United States Office of Air Quality EPA-450/3-81-016a
Environmental Protection Planning and Standards January 1983
A9ency Research Triangle Park NC 27711
Air
&ERA Flexible Vinyl Draft
Coating and EIS
Printing
Operations -
Backgound
Information
for Proposed
Standards
-------
EPA-450/3-81-016a
Flexible Vinyl Coating
and Printing Operations -
Background Information for
Proposed Standards
Emission Standards and Engineering Division
P: :•'r/!;cn Agsncy
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
January 1983
-------
This report has been reviewed by the Emission Standards a nd Engineering Division of the Office of Air Quality Planning
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended to
constitute endorsement or recommendation for use. Copies of this report are available through the Library Services
Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711; or, for a fee, from
the National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/3-81-016a
L',3. Environment! Frofecllflri Kpen
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Draft
Environmental Impact Statement
for the Flexible Vinyl
Coating and Printing Industry
Prepared by:
Jacb/K. Farmer
Acting Director, Emission Standards and Engineering Division
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
1. The proposed standards of performance would limit emissions of volatile
organic compounds (VOC) from new, modified, and reconstructed flexible
vinyl coating and printing facilities. Section 111 of the Clean Air
Act (42 U.S.C. 7411), as amended, directs the Administrator to establish
standards of performance for any category of new stationary source of
air pollution that "... causes or contributes significantly to air
pollution which may reasonably be anticipated to endanger public health
or welfare." The northeastern and north central regions of the country
would be particularly affected by the proposed standards.
2. Copies of this document have been sent to the following Federal
Departments: Labor, Health and Human Services, Defense, Transportation,
Agriculture, Commerce, Interior, and Energy; the National Science
Foundation; the Council on Environmental Quality; members of the State
and Territorial Air Pollution Program Administrators; the Association
of Local Air Pollution Control Officials; EPA Regional Administrators;
and other interested parties.
3. The comment period for review of this document is 60 days.
Mr. Gene W. Smith may be contacted regarding the date of the comment
period.
4. For additional information contact:
Gene W. Smith
Standards Development Branch (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
telephone: (919) 541-5624
5. Copies of this document may be obtained from:
U. S. EPA Library (MD-35)
Research Triangle Park, NC 27711
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
iii
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TABLE OF CONTENTS
Chapter Page
1 SUMMARY 1-1
1.1 Regulatory Alternatives 1-1
1.2 Environmental Impact 1-2
1.3 Economic Impacts 1-6
2 INTRODUCTION 2-1
2.1 Background and Authority for Standards 2-1
2.2 Selection of Categories of Stationary Sources . 2-5
2.3 Procedure for Development of Standards of
Performance 2-7
2.4 Consideration of Costs 2-9
2.5 Consideration of Environmental Impacts 2-10
2.6 Impact on Existing Sources 2-11
2.7 Revision of Standards of Performance 2-12
3 THE FLEXIBLE VINYL COATING AND PRINTING INDUSTRY
PROCESS AND POLLUTANT EMISSIONS 3-1
3.1 Background 3-1
3.2 FVC&P Product Processes and Emissions 3-1
3.2.1 Introduction 3-1
3.2.2 Raw Material Receiving and Storage ... 3-4
3.2.3 Substrate Preparation 3-4
3.2.4 Web Formation 3-5
3.2.5 Finishing Operations 3-14
3.2.6 Embossing 3-23
3.3 Baseline Emissions 3-24
3.3.1 State and Local Emission Regulations . . 3-24
3.3.2 Selection of the Baseline Emission Level. 3-31
3.4 References 3-32
4 EMISSION CONTROL TECHNIQUES 4-1
4.1 Volatile Organic Compound Control 4-3
4.1.1 Carbon Adsorption 4-3
1v
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TABLE OF CONTENTS (Continued)
Chapter Page
4.1.2 Incineration 4-14
4.1.3 Wet Scrubbing 4-23
4.1.4 Condensation Systems 4-30
4.1.5 Vapor Collection System 4-33
4.2 References 4-41
5 MODIFICATION AND RECONSTRUCTION 5-1
5.1 Modifications 5-1
5.1.1 Changes in Web Width 5-3
5.1.2 Changes in Line Speed 5-3
5.1.3 Changes in the Hours Available for
Operation and/or Scheduling Efficiency . 5-4
5.2 Reconstruction 5-5
5.3 References 5-7
6 MODEL PLANTS AND REGULATORY ALTERNATIVES 6-1
6.1 Model Plants 6-1
6.1.1 Model Plant Parameters 6-3
6.2 Regulatory Alternatives 6-6
6.2.1 Regulatory Alternative 1 6-9
6.2.2 Regulatory Alternative II 6-9
6.2.3 Regulatory Alternative III 6-9
6.2.4 Controlled Model Plant Parameters .... 6-10
6.3 References 6-15
7 ENVIRONMENTAL AND ENERGY IMPACTS 7-1
7.1 Air Pollution Impacts 7-2
7.1.1 Primary Air Pollution Impacts 7-2
7.1.2 Secondary Air Pollution Impacts 7-6
7.2 Water Pollution Impacts 7-7
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TABLE OF CONTENTS (Continued)
Chapter paqe
7.3 Solid Waste Impacts 7-12
7.4 Energy Impacts 7-16
7.5 Other Environmental Impacts 7-23
7.6 References 7-25
8 COSTS 8-1
8.1 Cost Analysis of Regulatory Alternatives . 8-1
8.1.1 New Facilities 8-2
8.1.2 Modified and Reconstructed
Facilities 8-13
8.2 Other Cost Considerations 8-13
8.3 References 8-15
9 ECONOMIC ANALYSIS 9-1
9.1 Industry Profile 9-1
9.1.1 General Industry Characteristics . . 9-1
9.1.2 Firm Characteristics 9-7
9.1.3 Industry Trends. 9-8
9.1.4 Growth Projections 9-20
9.2 Economic Impacts Analysis 9-21
9.2.1 Introduction 9-21
9.2.2 Potential Economic Impacts 9-31
9.3 Potential Socioeconomic and Inflationary
Impacts 9-42
9.4 References 9-43
APPENDIX A A-l
APPENDIX B B-1
APPENDIX C C-l
APPENDIX D D-l
APPENDIX E E-l
APPENDIX F F-l
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LIST OF TABLES
Table Page
1-1 Matrix of Environmental and Economic Impacts
of Regulatory Alternatives 1-3
3-1 FVC&P Products and End Uses 3-2
3-2 Estimate of Uncontrolled Web Formation Emissions
for an Average FVC&P Plant 3-13
3-3 Estimate of Uncontrolled FVC&P Emissions for
an Average Plant 3-21
3-4 Existing State Regulations on Emissions of Volatile
Organic Compounds Applicable to the Vinyl Coating
and Printing Industry 3-25
3-5 Summary of CTG Document for Coating of Fabric and
Vinyl 3-29
3-6 Summary of CTG Document for Graphic Arts-Rotogravure
and Flexography 3-30
4-1 Range of Capture Velocities 4-35
4-2 Coefficients of Entry for Selected Hood Openings . . . 4-37
6-1 Model Plants 6-2
6-2 Model Plant Parameters for Vinyl Coating Processes . . 6-5
6-3 Model Plant Parameters 6-7
6-4 Annual Production, Land, and Utility Requirements
(Without Control Devices) 6-8
6-5 Summary of Regulatory Alternatives 6-11
6-6 Control Option Parameters - Finishing Operation . . . 6-12
6-7 Land and Utility Requirements for Model Plant
Control Systems 6-13
7-1 Estimated National VOC Emissions from New Flexible
Vinyl Printing Lines 7-3
vii
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LIST OF TABLES (Continued)
Table Page
7-2 Air Emission Impacts of the Regulatory Alternatives
on the Model Plants 7-5
7-3 Wastewater Discharge Impacts of the Regulatory
Alternatives on the Model Plants 7-10
7-4 Estimated National Wastewater Discharge Impacts from
VOC Control Systems 7-11
7-5 Estimated National VOC Loading of VOC Control System
Wastewater Streams 7-13
7-6 Solid Waste Impacts of the Regulatory Alternatives
on the Model Plants 7-14
7-7 Estimated National Solid Waste Impacts from VOC
Control Systems 7-17
7-8 Electricity Impacts of the Regulatory Alternatives
on the Model Plants . . . ., 7-18
7-9 Estimated National Electricity Impacts from VOC
Control Systems ., 7-19
7-10 Fuel Oil Impacts of the Regulatory Alternatives on
the Model Plants ., 7-21
7-11 Estimated National Fuel Oil Impacts from VOC
Control Systems 7-22
7-12 Net National Energy Impacts of VOC Control 7-24
8-1 Model Plants 8-3
8-2 Bases for Annual ized Cost Estimates 8-4
8-3 Installed Capital and Annualized Costs for Uncontrolled
Model Plants ($1980) . . . „ 8-7
8-4 Annualized Costs for VOC Control Systems 8-10
8-5 Annualized Costs for Controlled Model Plants 8-11
9-1 Value of Shipments and Tota1 Quantity Produced
in the FVC&P Industry: 1977 9-2
viii
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LIST OF TABLES (Continued)
9-2 Companies Which Constitute the Majority of ~
Production in the Flexible Vinyl Coatinq and
Printing Industry .......... _ 9_4
9-3 Trends in Concentration: 1972-1977 ...... 9.9
9-4 Value of Shipments of Supported Vinyl Materials
(excluding wall coverings) for Various
End-Uses
9-5 Value of Shipments of Unsupported Vinyl Film . . 9-H
9-6 Value of Shipments of Wall Coverings ...... 9-13
9-7 Percentage Distribution of End-Use Markets for
Fvc&p ..................... g_14
9-8 Producer Price Index for Polyvinyl Chloride (PVC1
Resin: 1971-1979 ..... ........ / g_16
9-9 Exports and Imports of FVCP as Percentage of
Total Industry Output ............ g_17
9-10 Prices of FVC&P ............. g_18
9-11 Estimated Annual Production and Revenues for the
Flexible Vinyl Coating and Printing Model
Plants
9"1? G™" Profit Mar91ns f°r the Major Manufacturers
of PVC Coated Fabrics and Films ........ g_24
9-13 Operating Profit Margins for the Major Manufact-
urers of PVC Coated Fabrics and Films ..... 9.25
9-14 Net Profit Margins for the Major Manufacturers
of PVC Coated Fabrics and Films _
9-15 Net Profits to Assets Ratio for the Major
Manufacturers of PVC Coated Fabrics and Films . 9-27
9-16 Summary Financial Ration for the 65 Percent VOC
Control Level (Baseline Case) ......... 9_2g
9-17 ROI Analysis of the 65 Percent VOC Control Level
(Baseline) ................. 9_33
9-18 ROI Analysis of the 75 Percent VOC Control
Level ..................... 9-34
IX
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LIST OF TABLES (Continued)
Table Page
9-19 ROI Analysis of the 85 Percent VOC Control
Level 9-35
9-20 Debt Service Coverage Analysis 9-38
9-21 Percent Increases in CMLTD 9-39
9-22 Fifth Year Annualized Costs of Compliance for
the Worst Case 9-41
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LIST OF FIGURES
Figure
3-1
3-2
3-3
3-4
3-5
3-6
3-7
4-1
4-2
4-3
4-4
4-5
4-6
4-7
4-8
4-9
4-10
4-11
Flow Diagram of a Representative Vinyl Coating
and Printing Plant
Calendering Method of Web Formation
Cast Line Producing Supported Vinyl Sheet
Two Methods of Applying Coating to Fabric
Extrusion of Web
Typical Rotogravure Finishing Line with Embosser . .
Two-Roll Direct Rotogravure Coating Process ....
Schematic of Two-Bed Adsorber Units: Adsorber 1
Adsorbing, Adsorber 2 Regenerating
Schematic of Two-Bed Adsorber Unit: Adsorber 1
Regenerating, Adsorber 2 Adsorbing
Schematic of Solvent Recovery by Condensation
and Distillation
Typical Effect of Operating Temperature on
Effectiveness of Thermal Afterburner for Destruction
of Hydrocarbons and Carbon Monoxide
Incineration with Primary and Secondary Heat
Recovery
Schematic Diagram of a Catalytic Incinerator ....
Typical Packed Column Scrubber
Common Packings Used in Packed Column Scrubbers . .
Diagram of a Two Stage, Cross Flow Packed Scrubber .
Diagram of an Inert Gas Condensation Solvent
Recovery System
Typical Method of Recycling VOC-Laden Air Back to
the Drying Oven
Page
3-3
3-6
3-8
3-9
3-11
3-15
3-16
4-4
4-5
4-7
4-15
4-17
4-18
4-25
4-26
4-29
4-32
4-39
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LIST OF FIGURES (Continued)
Figure Page
6-1 Finishing Line Model Plant 6-4
7-1 Schematic of the Water Cycle in a FVC&P Plant
Solvent Recovery System 7-9
8-1 Estimated Installed Capital Costs for Model Plant
Control Systems 8-8
9-1 Geographical Locations of Vinyl Coating and
Printing Operations in the United States 9-3
9-2 Production Hierarchy for the Hexible Vinyl Coating
and Printing Industry 9-6
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1. SUMMARY
1.1 REGULATORY ALTERNATIVES
This Background Information Document (BID) supports proposal of the
Federal Regulation for limiting volatile organic compounds (VOC) vapor
emissions from the flexible vinyl printing industry. New Source Performance
Standards (NSPS) or standards of performance for new, modified, and
reconstructed flexible vinyl printing lines are being proposed under
Section 111 of the Clean Air Act (42 United States Code 7411). The
source of the VOC emissions are the organic solvent components in the
inks as well as any other solvent used at the print line, for example,
the solvent added to inks for viscosity control.
The three regulatory alternatives considered are presented in
Chapter 6. These alternatives call for an overall reduction of gaseous
VOC emissions from a fininshing line of 65 percent, 75 percent and 85
percent. The 65 percent control level, Regulatory Alternative I, is
defined as baseline control. It represents the VOC emission level that
would be allowed if no new source performance standard were promulgated
and is based on the control level recommended by EPA's Control Techniques
Guidelines document for packaging rate gravure operations. The 65
percent level represents a system which captures 70 percent of the total
gaseous VOC emitted from the flexible vinyl printing operation and
recovers or destroys 95 percent of these emissions.
Regulatory Alternative II is based on an overall VOC emission
reduction from the print line of 75 percent. The control system for
Alternative II would capture 80 percent of the total gaseous VOC emitted
from the finishing operation and then recover or destroy 95 percent of
those emissions. Similarly, Regulatory Alternative III is based on an
85 percent reduction resulting from 90 percent capture and 95 percent
recovery or destruction.
1-1
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All three regulatory control levels can be achieved with the installa-
tion of control equipment. Fixed-bed carbon adsorption is the most
popular method currently used to control VOC emissions from this industry.
The industry is developing waterborne inks that will meet VOC
emission limits without requiring control devices. Chapter 3 includes a
discussion of the development of waterborne inks. In the inks being
developed, the mass of VOC to mass of ink solids ratio ranges from 0 to
0.75.
1.2 ENVIRONMENTAL IMPACT
Detailed discussions of the environmental impacts associated with
the three regulatory alternatives are presented in Chapter 7.
An overview of the potential environmental impacts that could
result from the implementation of the regulatory alternatives is presented
in Table 1-1. The estimated effects s.hown in this table are based on
comparisons between Regulatory Alternatives II and III and the base case
(Regulatory Alternative I). The impacts represent changes above or
below the baseline regulatory alternative. No absolute impacts are
shown for any alternatives.
Regulatory Alternative I represents the base case. Because of
this, all of the impact values for this alternative are zero. There
would be no impact in comparing the baseline with itself. Under Regulatory
Alternatives II and III, increased reductions in VOC emissions, above
that achievable by Alternative I, would be expected. The reductions
would increase because the capture system efficiency under Alternative
II is higher than the efficiency used in Alternative I. The same control
device efficiency was assumed for all three regulatory alternatives.
The primary environmental impact from the flexible vinyl printing
industry is the uncontrolled emission of VOC from finishing line drying
ovens. The uncontrolled emission of VOC results primarily from the
vaporization of solvents in the drying ovens. These drying ovens are
used to evaporate the solvents from the inks used in the finishing
operations. A varying percentage of solvent vaporizes as fugitive
emissions around the rotogravure print head and from the wet web as it
travels to the oven.
1-2
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TABLE 1-1. MATRIX OF ENVIRONMENTAL AND ECONOMIC IMPACTS
OF REGULATORY ALTERNATIVES
Administrative
Action
Alternative I
65 percent control
Alternative II
75 percent control
Alternative III
85 percent control
Delayed
Standards
Air Water Solid Waste
Impact Impact Impact
00 0
+2** -1* -1*
+3** _2* -1*
00 0
KEY
+ Beneficial impact 0
- Adverse impact 1
* Short-term impact 2
** Long-term impact 3
*** Irreversible impact 4
Energy Noise
Impact Impact
0 0
+1** 0
+2** 0
0 0
- No impact
- Negligible impact
- Small impact
- Moderate impact
- Large impact
Economic
Impact
0
-1*
-1*
0
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VOC emissions can potentially cause an air pollution problem because
they are precursors to the formation of ozone and oxygenated organic
aerosols (photochemical smog).
VOC emissions from new, modified, or reconstructed flexible vinyl
printing lines were estimated on a national basis for the years 1983 to
1987. Under Regulatory Alternative I, in 1987, emissions from new
plants would be approximately 1400 megagrams (1600 tons), Regulatory
Alternative II would reduce emissions from new plants to 1000 megagrams
(1100 tons) in 1987. The strictest level of proposed NSPS control,
Alternative III, would reduce VOC emissions in 1987 to 610 megagrams
(670 tons) per year. The incremental iirpact of Alternative II on the
baseline control case (Alternative I) would be to reduce national VOC
emissions from flexible vinyl printing finishing operations by an
additional 30 percent in 1987. In 1987, Alternative III would reduce
national VOC emissions from flexible vinyl printing operations by 57
percent more than that achievable under Alternative I.
Table 1-1 indicates that Regulatory Alternatives II and III are
likely to cause negligible or small adverse impacts in terms of water
quality and solid wastes. The operation of carbon adsorption control
devices produces wastewater containing dissolved organics. On a national
basis in the year 1987, the total quantities of wastewater produced
under Alternative II would be 15 percent above the wastewater generated
by Alternative I. Similarly, Alternative III would generate 35 percent
more wastewater than Alternative I. In addition the operation of
carbon adsorbers also generates some wa';te carbon. Total quantities of
solid waste generated on a national basis in the year 1987 show a 15
percent increase from Alternative I to Alternative II and a 30 percent
increase from Alternative I to Alternative III. Wastewater and solid
waste impacts should decrease as waterborne inks begin to replace inks
containing organic solvents.
The emission control equipment for the flexible vinyl printing
industry utilizes electrical energy and steam. Net national energy
savings are possible in this industry when the energy value of the
1-4
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recovered solvent is considered. If all new flexible vinyl printing
lines built through 1987 were controlled to the level of Regulatory
Alternative I, the gross national energy demand would be equal to about
48,000 GJ (45 billion Btu). The amount of solvent potentially recoverable
under Alternative I (baseline) control could be translated into about
83,000 GJ (78 billion Btu) of energy. There is a net energy savings in
1987 of 35,000 GJ (33 billion Btu) under this baseline level of control.
Under Regulatory Alternative II control the gross national energy
demand would approach 55,000 GJ (52 billion Btu) in 1987. Alternative II
control would recover an energy equivalent of 95,000 GJ (90 billion
Btu). The net energy impact under Alternative II control, in 1987,
would be an energy savings of 40,000 GJ (38 billion Btu). The gross
national energy demand under Alternative III would equal approximately
64,000 GJ (61 billion Btu). The higher control efficiency of this
alternative would yield a potential solvent recovery equivalent to
105,000 GJ (100 billion Btu) of energy. The net energy impact under
Alternative III control, in 1987, would be an energy savings of 41,000
GJ (39 billion Btu).
The incremental energy savings of Alternative II compared to
Alternative I would equal 5,000 GJ (5 billion Btu). Alternative III
would have a potential energy savings of 6,000 GJ (6 billion Btu) when
compared to Alternative I. The favorable national energy impact is
important because of the lessening supply and increasing cost of petroleum
raw materials.
The impact of increased noise levels is not a significant problem
within the emission control systems of the flexible vinyl printing
industry. No noticeable increases in noise levels occur as a result of
increasingly stricter regulatory alternatives. Motors and solvent-laden
air fans are responsible for the majority of the noise in VOC control
systems.
1-5
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1.3 ECONOMIC IMPACTS
An analysis of potential economic effects of the three regulatory
alternatives was made based on the model plants described in Chapter 6.
A detailed discussion of the economic analysis is present in Chapter 9.
The large solvent recovery credits more than offset the costs of control
in four of the five model plants. The expected worst-case maximum price
impact is only 0.05 percent. No major impacts are expected on geographical
regions or local governments.
1-6
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2. INTRODUCTION
2.1 BACKGROUND AND AUTHORITY FOR STANDARDS
Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail. Various levels of control based on different technolo-
gies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for
a standard. The alternatives are investigated in terms of their impacts
on the economics and well-being of the industry, the impacts on the
national economy, and the impacts on the environment. This document
summarizes the information obtained through these studies so that inter-
ested persons will be able to see the information considered by EPA in
the development of the proposed standard.
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended,
hereinafter referred to as the Act. Section 111 directs the Admin-
istrator to establish standards of performance for any category of new
stationary source of air pollution which ". . . causes, or contributes
significantly to air pollution which may reasonably be anticipated to
endanger public health or welfare."
The Act requires that standards of performance for stationary
sources reflect ". . . the degree of emission reduction achievable which
(taking into consideration the cost of achieving such emission reduction,
and any nonair quality health and environmental impact and energy
requirements) the Administrator determines has been adequately demon-
strated for that category of sources." The standards apply only to
stationary sources, the construction or modification of which commences
after regulations are proposed by publication in the Federal Register.
2-1
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The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
1. EPA is required to list the categories of major stationary sources
that have not already been listed and regulated under standards of perform-
ance. Regulations must be promulgated for these new categories on the
following schedule:
a. 25 percent of the listed categories by August 7, 1980.
b. 75 percent of the listed categories by August 7, 1981.
c. 100 percent of the listed categories by August 7, 1982.
A governor of a State may apply to the Administrator to add a category not
on the list or may apply to the Administrator to have a standard of perform-
ance revised.
2. EPA is required to review the standards of performance every 4
years and, if appropriate, revise them.
3. EPA is authorized to promulgate a standard based on design, equip-
ment, work practice, or operational procedures when a standard based on
emission levels is not feasible.
4. The term "standards of performance" is redefined, and a new term
"technological system of continuous emission reduction" is defined. The new
definitions clarify that the control system must be continuous and may
include a low- or non-polluting process or operation.
5. The time between the proposal and promulgation of a standard under
Section 111 of the Act may be extended to 6 months.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking
into consideration the cost of achieving such emission reduction, any
non-air-quality health and environmental impacts, and energy requirements.
Congress had several reasons for including these requirements. First,
standards with a degree of uniformity are needed to avoid situations
where some states may attract industries; by relaxing standards relative to
other states. Second, stringent standards enhance the potential for
long-term growth. Third, stringent standards may help achieve long-term
2-2
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cost savings by avoiding the need for more expensive retrofitting when
pollution ceilings may be reduced in the future. Fourth, certain types
of standards for coal-burning sources can adversely affect the coal
market by driving up the price of low-sulfur coal or effectively excluding
certain coals from the reserve base because their untreated pollution
potentials are high. Congress does not intend that new source performance
standards contribute to these problems. Fifth, the standard-setting
process should create incentives for improved technology.
Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources. States are free under Section 116 of the Act to establish
even more stringent emission limits than those established under Section
111 or those necessary to attain or maintain the National Ambient Air
Quality Standards (NAAQS) under Section 110. Thus, new sources may in
some cases be subject to limitations more stringent than standards of
performance under Section 111, and prospective owners and operators of
new sources should be aware of this possibility in planning for such
facilities.
A similar situation may arise when a major emitting facility is to
be constructed in a geographic area that falls under the prevention of
significant deterioration of air quality provisions of Part C of the
Act. These provisions require, among other things, that major emitting
facilities to be constructed in such areas are to be subject to best
available control technology. The term Best Available Control Technology
(BACT), as defined in the Act, means
". . . an emission limitation based on the maximum degree of
reduction of each pollutant subject to regulation under this
Act emitted from, or which results from, any major emitting
facility, which the permitting authority, on a case-by-case
basis, taking into account energy, environmental, and economic
impacts and other costs, determines is achievable for such
facility through application of production processes and
available methods, systems, and techniques, including fuel
cleaning or treatment or innovative fuel combustion techniques
2-3
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for control of each such pollutant. In no event shall applica-
tion of "best available control technology" result in emissions
of any pollutants which will exceed the emissions allowed by
any applicable standard established pursuant to Sections 111
or 112 of this Act. (Section 169(3))."
Although standards of performance are normally structured in terms
of numerical emission limits where feasible, alternative approaches are
sometimes necessary. In some cases physical measurement of emissions
from a new source may be impractical or exorbitantly expensive. Section lll(h)
provides that the Administrator may promulgate a design or equipment
standard in those cases where it is not feasible to prescribe or enforce
a standard of performance. For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, high concentrations for short periods
during filling and low concentrations for longer periods during storage,
and the configuration of storage tanks make direct emission measurement
impractical. Therefore, a more practica' approach to standards of
performance for storage vessels has been equipment specification.
In addition, Section lll(j) authorizes the Administrator to grant
waivers of compliance to permit a source to use innovative continuous
emission control technology. In order to grant the waiver, the
Administrator must find: (1) a substantial likelihood that the technology
will produce greater emission reductions than the standards require or
an equivalent reduction at lower economic energy or environmental cost;
(2) the proposed system has not been adequately demonstrated; (3) the
technology will not cause or contribute to an unreasonable risk to the
public health, welfare, or safety; (4) the governor of the State where
the source is located consents; and (5) the waiver will not prevent the
attainment or maintenance of any ambient standard. A waiver may have
conditions attached to assure the source will not prevent attainment of
any NAAQS. Any such condition will have the force of a performance
standard. Finally, waivers have definite end dates and may be terminated
earlier if the conditions are not met or if the system fails to perform
as expected. In such a case, the source may be given up to three years to
2-4
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to meet the standards with a mandatory progress schedule.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Adminstrator to list categories
of stationary sources. The Administrator "... shall include a category
of sources in such list if in his judgement it causes, or contributes
significantly to, air pollution which may reasonably be anticipated to
endanger public health or welfare." Proposal and promulgation of
standards of performance are to follow.
Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of a system for assigning
priorities to various source categories. The approach specifies areas
of interest by considering the broad strategy of the Agency for imple-
menting the Clean Air Act. Often, these "areas" are actually pollutants
emitted by stationary sources. Source categories that emit these
pollutants are evaluated and ranked by a process involving such factors
as: (1) the level of emission control (if any) already required by
State regulations, (2) estimated levels of control that might be required
from standards of performance for the source category, (3) projections
of growth and replacement of existing facilities for the source category,
and (4) the estimated incremental amount of air pollution that could be
prevented in a preselected future year by standards of performance for
the source category. Sources for which new source performance standards
were promulgated or under development during 1977, or earlier, were
selected on these criteria.
The Act amendments of August 1977 establish specific criteria to be
used in determining priorities for all major source categories not yet
listed by EPA. These are: (1) the quantity of air pollutant emissions
that each such category will emit, or will be designed to emit; (2) the
extent to which each such pollutant may reasonably be anticipated to
endanger public health or welfare; and (3) the mobility and competitive
nature of each such category of sources and the consequent need for
nationally applicable new source standards of performance.
2-5
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The Administrator is to promulgate standards for these categories
according to the schedule referred to earlier.
In some cases it may not be feasible immediately to develop a
standard for a source category with a high priority. This might happen
when a program of research is needed to develop control techniques or
because techniques for sampling and measuring emissions may require
refinement. In the developing of standards, differences in the time
required to complete the necessary investigation for different source
categories must also be considered". For example, substantially more
time may be necessary if numerous pollutants must be investigated from a
single source category. Further, even late in the development process
the schedule for completion of a standard may change. For example,
inablility to obtain emission data from we! 1-controlled sources in time
to pursue the development process in a systematic fashion may force a
change in scheduling. Nevertheless, priority ranking is, and will
continue to be, used to establish the order in which projects are
initiated and resources assigned.
After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be
determined. A source category may have several facilities that cause
air pollution, and emissions from some of these facilities may vary from
insignificant to very expensive to control. Economic studies of the
source category and of applicable control technology may show that air
pollution control is better served by applying standards to the more
severe pollution sources. For this reason, and because there is no
adequately demonstrated system for controlling emissions from certain
facilities, standards often do not apply to all facilities at a source.
For the same reasons, the standards nay not apply to all air pollutants
emitted. Thus, although a source category may be selected to be covered
by a standard of performance, not all pollutants or facilities within
that source category may be covered by the standards.
2-6
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2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of performance must (1) realistically reflect best demon-
strated control practice; (2) adequately consider the cost, the non-air-
quality health and environmental impacts, and the energy requirements of
such control ; (3) be applicable to existing sources that are modified or
reconstructed as well as new installations; and (4) meet these conditions
for all variations of operating conditions being considered anywhere in
the country.
The objective of a program for developing standards is to identify
the best technological system of continuous emission reduction that has
been adequately demonstrated. The standard-setting process involves
three principal phases of activity: (1) information gathering,
(2) analysis of the information, and (3) development of the standard of
performance.
During the information-gathering phase, industries are queried
through a telephone survey, letters of inquiry, and plant visits by EPA
representatives. Information is also gathered from many other sources,
and a literature search is conducted. From the knowledge acquired about
the industry, EPA selects certain plants at which emission tests are
conducted to provide reliable data that characterize the pollutant
emissions from well-controlled existing facilities.
In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies. Hypothetical
"model plants" are defined to provide a common basis for analysis. The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives." These regulatory
alternatives are essentially different levels of emission control.
EPA conducts studies to determine the impact of each regulatory
alternative on the economics of the industry and on the national economy,
on the environment, and on energy consumption. From several possibly
applicable alternatives, EPA selects the single most plausible regulatory
alternative as the basis for a standard of performance for the source
category under study.
2-7
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In the third phase of a project, the selected regulatory alternative
is translated into a standard of performance, which, in turn, is written
in the form of a Federal regulation. The Federal regulation, when
applied to newly constructed plants, will limit emissions to the levels
indicated in the selected regulatory alternative.
As early as is practical in each standard-setting project, EPA
representatives discuss the possibilities of a standard and the form it
might take with members of the National Air Pollution Control Techniques
Advisory Committee. Industry representatives and other interested
parties also participate in these meetings.
The information acquired in the project is summarized in the Back-
ground Information Document (BID). The BID, the standard, and a preamble
explaining the standard are widely circulated to the industry being
considered for control, environmental groups, other government agencies,
and offices within EPA. Through tiis extensive review process, the
points of view of expert reviewers are taken into consideration as
changes are made to the documentation.
A "proposal package" is assembled and sent through the offices of
EPA Assistant Administrators for concurrence before the proposed standard
is officially endorsed by the EPA Administrator. After being approved
by the EPA Administrator, the preamble and the proposed regulation are
published in the Federal Register.
As a part of the Federal Register announcement of the proposed
regulation, the public is invited to participate in the standard-setting
process. EPA invites written comments on the proposal and also holds a
public hearing to discuss the proposed standard with interested parties.
All public comments are summarized and incorporated into a second volume
of the BID. All information reviewed and generated in studies in support
of the standard of performance is available to the public in a "docket"
on file in Washington, D. C.
Comments from the public are evaluated, and the standard of performance
may be altered in response to the comments.
2-8
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The significant comments and EPA's position on the issues raised
are included in the "preamble" of a "promulgation package," which also
contains the draft of the final regulation. The regulation is then
subjected to another round of review and refinement until it is approved
by the EPA Administrator. After the Administrator signs the regulation,
it is published as a "final rule" in the Federal Register.
2.4 CONSIDERATION OF COSTS
Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111
of the Act. The assessment is required to contain an analysis of
(1) the costs of compliance with the regulation, including the extent to
which the cost of compliance varies depending on the effective date of
the regulation and the development of less expensive or mo re.efficient
methods of compliance, (2) the potential inflationary or recessionary
effects of the regulation, (3) the effects the regulation might have on
small business with respect to competition, (4) the effects of the
regulation on consumer costs, and (5) the effects of the regulation on
energy use. Section 317 also requires that the economic impact assessment
be as extensive as practicable.
The economic impact of a proposed standard upon an industry is
usually addressed both in absolute terms and in terms of the control
costs that would be incurred as a result of compliance with typical,
existing State control regulations. An incremental approach is
necessary because both new and existing plants would be required to
comply with State regulations in the absence of a Federal standard of
performance. This approach requires a detailed analysis of the economic
impact from the cost differential that would exist between a proposed
standard of performance and the typical State standard.
Air pollutant emissions may cause water pollution problems, and
captured potential air pollutants may pose a solid waste disposal problem.
The total environmental impact of an emission source must, therefore, be
analyzed and the costs determined whenever possible.
2-9
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A thorough study of the profitability and price-s.etting mechanisms
of the industry is essential to the analysis so that an accurate estimate
of potential adverse economic impact:; can be made for proposed standards.
It is also essential to know the capital requirements for pollution
control systems already placed on plants so that the additional capital
requirements necessitated by these Federal standards can be placed in
proper perspective. Finally, it is necessary to assess the availability
of capital to provide the additional control equipment needed to meet
the standards of performance.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy Act (NEPA)
of 1969 requires Federal agencies to prepare detailed environmental
impact statements on proposals for legislation and other major Federal
actions significantly affecting the quality of the human environment.
The objective of NEPA is to build into the decision-making process of
Federal agencies a careful consideration of all environmental aspects of
proposed actions.
In a number of legal challenges to standards of performance for
various industries, the United States Court of Appeals for the District
of Columbia Circuit has held that environmental impact statements need
not be prepared by the Agency for proposed actions under Section 111 of
the Clean Air Act. Essentially, the Court of Appeals has determined
that the best system of emission reduction requires the Administrator to
take into account counter-productive environmental effects of a proposed
standard, as well as economic costs to the industry. On this basis,
therefore, the Court established a narrow exemption from NEPA for EPA
determination under Section 111.
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to section 7(c)(l), "No action taken under the Clean Air Act
shall be deemed a major Federal acticn significantly affecting the
quality of the human environment within the meaning of the National
Environmental Policy Act of 1969." (15 U.S.C. 793(c)(l))
2-10
-------
Nevertheless, the Agency has concluded that the preparation of
environmental impact statements could have beneficial effects on certain
regulatory actions. Consequently, although not legally required to do
so by section 102(2) (C) of NEPA, EPA has adopted a policy requiring that
environmental impact statements be prepared for various regulatory
actions, including standards of performance developed under section 111
of the Act. This voluntary preparation of environmental impact state-
ments, however, in no way legally subjects the Agency to NEPA requirements.
To implement this policy, a separate section in this document is
devoted solely to an analysis of the potential environmental impacts
associated with the proposed standards. Both adverse and beneficial
impacts in such areas as air and water pollution, increased solid waste
disposal, and increased energy consumption are discussed.
2.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as ". . . any stationary
source, the construction or modification of which is commenced ..."
after the proposed standards are published. An existing source is
redefined as a new source if "modified" or "reconstructed" as defined in
amendments to the general provisions of Subpart A of 40 CFR Part 60,
which were promulgated in the Federal Register on December 16, 1975 (40
FR 58416).
