&EPA
          United States
          Environmental Protection
          Agency
            Office of Air Quality
            Planning and Standards
            Research Triangle Park NC 27711
EPA-453/R-93-025
June 1993
          Air
AIR EMISSIONS AND CONTROL
TECHNOLOGY FOR LEATHER
TANNING AND FINISHING
OPERATIONS
         control
           technology center

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•o
K.
                                                 EPA-453/R-93-025
  AIR EMISSIONS AND CONTROL TECHNOLOGY  FOR
   LEATHER TANNING AND  FINISHING OPERATIONS
                  CONTROL TECHNOLOGY CENTER

                         SPONSORED BY:

                    Emissions Standards Division
               Office of Air Quality Planning and Standards
                 U. S. Environmental Protection Agency
              Research Triangle Park, North Carolina 27711

             Air and Energy Engineering Research Laboratory
                  Office of Research and Development
                 U. S. Environmental Protection Agency
              Research Triangle Park, North Carolina 27711
                            June 1993

                       U.S. Environ'---: •' iV^-tion Agency
                       Region 5, Li;,,,....   -12J)
                       77 West Jackson ;:.,j;evard, 12th Floor
                       Chicago, IL 60604-3590

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                                             EPA-453/R-93-025
                                                   June 1993
AIR EMISSIONS AND CONTROL TECHNOLOGY FOR
 LEATHER TANNING AND FINISHING OPERATIONS
                     Prepared by:

                    Barry F. Mitsch
                    Reese H. Howie
                 Samuel C. McClintock
            Alpha-Gamma  Technologies, Inc.
             900 Ridgefield Drive, Suite 350
             Raleigh, North Carolina  27609

                 Under Subcontract to:

                  Radian Corporation
        3200 E. Chapel Hill Road/Nelson Highway
       Research Triangle Park, North Carolina 27709

              EPA Contract No. 68-01-0117
               Work Assignment No. 79
                    Project Officer

                    Iliam Rosario
              Emission Standards Division
          U. S. Environmental Protection Agency
       Reserach Triangle Park, North Carolina 27711
                    Prepared for:

              Control Technology Center
          U. S. Environmental Protection Agency
      Research Triangle Park, North Carolina 27711

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                             Acknowledgement

This document was prepared for the EPA's Control Technology Center (CTC) by
Alpha-Gamma Technologies, Inc. under subcontract to Radian Corporation.  The
Alpha-Gamma project team included Barry F. Mitsch, Reese H. Howie, and Samuel C.
McClintock. The EPA Work Assignment Manager was Iliam Rosario.

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                                  PREFACE
      The purpose of this document is to provide information to State and local
agencies for use in assessing appropriate measures to control volatile organic
compound (VOC) emissions from leather tanning and finishing facilities. Another
objective of the report is to evaluate leather tanning and finishing processes and
determine their potential to emit VOC's and hazardous air pollutants (HAP's) to the
atmosphere.  This  document is the product of a study sponsored by EPA's Control
Technology Center (CTC).

      The CTC was established by EPA's Office of Research and Development (ORD)
and Office of Air Quality Planning and Standards (OAQPS) to provide  technical
assistance to State and local air pollution control agencies.  Three levels of assistance
are available through the CTC.  First, the CTC maintains a hotline to provide telephone
assistance on  matters relating to air pollution  control technology.  Second, engineering
assistance can be  provided by the Center when appropriate.  And finally, the CTC
provides technical  assistance through publication of technical assistance documents,
development of personal computer software,  and presentation of workshops on
control technology subjects.

      This document represents the product of a CTC technical assistance effort.
The CTC became interested  in pursuing this project as a result of numerous calls from
State and  local agencies regarding control of VOC emission from leather tanning and
finishing facilities.  This document was developed using information  obtained from
available literature,  information provided through Federal, State, and local air pollution
control agencies, and information obtained from the leather tanning  and finishing
industry.

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                           TABLE OF CONTENTS
1.0   Introduction	  1-1
      1.1  Objectives of the Report  	  1-2
      1.2  Overview of the Report 	  1-2
2.0   Industry Description  	  2-1
      2.1  Characterization of the Industry  	.,..	  2-4
      2.2  References	  2-8
3.0   Leather Tanning and Finishing Processes	  3-1
      3.1  Wet operations	   3-1
                3.1.1  Soaking	  3-3
                3.1.2 Unhairing	  3-3
                3.1.3 Bating 	  3-5
                3.1.4 Pickling  	  3-5
                3.1.5 Tanning	  3-5
                3.1.6 Trimming and Siding	  3-7
                3.1.7 Splitting  	  3-7
                3.1.8 Retanning	  3-9
                3.1.9 Coloring	  3-9
                3.1.10  Fatliquoring	  3-9
      3.2  Dry Operations	  3-11
                3.2.1  Drying 	  3-11
                3.2.2 Conditioning	  3-11
                3.2.3 Staking and Milling  	  3-12
                3.2.4 Buffing	  3-12
      3.3  Leather Finishing Operations  	  3-12
                3.3.1  Coatings Used for Leather Finishing	  3-12
                3.3.2 Application Methods for Leather Finishing	  3-19
                     3.3.2.1 Spray  Systems	  3-19
                     3.3.2.2 Roll Coating Machines  	  3-24
                     3.3.2.3 Flow Coating Machines	  3-24
      3.4  Additional Dry Operations  	  3-24
      3.4  Waterproofing Operations	  3-28
      3.5  References	  3-28
4.0 Characterization of Emissions  	  4-1
      4.1  Sources of VOC and  HAP Emissions  	  4-1
                4.1.1  Leather Finishing Operations	  4-1
                4.1.2 Waterproofing Operations  	  4-4
                4.1.3 Solvent Degreasing	  4-6
                4.1.4  Miscellaneous Fugitive Emissions	  4-6
      4.2  Factors Affecting VOC and HAP Emissions	  4-7
      4.3  Volatile Organic Compound Emissions	  4-9
      4.4  Hazardous Air Pollutant Emissions	  4-9
      4.5  References	  4-15

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5.0 Emission Reduction and Control Techniques	  5-1
      5.1  Emission Control Techniques	  5-1
               5.1.1  Total Enclosure for Effective Capture of
                    VOC and Gaseous HAP	  5-2
               5.1.2  Control Devices	  5-4
                    5.1.2.1  Thermal Incineration	  5-4
                    5.1.2.2 Catalytic Incineration	  5-9
                    5.1.2.3 Carbon Adsorption	  5-11
               5.1.3  Methods of Minimizing Control Costs - Volume Reduction  5-14
      5.2  Emission Reduction Techniques	  5-15
               5.2.1  Use of Lower VOC and Water-Based Coatings 	  5-16
               5.2.2  Emission Reductions from improved Transfer Efficiency  .  5-18
                    5.2.2.1  High Efficiency Spray Guns	  5-18
                    5.2.2.2 Optical Eye/Microprocessor Controls
                          on Spray Equipment	  5-21
               5.2.3  Housekeeping Operations	  5-21
               5.2.4  Degreasing Operations	  5-21
               5.2.5  Emission Reductions and Waterproofing Operations  . .  .  5-23
               5.2.6  Radiation Curing of Top Coats	  5-24
      5.3  References	  5-24
6.0 State and Local Regulations Affecting the Leather Tanning
      and Finishing Industry	  6-1
      6.1  Regulations Limiting VOC Content of the Finishing Coatings	  6-1
               6.1.1  State of New Jersey	  6-1
               6.1.2  State of New York		6-3
               6.1.3  State of Massachusetts	  6-3
               6.1.4  Monterey Bay Unified Air  Pollution Control District	6-4
      6.2  Regulations Limiting Emissions to Unit of Product Finished	  6-4
      6.3  State of Illinois	6-5
      6.4  References	6-7
Appendices
      Appendix A  Emissions Data	A-i
               A.1 Introduction to Appendix A .	  A-ii
      Appendix B  Leather Tanning and Finishing Plants - Case Studies	B-i
               B.1 Introduction to Appendix B	,	  B-ii
               Plant A		,	B-1
               Plant B	B-5
               Plant C	  B-10
               Plant D	  B-13
               PlantE	  B-17

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Appendix C  State and Local Regulations Affecting Leather Tanning and
           Finishing Facilities	  C-i
          C.1  Introduction to Appendix C  	  C-ii
          State of New Jersey	C-1
          State of New York  	C-15
          State of Wisconsin	C-37
          State of Massachusetts	C-73
          State of Illinois	C-79
          Monterey Bay Unified Air Pollution Control District	C-85
Appendix D  Leather Tanning and Finishing Facilities  	  D-i
          D.1  Introduction to Appendix D	  D ii
Appendix E  Selected Contacts	 . E-i
          E.1  Introduction to Appendix E	  E-ii

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                              LIST OF TABLES
                                                                          Page

Table

2-1   Leather Tanning and Finishing Facilities in the United States	  2-2
2-2   United States Production of Cattlehide Leather^	  2-6
2-3   Tanners' Stocks of all Cattlehide and  Leathers	  2-7

3-1   Comparison of Lacquer, Lacquer-emulsion and Water-based
      Top Coat Systems	  3-16
3-2   Generic Coating Formulations	  3-17
3-3   Top Ten Products by Year and VOC Content	  3-18
3-4   Surface Tensions of Various Solvents	  3-20

4-1   Air Emission Compounds from Leather Facilities  	  4-2
4-2   Emissions from Leather Processing Monitored in the
      United Kingdom in 1990	  4-3
4-3   Representative  Emission Factors for Leather Tanning and
      Finishing Facilities 	  4-10
4-4   VOC Emissions from Representative Leather Tanning and Finishing
      Facilities	  4-11
4-5   Leather Tanning and Finishing Industry -- Major Sources of Hazardous Air
      Pollutants   	  4-13

5-1   Design and Operating Parameters of Existing Regenerative
      Thermal Incinerators	  5-8
5-2   Comparison of  Lacquer, Lacquer-emulsion and Water-based
      Top Coat Systems	  5-17
5-3   Transfer Efficiencies of Different Spray Techniques	  5-19
5-5   Demonstration of Increased Transfer Efficiency with Optical Eyes  	  5-22

6-1   VOC Limitations in Existing State Regulations	  6-2
6-2   State of Wisconsin - Emission Rates Identified by Finishing
      Application Method  	  6-5

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                              LIST OF FIGURES
                                                                          Page

Figure

3-1   Leather Tanning and Finishing Process - Flow Diagram  	  3-2
                                                -•>
3-2   Mixing Drum used for Soaking and Unhairing  	  3-4
3-3   Drum Used for Bating, Pickling, and Tanning	  3-6
3-4   Sections of a Cattle Hide Used for Leather Making	  3-8
3-5   Splitting Machine	  3-10
3-6   Staking Machine  	  3-13
3-7   Contact Angles of Leather Coatings  	  3-21
3-8   Rotary Spray Booth and Drying Oven  	  3-23
3-9   Direct Roll Coating .	  3-25
3-10  Reverse Roll Coating	  3-26
3-11  Flow Coating Machine	  3-27

4-1   Rotary Spray Machine and Drying Oven 	  4-5
4-3   Trends in Nationwide HAP Emissions for All Reporting
      Facilities (1987-1990)and Facilities Reporting for All Four Years	  4-14
5-1   Thermal Incinerator Unit	  5-5
5-2   Regenerative Heat Recovery Unit	  5-8
5-3   Catalytic Incinerator Unit  	  5-10
5-4   Regenerative Carbon Adsorber	  5-13

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                            1.0  INTRODUCTION
      One of the major goals of the Clean Air Act Amendments of 1990 (CAAA) is to
achieve compliance with the national ambient air quality'standard for ozone.  Title I of
the amendments presents provisions for achieving the ozone standard.  Among these
provisions is a requirement that States adopt reasonably available control technology
(PACT)  for major sources of VOC's.

      Under the amendments, a major source is defined as one with a potential to
emit 100 tons or more of VOC's  if that source is located in an area classified as
marginal or moderate nonattainment for ozone.  If the area is classified as serious
nonattainment for ozone, the threshold for a major source is lowered to 50 tons per
year.  Further, the threshold for a major source is 25 tons per year in an area
classified as severe nonattainment, and 10 tons per year in an area classified as
extreme nonattainment.  In addition, Section 184 of the CAAA creates the Northeast
ozone transport region which includes 11 States in the Northeast corridor from
Washington, DC, to Maine. In the transport region,  a major source is one with a
potential to emit 50 tons or more of VOC.  Major sources in the transport region are
subject to the same requirements as major sources  in moderate nonattainment areas.

      The determination of RACT can be done on a case-by-case basis, but States
typically adopt RACT as defined  by Control Technique Guidelines (CTG's)  issued by
EPA.  As of 1990, EPA had issued 29 CTG documents and was in the process of
developing an additional 12 documents.  The CAAA requires States to adopt RACT for
both major sources in industries  covered by CTG's,  and for major sources in
industries  not covered by any existing CTG.

      These provisions of the CAAA have a potential impact on the leather tanning
and finishing industry.  Many  leather tanning and finishing facilities may be reclassified
as major sources under the stricter requirements of the Act. In addition, a large
number  of facilities are located in the Northeast transport region. The EPA has not
issued a CTG for this industry and does not anticipate issuing a CTG document in the
near future. Therefore, States are left with the burden of determining RACT for any
major sources of VOC's in the leather tanning and finishing industry.
                                     1-1

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1.1   Objectives of the Report

      The CTC has received a number of calls from State and local agencies
requesting guidance on controlling VOC's from leather tanning and finishing facilities.
One of the objectives  of this report is to document existing emission control and
reduction methods currently used in the industry.  State and local agencies will use
this information to help determine RACT for facilities in their jurisdiction.

      Another objective of the report is to identify and characterize the emissions of
HAP's from the industry. In Title III of the CAM, Section 112(c) requires EPA to
publish a list of categories of major and area sources for regulation that emit one or
more of the HAP's listed in the section. Presently, leather tanning and finishing plants
are not on the list of major or area sources listed for regulation. The information
contained in this report will be used to determine if leather tanning and finishing should
be added to the list.

1.2   Overview of the Report

      The information contained in this document has been obtained from a variety of
sources.  Contacts were made with numerous State and local agencies that have
leather tanning and finishing facilities located in their jurisdictions. These agencies
supplied available emissions data and information on regulations specific to the leather
tanning and finishing industry. Site visits  were made to five facilities, two of which
employ emission control devices. Information was also obtained from sources within
the leather tanning and finishing industry. These sources included trade associations,
suppliers of equipment,  and suppliers of finishing chemicals. An extensive literature
search was also conducted.

      This report is divided into 6 chapters and 5 appendices.  Chapter 2.0 provides a
general description of the industry while Chapter 3.0 describes the key processes
employed in manufacturing leather.  Chapter 4.0 characterizes the emissions of VOC's
and HAP's from the industry, and Chapter 5.0 describes applicable emission reduction
technologies.  Finally, Chapter 6.0 discusses current State and local air pollution
regulations affecting the industry.

      The appendices provide supplementary information related to specific  sections
of the report.  Appendix A includes all emissions data obtained during the study.
Appendix B is a series of case studies derived from site visits. These case studies
describe emission reduction strategies currently employed by  various facilities.
Appendix C contains the full text of all State and local air pollution regulations affecting
the leather tanning and finishing industry  along with all available supporting
documentation for these rules.  Appendix D lists the facilities identified by various
sources reviewed during the study including emissions data bases, State and local
                                       1-2

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agency emission inventories, and permitting records. Finally, Appendix E is a list of
selected contacts who provided information and assistance in compiling the report.
                                      1-3

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                       2.0  INDUSTRY DESCRIPTION
       Leather manufacturing is one of the oldest industrial processes in the world.
The origins of this craft can be traced to prehistoric times.  Early tanning operations
were conducted in open  pits using exclusively manual operations.  The  tanning agents
were plant substances such as oak, hemlock, and  chestnut barks.  With the arrival of
the industrial age, leather making evolved from a cottage craft to a full scale industry.

       The modern tannery uses advanced chemical and mechanical processes to
produce leather having hundreds of different finished characteristics. This leather is
used to produce products such as footwear, upholstery, clothing, gloves, luggage,
personal leather goods, and industrial parts. Production of each type of leather
involves integration of a complex series of operations that must be closely monitored
by experienced professionals.

       A distinction can be  made between  the leather tanning and finishing processes.
Leather tanning involves  primarily wet chemical processes that produce a stable,
usable product. Leather finishing involves a number of conditioning and enhancement
processes that  give tanned leather distinctive and desirable qualities required by end
users of the material.  Some facilities in the industry are only involved with leather
tanning while some are exclusively leather  finishers. There are also facilities that tan
and finish at the same location.

       The leather tanning and finishing industry has undergone a great number of
changes in recent years. In 1982, there were 342 companies in the industry operating
about 384 facilities. In 1991, the U. S. Industrial Outlook reported only 115 facilities of
significant size that were  involved with wet tanning of hides and production of
leather.1

       Developing an accurate list of leather tanning and finishing facilities is difficult.
Table 2-1  presents estimates of the number of leather tanning and finishing facilities in
the United States using three sources of information.  The 1991 International Leather
Guide  lists 225  leather tanning facilities and sales offices while a 1992 report prepared
for EPA listed 133 le.ather tanning and finishing facilities.2'3  A review of available
emissions inventories  and EPA data bases revealed 79 facilities conducting leather
tanning and/or finishing.  Mr. Frank Rutland of the  Leather Industries Research
Laboratory estimates that there are about 125 total facilities in the United States

                                      2-1

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Table 2-1.  Leather Tanning and Finishing
      Facilities in the United States
STATE

ALASKA
ARIZONA
CALIFORNIA
COLORADO
CONNECTICUT
FLORIDA
GEORGIA
IOWA
ILLINOIS
INDIANA
KENTUCKY
LOUISIANA
MASSACHUSETTS
MAINE
MARYLAND
MICHIGAN
MINNESOTA
MISSOURI
NORTH CAROLINA
NEBRASKA
NEW HAMPSHIRE
NEW JERSEY
NEW YORK
NUMBER OF FACILITIES
ILG'
1
2
8
2
2
2
2
2
8
1
2
0
40
9
1
4
2
4
1
1
5
15
64
EPA REPORT
0
0
4
0
0
2
1
1
3
0
2
1
26
6
1
3
1
2
1
2
1
10
32
EMISSIONS DATA0
0
0
1
1
0
1
0
1
3
0
0
0
6
5
1
3
1
2
1
1
0
5
24
                   2-2

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                          Table 2-1.  Leather Tanning and Finishing
                                Facilities in the United States
STATE

OHIO
OREGON
PENNSYLVANIA
SOUTH CAROLINA
TENNESSEE
TEXAS
UTAH
WASHINGTON
WISCONSIN
WEST VIRGINIA

NUMBER OF FACILITIES
ILG*
2
1
8
1
9
4
1
0
20
1
225
EPA REPORT
1
2-
5
0
4
3
2
1
16
0
133
EMISSIONS DATA6
1
0
6
0
4
1
1
0
9
1
79
a Reference 2

b Reference 3
c Toxic Release Inventory (1987-1990), AIRS data base, state inventories and permit information.
                                             2-3

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conducting some form of leather tanning and/or finishing, with about 85 facilities
having some type of finishing operation.4 Most of the plants are located in New York,
New Jersey, Wisconsin,  and Massachusetts.  A listing of the facilities identified using
emissions inventories and EPA data bases is provided in Appendix D.

      The discrepancies in the number of facilities identified in the United States is
indicative of the changes occurring within the industry and the characteristics of the
industry as a whole.  Some of the facilities identified by the International Leather Guide
are sales offices or specialty process support operations. For example, some smaller
companies may be involved with only one process of the leather manufacturing
operation such as embossing or cutting. There are also a large number of small
facilities that may not be reported  in all data bases.

2.1   Characterization of  the Industry

      When looking at the  leather tanning and finishing industry as a whole, a division
can be made between the larger and smaller companies. The larger companies
typically have integrated tanning, finishing, and marketing operations and employ 400
to 1,000 people.  These  larger companies usually have in-house research and
development capabilities and have some ability to develop customized  coating
formulations and finishing systems. The smaller  companies typically have less than
100 employees and rely  more heavily on chemical suppliers to provide tanning and
finishing chemicals.  They generally do not have  the in-house capabilities to develop
new coating formulations and finishing systems.5

      Most of the facilities in the industry fall into the category of smaller companies.
As indicated by the  1992 U. S. Industrial Outlook, total 1991 employment by the
industry was about 11,400 people spread among 115 facilities. Therefore,  the average
facility has less than 100 employees. This characterization of the industry is important
when considering the availability of resources needed to convert to new technologies
such as water based coatings. The majority of the leather tanning and finishing
facilities have limited technical capabilities.

      There are literally thousands of different products that can be  produced from
leather. However, the two largest markets for leather are the footwear  industry and
the upholstery industry.  In  1991, 52 percent of all leather shipments were used to
manufacture footwear. Conversely, the fastest growing market for leather is the
furniture and automotive upholstery industry.  It is estimated that in 1991 the
upholstery industry accounted for  nearly 35 percent of all leather shipments by value
as opposed to only  7 percent in 1982. This rapid growth is the result of changes in
consumer attitudes and more demand for leather products in furniture  and
automobiles.
                                      2-4

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      Tables 2-2 and 2-3 provide industry statistics for the cattlehide segment of the
industry. Most of the leather produced in the United States is from cattlehides.  As
shown in the tables, production levels have remained relatively stable over the past
few years.8

      Continued product development and refinement of existing products is a
standard activity in the industry.  Tanneries must react to the changing demands of
their customers and the tanning and finishing process must often be changed to adapt
to these demands.  For example, automotive upholstery manufacturers must meet a
wide range of  quality standards imposed by the automotive industry.  These standards
cover characteristics such as rubfastness, color, and heat resistance. The tannery
must closely monitor all phases of the  leather manufacturing process to ensure that
these standards can be met.

      Another example can be found in the footwear industry.  Footwear styles  are
determined by fashion trends that are ever changing.  As a result, shoe manufacturers
demand that the leather they purchase  match the latest trends.  Therefore, tanneries
producing footwear leather have to adapt their tanning and finishing systems to
produce suitable leathers.  Since shoe manufacturers apply their own finishes to the
leather they purchase, the finished leather supplied by the tannery must also be
compatible with the finishes being applied by the shoe manufacturer.

      The leather tanning  and finishing industry is a highly competitive industry.
Competition exists not only within the United States, but also from a vast overseas
leather industry. Over 50 percent of the leather imported to the United States is from
the countries of Argentina, Italy, the United Kingdom, Brazil, and Thailand.7
                                      2-5

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            Table 2-2.  United States Production of Cattlehide Leather
                           Unit - 1,000 Equivalent Hides

1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
WETTINGS
14,948
15,581
15,105
15,456
14,029
12,616
12,598
12,754
11,475
11,242
13,018
13,021
PRODUCTION
14,790
15,520
15,028 .
15,430
14,021
12,550
12,497
12,846
11,569
11,329
13,175
13,042
DELIVERIES
14,816
15,461
15,053
15,427
13,971
12,556
12,603
12,914
11,548
11,443
13,291
13,261
Source:  U.S. Leather Industries Statistics,  1992 Edition.

Note: Wettings refer to the number of hides soaked in the wet ends process. Production
refers to finished hides, while deliveries refer to the number of finished hides shipped to
customers. Deliveries can exceed production in a given year if hides finished in one year
are not shipped to customers until later years.
                                       2-6

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            Table 2-3.  Tanners' Stocks of all Cattlehide and Leathers
                           Unit - 1,000 Equivalent Hides
                           (Stocks as of December 31)

1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
RAW
870
990
1,140
1,160
1,070
487
51
356
348
377
787
928
1,323
1,491
1,584
1,638
2,210
3,399
NR
PROCESSED
2,258
2,362
2,230
2,229
2,304
2,133
2,015
2,162
2,210
2,294
2,319
2,328
2,396
2,450
2,470
2,318
2,229
2,072
2,058
FINISHED
908
975
568
745
654
672
657
534
590
535
563
535
457
406
418
392
390
397
413
TOTAL
4,036
4,327
3.938
4,204
4,028
3,283
2,723
3,052
3,148
3,206
3,669
3,791
4,176
4,347
4,472
4,348
4,829
5,868
NR
Source: U.S. Leather Industries Statistics, 1992 Edition.

Note:  Inclusion of raw stocks in this summary report was discontinued in 1991 due to
insufficient data.
                                      2-7

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2.2 References

1.    U.  S.  Industrial  Outlook,  1991.   United  States  Department of Commerce,
      International Trade Administration.

2.    1991 International Leather Guide.

3.    Science Applications International Corporation.  Assisting the New England States
      in Implementing Reasonably Available Control Technology  at Leather Finishing
      Plants.  Final  Report submitted  to the U. S. Environmental Protection Agency,
      Office of Air Quality Planning and Standards. July 31, 1992.  Appendix B.

4.    Telecon. Mitsch, B.F., Alpha-Gamma Technologies, Inc., with Rutland,  F., Leather
      Industry  Research  Laboratory.   March  3,  1993.   Clarification of information
      collected regarding the leather tanning and finishing industry.

5.    Reference 4.

6.    U. S. Leather Industries Statistics. 1992 Edition.  Leather Industries of America Inc.
      Washington, D. C.

7.    Reference 6.
                                       2-8

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         3.0  LEATHER TANNING AND FINISHING PROCESSES
      Hides and skins from many animals can be tanned and" finished. These animals
include cattle, sheep, goats, pigs, deer, horses, and reptiles.  In order to simplify the
description of the tanning and finishing process, the discussion in this section focuses
on cattle hides used to produce leather used for upholstery, footwear, and other
fashion goods.

      Production of finished leather is a complex procedure that includes many
chemical and physical processes.  These processes are interrelated and each can
have an effect on the characteristics of the finished leather. In this section, the
chemical and mechanical processes used to produce finished leather will be
discussed. A process flow diagram is provided in Figure 3-1.

      Leather tanning and finishing processes can be divided into wet operations and
dry operations.  The wet operations include all of the processes required for leather
tanning.  These processes include steps to purify and stabilize the collagen content of
the hide.  Collagen is the protein responsible for the strength and toughness of
leather.  Dry operations consist mostly of processes that enhance the natural
characteristics of the leather.  Dry operations include the leather finishing processes
which are responsible for most of the VOC and HAP emissions.

      Each of the major wet and dry operations are discussed below. The
information provided in the following sections was drawn from three primary sources:
a) the Kirk-Othmer Encyclopedia of Chemical Technology;1  b) Ullman's Encyclopedia
of Industrial Chemistry;2 and c) Leather Facts.3

3.1    Wet Operations

      Historically, wet operations have been divided into three phases: a) the
beamhouse; b) the tanyard; and c) the coloring department which includes the
retanning, coloring, and fatliquoring operations. The term beamhouse was derived
from the way that hides were prepared for tanning using a beam or log to support the
hide while it was hand treated. The tanning process was conducted in open pits often
dug in the ground.  Although modern tanneries have more advanced equipment for
processing hides, the terms beamhouse and tanyard are still used.  Figure 3-1 uses
these terms in showing the flow through the tanning and finishing process.
                                      3-1

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       Raw cured hides arrive at a tannery from slaughter houses and meat
processing plants. The hides are generally preserved following slaughter to prevent
putrefaction.  The most common method for preserving a hide is through brine curing.
Hides are placed in large vats containing a concentrated salt solution and soaked for
up to 24 hours.  After the hides are removed from the vat, dry salt is added and the
hides are bundled for shipment to the tannery.

       Upon arrival at the tannery the hides are sorted and weighed.  Most hides have
been fleshed by the slaughter houses.  Fleshing is the removal of excess flesh and
fatty material from the hide.  In cases where the hides have not been fleshed, fleshing
is conducted prior to the hides entering the leather manufacturing process.  This
process begins with a series of wet operations.

3.1.1  Soaking

      The objective of the soaking process is to remove salt and restore moisture lost
as a result of salt curing. The soaking process involves placing the hides in large
mixing drums containing water and chemical additives (Figure 3-2). The hides are
constantly moved in the drums to ensure flexing of the hides and absorption of
moisture.  The chemical additives include wetting agents and disinfectants that
facilitate the remoisturizing process and clean the hides.

      The soaking process can take from 8 to 20 hours depending on the thickness
of the hides.  Following soaking, fresh water is introduced to the mixing drums while
the water used for soaking is continuously  removed. This wash cycle  removes excess
salt, dirt, and biological debris from the  drums.

3.1.2  Unhairing

      The unhairing process takes place in the same drums or vessels used for
soaking.   Unhairing  is usually accomplished using chemicals. Concentrated solutions
of calcium hydroxide and sodium sulfide are added to the drums containing the  hides
and water. The objective of the unhairing process is to remove hair, loosen the  outer
layer of the skin covering the grain of the hide (the epidermis), and remove soluble
skin protein.  Care is taken during this process to avoid damaging the  collagen fibers
of the hide.  Collagen fibers are the essential component of leather.

      The chemicals used in the unhairing process raise the pH of the hides and
cause the hides to swell. Hides may swell to twice their normal thickness during
unhairing.
                                      3-3

-------
Figure 3-2. Mixing Drum Used in Soaking and Unhairing
                         3-4

-------
3.1.3 Bating

      Bating takes place in cylindrical drums with hollow axles (Figure 3-4).
Chemicals and water are introduced through pipes inserted into the hollow axles of the
drums.  The objective of the bating process is to remove the alkaline chemicals that
were used in the unhairing process, and remove remaining undesirable components in
the hide.

      Once the pK of the hide has been adjusted using chemical additives such as
ammonium sulphate or ammonium chloride, animal enzymes are added to the drum.
These enzymes are referred to as the bate.  The enzymes act ta destroy hair roots
and pigments remaining in the hides. The result of the bating process is a cleaner,
softer hide that is nearly ready to be tanned.

      In the case of pigskin and sheepskin, an  additional chemical step is employed
following the bating process.  Pig and sheep skins contain excess fats and greases
that must be removed prior to tanning.  Degreasing using solvents is one method of
extracting these unwanted components  of the hide.  Solvent degreasing is
accomplished by exposing the hides to  a solution containing  solvents and  surfactants.
Commonly used chemicals used for solvent degreasing include kerosene,  stoddard
solvent, nonionic and anionic surfactants, and solvents such as trichloroethylene and
perchloroethylene. Since volatile compounds are used for degreasing, this process is
a potential source of VOC emissions.

3.1.4 Pickling

      Prior to tanning, the pH of the hides must once again be adjusted.  The
objective of the pickling process is to lower the pH of the hides using salts and acids.
Pickling is accomplished in the same drums used for  bating and usually takes only a
few hours to obtain full penetration of the chemicals into the hides.

3.1.5 Tanning

      The objective of the tanning process  is to stabilize the collagen fibers in the hide
so that they are no longer biodegradable.  It is the tanning process that produces the
substance known as leather. The most  common method of tanning used in the
United States is referred to as chrome tanning.  Over 90 percent of the leather
produced in this country is chrome tanned.   Chrome tanning  is the preferred method
because it can be accomplished in shorter time  periods than  other methods such as
vegetable tanning, mineral tanning, and  resin tanning. Chrome tanning also produces
leather that is highly stable and serviceable  in use.

      The tanning process takes place  in the same drums used for bating and
pickling.  Tanning is complete in about 4 to  6 hours.  The tanned hides are removed


                                     3-5

-------
Figure 3-3. Drum Used for Bating, Pickling, and Tanning
                         3-6

-------
from the drums and placed in boxes located beneath the drums.  The boxes have
porous bottoms that allow excess tanning solution to be drained from the hides.
Hides that have been chrome tanned have a characteristic blue color, and are referred
to as "blues" or "wet blues."

      There are some chromium emissions generated by leather tanning and
finishing.  In the Toxic Release Inventory data presented in Section 4.0, some
tanneries report small quantities of chromium air emissions.  It is uncertain whether
these emissions are generated by the actual tanning process or by subsequent
operations.

3.1.6 Trimming and Siding-

      Following tanning, hides are removed from the mixing drums and prepared for
additional mechanical operations. Undesirable portions of the hide are trimmed using
hand knives. As shown in Figure 3-4, the head (section A) and belly portions
(sections F or G) are trimmed. These areas of the hide do not make good leather and
can interfere with some tanning and finishing equipment.

      The siding operation involves cutting the hides mechanically from head to tail
along the backbone.  This creates a left side and a right side, both of which are
referred to as a "side" of leather. From this point, many tanneries process sides as
opposed to the whole hide.  However, tanneries that produce leather for upholstery
products do not cut the hide into sides.  They process the whole hide.  Tanneries that
process sides are referred to as side leather tanneries while those that process the
whole hide are referred to as whole hide tanneries.  For the purposes of simplicity, the
word "hide" will be used generically while discussing the remaining tanning and
finishing processes in this section.

3.1.7 Splitting

      Following the tanning process, excess moisture is removed from  the hides
using mechanical devices. Wringing machines similar to a clothes wringer are used to
squeeze excess moisture from the hides.  Demoisturizing can also be accomplished
using vacuum presses, but this method of demoisturizing is more time consuming
than using wringers.

      The tanned hides are now ready to be split. The thickness of hides is highly
variable. In fact, the thickness of the various parts of a single hide may vary
significantly.  A splitting machine is used to correct the thickness of the hides. Splitting
creates  a uniform thickness across an entire hide, and also allows the tannery to
produce hides of different thicknesses depending on the requirements of the leather
product being  manufactured.
                                      3-7

-------
Head = A
Shoulder = B or C
Bend = D or E
Belly = F or G
Side = A+B + D + F or
Crop = A+B + D or
Back = B + D or C-t-E
Croupon = D+E
        Figure 3-4. Sections of a Cattle Hide Used for Leather Making

-------
      The splitting machine cuts the hides laterally, producing a top layer and a
bottom  layer.  The top layer or grain portion of the hide will have a uniform thickness.
This portion of the hide is the most desirable portion for producing leather. The
bottom  or flesh layer will have varying thicknesses and is referred to as the "split."
Splits can be used to make suede leather or can be used to make products such as
leather dog bones. Some tanneries sell the splits in the wet blue stage to other
tanneries or manufacturing facilities that make these products.  Figure 3-5 shows a
splitting machine.

      Following splitting, additional shaving of the hide is performed to ensure uniform
thickness prior to the final wet end processes.

3.1.8 Retanning

      Up to this point, most of the wet end processes are standardized throughout
the industry.  The wet blue hides that result from chrome tanning are sold in
commodity markets throughout the world and have relatively consistent characteristics.
The next three wet end processes begin to impart unique characteristics to the leather.

      The first of these processes is referred to as retanning.  Retanning is
accomplished in the same type of drums used in the initial tanning process.
Vegetable,  mineral, or synthetic agents are used in the retanning process.  The
objective of retanning is to begin developing the end use properties of the leather.
The retanning process helps to soften the leather and can bleach out the bluish color
left by the initial tannage.  Retanning  takes about 1 to 2 hours.

3.1.9 Coloring

      Following retanning, the hides remain in the same drum and are colored using
a wide range of chemical dyes. The dyes used  in the coloring stage reflect the colors
desired  in the finished product. There are hundreds of dyes and other products that
can be used to color leather.

3.1.10 Fatliquoring

      The final wet chemical process is known as fatliquoring.  In the fatliquoring
process, animal, vegetable, and mineral fats and oils are added to the drums
containing the hides.  Since these substances are not soluble in water, chemical
additives are used to allow dispersal. The type and amount of fatliquor influences the
softness of the finished leather.
                     4
      After fatliquoring, the leather is mechanically stretched, smoothed, and
compressed to remove excess moisture. At this  point, the hides have a moisture
                                      3-9

-------
a = unsplit hide
b = grain layer
c = flesh layer
d = cutting knife
              Figure 3-5.  Splitting Machine
                          3-10

-------
content of about 60 percent and are ready for additional processing in the dry end
operations.

3.2    Dry Operations

       After passing through the beamhouse, tanyard, and coloring operations, the
leather manufacturing process moves to the finishing room. In the finishing room, dry
operations are conducted such as drying, conditioning,  staking, buffing, and finishing.
The objective of these dry operations is to produce a product that has uniformity,
appearance characteristics, and resistance to scuffing and abrasion desired in a
commercial product such as upholstery or footwear.  Each of the primary dry
processes are discussed below.

3.2.1  Drying

       The moisture content of the leather is reduced using various  methods.
Typically, the drying process reduces the moisture content from about 60 percent to
nearly 10 to 15 percent.  Hides that have been dried are referred to as crust leather.
The four commonly used methods of drying leather are  hanging, toggling, pasting,
and vacuum drying.

       Hang drying involves hanging the leather over horizontal bars and hanging in a
drying loft.  In toggle drying, the leather is stretched over a frame and secured with
toggles.  One hide can be secured to each side of the frame, and then the frames are
slid into channels in the drying oven.

       In paste drying, hides are attached to flat plates using a paste solution.
Operators stretch and smooth the hide to the plate using manual instruments.  One
hide is pasted to each side of the plate, and the plates move into the drying oven on
conveyors.  The drying time for hang drying, toggle drying, and paste drying is about
4 to 7 hours.

       Vacuum drying is the fourth type of drying.  In vacuum drying, the hide is
placed on a heated steel plate then covered by a perforated steel plate wrapped  by a
felt of cloth. A vacuum is pulled on the hide thereby extracting the moisture.  Vacuum
drying takes about 3 to 8 minutes. The hides must be manually placed on the plates,
and only a small number of hides can be dried at any given time.  Vacuum drying is
typically used as a supplement to other drying techniques.

3.2.2 Conditioning
                                                       4
       Following the drying step, the leather is generally  suitable for finishing.
However, the drying operation can render leather too hard  for specific uses such as
footwear and garments. The objective of the conditioning step is to remoisturize  the


                                      3-11

-------
leather by applying fine mists of water to the surface, and allowing the moisture to
seep into the leather during overnight storage. The moisture content following
conditioning is about 15 to 25 percent.

3.2.3 Staking and Milling

      The purpose of staking and milling is to mechanically soften the leather.
Staking (along with fatliquoring) is responsible for the softness of the finished leather.
Staking and milling can be accomplished by two methods. The first method involves
mechanical softening using an automatic machine that flexes and stretches the leather
using a series of oscillating pins (Figure 3-6).  The second method, referred to as dry
milling, is similar to using a clothes dryer in a domestic household.  Previously dried
leather is placed in a large drum where it is tumbled as necessary to achieve the
desired softness.

3.2.4 Buffing

      The final dry process prior to finishing is the buffing operation. The objective of
buffing is to smooth the grain of the leather to enhance the finishing process.  Buffing
is achieved using a sanding cylinder that is covered with an abrasive material  similar to
sandpaper. Operators control the degree of buffing for a particular type of leather.
The buffing process produces leather that has a smooth, relatively uniform texture.
Leathers that are not buffed are referred to as full grain leathers.

3.3   Leather Finishing Operations

      Leather finishing is an additional dry operation that is discussed separately
because of the significance of this process in the production of VOC and HAP
emissions. The objective of leather finishing is to enhance the appearance of  the
leather and to impart stain  and abrasion resistance qualities to the material.

      Leather finishing involves an almost limitless combination of options.
Depending on the specific  end use of the leather, a variety of coatings can be applied
during the finishing process using a number of different application methods.
Typically, 3 to 5 coats  of finish are applied to  the leather although the actual number of
coatings can vary depending on the desired characteristics of the end product.

3.3.1 Coatings Used  for Leather Finishing

      Coatings can be categorized into three general classes:  base coats,
intermediate coats, and top (or finish) coats.  Characterization of all coatings into just
three classes is somewhat of an oversimplification. However, these classifications are
commonly used in the industry.  Base coats are  used to smooth out the leather
surface by covering up faults in the leather grain, staining or coloring the leather, and


                                      3-12

-------
      a = leather
      b = metal pin
      c = vibrating plate
      d = foamed rubber plate
      e = guide lever
      f = guide roll
Figure 3-6.  Staking Machine with a Vibrating Plate (A) or Lever (B)
                               3-13

-------
serve as a penetrating or flow aid.  Intermediate coats can also be used to impart
color or stains to the leather and serve as an adhesive coating for the top coat. Top
coats are responsible for protecting the leather from abrasion and give the leather
desired properties  such as resilience and gloss.

      Coatings can also be referred to by function.  Functional classifications were
used in the NESCAUM report on the leather finishing industry.4 Functional
classifications include impregnation, base coat, top coat, water proofing, stain, and
antique coats. Impregnation refers to  a heavy coating applied prior to the base coat
that serves as a primer coating for subsequent coating applications.  A water-based
material is usually used for impregnation. Waterproofing is usually considered a
separate process from finishing, and involves application of silicones or other water
resistance chemicals. Finally, antiquing can be a manual or machine applied coating
used to impart special effects on the leather.

      Hundreds of coating formulations are available for base, intermediate and top
coats. Each  coating formulation has unique chemical and physical characteristics and
is applied as  needed to  meet end-use requirements of the leather. Coating
formulations can be classified into one of three categories: lacquers, lacquer emulsion,
and water-based coatings. Although there are no strict definitions for each of these
categories, it is generally accepted that lacquers are the higher VOC-laden coatings,
lacquer emulsions  contain a mid-range of organic solvents, and the water-based
coatings contain the  lowest concentrations of VOC's.

      Until a decade ago, lacquers were the predominant type of coating formulation
used in leather finishing.  These resin-based coatings contain approximately 70-95
percent organic solvents by weight. The remaining material  are solids such as
pigments and additives. The pigments are finely divided organic or inorganic material
that impart color. The additives, usually organic resins and polymers, serve as a
binder between the pigment and the leather substrate and give the coating desired
characteristics such as gloss and scuff resistance. Lacquer  coatings have several
unique properties such as low surface tension, excellent flow properties, and quick
drying times.  However,  the solids-carrying capacity is considered low,  usually 5 to 10
percent.

      Lacquer emulsions are formulations with properties between those of lacquers
and water-based coatings. These coatings  are similar to lacquers as approximately 60
percent of the solution is organic solvents.  However, additives such as surfactants are
used to make the coating solids water-miscible. The leather finisher then dilutes the
material with water in appropriate amounts and the final emulsion may contain
between 20 and 30 percent water.  Lacquer emulsions have about the  same solids-
carrying capacity as lacquers.
                                      3-14

-------
      Water-based coatings typically contain less than 10 percent organic solvents,
and have become more popular over the last decade as formulation technology has
developed and the characteristics of these materials have improved.  Their popularity
is due in part to the reduced VOC emission characteristics, their increased solids-
carrying capability, and subsequent improvements in the working environment by
minimizing the use of organic solvents.

      Table 3-1 shows a comparison  of chemical characteristics of lacquer, lacquer
emulsion, and water-based coatings.58 Table 3-2 gives a comparison of the typical
composition of lacquer and water-based top coat formulations.  There is a trend in the
industry towards increased use of water-based coatings.  Currently, most base
coatings are water-based formulas and some intermediate and top coatings are also
water based. Table 3-3 shows the increased sales of water-based coatings by a
major coatings supplier to the leather industry.7  Conversations with various industry
representatives confirm this trend.

      Water-based coatings have the  advantage of being able to hold more solids in
the primary solution (water). As compared to lacquers, water-based coatings can hold
about 50 percent more solids by weight.  These properties are important in base and
intermediate coatings where less water-based coatings need to be applied than
comparable lacquers. Since gloss, resiliency and other surface characteristics are of
less concern at these earlier coating applications, water-based materials are suitable
for many types of leathers.

      The transfer efficiency of solids  also increases with the use of water-based
coatings.  Because of the  high-solids content and low volatility of water-based
coatings, the amount of coating used decreases. This can offset some of the costs
associated with moving from lacquer to water-based formulations.

      The reduction in VOC content has several major advantages from an
environmental and safety perspective.  The use of water-based coatings not only
decreases VOC emissions, but usually minimizes HAP emissions associated with many
lacquer  formulas.  Use of water-based coatings also improves the working
environment by limiting the use of toxic and flammable chemicals.

