United States Office of Air Quality December 1979 Environmental Protection Planning and Standards uecemoer Agency Research Triangle Park NC 27711 &EFA Summary of Group II Control Technique Guideline Documents for Control of Volatile Organic Emissions from Existing Stationary Sources ------- EPA-450/2-80-001 Summary of Group II Control Technique Guideline Documents for Control of Volatile Organic Emissions from Existing Stationary Sources by Stephen V. Capone and Malcolm Petroccia GCA Corporation GCA/Technology Division Burlington Road Bedford, MA 01730 Contract No. 68-02-2607 Work Assignment No. 39 EPA Project Officer: Tom Williams Prepared for U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Air, Noise, and Radiation Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 December 1979 ------- This report is issued by the Environmental Protection Agency to report technical data of interest to a limited number of readers. Copies are available free of charge to Federal employees, current contractors, general public, grantees, and nonprofit organizations - as supplies last - from the Library Services Office (MD-35) , U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711; or for a nominal fee, from the National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia 22161. This report was furnished to the Environmental Protection Agency by GCA Corporation, Technology Division, Burlington Road, Bedford, Massachusetts 01730 in fulfillment of Contract No. 68-02-2607, Work Assignment No. 39. This document has been reviewed by the Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, and approved for publication. Approval does not signify that the contents necessarily reflect the views and policies of the Environmental Protection Agency, nor does mention of trade names or commercial products constitute endorsement or recommendation for use. Publication No. EPA-450/2-80-001 ------- ABSTRACT r Huideline (CTC) documents have been prepared by the January 1978 (Croup I) was published in December 1978. summarizes the CTG documents issued facility. iii ------- CONTENTS ill Abstract 1 1. Introduction ... 1 Background 3 Purpose of Document • • • * s 2. Surface Coating of Miscellaneous Metal Parts and Products .... 5 3 Surface Coating of Flat Wood Paneling 4! Manufacture of Synthesized Pharmaceutical Products > 5. Manufacture of Pneumatic Rubber Tires • ^ 6. Manufacture of Vegetable Oil 7. Graphic Arts - Rotogravure and Flexography 8 Perchloroethylene Dry Cleaning Systems 2Q 9. Leaks from Petroleum Refinery Equipment . . . . • • • • 10. Petroleum Liquid Storage in External Floating Roof Tanks .... ^ 11. Leaks from Gasoline Tank Trucks and Vapor Collection Systems. . . 26 28 References v ------- SECTION 1 INTRODUCTION BACKGROUND have been published.* Eleven CTGs covering 15 VOC source categories were published prior to January 1978. These first eleven CTGs were: . Surface Coating of Cans, Coils Paper Fabric, Automobiles and Light-Duty Trucks (EPA-450/2-77-008). ' . Surface Coating of Metal Furniture (EPA-450/2-77-032). , Surface Coating for Insulation of Magnetic Wire (EPA-450/2-77-033). . Surface Coating of Large Appliances (EPA-450/2-77-034). • Storage of Petroleum Liquids in Fixed Roof Tanks (EPA-450/2-77-036). • Bulk Gasoline Plants (EPA-450/2-77-035). . Solvent Metal Cleaning (EPA-450/2-77-022). • Use of Cutback Asphalt (EPA-450/2-77-037). • Refinery Vacuum Producing Systems, Wastewater Separators and Process Unit Turnarounds (EPA-450/2-77-025). T^^nT^d not have to be adopted for these stationary sources if a state can demonstrate attainment of the photochemical oxxdant standard by photochemical dispersion modeling. ------- • Hydrocarbons from Tank Truck Gasoline Loading Terminals (EPA-450/2-77-026). • Design Criteria for Stage I Vapor Control Systems, Gasoline Service Stations, U.S. EPA, OAOPS, November 1975. For each source category, a CTG document describes the source, identifies the VOC emission points, discusses the applicable control methods, analyzes the costs required to implement the control methods, and recommends regulations for limiting VOC emissions from the source. A document entitled "Regulatory Guidance for Control of Volatile Organic Compound Emissions from 15 Categories of Stationary Sources," EPA-905/2-78-001, was published in April 1978. This document provided guidance to the states in preparing RACT regulations for the 15 source categories listed above. In December 1978, a document entitled "Summary of Group I Control Tech- nique Guideline Documents for Control of Volatile Organic Emissions from Existing Stationary Sources," EPA-450/3-78-120, was published. This document provided an overview of the affected source facilities, the magnitude of the VOC emissions emitted from the facilities, and the recommended VOC emission limits. EPA published an additional 10 CTG documents (Group II) in 1978. The 10 source categories covered were: • Leaks from Petroleum Refinery Equipment (EPA-450/2-78-036). • Surface Coating of Miscellaneous Metal Parts and Products (EPA-450/2-78-015). • Manufacture of Vegetable Oil (EPA-450/2-78-035). • Surface Coating of Flat Wood Paneling (EPA-450/2-78-032). • Manufacture of Synthesized Pharmaceutical Products (EPA-450/2-78-029). • Manufacture of Pneumatic Rubber Tires (EPA-450/2-78-030). • Graphic Arts - Rotogravure and Flexography (EPA-450/2-78-033). • Petroleum Liquid Storage in External Floating Roof Tanks (EPA-450/2-78-047). • Perchloroethylene Dry Cleaning Systems (EPA-450/2-78-050). • Leaks from Gasoline Tank Trucks and Vapor Collection Systems (EPA-450/2-78-051). ------- regulatory guidance document was developed from these Group II CTGs. £,rt\.— tJ"/ f. ij vy^-r, ~-- . in preparing RACT regulations for the 10 industrial Hjouau^-w-'v---1*""*-- — —1» *^ categories covered by the Group II CTG documents. PURPOSE OF DOCUMENT The purpose of this report is to summarize the Group II CTG documents. The summaries are intended to present an overview of ^Y^^^L.! tJe~ ities The magnitude of the VOC emissions emitted from the facilities, and the ShrJ6,:^^ ^^^^ r^j^ Er^r^;^^^^^ areas where difficulties exist in converting CTG infor- • •1 m__*_-_ -> C -I«J..