DETERMINATION OF: COATING SOURCE PROCESS TE CNTRL/CAPT/DEST EFF PA-28 disc gun electrostatic 80-95% none-using only compliant ctng: manu gun electrostatic 45-80%- both per manu specs PA-29 manu electrostatic spray 75-80%- none-using only compliant ctng per manu specs F - 22 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 3 OF 4 :al Regulatory Agency:PA PER Region 6 Set 1 of Idd EVIDENCE OF SOURCE RECORDS RE: DISPOSITION JRCE C/ T etc CATALYST RENEWAL ADSORPTION REGEN OF ADSORBATES -28 < not applicable > •29 < not applicable- F - 23 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 4 OF Local Regulatory Agency:PA PER Region 6 Set 1 of 1 EVIDENCE THAT REG AGNCY COMPARES USAGE QTYS SOURCE & PURCH/INV RCRDS OTHER PA-28 DER indicates compared only compliant coatings used; annually all manu spec sheets rvwd during inspections PA-29 DER indicates compared only compliant coatings used annually F - 24 ------- ' COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 1 OF 4 •al Regulatory Acrency: Maryland # INSPCTNS RCE VOC SIZE SINCE 1/1/88 11 Al 6 4 Al 3 EPA-1 12 Al 7 13 Al 3 6 Al 5 14 Al 3 •15 Al 3 -16 Al 3 -7 Al 1 W/EPA Department of Environment Set COATINGS # COATNGS METHOD 24 SINCE IN USE 1/1/88 & # COATNGS >22 none 5 10/89-5 ? none ? none ab 150 none ? none ? none ? none ? EPA took at least 3 8/89-no results in 1 of 2 ANLYZD BY EPA samples file -17 ? 10 none F - 25 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 2 OF Local Regulatory Agency;Maryland Department of Environment Set 1 of 2 EVIDENCE OF DETERMINATION OF: COATING SOURCE PROCESS TE CNTRL/CAPT/DEST EFF MD-11 10 kidder flexo no none-water based inks 5 spiralwound flexo no (4-20% VOC by wt) 2 plate no 1 wolverine press no MD-4 5 impregnation/oven bkng no paper tubing 10 dipcoat lines for no plastic winders none-using compliant coatings but 1 exceeded standard in 10/ testing MD-12 8 press—>2 ovens 9 press—>2 ovens 8 press—>2 ovens no no no 3 cat inc dest: 96.9% (86)-which,who? MD-13 MD-16 6 press no incin dest: 81.6% (9/89)-who? 99.8% (5/88)-who? which of the two thermal incinerators? MD-6 MD-14 MD-15 3 2 6 5 7 1 coaters press/coater rotagravure litho rotagravure proof press est 85% -who? no no no no 2 cat inc: none none-water 85%-when,who, which eff? based inks carb ads: 75% collection (6/89) none-emissions app 15 tons/yr 4 presses no none-must reduce emissions by 85% overall-how controlled? MD-7 adhsve-curtain coat adhsve-roll coat 2 screen printing 3 litho printing no no no _no_ none-compliant coatings MD-17 3 web presses 2 web presses no no 2 ther inc: new-95% cntrl-8/8< consultant hired by manufactu: uncontrolled F - 26 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 3 OF 4 :al Regulatory Agency;Maryland Department of Environment Set 1 of 2 EVIDENCE OF SOURCE RECORDS RE; DISPOSITION JRCE C/ T etc CATALYST RENEWAL ADSORPTION REGEN OF ADSORBATES -li < not applicable > -not applicable- -12 no no < not applicable- -13 no no < not applicable > -6 _T-yes no < not applicable- -charts -14 < not applicable- -15 no not applicable no no -16 < not applicable- -7 < not applicable- '-17 no < not applicable- F - 27 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET Local Regulatory Agency:Maryland Department of Environment # 4 OF Set 1 of 2 SOURCE MD-11 EVIDENCE THAT REG AGNCY COMPARES USAGE QTYS & PURCH/INV RCRDS no OTHER report Ibs ink, %VOC on monthly basis only for flexo presses MD-4 submitted 86/87 purch rcrds but not inventory rcrds compliance on daily basis by weighi substrate before & after coating fo each of 5 coatings;88-34 tons;89-24 MD-12 no MD-13 no MD-6 yes source submitting protocol for cat inc testing for MD apprvl; wrong CDS code-it is sheet metal decorate MD-14 yes-during agency inspections agency determines compliance by calculating emissions using manu spec data on coatings MD-15 no change CDS name to MD-15 with parent company of Quebecor MD-16 yes-during agency inspections-how emissions determined <50 tons/yr MD-7 no data for compliant coatings comes from MSDS/manu specs MD-17 no 2 small lines uncontrolled & indue in daily cap-must achieve 65% rdctr in accordance w/MD reg F - 28 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 1 OF 4 :al Regulatory Aaencv;Maryland Department of Environment Set 2 of 2 COATINGS # INSPCTNS | COATNGS METHOD 24 SINCE ANLYZD tRCE VOC SIZE SINCE 1/1/88 IN USE 1/1/88 & # COATNGS BY 8 Al 6 ? none Al ? ? none Al 6 ? none Al 7 ? none A2 5 ? none •5 A2 4 ? none-during EPA inspection line 1 w/EPA was down •10 Al 1 ? none F - 29 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 2 OF Local Regulatory Agency:Maryland Department of Environment Set 2 of 2 EVIDENCE OF DETERMINATION OF: COATING SOURCE PROCESS TE CNTRL/CAPT/DEST EFF MD-8 5 reactor kettles no l condenser for each:no eff da 5 thinning tanks no MD-9 mixdown tanks no condensers:no eff data MD-1 1 2 pc assembly line no 11 lacquer spray no 2 litho printers no none-using compliant coatings MD-2 5 coaters 7 end sealers no no ther incin:no eff data uncontrolled MD-3 end seal no others-not identified no none-compliant coatings MD-5 primer roll coat finish roll coat no no ther incin:90% dest eff by EP1 consultant-used for both lines MD-10 2 light bulb coat lines no carbon ads:95% overall cntrl < dtrmnd by src by comparing us« to recovered toluene F - 30 ------- : COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET # 3 OF 4 :al Regulatory AgencyiMaryland Department of Environment Set 2 of 2 EVIDENCE OF SOURCE RECORDS RE: DISPOSITION FRCE c/ T etc CATALYST RENEWAL ADSORPTION REGEN OF ADSORBATES 8 no not applicable no no no < not applicable- 1 < O T1 — /"-»}^ a T"^^/^ not applicable > -not applicable- no (as of < not applicable- 3/87) -10 no not applicable no no F - 31 ------- VOC COMPLIANCE STUDY - SUMMER 1990 DATA SPREAD SHEET Local Regulatory Agency:Maryland Department of Environment # 4 OF Set 2 of 2 SOURCE MD-8 EVIDENCE THAT REG AGNCY COMPARES USAGE QTYS & PURCH/INV RCRDS no OTHER about 2 tons VOC/yr- properly classified as Al? MD-9 no MD-l no informative description of process MD inspector in 3/89 application fc permit MD-2 no qtrly submts allowed vs act VOC daj base-no breakdwn by line/coat; uncontrolled lines averaged daily with controlled lines MD-3 no MD dtrmns act vs allowed VOC durinc inspections; MD dtrmnd noncompliani coating by reviewing MSDS MD-5 MD-10 no no source does not keep strict record.' on per coating basis due to large # of coatings used F - 32 ------- |