      Despite the  advantages, water-based coatings present a variety of problems,
particularly when used as top coats. The physical properties of water-based top coats
affect flow control of the coating during application.  This can affect the  gloss, water
resiliency and scuff-resistance of the final product.  Many water-based top coats also
require intermediate cross-linking agents to adequately bind the base  coat and top
coat. Several of these cross-linking agents are also toxic.  Finally, the leather takes
longer to dry using water-based coatings.
                                      3-15

-------
           Table 3-1.  Comparison of Lacquer, Lacquer-Emulsion
                   and Water-Based Top Coat Systems


Property

Application
Solids (%)
Wt.% Solvent
(as applied)
VOC (#/gal. less
water supplied)
Gallons to Finish
100 Sides
Pounds Organic
Lacquers

5-15

75-95

5.0-6.5

9

46.4-61.8
Lacquer
Emulsions
5-20

40-60

5.0-6.5

7-

22.8-30.9
Water-Based
Coatings
20-30+

5-15

0-3..0

4.5

0-4.0
Solvent Emitted per
100 Sides
                                 3-16

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                  Table 3-2. Generic Coating Formulations
LACQUER
WATER-BASED
Organic Solvents

Binders
Plasticizers

Pigments

Other Additives
 Conditioners
 Silicones
 Dulling Agents
 Feel Modifiers
Water

Organic Solvent or Coalescents

Binders

Surfactants

Pigments

Other Additives
 Leveling Agents
 Penetrators
 Thickeners
 Fillers and Dulling Agents
                                    3-17

-------
            Table 3-3. Top Ten Products by Year and VOC Content
         (Alpha-Numeric Characters Represent Product Formulations')
1986
D**
I**
G**
L
£**
V
M
K
F**
H**
Average VOC
Content
# of VOC-based
products in top ten
%
VOC
92.7
88.7
81.8
0.0
85.4
7.2
0.0
0.2
82.2
95.9
53.4
6

1989
S
W
I**
E**
AA
N
O
P
A
9
M



%
VOC
7.7
9.9
88.7
85.4
48.6
4.0
0.0
4.1
4.6
0.0
25.3
2

1990
S
W
I**
T
B
AB
O
Q
M
U



%
VOC
7.7
9.9
88.7
11.9
10.0
48.5
0.0
4.0
0.0
11.8
19.2
1

1992
W
X
R
O
C
AC
Y
J
S
z



% VOC
12.1
13.0
8.9
0.0
8.3
47.8
6.1
0.0
7.7
13.9
11.8
0

**
Each letter or group of letters depicts a different product sold to the leather
finishing industry during that year.

Indicates Organic Solvent-Based  Finishing System Component
                                    3-18

-------
       Some of the problems experienced with water-based top coats are the result of
the unique properties of water rather than the types of polymers used.  For example,
the surface tension of water is one factor that causes problems with water-based top
coats. Table 3-4 shows the surface tensions of various solvents, with water topping
the list. Figure 3-7 shows a comparison of contact angles with aqueous and with
organic solvent-containing lacquers when they are applied to the leather surface.  If
the contact angle is less than 90 degrees, as with water, the liquid beads up and does
not spread spontaneously over the surface. This property of water leads to
considerable problems with spreading and levelling of aqueous-based top coats.8  In
a recent survey conducted for EPA,  the leather finishing industry indicated that poor
flow characteristics were considered the number one problem of water-based coats.9

       Drying times are also an important cost factor for leather finishing.  The
increased drying times resulting from the use of water-based coatings is reflected in
costs such as labor,  energy requirements of ovens,  the number of ovens, space
requirements,  and inventory requirements. Finally, use of water-based top coats can
present problems with meeting market demands.  For example, shoe manufacturers
that apply additional finishes to the shoes need to have leather finished with a coating
compatible with their finish coating material. In addition, some water-based top coats
do not provide the desired look and feel desired  by  many end-users.

3.3.2 Application Methods for Leather Finishing

      There are three common methods of finishing leather. These methods Sre
spray coating, roll coating, and flow  coating.  Spray  coating is the most prevalent in
the leather tanning and finishing industry. Spray coalers can consist of rotary
sprayers, oscillating sprayers, stationary sprayers, or hand spray operations.

3.3.2.1  Spray Systems

      The most commonly used spray system in leather finishing is the rotary spray
machine.  The rotary sprayer consists of a series of  spray arms each having a spray
gun  located at the extremity of the arm.  The  spray arms are mounted on a central
shaft that rotates as the leather passes underneath on a conveyor.  Coatings are fed
to the spray guns through a vacuum hose immersed in a drum or other vessel
containing the coating.

      Most rotary spray machines are controlled by optical scanners and
microprocessors that minimize overspray. The leather passes through the optical
scanner prior to entering the spray booth. The scanner records the outline of the hide
and electronically triggers the spray guns to optimize the amount of coating that
contacts the hide.  Rotary spray machines can have 4, 8, or 16 guns. The 4 and 8
gun machines  are typically used to spray side leather while 16 gun machines are
better suited to spraying full hides.


                                      3-19

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            Table 3-4. Surface Tensions of Various Solvents
SOLVENT                        SURFACE
                                TENSION
                                (dynes/cm)
WATER                          73
ETHYLENE GLYCOL                 48
CYCLOHEXANONE                 35
XYLENE                          30
ETHYL GLYCOL                    28
TOLUENE                        28
METHYL ETHYL KETONE             25
MINERAL OIL                      30
SILICONS OIL                      23
                              3-20

-------
 Contact Angle <90 degrees
                   Substrate: Leather with Grounding
   Contact Angle >90 degrees
                              Top Coat
                   Substrate: Leather with Grounding
Figure 3-7. Contact Angles of Aqueous and Organic Leather Coatings on a
                           Leather Substrate
                                  3-21

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      Figure 3-8 shows a typical rotary spray booth.  Drying ovens usually follow each
spray booth used in the finishing system. Various types of drying ovens are used in
the industry.  Examples of drying ovens include catalytic ovens, steam-heated ovens,
and gas-fired ovens. Both the spray booth and the drying oven are typically enclosed,
either partially or fully.  High volumes of air are typically exhausted from the spray
booths and dryers to provide worker protection and prevent development of explosive
mixtures.

      Other types of spray machines used in finishing leather include the oscillating
spray machine, the stationary spray machine, and the hand operated spray gun.  The
oscillating spray machine consists of a single arm that swings back and forth as the
leather passes underneath.  The angle of the spray gun can be adjusted to impart
unique characteristics on the leather. Stationary spray machines consist of a series of
spray guns that  remain in place as the leather passes underneath.  Both of these
types of spray machine can also be optically controlled.

      Finally,  hand operated spray guns are used for various purposes in finishing
leather.  In larger facilities, hand operated spray guns are used for touch up, special
effects, and testing of coatings for texture and color.   In some of the smaller facilities,
hand operated spray guns may be the primary method of finishing the  leather.  Spray
booths used for manual spraying are usually enclosed on three sides and vented
through an exhaust system.

      Various types of spray guns can be used with each of the spray systems
mentioned above.  The design of the spray gun can influence the transfer efficiency of
the coating. The types of spray guns used in leather finishing include:  conventional
air spray guns; airless spray guns; air-assisted airless spray guns; and high volume
low pressure spray guns.  These different spray guns are discussed in greater detail in
Section 5.0.

      All of the spray machines are usually equipped with some type of system to
catch overspray and control particulate air emissions.   One method used to catch
overspray is the placement of a water bath or plastic sheet beneath the conveyer
moving the hides through the machine. Overspray is  captured by the water or plastic.
In some cases, coating caught by a plastic sheet can be placed back in the coating
drum and resprayed.

      Water curtains are the most commonly used technique to control particulate
emissions. The  spray booth is kept under negative pressure and the exhaust is
collected and vented through ductwork to either an additional pollution.control device
or the atmosphere. The exhaust passes through a water curtain that absorbs the
particulates in the gas stream. Although water curtains are used by most facilities, dry
filters can also be used for particulate control.
                                      3-22

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Figure 3-8. Rotary Spray Booth and Drying Oven
                     3-23

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3.3.2.2  Roll Coating Machines

      Roll coating machines have limited use in leather finishing because of the
relative thickness of the coating applied by this method.  Roll coating is usually used
to apply base coats that are relatively thick.  In roll coating, the coating is applied
directly from a rubber coated or steel roller.  The coating is fed to the roller using a
vacuum hose connected to a reservoir of coating  material. The coating is picked up
by the roller and transferred to the leather.
                                                  »
      One advantage of roll coating is that there is no overspray so transfer
efficiencies approach 100 percent. The disadvantages of this technology are the
potential for uneven application of the coating, lack of penetration, and  bunching of the
leather as it passes through the rollers.

      Roll coating machines can  be either direct roll or reverse roll machines.
Rgure 3-9 shows a typical direct roll coating machine. Figure 3-10 shows a reverse
roll coating machine.

3.3.2.3  Flow Coating Machines

      Flow coaters, or curtain coaters, can be used to deliver a heavy  coating to the
leather.  In a flow coater, the coating is applied to the leather by controlled pouring of
the coating directly to the leather  surface.  For example,  in one type of flow coater, the
coating flows from a reservoir over a thin barrier in a  motion resembling a waterfall.
Because of the nature of the application method, the  transfer efficiency  of flow coating
is close to 100 percent. Figure 3-11 shows a typical flow coater.

3.4   Additional Dry Operations

      Following the finishing process, there are a number  of additional  dry operations
prior to shipping the finished leather to the end user.  These additional operations
include plating, grading, and measuring.

      The plating process is used to either smooth the surface of the finished leather
or to impart grain textures using mechanical processes.  Plating is accomplished by
presses capable of applying high  pressure to the leather. The presses  can be either
manually or automatically operated.  The action of the plating process is similar to that
of an iron press in a commercial laundry. The high pressure applied to the leather can
simply smooth out the surface of  the leather or dye cast plates can be used to create
patterns in the leather.   Plating is  used to simulate animal characteristics such as
snake skin or to emboss patterns typically found in automotive leather.

      Following plating, the leather is graded and measured.  Leather is graded for
feel,  uniformity of color, thickness, and the presence of defects.

                                      3-24

-------
a = coating
b = application roll
c = transport roll
d = scraper
e = leather
f = conveyor belt
g = roll for distributing the coating
       Figure 3-9.  Direct Roll Coating Machine
                          3-25

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                                          Applicator Roll
                                                   \
Into Oven
       Applicator Roll
Pickup Roll
    Pickup Roll
                 Figure 3-10.  Reverse Roll Coating Machine
                                     3-26

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Figure 3-11. Flow Coating Machine
               3-27

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3.5   Waterproofing Operations

      Waterproofing is treated as a process separate from typical wet and dry
operations.  Waterproofing is a specialty process that is used for specific products and
is also a source of VOC and HAP emissions.  Although the term waterproof is
commonly used, there are actually three separate properties that can be imparted on
the leather.  These properties are water penetration resistance, water absorption, and
water repellency.  The methods used to achieve these properties are different.

      Water penetration resistance refers to the ability of water to  penetrate through
the thickness of leather during flexing.  This is a specific property required in military
combat boots, some work boots, and recreational footwear. The only available means
of achieving required levels of water penetration resistance is by silicone impregnation
using a flow or curtain coater.

      Water absorption properties are also required in military combat footwear as
well as some domestic footwear leathers.  This  property can be achieved by silicone
impregnation and also through the use of hydrophobic retanning in the wet end
process.  Depending on the degree of water absorption required, water  absorption
can be achieved using either technology.

      Finally, water repellency is a  surface phenomenon that can be achieved through
conventional finishing technology. Repellency is obtained by putting  a suitable barrier
on the surface of the leather and is not dependent on the properties  of the crust
leather. All three of these technologies are used to produce different types of leather
products. Often, more than one technology is used in combination.

3.5   References

1.    Kirk Othmer Encyclopedia of Chemical Technology.  Third  Edition,  Volume 14.
      John  Wiley and Sons.  New York, New York. 1991.

2.    Oilman's Encyclopedia of Industrial Chemistry. Fifth Edition, Volume A15.

3.    Leather Facts. Booklet published by the New England Tanner's  Club, PO Box 371,
      Peabody, MA 01960.

4.    Science Applications  International Corporation.  Assisting the New  England States
      in Implementing Reasonable Available Control Technology  at Leather Finishing
      Plants.  Final  Report submitted to the U. S. Environmental Protection Agency,
      Office of Air Quality Planning and Standards. July 31, 1992.

5.    Walther, W.  All-Aqueous Systems for Leather, Problems and Solutions. Journal
      of the American Leather Chemists Association. Volume 83,  p  74. 1988.
                                      3-28

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6.     Biles, J.  Parameters in the Application of Water-based topcoats.  Journal of the
      American Leather Chemists Association.  Volume 85. 1990.
7.     Letter and attachment from Ossoff, S.B.,  Stahl USA to Mitsch, B.F.,
      Alpha-Gamma Technologies, Inc.  Februarys, 1993.
8.     Reference 6.
9.     Reference 4.
                                    3-29

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                4.0  CHARACTERIZATION OF EMISSIONS
      This section includes a discussion of the sources of VOC and HAP emissions
from leather tanning and finishing and the factors affecting emissions. In addition,
plant-specific and industry-wide VOC and HAP emissions are quantified using existing
emissions data.

4.1   Sources of VOC and HAP Emissions

      There are a number of sources of VOC  and HAP emissions in the leather
tanning and finishing process. The major sources of emissions are:

      a)    Leather finishing operations;

      b)    Waterproofing operations;

      c)    Solvent degreasing operations; and

      d)    Miscellaneous fugitive sources.

      Table 4-1  lists the air pollutants emitted from leather tanning and finishing
operations.  These chemicals were identified in the Toxic Release Inventory (TRI) for
the years 1987-1990, and also in data obtained from operating facilities.  Both VOC's
and HAP's are listed in the table.  Table 4-2 shows the relative contribution of air
emissions from the beamhouse, tanyard, and finishing operations.1  With the exception
of solvent degreasing, all of the major sources  of emissions listed above are part of
the finishing operation. As shown  in the table,  finishing operations are the major
source of VOC's in the leather tanning and finishing industry.  The data in the table
also indicate that the greatest producer of VOC emissions is the spraying of VOC-
laden coatings in the finishing process.  Each of the major sources of VOC emissions
are discussed separately below.

4.1.1  Leather Finishing Operations

      Leather finishing operations are the single largest source of emissions in the
leather tanning and finishing industry.  In States that have regulations impacting the
industry, the regulations are directed specifically at the leather finishing operation.
                                      4-1

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         Table 4-1. Air Emission Compounds from Leather Facilities*
 Chemicals	Classification

 Acetone
 Cyclohexane
 Cyclohexanone
 n-Butyl Alcohol                         non-HAP VOC's
 Ethanol
 2-Ethoxyethanol
 Isopropyl Alcohol
 2-Methoxyethanol
 Naptha	         ^	

 Benzene
 Cumene
 Diethanolamine
 Ethylene Glycol
 Glycol Ethers
 Formaldehyde
 Methanol                              HAP VOC's
 Methyl Chloroform
 Methyl Ethyl Ketone
 Methyl Isobutyl Ketone
 Methylene Chloride
 Tetrachloroethylene
 Triethyl Amine
 Toluene
 Xylene (mixed)
 Chlorine
 Chromium
 Chromium Compounds                 non-VOC HAP's
 Hydrochloric Acid
 Manganese
 Manganese Compounds	

*     Sources include the TRI database, chemical industry, and the leather industry.
                                    4-2

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        Table 4-2. Emissions from Leather Processing Monitored
                   in the United Kingdom During 1990
   Source	Pollutant	Quantity (mg/m3)

   Crust Leather Operations

   Beamhouse     —               Hydrogen sulfide        up to 7.1  *
                                   Ammonia               up to 35.5  *

   Tanyard                         Ammonia               up to 14.2  *

   Finishing Operations

   Conveyorised Sprayer
   Water-diluted nitrocellulose         VOC                    7 to 800 **
   Solvent-diluted nitrocellulose       VOC                1200 to 3700 **

   Finish Dryer
   Water-diluted nitrocellulose         VOC                   nil to 100 **
   Solvent-diluted nitrocellulose	VOC	400 to 1200 **

*  Workplace levels, converted to mg/m3.
** Discharge to air via exhaust systems.
                                   4-3

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      As described in Section 3.0, leather finishing involves the application of various
coatings to the surface of the leather.  Typically, 3 to 5 coats are applied to any one
piece of leather. Various methods of application are used to apply the coatings with
spray coating being the most commonly used approach.  Other application methods
include  roll coating, reverse roll coating, and curtain coating.

      Figure 4-1 shows a typical rotary spray coating booth and drying oven.  Air
emissions result from the solvent flashing before the coating hits the surface of the
leather,  overspray of the coating, and bounce back of the coating from the surface of
the leather. Most spray coating booths are partially or fully enclosed.  Solvent vapors
are collected in the spray area and vented to the atmosphere or a control  device.

      Each spray booth is usually followed  by a drying oven.  Additional air emissions
are generated from the drying oven as a result of the drying and evaporation process.
The drying ovens are partially or fully enclosed and are usually vented to the
atmosphere or a control device. There is also a flash-off zone located between the
spray booth and the drying oven where VOC can be released to the air. The flashoff
zone between the spray booth and the drying oven may or may not be enclosed.

      High volumes of air are typically exhausted from the spray booths and the
drying ovens.  Dilute quantities of VOC's are present in the exhaust. Two  plants
visited during the course of this study vented the exhaust from the rotary spray booths
and drying ovens to a thermal incinerator.  Emissions testing conducted on the inlet air
to the incinerators showed VOC emission rates ranging from 120 and 370  pounds per
hour.2'3

      Other types  of spray booths are also sources of air emissions.  Hand spray
booths and oscillating spray booths produce emissions due to overspray, flash-off,
and bounceback.  Roll-coating machines and flow coating machines produce less
emissions because the transfer efficiency of the coating material is much higher.
Transfer efficiencies and a comparison of emissions potential of these spray machines
are discussed further in Section 5.0.

4.1.2  Waterproofing Operations

      Waterproofing is considered a separate operation from leather finishing.
Waterproofing involves treatment of the leather with a waterproofing agent  such as
silicone  or a fluorocarbon. Waterproofing agents are often applied using a curtain
coating  process that dispenses the agent in a solution  having "an organic solvent.
Emissions result from flashoff of the solvent during application and drying.  Air from
the waterproofing operation is typically collected and exhausted to the atmosphere.
                                      4-4

-------
      a = exhaust fan
      b = fugitive emissions from spray booth
      c = flash off zone
      d = fugitive emissions from drying oven
Figure 4-1.  Rotary Spray Coating Booth and Drying Oven Showing
                        Emission Points.
                              4-5

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      The emissions potential of the waterproofing process is high because of the
large amounts of organic solvent used to dispense the silicone material.  Data
obtained from industry sources indicate that VOC emissions from waterproofing range
from 12.3 to 27.8 pounds of VOC per 1,000 square feet of leather processed.

4.1.3  Solvent Oegreasing

      Solvent degreasing operations are used in a small segment of the industry in
the wet end processing of sheep and pig skins.  In solvent degreasing, solvents such
as perch loroethylene are used to reduce the skin grease content to desired levels and
evenly distribute the residual grease prior to tanning.  Emissions of VOC result
primarily  from evaporation as the degreasing drums are drained and the skins
unloaded.

      A study conducted in the United Kingdom generated emission estimates for the
degreasing operation. Measurements in the working area showed VOC
concentrations ranging from 600 to 700 mg/m 2.  Measurements of exhaust air from
the degreasing system during the airing  off cycle (draining and unloading of skins)
showed VOC concentrations ranging from 16,000 to 19,000 mg/m?5 Data provided
by the U. S. leather industry show  emissions resulting from the degreasing operation
to be about 12.4 pounds of VOC per 1,000 square feet of leather processed.6

      Typically, solvent degreasing operations are closed  loop systems where the
solvent is recovered.  Condensation recovery systems can reduce solvent loss by
about 90 percent compared to systems not having a recovery process. Carbon
adsorption systems are also used to recover solvent.7

4.1.4  Miscellaneous Fugitive Emissions

      There are a  number of sources of fugitive emissions in the leather tanning and
finishing industry.  These sources include:

      a)    Mixing rooms - the mixing room used to formulate the various leather
            coatings is a source of air emissions. Drums of coatings that are left
            open  can emit VOC and HAP emissions  through volatilization of the
            compounds.  In addition, normal handling, pouring, pumping, and mixing
            of the coatings can cause air emissions. Most leather finishing
            operations use a designated room  to mix finish coatings.  One facility
            estimates emissions from the mixing room to be about 10 tons per year,
            representing less than 0.5 percent  of the overall facility emissions.8

      b)    Coating drums - drums or other containers for the coating material" are
            placed next to the spray booths or roll coaters during the finishing
            process. The coatings are drawn from drums or other containers to the


                                      4-6

-------
             spray guns or rollers using vacuum pumps. These coating containers
             can be a source of fugitive emissions since they are often partially or fully
             open to room air.  Emissions enter the atmosphere with the normal
             building exhaust air.

      c)     Wastewater - wastewater can become contaminated with VOC and HAP
             laden material in a number of locations throughout a tanning and
             finishing plant.  Water curtains and water baths are used for particulate
             control and for catching overspray in the spray booths. Volatile organic
             compounds present in the wastewater can be emitted when wastewater
             is exposed to the ambient air in the collection and treatment system.
             One facility has measured the organic content  of the wastewater
             generated by the plant.  Total organic carbon (TOC) measurements were
             less than 10 mg/L9

      d)     Cleanup operations -  spray guns  can be cleaned using solvents
             containing VOC's. The emissions  potential of spray gun cleaning
             depends on whether the guns are  cleaned in a closed container or an
             open area.

      e)     Hand application of coatings - some finishing facilities apply coatings
             using hand application procedures. An example of a hand application
             operation is the antiquing process  used to impart special effects on the
             leather. Application of the coatings is usually conducted in an open
             space.  Fugitive emissions result from this operation due to volatilization
             of the coatings during application.  Emissions enter the atmosphere
             through the building exhaust system.

      f)      Drying operations - leather that has been finished is set out to dry prior
             to packing and shipping.  Residual evaporation and volatilization of VOC
             can occur during the drying process.  Again, emissions of VOC can
             enter the atmosphere through normal ventilation of the building air.

4.2   Factors Affecting VOC  and HAP Emissions

      There are both chemical and physical factors affecting emissions of VOC  and
HAP from leather tanning and finishing.  The primary factors affecting emissions  are
the following:

      a)    The VOC and/or HAP content of the leather coating;

      b)    The physical properties of the individual VOC or HAP  such as vapor
            pressure and boiling point;
                                      4-7

-------
      c)     The method of coating application (spray coating, roll coating, surface
             coating, type of spray guns) as it affects transfer efficiency;

      d)     Operator training; and

      e)     Maintenance and housekeeping procedures.

      The most important factor affecting emissions is the VOC/HAP content of the
coatings used to finish the leather. Significant reductions in emissions have been
reported through substitution of solvent coating systems with water based coatings.  A
detailed discussion of the emission reductions achievable through the use of water-
based coatings is provided in Section 5.0.

      There is very little quantitative data available to document the effects of most of
the other factors affecting emissions.  Estimates have been made of the difference in
transfer efficiencies between spray coating systems and  roll and flow coatings
systems.  The transfer efficiency of roll and flow coating  systems is close to 100
percent while efficiencies of spray coatings systems are estimated to be as low as 40
percent.

      In regards to spray coating systems, there is also a wide range of estimates
regarding the effects of different types of spray guns on  transfer efficiency. As will be
discussed in Section 5.0, the transfer efficiency of various spray guns can range from
15 to 90 percent.  Accurate quantification of actual effectiveness of the various guns is
difficult because of the numerous factors that can effect transfer efficiency.  Among
these factors are operator training and the solids content of the coating.

      Other factors that can affect transfer efficiency  of spray systems include the
type of spray controls used for the spray system (optical eye, pneumatic, or
mechanical controls), the number of spray guns, and the velocity of the rotary spray
arms and conveyor belt passing through the spray booth.  One study indicates that
the use of optical eye spray controls can increase transfer  efficiency by about 32
percent. x Conversations with industry personnel indicate that transfer efficiency is
affected by the number of spray guns operating on a rotary arm. The more spray
guns, the slower the rotor speed, and the greater the transfer efficiency.  A 16-gun
rotary sprayer can be more efficient than an 8 or 4-gun machine.X1

      Another factor in improving transfer efficiency is keeping the spray directed
vertically to the leather.  Rotary spray machines that are  rotating too fast can cause
the spray to "arc," creating a greater chance for bounceback. The speed of the
conveyor can also have a similar effect.

      Adequate operator training can optimize the effectiveness of the coating
operation.  A skilled operator can detect problems with spray guns, rotors speeds,


                                       4-8

-------
and conveyor speeds. Timely identification of inefficiencies with the coating operation
can minimize the amount of coating used and, therefore, reduce emissions.

       Finally,  good maintenance and housekeeping practices can reduce emissions.
Examples of these practices include keeping containers of solvent closed, maintaining
spray equipment to optimize operation, and closely monitoring overspray and other
waste  of material.

4.3   Volatile Organic Compound Emissions

       Data were collected from a number of sources in order to quantify the potential
of leather tanning and finishing facilities to emit VOC. These sources include the
Aerometric Information Retrieval System (AIRS),  State emission inventories and
permitting information, site visits, and information collected by the leather industry
trade association. Table 4-3 presents VOC emission factors for various facilities within
the industry.

      The range of emission factors presented in the table is indicative of the diversity
within the industry.  Emission potential varies from facility to facility depending on the
type of leather being manufactured. Emissions potential also varies among facilities
producing the same type of leather because of variations in the actual product mix and
the techniques used by each facility to meet the specifications of their customers.
Specialty operations such  as waterproofing and  solvent degreasing also increase the
emissions potential of individual facilities.

      Appendix A includes all  of the VOC emissions data collected during the study.
These  data were obtained from EPA data bases, State and local  agency inventories,
and permitting information. As shown in the Appendix, annual VOC emissions from
leather tanning and finishing facilities are extremely variable.  A small facility may emit
less than 1 ton per year while larger facilities may emit in excess  of 500 tons per year.
Table 4-4 shows the VOC  emissions from a representative number of facilities.

4.4   Hazardous Air Pollutant Emissions

      One of the objectives of this study was to quantify and characterize the
emissions of HAP's from the leather tanning and finishing industry. The CAAA require
EPA to publish a list of major and area sources for regulation that emit one or more of
the HAP's listed in Section 112(c) of the Act.  A major source of HAP's is defined by
Section 112(a)(1) of the CAAA as being a source that "emits or has the potential to
emit considering controls,  in the aggregate, 10 tons per year or more of any
hazardous  air  pollutant or 25 tons per year or more of any combination of hazardous
air pollutants."
                                      4-9

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                Table 4-3.  Representative Emission Factors for
                    Leather Tanning and Finishing Facilities
TYPE OF FACILITY
Upholstery
Footwear
Upholstery
Upholstery
Waterproofed Leather
Sheepskin
EMISSION FACTOR
Ibs VOC/1000 sq. ft.
3.2-4.8
8.1 - 36.1
9.1
47.7
12.3 - 27.8*
12.4"
**
Represents emissions from waterproofing operation only.
Represents emissions from solvent degreasing operation only.
Source:  Industry data.  Identification of facilities withheld for proprietary purposes.
                                      4-10

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                Table 4-4.  VOC Emissions from Representative
                    Leather Tanning and Finishing Facilities
FACILITY
Acme Sponge & Chamois
Horween Leather
Salem Suede
WD Byron & Sons
Prime Tanning
Lackawanna Leather (NC)
JBF Industries
Conneaut Leather
Garden State Tanning
Eagle Ottawa Leather
Seton Company (PA)
VOC EMISSIONS
(tons per year)
13.3
26.6
11.4
235.2
529.3
253.4
4.0
6.1
364.0
130.0*
120.0*
Note: Except as indicated, all data are for 1990. The source of the data is public
records obtained from State agencies or other sources.

*  1992 estimated data provided by the facilities.
                                     4-11

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      The most comprehensive data available for determining industry-wide HAP
emissions is found in the TRI.  For the leather tanning and finishing industry, the TRI
data can be considered relatively accurate information. In most cases, the emissions
data reported to TRI are based on solvent purchases and usage.  A material balance
approach is the most common method of determining emissions of HAP's. Assuming
that the record-keeping practices of the facilities reporting to TRI are reliable, the TRI
data provide a reasonably accurate summary of HAP air emissions from the industry.

      Seventeen major sources of HAP's have been identified in the industry.
Table 4-4 lists the major sources or HAP's.  It is estimated that the actual number of
major sources existing in 1993 is less than 17.  The trend in the industry is to convert
to water-based coatings in the leather finishing process and to reformulate coatings to
eliminate hazardous constituents.  The emphasis on water-based materials began in
1989, and many of the  reductions achieved by the transition  are not reflected in the
1990 TRI data.  Information obtained during  site visits, telephone conversations, and
through review of current literature indicates that HAP emissions are being reduced
industry wide.

      Rgure 4-3  shows the trends in nationwide HAP emissions from 1987 to 1990.
The upper line in  the graph represents data from all facilities  reporting to TRI in each
year (33 facilities). The lower line represents data for only those facilities that reported
emissions in each of the four years from 1987 to 1990 (23 facilities).  Although the
upper line shows a substantial increase in HAP emissions nationwide, it is primarily the
result of more facilities reporting to the data  base. The lower line is more indicative of
the actual trend in emissions production since it represents data for a fixed set  of
facilities.
                                      4-12

-------
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-------
  8.0-1
  5.0
             1987
1988               1989
    Reporting Year
                 All Facilities Reporting to TRI
1990
           &&£)  Facilities that Reported Emissions in Each of the Four Years
Figure 4-3.  Trends in Nationwide HAP Emissions for All Reporting Facilities
          (1987-1990) and Facilities Reporting for All Fours Years.
                                   4-14

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4.5 References

1.    Corning, D.R., NJ. Cory, S.W Nott, and R.L Sykes.  The Impact of Air Pollution
      Controls on Tannery Operations. Journal of the Society of Leather Technologists
      and Chemists.  Volume 75, p. 183. 1991.

2.    Trip Report.  Mitsch, B.F and Howie,  R. H., Alpha-Gamma Technologies, Inc. to
      Iliam  Rosario,  Industrial Studies Branch, Office of Air Quality  Planning  and
      Standards, U. S. EPA.  April 7, 1993.  Final trip report of visit to Seton Company,
      Saxton, PA, on January 7, 1993.

3.    Trip Report.  Mitsch, B.F. and Howie, R.H., Alpha-Gamma Technologies, Inc. to
      Iliam  Rosario,  Industrial Studies Branch, Office of Air Quality  Planning  and
      Standards, U. S. EPA.  April 6,  1993.  Final trip report of visit to Mercersburg
      Tanning, Mercersburg, PA,  on January 8,  1993.

4.    Letter from Rutland, F.H., Leather Industries of America, Inc. to Mitsch,  B.F.,
      Alpha-Gamma Technologies, Inc.  February 24,1993. Letter providing emissions
      data collected by the leather industry.

5.    Reference 1.
6.
7.
8.
9.
Reference 4.
Reference 5.
Reference 2.
Reference 3.
10.   Stockman, George.  "Determination  of Spray  Machine Transfer Efficiency  for
      Leather Finishing." Journal of the American Leather Chemists Association, Volume
      83. 1988.

11.   Reference 2.
                                     4-15

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       5.0  EMISSION REDUCTION AND CONTROL TECHNIQUES
      This section provides a discussion of the options available to reduce and
control VOC and HAP emissions from leather tanning and finishing operations. These
options originate from a wide variety of sources including State and local regulatory
agency documents, EPA documents, emission inventories and surveys, and visits to
several leather processing facilities.

      Under the Pollution Prevention Act, it is national policy that pollution be
prevented or reduced at the source whenever feasible. Where pollution cannot be
prevented, it should be recycled in an environmentally safe manner. In the absence of
feasible prevention and recycling opportunities, pollution should be treated.
Collectively, this technique of pollution prevention is called life cycle assessment, or
cradle-to-grave analysis.  This is certainly the strategy that should be employed in
reducing emissions from leather tanning  operations.

      This section includes a presentation of source reduction technologies as well as
treatment technologies.  Source reduction techniques available to leather finishing
operations and the associated emission reductions tend to be very site-specific. For
this reason, the more universally applicable treatment technologies  are discussed first.
Control technologies are discussed in Section 5.1 and emission reduction technologies
are discussed  in Section 5.2.

5.1   Emission Control Techniques

      This subsection provides a description of various abatement control
technologies applicable to VOC and gaseous HAP emissions from leather finishing
operations.  This discussion includes  generally applicable technologies applied in
similar industries, as well as those present  in the leather finishing industry.  The only
known abatement devices currently employed within the domestic leather finishing
industry are regenerative thermal incinerators which are presently operated at two
facilities.  Both of these facilities were visited as part of this study, and this  section
incudes a presentation of performance data obtained from these sites.

      As discussed in Section 4.0, the bulk of emissions  resulting from leather '
finishing operations are from the spray booth and the associated dryer. There is little
data available-to quantify what portion of total emissions occur between the spray
booth and the  exit of the associated dryer.  As discussed in Section 4.0, other points

                                      5-1

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of emission are the mixing room, fugitive emissions associated with supplying coatings
to the spray guns (often includes open drums of virgin material), clean up operations,
secondary emissions from the contaminated water wash, and solvent evaporation after
the drying operation. The most significant of these sources is likely to be emissions
associated with clean up, and most of these emissions can be captured by operating
the spray booth exhaust during gun cleaning. Since the bulk of emissions occur
between spray application and drying, this is the portion of the leather finishing
operation where abatement control technologies are  most applicable.
                                                     »
      Effective overall control of VOC and HAP emissions requires both the effective
capture-of emissions and the effective removal or destruction of the VOC and HAP.
The overall control efficiency is the product of capture efficiency of the system and the
control device removal or destruction efficiency.  The EPA has established a total
enclosure as the highest level of capture, and the capture efficiency of a structure
meeting EPA's criteria for a total enclosure is deemed to be 100 percent. The
applicability of total enclosures to leather finishing operations is  discussed in
Section 5.1.1.  It is generally recognized that air pollution control devices such as
thermal incinerators, catalytic incinerators, and carbon adsorbers are capable of
providing control efficiencies of greater than 95 percent for VOC and gaseous HAP.  A
description of these devices and their respective control efficiencies is provided in
Section 5.1.2

      Although control cost analysis is beyond the scope of this document, it is
important to note that there is also an economic component of effective capture.
Exhausts from spray booths and dryers are generally high volume streams with dilute
VOC concentrations. Methods to reduce the exhaust volume should be evaluated
prior to determining the required size of the control device.  Methods for reducing the
volume of spray booth and dryer exhausts are discussed in Section 5.1.3

5.1.1  Total Enclosure for Effective Capture of VOC and Gaseous HAP

      The first element of effective abatement control is the effective capture of
emissions. As indicated above, the capture efficiency is considered to be 100 percent,
if the source of VOC is totally enclosed (e.g., meets the EPA criteria for a total
enclosure). A total enclosure is a structure that completely surrounds a source of
emission such that all VOC emissions exhaust through a duct to a control device. The
EPA has established the following criteria for verifying that an enclosure is a total
enclosure:1

      a)    Any natural draft opening (NDO) is at least 4 equivalent opening
            diameters from each VOC emitting point.  An NDO is defined as any
            permanent opening in the enclosure that remains open during operation
            of the facility and is not connected to a duct in which a fan is installed.
                                       5-2

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      b)     The total area of all NDO's does not exceed 5 percent of the surface
             area of the enclosure's four walls, floor, and ceiling.

      c)     The average facial velocity (FV) of air through all NDO's is at least 3,600
             meters per hour (200 ft/min).  The direction of air through all NDO's is
             into the enclosure.

      d)     All access doors and windows whose areas are not included in number 3
             are closed during routine operation  of the process.

      Procedures for determining NDO's and FV are provided  in the  Method and in
the EPA enabling document,  The Measurement Solution, Using a Temporary Total
Enclosure for Capture Efficiency Testing.2

      A total enclosure may  be set up over an individual booth or oven, or over an
entire finishing line. Alternatively, an entire finishing room may function as a total
enclosure.

      Establishing a total enclosure over an entire finishing line is achievable on
automated spray finishing lines.  In fact, one of the leather finishing facilities currently
equipped with a regenerative thermal incinerator has demonstrated a  total enclosure
for the controlled lines.3 In this case, the new lines were installed with an enclosure
over the entire line.  NDO's are located at the front of each spray booth and at the exit
of each dryer where the hides enter and exit the line. These openings are narrow
slots 5  to 7 inches high and  about  76 inches long.  In addition, each  spray booth is
equipped with one NDO about 30 inches by 60 inches to provide access to the spray
guns. This opening is covered with a heavy, plastic  curtain. The curtain has small
openings that represent less than 0.5 ft2 of total opening.  The total area of all NDO's
on each of two lines are 1 percent or less of the total area of the  enclosure.   For
determination of equivalent opening diameters, the center of the rotary spray wheel in
each booth was considered the VOC emitting point.

      Establishing a total enclosure over an entire line may not be practical  in some
retrofit situations. But, much  of the necessary enclosure naturally exists in automated
leather finishing operations.  The most common spray equipment in medium and
larger operations is fully or partially enclosed rotary spray booths.  These systems are
more fully described in Section 4.0.  Following application of the coating in a rotary
spray booth,  the leather travels on a mechanical conveyor through a flash off area and
on to a  heated drying oven.   Emissions captured by the spray booths and dryers are
already  exhausted through ducts for protection of the workers.

      In manual or hand spray operations,  establishing a total  enclosure over
individual finishing lines is much more difficult.  In these situations, an  entire finishing
room could function as a total enclosure. All booths and ovens could be exhausted to


                                       5-3

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a VOC control device with no other exhaust points from the room.  The room would
have to be maintained at a slight negative pressure.  In this case, any open doors or
widows would be considered NDO's.

5.1.2  Control Devices

      This subsection provides a description of three types of add-on control
technologies applicable to the control of VOC and gaseous HAP emissions from
leather finishing operations.  These are thermal incineration, catalytic incineration, and
carbon adsorption.

      AS indicated above, the only known add-on control technology currently-
employed within the leather tanning and finishing industry is regenerative thermal
incineration. This control technology was installed at two new leather finishing facilities
and both were visited as part of this CTC effort.  Case study accounts of the findings
at each of these leather  finishing facilities are provided in Appendix  B. Information on
the operation and performance of these systems is included below  in the discussion of
regenerative thermal  incineration.

5.1.2.1  Thermal Incineration

      Thermal incineration is a process by which waste gas is brought to adequate
temperature, and held at that temperature for a sufficient residence  time with sufficient
oxygen for the organic compounds in the waste gas to oxidize.  Since the compounds
emitted from leather finishing operations are generally hydrocarbons consisting  of
carbon and hydrogen, the products of thermal oxidation are carbon dioxide and water
vapor.  Based on performance tests conducted at leather finishing facilities,  VOC
destruction efficiencies of greater than 98 percent can be achieved for emissions from
leather finishing operations.4'5 In addition, EPA studies indicate that  a well designed
and operated commercial incinerator can achieve at least 98 percent destruction
efficiency (or an outlet concentration of 20 ppm or less) of organics. This destruction
efficiency corresponds to incinerators that are operated at 1600T with a nominal
residence time of 0.75 seconds.8

      A schematic diagram of a typical thermal incineration unit-is provided in
Figure 5-1. Primary components of the thermal incineration unit include a fan, a heat
recovery device, the combustion chamber, and the exhaust stack.  The heat recovery
device is used to preheat the incoming waste stream so that less auxiliary fuel is
required in the combustion chamber.  This type of heat recovery is  known as primary
heat recovery and can be further categorized as  either  recuperative or regenerative.
The waste gas preheater shown in  Figure 5-1 would be referred to as a recuperative
heat exchanger. As shown in this figure, a heat exchanger is used  to transfer heat
from the hot incinerator  exhaust stream to the incoming waste stream. This is a
continuous steady state  process. Types of heat  exchangers typically used for


                                       5-4

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recuperative heat recovery include plate-to-plate and shell-and-tube. Recuperative
heat recovery can provide up to 70 percent recovery of the heat in the exhaust
stream, thereby reducing fuel use, the primary operating cost, by up to 70 percent.

      Regenerative heat recovery is accomplished by cycling the incinerator exhaust
gas through a ceramic bed.  An incinerator employing regenerative heat recovery is
presented in  Figure 5-2.  As  indicated in the figure, the waste gas stream first passes
through a hot ceramic bed, thereby heating the waste stream.  The ceramic bed in
turn, is cooled. The heated waste stream is introduced into the combustion chamber
where it is combusted, thus releasing energy.  The exhaust from the combustion
chamber is then routed through another ceramic bed, heating the ceramic material in
the bed. When the ceramic  bed reaches the desired temperature, the process flows
are then switched, and the waste gas flow is fed to the hot ceramic bed.
Regenerative heat recovery systems can recover up to 95 percent of the energy in the
incinerator exhaust gas, with a comparable reduction in fuel, the major operating
expense.78

      The choice of thermal incineration with regenerative versus recuperative heat
recovery or no heat recovery is driven by economics. Regenerative heat recovery
represents substantially more capital cost, but offers the long-term savings of reduced
auxiliary fuel costs.

      As indicated above, two leather finishing facilities currently operate regenerative
thermal incinerators for the control of VOC emissions. Both sites were visited as part
of this study to observe and  discuss the operation of these VOC control devices.  The
design and operating characteristics of each unit are presented in Table 5-1.  The
VOC destruction efficiency of each unit has been demonstrated to be greater than 98
percent using EPA Methods.  The results of these tests are also presented in
Table 5-1. As indicated in the table, the unit located at Plant A is designed to provide
control of VOC emissions from three eight-gun rotary spray booths and the three
associated dryers. The rated capacity of this unit is 30,000  cfm and the reported
capital cost is $1.5 million (1989)." The unit located at Plant B is designed to provide
control of VOC emissions from two sixteen-gun rotary spray booths and the two
associated dryers. The rated capacity of this unit is 24,000  cfm and the reported
capital cost is $800,000 (1989).10

      At Plant B, operation of the associated leather finishing  line is two 8-hour shifts,
seven days per week.  Additionally, the flow to the incinerator  varies periodically from
0 cfm to 12,000 cfm (one booth) to 24,000 cfm (two booths).  Based on discussions
with plant personnel, the  regenerative thermal  incineration system is able to handle this
wide variation with ease.  At  the end of the second shift, the incinerator is set to go
through a 3-hour cool down  where the combustion chamber temperature drops from
1500°F to SOOT.  To minimize operating cost, the combustion chamber temperature  is
maintained at 500°F during the idle period (when the  spray booths are not being

                                      5-6

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          Table 5-1.  Design and Operating Characteristics of Existing
                      Regenerative Thermal Incinerators

Design Flow Rate (cfm)
Combustion Temperature (°F)
Inlet Concentration (ppmv)"
VOC Destruction Efficiency (%)
Reported Capital Cost (1989$)
Sources Controlled
Plant A
30,000
1,450
660
99.5b
1,500,000
3 - Spray Booths
Plant B
24,000
1,500
1,540
98.6b
800,000
2 - Spray Booths
 Reported Capture Efficiency
 of Collection System
  2 - Catalytic Dryers
1 - Steam Heated Dryer

        100C
                                                             2 - Dryers
9V
* As propane.

b Based on perfromance test using EPA Method 25A on inlet and outlet of thermal
  incinerator.

c Based on the criteria for a total enclosure.

d Based on a material balance using coating consumption rate, coating VOC content,
  and Method 2A/25A measurements.  The accuracy of such determinations is
  suspect.
                                     5-8

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operated). Then prior to the start of the first shift, the incinerator is set to go through
a three-hour warm up, where the combustion chamber temperature is raised from
500°F to 1500°F. When both booths are operating, operation of the thermal
incinerator is self-sustaining,  i.e., there is no auxiliary fuel requirement.11

       Both of the existing thermal incinerator systems were installed on new leather
finishing facilities. Plant B was an entirely new facility that began operation in 1989.  At
Plant A, a new finishing facility was added on to an existing plant.  Installation of the
thermal incinerator systems are considered lowest achievable emission rate (LAER)
technology. Retrofitting this technology on  an existing finishing facility may be more
difficult and expensive than for a new facility.