Promulgation of a standard of performance requires States to
establish standards of performance for existing sources in the same
industry under Section 111 (d) of the Act if the standard for new sources
limits emissions of a designated pollutant (i.e., a pollutant for which
air quality criteria have not been issued under Section 108 or which has
not been listed as a hazardous pollutant under Section 112). If a State
does not act, EPA must establish such standards. General provisions
outlining procedures for control of existing sources under Section
111 (d) were promulgated on November 17, 1975, as Subpart B of 40 CFR
Part 60 (40 FR 53340).
2-11
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2.7 REVISION OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
Section 111 of the Act provides that the Administrator ". . . shall, at
least every four years, review and, if appropriate, revise . . ." the
standards. Revisions are made to assure that the standards continue to
reflect the best systems that become available in the future. Such
revisions will not be-retroactive, but will apply to stationary sources
constructed or modified after the proposal of the revised standards.
2-12
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3. THE FLEXIBLE VINYL COATING AND PRINTING INDUSTRY
PROCESS AND POLLUTANT EMISSIONS
3.1 BACKGROUND
The industry producing flexible vinyl coated and printed (FVC&P)
products coats and prints continuous vinyl webs primarily with solvent
solutions of polyvinyl chloride (PVC) resins. Other resins such as
urethanes and acrylics can also be used on the same equipment to produce
similar products. Almost all of the FVC&P products are produced as a
continuous web thicker than two mils. Hand printing processes and
dipping processes are not included in the FVC&P industry as defined in
this study. Resilient flooring processes are somewhat similar to the
FVC&P processes but overall the flooring industry is quite different and
will be considered for a separate NSPS.
A variety of FVC&P products for many end uses are manufactured by
the industry and most of these are identified in Table 3-1. These
products are produced in approximately one hundred plants which are
located in the industralized states. Growth in the FVC&P industry is
mixed. The real dollar value of shipments of several major product
lines are declining while the value of shipments in other areas is
increasing. These trends are discussed in detail in Chapter 9 and the
effect of these negative and positive trends on emission estimates is
described in the next section. Major raw materials are fabric substrates,
pigments, PVC, plasticizers and solvents.
3.2 FVC&P PRODUCT PROCESSES AND EMISSIONS
3.2.1 Introduction
The major processes used to produce FVC&P products are web formation,
finishing and embossing. These processes are modified in a variety of
ways to provide different types of products to satisfy the needs of many
end uses. These processes are summarized in Figure 3-1 and described in
3-1
-------
TABLE 3-1. FVC&P PRODUCTS AND END USES'
SUPPORTED SHEET
UNSUPPORTED SHEET
Wallcovering
Products for Automobile Industry
Roof Headlining
Landau Roofs
Upholstery
Door Panels
Seat Belts
Furniture Upholstery
Umbrellas
Window Awnings
Leatherette
Gloves
Shoe Uppers
Luggage
Athletic Items
Marine Items
Shower Curtains
Shades
Sheet for lamination to
substrates such as -
Furniture
Fabric
Ceiling Tile
a As described in Section 3.2.4, supported sheet has a substrate, usually
fabric, whereas unsupported sheet does not have such a substrate.
3-2
-------
OJ
GO
PVC Resin *
Plasticizer
Pigments
Solvents
Final
Product
PVC Resin
Plastlclzer
P1g»tnt
Solvent
PVC Resin *
Plasticizer
Pigment
Solvent
* PVC Resin or vinyl chloride/vinyl acetate ccpolymer
Figure 3-1. FLOW DIAGRAM OF A REPRESENATIVE VINYL COATING AND
PRINTING PLANT
-------
the following sections. Many of these steps may be omitted for any one
product. In the following sections, each of these processes is described
and emissions are characterized and quantified. The figures and tables
of Chapter 3 summarize the information obtained by a telephone survey of
the FVC&P industry and nine plant visits.
3.2.2 Raw Material Receiving and Storage.
3.2.2.1 Processes. Raw materials such as PVC resins are shipped
in 40 to 50 pound bags or handled in bulk by fluidized conveying equip-
ment. Other dry ingredients are shipped and stored in bags. Plasticizer
and solvents are shipped and stored in bulk or drums.
3.2.2.2 Emissions. There are particulate emissions involved in
the handling of materials such as PVC. The magnitude of the emissions
is influenced by the size of the resin particle and the design of the
material handling equipment. There are no industry data quantifying the
extent of these particulate emissions. The VOC emissions occur wherever
solvents are mixed, transported or stored in open containers. Generally
there are VOC emissions throughout the receiving and storage operation.
Uncontrolled particulate and VOC emissions from the materials
receiving and storage operations of an average FVC&P plant have been
estimated at 4.5 Mg (5 tons) to 18 Mg (20 tons) per year respectively.
If the point source emissions are over 45 Mg (50 tons) per year or if
the emissions are visible, particulate emissions from new plants or
major modifications are generally controlled by states. Most state and
local agencies have regulations for solvent storage emissions. Therefore,
raw material and storage emissions are not being considered for this
NSPS.
3.2.3 Substrate Preparation
3.2.3.1 Processes. A fabric substrate is purchased for use in
most FVC&P products. This substrate may be woven or non-woven. The
substrate provides mechanical strength and bulk to the FVC&P product.
This fabric substrate is frequently heated by a radiant heat source
as it enters the web preparation step. The heating controls moisture
-------
and assists in establishing a good bond between the substrate and the
first coat of vinyl.
3.2.3.2 Emissions. No significant emissions are involved in
substrate preparation.
3.2.4 Web Formation
3.2.4.1 Processes. Web formation includes the processes which
form the PVC resins, stabilizers, pigments and plasticizers into a
continuous vinyl sheet, termed a web. As indicated in Section 9.1 there
is excess capacity in the web preparation processes and therefore very
few or no new plants or production lines are expected in the web prepa-
ration processes.
The web formation process consists of vinyl coating preparation,
vinyl coating application to form the web, and sometimes expansion of
the web. This vinyl sheet or web may be unsupported or supported by
fabric. If the web is unsupported there may also be a step which involves
lamination of the vinyl to a fabric backing. The four major techniques
used to form the web are:
• calendering,
•casting followed by coating with knife or roll,
•coating with knife or roll, and
• extrusion.
These processes may be varied and combined as discussed below.
The calendering process is described in Figure 3-2. There are no
production figures available but it is thought that more than one-half
the FVC&P products are manufactured from a calendered web.2 As indicated
in Figure 3-2 the PVC resins, plasticizers, and pigments are blended
together in a series of blenders, Banbury mixers and 2-roll mills.
After mixing, the charge is conveyed to the calender. In an "inverted
L, 4-roll" type calender, the molten vinyl coating is roll-formed into a
continuous vinyl sheet. Most calendered products are embossed at this
point with a matte finish or other special finish by compression between
textured rollers. If the vinyl sheet is to be supported, then it is
also applied to a continuous sheet of fabric by compression between the
3-5
-------
PVC Resin
u>
en
ers 1
esin
nts ~~|
Blender
393° K (248°
i
T
Banbury Mi*
430° K (350C
*
2 Roll Mill
422° to 43C
(300°F to :
1
F)
er
F)
5°K
520
/
E
UF)
Aerosol
[missions
^
X
j 1 X,^
X
X
xx
X
X
1 x\
— -1
Infrared Oven
Fabric Substrate Feed
(310° to 370°F)'
Inverted L 4 Roll Calender
Coated Web Take-up
Reel
Cooling Roolers
Figure 3-2. CALENDERING^METHOD OF WEB FORMATION
-------
bottom roller and the support roller to form a supported product. The
supported or unsupported web is then cooled.
The advantages of the calendering process over other methods of web
preparation are high production rate, low labor and material costs, and
very accurate thickness control.
The disadvantages of the calendering process are high capital costs
and very stringent temperature control requirements. Again no production
figures are available. But it is thought that nearly one-half of the
FVC&P products require the web to be formed by casting or coating.
In the casting process a vinyl web is cast or coated onto a paper
carrier web using processes such as roll coating and knife coating.
This paper is ultimately removed and reused. The vinyl web surface
which was next to the paper becomes the finished product surface. The
paper carrier may impart a mirror like finish or a textured surface to
this vinyl web. If supported sheet is being produced, as shown in
Figure 3-3, a fabric web is bonded to the vinyl web in subsequent
processes.
Advantages of the casting process include: lower capital costs,
the ability to make short runs of specialty items, and an ability to
'texture the first coat to provide premium quality and a smooth glossy
surface (thus eliminating an embossing step). Disadvantages of the
process are higher priced raw materials, higher labor cost than the
calender process, and casting paper is a high cost component and must be
reused.
In a typical coating process the web is formed by coating the
substrate, using any one or more coating methods. The two most common
methods of coating a substrate are knife over roll and reverse roll.
These methods are shown in Figure 3-4 and discussed below.
Knife Coaters^. A tray or trough containing the plastisol
coating is located behind the knife blade. A continuous sheet
of fabric or paper is drawn between the knife blade and a
support roller. As coating is deposited on the sheet, the
knife blade spreads it across the fabric to the desired thickness,
3-7
-------
Skin Coat
Knife ove
roll
i
oo
Air Heaters
lecirculation of
Oven Gases
Casting Paper
UnWind
Fabric Unwind
1
Recirculatiorj
of Oven Gaseg
Thin Adhesive
Coat
Laydown
Roll
Air Heaters with
Recirculation of
/ Oven Gases
Aerosol Emissions
Expansion and Fusion Oven
463° to 477°K (375° to 400°F)
Strippei
Roll
Casting Paper
Winder
Cooling Drums
Coated Fabric
Winder
Figure 3-3. CAST LINE PRODUCING SUPPORTED VINYL SHEET
-------
Coating
CO
I
Web
Knife Blade
Coated Web
Metering Roll
Flexible Doctor
Blade
Coating
Application"
Roller
Support Roller
Knife Over Roll Coater
Drip Pan
Three Roll
Reverse-Roll Nip-Fed Coater
Doctor Blad
Web
Figure 3-4. TWO METHODS OF APPLYING COATING TO FABRIC
-------
The coated web then passes through an oven similar to that
shown in Figure 3-3 for fusion of this vinyl to the substrate.
Reverse-Roll Coaters. Figure 3-4 illustrates the three roll,
nip-fed, reverse-roll coater. Basically, there are three
component rollers: the metering roller, the applicator
roller, and the backing or support roller. The coating is
contained in a pool between the metering and applicator rollers
and a coating dam. The metering roller picks up the coating
material from the pool and transfers it to the applicator
roller. The applicator roller then transfers the coating to a
continuous sheet as it traverses between the backing and
applicator rollers. The coated web passes through an oven
similar to Figure 3-4 for fusion of the vinyl to the substrate.
Advantages of the coating process are that the capital costs are
less than the calender equipment and it is economical for short runs of
specialty items. Disadvantages are that the coating process requires
higher priced raw materials and higher labor costs than the calender
process.
Extrusion of a web is described in Figure 3-5. The PVC resins,
plasticizers, and pigments are blended together and fed to an extruder.
The extruder heats and then forces the homogeneous mass through a
narrow slit the width of the web. This vinyl coating is nipped to a
fabric by pressure rolls and then cooled and wound in a roll. Although
no production figures are available probably less than ten percent of
3
the total FVC&P products are extruded.
It is estimated that 20 percent of the supported FVC&P webs are
expanded. The expansion generally takes place as the final step in the
web formation process. If the final product is to be an expanded type,
the web is coated with a vinyl coating containing various chemicals
which emit an inert gas when heated to 469°K (375°F). This gas foams the
vinyl layer as it passes through the expansion oven and provides a
product having a special body quality. The application of the coating
and the heating of the web is presented in Figure 3-3. Any supported
3-10
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PVC Bulk Storage
"X
'
»• Resin Dust Emissions
PVC Batch Weighing
Resin Dust and Plasticizer Emissions
Plasticizer Addition
»• Aerosol Emissions*—x
Cooling Drums
Coated Fabric Winder
Figure 3-5. EXTRUSION OF WEB
-------
web may be expanded in a similar manner. Much of the expanded upholstery
product used by the automotive industry has been replaced in recent
years by a soft product which is not expanded and is more durable.
3.2.4.2 Emissions. Aerosol emissions are evolved at several
points in the preparation of the web. For the reasons stated below the
emissions from the web formation processes are not considered further
for NSPS. The sources are indicated as dotted lines in Figure 3-2, 3-3,
and 3-5. These particulate emissions are presented in Table 3-2 and
further described below.
Emissions from the calendering processes are high molecular weight
organic compounds which condense into aerosols. They are primarily
vaporized plasticizers from the heated material as it is blended,
mixed, conveyed, calendered and cooled. Point source emissions are
collected via ducts from the equipment and fugitive emissions are captured
by hoods and suction pick up points.
Emissions from casting processes are aerosols similar to those
described for the calendering process. Traces of solvent are also
emitted from gelling and fusion ovens. Point source emissions are
collected via ducts from the ovens. Some of the vapors and aerosols
which evaporate are captured by hoods from the hot web as it leaves the
ovens and are usually led back into the ovens.
Emissions from coating with knife or roller are similar to those
described for the casting/coating processes. Emissions from extrusions
processes are similar to those described for calendering processes.
Uncontrolled aerosol emissions from web formation in an average
FVC&P plant are estimated to be 35 Mg (38 tons) per year. The VOC
emissions are negligible since only a small amount of solvent is used
for viscosity control in some of the plastisol coating processes.
Some of these aerosol emissions from web formation processes are
controlled. Furthermore, it is unlikely that there will be many new
installations of web preparation equipment over the next five years, for
two reasons: there is a large amount of unused capacity available in
-------
TABLE 3-2. ESTIMATE OF UNCONTROLLED WEB FORMATION EMISSIONS
FOR AN AVERAGE FVC&P PLANT6
Sources
Web
a.
b.
c.
d.
Formation
Calendering
Mixing
Banbury
Roll millsc
Conveying0
Calendar6
Fugitives
Extruding
Mixer
Extruder
Cast/coating
Preparation
of coating
Coating
application
Fusion ovens"
Fugitives
Expansion
oven
Aerosol s
Mg
per year
0.45
1.80
0.45
0.27
15.00
in above
0.09
1.40
Negligible
in below
10.0
in above
5.5
Tons
per year
0.5
2.0
0.5
0.3
16.0
in above
0.1
1.6
Negligible
in below
11
in above
6
VOC
Mg Tons
per year per year
Negligible Negligible
Negligible Negligible
Negligible Negligible
Negligible Negligible
e. Laminating
Totals
Negligible Negligible
Negligible Negligible
35
38
Emissions for an average plant are based on estimated 1980 volumes of
FVC&P products and assuming 100 plants. The plant would calendar 2.3 M
kilogram (5 million pounds), cast/coat 0.8 M kilogram (1.8 million pounds)
and extrude 0.3 M kilogram (0.6 million pounds) per year of web. Some of
the web, 0.3 M kilogram (0.7 million pounds) per year would be laminated.
Calculated from state and industry estimates of emission factors.
Emission factors are estimated on basis of process and formulae informa-
tion.
Engineering estimate based on review of process, operating parameters.
3-13
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calendering equipment and this excess web preparation capacity can, in
most cases, be utilized to meet the requirements of the growing product
1ines.
3.2.5 Finishing Operations
3.2.5.1 Processes. The major operations involved in FVC&P finishing
operations are presented in Figure 3-6 and discussed below.
Most coatings and inks used in the finishing operations are solvent
solutions of vinyl chloride/vinyl acetate copolymers and PVC resins.
Smaller companies frequently buy ink concentrates. Larger companies
compound inks in a variety of compositions and colors. Each manufacturer
prepares inks and coatings in whatever tanks, and mixing equipment meet
his individual needs. The compositions range from 70 percent solvent
and 30 percent resin solids to 95 percent solvent and 5 percent solids,
on a weight basis. A typical ink or coating is 85 percent solvent and
15 percent solids. However, some manufacturers suggest 70 to 75 percent
solvent and 25 to 30 percent solids ink:; can be used.
A diagram of an individual rotogravure printing station is presented
in Figure 3-7. The rotogravure principle is always used on these high
speed continuous web lines. The gravure cylinder, on which the image
surface has been etched, is about one-fourth submerged in a trough (the
ink fountain) of ink or coating. Before a portion of the gravure cylinder
contacts the paper, it picks up ink by rotation through the ink fountain.
The ink used for rotogravure printing must instantly fill the cells or
pores in the image zones of the cylinder's surface. Therefore, the ink
must have a relatively low viscosity. The engraved cylinder is then
scraped by a flexible "doctor blade" which removes the ink from the
smooth non-image portion of the surface but leaves the ink in the cells.
There are many different arrangements of the printing stations in
relation to each other and in relation to the oven(s) . Most of the
printing units are arranged in an in-line configuration. A few lines
(less than 10 percent) use a U-type printer where the print heads are
arranged around a central point. (One' manufacturer suggests that
80 percent of the printing units in FVC&P industry are "U" shape printers.)
3-14
-------
CO
I
Aerosol Emissions and VOC
I
I
Radiant Heat
Embossing
Rolls Web Feed
to print
Line
VOC Emissions
I
i
Exhaust Fans to
Stack
Inlet Air Heated
With Steam Colls
Final Pass Fusion Zone
422° to 464°K (300° to 375°F)
0
Intermediate Stage Drying
380° to 422°K (225° to 300°F)
*" Fugitive .
Emissions
Precoat
Print Topcoat
a) Some part of these emissions
may be used as make up air to
oven or otherwise circulated
through oven and emitted as
oven exhaust.
Figure 3-6. TYPICAL ROTOGRAVURE FINISHING LINE WITH EMBOSSER
-------
Coated Web
Doctor Blade
I
CT)
Impression Cylinder
Engraved Cylinder
D
D
Ink Pump
^ Solvent
Indicates Sources of
Fugitive Emissions
Figure 3-7. TWO-ROLL DIRECT ROTOGRAVURE COATING PROCESS
-------
The in-line configuration is used in the newer plants to provide higher
line speeds and higher recovery of solvent vapors.1'2
A typical finishing line as shown in Figure 3-6 includes the following
steps:
Precoating. Only a few products are precoated. This step,
which also utilizes rotogravure equipment provides an extra
smooth surface for the printing step which follows.
Printing. Most FVC&P products are printed with one or more
colors. Each print station prints a different pattern or
color.
Wearcoat or Topcoating. Many supported fabrics, excluding
residential wallcovering, are coated with a final topcoating
to provide protection against scuffing and wear.
Fusion of Coating. Most FVC&P processes include a fusion
step. Most solvent based coatings will form a continuous film
upon air drying but plastisol and organise! coatings require a
higher temperature, 422°K to 464°K (300°F to 375°F), which
fuses the PVC and plasticizer into a continuous film.
The web is fed from a continuous roll through a series of rollers
which precisely adjust its path through the rotogravure print stations.
The rollers also help regulate the web tension and maintain constant
speed. The web is pressed against the image surface of the gravure
cylinder by a rubber roller, which serves as a backing. The point of
contact between web and gravure cylinder is called the "nip" area.
After the image has been transformed, the web travels through an enclosed
oven where heated air evaporates the volatile solvent. The web then
passes to the next printing unit.
In a typical controlled facility, the exhaust from the ovens is
directed to a carbon adsorption system. This oven exhaust is vented to
the atmosphere in an uncontrolled plant.
Several operating parameters of the finishing process are listed
below. ' ' Operating factors for the finishing line range from 40 to
60 percent due to time required for color changes, etc. Some manufacturers
3-17
-------
report operating factors as low as 25 to 30 percent due to color changes.8
A typical factor for a new line would be 40 percent downtime or 3600
operating hours per year.
Line speed varies from 14 to 64 in (15 to 70 yards) per minute. A
typical factor for a new line would be 55 m (60 yards) per minute.
Product width ranges from 76 to 150 cm (30 to 60 inches). A typical
width for a new line would be 76 cm (30 inches). Coating and ink
application rate varies from 0.016 to 0.390 kg per square meter (0.03
o
to 0.72 pounds per square yard) depending upon product requirements.
Coating and ink formulation varies from 5 to 30 (wt) percent solids
or 95 to 70 (wt) percent solvent. These variations occur on the same
line as a result of different product specifications. Some coating and
ink formulations eliminate or minimize the solvent used in these coatings
or inks.
The plastisols used to prepare the web, as described 'in Section
3.2.4, are usually 100 percent solids and contain no solvent except for
small amounts used to adjust viscosity. These 100 percent solids coatings
are viscous and not suitable for finishing operations.
Some manufacturers have attempted to substitute water for organic
solvent. At least five major companies, along with several vendors, are
seriously developing waterborne inks. The companies are:
•B.F. Goodrich
q
•Columbus Coated Fabric
g
•Chrysler Corporation
•General Tire and Rubber (GTR)
•Uniroyal
It is thought that the first three companies are in preliminary developmental
stages.
GTR is said to be producing seat belts for Volkswagen using a
1 o
waterborne ink. This ink or coating has the following composition:
Weight % Volume %
Non-volatiles 33.0 30.3
Water 48.4 50.3
Organics (VOC) 18.6 19.4
Density is 8.9 (Ib/gal)
3-18
-------
Uniroyal is making a major commitment in the development of waterborne
inks. Currently, Uniroyal is investigating waterborne inks with the
following composition:
0-15 wt. percent VOC
55 - 80 wt. percent water
20 - 30 wt. percent solids
Density varies from 9-11 Ib/gal
Two major vendors of waterborne inks are Polyvinyl Chemicals and
Sinclair and Valentine. Polyvinyl Chemicals, an ink manufacturing
company, produces waterborne inks and resins for the FVC&P industry. A
typical formulation is as follows:
12.5 wt. percent VOC
34 wt. percent solids
53.5 wt. percent water
Sinclair and Valentine is probably the number one or two company in the
ink supplying business. They report that the solvent concentrations in
all their waterborne inks are below the CTG limit for the fabric coating
n
industry. However, these formulations have not been accepted by the
FVC&P industry. They are difficult to dry and there have been difficulties
in obtaining the pigments and resins required for high quality products.
At present, organic solvents are used in most FVC&P finishing
operations. Oven air flow ranges from 60 dry standard cubic meters per
minute (2000 scfm) to 450 dry standard cubic meters per minute (16,000
scfm) per line depending upon desired drying rate and web and coating
drying characteristics, line widths, line speed, and number of print
heads.
The solvent content in oven air varies from 0 to 50 percent of the
lower explosive limit (LEL). The LEL is the lowest vapor concentration
in air, expressed as volume percent, at which the mixture could support
a flame or explosion at temperatures below 121°C (250°F). Insurance
safety regulations require normal operation at less than about 25 percent
of the LEL. Operation up to 50 to 60 percent of the LEL is permitted
when continuous vapor monitoring systems are employed to control the
vapor concentration in the air.
3-19
-------
Major raw materials for pringing vinyl are usually PVC resins or
vinyl chloride/vinyl acetate copolymer, plasticizers, pigments and
solvents. The solvents are primarily ketones, however, tetrahydrafuran,
toluene, xylene, and many other solvents are also used in small quantities.
Urethanes and acrylic systems are sometimes used on the same equipment.
Many of these operating parameters are interrelated. For example,
changes in web width, line speed, ink or coatings coverage, and solvent
type influence the oven exhaust flow rate and solvent concentration.
For example, a finishing line operating with a narrow web on a wide
cylinder will produce a dilute oven exhaust stream. The width of the
oven must be large enough to accomodate the widest desired web. Only a
portion of the makeup air will be flowing over the printed product. The
decreased solvent loading will result in a lower concentration of
solvent in the solvent laden air (SLA) stream. Most ovens are capable
of internal exhaust recirculation and air flow can be adjusted to provide
adequate fresh air makeup, without excessive oven exhaust dilution.
Excessive oven exhaust dilution requires a larger SLA collection and
control system. Thus the emission control systems become more expensive
as the SLA flow increases.
3.2.5.1 Emissions. There are VOC and traces of aerosol emissions
at several points in the finishing or printing operations. The majority
of the solvent used on a flexible vinyl finishing line is driven off in
the drying operation after the inks have been applied to the vinyl web.
These vapors are usually contained in an oven and the oven gases are
drawn through a fan and ducted away from the work area. Solvent vapors
not captured by the drying ovens may be collected by the vapor capture
system. The vapors that are not captured and which escape to the atmosphere
are called fugitive emissions. These emissions are indicated on Figure
3-6 and 3-7 and are further described below.
Uncontrolled emissions for an average size FVCiiP plant are presented
in Table 3-3. Aerosol emissions from the finishing operation of the
average plant are estimated to be less than 0.9 Mg (1 ton) per year and
therefore these emissions will not be considered further.
3-20
-------
TABLE 3.3 ESTIMATE OF UNCONTROLLED FINISHING AND EMBOSSING
EMISSIONS FOR AN AVERAGE PLANT9
Sources
Preparation of coating0
Cleanup0
Printing
Ovens .
Fugitives
Printing subtotal
t.
Embosser
TOTALS
Aerosols
Mg
per year
Negl igible
Negligible
0.9
in above
7
8
Tons
per year
Negligible
Negligible
1
in above
8
9
VOC
Mg
per year
23
29
490
130
620
9
~680~
Tons
per year
25
32
540
140
680
10
"750"
rr9nJ an Average plant are based on estimated 1980 volumes of
FVC&P products and assuming 100 plants. The plant would finish 6 million
square meters (7 million square yards) of supported fabric and 0.9 M
kilogram (2 million pounds) of unsupported sheet. After finishing
the plant would emboss 5 million square meters (6 million square yards)
of supported fabric products. Very little information is available as to
how much unsupported sheet is printed. However, assuming that the printed
unsupported product volume is approximately 40 percent of the supported
product volume, then the VOC printing emissions of 620 Mg (680 tons) per
year would be 0.075 kilogram per square meter (0.139 Ibs'per square
Calculated fpn state and industry estimates of emission factors One
manufacturer states oven emissions cannot be more than 66 percent of
total, or 449 Mg per year. If the printing subtotal is correct this
the OVen *nd 28
c
Emission factors are estimated on basis of process and formulae
information.
d-ru
There is very little data as to the quantity of fugitives emitted durina
the printing operation. This is an estimate basedon observ at ons dur ?n
field trips and engineering judgement. uurin
3-21
-------
The VOC emissions from an average printing operation are estimated
to be 620 Mg (680 tons) per year. The actual amount of VOC emissions in
any given operation will depend upon the quantity of solvents used in
the application of the inks in the finishing operations. However, all
of the solvent used to dissolve the resins ultimately enters the environment
and most of it is emitted during the drying of the inks. There is
very little information on what portion of this solvent is in the oven
gases and what portion is emitted
-------
Most of the emissions occur when the wet web is heated to remove
the solvent and fuse the resin into a continuous film. These solvent
vapors are usually contained in an oven and the oven gases are drawn
through a fan and ducted away from the work area. There is no data to
characterize these oven emissions. They make up 70 to 90 percent of the
solvent entering the print stations depending upon the volatility of the
solvent, coating thickness, exposure time of the wet web to the atmosphere,
residence time in the oven and other process and equipment parameters
such as air flows and temperatures.
The balance of the solvent entering the print station escapes as
fugitives. There are no data available to quantify these emissions.
The estimates presented in Table 3-3 are based on conversations with
plant personnel during nine plant trips.
3.2.6 Embossing
3.2.6.1 Processes. Most FVC&P products are embossed to improve
appearance and wearability. Process details are indicated in Figure 3-7.
The embossing press consists of two basic components: a rubber sleeve
support roller and a embossing cylinder. The image pattern is formed in
the surface of the embossing cylinder by mechanical or chemical means.
The vinyl coated web is heated and continuously drawn between the embossing
and support rollers. As it passes through the cooled rollers, the image
or pattern is set in the hot web surface.
Most FVC&P products are embossed as part of the finishing operation.
The embosser is often installed at the end of the print line as shown in
Figure 3-7. However, many manufacturers transfer the printed sheet to
an embosser located elsewhere in the plant.
Other exceptions are calendered and laminated products. As previously
described most calendered products are embossed with a matte or special
finish as they exit the calender. Also, as previously described some
products are manufactured by laminating an unsupported sheet to a fabric
substrate as a separate operation, and embossing is generally part of
that laminating step.
3-23
-------
3.2.6.2 Emissions. There are aerosol and varying amounts of VOC
emissions, depending on the printing process, from the finishing embossing
operation. These are indicated in Figure 3-6. The aerosols are high
molecular weight organic compounds which condense as they exit with the
stack gases. They are primarily vaporized plasticizers from the heated
coating and web. Aerosol emissions from the embossing operation of an
average plant, would be 7 Mg (8 tons) per year. These aerosol emissions
are highly visible. Hoods are installed over most embossers and state
opacity regulations generally require; new installations to capture and
control these emissions. These small quantities of aerosols are not
considered in the FVC&P NSPS.
3.3 BASELINE EMISSIONS
Existing state regulations applicable to the FVC&P industry are
presented in Section 3.3.1 and the logic and rationale leading to the
selection of the baseline emission level are presented in Section
3.3.2. The baseline emission level is the level of emission control
that would be achieved by the affected industry in the absence of an
NSPS. The baseline emission level is established to facilitate comparison
of the economic, energy, and environmental impacts of the regulatory
alternatives.
3.3.1 State and Local Emission Regulations
Table 3-4 presents a summary of the current state regulations for
volatile organic compound emissions. Twenty states, the District of
Columbia, and Puerto Rico have some farm of regulation to limit the
emission of VOC. All but one of the remaining states have an ambient
air quality standard but no emission limits.
Of the existing state regulations, the most restrictive standard
calls for a maximum of 6.8 kilograms aer day (15 pounds per day) or
1.4 kilograms per hour (3 pounds per hour) for "oven emissions." Oven
emissions are defined as organic materials emitted from coating opera-
tions wherein the coating is baked, heat-cured, heat-polymerized, or
comes in contact with a flame. If these ceiling values cannot be met,
control equipment must be provided to reduce the oven emissions by at
least 85 percent.
3-24
-------
TABLE 3-4. EXISTING STATE REGULATIONS ON EMISSIONS OF VOLATILE ORGANIC COMPOUNDS
APPLICABLE TO THE VINYL COATING AND PRINTING INDUSTRY
OJ
I
Ealaalon Unit*
State
Alabama
Alaska
Arizona
Arkansas
Cal 1 font la
Colorado
Connecticut
Delaware
Florida
Georgia.
Hawaii
Idalio
Illuola
Indiana
low it
Kansas
Kentucky
.out slana
Maine
Ml
Mlusouri
Montana
kR/day
6.8
6.8
6.tt
— — —
^
___
6.8
- —
~—
-—
6.0
(Ib/day) kg/hr
— — — — — ,
15
--
15 1.4
15 1.4
—
— — - .
— — ~-_ _
—
— — _
—
— — _
15 1.4
— — __«.
^-_
-- —
__ — -
— — ..__
15 1.4
—
«.-._
—
(Ib/hr) X Reduction
» — «
— -.— ,
— — —
3 05
3 85
_
—
— «.—
— __
3 B5
_
-»
- --
— _^
_ «.•
1 85
_
_
_
_
—
Notea
i
b
a , c
b
3 . n . p n
» ^ » ^ t y
a
f
i
i
j
b
b
j
e
i
i
i
It
i
.1
k
.
b
j
b
-------
TABLE 3-4. (continued). EXISTING STATE REGULATIONS ON EMISSIONS OF VOLATILE ORGANIC
COMPOUNDS APPLICABLE TO THE VINYL COATING AND PRINTING INDUSTRY
Emission limits
ro
cr>
State
kg/day (Ib/day) kg/hr (Ib/hr) X Reduction
Nebraska
Nevada
Hew Hampshire
New Jersey
Hen Mexico
Heu York
North Carolina -—-
North Dukota
Ohio
Oklahoma . 6.8
Oregon
Pennsylvania ——-
Khode Island —--
South Carolina
South Dakota
Tennessee
Texas ___
Utah
Vermont
Virginia
Washington ——
West Virginia
Wisconsin ———
Wyoming
District of Columbia 6.8
Puerto Hlco 6.0
15
B5
15
15
1.4
1.4
85
Notea
b
b
f
i
i
i
I.
i
a
j
i
.i
i
b
1
b
No regulation
.1
b
b
1
b
f. o
-------
TABLE 3-4. (continued). EXISTING STATE REGULATIONS ON EMISSIONS OF
VOLATILE ORGANIC COMPOUNDS APPLICABLE TO THE
VINYL COATING AND PRINTING INDUSTRY
a) Applies to oven emissions (organic compounds which have been exposed
to a flame or have been heat cured, heat polymerized, or baked).
b) Ambient air standard only.
c) Maricopa County only. Rest of the state calls for "no unreasonable
escape of solvents and use of control equipment where needed."
d) Applies to County of Los Angeles and San Francisco Bay Area APCD.
County by county regulations, most following this pattern.
e) Applies to photochemically reactive solvents, as defined in Rule 66.
f) Total emissions.
g) Applies to AQCR 7 only.
h) Unless equipped with acceptable control.
i) VOC emissions should not exceed 0.45 kilograms per liter (3.8 pounds
per gallon) of coating, excluding water, delivered to the coating
applicator.
j) VOC emissions should not exceed 0.35 kilograms per liter (2.9 pounds
per gallon) of coating, excluding water.
k) VOC emissions should not exceed 0.54 kilograms per liter (4.5 pounds
per gallon), excluding water.
3-27
-------
The current state regulations do not cover the fugitive VOC losses
from vinyl coating applicators/processing, printing/topcoating presses,
solvent cleaning and handling, and ink preparation. These losses can
account for up to 30 percent of a vinyl coating plant's total solvent
7
emissions.
The states that are non-attainment areas for photochemical oxidants
are currently preparing and submitting State Implementation Plans (SIP)
to the U.S. EPA for approval. As required in the Clean Air Act, the
U.S. EPA has published a series of Control Techniques Guideline (CTG)
documents containing information and recommended emission limits for
particular industries. A summary 3f the CTG document for coating of
fabric and vinyl is presented in Table 3-5.18
As a result of the fabric and vinyl coating CTG, some states' SIP
are calling for 90 percent capture of the solvent in the ink and coating
formulations that enter the coating and printing equipment.19 These
same SIP also require 90 percent control of the captured emissions which
results in an 81 percent overall reduction of VOC emissions from coating
and printing processes. This reduction is approximately equivalent
(based on 15 percent solids by volume) to the CTG emission limit of
0.45 kg per liter (3.8 Ib/gal) of coating minus water.
Some states have not used the fabric and vinyl coating CTG to
develop their SIP, but instead have used the CTG document developed for
rotogravure printing because a rotogravure technique is used to print
flexible vinyl. The rotogravure CTG document covers publication and
packaging rotogravure and flexographic printing. A summary of this CTG
document is presented in Table 3-6.20
The flexible vinyl printing industry has been classified under the
packaging rotogravure category. This category requires a 65 percent
overall VOC reduction wherever packaging rotogravure printing is used.
The rotogravure CTG also allows the use of waterborne inks to meet the
specified level of control. If waterborne inks are used, the volatile
fraction 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.11
3-28
-------
TABLE 3-5. SUMMARY OF CTG DOCUMENT FOR COATING OF
FABRIC AND VINYL1*5
Affected
facilities
Fabric and vinyl surface coating lines including the applica-
tion areas and the drying ovens. Fabric coating includes all
types of coatings applied to fabric. Vinyl coating refers to
any printing, decorative, or protective topcoat applied over
vinyl coated fabric or vinyl sheets.
Number of
affected
facilities
Estimated to be 130 facilities nationwide.