«rt+--V--»T f* ^\TTVfn£in t"G f^n { , I (-T from other sources. Cost estimates in the CTG documents were normally developed by use of model facilities to represent typical,operations. Applicable alternative controls were costed for these model facilities. As such, these costs, even with tJe broad ranges provided for several of the source categories, may not encompass the actual cost incurred at any specific facility. The CTG document summaries which follow include a brief discussion of the VOC source category and emission control techniques, as well as a tabular presentation of the following information for each source category: Affected Facilities - Types of operations, facilities, or equipment covered by the CTG Number of Affected Facilities - A national count of the operations, facilities, or equipment specified VOC Emissions Nationwide - Estimate of annual emissions from the source category VOC Emission Range per Facility - Estimate of annual emissions from a typical facility in the source category 100 Ton/Yr Source Size - The estimated size of a facility which would emit 100 ton/yr of VOC if uncontrolled CTG Emission Limit - VOC emission limits as recommended in the CTG document ------- VOC Reduction Per Facility - Percent emission reduction which can be effected by use of CTG recommended controls Costs — Values in parentheses represent net savings Capital — purchase and installation costs Annualized — includes operating cost, annualized capital charges plus tax and interest, less value of recovered VOC. Only primary heat recovery or fuel value credit considered Cost Effectiveness — Cost of control measure per ton of VOC controlled. ------- SECTION 2 SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS1 Tills CTG document provides guidance on VOC emission control for job shop and original equipment manufacturing industries which apply coatings on metal substrates, except those industries which were covered by previous CTG docu- ments T^ recolended emission limits in this CTG are also intended to apply to S; coating of hardware for wood and metal cabinets and the coating of metal pails and drums. There are many dissimilarities between the plants and in- dustries represented by this category. Slaving is the more common method of applying coatings for single-coat operations, but flow coating and dipping are also used For two-coat opera- tions the primers are more likely to be applied either by flow or dip coating while the topcoats are almost always sprayed. The coated parts are often conveyed through a flashoff tunnel to evapo- rate solvent and allow the coating to flow out properly. After coating and flashoff, the parts are baked in single or multiple pass bakxng ovens. Some products are air or forced air dried. The recommended emission limits are based on the use of coatings low in organic solvents. The CTG document recommends four different emission limi- tations based on the type of coating, the number of colors or color changes and the method of drying. The applicable control technology to meet the emis- sion limitations includes process modifications (such as conversion to water- borne, electrodeposition, higher solids or powder coatings) and exhaust gas treatment (such as incineration and carbon adsorption). Due to the large number of different coating processes and the varJous methods of controlling VOC emissions from each of these processes, there- are significant variations in the cost-effectiveness of control options for this CTG category. The CTG document provides cost estimates for small, medium and large model plants for seven different types of coating operations and between four and six control options depending on the type of coating operation. -------An error occurred while trying to OCR this image. ------- SECTION 3 SURFACE COATING OF FLAT WOOD PANELING2 Factory finished flat wood products includes printed interior panels made of hardwood plywood and thin particle board (1/4 inch or less); natural finish hardwood plywood panels; and hardboard paneling with Class II finishes. ANSI Class II finishes meet less stringent requirements than Class I coatings; spe- cifically there are no heat, humidity or steam requirements. Different forms of roll coating are the favored procedures for applying coatings to flat woods. However, curtain coating, spray coating, and brush coating techniques are also used. The basic series of coatings applied to printed interior panels consist of filler, basecoat, inks and topcoat. Natural hardwood plywood panels usually have the real wood surface modified in color and appearance by a series of stains, toners, fillers, sealers, glazes, and topcoats. For purposes of recommending levels of control, flat wood interior panel products have been divided into three subcategories: 1. Printed interior wall panels made of hardwood plywood and thin particle board (1/4 inch or less); 2. Natural finish hardwood plywood; and 3. Class II finishes for hardwood paneling. Class I hardwood panels, particle board used in furniture, insulation board, and softwood plywood are not considered in this CTG document. The emissions from inks used to print simulated grain or decorative patterns on printed interior panels are covered in this CTG category, and should not be considered a Graphic Arts activity. Recommended VOC limitations are given in kg/100 m2 (lb/1000 ft2) of sur- face covered to allow panel coaters maximum flexibility in adjusting VOC con- tent of the different coatings so as to meet the emission limitation while maintaining product quality. In each case, the aggregate of the VOC emissions from al] coating applied shall be used for comparison to the recommended emis- sion limitations. In general, the emission limitations are based on the use of a combination of water-borne coatings and solvent-borne coatings within a pro- duct line. Other applicable methods of VOC reduction include add-on devices (incinerators and carbon adsorbers), ultraviolet curing, and electron beam curing. ------- SUMMARY OF CTG DOCUMENT FOR FACTORY SURFACE COATING OF FLAT WOOD PANELING Affected facilities (p. 1-2)* Number of affected facilities (p. 1-2)* VOC emlHuions nationwide VOC emlBH ton range! per facility (Table 2-2 p. 2-5)* 100 tons/yr source size (calculated) CTC emisBion limit (p. v)* VOC reduction ler facility (Table 2-1 P. 2-4)* CoHtH (Table 3-2 p. 1-9)* The affected t.'icl tiles ,-ire factories that surface coat the following types of flat wood panels: a. Hardwood plywood b. Particleboard c. Hardboard Affected Facilities Nationwide Total a. Hardwood plywood 247 b. Particleboard 80 c. Hardboard 67 8.4 x 101* Mg/yr (9.3 x lO4 tons/yr) estimated for 1977 which