5.1.2.2 Catalytic Incineration

       Catalytic incineration is similar to thermal incineration in that VOC's are heated
to a temperature sufficient for oxidation to occur. However, with catalytic incineration,
the temperature required for  oxidation is considerably lower than that required for
thermal oxidation because a  catalyst is used to promote oxidation of the contaminants.
The catalyst is  imposed on a large surface containing many active sites on which the
catalytic reaction occurs.  Platinum is the most widely used catalyst while palladium is
also commonly used.12 Because these metals are  expensive, only a thin film is
applied to the supporting substrate.  A commonly used substrate is ceramic.

      A well designed and operated catalytic incineration unit can achieve destruction
efficiencies of 98 percent, comparable to thermal incineration units.  However, the
destruction efficiency decreases in the presence of catalyst poisons and
particulates.13

      The catalyst bed in catalytic incinerators generally operates at temperatures
ranging between 300°F and 900°F, with temperatures rarely exceeding 1000°F.  The
contact time required between the contaminant and the catalyst, so that complete
oxidation occurs, is normally  0.3 seconds. The excess air  requirements for catalytic
incineration units are only  1 to 2 percent higher than the stoichiometric
requirements.1415 Catalytic incinerators can be designed to control waste gas flow
rates up to about 50,000 ft3/min.  The VOC content of the  waste stream may be in the
part per million range up to 25 percent of the  lower explosive limit (LEL).

      A schematic of a typical catalytic incineration system is  presented in Figure 5-3.
As indicated in this figure,  components of the system include a fan, a preheat burner,
a combustion chamber, a waste gas preheater (recuperative), a  secondary heat
recovery, and a stack. The preheat burner  is used to heat the incoming waste stream
to the required oxidation temperature, usually between 300°F and 900°F for catalytic
incineration.16  The catalyst bed may be a fixed-bed or a fluidized bed consisting of
individual pellets enclosed in a screened unit.  The recuperative heat recovery device,


                                       5-9

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if included, is a shell-in-tube or plate-to-plate heat exchanger. Recuperative heat
recovery is incorporated if supplemental fuel requirements are expected to be high.

       Many factors affect the performance of a catalytic incineration system.  The
primary factors include operating temperature, space velocity (inverse of residence
time), VOC concentration and species, and  catalyst type and susceptibility to
contaminants. The optimum operating temperature is dependent on the type  of
catalyst, as well as the concentration and type of VOC's.  Space velocity is defined as
the volume of the gas entering the catalyst bed divided by the volume of the catalyst
bed.  Space velocity is very dependent on operating temperature.  However, in
general, as space velocity increases, destruction efficiency decreases.  The amount
and type of VOC determine the heating value of the waste stream,  and thus the -
amount of supplemental fuel required to maintain the desired operating temperature.17

       The type of catalyst selected is based on the VOC compounds in the waste
stream. Particulates and catalyst poisons in the waste stream can  affect the efficiency
of the catalyst, and  its lifetime. Some materials that are considered catalyst poisons
include heavy metals (mercury, lead, iron, etc.), silicon, sulfur, halogens, organic
solids, and inert particulates.  Particulates and poisons reduce the activity of the
catalyst site, minimizing sites available for the oxidation reaction.  These materials can
also mask, plug, or coat the catalyst surface.18

5.1.2.3 Carbon Adsorption

       Carbon adsorption recovery efficiencies of 95 percent and greater have been
demonstrated to be achievable in well designed and well operated units.192tt21'22
Fixed bed carbon adsorption units  have been  sized to handle flow rates ranging from
several hundred to several hundred thousand ft'/min.  There is no obvious practical
limit to flow rate because multi-bed systems operate with multiple beds in simultaneous
adsorption cycles.  The VOC concentrations of the waste streams controlled by
carbon adsorption units can range from the part per billion level to  as high as  20
percent of the LEL  Adsorption systems typically operate at ambient pressure and
temperatures ranging between 77 and 104°F.23

      The carbon adsorption process used to control VOC emissions from waste  gas
streams can be divided into two sequential processes. The first process involves the
adsorption cycle, in which the waste gas stream is passed over the adsorbent bed for
contaminant removal.  The second process  involves regeneration of the adsorbent
bed, in which contaminants are removed using steam  or hot gas, so that the carbon
can be reused for contaminant removal.

      Adsorption is the capture and retention  of a contaminant (adsorbate) from the
gas phase by an adsorbing solid (adsorbent).  Activated carbon is the most widely
used adsorbent for air pollution control.24  Both the internal and external surfaces of


                                     5-11

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the carbon are used as adsorption sites. Diffusion mechanisms control the transfer of
the adsorbate from the gas phase to the external surface of the carbon, from the
external surface of the carbon to internal pores, and finally to an active site in the
pores. Adsorption depends on a mass transfer gradient from the gas phase to the
surface.  Van der Waal forces attract the adsorbate to the carbon. Because
adsorption is an exothermic process, some method of heat removal from the carbon
may be necessary, depending on the amount of contaminant being removed from the
gas phase.29

      Regeneration is the process of desorbing the contaminants from the carbon.
Regeneration of the carbon bed is usually initiated prior to breakthrough.
Breakthrough is that point in the adsorption cycle when the carbon bed approaches
saturation and the concentration of organics in the effluent stream begins to increase
dramatically.  If the carbon bed is not regenerated, the concentration of VOC's in the
effluent will continue to increase until it is equal to  that of the inlet, i.e., the carbon is
saturated.29  The most common method of regeneration is through steam stripping.
Another regeneration method is the use of hot, inert gas or hot air.  With either steam
or hot air regeneration, the desorbing agent flows  through the bed in the direction
opposite to the waste stream. This desorption scheme  allows the exit end of the
carbon to remain  contaminant free.27

      In a regeneration process, some adsorbate, known as the  heel, may remain in
the carbon after regeneration. The actual capacity of the carbon  is referred to as the
working capacity,  and is equal to the total capacity of the carbon  less the capacity
taken by the heel.28

      Adsorption units that are commonly used for contaminant removal from waste
gas streams include:

      a)    Fixed, or rotating, regenerable carbon beds;
      b)    Disposable/rechargeable carbon beds;
      c)    Traveling bed carbon adsorbers;
      d)    Fluid bed carbon adsorbers; and
      e)    Chromatographic baghouses.

      Of the five adsorption systems listed  above, the first two are most commonly
used for air pollution control. The disposable/rechargeable canisters are used for
controlling low flow rates  (less than  100 cubic feet per minute) and would not be used
to control the high volume flow rates typical of leather finishing operations.  Only the
fixed bed, regenerable carbon adsorption system is discussed in this section.

      A fixed bed, regenerable carbon adsorption system is presented in  Figure 5-4.
The components of the carbon adsorption system include (1) a fan  (to convey the
waste gas into the carbon beds), at least (2) two fixed-bed carbon adsorption vessels,

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 (3) a stack for the treated waste gas outlet, (4) a steam valve for introduction of
desorbing steam, (5) a condenser for the steam/contaminant desorbed stream, and
(6) a decanter for separation of the VOC condensate and water. In the system
depicted in Rgure 5-4, one carbon vessel is being used for adsorption while the other
is being regenerated.  Both vessels will alternate in the adsorption and regeneration
modes. The steam is used to regenerate a vessel, and is then sent to a condenser.
The condensate is a water/VOC mixture. The decanter can be used to separate the
condensate into a water stream and a condensate stream. Depending on its
measured toxicity, the water may be treated or discharged to the sewer. The
condensed organics can be recycled (if usable), used as a fuel, or disposed.

      Several factors affect the amount of material that can be adsorbed onto the
carbon bed. These factors include type and concentration of contaminants in the
waste gas, system temperature, system pressure, humidity of waste gas, and
residence time.29

5.1.3  Methods of Minimizing Control Costs -- Volume Reduction

      Exhaust streams from leather finishing operations are generally high volume,
dilute concentration, streams. To minimize the size and cost of the abatement control
device, volume reduction measures should  be evaluated.  Such a volume reduction
can provide several economic benefits including: (a) reduced air flow to the add-on
device reducing capital costs; (b) a more concentrated stream for treatment reducing
capital and operating costs of the add-on control device; and (c) reduced makeup air
reducing plant heating and cooling costs.

      The first volume reduction  measure that should be considered is recirculation of
booth and dryer exhausts. Recirculation of booth and/or dryer exhausts could
provide substantial volume reduction of the abatement stream.  The amount of air that
can be recirculated is  limited by the maximum  VOC concentration allowed in the booth
or dryer.  In automatic spray booths such as the rotary spray booths used in the
leather finishing industry, insurance companies usually require that the VOC
concentration in the booth be less than 25 percent of the LEL  The same is true for
dryers. Additionally, the National Fire Protection Association (NFPA) requires an LEL
monitor if the VOC concentration is expected to exceed 20 percent of the LEL30

      Recirculation is much easier to address in the case of a new installation since it
may require substantial modification of the spray booth and dryer design.  But
considering the potential economic benefits, recirculation should be evaluated in
retrofit applications as well as new installations.

      Whether or not recirculation is currently used at leather finishing facilities is not
known.  However, recirculation has been used in both manual spray booths and
                                     5-14

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mechanical spray booths in other industries which are similar to those used in the
leather finishing industry.31 In addition, studies have also been conducted by EPA to
ascertain the feasibility and safety of recirculation.3*33 Those studies conclude that
recirculation can safely and effectively be used in spray booths.

      There  are also several emerging technologies specifically targeted at reducing
the volume of air that must be exhausted through manual spray booths.  Since a side
draft velocity  of 100 ft/min must be maintained across the worker to meet OSHA
requirements, the potential reductions in air volume are limited, without completely
changing the design of manual spray booths.  Two emerging technologies that show
great promise for reducing the volume of air that must be exhausted, while maintaining
an adequate  level of operator protection, are the Classic Systems Campbell Spray
Booth and the Mobile Zone system.

      Classic Systems indicates that its Campbell Spray Booth can reduce the volume
of exhaust air by approximately 80 percent.34 The basic design of this spray booth
involves the use of air curtains.  The worker stands outside of the booth and sprays
through the air curtain. The air curtain provides a barrier between the worker and the
solvent emissions inside the  booth, resulting from spraying the coating. The booth
design can also  include an adjacent, enclosed flash tunnel.  As with the spray booth,
air curtains separate the air inside the flash area from the outside air. The design is
such that the exhaust from the flash tunnel can be recirculated back to the spray
booth. By incorporating this recirculation, makeup air requirements are further
reduced.

      Mobile Zone Associates has developed a device that enables the worker to
spray coatings from a partially enclosed mobile work platform.35 The worker stands
inside of a moving cab.  The movement of this cab is controlled by the worker.   Within
the Mobile Zone cab, fresh ventilating air passes across the worker from an open
moving window at his rear.  The remaining section of the mobile work platform  is
ventilated using recirculated air.  The Mobile Zone design contrasts with a conventional
spray booth,  in which the entire length of the booth is supplied with fresh ventilating
air.  Through the use of the moving window, the ventilating air requirements for the
worker are greatly reduced.  In one EPA sponsored test of this system in a paint spray
operation, the Mobile Zone design allowed a 90  percent reduction in the spray booth
exhaust rate.39

5.2 Emission Reduction Techniques

      The largest source of VOC and HAP emissions from the leather tanning and
finishing industry is the finishing operation.  Because of the disproportional impact
finishing operations have on  emissions, they are the primary focus for emission
reduction measures.  Efforts  to reduce emissions from leather finishing can be
categorized by:  a) use of lower VOC or water-based coatings; b) improved transfer


                                      5-15

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efficiency of the coatings application process; and c) improved housekeeping
practices and employee training.

5.2.1  Use of Lower VOC and Water-Based Coatings

      As discussed in Section 3.0, coating formulations can be classified by VOC
content.  These classifications include lacquers, lacquer emulsions, and water-based
coatings.  Table 5-2 illustrates the differences in VOC content among these coating
classifications. In addition to reduced VOC content, water-based coatings have higher
solids-carrying capabilities, which usually translates to reduced volumes of coatings
needed to finish the leather.

      The leather industry has made progress in the use of lower VOC coatings over
the past few years.  This trend has been hastened by increased pressure to lower
VOC emissions to meet State and local air quality regulations.  In addition, the leather
industry recognizes there are several other benefits to using lower VOC coatings.
These benefits include improved working conditions and employee safety, reduced
costs in treating and disposing of hazardous wastes, and, improvement in local public
relations.  The potential exists for water-based coatings to be used in all finishing coats
with subsequent reductions in VOC emissions.

      From discussions with major coating suppliers, there are indications that many
leather manufacturers are converting to water-based coatings.37 As presented in
Table 3-3, one chemical supplier  has seen a shift from solvent-based coatings to lower
VOC coatings in it's top ten selling products to leather finishers. It should be noted
that although the predominant formulations may be water-based,  some applications
will require the addition of penetrator and leveling agents which contain VOC's. Still,
the shift to lower VOC coatings is apparent.

      The VOC reductions achieved by switching to water-based coatings can be
dramatic.  For example, one facility that was able to fully convert from solvent coatings
to water-based coatings reduced  VOC and HAP emissions by 95 percent.38 The use
of water-based coatings still presents numerous difficulties to the leather finisher, but
most of these difficulties have been overcome with regards to  base and intermediate
coatings.  In fact, water-based coatings are now typical for base and intermediate
coats in much of the industry. However, the use of water-based coatings is still
difficult in other applications, particularly the top coats. Situations that can prevent the
conversion to low VOC coatings include:

      a)     The conversion to water-based coatings can require  substantial research
            and development efforts.  The conversion process is generally not as
            simple as substituting a water-based coating for a solvent coating.
            Changes must often be made in the retannage and fatliquoring process
            to ensure compatibility of the leather with the coatings;


                                      5-16

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   Table 5-2. Comparison of Lacquer, Lacquer-Emulsion and Water-Based
                          Top Coat Systems


Property

Application
Solids (%)
Wt.% Solvent
(as applied)
VOC (#/gal. less
water supplied)
Gallons to Finish
100 Sides
Pounds Organic
Lacquers

5-15

75-95

5.0-6.5

9

46.4-61.8
Lacquer
Emulsions
5-20

40-60

5.0-6.5

7

22.8-30.9
Water-Based
Coatings
20-30+

5-15

0-3.0

4.5

0-4.0
Solvent Emitted per
100 Sides
                                5-17

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      b)     In situations where the look and feel of the leather are key
             characteristics, it may be impossible to produce the required esthetics
             that customers demand with water-based coatings; and

      c)     In shoe leather, additional coatings are applied to the leather by the shoe
             manufacturers.  As a result, finishes applied by the leather finisher must
             be compatible with the finishes applied by the shoe manufacturer.

5.2.2 Emission Reductions From Improved Transfer Efficiency

      Several advances have been made in the application techniques used for
leather finishing operations.  These advances include the use of higher efficiency spray
guns, use of optically controlled spray guns, and use of alternative application
techniques such as roll coating.  In addition, the potential for using radiation to cure
top coats is also being explored by the industry.  A discussion of the emissions
reduction potential offered by each of these technologies is provided below.

5.2.2.1  High Efficiency  Spray Guns

      In all spray coating operations, some coating solids either miss or bounce off
the material thereby reducing the transfer efficiency of the spray system. Transfer
efficiency is the ratio of the solids that adhere to the material divided by the solids
directed, or sprayed, at the material.  Conventional  spray systems have low transfer
efficiencies ranging from  10 to 30 percent. These low transfer efficiencies are
attributed to excessive bounce-back and overspray. Bounce-back is that portion of
the finish coating which impinges on the leather surface but does not stick.  Overspray
can be defined as the portion of the spray pattern which falls outside the area of the
material coated.  The resulting loss in solvents and  coating material can be in excess
of 75 percent.

      Bounce-back and  overspray are problems generally associated with  spray
guns. The various spray guns used to finish leather differ in the manner in which they
break up (atomize) the coating. Some methods are associated with inherently better
transfer efficiencies than others as shown in Table 5-3.  However, these transfer
efficiencies are only estimates and are dependent on many other factors which are
discussed below. Spray  guns can be divided into several basic types including:

      a)     Conventional air sprav - Conventional  air spray has been the traditional
             method of applying coatings. Compressed air is supplied through an air
             hose to a spray gun that atomizes the paint into a fine spray.  The
             pressure supplied to the fluid controls the  paint delivery rate with typical
             pressures ranging form 5 to 25 pounds per square inch (psi).  The air
             pressure controls the degree of atomization and is usually 30 to 90 psi.
             One of the major problems with conventional air spray is the bounce-


                                      5-18

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         Table 5-3. Transfer Efficiencies of Different Spray Techniques"
  Product Type                           Transfer Efficiencies**
                      	(in percent),	

  Conventional Air Spray                   15-30
  Airless Spray                            20-40
  Air Assisted Airless Spray                25-45

  Electrostatic Air Assisted Airless          55-85***
  High Volume Low Pressure Spray	55-90

 *   Based on manufacturer claims for various spray equipment products.

    Transfer efficiency is defined as the net amount of coating solids deposited on a part,
    divided by the total coating solids sprayed, and expressed as a percentage:
**
***
   Where:
   TE  =  Transfer Efficiency
   We  =  Weight of coating solids added to material, after drying
   %S  =  Percent of coating sprayed that is solids
   Q   =  Coating Flow Rate, weight per time unit
   T   =  Time coating is flowing

   Electrostatic modifications to spray equipment is not considered effective for leather
   finishing operations.
                                      5-19

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             back and overspray caused by the high volume of air required to achieve
          .   atomization.  This results in relatively poor transfer efficiency.

      b)     Airless sorav - With airless spray, a pump forces the coating through an
             atomizing nozzle at high pressure (1,000 to 6,000 psi) instead of using
             compressed  air to atomize the material.  Due to its high pressure, airless
             spray is ideal for rapid coverage of large areas and when a heavy film
             build is required. The size of airless spray droplets are larger, the spray
             cloud is less  turbulent, and the transfer efficiency is typically superior to
             conventional  air spray. However, airless spray leaves a rougher, more
             textured surface and is generally used when appearance is not critical.

      c)     Air-assisted airless sprav - An air-assisted airless system combines the
             benefits of conventional air  spray and airless spray.  The system consists
             of an airless  spray gun with a compressed air jet to atomize the coating.
             These systems use lower fluid pressures than airless spray and lower air
             pressures than conventional air spray (5 to 20 psi versus 30 to 90 psi).
             This fluid/air  pressure combination delivers a less turbulent spray than
             conventional  air systems  and applies a more uniform finish than airless
             systems.  However, due to  the lower air pressure, the amount of time
             needed to apply the coating is greater when using the air-assisted airless
             system.

      d)     High Volume Low Pressure Spray - A modification of conventional air
             spray is high volume low pressure (HVLP) spray which uses large
             volumes of air under reduced pressure (10 or less psi) to atomize the
             coatings.  Because of the lower air pressure, the atomized spray is
             released from the gun at a  lower velocity. Overspray has been reported
             to be reduced 25 to 50 percent over conventional air spray. The air
             source for the HVLP can be a turbine or a standard  air supply, both of
             which can handle multiple spray  guns.  Manufacturers have constructed
             fluid passages out of  stainless steel or plastic so that these guns are
             compatible with a full  range of solvents and water-based materials.  Many
             of the HVLP  spray systems are designed to atomize high, medium,  or
             low solids coatings.

      Some  states have mandated that all coating operations be  converted to use
more efficient spray equipment.39 However, as stated in other previous EPA studies
on surface coating, the degree of increased transfer efficiency is dependent on many
factors.40 These include coating characteristics, types of spray equipment, types of
spray booths, and operator training. While the actual transfer efficiency values may be
controversial, it is generally accepted that switching to HVLP or other current-
generation spray systems  will reduce coating usage. This in turn  leads to reductions
in the use of  VOC laden solvents and subsequent reductions in VOC emissions.


                                      5-20

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5.2.2.2 Optical Eye/Microprocessor Controls on Spray Equipment

       All of the spray guns described above can be attached to automated machines.
These machines range from horizontal reciprocating machines which maneuver the
spray guns back and forth, to the more common rotary spray machines which rotate
between four and sixteen spray guns over the surface to be coated. Either type of
spray system has the potential for a large amount of overspray resulting in VOC and
HAP emissions.

       Because of this inefficiency, microprocessor controls coupled with electronic
eyes are being used in tandem with the various spray  machines.  The efficiency of this
equipment was tested in one experiment where a copper-containing pigment was
sprayed on leather as the topcoat using equipment with and without microprocessor
controls. As Table 5-4 shows, the use of microprocessor controls improved the  net
transfer efficiency of copper by 66 percent.41

       Because of their relative low-cost,  the return-on-investment in these systems
can be realized within the first year.4*43 Recent industry surveys indicate that various
forms of this technology are used in over 70 percent of the leather finishing facilities
using automated spray equipment.44

5.2.3   Housekeeping Practices

       In addition to the emission reduction techniques mentioned above, VOC
emissions can be minimized through diligent housekeeping practices.   For example,
fugitive emissions can be minimized by storing fresh and spent solvents in containers
designed to minimize evaporative losses. Coating waste can be minimized by mixing
only as much coating as is  needed to complete finishing jobs. Cleaning solvents
should be used in enclosures and systems which minimize the volume  needed and
evaporation.  And waste coatings, spent solvents, and sludge  from gun cleaners and
in-house distillation units should be disposed of properly by transfer to  designated
hazardous waste management facilities.  Implementation of in-house training programs
can provide workers with guidance regarding practices that can reduce emissions.

5.2.4  Degreasing Operations

      Sheep skin and pigskin tanneries often use solvent degreasing operations in the
leather manufacturing process.  The hides of these animals contain high quantities of
inter-fiber fat that must be removed prior to tanning. Solvent degreasing
involvesplacing the hides in drums containing solvents such as trichloroethylene or
perchloroethylene, along with surfactants.49  Solvent recovery systems are usually used
when  hydrocarbons or solvents are used for degreasing.  However, a substantial
amount of solvent can be lost from the system because of inefficient condensation or
by diffuse evaporation as skins are drained  or inspected.


                                      5-21

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        Table 5-4.  Demonstration of Increased Transfer Efficiency Using
                      Optical Eye Spray Control Systems.
                                  Without Controls       With Controls
Total Cu Offered (10 Sides)
Net Cu Taken Up (10 Sides)
Transfer Efficiency
3.24 g
0.872 g
26.9%
2.46 g
1.098g
44.6%
Note:  Copper  (Cu) is a trace metal in the. dye used to study the transfer efficiency
differences in using optical eye spray control systems. The total copper dispensed with
the dye was measured against the copper found in the coated leather.
                                     5-22

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       Most of the organic solvents used in the degreasing process are hazardous
materials. Therefore, tanneries have been investigating the use of aqueous
degreasing systems. There are many commercial aqueous degreasing products
available to the tanner.  These products are most commonly based on blends of
nonionic surfactants.4*

       Aqueous degreasing systems are not common in the United States.  Solvent
degreasing systems are preferred because they have been proven to be effective.
Ongoing research indicates that aqueous systems using nonionic surfactants are still
less effective in degreasing fat-laden sheepskins than solvent systems.  Therefore,
substitution  of solvent systems with aqueous systems is not presently a viable
emission reduction technique for tanneries processing sheep and pig skins.47

5.2.5  Emission Reductions and Waterproofing Operations

       As discussed in  Section 3.0, waterproof finishing is considered separate from
finishing operations.  Waterproof is actually a term that collectively describes three
finished leather properties:  a) water penetration resistance; b) water absorption; and
c) water repellency.  These properties are desirable in various leather products and
particularly in footwear.

       Silicones are the most  efficient means of increasing water penetration
resistance. The backbone of silicone polymers consists of repeating siloxane units.
The stability of the link is responsible for the unique properties of these polymers
which include stability at high temperatures and good resistance to chemicals.  As a
result of silicone treatment, the water penetration resistance of footwear can be nearly
100 percent. Because  of the high degree of water penetration resistance that silicones
impart on the leather, leather  industry customers such as the Department of Defense
usually require that leather be treated with silicone.

       Silicones are normally applied using organic solvents, many of which contain
HAP's.  At present, there is no known  substitute for solvent-based silicone  coatings
that can achieve the desired water penetration resistance qualities demanded by
customers.48  Therefore, emission reductions cannot be achieved through substitution
with water-based coatings.

      Water absorption properties are also desirable on many leather footwear
products.  Water absorption can  be achieved by silicone impregnation and also
through hydrophobic retanning in the wet ends process. The hydrophobic retanning
process does not produce any air emissions. Therefore, depending on the degree of
water absorption needed, either technology can be used.  When hydrophobic
retanning can be used rather  than silicone impregnation, reductions in air emissions
can be achieved.
                                      5-23

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      Water repellency can be achieved using conventional finishing technology.
Some top coats impart water repellency characteristics on the leather.  Reduction of
the VOC content of these top coats can result in some reductions in emissions.

5.2.6 Radiation Curing of Top Coats

      Radiation curing is a relatively new technology and is just emerging as a
potential technique for finishing leather.  As such, economic viability and market
demand for this technique are unproven. However, these coating formulations contain
materials which are 100 percent reactive, and polymerize to form a coating without
emitting volatile organic compounds.  Radiation  curing of leather topcoats has been
used in limited production  in Europe and may prove to be an alternative leather
finishing process with low or no solvent emissions.

      Radiation curing is the polymerization of a chemical system by interaction with
incident radiation, specifically ultraviolet (UV) or electron beam (EB).  The chemical
system  is usually composed of acrylate  monomers and oligomers (intermediate length
polymers) that contain reactive carbon-carbon double bonds.  The oligomers provide
the basic film-forming properties of the cured coating. The monomers are used to
adjust the viscosity of the coating for application  and to impart additional properties to
the cured film. In the presence of a photo initiator and UV irradiation, the monomers
and oligomers are converted to a solid polymer with properties that frequently surpass
those of conventional solvent-borne coatings.48

      There are several disadvantages associated with this technology. First, the
monomers and UV initiators required by the process are toxic.  Second, there is
concern about the ability of UV light to penetrate heavier pigmented coatings. And
finally, there are costs associated with development of the process and purchase of
equipment.  The initial capital expenditures may exceed $100,000 for a  multi-lamp UV
system.  An EB system may cost several times this amount and these costs do not
include  changes in coating equipment needed for either technology.  Coating
formulation costs for  UV/EB systems are expected to be higher than their
conventional counterparts with  the photo initiators being the most expensive
components.5*"1

5.3   References

1.     U.S. Environmental Protection Agency.  Enabling Document. The Measurement
      Solution -  Using  a Temporary Total Enclosure for Capture Efficiency Testing.
      Publication No. EPA-450/4-9-020.  Final Draft.  August,  1991.

2.     Reference 1.
                                     5-24

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3.    Trip Report.  Mitsch, B.F. and Howie, R.H., Alpha-Gamma Technologies, Inc. to
      Iliam Rosario, Industrial  Studies  Branch,  Office of Air  Quality Planning and
      Standards, U.S.  EPA.  April 6,  1993.  Final trip report of visit to Mercersburg
      Tanning, Mercersburg, PA, on January 8, 1993.

4.    Reference 3.

5.    Trip Report.  Mitsch, B.F. and Howie, R.H., Alpha-Gamma Technologies, Inc. to
      Iliam Rosario, Industrial  Studies  Branch,  Office of Air  Quality Planning and
      Standards, U. S. EPA.  April 7, 1993. Final trip report of visit to Seton Company,
      Saxton, PA, on January 7, 1993.

6.    Memorandum and attachments from Farmer, J.R., Emission Standards Division,
      U. S. EPA, to Distribution.  Thermal Incinerator Performance for NSPS. August 22,
      1980.  29pgs.

7.    Letter and attachments from Lockaby, H.G., Spectrum Engineering to Mitsch, B.F.,
      Alpha-Gamma Technologies, Inc.  February 11, 1993.  1 p.

8.    Letter and attachments from Collard, W., Salem Engelhard to Mitsch, B.F.,
      Alpha-Gamma Technologies, Inc.  January 13,  1993.

9.    Reference 3.

10.   Reference 5.

11.   References.

12.   Bethea, R.M., Air Pollution Control Technology.  New York, Van Nostrand Reinhold
      Company.  1978. p 395.

13.   Telecon.   Caldwell,  M.J., Midwest Research Institute, with Minor, J.,  M&W
      Industries.  June 20, 1991. Discussion about catalytic incineration.

14.   Radian Corporation.  Catalytic incineration for  control of VOC emissions.  Park
      Ridge, New Jersey, Noyes Publications. 1985, pp 4-5.

15.   Reference 1, p 425.

16.   Reference 6, pp  12-24.

17.   Reference 4, pp  12-24.

18.   Reference 6, pp  12-24.
                                     5-25

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19.   Crane, G. Carbon Adsorption for VOC Control.  U. S. Environmental Protection
      Agency.  Research Triangle Park, NC. January 1982.  p. 23.
20.   Kenson, R.E. Operating Results from KPR Systems for VOC Control in Paint Spray
      Booths.  Met-Pro Corporation.  Harleyville, PA.  (Presented  at the CCA Surface
      Coating '88 Seminar and Exhibition. Grand Rapids, Ml. May 18, 1988.) 10 p.
21.   VIC Manufacturing. Carbon Adsorption/Emission Control.  Minneapolis, MN.
22.   U. S.  Environmental Protection Agency.  Carbon  Adsorption for Control of VOC
      Emissions: Theory and Full Scale System Performance.  Publication No.
      EPA-450/3-88-012. June 1988.
23.   Prudent Practices for Disposal of Chemicals from Laboratories. National Academy
      Press. Washington, D.C. 1983, pp 4-1 to 4-44.
24.   Reference 12, pp 375-376.
25.   Reference 12, p. 366.
26.   Calgon  Corporation.   Introduction to Vapor Phase  Adsorption  using  Granular
      Activated Carbon,  pp 11-1 through 11-16.
27.   Reference 12, pp 382-387.
28.   Reference 26.
29.   Reference 26.
30.   U. S. Environmental  Protection Agency.  Guideline Series. Control of Volatile
      Organic Compound Emissions from Wood Furniture Coating Operations.  Draft
      Chapters 1-4.  October 1991.  pp 3-21 through 3-22.
31.   Reference 30, pp 3-23 through 3-24.
32.   Norton, L.E., Bryan, R.J., and Becvar, D.P. (Engineering-Science, Inc.). Evaluation
      of Paint Spray Booth  Utilizing Air  Recirculation.    Prepared  for  the U.S.
      Environmental Protection Agency.  Cincinnati, Ohio.  Publication No. EPA-600/2-
      84-143.
33.   Ayer, J. (Acurex Corporation). Split-flow Exhaust for the Economic Control of VOC
      Emissions from Paint Spray  Booths.   Prepared for the U.  S.  Environmental
      Protection Agency.   Research  Triangle PArk, NC.   Paper  No. 90-104.3  for
      presentation  at the 83rd Annual Meeting of. the Air and Waste Management
      Association.  June 24-29, 1990.  12 pp.
                                     5-26

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34.    Reference 30, pp 3-42 through 3-43.

35.    Mobil  Zone  Associates.   Mobil  Zone Spray  Booth  for  Reduction  of  VOC
       Contaminated Air   Prepared for  the U. S. Environmental Protection  Agency.
       Research Triangle Park, NC. Contract No. 68D90122.  April 12, 1990.  17 pp.

36.    Reference 35.

37.    Telecon. Mitsch, B.F., Alpha-Gamma Technologies, Inc., with Levi, J., Stahl USA.
       January 11, 1993.  Discussion about leather finishing chemicals and trends.

38.    Trip Report.   Mitsch,  B.F., .Alpha-Gamma Technologies,  Inc. to  Iliam  Rosano,
       Industrial Studies-Branch, Office of Air Quality Planning and Standards, U. S. EPA.
       March 29,1993.  Final trip report of visit to Eagle Ottawa Leather Company, Grand
       Haven, Michigan on December 8, 1992.

39.    South  Coast Air  Quality Management District.  Rule 1136.

40.    U.  S.  Environmental Protection Agency.   Office of Air  Quality  Planning  and
       Standards. Surface Coating of Plastic Parts.  Draft Control Techniques Guidelines.
       October 1, 1992.

41.    Stockman,  G. Determination of Spray Machine Transfer Efficiency for Leather
       Finishing. JALCA, Volume 83.  1988.

42.    Technical Support Document for the Proposed Wisconsin Administrative Code Rule
       to  Limit VOC Emission from Major Leather  Coating  Facilities.   Wisconsin
       Department of Natural Resources.  1986.

43.    Reference 41.

44.    Telecon.   Mitsch,  B.F, Alpha-Gamma  Technologies,  Inc. with  Boynton, M.,
       Hampton Machine Company.  December 30, 1992.  Discussion regarding use of
       rotary spray machines.

45.    Bienkiewicz, K. Physical Chemistry of Leather Making.  Malabar, Florida: Krieger
       Publishing Company.  1983.

46.    Walters, P. J. and Price, S.M. A Study of Aqueous Degreasing of Australian Wooly
       Sheepskins  using Nonionic Surfactants.   Journal of the  Society of Leather
      Technologists and Chemists. Volume 75, p 197. 1991.

47.    Reference 46.

48.   Telecon. Mitsch,  B.F., and S.C. McClintock, Alpha-Gamma Technologies, Inc. with
                                     5-27

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      Rutland, F.H., Leather Industry Research Laboratory. March 3,1993. Clarification
      of information collected regarding the leather tanning and finishing industry.

49.   Scholnick, F.  Radiation Curing of Leather Finishes:  Pros and Cons  JALCA
      Volume 85, 1990.

50.   References!

51.   Telecon.  McClintock, S.C., Alpha-Gamma Technologies, Inc., with Johnson, M.
      and Guarino, J.,  UCB Radcure, Inc.  March 12, 1993.
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  6.0 STATE AND LOCAL REGULATIONS AFFECTING THE LEATHER
                   TANNING AND FINISHING INDUSTRY
       Six existing or proposed State and local regulations affecting the leather tanning
 and finishing industry have been identified.  The existing regulations are in the States
 of New Jersey, New York, and Wisconsin.  Regulations have been proposed in  Illinois
 and Massachusetts and in the Monterey Bay Air Unified Air Pollution Control District.

       All of these State and local regulations are targeted at leather finishing
 operations.  Of the 6 regulations identified, 4 impose limits on the VOC content  of the
 coating materials.  One of the regulations establishes emission limits based on the
 amount of VOC emitted per unit of leather finished. And one regulation includes
 characteristics of both formats - a limit on VOC content of the coating and a limit on
 emissions based on VOC emitted per unit of leather finished.  Table 6-1 summarizes
 the emission limitations established by these regulations.

       Each of these regulations is discussed below. Appendix C contains copies of
 the full texts of each regulation.  The full technical justification for the Wisconsin  rule is
 also included  in the appendix.

 6.1  Regulations limiting VOC content of the finishing coatings

       Three of the State and local regulations  identified limit the VOC content of the
 finishing material.  These regulations are found in New Jersey,  New York, and
 Massachusetts. New Jersey was the first State to adopt this type of regulation,  and
 New York and Massachusetts adopted the New Jersey rule.

 6.1.1  State of New Jersey

       The New Jersey rule for leather finishing is found in the New Jersey
 Administrative Code (N.J.A.C), Title 7, Chapter 27, Subchapter 16, Section 5. This
 section addresses surface coating and graphic arts operations as well as
 miscellaneous surface coating operations.  The full text of N.J.A.C. 7:27 is provided in
 Appendix C.
t
       For leather finishing operations, the maximum allowable VOC content per
 volume of coating  (minus water) is 5.8 pounds per gallon (0.70 kilograms per liter).
 This limit was  derived by determining.the equivalent reduction achievable by reducing

                                     6-1

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Table 6-1.  Summary of Existing and Proposed State/Local Regulations
   State
VOC Limitations
   Illinois
   Monterey Bay



   Massachusetts

   New Jersey

   New York

   Wisconsin
3.5 Ibs of VOC's per gallon of base and
intermediate coats; 38 Ibs VOC emissions per
1000 sq. ft. for top coats; 10 tons of VOC per year
for stain coatings.

7.5 Ibs of VOC per gallon of coating (minus water)
for stain and oil coatings; 1.3 Ibs per gallon for
resins, and 4.0 Ibs per gallon for top coats.

27.4 Ibs of VOC per gallon of solids applied.

5.8 Ibs of VOC per gallon of coating (minus water).

5.8 Ibs of VOC per gallon of coating (minus water).

38 Ibs of VOC per 1000 sq. ft. of finished leather.
                                 6-2

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 the VOC content of the coating as compared to emission reductions achievable using
 add-on controls. A number of assumptions were used by the State of New Jersey in
 developing this limit.

       First, it was assumed that the typical coating formulation used by the leather
 industry contains 7 pounds of organic solvent per gallon and that the average solvent
 density is 7.36 pounds per gallon.  Reasonably available control for this type of
 operation was expected to involve capture and venting to an incinerator.  A capture
 efficiency of 85 percent was assumed along with a destruction efficiency of 95 percent.
 Using a solids-applied equation, it was determined that the VOC content of the coating
 must be reduced to 5.8 pounds per gallon to achieve the equivalent 81 percent
 reduction obtainable using capture and add-on controls.

       The 5.8 pounds per gallon limit must be met on a daily basis.  If more than one
 coating is used, a daily  mean VOC content is determined using a formula provided in
 the rule. If coatings having VOC contents higher than 5.8 pounds per gallon are
 applied, control  equipment must be used to reduce VOC emissions to a specific
 overall control efficiency.  Quarterly reporting requirements are also specified.

 6.1.2  State of New York

       The New York  State regulation for leather finishing is found in Title 6, Part 228
 of the State code. Specific reference to  leather coating lines is found  in Section 228.9
 of this part. Section 228.9 contains a table that itemizes limits on  various processes
 including leather coating lines.  The limit for leather coating is identical to that found in
 New Jersey, 5.8 pounds of VOC per gallon of coating minus water.

       Discussions with  State of New York representatives indicate that New York
 adopted the New Jersey rule in total. The rule was initially applicable only  in the New
 York City metropolitan area.   However, most  of the leather finishing facilities are
'located in the central  part  of the State  and were not impacted by the  rule.  The
 establishment of the Northeast transport region by the Clean Air Act has caused the
 State to expand the rule to cover major sources statewide.  Since New York is in the
 transport region, a major source is one that emits 50 tons per year or greater of
 VOC's. Some of the facilities located in upstate New York may  now be impacted by
 the rule.

 6.1.3  State of Massachusetts

       The State of Massachusetts proposed a regulation to  limit emissions from
 leather finishing facilities as part of State  Implementation Plan (SIP) revisions needed to
 comply with the  Clean Air  Act Amendments.  Public hearings were being held on the
 proposed regulation in the Fall of 1992.
                                      6-3

-------
      The State is in the process of setting RACT emissions limitations on 7 industrial
categories not covered by their existing regulation, with leather surface coating being
one of the 7 categories.  The RACT limitations will be imposed on all stationary
sources having the potential to emit 50 tons of VOC per year.  The 50 ton  limit is in
response  to the Northeast transportation provision of the Act.

      Massachusetts is proposing  a limit of 27.4  pounds of VOC per gallon of solids
applied. This format parallels those of New Jersey and New York, but relates
emissions directly to solids application as opposed to gallons of coating minus water.

6.1.4 Monterey Bay Unified Air Pollution Control District

      The Monterey Bay Unified Air Pollution Control District (MBUAPCD), located in
Northern California,  has proposed a rule to limit VOC emissions from  leather
processing operations.  The rule is  expected to be promulgated in the Fall  of 1993.

      The MBUAPCD rule requires sources that emit greater than 250 tons per year
of VOC to use control technology that achieves a combined efficiency of 85 percent.
For sources that emit less than 250 tons per year, limits on the VOC content of the
coating material have been specified. These limits are: a) 7.5 pounds per gallon of
material (minus water) for stain coatings; b) 7.5 pounds per gallon of material (minus
water) for  oil coatings; c) 1.3 pounds per gallon of material (minus water) for resin
coatings; and d) 4.0 pounds per gallon of material (minus water) for top coats. It is
expected that these limits will become stricter in later years.

      In addition to the limits on VOC content of  the coatings, the rule also specifies
application methods and equipment to be used for leather finishing.  For example, roll
coating is  required for oil application and photoelectric controls are required for spray
guns used to apply  other VOC-containing treatments.

6.2 Regulations limiting emissions to  unit of product finished

      The State of Wisconsin regulation  limits  VOC emissions by the square footage
of leather finished.  The Wisconsin rule was promulgated on March 1, 1990.
Development of the regulation involved an extensive effort by Wisconsin's Department
of Natural  Resources over a 6 year period. In  developing the rule, Wisconsin focused
on the tanneries located in the Southeast Wisconsin nonattainment area. The
Department surveyed four tanneries in this  area and solicited information on the VOC
content of coatings used by each facility.

      The emission limit developed by Wisconsin is based on the coatings formulation
data obtained from the tanneries. The State recognized the diversity of coatings used
in finishing leather, and divided the  coatings into five functional classes. These
functional  classes are impregnation, stain, base, effect, and final finish.


                                      6-4

-------
Table 6-2 shows the VOC emission rates identified for these functional classes for
three types of application methods.

      Based on the emission rates identified, Wisconsin determined that the 16th
percentile in each spray coating range (frequency distribution) represented PACT.
The emission limit was determined by adding the RACT level for each functional class:
6.0 pounds per 1,000 square feet for impregnation; 19 pounds per 1,000 square feet
for stain; 2 pounds per 1,000 square feet for base; 4 pounds per 1,000 square feet for
effect; and 7 pounds per 1,000 square feet for finish. Adding the emission limits for
each functional class yielded an overall emission limit of 38 pounds of VOC per 1000
square feet of finished leather.

      Determination of compliance is based on a formula that takes into account the
total VOC's emitted during the day as compared to a prorated surface area of leather
finished.  In order to determine compliance, the plant must keep detailed records of all
coating formulations and the amount of each coating needed to finish each type of
leather product.  These records are kept on a daily basis and require computer
capabilities to effectively monitor coating usage and surface area  of leather finished.

      A copy of the technical support document developed to support the Wisconsin
rulemaking is provided in Appendix C.

6.3 The State of Illinois

      The State of Illinois proposed regulation incorporates components of both the
New Jersey rule and the Wisconsin rule.  As part of their strategy to comply with the
Clean Air Act Amendments, Illinois is developing rules to implement RACT for all major
sources.  In the Chicago area, which is a severe nonattainment area for ozone,  a
major source is 25 tons per year.

      The Federal Implementation Plan (FIP) in effect in  Illinois established RACT for
100 ton non-CTG sources to be either 3.5 pounds of VOC per gallon of coating
(minus water) or an overall emission reduction of 81 percent. In evaluating smaller
non-CTG sources such as leather finishing plants, Illinois determined that the 3.5
pounds/gallon limit was too strict.