VOC
emissions
nationwide
Estimated annual emission from fabric coating operations are
100,000 Mg/yr (110,000 ton/yr. [15] The vinyl segment of
the fabric industry emits about 36,000 Mg/yr (40,000 tons/yr)
VOC from fabric coating represents about 0.4 percent of the
estimated VOC emissions nationwide.
VOC
emission
range per
fac i1i ty
Average annual VOC emissions are estimated to be 850 Mq
(940 ton).
100 ton/yr
source size
Any but the smallest fabric coating facilities should exceed
emissions of 100 ton/yr of VOC.
CTG emission
limit
The recommended VOC emission limits are:
a. Fabric coating 0.35 kg per liter of coating minus water
(2.9 Ib/gal).
b. Vinyl coating 0.45 kg per liter of coating minus water
(3.8 Ib/gal).
VOC
reduction
per facility
The actual percent reduction will vary depending on the sol-
vent content of the existing coatings and the control method
selected. Implementation of the recommended control methods
can reduce VOC emissions by 80 to 100 percent.
Costs
BASIS: 15,000 scfm facility using incineration with primary
heat recovery or adsorption with recovered solvent credited
at fuel value.
Capital cost:
Annualized cost:
Cost effectiveness:
$150,000 - $320,000
$ 60,000 - $ 75,000
$34 - $39 per ton VOC
3-29
-------
TABLE 3-6. SUMMARY OF CTG DOCUMENT FOR GRAPHIC ARTS -
ROTOGRAVURE AND FLEXOGRAPHY
Affected
facilities
(p. 1-D*
Flexographic and rotogravure processes applied to publication
and packaging printing.
Number of
affected
facilities
(p. 2-5)*
Publication printing is done in large printing plants,
numbering less than 50 in total.
There are approximately 13 to 14 thousand gravure printing
units and 30 thousand flexographic printing units.
VOC
emissions
nationwide
(p. 2-8)*
a. Gravure
b. Flexography
100,000 Mg/yr 1976 (110,000 tons/yr)
30,000 Mg/yr 1976 (33,000 tons/yr)
This represents about,0.8 percent of stationary source
estimated emissions.
VOC
emission
range per
f ac i 1 i ty
(calculated)
Gravure
b. Flexography
7.4 Mg/pringin unit per year
(8.;? tons/unit)
L Mg/pringing unit per year
(l.L tons/printing unit per year)
100 tons/yr
source size
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.
CTG
emission
1 imi t
(pp. 1-2,
1-3)*
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 publica-
tion rotogravure process is employed;
b. 65 percent overall VOC reduction where a packaging
rotogravure process is employed; or,
c. 60 percent overall VOC reduction where a flexographic
printing process is employed.
*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.
3-30
-------
3.3.2 Selection of the Baseline Emission Level
The baseline emission level should represent the emission reduction
which has been demonstrated to be achievable by the majority of existing
flexible vinyl printing facilities. Contacts with existing controlled
flexible vinyl facilities and state regulatory agencies indicate that
the 65 percent control level of the packaging rotogravure printing CTG
is being applied to existing facilities in several states. Therefore,
the 65 percent overall control level is selected as the baseline for
this study.
3-31
-------
3.4 REFERENCES
1. Booth, G.L. Coating Equipment and Processes. New York, Lockwood
Publishing Company, 1970. 450 p.
2. Trip report. Laube, A.M. and N.E. Krohn. Radian Corporation, to
file. September 8, 1980. 19 p. Report of July 30, 1980 visit to
Stauffer Chemical Company in Anderson, S.C., (Docket Confidential
File).
3. Schechter, W.I. and E.J. Taylor. Polyvinyl Chloride Sheet and Film
from the Republic of China. (Prepared for U.S. International Trade
Commission.) Washington, D.C. Publication No. 879. April 1978.
p. A-16.
4. Reference 3, p. 9.
5. Letter and attachments from Hall, W.B., Chemical Fabrics & Film
Association, to Goodwin, D., EPA:ESED, August 8, 1980. 53 p.
CFFA vinyl printing operations survey.
6. Letter from Brookman, R.S., Pantosote, to Laube, A.H., Radian
Corporation. December 2, 1980.
7. Trip report. Laube, A.M. and D.T. Smith, Radian Corporation, to
file. November 15, 1979. 22 p. Report of visit to General Tire
and Rubber Company in Columbus,, Mississippi.
8. Letter from Niles, R.W., Uniroyal Inc. to Laube, A.H., Radian
Corporation. December 4, 1980.,
9. Telecon. Krohn, N.E., Radian Corporation, with Weimer, R., Sinclair
& Valentine. February 2, 1981, Conversation about waterborne
inks.
10. Meeting Notes. Laube, A.M., Radian Corporation, with Laundrie, R.,
General Tire and Rubber Corporation. February 5, 1981. Conversation
about waterborne inks.
11. Letter from Niles, W. Uniroyal Inc., to Grumpier, D., EPA.
February 2, 1981.
12. Letter from Laundrie, R.W., The General Tire & Rubber Company, to
Krohn, N.E., Radian Corporation. February 16, 1981.
13. Telecon. Krohn, N.E., Radian Corporation, with Fitzwater, J.,
Polyvinyl Chemicals. January 27, 1981. Conversation about waterborne
inks.
3-32
-------
14. Trip report. Laube, A.M., Radian Corporation, to file. October 10,
1979. 4 p. Report of September 28, 1979 visit to Uniroyal in
Mishawaka, Indiana.
15. Trip report. Laube, A.M. and D.T. Smith, Radian Corporation, to
file. January 27, 1980. 6 p. Report of December 12, 1979 visit
to Stauffer Chemical Company in Anderson, South Carolina.
16. Letter from Ilg, W.G., Columbus Coated Fabrics, to Laube, A.H.,
Radian Corporation. December 5, 1980.
17. Status summary of State Group I VOC RACT Regulations as of March 10,
1980. GCA Corporation. Bedford, Massachusetts. May 1980.
18. Peterson, P.R. and R.R. Sakaida. (Pacific Environmental Services,
Inc.) Summary of Group 1 Control Technique Guideline Documents for
Control of Volatile Organic Emissions from Existing Stationary
Sources. (Prepared for U.S. Environmental Protection Agency.)
Research Triangle Park, N.C. Publication No. EPA-450/3-78-120.
December 1978. p. 2-8.
19. Memo from Laube, A.M., Radian Corporation, to file. October 27, 1980.
25 p. Compilation of state agency contacts.
20. Capone, S.V. and M.W. Petroccla. (GCA Corp.) Summary of Group II
Control Technique Guideline Documents for Control of Volatile
Organic Emissions from Existing Stationary Sources. (Prepared for
U.S. Environmental Protection Agency.) Research Triangle Park, N.C.
Publication No. EPA-450/2-80-001). February 1980. p. 17.
21. Capone, S.V. and M. Petroccia. (GCA Corporation.) Guidance to
State and Local Agencies in Preparing Regulations to Control
Volatile Organic Compounds from Ten Stationary Source Categories.
(Prepared for U.S. Environmental Protection Agency.) Research
Triangle Park, N.C. Publication No. EPA-450/2-79-004. September
1979. pp. 89-101.
3-33
-------
4. EMISSION CONTROL TECHNIQUES
The flexible vinyl coating and printing (FVC&P) industry has
significant emissions of volatile organic compounds (VOC). These
emissions occur throughout the FVC&P plant wherever solvents are handled.
All of these VOC emissions have been characterized in Chapter 3. Only
the VOC emissions associated with the FVC&P finishing processes will be
discussed here. VOC emissions from storage, formulation activities, and
cleanup are not included in this discussion. VOC emissions from solvent
storage tanks are being examined in a separate NSPS background document.
Formulation VOC emissions are already controlled to low levels due to
safety reasons. VOC cleanup emissions are generally low concentration,
low volume sources which are very difficult to capture and control. The
combination of these three emissions sources is less than ten percent of
the total amount of VOC emitted from a typical FVC&P plant.
In the finishing operation VOC emissions result from the evaporative
loss of organic solvent as:
•process emissions (exhaust from drying ovens) and
• fugitive emissions (unintentional solvent evaporation
from the coating operation itself).
The printing and topcoating finishing operations are the principle
sources of VOC emissions in the FVC&P industry. This chapter will
review the technology available for the control of VOC emissions.
There are five basic control technologies used to reduce VOC
emissions. Those technologies are:
• carbon adsorption
• incineration
• wet scrubbing
4-1
-------
• condensation, and
• process modification.
Of these five technologies, only carbon adsorption, incineration, and
wet scrubbing will be discussed in detail in Section 4.1. Although not
used in the FVC&P industry condensation will be described briefly
because it is an innovative technology that has been successfully used
in the fabric coating industry and other related surface coating industries
to control VOC emissions. Process modifications, including changeovers
to low-VOC content (waterborne) ink:;, were covered in Chapter 3.
Carbon adsorption and incineration would be considered equivalent
in overall control effectiveness for reducing VOC emissions from vinyl
coating and printing facilities. The selection of either of these
control methods is dependent upon the specific application. When carbon
adsorption can be applied without unusual operating problems, it usually
holds an economic advantage because of the value of the recovered
solvent.
There are some applications, however, where the cost of auxiliary
equipment necessary to recover and purify solvent would be high enough
that incineration would be given careful consideration. The following
is a list of general factors which would favor incineration (the absence
or converse of these factors would therefore favor carbon adsorption):
• mixture of several solvents (which would require
distillation and reformulation to reuse),
• coatings that give off relatively high levels of entrained
particulates (which might foul and deactivate a carbon bed),
• water soluble solvents (which would require water
treatment or some form of noncondensable regenerant), and
• solvents whose market value approaches their fuel value.
While both carbon adsorption and incineration are equally effective
as emission controls, they are not as effective as process modifications.
Modifications such as waterborne inks hold a distinct advantage because
of the negligible amount or total absence of solvent. This absence or
negligible amount of solvent negate:; the difficult to control fugitive
emission problem. Wherever applicable, alternate coating techniques
4-2
-------
hold a strong advantage in environmental, energy, and economic factors.
These alternate coating techniques have not, however, been sufficiently
developed to replace solvent-based coating in most of the FVC&P industry
applications. The use of solvent systems with control devices is required
throughout the FVC&P industry.
4.1 VOLATILE ORGANIC COMPOUND CONTROL
4.1.1 Carbon Adsorption
Carbon adsorption is a method of reducing VOC emissions by adsorp-
tion of the organic to the surface of activated carbon. The VOC are
subsequently desorbed from the bed and recovered. Carbon adsorption is
a mature technology that has been applied to the control of VOC emissions
from a wide range of industrial processes, including vinyl coating and
printing. Its theory and principles have been extensively covered in
the literature. A very brief discussion of the operation of carbon
adsorption units will be presented here, with emphasis placed on the
specific applications in the FVC&P industry.
4.1.1.1 Operating Principles. Although there are several types of
continuous carbon adsorption units, most existing facilities use multiple
fixed bed adsorbers which are cycled in and out of service. Essentially
this cycling results in each adsorber operating in a batch mode. These
modes are characterized by an adsorption cycle and a regeneration
cycle. The operating discussion will be divided into these cycles (see
Figures 4-1 and 4-2).
In the adsorption cycle, the gas containing VOC is routed to an
adsorber containing freshly regenerated carbon. The VOC is quickly
adsorbed onto the surface of the carbon, and the gas exits with a very
low VOC concentration. As the capacity of the bed to hold VOC is used
up, the exit VOC concentration begins to rise. This is called the
breakthrough point, and it signals the need to switch the adsorber to
the regeneration cycle. Following the switch to regeneration, another
adsorber is moved into the adsorption cycle.
4-3
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BLOWER
'GAS
COOLER PARTICULATE
FILTER
VALVE 1
ADSORBER 1
VALVE 5
t
STEAM
OR ,
HOT GAS
SOLVENT-LADEN
VAPORS
VALVE 2, , 0VALVE4
VALVE 3/ ' T
N
XVALVE 6
VALVE 7
ADSORBER 2
; VALVE 8
SOLVENT RECOVERY
OH DESTRUCTION
EQUIPMENT
. CLEAN EXHAUST
"*" GAS
PROCESS WASTE
GAS
STEAM OR HOT
GAS REGENERANT
V VALVE OPEN
T VALVE CLOSED I
Figure 4
-1. Schematic of two-bed adsorber unit: adsorber 1 adsorbing, adsorber 2 regenerating.
-------
SOLVENT-LADEN
VAPORS
GAS
COOLER
PARTICULATE
FILTER
i
en
STEAM
OR •
HOT GAS
SOLVENT RECOVERY
OR DESTRUCTION
EQUIPMENT
CLEAN EXHAUST
GAS
_ PROCESS WASTE
GAS
•— STEAM OR HOT
GAS REGENERANT
A VALVE OPEN
VALVE CLOSED
Figure 4-2. Schematic of two-bed adsorber unit: adsorber 1 regenerating, adsorber 2 adsorbing.
-------
The important parameters during the adsorption mode include:
•degree of regeneration (or working capacity of carbon),
• VOC inlet concentration (% LEL),
• gas flow rate,
• cycle time,
• temperature of the inlet gas,
• type of solvent,
• type and amount of carbon,
• superficial velocity in the bed, and
• bed pressure drop.
The first six factors affect the variance of day to day operations,
while the latter factors are generally set by the initial design.
There are two basic types of bed regeneration, thermal and low
pressure. Both types are based on increasing the volatility of the
adsorbed organic to the point where it leaves the surface of the carbon.
Low pressure regeneration is best suited to units with very high VOC
loadings, and it is not used to any extent in this industry,. Thermal
regeneration may be accomplished by either steam or other hot gas, with
steam being used in all FVC&P applications. Hot air regeneration can be
attractive when dealing with water soluble solvents.
The regeneration cycle is also illustrated in Figures 4-1 and 4-2.
Steam is introduced to the bed which is loaded with adsorbed VOC. This
results in desorption by both heating the bed and steam stripping. The
combined water and organic vapors are condensed in a heat exchanger and
routed to a storage tank (see Figure 4-3). From storage the solvent/
water solution is sent to a distillation column for final solvent
reclamation.
The important operating variables during regeneration include:
• length of the cycle,
• pressure and degree of superheat of the steam,
• condenser water outlet temperature, and
• use of cooldown, drying, or expansion cycles before returning
the bed to the adsorption mode.
4-6
-------
Steam
Regenerating
Carbon
Adsorption
Unit
Condensed
SolventSWater
_Cool ing Water In
-^Cooling Water Out
». Cooling Water Out
Condenser
Distillation
Column
^ Recovered
Solvent
Wastewater
Figure 4-3. Schematic of Solvent Recovery by Condensation and Distillation
-------
4.1.1.2 Operating Problems. Then; are several areas of operating
problems with carbon adsorption units in the vinyl coating and printing
industry. Among these are:
• nonregenerable compounds fouling the bed,
•recovered solvent contamination,
• solvent/water separation,
• bedfires, and
• corrosion.
Many operating problems are associated with high boiling compounds
fouling the carbon bed. Polyvinyl chloride and other resins present in
coatings tend to be picked up by the collection system. These compounds
can plug and foul the carbon bed of a carbon adsorption unit. Plugging
would decrease bed efficiency, increase steam requirements, and increase
the unit's operating costs. Also, it has been theorized that iron (in
the form of mild steel) used in equipment construction acts as a catalyst
to form high boiling compounds in the carbon bed. One manufacturer
tested this theory in laboratory glassware, and produced more than 20
p
identifiable heavy organics. These heavy organic compounds foul the
carbon beds rapidly, and because of their high boiling nature are not
easily desorbed. This increases steam usage and shortens carbon life.
There are several problems associated with the use of recovered
solvents. Multicomponent systems usually require distillation to
separate the solvent components. The solvent components must then be
reformulated to meet specifications. Even in single solvent systems,
the recovered solvent may not always be suitable for reuse without
further treatment. Trace materials may alter the solvent properties
enough that it no longer meets specifications.
Because of the solubility of MEK in water, the process of solvent/
water separation is an important one in the FVC&P industry. In the
plants surveyed in this study, two methods were reportedly being used
for this separation. They were: distillation in a packed tower or
345
plate column and extraction in a liquid-liquid extraction column. ' '
In plants using distillation the recovered solvent is treated with a
4-8
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desiccant such as calcium chloride to dehydrate it. Adjustment of pH is
also necessary to prevent corrosion of the distillation unit. The pH of
the initial, untreated solvent ranges around 4 to 4.5. Neutral pH
condititon are desired for these systems. The importance of the pH
adjustment should be stressed. A solvent mixture that is too acidic
will result in severe corrosion. If the mixture is alkaline, poly-
merization of the MEK results in formation of solid matter which causes
quality problems and reduces yield.
For plants using liquid-liquid extraction columns, pH adjustment is
performed before any water separation processes begin. Sodium hydroxide
is again used as the treatment chemical. Following pH treatment the
MEK-water solution is sent to an extraction column. The MEK is separated
from the water by solvent extraction with toluene. Toluene is injected
at the bottom of the column and contacted with the MEK-water solution.
An MEK-toluene mixture is removed from the top of the column and water
is drawn off at the bottom. The MEK-toluene mixture is sent to a
conventional distillation column for the separation of the two solvents.
The distillation process recovers MEK and allows toluene to be recycled
to the extraction column.
Most recovered solvent in this industry is reused in the coating
process or used as wash solvent. There are two options for disposing of
recovered solvent that cannot be reused. The first is to sell this
material back to the solvent supplier or an independent firm that
specializes in reclaiming contaminated solvents. Payment for the spent
solvent usually takes the form of a credit against fresh solvent purchases,
and it is typically only about 30 percent of the virgin solvent price.
Another possibility is the use of recovered solvent as a fuel in the
boiler or the drying oven burners. Many of these devices are currently
qas fired, however, and would require burner modifications before being
able to burn the solvent. There is little economic incentive to burn
solvent since most solvents cost a great deal more than fuel oil.
Carbon adsorption is generally economically attractive only if the
recovered solvent can be reused directly.
4-9
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Corrosion is often a problem in carbon adsorption system. Host of
the solvents used in the vinyl coating and printing industry are not
intrinsically corrosive, but corrosive compounds may be formed in the
bed. The process is similar to that previously described in the form-
ation of high boiling compounds. The predominantly used ketone solvents
in this industry can break down in the carbon bed to form various corrosive
acids and peroxides. Corrosion resulting from such byproducts has
caused one major manufacturer to replace much of the mechanical internals
and supports of a carbon adsorption system after only two years of
operation. This manufacturer reported that 0.2 percent of the MEK
solvent passing through the adsorption system broke down to diacetyl
I O
products. Also, processes which use direct-fired heaters may have
problems with adsorbed carbon dioxide. On steam regeneration, the CO 2
combines with water to form corrosive carbonic acid.
Another potential problem is the occurrence of carbon bed fires.
These apparently result from spontaneous ignition of solvent on the
carbon surface. Since adsorption is an exothermic process, it is
possible that heat liberated in a dead spot (with no air flow to cool
it) could rise to the auto-ignition temperature. The occurrence of bed
fires is directly related to; (1) the oxidation properties of the
particular solvent, (2) the air velocity through the bed, and (3) the
design of the tank containing the activated carbon. Fires are predom-
inantly associated with ketone solvents and are most likely to occur
Q
after fresh carbon is added to the beid. Ketone solvents are the
predominant solvent used in this industry. To safely use ketone
solvents continuous monitoring of the following factors is recommended:
(1) the C0/C09 concentration, (2) the outlet adsorber temperature, (3)
9
the steam flowrate, and (4) the performance of the air valves. In the
FVC&P industry most gas streams are humidified prior to entering the bed
*3 A
to minimize overheating of the bed. " The humidity is generally kept
3
above 60 percent.
4-10
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While all of these operating problems mentioned above seriously affect
the economics and ease of operation of carbon adsorption, they can be
overcome. Most of the systems currently operating have only recently been
installed. These modern control devices should have the design features
necessary to solve the problems mentioned.
4.1.1.3 Existing Applications and Performance of Carbon Adsorption.
The industry survey found four carbon adsorption units in operation in the
vinyl coating and printing industry. Most of these units were installed
during the last five years and, therefore, are representative of relatively
modern technology. Two of these units will be described in detail to
illustrate the applicability of carbon adsorption to the FVC&P industry.
Vinyl Coater A installed a new carbon adsorption system in 1977 to
control VOC emissions from their solvent-based vinyl printing operation. The
solvents recovered by the system are MEK, MIBK, acetone, and toluene.
Separation of the solvent mixture is accomplished by dehydrating the mixture
with solid caustic soda and distilling it through three bubble cap tray
columns.
The unit is designed to handle approximately 2130 dry standard cubic
meters per minute (76,140 scfm) of oven exhaust gas. Fugitive emissions
captured by floor sweeps are ducted to the atmosphere. The system is
designed so that the operator could maintain the inlet gas stream at a
concentration of 40 percent of the Lower Explosive Limit (LEL). However, the
plant normally operates at 15 percent LEL. Automatic hydrocarbon sensing
devices activate a warning signal to the operator at 50 percent LEL and the
equipment is shut down at 60 percent LEL.3
The control system consists of two banks of carbon adsorption units
operated in parallel. Each bank is made up of three fixed carbon beds. At
any given time one carbon bed is adsorbing, one is regenerating, and
one is cooling. Cycle change is automatically initiated when the
4-11
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combustible qas monitor (in this case an infrared stack gas analyzer) on
the adsorber outlet exceeds the breakthrough setpoint or when a programed
time interval has elapsed. The inlet solvent-laden air stream is always
filtered, cooled, and humidified before entering the carbon adsorber.
The humidity is kept above 60 percent to minimize overheating of the bed
(which helps prevent bed fires). The carbon beds are regenerated with
steam, and the combined steam/solvent vapors are condensed. The conden-
sate is then decanted with the solvent layer being sent to a distillation
column and the water layer being steam stripped and discharged to a
waste pond.
The system manufacturer has guaranteed an overall carbon bed
recovery efficiency of 98 percent. This results in no more than 5 ppm
of VOC in the exhaust stream for 90 percent of the time and no more than
50 ppm for 10 percent of the time. The average VOC emission rate was
estimated to be less than 3.11 kg (6.86 pounds) per hour.
No major operating problems have occurred in this VOC control
system. Only routine maintenance procedures have been reouired on the
system. Although it has not caused any system operational problems, the
plant does have some carryover of plasticizer material into the solvent
recovery system. ' Plasticizer material is being entrained in the
gas stream entering the carbon adsorption device. The material does not
plug the carbon bed because it is desorbed during the bed's regeneration
cycle. Following desorption from the carbon bed, the plasticizer
material is transmitted into the distillation system. Wastewater
discharged from the. distillation column contains varying anounts of the
plasticizer material. The plasticizers are recovered by decanting the
water. The company currently secures the plasticizer material in
storage drums and landfills it.
Vinyl Coater B is also operating a carbon adsorption system for VOC
reduction, however, this system attempts to control both oven and fugitive
emissions. The system was installed in 1979 to control MEK solvent
emissions from a 76.2 centimeter (30 inch) wide vinyl printing line.
4-12
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The carbon adsorption unit is desinned to handle inlet solvent-
laden air flows of 220 dscm/nin (8,000 scfm). The concentration in the
inlet gas stream was designed to be approximately 4500 ppm MEK (25% LEL).
With these operating conditions, the carbon bed has a vendor guaranteed
minimum removal efficiency of 95 percent. The adsorption system has a
solvent recovery capacity of 363 kq (800 Ibs) per hour.
Vinyl Coater B uses two fixed bed adsorbers to recover solvent.
Each bed contains 2700 kg (6000 Ibs) of activated carbon. Prior to
entering the carbon beds, all solvent-laden air is filtered, cooled, and
humidified. One unit is always on line adsorbing for a 55 minute cycle.
The regeneration cycle of the other unit is 45 minutes (allowing ten
minutes for cooling). Approximately 907 kg (2000 Ihs) of steam per hour
at 2 psig are used to regenerate the solvents. Following regeneration
the solvent/steam mixture is condensed, adjusted for pH, and sent to a
storage tank. From storage the solvent/water solution is sent through a
distillation column and from there to a calcium chloride dehydration
12
unit to purify and recover the solvent components.
The wastewater discharges from the carbon adsorption and distilla-
tion systems used in the flexible vinyl printing industry represent
potential sources of secondary environmental impacts. Depending on the
particular situation being controlled, wastewater discharges from these
systems would contain varying amounts of dissolved VOC.
Industry representatives have indicated that the BID cost analysis
in Chapter 8 should include costs to cover the treatment of these wastewater
discharges. No costs have been included for this purpose because none
of the FVC&P plants currently operating carbon adsorption/distillation
solvent recovery systems have reported any instances where such treatment
of this wastewater stream is performed. The BID analysis suggests that
the wastewater stream can be used as boiler feedwater. It is recognized
that such wastewater streams may need to be deaerated and treated before
reusing them in a boiler. If such boiler water treatment is not available
or adequate, then the condensate could possibly be used as make-up for
water cooling towers. Manufacturers in this industry are currently
4-13
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discharging these wastewaters to municipal sewers without local penalties
or surcharges.
Local regulations may require treatment now or in the future. In
such cases several low cost options are available. The recovery and
solvent purification methods should be1 selected after considering the
requirements of local water regulations.
These two examples illustrate the1 range of carbon adsorption
applicability to the vinyl coating and printing industry. In other
cases, however, other control options may be more attractive from an
economic viewpoint. The ability to reuse the recovered solvent is the
key issue in the economic assessment. Although there are a number of
potential operating problems associated with carbon adsorption, these
problems have been overcome in several industrial applications of this
technology. Where carbon adsorption is economically attractive, it
presents a good control option in terms of both environmental factors
and resource conservation factors.
4.1.2 Incineration
The process of incineration involves the oxidation of organic
pollutants to carbon dioxide and water. Incineration has been used
extensively as an emission control technology in many industries, but
not in the FVC&P industry. It is a mature and well-documented technology.
This section presents a brief discussion of incinerator operation with
emphasis on those factors that affect its application to FVC&P emissions
because it may be considered for future applications.
4.1.2.1 Operating Principles. n"he operating principle of incinera-
tion is basically just oxidation (or burning) of the pollutants. In
thermal incineration, this is accomplished by raising the solvent-laden
air temperature to 540 to 820°C (1000 to 1600°F) or exposing same to a
13 14
direct flame, both for a period of 0.3 to 0.75 seconds. ' The percent
of VOC (solvent) destruction as a function of temperature has been well-
documented. Figure 4-4 shows the EPA's estimates of VOC reduction
versus firebox temperatures. Similar results can be achieved by
catalytic incineration at lower temperatures (400° to 540°C or 750° to
4-14
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100
HYDROCARBONS
ONLY
HYDROCARBON AND CARBON
MONOXIDE (PER LOS ANGELES
AIR POLLUTION CONTROL
DISTRICT RULE 66)
UJ
50
1150
1200
1250 1300 1350 1400
TEMPERATURE, °F
1450
1500
1550
Figure 44. Typical effect of operating temperature on effectiveness of thermal afterburner
for destruction of hydrocarbons and carbon monoxide.
-------
1000°F). In this study only one FVC&P manufacturer was identified
that operated an incinerator for VOC control. The estimated destruction
of VOC from this unit was 99 percent.3
Typical thermal and catalytic incinerators are shown in schematic
form in Figures 4-5 and 4-6, respectively.
The factors important to incinerator design and operation include:
• type and concentration of VOC,
• gas flow rate,
• preheat temperature,
• firebox temperature,
• supplemental fuel rate,
• residence time,
• efficiency of flame contact,
• burner type, and
• amount of excess air.
The first four factors are the primary operating variables, and they
determine the fifth factor, the rate of supplemental fuel firing. The
remaining factors are design parameters and are subject to variations on
a day to day basis.
Heat exchange equipment could be considered an optional accessory
to the incinerator system, but with rising fuel prices, it has almost
become a necessity. Heat recovery equipment is generally divided into
primary and secondary recovery. Primary heat recovery is defined as the
exchange of heat between the hot incinerator effluent and the relatively
cool process waste stream. Secondary heat recovery is defined as any
further exchange between the incinerator effluent and another process
s tream.
In describing a heat recovery system, the term efficiency is often
used. This should be the thermodynamic efficiency of the system, or in
other words, it represents the percent of available energy that is
recovered. For a single air-to-air heat exchanger, this thermal efficiency
may be approximated by:
4-16
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I
-J
PRIMARY HEAT
RECOVERY
1
PROCESS
SECONDARY HEAT
RECOVERY
INCINERATOR
SUPPLEMENTAL FUEL
- AIR
TO ATMOSPHERE
Figure 4-5. Incineration with primary and secondary heat recovery.
-------
oo
BLOWER
TEMPERATURE
I SENSOR/CONTROLLER
FUEL
BURNER
CATALYST
BED
WASTE STREAM INLET
EXHAUST
Figure 4-6. Schematic diagram of a catalytic incinerator.
-------
Exchanger Efficiency =32
T1-T2
where T, = Inlet Temperature - Hot side
T2 = Inlet Temperature - Cold side
T- = Outlet Temperature - Cold side
Primary heat exchanger efficiencies (using standard tube and shell
heat exchangers) are limited to about 45 percent efficiency not by heat
exchanger design, but by safe operating practice. At 25 percent of the
LEL, a temperature rise of up to 380°C (680°F) can occur on combustion.
A maximum operating temperature of 820°C (1500°F) is typically specified
to protect the incinerator and the heat exchangers.16 This then limits
the incinerator inlet temperature to about 440°C (790°F). This incin-
erator inlet limitation then limits the potential primary heat recovery
efficiency. This also minimizes the possibility of auto-ignition of the
waste stream in the primary heat exchanger. These primary heat recovery
limitations are based on a concentration of VOC at 25 percent of the
LEL. For lower concentrations, the safe limit for primary heat recovery
increases. Below 5 percent of the LEL, 100 percent heat recovery would
be safe, but technologically impractical.
Primary heat recovery in a catalytic incineration system is limited
to a lower temperature by catalyst sintering and deactivation. The
available heat in the incinerator exhaust is also lower, however,
because of less sensible heat in the low temperature combustion prod-
ucts. This results in about the same primary heat recovery efficiency
as thermal incineration.
Secondary heat exchange recovers waste heat for use in other
processes in the plant. This energy may be used for process air heat
requirements or for plant space heating. In coating facilities, sec-
ondary heat recovery could be used to heat inlet air to the drying
ovens. Heat exchanger efficiencies in secondary heat recovery are
typically in the 50 to 55 percent range.17 Assuming a primary heat
4-19
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recovery efficiency of 35 percent, this would yield an overall heat
recovery efficiency of 70 to 80 percent.
It is possible for the energy recovered from solvent incineration
to provide all of the energy needed for the incinerator and the drying
oven, with supplemental fuel required only for a small pilot burner to
prevent flame-out. This is, of course, highly dependent on the concen-
tration of the VOC in the oven exhaust. No supplemental fuel will be
required to incinerate air streams at 40 percent LEL or higher, while a
more conventional concentration of 25 percent LEL will almost always
require supplemental fuel. The exact break-even point will vary with
solvent type and the desired firebox temperature. The maximum percent
LEL is normally dictated by the company insuring the oven.
It should be pointed out that even for lower concentrations where
some supplemental fuel is required, additional heat is available in the
stack gases for further heat exchange. This is dependent on the avail-
ability of another heat requirement in the immediate area. Some pos-
sibilities for additional secondary heat recovery would include space
heating for the building, boiler combustion air preheat, and oven heat
for other coating lines. If the heat in the incinerator exhaust were
used to the fullest extent, a net energy savings over the uncontrolled
situation would result even if the incinerator requires supplemental
fuel.
4.1.2.2. Operating Problems. While incinerators are simple,
reliable, and not prone to extensive operating problems, some of the
potential problem areas include:
• fouling of heat transfer surfaces,
• corrosion,
• catalyst poisoning,
• secondary emissions, and
• high operating cost with low LEL gas streams.
The fouling of heat transfer surfaces is not a problem during
incineration of VOC gas streams. These VOC streams exit from the
printing and topcoating ovens and contain essentially zero particulates.
4-20
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Halogenated hydrocarbon solvents will produce highly corrosive
compounds when combusted. This problem is not significant in the FVC&P
industry because halogenated hydrocarbon solvents are seldom used. An
additional cause of corrosive atmospheres is the firing of supplemental
fuels with a high sulfur content.
There are more potential problems with catalytic incineration than
with thermal. The most serious of these problems is catalyst poisoning
or deactivation. Some common catalyst poisons include phosphorous,
1R
bismuth, arsenic, antimony, mercury, lead, zinc, and tin. Caution
should be used in a catalytic incineration system concerning the use of
phosphate metal cleaning compounds and galvanized ductwork.
A second problem in catalytic incineration is one of particulate
matter. Combustion efficiency is reduced by inhibited contact between
the catalyst active sites and the pollutant gases due to particulate
buildup on the catalyst bed. Also, pressure drop is increased which
increases utility requirements of the blower.
Any combustion source can potentially cause emissions of unburned
hydrocarbons, carbon monoxide, and nitrogen oxides. The emission levels
of these secondary pollutants should be very low considering that an
incinerator is designed specifically with complete combustion as the
objective. The typical operating temperatures of incinerators in the
FVC&P industry will not promote significant oxidation of nitrogen in the
combustion air to nitrogen oxides. Therefore the magnitude of any
secondary pollutants from incineration is outweighed by the benefits of
VOC reduction.
Dilute VOC streams can cause increased operating costs for incineration
units. Dilute streams result from air leakage into the gas ducting
systems, the dilution of oven gases with other process gases, or poor
turndown in process ovens. Air leakage can be minimized by proper
maintenance of ducts and ovens. The dilution of solvent-laden, oven
gases occurs when dilute VOC streams, such as those from fugitive
control equipment or curing oven zones, are combined directly with the
4-21
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drying oven gases. This problem can be minimized through efficient oven
design where dilute VOC streams are used as makeup air to solvent drying
zones in the oven.
A major operational problem with using incinerators cm flexible
1 q
vinyl printing lines is the 40 to 60 percent downtime inherent in the
printing operation. This high downtime is a result of: short production
runs (many pattern changes), a need for consistent color matching, and a
need for precise color and pattern registration. The operation of an
incinerator at these 40 to 60 percent downtime conditions would be very
inefficient and very costly because of the need to provide large amounts
of supplemental fuel. However, in the absence of concentrated VOC going
to the incinerator (during downtimes), supplemental fuel would be required
to keep the incinerator running at an adequate solvent destruction
temperature. The temperature of the incinerator cannot be allowed to
drop (during downtimes) because once the line is operating again and
emitting VOC, the incinerator cannot respond quickly enough from cold
status to achieve solvent destruction temperatures.
4.1.2.3 Existing Applications and Performance of Incineration.
The industry survey indicated that only one FVC&P facility uses an
incinerator to control VOC emissions,, The incinerator used by Vinyl
Coater A is not designed to control VOC emissions from vinyl printing
operations. The primary function of the incinerator is to control VOC
emissions from an accompanying pressure sensitive adhesive coating line
used to produce the final product. The incinerator can be used for VOC
control of the vinyl lines if the carbon adsorber, normally used,
malfunctions.
This thermal incinerator is designed to handle 550 dscm/min (19,700
scfm) of solvent laden air. It operates at 760°C (1400°F) and is expected
to achieve a 99 percent destruction rate of VOC. Natural gas is predominantly
used to fire the incinerator, but No,. 2 fuel oil can also be used.
Currently, this manufacturer does not recover any heat from the incinerator,
3
although the idea is under consideration. No major operating problems
have occurred with the incineration system.
