United States
Environmental Protection
Agency
Office of Air Quality EPA-453/P-00-001 *
Planning and Standards April 25, 2000
Research Triangle Park, NC 27711 http.//www.epa.gov/ttn/uatw
c/EPA
National Emission Standards
for Hazardous Air Pollutants:
Metal Coi! Surface Coating
Industry Background
Information for Proposed
Standards
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Table of Contents
Section Page
1.0 Summary "...-..-. 1-1
1.1 Compliance Options 1-1
1.2 Environmental Impact 1-2
1.3 Economic Impact 1-2
1.4 Energy Impact 1-3
2.0 Introduction 2-1
2.1 Overview 2-1
2.2 Project History 2-1
2.2.1 Regulatory Background 2-1
2.2.2 Data Gathering 2-4
2.3 References 2-5
3.0 Metal Coil Coating Industry Profile and Process Description 3-1
3.1 General Process Description 3-1
3.2 Industry Profile 3-2
3.3 Coatings 3-5
3.4 Process Descriptions, Current Industry Practices, and Emission Sources 3-6
3.4.1 Storage and Handling of Coatings and Other Materials 3-7
3.4.2 Wet Section Pretreatment 3-7
3.4.3 Coating Application Stations 3-8
3.4.4 Curing Ovens 3-9
3.4.5 Quench Area 3-9
3.4.6 Wastewater Handling and Treatment 3-10
3.4.7 Baseline Emissions 3-10
3.5 References 3-10
4.0 Emission Control Techniques 4-1
4.1 Introduction 4-1
4.2 Capture Systems 4-1
4.3 Control Devices 4-2
4.3.1 Thermal Incineration 4-3
4.3.2 Catalytic Incineration 4-4
4.4 Performance of Controls 4-6
4.5 Pollution Prevention Measures 4-6
4.6 References 4-8
U.S. Environmental Protection Agency
Region 5, Library (pi-12J)
77 West Jackson Bpulevard, 12th Floor
Chicago, IL 60604-3590
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Table of Contents (continued)
5.0 Model Plants and Compliance Options 5-1
5.1 Introduction 5-1
5.2 Model Plants ". . . T . .-. 5-1
5.3 Compliance Options 5-8
5.3.1 Criterion for Evaluating HAP Emissions Reductions from Metal Coil
Surface Coating Operations 5-8
5.3.2 Consideration of Data Quality in Evaluating HAP Emission Reductions
From Metal Coil Surface Coating HAP Sources 5-9
5.3.2.1 Representativeness of the Control Device Performance Data
In the Metal Coil Surface Coating MACT Database 5-9
5.3.2.2 Quality of Metal Coil Surface Coating Capture
Efficiency Data 5-11
5.3.3 MACT Floor Determination 5-12
5.3.3.1 Floor for Overall Control Efficiency 5-12
5.3.3.2 Floor for Emission Rate 5-18
5.4 References 5-23
6.0 Environmental and Energy Impacts 6-1
6.1 Introduction 6-1
6.2 Energy Impact 6-1
6.3 Air Pollution Impact 6-3
6.4 Water Impacts 6-4
6.5 Solid Waste Impacts 6-5
6.6 References 6-5
7.0 Costs 7-1
7.1 Introduction 7-1
7.2 Model Plant Compliance Costs 7-1
7.2.1 Permanent Total Enclosure Costs 7-3
7.2.2 Oxidizer Costs 7-5
7.2.3 Condenser Costs 7-9
7.3 Nationwide Compliance Costs 7-10
7.4 References 7-13
8.0 Economic Impact Analysis 8-1
8.1 Introduction 8-1
8.2 Industry Profile 8-1
8.2.1 Coatings 8-1
8.2.2 Costs of Production 8-1
8.2.3 Uses, Consumers, and Substitutes 8-2
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8.2.4 Affected Producers 8-3
8.2.4.1 Manufacturing Facilities 8-4
8.2.4.2 Companies 8-5
8.2.4.3 Industry Trends 8-6
8.2.5 Market Data 8-7
8.2.5.1 Market Trends :..-..-. 8-8
8.3 Economic Impacts 8-8
8.3.1 Facility Impacts 8-9
8.3.2 Coating Line Impacts 8-11
8.3.3 Market Impacts 8-13
8.4 Small Business Impacts 8-14
8.5 References 8-18
Appendix A Participants in the Data Collection Report A-l
Appendix B Coil Coating Plant List B-l
Appendix C Summary Data for Companies Owning Metal Coil Coating Facilities C-l
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Table of Contents (continued)
Figures
Figure 3-1 Typical Tandem Coil Coating Line T . . -. 3-3
Figure 8-1 Distribution of Coated Metal Coil Shipments by Market: 1997 8-3
Tables
Table 3-1. Typical Coatings Used in Metal Coil Surface Coating 3-6
Table 5-1. Model Plant Parameters for Model Plant No. 1 5-3
Table 5-2 . Model Plant Parameters for Model Plant No. 2 5-4
Table 5-3. Model Plant Parameters for Model Plant No. 3 5-5
Table 5-4. Model Plant Parameters for Model Plant No. 4 5-6
Table 5-5. Model Plant Parameters for Model Plant No. 5 5-7
Table 5-6. Metal Coil Surface Coating Average Facility OCE 5-13
Table 5-7. MACT Floor Facility Products 5-17
Table 5-8. Metal Coil Surface Coating Facility Average 5-20
Table 6-1. Summary of Metal Coils Surface Coating Model and Nationwide
Energy Impacts 6-2
Table 7-1. Model Plant Specifications Used for Compliance Costing 7-2
Table 7-2. Summary of Coating Room Costs 7-4
Table 7-3. Summary of Oxidizer Upgrade Costs for Coil Coating Solvent-Borne
Model Plants 7-6
Table 7-4. Summary of Oxidizer Replacement Costs for Coil Coating Solvent-Borne
Model Plants 7-7
Table 7-5. Condenser Costs for Coil Coating Waterborne Model Plant 7-9
Table 7-6. Summary of Metal Coil Surface Coating Model and Nationwide Compliance
Costs 7-12
Table 8-1. Spot Prices for Steel and Aluminum Sheet: 1999-1998 8-2
Table 8-2. Volume and Value of Coatings Applied to Coat Metal Coils: 1996-1997 8-2
Table 8-3. Summary of Coil Coating Facilities by Producer Type: 1997 8-5
Table 8-4. Location of Potentially Affected Facilities by State: 1997 8-5
Table 8-5. Summary of Coil Coating Facilities by Ownership Size: 1997 8-7
Table 8-6. Shipments of Coated Metal Coils by Metal Type (106 tons) 8-8
Table 8-7. Summary of Compliance Cost Burden on Coil Coating Facilities by Producer
Type: 1997 8-10
Table 8-8. Summary of Compliance Cost Burden on Coil Coating Facilities by Ownership
Size: 1997 8-11
IV
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Table of Contents (continued)
Table 8-9. Summary of Compliance Cost Burden on Coil Coating Lines by
Producer Type: 1997 8-12
Table 8-10. Summary of Compliance Cost Burden on Coil Coating Lines by Ownership Size:
1997 \..-..- 8-13
Table 8-11. Compliance Cost Share of the Value of Coated Metal Coil and Inputs: 1997 8-14
Table 8-12. Summary Statistics for SBREFA Screening Analysis: MACT Floor
Alternative 8-17
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1.0 SUMMARY
Under Section 112(d) of the Clean Air Act (the Act), the U.S. Environmental Protection
Agency (EPA) is developing national emission standards for hazardous air pollutants (NESHAP)
for the metal coil surface coating source category. The EPA is required to publish final emission
standards for the metal coil surface coating source category by November 15, 2000.
The Act requires that the emission standards for new sources be no less stringent than the
emission control achieved in practice by the best controlled similar source. For existing sources,
the emission control can be less stringent than the emission control for new sources, but it must be
no less stringent than the average emission limitation achieved by the best performing 12 percent
of existing sources (for which the EPA has emissions information). In categories or subcategories
with fewer than 30 sources, emission control for existing sources must be no less stringent than
the average emission limitation achieved by the best performing 5 sources. The NESHAP are
commonly known as maximum achievable control technology (MACT) standards.
1.1 COMPLIANCE OPTIONS
A 98 percent facility-wide coating line overall control efficiency (OCE) is determined to
be the MACT floor for new and existing sources in the metal coil surface coating industry. This
OCE represents the use of permanent total enclosures to achieve 100 percent capture of
application station HAP emissions and a thermal oxidizer to achieve a destruction efficiency of 98
percent. No technology was identified that could achieve a better OCE than the use of permanent
total enclosures to capture emissions from coating application stations and a thermal oxidizer to
destroy HAP emissions from application and the curing oven.
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An alternative facility HAP emission rate limit of 0.24 pounds of HAP per gallon of solids
applied is also being considered. The facility HAP emission rate limit is intended to provide a
compliance option for facilities that choose to limit their coating line HAP emissions either
through a combination of low-HAP coatings and add-on controls or through the use of
waterborne, high solids, or other coatings that are pollution preventing.
1.2 ENVIRONMENTAL IMPACT
Total nationwide HAP emissions from metal coil surface coating operations are estimated
to be reduced by approximately 1366 tons per year from 1997 levels; a reduction of almost 55
percent. The reduction in VOC emissions cannot be quantified with available data, but the
percent reduction should be similar to the percent reduction in HAP emissions. Electric utility
generation will result in small increases in sulfur dioxide and carbon dioxide emissions from fossil-
fuel powered generation plants. Water and solid waste impacts are negligible.
1.3 ECONOMIC IMPACT
Nationwide total capital investment costs for this regulation are estimated to be $11.6
million (1997 $) and nationwide total annual compliance costs are estimated to be $5.9 million.
The economic analysis indicates that the cost of coating operations will not increase sufficiently to
cause producers to cease or alter their current coating operations. In addition, the Agency has
determined that this regulation does not impose a significant impact on a substantial number of
small businesses.
1.4 ENERGY IMPACT
Energy requirements for implementation of the compliance options for metal coil surface
coating facilities include electricity to collect and treat ventilation air, electricity for lighting
permanent total enclosures, and natural gas to provide supplemental fuel needed for stable
operation of oxidizers. The nationwide increase in electricity usage is estimated to be
14,575,603 kWh/y and the nationwide incremental natural gas usage is estimated to be
110,605,249 scf/y.
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2.0 INTRODUCTION
2.1 OVERVIEW
Under Section 112(d) of the Clean Air Act (the Act), the U.S. Environmental Protection
Agency (EPA) is developing national emission standards for hazardous air pollutants (NESHAP)
for the metal coil surface coating source category. The EPA is required to publish final emission
standards for the metal coil surface coating source category by November 15, 2000.
The Act requires that the emission standards for new sources be no less stringent than the
emission control achieved in practice by the best controlled similar source. For existing sources,
the emission control can be less stringent than the emission control for new sources, but it must be
no less stringent than the average emission limitation achieved by the best performing 12 percent
of existing sources (for which the EPA has emissions information). In categories or subcategories
with fewer than 30 sources, emission control for existing sources must be no less stringent than
the average emission limitation achieved by the best performing 5 sources. The NESHAP are
commonly known as maximum achievable control technology (MACT) standards.
The purpose of this document is to summarize the background information gathered
during the development of the metal coil surface coating industry NESHAP.
2.2 PROJECT HISTORY
2.2.1 Regulatory Background
Federal regulations that apply to metal coil surface coating include a New Source
Performance Standard (NSPS) under 40 CFR Part 60, Subpart TT, "Standards of Performance
for Metal Coil Surface Coating", which is applicable to each prime coat operation, each finish
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coat operation, and each prime and finish coat operation combined when the finish coat is applied
wet on wet over the prime coat and both coatings are cured simultaneously. The coil coating
NSPS regulates emissions of volatile organic compounds (VOC) and contains emission limits in
several forms. If an emission control device is used on a continuous basis,-VOC emissions are
limited to 0.14 kilograms per liter (kg//) of coatings solids applied or the owner or operator must
reduce emissions by 90 percent for each affected facility for each calendar month. If an emission
control device is not used, VOC emissions are limited to 0.28 kg// for each affected facility for
each calendar month. If an emission control device is used intermittently, VOC emissions are
limited to a value between 0.14 kg// ( or a 90 percent reduction) and 0.28 kg//. The NSPS was
proposed on January 5, 1981 and promulgated on April 26, 1982. All coil coating lines that were
modified or began construction or reconstruction after January 5, 1981 must be in compliance
with the NSPS. At least 43 plants are subject to this NSPS.
In addition to the NSPS, EPA also published a Control Techniques Guideline (CTG)
document' that covers metal coil surface coating operations. The CTG was intended as guidance
for States in the development of State Implementation Plans (SIP). The CTG defined a model of
reasonably available control technology (RACT) for coil coating operations, consisting of the
coating application station, the curing oven, and the quench area as 0.31 kg VOC// of applied
coating (minus water and exempt solvents). This limit is based on the use of waterborne coatings
or the use of coatings that contain 25 volume percent solids and an emission control system in
which at least 90 percent of the emissions are captured and routed to a control device
(incinerator) which achieves at least a 90 percent emission reduction.
The emission control requirements that the States impose on coil coating operations vary
substantially among the different State Implementation Plans (SIPs). The SIPs for 24 States
include the CTG VOC RACT limit of 0.31 kg// of coating excluding water and exempt solvents.
In nine other States, the SIP requires reductions equal to that required by the NSPS. California
has separate emission limits for each of its Air Quality Management Districts. Most districts
impose an emission limit of 0.20 kg// of coatings (less water and exempt solvents). One district
requires an overall reduction of 85 percent. Two States have emission limits of 0.48 kg// of
coating solids and one other State has a limit of 0.20 kg// of coating excluding water and exempt
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solvents. The remaining States do not have rules targeted specifically for coil coating operations.
None of the Federal and State regulatory efforts are specifically directed towards HAP,
however, most HAP of concern in the metal coil surface coating industry are VOC and the same
control devices used to limit VOC emissions are also applicable to HAP emissions: The primary
use of HAP is as a solvent in the primers and coatings applied to metal coil. HAP are also present
in some of the materials used for cleaning coating application equipment. The types of HAP used
in the metal coil surface coating industry and the sources of HAP emissions are described in
Chapter 3 of this document.
The MACT standards development for the metal coil surface coating industry began with
a Coating Regulations Workshop for representatives of EPA and interested stakeholders in April
1997 and continues as a coordinated effort to promote consistency and joint resolution of issues
common across nine coating source categories. The workshop covered eight categories: fabric
printing, coating and dyeing; large appliances; metal can; metal coil; metal furniture; miscellaneous
metal parts; plastic parts; and wood building products. The automobile and light duty truck
project was started subsequently.
The first phase was one in which EPA gathered readily available information about the
industry with the help of representatives from the regulated industry, State and local air pollution
agencies, small business assistance providers, and environmental groups. The goals of the first
phase were to either fully or partially:
Understand the coating process
Identify typical emission points and the relative emissions from each
Identify the range(s) of emission reduction techniques and their effectiveness
• Make an initial determination on the scope of each source category
Determine the relationships and overlaps of the source categories
• Locate as many facilities as possible, particularly major sources
Identify and involve representatives for each industry segment
• Complete informational site visits
• Identify issues and data needs and develop a plan for addressing them
• Develop questionnaire(s) for additional data gathering and
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• Document results of the first phase of regulatory development for each category.
The industry members that participated in the stakeholder process included members of
the National Coil Coaters Association (NCCA), members of the Aluminum Association (AA),
representatives of individual companies in the regulated industry, and representatives of
companies that supply coatings to the industry. States that participated in the process included
Florida, Illinois, and Pennsylvania. In addition, data were obtained from several other States
including Georgia, Michigan, California, West Virginia, Indiana, and Ohio. The U.S. EPA was
represented by EPA Region 5, the EPA Office of Air Quality Planning and Standards
(EPA/OAQPS), the EPA Office of Enforcement and Compliance Assurance (OECA), the EPA
Office of Pollution Prevention and Toxic Substances (OPPTS), and an EPA Small Business
Ombudsman. A list of participants in the data collection effort is presented in Appendix A of this
document.
The first phase of MACT standards development concluded with the drafting of a
preliminary industry characterization (PIC) document for the metal coil surface coating industry.
The information summarized in the PIC document can be used by States that may have to make
case-by-case MACT determinations under Sections 112(g) or 112(j) of the Act. The initial phase
of the regulatory development focused primarily on familiarizing the project team with metal coil
surface coating operations, identifying plants that make up the industry, and investigating the
emission control technologies in use by plants in the industry.
2.2.2 Data Gathering
Information presented in this document was collected from a variety of sources. Data
collection began with a review of information collected by the Agency during development of the
New Source Performance Standard (NSPS). A total of four meetings were held involving
representatives of all stakeholders for the purpose of information exchange and the identification
of potential data sources. A list of participants in the data collection effort is presented in
Appendix A of this document. Information was also collected during site visits to four metal coil
surface coating facilities that operate coil coating lines with a wide range of production rates. A
telephone conference meeting was also held with the regulatory subgroup which is made up of
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EPA and State representatives.
In the Spring of 1998, an information collection request (ICR) was developed for
gathering information for the development of the metal coil surface coating industry MACT
standard. The ICR was sent to 110 companies with coil coating operations identified through
literature sources and stakeholder contacts. Responses were received from 119 facilities and can
be summarized as follows:
• 26 facilities performed no coil coating
• 2 facilities coated only foil (<0.006 inch thickness)
7 facilities classified the entire response confidential business information (CBI)
2 facilities were not in operation.
Therefore, the ICR MACT database contained public information from 82 facilities which operate
133 coating lines.
Emissions and control information from the ICR MACT database are summarized in
Chapter 3 and Chapter 4, respectively, of this document. The information on HAP emissions and
controls served as the basis for the MACT floor determination described in Chapter 5 of this
document.
2.3 REFERENCES
1. U. S. Environmental Protection Agency. Control of Volatile Organic Emissions from
Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils, Papers, Fabrics,
Automobiles, and Light-Duty Trucks. Publication No. EPA-450/2-77-008. Research
Triangle Park, NC. May, 1977. 232 pages.