      Based on a survey of the leather finishing industry conducted for EPA,1 the
State determined that the 3.5 pounds/gallon limit was achievable  for base and
intermediate coatings. However, top coats and stains used in specialty leathers
cannot meet this limit. Illinois has proposed using Wisconsin's RACT limitation of 38
pounds per 1,000 square feet of finished leather for these specialty leathers. In
addition, a limit of 10 tons per year of VOC emissions from stains other than those
used in specialty leathers is in the rule.
                                      6-5

-------
         Table 6-2. State of Wisconsin - Emission Rates Identified by
                        Finishing Application Method*
Application Method
Row
Air Atomized Spray
Air Atomized Spray
Air Atomized Spray
Air Atomized Spray
Air Atomized Spray
Roll
Roll
Coating Type
Oil Impregnation
Stain
Middle
Emulsion
Top Coat
Top Coat
Oil Impregnation
Stain
VOC Emission Rate
(kg/100 m2)
2.39-9.76.
7.81-14.16
0.33-6.41
3.42b
1.95-12.7
2.44-16.11
2.93b
1.12-2.93
"Based on information received from Amity Leather Products Company, Gebhardt-Vogel
 Tanning Company, and Pfister-Vogel Tanning Company during November 1985 - April
 1986.

bOnly one value presented from the above listed leather finishers.
                                    6-6

-------
      A technical document was prepared by one source impacted by these limits as
part of Illinois' rulemaking process. Copies of that report are not available at this time
due to proprietary reasons.

6.4 References

1.     Science Applications International Corporation. Assisting the New England States
      in  Implementing Reasonable Available Control Technology at Leather Finishing
      Plants.  Final Report submitted to the  U. S. Environmental Protection  Agency,
      Office of Air Quality Planning and Standards.  July 31, 1992.
                                      6-7

-------
APPENDIX A
EMISSIONS DATA
     A-i

-------

-------
A.1  Introduction to Appendix A

      This appendix contains all of the emissions data collected during the course of
the project.  Data were obtained from EPA data bases such as the Aerometric
Information Retrieval System (AIRS) and the Toxic Release Inventory (TRI). Additional
data were obtained from State agencies and from plant sites.

      Seventy-nine facilities are listed in the appendix. For many facilities, emissions
are not reported (NR).  The emissions from these facilities are either below the
reporting threshold for the TRI or were not reported in any other available data base.
                                      A-ii

-------
List of Tanning and Finishing Facilities in the United States
KEY: TRI  - Toxic Release Inventory
     AIRS - Aerometric Information Retrieval System
Facility
Calnap Tanning
Salz Leathers, Inc.
Western Tanning, Inc.
ACME Sponge & Chamois Co. Inc
Oshkosh Tanning Co., Inc.
Gutman and Company
Horween Leather Company
Much Leather Company
Carr Leather Co.
Barnet Corporation
Bond Leather Co., Inc.
Salem Suede, Inc.
Richard Tanning Co.
W.D. Byron & Sons Inc.
Prime Tanning Co., Inc
Camden Tanning Corporation
Irving Tanning Company
Rockland Leathers, Inc.
Wilton Tanning Company
Eagle Ottawa Leather Co.
Whitehall Leather Company
S.B. Foot Tanning Company
Blueside Companies, Inc.
Hermann Oak Leather Company
Lackawanna Leather Co.
Lackawanna Leather Co.
Schwartz Leather Company
New Jersey Tanning Co., Inc.
Seton Company
UDO Finishing Co
American Leather
Androme Leather Corp
Colonial Tanning Corp.
Fashion Tanning Co., Inc.

City
Napa
Santa Cruz
Delta
Tarpon Springs
Boone
Chicago
Chicago
Chicago
Lynn
Peabody
Peabody
Salem
Salem
Williamsport
Berwick
Camden
Hartland
Rockland
Wilton
Grand Haven
Whitehall
Red Wing
Saint Joseph
St. Loius
Conover
Omaha
Carlstadt
Newark
Newark
Newark
Rahway
Gloversville
Gloversville
Gloversville
A-1
State
CA
CA
CO
FL
IA
IL
IL
IL
MA
MA
MA
MA
MA
MD
ME
ME
ME
ME
ME
Ml
Ml
MN
MO
MO
NC
NE
NJ
NJ
NJ
NJ
NJ
NY
NY
NY

Source of
Emission
Data
AIRS
TRI, AIRS, Mont. Bay
TRI
TRI
TRI
AIRS
TRI, AIRS
AIRS
TRI
AIRS
TRI
TRI
AIRS
TRI
TRI, AIRS
AIRS
TRI
AIRS
AIRS
TRI
TRI
TRI, AIRS
TRI
TRI
TRI, AIRS
TRI
TRI
TRI
TRI, NJ permits
.NJ permits
AIRS, NJ permits
NY data
TRI
TRI, NY data


-------
List of Tanning and Finishing Facilities in the United States
KEY: TRI  - Toxic Release Inventory
     AIRS - Aerometric Information Retrieval System
Facility
Framglo Plant
Independent Leather Mfg. Corp.
JBF industries inc.
Leather Agent Inc
Pan American Tanning Corp.
Twin City Leather CO., Inc.
Wood & Hyde Leather co Inc
Moench Tannning Company
Adirondac Leather Inc
Allied Split Corp.
Arrow Leather Finishing Co
Carville National Leather Co
Classic Leather corp
Gordon Finishing Co Inc
H & J Leather Finishers Inc
Karg Brothers, Inc.
K-lynn Split Inc
Pearl Leather Finishers Inc
Peerless Tanning Co Inc
Simco Leather Corp.
Townsend Leather Co
Conneaut Leather Inc.
Howes Leather Co., Inc.
Garden State Tanning
Mercersburg Tanning
Garden State Tanning
Seton Company
Westfield Tanning Company
Volunteer Leather Company
Lannom Tannery
Tennessee Tanning Co.
Coey Tanning Co., Inc.
S.B. Foot Tanning Co.
Fox Valley Leathers, Inc.
City
Gloversville
Gloversville
Gioversviiie
Gloversville
Gloversville
Gloversville
Gloversville
Gowanda
Johnstown
Johnstown
Johnstown
Johnstown
Johnstown
Johnstown
Johnstown
Johnstown
Johnstown
Johnstown
Johnstown
Johnstown
Johnstown
Conneaut
Curwensville
Fleetwood
Mercersburg
Reading
Saxton
Westfield
Milan
Tullahoma
Tullahoma
Wartrace
Cactus
North Salt Lake
State
• NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
OH
PA
PA
PA
PA
PA
PA
TN
TN
TN
TN
TX
UT
Source of
Emission
Data
NY data
TRI
TRi, NY data
NY data
TRI, NY data
TRI
NY data
TRI
NY data
TRI, NY data
NY data
NY data
NY data
NY data
NY data
TRI, NY data
NY data
TRI
NY data
TRI, NY data
NY data
TRI
TRI, AIRS
TRI, AIRS
TRI
TRI
TRI
TRI, AIRS
TRI, AIRS, TN permits
ILG, TN permits
TRI.TN permits
TRI, TN permits
TRI
TRI
                                             A-2

-------
List of Tanning and Finishing Facilities in the United States
KEY:  TRI  -Toxic Release Inventory
     AIRS - Aerometric Information Retrieval System
Facility
Berlin Tanning Co.
Cudahy Tanning Company
A.F. Gallun & Sons Co.
Blackhawk Tanning Co.
Gebhardt-Vogel Tanning Co.
Gebhardt-Vogel Tanning Co.
Paul Flagg Inc
PFister & Vogel Tanning Co.
Theile Tanning Co.
Paul Flagg Leather Corp.
Howes Leather Co., Inc.
City
Berlin
Cudahy
Milwaukee
Milwaukee
Milwaukee
Milwaukee
Milwaukee
Milwaukee
Milwaukee
Sheboygan
Frank
State
Wl
Wl
Wl
Wl
Wl
Wl
Wl
Wl
Wl
Wl
WV
Source of
Emission
Data
TRI
TRI
TRI
AIRS
TRI
TRI
AIRS
TRI
TRI
TRI
TRI
Total Number of Facilities Reporting    79
                                            A-3

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Cal Nap Tanning
Napa, CA


Salz Leathers, Inc.
Santa Cruz, CA


Western Tanning, Inc.
Delta, CO


ACME Sponge & Chamois
Tarpon Springs, FL


Oshkosh Tanning Co., Inc.
Boone, IA


Gutman and Company
Chicago, IL


Horween Leather Compan
Chicago, IL



Total HAP Total VOC Total NonHAP Total HAP
Year Emissions Emissions VOC emissions nonVOC emissions
(Ibs/yr) (HAP&nonHAP) (Ibs/yr) (Ibs/yr)
(Ibs/vr)
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1991
NR
NR
NR
NR
250
250
250
250
500
250
250
5
NR
31850
42000
26644
NR
NR
NR
NR
NR
NR
NR
NR
31000
47000
14950
53250
NR
NR
NR
NR
NR
37000
33214
NR
NR
250
NR
NR
NR
NR
31850
42000
26638
NR
NR
NR
NR
NR
NR
NR
NR
31000
47000
14950
53250
NR
NR
NR
NR
NR
37000
'33214
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
250
250
250
250
250
250
250
5
NR
NR
NR
6
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
                                                  A-4

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Huch Leather Company
Chicago, IL


Carr Leather Co.
Lynn, MA


Bamet Corp.
Peabody, MA


Bond Leather Co., Inc.
Peabody, MA


Rex Finishing Inc.
Peabody, MA


Richard Tanning Co.
Salem, MA


Salem Suede, Inc.
Salem, MA


W.D. Byron & Sons Inc.
Williamsport, MO


Total HAP Total VOC Total NonHAP Total HAP
Year Emissions Emissions VOC emissions nonVOC emissions
(Ibs/yr) (HAP&nonHAP) (Ibs/yr) (Ibs/yr)
(Ibs/yr)
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
16750
8610
26074
22884
NR
NR
NR
461183
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
16750
8610
26074
22884
NR
NR
NR
470332
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
9149
NR
NR
NR
NR
NR
Nrt
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
                                                  A-5

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Prime Tanning Co., Inc
Berwick, ME


Camden Tanning Corporat
Camden, ME


In/ing Tanning Company
Hartand, ME


Rockland Leathers, Inc.
Rockland, ME


Wilton Tanning Company
Wilton, ME


Eagle Ottawa Leather Co.
Grand Haven, Ml


Whitehall Leather Compan
Whitehall, Ml


S.B. Foot Tanning Compa
Red Wing, MN


Year
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
Total HAP Total VOC Total NonHAP Total HAP
Emissions Emissions VOC emissions nonVOC emissions
(Ibs/yr) (HAP&nonHAP) (Ibs/yr) (ibs/yr)
(Ibs/yr)
460750
434957
881296
1058585
NR
NR
NR
NR
676350
495981
261863
398886
NR
NR
NR
NR
NR
NR
NR
NR
2820000
2730000
2618000
1915231
4500
NR
NR
NR
309468
284979
260866
154811
682500
527805
970872
1058585
NR~
NR
NR
NR
1241070
1486742
277635
398886
NR
NR
NR
NR
NR
NR
NR
NR
3570000
3360000
2977000
2154210
4500
NR
NR
NR
349606
317008
318293
185952
222000
92848 .
89576
NR
NR
' NR
NR
NR
564720
990761
15772
NR
NR
NR
NR
NR
NR
NR
NR
NR
750000
630000
359000
239234
NR
NR
NR
NR
41000
32891
58289
31306
250
NR
NR
NR
NR
NF<
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
255
NR
NR
NR
NR
862
862
862
165
                                                 A-6

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Hermann Oak Leather Co
St Loius, MO


Blueside Companies, Inc.
Saint Joseph, MO


Lackawanna Leather Co.
Conover, NC


Lackawanna Leather Co.
Omaha, NE


Schwartz Leather Compan
Carlstadt, NJ


New Jersey Tanning Co., I
Newark, NJ


Seton Company
Newark, NJ


UDO Finishing
Newark, NJ


Year
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
Total HAP
Emissions
(Ibs/yr)
NR
NR
NR
NR
NR
NR
NR
250
628195
372390
551025
319586
NR
NR
NR
239005
NR
250
NR
255
NR
NR
NR
NR
1678500
609310
658750
1359991
NR
NR
NR
NR
Total VOC
Emissions
(HAP & nonHAP)
(Ibs/vr)
NR
NR
NR
NR
NR
NR
NR
250
674752
670988
728647
506759
NR
NR
NR
318962
NR
250
NR
255
NR
NR
NR
NR
1678500
608810
658250
1359991
NR
NR
NR
NR
Total NonHAP
VOC emissions
(Ibs/yr)
NR
NR
NR
NR
NR
NR
NR
NR
46557
298598
177622
187173
NR
NR
NR
79957
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Total HAP
nonVOC emissions
(Ibs/yr)
NR
NR
NR
NR
NR
N9
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
500
500
NR
NR
NR
NR
NR
                                                  A-7

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
American Leather
Rahway, NJ


Androme Leather Corp
Gloversville, NY


Colonial Tanning Corp.
Gloversville, NY


Fashion Tanning Co., Inc.
Gloversviile, NY


Framglo Plant
Gloversville, NY


JBF Industries Inc.
Gloversville, NY


Independent Leather Mfg.
Gloversville, NY


Leather Agent Inc.
Gloversville, NY


Year
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
Total HAP
Emissions
(Ibs/yr)
NR
NR
NR
30994
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
7900
NR
NR
NR
NR
NR
NR
NR
NR
Total VOC
Emissions
(HAP & nonHAP)
(Ibs/yr)
NR
NR
NR
56031
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
7900
NR
NR
NR
NR
NR
NR
NR
NR
Total NonHAP
VOC emissions
(Ibs/yr)
NR
NR
NR
25037
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Total HAP
nonVOC emissions
(Ibs/yr)
NR
NR
NR
NR
NR
N3
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
                                                 A-8

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Pan American Tanning Co
Gloversville, NY


Twin City Leather CO., Inc.
Gloversville, NY


Wood & Hyde Leather Co
Gloversville, NY


Moench Tannning Compa
Gowanda, NY


Adirondac Leather Inc
Johnstown, NY


Allied Split Corp.
Johnstown, NY


Arrow Leather Finishing C
Johnstown, NY


Carviile National Leather C
Johnstown, NY



Year
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1991
Total HAP
Emissions
(Ibs/yr)
28000
42250
67750
53750
NR
NR
NR
NR
NR
NR
NR
NR
285000
158145
157041
146261
NR
NR
NR
NR
NR
NR
NR
250
NR
NR
NR
NR
NR
NR
NR
NR
NR
Total VOC
Emissions
(HAP & nonHAP)
(Ibs/yr)
28000
42250
67250
53250
NR
NR
NR
NR
NR
NR
NR
NR
285000
158145
157041
159716
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Total NonHAP
VOC emissions
(Ibs/yr)
NR
NR
NR
NR
NR
• NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
13455
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Total HAP
nonVOC emissions
(Ibs/yr)
NR
NR
500
500
NR
NS
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
250
NR
NR
NR
NR
NR
NR
NR
NR
NR
                                                  A-9

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Classic Leather Corp
Johnstown, NY


Gordon Finishing Co Inc
Johnstown, NY


H & J Leather Finishers In
Johnstown, NY


Karg Brothers, Inc.
Johnstown, NY



K-Lynn Split Inc
Johnstown, NY


Peart Leather Finishers Inc
Johnstown, NY


Peerless Tanning Co Inc
Johnstown, NY


Total HAP Total VOC Total NonHAP Total HAP
Year Emissions Emissions VOC emissions nonVOC emissions
(Ibs/yr) (HAP&nonHAP) (Ibs/yr) (Ibs/yr)
(Ibs/Vrt
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1992
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
12000
20250
15750
13574
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
12000
20250
15250
13074
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
' NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NF1
NR
NR
NR
NR
NR
NR
NR
NR
500
500
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
                                                 A-10

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Simco Leather Corp.
Johnstown, NY


Townsend Leather Compa
Johnstown, NY


Conneaut Leather Inc.
Conneaut, OH


Howes Leather Co., Inc.
Curwensville, PA


Garden State Tanning
Fleetwood, PA


Mercersburg Tanning
Mercersburg, PA


Garden State Tanning
Reading, PA


Seton Company
Saxton, PA


Year
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1989
1990
1991
1992
Total HAP
Emissions
(Ibs/yr)
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
55298
7522
NR
NR
NR
NR
NR
NR
NR
699089
148900
225800
49500
46700
NR
NR
NR
10
NR
169444
265994
267623
Total VOC
Emissions
(HAP & nonHAP)
(Ibs/yr)
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
68092
12277
NR
NR
NR
NR
NR
NR
NR
727987
204000
236850
109050
81250
NR
NR
NR
NR
NR
NR
NR
NR
Total NonHAP
VOC emissions
(Ibs/yr)
NR
NR
NR
NR
NR
• NR
NR
NR
NR
NR
12794
4755
NR
NR
NR
NR
NR
NR
NR
28898
55100
11050
60050
35050
NR
NR
NR
NR
NR
NR
NR
NR
Total HAP
nonVOC emissions
(Ibs/yr)
NR
NR
NR
NR
NR
Nfl
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
500
500
NR
NR
NR
10
NR
NR
NR
NR
                                                 A-11

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Westfield Tanning Compa
Westfiald, PA


Volunteer Leather Compa
Milan, TN


Lannom Tannery
Tullahoma, TN


Tennessee Tanning Co.
Tullahoma, TN


Coey Tanning Co., Inc.
Wartrace, TN


S.B. Foot Tanning Co.
Cactus, TX


Fox Valley Leathers, Inc.
North Salt Lake, UT


Total HAP
Year Emissions
(!bs/yr)
1987
1988
1989
1990
1987 .
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
NR
NR
NR
NR
66000
81000
64SCC
45500
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Total VOC Total NonHAP Total HAP
Emissions VOC emissions nonVOC emissions
(HAP & nonHAP) (Ibs/yr) (Ibs/yr)
(Ibs/vrt
NR
NR
NR
NR
85000
115000
75750
45500
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
19000
34000
1125Q
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Ntf
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
                                                 A-12

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Berlin Tanning Co.
Berlin , Wl


Cudahy Tanning Compan
Cudahy, Wl


A.F. Gallun & Sons Co.
Milwaukee, Wl


Blackhawk Tanning Co
Milwaukee, Wl


Gebhardt-Vogel Tanning
Milwaukee, Wl



Gebhardt-Vogel Tanning
Milwaukee, Wl



Paul Flagg Leather
Milwaukee, Wl



PFister & Vogel Tanning C
Milwaukee, Wl


Total HAP Total VOC Total NonHAP Total HAP
Year Emissions Emissions VOC emissions nonVOC emissions
(Ibs/yr) (HAP&nonHAP) (Ibs/yr) (Ibs/yr)
(Ibs/yr)
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990
1987
1988
1989
1990

1987
1988
1989
1990

1987
1988
1989
1990

1987
1988
1989
1990
250
NR
NR
NR
161050
99250
77950
78050
250
250
250
NR
NR
NR
NR
NR
500
250
250
45

40750
48600
20000
51280
*
NR
NR
NR
NR

159022
171018
111090
146260 .
14250
NR
NR
NR
160800
99000
77700
77800
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR

54750
65100
31000
51200

NR
NR
NR
NR

193100
256600
129650
172070
14250
NR
NR
.NR
NR
• NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
14250
16750
11250
NR
NR
NR
NR
NR
NR
NR
34100
85600
19700
26600
250
NR
NR
NR
250
2EO
250
250
250
250
250
NR
NR
NR
NR
NR
500
250
250
45

250
250
250
80

NR
NR
NR
NR

22
18
1140
790
                                                  A-13

-------
1987-1990 VOC and HAP Emissions from Tanning Operations
Facility
Theile Tanning Co.
Milwaukee, Wl



Paul Flagg Leather Corp.
Sheboygan, Wl



Howes Leather Co., Inc.
Frank, WV


Year
1987
1988
1989
1990

1987
1988
1989
1990

1987
1988
1989
1990
Total HAP
Emissions
(Ibs/yr)
NR
NR
NR
NR

NR
NR
NR
NR

NR
NR
NR
10
Total VOC
Emissions
(HAP & nonHAP)
(Ibs/yr)
NR
NR
NR
NR

NR
NR
NR
NR

NR
NR
NR
NR
Total NonHAP
VOC emissions
(Ibs/yr)
NR
NR
NR
NR
NR
NR
' NR
NR
NR
NR
NR
NR
NR
NR
Total HAP
nonVOC emissions
(Ibs/yr)
NR
NR
NR
NR

NR
N!3
k ir>
[\n
NR

NR
NR
NR
10
                                                  A-14

-------
                 APPENDIX B
LEATHER TANNING AND FINISHING PLANTS - CASE STUDIES
                      B-i

-------

-------
B.1  Introduction to Appendix B

      Appendix B includes case studies for five leather manufacturing facilities.  The
information included in the case studies was obtained during site visits to the respective
plants. All information claimed as confidential has been removed from the case studies.
                                      B-ii

-------

-------
                                   PLANT A

A.  General

      Plant A is a retanning and finishing facility that produces leather used for
manufacturing shoes, handbags, and belts. These products tend to be leathers with
heavy, oily finishes.

      The raw materials used at the plant are wet blue, or crust leather, that has been
chrome tanned at another leather tannery. The primary supplier of the wet blues is a
tannery located in another State.  The wet blues are retanned  prior to being finished.
The crust leather has already been retanned and is simply finished by Plant A.

      Most of the finishing is conducted in the newest section of the plant that houses
three leather coating lines, two of which are vented to an incinerator to control VOC
emissions. Older finishing lines are located in the original plant buildings and are
primarily used for specialty finishing. For example, one gun spray  booths are used to
create shadowing and antiquing effects on the leather by altering the angle of the
spray.

      . Plant A is capable of producing hundreds of product lines. This includes
variations in color, texture, feel, and grain thickness. Over 370 different chemicals and
additives are used to  produce coatings applied during the leather finishing process.
All coatings are custom  formulated on site, and coating formulations and usage are
closely tracked by the plant.  The major suppliers of coating components are Stahl,
BASF, Rohm & Haas, and Mobay.

B.  Process Description

      The primary purpose for visiting Plant A was to observe the  operation of the
newer finishing lines that are vented to a control device.  Most of the time spent at the
facility was focused on this part of the operation.  However, some wet-end processes
are performed at Plant A prior to finishing. The leather arrives at the plant in the wet
blue or chrome tanned condition.  The wet blue hides are retanned at the plant, and
some mechanical operations are performed prior to the leather being finished. These
operations include drying, softening and splitting of the leather. Plant A primarily
finishes the grain portion (top half) following splitting, but they  occasionally finish some
splits (the fleshy, or bottom half of the hide).
                                       B-1

-------
      Leather finishing is conducted using old and new technology. In the older
sections of the plant, one-gun finishing machines and four-gun finishing machine are
used for most of the leather finishing.  The one-gun spray equipment observed during
the visit is not controlled by optical eye or mechanical sensors, and the degree of
overspray was noticeably greater than optically controlled equipment.  The emissions
from these spray booths are uncontrolled. Most of the coating used in this section of
the facility are solvent-based coatings.  Although Plant A is in the process of moving
most of their finishing processes to the new spray facilities, these older machines are
used to apply special effects to the leather.  For example, the spray nozzle of a one-
gun machine can be angled to achieve a shadowing; effect on the leather.

      in the new section of the plant, modern finishing technology is used to finish the
leather.  Three finish lines are used in the new part of the plant and all of the spray
booths use eight-gun rotary sprayers that are optically controlled. The optical  controls
help to minimize overspray. Typically, three types of coatings are applied to the
leather:  a base coat, an intermediate coat, and a top coat.

C.  Sources of Emissions

      The leather finishing  operation is responsible for nearly all of the VOC and
hazardous air pollutant (HAP) emissions from the facility.  There are little, if any, VOC
emissions from the wet-end processes or from associated operations such as  the
wastewater treatment system.  Wastewater samples have been analyzed for total
organic  compounds and the concentrations were less than 10 mg/L

      In the older part of the plant, all of the finishing operations are uncontrolled for
VOC's.  Emission control measures are in place for particulate control.   Over half of
the total VOC emissions from the facility are emitted from this section of the plant.
      The new section of the plant was built in 1990 and is used for the majority of
the leather finishing.  There are three finishing lines located in this plant addition and
they are identified as Lines A, B,  and C by the State permitting authority.  At the plant
site, Line C consists of two spray booths, designated as machines 9B and 9C by the
plant, three drying ovens,  and one stick dryer. Line C also has a manual coatings
operation  that is identified by the plant as machine 9A.   The manual operation involves
application of coatings for special effects using hand spray guns.

      Line C is an uncontrolled finishing line that is used to apply water-based
coatings only. There is a VOC emissions limit of 20 tons per year for this line, along
with limitations on the VOC content of coatings applied during finishing.  The limitation
on the base coatings is 3.5 pounds of VOC per gallon (minus water) and the limitation
on intermediate coatings is 2.8 pounds  of VOC per gallon (minus water).
                                       B-2

-------
       Line A consists of two eight-gun spray booths (machines 1A and 1B) and two
 catalytic dryers. Line B (machine 2) consists of one eight-gun spray booth and one
 stream dryer.  As stated in the permit, VOC emissions from these two lines are limited
 to 35 tons per year.

       All  of the spray booths and dryers on lines A and B are vented to a
 regenerative thermal oxidizer (RTO) supplied by Salem Engelhard. The rated capacity
 of the RTO is 30,000 standard cubic feet per minute.  VOC destruction efficiencies of
 greater than 99 percent were determined by the tests. The incinerator is
 supplemented with natural gas to maintain combustion temperatures.  However, when
 two spray booths are operating in tandem and applying solvent-based coatings, the
 RTO temperatures can be maintained with little supplemental fuel.

       Emissions data for the plant were provided following the plant visit.  As noted
 above, the new addition to the plant and the incinerator were built in 1990.  The
 emissions data given below were recorded prior to emissions testing of the RTO. A
 95 percent destruction efficiency was assumed for the incinerator in estimating
 emissions from the incinerator outlet.

       1988        Total Plant VOC   276 tons

       1989        Total Plant VOC   136 tons

       1990        Total Plant VOC   154 tons
                  Line C            10.03 tons
                  VOC to RTO      54 tons
                  VOC out of RTO   2.7 tons

       1991        Total Plant VOC   119 tons
                  Line C            2.2 tons
                  VOC to RTO      41 tons
                  VOC out of RTO   2.0 tons

      The specific VOC emission points from the finishing operation are the vents
from the spray booths and dyers, the uncovered areas of the conveyers carrying the
leather from  the spray booths and dryers, fugitive emissions from the partially covered
drums containing coating, and  fugitive emissions from the finished leather. There is
also a small  mixing room that is a source of fugitive emissions.  The largest single
emission point in the plant is the vent to the RTO.
                                      B-3

-------
D.  Emission Reduction Measures

      The installation of the incinerator is the major emission reduction measure   -
employed by the plant. The system cost about $1.5 million dollars in 1989.  The
purpose of installing the incinerator to control emissions from the plant modification
was to allow for expansion of production without exceeding any State emission
limitations. Plant A was also anticipating increased business in producing military
leather. Military leather has to be waterproofed using high VOC-based sealing
systems.

      Other than the incinerator, Plant A is under little pressure to look for additional
VOC reductions.  The transition to more water^based coatings will only be made when
water-based technology is capable of producing the same quality leather as the
solvent-based systems.  Plant A believes that solvent-based coatings are still essential
to producing leather to meet their customers specifications. The coatings applied to
their leathers must be compatible with the finished coatings used by the shoe
manufacturers.  As the water-based technology improves, solvent-based coatings may
be phased out.

      Plant A has made progress in limiting emissions of some HAP's.  In the 1990
Toxic Release Inventory, Plant A reported emissions of 5 HAP's:  6.38 tons of toluene;
3.48 tons of xylene; 4.63 tons of methyl ethyl ketone (MEK); 8.6 tons of glycol ethers;
and 0.25 tons of chromium.  According to information provided by the plant, emissions
of toluene and MEK were eliminated in 1991 and emissions of xylene and  glycol ethers
have been reduced.  1991 emissions of xylene were reported to be 2.4 tons and
emissions of glycol ethers were reported as 5.75 tons per year.  These emission
reductions were the result of new coating formulations.

E.  Regulatory Compliance

      When Plant A  decided to modify the existing facility by adding the new finishing
lines, they entered into negotiations with the State. At the time, the area was an
unclassified air  quality management district.  However, for the purposes of permitting,
the  facility was considered to be in  a non-attainment area and, therefore, subject to a
lowest achievable emission rate (LAER) determination.  Part of the reason for setting
the  emission limit of 35 tons on  the new spray lines was to avoid new source review.
                                      B-4

-------
                                   PLANTS

A.  General
                                                  T
       Plant B produces automotive upholstery leather.  The leather production
process is divided between two facilities. Raw hides are processed and tanned at
another facility and then shipped to Plant B.  The tanned leather is referred to as crust
leather at this stage in the leather tanning and finishing process.  Plant B is strictly a
finishing and cutting plant.  The final product is cut automotive upholstery parts.

       Plant B is a new facility that began operations in 1989.  In 1992, all of the
finishing operations were transferred to this location with the exception of some minor
finishing processes that are still performed at the old site. The State has set an
emission limit of 250 tons per year (on a rolling monthly average) for the Plant B. The
area in which Plant B  is located was designated as an ozone attainment area when the
facility was constructed.  The 250 ton per year limit was set to avoid prevention of
significant deterioration (PSD) review.  This source appears in the Best Available
Control Technology/Lowest Achievable Emission Rate (BACT/LAER) Clearinghouse.
However,  the source did not actually undergo PSD review. Rather than proceed
through the review process, Plant B applied for a non-PSD permit with a 250 ton per
year limit.

B.  Process Description

       Plant B operates five finishing spray lines at this facility. All of the equipment
was supplied by Hampton Machine Company. Initially, four spray lines were permitted
by the State, with the  fifth spray line added in  1992.

       Plant B is equipped with five spray lines.  Four of these spray lines are vented
to a Reeco Incinerator.  The spray booths and dryers on each of these  lines are totally
enclosed.  The fifth spray line is not vented to the  incinerator.  Lines 1, 2, and  5 are
arranged in a row and can operate in series.  Lines 3 and 4 are also in-line and can
be operated in series.

       Both water-based and  solvent-based coatings are applied to the leather. The
spray lines are designed so that solvent-based applications can be vented to the
incinerator, while water-based applications are vented to the atmosphere.  Line 1 is
used to apply exclusively water-based coatings. The spray booth and dryer on this
line are not vented to  the incinerator. Lines 2 and 4 are used to apply either water or

                                       B-5

-------
solvent-based coatings. When solvent coatings are applied on these tines, the spray
booth and dryer exhaust are vented to the incinerator.  When water-based coatings
are applied on these lines, the spray booth and dryer exhausts are vented to the
atmosphere.  Lines 3 and 5 are used exclusively for applying solvent-based coatings,
usually topcoats. In  general the leather receives a total of three coatings.
Occasionally, the leather receives a fourth coating.

      Whenever a solvent based coating is applied on any line, the spray booth and
dryer exhaust are routed to an incinerator.  The incinerator is designed to handle a
maximum flow of 24,000 cubic feet per minute (cfm). At any given time,  two spray
lines can be vented to the incinerator.  The exhaust flow from each finishing line is
approximately 12,000 cfm. Theoretically, all five lines can be operating at one time if
only two are applying solvent based coatings.

      There is no process wastewater discharged from the plant. All process
wastewater is treated on site and then reused.  The water treatment system is located
inside the building. Any emissions resulting from the treatment (volatilization of
organic contaminates) of wastewater are exhausted through the building ventilation.  A
filter cake is generated from the waste water treatment which is disposed of as
hazardous waste.

C.  Sources of Emissions

      The major source of emissions at the plant is the incinerator stack.  Four of the
5 finishing lines can potentially be vented to the incinerator when solvent-based
coatings are being applied. At any given time,  a maximum of two lines can be vented
to the unit. All of the spray booths and dryers are totally enclosed.  Capture efficiency
testing has been conducted on two occasions and capture efficiencies of 65 to over
90 percent have been estimated. Based on test results, there are some  fugitive
emissions from the drying ovens, and also some emissions from spray booths not
vented to the incinerator.

      An additional source of VOC emissions is the mixing room. Plant  B estimates
emissions from the mixing room to be approximately 10 tons per year. This estimate
is based on analysis  of grab samples taken from the mixing room ventilation system,
personnel monitoring in the mixing room, and mixing room ventilation rates.

      Plant B maintains a detailed tracking system of product usage and VOC
emissions.  In all spray booths using water-based coatings, all overspray is collected
and reused or disposed. Plastic sheets are placed on the bottom of the spray booths.
The water-based coating is collected on the plastic and placed in buckets. The
buckets are weighed before the product is reused or disposed.  Some coating
remains on the plastic sheets, and these sheets are disposed as solid waste.  Prior to
disposal, all wastes are analyzed and the off-site disposal of VOC and individual toxics


                                      B-6

-------
are quantified.  Plant B accounts for any volatile component that leaves the plant in
solid or liquid waste in determining their air emissions.

       Plant B also attempts to account for any organic compounds that stay in the
product. Based on analysis of finished leather products,  Plant B has determined that
significant quantities of high boiling volatiles remain in the finished leather.  This is
based on analysis of finished leather samples up to a year after they are finished.  In
the case of water-based coatings this becomes significant in that a major portion of
the VOC's  are often high boiling compounds.

       Four of the 5 spray booths have water curtains for control of particulate
emissions.  The water used for the curtains is recycled until saturated, treated on site,
and then reused. The newest spray booth (Line 5) is a "dry" booth that does not have
a water curtain.  A dual bank of dry filters control particulate emissions.

D.  Emission Reduction Measures

       Plant B has implemented two strategies to reduce  VOC emissions. First, the
incinerator  was installed as part of the initial startup of the facility.  The incinerator is a
Reeco Re-therm,  Model #VF-C-24000-85, with a capacity of 24,000 cfm.  The installed
capital cost of this unit was about $800,000 in 1989. Efficiency tests have been
conducted  on the incinerator and VOC destruction efficiencies of greater than 98
percent have been documented. The operating temperature of the incinerator is
maintained at about 1500 degrees fahrenheit.  Supplemental fuel is used to maintain
the combustion temperature and to preheat the combustion chambers prior to venting
of the spray booths. When two spray booths are operating with applications of
solvent-based coatings, the incinerator does not require any supplemental fuel.

      The  Reeco incinerator is equipped with three ceramic packing beds to recoup
heat from the combustion flue gas.  Heat energy is transferred from the hot
combustion flue gas to the ceramic packing and then transferred to the incinerator
feed. At any time, the combustion chamber flue gas is  being routed through one bed
to heat the packing, the inlet stream to be incinerated is being passed through a
heated bed, and the third bed is idle.

      Plant B is currently operating two shifts.  Prior to starting production  on the first
shift, the incinerator goes through a two hour warm up  period to take the combustion
chamber temperature  from 500 F up to the 1500 F operating temperature.  At the end
of the second shift, the incinerator goes through a  3 hour cool down, from  1500 F to
500 F,  and  remains  at an idle temperature of 500 F while  the spray booths are not
being operated.

      Plant B has also initiated a program to introduce water-based coatings
wherever possible, and to find formulations that reduce emissions of VOC and HAP's.


                                      B-7

-------
For example, one base coat that previously had a VOC content of 10 percent along
with some HAP's, now has a VOC content of 1.74 percent with no HAP's.  Conversely,
there are other coatings for which Plant B has been unable to find a suitable water-
based substitute. Antique coatings have VOC contents greater than 95 percent, while
most of their topcoats have VOC contents greater than 85 percent.  At present, Plant
B feels that switching to all water-based coatings is not technically or economically
feasible.  The performance of most water-based top coats evaluated is not adequate
to meet their client specifications.  Additionally, Plant B estimates that the application of
some water-based coatings currently being considered could result in higher
emissions than applications of the controlled solvent-based coating.  In the case of top
coats, the VOC content of water-based alternatives can be as high as 20 percent.
Through calculations,  Plant B demonstrated that the use of such a top coat could
actually result in  higher emissions than using a solvent based coating and routing the
spray booth and dryer exhaust to the incinerator.  In the case of base coats, the
water-based coatings  used by Plant B  typically have 2 to 3 weight percent VOC in
their formulation.

      Another effort to minimize VOC emissions is optimization of the spray booth
design and operation. Plant B continues to experiment with their spray booths to
maximize transfer efficiencies and minimize the loss of material through overspray and
bounce back.  All of the spray booths are optically controlled. The leather passes
over infrared sensors that record the outline of the hide passing on the conveyor belt.
The spray guns turn off and on  according to the outline of the hide.

      Other factors also  influence the efficiency of the spray booth.  These factors
include conveyor speed, speed  of the rotary spray arm, spray gun efficiency, and
operator training. Plant B continues to experiment with approaches to optimize
transfer efficiency, including the  use of high-volume-low-pressure (HVLP) spray guns.
The rotary spray equipment at Plant B  is equipped with 16 guns as opposed to 8 used
by many other companies.

E. Regulatory Compliance

      As mentioned earlier, Plant B has taken a VOC limit of 250 tons per year to
avoid PSD review. Plant B is required to maintain annual VOC emissions on a rolling
12 month basis.  For the  calendar year 1992, Plant B indicated that VOC emissions
were about 120 tons.

F. Additional Information

      In one state, the company is required to comply with a limit of 5.8 Ibs of VOC
per gallon.  Most of the operations personnel at Plant B have been relocated from this
state to another location and in  some cases they are still involved in  the remaining
finishing operations. They were quick to point out the hinderance on operating


                                      B-8

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flexibility posed by the state leather finishing rule.  Instances where production was
dictated by compliance with the 5.8 Ibs VOC per gallon on a daily basis were cited.  In
some instances production schedules were modified so that a water-based finish was
applied on a given day to offset the use of solvent-based material.

      Plant B personnel pointed out that, as a company overall, they have reduced
VOC emissions from about 900 tons in 1989 to about 125 tons in 1992, with a
doubling in production. They also estimated that VOC emissions on a  per hide basis
have dropped from 1.2 to 0.4 Ibs/hide.
                                     B-9

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                                   PLANTC

A.  General

      Plant C supplies finished leather to the automotive industry.  According to Plant
C personnel, automotive upholstery is one of the most demanding leather products to
manufacture.  The automotive industry requires that the leather meet strict quality
standards. These quality standards include specifications for color, rubfastness, light
resistance, and various durability requirements. The finished product typically must
meet 20-25 specifications.  Plant C produces  about 400-500 different leather
upholstery products, taking into account the variety of colors, textures, and other
specialty leathers produced at the plant.

B.  Process Description

      Raw cattle hides are first treated to remove hair and other undesirable elements.
Following this initial treatment, the hides are laterally split into two layers.  The top half
is the grain side (or top side) while the bottom half is the flesh side or split.  Plant C
processes the full hide as opposed to many leather finishing operations that process
sides (a full hide cut into longitudinal halves).  The upper portions of the split hides
(top grain or full grain) are used to make upholstery leather while the splits are sold as
secondary products.  Many of the splits produced at Plant C are used to make raw
hide dog bones.

      From this point in the process, only the grain side of the hide is processed.
Following splitting, the hides are chrome tanned and then demoisturized.  The tanned
hides are then mechanically treated to adjust  the thickness of the raw material, and
then sorted by quality. Higher quality hides have fewer natural defects such as holes
and scratches. Plant C does not purchase hides that have been branded.

      After the hides are sorted, they are retanned using dyes and fatliquors. The
dyes used at this stage form the base color for the final product. Before the leather is
finished,  a number of intermediate steps are taken to dry, soften, and condition the
leather.  At this point, the leather is ready for finishing. The finishing process involves
the application of coatings to enhance the quality of the leather and provide protection
of the product.

      Plant C has a number of leather finishing lines used for both regular coating
operations and for research and development purposes.  At present, all of the finishing

                                      B-10

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lines use rotary spray coating applicators. Optical eye technology is used to minimize
overspray. The leather to be finished passes under an optical eye that reads the
outline of the leather.  The rotary spray applicators are controlled by computer and
turn off and on according to the pattern of the leather.

C.  Sources of Emissions

      The sources of VOC emissions are primarily from the leather finishing process.
All leather coatings are mixed on-site using components purchased from various
suppliers.  Although there is potential for some fugitive emissions from the mixing
process, Plant C uses mostly water based materials. The coatings  mixing room was
observed during the site visit and there was little, if any, evidence of solvent odors in
the room.

      Coatings are applied using rotary spray application equipment. Typically, three
finish coats are applied to each piece of leather.  The actual number of coatings will
vary according to the requirements of individual leather products. The rotary spray
equipment is housed in a partially enclosed chamber.  Coatings are applied from
airless spray guns located above the leather which moves through the spray chamber
on a conveyer belt. The conveyer belt is actually made up of a series of parallel  wire
coils.  A water bath is located below the conveyer belt and captures some of the
overspray.

      VOC emissions from the leather finishing operation result from overspray,
"bounce-back" of coating from  the leather, and from fugitive sources.  Some emissions
may also result from the open mixing drums that feed coating to the spray guns, and
from wastewater generated by the water baths.

      One additional source of VOC emissions at similar facilities could  be the leather
retanning process. At Plant C, very little, if any VOC laden materials are used for
retanning.  However,  retanning may be a source of VOC in facilities that use VOC
containing oils for retanning. In addition, wastewater produced by the retanning
process could be a source  of VOC, if VOC laden products are used in this process.

O.  Emission Reduction Measures

      Plant C has spent a great deal of resources in reducing the amount of VOC
used in their leather finishing process.  As a result, the facility has reduced their VOC
emissions and emissions of hazardous air pollutants dramatically since 1988.

      Conversion to water  based coatings is the primary emission reduction measure
implemented by Plant C.  Plant C claims that the transition to water based finishes has
reduced VOC emissions by 98 percent from 1988. In addition, there have been similar
                                     B-11

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reductions in HAP emissions. Most of the toluene and xylene emissions reported in
the 1990 Toxic Release Inventory have been eliminated.

      Data provided by Plant C indicate that total VOC emissions have been reduced
from 5.3 million pounds per year in 1988 to an estimated 0.26 million pounds for 1992.
Emissions data are also given in terms of pounds of VOC per 1,000 square feet of
processed hide, and for individual HAP's.

      Plant C plans to continue to look for additional reductions in VOC emissions.
However, any additional reductions will be relatively minor compared to the reductions
achieved thus far. It will become more difficult to find further ways to reduce the
amount of VOC used in the coatings. There are applications where some VOC is"
needed in the coating.  Plant C has also started to use roll coating machines to
supplement the rotary spray coating  machines.  The roll coating machines are
expected to have  a higher transfer efficiency than the spray coating machines,  thereby
reducing emissions resulting from  overspray and bounce-back.  However, there are
some limitations with the use of  roll coating in producing automotive leather
upholstery. Roll coating usually imparts a thinner coating than desired in most leather
upholstery applications.

E.  Regulatory Compliance

      Plant C is located in a moderate non-attainment area for ozone.  Currently,
Plant C  is permitted  as a major source of VOC. There is no specific rule for leather
finishing operations in the State. The State is in the process of developing a site-
specific rule for Plant C in the form of a consent order with the company.
                                     B-12

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                                   PLANTD

A.  General
                                                    *
       Plant D produces finished leather to be used primarily for footwear and other
fashion related products.  The raw material is cattle hide, and approximately 50,000
sides of leather are processed weekly.  A side of leather is a longitudinal half of a full
hide. The full hides are cut in two to facilitate processing.  The raw hides are tanned
and finished at the site.

       A wide range of finished leather is produced by Plant D.  Accounting for the
differences in color, weight, physical characteristics, and grain textures, Plant D
produces about 8,000 products.  The finishing process for each of these products is
specific, thereby making it difficult to characterize one specific leather finishing process
at the plant.  All of the finishes used at the facility are mixed on-site using varying
combinations of pigments,  dyes, binders, solvent, and other materials.

B.  Process Description

       Raw hides are first treated to remove hair and undesirable fats and oils using
water based chemicals. The  hides are pickled and then chrome tanned to stabilize the
collagen fibers vital for leather production.  Following these processes, the hides are
wrung out, cut into two sides, and split.  The bottom or fleshy part of the split (referred
to as the "split") is sold to  other manufacturers and the top part (referred to as the top
or full grain) is  processed further.  Following a mechanical demoisturizing process,
the hides  are retanned and dyed using soluble dyes and fat liquor.  The hides are then
placed in  drying ovens to remove moisture and sent through mechanical operations to
soften  the leather prior to finishing.