4-22
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One other major manufacturer in the FVC&P industry is considering
the installation of a thermal incinerator to control VOC em'ssions.
Incineration is being considered instead of carbon adsorption because
the LEL need not be as high as for solvent recovery methods, mixed
solvents can be handled easily, and energy recovery benefits are possible.20
4.1.3 Wet Scrubbing
Wet scrubbers or wet collectors are in prominent use as air pollution
control devices in many varied industries. The theory and technology
behind wet scrubbing is well-developed and well-documented in the
literature. Most simply a scrubber is a device which uses an aqueous
stream or slurry to remove particulate matter and/or gaseous pollutants
from an industrial process gas stream. In the vinyl coating industry
scrubbers are used to control VOC emissions from flexible vinyl printing
lines.
The survey of the vinyl coating and printing industry found three
companies using wet scrubbing techniques to control VOC emissions. All
three companies use packed tower or packed column scrubbers to reduce
their VOC emissions and to control a related odor problem. The follow-
ing sections, therefore, explain the general operation of packed column
scrubbers for VOC control and their specific applications in the FVC&P
industry.
4-1-3-1 Operating Principles. Packed columns are vertical structures
containing manufactured packing elements such as raschig rings, spiral
rings, lessing rings, berl saddles, and intalox saddles.21 The columns
control gaseous pollutants (solvent vapors) by absorbing them in a
liquid medium. Solvent removal is initiated when the polluted gas
stream enters the distributing space at the bottom of the column (below
the packing area) and flows upward through the packing interstices. As
the gas flows up through the packing, a scrubbing liquid is introduced
at the top of the column and flows down over the packing counter to the
qas flow. When the gas and liquid streams contact, the gaseous pollutants
are absorbed into the liquid from the gas. The packing material aids in
the absorption process by providing a large contact area between the
4-23
-------
liquid and gas streams. Figure 4-7 illustrates the arrangement of a
22
typical packed column scrubber.
Figure 4-8 illustrates the various types of packing elements used
23
in conventional packed columns. Packings are used to increase column
stability, to reduce liquid channelling, and to increase surface area
pi
utilization. Packing elements generally vary in diameter from 0.65 cm
(0.25 in) to 7.6 cm (3 in). As the size of packing elements increases,
the area of wetted surfaces decreases; thereby resulting in an effi-
ciency reduction. The more desirable properties of packing elements
are given below:
•high surface area per unit volume,
•high ratio of effective area to total area,
•high percentage of free space,
• irregularity of shape,
• favorable liquor distributing qualities,
• low pressure drop, and
• durability.21
Another factor affecting VOC reduction is the method of liquid
pr
distribution inside the column. Plates stationed in the packed column
determine the efficiency of distribution. If the absorbing liquid is
not evenly distributed at the top of the packed column, the VOC control
efficiency will be considerably reduced. As the liquid flows down the
column, it tends to flow towards the side walls. To counteract this
occurrence and to maintain column efficiency, liquid redistribution
24
systems are used.
The primary reasons packed column scrubbers are used for VOC
control include the following:
• high absorption efficiency,
•inexpensive corrosion resistant construction,
•extensive application experience,
• simplicity of installation, and
O/T
• availability in standard sizes.
4-24
-------
Clean
Gas
Outlet
Liquid
Inlet '
1 \ s
Gas
Inlet
-Demister
•Liquid Spray
Distributor
"-Packed Bed
Plate
=0—Overflow
-Liquid Storage
J3-—-Pump Suction
Drain
Figure 4-7, Typical Packed Column Scrubber
4-25
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Raschig
Ring
Lessing
Ring
Cross-Partition
Ring
Single Spiral
Ring
Ring
Double Spiral Tn-ple $piral
$addle
Intalox Saddle
Ring
Figure 4-8. Common Packings Used In Packed Column Scrubbers
4-26
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4-l-3-2 Operating Problems. Packed column scrubbers have to be
operated within a narrow range of conditions to avoid maintenance
problems. If either the liquid or gas flow rates are accelerated, the
loading point of the column is eventually reached. The loading point is
defined as that point at which liquid hold-up starts increasing, thereby,
resulting in increased pressure drop across the column. The acceleration
of gas velocities beyond the loading point will cause a flooding condition.
Flooding conditions generally cause high pressure drops and the entrapment
of absorption liquid in the gas stream.24
In some applications of packed column scrubbers the build-up of
solids in the packing becomes a serious operating problem. Solids in a
column can be caused by particulate material in the gas stream and by
absorption reaction precipitates.24 Clogged packings could disrupt even
liquid distribution and consequently lower the column VOC absorption
efficiency. Cleaning solids build-up in most packed columns is difficult
due to the inaccessibility of the column internals. Solids build-up is
generally not a problem for packed columns used in the FVC&P industry.
4.1.3.3 Existing Applications and Performance of Wet Scrubbers.
Three applications of wet scrubbers for VOC control were found in the
FVC&P industry survey. Two of these cases will be discussed so as to
demonstrate the applicability of this control method in the FVC&P
industry.
Vinyl Coater Y prints and laminates purchased vinyl sheet to
produce shower curtains and table cloths. Chlorophenol, MEK, and MIBK
are the primary solvents used to formulate the company's printing inks.
In a totally uncontrolled status the plant emits 6.3 kg/hr (13.8 Ib/hr)
of MEK, 0.22 kg/hr (0.48 Ib/hr) of MIBK, and 0.012 kg/hr (0.027 Ib/hr)
of Chlorophenol. Because of solvent emissions the plant has a discernible
odor problem beyond their property line. In 1975 the company installed
a wet scrubbing system to control these solvent emissions.27
The control device installed by the plant was a cylindrical, single
stage, vertical packed column scrubber. The MEK, MIBK, and Chlorophenol
vapors are removed from the gas stream by absorption in chemically
4-27
-------
treated water. The water is treated with caustic soda and sodium
hypochlorite for odor control purposes. Generally about 45 liters (12
gallons) of water are used per 28.3 cubic meters (1000 cubic feet) of
gas. The liquid recirculation rate in the absorption column is about 90
27
to 95 percent.
The scrubber is designed to handle 260 dscm/min (9300 scfm) of air
at a temperature of 29°C (85°F). The; design gas velocity of the unit is
1.5 m/sec (5 feet/sec). The overall scrubbing efficiency is about 90
percent. The waste scrubber liquid, containing the solvents, is diluted
27
with other sewer water and is discharged to a municipal sewer.
Vinyl Coater Z also prints and laminates PVC film in a manner very
similar to Vinyl Coater Y. The solvents used by Coater Z include MEK,
MIBK, and toluene. Before controls were installed in 1973 the plant was
emitting about 23.6 kg/hr (52 Ib/hr) of ketone solvents and 14.5 kg/hr
(32 Ib/hr) of toluene. Complaints about plant odors beyond the property
line were also a problem.
The VOC control system of Coater Z consists of an air ventilation
system operated in conjunction with a wet scrubbing device. On the
print lines a system of slot type ducts provides an air sweep over the
coated fabric rolls and the coating application areas. In this plant
the air sweeps from three printing machines are ducted together and sent
to the scrubber. The scrubber is a two stage, cross flow packed device
designed to handle 390 dscm/min (13,800 scfm) of solvent-laden air at an
inlet temperature of 24 to 27°C (75 to 80°F). Stage one of the scrubber
recirculates a dilute aqueous alcohol solution, while stage two recircu-
lates a dilute aqueous solution of an emulsifying agent. A diagram of
the scrubber is shown in Figure 4-9.
The scrubber is designed to remove MEK, MIBK, and toluene vapors
from the entering air stream by absorbing them in water to which ali-
phatic alcohol has been added. Alcohol is added to increase solubility,
especially of MIBK. Toluene vapors are solubilized in a dilute emulsi-
fying agent solution. In stage one of the scrubber about 34 liters/min
(9 gal/min) of liquid are required per 28.3 cubic meters (1000 cubic feet)
4-28
-------
Figure 4-9.
Dfagram Of A Two Stage, Cross Flow
Packed Scrubber
4-29
-------
of solvent-laden gas. In stage two (toluene removal), only 26.5 liters/min
(7 gal/min) of liquid are needed for every 28.3 cubic meters (1000 cubic
feet) of air to be cleaned. The efficiency of the scrubbing device is
90 percent. No data on overall plant VOC reductions were available.27
The amount of waste scrubber liquid that is discharged from this
facility into a municipal sewer is very small. The discharge load is
reduced because the facility continually recycles the majority of the
water used by the scrubbing system. Only a small bleed off stream of
two gallons per minute is discharged from the system into a municipal
sewer. The remainder of the scrubber liquid goes into a recycle tank,
where after the addition of treatment chemicals, it is pumped back to
the scrubber for reuse.
4.1.4 Condensation Systems
Condensation is a VOC control technology which may also be applied
to vinyl coating and printing operations. This technology could be
applicable to control drying oven VOC emissions, but generally not
fugitive VOC. One major manufacturer of printed vinyl has stated that
they are installing inert air condensation systems on two print line
ovens as a retrofit technology to meet state VOC standards.28 No other
commercial vinyl coater identified in this survey is using a condensa-
tion system to control VOC emissions. However, in 1979 a condensation
system vendor performed pilot plant tests on a fabric coating facility
to determine an overall recovery efficiency figure for a solvent-based
surface coating operation. In these tests the condensation system
itself had a recovery efficiency of 99.9 percent.29 By using the
condensation system, operating costs at the pilot facility were reduced
more than 70 percent below what would be expected from a conventional
solvent drying oven system. Savings were achieved by:: 1) eliminating
the energy needed to heat dilution air, 2) lowering the energy consump-
tion of the oven, and 3) receiving a credit for recovered solvent.30
The fabric coating company plans to scale up the pilot program to control
their commercial lines by early 1980.
4-30
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4.1.4.1 Operating principles. Inert gas condensation is an emerging
solvent recovery technology. Although most companies offering this
technology have their own proprietary recovery processes, a general
description of condensation systems can be made. Figure 4-10 shows a
?9
typical condensation system design currently being marketed.
Nitrogen is used as the inert gas in many of these condensation
systems. Gaseous nitrogen is used to provide inert oven atmospheres and
liquid nitrogen is employed as a refrigerant for condensation purposes.
The inert oven atmosphere means all oxygen has been displaced from the
system. The removal of oxygen allows the web to dry in an inert, non-
flammable atmosphere with solvent concentrations much higher than those
allowed in a conventional drying oven system.
Initially in the drying process the coated web enters the inert
oven atmosphere. Heat and recirculated inert gases are used to dry the
solvent from the coated web. Upon drying, a portion of the inert qas
containing highly concentrated solvent vapors is ducted to a solvent
recovery vessel. In the vessel liquid solvent is recovered by condensation
in several stages of heat exchange. If necessary a final stage of heat
exchange uses liquid nitrogen refrigeration to accomplish the desired
30
recovery. Recovery rates of 99 percent are attainable. The inert gas
which has been stripped from the solvent is reused to keep the oven
atmosphere balanced and inert. Inert qas vaporized from the liquid
refrigerant is also used for balancing purposes.
To successfully use inert gas condensation the oven must be sealed
from outside air, dust, and moisture. Oven sealing is generally accom-
plished through the use of nitrogen gas curtains. These curtains prohibit
any leakage into the system, but a small quantity of nitrogen flows out
of the oven. This necessary sealing process would limit the application
of the condensation method to only drying oven emissions because captured
fugitive emissions could not be ducted into the system. Condensation
systems could not be used to achieve some of the regulatory alternatives
presented in Chapter 6 because of the inability to control fugitive
emissions. Because the drying oven is sealed and ventilation prohibited,
4-31
-------
-pi
r . %
po
UNWIND
INERT GAS
RECOVERED
SOLVENT
WEB
CONDENSATION REACTION
AND
INERT GAS
EVAPORATION
AIR
HEATER
GAS FLOW
INERT ATMOSHERE
REFRIGERANT
SUPPLY
DRYING OVEN
WIND
Figure 4-10. Diagram of an Inert Gas Condensation Solvent Recovery System29
-------
the drying atmosphere can readily be contained and recirculated. The
internal recirculation allows heat energy to be maintained and solvent
concentrations to rise. Heat is required only as is needed to evaporate
the solvent and dry the product. Impingement velocities and the oven
flow rate are then independent of heating and may be, according to
29
system manufacturers, increased at no cost.
One of the primary benefits of inert gas condensation systems is
that they save energy. Manufacturers of these systems claim savings of
30
40 to 90 percent depending on the type of coating being applied. The
higher 90 percent figure applies where very light paper or plastic film
substrates are being heated. The coating of materials like heavy-gauge
steel will result in lower savings. Energy is saved because large
volumes of oven dilution air do not have to be heated and drawn through
the oven.
The main drawback to inert condensation systems is that they can
only be used on webs that generally do not break (metal, fabric, or
heavy paper or plastic). When a web breaks in a drying oven, operators
must go into the oven and repair the break. To do this in inert systems
the oven must first be purged of the inert gas atmosphere. This procedure
is very costly and time-consuming to the operator. This limitation
hinders the use of these solvent recovery systems on some high speed,
thin web operations.
4.1.5 Vapor Collection Systems
The design of the vapor collection system is very important to the
overall emission reduction from a given facility. Control equipment can
only recover or destroy those emissions which are captured and routed to
it. Fugitive emissions escape directly. Only proper collection system
design can minimize these fugitive emissions. Fugitive VOC emissions
from flexible vinyl printing facilities occur from: evaporated solvent
in the ink troughs, the exposed part of the gravure printing cylinder,
and exposed portions of the coated vinyl web prior to entering the
drying oven.
4-33
-------
An efficient collection system should maximize the capture of
fugitive emissions while minimizing the capture of dilution air. Since
these are opposing functions, there should be an optimum degree of
collection. This section will identify those factors important in
collection system design, and qualitatively address the optimum degree
of collection.
The factors important to the efficiency of a collection system
include:
• degree of turbulence,
• capture velocity,
• selectivity of collection, and
• degree of containment.
Although these factors are interdependent, each one will be discussed
separately.
It is obvious that turbulence in the air around a fugitive emission
source will make effective collection much more difficult. Sources of
turbulence that should be recognized and minimized (within operating
constraints) include:
• thermal air currents,
• machinery motion,
• material motion,
•operator movements,
• room air currents, and
• spot cooling and heating of equipment.
The velocity necessary to collect contaminated air and draw it into
an exhaust hood is called the capture velocity. At capture velocity,
the inflow of air to the hood is sufficient to overcome the effects of
turbulence and thereby minimize the escape of contaminated air. Empirical
testing of operating systems has been used to develop the guidelines for
capture velocity presented in Table 4-1.3*
The selectivity of a collection system is as important as its
overall efficiency. Selectivity describes the ability of the collection
system to capture pollutants at their highest concentration by mini-
4-34
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-Table 4-1. RANGE OF CAPTURE VELOCITIES
Condition of dispersion of
contaminant
Released with little velocity
into quiet air
Released at low velocity into
moderately still air
Active generation into zone of
rapid air motion
Released at high initial velocity
into zone of very rapid air motion
Capture velocity m/s (fpm)
.25 - .51 (50-100)
.51 - 1.02 (100-200)
1.02 - 2.54 (200-500)
2.54 - 10.2 (500-2000)
4-35
-------
mi zing the inflow of clean air. A highly selective system will require
less power to achieve a given collection efficiency, and the high
concentrations can have a great benefit in the subsequent treatment of
the collected vapor.
One method of improving selectivity is the use of flanges in hood
design to minimize air flow from areas of low concentration. This
technique can reduce dilution air by as much as 25 percent.32
Flanges can also lower the pressure drop at the hood by altering
its coefficients of entry (Cj. The value of C is a measure of the
C c
degree of turbulence caused by the shape of the opening. A perfect hood
with no turbulence losses would have a C equal to one. Table 4-2 gives
0-3
coefficients of entry for selected hood openings.
The final and potentially the most important factor is the degree
of containment that the collection system has around the source of
emissions. Ideally that source should be isolated in an air tight
container with all air exhausted into the collection system.
Several alternate hood designs are available for capturing vapors
heavier than or about the same specific gravity as air. The first of
these is the floor sweep, which, as the name implies,, is a hood that
takes suction near the source at floor level. Here again the web to
hood distance is too large for very efficient collection. The slotted
hood design remedies that. Here a slotted duct is run along each edge
of the exposed web and draws air across the web into the hood.3^ In
both the slotted duct and vacuum blanket controls, the captured VOC can
be routed back into the drying ovens.
Routing or recycling VOC back into the drying ovens is a very
efficient method of operating a VOC capture and control system. By
recycling a VOC-laden air stream back into the drying ovens, higher VOC
concentrations (as % LEL) can be maintained. Higher VOC concentrations
being sent to the control device will result in better performance
efficiencies and lower energy costs (when incinerators are used).
4-36
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Table 4-2. COEFFICIENTS OF ENTRY FOR SELECTED HOOD OPENINGS
Hood Type
Description
^
PLAIN OPENING
.72
FLANGED OPENING
.82
BELL MOUTH INLET
.98
4-37
-------
Many variations or designs of VOC recycling are possible depending
on the particular configuration of the print line. A typical recycling
arrangement is shown in Figure 4-11. A portion of the VOC-laden air
stream being exhausted from the drying oven is drawn off and sent to a
burner for reheating. The heated VOC-laden air is reintroduced into the
oven and can be used to dry the coated, wet web. By using recycled air,
the VOC concentration to the control device can be increased because no
additional outside air has to be brought into the oven. Additional
outside air would dilute the VOC concentration below the level that 25 percent
LEL to the control device could be maintained.
Another method that potentially could be used to obtain high VOC
capture efficiencies is total containment of emissions. Total containment
means that all print lines are enclosed in a room or structure which is
maintained at a slight vacuum by drawing all required oven air from
inside the room or structure. A booster blower would be used to move
oven air exhausts on to a control device. This results in drying ovens
which operate at a slight negative pressure with respect to the coating
room. This type of totally contained collection system can approach
100 percent efficiency without diluting the VOC-laden air stream going
to the control device.
In contrast to totally enclosing the coating line (or coating
room), some continuous web surface coating industries only enclose their
coater to contain fugitive emissions. One of these companies is involved
in coil coating operations and the other in zinc oxide paper coating.
Each operation uses a totally enclosed structure around their coater.
The structure itself contains the majority of escaping fugitives. Fans
and hoods inside the enclosure are used to vent the fugitive emissions
or "3f.
to the ovens and from there on to a control device. '
All web coaters using total enclosures reported satisfaction with
their systems. No problems arose in connection with the operation of
the coating line. In addition to capturing the fugitives for environ-
mental purposes, the enclosure also acts as a safety mechanism. It
reduces the potential for explosions and other hydrocarbon-related work
4-38
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-p.
I
OJ
Coated Web
Fresh Air
Makeup
BlowerO
Recircul^tion
Loop
Burner,
Oven Exhausts
to Control Device
VOC-Laden Air
Drying Oven
Figure 4-11. Basic Method of Recycling VOC-Laden Air Back to the Drying Oven
-------
area problems. Through proper technology transfer, the vinyl coating
and printing industry should be able to capture their fugitive emissions
in a similar manner.
Although it does not use a total enclosure technique, the best
controlled facility in the FVC&P industry has been designed and equipped
with a very effective emission capture system. In this system each
printing head and its associated dryer have been designed in conjunction
with each other to achieve high levels of VOC emissions capture. This
facility concentrates particularly on capturing fugitive VOC emissions.
The ink supply drums and the ink pumping systems to each print station
are closed, thereby greatly reducing fugitive VOC emissions from a print
station. The near complete enclosure of the gravure rollers and the
wet, coated web further reduces fugitive emissions from the print station
area.12
Each print station is equipped with a drying plenum which extends
down from the drying oven to just above the rotogravure rolls. This
plenum captures fugitive VOC emissions evaporating from the wet web as
it is being dried. The amount of wet web exposed to the atmosphere is
greatly reduced by the drying plenum. Despite the attentions given to
emissions capture at this facility, excellent visibility of the process
and easy access to the coating equipment are maintained by the use of
i o
large, movable plexiglass covering panels. The vapor capture system
was determined to be 90 percent efficient in capturing VOC emissions
from the facility's flexible vinyl printing line.
4-40
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4.2 REFERENCES
1. Breed, L.W. Report for Pressure Sensitive Adhesives-3M, St Paul MN
EPA Contract No. 58-02-1399. October 15, 1976. '
2. Trip Report. Harris, G.E., Radian Corporation, to file. July 27,
1978. Report of visit to Anchor Continental, Incorporated in
Columbia, South Carolina.
3. Trip report. Laube, A.M., Radian Corporation, to file. January 27
1980. 6 p. Report of visit to Stauffer Chemical Company in '
Anderson, South Carolina.
4. Trip Report. Laube, A.H., Radian Corporation, to file. March 27
1980. 8 p. Report of visit to Pervel Industries in Plainfield '
Connecticut. (Docket Confidential File).
n Report. Laube, A.H. , Radian Corporation, to file. March 20
1980. 7 p. Report of March 5, 1980 visit to Standard Coated
Products in Hazelton, Pennsylvania. (Docket Confidential File).
6< TnJi! ReP°rt> Nelson» T-p" Radian Corporation, to file. February 16
1979. Report of visit to Adhesives Research in Glen Rock, Pennsylvania
7. Letter and attachments from Schwab, R.F., Allied Chemical Corporation,
Mornstown, N.J., to Farmer, J., U.S. Environmental Protection
Agency. December 27, 1979.
8. Ostojic, N. Evaluation of the Impact of the Proposed SIP for
Massachusetts on Paper Coating Industry. Wethersfield, Connecticut.
IKL. March 7, 1979.
9. Trip Report. Harris, G.E., Radian Corporation, to file. July 28
1978. Report of visit to Shuford Mills in Hickory, N.C.
10. Jelecon. Brooks, G.W., Radian Corporation, with Backhaus, K
Stauffer Chemical Company. May 15, 1980. Discussion on control
equipment problems.
11. Jelecon. Brooks, G.W., Radian Corporation, with Lewandowski, A.,
Stauffer Chemical Company. June 23, 1980. Discussion on carbon
adsorption system.
12. Trip Report. Laube, A.H., Radian Corporation, to file March 6
1980. 19 p. Report of February 27, 1980 visit to General Tire and
Rubber Company. (Docket Confidential File)
4-41
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13. Memo from Mascone, D.C., U.S. EPA, to Fanner, J.R., U.S. EPA.
June 11, 1980. Thermal incinerator performance for NSPS.
14. U.S. Environmental Protection Agency. Control of Volatile Organic
Emissions from Existing Stationary Sources - Volume 1: Control
Methods for Surface Coating Operations. Research Triangle Park, N.C.
EPA-450/2-76-028. November 1976. pp. 39-42.
15. Reference 13, p. 51.
16. Reference 13, p. 44.
17. C.E. Air Preheater. Report of Fuel Requirements, Capital Cost and
Operating Expense for Catalytic and Thermal Afterburners. (Prepared
for U.S. Environmental Protection Agency.) Research Triangle
Park, N.C. Publication No. EPA-450/3-76-031. September 1976.
p. 241.
18. Reference 13, p. 55.
19. Letter from Niles, R.W., Uniroyal, Inc., to Laube, A.M., Radian
Corporation. December 4, 1980.
20. Trip Report. Laube, A.M., Radian Corporation, to file. November 15,
1979. Report of visit to General Tire and Rubber Company, Columbus, MS,
21. Mcllvaine Company. The Mcllvaine Scrubber Manual, Volume I.
Northbrook, Illinois. 1974. Chapter III, p. 8.0.
22. Reference 21, p. 9.0.
23. Reference 21, p. 10.0.
24. Reference 21, p. 16.0.
25. Reference 21, p. 13.0.
26. Reference 21, p. 21.0.
27. Letter and attachments from Durst, D.T., Purification Industries,
to Rawlings, J.B., Radian Corporation. December 27, 1979.
28. Meeting Notes. Krohn, N., Radian Corporation, to file. February 5,
1981. Meeting of EPA and Flexible Vinyl Printing Industry Represen-
tatives, p. 3.
29. Letter from Rothchild, R.D., Airco Industrial Gases, to Smith, D.T.,
Radian Corporation. March 20, 1980.
4-42
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30. Airco Develops Solvent Recovery System. Chemical and Engineering
News. .58(4):7. January 28, 1980.
31. Industrial Ventilation. A Manual of Recommended Practice (14th
Edition). American Conference of Governmental Industrial Hygienists.
Committee on Industrial Ventilation. Lansing, MI. pp. 4-4, 4-5.
32. Reference 31, p. 4-1.
33. Reference 31, p. 4-12.
34. Telecon. North, Charles, Avery-Fasson, with Nelson, T.P., Radian
Corporation. May 2, 1979. Discussion on VOC control systems.
35. Trip Report. Nelson, T.P., Radian Corporation, to file. August 28,
1979. Report of visit to Precoat Metals, St. Louis, Missouri.
36. Trip Report. Brooks, G.W., Radian Corporation, to file. September 12
1979. Report of visit to E.J. Gaisser, Inc., Stamford, CT.
4-43
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5. MODIFICATION AND RECONSTRUCTION
While New Source Performance Standards (NSPS) are intended primarily
for newly constructed facilities, existing sources can become subject to
an NSPS through either "modification" or "reconstruction." These terms
are defined in detail in 40 CFR 60.14 through 40 CFR 60.21. A modification
is any change in an existing facility that results in increased emissions.
A reconstruction is any change in an existing facility to the extent
that the fixed capital cost of the new components is 50 percent or more
of the fixed capital cost of a comparable entirely new facility. Examples
of possible modification and reconstruction in the vinyl coating and
printing industry are also discussed in this section.
5.1 MODIFICATIONS
EPA has promulgated general regulations in 40 CFR 60.14 for implementing
Section 111 of the Clean Air Act with regard to modifications. As
defined in these regulations, a modification is a physical or operational
change to an existing facility which results in an increase in the
emission rate to the atmosphere of any pollutant to which a standard
applies.
Under the regulations, certain physical or operational changes are
not considered to be modifications even though emissions may increase as
a result of the change. It is stated in 40 CFR 60.14 that the addition
or modification of one facility at a source will not cause other unaffected
facilities at that source to be subject to NSPS provisions. Other
exceptions or exemptions to the modification provision include:
•routine maintenance, repair and replacement,
•production increases achieved without any capital expenditure,
5-1
-------
• production increases resulting from an increase in the
hours of operation,
• use of an alternative fuel or raw material if the existing
facility was designed to accomodate it,
conversion to coal for energy considerations,
• addition or replacement of equipment for emission control
(as long as the replacement does not increase emissions),
and
•relocation or change of ownership of an existing facility.
The key criterion for a modification determination is whether
actual emissions to the atmosphere have increased on a mass per time
basis (kg/hr) as a result of the change. Changes in emission rate may
be determined by the use of emission factors, or by material balances,
continuous monitoring data or manual emission tests in cases where the
use of emission factors does not clearly demonstrate that emissions do
or do not increase. If any increase in emissions that would result from
a change to an existing facility can be offset by improving an existing
control system or installing a new control system for that facility,
such a change would not be considered a modification (since actual
emissions would not increase). However, emission decreases at other
facilities at a plant cannot be considered when making a modification
determination for a particular facility.
Once an existing facility is determined to be modified, it becomes
an affected facility, subject to the standards of performance for the
pollutant or pollutants which have increased due to the modification.
All of the emissions of the pollutants which have increased must be in
compliance with the applicable standards, not just the new emissions.
The following paragraphs will list potential modifications in the
flexible vinyl coating and printing industry (FVC&P) and how they relate
to the proposed NSPS.
The productivity of a FVC&P finishing line is determined by the web
width, the line speed, the hours of operation, and the efficiency of
scheduling. This industry has historically experienced a steady growth.
5-2
-------
Production increases to accommodate that growth can be accomplished by
two methods. In the first method, the operation of the existing equipment
is pushed to its capacity by debottlenecking, more efficient scheduling,
and increasing the hours of operation. When no more capacity can be
achieved in this manner, new finishing lines are built or existing lines
are upgraded. Most of the production increases (and the associated
emission increases) from the first method are specifically exempted from
NSPS compliance. Most of the equipment modifications in the second
method involve totally new sources, or investments so large as to qualify
as reconstruction. Specific examples are given below, with emphasis on
the few cases where the modification clause might apply.
5.1.1 Changes in Web Width
Changes in the width of web would increase both production and
emissions. The maximum web width that any given finishing line can
handle is an integral part of the basic design of the line. Therefore,
web width cannot be increased without installing essentially all new
equipment. If an increase in web width were desired, it would normally
be more attractive to build a totally new line than to modify an existing
line. If such a modification were to be made, capital expenditures
would be required and the work would fall under the reconstruction
provisions.
5.1.2 Changes in Line Speed
An increase in line speed is the most likely change that could
constitute a modification. The maximum line speed for a given facility
depends on both the basic design of the finishing line and on the specifications
for each product. The factors which might constitute a line speed
limitation include:
« a limitation on the available power and/or speed of the
motors which drive the web,
• drying limitations based either on the amount of heat
available or on residence time in the oven,
*a limitation on oven circulation which causes the Lower
Explosive Limit (LEL) to be exceeded,
5-3
-------
•a limitation on the maximum speed at which a smooth
finish can be achieved, and
•a limitation due to fragility of the web.
For a given finishing line, the maximum line speed will differ
between products, and the limiting equipment factor may differ also.
Any equipment changes (such as larger/faster drive motors, higher capacity
burners for the ovens, higher capacity oven circulating blowers, LEL
sensors with alarm/shutdown capacity, or a change in printing stations
which might be made to increase line speed) would require capital expenditure
and result in increased emissions. As such, they might be considered
modifications which would require that facility to comply with NSPS.
Many changes in production specifications (such as type of substrate,
web, ink, or coat weight) could alleviate an equipment limitation resulting
in a production increase. Some combinations of these changes could also
result in increased emissions. They might not be termed modifications,
however, since no capital expenditure would be required.
5.1.3 Changes in the Hours Available for Operation and/or Scheduling
Efficiency
A typical FVC&P finishing line operates from 120 to 140 hours per
week. Significant increases in production and emissions could result
from extending the working hours, but this is specifically exempted
under the modification clause.
Even during the hours of operation, a finishing line must often be
shut down or slowed down. This iright be done to remove a finished roll
of product and add a fresh roll of substrate to splice a broken web, to
make an adjustment at the print stations or to change inks or color
pattern. Each time a change is trade in the type of product to be coated
or printed on a given line, time must be allowed to clean up the equipment
and to reset the controls to the new product specifications. Any given
FVC&P product potentially receives several different coats in its production
(precoat, printcoat, topcoat). All of these factors indicate that
5-4
-------
careful scheduling can increase production which will result in increased
emissions. This process might not be a modification because it requires
no capital expenditures and no equipment modification.
5.2 RECONSTRUCTION
An existing facility may also become subject to new source performance
standards if it is "reconstructed." As defined in 40 CFR 60.15, a
reconstruction is the replacement of the components of an existing
facility to the extent that 1) the fixed capital cost of new components
exceeds 50 percent of the fixed capital cost of a comparable entirely
new facility, and 2) it is technically and economically feasible for the
facility to meet the applicable standards. Because EPA considers reconstructed
facilities to constitute new construction rather than modification,
reconstruction determinations are made irrespective of changes in emission
rate.
The purpose of the reconstruction provisions is to ensure that an
owner or operator does not rebuild an existing facility without consideration
of the achievability of the standards of performance. Without such
provisions, circumvention of the standards could be attempted by replacing
all but vestigial components (such as, frames, housing, and support
structures) rather than constructing a "new" replacement facility subject
to the standards of performance. The reconstruction provisions prevent
such a circumvention where it is technically and economically feasible
to achieve the standards. If a facility is determined to be reconstructed,
all of the provisions of the standards of performance applicable to that
facility must be satisfied.
Many of the changes mentioned in the section of modifications would
likely be high enough in cost to qualify under reconstruction. Any
change of equipment to increase web width would require such massive
equipment replacement that it would certainly require EPA's determination
as to whether it would be reconstruction. It is doubtful that this
would occur, however, since the plant could likely build a totally new
line for the same expenditure.
5-5
-------
Several of the equipment changes to increase line speed could
conceivably be costly enough to require a reconstruction determination.
This would be most likely in the case of a severe drying limitation
which might require the addition of one or more oven zones. Many of the
smaller investment options (such as higher capacity burners, larger
circulating blowers, high speed drive systems, or instrumentation to
allow operation at a higher percentage of the LEL) would not meet the
guideline of greater than 50 percent of new construction cost. Combinations
of these items could conceivably be costly enough to exceed 50 percent.
5-6
-------
5.3 REFERENCES
1. Trip Report. Laube, A.M., Radian Corporation, to file. December 11
1979. Report of visit to Stauffer Chemical Company, Anderson,
South Carolina.
5-7
-------
6. MODEL PLANTS AND REGULATORY ALTERNATIVES
The purpose of this chapter is to define the model plants and the
regulatory alternatives that will be applied to them. The model plants
represent typical expansions of existing facilities or typical new
plants to be built in the vinyl coating and printing industry. The
regulatory alternatives developed in this chapter represent various
courses of action the EPA could take towards controlling VOC emissions
from the vinyl coating and printing process. The environmental and
economic impacts of these alternatives are examined in Chapters 7-9 for
each model plant.
6.1 MODEL PLANTS
As discussed in Chapter 3, a variety of web widths, ink compositions,
ink application rates, number of print lines and number of print stations
are found in the vinyl coating and printing industry. A complete
characterization of an industry as complex as the vinyl coating and
printing industry would require many cases. The models presented here
are an attempt to find a workable and meaningful set of cases.
Table 6-1 contains the configuration parameters of the model
plants. Two web widths, 1.5 meters (60 inches) and 0.76 meters (30
inches), were chosen. The larger product width is commonly found in
industry. The smaller product width allows representation of a small
capacity plant or expansion.
The single print line model plants, A, B, and C, represent expansions
and major modifications of existing plants or new, small plants. The
multiple print line plants D and E represent new, large plants. There
are many lines now in operation with less capacity than these models,
however, it is thought unlikely that a line smaller than model C will be
chosen for a new plant or to replace obsolete lines.
6-1
-------
TABLE 6-1. MODEL PLANTS
Model
Plant
A
B
C
D
E
Webl,2,3,4,6,7,8,9
Width
m
(inches)
1.5
(60)
1.5
(60)
0.76
(30)
1.5
(60)
1.5
(60)
Number
of
Print
Lines
1
•1
1
6
6
Number1'2'
of
Print
Stations
3
6
6
18a
36b
3,4,5,6,7,8,9
Ink1'6
Formulation
5% solids
5% solids
5% solids
5% solids
5% solids
Three print stations per print line.
Six print stations per print line.
6-2
-------
Each print station applies one coating. Some products require up
to six coatings and Model Plants B, C, and E reflect this. Other
products require fewer coatings and Model Plants A and D, with three
stations per print line reflect this. The three print station model is
depicted in Figure 6-1.
Ink formulations used by industry range from 70 to 95 percent
solvent, 5 to 30 percent solids, by weight. Emission control equipment
must be designed to accomodate the highest solvent loading, therefore, the
ink formulation was chosen to be 5 percent solids, 95 percent solvent.
More detailed information on the finishing process is given in
Chapter 3 of this report.
6.1.1 Model Plant Parameters
The model plant parameters for the processes used in coated vinyl
manufacturing are based on data from existing facilities in the vinyl
coating and printing industry. Table 6-2 lists the parameters which are
used to calculate material balances for the model plants. Each plant
operates 6000 hours per year with the finishing process operating 60
percent of that time as shown in Table 6-2. This value is based on
estimated, typical downtimes and production schedules for the finishing
process.
