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
                                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

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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

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 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

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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

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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

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 : 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

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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

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: 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

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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

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 : 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

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: 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

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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

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: 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

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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

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: 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

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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

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: 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

-------