      The finishing process varies according to the type of leather being produced.
In general, each side receives a base coat, a middle coat, and a top coat or finish
coat. At Plant D,  the base and middle coats are mostly water based, while some of
the  finish coats are solvent based coatings or emulsions.  Some of the water based
finishing materials contain  some VOC's,  usually less than 10 percent by weight.  The
water based emulsions contain higher VOC concentrations than the water based
coatings.  The company is  attempting to convert most of their finishing processes to
water based coatings.  However, some product lines require a solvent based coating
or an emulsion to achieve  the desired properties in the finished  leather.
                                      B-13

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C.  Sources of VOC Emissions

      The primary source of VOC emissions at the facility is the leather finishing process.
Emissions  result from the application of coatings using various types of coating
technology. For example, rotary spray machines consist of multiple spray guns that apply
finishes to the leather as it passes on a conveyer belt. Emissions result from the solvent
flashing before the coating hits the surface of the  leather, and overspray of material
(including bounce-back from the  surface  of the leather).  The rotary spray coating
machines at Plant D are partially enclosed in a water wash booth under negative exhaust
pressure. Solvent vapors are collected in the spray areas  and exhausted to the outside
ambient air. There are no vapor control systems on vents to the ambient air.

      Small quantities of VOC emissions  also result from mixing and formulating of
coatings, fugitive losses prior to application of the coatings, equipment cleaning, and
wastewater disposal.  The mixing and formulation process was not observed during the
site visit.  However, it seems probable that small losses occur during the mixing  of the
coatings.  Once a coating is mixed, it is transferred to the  applications area in 30  gallon
drums. The coating material is pumped from the drums to the spray guns. The drums
are equipped with covers.  However, the drums can  remain partially or fully open  to the
atmosphere during the coating process thereby creating the potential for small emissions
of VOC's.

      Located beneath the conveyer belt that carries leather through the spray area is
a water bath.  Some of the overspray of the coatings is deposited in this water which is
recirculated and then discharged as wastewater.  This wastewater can be  a secondary
source of VOC emissions.

      Another source of air emissions is the tanning process.  This process  produces
small quantities of hydrogen sulfide and ammonia.  However, this part of the  operation
is not a significant contributor of VOC.

      Leather finishing is accomplished using 8 roll coaters, 6 rotary spray  coaters, and
one flow coater.  All of the coatings are mixed on-site. The individual components of the
coatings are purchased from suppliers such as Rohm & Haas, Stahl, BASF, Ciba-Geigy,
and Prime Leather Finishes.  Depending on the product, different coating formulations are
used. Each leather finishing process has a distinct formula that is kept in a computerized
file.  Plant D uses this information to calculate the amount of solvent used  on a daily
basis.  Use of all toxic chemicals is tracked by Chemical Abstract Service (CAS) number
on a daily and annual  basis.
      Plant personnel estimate that 90 percent of the bottom and middle coats are water
based coatings.  Most of the coatings containing the higher VOC quantities are used in
the top (or finish) coat.
                                     B-14

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      Toxic Release Inventory (TRI) data indicate that Plant D emitted over 45 tons of
hazardous air pollutants (HAP's) in 1990. Plant personnel verified this value, but indicated
that their emissions of both HAP's and VOC have been reduced since 1990.  All emission
estimates at the facility are based on solvent usage.  Emissions testing has not been
conducted.

D.  Emission Reduction Measures

      Reduction of VOC emissions has been achieved primarily through introduction of
water based coatings  and process changes over the'past several years.   Process
changes have included substitution of a roll coating machine for a curtain spray machine
and the application of oil coatings using heated oil.  The use of heated oil has enabled
Plant D to use an oil coating having a lower VOC content. In addition, optical eye spray
technology is used to minimize overspray and use of coating material.

      Specifically,  one coating process in the plant was responsible for an estimated 35-
40 percent of the total VOC emissions.  In this process, solvents were used to facilitate
oil penetration of the leather during coating. Plant D changed from a high solvent based
coating to a lower solvent based coating that was preheated prior to application to lower
viscosity.  Plant personnel reported that these changes reduced VOC emissions from this
process by about 90 percent.

      Plant D also has a policy of not allowing development of any leather product that
will exceed the daily limit set by the State.  Any further reduction in VOC emissions will
be achieved through  use of additional water based coatings.

E.  Regulatory Compliance

      Plant D is subject to the State rule for leather finishing operations.  This rule limits
VOC emissions from leather coating facilities to 18.6 kilograms per 100 square meters
(38.0 pounds per 1000 square feet) of  coated  product calculated on a daily average.
Plant D meets this  limit by using an "internal offset" system whereby products requiring
high VOC coatings are produced on the same day as those requiring low VOC, or water
based coatings.  Since the limit is based on a summation of total VOC's emitted during
the day divided by the prorated surface area of leather coated during the same day, Plant
D can meet the limit on a daily basis by monitoring the types and amount of products
produced on  a given day.

      Compliance  with the State regulation requires extensive recordkeeping. Plant D
keeps daily records of solvent usage and square footage of leather processed.

      Plant personnel indicated that the State regulation was conducive to computerized
tracking of coatings formulations and production. They are in favor of the production
based limit because it allows them to use the internal system of offsetting  to meet the


                                     B-15

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regulation. This enables the company to produce a greater variety of products, including
some that require high VOC finishes, and allows Plant D to remain responsive to the
needs of the fashion industry.
                                    B-16

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                                   PLANTE

A.  General
                                               »
       Plant E is exclusively a leather finishing plant.  The finished leather produced at
Plant E is sold primarily to the furniture manufacturing industry.

B.  Process Description

      Tanned cattle hides are shipped to Plant E from the company's tannery, located
in another state.  The hides are  in the crust stage, having been  chromed tanned,
retanned, colored, and dried at the tannery.  After arrival, the hides are conditioned by
introducing controlled amounts of moisture. They are then softened in large dryers and
mechanically treated to achieve desired properties prior to finishing.

      The finishing process involves application of 3 to 7 coats of finish on each  hide,
depending on the desired characteristics of the specific product line. Plant E is equipped
with eight rotary spray booths for leather finishing.  Each spray booth is followed by one
or  two drying  ovens.   All  of the spray booth and drying oven machinery  was
manufactured by the Hampton Machine Company.  Each of the spray booths is equipped
with optical eye controls to minimize overspray.  Some of the spray booths are equipped
with 16 spray guns while others  are eight gun booths.  Only 8 guns are operating at any
given time in the 16-gun booths.  Both high-volume-low-pressure (HVLP) and air assisted
spray guns are used at Plant E.  One of the base coat booths is currently equipped with
HVLP guns. The other booths are equipped with air assisted airless guns.

      Of the eight spray  booths,  five are used  exclusively for  applying water-based
coatings.  One spray booth is used for both water and solvent-based coatings, and two
booths are used only for application of solvent-based coatings. The water-based coating
booths and the solvent-based coating booths are segregated in the plant for safety
reasons.  The dryers used with the solvent-based spray booths are explosion  proof.

      There are five additional spray booths  at the plant. Two of the spray booths are
for hand spraying of finishes and three booths are hand spraying operations for testings
coatings  and .touch-up.

      Following application of the base coats and top coats, the leather is moved to  a
finishing room.  In the finishing room, the leather can be embossed using high pressure
machinery and/or put through additional softening and conditioning operations.  In

                                      B-17

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addition, some leather are antiqued in the finishing area through hand application of
special coatings.  Following all of the finishing operations, the feather is measured and
packed for shipping.

C.  Sources of Emissions

      All leather coatings are mixed on-site using components purchased from vendors.
The mixing room is a source of fugitive VOC emissions.  Plant E has not attempted to
quantify emissions from the mixing room.

      Coatings are applied using rotary spray application equipment.  Typically, three to
five finish coats are applied to each piece of leather, with seven coatings being  the
maximum number applied by Plant E. The actual number of coatings varies according
to the requirements of individual leather products. The rotary spray equipment is housed
in enclosed chambers.  Coatings are applied from airless and\or HVLP spray guns
located above the leather which  moves through the spray chamber on a parallel cable
conveyer.

      VOC emissions from the leather finishing operation result from overspray, bounce-
back of coating from the leather, and from fugitive sources.  Most of the VOC can be
expected to flash-off in the spray booths or in the drying ovens.  All of the spray booths
and ovens are vented to the atmosphere. Source sampling was conducted on two spray
booths in 1989 in preparation for a prevention of significant deterioration  (PSD) permit
application.  This permit application effort was abandoned.  There are no air pollution
control systems on the building ventilation system.

      Plant E has a small distillation unit in the plant to recover solvent from waste
coatings and cleanup solvents.   These waste streams and the plant  wastewater  are
segregated. Little,  if any, VOC emissions are generated from the wastewater system.

      Additional sources of fugitive emissions  are the partially covered coatings drum
located at each spray booth, and the antiquing process in the finish room. The antiquing
process consists of manual application of  a solvent based coating to the leather to
achieve an antique appearance.

D.  Emission Reduction Measures

      The only emission reduction strategy being employed by Plant E to control VOC's
is the transition to more water-based coatings. Plant E began using water-based coatings
in 1990.  Prior to that time, most of their coating formulations were solvent-based. The
reductions  from 1987 to 1990 were most likely  a result of formulation  changes by the
suppliers. According to plant personnel, the plant did not make a concerted effort to use
water-based materials  until 1990.
                                     B-18

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      VOC emissions per hide began to increase following 1990.  This increase was a
result of quality problems resulting from use of water-based coatings.  Plant E was forced
to use more solvent-based materials to satisfy customer requirements. Plant personnel
noted that it is often difficult to achieve the aesthetic feels needed for furniture leather with
water-based materials.   However, water-based technology is improving, and Plant E is
moving  back to water-based materials, particularly for their Spring  1993  product line.
According to plant personnel, the driving force behind the move to water-based materials
is from within the industry itself.  Minimization of solvent  usage improves the working
environment in regards to both aesthetics and safety. Some of. the water-based coatings
have 1.5 to 5 percent VOC in the formulations, while the largest percentage of water-
based coatings have no VOC.

      Other emission reduction efforts focus on optimization of the coatings application
process. Plant E has noticed some improvements in coating efficiency with the HVLP
guns, but this improvement is not documented.  Currently, HVLP guns are used only  on
the water-based lines.

      Emissions data provided by the plant for 1991 show some reduction in emissions
of hazardous air pollutants (HAP's) compared to 1990.  The 1990 Toxic Release Inventory
(TRI) indicated that Plant E emitted 223.5 tons of HAP's during that year:  methyl ethyl
ketone (MEK)(73.5 tons); toluene (70.03 tons); methyl isobutyl ketone (MIK)(16.31  tons;
and cyclohexane (63.72 tons). According to plant data, 1991 emission of HAP's were
about 185 tons:  MEK (6.83 tons); xylene (35.1 tons); MIK (49.31  tons); and toluene
(93.75 tons).  Cyclohexane emissions were below the reporting threshold for 1991.

E.  Regulatory Compliance

      Plant E is located  in an attainment area for ozone. Their current permit limits total
plant emissions to 702.3 tons per year on  a rolling twelve month average. Emissions
estimates are based on consumption  records kept by the plant.  The current emissions
limit is the result of steps taken in 1989 to avoid PSD. When modifications were proposed
in that year, 39.9 tons per year was added to the existing annual emission limit. The plant
also complies  with the  State regulations by  using solvent  mixtures  that are not
photochemically reactive as defined by the code.
                                     B-19

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                   APPENDIX C

STATE AND LOCAL REGULATIONS AFFECTING LEATHER TANNING
               AND FINISHING FACILITIES
                        C-i

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C.1  Introduction to Appendix C

      This appendix contains the full text of existing and proposed regulations affecting
leather tanning and finishing facilities. Regulations from these six State and local agencies
are included: a) New Jersey; b) New York (with proposed amendments); c) Wisconsin;
d) Massachusetts (draft rule); e) Illinois (draft rule); and e) the Monterey Bay Unified Air
Pollution Control District (draft rule).
                                                •»
      For the Wisconsin  rule,  the full text of  the technical support document for the
regulation is included in the appendix.  This document provides a detailed rationale for
the format of the rule.
                                       C-ii

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State of New Jersey
        C-1

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C-2

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                  NEW JERSEY STATE DEPARTMENT OF ENVIRONMENTAL
                             PROTECTION AND ENERGY

                         NEW JERSEY ADMINISTRATIVE CODE

                              TITLE 7, CHAPTER 27

                                 SUBCHAPTER 16

                  CONTROL AND PROHIBITION OF AIR POLLUTION BY
                           VOLATILE ORGANIC  COMPOUNDS
                                  Filed:
                              Effective:
                   Revision Promulgated:
                     Revision Effective:
                   Revision 'I'romulgated:
                     Revision Operative:
                   Revision Promulgated:
                     Revision Operative:
                   Revision Promulgated:
                     Revision Operative:
                   Revision Promulgated:
                     Revision Operative:
                   Revision Promulgated:
                     Revision Operative:
                   Revision Promulgated:
                     Revision Operative:
                   Revision Promulgated:
                     Revision Operative:
December 18, 1975
March 1, 1976
October 17, 1979
December 17, 1979
December 31, 1981
March 1, 1982
August 19, 1986
October 18, 1986
December 23, 1987
February 21, 1988
December 30, 1988
February 28, 1989
May 26, 1989
July 25, 1989
November 6, 1989
January 5, 1990
January 28, 1992
March 28,  1992
                               TABLE OF CONTENTS
7:27-16.1     Definitions
7:27-16.2     Storage of Volatile Organic Compounds
7:27-16.3     Transfer Operations
7:27-16.4     Open Top Tanks and Surface Cleaners
7:27-16.5     Surface Coating and Graphic Arts Operations
7:27-16.6     Source Operations Other Than Storage Tanks, Transfers, Open Top
              Tanks, Surface Cleaners, and Surface Coaters and Graphic Arts
7:27-16.7     Cutback and Emulsified Asphalts
7:27-16.8     Petroleum Solvent Dry Cleaning Operations
7:27-16.9     Emission Information and Tests
7:27-16.10    Variances
7:27-16.11    Applicability
7:27-16.12    Exceptions
                                      C-3

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/:2/-Lt>.3     ourrace  coating ana grapaic  arcs  operations

(a)  No person shall  cause,  suffer,  allow,  or permit  the  use  of  any surface
    coating  operation  unless:

    1.   The VOC content  of any  surface  coating formulation  as  applied does
         not exceed the  maximum allowable  VOC  content as  specified  in Table
         3A, 3B,  3C, 3D  or 3E;  or

    2.   If  more  than one  surface,  coating formulation subject  to  the same
         maximum  allowable  VOG  content limit  as  set forth  in the applicable
         table is  applied by  a single surface  coating operation,  the daily
         weighted mean of the VOC  content of  the  coatings  as applied does  not
         exceed  the maximum allowable VOC  content  as  set  forth  in Table  3A,
         3B, 3C,  3D or 3E,  as calculated ..using  the following equation:
              Daily mean  VOC  content »
             where      n  »  number of coatings,  subject  to the same maximum
                             allowable VOC content standard,  applied in one
                             day;

                        i  »  subscript denoting an individual surface coating
                             formulation;

                       Cj  »  maximum actual VOC content per volume of each
                             coating (minus water) applied in one day, in
                             pounds per gallon or kilograms per liter; and

                       v^  =  volume of each coating (minus water) applied in
                             one day, in gallons or liters; or
         If  the  surface coating operation is served by VOC control apparatus:

         i.    The  control apparatus  prevents no  less  than 90 per'-'*"'- bv weight
              of the VOC content  in  the  surface  coatine fortnuL-''      ••  M-I-I ••'*'*
              each hour  from  being discharged directlv  or  i^d'1   ' '    im-..  > 1,=,
              outdoor atmosphere: or

        ii.    The   VOC  emissions   from   the   surface  coating  operation   are
              controlled  by  the  control  apparatus   so  that   the  operation
              results  in an  hourly  VOC  emission rate' no  greater  thari  the
              maximum allowable hourly emission  rate  calculated on a solids as
              applied basis in accordance with the  following  equation:
                                    C-4

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       Maximum allowable hourly rate = (L-y/d)(z)(x)/(1-x/d)

       whire x = maximum allowable VOC content per volume of coating
                 (minus water), in pounds per gallon (Ib/gal) or
                 kilograms per liter (kg/1) as set forth in Table 3A,
                 3B, 3C, 3D, or 3E of this section;

             d = density of the VOC of the applied surface coating
                 formulation, in pounds per gallon (Ib/gal) or
                 kilograms per liter (kg/1);

             y = .VOC content of the applied surface coating formulation
                 (minus water) in .pounds per gallon (Ib/gal) or
                 kilograms per liter (kg/1); and

             z = volume of the coating (minus water) applied per hour
                 in gallons per hour (gal/hr) or liters per hour
                 (1/hr); or


iii.    For  a  surface   coating  operation  that  applies more   than  one
       surface   coating  formulation  subject   to  the   same  maximum
       allowable  VOC  content »limit  as  set  forth  in the  applicable
       table,  the  control  apparatus  collects  and  prevents   VOC  from
       being discharged  into  the outdoor atmosphere  so that the actual
       daily emissions  are  less  than  the allowable daily emissions  as
       calculated below:

       Actual daily emissions = (1-*? rTy )(VOCa)(V)
       where:    VOCa =    daily mean VpC content of the surface
                           coating formulations as calculated by 2
                           above;

                 V =       total daily volume of the surface coating
                           formulations, as applied;

                     =     capture efficiency, i.e. the ratio of the
                           VOC collected by the control apparatus  to
                           the VOC in the surface coating  formulations
                           as applied, as determined by a  method
                           approved by the Department  and  EPA;  and

                     =     destruction efficiency of the cqntrol
                           apparatus, i.e. the ratio of the VOC
                           prevented from being dischare0-' '••'•  ''"-•
                           outdoor atmosphere  to  th<; "'»* .  •• i i <•• i •>-!  i-v
                           the control apparatus, as de|:9'-min"rl ^v  -••>
                           method approved by  the Department -and EPA:
                           and
       Allowable daily emissions =  (l-VOC  /d)(V)(x)/(l-x/d)
                               C-5

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              where x = maximum allowable VOC content per volume of  coating
                        (minus water), in pounds per gallon (Ib/gal) or
                        kilograms per liter (kg/L) as set forth in Table 3A,
                        3B, 3C, 3D, or 3E of  this section;

                    d = density of the VOC of the applied surface coating
                        formulations in pounds per gallon (Ib/gal) or
                        kilograms per liter (kg/1);

                  .  V = total daily volume, in gallons or liters, of the
                        surface coating formulations (minus water) as applied
                        per day; and

                 VOCa = daily mean VOC content of the applied surface coating
                        formulations as calculated by 2 above; or


    4.   Until March 28,  1994,  the surface coating operation  is  included  in a
         mathematical  combination  of  sources   which   was   approved  by   the
         Department prior to March 28, 1992.

(b) No person  shall cause,  suffer,  allow, or  permit the installation  of any
    surface  coating or  graphic  arts »operation  to  apply  a  surface  coating
    formulation which  does  not contain water deliberately added  in a planned
    proportion  unless   a  coating   application  system  having   a  transfer
    efficiency  of   60  percent  or greater,  or  as otherwise  approved by the
    Department, is used.             *

(c) The provisions  of  (a)  and (b) above and  (f),  (g),  and (h) below shall not
    apply to any individual  surface  coating  or graphic  arts  operation in which
    the total surface coating formulations containing VOC are applied:

    1.   Prior to June 15, 1990,  at  rates  not in excess of one gallon per hour
         and five gallons per day;

    2.   As  of  June  15,  1990  and  continuously thereafter,  at rates  not   in
         excess of  one  half  gallon  per hour and two and  one half gallons  per
         day; or

    3.   For the purpose  of  developing new  coatings  or new coating  equipment,
         or  for the purpose  of performing research preceding such  development
         provided such formulations  are applied at  rates  not in excess of  two
         gallons per hour and three gallons  per  day.

(d) Any  person  responsible  for  any automobile  or  light dutv  truck  surface
    coating  operation  may,  as an  alternative  to  ^"r'ving.  i	•>  >••  ' •
    above,  with  the  content limits  set   ^orth  in  TaM• -
    coating  formulations,  provided  that  the  transfer  efficiency ot  the  spr.iy
    coating  operation  is determined in accordance with  a  method  approved  by
    the Department and the EPA.

                                      C-6

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                                    TABLE  3A

           MAXIMUPI ALLOWABLE  VOC  CONTENT  IN  COATINGS  FOR AUTOMOBILE
                AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS
Tvoe of Operation
   Maximum Allowable
 VOC Content per Volume
of Coating (minus water)
                   Final
               Compliance Date
 Prime

    Electrophoretic dip
    prime Spray prime

 Topcoat

    Spray topcoat

 Repair

 Custom  Topcoating

 Refinishing

    Base coat
    Clear coat
    All  others
                             Pounds Per
                               Gallon
   1.2
   2.8
   2.8

   4.8

   5.0
   6.0
   4.4
   5.0
               Kilograms
               Per Liter
0.14
0.34
0.34

0.58

0.60
0.75
0.54
0.60
December 31, 1982
December 31, 1984
December 31, 1986

December 31, 1986

June 15, 1990
June 15, 1990
June 15, 1990
June 15, 1990
                                      C-7

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                                   TABLE 3B

                   MAXIMUM ALLOWABLE VOC CONTENT IN COATINGS
                 FOR MISCELLANEOUS SURFACE COATING OPERATIONS
         Type of Operation
   Maximum Allowable
 VOC Content per Volume
of Coating (minus water)
Group I
    Can Coating
      Sheet basecoat
      Two-piece can exterior

      Two- & three-piece can
      interior body spray,
      two-piece and exterior

      Side-seam spray
      End sealing compound
                                     i
    Coil Coating
    Fabric Coating
    Vinyl Coating
    Paper Coating
    Metal Furniture Coating
    Magnet Wire Coating
    Large Appliance Coating

    Miscellaneous Metal Parts
         and Products
      Clear coating
      Air-dried coating
      Extreme performance coating

      All other coatings

    Flat Wood Paneling
      Printed hardwood plywood panels
        and particleboard panels
      Natural finish hardwood plywood
      Hardboard panels

Group II
    Leather Coating
    Urethane Coating
    Tablet Coating
    Glass Coating
                                            Pounds per
                                              Gallon
   2.8
   4.2
   5.5
   3.7

   2.6
   2.9
   3.8
   2.9
   3.0
   1.7
   2.8
   4.3
   3.5
   3.5

   3.0
    2.7
    3.3
    3.6
    5.8
    3.8
    5.5
    3.0
               Kilograms
               per Liter
0.34
0.51
0.66
0.44

0.31
0.35
0.45
0.35
0.36
0.20
0.34
0.52
0.42
0.42

0.36
 0.32
 0.40
 0.43
 0. frh
 0.36
                                      C-8

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                                    TABLE  3C
       ALTERNATIVE MAXIMUM ALLOWABLE VOC  CONTENT IN COATINGS WITH MINIMUM
          TRANSFER EFFICIENCIES REQUIRED FOR SPRAY COATING OPERATIONS
    Maximum Allowable VOC Content
       per Volume of Coating                      Minimum Transfer
    _ (minus water) _                  Efficiency Required

    Pounds per     Kilograms
      Gallon       per Liter

       3.0            0.36              -.                  34
       3.2            0.38                     -            37
       3.4            0.41                                 42
       3.6            0.43                               "  47
       3.8            0.46                                 52
       4.0            0.48                                 58
       4.2            0.50                                 65

NOTE:    Each combination  of VOC consent, and  transfer efficiency  in  Table  3C
         is equivalent to a  daily emission of  15.1  pounds  of VOC per gallon  of
         solids  deposited,  minus  water.   Verification  of  this  equivalent
         emission  rate  using  the  methods  prescribed  in  the  "Protocol  for
         Determining  the  Daily Volatile  Organic  Compound  Emission  Rate  of
         Automobile   and   Light   Duty   Truck   Topcoat   Operations"   (EPA
         450/3-88-018) shall satisfy compliance with Table 3C.


                                    TABLE  3D

                  MAXIMUM  ALLOWABLE VOC CONTENT IN  COATINGS
                       FOR GRAPHIC ARTS SOURCE OPERATIONS
                                                 Control Criterion

For formulations that contain water:   Maximum Allowable volume percent VOC in
                                       volatile fraction of coatings  (VOC plus
                                       water) as applied.
                                                 Volume Percent
                                                      25.0

                                  or

For formulations that do not
    contain water:                     Maximum Allowable VOC Content  per
                                       volume of ; formulation (minus water)

                                            Pounds per     Kilograms
                                              Gallon       per  Liter

                                                2.9           0.35


                                     C-9

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                                   TABLE 3E

                 MAXIMUM ALLOWABLE VOC CONTENT IN COATINGS  FOR
                   WOOD FURNITURE SURFACE COATING OPERATIONS
      Type of Surface
    Coating Formulation
   Maximum Allowable
 VOC Content per Volume
of Coating (minus water)
Semitransparent stain
Wash coat
Opaque stain
Sealer
Pigraented coat
Clear topcoat
Pounds per
Gallon
6.8
6.1
4.7
5.6
5.0
5.6
Kilograms
per Liter
0.82
0.73
0.56
0. 6 7
0.60
0.67
(e) Any person responsible  for  any metal furniture or large appliance  surface
    coating operation may,  as  an alternative to complying with  the  applicable
    maximum allowable VOC  content limits per volume  of  coating  (minus  water)
    set forth  in  Group I  of  Table  3B,  pursuant  to  (a)l  above,  apply  to  the
    Department for  an  alternative  maximum  allowable VOC content  limit  per
    volume  of  coating,   provided  such  person   can  demonstrate   to   the
    satisfaction   of   the  Department  and  the  EPA that  the  surface  coating
    formulation is applied at transfer efficiency of greater than 60 percent.

(f) Any person responsible  for  a rotogravure, flexographic, or  fabric  printing
    operation may, as an  alternative  to complying with  the requirements  set
    forth  in  Table   3D,  pursuant  to  (a)l   above,   install  and  use  control
    apparatus which:

    I.    Collects  at   least  75 percent by volume of the source  gas emitted from
         a  rotogravure  printing  operation,  including associated dryers,  and
         prevents  from  being  discharged into the  outdoor atmosphere  at least
         90 percent by volume of the VOC collected on an  hourly basis;

    2.    Collects  at   least  7"0 percent by volume of the source  gas emitted from
         a  flexographic  printing  operation,  including associated  dryers,   and
         prevents  from  being  discharged into the  outdoor atmosphere  at least
         90 percent by volume of the VOC collected on an  hourly basis; or

    3.    Collects  at   least  70 percent by --^Lume  of tho =n,,v-°  c.  .••••> ,i i, .,,,
         a  fabric   printing   operation.  includinc   a?<=°' i->'<>-    •  •" • .
         prevents  from  beir.e  discharged :.nto  the  outdoor  a tm^-r1'0 • -   "•  >•-!-'
         90 percent by volume of the VOC collected on  an hourly basis.

(g) Notwithstanding  the  provisions  of  (a)3.ii   and  (a)4  above,  any  person
    responsible for  a  tablet   coating  operation   that uses a  surface  coating
    formulation that  does  not  comply with  the  maximum  allowable VOC  content
    limits  per volume of  :cating  (minus water) set  forth in  Table  3B,  Group
    II, shall install and  use  control apparatus which prevents no  Less  than 30
                                     C-10

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    t/ti-jeu- „>• weignL ui  w^e  ^^^  concent:  in  cne  surrace  coating  tormuiati.cn as
    applied each-"hour from being discharged directly or  indirectly into  the
    outdoor atmosphere.

(h) Any  person  responsible  for  a  wood  furniture  surface  coating  operation
    shall comply with the following requirements:

    1.   At a facility emitting less than 50 tons  (45.36 megagrams)  of VOC  per
         year, each surface coating formulation  specified  in Table  3E shall be
         applied using airless, air-assisted airless,  or heated airless  spray
         techniques, or another application  method approved by  the  Department
         and the EPA as  having a transfer efficiency of at  least  40  percent; or

    2.   At a  facility  emitting  50  tons (45.36 megagrams)  of  VOC  or greater
         per  year,  each  surface  coating formulation specified in Table 3E
         shall be applied using airless,  air-assisted  airless, heated airless,
         electrostatic spray  techniques, or flat  line  processes,   or another
         application method approved by  the  Department and  the EPA  as having  a
         transfer efficiency of at least 65  percent.

(i.) Any  person  responsible  for  an  automobile  or  light   duty  truck surface
    coating operation subject  to  a. VOC content limit for  custom topcoating or
    refinishing set  forth in  Table  3A of this  section  shall comply with  the
    following schedule:

    1.   By July 1,  1989,  a  plan  must be submitted to the Assistant Director,
         Enforcement  Element,   New    Jersey   Department   of   Environmental
         Protection, CN  027,   Trenton,  NJ 08625,  for  approval  describing  the
         measures which will  be applied  in  order  to achieve  compliance.   The
         plan submittal  shall include:

         i.   Completed  applications  for all  "Permits to  Construct,  Install,
              or Alter  Control Apparatus or Equipment"  and "Certificates  to
              Operate Control Apparatus  or  Equipment"  required  by N.J.A.C.
              7:27-8; and

        ii.   Documentation of the  rates of  application  of surface  coating
              formulations in surface  coating   operations  excluded  under  the
              provisions of (c) above and (k) below; and

       iii.   Details of  production  rate changes  or process  modifications for
              which  no   "Permits   to  Construct,   Install,  or  Alter  Control
              .Apparatus  or Equipment" are required.

    2.   By  July  1,  1989,   and  by   the first  day  of   everv fourth  month
         thereafter,  persons   subject   to  an  emissi^-'  Limit-i*-- •   •.,'.,, i  .....
         topcoating or  refinishing  usine surface  ••••?':ine '-of	
         measure 'for  complying with  the  provision? of  ' 9 >  ?b^"~    'i'M   <=uhnn<
         detailed  reports describing  the  progress being  made  with spec if i-
         coating  manufacturers   and   suppliers   toward   the   development   of
         suitable .formulations.   The  reports  shall b-e  sent  to the Assistant
         Director,  Enforcement Element, at the address in  (i)l above.

    3.   By no later  than six months  prior  to  the applicable final compliance
         date set forth in Table  3A,  construction or installation  of equipment


                                     C-11

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         and control  apparatus,  in accordance  with the  approved  plan,  shall
         commence.

    U.    By  the  applicable  final  compliance   date  set  forth  in  Table   3A,
         compliance with this  Section  shall be achieved.

(j) Any person responsible  for a  surface  coating.operation  subject  to  a  VOC
    content  limit   set -forth  in  Table  3B,  Group  II  for  leather coating,
    urethane coating, tablet coating,  glass coating; in Table 3D for fabric or
    urethane printing operations;  or  in  Table  3E  for  wood furniture coating,
    shall comply  with the following schedule:

    1.    By January  30,  1987,  a  plan  must be submitted  to the Department  for
         approval describing  the  measures  which  will  be applied  in order to
         achieve  compliance.   The  plan submittal shall  include:

         i.   Completed applications  for  all "Permits  to Construct, Install,
              or  Alter  Control Apparatus  or Equipment"  and  "Certificates to
              Operate Control Apparatus or Equipment"  as required by N.J.A.C.
              7:27-8;

        ii.   Completed  applications,  if   relevant,   for   the   mathematical
              combination of  source gases;

       iii.   Documentation of  the rates  of  application  of surface  coating
              formulations in  surface coating  operations  excluded  under  the
              provisions of (c) above; and

        iv.   Details of  production rate  changes or process  modifications  for
              which  no  "Permits   to   Construct,  Install,  or  Alter  Control
              Apparatus or Equipment"  are  required.

    2.    By 'January  1,  1987  and  by the  first  day  of  every  fourth  month
         thereafter, persons using surface coating reformulation  as a  measure
         for complying  with  the  provisions  of   (a) or (h) above  shall  submit
         detailed  reports  describing  the  progress  being  made with  specific
         surface  coating manufacturers and suppliers  toward the development of
         suitable formulations.

    3.    By May 1,  1987,  construction or installation  of equipment and control
         apparatus, in accordance with the  approved plan shall commence.

    U.    By December 31, 1987, compliance with  this section shall be achieved.

(k) The provisions of this section shall not apply  to:

    1.    The  surface   coatine  of   aircraft   and     ••  >"> '••• -
         exclusive of parts coated pric". 10  ins tall?h. i'?"  or gs = °inM"-

    2.    The  refinishing  of   automobiles,   if   coating   use  is  less  than  ^"
         gallons  (189 liters) per  week;

    3.    The customized  topcoating of  automobiles and  trucks,  if  coating use
         is less  than ^8 gallons  (182 liters) per week;  and


                                    C-12

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    4.   The on-site coating of  assembled  structures  such as, but not  Limited
         to,  equipment  used  for  manufacturing  processes,  storage   tanks,
         bridges, and swjjnming  pools.

(1) Any  person   responsible  for  the  emission  of any VOC  from  any  surface
    coating operation  subject  to  this  section applying  only surface  coating
    formulations which  are  subject  to  and conform  with the  applicable VOC
    content limit  set  forth in  Table  3A,  3B, 3C,  3D,  or  3E  shall maintain
    records of  the  VOC  content  of  each  surface coating  formulation   (minus
    water) as applied, in  pounds  of VOC per gallon of coating or kilograms of
    VOC  per  liter of  coating;   the  percent by weight of any  exempt  organic
    substance;   and  the  daily  volume  of  each  surface   coating formulation
    applied.

(m) Any person responsible for any surface  coating operation, which  is  subject
    to this section  and which uses  one or more  surface  - coating  formulations
    which do not  conform with the -applicable  VOC content limit  set forth in
    Table 3A,  3B, 3C, 3D, or 3E,  shall maintain the following records:

    1.   On a  daily basis,  specification   of  the following  for  each  surface
         coating formulation as applied:

         i.    The number  of hours applied;

        ii.    The volume  applied;

       iii.    The density of the  formulation;

        iv.    The density of the  VOC  in  the formulation;

         v.    The percent by weight of  the  VOC  in  the formulation;

       vi.    The percent  by weight  of any exempt  organic  substance   in  the
              formulation;  and

       vii.    The percent by weight of  any water in the formulation;

    2.    For any surface coating operation  that has a  thermal oxidizer  used to
         control the emission  of  VOC,  record   on  a  continuous basis or  at  a
         frequency  approved  in  writing   by   the  Department   the   operating
         temperature  at  the exit of  the   combustion  chamber  and  the  carbon
         monoxide  concentration   in   the  flue  gas   emitted  to   the  outdoor
         atmosphere;

    3.    For any surface coating  operation that has a control  ?i?p?r?ituj: ».?inz
         carbon  or other  adsorptive material to coot-?' ^Ho ami-   ••   r  "<"••

         i.    Record  on  a  continuous  basis  or   ?h.  * freq"e<";  -MM"  ^V-°H
             writing by the Department the concentration of tlie total VOL  m
              the flue  gas  emitted to the outdoor atmosphere; or

        ii.    Record  the date and  time  the carbon or other adsorptive material
              used in  the  control apparatus  is  regenerated or  replaced; and
             maintain  any other  information required to document whether the
              control apparatus   is  being  used and  maintained  in   accordance

                                     C-13

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             with    the    manufacturer's   recommended    procedures.      The
             manufacturer's  recommendations  for use and maintenance are  to  be
             readily  available  on  the  operating  premises,  and  the   person
             responsible   for   the  surface  coating  operation  shall   provide
             these  to  the  Department  upon request;  and

    4.    Upon  request of  the Department  and  at a  frequency  specified  by  the
         Department,  record  any  other  operation   parameter  relevant  to  the
         prevention  or control  of  air  contaminant  emissions  from the  surface
         coating  operation  or control  apparatus.

(n)  All or part  of  the information  documenting the  composition  of a  surface
    coating  formulation  as  required by  (1) or  (m)  above may be in the  form  of
    standard  formulation sheets, material safety data  sheets,  the results  of
 1   analytical  tests,  or another  form  provided  that  the required  information
    can be readily extracted.
                                   C-14

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State of New York
       C-15

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THIS DOCUMENT IS BASED ON THE PROPOSED AMENDMENTS INCLUDED IN THE
EXPRESS TERMS APPROVED BY THE ENVIRONMENTAL BOARD ON 1-29-93.
(3-30-93:JRC)


                             PART  228
                    SURFACE COATING PROCESSES

228.1 Applicability and compliance
228.2 Definitions
228.3 Volatile organic compound emission control requirements
228.4 Opacity
228.5 Reports, recordkeeping, sampling and analysis
228.6 Prohibition of sale or specification
228.7 Table  1
228.8 Table  2
228.9 Products regulated
228.10 Handling, storage and disposal of volatile organic
compounds(VOC)

          Section 228.1 Applicability and compliance, (a)  Any
owner or operator of a facility involving a coating line
described in table 1 of section 228.7 or in table 2 of section
228.8 of this Part and which meets the current applicability
criteria, must when applying for a permit to construct or a
certificate  to operate as required.by Part 201(Permits and
Certificates), include with the application for a permit to
construct or certificate to operate, the method or methods which
will be used to comply with the requirements of this Part.

               (b)  Except as provided in section 228.l(h) of
this Part, any owner or operator of a facility involving a
coating line described in table 1 of section 228.7 or in table 2
of section 228.8 of this Part, which is located in the New York
City metropolitan area, must comply with this Part according to
the following schedule.

               (1) Except as provided in 228.1(b)(2), any owner
or operator  of a facility involving a coating line described in
table 1 of section 228.7 of this Part which was constructed on or
prior to August 23, 1979 must have demonstrated compliance with
this Part not later than May 10, 1984.

               (2) Any owner or operator of a facility involving
a coating line described in table 1 of section 228.7 of this
Part, who utilized less than five gallons per day of coating
material on  a facility-wide basis and had valid certificates to
operate, must have demonstrated compliance with this Part not
later than May 15, 1991.

               (3)  Any owner or operator of a facility involving
a coating line described in table 1 of section 228.7 of this Part

                               C-17

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which was constructed after May 10, 1981 must have demonstrated
compliance with this Part upon start-up.

               (4)  Any owner or operator of a facility involving
a coating line described in table 2 of section 228.8 of this Part
which was constructed on or before September 1,  1988 must have
demonstrated compliance with this Part not later than
May 15, 1991.

               (5)  Any owner or operator of a facility involving
a coating line described in table 2 of section 228.8 of this Part
which was constructed after September 1,^1988 must have
demonstrated compliance with this Part upon start-up.

               (c)  Except as provided in section 22&.l(h) of
this Part, any owner or operator of a facility involving a
coating line described in table l of section 228.7 or in table 2
of section 228.8 of this Part, which is located in Lower Orange
County metropolitan area must comply with this Part according to
the following schedule.

               (1)   Any owner or operator of a facility
involving a coating line described in table 1 of section 228.7 of
this Part which was constructed on or before  August 23, 1979 for
which the annual potential to emit volatile organic compounds
from all sources regardless of process type, but excluding
combustion installations, at the facility equal or exceed 100
tons must have demonstrated compliance with this Part not later
than May 10, 1984.

               (2)  Any owner or operator of a facility involving
a coating line described in table 1 of section 228.7 of this Part
which was constructed after May, 10, 1981 for which the annual
potential to emit volatile organic compounds from all sources
regardless of process type, but excluding combustion
installations, at the facility equal or exceed 100 tons must have
demonstrated compliance with this Part upon start-up.

               (3)  Any owner or operator of a facility involving
a coating line described in table 1 of section 228.7 for which
the annual potential to emit volatile organic compounds from all
sources regardless of process type, but excluding combustion
installations, at the facility equal or exceed 10 tons, or a
coating line described  in table 2 of section 228.8 of this Fart,
for which the annual potential to emit volatile organic compounds
from all sources  regardless of process type, but excluding
combustion installations at the facility equal or exceed 25 tons,
must:

               (i)  submit a compliance plan to the Department  of
Environmental Conservation by November  15, 1993  which contains a
schedule of the steps necessary for the facility to achieve


                               C-18

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compliance with this Part or limit its annual potential to emit
below the applicability criteria and the dates by which each step
will be completed;

               (ii)  be in compliance with this Part or have had
its permits modified to limit its annual potential to emit below
the applicability criteria by June 1, 1995; and

               (iii) maintain the VOC control requirements and
compliance schedule included in any permit, regulation, rule,
administrative order, or any judicial order,, until compliance
with the provisions of this Part is demonstrated to the
satisfaction of the commissioner.

               (4) Any owner or operator of a facility involving
a coating line described in table 1 of 228.7 or table 2 of
section 228.8 which is constructed after March 1, 1993 and which
meets the applicability criteria specified in 228.1(c)(3), must
demonstrate compliance with this Part upon start-up.

               (d)  Except as provided in section 228.l(h) of
this Part, any owner or operator of a facility involving a
coating line described in table 1 of section 228.7 or in table 2
of section 228.8 of this Part, which is located outside the New
York City metropolitan area and Lower Orange County metropolitan
area, must comply with this Part according to the following
schedule.
               (1)  Any owner or operator of a facility involving
a coating line described in table 1 of section 228.7 of this Part
which was constructed on or before August 23, 1979 and is located
in the counties of Albany, Cayuga, Columbia, Dutchess, Erie,
Genesee, Greene, Livingston, Monroe, Niagara, Onondaga, Ontario,
Orange  (outside the Lower Orange County metropolitan area)
Orleans, Putnam, Rensselaer, Saratoga (limited to the towns of
Clifton Park and Halfmoon, the city of Mechanicville, and the
town and village of Waterford), Schenectady, Seneca, Ulster,
Wayne, Wyoming, or Yates for which the annual potential to emit
volatile organic compounds from all sources regardless of process
type, but excluding combustion installations, at the facility
equal or exceed 100 tons must have been in compliance with this
Part not later than May 10, 1984.

               (2)  Any owner or operator of a facility involving
a coating line described in table 1 of section 228.7 of this Part
which was constructed after May 10, 1981 and is located outside
the New York City metropolitan area and Lower Orange County
metropolitan area for which the annual potential to emit volatile
organic compounds from all sources regardless of process type,
but excluding combustion installations, at the facility equal or
exceed 100 tons must have demonstrated compliance with this Part
upon start-up.
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               (3)   Any owner or operator of a facility involving
a coating line described in table 1 of section 228.7 for which
the annual potential to emit volatile organic compounds from all
sources regardless of process type, but excluding combustion
installations, at the facility equal or exceed 10 tons, or a
coating line described in table 2 of section 228.8 of this Part
for which the annual potential to emit volatile organic compounds
from all sources regardless of process type, but excluding
combustion installations, at the facility equal or exceed 50 tons
must:

               (i) submit a compliance plan to the Department of
Environmental Conservation by November 15, 1993  which contains a
schedule of the steps necessary for the facility to achieve
compliance with this Part or reduce its annual potential to emit
below the applicability criteria and the dates by which each step
will be completed;

               (ii)  be in compliance with this Part or have had
its permits modified to limit its annual potential to emit below
the applicability criteria by  June 1, 1995; and

               (iii) maintain the VOC control requirements and
compliance schedule included in any permit, regulation, rule,
administrative order, or any judicial order, until compliance
with the provisions of this Part is demonstrated to the
satisfaction  of the commissioner.

               (4) Any owner or operator of a facility involving
a coating line described in table  1 of 228.7 or table 2 of
section 228.8 which is constructed after March 1, 1993 and which
meets the applicability criteria specified in 228.1(d)(3), must
demonstrate compliance with this Part upon start-up.