Many existing print lines operate at slower line speeds than these
models, however, it is thought that any new installations will utilize
the higher speed equipment now available.
The solvent used in the finishing coatings for the model plants
consists of 25 weight percent toluene, 25 weight percent methyl isobutyl
ketone (MIBK), and 50 weight percent methyl ethyl ketone (MEK). Many of
the coating formulas used by the FVC&P industry are more nearly one
component formulas and often contain over ninety percent MEK. The
solvent mixture chosen for the model plants requires complex distillation
equipment in order to recover and purify these solvents. The industry
also uses small quantities of 10 or 15 other solvents. It is generally
not economical to purify or separate these because no single solvent
represents more than one or two percent of the total solvent usage.
6-3
-------
VOC Emissions
I
Final Product
Wind
Vinyl We
Unwind
Three Print Station
Finishing Operation
Figure 6-1. FINISHING LINE MODEL PLANT
-------
en
tn
TABLE 6-2. MODEL PLANT PARAMETERS FOR VINYL COATING PROCESSES
Operating1'6 Annual1'2'3'4*6'7*8'9 Coating1'2'3'4'6'7'8'9
Speed Operating Application Rate ? Type of
(ypm) Hours kg/m (Ib/yd ) Emission
Finishing Operation
- 3 Print stations 0.91 (60) 3600 0.016 (0.030) VOC
- 6 Print stations 0.91 (60) 3600 0.076 (0.144) VOC
-------
The Industry makes every effort to reduce the amount of solvent
retained in the finished product to a level less than can be detected by
analytical methods. Therefore, in order to develop a solvent balance
around each model plant it is assumed that none of the solvent is
retained in the product so that all of the solvent applied with the
finishing coatings becomes VOC enissions.
The oven on each rotogravure print line in the model plant is
designed to operate at 25 percent of the lower explosive limit (LEL)
(3925 ppmv) during normal coating operations.1'6 Some ovens in the
FVC&P industry have been designed and equipped to operate at higher LEL
(up to 40 percent). However, these higher LEL levels are not yet fully
operational.
Using these parameters and assumptions, VOC emission rates can be
calculated for each of the five model plants. Table 6-3 contains the
results of these calculations.
6.1.1.1 Land and Utility Requirements. Table 6-4 lists the land
and utility requirements for the model plants. The land requirements
were estimated from observations of existing plant sites.
The utilities for the model plants consist of electricity for
motors and natural gas for oven heat. Electric motors are used on
winders and rewinders, print rolls, recirculation fans and exhaust fans.
The electrical requirements are estimated at 0.04 kWh per square meter
of production (0.045 hph per square yard of product).
The ovens are assumed to be heated with direct-fired natural gas
furnaces. The fuel requirements are estimated at 110 J/hr per dscm/hr of
oven air(250 Btu/hr per SCFM).
6.2 REGULATORY ALTERNATIVES
Three regulatory alternatives are investigated. Regulatory Alternative
I represents baseline control which is the level of control that would
probably result if the NSPS were not promulgated. Regulatory Alternative
II represents the first level of NSPS control being considered. Regulatory
Alternative III represents the second level of NSPS control being considered,
a level of control achievable through the optimum capture of emissions
and control with a carbon adsorption system.
6-6
-------
TABLE 6-3. MODEL PLANT PARAMETERS
Model
Plant
A
B
C
D
E
Number
of
Li nes
1
1
1
6
6
Web
width
m
(inches)
1.5
(60)
1.5
(60)
0.76
(30)
1.5
(60)
1.5
(60)
Number of
Print
Stations
3
6
6
18b
•
36C
Line Speed
m/s
(ypm)
0.91
( 60)
0.91
( 60)
0.91
( 60)
0.91
( 60)
0.91
( 60)
Ink Application
Rate 2
Per Iine9k.g/m
Ob/yd')
0.016
CO. 030)
0.076
(0.144)
0.076
(0.144)
0.016
( 0.030)
0.076
( 0.144)
Uncontrolled VOC
Emissi
kg/hr
(Ib/hr)
77
(170)
370
(820)
190
(410)
470
(1030)
2230
(4920)
ons
Mg/yra
(ton/yr)
280
(310)
1300
(1480)
650
(740)
1700
(1850)
8000
(8860)
Based on an operating factor of 3600 hr/yr.
Three stations per line.
c Six stations per line.
-------
oo
TABLE 6-4. ANNUAL PRODUCTION, LAND, AND UTILITY REQUIREMENTS
(WITHOUT CONTROL DEVICES)
. __ - ••
Model Plant
A
B
C
D
E
Annual Production
ITU
(y
-------
Fixed-bed carbon adsorption systems are used as the VOC emission
control devices in the model plants. Other control devices, such as
incinerators, are available, however, fixed-bed carbon adsorption systems
currently are used almost exclusively in the industry. This may be the
result of increasing incinerator fuel costs and rising raw material
solvent costs.
6.2.1 Regulatory Alternative I
As discussed in Chapter 3, the baseline control level for VOC
emissions from the finishing operations is based on the graphic arts CTG
which calls for 65 percent overall control. This 65 percent level
represents a system which captures 70 percent of the total solvent from
the FVC&P finishing operation and recovers or destroys 95 percent of
those emissions.
6.2.2 Regulatory Alternative II
As also discussed in Chapter 3, the moderate control level for VOC
emissions from the finishing operations is based on the rotogravure CTG
which calls for 75 percent overall control. The moderate control level
for VOC emissions may be achieved by capturing 80 percent of the solvent
supplied at the presses and then controlling those captured emissions
with a 95 percent efficient control device.
6.2.3 Regulatory Alternative III
For this alternative, optimum capture and control of oven exhaust
gases and fugitive VOC emissions around the coating area of the printing
devices are required. This is intended to correspond to 95 percent
adsorber efficiency and 90 percent capture of the solvent emitted from
the finishing operation resulting in 85 percent overall control. This
may be accomplished by a system of ducts to capture and control all oven
exhausts and one or both of the following plans:
•A system of fugitive vapor capture vents that capture emissions
from the printing heads and the wet web as it travels into and
out of the equipment, and duct these emissions to a carbon
adsorber, or
6-9
-------
A partial or total enclosure of the finishing line and the
venting of the captured emissions to the carbon adsorber.
No additional dilution of the solvent laden air to the carbon adsorber
due to the fugitive capture system is considered. This may be accomp-
lished by drawing oven makeup air from around the printing line where
fugitive vapors are generated.
6.2.4 Controlled Podel Plant Parameters
The three regulatory alternatives were applied to each model plant.
Table 6-5 contains a summary of the regulatory alternatives as they
apply to the model plants. Cases A-l, R-l, C-l, D-l, and E-l use the
baseline control level for the finishing operations. Cases A-2, B-2,
C-2, D-2, and Ei-2 use the moderate control level, Cases A-3, P-3, C-3,
D-3 and E-3 use the stringent control level.
Material balances are calculated for all control cases. The
results of these calculations and control device parameters are shown in
Table 6-6. The control case numbers relate to the controlled model
plants listed in Table 6-5.
6.2.4.1 Land and Utility Requirements for Model Plant Control
Systems. Table 6-7 gives the land and utility requirements for the
model plant control systems. Land requirements were estimated from
observations of existing carbon adsorption, solvent recovery systems in
industry.
The utilities for the control systems consist of cooling water for
stean condensation, electricity for adsorber inlet fans and various
pumps in the solvent recovery system, steam for desorbtion and tor
distillation columns, and carbon replacement. Cooling water requirements
o
were estimated at 0.1 m per 100 kg steam (12 gal per 100 Ibs. steam).
The major electricity user is the adsorber fan, therefore, the electrical
requirements are based on airflow and estimated at 2.4 kWh/hr per dscm/h
of adsorber inlet flow(8 hph/hr per 1000 SCFM). Steam requirements were
estimated at 4.9 kg steam/kg recovered solvent. Carbon requirements
were estimated using vendor data. The approximate ratio of carbon to
solvent laden air is 3.2 Mg per 10,000 dscm/hr (6 tons per 10,000 SCFM).
6-10
-------
TABLE 6-5. SUMMARY OF REGULATORY ALTERNATIVES
Finishing Operation
Case Regulatory VOC Control
Alternative Level
A-l I 65% overall
B-l control
C-l
D-l
E-l
A-2
B-2
C-2
D-2
E-2
II 75% overall
control
A-3
B-3
C-3
D-3
E-3
III 85% overall
control
6-11
-------
TABLE 6-6. CONTROL OPTION PARAMETERS - FINISHING OPERATION
CT)
ro
Model
Plant
A
B
C
D
E
NMfcer
Case of
No. Lines
A-l 1
A-2
A- 3
9-1 1
B-2
B-3
C-l 1
C-2
C-3
0-1 6
0-2
0-3
E-l 6
E-2
E-3
Nunber of Regulatory
Print Stations Alternatives
3 I
II
III
6 I
II
III
6 I
II
III
18» I
11
III
36* I
II
til
WC tali
Hunger of Carbon Uncontrolled
Adsorption Systems Kg/hr (Ib/hr)
1 77 (170)
1 370 (820)
1 190 (410)
1 470 (1030)
1 2230 (4920)
5 Ions c,
fnnlrnllort i!
ack Emissions ..
kg/hr (Ib/hr) dson/sec (SCFN) 'K
27 (60
20 (43
12 (26
130 (290)
95 (210)
54 (120)
65 (140
45 (100
28 (62
160 (360)
110 (250)
68 (ISO)
780 (1720
560 (1230
140 (740
0.93 2200 310
1.1 2600 310
1.1 3000 310
4.8 (11000) 310
5.7 (13000) -310
Cirlxm Adsorption Systea
(^crating Dtta
n Te*p Out P
•F) °K ("F) Pa (
95) 310
95) 310
95) 310
95) 310
95) 310
6.6 (15000) 310 (95) 310
2.4 (5400) 310
2.8 (6300) 310
3.2 (7200) 310
95) (310)
951 (310)
95) (310)
6.1 (14000) 310 (95) 310
7.0 (16000) 310
7.9 (18000) 310
>8 65000) 310
i3 76000) 310
)£ 83000) 310
95) 310
95) 310
95) 310
95) 310
95
95
95
95
95
95
95
9b
4000
4000
4000
5000
5000
5000
4500
4500
95 4500
95) 5000
95
95
95
95
5000
5000
5500
5500
(95) 310 (95) 5500
In. of hyj)
jl«j
(«)
(20)
20J
(20)
(18)
!S(
(1»)
(20)
(20}
(20)
(22)
(&)
'Three stations per 11m.
bSlx stations per line.
-------
CO
TABLE 6-7. LAND AND UTILITY REQUIREMENTS FOR
MODEL PLANT CONTROL SYSTEMS
Case
No.
A-1
fl-2
A-3
B-l
B-2
B-3
C-l
C-2
C-3
D-l
D-2
D-3
E-l
E-2
E-3
Cooling Water 1>5'6
m3/hra (gal/hr)a
0.25
0.28
0.32
1.2
1.4
1.6
0.61
0.68
0.77
1.5
1.7
2.0
7.2
8.3
9.1
(65)
(74)
(85)
(310)
(360)
(410)
(160)
080)
(200)
(400)
(460)
(520)
(1900)
(2200)
(2400)
Electricity
kwh/hr (hph/hr)
14
16
19
69
82
95
34
40
45
88
100
110
410
480
520
(19)
(21)
(25)
(93)
(no)
(130)
(46)
(54)
(60)
(120)
(130)
(150)
(550)
(640)
(700)
Steam1'5'6
kg/hr (Ib/hr)
250
280
320
1200
1400
1500
590
680
770
1500
1700
2000
7300
8200
9100
(540)
(620)
(710)
(2,600)
(3,000)
(3,400)
(1,300)
(1,500)
(1,700)
(3,300)
(3,800)
(4,300)
(16,000)
(18,000)
(20,000)
Replacement
Carbonb
Mg Tons
1
1
1
6
7
8
3
3
4
7
8
10
37
43
48
.3
.5
.6
.2
.1
.1
.1
.5
.0
.7
.9
(1.4)
(1.6)
(1.8)
(6.8)
(7.8)
(8.9)
(3.4)
(3.9)
(4.4)
(8.5)
(9.8)
(ID
(41)
(47)
(53)
Land
Requirements0
m2 ft?
290
290
290
480
480
480
300
300
300
1900
1900
1900
2900
2900
2900
(3,000)
(3,000)
(3,000)
(5,000)
(5,000)
(5,000)
(3,200)
(3,200)
(3,200)
(20,000)
(20,000)
(20,000)
(30,000)
(30,000)
(30,000)
Coolinq tower makeup.
Carbon replacement will vary with process conditions but may be assumed to be every three years.
Provides for carbon adsorption unit, cooling tower, solvent distillation, solvent drying, and recovered solvent
s torcicjG tcink s.
-------
Moisture removal down to 0.5 weight percent water is necessary in
the solvent recovery system. This is achieved through a complex distillation
and dehydration system. The dehydration system requires approximately
60 kg of desiccant per m3 of solvent (0.5 Ib/gal.) in order to meet this
requirement.
6-14
-------
6.3 REFERENCES
1. Trip Report. Laube, A.H. and D.T. Smith, Radian Corporation, to
file. March 6, 1980. 19 p. Report of February 27, 1980 visit to
General Tire Company in Reading, Mass. (Docket Confidential file.)
2. Trip Report. Laube, A.H., Radian Corporation, to file. September 28
1979. Report of visit to Uniroyal, Inc., in Mishawaka, Indiana.
3. Trip Report. Brooks, G. and D.T. Smith, Radian Corporation, to
file. May 12, 1980. 9 p. Report of April 14, 1980 visit to Compo
Industries, Inc. in Lowell, Mass. (Docket Confidential file.)
4. Athol Manufacturing Corporation, Butner, North Carolina. Emission
and operation data furnished to North Carolina Division of Environmental
Management. 1977-1978.
5. Trip Report. Laube, A.H. and N.E. Krohn, Radian Corporation, to
file. September 8, 1980. 19 p. Report of July 30 visit to Stauffer
Chemical Company, Anderson, South Carolina. (Docket Confidential
file.)
6. General Tire and Rubber Company, Reading, Massachusetts, Emission
and operation data furnished to Metropolitan Boston Air Pollution
Control District. 1974-1979.
7. Panasote, Butler, New Jersey. Emission and operation data furnished
to the EPA.
8. Ford Motor Company, Dearborn, Michigan. Emission and operation
data furnished to Michigan Department of Natural Resources. 1978-
9. General Tire and Rubber Company, Columbus, Mississippi. Emission
and operation data furnished to Mississippi Department of Natural
Resources.
10. Trip Report. Laube, A.H., N.E. Krohn, and A.J. Miles, Radian
Corporation, to file. November 4, 1980. 4 p. Report of August 6,
1980 visit to Firestone Plastics Company in Salisbury, Maryland.
(Docket Confidential file.)
11. Letter from Brookman, R.S., Pantasote, Inc., to Laube, A.H., Radian
Corporation, December 2, 1980. 2 p. Technical review of the BID.
6-15
-------
7. ENVIRONMENTAL AND ENERGY IMPACTS
The major environmental problem in the flexible vinyl coating and
printing (FVC&P) industry is the emission of large amounts of volatile
organic compounds (VOC). As discussed in Chapter 3, the VOC emissions
result from the evaporation of organic solvent during the finishing
operations of a FVC&P line.
Each finishing operation contains several printing stations, a
topcoat station, and may include a precoater. The drying ovens used to
remove the solvent and fuse the vinyl resins or inks onto the vinyl
surface of the web, are the largest single source of VOC emissions in
the plant production process. Fugitive VOC are emitted from around the
coat/print stations and from the exposed wet web as it enters the drying
oven. Small amounts of VOC emissions also occur during solvent handling
and coatings formulation activities. In an uncontrolled plant the
entire amount of solvent is vented to the atmosphere.
In this chapter the air, water, and solid waste pollution impacts,
as well as energy impacts associated with the regulatory alternatives
described in Chapter 6 are examined. These impacts are examined for
individual model plants and for the United States as a whole. Basically
the regulatory alternatives can be summarized as follows:
• Regulatory Alternative I (baseline control) - This alternative
represents the control level recommended by EPA's Control
Techniques Guidelines document for flexible packaging rotogravure
operations (65 percent overall control).
• Regulatory Alternative II - This alternative represents the
first level of NSPS control being considered. An overall
VOC emission reduction of 75 percent would be achieved.
7-1
-------
• Regulatory Alternative III - This alternative represents the
second level of NSPS control being considered. This control
level applies the best technological system of continuous VOC
emission reduction for the flexible vinyl printing industry.
The level of overall VOC reduction would be 85 percent.
Because of the reasons stated in Chapter 6 carbon adsorption
systems are used in all regulatory alternatives as the means for con-
trolling VOC emissions from the FVC&P industry. The environmental and
energy analysis will, therefore, concentrate on the impacts resulting
from the use of carbon adsorption solvent recovery systems.
7.1 AIR POLLUTION IMPACTS
7.1.1 Primary Air Pollution Impacts
Emissions estimates discussed in Chapter 3 indicate that about
21,600 megagrams (23,800 tons) of solvent should have been emitted to
the atmosphere by existing controlled flexible vinyl coating and printing
lines in 1980. The total potential emissions by existing FVC&P finishing
lines for this year were about 61,700 megagrams (68,000 tons). The
estimated emissions for 1980 assume that existing FVC&P lines are controlled
to the recommended specialty gravure CTG limit of 65 percent overall
reduction of VOC emissions. This section will compare the impacts of
each regulatory alternative on national VOC emissions through the year
1987. The emissions of typical FVC&P finishing lines to be built through
1987 will also be characterized. These emission estimates are calculated
based on predicted industry growth for the first five years that the
regulatory alternative may be in effect.
Table 7-1 illustrates the estimated national VOC emissions from
new, modified, or reconstructed FVC&P finishing lines from 1983 to 1987.
The emissions resulting from Alternative I control (65 percent overall
reduction), Alternative II control (75 percent overall reduction), and
Alternative III control (85 percent, overall reduction) are shown. By
1987 new, modified, or reconstructed FVC&P plants would have the potential
to emit approximately 4100 megagrams (4500 tons) per year of uncontrolled
7-2
-------
TABLE 7-1. ESTIMATED NATIONAL VOC EMISSIONS FROM NEW FLEXIBLE VINYL PRINTING LINES
co
Year
1984
1985
1986
1987
TTTI — T^
Potential Uncontrolled
Emissions,
Mg/yr (Tons/yr)
820 (900)
1600 (1800)
2400 (2700)
3300 (3600)
4100 (4500)
Regulatory
Alternative I
290 (320)
570 (630)
860 (950)
1100 (1200)
1400 (1600)
Level of Controlled VOC Emissions
Mg/yr { Ton/yr)
Regulatory Regulatory
Alternative II Alternative III
200 (220) 120 (130)
410 (450) 250 (270)
610 (670) 370 (410)
820 (900) 490 (540)
1000 (1100) 610 (670)
Incremental Impact on Baseline,
Mg/yr (Ton/yr)
Alt. I-Alt. II Alt. I-Alt. Ill
90 (100J 170 (190)
160 (180) 320 (360)
250 (280) 490 (540)
280 (300) 610 (660)
400 (500) 790 (900)
*As d scussea m Chapter 9 p 9-21 during the period 1983 to 1987, 6 new plants with an annual" outpUOT
9 million square meters (10.8 million sq yd) will be required. That estimate is the basis for this table.
-------
VOC. State SIP regulations at the Regulatory Alternative I level (65
percent control) would lower emissions of VOC to 1400 megagrams (1500
tons) per year. Regulatory Alternative II would further reduce emissions
from new plants to 1000 megagrams (1100 tons) per year. The strictest
level of proposed NSPS control, Alternative III, would reduce VOC emissions
in 1987 to 610 megagrams (670 tons) per year. The incremental impact of
Alternative II over the baseline control case (Alternative I) would be
to reduce national VOC emissions from FVC&P finishing operations by an
additional 30 percent in 1987. In 1987, Alternative III would reduce
national VOC emissions from FVC&P finishing operations by 57 percent
more than that achievable under Alternative I.
Similar incremental impacts occur when the regulatory alternatives
are applied to the individual model plants developed in Chapter 6.
Table 7-2 illustrates the results of such an application. Based on an
analysis of FVC&P industry needs up to 1987, a plant which is somewhat
larger than model plant C seems to be the most likely type to be built.
Model plant C, controlled to the Alternative II level, would emit about
170 megagrams (190 tons) of solvent, a year. Model plant C, controlled
to the Alternative III level, woulc emit 100 megagrams (110 tons) of
solvent per year. These emissions are 70 and 140 megagrams (70 and 150
tons) less respectively, than that expected from a comparable plant
controlled to the Alternative I baseline level.
The primary impact of a VOC emissions reduction from this industry
is a potential decline in ambient air organics levels and thus a reduction
in ozone and photochemical smog formation. The major cause of smog is a
photochemical reaction which starts with hydrocarbons and other organics
in the atmosphere and produces a cloud of irritating chemicals. The VOC
emitted from the FVC&P industry can, therefore, play an active part in
the formation of oxygenated organic aerosols (photochemical smog).
However, as an air pollution impact, the toxicity of the organic solvent
component vapors is generally less important than the toxicity of their
reaction products.
7-4
-------
I
en
TABLE 7-2. AIR EMISSION IMPACTS OF THE REGULATORY ALTERNATIVES
ON THE MODEL PLANTS*
(1.5m, 36)
*Based on the model p
, _ -.,.,,a IIUU , riant \, as an example* ~~
SvenjoT rcKg-'Sen0. sj-as:1.^ i°?d5 srw r^Tssv0-001 to °-17 ib T «• ^-z-6 * ^
per ydz). There is son* Indication that new plants i7«h1w.rd«lSJ rl^l $>?? SqU^6 Beter (°-°008 to °'144 P°unds
pounds per yd2 (See note a, Table 3-3): * ac"1eve deslred results with less solvent. Therefore, using OJ39
10.8 yd2 x 106 x 0.139
2TOO
750 tons/yr. 750 x 0.907 = 680 Mg/yr - potential uncontrolled emissions.
-------
The transformation of organic vapors to aerosols involves reactions
between the organics, ozone, ultraviolet irradiation (sunlight), and
nitrogen oxides (NO ). The organics react to produce additional ozone
/\
and oxygenated compounds which form aerosols by either nucleation or
3
condensation. The nitrogen oxide levels required for photochemical
smog formation are generally only encountered in industrial or urban
areas. This is very pertinent to the study of the FVC&P industry since
the majority of the industry's plants are located in the heavily industri-
alized north central and northeastern regions of the country.
7.1.2 Secondary Air Pollution Impacts
Secondary environmental impacts are defined as those impacts which
result from the addition of pollution control equipment. In the case of
the FVC&P industry, solvent emissions control systems are sources of
potential secondary emissions.
The major secondary air pollution impacts of carbon adsorption
systems are the fuel combustion emissions from the boiler used to
produce steam. The steam is used to strip the carbon bed of adsorbed
VOC at a ratio of 4 kilograms of steam per kilogram recovered solvent.
Steam is also produced (1 kilogram per kilogram recovered solvent) for
use in the distillation column used to refine the recovered solvent.
Assuming the model plants use number two fuel oil in their boilers,
estimates can be made on the relative levels of secondary emissions
resulting from controls. Hydrocarbon emissions would be negligible,
only about 0.000051 kilograms per kilogram (0.000051 Ib per Ib) recovered
solvent, assuming the boiler was well operated and maintained. For
particulates the emission rate is approximately 0.0125 kilograms per
kilogram recovered solvent (0.0125 Ib per Ib recovered solvent). '
The emission rates of sulfur oxides (SO ) are dependent on the level of
A.
sulfur in the fuel oil. For a 0.3 weight percent sulfur fuel oil,
0.0027 kilograms of SO^ per kilogram recovered solvent (0.0027 Ib per Ib
recovered solvent) are emitted. The magnitude of the secondary pollutants
generated by the operation of the control system is much smaller than
trse magnitude of the solvent emissions being recovered.
7-6
-------
An NSPS for industrial boilers, currently being developed by EPA,
will further reduce the impact of these secondary emissions by requiring
the control of NO , SO , and other boiler emissions.
A A
Secondary air pollutants are also formed as a result of electrical
power generation. The electrical power is required to drive solvent-
laden air fans, cooling tower pumps and fans, boiler pumps and fans, and
all emission controls instrumentation. The quantity and type of pollution
produced would vary considerably depending on the geographical location
and the fuel resources available. Prediction of the secondary environmental
impact associated with electrical power generation is beyond the scope
of this study. Electrical consumption is not large and not considered
to be a significant impact. Since the power plants are separate offsite
facilities, which are already governed by emission regulations, this
source was not considered.
Cooling towers could be an additional source of secondary air
pollution with a carbon adsorption unit. Particulates in cooling towers
result from dissolved solids emitted to the atmosphere by cooling tower
drift. This particulate emission is generally not a problem in cooling
towers of the size found on carbon adsorption units in the FVC&P industry.
7.2 WATER POLLUTION IMPACTS
The only potential wastewater pollution from a controlled FVC&P
plant arises from the use of the carbon adsorption emission reduction
system. Dissolved solvent in the condensate from the carbon adsorption
system represents the primary potential water pollutant.
Carbon adsorption devices use steam to strip adsorbed solvent from
the carbon beds. During the stripping operation, the solvent-steam
vapors are fed to a condenser. The condensed solvent-water solution
from the condenser is then sent to a storage tank after pH adjustment.
Little separation of solvent and water takes place in the storage tank
because of the high miscibility of ketone solvents in water.
7-7
-------
From storage the solvent-water solution is sent to a distillation
column. The majority of solvent is removed from the solution during
distillation. After distillation the vaporized solvent (which contains
a small amount of water) is sent to a second condensation step. Following
the second condensation step, a solution of solvent and a small amount
of water is sent to a dehydration unit. In the dehydration unit calcium
chloride is used to dry the solvent/water mixture. The spent calcium
chloride brine is sent back through the distillation column and eventually
is discharged to a publically owned treatment works (POTW) or the environ-
ment. A schematic view of the water cycle in a controlled FVC&P model
plant is shown in Figure 7-1.
The wastewater discharges for the FVC&P model plants were estimated
based on the total quantity of incoming make-up water used to produce
steam for the carbon adsorption/distillation system. The wastewater
discharges associated with the irodel plants of Chapter 6 are given in
Table 7-3. A typical plant to be built in this industry would have an
annual wastewater discharge, attributable to VOC control, of 2.6 million
liters (690,000 gallons) under Regulatory Alternative II and 3 million
liters (780,000 gallons) under Alternative III.
The national wastewater discharges resulting from the implementation
of emissions controls on new FVC&P plants are presented in Table 7-4.
In 1987 plants controlled to the Alternative I level would discharge
approximately 13.2 million liters (3.5 million gallons) of wastewater
per year. An increased emissions reduction to the Alternative II level
would increase wastewater discharges to about 15.6 million liters (4.1
million gallons) per year. This represents a 2.4 million liter (600,000
gallons) increase in wastewater discharges to achieve a 400 megagrams
(440 tons) VOC emissions reduction. Control to the Alternative III
level in 1987 would increase potential wastewater discharges to 18
million liters (4.8 million gallons) per year from new FVC&P finishing
facilities. Compared to the baseline case, Alternative III control
would cause the discharge of 4.8 million liters (1.3 million gallons)
more wastewater to achieve a national VOC emissions reduction of 790
megagrams (870 tons) from new FVC&P finishing lines.
7-8
-------
MD
Solvent-Steam Vapors
lai
Ms
I In I
V
Steam
Inn
Hill1-ill)
U.iler
V
llollni
i ovpralile
FIGURE 7-1. SCHEMATIC OF THE WATER CYCLE IN A FVC&P PLANT SOLVENT RECOVERY SYSTEM
-------
TABLE 7-3. WASTEWATER DISCHARGE IMPACTS OF THE REGULATORY ALTERNATIVES
ON THE MODEL PLANTS*
-vl
I
Model Plants
(line width, No. Print Stations
A
(1.5m, 3)
B
(1.5m, 6)
(0.76m, 6)
(1.5m, 18)
(1.5m, 36)
nodel plants developed in Chapter 6.
Annual Wastewater Discharges, liters (gallons)
Regulatory Alternative I
910,000 (240,000)
4,200,000 (1,100,000)
2,200,000 (590,000)
5,700,000 (1,500,000)
26,100,000 (6,900,000)
Regulatory Alternative II
1,100,000 (290,000)
5,300,000 (1,400,000)
2,600,000 (690,000)
6,400,000 (1,700,080)
31,000,000 (8,200,000)
Regulatory Alternative III
1,200,000 (330,000)
6,100,000 (1,600,000)
3,000,000 (700,000)
7,600,000 (2,000,000)
36,000,000 (9,500,000)
-------
TABLE 7-4. ESTIMATED NATIONAL WASTEWATER DISCHARGE IMPACTS FROM VOC CONTROL SYSTEMS
Year
1983
1984
1985
1986
1987
Regulatory Alternative
2,600,000 (700,000)
5,300,000 (1,400,000)
7,900,000 (2,100,000)
10,600,000 (2,800,000)
13,200,000 (3,500,000)
Annual Wastewater Discharge,
liters (gallons)
I Regulatory Alternative II
3,100,000 (820,000)
6,200,000 (1,600,000)
9,400,000 (2,500,000)
12,500,000 (3,300,000)
15,600,000 (4,100,000)
Incremental Impact on Baseline,
liters (gallons)
Regulatory Alternative III
3,600,000 (950,000)
7,200,000 (1,900,000)
10,800,000 (2,900,000)
14,400,000 (3,800,000)
18,000,000 (4,800,000)
Alt. I - Alt. II Alt. I - Alt. Ill
480,000 (120,000) 960,000 (250,000)
960,000 (200,000) 1,900,000 (500,000)
1,400,000 (400,000) 2,900,000 (800,000)
1,900,000 (500,000) 3,800,000 (1,000,000)
>, 400,000 (600,000) 4,800,000 (1,300,000)
-------
The amount of VOC beinn emitted in these national wastewater dis-
charges would be relatively small. In 1987, under Regulatory Alternative
I, the wastewater streams of VOC control systems, for new flexible vinyl
finishing lines, would contain about 4.9 megagrams (5.4 tons) of VOC.
Increasing the reauired control level to Alternative II would increase
the quantity of VOC discharged in wastewater streams to 5.7 megagrams
(6.3 tons) per year. Control to the Alternative III level would increase
VOC released in the control system wastewater discharges to 6.5 negagrams
(7.1 tons) per year. These VOC irnnacts represent worst case situations.
These impacts were based on the assumptions that all new facilities
would use a solvent recovery control system and all wastewater is discharged
with no process recycle and reuse. Table 7-5 fully illustrates the
impacts of VOC in the control system wastewater discharges.
The environmental impact on natural water systems from these
wastewater discharges would be minimal because: (1) the total volume of
annual wastewater discharge is small and (2) the discharge contains only
alkaline dehydration chemicals (calcium chloride or sodium hydroxide)
and snail amounts of organic solvent. Plants currently operating in
this industry with carbon adsorption/distillation systems are permitted
to discharge wastewater streams attributable to VOC control to POTW
without any penalties or surcharges.
7.3 SOLID WASTE IMPACTS
The only expected solid wastes from VOC emissions control systems
come from the carbon adsorption devices. The activated carbon in these
units gradually degrades during normal operation. The adsorption
efficiency of the carhon eventually drops to such a level that replace-
ment is necessary. This replacement creates a solid waste load for the
plant. The quantities of waste carbon generated annually by the various
model R'C&P plants are given in Table 7-6. Waste carbon from the
largest plant controlled to the highest level would equal 48 negagrams
per year (53 tons/yr).
7-1?
-------
TABLE 7-5. ESTIMATED NATIONAL VOC LOADING OF VOC CONTROL SYSTEM WASTEWATER STREAMS
Year
1903
1984
1985
1986
1987
Annual VOC Emissions,
Mg (Tons)
Regulatory Alternative I
0.89 (0.98)
1.9 (2.1)
2.9 (3.2)
3.9 (4.3)
4.9 (5.4)
Regulatory Alternative II
1.0 (1.1)
2.2 (2.4)
3.3 (3.7)
4.5 (5.0)
5.7 (6.3)
Regulatory Alternative III
1.2 (1.3)
2.5 (2.8)
3.8 (4.2)
5.1 (5.7)
6.5 (7.1)
Incremental Impact on Baseline,
Mg (Tons)
Alt. I - Alt. II
0.15 (0.16)
0.27 (0.30)
0.40 (0.50)
0.60 (0.71)
0.80 (0.90)
Alt. I - Alt. Ill
0.31 (0.32)
0.60 (0.70)
0.90 (1.0)
1.2 (1.4)
1.6 (1.7)
I
CO
-------
TABLE 7-6. SOLID WASTE IMPACTS OF THE REGULATORY
ALTERNATIVES ON THE MODEL PLANTS*
I
t—'
*»
(line M
*6ased
Model Plants
idth, No. Print Stations)
A
M Cm t\
\ • • -"•? ~ /
B
(1.5m, 6)
C
(0.76m, 6)
D
(1.5m, 18)
E
(1.5m, 36)
on the model plants develope<
Annual
Regulatory
1.3
6.2
3.1
7.7
37
In Chapter
Solid Waste Impacts, Mg(Tons)
Alternative I
(1-4)
(6.8)
(3.4)
(8.5)
(41)
Regulatory Alternative II
1.5
7.1
3.5
8.9
43
6.
(1-6)
(7.8)
(3.9)
(9-8)
(47)
Regulatory
1.6
8.1
4.0
10
48
Alternative III
(1.8)
(8.9)
(4.4)
(ID
(53)
-------
This disposal of the waste carbon material creates a potential
secondary environmental innact. Three procedures are available for
handling waste carbon that reduce the potential of adverse environmental
innacts. The three involve: a) properly landfilling the carbon, b)
recycling the carbon by reactivation, and c) using the carbon as a fuel
source.
The implementation of the landfill method will be simple and
efficient because the technology for the operation is considered common
practice. No environmental problems should occur provided the landfill
site has been properly constructed. If the site is not secured by a
lining of some type (either natural or artificial), possible soil
leaching could occur. The leachate may contain traces of organics which
have been left on the carbon as residues. Transmission of this leachate
into ground and surface waters would represent a potential environmental
impact.
The second treatment procedure for the waste carbon involves
recycling the carbon to its manufacturer. The manufacturer can process
the waste carbon and reactivate it for reuse in carbon adsorption units.
At least one manufacturer is using this method.2
The third disposal method involves selling the waste carbon as a
fuel. The physical and chemical structure of the carbon in combination
with the hydrocarbon residues make the wastes a fuel product similar to
other solid fuels such as coal. Potential users of this fuel include
industrial and snail utility boilers. Since activated carbon Generally
contains very little sulfur, furnace S02 emissions resulting from
combustion would be negligible. Particulate and NO emissions from the
• • **
burning of activated carbon would be comparable to those of coal-fired
operations. However, the use of this disposal method would be limited
because of the small quantities of carbon generated by plants in this
industry.
Nationwide solid waste resulting from the VOC emission control
systems of FVC&P plants would not pose adverse environmental impacts.