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3.0 METAL COIL COATING INDUSTRY PROFILE AND PROCESS DESCRIPTION1>2
3.1 GENERAL PROCESS DESCRIPTION
The metal coil surface coating source category includes any facility engaged in the surface
coating of metal coil. In this process, a coil or roll of uncoated sheet metal is coated on one or
both sides and repackaged as a coil or otherwise handled. Although the physical configuration of
the equipment used in coil coating lines varies from one installation to another, the individual
operations generally follow a set pattern. The coil coating process begins with a coil (or roll) of
bare sheet metal and, in most cases, terminates with a coil of metal with a dried and cured coating
on one or both sides. The metal strip is unrolled from the coil at the entry to the coil coating line
and first passes through a wet section, where the metal is cleaned and may be given a chemical
treatment to inhibit rust and promote adhesion of the coating to the metal surface. In some
installations, the wet section may also contain an electrogalvanizing operation in which zinc is
applied through an electroplating process to a steel substrate. After the metal strip leaves the wet
section, it is squeegeed and air dried and then passes to a coating applicator station.
Coating application stations may be used to apply a variety of coatings. In addition to
protective or decorative coatings, adhesives and printed patterns using ink may also be applied.
The most prevalent operation includes the application of protective and decorative coatings to
one or both sides of the metal strip using rollers. Following the coating application, the strip
passes through an oven where the temperature is increased to the desired curing temperature of
the coating. The strip is then cooled by a water spray, air spray, or combination of the two. If the
line is a tandem line, the first coating application is a prune coat and the metal strip next enters
another coating applicator station where a top or finish coating is applied by rollers to one or both
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sides of the metal. The strip then enters a second oven for drying and curing of the top or finish
coat. This is followed by another cooling or quench station. The finished metal strip is then
normally rewound into a coil and packaged for shipment or further processing. In some cases, the
coated metal strip may be cut rather than rerolled into a coil. Most metal coil surface coating
lines have accumulators at the entry and exit that permit the strip to move continuously through
the coating process while a new coil is mounted at the entry or a full coil removed at the exit.
Figure 3-1 is a schematic diagram of a typical, tandem coil coating line.
For existing coil coating lines, processing speed varies considerably, with some lines
having processing speeds as high as 1,200 feet per minute 3. The widths of the metal strip vary
from a few inches up to 6 feet, and thickness may vary from about 0.006 inch to more than 0.15
inch. The lower thickness of 0.006 inch has been considered to be the line of distinction between
metal coil and foil. However, 5 facilities have been identified that process coiled metal with a
thickness both above and below 0.006 inch. Three of these facilities process 5 percent foil on
each line, the fourth facility processes less than 25 percent foil on one of 6 coating lines in the
facility, and the fifth facility processes 86 percent foil on one of 9 coating lines in the facility. The
processing of foil is considered to be part of the paper and other web surface coating source
category. Thus, there is some overlap between coil coating processes and foil coating processes
within individual coil coating facilities. Unless a facility reported 100% of its substrate(s) as being
below 0.006 inch, the facility was considered to be part of the metal coil surface coating source
category.
3.2 INDUSTRY PROFILE
A total of 110 companies performing metal coil surface coating operations were identified
through literature sources and stakeholder contacts. Information collection requests (ICRs) were
sent to each of these companies in the summer of 1998. The intent of the survey was to acquire
data on HAP use and emission control in metal coil surface coating operations and associated
ancillary activities such as storage of HAP-containing materials in tanks, wet section operations,
equipment cleaning, and wastewater treatment.
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Responses were received from 119 facilities, of which 26 indicated that the facilities are
not coil coaters, 2 provided information showing that the facility only coats foil, and two were not
in operation in 1997. Therefore, 89 coil coating facilities returned completed questionnaires; 14
companies did not respond to the questionnaire.
The information collected from the metal coil surface coating industry was entered into a
database. The metal coil surface coating MACT database (MACT database) contains a total of
82 facilities, excluding 7 facilities that classified the entire ICR response confidential business
information (CBI). The MACT database facilities had a total of 125 coating lines reported.
Appendix B of this document contains information on plant location, number of lines, type of
control device used, and annual HAP emissions.
Major markets for coil coated metal include the transportation industry, building products
industry, large appliance industry, can industry, and packaging industry. Other end products
include coated tape rules, ventilation systems for walls and roofs, lighting fixtures, office filing
cabinets, cookware, and sign stock. The industry has maintained a positive growth rate for a
number of years as new end uses for precoated metal have continued to emerge.
Although coil coated metal is used in a wide variety of products, metal coil surface coating
is typically not a product specific operation but rather is a distinct process. Many of the other
surface coating source categories being regulated under section 112 of the Act are product
specific, such as the metal can and large appliances source categories. For the purposes of
standard development, the EPA considers any coil coating process, regardless of the end product,
as part of the metal coil source category. Product-specific source categories include surface
coating operations that are not coil coating processes.
Types of metal processed by the coil coating industry are mainly aluminum, cold rolled
steel, cold rolled steel (galvanized on-line), hot-dipped galvanized steel, and galvalum/zincalum.
Small quantities of other metals including brass are also coated. Coil coated metal is fabricated
into end products after it is coated, thus eliminating the need for post-assembly painting. Toll and
captive coaters represent the two basic industry divisions. Toll coaters produce metal that is
coated in accordance with specifications of their customers. Captive coaters both coat the metal
and fabricate it into end products within the same company. Examples of captive coaters are can
manufacturers who have dedicated coil coating lines for metal used in the can manufacturing
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process, and housing products manufacturers who coat the material for their products using
company owned and operated coil coating lines. Some plants perform both toll and captive
operations. Data from the MACT database indicate that approximately 40% of the facilities
reported being toll coaters, 38% reported being captive coaters, and 22% reported performing
both toll and captive coating.
3.3 COATINGS
The types of coatings applied in coil coating operations include a wide variety of
formulations. Among the more prevalent types are polyesters, acrylics, fluorocarbons, alkyds,
vinyls, epoxies, plastisols, and organosols. Table 3-1 lists the coatings commonly used in the
industry and gives the approximate range of organic solvent content of each. In addition to these
traditional coatings, adhesives, bondable backers, strippable protective coatings, lacquers, teflons,
liquid rubber, graphite, kynar, latex, extruded synthetic rubber-based solid resins, and other non-
traditional coatings are also used by the industry 5. The majority of the coatings, estimated at
about 85 percent6, are organic solvent based and have solvent contents ranging up to 80 percent
by volume with most being in the range from 30 to 70 percent. The remaining 15 percent of
coatings are mostly of the waterborne type which also contain some organic solvents ranging
from about 2 to 15 percent by volume 7. While waterborne coatings are in use at a number of coil
coating facilities, they are not available in formulations that are suitable for all end product
applications. The choice of waterborne versus solvent borne coatings usually depends on the end
use of the coated metal and the type of metal used. The most prevalent use of waterborne
coatings is on aluminum used for siding in the construction industry. Other uses include printing
plates, suspended ceiling systems, and body and endstock for food cans.
High-solids coatings in the form of plastisols, organosols, and powder are also used to
some extent by the coil coating industry. Because these coatings have a lower organic solvent
content, potential organic emissions are lower than from the other, more commonly used
coatings. However, these coatings also have limited applicability and are not available in
formulations suitable for use on all end products. Typical uses for these coatings are residential
siding, drapery hardware, and other products.
Little data have been identified that represent the HAP content of coatings used in the
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metal coil surface coating industry. Information provided by one of the coating suppliers 8 for
three typical coatings showed HAP contents ranging from about 5 to 28 percent by weight.
Reported data from the MACT database indicate that HAP contents for all coatings used in the
coil coating industry range from 0 to 95 percent by weight, with an average reported value of
approximately 16 percent.
Table 3-1. Typical Coatings Used in Metal Coil Surface Coating
Volatile Content
Coatings (Weight %)
Acrylics 40-45
Adhesives 70-80
Alkyds 50-70
Epoxies 45-70
Fluorocarbons 55-60
Organosols 15-45
Phenolics 50-75
Plastisols 5-30
Polyesters 45-50
Silicone Acrylics & Polyesters 35-60
Urethanes 60-75
Inks 50-65
Solution Vinyls 75-85
Vinyls 60-75
Source: Reference 4.
3.4 PROCESS DESCRIPTIONS, CURRENT INDUSTRY PRACTICES, AND EMISSION
SOURCES
Although specific steps in a coil coating operation differ between plants, most have a
common series of steps that include storage and handling of raw materials and a coating line that
includes a wet section and one or more coating operations consisting of a coating application
station, a curing oven, and a quench area. Most plants also generate wastewater and have some
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type of wastewater treatment system. The following paragraphs provide brief descriptions of the
common operations found on coil coating lines and provides general information regarding
potential HAP emissions.
3.4.1 Storage and Handling of Coatings and Other Materials
Many of the coatings, solvents, and wet section chemicals are delivered and stored in 55
gallon drums but may also be delivered and stored in totes, which are transportable containers
with a capacity generally in the range of from 200 to 500 gallons. Some plants also receive raw
materials in bulk by tank trucks or rail cars and store the materials in bulk storage tanks. These
tanks may be located inside a building or may be outdoors either above ground or underground.
For raw materials delivered and stored in drums or totes, no emissions should occur during
normal storage provided that they typically are kept sealed and generally do not leak. Emissions
would only occur when the drums or totes are opened.
Where coatings are delivered by tank truck or rail car, working loss emissions occur when
the coatings are pumped from the delivery vehicle to bulk storage tanks. Some tanks are vented
to the tank trucks while they are being filled, thus making working losses negligible. During
storage, daily temperature fluctuations generate breathing loss emissions. Breathing losses would
be expected to be low for tanks that are underground or enclosed in controlled temperature
environments relative to tanks that are outdoors, above ground and exposed to diurnal
temperature cycles. Based on data from the MACT database, emissions from storage tanks
account for approximately 2% of nationwide HAP emissions from metal coil surface coating
operations.
Before application of the coatings to the coil, the coatings are typically stirred. They may
also be thinned with solvent to adjust the viscosity. In some cases, coatings are mixed together.
One example is mixing to achieve a particular color. Another example is the blending of excess
coatings together to use as a backer. Another coating modification operation, intermixing,
involves adding ingredients to perform coating color tinting (with no pigment dispersion). Data
from ICR responses indicate that emissions from mixing and thinning account for approximately
3.5% of nationwide HAP emissions from metal coil surface coating operations.
3.4.2 Wet Section Pretreatment
The wet section of a metal coil surface coating line includes cleaning steps that may use
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water, caustic cleaners, brushing, or acid treatment. Processes may include spray applications of
materials or may include submersion of the metal strip. Specific processes included in the wet
section depend on the type of metal substrate, characteristics of the coatings to be applied, and
other parameters. The chemical treatments used in the wet section may contain HAP. Data from
ICR responses indicate that HAP emissions from wet section operations account for
approximately 0.29% of nationwide HAP emissions from metal coil surface coating operations.
3.4.3 Coating Application Stations
At the coating application stations, coatings are applied by rollers to one or both surfaces
of the metal strip as it passes through the station. Emissions of HAP occur when HAP-containing
solvents contained in the applied coatings evaporate. It is estimated that between 0 and 15
percent of the coating solvent evaporates at the coating station9. Data from the MACT database
indicate an average of approximately 9.1 percent of coating solvent evaporation taking place at
the coating station. If HAP-containing cleaning solvents are used, emissions of HAP also occur
during cleaning of the paint rollers and other parts of the application station between coating
sessions or when a color change is made. Cleaning may be carried out in place using solvent and
rags, or portions of the coaters may be removed for cleaning. Data for HAP emissions from parts
and equipment cleaning were available for 40 percent of the facilities that returned ICR responses.
For these facilities, parts and equipment cleaning HAP emissions account for approximately 4
percent of nationwide HAP emissions from metal coil surface coating operations.
At many plants, the coating application stations are enclosed in rooms. Because air is
drawn into the ovens from these rooms, it is generally believed that a large fraction, and in some
cases all, of the solvent that evaporates in this area is captured by the ovens. Hoods or "snouts"
may be used to increase the fraction of solvent emissions captured by the ovens. Plants may also
use smaller coating station enclosures, which require less ventilation air, and are not occupied by
workers except when the enclosure is opened for maintenance or inspection. On lines that do not
have coating rooms or smaller enclosures, an exhaust hood is frequently installed directly over the
roll coaters to exhaust the solvent that evaporates in that area. In these cases, the hoods may be
exhausted to the ovens, a control device, or to the atmosphere. Some plants do not use hoods or
enclosures around the coating application stations; therefore, the majority of the solvent
evaporated at the coating station would be emitted to the atmosphere. Data from the MACT
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database indicate that permanent total enclosures, partial enclosures, hoods, floor sweeps, extra
ventilation to control devices, walls around coating stations, and oven extensions are used
throughout the metal coil coating industry as enclosure and capture methods.
3.4.4 Curing Ovens
After coatings are applied to the surface of the metal strip, the strip enters an oven where
heat is applied to evaporate the organic solvent and water contained in the applied coatings. An
estimated 85 to 100 percent of the organic solvent content of applied coatings evaporate inside
the curing ovens 10. Data from the MACT database indicate an average of approximately 90
percent of the organic solvent content of applied coatings evaporating inside the curing ovens.
Most curing ovens used in coil coating operations are direct fired and use natural gas as fuel.
Many ovens are designed to use propane as a backup fuel in case of natural gas curtailments.
Ovens heated by fuel oil or electricity are used in some plants, but to a much lesser extent than
those heated by natural gas. The heat input to the ovens must be sufficient to evaporate the
solvent in the coatings, to bring the metal and coatings up to the design temperature, usually in
the range of 375 to 600 °F, to replace the heat lost from the ovens by radiation and conduction,
and to heat dilution air to oven operating temperature. Oven ventilating air (or dilution air) is
normally the largest single factor in the total oven heat load. Data from the MACT database
indicate an average oven exhaust gas temperature of approximately 560 degrees Fahrenheit.
Solvent borne coatings, if uncontrolled, would result in higher organic emissions from the
oven than either waterborne coatings or high solids coatings. Emissions of HAP compared to
organic emissions depend on the proportion of HAP as compared with non-HAP solvents in the
coatings.
3.4.5 Quench Area
When the metal strip exits the curing oven, it is cooled, usually by a water spray, an air
spray, or a combination of the two before being repackaged as a coil or passing to another coating
station. An estimated 0 to 2 percent of the organic solvent in the applied coatings is released in
the quench area ". Data from ICR responses indicate an average of approximately 0.6 percent of
the organic solvent in the applied coatings is released in the quench area. The quench area is
normally an enclosed area adjacent to the exit from the curing oven and a large fraction of the
emissions released in this area are estimated to be captured by the oven ventilation system.
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However, at some plants, the quench area is vented directly to the atmosphere.
3.4.6 Wastewater Handling and Treatment
Most plants generate wastewater from wet section operations, quenching operations, or
both. Based on data from ICR responses, organic solvents are not typically used in the wet
section. Consequently, not much organic solvent gets into plant wastewater. Response data from
the ICRs indicate that wastewater handling and treatment operations account for approximately
0.07 percent of nationwide HAP emissions from metal coil coating operations. Coil coating
wastewater may contain chromium compounds, but the potential for air emissions of these
compounds is small. Wastewater may also be generated by clean up activities at plants that use
waterborne coatings.
3.4.7 Baseline Emissions
Information collection requests were sent to 110 companies performing metal coil coating
operations that were identified through literature sources and stakeholder contacts. Responses
were received from 119 facilities. Twenty-six of those facilities indicated that they are not coil
coaters, 2 provided data showing that the facility coats foil only, and two facilities were not in
operation in 1997. Therefore, 89 coil coating facilities returned completed ICRs; 14 companies
did not respond to the questionnaire. The surveyed facilities were asked to provide facility HAP
emissions from metal coil surface coating operations as well as HAP emissions from specific unit
operations associated with metal coil surface coating. Total nationwide HAP emissions from
metal coil surface coating operations were calculated to be 2484 tons in 1997 by summing facility
HAP emissions reported by these facilities.
3.5 REFERENCES
1. U.S. Environmental Protection Agency. Metal Coil Surface Coatings MACT Docket
Number A-97-47 Item Numbers II-D-1 through II-D-113. ICR Responses. Office of Air
Quality Planning and Standards. Research Triangle Park, NC. Responses received
September 1998-April 1999.
2. U.S. Environmental Protection Agency. Metal Coil Surface Coating Industry-Background
Information for Proposed Standards. Office of Air Quality Planning and Standards.
Research Triangle Park, NC. EPA-450/3-80-035a. October 1980.
3. Reference 1.
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4. Reference 2, p. 3-4 updated with information from Reference 1.
5. Reference 1.
6. Reference 2, p. 3-2. ~ - -
7. Reference 2, p. 3-2 and 3-5.
8. Letter from Jelf, III, William E., Akzo Nobel Coatings, Inc. to Lacy, Gail, US EPA.
September 12, 1997. Data sets for three (3) typical coil coatings.
9. Reference 2, p. 3-7.
10. Reference 9.
11. Reference 9.
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4.0 EMISSION CONTROL TECHNIQUES
1,2
4.1 INTRODUCTION
The emission reduction techniques in use by the metal coil coating industry that have been
identified to date primarily are related to coating application and curing ovens. There are two
main approaches to limiting HAP emissions in the coil coating industry. The approach most
commonly used is to improve capture and control systems. For most coil coating facilities in the
industry, oven emissions are typically controlled by the use of thermal or catalytic incinerators
which may be located inside or outside the ovens. Most plants employ some form of heat
recovery to improve the overall energy efficiency of the coil coating operation. The second
approach, focusing on pollution prevention, involves using low-HAP or HAP-free materials.
4.2 CAPTURE SYSTEMS
Capture systems are designed to collect solvent-laden air and direct it to a control device.