               (e)  This Part previously contained a facility-
wide emission reduction  (bubble) plan involving processes covered
by the provisions of this Part to  reduce emissions to the level
which would be allowed if a surface coating complied with the
limits specified  in table 1 of section 228.7 of this Part.  Any
owner or operator of a facility which has operated in accordance
with a facility-wide emission reduction plan approved by the
commissioner  must:

               (1)  submit a compliance plan to the Department of
Environmental Conservation by November 15, 1993  which contains a
schedule of the steps necessary for the facility to achieve
compliance with this Part and the  dates by which each  step will
be completed;

                (2)  be in compliance with this Part by June  1,
 1995; and
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               (3) maintain the VOC control requirements and
compliance schedule included in any permit, regulation, rule,
administrative order, or any judicial order, until compliance
with the provisions of this Part is demonstrated to the
satisfaction of the commissioner.

               (f) Any owner or operator of a surface coating
process, which is not regulated under this Part, shall comply
with all other applicable Parts of this Subchapter.

               (g) Any coating line that is subject to the
provisions of this Part, will remain subject to these provisions
even if the annual potential to emit volatile organic compounds
from the facility later fall below the applicability criteria.

               (h) This Part does not apply to the following
coatings:

               (1) research and development processes involving
surface coating which produce a product for study rather than
eventual sale;

               (2) adhesives and materials used to prepare a
surface for adhesion where the coating is manually applied
without the use of mechanical means;

               (3) sealant or filler used to seal or fill seams,
joints, holes and minor imperfections of the surface where the
coating is manually applied without the use of mechanical means;

               (4) anti-corrosive wax and heat resistant anti-
corrosive coatings used in the automobile manufacturing industry
to protect door opening seam areas and floor pan areas,
respectively;

               (5) clear or translucent coatings, applied to
clear or translucent plastic substrates which are utilized in the
manufacture of backlighted outdoor signs;

               (6)  coatings which are applied manually with a
brush, roller, or an aerosol spray can;

               (7)  aerospace coatings which are utilized for
pretreatment, adhesive bonding primers, flight testing, fuel
tanks, electric/radiation effects, space vehicles and temporary
mechanical maskant/high temperature heat treatment.

               (8) clear and pearlescent coatings applied to
plastic fashion items such as beads, buttons, buckles or other
plastic accessories used in the fashion industry;
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               (9)  coatings which are applied to optical lens at
facilities whose annual potential to emit volatile organic
compounds are less  than 10 tons;

               (10)  reflective coatings applied to highway cones;

               (11)  electromagnetic interference/radio frequency
interference (EMI/RFI)  coatings applied on plastic electronic
equipment to provide shielding against electromagnetic
interference, radio frequency interference, or static charge; or

               (12)  electric dissipating.coatings that rapidly
dissipate a high-voltage electric charge applied on plastic
parts.

               (13)  low-use specialty coatings where the
plantwide total annual usage is equal to or less than 55 gallons
provided that:

               (i)  each specialty coating must be approved by the
commissioner's representative prior to application;

               (ii)  records must be maintained on an as used
basis in a format acceptable to the commissioner that document
the annual usage;

               (iii) the annual potential to emit from low-use
specialty coatings does not exceed 5 percent of the facility's
total annual potential to emit; and

               (iv)  the facility's permits are modified to
identify any coating(s) approved by the commissioner's
representative which are exempt from this Part.

               228.2 Definitions,  (a) For the purpose of this
Part, the general definitions of Part 200 will apply.

               (b)  For the purpose of this Part, the following
definitions also apply:

               (1)  Annual. Refers to a period of time based upon
a calendar year commencing January 1st and terminating midnight
December 31st.

               (2)  Capture system. All the equipment including,
but not limited to, hoods, ducts,  fans, booths, ovens or dryers
that  contains, collects, and transports  an air pollutant to a
control device.

                (3) Clear coating.  A coating which lacks color
and opacity  or is transparent and  uses the undercoat as a
reflectant base or under-tone color.


                               C-22

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               (4)  Clear topcoat.  The final coating which
contains binders but not opaque pigments and which is
specifically formulated to form a transparent or translucent
solid protective film 'on wood furniture.

               (5)  Coating line. The application of one or more
surface coatings, using one or more applicators, together with
any associated drying or curing areas. A single coating line ends
after drying or curing and before other surface coatings are
applied. For any web coating line this term means an entire
coating application system, including any associated drying ovens
or areas located between an unwind station and rewind station,
that is used to . apply surface coatings onto a continuous strip or
web. It is not necessary to have an oven or flash area in order
to be included in this definition.

               (6) Coating system. A series of surface coatings
applied in subsequent layers at the same coating line for
protective, decorative, or functional purposes. Each layer of the
coating system must be dependent upon the previously applied to
produce a marketable product. The coatings must be applied
simultaneously at multiple coating stations within the same
coating line.

               (7) Container. Any portable device in which a
material is stored, transported, or otherwise handled.

               (8)  Excluded VOC.  Any of the compounds expressly
excluded from the definition of volatile organic compound in
section 200.1 of this Title.

               (9)  Extreme performance coating.  A coating
formulated for and exposed to harsh environmental conditions,
including but not limited to continuous exposure to outside
weather, temperatures consistently above 95° C,  temperatures
consistently below 0° C,  solvents, detergents,  abrasives,
scouring agents or corrosive gases and fluids.

               (10) Lower Orange County metropolitan area. The
area including the towns of Blooming Grove, Chester, Highlands,
Monroe, Tuxedo, Warwick and Woodbury.

               (11)  Maximum permitted pounds of volatile organic
compounds (VOC) per gallon of coating, minus water and excluded
VOC, at application.  The permissible quantity of volatile
organic compounds per gallon of coating minus water and excluded
VOC, at application as specified  in tables 1 and 2 of this Part.
The actual VOC content of the as applied coating is calculated as
follows:
           (VOC) a =  (Dc)a  ffWv^a -  fWw)a -.(Wela)
                     1  -  ((Vw)a +  (Ve)a)

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          where:

          (VOC)a = VOC content of "as applied" coating, expressed
as a mass of VOC, in pounds,  per volume of coating,  in gallons,
minus water and excluded VOC
          (Dc)a = coating density as applied,  in pounds per
                  gallon

          (Wv) a = the weight fraction of total volatiles in the
                  coating, as applied

          (Ww)a = the weight fraction of,water in the coating, as
                  applied

          (Vw) a = the volume fraction of water in the coating, -as
                  applied

          (We)a = the weight fraction of excluded VOC in the
                  coating, as applied

          (Ve) a = the volume fraction of excluded VOC in the
                  coating, as applied

               (12)  Natural finish hardwood plywood panels.
Panels whose original grain pattern, frequently supplemented  by
fillers or toners,  is enhanced by essentially transparent
finishes.

               (13)  New  York City metropolitan area.  All of the
city of New York, and Nassau, Suffolk, Westchester and Rockland
Counties.

               (14)  Opaque stain.  Any stain that contains
pigments but which  is not classified as a semitransparent stain,
including stains, glazes, and other opaque materials applied  to
wood surfaces.

                (15)  Overall removal efficiency.  The total
reduction of volatile organic compound emissions considering  the
efficiency of both  the  capture system and of the subsequent
destruction and/or  removal of these air contaminants by the
control  equipment prior to their release into the atmosphere.

                (16)  Pigmented coat.  Opaque coatings, applied
either as an undercoat  or a topcoat, that contain binders and
colored  pigments and are  formulated to conceal the wood surface.

                (17)  Plastic parts. Plastic parts are parts made
from a substance that has been formed from a resin through the
application of heat, pressure or both. They include but are  not
limited  to thermoplastics and thermosets such as acrylonitrile-
butadiene-styrene  (ABS),  acrylic  (AC), cellulosics, nylon,


                              C-24

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polycarbonatevinyls, xenoy, melamines, polyester (BMC),  reaction
injection molding  (RIM), polyurethanes  (PU).  This also includes
composites such as fiberglass-reinforced  plastics (FPR),  which
are comprised of thermosetting  or  thermoplastic resins and
fibers, filaments, or  fine powders.

               (18) Potential to emit. The  maximum capacity of an
air contamination source to emit any  air  contaminant under its
physical and operational design. Any  physical or operational
limitation on the capacity of the  facility  or air contamination
source to emit any air contaminant, including air pollution
control equipment and/or restriction  on the hours of operation,
or type of material combusted, .^stored, or processed,  shall be
treated as part of the design only if the limitation is contained
in enforceable permit  conditions.  Fugitive  emissions,  to the
extent that they are quantifiable,  are included in determining
the potential to emit.

               (19)  Printed interior panels.  Panels whose grain
or natural surface is  obscured  by  fillers and basecoats upon
which a simulated grain or decorative pattern is printed.

               (20)  Sealer.  A coating which contains binders
that seal a wood surface prior  to  application of a subsequent
coating.

               (21)  Semitransparent  stain.   Stains that contain
dyes and/or semitransparent pigments  and  are  formulated to
enhance wood grain and to change the  color  of the surface, but
not to conceal the surface;  including sap  stain, toner,  nongrain
raising stain, pad stain, spatter  stain,  and  other
semitransparent stains.

               (22)  Solids as  applied.   Utilizing the actual
volume of coating solids applied,  compliance  is determined as
follows:
 {lVn)al, ) f(l. overall removal efficiency) jVOOa)  - f(VOO£\> =
    f \\                   ivs*-/   \ (vs)c/j
(+) Ibs. over allowable
(0) compliance
(') Ibs, under allowable
          where:

               V = the  volume of actual  coating used,  gallons

                (Vn)a  =  volume fraction solids in the actual
                        coating

                (VOC)a = VOC content of "as applied" coating,
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                        expressed as a mass of VOC,  in pounds,
                        per volume of coating ,  in gallons, minus
                        water and excluded VOC


               (VOC)c = mass of VOC in a volume of solids and VOC
                        for complying coating, pounds VOC/gallon

               d(VOC)a =  density of volatile organic content
                          (total volatiles minus exempt solvents
                          and water) as applied, pounds per
                          gallon and,

     (Vs)a = 1 - fVOC^a          (Vs)c = 1 -  (VOC) c
                 d(VOC)a                     d(VOC)a

               (23) Solvent. A substance that is liquid at
standard conditions and is used to dissolve or dilute another
substance; this term includes, but is not limited to, organic
materials used as dissolvers, viscosity reducers, degreasing
agents, or cleaning agents. Any excluded VOC is not a solvent.

               (24) Substrate. The surface onto which a coating
is applied or into which a coating is impregnated.

               (25)  Surface coating.  A material applied onto or
impregnated into a substrate for protective, decorative, or
functional purposes. Such materials include, but are not limited
to, paints, varnishes, primers, sealants, adhesives, inks and
maskants.

               (26)  Wash coat.  A coating which contains binders
that raise wood surfaces, prevent undesired staining, and control
penetration.

               223.3 Volatile organic compound emission control
requirements.

               (a) No person shall cause or allow the usage of
coatings that exceed the allowable pounds of volatile organic
compounds per gallon, minus water and excluded VOC at application
specified in table 1 of section 228.7 and table 2 of section
228.8  of this Part, unless a coating system meeting the
requirements of 228.3(d) is utilized or unless control equipment
meeting the requirements of 228.3(b) and 228.3(c) is installed
and operated.

               (b) Any afterburner used as control equipment
shall  be energy-efficient and shall be designed and operated to
provide, at a minimum, for an 80 percent overall  removal
efficiency of volatile organic compounds. This assumes 90 percent
of the volatile organic compounds emitted are captured and


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delivered to the afterburner which converts 90 percent of the
volatile organic compounds to carbon dioxide and water vapor. The
control equipment shall operate on minimal auxiliary fuel and
provide for maximum heat recovery.

                (c) Notwithstanding the control requirements
specified in 228.3(b), control strategies utilizing an air
cleaning device must determine the required overall removal
efficiency  on a solids as applied basis as per 228.2(b)(22).
Using the appropriate coating parameters and VOC limits as
specified in sections 228.7 and 228.8, the overall removal
efficiency required is the lesser of the value calculated
according to the above procedure or 85 percent.

                (d)  An owner or operator of a coating line which
utilizes a coating system as a control strategy must comply with
the following provisions:


                (1) Each coating system must be approved by the
commissioner's representative prior to the use of the coating
system in the manufacture of a product for sale;

                (2) The coatings must be applied on the same
substrate and at the same coating line. Coating applied at
different coating lines cannot be included in any compliance
demonstration involving a coating system. In addition,  due to
the variability in coating application rates, coatings which are
applied manually by hand held spray guns cannot be utilized in a
coating system compliance demonstration.

                (3) Compliance must be demonstrated using actual
coating usages calculated on a solids as applied basis using the
formula in 228.2(b)(22). The calculation must be performed for
each coating and the aggregate of the results for all coatings
applied in each coating system must demonstrate compliance;

                (4) Compliance must be demonstrated
instantaneously. There is no averaging period for individual
coatings which  are part of a coating system;

                (5) The method or instrument which the source
owner will accurately measure or calculate the volume of coating
applied must be approved by the commissioner's representative;

                (6) Collect and record all of the following
information:

                (i) the name or identification of each coating
which is part of a coating system;

                (ii) the coating parameters used to determine

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(VOC)a for each coating which is part of a coating system; and

               (7)  Any record showing noncompliance with this
Part shall be reported by sending a copy of the record to the
commissioner's representative within thirty days following the
occurrence.

               (e)(l)The commissioner may allow surface coating
processes to operate with a lesser degree of control than is
required by 228.3 provided that a process specific reasonably
available control technology (RACT) demonstration has been made
to the satisfaction of the commissioner.•» Process specific RACT
demonstrations shall be submitted with the application for a
permit to construct, a certificate to operate,  or renewal of a
certificate to operate for an existing source under the
provisions of Part 201 of this Subchapter. Such process specific
RACT demonstrations must be submitted to the United States
Environmental Protection Agency as a revision to the State
Implementation Plan and must address the technical and economic
feasibility of:

          (i) utilizing compliant coating(s) and/or inks;

          (ii) utilizing demonstrated and proven emission control
technologies which would achieve the required overall removal
efficiency as determined per 228.3 (c);

          (iii) utilizing demonstrated and proven emission
control technologies which would achieve a degree of overall
removal efficiency less than required as determined per 228.3(c);
and

          (iv) utilizing demonstrated and proven production
modification methods which would result in real, documented, and
enforceable reductions in the volatile organic compound emissions
from the process.

      (2) Facilities with surface coating processes  subject to
this Part with an annual potential to emit of less than 5 tons of
volatile organic compounds will only be required to comply with
(d)(1)(i) and  (d)(1)(iv) in order to demonstrate that a lesser
degree of control is RACT for these processes.

      (3) The commissioner may allow sources which use natural gas
fired afterburners as control devices for processes subject to
this Part, to shut down these natural gas fired afterburners from
November 1st through March 31st for the purposes of natural gas
conservation, provided that the commissioner has determined that
this action will not jeopardize air quality.  Such evidence shall
be  submitted with the application  for a permit to construct, a
certificate, or  renewal of a certificate to operate for an
existing source  under the provisions of Part 201 of this


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Subchapter.

               228.4 Opacity. No person shall cause or allow
emissions to the outdoor atmosphere having an opacity of 20
percent or greater for any consecutive six-minute period from any
emission source subject to this Part.


               228.5 Reports, recordkeeping, sampling and
analysis.

               (a)  The owner or operator of any emission source
subject to this Part must maintain and, upon request, provide the
Department's representative with certification from the coating
supplier/manufacturer which verifies the parameters used to
determine the actual VOC content of the as applied coating,
(VOC)a, as defined in section 228.2(b)(ll) of this Part, for each
coating used at the facility.  In addition, purchase, usage
and/or production records of the coating material, including
solvents, must be maintained in a format acceptable to the
commissioner's representative and, upon request, these records
must be submitted to the Department. Any facility required to
perform  solids as applied calculations as defined in section
228.2(b)(22), must maintain records to verify the parameters used
in the formula. Any additional information required to determine
compliance with this Part shall be provided to the commissioner's
representative in a format acceptable to the representative.
Records must be maintained at the facility for a period of five
years.

               (b) Acceptable analytical methods for determining
the volatile content, water content, density, volume solids of
surface coatings are presented in appendix A, method 24, of 40
CFR 60  (see table 1, section 200.9 of this Title).

               (c) Where the methods referenced in subdivision
(b) of this section are not applicable, alternate analytical
methods for surface coating may be acceptable, subject to the
approval of the commissioner.

               (d) Representatives of the Department of
Environmental Conservation shall be permitted, during reasonable
business hours, to obtain coating samples for the purpose of
determining compliance with this Part.

               (e)  When a coating line utilizes control
equipment to comply with the provisions of this Part, test
methods acceptable to the Department of Environmental
Conservation must be used when demonstrating the overall removal
efficiency.

           (i) This demonstration may be performed by directly

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measuring VOC/solvent recovery and VOC/solvent usage rates where
VOC/solvent recovery is the only control technique. Methods
described in 228.5(b) and (c) must be used.

          (ii) For control equipment other than VOC/solvent
recovery, this demonstration must include provisions to determine
both the efficiency of the capture system and of the subsequent
destruction and/or removal of these air contaminants by the
control equipment prior to their release to the atmosphere.

               (f) The owner and/or operator of a surface coating
process must follow notification requirements, protocol
requirements and test procedures of Part 202 of this Title for
testing and monitoring. Depending upon conditions at a test site,
one of the following test methods from appendix A of 40 CFR 60
(see Table 1, section 200.9 of this Title) must be used when
measuring volatile organic compound (VOC) concentrations of a gas
stream at the inlet and outlet of a control device to determine
the destruction and/or removal efficiency:

          (i) Method 18, Measurement of Gaseous Organic Compound
Emissions by Gas Chromatography;

          (ii) Method 25, Determination of Total Gaseous Organic
Emissions as Carbon; or

          (iii) Method 25A, Determination of Total Gaseous
Organic Concentration Using a Flame lonization Analyzer.

          (iv) Methods not listed above must be approved in
advance by the Department's representative and the United States
Environmental Protection Agency.

               (g) If an air cleaning device is used, continuous
monitors of the following parameters shall be installed,
periodically calibrated, and operated at all times that the
associated control equipment is operating:

                     (1) exhaust gas temperature of all
incinerators;

                     (2) temperature rise across catalytic
incinerator bed;

                     (3) breakthrough of volatile organic
compounds on a carbon adsorption unit; and

                     (4) any other continuous monitoring or
recording device  required by the commissioner.

                (h) Any  facility which  is not  subject to the
control requirements of this Part because  its annual potential  to

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emit volatile organic compounds are below the applicability
criteria, must maintain records in a format acceptable to the
commissioner's representative that verify the facility's annual
potential to emit VOCs. Upon request, these records must be
submitted to the Department.


               228.6 Prohibition of sale or specification.

                (a)  No person shall sell, specify, or require
for use the application of a coating on a part or product at a
facility with a coating line described in table 1 or 2 in section
228.8 or 228.9 if such use is prohibited by any of the provisions
of this Part.  The prohibition shall apply to all written or- oral
contracts under the terms of which any coating is to be applied
to any part or product at an affected facility.  This prohibition
shall not apply to the following:

               (1)  coatings utilized at surface coating lines
where control equipment has been installed to meet the allowable
VOC content limitations specified in tables 1 and 2 of
sections 228.8 and 228.9 of this Part;

               (2)  coatings utilized at surface coating lines
where a coating system is used which meets the requirements
specified in 228.3(d); and

               (3)  coatings utilized at surface coating lines
that have been granted variances for reasons of technological and
economic feasibility per section 228.3(e) of this Part.

               (b) Any person selling a coating for use in a
coating line subject to this part must, upon request, provide the
user with certification of the volatile organic compound content
of the coating supplied.
                         228.7 Table 1

Process, emission source,                       Maximum permitted
and description of products         pounds of volatile organic
                                      compounds per gallon (minus
                                          water and excluded VOC)
                                        of coating at application

Large appliance     Residential and commercial washers,
coating lines       refrigerators, freezers, water heaters,
                    dishwashers, trash compactors, air
                    conditioners.                            2.8
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Magnet wire insu-
lation coating
lines
Enameling or varnish of aluminum or
copper wire for use in electrical
machinery to create an electromagnetic
field.
                                                             1.7
Metal furniture
coating lines
Metal parts used in household, business
and institutional furniture such as but
not limited to tables, chairs, waste-
baskets, beds, lighting fixtures,
shelves, room dividers, bathropm
dividers.                                3.0
Metal can
coating lines
Fabric coating
lines
Vinyl  coating
lines
Paper  coating
lines
Automobile
assembly coating
lines
Sheet basecoat - exterior and interior
over-varnish                             2.8
Two-piece can exterior (basecoat and
over-varnish)                            2.8
Two- and three-piece can interior
body spray                               4 .2
Two-piece can exterior end (spray or
roll coat)                               4.2
Three-piece can side-seam spray          5.5
End sealing compound                     3.7

Fabric coatings, such as but not limited
to: rubber, used for rainwear, tents,
industrial gaskets.                      2.9

Printing, decorations or protecting coats
over vinyl-coated fabric or vinyl
sheets.                                  3.8

Paper, pressure-sensitive tape regardless
of substance  (including paper, fabric or
plastic film) and related web coating
processes on plastic film such as but not
limited to: typewriter ribbons, photo-
graphic film and magnetic tape.  Also
metal foil gift wrap and packaging.      2.9

Automobiles and light-duty trucks,
exterior  and main body sheet metal parts
excluding nonmetallic parts.
                       Prime coat
                       Primer-surfacer
                       Top coats
                       Repair coat
                                          1.9
                                          2.8
                                          2.8
                                          4.8
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Coil coating
lines
Flat metal sheet from a coil or roll
which is coated and later used for items
such as but not limited to: cans,
appliances, roof decks, siding, cars,
gutters.                                 2.6
Coating lines for
misc. metal parts
arid products
Large farm machinery, small farm and
garden machinery, small appliances,
commercial and office machinery,
computer equipment, industrial machinery,
fabricated metal products and any other
industrial category which coats
miscellaneous metal machinery/ instruments
or equipment, excluding all nonmetallic
parts.

  Clear coatings                         4.3
  Coating application system is air
    dried or forced warm air dried at
    temperature up to 90°C               3.5
  Extreme performance coatings
    designed for harsh exposure or
    extreme environmental conditions     3 .5
  All other misc. metal parts and
    products coatings                    3 .0
Coating lines  for
flat wood surface
finishing
Printed interior panels made of
hardwood, plywood and thin particle
board                                     2.5
Natural finish hardwood plywood panels    3.3
Hardboard paneling                        3 .6
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                          228.8 Table  2
Process, emission source,
and description of products
Woo.d coating lines
                            Maximum permitted
                   pounds of volatile organic
                  compounds per gallon (minus
                      water and excluded VOC)
                    of coating at application
Coated room furnishings, such as but
not limited to cabinets (kitchen, bath
and vanity), tables,  chairs, beds, sofas,
shutters, art objects and any other
coated product made of solid wood
composition or wood material.

  Semi transparent stain                 6.8
  Wash coat                              6.1
  Opaque stain                           4.7
  Sealer                                 5.6
  Pigmented coat                         5.0
  Clear topcoat                          5.6
Tablet coating
lines
Formed pharmaceutical products, such as
but not limited to pills, capsules.
5.5
Glass coating
lines
Leather coating
lines
Miscellaneous
plastic  part
coating  lines
Lamps, incandescent light bulbs and
miscellaneous glass products.
Fluorescent light bulbs.

Leather substrates, such as but not
limited to clothing, furniture,
automobile components.
3.0
4.1
                                                              5.8
Plastic parts and products such as but not
limited to business and office machine parts
toys, sporting goods, architectural
structures such as doors and window frames,
automotive interior parts; automotive
exterior parts, both flexible and rigid;
musical equipment housings; and other
miscellaneous plastic parts.
                          Color  topcoat
                          Clear  coat
                                         3.8
                                         4.8
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Aerospace           Aerospace components, including but not
 coating lines      limited to assembly of parts or completed
                    unit of any aircraft, helicopter or
                    missile.

                      Primer                                 2.9
                      Topcoat                                5.1
                      Maskant for chemical processing        5.1

Motor vehicle       Automobile, truck or bus coating,
refinishing         including but not limited to repair
                    coats, repainting and touch-ups, except
                    at automobile assembly plants.

                      Repair/touchups                        6.2
                      Overall (coating entire vehicle)       5.0

Urethane coating    Urethane substrates that are more than
lines               50 micrometers (0.002 inches) thick,
                    except for resilient floor covering and
                    flexible packaging.                      3.8


               228.9 Products regulated. The "Process, emission
source, and description of products" column in tables 1 and 2 of
sections 228.7 and 228.8 of this Part may not contain all
possible products in each category. For any products not
specifically listed, the commissioner will determine, based on
inspections of the process, emission source and product to be
coated, which limits in table 1 or 2 apply.


               228.10 Handling, storage and disposal of volatile
organic compounds(VOC). No owner or operator of a facility
subject to this Part shall:

               (a) Use open containers to store or dispose of
cloth or paper impregnated with VOC and/or solvents that are used
for surface preparation, cleanup or coating removal;

               (b) Store in open containers spent or fresh VOC
and/or solvents to be used for surface preparation, cleanup or
coating removal;

               (c) After January 1, 1994 use VOC and/or solvents
to cleanup spray equipment unless equipment is used to collect
the cleaning compounds and to minimize their evaporation to the
atmosphere;

               (d) Use open containers to store or dispense
surface coatings and/or inks unless production, sampling,
maintenance or inspection procedures require operational access.

                              C-35

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This provision does not apply to the actual device or equipment
designed for the purpose of applying a coating material to a
substrate. These devices may include, but are not limited to
spray guns, flow coaters, dip tanks, rollers, knife coaters, and
extrusion coaters; or

                (e) Use open containers to store or dispose of
spent surface coatings, spent VOCs and/or solvents.
                               C-36

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State of Wisconsin
       C-37

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C-38

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  NR 422.085 Leather coating. (1) APPLICABILITY. Effective February 1,
1987, this section applies to coating applications at leather coating facili-
ties. This section does not apply to sources exempted under s. NR 422.03
(6).

  (2) EMISSION LIMITATIONS. No owner or operator of a leather coating
facility may cause, allow, or permit the emission of any VOGs from coat-
ing applications in excess of  18.6 kilograms per 100 square meters (38.0
pounds per 1000 square feet) of coated product calculated on a daily av-
erage basis.
                                             Register. May, 1992. No. 437

  (3) COMPLIANCE REQUIREMENTS AND SCHEDULES. The owner or opera-
tor of a leather coating facility shall comply with the requirements of
sub. (4) and s. NR 425.03 (1), (8) and (9).

  (4) REPORTING AND RECORDKEEPING. (a) To determine compliance
with the leather coating VOC emission limit in this section, the  facility
shall maintain daily coating usage and leather production records in a
format approved by the department. Reporting, recordkeeping and  ac-
cess to these records shall be in accordance with ss. NR 439.03 to  439.05.

  (b) The daily VOC emission rate shall be determined by the following
equation:

  c - a/b

  where:

  c is the daily average VOC emission rate,

  a is the total amount of VOCs emitted during the day, and

  b is the prorated surface area of leather coated during the day, where:
  di is the'total area of the ith batch of hides coated during the day, and

  6j is the ratio of actual VOC emissions resulting from coating any por-
tion of the ith batch of hides during the day to the total predicted VOC
emissions resulting from all coating of the entire ith batch.

  (c) The facility shall measure the surface area of each piece of leather
coated with a mechanism initially calibrated for minimum accuracy to
the Turner Korrect Machine or Sawyer Measurement systems. The av-
erage surface area per coated piece of leather may be used for a batch of
leather provided that the average is based on a minimum of 500 pieces.
Otherwise, the facility average surface area per coated leather piece shall
be used. In no case may  the total area allocated to production over all
days from a piece of leather exceed the average area for that leather.
  History: Cr. Register, January, 1987, No. 373. eff. 2-1-87; am. (2) and (3), er. (4). Register.
February,  1990. No. 410. eff. 3-1-90.

  NR 422.09 Automobile and light-duty truck manufacturing. ( 1 ) APPLICA-
BILITY. This section applies, subject to the provisions of s. NR 425.03
(6), to the application areas, flashoff areas, and ovens of automobile and
light-duty truck manufacturing plants involved in prime,  topcoat and
final repair coating of metallic front end and main body parts. This sec-
tion does not apply to the coating of wheels, trunk interiors, steering
columns or nonmetallic parts; to sealers or nonpriming anti-rust coat-
ings; or to sources exempted under s. NR 422.03.

  (2) EMISSION LIMITATIONS — ENAMELS. No owner  or operator of an
automobile surface coating line  which, prior to January 1,  1979, used an
enamel coating system, may cause, allow or permit the emission of any
VOCs in excess of:

  (a) After December 31, 1983, 0.14 kilograms per liter of coating (1.2
pounds  per gallon), excluding  water, from an electrodeposition  prime
coat or equivalent coating line.
Register. May. 1992. No 437

                                       C-39

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             Technical  Support Oocumeat

                       For  The

Proposed Wisconsin Administrative Code Rule To Limit
         Volatile  Organic Compound  Emissions
        From Major Leather  Coating  Facilities
            In  the Southeastern  Wisconsin
              Ozone Nonattainment Area
      Wi
sconsin Department of Natural  Resources
       Bureau of Air Management
            P.O.  Box 7921
      Madison,  Wisconsin  53707"
                    August, 1986
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                                     Preface
This draft  document  details  the  Wisconsin Department of  Natural  Resources
CWONR) Bureau of Air Management's  efforts to research and develop a proposed
administrative rule  that  would establish volatile organic compound (VOC)
emission  limitations for  large leather coating facilities.  Large leather
coating facilities are defined as  emitting at least 100  tont of VOC's during a
calendar year.

VOC emissions are a precursor to ambient ozone formation.  The accepted
general strategy to reducing ambient ozone is to lower VOC emissions.

This proposed rule would apply to approximately three major stationary sources
in the  southeastern Wisconsin ozone nonattainment area.
                                      C-42

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                                TABLE OF CONTENTS
Title Page
Preface	i
Table of Contents	iii
List of Tables	iv
List of Figures	iv

BODY  OF REPORT

1.    Introduction

     1.1  Document Purpose	1
     1.2  Ozone:   Cause and  Effects	1
     1.3  Regulatory Background	2
     1.4  Document Outline	5

2.    RACT  IV  Source Investigation	7

     2.1  InitialPotential RACT  IV Listing	7
     2.2  Revised  Potential VOC RACT Facilities Listing	7
     2,3  RACT IV Criteria and Data Sources	8

3.    Leather coating - VOC RACT Assessment	9

     3.1  Leather  coating in  Southeast Wisconsin	9
     3. 2  Process  Description 	9
          3.2.1.   The  Tanning  Process	9
          3.2.2.  Leather  Finishing Methods	10
          3.2.3.   Coating  Formulations	n
     3  . 3  VOC Emission Rates	14
     3.4  Potential Leather coating VOC  RACT Measures and  Cost	16
          3.4.1.  Low  Organic  Solvent Coatings	16
          3.4.2.   Roll  Coating	16
          3'.4.3    Microprocessor Controls on  Air-Atomized
                   Spray Equipment	18
          3.4.4.   Add-on  Controls.	20
     3.5  Proposed Leather Coating  VOC RACT Emission
            Limitations  Rule	21
          3.5.1.   Proposed VOC Emission Limits	21
          3.5.2.   Proposed Rule Flexibility in Meeting the VOC
                   Emission Limits	24
          3.5.3.   Recordkeeping  and Reporting Requirements	25
          3.5.4.   Proposed Compliance Schedule and Variance
                   Provisions	25
          3.5.5.   Estimated Impact of the Proposed  Rule	.'	26

 References	'. . .	21
                                          C-43

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                                  LIST OF TABLES


Table                                                                 Paj


1    VOC RACT Source  Categories - Southeastern Wisconsin	4
2    Representative Leather Coating  Formulations and  Cost	15
3    VOC Emission Rates - Various  Leather	17
4    Estimated Annualized Cost per Ton of VOC Reductions -
       Industrial Surface Coating Categories  in Wisconsin
       that  are Subject to RACT	19
5    Estimated Annuaiized Cost - Thermal Incineration
       No Heat Recovery)	22
                                  LIST  OF FIGURES


Figure            Description
1                 Southeastern Wisconsin Ozone Nonattainment Area	6
2                 Spray Coating - Schematic Picture	11
3                 Roll Coating  Operations - Schematic Diagram	11
                                         C-44

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                                    Chapter One

                                    Introduction
1.1   Document Purpose
     This document details the Wisconsin Department of  Natural  Resources
     ("Department") Bureau of A1r Management's  efforts  to  research and develop  a
     proposed administrative rule that would  establish  volatile organic compound
     (VOC) emission limitations for certain leather coating  operations.  This  rule
     for leather coating operations Is the last In a  series, of four rules to limit
     VOC emissions from certain sources In southeastern Wisconsin.

     VOC emissions are precursors to ambient  ozone formation.   The accepted
     strategy to reducing ambient ozone concentrations  Is  to reduce VOC emissions.
     The criteria that all these sources would  have to  meet  for rule applicability
     are as follows:

         Sources that emitted 100 tons or more  of VOCs  during calendar year 1984
         (or the most recent year for which emissions data are available);

         Sources that are located in the southeastern Wisconsin ozone nonattainment
         area (I.e., within the counties of Kenosha,  Ozaukee, Racine, Milwaukee,
         Washington or Waukesha);

         Processes that are -not subject to any  existing DNR Reasonably Available
         Control Technology (RACT) VOC emission limitations; and

         Processes that are not the subject of  any Control Technique Guideline
         (CTG) issued by  the U.S. Environmental Protection Agency (U.S. EPA),  which
         recommends Reasonably Available Control Techniques (RACT).

     Following these criteria, the WDNR developed,  proposed, and  eventually
     promulgated non-CTG  or "RACT IV"  rules to  limit  VOC emission from the
     following applicable sources:

         Synthetic resin  manufacturing

         Coatings manufacturing, and

         Aerosol can fi11 ing

     At  its  February 1986 meeting,  the  Natural  Resources Board  adopted these rules
     as  part of  the administrative  code.   The  rules are scheduled  to  take  effect on
     September  1,  1986.

     The  remainder of  this  document addresses  the technical  background and  basis
     for  the proposed VOC RACT  IV  rule  for leather coating  facilities.
                                          0-45

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1.2  Ozone:   Cause  and  Effects

   •  Ozone  (Oi)  is  formed  in  the  lower  atmosphere  in  the presence of nitrogen
     dioxide  and  sunlight.  Ultraviolet radiation  from the sun provides  the
     necessary energy  level to  disassociate  nitrogen  dioxide  (NO,)  into  nitric
   •  oxide  (NO)  and a  free oxygen atom  which quickly  combines with  an oxygen
     molecule to  form  ozone.  Ozone  may then disassociate to  form H0t and  this
     photochemical  process continues to repeat, always attempting to reach
     equl1Ibrlum.

     However, If the atmosphere is polluted  with VOC  emissions as well as  NO;.
     the equilibrium shifts  towards  greater  concentrations of ozone.  Although  some
     organic  compounds.react  much more  rapidly  than others, almost  all will react
     with NO  and  both  ordinary  oxygen and ozone.   In  a series of reactions, oxygen
     as well  as  ozone  react with  NO to  form  N02.   Organic compounds and  oxygen
     are replaced In the reaction with  NO, causing ozone concentrations  to
     bu1ld-up.   Thus,  the  simultaneous  presence of both nitrogen-dioxide and  VOC  in
     the presence of sufficient solar radiation causes ozone  to accumulate.

     Since  VOCs  and N02  react In  the presence of sunlight to  form ozone, they are
     called precursors of  ozone.   VOC's can  also unite directly with ozone to form
     other  photochemical oxldants which are  often  as  harmful  as ozone  Itself.

     The toxlcity of Inhaled  ozone is well known,  and the presence  of  this oxidant
     In most  urban and Industrial environments  has made  the  study of  its health
     effects  important.

     At ozone concentrations  greater than 0.25  parts  per million  (ppm),  irritation,
     headaches,  decreased  cardiopulmonary reserve  (in healthy adults),  aggravation
     of certain  anemias, aggravation of chronic lung  disease, aggravation of
     asthma,  and Increased susceptibility to acute respiratory disease  have been
     noted.

     At ozone concentrations  from 0.20  ppm to 0.25 ppm,  Brinkman, Kleinfield,
     Remmers  and Schoettlen  (1957) found  that aggravation of certain  respiratory
     aiIments occurred.

     At ozone levels below 0.20  ppm, Wayne,  Hammer,  and  Coffin (1967)  discovered
     mild reactions in normal  subjects, ranging from headaches without  fever  at
     0.05 ppm to eye irritations  at 0.10-0.15 ppm.

     A 1982  study by the United  States  Congress's  Office of Technology  Assessment
     (OTA) estimates that ozone-induced damage is  costing  the nation between S2
     billion  and $4.5 billion  per year in reduced  yields for four major crops
     (corn,  wheat,  soybeans, peanuts).   These estimated  losses represent as much as
     five per cent of the nation's output.

     Ozone is also  a major factor in the  overall  deterioration of  several different
     types of organic materials.  The  magnitude of damage is difficult  to assess
     because ozone  is one of many oxidizing chemicals which  contribute  to the
     "weathering" of materials.   Nevertheless, ozone is known to accelerate  the
     deterioration  of rubber,  textile  dyes  and fibers, and certain types  of  paints
     and coatings.
                                          C-46

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1.3   Regulatory Background

     The  U.S.  EPA,  based upon  the  most  reliable  data available,  has  established  a
     National  Ambient Afr Quality  Standard  (NAAQS) for ozone  to  protect  human
     health  (primary standard)  and welfare  (secondary standard).   For  ozone  the
     primary and secondary  NAAQS are the same:   0.12 parts  per million (ppm) -
     daily maximum 1-hour concentration. The  ozone standards are  attained when  the
     expected  number of days  per calendar year with maximum hourly average
     concentrations above the  designated level  is equal  to  or less than  one, as
     determined by the methodology of Chapter  40 of the  Code of  Federal
     Regulations. Appendix  H  (40 CFR 50.9.  Appendix H)   The WONR has adopted this
     ozone NAAQS as part of Wisconsin Administrative C,ode section  NR 155.03.

     Areas where violations of any of the NAAQS  exist are considered by  the  U.S.
     EPA  and the affected state to be in-nonattainment for  that  criteria pollutant
     for  which the NAAQS exists.  Officially,  these nonattainment  areas  are  deemed
     to contain ambient air quality that is less than what  Is considered safe for
     human health and/or welfare.

     Section 110(a) of the  Federal Clean Air Act. amended August,  1977 required
     each state to submit a revised air quality  state Implementation plan to the
     U.S. EPA  by July 1, 1979  that demonstrates  attainment  of the  NAAQS  by
     December  31, 1982 for  each pollutant that did not meet the  NAAQS  in any part
     of the  state (i.e., the  nonattainment  areas).  The  WONR  Bureau of Air
     Management submitted a 1979 Plan for ozone  attainment  to the  U.S. EPA for
     approval.

     The  two general strategies to reduce ozon-e, as proposed  in  the 1979 Ozone
     Plan, were to limit VOC  emissions  from new cars  (The  Federal  Motor  Vehicle
     Emission  Control Program - FMVECP), and from certain  stationary sources.   The
     remainder of this report will be concerned  with  the VOC  emissions and their
     limitations from stationary sources.

     The  stationary source  VOC emission limitations  (called VOC  Reasonably
     Available Control Technology  - RACT) that are described  in  the 1979 Ozone  Plan
     were developed by the  WDNR Bureau  of Air Management and  are contained as  rules
     in section NR 154.13 of  the Wisconsin  Administrative  Code.   In September,
     1986, these rules will be renumbered into the NR 400  series.   These VOC RACT
     rules were adopted from  U.S.  EPA control  technique  guidelines (CTG's).   The
     CTG's and subsequent RACT rules were issued in Group  I and  Group  II series.
     Table 1 lists those VOC  stationary source RACT  I  and  RACT  II  categories that
     are  currently applied  in the  southeastern Wisconsin ozone  nonattainment area

     The  1979 Ozone Plan's  general strategy to attain  the  ozone  NAAQS  was and  still
     is to reduce VOC emissions.  Based upon the analysis  of the impacts of
     specific VOC-reducing  strategies,   the  WONR determined that the ozone NAAQS
     would not be met by December 31,  1982  for southeastern Wisconsin.

     Section 129(c)  (uncodified) of  the Clean Air Act allowed the U.S.  EPA to grant
     extensions for achieving ozone  NAAQS attainment  to  Oecemb-er  31,  1987 to tnose
     states  which could not demonstrate attainment  by the  end of  1982.  As a
     condition of U.S EPA's approving  this  extension,  each state  that applied for
     the extension (e.g., Wisconsin) was required to develop a motor  vehicle
     emissions  inspection and maintenance  (I/M) program and additional  stationary
     source VOC  RACT  rules  for  the ozone nonattainment  areas (Section 172(a>(2> of
     the Clean Air Act).

                                         C-47

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                                     Table  1

              Implementation and Anticipated Ful1-Compliance Dates
            Stationary  Source Categories Subject to  .423(a)  VOC Rules
                          Contained In Chapters NR 419

                    Southeastern  Hisconsln  Seven Counties  '"'
Source Category
Effective Date
of Implementing
the Regulation
Anticipated Date of
Full Source Category
     Compllance
Bulk Gasoline Plants
Gasoline Loading Terminals
Service Stations (Stage I)
Industrial Coating Categories
Appl lances
Automobi les
Cans
Metal Colls
Paper
Fabrics
Metal Furniture
Misc. Metals
Solvent Metal Cleaning
Cutback Asphalt Oper.
Rubber Products
Drycleanlng
Graphic Arts
Petroleum-based Dry Cleaning
Synthetic Resin Manufacturing'
Coatings Manufacturing6
Aerosol Can Filling6
August 1, 1979
August 1, 1979
August 1, 1979
August 1. 1979
August 1, 1979
August 1, 1979
August 1 , 1979
August 1, 1979
August 1, 1979
August 1, 1979
April 1, 1981
August 1, 1979
August 1 , 1979
April 1, 1981
April 1, 1981
April 1, 1981
January 1 , 1984
September 1 , 1986
September 1 . 1986
September 1 , 1986
December 31 ,
December 31 ,
December 31 ,
December 31 ,
December 31 ,
December 31 ,
December 31 .
December 31 ,
December 31 ,
December 31 ,
December 31 ,
December 31 ,
December 31 .
December 31 ,
December 31 ,
December 31 ,
December 31 ,
December 31 ,
December 31 ,
December 31 ,
1981
1981
1981
1981
1987
1985
1982
1985
1979
1982
1987
1981
1980
198-3
1983
1985
1987
1987
1987
1987
         Transferred  from  the old NR  154.13, effective October  1,  1986.

         This  list of  stationary source categories  subject  to VOC  emission
         control  regulations are for  only  those  categories  that have  sources
         In  the Southeastern Wisconsin seven counties.  Additional  source
         types  subject to  NR 154.13 regulations  but presently not  located  in
         Southeastern  Wisconsin are:  Storage of petroleum  liquids,
         miscellaneous refinery sources, petroleum  refinery fugitive
         emissions,  pharmaceutical manufacturing, gasoline  tank truck  leaks.
          RACT  IV  source  category.
 7634Q.PERM
                                   C-48

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     In March,  1983  the  Department  submitted to the U.S. EPA the final revision to
     the  1982 State  Air  Quality  Management Implementation-Plan, for ozone control
     in the six  county  southeastern  Wisconsin ozone nonattalnment region
     (Figure  1>.   This  document,  referred to herein as  1982 Ozone Plan, contains
     predictions of  the  Impact  that  federal and Wisconsin VOC emission limitation
     rules would have on high ozone  levels In the region in 1987 (projected
     attainment  year) relative  to concentrations In 1979-81.  1980 was the base
     year for this analysis.

     As part of  the  1982 Ozone  Plan,  the Department committed to developing an  I/M
     program  In  the  southeastern Wisconsin ozone nonattalnment Area,  per U.S. EPA
     requirements.   This program commenced operation ,on April 2, 1984.