represents about 0.5 percent of stationary source estimated emissions. l l Potential VOC emissions per coated surface area are: 0.4 to 8.0 kg/100 m? (0.8 to 16.5 lb/1000 ft2) depending on the coating/curing process as well as the coating materials used. Based on the VOC emission range above, a 100 tpy source would coat a minimum annual throughput of: 3.8 * 10'' to 7.7 x 10fc standard panels/yr Where a standard panel is 2.97 m2 (32 ft2). Recommended limitation Printed hardwood plywood 2.9 kg VOC/100 m? and particleboard (6.0 Ib VOC/1000 ft2) Natural finish hardwood plywood 5.8 kg VOC/100 m2) (12.0 Ib VOC/1000 ft?) Class II1 finishes for hard- 4.8 kg VOC/100 m2) board paneling (10.0 Ib VOC/1000 ft2) 70 to 90 percent VOC emission reduction, depending on coating material and coverage, through use of water-borne coatings, incineration, adsorption, ultraviolet curing or electron beam curing. Basis: Shifts: 1 2 Panels/yr: 2,000,000 4,000,000 Waterborne UV/Waterborne Waterborne UV/Waterborne Capital cost 52 155 52 155 ($1000) Annual i/.ecl cost 101 124.6 200 8 234 A ($1000) Cost effectiveness ($/Mg) 269 292 256 264 ($/ton) 244 264 232 240 *The source of the summary information is the indicated page number in "Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VII- Factory Surface Coating of Flat Wood Paneling," EPA-450/2-78-032. 'Definition on p. vil of KPA-450/2-78-032. ------- SECTION 4 MANUFACTURE OF SYNTHESIZED PHARMACEUTICAL PRODUCTS3 The CTG covers the manufacture of synthesized pharmaceutical products under SIC codes 2833 and 2834. Synthesized pharmaceutical products are nor- mally manufactured in a series of batch operations according to the following sequence: (a) reaction(s), (b) product separation, (c) purification, and (d) drying. The equipment which emit VOC during this process are: reactors, distillation units, dryers, crystallizers, filters, centrifuges, extractors and VOC storage tanks. VOC emission rates from each of these sources vary tremendously, so that typical emission rates by either process component or facility type are not calculated in the CTG document. The recommended control strategy for reactors, distillation operations, crystallizers, centrifuges and vacuum dryers that emit 6.8 kg/day (15 Ib/day) or more of VOC is Installation of a surface condenser on the equipment uxhaust. Operation of the surface condenser must be such that the exhaust gas temperature is reduced to: (1) -25°C when condensing VOC of vapor pressure greater than 40 kPa (5.8 psi),* (2) -15°C when condensing VOC of vapor pressure greater than 20 kPa (2.9 psi),* (3) 0°C when condensing VOC of vapor pressure greater than 10 kPa (1.5 psi),* (4) 10°C when condensing VOC of vapor pressure greater than 7 kPa (1.0 psi),* and (5) 25°C when condensing VOC of vapor pressure greater than 3.5 kPa (0.5 psi),* Additional controls are recommended for air dryers, production equipment exhaust systems and storage and transfer of liquids containing VOC. VOC emis- sions from air dryers and production equipment exhaust systems should be re- duced by 90 percent if they emit 150 kg/day (330 Ib/day) or more and should be reduced to 15 kg/day (33 Ib/day) if they emit less than 150 kg/day (330 Ib/day). Transfer of liquids containing VOC from trucks or railcars to tanks with a *Vapor pressures as measured at 20°C. ------- capacity of more than 7,500 liters (2000 gal) should employ a 90 percent effec- tive vapor balance system or equivalent. Tanks storing liquid containing VOC with a vapor pressure greater than 10 kPa (1.5 psi) at 20°C, should have pressure/vacuum vents set at ±0.2 kPa (±0.03 psi) except where more effective controls are used. There arc three remaining recommendations to reduce VOC emissions from pharmaceutical synthesis operations. First, all centrifuges, rotary vacuum filters and other filters with exposed liquid surfaces should be enclosed when processing liquids with a total VOC vapor pressure of 3.5 kPa (0.5 psi) or more at 20°C. Second, all in-process tanks containing liquids with VOC should be covered. Third, all leaks of VOC containing liquids should be re- paired as soon as possible. 10 ------- SUMMARY OF CTG DOCUMENT FOR MANUFACTURE OF SYNTHESIZED PHARMACEUTICAL PRODUCTS Affected facilities (p. 1-4)* Number of affected facilities (p. 1-2)* voc amisulons nationwide VOC etnlsHion range per facility Synthesized pharmaceutical manufacturing facilities. Specific aources include: 5. Filters 6. Extraction equipment 7. Centrifuges 8. Crystallizers. 1. Dryers 2. Reactors 3. Distillation Units 4. Storage and transfer of VOC Estimated 800 plants nationwide 50,000 Mg/yr (55,000 tons/yr) estimated for 1977 which represents about 0.3 percent of stationary source estimated VOC emissions. Not available 100 ton/yr source size Not available CTG amission limit (p. 1-5)* 1. a. Surface condensers or equivalent control on vents from reactors, distillation operations, crystallizers, cen- trifuges, and vacuum dryers that emit 6.8 kg/day (15 Ib/day) or more VOC. b. Surface condensers must meet certain temperature versus VOC vapor pressure criteria. 2. Additional specific emission reductions are required for air dryers, production equipment exhaust systems, and storage and transfer of VOC. 3. Enclosures or covers are recommended for rotary vacuum filters, processing liquid containing VOC and in-process tanks. 4. Repair of components leaking liquids containing VOC. VOC reduction par facility Not available Costs (pp. 5-14 to 5-42)* Capital and Annualized Cost graphs are provided for the following types of control equipment: conservation vents, floating roofs, pressure vessels, carbon adsorption systems, thermal and catalytic incineration systems, water cooled condensers, chilled water and brine cooled con- densers, freon cooled condensers, packed bed scrubbers and venturi scrubbers. Cost effectiveness data is not calculated for typical plants. The source of the summary information is the indicated page(s) in "Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products," EPA-450/2-78-029. 