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
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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
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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.
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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
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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.
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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
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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.
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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.
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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).
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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
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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
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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,
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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,
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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.
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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
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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.
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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
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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.
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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
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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
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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.
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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
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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
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: 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
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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
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: 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
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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
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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
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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
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: 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
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' 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
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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
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: 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
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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
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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
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: 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
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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
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