     The  Department,  1n  Its  1982 Ozone  Plan, also committed to developing
     additional  VOC  RACT rules  for any  applicable- stationary processes, per the
     federal  requirements.   This commitment included the adoption of  the CTG  -
     Group III  VOC emission  limitations ("RACT  III") for applicable operations
     located  in  southeastern Wisconsin. The DNR has complied with this commitment
     by promulgating a  RACT  III  rule for petroleum-based dry cleaning operations  in
     the  region  with annual  VOC emissions greater than  100  tons per year (TPY).
     Additional  RACT III enactment will occur if and when  there are applicable
     facilities  in southeastern  Wisconsin.

     The  U.S. EPA, in  the January 22. 1981 Federal  Register  (46 FR Page 7186).  also
     stated  that the additional  requirements to be  a part  of the  1982 Ozone Plan
     are  to  Include  the adoption of rules  "applying RACT to  ... all remaining
     [non-CTG]  major stationary sources of VOC's" [i.e., emitting more  than  100
     tons per year actual emissions as  defined  under Section 302(j) of  the Clean
     Air  Act].   These  sources are referred to as non-CTG or  RACT  IV VOC  sources.
     The  Department  is  in the process of meeting this  requirement, as discussed
     herein.

1.4  Document Outline

     In  this  document,  the Department details  its analysis  of  three potential
     leather  coating RACT IV sources in southeastern Wisconsin,  and how  the
     criteria for  probable RACT IV sources were established  (Chapter  Two).
     Technical  support  for promulgating the  proposed  leather coating  VOC  RACT IV
     rule is  detailed  in Chapter Three.
                                        C-49

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                             Figure 1
                      Southeastern Wisconsin
                   Czone  Nonattainment Court
• WASHINGTON p
•
!
/
• Grafton
                                       Slinger
                                     V%AU«. £Sn-.
                                               •  i
                                           Waukesha
I .V,lwauk«
\
'             7 /
V         7
                               C-50

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                                    Chapter Two

                            RACT IV Source Investigation
2.1   Initial  Potential  RACT IV Listing

     This phase of the  project commenced by defining a potential RACT IV source,  in
     terms of both total emissions and geographical  location.  Potential RACT IV
     processes were defined to have had the potential  to emit at least 100 tons of
     VOCs for calendar year 1983, assuming continuous, maximum operations for the
     entire year.  The Department's 1983 Air Emissions Inventory (AEI) was the
     primary source for this data survey.

     Since only the ozone plan for the southeastern Wisconsin ozone nonattainment
     area had to be revised, it was deemed that any additional VOC control rules
     would apply only to appropriate sources that are located in this region (i.e.,
     the counties of Kenosha, Milwaukee, Ozaukee, Racine, Washington, and Waukesha,
     Figure 1).  This geographical limitation Identically applies to any RACT III
     VOC limitation and the I/M program, which were also commitments from the 1982
     Ozone Plan.

     In reviewing the 1983 AEI, the Department identified twelve facilities that
     met the above-mentioned criteria.  For each of these facilities, a plant
     inspection and a developed detailed 1983 VOC emissions  inventory.  The
     facility  inspections were carried out during April - June,  1984.   Each of
     these plant visits had the following purposes:

         To enable the DNR  to better understand  those processes  that result in the
         VOC emissions;

         To explain the purpose and background for  this rule  development; and

         To solicit operations Information and detailed VOC  emission estimates
         regarding each of  the processes in question.  Confidentiality  privileges
         under Wisconsin Statute  and Wisconsin Administrative Code were offered  by
         the DNR.

     Based upon data supplied by  the facilities  and their coatings/solvents
     vendors,  the Department was  able  to develop a  detailed  1983 VOC emissions
     inventory for each facility.  Each  inventory was finalized  and  considered
     complete.  Appropriate facility personnel approved,  in  writing, the  DNR
     Inventorying method and calculations.  The  reported  VOC emissions  from
     calendar  year 1984 operations are  now used  in  this  RACT analysis.

 2.2  Revised  Potential  VOC  RACT  IV Facilities  List

     In  December,  1983  the  Department  promulgated  the RACT  III  rule  that  limited
     VOC emissions from major petroleum-based  drycleaning operations  in
     southeastern  Wisconsin.   "Major"  operations were defined as any facility
     process  (or  group  of  processes  if similar but  more  than one)  emitting  100 tons
     or  more  VOCs  per  calendar year.   The  Department  decided to propose that  the
     diminimus VOC emission value, below which a source  would be exempt from
     further  RACT IV consideration,  would  also be  100 ac-tual tons  per  calendar
     year.   This  diminimus  value  would conform to  the U.S.  EPA guidance on  RACT  [[I
     rule  promulgation  (46FR7136. see  Section  1.3  herein).
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     Based  upon  the  Inventorying  effort,  geographical  restriction,  and  the  100
     ton-per-year  actual  VOC emissions  minimum for potential  RACT  IV  sources,  the
     list of facilities  that may  be  subject  to an.RACT emission  limitations  was
     culled to seven  (four  leather coater's, a resin manufacturer,  a  coatings
     manufacturer, and  an aerosol can filling operation).   The primary  step  in  this
     rule-development process is  a RACT assessment and feasibility analysis  for
     each of the process  types  listed above.

     During October  - mid-December,  1985,  the Department  solicited public comment
     on all draft  VOC RACT  IV rules.  This  included a  public  hearing  on
     November 15,  1985  In Milwaukee.

     Based  upon the  comments received,  the  Department  decided to separate the  VOC
     RACT IV rules package.  The  revised rules for synthetic  resin manufacturing,
     coatings manufacturing and aerosol can  filling-operations were eventually
     adopted by the  Natural Resources Board, at  Its February, 1986 meeting.   Thess
     three  rules are scheduled to become effective as  part of the  Wisconsin
     Administrative  Code on September  1, 1986.

    .Further Department work on the  remaining draft VOC RACT  IV  rule  (leather
     coating) was  delayed until after  the other  RACT  IV rules were adopted  by  the
     Natural Resources  Board.  The  comments  received on both  proposed rule  and its
     supporting materials were considerably more substantial  than  for the other
     rules.  This  technical support  document focuses  solely upon background and
     basis  for the proposed leather  coating VOC  RACT  rule.

2.3  RACT IV.Criteria and Data Sources

     The U.S. EPA has defined RACT  as  follows:

     "The  lowest emission  limitation that a particular source Is capable of meeting
     by the application of control  technology  that  is  reasonably available
     considering technological and  economic feasibility.   RACT for a  particular
     source is determined on a case-by-case basis,  considering the technological
     and economic circumstances of  the  Individual  source."  (Federal  Register,
     September  17, 1979, Page 53762).   This definition was a primary  criteria, in
     the entire RACT IV rule development process.

     In working towards understanding  the leather coating process as  a VOC  source,
     the Department has used the following sources  of Information:

         Existing CTG's and  Wisconsin  VOC RACT rules  - noting where  similarities
         may  exist between CTG and the non-CTG processes;

         Facility Information  and recommendations,  primarily during  the fall, 1985
         public comment  period;

         Information from  other  states which have leather coating VOC RACT  rules;
         and

         The  Department's  understanding of  this process    In assessing what might
         constitute  RACT for it.

     Chapter  Three  contains  the  Department's understanding of the leather  coating
     process,  Its role  as  a  VOC  emission source and how  these emissions could: be
     reduced through reasonably  available  control technology (RACT).
                                          C-52

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                                    Chapter Three
                                   Leather Coating
                                 VOC RACT Assessment
3.1
Leather Coating in Southeast Wisconsin

Leather coating is a principle process In the animal hide tanning industry
which stabilizes and transforms animal hides Into a diverse variety of lea
types.  This Industry is quite significant In southeastern Wisconsin.
                                                                               ,
                                                                             eather
     Leather coating Is a large source of VOC emissions.
     coating facilities In the region which each emitted
     during 1984.  These four facilities reported to the
     Inventory a total of 1054 tons of VOC emissions for
     are 1isted as follows:
                                                     There were four leather
                                                    at least 100 tons of VOC's
                                                    ONR Air Emissions
                                                    calendar year 1984, and
     1)    Amity Leather Products Company
           West Bend
           DNR Facility Identification Number (FID#) 267009710
     2)    Flagg Tanning Corporation
           Ml Iwaukee
           FID #241030020
     3)    Gebhardt - Vogel Tanning Company
           Mi Iwaukee
           FID #241038490
     4)    Pfister and Vogel Tanning Company
           M1 Iwaukee
           FID #241023750

3.2  Process Description

     3.2.1 The Tanning Process

           The raw hides that arrive at  the leather coating facility  (also called
           tannery) must be readied before coatings can be applied  to  them.  The
           hides are  trimmed, washed, and then removed of all  remaining  hair, fat,
           muscle and other unwanted animal tissue  by applying enzymes.  A bating
           (enzymes and salts)  solution  1s applied  to the hides  to  reduce swelling,
           lower pH,  and reopen  the hide structure  to allow removal of the degraded
           proteins.  After bating, hides are thoroughly washed  to  remove any
           substances that  have  been loosed or dissolved.

           The next major  phase  in  hide  processing  is the actual  tanning.  Hides  or
           skins are  tanned to  give  them the mechanical properties  of  leather,  such
           as  abrasion resistance  and flexibility,  and to prevent them from
           decaying.  The  main  tanning agents used  commercially  are chromium
           sulfate  solutions.
       Next,  the hides  are fed through  a  machine  with  two large rollers  to
       wring  excess  moisture from the material.   Because hides are usually too
                      uses,  the finer grade  grain leather is often separated
                      side leather (called  the  split)  after the initial  tanning
       operation using  a machine resembling  a  horizontal
            thick for  most
            from the  flesh
                                                              bandsaw.
                                       C-53

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      Following the  Initial  tanning  process,  which Is  primarily for
      preservation of  the  fibers,  operations  are  carried out to Impart  the
      desired look,  feel,  and  working qualities  specified by the customer.
      Hides are placed In  drums  and  first treated with retan formulations,
      followed by dye  formulations,  and then  by  fat liquoring chemicals.

      Finishing requires  a series  of operations  which  give leather  its  final
      surface qualities.   For  this,  chrome tanned hides are subjected  to
      several finishing processes, as follows:

      - Setting out  (smoothing and stretching),
      - Drying,
      - Water conditioning and buffing,
      - Plating (smoothing and embossing), and
      - Finishing

3.2.2 Leather Finishing Methods

      The finishing  materials  are  applied to leather by flow, rolling,  or
      spray equipment.  Various coating materials, both water-based  and
      solvent-based, are used  to provide abrasion and stain resistance, and to
      enhance color  and gloss.  This stage of the tanning process results in
      emissions of  volatile organic compounds (VOCs) to the atmosphere.

      A hide's first coating is often applied via the "flow" method.  The flow
      method 1s commonly used  to soften and waterproof  leather principally for
      the shoe industry.  Some of the VOC's in the coating may be permanently
      bound  in the  leather.  This  is called impregnation.  The conveyoMzed
      hides are fed  under a conduit for the flow coating.  This conduit has a
      line of holes  at Its bottom.  The coating  flows through  these holes in a
      slow,  steady  stream or "curtain".   The transfer efficiency of flow
      coating  is close to 1001.  Sometimes this  "impregnation" coat is applied
      by roll coating, a method which will be discussed  later.

      Next,  the hides are hand fed onto a conveyor belt  that goes through a
      varied combination of air atomized  (Figure 2) and/or  roll coating
      machine  (Figure 3) applications.  The predominant  type of leather
      coating machine uses a rotary nozzle spray method,  with  either six or
      eight  spraying  heads.  For  spray applications,  the  coating material  is
      fed  Into the spraying system by  vacuum hose  from  a  55  gallon  drum.  Only
      one  coating material  is sprayed  at  each application.

      The  spraying arms are mounted on a  central  shaft  and  have the coating
      fed  to the spray guns via lines  mounted on  the  arms.   The arm rotates
      and  sprays the  coating on the  hide  as  it passes  underneath it.

      The  front  portion of  the  spray  coater  contains  an optical or  electrical
      scanner  that  sizes  up the continually-varying widths  and gaps between
      hides.   This  Information  is used by a  microprocessor  to  control  the
      release  of coating  through  the  spray  nozzles so as to reduce  the amount
      of overspray.   There  is  a water wash  holding tank at'the bottom  of the
      open spray booth  to catch any  coating  material  that run  off or  miss  the
      hide.   After  the  coating  has  been  applied, the  hide is allowed  to dry,
      either by  passing  through a dryer  or by  hang-drying before  the  nex:  coat
       i s applted.

                                     C-54

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              Figure  2

  Single Spray Nozzle Operations
         Schematic Picture
    COATING
    A.  DIRECT ROLL COATER
         APPLICATOR
COATING—i
DOCTOR BLADE
                              EVERSE ROLLER

                                PANEL
     1.  REVERSE ROLL CQATER
            Figure 3

      A. Direct Roll Coater
      B. Reverse Rol1 Coater
       Schematic Diagrams
                    C-55

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Another type of spray coating Is the oscillating arm.   This system uses
the same conveying and drying system as the rotary sprayer.  It differs
in that instead of having several guns mounted on a carousel,  one  gun i
mounted on an arm that swings back and forth.   As with spray coater's,
microprocessors can be here used to reduce overspray.

The stationary sprayer is a line of spray nozzles that remain  stationar
as the hides move underneath them.  Again, microprocessors can be  used
to reduce overspray from this equipment.

The sprinkler sprayer (or seasoner) Is used to sprinkle a coating  onto
the hides at low pressure as they pass underneath.  Microprocessors are
not commonly used here as the coating Is collected In a trough and
reused.

The use of the roll coater In leather coating is relatively new
technology that is based upon a combination of both pure roll  coating
and the rotogravure process.  The coating material Is applied  to the
leather, In the opposite direction of the substrate movement by
revolving hard steel rolls (Figure 3).  The depth of the coating is
determined by the gap between the rolls (A and 8 in Figure 3).  This
process borrows from the rotogravure technique In that the coated  roll
Is "pitted" with thousands of tiny recessed dots.  The coating material
Is usually fed from a small container such as a 5 gallon can,  via vacuum
hose Into a reservoir at the base of the  lower roller.  The coating  is
picked up by the recessed dots, held In by the liquid's surface tension,
and then transferred to the hide upon Impact.  The pitted  roller aids  in
the uniform coating application to the  leather.

The coating transfer efficiency of a roll coater can approach  1007.  <
a  tray beneath the rollers catches any  unused coating and  channels
back Into the feeder can.  According to Pfister and Vogel  (1986),  re
coating requires only 201 of the material used in an equivalent
air-atomized spray application.  After  each coating,, the hide  is subject
to either air or oven drying.

Technical problems such as  lack of penetration, uneven applications, and
bunching of hides  (particularly  thinner ones) have limited the  use  of
roll coating equipment.  However, with  experience and  improvement,  this
economical  technology has been gaining  in  use  in  the  leather  coating
industry.

Each hide  is subjected  to several  different  coatings.   The three  general
types  of  applications are called  base,  intermediate,  and  finishing
coats.  The base  coat is usually  applied  to  the  hide  as  a  stain,
penetrator  and flow  aid.  The  primary  purpose of  intermediate coats is
to promote  and Improve  the  adhesion  properties of  the  hide allowing for
Improved  application of  the  finish  or  top coats.   The  intermediate coats
may  also  fine  tune  the  hide's  texture,  color  or  print  since penetration
and  flow  ability  is  also  important here.   The top coats  give  the  leather
its  desired gloss  and resiliency.   It  is  essential  that  these coatings
be applied  in  a  series  of  thin layers  rather than in  one or two spreads
so that  the drying and  flexibility properties of the  leather  can  be
maintained.   The  question  of how many,  and what types of materials  that
are .sprayed onto any particurar piece of leather depends upon the  type
of initial  raw hide  used  and desired finished product.
                          C-56

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In the case of air-atomized spray systems,  the  various  base,
Intermediate and final coating applications  have a variety  of names.
These different applications are sometimes  referred to  as follows:
    "spray stain" (base)
    "spray middle" (middle)
    "spray effect (1st top coat),  and
    "spray lacquer" (2nd top coat)
          'spray lacquer" (2nd

      Each of these different coating types  pertains  to the  type  of  material
      that 1s being used (I.e., "stain",  "middle",  "lacquer",  or  "effect").
      Many leathers are not subject to each  of  these.finishes.  Some leathers
      receive more than one coat of certain  finishes.   As  stated  earlier,  each
      coating system can be highly Individualistic.

      In the final stage, the completed material  1s  measured,  graded and
      shipped to the appropriate leather goods  manufacturing facility for
      final  production fabrication.

3.2.3 Coating Formulations

      The Department surveyed the tanneries  of  southeastern  Wisconsin during
      1984 and found that each tannery maintains  an extensive variety of
      coatings in its stock.  The multitude  of  different hides,  desired
      colors, textures, conditions and finishes necessitate  a large, varied
      coating Inventory.  The data collected during the Department survey
      indicate that any particular coating falls  Into one  of three categories
      as follows:

          Strict lacquers.  These resin-based coatings contain approximately
          70-951 organic solvents (VOCs) by  weight.   The remaining material
          are resins and pigments (i.e., the "solids").  The lacquers contain
          three components; the coloring ingredient (pigments),  additives, and
          solvent.  Pigments are finely divided organic or inorganic material
          that imparts color.  No known heavy metals or toxics are commonly
          used In lacquer formulations.  The additives, usually organic resins
          and polymers serve as a binder (stabilizer) between pigment and the
          leather substrate and give the coating the desired characteristics,
          such as gloss and skuff resistance.  The solvent is the medium  in
          which the additives  are dissolved  and dispersed to transfer the
          pigment to the  leather substrate.

          Lacquer emulsions.   These  coatings are similar to strict  lacquers
          However a surfactant  (e.g.,  sodium laural sulfate) is applied to  the
          material  so  that  it  can  be water-misclble.  The user then  dilutes
          the material with water  in appropriate amounts.   These coatings vary
          from 20-301  water by weight  and 5-151 solids by weight.   The
          remaining 55-751 of  these  emulsions are comprised of solvents.  The
          lacquer emulsions, which a/e water-miscible, are diluted  with about
          251 water by the  leather coater before application.

          Water-based  coatings.  These coatings contain less  than 107. organ i:
          solvents.  This  type of  coating has-gained  in use over  the past re*
          years as  the  technology  has  developed and use of  these  materials  •M-;
          improved.  Their  popularity  is due to their  increased
          solids-carrying  capability.  With  water-based coatings, less
          "vehicle"  is  necessary  to  spread  the solids  onto  the aides.
                                   C-57

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           Representative formulations for  these  various  coatings along with their
           typical costs are presented In Table 2.  As  Table  I  Indicates, the
           solvent-based coatings are generally slightly  less expensive than their
           water-based counterparts.

           Lacquers have the following advantages over  water-based coatings:

               They have much  less  surface  tension, thus  allowing a more uniform
               spread and better penetration when applied.  Water, with its higher
               surface tension  is a poor  thinner  that  Is  more  likely  to "bead" on
               the product.  Poor penetration  Into  the  leather  and reduced drying
               capacity are also of concern with  water-based  coatings  in some  cases

               There  Is less sticking to  the pVatlng machine  during the embossing
               or  "plating" when the leather's  texture  Is being modified;

               They give higher quality gloss  to  the finished leather; and

               They  Impact enhanced water resiliency and  scruff-resistance.

           Most of the advantages that solvent-based coatings have over their
           water-based counterparts are at  the  top  coat application stage where
           gloss and  resiliency must be well-established.

           However,  the water-based coatings  have the  advantage of  being  able  to
           hold more  solids  in the  primary  vehicle  (water).   Water-based  coatings
           can carry  upwards of 501 more  solids by  weight.  This can  be  important
           in the  base and  Intermediate  coating stages where  much less water-based
           coatings  need  be  applied than  comparable lacquers.  Since  gloss,
           resiliency and  other surface  characteristics are of less  concern  at
           these earlier  coating  applications  water-based materials  can  and  are
           used here.

3.3  VQC Emission Rates

     After the flow coating  (if applied),  the subsequent coatings are usually
     applied to the leather  by either  a  rotary nozzle   sprayer or by a roll  coater.
     with  the former being the predominant  method in southeastern Wisconsin.  Tne
     rotary nozzle sprayer has been described In Section 3.2.2.

     The leather coating process  Involves  a wide variety of hides,  and tyqe, nu~oe
     and thickness of coatings.  As such,  the Department decided to estimate VCC
     emission rates based upon the amount  of coating material,  per each coating.
     that  would be applied to any one series of hides.   The VOC emission rats u-n:
     is kilograms per 100 square meters   (kg VOC/IOOm') of leather for each
     application.  Each VOC emission factor would highlight  the above-listed
     variations.

     In calculating VOC emissions from any uncontrolled  surface coating operation .
     it Is generally assumed  that all  VOCs contained  In  the  coating  evaporate  i^
     are eventually  emitted into the ambient atmosphere.   This  assumption ;oui:  :?
     modified  in  light of conclusive evidence  to the  contrary.
                                    C-58

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                                      Table 2

              Representative Leather  Coating  Formulations  and Cost '"


                              Percent Content by Height

Ingredient	  Hater-based  	Lacquer Emulsions'"'	Strict  Lacquer
VOCS
Solids
Hater
Cost range
($/lb)
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     The  large Milwaukee  area  tanneries  supplied VOC emission  rate data  to the
     Department  during  late  1985  -  early,  1986.  This  Information  shows  that  there
     Is  a wide variation  In  the coating  application among  the  leather  finishers  in
     southeastern  Wisconsin.   One coater uses  very  little  water-based  materials  and
     no  roll  coating.   Another facility  needs  to apply  several  extra coats to much
     of  Its  leather  to  enhance the  leather's  scruff-resistance  and waterproof
     qualities for use  In footwear  manufacturing.   Different coatings  are sometimes
     applied  separately.   On other  occasions,  various  coatings  are mixed  together
     and  then applied.  One  tannery uses the  roll coating  technology primarily  with
     low  solvent coatings; another  employs similar  equipment mostly with  lacquers.
     In  general,  there  are numerous permutations and combinations  of different
     coating  materials  and methods  of application  In use  In  southern Hisconsin.
     The  result  !s that there  is  a  wide  range  in the.VOC  emission  rates.  Table  3
     presents some ranges for  various coating  systems  (I.e., coating type and
     application method)  based on the information  supplied by  the  leather finishers
     to  the  Department  during  the past seven  months.   The  numbers  contained  in
     Table 3  highlight  the wide  variation In  VOC emission  rates from  leather
     coating  operations.

3.4  Potential  Leather  Coating VOC  RACT  Measures and Cost

     3.4.1 Low Organic  Solvent/High Solids Coatings

           VOC  emissions  from  lacquers (over  801 VOCs)  or .lacquer  emulsion-based
           coatings  (over 50%  VOCs) can  be reduced  by  more than 50 percent  by
           employing coatings  which have low  levels of organic solvents (less than
           201 VOCs).   The actual VOC reduction achievable depends on  the organic
           solvent contents of the  original coating and the  proposed
           alternatlve(s).  Substituting low  organic  solvent or high   solids
           coatings  is  the accepted method to lower VOC emissions  from all
           Industrial  surface  coating operators.

           Using a coating which has a  low organic solvent content may preclude the
           need for any further controls.  In some cases, the  coating  equipment and
           procedures may need not be altered when a  plant converts to low solvent
           coatings.  This would keep the capital  investment in coatings
           substitution or reformulation  to a minimum.

           Because water-based and high  solids coatings are a  proven  technology
           that can feasibly  reduce VOC  emissions, the Department is  proposing  that
           this type of  coating  constitutes a reasonably available control
           technique for  reducing  VOC emissions from leather coating  operations.

           The Department is  aware that  product specification  requirements can
           often  necessitate  the continued use of high solvent coatings.  Each  type
           of leather  has Its own  requirements that must  be met.  Each  individual
           coating  system must be  evaluated on a case-by-case  basis as  to whether
           low  solvent/high solids finishes can be adequately  substituted.

      3.4.2 Roll Coating

           Roll coating,  as stated in section  3.2.2,  has  become increasingly
           popular  In  certain sectors of the  leather  finishing industry due  to its
           higher transfer  efficiency (estimated  to be close  to  1001).   Pfister arn
           Vogel  Tanning Company (1986) stated that roll  coating  applications
            require  only  about 201  of the finishing material used  in  a comparable
            air-atomized  spray application.

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                                       Table 3

                                  VOC Emi ssion  Rates
                               Various Coating Systems
                            Southeastern  Wisconsin  -  1985*
.Application  Method           Coating Type             VOC Emission  Rate  (kg/100  m')


 Flow                       Oil  Impregnation          '          2.39-9.76

 Air  Atomized Spray         Stain    _      .                    7.81-H.16

 Air  Atomized Spray         Middle                             0.33-6.41

 Air  Atomized Spray         Emulsion                              3.42"

 Air  Atomized Spray         Effect (1st top coat)               1.95-12.7

 Air  Atomized Spray         Lacquer (final  top coat,  sealer)   2.44-16.11

 Roll                        Oil  Impregnation                       2.93"

 Roll                        Stain                              1.12-2.93



 'Based upon  information received from Amity  Leather Products Co.,  Gebhardt-Vogel
 Tanning Company, and Pfister & Vogel Tanning Company during November 1985 - April
 1986.

 "Only  one value presented from the above listed leather finishers.


 7634Q.PERM
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     According to a midwest distributor of  leather  coating  equipment, a
     typical roll coater costs between $26,000  and  S35.000  (year  1984
     dollars, including installation and  setup  costs).

     Assuming that roll coater's use one-fifth  the  finish of  spray systems,
     It  is  likely that a roll coating machine could pay  for itself within  ten
     years  of operation through reduced coating usage.   After  its payback
     period, the equipment would give the company a net  savings  in reduced
     coating costs.  This benefit could occur even  if depreciation and tax
     write-off deductions are not included.  A  net  zero  cost of  the equipment
     over  10 years would imply that  the ten  year, gross  annualized cost  per
     ton of VOCs reduced would also  be zero.  This  compares quite favorably
     with  the cost of  reducing VOCs  for other surface coating  categories
     (Table 4>.

     The high efficiency, relative simplicity,  proven experience, and
     anticipated capita! return of this equipment makes  it  a  pragmatic
     technique for reducing  the amount of VOCs  Into the  atmosphere.  As  such,
     the Department  Is proposing that roll  coating  constitute  a  VOC
     reasonably  available control technique  (RACT)  for  leather coating
     operations.  Roll coating would be a Department approved  method to  meet
     compliance  with any promulgated leather coating VOC emission  limitation
     control requirement.

     In  recommending roll coating as one  VOC RACT for leather finishing, the
     Department  1s aware that  this method cannot be substituted for  the
     air-atomized spray method  in all cases.  Product specifications often
     require the use of spraying.  Because  of the roll  coater's considerable
      savings  in  coating, It  is  to the  leather finishers  economic advantage to
      continually investigate  every- possible use of this  technology in  its
     operations.

3.4.3 Microprocessor  Controls  on Air-Atomized Spray Equipment

      The rotary  arm  sprayer  has  the  potential  for much  overspray and
      underspray  on  the hides  passing below  it.   This unevenness in the
      finishing  application  also  results  in  much unnecessary solvent (and
      VOC's) being  emitted  into the atmosphere.   As such, the Department is
      proposing  that  microprocessor controls (e.g.,  "electric eyes")  on all
      air-atomized  spray equipment  be a  required VOC RACT for the leather
      coater's.   According  to the  Pfister and Vogel  Tanning Company (1986),
      rotary air  atomized  spray equipment without microprocessor controls
      results In  a  typical  transfer  efficiency of 271.  However, Pfister and
      Vogel stated  that the  use of a  microprocessor increases  the efficiency
      to 451.   This  results  in a reduced coatings consumption by 407..

      This equipment is relatively inexpensive  to install and  can pay for
      Itself in reduced coating costs in  several months.  Indeed, most air
      atomized spray systems used in  the  southeastern Wisconsin  leather
      coating industry are  already fitted with  these microprocessor controls.
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                                    Table 4

                  Analyzed  Estimated Cost (Year 1985 Dollars)
                            Per Ton of  VOC Reduction
                      Industrial  Surface Coating Categories
                    In Wisconsin that  are Subject  to  RACT     Adjusted from Booz-Allen's year 1978 dollar  estimate  to 1985 dollars  by
       assuming 401 Inflation in cost between  these years.


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    3.4.4 Add-On Controls

          Add-on VOC controls are post-process techniques that allow for the
          venting and either destruction or removal of VOC's after the coatings
          have been applied to the hides.  Incinerator and carbon adsorbers wouic
          be examples of add-on controls.

          Add-on controls as a potential leather coating VOC RACT must be
          evaluated In terms of annualIzed cost portion of VOCs reduced.  These
          calculations for a representative thermal Incinerator (no heat recovery
          are based on equations developed by WAPORA (1981) and contained in
          Table 5.

          The gross ten-year annualIzed cost of an incinerator, as calculated  in
          Table 5, Is $144,230.  Assuming an overall control efficiency of 857., a
          source that approximates the parameters  listed in Table 5 and emits  100
          tons VOCs per year would pay $144,230/(0.85*100 tons) - $1,697/ton VOC
          reduced.  A two hundred ton/year VOC source with similar operating
          specifications would pay $1697/2 - $848/to VOC reduced.  However, it ca
          be assumed that the  larger  the source, the more operation and
          maintenance costs.   The cost/VOC reduction factor Is not a constant
          multiple of one baseline value.  Nevertheless, the cost of reducing
          leather coating VOC  emissions  is comparable when compared with similar
          estimates for other  surface coating operations (Table 4).  The
          Department, based upon the  Information available to  it, and  th-e
          subsequent calculations (Table 5).  is recommending that thermal
          incineration be considered  on  a case-by-case  as VOC  RACT.

          At this time,  the Department  is also preliminarily recommending  that
          compliance with any  promulgated leather  coating VOC  emission limitation
          rule  be achievable  through  the appropriate application of  low-solvent
          coatings, microprocessor controls on spray systems,  and roll  coating
          technology alone.   The status  of  this recommendation may change  in  ligh
          of new data.

          Carbon adsorption  is not being recommended as  VOC RACT for  leather
          coating.   This  type  of system, which  is  approximately,  three times  as
          expensive  as  a thermal  incinerator  of comparable  size  (WAPORA,  1981 ) ar
          only  feasible  when  much of  the captured  solvent  can  be  recycled.   The
          multitude  of  different  leather coating vented  to  a  carbon  adsorber  maK;
          such  recovery  system economically unfeasible  since  additional expensive
          distillation  would  be  required for  any  solvent recovery.

3.5  Proposed  Leather  Coating  RACT  VOC Emission  Limitation  Rule

     3.5.1 Proposed  VOC  Emission  Limits

          As  section 3.2 and 3.3 describe,  the  leather coating VOC  emissions are
           derived  from  a large number of permutations  in the  coating for-nulation
           and  application types.   This  wide variety of coating systems make it
           difficult to  succinctly  define a VOC emission limitation  or  limitation
           that would reflect an  adequate implementation of RACT (section 3.4).
           The  absence of a U.S.  EPA  control  technique gu.ideline (CTG)  for this
           category compounds  the problems  involved in setting VOC RACT limits fo
           leather coating.
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                                    Table  5
                           Estimated Annualized Cost
                    Thermal Incinerator (No Heat Recovery)
                           Leather Coating Facility
                                  Assumptions

   Representative  air  velocity  In the vicinity of the coating equipment:
         150 ft./min
   Flow  rate  In  vicinity of coating equipment:
         150 ft/rain * 8 ft. (wide) * ft. (high) - 1200 ft.Vraln •
   Operating  Temperature:  1300*F - Temp.
   VOC Cone.  1n  gas stream:   50 ppm
   Hours  per  year  operation - 40 hrs/day  * 260 days/yr - 2600 hrs/yr. actual
   running time  is 1300 hrs/yr.  (0.5  * operating time)
   Overall Control  Efficiency:   851
                   /
   Heat  recover  »  6
   Base  year  (1981) fuel  cost:   S2.13/MMBTU'•'  (#2 fuel oil)
   Base  year  (1981) electrical  cost:   50.055/kwh'a),
   Inflation  factor, year  1985  dollars  to year 1981  dollars:  1.4,
   Interest on equipment  purchase loan:   181,
   Full  loan  payment annually uniform in  10  years,
   Deduction  for depreciation,  taxes  and  Interest  not  included,  and
    Installation  Cost:   2.8 *  unit cost (not  including  interest)18'
                                  Calculations
1) Unit  cost:     $ «  2.7* flow rate  + 22.000
                     -  2.7 *  12000 > 22,000
                     -  54,400  (year  1981  dollars)
2)  Including  factors  for  inflation  and installation:
    (1.4) * (2.8) ' $54,400 »  $213,200
                                         C-65

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                              Table 5 (Continued)


3)  Total interest on the equipment and  installation  loan,  assuming complete
    uniform payment over ten years:

    C
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 The original draft  rule had only one  limit representing a composite of
 various  leather  coating materials  (water-borne, emulsions and lacquers) .
•and application  types  (spray and roll).   Based upon comments received on
 this first draft of the rule,  the  Department has striven to improve the
 rule by  establishing VOc  limits that  more accurately reflect the wide
 variety  of coating  types.

 The revised  rule would establish VOC  emission  limits for each of the
 basic  functional coating  types  (Impregnation,  stain, baseyor middle,
 effect and finish  coats)  that  are  significant  emitters of VOC's.   It  is
 recognized that  each of these  function  types (save for Impregnation)  has
 a somewhat Identifiable range  of VOC  emission  rates for air-atomized
 spray  systems.   Based  on  data  received  by the  Department, qualitative
 assessments  of potential  VX emission reductions have been projected  fcr
 each function type. These  assessments_are based upon research  and
 testing  with the available  technology that Is  proposed as RACT.  These
 projections  are  based  upon  the assumption that customer specifications
 and state-of-the-art technology will  remain  essentially the same for  the
 Immediate future.

 U.S. EPA CTG's recommended  VX emission limits based, In part,  upon
 evidence that  some facilities  had  already met  these  limits by applying
 the categoryOspeclfic  RACT.  The Department  has developed its leather
 coating  VX  RACT limits  in  a similar  manner.   Namely, the Department
 studied  the  total  range of  VOC emission rates  foV  each function type  as
 submitted by the leather  coating facilities.   Based  upon these  ranges
 (minimum and maximum values  are listed  in Table 3),
 determined  that  theJJ%*in  each spray coating  range
1-IStrioution;  wou ia "represent  an adequate degree of
 words, the  proposed VOC  limits would  be established
                                                    the  Department  has
                                                    (frequency
                                                    RACT.   In  other
                                                    at a level  that is
currently being achieved about
coater's in the Milwaukee area.
                                161 of the time at the 3 largest  leather
This standard translates into the proposed VOC RACT emission  limitations
for the following categories (with accompanying proposed Department
defini tions):

    Impregnation coat (penetration into the hide for tightening or
    setting up the fibers.   Also used for increased hide flexibility
    without cracking)? A

                                                     VOCs/tOOm2) of
   / 2.9 kilograms VOCs per 100 square meters (2.9 kg
     finished product, regardless of the number of impregnation coats
     applied (6.0 pounds VOC per 1000 square feet - 6.0 Ibs VOCs/1000
     fttf).      _____—	.	
    Stain coat (color development, or color deepening of the hide's
    base):  9.3 kg VOCs/100m2 (19 Ibs VOC/1000 ft2) of finished product
    regardless of the number of stain coats applied.

    Base color coat (gives the leather its predominant color   It
    follows any impregnation and/or stain coats, or precedes any effect
    or final finish coats):  1.0 kg VOCs/100m2 (2.0 Ibs VOCs/1000  ft2>
    of finished product, regardless of the number of base color coats
    applied.
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          Effect  coat  (tonesV the base color and  reduces  the  leather's  surfac-
          coefflclent  of  friction):  2.0 kg VOCs/100m2  (4.0  ibs VOCs/1000 ft2
          of  finished  product,  regardless of the  number of effect coats
          applied,  and

          Final finish coat  (to help improve the  leather's gloss,
          water-resistance and  scruff-reslstence  qualities):   3.4 kg VOCs/lOOC
          ft2) of finished product, regardless of the  number  of final  finish
          coats applled.

      The  Department  Is aware that  each finished  leather  product  Is  subject  tc
      one, and only one application of  the above-listed coating types.   Some
      leathers receive several  applications of one coat,  others experience
      none at all of  certain coats, while still other  leathers receive  coats
      that are not even contained  in any of  the above-1listed coating
      categories.  The Department has defined these categories and  subsequent
      VOC  emission limits based upon a  fair  statistical representation  of  the
      major VOC - emitting spray lines.  Some other coating  function  types
      (e.g.,  seasoning) result in negligible amounts of VOC  emissions.   8y
      controlling the  amount of VOCs emitted from the  five -  previously listed
      coating function types, the Department fully addresses  the  VOC  emissions
      concern In  southeast Wisconsin's  leather  coating industry.

3.5.2 Proposed Rule Flexibility in  Meeting  the  VOC Emission  Limits

      The  purpose of this proposed  rule is  to  help reduce the total  amount of
      ozone - precursor (VOCs) emitted  into  southeastern  Wisconsin's
      atmosphere.  The separate limits  listed  in  Section  3.5.1  reflect what
      might be reasonably expected  for  each  coating function type in achieving
      this goal.   However,  the Department  is  aware that achieving each limit
      for  each product may be difficult.  Furthermore,  the leather coater's  may
      more readily comply with other  certain application  limits  at  certain
      times.   Subsequently,  the proposed  rule  contains a  subsection on
      internal offsets (NR 422.17(03))  of  VOC  emission rates to  meet the
      facility's  monthly-weighted allowable  emission limit.   Some of the
      facility's  specific leather coating  production runs would  be  allowed to
      exceed the  RACT  limit  for any given  month  if the VOC emissions in excess
      of  that allowable for  that month  would be  "offset"  by VOC emissions from
      other lines that are below their  respective RACT limits for the  same
      month.   Furthermore, the proposed leather  coating VOC  emission
      limitations are  expressed in units  of kilograms  VOC per 100 square
      meters (kg/lOOmM of finished leather product regardless of the  numoer
      of  specific coats applied.  These emission  rate units  allow for maximum
      flexibility  in  determining which RACT method(s)  may be employed  to
      achieve the  limit.   Any  combination of low  solvent coating technology
      roll coating, computer - controlled spray  systems,  incineration  or any
      other department - approved RACT method may  achieve this primary
      requirement of  the rule.  Subsection NR 422.04(1),  His. Adm. Code
      ("Methods  of Compliance") lists the VOC control options that would  te
      available  to any leather  coating facility  subject  to  the rule.
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3.5.3 Recordkeeping and Reporting Requirements

      Each affected facility will obviously have to closely monitor its
      coatings usage, VOC emission totals, production totals, and methods of
      compliance employed for all coating lines subject to the rule.  This
      monitoring must necessarily be done on a monthly basis to meet the
      Internal offset provisions.  In the short run, monthly production
      schedules will need to be evaluated, possibly revised and closely
      followed to ensure that the facility's overall monthly-weighted emission
      rate Is not exceeded.  Records of these activities must be maintained
      and reported to the Department in accordance with proposed Chapter
      NR 439  ("Compliance Demonstration") . whl'ch w.1 1 1 be proposed for adoption
      approximately concurrently with this rule, but as part ofxdlfferent
      Natural Resources Board order number.                  • /\
3.5.4 Proposed Compliance Schedule and Variance Provisions

      The Department's commitment to develop, promulgate and implement all VOC
      RACT rules Include the provision of certified final compliance for each
      affected facility not later than December 31, 1987.  This date 1s the
      same as the ozone attainment deadline for the southeastern Wisconsin
      ozone nonattainment area.  Each stationary sources subject to any RACT
      must achieve compliance with the appropriate rule before this date  in
      order for the region to take certified credit for the subsequent VOC
      reductions.  These VOC reductions are required under the 1982 Ozone
      State Implementation Plan for 'southeastern Wisconsin.

      If this proposed rule is promulgated, it will be done so at a  late  date,
      relative to the December 31, 1987 deadline.  On  the other hand, much  (if
      not most) of the technology necessary to achieve compliance is already
      in place for the affected leather coating facilities.  It would be  a
      matter of improving and enlarging the role of these VOC emission control
      technologies to meet the rule requirements.  As  such, the Department
      believes that this rule can be coupled with  in the required timeline
      (i.e., before December 31,  1987) by meeting  the  following compliance
      schedule, as measured from  the effective date of the rule:

          Submit final plans for  achieving compliance  within 4 months,

          Award contracts for equipment modifications  or  issue orders  for the
          purchase of component parts to accomplish equipment modifications
          within 5 months ,

          Commence construction or installation of equipment modifications
          within 7 months, and

          Achieve final  compliance not  later  than  December  31,  1987.

      This  schedule  is  somewhat tighter  than  that  required  in  previous  VOC
      RACT  rules.  However, any affected facility  that believes  it  can  not
      meet  this  schedule, or any  othej"  provi sion( s)- in the  rule,  may apply  for
      a  variance under  section NR 43^.05.
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    3.5.5 Estimated Impact of the Proposed Rule

          1980 Is the base year for estimating the Impact of any RACT rule  as  part
          of the 1982 ozone plan.  Since that time,  the southeastern Wisconsin
          leather coater's have substantially Increased the efficiency of their
          operations.  Computer-controlled spray equipment, roll coating and low
          solvent coatings either came into Initial  use or were greatly expanded
          In use during the first half of the 1980's at these tanneries.  The
          surge in foreign competition will further  mandate continued improvements
          1n their operations.

          And most of these Improvements have and will continue to result in less
          coating be applied  to the leather.  Less coating means fewer vocs
          emitted.  A prime example Is by simply employing computer controls on
          spray lines, the amount of coating used has been reduced by 401 since
          1980 (Pflster and Vogel (1980)).  Furthermore, the leather coater's  are
          always seeking ways to expand their use of water-based coatings,  which
          are less costly  than solvent-based coatings on per unit area basis.   By
          setting the VOC  emission rates near the low end of the air atomized
          spray ranges listed on Tgble 3,  the Department has established goals
          that are achievable by the affected facilities In the required timeline
          (I.e., before December 31, 1987).

          The projected Impact of this rule on the  region's leather  coating VOC
          emissions can not be made at. this  time.   Currently,  there  is  not  enough
          Information available  to the Department to  make  this  estimate.   Such
          calculations will be conducted when the affected facilities  begin
          supplying monthly records as part of Its  rule  compliance  requirements.

          The leather coating Industry  is  relatively  complicated  in  understanding
          its impact on VOC emissions.   Developing  VOC  RACT and proposed rule  for
          this  Industry has not  been  easy  either.   Subsequently,  the  rule's impact
          will  also  take  awhile  to understand.

     Both the energy  and environmental  Impacts (primarily industrial  wastewater)
     from leather  coating  operations are  approximately proportional  to the  amount
     of coating  used.  Since  roll  coating is  more efficient than spray coating,
     there would  be  a net  reduction  in  energy consumption and  process wastewater
     when the former  equipment is employed.

     When substituting water-based coatings,  there may be a slight increase in
     energy  consumption  due to some  additional oven-drying.
           would be an Increase in natural  gas  consumption if thermal  incineration
          fllzed as a method to comply with any emission limitation.  The impact 01
There
Is utilized as a method to comply with any emission limitation.  The impact or
the environment from Increased natural gas usage would be negligence.
7634Q.PERM
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                                     References
Booz,. Allen and Hamilton, Inc., 1978:  Economic Impact of Implementing RACT '
Guidelines In the State of Wisconsin. Vol. 1, Executive Summary,  Draft Final  Report.

U.S. EPA, 1983:  "Compilation of Air Pollution Emission Factors"   AP-42.

Pfister and Vogel Tanning Company, April 29, 1986A* VOC Reduction Study Report.
Submitted to the Hisconsin Department of Natural  Resources, Bureau of Air
Management.