11 ------- SECTION 5 MANUFACTURE OF PNEUMATIC RUBBER TIRES4 The manufacture of pneumatic rubber tires includes the production of passenger vehicle and light- and medium-duty truck tires, and tires manufac- tured on assembly lines using automated equipment. The general process for tire manufacturing consists of: (1) preparation or compounding of raw materials, (2) transformation of these compound ma- terials into tire components, (3) tire assembly, and (A) molding of the final product. Each step employs unit operations that are sources of VOC emissions. Recommended levels of control are applicable to four of the unit opera- tions which are major sources of VOC emissions at a tire manufacturing plant. The operations are undertread cementing, treadend cementing, bead dipping, and green tire spraying which account for 83 percent of potential VOC emis- sions from a typical tire manufacturing plant. Compounding, milling, tread and sidewall preparation, calendering, molding and curing, and finishing are not recommended for control because of their lower emission factors. Latex dipping is not frequently employed and will be covered under a textile manu- facturing CTG. Tire building, although a significant source, is not recom- mended for control because the machines occupy about 25 percent of a plant's floor space over which the VOCs are emitted at very dilute concentrations. A plant which manufactures a part of a pneumatic rubber tire by employing one or more of the four affected unit operations is also recommended for control. The manufacture of tire treads for the tire recapping industry should be con- trolled while the actual recapping operation is not recommended for control. Quantitative emission limitations are not recommended. However, VOC emissions from the four affected unit operations can be effectively reduced by application of carbon adsorption or incineration systems if capture hoods and ductwork are designed in accordance with good engineering practice. The recommended scheme for reducing VOC emissions from green tire spraying is conversion to water-based sprays. The expected reduction in VOC emissions is shown in the following table. 12 ------- SUMMARY OF CTG DOCUMENT FOR MANUFACTURE OF PNEUMATIC RUBBER TIRES Affected facilities (PP. 1-1, 1-3)* Number of affected facilities (p. 2-2)* VOC emissions nationwide (p. 1-2)* nting, bead dipping, tread end cementing, and green tire spraying. Maximum of 62 rubber tire plants nationwide 1976 VOC emissions estimate from rubber tire manufacturing totalled 88,200 Mg/yr (97,200 tons/yr). This quantity represents 0.6 percent of'total national VOC emissions from stationary sources. VOC emission range per facility (p. 1-2)* The average tire plant is estimated to release 4,000 kg per day (8,820 Ib/day) of emissions or 1,000 Mg VOC per year (1,100 tons/yr), 100 tons/yr source size (p. 2-8)* The model plant, producing 16,000 tires/day, has potential to emit 1 A60 Mg/yr (1,600 tons VOC/yr). Therefore a plant producing approxi- mately 1,000 Lires/day would be a potential 100 tons/yr source. CTG emission limit (p. 4-2) * VOC emissions reduction from the affected operations is recommended through use of carbon adsorption or incineration. Water-based coat- ings may be used for green tire spraying. VOC reduction per facility (p. 1-4) * a. Carbon adsorption gives an overall efficiency of 62-86 percent in reducing VOC emissions, when applied to the affected operations. b. Incineration gives an overall efficiency of 59-81 percent when applied to the affected operations. c. Water-based coatings, applied to green tire spraying, provide an overall emission reduction efficiency of 97 percent. Costs (pp. 4-11, 4-15) * Basis: A model 16,000 tires/day plant using the various control technologies recommended on the following affected operations. All costs are based on January 1978 dollars. Capital cost ($1000) Annual!zed cost ($1000) Cost effectiveness ($/Mg) ($/ton) Undertread cementing 130-340 92-280 166-505 150-458 Bead dipping 115-250 70-985 1,400-20,800 1,340-18,800 Tread end cementing 135-375 100-340 1,140-3,880 1,000-3,500 Green tire spraying 15-450 118-490 202-839 184-763 *The source of the summary information is the indicated page(s) in "Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires," EPA-450/2-78-030. 13 ------- SECTION 6 MANUFACTURE OF VEGETABLE OIL5 This guideline provides information on the vegetable oil process as well as guidance on the planning and analysis required for the control of VOC emis- sions at vegetable oil extraction facilities. At the time this document was published, EPA acknowledged that there were uncertainties about the testing methods. EPA also had a field testing program that was developing useful data in the area of testing and monitoring. Initial results from several scheduled field tests indicated that the measured data are significantly more variable than had been anticipated. Consequently, in a letter dated June 22, 1979 (see next page), EPA asked the States to defer any regulatory action for veg- etable oil plants until after the field testing program is completed and all the data analyzed. It is anticipated that the testing program will be com- pleted in mid-1980. Since the original CTG document may be modified, it is not summarized in this report. 14 ------- SUBJECT FROM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Office of Air QualHy, Plaiming and Standards Research Triangle Park, North Carolina 27711 DATE JUN 2 2 1979 Initial Results of Emission Testing of Volatile Organic Compounds from Vegetable Oils Manufacture n Walter C. Barber, Director ^ Office of Air Quality Planning Standards (MD-10) T0 Director, Air and Hazardous Materials Division, Regions I-X As you are aware, in June 1978 EPA published a Control Techniques Guideline (CTG) for the manufacture of vegetable oils Control of Volatile Organic Emissions from Manufacture of Vegetable Oils, EPA-450/2-78-035, June 1978). That document stated that the regulatory Guidelines were based on engineering calculations and that further verification of these emission levels would be made upon review of data developed in conjunction with New Source Performance Standard development, Initial results from the first of several scheduled field tests indicate that the measured results are significantly more variable than originally anticipated. Accordingly, I have concluded that it would be prudent to defer regulatory action for vegetable oil plants until after the test program is completed this fall and all the data have been analyzed. States should not be required to adopt rules for this CTG category during 1979. Further information will be provided on this matter after the completion of the field test program. cc: Don Goodwin Jack Fanner Fred Porter George Walsh EPA Fo.m 1320-6 (R»v- 3-76) 15 ------- SECTION 7 GRAPHIC ARTS - ROTOGRAVURE AND FLEXOGRAPHY6 The graphic arts industry encompasses printing operations which fall into four principal categories: letterpress, offset lithography, rotogravure and flexography. This guideline is applicable to the flexographic and rotogravure processes as applied to both publication and packaging printing. Letterpress and offset lithography printing are not affected since these processes use inks containing small quantities of volatile organic compounds. In flexographic printing, the image areas are raised above the nonimage surface. The distinguishing feature is that the image carrier is made of rubber and other elastomeric materials. In the gravure method of printing, image areas are recessed relative to nonimage area. The image carrier is a copper-plated steel cylinder usually also chrome plated to enhance wear resistance. The emission limits are based on the use of VOC capture and control equip- ment, water-borne inks or high solids inks. Emission limits vary for opera- tions using capture and control equipment, primarily because the expected capture efficiencies vary with the type of printing operation. If water-borne inks are used as a control technique, the volatile frac- tion of the ink must contain 25 percent or less by volume organic solvent and 75 percent or more water. High solids inks must contain 60 percent or more by volume nonvolatile material. A potential issue in this CTG category is whether a particular operation is a coating or printing operation. A coating operation is the application of a uniform layer of material across the entire width of a web. A printing operation is the formation of words, designs and pictures, usually by a series of application rolls each with only partial coverage. All units in a machine which contains both coating and printing units will be considered as perform- ing a printing operation. However, the printing of simulated grain or decora- tive patterns on printed interior panels is not covered in this CTG category, and should be considered as a Flat Wood Paneling coating activity. 16 ------- SUMMARY OF CTG DOCUMENT FOR GRAPHIC ARTS AND FLEXOGRAPHY ROTOGRAVURE Affected facilities (p. 1-0* Nunfcer of affected facilities (p. 2-5)* VOC emissions nationwide (p. 2-8)* VOC emission range per facility (calculated) 100 tons/yr source size CTG emission limit (pp. 1-2, 1-3) * VOC reduction per facility Costs (pp. 4-8 4-13) * Flexographic and rotogravure processes packaging printing. applied to publication and a. Publication printing is done in large printing plants, m.mbi-r In,-. less than 50 in total. b. There are approximately 13 to 14 thousand gravure printing unlis and 30 thousand flexographic printing units. a. Gravure 100,000 Mg/yr 1976 (110,000 tons/yr) b. Flexography 30,000 Mg/yr 1976 (33,000 tons/yr) This represents about 0.8 percent of stationary source estimated emissions. ' ' a. Cravure 7.4 Mg/printing unit per year (8.2 tons /unit) b. Flexography 1 Mg/printing unit per year (1.1 tons/printing unit per year) A plant will be a potential 100 tons/yr VOC source if it uses 110-180 Mg (120-200 tons) of ink per year, where the solvent concentration is 50-85 percent. ! 1 1 Use of water-borne or high solids inks meeting certain composition criteria or the use of capture and control equipment which provides: a. 75 percent overall VOC reduction where a publication rotogravure process is employed; b. 65 percent overall VOC reduction where a packaging roto- rotogravure process is employed; or, c. 60 percent overall VOC reduction where a flexographic printing process is employed. Same as CTG limit above. VOC control option Ink usage, Mg/yr (tons/yr) VOC concentration ppm Capital cost Annual! zed cost Cost effectiveness S/Mf, $/ton Incinerator 7 (7.7) 500 94,000 24,900 8,360 7,570 ' Incinerator 2,500 (2,750) 500 1,110,000 1,665,500 1,650 1,480 Carbon adsorption 3,500 (3,860) 1,200 701,000 72,800 51 46 Carbon adsorpt Ion 7 ,000 (7,720) 2 , 400 701 ,000 (41,700)1- (lr-)l I ] O> *The source of the summary information is the indicated page number in "Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VIII: Graphic Arts - Rotogravure and Flexography," EPA-450/2-78-033. '''Numbers in parentheses arc savings. 17 ------- SECTION 8 PERCHLOROETHYLENE DRY CLEANING SYSTEMS" The dry cleaning industry is segregated into three categories: (1) coin- operated, (2) commercial, and (3) industrial. The principal steps in the dry cleaning process are identical to those of ordinary laundering in water: (1) one or more washes (baths) in solvent; (2) extraction of excess solvent by spinning; and (3) drying by tumbling in an air stream. The CTG recommended emission limitation is based on use of a carbon adsorption system, good maintenance practices and reduction of VOC emissions from filtration and distillation wastes. The carbon adsorption system should reduce VOC emissions to 100 ppm or less before dilution. Good maintenance practices include repairing all gaseous and liquid leaks. Diatomaceous earth filters should be reduced to no more than 25 kg of solvent per 100 kg of wet waste materials. Residue from solvent stills should contain no more than 60 kg of solvent per 100 kg of wet waste material. Filtration cartridges should be drained in the filter housing for at least 24 hours before being discarded. The CTG document indicates that most, if not all, coin-operated facilities will have Insufficient space or steam capacity to install a carbon adsorption system. These facilities should be exempted from having to install adsorption equipment, but should be required to meet the other housekeeping type of requirements. 18 ------- SUMMARY OF CTG DOCUMENT FOR PERCHLOROETHYLENE DRY CLEANING SYSTEMS Affected facilities (p. 2-1)* Number of affected facilities (calculated) VOC emissions nationwide (pp. 1-2, 2-1) * Affected facilities are coin-operated, commercial, and industrial dry cleaning systems which utilize perchloroethylene as solvent. a. Coin-op b. Commercial c. Industrial 14,900 44,600 230 a. Coin-op b. Commercial c. Industrial 21,400 Mg/yr 123,000 Mg/yr 13,600 Mg/yr (23,500 tons/yr) (135,000 tons/yr) (15,000 tons/yr) The estimated 158,000 Mg VOC/yr is 0.9 percent of total stationary source estimated emissions. VOC emission range per facility (l>. 