Estimates of national solid waste resulting from new, controlled FVC&P
7-15
-------
plants are given in Table 7-7. In 1987 plants controlled to the Alter-
native I level would be generating approximately 19 megagrams per year
(21 tons/yr) of waste carbon. The same plants controlled to the Alternative
II level would generate about 21 megagrams per year (23 tons/yr) of
carbon waste. The 3 megagrams of increased carbon waste is a trade-off
for an increase in overall VOC emissions reduction of 400 megagrams per
year (440 tons/yr). Plants control'ed to the Alternative III level
would generate 24 megagrams (26 tons) per year of waste carbon, or 5
megagrams per year more than facilities under Alternative I control.
The additional solid waste generation results in increased VOC emission
reductions from new FVC&P facilities of 790 megagrams (870 tons) per
year in 1987.
7.4 ENERGY IMPACT
The air emissions control equipment for the FVC&P industry, utilizes
electrical energy and steam. The electrical energy is required to
operate solvent-laden air fans, cooling tower pumps and fans, boiler
support systems, and all control system instrumentation. Fossil fuel,
typically fuel oil, is combusted in the solvent recovery system's boilers
to produce steam for carbon adsorption and distillation. For the energy
impact analysis an 80 percent thermal efficiency was assumed for the
fuel oil usage.
The electricity consumptions calculated for each model plant and
regulatory alternative case are presented in Table 7-8. In the model
plant cases an average of 15 percent more electricity is required to
reduce overall VOC emissions from the Alternative I to the Alternative
II control level. A typical new FVC&P finishing line, under Alternative
II control, would require about 840 GJ (230,000 kwh) per year of electrical
energy. Control to the Alternative III level would require approximately
30 percent more electrical energy than Alternative I control. In 1987
a new finishing line under Alternative III control would require about
970 GJ (270,000 kwh) per year of electrical energy.
The gross nationwide consumption of electricity by new FVC&P finishing
lines, for VOC control purposes, is shown in Table 7-9. In 1987 new
7-16
-------
TABLE 7-7. ESTIMATED NATIONAL SOLID WASTE IMPACTS FROM VOC CONTROL SYSTEMS
Year
1983
1984
1985
1986
1987
Regulatory
Alternative I
3.7 (4.1)
7.4 (8.2)
11 (12)
15 (16)
19 (21)
Annual Solid Waste
Mg (Tons)
Regulatory
Alternative II
4.2 (4.6)
8.4 (9.3)
13 (14)
17 (19)
21 (23)
Impact,
Regulatory
Alternative III
4.8 (5.3)
9.6 (10.6)
14 (16)
19 (21)
24 (26)
Incremental Impact on Baseline
Mg (Tons)
AH. I-AH. II Alt. I-Alt. Ill
0.5 (0.5) 1.1 (1.2)
1.0 (1.1) 2.2 (2.4)
1.5 (1.6) 3.2 (3.6)
1.9 (2.1) 4.3 (4.8)
2.4 (2.7) 5.4 (6.0)
-------
TABLE 7-8. ELECTRICITY IMPACTS OF THE REGULATORY ALTERNATIVES ON
THE MODEL PLANTS
1
00
Model Plants
(line width,
No. Print Stations
A
(1.5m, 3)
B
(1.5m, 6)
C
(0.76m, 6)
D
(1.5m, 18)
E
(1.5m, 36)
Annual Electricity Consumption, GJ (kwh)
Regulatory Alternative I
300
1500
720
2000
9000
(84,000)
(420,000)
(200,000)
(530,000)
(2,500,000)
Regulatory Alternative II
350 (97,000)
1800 (500,000)
840 (230,000)
2200 (600,000)
10.200 (2,800,000)
Regulatory
420
2000
970
2300
11,400
Alternative III
(110,000)
(570,000)
(270,000)
(670,000)
(3,200,000)
*Based on the model plants developed in Chapter 6.
-------
TABLE 7-9. ESTIMATED NATIONAL ELECTRICITY IMPACTS FROM VOC CONTROL SYSTEMS
Year
IRA'S
17OJ
1984
1985
1986
1987
Annual
Keguiatury
Alternative I
860
1700
2600
3500
4300(1
l£1U,UUUJ
(480,000)
(720,000)
(960,000)
,200,000)
Electricity Consumption, GJ
Regulatory
Alternative 11
1000
2000
3000
4000
5000
1280,000)
(560,000)
(840,000)
(1,100,000)
(1,400,000)
(kHh)
Regulatory
Alternative
1200
2300
3500
4700 (1
5800 (1
320
(650
(970
,300
,600
HI
,'ooo)
,000)
,000)
,000)
Incremental Impact
Alt.
140
300
400
500
700
I - AH. 11
(40,0001
(80,000)
(120,000)
(140,000)
(200,000)
on Baseline, GJ (IcHh)
Alt. I
340
600
900
1200
1500
- Alt. Ill
(80,000
(170,000)
(250,000)
(340,000)
(400,000)
-------
facilities controlled to the Alternative II level would consume 15
percent more electricity than facilities under Alternative I control.
Alternative II control, in 1987, would require 5000 GJ (1,400,000 kwh)
of electricity per year. Alternative III control in 1987 would require
about 30 percent more electrical energy than if all new FVC&P finishing
operations were controlled to the Alternative I level. Finishing lines
under Alternative III control would use about 5800 GJ (1,600,000 kwh) of
electricity for VOC control.
The fuel oil consumptions for the model plant and regulatory
alternative cases of Chapter 6 are given in Table 7-10. A typical new
FVC&P finishing line to be built within the next five years would
require about 7,200 GJ (6.8 billion Btu) of fuel oil to meet the Alternative
I emission control level. Approximately 1,100 additional GJ (1.0 billion
Btu) of energy would be required to control the plant's VOC emissions to
the Alternative II level. Control of new finishing lines to the Alternative
III level would require 2,500 GJ (2.4 billion Btu) of fuel oil energy
above the amount required for Alternative I control.
The estimated gross national fuel oil impacts resulting from VOC
control systems are given in Table 7-11. Nationwide, in 1987, about
43,000 GJ (41 billion Btu) of fuel oil energy would be consumed by new
FVC&P finishing lines controlled to the Alternative I level. An additional
7,000 GJ (6.0 billion Btu) of fuel oil would be required nationwide to
raise the overall emission reduction being achieved by new FVC&P finishing
lines to the Alternative II level. Control to the Alternative III level
would raise fuel oil use by 15,000 GJ (14 billion Btu) above that
required for Alternative I control.
Net national energy savings are possible in this industry when the
energy value of the recovered solvent is considered. If all new FVC&P
finishing lines built through 1987 were controlled to the level of
Regulatory Alternative I, the gross national energy demand would be
equal to about 48,000 GJ (45 billion Btu). The amount of solvent
potentially recoverable under Alternative I control could be translated
into about 83,000 GJ (78 billion Btu) of energy. The net energy impact
7-20
-------
TABLE 7-10. FUEL OIL IMPACTS OF THE REGULATORY ALTERNATIVES ON THE MODEL PLANTS*
I
ro
(line
*Based on
Model Plants
width, No. Print Stations)
A
(1.5m, 3)
B
(1.5m, 6)
C
(0.76m, 6)
D
(1.5m, 18)
E
(1.5m, 36)
the model plants developed i
Regulatory
3,000
14,000
7,200
18,000
86,000
n Chapter 6.
Alternative I
(2.8)
(13)
(6.8)
(17)
(82)
Annual Fuel
Regulatory
3,500
16,000
8,300
21,000
99,000
Oil Consumption
Alternative II
(3.3)
(15 )
(7.9)
(20)
(94)
, GO (billions
of Btu)
Regulatory Alternative III
4,000
18,000
9,700
24,000
112,000
(3.8)
(17)
(9.2)
(23)
(no)
-------
TABLE 7-11. ESTIMATED NATIONAL FUEL OIL IMPACTS FROM VOC CONTROL SYSTEMS
Year
1983
1984
1985
1986
1987
Annual Consumption of No. 2
GJ
Regulatory
Alternative
8,600 (8.
17,000 (16)
26,000 (25)
35,000 (33)
43,000 (41)
(billions of Btu)
Regulatory
I Alternative II
2) 10,000 (9.4)
20,000 (1.9)
30,000(28)
40,000(38)
50,000(47)
Fuel Oil,
Regulatory
Alternative III
12,000 (11)
23,000 (22)
35,000 (33)
47,000 (44)
58,000 (55)
Incremental Impact on Baseline.
GJ (billions
Alt. I - Alt. II
1,400 (1.2)
3,000 (3.0)
4,000 (3.0)
5,000 (5.0)
7,000 (6.0)
of Btu)
Alt. I - Alt. Ill
3,400 (2.8)
6,000 (6.0)
9,000 (8.0)
12,000(11)
15,000(14)
I
ro
ro
-------
in 1987, under Alternative I control, is an energy savings of 35,000 GJ
(33 billion Btu).
Under Regulatory Alternative II control the gross national energy
demand would approach 55,000 GJ (52 billion Btu) in 1987. Alternative
II control would recover an energy equivalent of 95,000 GJ (90 billion
Btu). The net energy impact under Alternative II control, in 1987,
would be an energy savings of 40,000 GJ (38 billion Btu). The gross
national energy demand under Alternative III control would equal approx-
imately 64,000 GJ (61 billion Btu). The higher control efficiency of
this alternative would yield a potential solvent recovery equivalent to
105,000 GJ (100 billion Btu) of energy. The net energy impact under
Alternative III control, in 1987, would be an energy savings of 41,000
GJ (39 billion Btu).
The incremental energy savings of Alternative II compared to
Alternative I would equal 5,000 GJ (5.0 billion Btu). Alternative III
would have a potential energy savings of 6,000 GJ (6.0 billion Btu) when
compared to Alternative I. Table 7-12 fully illustrates the potential
net national energy impacts in the FVC&P industry. The favorable national
energy impact is important because of the lessening supply and increasing
cost of petroleum raw materials.
7.5 OTHER ENVIRONMENTAL IMPACTS
The impact of increased noise levels is not a significant problem
within the emission control systems of the FVC&P industry. No notice-
able increases in noise levels occur as a result of increasingly stricter
regulatory alternatives. Motors and solvent-laden air fans are responsible
for the majority of the noise in VOC control systems.
Other than the fuels required for steam and electricity generation,
and the materials required for the construction of the system, there is
no apparent irreversible or irretrievable commitment of resources
associated with the construction or operation of the emission control
systems. Essentially the VOC emission controls for this industry do not
produce any significant air, water, or land pollution problems. The
control and recovery of these solvent emissions is both energy efficient
and economical.
7-23
-------
TABLE 7-12. NET NATIONAL ENERGY IMPACTS OF VOC CONTROL, GJ (billions of Btu)
National Totals
Recovered Solvent
Energy Demand
Energy Savings
Regulatory
Alternative I
83,000 (78)
48,000 (45)
35,000 (33)
Regulatory
Alternative II
95,000 (90)
55,000 (52)
40,000 (38)
Regulatory
Alternative III
105,000 (100)
64,000 (61)
41,000 (39)
Incremental Impact on Baseline
Alt. I - Alt. II Alt. I - Alt. Ill
12,000 (12) 22,000 (22)
7,000 (7) 16,000 (16)
5,000 (5) 6,000 (6)
I
ro
-------
7.6 REFERENCES
1. Letter and attachments from Hall, W.B., Chemical Fabrics & Film
Association, to Goodwin, D., EPArESED. August 8, 1980 53 n
CFFA Vinyl Printing Operations Survey.
TriP Report Laube A.H. and N.E. Krohn, Radian Corporation, to
file. March 6, 1980. 19 p. Report of February 27, 1980 visit to
General Tire and Rubber Company in Reading, Massachusetts. (Docket
Confidential File.)
3- IrlP1^,',8-?- (ed1tor)- Environmental Engineers Handbook, Volume 2
Air Pollution. Radnor, PA. Chilton Book Company, 1974. pp. 82-85.
4. U.S. Environmental Protection Agency. Compilation of Air Pollutant
PartT" AuIstSi977eSearCh Tn'ang1e Park' N'C' Publication No. AP-42,
5. Devitt, T , P. Spaite, and L. Gibbs. (PEDCo Environmental) Background
Study in Support of New Source Performance Standards for Industrial
Boilers. (Prepared for U.S. Environmental Protection Aqency )
Research Triangle Park, N.C. EPA Contract No. 68-02-2603. March
6. Trip Report. Laube, A.H. and N.E. Krohn, Radian Corporation, to
SeKan?er18» 198°- 19 P- Report of July 30, 1980 visit to
Chemical Company in Anderson, South Carolina
7-25
-------
8. COSTS
The cost impacts of implementing the various regulatory alternatives
are presented for each model plant in this chapter. Both process and
control costs are presented, however, the emphasis is on the incremental
control costs above an assumed baseline regulatory alternative. The
bases for the cost analysis are presented in terms of the data sources,
assumptions, and factors used in this analysis. These cost impacts will
serve as inputs to the economic analysis in Chapter 9.
8.1 COST ANALYSIS OF REGULATORY ALTERNATIVES
Three regulatory alternatives are presented in Chapter 6. These
alternatives call for an overall volatile organic compound (VOC) reduction
of 65, 75, or 85 percent.
• Regulatory Alternative I, the baseline, is based on the Control
Techniques Guideline (CTG) document for special products in the Graphic
Arts industry. This control alternative assumes no NSPS would be
promulgated. Regulatory Alternative I is based on an overall VOC emission
reduction of 65 percent. This 65 percent level represents a system
which captures 70 percent of the total solvent from the FVC&P finishing
operation and recovers or destroys 95 percent of those emissions.
• Regulatory Alternative II represents the first level of NSPS control
being considered. This control level is based on an overall VOC emission
reduction of 75 percent. The control system for Alternative II would
capture 80 percent of the total solvent emitted from the finishing
operation and then recover or destroy 95 percent of those emissions.
• Regulatory Alternative III represents the second level of NSPS
control being considered. Alternative III is based on an overall VOC
emission reduction of 85 percent. The 85 percent level represents a
8-1
-------
system which captures 90 percent of the total solvent emitted from the
finishing operation and then recovers or destroys 95 percent of those
emissions.
Each regulatory alternative is applied to five model plants. A
total of fifteen model plant cases result. Specific information about
each model plant is presented in Chapter 6. A cost analysis is presented
in this section for each model plant and corresponding emission control
system. A discussion concerning modified or reconstructed facilities is
also presented.
8.1.1 New Facilities
Table 8-1 outlines the five model plants that are examined in this
cost analysis. The probable accuracy of the cost estimates presented in
this section is ±30 percent. The results are to be used as a comparative
basis to document the economics which may face a manufacturer if a
regulation goes into effect. All costs for this study are expressed in
mid-1980 dollars.
8.1.1.1 Installed Capital and Annualized Costs. Fixed-bed carbon
adsorption systems are used as the VOC emission control devices in the
model plants. Other control devices, such as incinerators, are available,
however, fixed-bed carbon adsorption systems currently are used almost
exclusively in the industry. The use of waterborne inks is another
control option but no cost information is available from industry.
There is little commercial use of waterborne inks in the FVC&P industry.
Presently, it is likely that incineration and waterborne inks prove
to be more costly control options. With further development, waterborne
inks may prove to be a less costly control option. If incineration or
waterborne inks provide lower costs than carbon adsorbers, and are
implemented by industry, this would not effect the conclusions of this
study.
Table 8-2 lists the assumptions used in calculating the capital and
operating costs of the model plants and their control systems. Some
costs such as raw materials, utilities and labor are highly dependent on
location. A detailed study of these variations will not be presented in
this report.
8-2
-------
TABLE 8-1. MODEL PLANTS
Model
Plant
A
B
C
D
E
Web2'3'4'5
Width
m
(inches)
1.5
(60)
1.5
(60)
0.76
(30)
1.5
(60)
1.5
(60)
Number
of
Print
Lines
1
1
1
6
6
234
Number ' *
of
Print
Stations
3
6
6
18a
36b
,5
i f
Ink1'6
Formulation
5% solids
5% solids
5% solids
5% solids
5% solids
Three print stations per print line
Six print stations per print line
8-3
-------
TABLE 8-2. BASES FOR ANNUALIZED COST ESTIMATES
Description
Unit Cost
Basis for Costs
Annualized costs for new
installation
Average model plant operating time
Average Carbon adsorption, solvent
recovery system operating time
Direct Operating Costs
Operating Labor
Operator
Supervisor
Maintenance
Raw Materials
Carbon Replacement
Utilities
Steam
Electricity
Water
Fuel
One Year
3600 hr/yr
Commencing mid-June
(1980)
60% of scheduled
operating time
6000 hr/yr for adsorbers
3600 hr/yr for solvent recovery
$10.00/hr
15% of operator
labor
5% of installed
capital
0.52/sq.m
(0.46/sq. yd)
0.59 sq.m
(0.49/sq. yd)
$2.53/kg
Replace every
three years
$11.00/Mg
($5.00/1000 Ib)
$0.05/kWh
$0.26/m3
($0.972/1000 gal)
$3.80/loil
($4.00/10DBtu)
Reference 10
Reference 10
Reference 10
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
Reference 6
8-4
-------
TABLE 8-2. (CONTINUED)
Description
Unit Cost
Basis for Costs
Indirect Operating Costs
Overhead
Taxes and Insurance
Administration
Capital Recovery Factor
Finishing line
Carbon adsorption
Credits
Solvent credit
80% of labor Reference 10
2% of installed capital Reference 10
2% of installed capital Reference 10
10.226% of installed capital 10% interest
rate, 40,-year
lifetime6
11.746% of installed capital 10% interest
rate, 20,-year
lifetime6
$0.704/kg($0.32/lb)
Recovered solvent
for sale or reuse
12
8-5
-------
Finishing Line Costs
The installed capital costs for the finishing lines (without control
equipment) are based on vendor' and industry sources. The installed
capital cost of a 1.5 meter (60 inch), 3 station model plant printing
line is estimated at 1 million dollars. The installed capital cost of a
1.5 meter (60 inch), 6 station model plant printing line is estimated at
1.8 million dollars. The installed capital cost for a 0.76 meter (30
inch), 6 station model plant print line is estimated at 1 million dollars.
These model plant printing lines include the rotogravure presses and
associated ovens, web winders and rewinders, ink tanks, pumps, LEL
meters, steam piping, motors and starters, quality control inspection
equipment, web speed control devices, ventilation equipment (such as
fans and hoods to meet OSHA regulations), and housing structures.
Annualized costs for the model plant print lines were developed using
the assumptions presented in Table 8-2 and utility requirements presented
in Table 6-4. The installed capital and annualized costs for the model
plant finishing lines are presented in Table 8-3.
Control Equipment Costs
Several sources were investigated in the development of the control
equipment installed capital costs: industry contacts, vendor quotes8'9
and EPA reference manuals.1 '13 EPA reference manuals10'13 were not
adequate because complex distillation equipment must be used in this
industry and these manuals did not contain costing information for this
8 9
equipment. Vendor ' information was often incomplete and did not
reflect the installation costs for these systems. Equipment costs
before installation were not available from industry sources because the
control systems were installed and turned over to the plants as operational
units. Therefore, the installed capital costs for the model plant
control systems were estimated using industry cost data for installed
control systems. Figure 8-1 is the cost curve used to estimate the
installed capital costs of the model plant control systems. This cost
curve was used to cost model plant control systems for all the Regulatory
Alternatives.
8-6
-------
TABLE 8-3. INSTALLED CAPITAL AND ANNUALIZED COSTS FOR UNCONTROLLED
MODEL PLANTS ($1980)
Model Plant
Production m Xyr
(ydVyr)
Installed Capital Cost
Direct Operating Costs
Operating Labor
Operator
Supervisor
Maintenance
Utilities
Electricity
Fuel
Raw Material:.
Indirect Op era ti mi Costs
Overhead
Taxes and Insurance
Administration
Capital Recovery Cost
Total Annual ized Cost
$/sq.m
($/sq.yd)
A
1.8 x 10*
(21.6 x 10°)
1,000,000
240,000
36,000
50,000
37,000
18,000
9,936,000
241,000
20,000
20,000
100,000
10,698,000
0.59
(0.50)
B
1.8 x 10*
(21.6 x 10b)
1,800,000
300,000
45,000
90,000
37,000
92,000
10,600,000
312,000
36,000
36,000
180,000
11,728,000
0.65
(0.54)
C
0.9 x 10*
(10.8 x 10b)
1,000,000
240,000
36,000
50,000
18,000
44,000
5,300,000
241,000
20,000
20,000
100,000
6,069,000
0.67
(0.56)
D
11 x 10*
(130 x 10b)
6,000,000
1,320,000
198,000
300,000
220,000
110,000
59,800,000
1,334,000
120,000
120,000
610,000
64,132,000
0.58
(0.49)
E
11 x 10*
(130 x 10b)
10,800,000
1,680,000
252,000
540,000
220,000
480,000
63,700,000
1,762,000
216,000
216,000
1,100,000
69,914,000
0.64
(0.54)
-------
itr
Figure 8-1. Estimated installed capital costs for
model plant control systems
8-8
-------
Figure 8-1 was developed using the 0.6 power law estimating equation
and industry cost data for a medium sized control system3 represented by
point A in Figure 8-1. The equation is as follows:
Cost of new system ($1980) = Cost of system A ($1980) fCapaci'ty of new system. SCF^f
^Capacity of system A, SCFM I
The validity of this equation is demonstrated by the fit, to the cost
curve, of the installed capital cost ($1980) of another control system
in the industry much larger in capacity than system A, represented by
point B in Figure 8-1. Comparisons of the installed capital costs based
on the above equation with vendor data and EPA manuals indicate these
costs may be on the high side. This would cause the annualized costs
for the model plant control systems to be on the high side. For the
purpose of this study, this conservatism is acceptable.
Equipment included in the model plant control systems are air
filters, humidifiers, fans, motors; 316 stainless steel adsorption
vessels, condensers, product coolers, seal pots and piping; carbon steel
mixing tanks, distillation columns with bubble cap trays, reflux drums,
and dehydrators; appropriate instrumentation and housing structures for
this equipment, and the necessary vapor capture systems to achieve the
required levels of VOC capture. Annual ized costs for the model plant
control systems were developed using the assumptions listed in Table 8-2
and the utility usages listed in Table 6-7. Credits for recovered
solvent were given based on recoveries of 90 percent of the potentially
recoverable solvent. This allows for a 10 percent loss in the distillation
and dehydration systems and provides for any solvent in the printed web
leaving the finishing line. The installed capital and annualized costs
for the model plant control systems may be found in Table 8-4.
8-1.1.2 Cost Analysis and Cost Effectiveness. Table 8-5 contains
the total annualized costs for the controlled model plants. Analysis of
these costs lead to several conclusions:
.6
8-9
-------
TABLE s-4. ANNUALIZFP COSTS FOR voc CONTROL SYSTFMS
co
i
! — »
CD
MODEL PL MIT
Overall VOC Control Efficiency
Carbon Adsorption System
Capacity risen/sec
(SCFH)
Installed Capital Cost
Direct Operating Costs
Operating Labor
Operator
Supervisor
Maintenance
Ca -bon Replacement
Ut Htles
Electricity
Water
Indirect Operating Costs
Overhead
Taxes and Insurance
Administration
Capital Recovery Cost
r^oAttrl V
Recovered Solvent
Total Annual ized Cost
.
65
0.93
(2200)
607,000
30,000
4,500
30,000
1.100
16,000
4,200
400
40,000
12,000
12,000
71,000
(110,000)
111,200
A
75
1 l
(2600)
672,000
30,000
4,500
34,000
1.200
19,000
4.800
400
41,000
13,000
13,000
79,000
(130,000 )
109,900
85
(3000)
732,000
30.000
4,500
37.000
1,400
21.000
5,700
500
42,000
15,000
15,000
86,000
(150,000)
108 100
510
65
(11000)
45,000
6,800
80,000
5,200
78,000
21,000
1.800
73.000
32,000
32,000
190,000
(550,000)
19
75
(13000)
45.000
6,800
88,000
6,000
90,000
25,000
2,100
77.000
35.000
35,000
210,000
(640,000)
(22)
85
(15000)
45,000
6.800
96,000
6,800
100,000
29,000
2.400
80,000
38,000
38,000
230,000
(720,000)
(47)
65
2.4
(5400)
30,000
4,500
52,000
2,600
39,000
10,000
900
48,000
21.000
21.000
120,000
(280,000)
180
c
75
2.8
(6300)
1.140, COO
30,000
4,500
57,000
3,000
45.000
12.000
1,000
50,000
23.000
?3,nno
130,000
(320.000)
58,500
130
85
3.2
(7200)
1,240,000
30,000
4,500
62,000
3,400
51,000
14,000
1,200
52,000
25,000
25,000
140,000
(360,01X1)
48,100
93
65
6.1
(14000)
1,840,000
45,000
6,800
92,000
6,500
99,000
26,000
2,300
78,000
37,000
37,000
220,000
(690,000)
(40,400)
(41)
D
75
7.0
(16000)
2,000,000
45,000
6,800
100,000
7,500
110.000
30,000
2,700
81,000
40.000
40,000
230,000
(800,000)
(107.000)
(94)
85
7.9
(18000)
2,150,000
45,000
6,800
110,000
8,400
130,000
33,000
3,000
as, ooo
43,000
43.000
250,000
(910,000)
(152,800)
(120)
65
28
(65000)
4,630,000
75,000
11.000
230,000
31,000
480,000
120,000
11.000
160,000
93,000
93,000
540.000
(3,300,000)
(1,456,000)
(310)
E
75
33
(76000)
5.090,000
75,000
11,000
250,000
36,000
540,000
140,000
13,000
170,000
100,000
100,000
600,000
(3,800,000)
(1,765,000)
(320)
85
36
(83000)
5,370,000
75,000
11,000
270,000
41 000
600.000
160,000
14,000
180,000
110,000
110,000
630,000
(4,300,000)
(340)
-------
TABLE 8-5. ANNUALIZED COSTS FOR CONTROLLED MODEL PLANTS
MmlpI PUnt
Proiliirt ion uu/yt
(y /y)
Iota) Annual Izeil Cost
foi Uncontrolled I'lant
Ovpull VOC Control
lotal Annual l/pd Cost for
Control Syslpm (credits)
Total Annnallzpd Cos!
for Control IPC! Plant
I/si..
(t/sn.yii)
A
1.8 K IflJ
(71.6 x 10")
10,690,000
65 75 BO
111,200 109.900 Kin. Kill
10,809,200 I0.n07.90fl 10.n4n.000
0.60 0.60 0.60
(0.50) (0.50) (0.50)
B
l.n x 10'
(71.6 x in )
11,720,000
65 75
14.BOO (20,100)
11,747,1100 11,707,900
0.65 0.65
(0.54) (0.54)
C
0 9 x K)'
(Ifl.n x I0h)
6,069,000
05 65 75 B5 65
(48,000) 69,000 TO, 500 411,100 (40,400)
ii.eno.ooo 6,nn.ooo 6,177,500 6, n/.ioo 64, 091, 500
0.65 0. 6B 0.6B O.fifl 0. 5B
(0.54) (0.57) (0.57) (0.57) (0.49)
D
11 x 10J?
(130 x 10")
64,132,000
75 85
(107,000) (162,000)
64,025,000 63,979. 70(1
0.5fl 0. 5B
(0.49) (0.4'J)
r
11 x I0fl
(110 x III5)
69,914,00(1
6', 75
(1.4%, 000) (1,765,000)
GII,4'iH,m«t 6R, ll'l.ilim
0.6? 0.6?
(0.5?) (0.52)
B5
(7,099,000
ft!,ttlrt,00
-------
1) The total annualized costs for the control systems represent
0.6 to 1.2 percent of the total annualized costs for the controlled
model plants.
2) As can be seen in Table 8-5, the incremental costs above the
baseline cases (65 percent overall control) for Regulatory Alternatives
II and III are negligible.
3) The total annualized costs for both the uncontrolled model
plants and the controlled model plants are dominated by raw material
costs as can be seen in Tables 8-3 and 8-5.
8.1.1.3 Compliance Monitoring and Performance Testing Costs.
Monitoring of the exit gases from the carbon adsorption, solvent recovery
systems should not present a major added cost. Monitoring requirements
will include the continuous measurement and recording of VOC emissions
from the control device if carbon adsorption is used, continuous measurement
and recording of flame box temperature if incineration is used. Costs
associated with these requirements for carbon adsorption are included in
the capital and annualized costs presented in this chapter. In addition,
compliance monitoring will require the determination of the weight of
VOC (solvent) per unit weight of solids (resins) applied to the web for
each waterborne ink used on the print line. Compliance testing also
should not be a major added cost. However, a nominal cost of $5,000 and
$10,000 per year is included in the operating costs. Appendix D gives
more information on emission measurement and continuous monitoring of
controlled finishing line facilities.
Performance testing will require the capture and measurement of all
fugitive emissions escaping the finishing line. This may require temporary
modifications to the structure housing the print line so as to provide a
total enclosure of the print line. Performance testing would be infre-
quent, possibly a one time test. Costs associated with this testing are
included in the installed capital costs tabulated in this document.
8-1?.
-------
8.1.1.4 Costs Associated With Increased Water Pollution or
Solid Waste Disposal. There are two potential water wastes from the
carbon adsorption, solvent recovery system: bottoms product from the
distillation column and cooling tower blowdown. Because of complex
distillation involved in the solvent recovery system, the bottoms product
will contain a very low concentration of solvent ( 400 ppm) and may be
disposed of in a municipal sewer system. The cooling tower blowdown is
expected to be small ( 12 gpm), allowing its disposal in a municipal
sewer system. These discharges are not expected to generate any surcharges.
The actual amount of any surcharges would be determined by local regula-
tions. In any event, it is unlikely that such charges would be signifi-
cant costs.
Carbon adsorption has a solid waste also: spent carbon. The spent
carbon is usually sold back to processors, reactivated, and then sold
again to the original purchaser or other carbon adsorber operators.
Therefore, there is no solid waste disposal cost.
8.1.2 Modified or Reconstructed Facilities
The definitions of modified or reconstructed facilities are given
in Chapter 5. Modifications and reconstructions may occur in existing
facilities, however, modifications and reconstructions are not considered
major items of significance in this industry. The cost analysis presented
in section 8.1.1 can be applied to a modified or reconstructed facility
with the following qualifications:
1) Land requirements for control equipment may be critical for an
existing facility.
2) Fugitive capture equipment costs will be higher on older presses
due to the generally poor fume containment within older printing lines.
3) Ducting costs may become more expensive if control equipment
must be located far from the printing lines.
8.2 OTHER COST CONSIDERATIONS
The flexible vinyl coating and printing industry is governed by
regulations concerning the environment within the plant as well as the
outside environment.
8-13
-------
The costs incurred by other governmental regulations are not expected
to limit the financial ability of these plants to comply with the proposed
NSPS. Such governmental regulations would consist of the following:
•Standard OSHA work place regulations,
• RCRA regulations affecting disposal of scrap materials,
• Monitoring regulations for vinyl chloride monomer,
•State regulation monitoring requirements for existing facilities.
8-14
-------
8.3 REFERENCES
1. Vincent, E.J. and W.M. Vatavuk. Control of Volatile Organic
Emissions from Existing Stationary Sources - Volume VIII Graphic
Arts -Rotogravure and Flexography. (Prepared for U.S. Environmental
Protection Agency.) Research Triangle Park, North Carolina. Publica-
tion No. EPA-450/2-78-033. December 1978.
2. Trip report. Laube, A.M. and D.T. Smith, Radian Corporation, to
file. January 27, 1980. 6 p. Report of December 12, 1979 visit
to Stauffer Chemical Company in Anderson, South Carolina.
3. Telecon. Laundrie, R., General Tire and Rubber Company, with
Laube, A.M., Radian Corporation. September 26, 1980. Conversation
about solvent recovery costs.
4. North Carolina Department of Natural Resources and Community Develop-
ment to Radian Corporation. 1980. pp. 68-159. Permit applications.
5. Letter and attachments from Manufacturer G to Farmer, J , EPA-CPB
May 23, 1980. 14p. Response to Section 114 letter.
6. Memo. Krohn, N.E., Radian Corporation, to Laube, A.M., Radian
Corporation. January 12, 1981. 3 p. Information about bases for
annualized costs.
7. Letter from Deamer, H.A., Windmoeller & Hoelscher Corporation, to
Krohn, ME., Radian Corporation. February 9, 1981. 1 p. Information
on finishing line costs.
8. Letter from Holden, J.T., Sutcliffe-Speakman, Ltd., to Krohn N E
Radian Corporation. October 6, 1980. 7 p. Information about ' "
solvent recovery.
9. Telecon. Thomas, M., Vara International, with Laube, A.H Radian
Corporation. October 8, 1980. Conversation about costs of carbon
adsorption systems.
10. Neveril R.B. (GARD, Inc.) Capital and Operating Costs of Selected
Air Pollution Control Systems. (Prepared for U.S. Environmental
K? l™}*nd?%X?'}n Res*arch ^Tangle Park, N.C. Publication No.
EPA-450/5-80-002. December 1978. pp. 3-12, 3-14, 5-45, 5-46, 5-48.
11. Memo. Krohn, N.E., Radian Corporation, to Laube, A.H., Radian
Corporation. January 12, 1981. 2 p. Information about installed
capital costs for model plant finishing lines.
8-15
-------
12. Current Prices of Chemicals and Related Materials. Chemical
Marketing Reporter. 217_(26): 37, 41. June 30, 1980.
13. U.S. Environmental Protection Agency. Cost Analysis Manual for
Standards Support Document. April 1978.
14. Memo. Krohn, N.E., Radian Corporation, to Laube, A.M., Radian
Corporation. January 29, 1981. 5 p. Information about installed
capital costs for control systems of model plants.
8-16
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9.0 ECONOMIC ANALYSIS
9.1 INDUSTRY PROFILE
9.1.1 General Industry Characteristics
9.1.1.1 Introduction. The flexible vinyl coating and printing indus-
try (FVCP) produces a wide variety of diversified products. These products
may be divided into two main groups: supported and unsupported vinyl mater-
ials. Supported vinyl materials (usually supported with a fabric or paper
substrate) may be further subdivided into three major categories: 1) wall
coverings; 2) automobile-related products (such as landau roofs, roof head-
linings, upholstery, door panels, etc.); and 3) miscellaneous products (such
as luggage, handbags, footwear, upholstery, artificial leather, and marine
products). Unsupported vinyl materials are used to manufacture shower
curtains, book binding, window awnings, shades, and are also printed with
a wood grain finish for lamination to furniture.
There are approximately 107 firms producing flexible vinyl coated and
printed materials (FVCP) in 112 plants.1 These firms are identified in
Appendix E. The industry is partially contained in SIC 2295 (coated fabrics
not rubberized) and SIC 2649 (converted paper and wall coverings). Table
9-1 displays the value of shipments and total quantity produced in the FVCP
industry in the latest year available. As the Table reveals, the 1977 value
of industry shipments was $981.5 mill ion.2
Geographically, most of the industry is concentrated in the northeast
and north central regions in the U.S. The bulk of the production comes from
Massachusetts, New Jersey, New York, Ohio, Connecticut, and Pennsylvania.1*2
Figure 9-1 depicts the geographical locations of FVCP operations in the U.S.
Approximately 60 percent of the total output of the industry is produced
by twenty firms.4 Table 9-2 shows these major producers, their location, and
the primary end-use markets for their products.
9-1
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Table 9-1. VALUE OF SHIPMENTS AND TOTAL QUANTITY
PRODUCED IN THE FVCP INDUSTRY: 1977
Vinyl Coated Fabrics (SIC 22952)
Total Quantity Produced
Value of Shipments Millions of Square Meters
(Millions) (Sq. Yds.)