At many coil coating facilities, the coating application stations are enclosed hi rooms. If a source
of emissions is contained in a room or building such that the entire ventilation air is directed to the
control device, the capture efficiency is essentially 100 percent3. This type of capture system is
called a permanent total enclosure (PTE). EPA Test Method 204 outlines the five criteria
necessary for operating a PTE; briefly, they are as follows:
• Any natural draft opening (NDO) shall be at least 4 equivalent opening diameters from
each emission source. An equivalent diameter is equal to the diameter of a circle that has
the same area as the opening.
The total area of combined NDOs shall not exceed 5% of the total surface area the
enclosure including the floor and ceiling.
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The average face velocity (FV) of air through the NDOs shall be at least 200 feet per
minute and the direction of flow shall be into the enclosure.
• All access doors and windows not included as NDOs shall be closed during routine
operation of the process.
• All exhaust gases from the enclosure must be directed to a control device 4.
Data from the MACT database indicate that approximately 49 percent of the surveyed facilities
use permanent total enclosures.
The MACT database information also indicates that partial enclosures, hoods, floor
sweeps, extra ventilation to control devices, walls around coating stations, and oven extensions
are used throughout the metal coil coating industry as enclosure and capture methods. According
to the responses, approximately 19 percent of the surveyed facilities use at least partial enclosures,
24 percent reported the use of at least hoods, 14 percent reported using at least floor sweeps,
approximately 20 percent reported at least the use of extra ventilation to a control device, 10
percent reported at least the presence of walls around coating stations, 29 percent reported using
at least oven extensions, and approximately 7 percent reported "other", with those answers
ranging from "enclosed room under negative pressure with an exhaust fan that is discharged into
the oven" to "applicator is open, oven exhaust uncontrolled."
4.3 CONTROL DEVICES
Oven emissions in the coil coating industry are typically controlled by the use of thermal
or catalytic incinerators. These devices may be located inside or outside the curing ovens. Data
from the MACT database indicate that 72 facilities operate incinerators on their coating lines; 10
facilities reported operating with no incinerators. There were 105 controlled coil coating lines; of
the 105 controlled lines, 79 lines were controlled with thermal incinerators and 24 lines with
catalytic oxidizers. Two lines were controlled with condenser/scrubber systems. In general, all of
the metal coil surface coating facilities with control devices that responded to the survey have
similar capture and control systems. The reported data on capture and control device destruction
efficiency consisted of test data, mass balance comparisons, vendor guarantees, and engineering
judgement.
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4.3.1 Thermal Incineration
Thermal incinerators use a flame combined with a chamber to convert HAP-containing,
solvent-laden air into carbon dioxide and water. An incinerator typically consists of a refractory-
lined chamber equipped with one or more sets of burners. The contaminated airstream is passed
through the burners and heated above its ignition temperature. The hot gases then pass through
one or more residence chambers where they are held for a certain length of time to ensure
complete combustion5.
The most important factors to consider in the operation of a thermal incinerator are
combustion temperature and residence time because these parameters determine the incinerator's
destruction efficiency. In addition, at a given temperature and residence time, destruction
efficiency is also affected by the degree of turbulence (mixing) of the emission stream and heated
combustion gases in the incinerator6. Data in the MACT database indicate that metal coil coating
facilities typically operate incinerators at a temperature of 1400 degrees Fahrenheit. Most
facilities also employ continuous monitoring for this parameter.
Destruction efficiencies of up to 99+ percent are achievable with thermal incineration at
inlet stream HAP concentrations as low as 100 parts per million by volume (ppmv). Even though
they accommodate small fluctuations in flow, thermal incinerators are not well suited for streams
with highly variable flow because reduced residence time and poor mixing caused by increased
flow conditions decrease the completeness of combustion; this causes the combustion chamber
temperature to fall and decreases destruction efficiency 7.
Thermal incineration is typically applied to emission streams that are dilute mixtures of
HAP and air. In these cases, due to safety considerations, the concentration of pollutants is
routinely limited by insurance companies to 25 percent of the lower explosive limit (LEL) for the
pollutant(s) in question. The LEL for a flammable vapor is defined as the minimum concentration
in air or oxygen at and above which the vapor burns upon contact with an ignition source and the
flame spreads through the flammable gas mixture 8. Thus, if the pollutant concentration is high,
dilution may be required.
The heating of the exhaust stream to the high incineration temperatures requires large
amounts of energy unless some means of heat recovery is incorporated into the system. Several
concepts of heat recovery are used in the coil coating industry. These include direct recycle of a
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portion of the oven atmosphere through internal oven burners or incinerators, the use of
regenerative heat exchangers, and the use of recuperative heat exchangers. Waste heat boilers are
also employed in conjunction with some of these systems. Steam from these boilers can be used
in the wet section of the coil coating line or in other processes in the facility.
Data from the MACT database indicate that 11 percent of the facilities reporting control
device data reported the use of regenerative oxidizers. Likewise, 7 percent reported the use of
recuperative oxidizers. Reported data from the MACT database indicate an average value of heat
recovery of 39 percent.
4.3.2 Catalytic Incineration
Catalytic incinerators operate on the same basic principles as thermal oxidizers but contain
a catalyst. The catalyst causes the oxidation reaction between the solvent and air to occur at a
lower temperature for the same solvent concentration and composition; therefore, catalytic units
require less fuel to heat the oven exhaust gases to combustion temperatures, and they have a
lower exhaust temperature than equivalent thermal incinerators.
Installation costs for catalytic incinerators are comparable to those of thermal oxidation
units, but catalytic incinerators are generally smaller than equivalent thermal systems, resulting in
a space savings over a thermal system. These savings are offset by the cost of the catalysts, which
are noble metals or metal oxides. One of the most commonly used catalysts is platinum and its
salts.
In some situations, problems may be encountered with the use of catalytic incineration
systems. The major problem is catalyst deactivation. Materials such as phosphorus, bismuth,
lead, arsenic, antimony, mercury, iron oxide, tin, zinc, sulfur, and halogens in the emission stream
can poison the catalyst and adversely affect its performance. Some of these elements may be
present in the pigments used in some coil coatings. The catalyst may be masked by high
molecular weight organics, alumina, and silica dusts and may be suppressed by halogens and
sulfur, each of which can be present in some coating formulations. However, recent advances
have produced catalysts that are relatively tolerant of compounds containing sulfur or chlorine.
These new catalysts are single or mixed metal oxides that are supported by a mechanically strong
carrier. Catalysts such as chrome/alumina, cobalt oxide, and copper oxide/manganese oxide have
been demonstrated to control emission streams containing chlorinated compounds. When a
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catalyst becomes deactivated or masked, it must be regenerated or cleaned. The time necessary
for cleaning/regeneration can vary from a few hours to a day. Catalyst life is limited by thermal
aging and loss of active sites by erosion, attrition, and vaporization. With proper operating
temperatures and temperature control, these processes are normally slow, and satisfactory
performance can be maintained for 2 to 5 years before replacing catalysts 9.
Factors affecting the performance of catalytic incinerators are: 1) operating temperature
(operating temperature at the catalyst bed inlet and the temperature rise across the catalyst bed),
2) space velocity (reciprocal of residence time), 3) pollutant composition and concentration, 4)
catalyst properties, and 5) presence of poisons/catalyst inhibitors in the emissions stream. The
operating temperature for a particular destruction efficiency is dependent on the concentration
and composition of the pollutant in the emission stream and the catalyst type. Typically, the
concentration of flammable vapors in HAP emission streams containing air is limited to less than
25 percent of the LEL for safety requirements 10.
Space velocity is the volumetric flow rate of the combined gas stream (i.e., emission
stream, supplemental fuel, and combustion air) entering the catalyst bed divided by the volume of
the catalyst bed. At a given space velocity, increasing the operating temperature at the inlet of the
catalyst bed increases destruction efficiency. At a given temperature, as space velocity decreases
(i.e., as residence time in the catalyst bed increases), destruction efficiency increases. Catalytic
incinerators can achieve overall destruction efficiencies for HAP of about 95 percent with space
velocities in the range of 30,000-40,000 hf1 with precious metal catalysts, or 10,000-15,000 hr1
with base metal catalysts. However, larger catalyst volumes and/or higher operating temperatures
are required to achieve higher destruction efficiencies (i.e., 99 percent). The 95 percent
destruction efficiency can be achieved at inlet stream HAP concentrations of 100 ppmv ".
After oxidation of the emission stream, the energy in the flue gases leaving the catalyst bed
may be recovered. Ways of recovering flue gases include 1) use of a recuperative heat exchanger
to preheat the emission stream and/or combustion air, or 2) by use of the available energy for
process heat requirements (e.g., recycling flue gases to the process, producing hot water or steam,
etc.).
Traditionally, the industry members that have found catalytic incineration suitable for their
operations are the captive coaters that coat only a few different products with a limited number of
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coatings. These coaters can control the coating materials used to insure that no chemical poisons
are present to deactivate the catalysts. In contrast, for toll coaters, who must often use a wider
variety of coatings specified by their customers, the chance of catalyst poisons being introduced
into the catalytic incineration system is proportionately greater. Data from the MACT database
indicate that 75 percent of the facilities reporting catalytic incinerator use reported being captive
coaters with an average of 99.5 percent by weight of coatings applied in captive processes.
4.4 PERFORMANCE OF CONTROLS
The information concerning the level of HAP emissions from coating application and
curing collected in the metal coil surface coating MACT survey included the capture efficiency for
each coating application area or for the entire coating line and the destruction efficiency of the
control device receiving the HAP emissions. The data from the MACT database indicate capture
efficiencies ranging from 86.4 percent up to 100 percent and destruction efficiencies ranging from
84 percent up to 99.99 percent. The industry-wide average capture efficiency is 97.3 percent and
the industry-wide average destruction efficiency is 96.9 percent.
4.5 POLLUTION PREVENTION MEASURES
Pollution prevention involves reducing or eliminating waste where it originates and
includes practices that increase efficiency in the use of raw materials. In the metal coil coating
industry, pollution prevention measures include the use of waterborne coatings, powder coatings,
and work practices/housekeeping alternatives.
According to data in the MACT database, the average HAP content of solvent-borne
coatings used in the metal coil coating industry is greater than 40 percent. One method of
reducing HAP emissions from the metal coil coating process is to use coatings that have been
reformulated to contain less HAP. To this end, several facilities in the coil coating industry use
waterborne coatings exclusively. Data from the MACT database indicate that 10 facilities use
only waterborne coatings. For these facilities, the average by-weight HAP content of the coatings
ranged from 0.1 percent to 15.7 percent. The average value for the 10 facilities using only
waterborne coatings was 5.1 percent. The data in the MACT database also indicate that for 30
coil coating lines, at least 50 percent by volume of the coatings applied were waterborne coatings.
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The average by-weight HAP content of these coatings was 5 percent.
Powder coatings have not been used to an appreciable extent in the coil coating industry,
presumably due to technical problems in application and the limited selection of suitable coatings
for metal coil coated products. No facilities in the MACT database use powder coatings.
Work practices and housekeeping involve human activities undertaken to reduce emissions
or waste such as operator training, management directives, and work procedures or other
techniques for conducting emission or waste generating processes. Data from the MACT
database reveal that several types of work practices and housekeeping techniques are being used,
including the following:
Improving substrate pretreatment methods to control the amount of chemicals being
discharged for treatment
• Optimizing production run scheduling to generate long production runs per color to
reduce color changeovers
• Keeping all containers covered at all times except during filling and emptying operations
• Cleaning coating rolls and pans inside enclosed coating booths to insure that emissions are
captured and controlled
• Keeping all solvent soaked rags in closed containers
Reducing paint spillage when filling totes
• Improving paint inventory systems by tracking and recording paint consumption on a
revised manufacturing order which facilitates the prioritization of drums of paint such that
the shelf life is not exceeded, thus reducing the amount of hazardous waste resulting from
degraded paint
• Conducting employee training and awareness programs to aid in the implementation of
process changes designed to minimize paint related waste generation
Conducting training and department housekeeping inspections.
Based on data collected in a survey conducted by the National Coil Coaters Association
(NCCA)12, the following work practices were identified for coating line cleanup
operations:
Cleaning solvent is typically transferred into closed containers which are then used to
dispense the solvent at the production line
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• Soak tanks used for cleaning rollers or other miscellaneous parts removed from the line
are typically equipped with covers
Containers that are typically used to collect liquid waste are typically equipped with covers
• Solvent soaked rags are stored in closed containers or are compressed to remove free
solvent before storage.
The NCCA's data analysis also indicated that open top containers or vessels were typically used
for mixing and blending and the majority of the plants were conducting mixing and thinning
operations in areas of the plant that were not vented to a control device.
4.6 REFERENCES
1. U.S. Environmental Protection Agency. Metal Coil Surface Coatings MACT Docket
Number A-97-47 Item Numbers II-D-1 through II-D-113. ICR Responses. Office of Air
Quality Planning and Standards. Research Triangle Park, NC. Responses received
September 1998-April 1999.
2. U.S. Environmental Protection Agency. Metal Coil Surface Coating Industry-Background
Information for Proposed Standards. Office of Air Quality Planning and Standards.
Research Triangle Park, NC. EPA-450/3-80-035a. October 1980.
3. Olestad, Andrew. Fugitive VOC Capture Systems using the "Total Permanent Enclosure
Concept". Paper No. 93-TA-33.03, presented at the Air and Waste Management
Association Annual Meeting and Exhibition. Denver, Colorado. June 1993.
4. Bemi, Dan. "Demonstrating VOC Capture Efficiency Using Permanent Total Enclosure
Technology: Common Practices, Challenges and Rewards." Paper No. 97-TA4B.04,
presented at the Air and Waste Management Association Annual Meeting and Exhibition.
Toronto, Ontario, Canada. June 1997.
5. U.S. Environmental Protection Agency. APTI Course 415 Control of Gaseous Emissions.
EPA 450/2-81-005. Air Pollution Training Institute, Environmental Research Center.
Research Triangle Park, NC. December 1981.
6. U.S. Environmental Protection Agency. Control Technologies for Hazardous Air
Pollutants Handbook. EPA/625/6-91/014. Office of Research and Development.
Washington, DC. June 1991. p. 4-2.
7. Reference 6, p. 3-2 and 3-3.
8. Reference 6, p. 4-3.
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9. Reference 6, p. 3-3.
10. Reference 6. p. 4-12.
11. Reference 6. p. 3-2.
12. Environmental Resources Management. Metal Coil Surface Coating ICR Data Analysis
and MACT Floor Proposals. June 2, 1999.
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5.0 MODEL PLANTS AND COMPLIANCE OPTIONS
/
5.1 INTRODUCTION
This chapter presents the five model plants developed as parametric descriptions of the
coating application and curing operations on a metal coil surface coating line and the approach
followed to specify the model plants. This chapter also presents the MACT floor determination
for the metal coil surface coating source category and the compliance options representing the
MACT floor. No options more stringent than MACT floor were identified.
The model plants were used to estimate the control costs presented in Chapter 7 and the
environmental and energy impacts presented in Chapter 6 resulting from conformance with the
compliance options.
5.2 MODEL PLANTS ' 2
The coatings applied in the metal coil surface coating industry can be classified as solvent-
borne and waterborne, with the vast majority of the coatings applied being solvent borne.
Volume of solids applied annually was determined to be the best parameter in the database to
serve as the basis for the size of the coating line applying solvent-borne coatings. Therefore, the
volume of solids applied was used to define four different sizes of model plants. The coating lines
applying solvent-borne coatings in facilities in the database were grouped by volume of solids
applied annually as follows:
• Model Plant No. 1, less than 50,000 gallons of solids applied per year
• Model Plant No. 2, between 50,000 and 100,000 gallons of solids applied per year
• Model Plant No. 3, between 100,000 and 200,000 gallons of solids applied per
year
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• Model Plant No. 4, more than 200,000 gallons of solids applied per year.
For each size model plant, average values across the coating lines in each size category were
calculated for each parameter used to describe the model plant. Tables 5-1 through 5-4 present
the model plant parameters for the four different sizes of model plants representing coating lines
applying solvent-borne coatings.
Five plants have been identified in the metal coil surface coating database that apply only
waterborne coatings and do not use add-on controls to reduce HAP emissions from coating.
Since the emission characteristics are different for waterborne coatings compared to solvent-borne
coatings and for four of the facilities, the HAP emissions are considerably lower than for Model
Plants 1 through 4, a fifth model plant was defined to represent a coating line applying waterborne
coatings. Average values across the waterborne coating lines were calculated for each parameter
used to describe the model plant. Table 5-5 presents the parameters for the waterborne coating
line model plant.
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Table 5-1. Model Plant Parameters for Model Plant No. 1
Annual operating time:
Annual coating time a:
Annual gallons of solids applied:
Coating:
Ovensb:
Number
Maximum solvent concentration
Solvent capacity
Air flow
Exhaust temperature
4270 hours
2990 hours
13,700 gallons
Solvent-borne, 35% HAP by weight; 41% solids by
weight
1
25% LEL
56 gallons/hour
9333 ACFM
410 °F
Annual coating time is estimated to be 70% of annual operating hours.
Parameters are given on a per oven basis.
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Table 5-2. Model Plant Parameters for Model Plant No. 2
Annual operating time:
Annual coating time a:
Annual gallons of solids applied:
Coating:
Ovens b:
Number
Maximum solvent concentration
Solvent capacity
Air flow
Exhaust temperature
5300 hours
3710 hours
79,500 gallons
Solvent-borne, 40% HAP by weight; 35% solids by
weight
1
25% LEL
51 gallons/hour
8500 ACFM
515 °F
Annual coating time is estimated to be 70% of annual operating hours.
Parameters are given on a per oven basis.
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Table 5-3. Model Plant Parameters for Model Plant No. 3
Annual operating time:
Annual coating time a:
Annual gallons of solids applied:
7700 hours
5390 hours
129,000 gallons
Coating:
Ovensb:
Number
Maximum solvent concentration
Solvent capacity
Air flow
Exhaust temperature
Solvent-borne, 41% HAP by weight; 49% solids by
weight
25% LEL
88 gallons/hour
14,700 ACFM
710 °F
Annual coating time is estimated to be 70% of annual operating hours.