5-2)* 100 tons/yr source size (extrapolated) Uncontrolled VOC emissions Type of plant a. Coin-op b. Commercial c. Industrial 1,460 3,240 32,400 (Ib/yr) (3,200) (7,200) (72,000) A large industrinJ dry cleaning plant, processing 750 Mg (825 tons) of clothes per year, would be a potential 100 tons VOC per year source. CTG emission limit (pp. .6-1 6-4)* a. Reduction of dryer outlet concentration to less than 100 ppm VOC, by means of carbon adsorption. (Facilities with inadequate space or steam capacity for adsorbers are excluded.) b. Reduction of VOC emissions from filter and distillation wastes. c. Eliminate liquid and vapor leaks. VOC reduction per facility (pp. 2-5, 2-7)* Carbon adsorption applied to commercial and industrial plants will reduce overall VOC emissions by 40-75 percent. Costs (p. 4-5)* Basis; Carbon adsorbers for a commercial plant cleaning 46,000 kg (100,000 lb) of clothes per year. Cap!tal cost Annualized cost Cost effectiveness $4,500 $300 $90. credit/Mg $80 credit/ton *The source of the summary information is the indicated page number in "Control of Volatile Organic Emissions from Perchloroethylene Dry Cleaning Systems," EPA-450/2-78-050. 19 ------- SECTION 9 LEAKS FROM PETROLEUM REFINERY EQUIPMENT8 Petroleum refineries produce gasoline, aromatics, kerosene, distillate finery VOC emissions, that have been addressed in previous CTG documents are fixed roof storage tanks; vacuum producing systems, wastewater separators and process unit turnarounds; and gasoline transfer operations. Parators> and Even though present estimates show that petroleum refinery leaks are a significant .source of VOC emissions, the emission factors which yield ?hese estimates are based on 20-year old data. Emission factors for petroleum re- oLT^ak ePrV6akS 3re belng UPdated' ^ P'^nary data indicate the total Jeak emission rate is greater than present estimates. The CTG document recommends a two-phase program of monitoring and main- V'rvor V°C emiS?10nS fr°m Petr°leUm refiner>' ei«iP"en? Tea™ A 10,000 ppm VOC concentration, when tested in the manner described in Appendix B of the document, constitutes a leak. The monitoring plan consists of annual inspection of pump seals, pipeline valves in liquid Lrvice and process drains; quarterly inspection of compressor seals, pipelinf valves in in8YeM Y PrGSSUre reUef ValV6S ln gas Servlce; ««d weekly visual inspection of pump seals. The maintenance portion of the program consists of repairing any detected leaks within 15 days. In some cases ifwill not be possible to compete the repair until the next scheduled unit turnaround £ cer af fT*" "^ "^ ^ rGPalred UDtil the ne— ^ shutdown occurs. f ,lnsta"ces «»re than unit shutdown repairs will be necessary to g "°mPnent lnt° comPliance- Temporary variances should be ^^enance or equip- fn, I!'0 CT(;,als« ^commends recording and reporting requirements to facili- tate the monitoring and maintenance program. A leaking components monitoring M "** ^ C°ntainS "**"&** information on leaks and their Also quarterly reports should be submitted to the air pollution con- c certif o e ar pouto trol agency certifying that the monitoring has been performed according " "^"^ **** ^ «" «* "*»* rrecHt1^ CTG ^^T" d°eS n0t PreSent calculati°ns fpr recovered product credits or cost-effectiveness ratios because emission reduction factors were 20 ------- not available. The necessary factors became available in January 1980 and have been used to calculate the emission reduction and cost-effectiveness figures presented in the following table.13 21 ------- SUMMARY OF CTG DOCUMENT FOR LEAKS FROM PETROLEUM REFINERY EQUIPMENT Affected facilities (p. 6-1)* Petroleum refinery equipment including pump seals, compressor seals, seal oil degassing vents, pipeline valves, flanges and other connections, pressure relief devices, process drains and open ended pipes. ' Number of affected facilities There were 311 petroleum refineries in the nation as of January 1, 1979.12 VOC emissions nationwide (p. 5-1)* The estimated VOC emissions nationwide are 170,000 Mg/year or about ] percent of the total VOC emissions from stationary sources. VOC emissions range per facility (p. 3-2)* The potential VOC emissions per leaking source range from 1.0 to 10 kg/day. 100 ton/year source size (p. 1-3, 2-3)* vnr/ n to emit O.A to 3.7 Mg VOC/year (0.5 to 4.1 ton/yr). A refinery with between 25 and 227 leaking components would emit 100 tons/year of VOC. A model medium size refinery may have 90,000 leaking components. CTG emission limits (p. 1-3)* If a leaking component has a VOC concentration of over 10 000 ppm at the potential leak source, it should be scheduled for main- tenance and repaired within 15 days. VOC reduction per facility (calculated) vearTofvoc P"vent/fe r^ease °f 1821.1 Kg/year (2007.4 ton/ year) of VOC at a model medium size refinery (15,900 m3/day) by reducing emissions from 2933.6 Mg (3233.5 ton) to 1112.5 Mg (1226.1 ton) per year.13 Costs (p. 4-8)* Basis: A monitoring and maintenance program for a 15,900 m3/day (100,000 bbl/day) refinery (Fourth quarter 1977 dollars). Instrumentation Capital Cost 8,80p Total Annual!zed Costs 115,000 Cost Effectiveness $/Mg (86.85)tl3 $/ton (78.81.)tl3 The source of the summary Information is the indicated page number(s) in "Control ?r/ Or8anlc Compound Leaks from Petroleum Refinery Equipment," — ~* ~ Numbers in parentheses are savings. 22 ------- SECTION 10 PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS9 Petroleum liquid storage in external floating roof tanks occurs at pe- troleum refineries, terminals, tank farms and along pipelines The recom- mended control technology Us retrofitting certain affected tanks with rim- mounted secondary seals. There are several exceptions to the general requirement that all exter- nal floating roof petroleum liquid storage tanks larger than 150,000 liters (40,000 gal) must have secondary seals. The exempt liquid storage tanks are those which: 1. are used to store waxv, heavy pour crude oil; 2. have capacities less than 1,600,000 liters (420,000 gal) and are used to store produced crude oil and condensate prior to lease custody transfer; 3. contain a petroleum liquid with a true vapor pressure of less than 10.5 kPa (1.5 psi); 4. contain a petroleum liquid with a true vapor pressure less than 27.6 kPa (4.0 psi); and (a) are of welded construction; and (b) presently possess a metallic-type shoe seal, a liquid- mounted liquid filled type seal, or other closure device of demonstrated equivalence; 5. are of welded construction, equipped with a metallic-type shoe primary seal and have a secondary seal from the top of the shoe seal to the tank wall (shoe-mounted secondary seal). Tanks storing waxy, heavy pour crude oil are exempted because waxy depo- sits on the tank wall would damage the secondary seal. If the tank is of riveted construction and not used for lease custody transfer, the only exemp- tion IK when true vapor pressure is less than 10.5 kPa. If the vessel is welded construction (and also not used for lease custody transfer) the vapor pressure exemption becomes a function of the existing primary seal type. If the seal Is a metallic-shoe type, liquid-mounted foam type, liquid-mounted liquid filled type, or equivalent, the minimum true vapor pressure for exemp- tion rises to 27.6 kPa (4.0 psi). For other primary seals on welded tanks, the minimum vapor pressure for exemption remains at 10.5 kPa (1.5 psi). 