Pfister and Vogel Tanning Company, 19868.  July 1/1986 telephone conversation
between George Stockman, Manager, Research and Development, Pfister and Vogel and
Mr. William Adamski, Environmental Specialist, Wisconsin Department of Natural
Resources.

Wayne, W. S.; Wehrle, P. P.; and Carroll, R. E., 1967:  "Qxidant Air Pollution and
Athletic Performance." Journal of the American Medical Association. 199:901.

United States Congress.  1977:  The Federal Clean Air Act As Amended, August,   1977,
PL 95-95.

U.S. EPA, January 22, 1981:  Federal Register. Vol. 46. pp. 7186.

U.S. EPA, September  17,  1979:  Federal  Register. Vol. 44.  pp. 53782.

U.S. EPA, 1980:  Environmental Impact Guidelines for New Source Leather  Tanning and
Finishing Industries (EPA-130/6-8Q-QQ2).  pp. 143.

WAPORA, Inc. 1981; Assessment  of Organic  Emissions  In the  Flexible Packaging
Industry.  EPA-600/2-81-009. 85  pp.

Wisconsin Department of  Natural  Resources,  1983:   1982 Revision to the State
Implementation Plan  for  Ozone/Carbon Monoxide  in Southeastern Wisconsin.


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State of Massachusetts
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PUBLIC HEARING DRAFT
(22) _
          Leather Surface Coatina
(a)  Applicability.  310 CMR 7.18(22) applies in its entirety to
     any person who owns, leases, operates or controls leather
     surface coating line(s) which in total have the potential to
     emit, before the application of air pollution control
     equipment, equal to or greater than 50 tons per year of
     volatile organic compounds.

(b)  Reasonably Available Control Technology Requirements.  On or
     after July 1, 1993, unless exempted by 310 CMR 7.18(22)(c)
     or granted a non-renewable extension by the Department, under
     310 CMR 7.18(22)(d), no person subject to 310 CMR
     7.18(22)(a) shall cause, suffer, allow or permit emissions
     from any leather surface coating line in excess of 27.4 Ibs
     VOC/gallon of solids applied.

(c)  Exemptions.  The requirements of 310 CMR 7.18(22)(b) do not
     apply to:
          1.   a.  any person subject to 310 CMR 7.18(22)(a) who
               is able to demonstrate to the Department that,
               since January 1, 1990, the leather surface coating
               line(s)  have not, in total, emitted, before the
               application of air pollution control equipment,
               greater than or equal to 50 tons per year of
               volatile organic-compounds; and
               b.  provided the person obtains a permit
               restriction from the Department under 310 CMR
               7.02(12) which restricts the potential emissions
               to below 50 tons per year; and
               c.  provided the person complies with other
               sections of 310 CMR 7.18(22).
          2.  any person subject to 310 CMR 7.18(22)(a)  who,
          according to the Department, has complied with 310 CMR
          7.18(17) prior to January 1, 1993.

(d)  Extensions.
     1.  Any person subject to 310 CMR 7.18(22)(b) may apply in
     writing to the Department for a non-renewable extension of
     the implementation deadline.  The person must apply to the
     Department for the non-renewable extension at the same time
     the person submits the emission control plan required by  310
     CMR 7.18(20).
     2.  The Department will consider a non-renewable extension
     of the deadline in 310 CMR 7.18(22)(b) until no later than
     July 1, 1994, provided the emission control plan submitted
     for approval 7.18(20), meets the following criteria  in
     addition to those of 310 CMR 7.18(20):
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PUBLIC HEARING DRAFT


          a.   the emission control plan must meet all
               requirements of M.G.L.c. 211; and,
          b.   the emission control plan must be approved by a
               Toxics Use Reduction Planner certified under
               M.G.L.c. 211, or an employee of the facility must
               be certified as a Toxics Use Reduction Planner?
               and,
          c,   implementation of the plan must meet the emission
               limitations of 310 CMR 7.18(22)(b) or achieve a
               85% emissions reduction, whichever is greater,
               without using add-on air pollution control
               equipment, as calculated on a mass of VOC emitted
               per gallons of solids or unit of production; and,
          d.   the emission control plan must also contain
               contingency measures to meet the RACT emission
               limitation in 310 CMR 7.18(22)(b); such measures
               must automatically take effect if the emissions
               reductions achieved by meeting the requirements of
               M.G.L.c. 211 do not satisfy 310 CMR 7.18(22)(b).

 (e)  Plan ..Submittal Requirements.  Any person who owns, leases,
     operates or controls a leather surface coating line(s)
     subject to 310 CKR 7.18(22)(a) must submit an emissions
     control plan, and have the plan approved by the Department
     under  310 CMR 7.18(20).
                      s>
 (f)  Continuous Compliance.  Any person who owns, leases,
     operates or controls a leather surface coating line(s)
     subject to 310 CMR 7.18(22)(a) shall maintain continuous
     compliance at all times with their approved emissions
     control plan.  Compliance averaging times will be met  in
     accordance with  the requirements  of 310  CMR 7.18(2) (a).
     Demonstrations of compliance may  include considerations of
     transfer efficiency provided that the baseline transfer
     efficiency is equal to or greater than  65%, and the  transfer
     efficiency test  method is detailed in the emission control
     plan (310 CMR 7.18(20)) approved  by the  Department.

 (g)  RecordXeepina Requirements.  Any  person  who owns, leases,
     operates or controls a leather surface  coating  line(s)
     subject to 310 CMR 7.18(22)(a) shall prepare and maintain
     daily records sufficient to demonstrate  compliance
     consistent with  the applicable averaging time as stated  in
     310 CMR 7.18(2) (a).  Records kept to demonstrate compliance
     shall be kept on site  for  five years and shall  be made
     available  to  representatives of the  Department  and  EPA in
     accordance with  the requirements  of  an approved emission
      control plan  (310 CMR  7.18(20) or upon request.   Such
      records  shall  include, but  are not limited  to:


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PUBLIC HEARING DRAFT


transfer efficiency test method is detailed in the emission ,
control plan approved by the Department.

(h) Recordkeeping Requirements.  Any person who owns, leases,
operates or controls a coating line(s) subject to 310 CMR
7.18(21)(a) shall prepare and maintain daily records sufficient
to demonstrate compliance consistent with the applicable
averaging time as stated in 310 CMR 7.18 (2) (a)-. Records kept to
demonstrate compliance shall be kept on site for five years and
shall be made available to representatives of the Department and
EPA in accordance with the requirements of an approved emission
control plan (310 CMR 7.18(20)) or upon request. Such records
shall include, but are not limited to:

    1.    identity, quantity, formulation and density of
          coating(s) used;
    2.    identity, quantity, formulation and density of any
          diluent(s) and clean-up solvent(s)  used;
    3.    solids content of any coating(s) used;
    4.    actual operational and emissions characteristics of  the
          coating line and any appurtenant emissions capture and
          control equipment;
    5.    quantity of product processed;
    6.    any other requirements specified by the Department in
          any approval(s) issued under 310 CMR 7.18(20) or. any
          order(s)  issued to the person.

(i)  Testing Requirements.  Any person who owns, leases, operates
or controls a coating line(s) subject to 310 CMR 7.18(21)(a)
shall, upon request of the Department, perform or have performed
tests- to demonstrate compliance with 310 CMR 7.18(21).  Testing
shall be conducted in accordance with EPA Method 24 and/or Method
25 as described in CFR Title 40 Part 60, or by other methods
approved by the Department and EPA.
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PUBLIC SEARING DRAFT


     1.  identity, quantity, formulation and density of
     coating(s) used;
     2.  identity, quantity, formulation and density of any
     diluent(s) and clean-up solvent(s) used;
     3.  solids content of any coating(s) used;
     4.  actual operational and emissions characteristics of the
     coating line and any appurtenant emissions capture and
     control equipment;
     5.  quantity of product processed;
     6.  any other requirements specified by the Department in
     any approval(s) issued under 310 CMR 7.18(20) or any
     order(s) issued to the person.

(h)  Testing Requirements.  Any person who owns, leases, operates
     or controls a leather surface coating line(s) subject to 310
     CMR 7.18(22)(a) shall, upon request of the Department,
     perform or have performed tests to demonstrate compliance
     with 310 CMR 7.18(22).  Testing shall be conducted in
     accordance with -EPA Method 24 and/or Method 25 as described
     in CFR Title 40 Part 60, or by other methods approved by the
     Department and EPA.
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State of Illinois
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                        TT.T.TNOIS REGISTER
                     POLLUTION CONTROL BOARD

                  NOTICE OF PROPOSED AMENDMENTS
Section 218.920    Applicability

  a}-  The rcquircmcnto of this • Subpart shall apply to a source 'a
       miaocllanooug fabricated product-manufacturing process
       omioaion units whiah.-o.re not included within any of the
       categories specified in Subparta D, E, F, H, Q, R, S, T,
       V>  X/  Y, Z or DD if the aouroc ia aubjcct to thia Cubpart.
       A oouroo io aubjoot to thin Cubpart if it oontaina procoaa
       omioaion units, — not regulated 'by- Subparto B, — S-, — F
       (excluding Ccotion 210.204(1) of thia Tart), II  (eucluding
       Section 210.405 of thia Part), Q, n, C, T (excluding
       Section 218.406 of thia Part), V, X, ¥, Z or DB of thia
       Part;  which an a group both!

       3J-  Have • maximum • theoretical cmiasions of 01 Mg-(100 tona)
           or moro per calendar yoar of VOM  if no  air  pollution
           control equipment were uncd,
       3-)-  Are not limited to loan than 01 Mg  (100  tons) of VOM
           omigQiono per calendar year in the.  abacnce' of air
           pollution control equipment, — through production or
           capacity limitations contained in a federally
           enforceable permit or a CIP revision.

       Maximum theoretical emission:

       1)  A source is subject to this Subpart if  it  contains
           process emission units, not reorulated by Subparts B,
           E. F  (excluding Section 218.204(1). H  (excluding
           Section 218.405). 0, R, S, T,  (excluding Section
           218.486) V, X, Y. Z or BB of this Part;  which as  a
           group both:

           A)  Have maximum  theoretical emissions  of  90.7  Mg (100
               tons) or  more per  calendar year of  VOM if  no  air
               pollution control  equipment  were  used, and
April  15,  1993            DRAFT-25TPY-46
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                       ILLINOIS REGISTER
                    POLLUTION CONTROL BOARD

                 NOTICE OF PROPOSED AMENDMENTS

              Are not limited to less than 90.7 Ma  ClOO j:ons) of
              VOM emissions per calendar year in the absence of
              air pollution control equipment, through
              production or capacity limitations contained  in a
              federally enforceable permit or a SIP revision.

      2)   If a source is subject to this Subpart as provided
          above, the requirements of this Subpart shall apply to
          a source7s miscellaneous fabricated product
          manufacturing process emission units which are not
          included within any of the categories specified in
          SuboartS B. E. F. H. 0. R. S. T. V. X. Y. Z. AA.  BB.
          OQ. RR. or TT.

  b)   Potential to emit;

      lj  A source is subject to this Subpart if it has the
          potential to emit 22.7 Mg (25 tonsl or more of VOM per
          year, in aggregate, from emission units that are:

          A!  Not regulated within Subparts  B,  E. Fr H, Q,  R. _S,
              T  (excluding Section 218.486)L V/ X.  Y.  Z.  or BB
              of this Part, or

          B.1  Not  included within one  of  the following
              categories:  synthetic organic chemical
              manufacturingsindustry  fSOCMI) distillation,  SOCMI
              reactors,, wood  furniture, plastic parts  coating
              Xbusiness_jnachinesl. plastic parts  coating
               (other),  offset lithography,  industrial
              wastevater,  autobodyrjrefinishing. SOCMI  batch
              processing,  volatile organic  liquid storage tanks
              and  clean-up solvents operations.

      2.L  If a  source is  subject to this  Subpart, as provided
          above, the reguirements of this Subpart  shall  apply  to
          a  source1's miscellaneous fabricated product
          manufacturing process  emission  units, which  are not
          included  within:

          Al  Subparts  B,  E,  F,  H.  Q.  R.  S,  T,  V,  X, .Y.  2,  AA.
               BB,  CC,  DP,  QO, RR or TT of this  Part, or

          B)   One  of the  following  categories:   synthetic
               organic  chemical manufacturing industry (SOCMI)
               distillation,  SOCMI  reactors,  wood furniture,
               plastic  parts  coating (business machines)-, plasric
               parts •:->.!ting   (other),  offset lithography,

April 15,  1993             DRAFT-25TPY-47
                                   C-82

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                        ILLINOIS REGISTER
                     POLLUTION CONTROL BOARD

                  NOTICE OF PROPOSED AMENDMENTS

               industrial wastewater. autobodv refinishina.  SOCMI
               batch processing,  volatile  organic liquid storage
               tanks and clean-up solvents operations.

  tec) If a  source ceases to fulfill the criteria  of subsections.
      (a) and Jb). above,  the requirements of  this Subpart shall
      continue to apply to a miscellaneous fabricated products
      manufacturing process emission unit which was ever subject
    .  to the control requirements of Section  218.926 of this
      Part.

  ed) No limits  under  this Subpart shall  apply to emission  units
      with  emissions of VOM to the atmosphere less than or  equal
      to 0.91 Mg (1.0  ton)  per calendar year  if the total
      emissions  from such emission units  not  complying with
      Section 218.926  does- not exceed 4.5 Mg  (5.0 tons) per
      calendar year of this Part.

  4e) For the purposes of this Subpart, an emission unit shall
      be considered regulated by a Subpart if it  is subject to
      the limits of that Subpart.  An emission unit is fte%
      considered not regulated by a Subpart if it is not subject
      to the  limits of that Subpart, e.g., the emission unit  is
      covered by an exemption in the Subpart  or  the
      applicability criteria of  the Subpart are  not met.

  ef) For the purposes of this Subpart, uncontrolled VOM
      emissions  in  the absence of air pollution  control
      equipment  are the emissions of VOM  which would result if
      no air pollution control equipment  were used.

(Source:  Amended at 	 111. Reg. 	, effective    '	)

Section 218.926     Control  Requirements

Every owner or operator  of  a miscellaneous fabricated product
manufacturing process  emission unit subject to this Subpart shall
comply with the requirements of subsection (a) , (b) or (c)  of
this Section:

  a)  Emission capture and control  techniques which  achieve an
      overall  reduction in uncontrolled VOM  emissions  of at
      least 81  percent from each emission unit,  or

       (Board  Note:   For the purpose of  this  provision,  an
      emission unit is any part  or. activity  at a source of a
      type  that by  itself  is subject  to control  requirements in
      other Subparts of this Part or  40 CFR  60,   incorporated by

April 15, 1993            DRAFT-25TPY-48
                                  C-83

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                        ir.T.INOlS REGISTER
                    POLLUTION CONTROL BOARD

                 NOTICE OF PROPOSED AMENDMENTS

      reference in Section 218.112, e.g., a coating line,  a
      printing line, a process unit, a wastewater system,  or
      other equipment, or is otherwise any part or activity at a
      source.)

  b)   For coating lines-?-!,

      IX  %T_he daily-weighted average VOtt content shall not
          exceed 0.42 kg VOM/1  (3.5 Ibs VOM/gal) of coating as
          applied  (minus water  and any compounds which are
          specifically exempted from the definition of VOM)
          during any day.  owners and operators complying with
          this Ccction limitation are not required to comply
          with Section 218.301  of this Part,  or

      2)  For leather coatincr lines at a source where the
          criteria  of Section 218.920fa), are  not met;

          A)  The  VOM contained in  staincoatings,  other than
              stain coatings applied  to ^specialty leather, as
              applied at the source in anv  consecutive 12 month
              period shall  not  exceed 10 tons;  and

          B)  The  total  VOM content of all  coatings,  including
               stains,  as applied to a category of specialty
               leather,  shall not exceed  38  Ibs per 1000 square
               feet of such  specialty leather produced,
              determined on a monthly basis,  or

  c)  An  alternative  control plan which  has  been  approved by  the
      Agency  and approved by the USEPA as a  SIP revision.

(Source:  Amended at 	 111. Reg.  	,  effective  	.)
April  15,  1993            DRAFT-25TPY-49
                               C-84

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Monterey Bay Unified Air Pollution Control District
                     C-85

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C-86

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             Rule 430: Leather Processing Operations      80Silver CJoud Court
                                                         Monterey, CA 93940
PART 1  GENERAL
1 . 1   Purpose

  The purpose of this rule is to reduce the emissions of volatile
  organic compounds (VOCs) into the atmosphere during the use,
  application, or drying of VOC-containing leather treatment
  materials and solvents used in leather ^process ing facilities,
  operations, and processes.


1.2   Applicability


  The provisions of this rule shall apply to all  facilities,
  operations, and processes where leather is treated with
  volatile organic compounds or with materials that contain VOCs.
  As of the date of adoption of this rule, Salz Leathers of Santa
  Cruz is the sole affected source
                                                  ~» &I •
1.3   Exemptions

  There are no exemptions to the rule.


1.4   Effective Dates

  1.4.1   The requirements of this rule shall be effective on the
    date of adoption.

  1.4.2   Effective dates for emission reduction measures are
    given in sections 3.1 and 3.2 of this rule.


1.5   References

  1.5.1  The requirements of this rule implement provisions of
    the District Air Quality Management Plan of 1991.

  1.5.2  The requirements of Sections 3.1 and 3.2 of this rule
    are derived from Section 40918 (b) of the California Health
    and Safety Code and Section 182 (b)(2) of the federal Clean
    Air Act which require the use of the best available retrofit
    control technology and reasonably available control
    technology for the attainment of state and federal ambient
    air quality standards for ozone.
                              C-87

041593                                          Draft Rule 430;

-------
Monterey Bay Unified Air
Pollution Control District          CONCFPT   DRAFT   ONT.Y
24580 Silver Cloud Court          CONCEPT   DRAFT   ONLY

 Monterey, CA 93340               REGULATION   iv
                              PROHIBITIONS

   PART 2   DEFINITIONS
   2.1   Combined efficiency

     The capture efficiency multiplied by the control efficiency of
     capture and control equipment, expressed as overall weight
     percent, to be used for compliance witn section 3.1 of  this
     rule.
   2.2   Exempt organic compounds

     Group III compounds as defined below.


   2.3   Group I compounds

     any organic compound which has been  identified as a  toxic air
     contaminant including, but not limited to, methylene chloride.


   2.4   Group II compounds

     any stratospheric ozone depleting compound including,  but not
     limited to: 1,l,l-trichloroethane, trichlorofluoromethane (CFO
     11), dichlorodifluoromethane  (CFC-12), chlorodifluoromethane
     (HCFC-22), l,l,l-trichloro-2,2,2-trifluoroethane  (CFC-113),  l-
     chloro-l,l-difluoro-2-chloro-2,2-difluoroethane  (CFC-114),
     chloropentafluoroethane  (CFC-115), 2,2-dichloro-l,l,l-
     trifluoroethane (HCFC-123), 1,1-dichloro-l-fluoroethane (HCFC-
     141b), l-chloro-l,l-difluoroethane (HCFC-142b), 2-chloro-
     1,1,1,2-tetrafluoroethane  (HCFC-124).


   2.5   Group III compounds

     any of the following: trifluoromethane  (HFC-23),  1,1,1,2-
     tetrafluoroethane  (HFO134a), pentafluoroethane  (HFC-125),
     1,1,2,2-tetrafluoroethane  (HFC-134), 1,1,1-trifluoroethane
     (HFC-143a), 1,1-difluoroethane  (HFC-152a), and the  following
     classes of perfluorocarbons:  (a)  cyclic,  branched,  or linear,
     completely fluorinated alkanes?  (b)  cyclic, branched,  or
     linear, completely fluorinated ethers with no unsaturations;
     (c) cyclic, branched, or linear,  completely fluorinated
     tertiary amines with  no  unsaturations; and  (d)  sulfur-
     containing perfluorocarbons with  no  unsaturations and with
     sulfur bonds only to  carbon and fluorine.

                                  C-88

    041593                                          Draft Rule 430:

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                                                 Monterey Bay Unified Air
                       CONCEPT  DRAFT  ONLY      Pollution Control District
                          REGULATION  IV
                           PROHIBITIONS            Monterey, CA 93940

2 . 6   High-volume low-pressure spray

  to spray a coating by means of a  spray gun that  operates
  between 0.1 and 10.0 psig air pressure.


2.7   Leather treatment

  any liquid material applied onto  or  impregnated  into  leather to
  beautify, protect, or give a finished appearance or quality to,
  the leather, including, but not limited to;  lacquers r oils-,
  resins, stains, and top coats.


2 . 8   Leather treatment process

  any portion of an operation where leather treatment materials
  are applied and/or cured, including  material application and
  the heating, drying or  storage of treated leather.


2.9   Ozone depleting compounds

  Group II compounds, as  defined above.


2.10   Volatile organic compound  (VOC)

  any compound containing at least  one atom of carbon,  except:
  methane, carbon monoxide, carbon  dioxide, carbonic acid,
  metallic carbides or carbonates,  ammonium carbonate,  and Group
  I, Group II, and Group  III compounds.  When  measured  or
  calculated, the VOC concentration of leather treatment
  materials shall be expressed as the  weight of VOCs per volume
  of treatment material.  The volume of treatment  material shall
  not include water or exempt solvents as defined. The oil
  portion of oil treatment mixtures shall be considered
  nonvolatile for the purpose of this  definition.
                               C-89

041593                                          Draft Rule 430:

-------
                       CONCEPT  DRAFT   ONLY

                          REGULATION   IV
                           PROHIBITIONS
   4nContro1 District
  24580 Silver Cloud Court
   Monterey, CA 93940
PART 3  REQUIREMENTS
3.1   Sources permitted to emit more than 250 tons per year

  By no later than November 1, 1994, any leather processing
  operation with permitted VOC emissions of five or more tons per
  day or 250 or more tons per year shall,control emissions by the
  use of control technology which achieves a combined efficiency
  of 85 percent.

3.2   Sources permitted to emit less than 250 tons per year

  By no later than November 1, 1993, any leather processing
  operation with permitted VOC emissions of less than five tons
  per day or less than 250 tons per year shall comply with the
  following requirements:

  3.2.1   Leather treatment materials shall be reformulated  so
    that the VOC content of each material does not exceed the
    following limits in pounds per gallon of material as applied:
Material
Stain
Oil
Resin
Top coat
11/1/93
7.5
7.5
1.3
4.0
1/1/95

nJOl
o^!

1/1/96
rff
^


  3.2.2    By no  later  than November 1,  1993, the  following
    methods shall be utilized to minimize VOC  emissions:  roll
    coating for  oil application and photoelectric spray
    controlled spray guns for the application  of  other VOC-
    containing treatments.

  3.2.3    On or  after  November 1, 1995,  a person  or facility may
    not  apply leather  treatment materials to leather unless the
    material is  applied with properly  operating equipment,
    according to proper operating procedures,  and by the use of
    one  of the following methods: roll coating, flow coating, dip
    coating, or  photoelectric spray controlled high-volume low-
    pressure spray.

 3.3.   Restricted reformulations

  A leather treatment  material shall not be reformulated with
  Group  I compounds  (toxic air contaminants) or Group II
                              C-90
 041593
Draft Rule 430:

-------
Monterey Bay Unified Air
Pollution Control District          CONCEPT  DRAFT  ONLY             ^ IV Ct
24580 Silver Cloud Court                                         -~p f^f 1
 Monterey, CA 93940              REGULATION  iv              i  **^«.
                             PROHIBITIONS

    compounds  (stratospheric ozone depleting  compounds)  for the
    purpose of compliance with this rule.

  3.4   Restricted clean-up solvents

    Group I or Group II compounds shall  not be  used as clean-up
    solvents for leather treatment processes  or equipment.

  3.5   Storage in closed containers

    All materials which contain VOCs,  including, treatments,
    solvents, and clean-up wastes, shall be kept in containers that
    are closed except when filling or  emptying.

  3.6   Incidental emissions

    All materials which contain VOCs,  including media into
    which VOCs have been absorbed or adsorbed by emissions control
    devices and all forms of VOCs to be  recovered,  recycled or
    disposed,  shall be handled, stored and transported so that
    emissions  of VOCs to the atmosphere, soil,  groundwater, or any
    other environmental media  are minimized.
  PART 4  ADMINISTRATIVE REQUIREMENTS


  4.1   Daily Material  Usage Record

     A Record of  daily VOC usage shall  be created and maintained for
     each  day that  leather is processed.

     4.1.1  The Record shall be in a format which is approved by the
      District.

     4.1.2  The Record shall be signed  at the end of each shift or
      at  the end of each day by the responsible operator or
      facility manager.

     4.1.3  The Record shall be kept on a 24 hour daily basis and
      made  available upon request for  inspection by the District
      for two years from the date of each entry.

     4.1.4  The Record shall provide the following data for each
      day:

      4.1.4.1  the amount of VOCs mixed, dispensed, and emitted
        from each  designated stock or  brand name mixture,
                                 C-91

  041593                                          Draft Rule 430:  6

-------
                                                   Monterey Bay Unified Air
                       CONCEPT  DRAFT  ONLY        Pollution Control District
                          REGULATION  TV           24580 Silver Ooud Court
                          Kt.GuijA.LJ.uH  iv            Monterev PA Q3a/tn
                           PROHIBITIONS             wonierey, u\ 93940
    4.1.4.2  the amount of VOCs used and  emitted as clean-up or
      testing materials, and

    4.1.4.3  a summation of the amount  of VOCs  emitted from all
      operations in the facility.

4.2   Quarterly summary

  A summary of daily emission amounts,  tabulated monthly,  shall
  be submitted _quarterly.

4.3   Book of formulas

  A book of designated leather treatment  material formulas shall
  be maintained at the facility and provided to the District upon
  request.  The book shall contain such treatment designations
  and technical data sheets for stock and brand name chemicals
  and mixtures used to formulate  each designated treatment so
  that the estimates of daily emissions may be  verified.
PART 5    TEST METHODS
5.1   The VOC content of treatments  and solvents shall be
  determined using Method  24  of  the  U.S.  Environmental Protection
  Agency  (40 CFR 60, Appendix A).

5.2   The quantity of exempt  organic compounds in treatment
  formulas and solvents shall be determined using California Air
  Resources Board Test Method 432.

5.3   The control efficiency  of  air  pollution control equipment
  shall be determined using EPA  Methods 2,  2A, 2C, or 2D for
  measuring flow rates and EPA Methods 25,  25A, or 25B for
  measuring the total gaseous organic concentrations at the inlet
  and outlet of the  control device.

5.4   The capture efficiency  of  control equipment shall be
  determined according to  the EPA protocol of Title 40, Code of
  Federal Regulations, Part 52.741.
                             * * * * *
                               C-92

 041593                                          Draft Rule  430;

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            APPENDIX D
LEATHER TANNING AND FINISHING FACILITIES
                 D-i

-------
D.1  Introduction to Appendix D

      This appendix lists all of the facilities known to be tanning or finishing leather.
Various sources were used to compile this list. These sources included emissions data
bases, State and local  agency inventories,  industry directories,  conversations with
professionals in the leather industry, and published reports.  Due to constant changes
within the industry, there may be some inadvertent omissions or inclusions of plants in
the list.
                                      D-ii

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    APPENDIX D - LEATHER TANNING AND FINISHING FACILITIES
CALIFORNIA

Salz Leathers, Inc.
1040 River Street, Box 1840
Santa Cruz, CA 95061
(408) 423-4470

COLORADO

Western Tanning Inc.
1454 Highway 50
Delta, CO  81416
(303) 874-7631

FLORIDA

Acme Sponge & Chamois Co, Inc.
855 E. Pine Street, Box 338
Tarpon Springs, FL
(813) 937-3222

IOWA

Oshkosh Tanning Co., Inc.
Industrial Park Road
Boone, IA  50036
(515) 432-8500

ILLINOIS

Gutmann Leather Co.
1511 W. Webster Ave.,
Chicago, IL 60614
(312) 348-5300

Horween Leather Company
2015 Elston Avenue
Chicago, IL 60614
(312) 772-2026
                                  D-1

-------
Much Leather Company
1525 West Homer Street
Chicago, IL

MASSACHUSETTS

Carr Leather Company
500 Boston Street
P.O. Box 270
Lynn, MA  01903
(617) 599-2511

Bamet Corp.
58 Pulask Rd.
Peabody, MA 01960

Bond Leather Co., Inc.
Summit Industrial Park
Bldg. 38, Summit Street
Peabody, MA 01960
(508) 531-3227

Rex Finishing, Inc.
R 119 Foster St.
Peabody, MA 01960
(508) 531-2076

Richard Leather Co., Inc.
9 Webb Street,  Box 868
Salem, MA  01971
(508) 745-5440

Salem Suede, Inc.
72 Flint Street
Salem, MA  01970

MAINE

Irving Tanning Co.
Main Street
Hartland, ME 04943
(207) 938-4491
                                   D-2

-------
Camden Tanning Corp.
116 Washington St.
P.O. Box C
Camden, ME  04843
(207) 236-3394

Prime Tanning Co., Inc.
Sullivan Street
P.O. Box 713
Berwick, ME 03901
(207)698-1100

Wilton Tanning Company
Route 2 & 4
Wilton, ME

MARYLAND

W.D. Byron &  Sons, Inc.
312 N. Conocoheague St.
Williamsport MD 21795
(301) 233-7500

MICHIGAN

Eagle Ottawa Leather Company
200 N. Beechtree Street
Grand Haven,  Ml 49417
(616) 842-4000

Whitehall Leather Company
900 South lake Street
Whitehall, Ml  49461
(616) 893-1315

MINNESOTA

S.B. Foot Tanning Co.
Bench Street
Red Wing, MN 55066
(612) 388-4731
                                   D-3

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MISSOURI

Blueside Companies
205 Florence Rd
St. Joseph, MO 64502
(816) 279-7468

Hermann Oak Leather Co.
4050 North First Street
St. Louis, MO 63147
(314)421-1173

NORTH CAROLINA

Lackawanna Leather Company
P.O. Box 939
Conover, NC 28613
(704) 322-2015

NEBRASKA

Lackawanna Leather Company
2420 Z Street
Omaha, NE  68107
(402) 734-2360

NEW JERSEY

Schwarz Leather Co.
400 Gotham Pkwy
Carlstadt, NJ 07072

UDO Finishing Company
49 Vesey Street
Newark, NJ  07105

Seton Company
849 Broadway
Newark, NJ  07104
(201) 485-4800
                                  D-4

-------
American Leather Manufacturing Co.
219 Elizabeth Ave.
Rahway, NJ 07065
(201) 382-1700

NEW YORK

Colonial Tanning Corp.
8-10 Wilson Street
Box 1068
Gloversville, NY  12078
(518) 725-7190

Fashion Tanning Co., Inc.
6 Van Rd,  P.O. Box 1220
Gloversville, NY  12078
(518) 733-7961

Leather Agent, Inc. Tannery
177W. Fulton  Street
Gloversville, NY  12078
(518) 735-3777

Androme Leather Corp.
21 Foster Street
Gloversville, NY  12078

Fromglo Plant
91 Second  Street
Gloversville, NY  12078
               »

Independent Leather Mfg. Corp.
315-329 S.  Main Street
Gloversville, NY  12078
(518)  725-9416

JBF Industries  Inc.
41 W. 11th  Ave
Gloversville, NY 12078
(518)  725-7414
                                     D-5

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Pan American Tanning Corp.
318 W. Fulton Street
Gloversville, NY  12078
(518) 773-7565

Twin City Leather Co., Inc.
3-15 River Street
Gloversville, NY  12078
(518) 725-8113

Wood & Hide Leather Co., Inc.
68 Wood St., P.O. Box 786
Gloversville, NY  12078
(518) 725-7105

Classic Leather Sales Corp.
126 West Fulton  St.
Johnstown, NY  12095
(518) 762-9294

Karg Brothers, Inc.
6-20 East Fulton  St.
Johnstown, NY  12095
(518) 762-3148

Adirondac Leather Inc.
Fisher Avenue
Johnstown, NY  12095

Allied Split Corp.
422 N. Perry Street
Johnstown, NY  12095

Arrow Leather Finishing Co.
21-23 West St.
Johnstown, NY  12095

Gordon Finishing Co., Inc.
19 West State St.
Johnstown, NY  12095

Pearl  Leather Finishers Inc.
Industrial Park
Johnstown, NY  12095
                                     D-6

-------
Simco Leather Corp.
99 Pleasant Ave.
Johnstown, NY  12095
(518) 762-7100

Carville National Leather Corp.
Knox Avenue, P.O. Box 40
Johnstown, NY  12095
(518) 762-1634

H&J Leather Finishers, Inc.
312 N. Perry Street
Johnstown, NY  12095

K-Lynn Split Inc.
40-52 W. State St.
Johnstown, NY  12095

Peerless Tanning Co., Inc.
24 Briggs Street
Johnstown, NY  12095

Townsend Leather Co.
45-49 Townsend Ave.
Johnstown, NY  12095

OHIO

Conneaut Leather Inc.
West Adams St.
Conneaut, OH 44030-1160
(216) 593-5205

PENNSYLVANIA

Howes Leather Co., Inc.
Cooper Road
Curwensville, PA 16833

Garden State Tanning
Locust & Franklin Streets
Fleetwood, PA 19522
                                    D-7

-------
Gunnison Brothers, Inc.
9041 Tanning Road
Girard, PA  16417-0327
(814) 774-5616

Leather Tech, Inc.
964 Postal Rd.
Allentown, PA 18103

Mercersburg Tanning
209 Oregon St.
Mercersburg, PA 17236
(212) 686-7666

Westfield Tanning Company
360 Church Street
Westfield, PA 16950
(814) 367-5951

Seton Company
Morton Road
Saxton, PA 16678
(814) 635-2937

TENNESSEE

Volunteer Leather Company
Kefauver Drive
Milan, TN  38358
(615) 367-8417

Lannom Tannery
Box 550
Tullahoma, TN 37388
(615) 455-2288

Tennessee Tanning Co.
915 N. Atlantic St., Box 967
Tullahoma, TN 37388
(615) 455-3441

Coey Tanning Co., Inc.
441 Bugscuffle Rd.
Wartrace, TN 33713
                                    D-8

-------
 TEXAS

 S.B. Foot Tanning Co.
 Schroetner Industrial Park
 Cactus, TX 79013
 (612) 388-4731

 UTAH

 Fox Valley Tanning, Inc.
 633 West Center Street
 North Salt Lake, UT  84054
 (801) 298-3894

 WISCONSIN

 Berlin Tanning & Mfg, Co
 235-T S. Wisconsin St.
 Berlin, Wl 54923
 (414) 361-1818

 Cudahy Tanning Company
 5043 S. Packard Ave
"Cudahy, Wl 53110
 (414) 483-8100

 Blackhawk  Leather Ltd.
 1000 West  Bruce St.
 Milwaukee, Wl 53204
 (414) 671-2690

 Gebhardt-Vogel Tanning Co.
 2615 W. Greves Street
 Milwaukee, Wl 53233
 (414) 383-4818

 Pfister & Vogel Tanning Co.
 1513 N. Water St.
 Milwaukee,  Wl 53201
 (414) 273-7160

 Paul Flagg
 1031 Maryland Avenue
 Sheboygan, Wl  53082
                                    D-9

-------
Thiele Tanning Co.
123 N. 27th Street
Milwaukee, Wl 53208
(414) 933-1526

Amity Leather Products Co.
742 Indiana Ave
West Bend, Wl 53095
(414) 338-6601

WEST VIRGINIA

Howes Leather Co., Inc.
Rt. 250
Frank, WV 24920
(304) 456-4898
                                   D-10

-------
  APPENDIX E



SELECTED CONTACTS
       E-i

-------
E.1  Introduction to Appendix E

      This appendix includes a list of selected contacts made during the development
of the report. This list is provided to assist State and local agency personnel in identifying
key professionals who may be of assistance in developing rules  for leather tanning and
finishing facilities.
                                      E-ii

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                 APPENDIX E. SELECTED CONTACTS
Environmental Protection Agency

Anne Arnold
EPA Region I
JFK Federal Building
Boston, MA 02203-2211
(617)-565-3166

Wendy Columbo
EPA Region IX
75 Hawthorne Street
San Francisco, CA  94105
(415)-744-1219

Iliam Rosario
Industrial Studies Branch
Office of Air Quality  Planning and Standards
MD-13
Research Triangle Park, NC 27711
(919)-541-5308

Steve Rosenthal
EPA Region V
230 South  Dearborn Street
Chicago, IL 60604
(312)-886-6052

Paul Truchan
EPA Region II
26 Federal Plaza
New York,  NY 10278
(212J-264-2517
State and Local Agencies

Proveen Amar
NESCAUM
85 Merrimac Street
Boston, MA 02114
(617)-367-8540

                                   E-1

-------
Steve Barlow
State of New York Region V
Hudson Street Extension
PO Box 220
Warrensburg, NY 12885

Gary Beckstead
State of Illinois EPA
2200 Churchill Road
Springfield, IL 62794-9276
(217)-524-4343

Dan Belik
Bay Area Air Quality Management District
939 Ellis Street
San Francisco, CA 94109
(415)-771-6000

Jim Coyle
State of New York
Environmental Conservation
50 Wolf Road, Room  138
Albany 12233
(518)-457-2044

Art Diem
State of New Jersey DEPA
CN027
Trenton, NJ 08625-0027
(609)-984-0490

Rich Driscoll
State of Massachusetts
Division of Air Quality
1  Winter Street, 7th Floor
Boston, MA 02108
(617)-292-5605

Steve Dunn
State of Wisconsin DNR
101 South Webster Street
Madison, Wl  53707-7921
(608)-267-0566
                                     E-2

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Eric Flowers
State of Tennessee
Division of Air Pollution Control
701  Broadway, Customs House
Nashville, TN 37423-1531
(615)-532-0554

Jill Koebbe
State of Michigan
State Office Building, Suite 6D
350  Ottawa N.W.
Grand Rapids, Ml  49503
(616)-456-5071

John Krueger
State of Pensylvania
One Ararat Blvd.
Harrisburg, PA  17110
(717)-657-4587

Guy Neenan
Monterey Bay Air Quality Management District
24580 Silver Cloud Court
Monterey, CA 93940
(408)-647-9411

Cal Peters
State of Michigan
State Office Building, Suite 6D
350 Ottawa N.W.
Grand Rapids, Ml 49503
(616)-456-5071

Ron  Severance
State of Maine Air Quality
State House Station, #17
Augusta, ME  04333
(207)-289-2437
                                     E-3

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George Volpentesta
State of Wisconsin
DNR SE District {Milwaukee area)
PO Box 12436
Milwaukee, Wl 53212
(414)-263-8571
Leather Tanning and Finishing Industry

Wilhelm Bley
Lackawanna Leather Company
PO Box 939
Conover, NC  28613
(704)-322-2015

Peter Dykes
Mercersburg Tanning
209 Oregon St.
Mercersburg,  PA 17236
(717)-328-3111

Paul Erickson
Environmental Manager
U. S. Leather  Holdings
1110 North Old World Street, Suite 400
Milwaukee, Wl 53202
(414)-291-3042

Buz Haltenhoff
Environmental Manager
Eagle Ottawa  Leather Company
200 N.  Beechtree St.
Grand Haven, Ml 49417
(616)-842-4000

Charles S. Myers
Leather Industry of America, Inc.
1000 Thomas Jefferson St., NW
Suite 515
Washington, DC 20007
(202)-342-8086
                                    E-4

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 Frank Rutland
 Tanner's Council Laboratory
 ML 14
 Cincinnati, OH 45221
 (513)-556-1200

 Dan Schedlar
 Pfister & Vogel Leather Company
 1531 North Water Street
 PO Box 745
 Milwaukee, Wl 53201
 (414)-273-7160

 Robert White
 Executive Vice President
 Eagle Ottawa Leather Company
 200 N. Beechtree St.
 Grand Haven, Ml 49417
 (616)-842-4000

 John Wittenborn
 Collier, Shannon, Rill & Scott
 3050 K Street, NW
 Suite 400
 Washington, DC  20007
 (202)-342-8400

 Carl Zipfel
 Corporate Environmental Manager
 Seton Company
 2500 Monroe Blvd.
 Norristown, PA 19403
 (215)-666-9600
Equipment Suppliers

Mark Boynton
Hampton Machine Company
63 Epping Street
Raymond, NH 03077
(603)-895-4724
                                    E-5

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Wayne Collard
Salem Industries
245 South Mill Street
South Lyon, Ml  48178
(313)-437-4188

Jerry  Hunt
Sinks Manufacturing Company
9201 W. Belmont Avenue
Franklin Park, IL 60131-2887
(708)-671-3000

Jeff Machusek
REECO (Research-Cottrell)
PO Box 1500
Somerville,  NJ 08876
(201)-538-8585

Greg Olsen
Graco
PO Box 1441
Minneapolis, MN 55440-1441
(800)-543-0339
Leather Finishing Chemicals and Supplies

Steve Ossaf
Stahl USA
26 Howley Street
Peabody, MA 01966-3599
(508)-531-0371

Lori Schneider
Prime Leather Finishes
205 S. Second Street
Milwaukee,  Wl 53204
(414)-276-1668

Robert Welch
Prime Leather Finishes
205 S. Second Street
Milwaukee,  Wl 53204
(414)-276-1668
                                    E-6

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                                  TECHNICAL REPORT DATA
                           ffteast read Instructions OH tkt revent be fort completing)
 . H6POBT NO.
 EPA-453/R-93-025
                                                          3. RECIPIENT'S ACCESSION NO.
4, TITLE AND SUBTITL*
 Air Emissions and Control Technology for
 Leather Tanning and Finishing  Operations
                        5. REPORT DATE
                         June  1993
                        8. PERFORMING ORGANIZATION CODE
 . AUTHORtS*                    ~
 Barry F. Mitsch,  Reeae H. Howie,  Samuel C. McClintok
                        8. PERFORMING ORGANIZATION REPORT NO.
                                                           10. PROGRAM ELEMENT NO.
 . PERFORMING ORGANIZATION NAME AND AOORESS
 Alpha-Gamma  Technologies, Inc.
 900 Ridgefield Drive, Suite 350
 Raleigh,  NC   27609
                        11. CONTRACT/GRANT NO.
                         68-D1-0117,  WA #79
12. SPONSORING AGENCY NAME AND AOORESS
 U.S. Environmental Protection Agency (MD-13)
 Emission Standards Division
 Office of Air  Quality Planning and  Standards
 Research Triangle Park. NC  27711
                                                           13. TYPE Of REPORT AND PERIOD COVERED
                        14. SPONSORING AGENCY CODE
19. SUPPLEMENTARY NOTES
   ESD Work Assignment Manager:
Iliam D. Rosario,  MD-13, 919-541-5308
16. ABSTRACT  	—~
   This document  was  developed in response to an interest  through the years  from
   the States  and industries.  The  information has been obtained from available
   literature,  information provided through Federal, State,  and local air pollxition
   control agencies,  and information obtained from the leather tanning and finishing
   industry.   This document provides information for use in  assessing appropriate
   measures to control volatile organic  compound (VOC) emissions from leather
   tanning and finishing facilities.   It also provides a general description of
   the industry;  describes the key  processes employed in manufacturing leather;
   characterizes  the  emissions of VOC's  and HAPs from the  industry; describes
   applicable  emission reduction technologies; an.d finally,  discusses current
   State and local air pollution regulations affecting the industry.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS;OPEN ENDED TERMS
                                                                        c.  COSATi Field/Group
   Air Pollution
   Leather Tanning
   Leather Finishing
   VOC Emission Controls
   VOC Emission Reduction
   Regulations
18. DISTRIBUTION STATEMENT

   Release Unlimited
           19. SECURITY CLASS I Tins Report I
             " Unclassified
NO. OF
271
                                              20. SECURITY CLASS (Tltiipagtl
                                                  Unclassified
                                      22. PRICE
 EPA fftm 2220.1 (R«». 4-77)   P««VIOUS EDITION is ossouere

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