Parameters are given on a per oven basis.
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Table 5-4. Model Plant Parameters for Model Plant No. 4
Annual operating time:
Annual coating time a:
Annual gallons of solids applied:
7700 hours
5390 hours
293,000 gallons
Coating:
Ovens b:
Number
Maximum solvent concentration
Solvent capacity
Air flow
Exhaust temperature
Solvent-borne, 13% HAP by weight; 59% solids by
weight
25% LEL
98 gallons/hour
16,300 ACFM
470 °F
Annual coating time is estimated to be 70% of annual operating hours.
Parameters are given on a per oven basis.
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Table 5-5. Model Plant Parameters for Model Plant No. 5
Annual operating time: 2660 hours
Annual coating time a: 1860 hours
Annual gallons of solids applied: 40,300 gallons
Coating: Water-borne, 3.5% HAP (glycol ethers) by weight;
49% solids by weight
Ovens:
Number 1
Solvent capacity 1.4 gallons/hour (14 gallons water/hour)
Air flow 6650 ACFM
Exhaust temperature 295 °F
a Annual coating time is estimated to be 70% of annual operating hours.
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5.3 COMPLIANCE OPTIONS
5.3.1 Criterion for Evaluating HAP Emission Reductions from Metal Coil Surface Coating
Operations
The MACT floor for metal coil surface coating was evaluated on an emission source or
unit operation basis rather than on a plant-wide basis, because, in general, the facilities in the
metal coil surface coating source category capture and control emissions from their HAP emission
sources in this same manner.
From a HAP emission source analysis of the metal coil surface coating survey responses, it
was found that coating application and curing are the largest sources of HAP emissions at metal
coil surface coating facilities. On a nationwide basis, the portion of total facility HAP emissions
attributed to coating application and curing by respondents to the metal coil surface coating
MACT survey was approximately 90 percent.
Other sources of HAP emissions associated with metal coil surface coating include storage
tanks, wet section operations, coating mixing/thinning operations, quenching, parts and equipment
cleaning, and wastewater operations. Few of the surveyed facilities reported controlled HAP
emissions from these sources, though some facilities reported the use of work practices that are
not attributed with a numerical level of control to limit HAP emissions. For facilities that
reported control of HAP emissions from these sources, the data were not sufficiently detailed to
determine if the reported control represented the facility level of control or the control for one
unit operation of this type out of several in the facility. For example, mixing may be performed in
a mix room and at the application station. It was not clear from the responses if a facility
reporting mixing in a permanent total enclosure vented to a control device conducted all mixing at
this level of control or possibly just the mixing at the coating application station. The limited data
available from the metal coil surface coating survey for these operations is inadequate to
determine floor levels of control.
The information concerning the level of HAP emissions from coating application and
curing collected in the metal coil surface coating MACT survey included the capture efficiency for
each coating application area or for the entire coating line and the destruction efficiency of the
control device receiving the HAP emissions. The OCE for the coating line application and curing
could be calculated from this information. Because this information was the value that was most
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common among all the data available, and because it was determined that the coating application
and curing OCE was the value that was most correlated with HAP emissions, coating application
and curing OCE was used as the basis for the MACT floor calculations for coating lines. The
application and curing OCE for the facilities in the MACT floor was calculated_as a facility-wide
average, to incorporate the effects of averaging across coating lines in facilities with more than
one coating line.
5.3.2 Consideration of Data Quality in Evaluating HAP Emission Reductions from Metal
Coil Surface Coating HAP Sources
There are a number of data quality issues that were considered in determining the MACT
floor for the metal coil surface coating industry. These issues raised questions concerning the
representativeness of the data in terms of what OCE the facilities can achieve in daily operations
and over the entire year versus what facilities report; the quality of the metal coil surface coating
capture efficiency data; and the practical limitations of coating line capture systems.
5.3.2.1 Representativeness of the Control Device Performance Data in the Metal Coil
Surface Coating MACT Database.
The metal coil surface coating industry has noted that reported destruction efficiencies can
differ from those actually achieved in daily operation. The industry reports that efficiencies
determined by testing are generally measured during the initial compliance test, when the control
device is new 3. Destruction efficiency will gradually degrade with age (e.g., because of leaking
heat exchangers or leaking isolation valves), so that the reported destruction efficiency may not be
representative of the efficiency actually being achieved by control devices that have been in
operation several years. Furthermore the industry notes that when a facility reports an efficiency
based on testing, it is usually based on test methods that call for averaging the results of three
source tests of the inlet and outlet emissions from the control device. These tests are generally
relatively short in duration (approximately one hour). Depending on the conditions of operation
during these tests, e.g., inlet HAP loading to the control device, the control efficiency data
acquired from the metal coil surface coating industry may not be representative of control device
performance over the entire range of normal facility operation and over longer time periods.
An important operating parameter at metal coil surface coating facilities that can cause
control device test results to differ from control device performance during normal operation is
5-9
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the variation in loading rates. It is possible that during compliance tests, the inlet HAP loading
(i.e., the amount of HAP volatilized from the metal coil surface and exhausted to the control
device) is much higher than it is during normal operations. This situation may result in artificially
high destruction efficiency rates achieved during testing. For example, thermal oxidizers typically
achieve high levels of control, such as the greater than 99 percent destruction efficiencies reported
by some facilities in the MACT database, when their inlet loadings are high. Therefore, it is
possible that differences in reported destruction efficiencies in the metal coil coating database may
only be a result of variation in test conditions. The wide range of inlet loadings (from less than
100 ppmv to 14,000 ppmv) reported by metal coil surface coating facilities and the range of inlet
loadings reported by individual facilities (as much as 3000 ppmv difference between minimum and
maximum loadings) indicate that inlet loadings do fluctuate because of the batch nature of the
coating process (i.e., different products with different coating specifications are often produced
on the same line throughout the day). Therefore, inlet loadings will likely often be lower than the
inlet loading when the facility undergoes source testing for compliance purposes.
As a step in the data validation process, available literature was reviewed and thermal
oxidizer vendors were contacted to determine maximum destruction efficiencies that could be
expected for thermal oxidizers 4. The literature review on thermal oxidizers indicated that 99
percent destruction efficiency is achievable under ideal conditions, but that lower efficiencies are
typically achieved under normal operating conditions. For example, the alternation between beds
in a regenerative thermal oxidizer typically results in somewhat lower destruction efficiencies than
are achieved in a conventional recuperative thermal incinerator, generally below 99 percent5. The
lower destruction efficiency for regenerative thermal incinerators has been attributed in part to
valve leaks within the system.
Telephone surveys of thermal oxidizer manufacturers indicated that 98 percent is the
routine guarantee for regenerative or recuperative thermal oxidizers. Typically, this guarantee
only covers the first year of operation due to potential destruction efficiency degradation caused
by operational factors6. Vendors confirmed that long-term performance likely degrades because
of leakage problems. Typically, vendors reported that untreated gas leaks into the treated gas
stream through deterioration of heat exchange systems or leakage through isolation valves used
on multiple chamber regenerative units. In addition, a study conducted by EPA 7 concluded that
5-10
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98 percent VOC reduction, or 20 ppmv by compound exit concentration is the highest control
level achievable by all new incinerators, even though individual units may achieve higher
efficiencies. This level is expressed as both percent reduction and ppmw to account for the
leveling off of exit concentrations as inlet concentrations drop below 2000 ppmw.
Because of the practical limitations of the metal coil surface coating survey and other
industry research, information on the specific test conditions for the control efficiency data
collected was not available. For this reason and the various factors described above, the
determination of the MACT floor for metal coil surface coating took into account the likelihood
that the metal coil surface coating survey responses included only "best case" data, which do not
reflect degradation in performance over time or normal variations in coil coating operations over
extended time periods.
5.3.2.2 Quality of Metal Coil Surface Coating Capture Efficiency Data.
Because of the high capture efficiencies reported in the metal coil coating MACT
database, a data validation effort was undertaken to determine the basis of the high capture
efficiency claims 8. The focus of the data validation was to ascertain whether the appropriate EPA
reference test methods had been used to verify the reported capture efficiencies. The MACT
database included 33 lines operating with permanent total enclosures (PTE) without indication
that the enclosure had been properly verified using EPA Method 204 or Procedure T. The
MACT database also included 17 lines operating without a PTE and reporting capture efficiency
above 95 percent, but did not indicate that the capture efficiency for these lines had been
measured in accordance with the latest EPA guidance. A telephone survey9 of each of the above-
referenced lines was conducted to verify the basis for the reported capture efficiency. The results
of the data validation can be summarized as follows:
Of the 33 lines reported to be operating with PTEs, 20 lines had been properly verified as
PTEs using either Method 204 or Procedure T. The remaining 13 lines had not been
formally tested against the Method 204 criteria.
Of the 17 lines operating without a PTE, but reporting 95 percent or higher capture
efficiency, 8 had not run a capture efficiency test and were relying on an engineering
assessment to estimate capture efficiency. Three of the 17 lines were tested by a mass
balance procedure that involved using Method 24 to determine coating volatile matter
5-11
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content and Method 25 to measure VOC emissions and that did not meet EPA precision
or test method criteria. The remaining 6 lines conducted an appropriate test (typically a
temporary total enclosure procedure).
5.3.3 MACT Floor Determination
For this analysis, EPA determined that all of the 89 facilities in the metal coil surface
coating MACT data base were major or synthetic minor facilities with coating lines. Therefore,
this set of 89 facilities was used to identify the top performing 12 percent of facilities for coating
line control.
5.3.3.1 Floor for Overall Control Efficiency.
The coating line overall control efficiency (OCE) was calculated for all of the facilities
with sufficient information in the data base as a facility-wide average, i.e., as an average of all of
the coating lines at a facility (that accounts for the effect of averaging across coating lines.) The
calculation procedure consisted of calculating an arithmetic average facility capture efficiency
(arithmetic average for all application stations or lines, depending on the reported data), an
arithmetic average facility destruction efficiency (arithmetic average for all application stations or
lines, depending on reported data), and an average facility OCE (product of average facility
capture efficiency and average facility destruction efficiency.) Table 5-6 presents the average
facility OCE for all facilities in the MACT database with sufficient non-CBI information to
calculate the average facility OCE. For facilities listed in the table without an average facility
OCE, the reason the OCE was not calculated (no controls, information not available, or CBI) is
noted.
As has been described previously, some facilities reported OCE's that could not be
substantiated based on the data provided supporting reported capture efficiency. Facilities with
unsubstantiated OCE's were not used in the MACT floor determination. Removing facilities with
unsubstantiated OCE's from the MACT floor facilities resulted in the removal of six facilities,
which were replaced with the next best performing facilities with OCE's substantiated by Method
204 or Procedure T verification of capture efficiency. The resulting top performing 12 percent of
the facilities are the 11 facilities identified in Table 5-6 as MACT-floor facilities.
5-12
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Table 5-6. Metal Coil Surface Coating Average Facility OCE
Facility
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
:14
15
16
17
18
19
20
21
22
23
24
25
26
OCE"
(%)
99.97
99.96
99.8
99.7
99.7
99.6
99.6
99.6
99.5
?,9.3
99.1
99.0
98.97
98.8
£8.5
98.5
£8.2
98.0
98.0
98.0
97.8
97.7
97.2
97.0
97.0
97.0
Capture (%) c
ioo.o
100.0
100.0
100.0
100.0
99.8
700.0
100.0
700.0
ioo.o
99.4
100,0
99.0
|9.0
'99.0
99.4
foo.o
100.0
100.0
700.0
100.0
99.0
99.0
99.0
99.0
99.0
Control Device
(%)c ,
$9.97
99,96
R9.8
99.7
99.7
99.8
99.6
99.6
99.5
&3
99.7
99.0
99.97
l§-8
IV-5
99.1
|8.2
98.0
98.0
97.98
97.8
98.7
98.2
98.0
98.0
98.0
5-13
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Table 5-6. (Continued)
Facility
No.
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
OCEb
(%)
97.0
96.9
96.8
96.4
96.0
96.0
95.9
95.8
95.7
95.0
94.9
94.4
94.2
94.2
93.8
93.4
93.1
93.0
92.8
92.6
92.6
92.2
91.4
91.2
91.0
90.3
90.2
Capture (%) c
97.5
97.6
99.9
97.2
100.0
99.99
97.4
97.9
100.0
100.0
99.9
94.5
97.5
94.2
100.0
97.6
96.0
100.0
94.3
97.5
95.0
93.2
95.2
97.0
100.0
95.0
92.0
Control Device
(%)c
99.5
99.3
96.9
99.2
96.0
96.0
98.5
97.9
95.7
95.0
95.0
99.9
96.7
99.99
93.8
95.7
96.97
93.0
98.4
95.0
97.5
98.9
96.0
94.0
91.0
95.0
98.0
5-14
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Table 5-6. (Continued)
Facility
No.
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
OCEb
(%)
90.1
89.3
88.7
88.2
85.97
85.7
85.4
83.3
83.3
82.8
82.8
81.8
79.8
79.6
73.6
66.6
NC"
NC
NAe
NC
NC
NC
NC
NC
NC
NA
CBIf
Capture (%) c
95.0
94.0
90.0
98.0
86.4
95.2
88.0
90.0
90.0
92.0
90.0
87.0
95.0
94.0
92.0
100.0
NC
NC
95.7
NC
NC
90.0
NC
90.0
NC
NA
CBI
Control Device
(%r .
94.8
95.0
98.5
90.0
99.5
90.0
97.0
92.5
92.5
90.0
92.0
94.0
84.0
84.7
80.0
66.6
NC
NC
NA
NC
NC
NC
NC
NC
NC
91.4
CBI
5-15
-------
Table 5-6. (Continued)
Facility
No.
81
82
83
84
85
86
87
88
89
OCEb
(%)
NA
NA
CBI
CBI
CBI
CBI
CBI
CBI
CBI
Capture (%) c
NA
NA
CBI
CBI
CBI
CBI
CBI
CBI
CBI
Control Device
(%)c ,
NA
99.5
CBI
CBI
CBI
CBI
CBI
CBI
CBI
* Includes average facility OCE for all facilities in the MACT database with sufficient non-CBI information to
calculate average facility OCE.
b Product of average facility capture and control efficiencies as calculated from data reported by facility.
c Arithmetic average of data reported by facility if different efficienc es reported for different application
stations or lines.
d NC = No Control
' NA = Not Applicable
1 CBI = Confidential Business Information
NOTE: Capture efficiencies in italics were unsubstantiated by the data provided. The 11 MACT floor facilities
are highlighted.
5-16
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Table 5-7 presents a summary of the products in which the coil coated by the MACT-floor
facilities is used. As shown in Table 5-7, the MACT floor facilities represent a number of industry
segments, including, but not limited to; building products, automotive products, office furniture,
beverage lids and appliances.
All of the top 12 percent MACT floor facilities use thermal oxidizers and 8 of the facilities
are achieving 100 percent capture of application station emissions through the use of
permanent total enclosures. Table 5-6 shows that the range of reported OCE for the top 12
percent was 98.2 to 99.97 percent. The reported metal coil surface coating values show that
controls on some specific coating operations may be capable of achieving greater than 99 percent
HAP destruction based on 100 percent capture and destruction efficiency greater than 99 percent.
The average OCE of the MACT floor facilities is 99.4 percent. However, to determine the level
of emission control achievable with this technology, it is important to consider not only the level
of control reported, but also the previously cited data quality concerns as well as the control
Table 5-7. MACT Floor Facility Products
Facility No.
1
2
3
4
5
6
8
10
14
15
17
Products Reported in ICR Response
Metal building products
Beverage lids
CBI
Ceiling grids
Soffit, flashing, rain carrying products
Coil coated products
Automotive products - body panels and computer chasses
Galvanized steel and aluminum strip
Auto ride control components, entry & garage doors, appliances and office
furniture
Light fixtures, office furniture components, can lids, rainware, closet hardware,
roll up panel doors, metal building components, T-bar ceiling systems
Lawn sheds
5-17
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levels that EPA has generally found to be achievable for this type of control technology. This
approach ensures that factors that affect control levels, such as variations in source operative
conditions and inlet loadings to the control device are accommodated in the selection of the
MACT floor.
Because of the previously cited data quality concerns, a 98 percent facility-wide coating
line OCE was determined to be the MACT floor for existing sources. This OCE represents the
use of permanent total enclosure to achieve 100 percent capture of application station HAP
emissions and a thermal oxidizer to achieve a destruction efficiency of 98 percent. Previously
cited information from literature sources and vendors supports the determination of a destruction
efficiency of 98 percent for thermal incinerators. An OCE of 98 percent is attainable by all of the
facilities in the MACT floor considering the available information regarding the capture and
control technologies currently used at existing sources in the metal coil surface coating industry.
A 98 percent facility-wide coating line OCE also was determined to be the MACT floor
for new sources in the metal coil surface coating industry. No technology was identified that
could achieve a better OCE than the use of permanent total enclosure to capture emissions from
coating application stations and a thermal oxidizer to destroy HAP emissions from application and
the curing oven.
5.3.3.2 Floor for Emission Rate.
The EPA recognizes that some facilities may choose to limit their coating line HAP
emissions either through a combination of low-HAP coatings and add-on controls or through the
use of waterborne coatings that are pollution preventing. For example, the facilities in the metal
coil surface coating MACT survey reporting zero OCE also reported using waterborne coatings.
To allow for these situations, data from the metal coil surface coating MACT database were used
to calculate an alternative facility emission rate limit. The facility HAP emission rate was
calculated based on applying the 98 percent MACT floor OCE to a pre-controlled facility HAP
emission rate representative for this industry. The rationale for this is that the facility HAP
emission rate should not be more stringent than the controlled HAP emission rate that can be
attained by a metal coil coating facility using a representative coating formulation and applying
MACT floor control.