23 ------- Finally, if the tank is of welded construction, equipped with a metallic shoe seal and has a secondary seal from the top of the shoe seal to the tank wall (shoe mounted secondary seal) it is not an affected facility. The affected tank size changes from 150,000 liters (40,000 gal) to 1,600,000 liters (420,000 gal) only for tanks storing produced crude oil and condensatc prior to lease custody transfer (oil field production storage). This exception applies to tanks storing petroleum liquid from the time it is removed from the ground until custody is transferred from the production operation to the transportation operation. A rim-mounted secondary seal is continuous and extends from the floating roof to the tank wall, above, and covering the entire primary seal. Installed over mechanical shoe seals, liquid mounted primary seals or vapor mounted primary seals, rim-mounted secondary seals effectively reduce VOC emissions. In order for the secondary seal to be effective, the accumulated area of gaps exceeding 0.32 cm (1/8 in.) in width between the secondary seal and the tank wall should not exceed 2].2 cm7 per meter of tank diameter (1.0 in.2 per foot of tank diameter). Several ancillary control techniques are recommended in the CTG document. These include keeping covers, seals and lids closed except when in actual use and providing projections below the liquid surface on certain openings. Also automatic bleeder vents should be kept closed except when the roof is floated off or landed on the roof leg supports, and rim vents should be set to open only when the roof is being floated off the roof leg supports. Finally, roof drains should be provided with slotted membrane fabric covers or equivalent. 24 ------- SUMMARY OF CTG DOCUMENT FOR EXTERNAL FLOATING ROOF TANKS Affected facilities (p. 1-2)* Number of affected facilities (p. 2-1) * voc emissions nationwide (p. 1-2)* VOC emission range per facility (pp. 3-3, 3-9)* 100 tons/yr source size CTG emission limit (PP. 5-1, 5-4)* VOC reduction per facility (pp. 3-3, 3-9)* Costs (PP. 4-9, 4-12) * External floating roof tanks larger than 150,000 liters (40,000 gal) storing petroleum liquids. See exceptions noted in text. There is an estimated 13,800 internal and external floating roof tanks that are larger than 150,000 liters (40,000 gal). The number of ex- ternal floating roof tanks is not available. An estimated 65,000 Mg (71,630 tons) of VOC was emitted in 1978 which represents about 4.0 percent of stationary source estimated emissions. The emission range for a 30.5 m (100 ft) diameter tank storing 41.4 kPa (6 psi) vapor pressure gasoline is 212 Mg/yr (233 tons/yr) for a slightly gapped primary seal to 2.2 Mg/yr (2.4 tons/yr) for a tight rim-mounted secondary seal over a tight primary seal. No single floating roof tank is expected to emit more than 100 tons/yr. ] r' A continuous secondary seal or equivalent closure on all affected storage tanks, plus certain inspection and recordkeeping requirements. Ranges from about 200 to 2 Mg/yr (220 to 2.2 tons/yr). Basis: External floating roof tank 30.5 m (100 ft) in diameter with a capacity of 8.91 * 106 liters (55,000 bbl) controlled by a rim mounted secondary seal. Capital cost 16.9 ($1000) Annualized cost ($1000) Cost effectiveness ($/Mg) ($/ton) 3.3 (66)f-3,655 (59)f-3,316 *The source of the summary information is the indicated page(s) in "Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks," EPA-450/2-78-047. ^Numbers in parenthesis indicate credits. 25 ------- SECTION 11 LEAKS FROM GASOLINE TANK TRUCKS AND VAPOR COLLECTION SYSTEMS10 The Intent of this guideline is to define leak tight conditions and re- lated te.st procedures for vapor collection systems and tank trucks while loading and unloading at bulk plants, bulk terminals and service stations. The two separate affected facilities are gasoline tank trucks that are equipped for vapor collection and vapor collection systems at bulk terminals, bulk plants, and service stations that are equipped with vapor balance and/or vapor processing systems. The control approach is a combination of testing, monitoring, and equipment design requirements to ensure good operation and maintenance practices. Annual testing of gasoline tank trucks is recommended. The test consists of pressurizing to 4,500 Pa (18 in. of water) and evacuating to 1,500 Pa (6 In. of water). The truck tank should not sustain a pressure change of more than 750 Pa (3 in. of water) in 5 minutes under either condition. Each truck tank should display a sticker indicating the date it last met this pressure and vacuum test criteria. The vapor collection and vapor processing equipment should be designed and operated to prevent gauge pressure in the tank truck from exceeding 4,500 Pa (18 in. of water) and prevent vacuum from exceeding 1,500 Pa (6 in. of water). In addition, vapor concentration at 2.5 cm around the perimeter of a potential leak source should be below 100 percent of the lower explosive limit (LEI.,, measured as propane) at all times when measured by a combustible gas detector. The CTG document provides detailed descriptions of the testing of tank trucks and vapor collection systems. In addition, calibration procedures for the combustible gas detectors which are recommended for use by regulatory agencies for compliance monitoring are provided. Recordkeeping and reporting requirements are also discussed in the CTG document. Additional information on control techniques, costs, and monitoring pro- cedures IH presented in a report entitled "Evaluation of Vapor Leaks and Development of Monitoring Procedures for Gasoline Tank Trucks and Vapor Piping," EPA-450/3-79-018, April 1979. 