Lightweight Fabrics
Mediumweight Fabrics
Heavyweight Fabrics
Not Specified by Kind
$160.0
214.1
382.2
50.6
137
204
224
31a
(164)
(244)
(268)
(37)
$806.9 596 (713)
Wall Coverings (SIC 26493)
Value of Shipments Total Quantity Produced
(Millions) Millions of kg (Ibs.)
Wallpaper $174.6 63.3b (139.3)
Total $981.5
aEstimate based on 1972 data.
bEstimated by dividing value of shipments by the average price per kilogram
of wallpaper. The average price per kilogram of wallpaper was taken to be
equivalent to the implicit price of wallpaper exports, i.e., the 1977 dollar
value of wallpaper exports divided by the total quantity (in millions of
kilograms) of wallpaper exported.3
Source: Reference 2.
9-2
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UD
CO
V...V rS'a-^3A"6~A'~1 ~i f«,SCONSr-^
^-•V'VC^; . I ' m
L •.MISSOURI \
Fiqure Q-l. r.m^p.APHICAL LOCATIONS OF VTiYL CO/'TIMG AND PRINTING OPERATIONS
IN THE UNITED STATES
-------
Table 9-2. COMPANIES WHICH CONSTITUTE THE MAJORITY OF PRODUCTION
IN THE FLEXIBLE VINYL COATING AND PRINTING INDUSTRY
Company
Plant Location
Primary End-Use
Markets for Products
Althol Manufacturing Corp.
(Emhart)
B. F. Goodrich Co.
L. E. Carpenter and Co. (Dayco)
Chrysler Plastic Products Corp.
Borden Chemical Div.
(Borden, Inc.)
Commercial Vinyls, Inc.
Firestone
Ford Motor Co.
General Motors
General Tire and Rubber Co.
Hart and Co.
Joanna Western Mills Co.
Masland Duraleather Co.
Pandel Bradford (Compo)
Ross and Robert's Inc.
(Pervel)
Shelter-rite
Standard Coated Products
Stauffer Chemical Co.
Uniroyal Inc.
Weymouth Art Leather Co.
Butner, NC
Mariott, OH
Wharton, NJ
Sandusky, OH
Columbus, OH
Haverhill, Mass,
Glen Cove, NY
New Castle, IN
Pottstown, PA
Dearborn, MI
Dearborn, MI
Columbus, MS
Reading, MA
Toledo, OH
Brooklyn, NY
Chicago, IL
Mishawaka, IN
Lowell, MA
Stratford, CT
Millersburg, OH
Hazleton, PA
Anderson, SC
Stoughton, WI
Port Clinton, OH
Mishawaka, IN
Braintree, MA
Automobile Interiors,
Upholstery
Wallcovering
WaiIcovering
Automobile Interiors,
Landau tops
Wallcovering, Automobile
Interiors, Upholstery
Footwear, Handbags, Uphol-
stery
Luggage, Footwear
Automobile Interiors,
Upholstery
Upholstery, Auto Interiors
Automobile Interiors,
Wallcoverings, Luggage,
Footwear, Shower Cur-
tains, Upholstery,
Marine Uses
Housewares, Mats, Vinyl
Fabric
Window Shades, Handbags,
Luggage
Artificial Leather Goods
Footwear, Luggage, Hand-
bags
Footwear, Handbags, Uphol-
stery
Awnings
Wallcovering
Automobile Interiors,
WaiIcovering
Automobile Interiors,
Upholstery, Marine Uses
Leather Goods, Automobile
Interiors, Upholstery
Source: References 1 and 4.
y-4
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9.1.1.2 Production Processes. The production hierarchy for the vinyl
coating and printing industry is shown in Figure 9-2. The four basic pro-
cessing steps in the manufacture of a vinyl-based consumer product are:
• Manufacture of the vinyl coating and ink raw materials (PVC,
plasticizers, pigments),
•Formulation of the vinyl and ink coatings,
•Manufacture of the vinyl coated or printed roll, and
•Conversion of the flexible vinyl roll to a consumer good (shoes,
luggage, etc.).
The chemical industry manufactures the raw materials used in compounding
the vinyls to be coated and printed. PVC resins (a product of vinyl chloride
monomer), plasticizers, pigments, and organic solvents are examples of such
raw materials. Companies in the FVCP industry may purchase coatings and inks
from independent formulators, but the majority formulate their own coatings
and inks in house. These latter companies buy raw materials directly from
the chemical firm and compound them into the desired coating at the vinyl
coating plant. These coatings are transformed into supported or unsupported
vinyl sheet by one of the following processes: casting, calendering, or
extrusion. Once a vinyl sheet has been produced, it may be printed or
topcoated (by rotogravure print heads) to impart a particular color, design,
or texture. In some cases the printed vinyl sheet product can be sold to
consumers as is. Wallcoverings and shower curtains are examples of such
products. The remaining vinyl sheet products are used as raw materials by
captive or private manufacturers of shoes, luggage, handbags, automobiles,
and upholstery. The final consumer goods are produced by these secondary
converters.
The primary component of the topcoats and printing inks applied in the
vinyl industry is organic solvent. Oven drying of the printed web releases
the solvent as volatile organic compound (VOC) emissions. Both single and
multi-component solvent systems are used. The use of solvent-based formula-
tions is expected to continue for several years despite industry efforts to
changeover to waterborne formulations. A massive switch to a waterborne
formulation system would eliminate VOC emissions; however, three major
9-5
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Manufacture of Raw
Materials (PVC, Pigments,
Plasticizers)
Supplier of Fabric
and Paper Substrates
Formulation of
Vinyl Coatings and Inks
1
Manufacture of Vinyl-coated
Sheets
1
Printing and Topcoating
of Vinyl-coated Sheets
Manufacture of Vinyl-based
Consumer Product
Consumer
Figure 9-2. PRODUCTION HIERARCHY FOR THE FLEXIBLE
VINYL COATING AND PRINTING INDUSTRY
9,-e
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problems prohibit such a changeover. These problems are: 1) the technical
inability to develop waterborne products that duplicate the specifications
of solvent-based products, 2) customer acceptance of waterborne coated
products, and 3) waterborne raw materials have higher costs than comparable
solvent-based materials.
9.1.2 Firm Characteristics
9.1.2.1 Ownership. Of the twenty major producers listed in Table 9-2,
fourteen are publicly-held or owned by publicly-held corporations, and six
(Weymouth Art Leather, Hart, and Co., Joanna Western Mills, Pervel Industries,
Commercial Vinyls, and Masland Duraleather) are privately-held. Only 15
percent of the remaining 87 producers in the FVCP industry are publicly-held.5
The remaining firms are either privately-held or very small (over-the-counter)
companies (so as not to be listed in Standard and Poor's Corporate Records).
9.1.2.2 Vertical/Horizontal Integration. Vertical integration backward
to suppliers of polyvinyl chloride (PVC), which is the major raw material
used in vinyl coating, is evident in one-fourth of the major producers:
Stauffer, B. F. Goodrich (the largest producer of PVC), General Tire, Fire-
stone, Bordon (Columbus Coated Fabrics).1>6 if one focuses exclusively on
wall coverings, two-thirds of the PVC used is produced captively.? Only
two firms produce their own PVC monomer (the raw material used to make PVC):
B. F. Goodrich and Borden.
There also exists a considerable degree of forward integration to final
end-use products, particularly for the larger firms. For example, eleven of
the major producers manufacture automobile interiors and upholstery, six
produce wall coverings, and nine produce a variety of miscellaneous products,
such as footwear, handbags, luggage, and artificial leather goods.1»8
With respect to horizontal integration, the larger firms are the most
diversified, producing a myriad of products. In addition to FVCP products
and tires, for example, Goodrich, General Tire, and Uniroyal also manufacture
chemicals, plastics, industrial and aerospace products, and rubber goods.8
The major automobile firms also produce weapons, communications systems,
sewage treatment systems, refrigerators and other appliances, and glass.l
Others, such as Borden and Stauffer Chemicals make food products, industrial
chemicals, fertilizers, and cosmetics.1
9-7
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9.1.2.3 Concentration. Table 9-3 shows the trend in concentration in
the industry over the 1954-1977 period. The prevailing trend in the first
part of this period was toward a decrease in concentration. The end of this
trend occurs between 1963 and 1972. The concentration ratios reach their low
point in the 1967-1972 period for the vinyl coated fabrics industry (SIC
22952) and in 1963 for the wallcovering industry (SIC 26493).
In recent years the trend has changed toward more concentration in both
industrial sectors. This trend is most evident in the category of the four
largest manufacturers. For the 22952 SIC code, the concentration ratio has
increased from a low of 41 percent in 1967 to 53 percent in 1977. Similarly,
for the 26493 SIC code, the concentration ratio has increased from a low of
32 percent in 1963 to 45 percent ir 1977.
9.1.3 Industry Trends
9.1.3.1 Historical Production. Because growth within the flexible
vinyl coating and printing (FVCP) industry has been uneven, it is best to
divide the industry into three subgroups: supported vinyl materials (exclud-
ing wall coverings), unsupported vinyl film, and wall coverings. Each of
these sub-groups is treated separately below.
9.1.3.1.1 Supported vinyl materials. Table 9-4 displays the value of
shipments of supported vinyl materials (coated fabrics) for various end-uses
for the 1971-79 period. According to these figures, the annual growth rate
was 3.7 percent in dollar volume (see Appendix F for the computation of this
growth rate). In order to determine the annual growth rate of physical
output, the dollar volumes must be deflated by an appropriate price index.
The most appropriate index is the wholesale price of apparel goods (including
coated fabrics) which grew at a 4.2 percent annual rate over this period.
Thus, the real output growth of this industry segment was negative over the
1970 decade since the price index outpaced the value of shipments (see
Appendix G).
Thus, no real output growth is expected over the next five years due to:
a) The switch to smaller cars in general and foreign cars in particular
and to the health hazard controversy surrounding vinyl and PVC; and
b) The assumption that past trends will continue into the future.
9.1.3.1.2 Unsupported vinyl film. The value of shipments of unsupported
flexible vinyl film is displayed in Table 9-5. As the table reveals, value
of shipments grew at an annual rate of 4.51 percent. The price index which
9-8
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Table 9-3. TRENDS IN CONCENTRATION: 1954-1977
SIC
22952
26493
Year
1954
1958
1963
1967
1972
1977
1954
1958
1963
1967
1972
1977
4 Largest3
55%
47%
47%
41%
43%
53%
40%
41%
32%
39%
49%
45%
8 Largest
73%
67%
71%
63%
62%
68%
57%
57%
48%
56%
63%
63%
20 Largest
92%
90%
90%
85%
83%
86%
79%
82%
75%
79%
84%
87%
Represents the percentage of total output produced by the four largest manu-
facturers.
Source: Reference 9.
9-9
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Table 9-4. VALUE OF SHIPMENTS OF SUPPORTED VINYL MATERIALS
(EXCLUDING WALL COVERINGS) FOR VARIOUS END-USES
(Millions of Dollars)
End-Use
Automotive
Upholstery
Luggage
Footwear
Transportation
Garments
Handbags
Other
Total
1971
274.40
113.50
11.90
38.30
18.40
3.75
1.86
26.80
488.90
1973
393.20
141.00
21.40
40.20
24.30
6.98
2.99
34.50
664.60
1975
330.60
160.50
22.70
21.40
23.00
4.80
1.48
42.70
607.20
1977
485.90
161.10
21.60
8.90
27.80
5.21
0.59
49.30
760.50
1979
371.10
144.00
17.40
10.10
53.80
4.65
3.37
97.70
702.10
Source: The Chemical Film and Fabric Association.
9-10
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Table 9-5. VALUE OF SHIPMENTS OF UNSUPPORTED VINYL FILM
(Millions of Dollars)
Year Value of Shipments
1971 305.3
1973 548.6
1975 513.6
1977 581.7
1979 531.9
Source: The Chemical Film and Fabric Association.
9-11
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closely approximates this product group (so as to permit the deflation of the
series) is that for unsupported plastic (PVC) film. This index advanced at an
8.35 percent annual rate over the 1971-1979 period. Since this index advanced
at a faster pace than the value of shipments, a negative growth in real output
is implied. Moreover, there is much excess capacity currently in this industri-
al segment. Accordingly, if it is assumed that past trends will continue, then
no growth over the next five years is anticipated in unsupported vinyl film.
9.1.3.1.3 Wall coverings. Table 9-6 shows the volume of shipments for
wall coverings over the 1971-79 period. According to the table, the dollar
volume of shipments increased at an annual rate of 14.68 percent. The impli-
cit (export) price of wall coverings (found by dividing value of shipments ex-
ported by quantity exported) increased at a 5.3 percent annual pace over the
same period. Consequently, an 8.9 percent annual growth rate in real output
is implied (see Appendix F). This rate will be taken as the projected growth
rate over the next five years because it reflects the growing popularity of
wall coverings over paint for interior decorating purposes -- a trend reflec-
ted in the optimistic forecasts for this market segment by B. F. Goodrich and
Peter Sherwood Associates.
9.1.3.2 Demand Determinants. Table 9-7 contains the percentage distribu-
tion of the various end-use markets for FVCP over the 1971-1979 period. Uphol-
stery and auto-related commodities account for almost three-quarters of the
FVCP produced. 10 The remaining one-quarter is consumed by transportation
(other than auto), luggage, footwear, garments, handbags, and other miscellan-
eous uses (shower curtains, marine canvas, bookbinding, etc.). Wall coverings
are excluded from Table 9-7 since they are already a final product.
The outlook for the automobile-related markets does not appear promising
over the next few years -- partly due to the switch to smaller cars in general
and to the growing market share of foreign cars in particular. Little growth
is also expected in end markets such as upholstery, luggage, handbags, apparel,
and sporting goods over the next five years.H Steady growth, however, is
expected for wall coverings, which account for about 7 percent of FVCP indus-
try sales.
9.1.3.3 Raw Materials. The major raw material in the FVCP industry is
PVC resin. The largest producer, B» F. Goodrich, has announced plans to doub-
le its present capacity (currently 1522 millions of kilograms^) by 1986. Other
producers, such as Borden, Diamond Shamrock, Skintech, Air Products, Tenneco,
9-12
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Table 9-6. VALUE OF SHIPMENTS OF WALL COVERINGS
(Millions of Dollars)
Year
1971
1973
1975
1977
1979
Value of Shipments
60.6
102.4
119.9
163.9
210.0
Source: The Chemical Film and
Fabric Association.
9-13
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Table 9-7. PERCENTAGE DISTRIBUTION OF END-USE MARKETS FOR FVCP
End-Use
Automotive
Upholstery
Luggage
Footwear
Transportation
Garments
Handbags
Other
Total
1971
56.1%
23.2
2.4
7.8
3.7
0.7
0.3
5.8
100.0
1973
59.2%
21.2
3.2
6.0
3.7
1.0
0.4
5.2
100.0
1975
54.4%
26.4
3.7
3.5
3.8
0.8
0.2
7.0
100.0
1977
63.9%
21.2
2.8
1.2
3.7
0.7
0.1
6.5
100.0
1979
52.9%
20.5
2.5
1.4
7.7
0.7
0.5
13.9
100.0
Source: The Chemical Film and Faiaric Association,
9-14
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Conoco, Georgia-Pacific, and Keysor, have also announced expansions and/or
new plants to be completed in the near future (1982).12 Consequently, an
adequate supply should be available in the 1980's.
Table 9-8 shows the producer price index for polyvinyl chloride (PVC)
resin over the 1971-1979 period. While the index advanced at a 4.1 percent
annual rate over the 1971-73 period, it advanced at an accelerated rate (9.1%)
after 1973. Since PVC is a petroleum based product, the accelerated rate re-
flects the oil embargo in 1973. Future price changes for PVC resin will no
doubt continue to be extremely sensitive to oil price changes.
9.1.3.4 Foreign Competition. The major countries to whom the U.S.
exports vinyl coated fabrics and materials are: Canada, Dominican Republic,
Venezuela, United Kingdom, Italy, Haiti, Japan, and Australia.3 U.S.
exports of wall coverings go to Canada, West Germany, France, United Kingdom,
Venezuela, Sweden, Mexico, Australia, Saudi Arabia, and Japan. As Table 9-9
makes clear, exports of FVCP as a percentage of total industry output have
remained fairly constant over the 1973-77 period.14 Hence, exports are
not considered a growth center over the next few years.
According to Table 9-9, imports have actually declined in importance over
time, from 4 percent in 1973 to 1 percent in 1977 for vinyl coated fabrics.14
The major trading partners from whom we receive these materials include West
Germany, Austria, Switzerland, Belgium, France, India, Canada, and United
Kingdom.I5 In contrast to fabrics, imports of wall coverings have been
growing in importance, growing at a 12.7 annual rate over the 1973-77 period.
Imports of wall coverings flow in mainly from Japan, Korea, West Germany,
France, United Kingdom, Sweden, Canada, and Netherlands.15 Fierce compe-
tition from imported wall coverings is expected over the next five years.
9.1.3.5 Prices. Because the FVCP industry consists of a wide variety of
diverse products, obtaining a single representative price is quite a challenge.
Because of the large amount of resources needed to compute a weighted average
price for hundreds of products, an implicit price method is proposed. An
implicit price is found by dividing value of shipments (i.e., price times
quantity) by quantity. Table 9-10 shows the results of such calculations.
As Table 9-10 reveals, the implicit price per square meter of vinyl coat-
ed fabrics was $0.93 in 1967, $0.90 in 1973, and $1.02 in 1977. The implicit
price per kilogram of wall coverings was $1.50 in 1967, $2.23 in 1972, and
$2.76 in 1977. In an attempt to check the reasonableness of using these
9-15
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Table 9-8. PRODUCER PRICE INDEX
FOR POLYVINYL CHLORIDE (PVC) RESIN: 1971-1979
Year Price Index
1971 86.6
1972 88.0
1973 97.4
1974 152.7
1975 170.1
1976 182.2
1977 187.1
1978 191.6
1979 223.8
Source: Reference 13.
9-16
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Table 9-9. EXPORTS AND IMPORTS OF FVCP
AS PERCENTAGE OF TOTAL INDUSTRY OUTPUT
Year Exports Imports3
Vinyl Coated Fabrics
1977 9% 1%
1976 8% 2%
1975 8% 2%
1974 8% 2%
1973 8% 4%
Wallcoverings
1977 8% 18%
1976 8% 15%
1975 7% 10%
1974 7% u%
1973 7% 11%
almport figures are for SIC 2295, while exports are for SIC 22952. In
addition, imports are a percentage of new supply (i.e., total industry
cutout n1u<; imnnrtc^
output plus imports).
Source: Reference 14.
9-17
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Table 9-10. PRICES OF FVCP
Impl Icit Export
Value of Quantity Implicit Price Price Per
Shipments Millions Sq. Meters Per Sq. Meter Sq. Meter
Year (millions $) (Millions Sq. Yds.) (Per Sq. Yd.) (Sq. Yd.)
Vinyl Coated Fabrics
1977
$806.9
596.0 (713.0) $1.35 (1.13) $1.06 (0.87)
1972
601.9
669.8 (314.0)
0.90 (0.74) 0.78 (0.64)
1967
380.7
408.9 (496.9)
0.93 (0.79) 0.62 (0.52)
Quantity
Million:; kg.
(Millions 1b.)
Implicit Price Implicit Export
Per kg. Price Per kg.
(Per 1b.) (Per Ib.)
Wallcoverings
1977
$174.6
63.4 (139.5)
$2.76 (1.25) $2.76 (1.25)
1972
83.0
37.5 ( 82.5)
2.23 (1.01) 2.18 (0.99)
1967
46.2
30.8 ( 67.8)
1.50 (0.68) 1.59 (0.72)
Source: References 2, 3, and 16.
9-18
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prices as proxies for FVCP, the implicit price per square meter (and per
kilogram) for exports was computed from another source.3 As is evident
from Table 9-10, the two methods of construction yield fairly similar results,
especially for wall coverings. Consequently, since export information is
available annually (whereas value of shipment data is currently available
only up to 1977), the 1979 implicit (export) price of $1.91 per square meter
($1.60 per sq. yd.) for vinyl coated fabrics and an implicit (export) price
of $3.41 per kilogram ($1.55 per pound) for wall coverings will be employed
in the economic analysis. These prices will be adjusted to a 1980 level via
an appropriate producer price index.
9.1.3.6 Substitutes. Competition by substitutes for flexible vinyl coat-
ed and printed products varies depending upon the cost and functional suita-
bility of the substitute products. Polyurethanes, as a substitute for vinyl
coated fabrics, offer some outstanding physical properties such as resistance
to abrasion, cutting and tearing, and resistance to grease, oils, and chemi-
cals. 17 There was great interest in urethanes as vinyl substitutes during
the early 1970's; however, urethanes and vinyl fabrics have some differences
in characteristics. Poor surface appearance, poor long-term quality, and
higher raw material costs have prevented the substitution of polyurethane for
vinyl seat covering materials in the automotive industry.18 Nonetheless,
nylon and certain polyester fabrics are making in-roads in the automotive
market. It appears that as the average size of the automobile shrinks, the
luxury content of the interior (such as valour upholstery) rises, perhaps as
a justification for the higher price tags.
Urethanes, of course, do provide some competition for other supported
vinyl products, such as luggage, handbags, footwear, and rainwear. Urethanes
possess a wealth of functional properties and are highly cost competitive.19
With respect to the unsupported vinyl film segment, polyethylene and poly-
propylene can be substituted for flexibile vinyl in pool linings, laminations,
and packaging, while styrene-butadiene latexes may be substituted in the
manufacturing of tablecloths.20
Finally, vinyl wall coverings face continual competitive pressures from
regular (nonvinyl) wall coverings, paint, and a myriad of panel decorations.
Given the number and nature of substitutes for FVCP products, it is rea-
sonable to infer that the price elasticity of demand is probably relatively
elastic.
9-19
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9.1.4 Growth Projections
9.1.4.1 Projected New Sources
9.1.4.1.1 Supported vinyl materials. The number of new (grass roots)
sources in the supported vinyl materials segment is projected to be zero.
This projection is based upon the negative growth rate observed (histori-
cally) in a previous section (see Section 9.1.3.1.1).
9.1.4.1.2 Unsupported vinyl film. The number of new sources in the
unsupported vinyl film group is expected to be zero. This expectation is
based upon the negative growth rate observed (historically) in a previous
section and the fact that there is excess capacity presently (see Section
9.1.3.1.2).
9.1.4.1.3 Wall coverings. The number of new sources in the wall
coverings group is forecasted to be six. This forecast, was obtained by
employing the following assumptions:
1. The 1979 value of shipments for members of the Chemical Film and
Fabric Association (CFFA) was $210 million.
2. CFFA members represent approximately 60 percent of the industry.
3. The 1979 value of shipments for wall coverings was $350 million
(210 4 .60).
4. The 1979 wholesale price for vinyl wall coverings ranged between
$10-20 per roll.21»22 Since each roll is approximately 3.33
square meters (or 4 square yards), the median price per square
meter is $4.50.
5. 77.78 millions of square meters were shipped in 1979 ($350 *
$4.50 per square meter),
6. Average capacity utilization is 60 percent.
7. This represents a 1979 capacity of 129.6 millions of square
meters (77.78 * .60).
8. Assuming an annual growth rate of 8.9 percent, the 1982 and 1987
capacity is projected to be 167.4 and 256.3 millions of square
meters, respectively.
Hence, the projected increase in capacity over the next five years will
be 88.9 millions of square meters (i.e., 256.3 - 167.4 = 88.9), or approxi-
mately six (6) new sources with an annual output of 9 million square meters
(and with a capacity of 15 million square meters) each.
9-20
-------
9.1.4.2 Replacement/Reconstruction/Modification. No replacements, re-
constructions, or modifications are expected over the next five years.
9.1.4.2.1 Reconstruction/Modification. No major additions in the equip-
ment or changes in the process that would be subject to regulation by the pro-
posed NSPS are projected for the next five years. A more detailed discussion
of reconstruction and modification is contained in Chapter 5.
9.1.4.2.2 Replacement. The flexible vinyl and printing industry is
relatively young. Most of the existing equipment is less than 15 years old.
For this reason, it is very difficult to estimate the actual useful life of
one of these printing lines, a statistic essential for projecting the inci-
dence of replacement, modification, and reconstruction. There are some
indirect indicators that this type of equipment is long lived. For example,
a 30-year life is used for accounting purposes. Many similar machines (intag-
lio printers) in the textile industry are over 80 years old and continue to
operate. Obviously, this type of equipment appears near immune to obsolesence
and owners tend to maintain and repair parts of existing lines rather than re-
place entire lines. For these reasons, the useful life of the vinyl printing
lines is expected to be significantly greater than 30 years; therefore no
replacements are projected for the next five years.23,24,25,26,49,50
9.2 ECONOMIC IMPACT ANALYSIS
9.2.1 Introduction
In the following sections, the potential economic impacts of the proposed
regulatory alternatives on the flexible vinyl coating and printing industry
(FVCP) are examined. Prior to the impact analysis, a financial profile of
the industry is presented. The economic impact analysis then follows with an
examination of the profitability, price, and capital availability impacts of
each regulatory alternative for five model plants.
This analysis presents estimates of economic impact which may be consid-
ered rather modest. In the worst case, a 1.68 percent decline in the return
on investment would be experienced by the small modified plants. The price
pass-through analysis estimates a worst case increase in price of only 0.047
percent. The capital financing capabilities of the FVCP industry are nega-
tively impacted for all model plants with a decline in the debt service
coverage ratios of between 5.58 to 26.23 percent. However, for both regu-
latory alternatives, the absolute value of all the coverage ratios still
9-21
-------
attains a level of 3 or better, suggesting that no problems should occur in
the capital financing capabilities of the model plants.
9.2.1.1 Financial Profile. Table 9-11 describes annual production for
the five model plants in terms of square meters (square yards) and dollars of
output. Estimated production for the model plants ranges from 9 to 110 mil-
lion square meters with a respective range in revenue from 7 to 84 millions
of dollars. Model Plant C represents a reconstructed or modified small plant.
Model plants A and B represent reconstructed or modified medium plants. Model
plants D and E represent new large plants. For a more detailed description
of the model plants see Chapter 6.
In order to describe as accurately as possible the different size model
plants presented in Table 9-11, financial data was necessary. Financial sta-
tistics to proxy for model plants A, B and C were obtained from Annual State-
ment Studies.?7 Financial statistics for model plants D and E were unavail-
able from this source since too few reporting firms were large. As an alter-
native, financial data was taken from the annual reports of the fourteen major
manufacturers in the FVCP industry. These statistics are presented in Tables
9-12 through 9-15 for the years 1975 to 1979.
The statistics in these tables are also divided into two subgroups. The
first three firms are those whose statistics are available only in a consoli-
dated form, while the last eleven are those whose statistics are separated by
divisions (usually speciality plastics or man-made fabrics divisions). Conse-
quently, the statistics on the second group of eleven firms will more accurate-
ly reflect the true financial conditions in the FVCP industry. It should be
noted, however, that these profit summaries in many cases are for very large
divisions. For many of the major producers in the FVCP industry, the divi-
sional statistics reflect a very diversified product line with FVCP just a
small part. In other cases, FVCP is the major product in the division.
Tables 9-12 thru 9-14 demonstrate that profit margins for the major pro-
ducers (individually) showed no discernible trend over the five year period.
Profit margins increased or decreased in response to factors such as changes
in costs, the degree of product diversification, the degree of saturation in
different product markets, and in one case, extremely high start up costs for
a new pi ant.43 However, the profit margin averages for the eleven firms ex-
hibit a very noticeable downward trend for the five year period. This is due
for the most part to the increased cost of raw materials in the production
9-22
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Table 9-11. ESTIMATED ANNUAL PRODUCTION AND REVENUES FOR THE
FLEXIBLE VINYL COATING AND PRINTING MODEL PLANTS
(1980)
Model Plants
C D
Annual Production3
millions of m2 18 18 9 110 110
(millions yd2) (21.6) (21.6) (10.8) (130) (130)
Annual Revenue^
($ millions) 12.883 13.582 7.173 80.755 84.029
aAnnual production volumes were estimated by Radian Corp.
bAnnual Revenues were estimated from costs of sales provided by Radian Corp.
Source: Reference No. 28.
9-23
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Table 9-12. GROSS PROFIT MARGINS FOR THE MAJOR MANU-
FACTURERS OF PVC COATED FABRICS AND FILMS3
Company
Chrysler
Ford Motor Co.
General Motors
Althol Manufacturing
(Sub. of Emhart)
Borden Inc.
Compo
L.E. Carpenter
(Sub. of Dayco)
Firestone
General Tire and Rubber Co.
Goodrich
Harte and Co. (Sub. of
Diamond Shamrock)
Pervel (Sub. of Bern is)
Stauffer Chemical Co.
Uni royal Inc.
All fourteen Firms
Average
Last Eleven Firms
Average0
- -
1975
.078
.121
.163
.327b
.316
.195
.211
.317
.196
.230
.348
.169
.234
.275
.227
.256
1976
.128
.151
.194
.314
.358
.228
.213
.280
.194
.229
.192
.153
.245
.239
.223
.240
Year
1977
.102
.156
.191
.326
.364
.197
.219
.252
.223
.235
.150
.199
.231
.214
.218
.237
1978
.075
.148
.189
.315
.242'
.255
.234
.246
.234
.282
.218
.185
.197
.219
.217
.239
1979
.031
.156
.158
.293
.231
.260
.204
.259
.210
.323
.243
.193
.017
.221
.198
.220
Five Year
Average
.217
.238
aGross profits (i.e., profits before depreciation, selling and administrative
expenses, other expenses, interest and taxes) divided by sales.
^Estimated using industry average growth for the year. Data for Althol Manu-
facturing was unavailable for this year.
cThis average disregards the data for Chrysler, Ford, and GM (Annual Reports
are consolidated) and includes only financial data disaggregated by divi-
sions.
Source: References 29 through 42.
9-24
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Table 9-13. OPERATING PROFIT MARGINS FOR THE MAJOR MANU-
FACTURERS OF PVC COATED FABRICS AND FILMS3
Company
Chrysler
Ford Motor Co .
General Motors
Althol Manufacturing
(Sub. of Emhart)
Borden Inc.
Compo
I.E. Carpenter
(Sub. of Dayco)
Firestone
General Tire and Rubber Co.
Goodrich
Harte and Co. (Sub. of
Diamond Shamrock)
Pervel (Sub. Bemis)
Stauffer Chemical Co.
Uniroyal Inc.
All fourteen Firms
Average
Last Eleven Firms
Average0
1975
.000
.018
.070
.078b
.136
.036
.020
.141
.088
.037
.192
-.008
.080
.058
.068
.078
1976
.039
.055
.107
.093
.129
.074
.030
.105
.083
.072
.079
-.006
.113
.042
.073
.074
Year
1977
.021
.073
.116
.109
.135
.025
.054
.085
.108
.051
.046
.039
.082
.038
.070
.070
1978
-.015
.092
.105
.108
.119
.091
.050
.095
.111
.062
.062
.026
.029
.044
.070
.072
1979
-.074
.103
.072
.089
.114
.109
.017
.096
.078
.104
.102
.027
-.205
.045
.048
.052
Five Year
Average
.066
.069
Operating Income (i.e., income before other expenses, interest and taxes)
divided by sales.
bEstimated using the industry average growth rate for the year. Data for
Althol Manufacturing was unavailable for this year.
cThis average disregards the data for Chrysler, Ford, and GM (Annual Reports
are consolidated) and includes only financial data disaggregated by divi-
sions.
Source: References 29 through 42.
9-25
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Table 9-14. NET PROFIT MARGINS FOR THE MAJOR MANU-
FACTURERS OF PVC COATED FABRICS AND FILMS3
Company
Chrysler
Ford Motor Co .
General Motors
Althol Manufacturing
(Sub. of Emhart)
Borden Inc.
Compo
L.E. Carpenter
(Sub . of Dayco)
Firestone
General Tire and Rubber Co.
Goodrich
Harte and Co. (Sub . of
Diamond Shamrock)
Pervel (Sub. Bemis)
Stauffer Chemical Co.
Uniroyal Inc.
All fourteen Firms
Average
Last Eleven Firms
Average0
1975
-.030
.008
.035
.024b
.058
.013
-.005
.056
.033
.004
.160
-.020
.010
.016
.026
.032
:
1976
.034
.035
.062
.039
.059
.034
.001
.036
.030
.024
.025
-.028
.029
.007
.028
'.023
Year
1977
.012
.045
.061
.046
.065
.015
.016
.029
.044
.016
.005
.016
.014
.005
.028
.025
1978
-.015
.061
.055
.049
.063
.017
.013
.029
.048
.024
.010
.001
-.025
.007
.024
.021
1979
-.091
.109
.044
.036
.061
.026
-.006
.038
.030
.054
.027
.001
-.150
.003
.013
.011
Five Year
Average
.024
.022
aNet profits divided by sales.
Estimated using the industry average growth rate for the year. Data for
Althol Manufacturing was unavailable for this year.
cThis average disregards the data for Chrysler, Ford, and GM (Annual Reports
are consolidated) and includes only financial data disaggregated by divi-
sions.
Source: References 29 through 42.
9-26
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Table 9-15. NET PROFITS TO ASSETS RATIO FOR THE MAJOR
MANUFACTURERS OF PVC COATED FABRICS AND FILMS3
Company
Chrysler
Ford Motor Co .
General Motors
Althol Manufacturing
(Sub . of Emhart)
Borden Inc.
Compo
I.E. Carpenter
(Sub. of Dayco)
Firestone
General Tire and Rubber Co.
Goodrich
Harte and Co. (Sub. of
Diamond Shamrock)
Pervel (Sub. Bern is)
Stauffer Chemical Co.
Uniroyal Inc.
All fourteen Firms
Average
Last Eleven Firms
Average0
1975
-.041
.013
.058
.075b
.056
.027
-.006
.077
.057
.020
.117
-.036
.011
.032
.033
.039
1976
.060
.063
.119
.096
.086
.082
.006
.070
.058
.027
.026
-.075
.034
.012
.047
.038
Year
1977
.021
.088
.125
.109
.089
.024
.032
.126
.096
.023
.004
.036
.014
.008
.057
.051
1978
-.029
.136
.115
.112
.081
.044
.024
.074
.095
.033
.006
.003
-.018
.014
.049
.043
1979
-.165
.236
.090
.084
.080
.063
-.013
.096
.059
.091
.027
.002
-.115
.006
.035
.039
Five Year
Average
.044
.042
aNet profits divided by total assets.
^Estimated using the industry average growth rate for that year. Data for
Althol Manufacturing was unavailable for this year.
cThis average disregards the data for Chrysler, Ford, and GM (Annual Reports
are consolidated) and includes only financial data disaggregated by divi-
sions .
Source: References 29 through 42.
9-27
-------
process. The profit margin squeeze was also exacerbated! by a less than satisfac-
tory ability to pass these higher costs along to the consumer.44 As a result,
profit margins for 1979 were well below the average for the five year period.
Table 9-15 demonstrates a similar trend in the net profits to asset ratios
for the major producers in the FVCP industry. Return on assets for the subgroup
of eleven major producers rebounded from a low of .038 in 1976 to .051 in 1977,
but then proceeded to decline to .039 in 1979. This downward trend can be
attributed to the same factors causing the downward trend in the profit margins.
Financial ratios averaged for the five year period for the five model
plants are summarized in Table 9-16. When considering the size of the model
plants, the smallest, model plant C, exhibits the largest net profit margin
and return on assets. Operating profits, on the other hand, are the lowest
for model plant C. Other expenses, such as general corporate expenses and
interest expenses, are of less importance to the smallest model plant which
seems to demonstrate a much tighter control over these types of expenses.