The calculation procedure consisted of defining a representative coating for this industry
5-18
-------
by calculating the average volume solids coating content for all of the facilities in the MA.CT
database with sufficient coating information and assuming that HAP constitutes the remainder of
the coating. As shown in Table 5-8, the average volume solids is 43.5 percent, which when
rounded to 40 percent yielded a coating with 40 percent by volume solids and 60 percent by
volume HAP. The pre-controlled facility HAP emission rate was calculated as 12.11 pounds of
HAP emitted per gallon of solids applied using glycol ethers as the coating HAP for the purpose
of the conversion of HAP from volume to mass. Glycol ethers were chosen as the HAP for the
coating solvent because glycol ethers may be constituents in solvent-borne or waterborne coatings
and represent the second largest quantity of HAP emitted, accounting for 23 percent of the
nationwide HAP emissions from the coil coating industry. The pre-controlled facility emission
rate was then factored by the 98 percent facility OCE MACT floor to derive the equivalent facility
HAP emission rate limit of 0.24 pounds of HAP emitted per gallon of solids applied.
5-19
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Table 5-8. Metal Coil Surface Coating Facility Average Volume Solids Coating Content'
Facility
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Facility Average Coating Solids
by Volume b
(%)
76.4
63.0
62.8
61.9
58.3
58.3
55.5
55.0
53.0 '
52.0
52.0
51.0
50.4
50.0
50.0
50.0
50.0
50.0
49.4
49.4
48.9
48.7
48.0
47.7
47.5
47.0
5-20
-------
Table 5-8. (Continued)
Facility
Number
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
Facility Average Coating Solids
by Volume b
(%)
46.7
46.5
46.4
46.3
46.0
46.0
46.0
46.0
46.0
45.9
45.0
45.0
45.0
44.8
44.7
44.4
44.4
42.0
41.6
41.4
41.3
41.0
40.0
40.0
39.8
38.1
38.0
5-21
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Table 5-8. (Continued)
Facility
Number
54
55
56
57
58
59
60
61
62
63
64
65
66
Facility Average Coating Solids
by Volume b
(%)
38.0
37.0
36.7
33.7
31.9
30.0
22.8
22.1
18.4
18.0
10.5
8.7
1.0
Average Volume Percent Solids = 43.5
Emission Rate @ 98% OCE =
0.24 Ib HAP Emitted/Gallon Solids Applied
a Lists all facilities in the MACT database with sufficient non-CBI information to calculate average facility
volume solids coating content.
b Calculated by dividing total gallons of solids applied by total gallons of coatings applied as reported by facility
for 1997 multiplied by 100.
5-22
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5.4 REFERENCES
1. U.S. Environmental Protection Agency. Metal Coil Surface Coatings MACT Docket
Number A-97-47 Item Numbers II-D-1 through II-D-113. ICR Responses. Office of Air
Quality Planning and Standards. Research Triangle Park, NC. Responses received
September 1998-April 1999.
2. Memorandum from Rhea Jones, EPA/OAQPS/ESD/CCPG to Metal Coil Surface Coating
Docket. July 29, 1999. Revised draft metal coil surface coating model plants.
3. Environmental Resources Management. Metal Coil Surface Coating ICR Data Analysis
and MACT Floor Proposals. St Charles, Missouri. June 2, 1999. p. 9.
4. Reference 3.
5. USEPA. Survey of Control Technologies for Low Concentration Organic Vapor Gas
Streams. USEPA, Office of Air Quality Planning and Standards. May 1995. p. 28.
6. Reference 3, p. 10.
7. Memorandum (and attachments) from Farmer, J. R., U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina, to distribution. August 22, 1980.
Thermal incinerator and flare removal efficiency.
8. Reference 3, p. 8.
9. Reference 8.
5-23
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6.0 ENVIRONMENTAL AND ENERGY IMPACTS
6.1 INTRODUCTION
Model plants and the criteria used to choose them have been described in Chapter 5.
Compliance options have also been described in Chapter 5. The assignment of model plants to
facilities in the MACT database for the purpose of estimating impacts is described in Section 7.3
of Chapter 7. This chapter describes the estimated nationwide environmental and energy impacts
of applying the compliance options to the model plants.
6.2 ENERGY IMPACT
Energy requirements for implementation of the compliance options for metal coil surface
coating plants include electricity to collect and treat ventilation air, electricity for lighting
permanent total enclosures, and natural gas to provide supplemental fuel needed for stable
operation of oxidizers. Energy use has been estimated for operating a baseline thermal oxidizer
system on Model Plant 1, for operating a condenser system on Model Plant 5, and for operating
coating rooms (permanent total enclosures) on application stations for Model Plants 1 through 4.
Incremental energy use has been estimated for operating upgraded (existing and replacement)
oxidizers for Model Plants 1 through 4.
Table 6-1 provides a summary of the increased model plant and nationwide energy
requirements associated with implementation of the compliance options. It should be noted that
some models show no change from oxidizer baseline to upgrade or replacement. For example, for
the upgraded oxidizers, electricity usage doesn't change because the air flow doesn't change.
6- 1
-------
Table 6-1 Summary of Metal Coil Surface Coating Model and Nationwide Energy Impacts
Model
Baseline
Model 2, thermal, one oven
Upgrade of Baseline Unit
Model 1 , catalytic, one oven
Model 2, thermal, one oven
Model 3, catalytic, one oven
Replacement of Baseline Unit
Model 1 , thermal, one oven
Model 1 , catalytic, one oven
Model 2, thermal, one oven
Model 2, thermal, two ovens
Model 2, catalytic, one oven
Model 3, thermal, one oven
Model 3, catalytic, one oven
Model 4, thermal, two ovens
Model 5, condenser
Operation of Coating Room
Small
Medium
Large
Nationwide Total for Model Plants
Nationwide Total for All Plants'
Number
of plants"
1
1
1
1
1
2
2
1
2
1
1
1
4
51
5
6
Model
incremental
energy usage,
kWh/v
54,398
0
22
0
31,617
31,487
31,885
15,942
31,680
66,277
66,101
46,637
2,287,708
11,200
12,250
12,600
Nationwide
incremental
energy usage,
kWh/v
54,398
0
22
0
31,617
62,974
63,770
15,942
63,361
66,277
66,101
46,637
9,150,832
571,200
61,250
75,600
10,329,981
14,575,603
Model
incremental
natural gas
usage, scf/v
—
69,627,016
44,262
0
7,642,229
0
-1,235,560
0
0
-609,860
0
1,181,496
0
0
0
0
0
Nationwide
incremental
natural gas usage,
scf/v
69,627,016
44,262
0
7,642,229
0
-2,471,120
0
0
-1,219,721
0
1,181,496
0
0
0
0
0
78,412,175
110,605,249
' Number of model plants assigned to the 64 facilities in the M ACT database with sufficient information to calculate the facility OCE and HAP
emission rate to estimate the incremental energy requirement of achieving the MACT floor compliance options.
b Nationwide totals for all plants in metal coil surface coating industry are based on the ratio of HAP emissions reported by plants that are
represented by model plants to the HAP emissions reported by all plants in the MACT database. The ratio is 1.411.
6-2
-------
For natural gas usage, supplemental gas may be required for flame stabilization, however, in some
cases the quantity of gas required for stable operation is the same for baseline as for upgrade or
replacement models. For some of the catalytic model plant replacements, gas usage decreases
because the heat recovery is changed to 70 percent from 50 percent.
6.3 AIR POLLUTION IMPACT
The major air pollution impact of implementing the compliance options is reduced
emissions of HAP to the atmosphere. The emission control systems used to reduce FLAP
emissions also reduce non-HAP volatile organic compound (VOC) emissions to the atmosphere.
Since the MACT database does not contain information on VOC emissions, the reduction of VOC
emissions cannot be quantified, however, the percent reduction should be similar to the percent
reduction in HAP emissions. There will also be minor impacts associated with the production and
use of electricity required for fans and for lighting in coating rooms. Electric utility generation
will result in small increases in sulfur dioxide and carbon dioxide emissions from fossil-fuel
powered generation plants.
The metal coil surface coating MACT database was used to estimate the reduction of
HAP emissions to the atmosphere resulting from implementing the compliance options. The
MACT database contains sufficient information from 64 facilities to calculate a facility OCE and
facility emission rate. Of this set of facilities with complete information, 10 facilities report being
permitted under Title V as synthetic minor or as non-major sources. Of the 54 major facilities,
based on adjusted facility OCE (see Section 5.3.2 of this document for a description of data
quality issues related to reported capture and destruction efficiencies and Reference 1 for a
description of adjustments to the capture and destruction efficiencies) and average facility
emission rates, 26 are in compliance with either the facility OCE or the emission rate limit. The
remaining 28 facilities will be required to take measures to reduce HAP emissions either through
coatings reformulation or improved emission control systems. Because more than 85 percent of
the facilities in the MACT database already have emission controls in place, the EPA assumes
facilities required to reduce HAP emissions will do so either by upgrading existing controls or by
installing controls if emissions are currently uncontrolled.
The EPA examined the average facility emission rate and the adjusted facility OCE for
each of the 28 facilities that would need to reduce HAP emissions to meet the standard and
6-3
-------
determined the least costly measure needed to reach compliance. For example if a facility
reported a 98 percent efficient thermal oxidizer but less than 100 percent capture efficiency, EPA
assumed the facility will need to install coating rooms on application stations to meet the 98
percent facility OCE. For each facility needing to reduce HAP emissions, -estimates were made of
the HAP emitted at the current facility OCE and of the HAP emitted after upgrade or installation
of the emission control system to attain one of the compliance options. Estimates of HAP emitted
at the current facility OCE were based on the total pounds of HAP applied in coatings as reported
by the facility for 1997 factored by the adjusted facility OCE. Estimates of the HAP emitted after
upgrade or installation of the emission control system were based on the total pounds of HAP
applied in coatings as reported by the facility for 1997 factored by the upgraded facility OCE to
comply with one of the MACT compliance options.
The 64 facilities in the metal coil surface coating MACT database which served as the
basis for the detailed impacts analysis emitted a total of 1761 tons of HAP in 1997. For the 28 of
these 64 facilities required to take measures to reduce HAP emissions, the total HAP emission
reduction was estimated to be 968 tons, or a percentage reduction of almost 55 percent. The
total nationwide HAP emissions reported by all 89 facilities in the database, including the 25
facilities for which insufficient information was available to determine if HAP emission reductions
would be needed to meet the standard, were 2484 tons of HAP in 1997. Applying the HAP
emission reduction of 55 percent for the 64 facilities with sufficient information to determine
emission reductions to the total nationwide HAP emissions reported in 1997 yields an estimated
total nationwide HAP emission reduction of approximately 1366 tons per year.
6.4 WATER IMPACTS
Nationwide water impacts resulting from implementation of the compliance options are
insignificant. Four facilities using waterbome coatings are each assumed to apply a condenser
system to comply with the emission rate limit. This will result in the generation of wastewater
streams that will require treatment to remove the HAP. However, if the facilities are able to
reduce HAP usage in coatings to comply with the emission rate limit, then there will be no
associated water impacts.
6-4
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6.5 SOLID WASTE IMPACTS
The impact of the compliance options on solid waste will be negligible. Facilities using
catalytic incinerators to comply with the emission rate limit or the facility OCE probably will be
required to install larger volumes of catalysts and to replace catalysts more frequently than current
replacement cycles to maintain high performance levels, resulting in a small increase in solid waste
generation.
6.6 REFERENCES
1. Environmental Resources Management. Metal Coil Surface Coating ICR Data Analysis
and MACT Floor Proposals. St Charles, Missouri. June 2, 1999. Table 5.
6-5
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7.0 COSTS
7.1 INTRODUCTION
Model plants and the criteria used to choose them have been described in Chapter 5.
Compliance options have also been described in Chapter 5. This chapter describes the estimated
costs of applying the compliance options to the model plants.
7.2 MODEL PLANT COMPLIANCE COSTS
Model plant specifications used in estimating compliance costs are summarized in Table 7-
1. All existing plants applying solvent-borne coatings have HAP emission control systems in
place. Therefore, for existing plants applying solvent-borne coatings as represented by Model
Plants 1 through 4, compliance is based on upgrading or replacing HAP emission controls.
Emission control systems needed to comply include coating rooms (permanent total enclosures)
to capture fugitive HAP emissions from coating application stations and oxidizers with 98 percent
destruction efficiency.
Some existing plants applying waterborne coatings that currently operate without HAP
emission control systems will need either to reformulate coatings or to add emission control
systems to comply with either the emission rate limit or the compliant coating limit. Model Plant
5 represents a facility applying waterborne coatings. To estimate compliance costs, it is assumed
that a plant applying waterborne coatings that are not compliant will install a condenser system to
meet the emission rate limit. All but one facility in the MACT database that reports using only
waterborne coatings will need much less than a 90 percent overall control efficiency to comply
with the emission rate limit. Because of the relatively low overall control efficiency required and
the low organic solvent concentrations in the oven exhausts, a condenser was chosen as the HAP
emission control device to apply to the waterborne coatings model plant.
7-1
-------
Table 7-1. Model Plant Specifications Used for Compliance Costing
Model Plant
1
Annual operating time (hr)
Annual coating time " (hr)
Solids applied annually (gal)
Coating formulation b :
Weight percent HAP
Weight percent solids
Ovens c :
Number
Maximum solvent
concentration (% LEL)
Solvent capacity (gal/hr)
Air flow (ACFM)
Exhaust temperature (°F)
4270
2990
13,700
35
41
1
25
56
9333
410
5300
3710
79,500
40
35
1
25
51
8500
515
7700
5390
129,000
41
49
2
25
88
14,700
710
7700
5390
293,000
13
59
2
25
98
16,300
470
2660
1860
40,300
3.5
49
1
NA
1.4 d
6650
295
NA = Not applicable, HAP = hazardous air pollutant, LEL = lower explosive limit.
a Annual coating time is estimated to be 70 percent of annual operating hours.
b Model plants 1 through 4 are applying solvent-borne coating; model plant 5 is applying
waterborne coating.
c Parameters are given on a per oven basis.
d Also 14 gallons of water per hour.
7-2
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7.2.1 Permanent Total Enclosure Costs
Table 7-2 presents a summary of permanent total enclosure (PTE) costs. As shown in
Table 7-2, PTEs are costed in three sizes: 8,000 ft3; 13,000 ft3; and 18,000 ft3. Floor areas for the
three enclosures are taken as 800 ft2, 875 ft2, and 900 ft2, respectively, based on typical coating
application station sizes for the model plants. To estimate compliance costs for a coating line
needing to upgrade capture efficiency, the costs of a small PTE are applied to Model Plants 1 and
2, the costs of a medium PTE to Model Plant 3, and the costs of a large PTE to Model Plant 4.
Facilities represented by Model Plant 5 will not need to upgrade capture efficiency to comply with
the emission rate limit.
Each PTE is assumed to have two swing doors and four windows. Costing on a square-
foot basis plus doors and windows, is taken from Reference 1. The structure is assumed to be
constructed of steel. Auxiliary costs that contribute to the purchased equipment cost (PEC) are
assumed to add 50 percent to the purchase price. Total capital investment (TCI) is taken as 1.6
times the PEC. Annual costs are charged for maintenance ($6^ y) and electricity for lighting (14
kWh/ft2 y). Indirect annual costs are based on typical values in the OAQPS Control Cost Manual
2 (Manual), i.e., 60 percent labor and materials overhead, other indirect costs of 4 percent of TCI,
and capital recovery based on 7 percent interest and a 15-year life for the enclosure.
In estimating the costs of a PTE, it has been assumed that existing process exhaust airflow
will be adequate to satisfy the EPA Method 204 criteria and to provide for worker safety and
comfort. This assumption is based on experience cited by several engineering contractors 3'4'5 that
install PTEs. For example, Pacific Environmental Services reported that of more than 100 PTE
designs completed, none has required an increase in the size of the air pollution control device in
order to maintain worker comfort.
7-3
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Table 7-2. Summary of Coating Room Costs
Model
Floor area, ft2
Cost/ft2, $
Cost, $
Swing doors (2), $
Windows (4), $
Sum, $
Auxiliaries (at 50 %), $
Purchased equipment cost (PEC), $
Total capital investment (TCI, 1 .6 x PEC), $
Maintenance (6$/ft2 y), $/y
Maintenance supervision (15 % of maintenance), $/y
Materials (50 % of maintenance labor), $/y
Electricity (lighting, 14 kWh/ft2 y and $.06/kWh), $/y
Direct costs, $/y
Labor/materials overhead (60 % of labor and materials), $/y
Other indirect costs (4 % of TCI), $/y
Capital recovery (7 % interest rate, 15-year life), $/y
Indirect costs, $/y
Total annual costs, TAG, $/y
Small (8,000 ff)
800
15
12,000
5,000
800
17,800
8,900
26,700
42,720
4,800
720
2,400
672
8,592
4,752
1,709
4,691
11,151
19,743
Medium (1 3,000 ff)
875
18
.J5.313
5,000
800
21,113
10,556
31,669
50,670
5,250
788
2,625
735
9,398
5,198
2,027
5,564
12,788
22,186
Large (1 8,000 ff)
900
20
18,000
5,000
800
23,800
11,900
35,700
57,120
5,400
810
2,700
756
9,666
5,346
2,285
6,272
13,903
23,569
Note: Costs for enclosure, doors, and windows based on cost factors presented in Reference 1.
7-4
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7.2.2 Oxidizer Costs
For each model plant representing a coating line that applies solvent-borne coatings, costs
are estimated for upgrading an existing thermal or catalytic oxidizer and for replacing an existing
thermal or catalytic oxidizer. Most of the facilities in the MACT database 4hat will need to reduce
HAP emissions to comply with the standard will need to replace existing oxidizers within the next
4 years as the oxidizers reach the end of their useful life. Table 7-3 presents a summary of the
oxidizer upgrade costs; Table 7-4 presents a summary of the oxidizer replacement costs. The
costs are estimated based on the Manual. Costs estimated from the Manual are expected to be
within about 30 percent of the cost a buyer might pay for the equipment being costed. However,
much larger deviations can be found if the input parameters for the model differ from values found
in practice.