26 ------- SUMMARY OF CTG DOCUMENT FOR LEAKS FROM GASOLINE TANK TRUCKS AND VAPOR COLLECTION SYSTEM Affected facilities (p. 2)* Number of affected facilities VOC emissions nationwide a. Gasoline tank trucks that are equipped for vapor collection. b. Vapor collection systems at bulk terminals, bulk plants, and service stations that are equipped with vapor balance and/or vapor processing systems. Not available Not available VOC emission range per facility Not available CTG emission limit (pp. 1 and 2) VOC reduction per facility The control approach is a combination of testing, monitoring, and equip- ment design to ensure that good maintenance practices are employed to prevent leaks from truck tanks or tank compartments and vapor collection systems during gasoline transfer at bulk plants, bulk terminals, and service stations. A leak is a reading greater than or equal to 100 percent of the LEL at 2.5 cm from a potential leak source as detected by a combustible gas detector. Not available Costa Not available *The source of the summary information is the indicated page number in "Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems," EPA-450/2-78-051. 27 ------- REFERENCES 1. Control of Volatile Organic Emissions from Existing Stationary Sources - Volume VI: Surface Coating of Miscellaneous Metal Parts and Products, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, June 1978, EPA-450/2-78-015. 2. Control of Volatile Organic Emissions from Existing Stationary Sources - Volume VII: Factory Surface Coating of Flat Wood Paneling, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, June 1978, EPA-450/2-78-032. 3. Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, December 1978, EPA-450/2-78-029. 4. Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, December 1978, EPA-450/2-78-030. 5. Control of Volatile Organic Emissions from Manufacture of Vegetable Oils, U.S. Environmental Protection Agency, Office of Air Quality Plan- ning and Standards, June 1978, EPA-450/2-78-035. 6. Control of Volatile Organic Emissions from Existing Stationary Sources - Volume VIII: Graphic Arts - Rotogravure and Flexography, U.S. Environ- mental Protection Agency, Office of Air Quality Planning and Standards, December 1978, EPA-450/2-78-033. 7. Control of Volatile Organic Emissions from Perchloroethylene Dry Clean- ing Systems, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, December 1978, EPA-450/2-78-050. 8. Control of Volatile Organic Compound Leaks from Petroleum Refinery Equip- ment, U.S. Environmental Protection Agency, Office of Air Quality Plan- ning and Standards, June 1978, EPA-450/2-78-036. 9. Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, December 1978, EPA-450/2- 78-047. 10. Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, December 1978, EPA-450/2-78-051. 11. Control Techniques for Volatile Organic Emissions from Stationary Sources, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, May 1978, EPA-450/2-78-022. 28 ------- 12. Energy Data Reports, Petroleum Refineries in the United States and U.S. Territories, Department of Energy, Energy Information Administration, Washington, D.C., dated January 1, 1979, released for printing June 28, 1979, DOE/EIA-0111/79. 13. Memorandum from S. V. Capone, GCA/Technology Division, to T. Williams, EPA/CPDD. Cost Effectiveness for RACT Application to Leaks from Pe- troleum Refinery Equipment. February 1, 1980. 14. Enforceability Aspects of RACT for Surface Coating of Miscellaneous Metal Parts and Products, Preliminary Memorandum. PEDCo. EPA Contract 68-01-4147, Task Order No. 121. January 11, 1980. 15. Calculations by R. K. Burr, ESED, author of Reference 9. 29 ------- TECHNICAL REPORT DATA mill l/jiirnclKins on the riTcnc hc/oic completing) I H I I' (1 R 1 N O _FPA-450/2-80-001 4. 1 I I L L AND SUB1 Hit SUMMARY OF GROUP II CONTROL TECHNIQUE GUIDELINE DOCUMENTS FOR CONTROL OF VOLATILE ORGANIC EMISSIONS FROM EXISTING STATIONARY SOURCES Stephen V. Cnpone Mslcolm W. IVtroccia Pt RF ORMING ORGAN I/ATI ON NAME AND ADDRESS CCA CORPORATION OCA/TECHNOLOGY D i V ISION Burlington Road Bedford, Massachusetts 01730 1.2. SPONSORING AGLNCY NAME AND ADDRESS U.S. ENVIRONMENTAL PROTECT!ON AGENCY Office of Air, Noise, and Radiation Office of Air Quality Planning, and Standards Research Triangle Park, North Carolina 27711 15. SUI'PLI MENTAHY NOTES P'-ojcct Officer: Tom Williams 3 RECIPIENTS ACCESSIOONO. 5 REPORT DATE _February 1_980 _ 6. PERFORMING ORGANIZATION CODE 8. PERFORMING ORGANIZATION REPORT NO. GCA-TR-79-79-G 10 PROGRAM ELEMENT NO. 11 CONTRACT/GRANT NO 68-02-2607 Work Assignment No. 39 13 TYPE OF REPORT AND PERIOD COVERED _ ____ 14. SPONSOR I NG~AG¥rgcV~COD~E 6. ABSTRACT Control Technirnie Guideline CCTG) documents have been prepared b/ the Office of Air Oualitv Planning and Standards of the U.S. F?A to assist states in defin- ing reasonably available control technology (RACT) for the control of volatile organic compound emissions from existing stationary sources. A document (EPA- 450/1-78-120) summarizing the CTG documents issued prior to January 1978 (Croup I) was published in December 1978. This document (FPA-45D/2-80-001) summarizes the CTG documents issued between Tnmmrv 1978 and January 1979 (Group IT). A description of each source category is provided, a I on p. with RACT and costs to retrofit a model facility. The source categories included are: leaks from petroleum refinery equipment, surface coat- ing of miscellaneous metal parts and products, manufacture of vegetable oil, surface coating of flat wood paneling, synthesized pharmaceutical products manu- facturing, pneumatic rubber tire manufacturing, graphic arts (rotogravure and flexographv), external floating roof tanks, perchloroethylene dry cleaning, and leaks from gasoline tank trucks and vapor collection systems. IK SCRIPT OHf, Air Pollut ion Control Guidelines Volatile Organic Chemicals Organic Compounds K( Y WORDS AND DOCUMENT ANALYSIS l>. IDENTIFIERS/OPEN ENDED TERMS Air Pollution Control Stationary Sources Reasonably Available Control Technology Organic Chemical Emissions Emission Limitations ui"> r RIHU rioN s r A u MI NT Unlimited EPA Ponn 2220-1 (9-73) 19 SFCURITY CLASS (1 His Report)' Uncla s sjijfi e d 20 " Unclassi fied COSATI 1 k'kl/(lroii|i 21 NO OF PAGES 34 22 PRICE 31 ------- |