To estimate incremental costs of upgrading or replacing existing HAP emission controls,
costs of baseline controls are subtracted from the costs of upgraded or replacement units. Costs
are estimated and are summarized in Tables 7-3 and 7-4 in three areas: TCI, total annual cost
(TAC), and operation and maintenance costs (O&M). The TCI includes purchased equipment
costs (incinerator and auxiliary equipment, instrumentation, sales tax, and freight), direct
installation costs (foundation and supports, handling and erection, electrical, piping, insulation for
duct work, and painting where not included in auxiliary costs), and indirect installation costs
(engineering, construction or field expenses, contractor fees, start-up, performance test, and
contingencies). The TAC includes indirect annual costs (overhead, administrative charges,
property taxes, insurance, and capital recovery) and direct annual costs (O&M). The O&M costs
are made up of electricity, natural gas, operating labor, and maintenance labor and materials.
The Manual is designed so that the user supplies information for a variety of model
parameters. For oxidizers, some of these parameters are gas flow rate, gas temperatures at the
inlet and outlet, HAP concentration, heats of combustion and heat capacities for the HAPs, and
amount of heat recovery for oxidizers so equipped. Some of the model parameters come directly
from the model plants, e.g., values for gas flow, temperature, annual hours of operation, and
quantity of solvent are consistent with each of the model plants. For other model parameters,
assumptions are required, as are explained in the following paragraphs.
7-5
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Table 7-3 Summary of Oxidizer Upgrade Costs for
Coil Coating Solvent-Borne Model Plants
Model
Baseline
Model 1 , one oven
Model 1 , two ovens
Model 1 , catalytic, one oven
Model 1 , catalytic, two ovens
Model 2, one oven
Model 2, two ovens
Model 2, catalytic, one oven
Model 2, catalytic, two ovens
Model 3, one oven
Model 3, two ovens
Model 3, catalytic, one oven
Model 3, catalytic, two ovens
Model 4, 1 oven
Model 4, 2 ovens
Total capital
investment, $
372,049
562,893
373,400
456,389
352,970
534,186
331,943
405,987
386,379
584,747
405,690
496,184
420,902
636,994
Total
annual cost,
$/v
336,574
387,908
143,713
191,486
340,994
396,197
136,371
187,478
640,456
704,445
186,176
253,549
866,022
927,808
O&M cost,
$/v
271,981
286,445
66,799
81,448
277,123
295,450
63,987
82,315
566,600
593,227
96,974
123,601
786,995
813,622
Capital cost
above baseline,
$
--
Annual cost
above
baseline, $/v
.
O&M cost
above baseline,
$/v
Assumptions: Baseline units are thermal oxidizers operating at 1,350F or catalytic oxidizers operating at 1,000T.
Efficiency is 95 percent (thermal) or 94 percent (catalytic). Heat recovery is 50 % and retrofit factor is 1.2.
Upgrade of Baseline Unit
Model l,one oven
Model 1 , two ovens
Model 1 , catalytic, one oven
Model 1 , catalytic, two ovens
Model 2, one oven
Model 2, two ovens
Model 2, catalytic, one oven
Model 2, catalytic, two ovens
Model 3, one oven
Model 3, two ovens
Model 3, catalytic, one oven
Model 3, catalytic, two ovens
Model 4, one oven
Model 4, two ovens
434,716
657,900
436,268
533,583
412,481
624,250
387,831
474,342
451,291
682,986
473,995
579,726
491,726
744,180
365,369
441,446
187,975
258,511
373,995
457,760
184,254
261,995
685,172
788,592
261,521
366,227
911,646
1,013,429
284,118
311,002
92,331
119,215
292,185
325,553
92,507
125,875
588,482
636,960
146,885
195,363
808,898
857,376
62,667
95,007
62,868
77,194
59,511
90,064
55,888
68,355
64,913
98,239
68,305
83,541
70,825
107,186
28,795
53,538
44,262
67,025
33,001
61,563
47,883
74,516
44,717
84,148
75,345
112,678
45,624
85,621
12,137
24,557
25,533
37,766
15,062
30,102
28,520
43,561
21,882
43,733
49,911
71,762
21,904
43,755
Assumptions. Units operate at 1,600°F (thermal) or 1,200 °F (catalytic), have 50 % heat recovery and have a retrofit factor of 1.4
Efficiency is 98 percent for all oxidizers, which requires 1.5 x operating labor cost and double the maintenance ot existing units.
Baseline and Upgrade Assumptions' Costs exclude ductwork, dampers, fan, motor, and stack.
Two oxidizers purchased at the same time receive a 20 percent discount; annual cost is reduced by 5 percent.
All costs are in 1997$.
7-6
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Table 7-4 Summary of Oxidizer Replacement Costs for
Coil Coating Solvent-Borne Model Plants
Model
Baseline
Model 1 , one oven
Model 1 , two ovens
Model 1, catalytic, one oven
Model 1 , catalytic, two ovens
Model 2, one oven
Model 2, two ovens
Model 2, catalytic, one oven
Model 2, catalytic, two ovens
Model 3, one oven
Model 3, two ovens
Model 3, catalytic, one oven
Model 3, catalytic, two ovens
Model 4, 1 oven
Model 4. 2 ovens
Total capital
investment $
372,049
562,893
373,400
456,389
352,970
534,186
331,943
405,987
386,379
584,747
405,690
496,184
420,902
636.994
Total annual
COSt. $/Y
336,574
387,908
143,713
191,486
340,994
396,197
136,371
187,478
640,456
704,445
186,176
253,549
866,022
927.808
O&M cost,
$/v
271,981
286,445
66,799
81,448
277,123
295,450
63,987
82,315
566,600
593,227
96,974
123,601
786,995
813.622
Capital cost
above baseline,
$
Annual cost
above
baseline, $/v
O&M cost above
baseline $/v
Assumptions: Baseline units are thermal oxidizers operating at 1,350F or catalytic oxidizers operating at 1 ,000T.
Efficiency is 95 percent (thermal) or 94 percent (catalytic). Heat recovery is 50 % and retrofit factor is 1.2.
Replacement of Baseline Unit
Model 1, one oven
Model 1 , two ovens
Model 1 , catalytic, one oven
Model 1 , catalytic, two ovens
Model 2, one oven
Model 2, two ovens
Model 2, catalytic, one oven
Model 2, catalytic, two ovens
Model 3, one oven
Model 3, two ovens
Model 3, catalytic, one oven
Model 3, catalytic, two ovens
Model 4, one oven
Model 4, two ovens
542,301
820,835
496,209
608,916
514,644
778,971
441,674
541,995
563,144
852,383
539,119
661,573
613,400
928,450
383,362
469,718
184,749
261,530
391,190
484,713
182,189
265,662
705,873
819,929
255,512
366,932
935,416
1,048,738
285,996
312,879
76,267
103,150
294,076
327,444
78,688
112,056
592,427
640,905
127,129
175,607
814,442
862,920
170,252
257,941
122,809
152,527
161,673
244,785
109,731
136,008
176,766
267,636
133,428
165,388
192,498
291,456
46,789
81,810
41,037
70,044
50,196
88,515
45,818
78,184
65,418
115,485
69,336
113,383
69,394
120,930
14,014
26,434
9,468
21,702
16,953
31,994
14,701
29,742
25,828
47,678
30,155
52,006
27,447
49,298
Assumptions: Units operate at 1,600°F (thermal) or 1,200°F (catalytic), have 70 % heat recovery and have a retrofit factor if 1.4.
Efficiency is 98 percent for all oxidizers, which requires 1.5 x operating labor cost and double the maintenance of existing units
Baseline and Replacement Assumptions: Costs exclude ductwork, dampers, fan, moter, and stack.
Two oxidizers purchased at the same time receive a 20 percent discount; annual cost is reduced by 5 percent.
All costs are in 1997$.
7-7
-------
Solvents assumed to be in the oxidizer inlet are approximately 60 percent methyl ethyl
ketone (MEK) and 40 percent ethylene glycol monoethyl ether (EGME). This allocation is based
on the nationwide distribution of HAP emissions from coil coating operations by HAP derived
from the ICR database which shows MEK accounted for 30 percent and glycol ethers for 23
percent of nationwide HAP emissions in 1997. Heats of combustion for the two compounds are
taken as 2,897 Btu/scf for MEK and 2,986 Btu/scf for EGME. Auxiliary fuel is assumed to be
natural gas with a heat of combustion of 21,502 Btu/lb.
For baseline model plants, oxidizer efficiency is assumed to be 95 percent for thermal units
and 94 percent for catalytic units. Outlet temperatures are assumed to be 1,350 °F and 1,000 °F
for the thermal and catalytic units, respectively. Heat recovery is assumed to be 50 percent.
Retrofit costs are assumed to add 20 percent to the TCI.
Costs for upgraded oxidizers are based on an efficiency of 98 percent for all units. Outlet
temperatures are assumed to be 1,600 °F and 1,200 °F for thermal and catalytic units,
respectively. Heat recovery is assumed to be 50 percent, consistent with the assumed heat
recovery for baseline units. Retrofit costs are assumed to add 40 percent to the TCI, and the need
for operating and maintaining the oxidizer system at constant high efficiency is assume to require
an additional 50 percent in operating and maintenance labor and maintenance materials.
Costs for replacement oxidizers are based on an efficiency of 98 percent for all units.
Outlet temperatures are assumed to be 1,600 °F and 1,200 °F for thermal and catalytic units,
respectively. Heat recovery is assumed to be 70 percent. Retrofit costs are assumed to add 40
percent to the TCI and the need for operating and maintaining the oxidizer system at constant
high efficiency is assumed to require an additional 50 percent in operating and maintenance labor
and maintenance materials.
For all cases representing the upgrade or replacement of an existing control system, costs
exclude ductwork, butterfly dampers, fans, motors, and stacks. One model (Model 2) needed to
represent the installation of a control system in a facility with no existing controls is costed with
these auxiliaries using Chapter 10 of the Manual for ductwork, dampers, and stack. Information
in Chapter 4.12 of the Handbook - Control Technologies for Hazardous Air Pollutants 6 is used
for costing fans and motors and also for sizing ductwork. Ductwork is assumed to be cold-rolled,
spiral-wound steel with three inches of insulation. For plants having two oxidizers, both are
7-8
-------
assumed to be purchased at the same time and at a discount of 20 percent. Labor costs are
derived from tables provided by the Bureau of Labor Statistics at its Internet website. All costs
are in 1997 dollars.
The Manual provides equipment sizing equations based on simplifying assumptions. The
equations can be altered if the underlying assumptions are changed. One such change is the
assumed system heat loss. Because the waste-gas streams entering the oxidizers are at relatively
high temperatures, heat losses are assumed to be from 35 to 55 percent, depending on inlet
temperature assigned to the model plant being costed. For cases in which the model predicts
auxiliary gas consumption to be less than five percent of total gas, additional auxiliary gas is
provided for flame stabilization.
7.2.3 Condenser Costs
To represent measures that a plant using waterborne coatings could take to comply with
the emission rate limit, a condenser is costed as the control device for Model Plant 5. Table 7-5
presents the estimated condenser costs. Information from Chapter 8 of the Manual7 is used to
develop the condenser costs. Assumptions include purchase of a packaged system installed with
25 feet of duct, ethylene glycol as the refrigerant and an efficiency of 62 percent based on EGME.
Auxiliaries are estimated as described above for Model Plant 2 for ductwork, dampers, fans, and
motors. A retrofit factor of 1.2 is assumed.
Table 7-5. Condenser Costs for Coil Coating Waterborne Model Plant
Costing for condenser system with auxiliaries
Total capital investment, TCI, $
Total annual cost, TAG, $/y
O&M cost. $/v
779,518
259,571
137.262
Assumptions: Packaged condenser system installed with 25 ft of duct, fan, motor, damper.
No credit taken for recovered materials. No precooler. Ethylene glycol/water refrigerant.
Efficiency of 62 percent based on ethylene glycol monoethyl ether. Retrofit factor of 1.2, 1997 dollars.
7-9
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7.3 NATIONWIDE COMPLIANCE COSTS
The metal coil surface coating MACT database contains sufficient information from 64
facilities to calculate a facility OCE and facility emission rate. Of this set of facilities with
complete information, 10 facilities report being permitted under Title V as synthetic minor or as
non-major sources. Of the 54 major facilities, based on adjusted facility OCE (see Section 5.3.2
of this document for a description of data quality issues related to reported capture and
destruction efficiencies and Reference 8 for a description of adjustments to the capture and
destruction efficiencies) and average facility emission rates reported for 1997, 26 are in
compliance with either the facility OCE or the emission rate limit. The remaining 28 facilities will
be required to take measures to reduce HAP emissions either through coatings reformulation or
improved emission control systems. Because more than 85 percent of the facilities in the MACT
database already have emission controls in place, the EPA assumes facilities required to reduce
HAP emissions to comply with one of the compliance options will do so either by upgrading
existing controls or by installing controls if emissions are currently uncontrolled. The EPA
examined the average facility emission rate and the adjusted facility OCE for each of the 28
facilities currently not attaining any one of the compliance options to determine the least costly
measure needed to reach compliance, e.g., a facility with a 98 percent efficient thermal oxidizer
but less than 100 percent capture efficiency will need to install coating rooms on application
stations to meet the 98 percent facility OCE. For a facility with an existing oxidizer needing
increased destruction efficiency to comply, two options for increasing destruction efficiency have
been costed, i.e., an oxidizer upgrade or an oxidizer replacement.
The cost that is assigned to a specific facility in the MACT database depends on the age of
the existing oxidizer to be upgraded. The EPA assumes the life of an oxidizer is 15 years,
therefore, an oxidizer for which increased destruction efficiency is needed and that will be greater
than 15 years old by the expected compliance date of 2004 is assumed to be replaced by a more
efficient oxidizer. If the oxidizer will be less that 15 years old, the existing oxidizer is assumed to
be upgraded. It should be noted that 75 percent of the oxidizers identified as being replaced will
be over 20 years old in 2004. In the case of an upgrade or a replacement, an incremental cost is
incurred as has been explained in Section 7.2.2 of this Chapter.
Five facilities that are currently using waterborne coatings to comply with State and
7-10
-------
Federal VOC emission limits but will need to reduce HAP emissions to comply with the MACT
standard will incur the cost of installing a complete emission control system. Because of the
relatively low emission rates of four of these facilities, they will be able to comply with the facility
emission rate limit without capturing fugitive emissions from the coating application station.
Table 7-6 presents a summary of metal coil surface coating model and nationwide
compliance costs. The nationwide compliance costs for model plants are calculated based on the
total number of small, medium and large coating rooms needed to upgrade capture efficiency, the
total number of oxidizer upgrades and replacements needed for each model plant assigned to
represent a facility, and the number of new emission control systems needed for facilities that are
currently uncontrolled. For the 28 facilities in the MACT database to which model plants are
assigned, the total capital investment is $8,255,683 and the total annual cost associated with the
emission control systems is $3,456,213 per year hi 1997 dollars. In addition, for all 89 facilities in
the MACT database, the estimated annual cost for monitoring, reporting, and recordkeeping
totals $1,019,039.
The 64 facilities in the metal coil surface coating MACT database which served as the
basis for the detailed emission control system cost calculations emitted a total of 1761 tons of
HAP in 1997. The total nationwide HAP emissions reported by all 89 facilities in the database
were 2484 tons of HAP in 1997. To estimate the total compliance costs for all metal coil surface
coating facilities, the emission control system costs for the facilities represented by the model
plants were factored by the ratio of HAP emissions reported by all facilities in the database to
HAP emissions reported by the facilities represented by model plants (i.e., 2484/1761 = 1.411)
and the estimated annual costs for monitoring, reporting, and recordkeeping were added to the
total annual costs associated with the emission control systems. Therefore, the estimated
nationwide total capital investment is $11,648,769 and the nationwide total annual cost is
$5,895,756 per year in 1997 dollars.
7-11
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Table 7-6 Summary of Metal Coil Surface Coating Model and
Nationwide Compliance Costs *
Model
Baseline
Model 2, thermal, one oven4 '
Upgrade of Baseline Unit
Model 1, catalytic, one oven
Model 2, thermal, one oven
Model 3, catalytic, one oven
Replacement of Baseline Unit
Model 1, thermal, one oven
Model 1 , catalytic, one oven
Model 2, thermal, one oven
Model 2, thermal, two ovens
Model 2, catalytic, one oven
Model 3, thermal, one oven
Model 3, catalytic, one oven
Model 4, thermal, two ovens
Model 5, condenser'
Installation of Coating Room
Small
Medium
Large
Total Cost for Model Plants
MRR costs '
Nationwide Total Cost for All Plants8
Number of
plants b
1
1
1
1
1
2
2
1
2
1
1
1
4
51
5
6
Model total
capital
investment1, $
367,024
62,868
59,511
68,305
170,252
122,809
161,673
244,785
109,731
176,766
133,428
291,456
779,518
42,720
50,670
57,120
Nationwide
total capital
investment, $
367,024
62,868
59,511
68,305
170,252
245,618
323,346
244,785
219,462
176,766
133,428
291,456
3,118,072
2,178,720
253,350
342,720
8,255,683
11,648,769
Model total
annual cost',
$/vr
-340,994 ,
44,262
33,001
75,345
46,789
41,037
50,196
88,515
45,818
65,418
69,336
120,930
259,571
19,743
22,186
23,569
Nationwide total
annual cost, $/vr
340,994
44,262
33,001
75,345
46,789
82,074
100,392
88,515
91,636
65,418
69,336
120,930
1,038,284
1,006,893
110,930
141,414
3,456,213
5,895,756
All costs are in 1997$.
Number of model plants assigned to the 64 facilities in the MACT database with sufficient information to calculate the facility OCE and HAP
emission rate to estimate the compliance cost of achieving the MACT floor compliance options.
From coating room costs in Table 7-2 and control device costs in Tables 7-3 through 7-5. Note that the upgrade and replacement costs represent
incremental costs above the costs of the baseline unit.
One facility reporting the use of waterbome coatings requires a 90 percent HAP emission reduction to meet the emission rate limit and
consequently was assigned a 95-percent efficient emission control system consisting of a 95-percent efficient thermal oxidizer and a coating room.
Model plant costs represent the costs of a new emission control system, including ductwork, butterfly dampers, fans, motors, and stacks.
For all 89 facilities in MACT database, includes initial one-time costs (acquiring and installing MRR systems, initial control system performance
tests, developing startup, shutdown, malfunction plan, initial notifications, performance test report) annualized over 15 years at 7 percent interest
and annual costs (compliance determinations, compliance reports and recordkeeping).
Nationwide totals for all plants in metal coil surface coating industry are based on factoring the total costs for model plants by the ratio of HAP
emissions reported by plants that are represented by model plants to the HAP emissions reported by all plants in the MACT database (the ratio is
1.411) and adding MRR costs to the nationwide total annual costs
7-12
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7.4 REFERENCES
1. Lukey, Michael E., P.E. Permanent Total Enclosures Needed in Response to Subpart KK
and Changes in Test Procedures. Paper No. 97-TA4B.05, presented at the Air and Waste
Management Association Annual Meeting & Exhibition. Toronto, Ontario, Canada. June
1997. Table 2. " - -
2. U. S. Environmental Protection Agency. OAQPS Control Cost Manual, Fourth Edition.
EPA-450/3-90-006. January 1990. Pages 3-1 thru 3-66.
3. Reference 1, page 3 of 4.
4. Turner, Thomas K. Local Capture or Total Enclosure? The Answer is Yes! Paper No.
94-RA111.01, presented at the Air and Waste Management Association Annual Meeting
& Exhibition. Cincinnati, OH. June 1994.
5. Bemi, Dan. "Demonstrating VOC Capture Efficiency Using Permanent Total Enclosure
Technology: Common Practices, Challenges and Rewards." Paper No. 97-TA4B.04,
presented at the Air and Waste Management Association Annual Meeting & Exhibition.
Toronto, Ontario, Canada. June 1997.
6. U.S. Environmental Protection Agency. Control Technologies for Hazardous Air
Pollutants. EPA/625/6-91/014. Office of Research and Development. Washington, DC.
June 1991. Pages 4-98 thru 4-101.
7. Reference 2, pages 8-1 thru 8-50.
8. Environmental Resources Management. Metal Coil Surface Coating ICR Data Analysis
and MACT Floor Proposals. St Charles, Missouri. June 2, 1999. Table 5.
9. Part A of the Supporting Statement for the Information Collection Request under the
Paperwork Reduction Act of 1995. Prepared by the US EPA for the OMB. April 2000.
Table 2C.
7-13
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8.0 ECONOMIC IMPACT ANALYSIS
8.1 INTRODUCTION
This chapter presents information from the economic impact analysis (EIA) developed by
the EPA's Innovative Strategies and Economics Group (ISEG) to support the evaluation of
impacts associated with regulatory options considered for this NESHAP.
The remainder of this report provides a summary profile of the metal coil coating industry
(Section 8.2), an overview of the economic impacts associated with this regulatory action
(Section 8.3), and a discussion of small business impacts (Section 8.4).
8.2 INDUSTRY PROFILE
8.2.1 Coatings
There are a wide variety of coatings applied to metal coils. These include polyesters,
acrylics, fluorocarbons, alkyds, vinyls, epoxies, pastisols, and organosols. The majority of the
coatings (85 percent) are organic solvent based and the remaining 15 percent are waterborne
type '. High-solid coatings currently have limited use because of applicability and availability of
suitable formulations. The six largest coatings suppliers are Akzo, Dexter, Lilly, Morton, PPG,
and Valspar; which combined provide 85 percent of coatings 2.
8.2.2 Costs of Production
The types of metal processed by the coil coating industry include cold-rolled steel,
galvanized steel, and aluminum '. For 1998, as shown in Table 8-1, Purchasing Online reported
spot prices for cold-rolled steel sheet at $420 per ton, HD galvanized steel sheet $590 per ton,
and aluminum common alloy sheet at $1.05 per pound. However, the price of steel has dropped
8-1
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significantly during the past year. For April 1999, Purchasing Online reported spot prices for
cold-rolled steel sheet at $360 per ton, HD galvanized steel sheet $410 per ton.
During 1997, as shown in Table 8-2, the coatings industry provided coil coating
companies with 39.2 million gallons of coating at a value of $611.7 million, or an average $15.60
per gallon. However, some specialty coatings sell for more than $50 per galloa2'3.
Table 8-1. Spot Prices for Steel and Aluminum Sheet: 1998-1999
Year
Cold-rolled steel sheet (Midwest, $/ton)
HD galvanized steel sheet (Midwest, $/ton)
Aluminum (common alloy sheet 3003, $/lb)
1999
$360
$410
$0.94
1998
$420
$590
$1.05
Source: Purchasing Online. 1999. "Hotlines."
Table 8-2. Volume and Value of Coatings Applied to Coat Metal Coils: 1996-1997
Year
1997
1996
Total/Average
Volume
(106 gallons)
39.2
30.0
69.2
Value
($106)
$611.7
$550.0
$1,161.7
Price
$/galIon
$15.60
$18.33
$16.79
Source: References 2 and 3.
8.2.3 Uses. Consumers, and Substitutes
One of the earliest applications for metal coil coatings was the in the production of
Venetian blinds 4. During the 1970's, environmental and work safety regulations led many
companies to explore prepainting applications and this generated interest in coil coating
applications in a variety of industries. Currently, coil coated products are used in building and
construction, business and consumer, transportation, package, and other goods. As shown in
Figure 8-1, building and construction products accounted for more than 60 percent of coil
consumption in 1997. Uses in this segment include residential siding, roofing, trim, gutters, metal
8-2
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doors, mobile homes, and modular housing. Business and consumer products (i.e., appliances and
furniture) accounted for 17.4 percent, followed by transportation (8.8 percent), packaging (4.9
percent), and other (9.3 percent).
Coil coating competes with other methods of producing finished coated sheet metal,
mostly post-fabrication methods such as spraying, dipping, and brushing. Currently, one coil
coating company estimates that roughly 10 percent of coated sheet metal is currently being coil
coated 5. All coated steel competes directly with wood products in building and construction
applications such as roofing. The relative price of lumber has risen over the past several years
making steel coated products more attractive 6.
Business
and
Consumer
17.4%
Building and
Construction
59 6%
Transportation
8.8%
Other
9.3%
Packaging
4.9%
13 billion square feet
Figure 8-1. Distribution of Coated Metal Coil Shipments by Market: 1997
8.2.4 Affected Producers
Based on non-CBI facility responses to the Section 114 letters 7, the Agency identified 49
companies that owned 82 potentially affected metal coil coating facilities. The following section
describes types of manufacturing facilities, identifies the companies that own them, and presents
recent trends in products and processes.
8-3
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8.2.4.1 Manufacturing Facilities.
Metal coil manufacturers can be classified as one of two types of producers: toll coaters
and captive coaters. Toll coaters process coils provided by steel or aluminum mills or their
customers, who in turn, fabricate the coated coil into end products. For example, Materials
Sciences Corporation has a tolling agreement with AK Steel Corporation whereby jt agrees to
provide coil coating services to its steel plants in Ohio 5. These coaters are providing a service
rather than fabricating an end product and charge a fee based on weight or surface area. Captive
producers' coating operations are part of a vertical operation that both coat and fabricate end
products. Some coil coaters perform both types of these functions.
Based on responses to the Section 114 letters, Table 8-3 provides a summary of the
descriptive statistics for coil coating facilities by producer type, as available in the MACT
database. As shown, toll and captive only facilities account for roughly 78 percent of the
reporting facilities with facilities performing both functions accounting for the remaining
22 percent. Coil coating lines are distributed similarly across producer types with the average by
group and overall being roughly 1.5 coating lines per facility. Furthermore, captive only facilities
are larger in terms of average number of employees because of the additional production process
related to final products co-located at the site. Alternatively, toll only facilities have a larger
average number of employees devoted to their coating line both in absolute magnitude and
relative to facility employment. This is consistent with the fact that their primary function is
providing coil coating services.
In general, coil coating plants are typically located near steel and aluminum plants to
reduce raw material shipping costs. High transportation costs influence the geographic market
where coated coil products are exchanged. As shown in Table 8-4, over half of the potentially
affected facilities are located in six states, mostly in the "rust-belt." Pennsylvania has the highest
number of facilities (13, or 16 percent of total), followed by Alabama (8), Ohio (7), Indiana and
Texas (both with six facilities), and Illinois (5).
8-4
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Table 8-3. Summary of Coil Coating Facilities by Producer Type: 1997
Item
Facilities (share)
Coating Lines (share)
Facility Employment
Average
Coating Line Employment
Average
Toll Only
30
(39.5%)
45
(38.8%)
241.9
66.8
Producer Type
Captive Only
29
(38.2%)
45
(38.8%)
364.2
30.7
Both
17
(22.4%) -
26
(22.4%)
183.5
33.4
All Facilities"
76
116
277.6
44.6
* 76 facilities reported producer type These 76 facilities operate 116 coating lines.
Table 8-4. Location of Potentially Affected Facilities by State: 1997
State
PA
AL
OH
IN
TX
IL
Other
Total
Number of Facilities
13
8
7
6
6
5
37
82
Percentage
15.9%
9.8%
8.5%
7J%
7.3%
6.1%
45.1%
100.0%
8.2.4.2 Companies.
The Agency identified 49 ultimate parent companies for the metal coil facilities and
obtained their sales and employment data from either their survey response or one of the
following secondary sources:
• Dun and Bradstreet Market Identifiers 8
• Hoover's Company Profiles 9
• Business and Company ProFile 10
• Company Websites.
8-5
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Appendix C provides a listing of the 49 companies that own and operate the 82 non-CBI
potentially affected facilities within this source category. The average (median) annual sales across
all companies reporting data were $1.8 billion ($650 million). This includes revenue from
operations other than metal coil coating. The average (median) employment was 9,918 (2,512)
employees. The top four companies in annual sales are:
• Alcoa—$15.34 billion with 103,500 employees.
Alusuisse-Lonza Group Ltd—$6.98 billion with 28, 495 employees.
• Crown Cork and Seal Company, Inc.—$8.3 billion with 38, 459 employees.
• Reynolds Metals Company—$5.86 billion with 20,000 employees.
Metal coil coating companies can also be grouped into small and large categories using
Small Business Administration (SBA) general size standard definitions by SIC Codes. Responses
by metal coil coating facilities to the industry survey indicated more than 30 different SIC codes
with a small business definition range from 100 to 1,000 employees. Using these guidelines and
available data, the Agency has identified 19 small businesses, or 38.8 percent of total. The annual
average (median) sales for these companies are $51.7 ($41.0) million. The average (median)
employment for these companies is 245 (175) employees. Many of these small coil coating
companies compete in smaller niche markets 6.
Based on responses to the Section 114 letters 7, Table 8-5 provides a summary of the
descriptive statistics for coil coating facilities by ownership size. As shown, the 19 small
companies own and operate 21 coil coating facilities, or 25.6 percent of total, with an average of
1.1 facility per company. The 30 large companies own and operate 61 coil coating facilities, or
74.4 percent, with an average of 2 facilities per company. Coil coating lines are distributed
similarly across these facilities with the average by group and overall being roughly 1.5 coating
lines per facility. Furthermore, facilities owned by large companies are larger in terms of average
number of employees, i.e., 310 employees per facility versus 157 employees per facilities.
Facilities owned by large companies also have a larger average absolute number of employees
devoted to their coating line but less relative to facility employment.
8.2.4.3 Industry Trends.
Industry has focused on the development of new or improved applications and processes.
For example, NKK Corporation announced the development of a new precoated steel sheet in fall
8-6
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of 1998. The company plans to market is for use in audiovisual equipment and home appliances,
and is targeting production levels to 1,000 tons per month by fiscal 1999 ". On the process side,
Material Sciences Corporation (MSC) has developed a high-speed powder coating technology
and by the end of 1999, plans on operating a 54 inch line running at 400 fpm. Current powder
coating lines typically run at 200 fpm l2. ~-
Table 8-5. Summary of Coil Coating Facilities by Ownership Size: 1997
Item
Facilities
Toll.
Captive
Both
Not reporting
Coating Lines
Share of total reported
Facility Employment
Average
Median
Minimum
Maximum
Coating Line Employment
Average
Median
Minimum
Maximum
Facilities
Small Companies
21
6
7
5
3
31
25%
157.1
97.5
26
1,000
30.4
30.0
6
115
Owned by
Large
Companies
61
24
22
12
3
94
75%
310.3
165.0
24
2,500
48.7
34.0
4
194
All Facilities
82
30
29
17
6
125
277.6
126.0
24
2,500
44.6
30.0
4
194
8.2.5 Market Data
Competition within the coil coating industry is regional due to the high cost of
transporting sheet metal coils 5. The coil coatings industry has experience rapid growth since the
early 1990s with an annual growth rate of 6 percent per year. As shown in Table 8-6, for 1997,
4.9 million tons of coated coil were shipped. Of this total, steel coil shipments were 4.2 million
tons, or 85 percent, and aluminum coil shipments were 0.7 million, or 15 percent. Industry also
reported data on square footage of coated coil for 1997 (13 billion square feet) because it is a
better measure of coil coating requirements. Table 8-6 also provides estimates of 1996 shipments
based on reported annual growth rates.
To our knowledge, no publicly available price data exists for coated metal coil products.
8-7
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However, one coil company does report coil coating service revenues and estimates its share of
market production for 1996 5. Based on this data, the Agency estimated a price of toll coating
services to be roughly $150 per ton of coil processed. Combining this estimate with data on the
substrate value provides a rough estimate of the price for coated metal coils. Therefore, using the
substrate costs from Table 8-1 and the relative share of steel and aluminum coaled-from Table 8-
6, we compute a value of coated metal coils of $3,900 million and a price of roughly $800 per ton
for 1997. The value added of coating the metal coil is approximately 20 percent of the total value
or price of the final product (i.e., $150 divided into $800).
Table 8-6. Shipments of Coated Metal Coils by Metal Type (106 tons)
Type
Steel
Aluminum
Total
1997
4.2
0.7
4.9
1996
3.7
0.6
4.3
Source: Reference 3
8.2.5.1 Market Trends.
Industry representatives anticipate a growth rate of 8 to 10 percent for 1998 and 1999 13.
Growth in the building and construction market is expected to contribute to strong demand.
Representatives see future growth in the appliance market, particularly the refrigeration segment.
They also see new opportunities in full-body applications in the automotive industry as well as
office furniture segment. Recently, coil coaters have expressed a desire in forming partnerships
with steel service centers in identifying new end-user demands 13.
8.3 ECONOMIC IMPACTS
The MACT standards on metal coil coating facilities require these producers to install
new, replace old, or upgrade existing equipment designed to destroy (e.g., incineration) or
capture (e.g., PTEs) hazardous air pollutants currently being released to the environment. As
described in Chapter 7 of this document, these costs will vary across facilities depending upon
their physical characteristics and baseline controls. These regulatory costs will have financial
8-8
-------
implications for the affected producers, and broader implications as these effects are transmitted
through market relationships to other producers and consumers. These potential economic
impacts are the subject of this section.
Inputs to the economic analysis include:
• Baseline characterization of metal coil coating facilities based on responses to the
Section 114 letters7.
• Baseline market data as projected from industry and secondary sources.
• Compliance cost estimates for individual facilities (through model plants) to meet the
MACT floor standards.
The Agency has estimated the national total annual compliance costs for this regulation to be $5.9
million in 1997. Because these costs are such a small share of the coating operations and overall
economic activity at affected facilities, the analysis focuses on the magnitude and distribution of
these costs across affected entities (facilities and coating lines) and affected inputs and products
(coating services and coated metal coils). The following subsections address the economic
impacts of the regulation on metal coil coating facilities, coating lines at these facilities, and the
product markets served by these facilities.
8.3.1 Facility Impacts
Absent facility-level sales data, the Agency measured the economic impact on metal coil
coating facilities based on the compliance costs incurred per facility and per facility employee. As
described in Section 8.2, these facilities may be categorized by producer type (i.e., toll, captive, or
both) and by ownership size (owned by small or large company). The economic impacts on these
facilities are presented below for both categories. The projected economic impacts on the owners
of these facilities are provided in Section 8.4 "Small Business Impacts."
Table 8-7 summarizes the magnitude and distribution of compliance costs across facilities
by producer type. Captive only facilities are expected to incur 62 percent of the total annual
compliance costs of the regulation ($3.6 million of $5.8 million for facilities reporting producer
type), while toll only facilities incur 24 percent ($1.4 million) and facilities that perform both
functions incur 14 percent ($0.8 million). It follows that the relative impact of these costs per
facility is higher for captive only facilities at $124,000 per year compared to the average across all
facilities at $75,800 per year. Alternatively, the annual cost per facility for toll only facilities and
facilities that perform both functions is lower than the industry average at $46,700 and $47,500,
8-9
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respectively. The estimates shown in Table 8-7 also indicate that the distribution of costs across
facilities is skewed toward the lower impact levels, i.e., the median value is significantly less than
the average value. This outcome results from the large number of facilities that either incur
minimal costs (facilities that are already permitted as synthetic minor sources) or only those costs
related to initial performance testing and annually recurring monitoring, reporting, and
recordkeeping (facilities that are already in compliance with the proposed regulation).
Furthermore, as shown in Table 8-7, similar relative impacts for costs per facility employment are
observed across these producer types.
Table 8-7. Summary of Compliance Cost Burden on Coil Coating Facilities by Producer
Type; 1997
Compliance Costs
Per Facility ($103/yr)
Average
Median
Minimum
Maximum
Per Facility Employee ($/yr)
Average
Median
Minimum
Maximum
Toll Only
$46.7
$21.0
$0.0
$277.1
$373
$163
$0
$1,802
Producer Type
Captive Only
$124.0
$24.5
$0.0
$780.7
$831
$155
$0
$6,612
Both
$47.5
$19.7
$0.0
$243.4
$463
$176
$0
$2,039
All Facilities
$75.8
$21.0
$0.0
$780.7
$576
$175
$0
$6,612
Table 8-8 summarizes the magnitude and distribution of compliance costs across facilities
by ownership size. Facilities owned by small companies (as defined in Section 4) are expected to
incur only 8.5 percent of the total annual compliance costs of the regulation ($0.5 million of $5.9
million for all facilities), while facilities owned by large companies incur 91.5 percent ($5.7
million). It follows that the relative impact of these costs per facility is much lower for facilities
owned by small companies at $25,200 per year compared to the average across all facilities at
$75,800 per year. Alternatively, the annual cost per facility for facilities owned by large
companies is higher than the industry average at $93,200. As shown in the previous table, the
estimates shown here indicate that the distribution of costs across facilities is skewed toward the
lower impact levels, i.e., the median value is significantly less than the average value.
Furthermore, the relative cost burden measured per employee is distributed in a similar fashion
across facilities owned by small and large companies, i.e., $248 per employee vs. $664 per
8-10
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employee.
Table 8-8. Summary of Compliance Cost Burden on Coil Coating Facilities by Ownership
Size: 1997
Facilities Owned by
Compliance Cost
Per Facility ($103/yr)
Average
Median
Minimum
Maximum
Per Facility Employee ($/yr)
Average
Median
Minimum
Maximum
Small Companies
$25.2
$11.5
$0.0
$169.9
$248
$72
$0
$1,335
Large
Companies -
$93.2
$31.3
$0.0
$780.7
$664
$206
$0
$6,612
All Facilities
$75.8
$21.0
$0.0
$780.7
$576
$175
$0
$6,612
8.3.2 Coating Line Impacts
Absent coating line-level sales data, the Agency measured the economic impact on metal
coil coating lines based on the compliance costs incurred per coating-line and per coating-line
employee. As described in Section 8.2, these facilities may be categorized by producer type (i.e.,
toll, captive, or both) and by ownership size (owned by small or large company). The economic
impacts on these coating lines are presented below for both categories. The projected economic
impacts on the owners of these coating lines and facilities are provided in Section 8.4 "Small
Business Impacts."
Table 8-9 summarizes the magnitude and distribution of compliance costs across coating
lines by producer type. Based on the relative incidence of compliance costs across facilities by
producer type, it follows that the relative impact of these costs per coating line is higher for
captive only facilities at $101,800 per year compared to the average across all coating lines at
$60,900 per year. Alternatively, the annual cost per coating line for toll only facilities and
facilities that perform both functions is lower than the industry average at $37,500 and $26,700,
respectively. The estimates shown in this table also indicate that the distribution of costs across
coating lines is skewed toward the lower impact levels, i.e., the median value is significantly less
than the average value. As mentioned in the previous section, this outcome results from the large
number of facilities that either incur zero costs or only those costs related initial performance
8-11
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testing and annually recurring monitoring, reporting, and recordkeeping. Furthermore, coating
lines at toll only facilities have twice the employment level as other producer types so that their
impact measure per employee is even less than the relative cost differential per coating line.
Table 8-9. Summary of Compliance Cost Burden on Coil Coating Lines
by Producer Type: 1997
Compliance Costs
Per Coating Line ($103/yr)
Average
Median
Minimum
Maximum
Per Coating Line Emp.($/yr)
Average
Median
Minimum
Maximum
Toll Only
$37.5
$20.3
$0.0
$277.1
$856
$277
$0
$5,149
Producer Type
Captive Only
$101.8
$22.8
$0.0
$780.7
$8,996
$1,760
$0
$63,217
Both
$26.7
$16.0
$0.0
$122.4
$2,177
$405
$0
$15,774
All Facilities
$60.9
$19.7
$0.0
$780.7
$4,748
$691
$0
$63,217
Table 8-10 summarizes the magnitude and distribution of compliance costs across coating
lines by ownership size. Based on the relative incidence of compliance costs across facilities by
ownership size, it follows that the relative impact of these costs per coating line is much lower for
those owned by small companies at $17,000 per year compared to the average across all coating
lines at $60,900 per year. Alternatively, the annual cost per coating line owned by large
companies is higher than the industry average at $76,200. Similar to results from the previous
table, the estimates shown here indicate that the distribution of costs across coating lines is
skewed toward the lower impact levels, i.e., the median value is significantly less than the average
value. Furthermore, the relative cost burden measured per coating line employee is distributed in
a similar fashion across ownership size, i.e., $1,175 per employee for facilities owned by small
companies vs. $5,594 per employee for those owned by large companies.
8-12
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Table 8-10. Summary of Compliance Cost Burden on Coil Coating Lines
by Ownership Size: 1997
Facilities Owned by
Compliance Cost
Per Coating Line ($103/yr)
Average
Median
Minimum
Maximum
Per Coating Line Emp. ($/yr)
Average
Median
Minimum
Maximum
Small Companies
$17.0
$11.5
$0.0
$82.8
$1,175
$59
$0
$6,677
Large
Companies
$76.2
$26.4
$0.0
$780.7
$5,594
$901
$0
$63,217
All Facilities
~ "
$60.9
$19.7
$0.0
$780.7
$4,748
$692
$0
$63,217
8.3.3 Market Impacts
In conducting an economic impact analysis, the Agency typically models the responses by
producers and markets to the imposition of the proposed regulation. The alternatives available to
producers in response to the regulation and the context of these choices are important in
determining the economic and financial impacts. Economic theory predicts that producers will
take actions to minimize their share of the regulatory costs. Producers decide whether to
continue production and, if so, to determine the optimal level consistent with market signals.
These choices and market feedbacks allow them to pass costs forward to the consumers of their
end-products or services and/or to pass costs backward to the suppliers of production inputs.
However, based on the small absolute and relative magnitude of the estimated regulatory costs,
the Agency focuses the economic impact analysis on the initial distribution of costs across
facilities and coating lines presented above. The financial impact of the regulation on affected
businesses is analyzed in Section 8.4.
Table 8-11 shows that the total annual compliance cost estimate of $5.9 million for the
metal coil coating industry is small relative to the sales value of its end-product, i.e., coated metal
coil, and the value of inputs to the production process. Absent observed price and cost data for
this industry, we gauge these potential market impacts using approximations for end-product and
input values based on available market data presented in Section 8.2. As shown in Table 8-11,
total annual compliance costs for this regulation represent less than 0.2 percent of the computed
8-13
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value of coated metal coils for 1997. Therefore, the potential increase in the projected baseline
market price of $790 per ton would be a similarly small proportion, or only $1.27 per short ton.
Furthermore, the regulatory costs are also expected to represent only 0.8 percent of the computed
value of coating services ($150 per ton of coated metal coil), which does not indicate the cost of
coating operations will increase sufficiently to cause producers to cease or filter, their current
coating operations.
Table 8-11. Compliance Cost Share of the Value of Coated Metal Coil and Inputs: 1997
Item
Coating Operations
Coatings
Value Added
Substrates
Steel
Aluminum
Coated Metal Coils
Baseline
Total
($106)
$735
$612
$123
$3,150
$1,750
$1,400
$3,885
Value
Per Unit "
($/ton)
$150
$125
$25
$643
$416
$2,000
$793
Compliance Cost
Share (%)
0.8%
1.0%
5.0%
0.2%
0,3%
0.4%
0.16%
• Per unit value as measured based on the reported volume of coated metal coil volume in 1997 of 4.9 million short tons with
the per unit values for substrate measure based on their share of that total, i.e., 4.2 million for steel and 0.7 million for
aluminum.
8.4 SMALL BUSINESS IMPACTS
This regulatory action will potentially affect the economic welfare of owners of metal coil
coating facilities. The ownership of these facilities ultimately falls on private individuals who may
be owner/operators that directly conduct the business of the firm (i.e., "mom and pop shops" or
partnerships) or, more commonly, investors or stockholders that employ others to conduct the
business of the firm on their behalf (i.e., privately-held or publicly-traded corporations). The
individuals or agents that manage these facilities have the capacity to conduct business
8-14
-------
transactions and make business decisions that affect the facility. The legal and financial
responsibility for compliance with a regulatory action ultimately rests with these agents; however,
the owners must bear the financial consequences of the decisions. Environmental regulations like
this rule potentially affect all businesses, large and small, but small businesses may have special
problems in complying with such regulations.
The Regulatory Flexibility Act (RFA) of 1980 requires that special consideration be given
to small entities affected by federal regulation. The RFA was amended in 1996 by the Small
Business Regulatory Enforcement Fairness Act (SBREFA) to strengthen the RFA's analytical and
procedural requirements. Prior to enactment of SBREFA, EPA exceeded the requirements of the
RFA by requiring the preparation of a regulatory flexibility analysis for every rule that would have
any impact, no matter how minor, on any number, no matter how small, of small entities. Under
SBREFA, however, the Agency decided to implement the RFA as written and that a regulatory
flexibility analysis will be required only for rules that will have a significant impact on a substantial
number of small entities.
This section identifies the businesses that will be affected by this proposed rule and
provides a preliminary screening-level analysis to assist in determining whether this rule is likely to
impose a significant impact on a substantial number of the small businesses within this industry.
The screening-level analysis employed here is a "sales test," which computes the annualized
compliance costs as a share of sales for each company. Appendix A provides a listing of the 49
companies that own and operate the 82 non-CBI potentially affected facilities within this source
category.
The Small Business Administration (SBA) defines a small business in terms of the sales or
employment of the owning entity. These thresholds vary by industry and are evaluated based on
the industry classification (SIC Code) of the impacted facility. Responses by metal coil coating
facilities to the industry survey indicated over 30 different SIC codes with a small business
definition range from 100 to 1,000 employees. The Agency developed a company's size standard
based on the reported SIC codes for these facilities. In determining the companies' SIC size
standard, the following assumptions were made:
• In cases where companies own facilities with multiple SIC's, the most conservative
SBA definition was used. For example, if a company owned facilities within
SICs 3448 (size standard equal to 500 employees) and 3334 (size standard equal to
1,000 employees), we used the size standard of 1,000 employees.
8-15
-------
• Four companies owning facilities that did not report an SIC code. We assigned these
companies the most conservative size standard of 1,000 employees.
Based on EPA's database, 19 of the companies owning facilities (38.8 percent) that perform metal
coil coating were identified as small with the remaining 30 companies being large (61.2 percent)
(See Appendix C for detailed listing).
For the purposes of assessing the potential impact of this rule on these small businesses,
the Agency calculated the share of annual compliance cost relative to baseline sales for each
company. When a company owns more than one facility, the costs for each facility it owns are
summed to develop the numerator of the test ratio. For this screening-level analysis, annual
compliance costs were defined as the engineering control costs imposed on these companies; thus,
they do not reflect the changes in production expected to occur hi response to imposition of these
costs and the resulting market adjustments.
Table 8-12 reports total annual compliance costs and the number of companies impacted
at various threshold levels. It also provides summary statistics for the cost-to-sales ratios (CSRs)
for small and large companies reporting the necessary sales data. Although small businesses
represent almost 39 percent of the companies within this source category, Table 4-1 shows that
their aggregate compliance costs totals $0.5 million, or only 8.5 percent of the total industry costs
of $5.9 million. Under the proposed rule, the annual compliance costs for small businesses range
from zero to 1.65 percent of sales with 7 of the 19 small businesses not incurring any regulatory
costs. The vast majority of small companies with sales data have CSRs below 0.5 percent." The
mean (median) cost-to-sales ratio is 0.17 (0.03) percent for the identified small businesses and
0.02 (<0.01) percent for the large businesses. Therefore, based on the results of this screening
analysis, the Agency has determined that this regulation does not impose a significant impact on a
substantial number of small businesses.
a Three of the four small companies without sales data incur compliance costs ranging from $11,520 to $82,850 per
year. Therefore, annual company sales for these companies would have to fall below $1.15 or $8.3 million per year for these
companies to be impacted at the 1 percent level.
8-16
-------
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8-17
-------
8.5 REFERENCES
1. U.S. Environmental Protection Agency. 1998. Preliminary Industry Characterization
Metal Coil Surface Coating Industry.
«http://www.epa.gov/ttn/uatw/coat/mcoil/rnet_coil.html».
2. Bourguignon, Edward W. 1998. "Coil Coating Industry Promises Continuing Growth."
Paint & Coatings Industry. 14 (6): 33. - _ .
3. Bourguignon, Edward W. 1999. "Growth Accelerating for Coil Coating." Paint &
Coatings Industry. 15 (3): 44-45.
4. National Coil Coaters Association. 1999. "Why Coil Coating."
. Obtained August 30, 1999.
5. Material Sciences Corporation. 1997. 10-K Report filed May 28, 1997.
.
Obtained September 1, 1999.
6. Stundza, Tom. 1998. "Demand Keeps Pace with Supply." Purchasing Online. April, 9
1998.
Obtained August 31, 1999.
7. U.S. Environmental Protection Agency. ICR Responses. Metal Coil Surface Coatings
MACT Docket Number A-97-47, Item Numbers II-D-1 through II-D-113. Office of Air
Quality Planning and Standards. Research Triangle Park, NC. Responses received
September 1998 - April 1999.
8. Dun & Bradstreet. 1999. Dun's Market Identifiers [computer file]. New York, NY:
Dialog Corporation.
9. Hoover's Incorporated. 1999. Hoover's Company Profiles. Austin, TX: Hoover's
Incorporated. .
10. Information Access Corporation. 1999. Business & Company ProFile [computer file].
Foster City, CA: Information Access Corporation.
11. Drukenbrod, Mark. 1998. "NKK Develops Tougher Coil Coating." Paint & Coatings
Online. November 30, 1998. Obtained August, 1999.
12. Graves, Beverly. 1999. "Coil Powder Coating." Pfonline.
. Obtained August 31, 1999.
13. Pinkham, Myra. 1999. "Demand Growing for Prepainted Coil." Metal/Center News.
February, 1999.
8-18
-------
APPENDIX A
PARTICIPANTS IN THE DATA COLLECTION EFFORT
-------
Name
Glen Anderson
Tom Ashy
Kevin Bald
Kevin Barnett
Jim Bercaw
Allen Bracey
Sam Bruntz
Stephen Byrne
Dennis Carson
Roy Carwile
Dwight Cohagan
Jim Dodson
Steven Dubois
Jack Farmer
Bob Fegley
Tyler Fox
Barbara Francis
David Friedland
Kelly Garbin
Gregory Gemgnani
Steve Gross
Susan Hoyle
Jesse Hackenberg
Madelyn Harding
Gary Hayden
Linda Herring
William Jelf
Affiliation
National Coil Coaters Association
Metal Prep
Reynolds Metals
Alcoa
Technical Coatings
Vulcraft
Commonwealth Aluminum
Cytec Industries
PPG Industries
Alcoa
The Sherwin Williams Company
Roll Coater
Alcan
Research Triangle Institute
EPA/ORD
EPA/OAQPS
Chemical Manufacturers Association
Beveridge and Diamond - Representing NCCA
National Coil Coaters Association
Prior Coated Metals
Pennsylvania Bureau of Air Quality
Pennsylvania Bureau of Air Quality
Chromographic Processing
The Sherwin Williams Company
MSC Pre Finish Metals
EPA/OAQPS
AKZO Nobel Coatings
A-2
-------
Name
Matt Johnston
Rhea Jones
Joseph Junker
Peter Kehayes
Trish Koman
Mike Kosuko
Gail Lacy
David Leligdon
William Madigan
Brent Marable
Joseph McCloskey
Tom McElven
Arnold Medberry
Larry Melgary
Hank Nauer
Carol Neimi
Bob Nelson
Stanley Ogrodnick
Dave Ozawa
Venkata Panchakaria
Alton Peters
Jack Peterson
Mary Ellen Roddy
Alexander Ross
Norbert Saatkoski
Mona Salem
Jason Schnepp
Affiliation
Worthington Industries
EPA/OAQPS
ARCO Chemical Co.
Industry Consultant
EPA/OAQPS
EPA/ORD
EPA/OAQPS
Precoat Metals
Metropolitan Metal Sales
EPA Region V
Benjamin Moore & Co.
Owens Corning Metal Systems
EPA Small Business Ombudsman
Northern Coatings and Chemical Company
Illinois Environmental Protection Agency
Representing CMA Solvent's Council
National Paint and Coatings Association
Owens Corning Metal Systems
Mostardi-Platt Associates
Florida Dept. of Environmental Protection
Research Triangle Institute
Allegheny County Health Dept.
National Paint and Coatings Association
Rad Tech International, NA
Roll Coater
Arvin Roll Coater
Illinois Environmental Protection Agency
A-3
-------
Name
Mohamed Serageldin
George Smith
Gary Stimpson
Robert P. Stricter
Scott Throwe
William Vallier
Deon Vaughan
Greg Verret
Bill Vinzant
Milton Wright
Steve York
Tom Young
Affiliation
EPA/OAQPS
EPA/OAQPS
Nichols Aluminum
Aluminum Association
EPA/OECA
Gentek Building Products
Owens Corning Metal Systems
Environmental Resources Management
Kaiser Aluminum
Research Triangle Institute
Research Triangle Institute
MSC Pre Finish Metals
A-4
-------
APPENDIX B
COIL COATING PLANT LIST
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO. 2.
EPA-453-P-00-001
4. TITLE AND SUBTITLE
National Emission Standards for Hazardous Air Pollutants: Metal
Coil Surface Coating Industry Background Information for
Proposed Standards
7. AUTHOR®
9. PERFORMING ORGANIZATION NAME AND ADDRESS
CIS. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
April 25, 2000
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO'.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D6-0014
13. TYPE OF REPORT AND PERIOD COVERED
Interim
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document contains a summary of the EPA's current level of knowledge on hazardous air pollutants
and their emission points at metal coil surface coating facilities. This document presents descriptions of
representative processes and operations, hazardous air pollutant emission sources and estimated emissions,
and applicable air emission control technologies. The capital and annual costs of air emission controls are
also presented in this document.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group
Hazardous Air Pollutants Air Pollution Control
Metal Coil Surface Coating Operations
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18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Report)
Unclassified
20. SECURITY CLASS (Page)
Unclassified
21. NO. OF PAGES
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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