This results in a much larger net income margin (as a percent of sales) for
model plant C.
9.2.1.2 Pricing and Market Structure. To assess the impact of the reg-
ulatory alternatives on the FVCP product prices, it is necessary to examine
the pricing behavior and the market structure in the industry. Pricing in
the industry depends on the demand characteristics of the FVCP products and
on the market structure in the FVCP industry.
The major demand characteristic which influences pricing decisions is the
demand elasticity. It is quite difficult to quantitatively assess a specific
demand elasticity since the number of products employing FVCP fabrics and films
in their production process is so njmerous. A qualitative approach can be sub-
stituted adequately. The major determinant of the demand elasticity of PVC
fabrics, films, and wallpaper is the number of available substitute products
and the ease with which these products can be substituted for FVCP materials.
Many of the end use markets for the FVCP products have readily available sub-
stitutes at their disposal. The supported vinyl fabrics sector has cloth
fabric as a very good substitute. Substitutes for the unsupported vinyl film
are other plastic films, such as polyethylene and polypropylene. Vinyl wall
coverings have paper and paint as readily available substitutes. The ease
with which these products can be substituted for vinyl creates a very elastic
demand for FVCP products.
5-2G
-------
Table 9-16. SUMMARY FINANCIAL RATIOS FOR THE 65%
VOC CONTROL LEVEL (BASELINE CASE)3
Model Plants
Cost of Sales (% of Sales)
Gross Profits (% of Sales)
Operating Profits
(% of Sales)
EBIT (% of Sales)
Net Income (% of Sales)
EBIT/Assets
Baseline ROIb
Depreci at ion/ Revenue
CMLTD/AssetsC
A
79.90
20.10
4.67
3.46
1.97
7.7%
4.16%
2.18%
2.04%
B^
79.90
20.10
4.67
3.46
1.97
7.7%
4.16%
2.18%
2.04%
C
77.75
22.25
4.55
4.25
2.42
7.9%
4.27%
2.13%
1.95%
D
76.20
23.80
6.90
3.90
2.22
7.3%
3.94%
2.94%
0.85%
E
76.20
23.80
6.90
3.90
2.22
7.3%
3.94%
2.94%
0.85%
aThe ratios for model plants A, B and C represent five year historical
averages from Robert Morris Associates. The ratios for model plants D and E
are five year historical averages (by division) from the eleven major manufac-
turers' annual reports.
b(EBIT/Assets) x (1-.46). The average tax rate for the major manufacturers
is .46.
cCurrent Maturity Long Term Debt 4 Assets.
Sources: References 27 and 29 through 42.
9-29
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Evidence that complete price pass through is very difficult in the FVCP
industry is presented in a few of the annual reports of the major producers.
One manufacturer attributed the majority of their recent profit margin squeeze
to their ability to only pass through less than half of the increase in petro-
chemical costs.45 Evidence was presented earlier in Table 9-14 that profit
margins have been rather unstable with a declining trend for the last five
years. This implies that the firms in the industry have very little market
power over price and demand is relatively elastic.
A description of the FVCP industry market structure is most difficult be-
cause of the varied end uses of FVCF products and the degree of vertical inte-
gration as described in Section 9.1.2.2. Market structure per se in the FVCP
industry is generally not considered a significant determinant for pricing be-
havior due to the extreme importance of the availability of substitutes in the
market. However, it is important to examine the market structures of both the
captive and merchant markets of the supported, unsupported, and wall covering
sectors in the industry.
The industry can be described as a generally competitive market but with a
few isolated segments which exercise limited market power over prices. Both the
merchant market in the supported and unsupported sectors as well as the captive
unsupported sector exhibit characteristics of a competitive market structure.
These sectors of the industry are characterized as having a large number of
firms producing very similar products with little or no market power over prices
In the captive portion of the supported vinyl sector the auto industry is
an important producer. A majority (52.9%) of the supported vinyl produced in
1979 was used by the auto industry.45 Much of this supported vinyl was cap-
tively produced with its cost representing only a small portion of the final
product price. The large auto firms have a large degree of power over pricing
in the final product market; however, the captively produced vinyl must still
remain cost competitive with substitutes such as cloth fabrics and leather.
The market structure for the wall covering sector can also be described
as competitive. Close examination of the wall covering sector at the seven-
digit SIC level reveals that the vinyl paper wall covering sector (SIC 2649325)
is composed of only fourteen companies (sales of $100,000 or more) with total
value of shipments of $36.2 million [1977 dollars).4'' The vinyl fabric wall
covering sector (SIC 2649331) is composed of nine companies (sales of $100,000
or more) with total value of shipments of $36.9 million (1977 dollars). Although
9-30
-------
these figures might be suggestive of a significant degree of market power, de-
mand considerations prevent any such market power over pricing. Substitutes,
such as regular paper wall coverings, panel decorations, and paint, provide
enough competition to prevent any oligopolistic behavior from occurring. There-
fore, this sector can also be considered competitive in its market structure.
9.2.2 Potential Economic Impacts
9.2.2.1 Economic Impact Assessment Methodology. Three types of economic
impact analyses are examined:
1. Return-on-investment (ROI),
2. Price pass-through and
3. Capital availability.
The return on investment analysis examines the impact of control costs on
model plant viability and the attractiveness of investment in new plants. The
basic measure of ROI employed in the following analysis can be obtained as
follows:
Return on Investment -
The measure of investment in this analysis is total assets (which are equal to
debt plus equity). The ROI analysis will also assume that the total cost of
control will be fully absorbed by the impacted firms without any price pass-
through. The impact on ROI will be a worst case situation.
Caution must be exercised in the application of this ROI analysis to new
plants since the data is based on existing firms and plants. The ROI presented
here will most likely be overstated for two reasons. First, total assets used
in the calculations will be net of depreciation, whereas a new plant's asset
level would be void of any deductions for depreciation. Second, assets purchased
in the past are not valued at replacement cost. Assets of existing plants would
be understated by the impact inflation has on replacement costs. However, some
of the effect that these two factors have in reducing ROI for new plants would
be offset by expected cost savings from more efficient new plant operations.
Price pass-through analysis examines the maximum price increase which
would take place if firms passed control costs through to customers in the form
of higher prices. It is assumed in the analysis that firms will increase oper-
ating income by raising prices in order to maintain precontrol ROI after the
imposition of controls. These increases would be a worst case situation.
9-31
-------
The results of the ROI and price pass-through analysis must be interpret-
ed very carefully because they were based on worst case assumptions. By relax-
ing these worst case assumptions, the results would be more realistic and more
consistent with the qualitative scenario presented in Section 9.2.1.2.
Whether or not firms can meet increased annual debt service costs under
controls is assessed in the debt service coverage analysis. The debt service
coverage ratio is calculated by dividing a firm's cash flow (net income after
taxes plus depreciation) by its level of current maturity of long-term debt
(CMLTD). The resulting ratio provides an index describing the cash (capital)
available to a firm for retiring long-term debt commitments. The ratio is fre-
quently used by the banking community for making loan decisions. If the ratio
for a firm is two or greater, debt service coverage is considered to be healthy.
A ratio less than one indicates that annual debt service costs cannot be met
and that firms will therefore find their access to capital restricted.48
9.2.2.2 Return on Investment Analysis. Using the necessary ratios pre-
sented in Table 9-16, pro forma income statements for each model plant are cal-
culated and presented in Table 9-17 for the baseline case. It is assumed that
these costs account for costs associated with a 65% "level of pollution control.
After the net income before taxes (EBIT) is calculated, the level of assets
can be estimated from the available EBIT/Assets ratio. Baseline ROI can then
be calculated by dividing net income by the estimated assets. Tables 9-18
and 9-19 employ similar calculations to obtain the ROI's for the 75% and 85%
levels of pollution control. Appropriate adjustments are made to cost of
sales and assets to account for the additional costs of control .
The results presented in Tables 9-18 suggests a change in ROI for the 75
percent level of control to range between a 0.96 percent decline and an 8.38
percent increase. Table 9-19 suggests a range of between a 1.68 percent decline
and a 17.77 percent increase in ROI for the 85 percent of control. The favor-
able impact on four of the five model plants is due to the large solvent reco-
very credits that more than offset tne annualized cost of control. For model
plant A the solvent recovery credit is also sufficient to offset the annualized
cost of control and result in an increase in net income. However, the percent
increase in the level of assets is mjch larger than the percent increase in
net income resulting in a decrease ii the net income/assets ratio. Conversely,
ROIs for model plants B through E increase because the percent increase in
the level of assets is much smaller than the percent increase in net income.
9-32
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Table 9-17. ROI ANALYSIS OF THE 65 PERCENT
VOC CONTROL LEVEL (BASELINE)
($ mill ion)
Model Plants
Sales9
Cost of Salesb
Gross Profits
Operating Expenses
Operating Profits0
Other Expenses
EBITd
Income Tax ( .46 x EBIT)
Net Income6
EBIT/Assets
Assetsf
ROI9
A
12.883
10.293
2.590
1.988
.602
.157
.445
.204
.241
7.7%
5.779
4.17%
B
13.583
10.852
2.730
2.096
.634
.166
.468
.215
.253
7.7%
6.078
4.16%
C
7.173
5.577
1.596
1.273
.323
.021
.302
.139
.163
7.9%
3.823
4 . 26%
D
80.755
61.535
19.220
13,648
5.572
2.423
3.149
1.449
1.700
7.3%
43.137
3.94%
E
84.029
64.030
19.999
14.201
5.798
2.521
3.277
1.507
1.770
7.3%
44.890
3.94%
aCost of Sales T (1-Gross Profit margin).
^Cost estimates were obtained from Radian Corp.
cSales x Operating profit margin.
dSales x (EBIT/Sales) .
eSales x Net Income Margin.
fEBIT 4 (EBIT/Assets).
9Net Income 4 Assets.
9-33
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Table 9-18. ROI ANALYSIS OF THE 75 PERCENT
VOC CONTROL LEVEL
($ million)
Sales*
Cost of Salesb
Gross Profits
Operating Expenses
Operating Profits
Other Expenses
EBIT
Income Tax
Net Income
Assets (65% level)
Additional Capital0
Assets (75% level)
ROI (75% level )d
% Change from Baseline
- -
A
12.883
10.292
2.591
1.988
.603
.157
.446
.205
.241
5.771
.065
5.836
4.13%
-0.96%
B
13.582
10.817
2.765
2.096
.669
.166
.503
.231
.272
6.086
.160
6.246
4.36%
+4.81%
Model Plants
C
7.173
5.567
1.606
1.273
.333
.021
.312
.144
.168
3.814
.100
3.914
4.29%
+0.70%
D
80.755
61.469
19.286
13.648
5.638
2.422
3.216
1.479
1.737
43.143
.160
43.303
4.03%
+2.28%
E
84.029
63.721
20.308
14.201
6.107
2.521
3.586
1.650
1.936
44.892
.460
45.352
4.27%
+8.38%
aFrom Table 9-17.
^Baseline cost of sales + the annualized cost of pollution control for the
75% level .
cCapital Cost (75% level) - Capital Costs (65% level).
dNet Income * Assets (75% level).
9-34
-------
Table 9-19. ROI ANALYSIS OF THE 85 PERCENT
VOC CONTROL LEVEL
($ mil lion)
Model Plants
Sales3
Cost of Sales'3
Gross Profits
Operating Expenses
Operating Profits
Other Expenses
EBIT
Income Tax
Net Income
Assets (65% level)
Additional Capital0
Assets (85% level)
ROI (85% level)d
% Change from Baseline
A
12.883
10.289
2.594
1.988
.606
.157
.449
.207
.242
5.771
.125
5.896
4.10%
-1.68%
B
13.582
10.789
2.793
2.096
.697
.166
.531
.244
.287
6.086
.320
6.406
4.48%
+7.69%
C
7.173
5.556
1.617
1.273
.344
.022
.322
.148
.174
3.814
.200
4.014
4.33%
+1.64%
D
80.755
61.423
19.332
13.648
5.684
2.422
3.261
1.500
1.762
43.143
.310
43.453
4.05%
+2.79%
E
84.029
63.387
20.642
14.201
6.441
2.521
3.920
1.803
2.117
44.892
.740
45.632
4.64%
+17.77%
aFrom Table 9-17.
bBaseline cost of sales + the annualized cost of pollution control for the
85% level .
cCapital Cost (85% level) - Capital Costs (65% level).
dNet Income 4 Assets (85% level).
9-35
-------
9-2.2.3 Price Pass-Through Analysis. The price pass-through analysis
will employ equation (1) utilized earlier, but in a modified form. The form
of ROI to be used here is:
ROI* =
-------
In summary, the worst case would suggest a very modest price increase
for Model Plant A of between 0.039 to 0.047 percent. The worst possible case
for model plants B thru E would be no price change whatsoever, since the
positive impacts on ROI provide no incentive for a price increase.
9-2-2-4 Capital Availability Analysis. Table 9-20 presents the results
of the debt service coverage analysis. For the baseline case, all of the model
plants exhibit very healthy debt service coverage ratios of at least 4. Model
plants D and E are in an especially healthy position with ratios of 11.10.
The additional capital requirements for the 75 percent regulatory alterna-
tive reduce the debt service coverage ratios by 5.58 to 16.16 percent depending
upon the model plant size. Although this relative change seems rather large,
the absolute level of the ratios do not fall below a healthy level of 3 for '
any of the model plants. For the 85 percent regulatory alternative, the debt
service coverage ratio is reduced by 10.34 to 26.23 percent. Again, in no
case does the absolute level of the ratio fall below 3.
Especially noticable from Table 9-20 is the disproportionate impacts on
the smallest and largest model plants. Model plant C would experience the
most negative impact under either regulatory alternative while the larger
model plant D is impacted the least under either regulatory alternative.
Model plant A, however, was the only model plant which exhibited negative
impacts in the ROI and price pass-through analysis, and it is impacted
relatively little compared to the other model plants.
This unexpected impact on model plant C is due primarily to the large
increase in its CMLTD necessary to pay back the increased debt. Table 9-21
shows the percent increases in CMLTD for each regulatory alternative. An
examination of the percent increases in CMLTD reveals a pattern similar to
the pattern of decreases in the debt service coverage ratios.
9'2'2-5 Smluine The Regul atory Flex ibil ity Act requires
among other things, the economic impact assessment to determine wnether or
not a regulation is likely to have a significant impact on a significant mm-
ber of small businesses. If the analysis shows a likely significant impact,
the Agency must prepare and publish a regulatory flexibility analysis This
section assesses the likelihood of such a significant impact, it concludes
that a significant impact is not expected.
The assessment in Sections 9.2.2.1 through 9.2.2.4 examined small busi-
nesses through the analysis of three small model plants of a size of 1 print
9-37
-------
Table 9-20. DEBT SERVICE COVERAGE ANALYSIS
($ Million)
Baseline 65%
Net Income After Tax
Depreciation3
Cash Flowb
CMLTDC
Debt Service Coverage Ratiod
75% Level
Net Income After Taxes
Depreciation6
Cash Flowb
CMLTDf
Debt Service Coverage Ratio0*
Percent Change from Baseline
85% Level
Net Income After Taxes
Depreciation6
Cash Flowb
CMLTDf
Debt Service Coverage Ratio0'
Percent Change from Baseline
A
0.241
0.281
0.522
0.118
4.42
0.241
0.284
0.525
0.128
6.10
-7.24
0.242
0.287
0.529
0.138
3.83
-13.35
B
0.253
0.296
0.549
0.124
4.42
0.272
0.304
0.576
0.150
3.84
-13.12
0.287
0.312
0.599
0.176
3.40
-23.08
Model P
C
0.163
0.153
0.316
0.074
4.27
0.168
0.158
0.326
0.091
3.58
-16.16
0.174
0.163
0.337
0.107
3.15
-26.23
lants
D
1.700
2.374
4.074
0.367
11.10
1.737
2.382
4.119
0.393
10.48
-5.58
1.762
2.390
4.152
0.417
9.95
-10.34
E
1.770
2.470
4.240
0.382
11.10
1.936
2.493
4.429
0.457
9.69
-12.69
2.117
2.507
4.624
0.502
9.21
-17.03
a(Dep./Revenue) x Revenue.
bNet income after taxes plus depreciation.
cCurrent maturity long term debt (CMLTD) = (CMLTD/Assets) x Assets.
dCash Flow/CMLTD.
6Baseline depreciation + (.05 x capital cost of control) (assumes a 20 year
life of equipment).
fBaseline CMLTD + [Capital Recovery Factor (1.63) x Incremental Capital
Control Cost].
9-38
-------
Table 9-21. PERCENT INCREASES IN CMLTD
Model Plant
/\ B C
75% Alternative 8.5% 21.0% 23.0% 7.1% 19.6%
85% Alternative 16.9% 41.9% 44.6% 13.6% 31.4%
9-39
-------
line each. The assessment examined the impact categories of price increases,
changes in return on investment, and capital availability. These impact
categories were examined for absolute small plant impacts and for differen-
tial impacts between small and large plants.
The estimated number of plants to be impacted by a regulation on this
industry over the next five years is six, which is only 5 percent of the 112
plants, or 107 firms, in this industry. The analysis did pinpoint the size
of these six plants to be small. However, even in such an event the size of
the impacts are not considered significant.
According to the results presented earlier in Tables 9-18 and 9-19, dif-
ferential impacts of a level that are not considered significant can be expec-
ted to occur with respect to a change in ROI. For the 75 percent regulatory
alternative, changes in ROI will range between a decrease of 0.96 percent to
an increase of 4.81 percent for the smaller modified model plants as opposed
to an increase of between 2.28 to 8.38 percent for the new larger model plants,
A similar pattern is evident for the 85 percent regulatory alternative.
Although the ranges overlap, the extreme endpoints would seem to indicate
that the larger model plants will acquire cost advantages which would place
the smaller model plants at a disadvantage although the total impact is not
considered significant. This possibility could become more pronounced because
the incentive exists for the larger model plants to lower prices, thus placing
a small impact on plants similar to model plant A.
The debt service coverage results from Table 9-20 provides a similar
pattern of differential impacts. For the 75 percent regulatory alternative,
changes in the debt service coverage ratio ranges between a decrease of 7.24
to 16.16 percent for the smaller modified model plants as compared to a de-
crease of between 5.58 to 12.69 percent for the new larger model plants. A
similar pattern results for the 85 percent regulatory alternative. Again,
the exact pattern is somewhat obscured by the overlap of the ranges; however,
the extreme endpoints seem to indicate that the smaller model plants are
impacted slightly more than the larger model plants.
The potential price increases are significantly less than the 5 percent
level contained in Executive Order 12291 and cost savings occur in some regu-
latory alternatives. Slight differential impacts occur between the small and
large model plants with regard to maximum price increases associated with the
9-40
-------
Table 9-22. FIFTH YEAR ANNUALIZED SAVINGS OF COMPLIANCE3
Model Plant
With
Worst Case
Lowest Annualized
Sav i ng s
Per Plant
Total Fifth Year
Annualized Savings
of Compliance
6 New Plants, 75% level
of Control
$10,000
$ 60,000
6 New Plants, 85% level
of control
$21,000
$126,000
aAs mentioned in Section 9.2.2.2 the solvent recovery credits more than off-
set the annualized cost of control. Thus, in both the 75% and 85% levels of
control, there is savings rather than costs.
9-41
-------
regulatory alternatives. With the 75 percent regulatory alternative, the
maximum price increase for the small model plant, A, is .039 percent while a
slight savings occurs for the large model plant. With the 85 percent regula-
tory alternative, the maximum price increases for model plant A is .047
percent while a savings occurs for the large model plant.
9.3 POTENTIAL SOCIOECONOMIC AND INFLATIONARY IMPACTS
The purpose of Section 9.3 is to address those tests of macroeconomic
impact to determine whether or not a detailed regulatory analysis is required
under E.O. 12291. There are three principal review criteria to aid in this
determination. They are:
1. If additional annualized costs of compliance, including capital
charges (interest and depreciation), total $100 million (i) within
any one of the first five years of implementation, or (ii) if
applicable, within any calendar year up to the date by which the
law requires attainment of the relevant pollution standard.
2. If a major increase in the selling price of the product results for
consumers, individual industries, Federal, State or local govern-
ment agencies, or geographic regions, or
3. If significant adverse effects on competition, investment, produc-
tivity, employment, innovation, or the ability of U.S. firms to
compete with foreign firms results.
The macroeconomic impact from the proposed regulatory alternatives would
not be significant enough to meet any one of the above criteria for the deter-
mination of major economic impact. The expected worst case maximum price
impact of .047 percent increase i;; well below a major criterion. Table 9-22
presents the estimated total fifth year annualized costs (really savings) of
compliance given the following assumptions:
1. Six new plants will be built as specified in Section 9.1.4.
2. All new plants will produce wall coverings characterized by model
plant C.
Due to significant positive recovery credits, the total additional annualized
cost of control in the fifth year will be $-60,000 at the 75 percent level
and $-126,000 at the 85 percent level. These results are summarized in Table
9-22. Finally, no major impacts eire expected on geographical regions, local
governments, competition, investment, productivity, and so on. Therefore, no
significant macroeconomic impacts are likely.
9-42
-------
9.4 REFERENCES
1. Thomas Register of American Manufactures. New York: Thomas Publishing
Co., 1981.
2. U.S. Department of Commerce, Bureau of the Census, Census of Manufac-
tures. Washington, DC: U.S. Government Printing Office, 1977.
3. , U.S. Exports, Washington, DC: U.S. Government Printing Office,
1967, 1972, 1977, and 1979.
4. Letter from W. B. Hall, Secretary, Chemical Film and Fabric Association,
to H. Laube, Radian Corporation, July 1, 1980.
5. Standard and Poor's Corporate Records. New York: Standard and Poor's
Corp., 1980.
6. Standard and Poor's Industry Survey: Plastic Resins. 1980, p. C23.
7. Chemical Marketing Reporter. May 23, 1977, p. 16.
8. Standard and Poor's Industry Survey: Rubber Fabricating. 1979, p.
R.194.
9. U.S. Department of Commerce, Bureau of the Census, 1977 Census of
Manufactures: Concentration Ratios in Manufacturing. Washington,
D.C.: U.S. Government Printing Office, May 1981.
10. Letters and attachments from Hall, W. B., Chemical Fabrics and Film
Association, to Brooks, Garry, Radian Corporation. July 1, 1980. July
24, 1980. CFFA End-Use Shipments of Industry Products Information for
Unsupported and Supported Vinyl materials.
11. Reference 7.
12. "PVC: A Bonus in New Capacity". Modern Packaging. November 1979,
p. 31.
13. Memo from U.S. Department of Labor, Bureau of Labor Statistics, to Kevan
Deardorff, JACA Corp., September 23, 1980. Computer printout of PVC
price index.
14. U.S. Department of Commerce, Bureau of the Census, U.S. Commodity
Exports and Imports as Related to Output. Washington, DC: U.S. Govern-
ment Printing Office, 1975, 1976, 1977.
15. , U.S. General Imports. Washington, DC: U.S. Government Printing
Office, 1977.
16. U.S. Department of Commerce, Bureau of the Census, Census of Manufacture.
Washington, D.C.: U.S. Government Printing Office, 1972.
9-43
-------
17. B.F. Goodrich, The Many Product Lines of B.F. Goodrich Chemical Division,
1980.
18. The Society of the Plastics Industry, Inc., fact and Figures of the
Plastics Industry, New York, p. 89, 1978 Edition.
19. Reference 18, p. 41.
20. Reference 18, p. 57.
21. Telecon. Schultz, D., Schult? Wallcoverings with Doyle, J., JACA Corp.
February 10, 1981.
22. Telecon. Silver, M., AAPCO Wallcovering Distributors with Doyle, J.,
JACA Corp. February 10, 1981.
23. Telecon. Nelson, D., North Atrerican Cerutti with Doyle, J., JACA Corp.
February 18, 1981.
24. Telecon. Cappa, P., American Tool and Machinery with Doyle, J., JACA
Corp. February 18, 1981.
25. Telecon. Baser, J., American Tool and Machinery with Doyle, J., JACA
Corp. February 18, 1981.
26. Telecon. D'Angelo, F., Lembo Corp. with Doyle, J., JACA Corp. February
18, 1981.
27. Annual Statement Studies. Robert Morris Associates. Philadelphia, PA.
1976, p. 102. 1977, p. 95. 1978, p. 94. 1979, p. 153. 1980, p. 155.
28. Letter and attachment from Laube, Hal, Radian, Incorporated, to Deardorff,
Kevan, JACA Corporation. January 23, 1981. Annual!zed costs of plants.
29. Chrysler Corporation. Annual Report 1979. March 1980. p. 19.
30. Ford Motor Company. Annual Report 1979. March 1980. pp. 36-37.
31. General Motors Corporation. Annual Report 1979. February 1980. pp.
26-27.
32. Emhart Corporation. Annual Report 1979. February 1980. pp. 14-16,
p.28.
33. Borden Corporation. Annual Report 1979. March 1980. pp. 30-31.
34. Compo Industries Corporation. Annual Report 1979. December 1979. pp.
4, 17, 19.
35. Dayco Corporation. Annual Report 1979. January 1980. pp. 23, 43, 46,
48.
36. Firestone Corporation. Annual Report 1979. December 1979. pp. 20-23.
-------
37. General Tire and Rubber Company. Annual Report 1979. February 1980.
pp. 19-22.
38. Goodrich Corporation. Annual Report 1979. February 1980. pp. 27-28,
35, 46.
39. Diamond Shamrock Corporation. Annual Report 1979. February 1980. pp.
32-33, 44, 47.
40. Bemis Corporation. Annual Report 1979. February 1980. pp. 5, 16,
29.
41. Stauffer Chemical Company. Annual Report 1979. February 1980. pp.
1-4, 32-33, 38.
42. Uniroyal Corporation. Annual Report 1979. March 1980. pp. 21-23.
43. Reference 33, p. 2.
44. Reference 33, p. 2.
45. Reference 33, p. 2.
46. Reference 10.
47. Reference 2, p. 3.
48. U.S. Environmental Protection Agency, Guidance for Lowest Achievable
Emission Rates from 18 Major Stationary Sources of Particulate, Nitrogen
Oxides, Sulfur Dioxide, or Volatile Organic Compounds. Publication No.
EPA-450/3-79-024. April 1979. p. 5-6.
9-45
-------
Appendix A - Evolution of the Background Infornation Document
The purpose of this study was to develop a basis for supporting
proposed new source performance standards (NSPS) for the flexible vinyl
coating and printing industry (FVC&P). To accomplish the objectives of
this program technical data was acquired on the following aspects of the
FVC&P industry: (1) web fomation; (2) coating and printing operations
(3) the release and controllability of organic emissions into the atnosphere
by these sources; and (4) the types and costs of demonstrated emission
control technologies. The bulk of this information was retrieved fron
the following sources:
- open technical literature
- meetings with specific companies, trade associations, and
regulatory authorities
- plant visits
- emissions source testing.
In October, 1979, a literature search began with the automated
bibliographic and direct type data bases available through Lockhead
Retrieval Service's DIALOG and Systems Development Corporation's ORBIT.
The data bases search included APTIC, Chemical Abstracts, Engineering
Index. MTIS, ENVIROLINE, and Predicast's EIS Plants. The information
found in the literature helped in developing an understanding of the
vinyl coating industry and the processes used. Rut there was very
little factual information as to the quantity or type of pollutants
emitted by the industry.
The following chronology of events lists the major activities
undertaken in gathering data and information to support the proposed
standard.
A-l
-------
September 28, 1979
October 1979
November 1979
November 7, 1979
December 2, 1979
December 12, 1979
January 1980
February 27, 1980
March 5, 1980
March 27, 1980
April 14, 1980
April 17, 1980
Visited Uniroyal, Inc.
312 North Hill Street
Mishawaka, Indiana 46544
Telephone survey of industry
Telephone survey of State agencies
Visited General Tire and Rubber Company
Columbus, Mississippi
Visited General Tire and Rubber Company
Coated Fabrics Company
Reading Division
General Street
Reading, Massachusetts 01867
Visited Stauffer Chemical Company
Anderson, South Carolina 29623
Section 114 Letters sent to selected companies
within flexible vinyl coating industry and
vinyl flooring industry
Visited General Tire and Rubber Company
Coated Fabrics Company
Reading Division
Reading, Mass. 01867
Visited Standard Coated Products
Department of American Cyanamid Company
Now Division of L. F. Carpenter & Co.
Humboldt Industrial Park
P.O. Box D
Hazelton, Pa. 18201
Visited Pervell Industries, Inc.
Plainfield, Connecticut 06374
Visited Compo Industries,, Inc.,
Bradford Division
200 Market Street
Lowell, Mass. 01852
Visited Armstrong Cork Company
Lancaster Floor Plant
Lancaster, Pennsylvania 17604
-------
April, 1980
April 24, 1980
July 30, 1980
August 6, 1980
August 1980
September 29 through
October 3, 1980
December 1980
February 1980
February 1980
March 18 through
March 26, 1981
July 1981
Floorino industrv was excluded from this
NSPS
Visited Athol Manufacturing Corporation
P.O. Box 105
Butner, North Carolina 27509
Visited Stauffer Chemical Company
Anderson, South Carolina 29623
Visited Firestone Plastics Company
Salisbury, Maryland
Emissions from the vinyl web preparatory
processes were excluded from this NSPS.
Visited General Tire and Rubber Company
Coated Fabrics Company
Reading Division
General Street
Reading, Mass. 01867
(Emission source testing)
Visited General Tire and Rubber Company
Coated Fabrics Company
Reading Division
General Street
Reading, Mass. 01867
EPA Project team net with a representative of
the Chemical Film and Fabric Association and
several members of the FVC&P Industry.
Embossers were excluded fron the FVC&P NSPS.
Visited General Tire and Rubber Company
Coated Fabrics Company
Reading Division
General Street
Reading, Mass, 01867
(Emission source testing)
RID sent to 24 Industry members for early
review.
A-3
-------
APPENDIX B
INDEX TO ENVIRONMENTAL CONSIDERATIONS
This appendix consists of a reference system which is cross indexed
with the October 21, 1974, Federal Register (39 FR 37419) containing EPA
guidelines for the preparation of Environmental Impact Statements. This
index can be used to identify sections of the document which contain
data and information germane to any portion of the Federal Register
guidelines.
B-l
-------
APPENDIX B
CROSS-INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
Location Within the Background
Information Document (BID)
1. Background and Summary of
Regulatory Alternatives
Statutory Basis for the
Standard
Industry Affected
Process Affected
Availability of Control
Technology
Existing Regulations
at State or Local Level
2. Environmental, Energy, and
Economic Impacts of Regulatory
Alternatives
Health and Welfare Impact
The regulatory alternatives from
which standards will be chosen for
proposal are summarized in Chapter 1,
Section 1.1.
The statutory basis for proposing
standards is summarized in Chapter 2,
Section 2.1.
A description of the industry to
be affected is given in Chapter 3,
Section 3.1.
A description of the process to be
affected is given in Chapter 3,
Section 3.2.
Information on the availability
of control technology is given
in Chapter 4.
A discussion of existing regulations
for the industry to be affected by
the standards are included in
Chapter 3, Section 3.3.
The impact of emission control
systems on health and welfare
is considered in Chapter 7,
Section 7.1.
Continued
B-2
-------
CROSS-INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS (Concluded)
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
Location Within the Background
Information Document (BID)
Air Pollution
Water Pollution
Solid Waste Disposal
Energy
Costs
Economics
The air pollution impact of the
regulatory alternatives are
considered in Chapter 7, Section 7.1
The impacts of the regulatory
alternatives on water pollution are
considered in Chapter 7,
Section 7.2.
The impact of the regulatory
alternatives on solid waste disposal
are considered in Chapter 7,
Section 7.3.
The impacts of the regulatory
alternatives on energy use are
considered in Chapter 7,
Section 7.4.
The cost impact of the emission
control systems is considered in
Chapter 8, Section 8.1.
Economic impacts of the regulatory
alternatives are considered in
Chapter 9, Section 9.2.
B-3
-------
APPENDIX C
EMISSION SOURCE TEST DATA
In order to obtain emission data on a controlled plant in the
flexible vinyl printing (FVC&P) industry, a testing program was conducted.
The results of the program provide support for a new source performance
standard (NSPS) for FVC&P industry.
The General Tire and Rubber Company plant, located at 1 General
Street, Reading, Massachusetts was the test site during the weeks of
September 30, through October 10, 1980 and later in March 1981. The
plant occupies a single floor building and produces vinyl coated fabric
for automotive, marine, wallcovering and industrial end uses. A new,
six station, Baker Perkins print line, with an inline embosser, had
recently been brought on stream to print and emboss wallcovering.
The print line tested by EPA, is housed in a separate room in the
plant. The print room's ventilation system consists of a wall exhaust
fan, a room air supply fan, a carbon adsorption inlet fan, an embosser
exhaust fan and several open doorways. Figure C-l is a graphical
representation of the room.
The print line VOC emissions are captured by a hooding system that
directs the captured emissions into the individual print head ovens.
The capture emissions from the print line are controlled by a Sutcliffe
Speakman carbon adsorption system.
C.I GENERAL TIRE AND RUBBER COMPANY PLANT - First Test Program
The purpose of the first test was to determine the capture efficiency
of the print line based on a comparison between the mass of solvent
C-l
-------
OVERHEAD
DOOR
o
ro
Wall Fans, but
1
#2
Embosser Exhaust Fan, out
(above embosser)
PRINT HEADS (STAGES)
SUBSTRATE
DRYER
1
Web direction
EMBOSSER
:«°1
PRODUCT
]
0
r ' Room Air
I00 ! Supply Fan, in
• -I (ceilinq)
DESKS
MIXING
AKtA
D
SWITCH
ROOM
OFFICE
• Ambient VOC Measurement Locations for VOC
Measurement in Figure C-3
Figure C-l. GTR Print Room.
NOT TO SCALE
a. ~Z wall fan v/as not used during the GTR test
-------
applied at the print line and the mass of gaseous VOC emissions ducted
to the adsorber. In order to make this comparison, a material balance
between liquid VOC input and gaseous VOC output was required. In order
for the results to be meaningful, closure of a material balance around
the print line was necessary.
VOC measurements were made on a continuous basis at the wall fan
exhaust, embosser exhaust and carbon adsorber inlet. Ink usage was
determined by measuring changes in the level of the ink tanks supplying
the print line. Ink samples were obtained during each run from each of
the print stations applying ink and later analyzed for solvent content.
Product samples were also obtained for solvent retention analysis.
The 35,000 SCFM room air supply fan was large enough to supply
outside air to the print room when three print lines were installed.
During the test, only one print line was housed in the print room and
the room air supply fan was on. Lack of proper air distribution caused
most of the flow from this fan to be directed down through the print
line. Approximately 15,000 SCFM were exhausted from the print room
through the carbon adsorber, wall exhaust fan, and embosser. The balance,
20,000 SCFM, was exhausted through open doors. During the test the
large air flow from the room air supply fan caused excessive turbulence
around the print stations. Results indicated that capture efficiency
had been affected and was much less than design expectations. Also
closure of the material balance, based on liquid VOC in and gaseous VOC
out, was not achieved.
C-3
-------
C.2 GENERAL TIRE AND RUBBER COMPANY - Second Test Program
The General Tire and Rubber Company was revisited for further
testing March 18-26, 1981. The testing approach was modified from the
first test in two very important ways. Unlike the first test which
based capture efficiency on liquid and gaseous VOC measurements, this
test required only gaseous VOC measurements. Secondly, the retest was
conducted with the room air supply fan off to improve air management
around the print line. In addition, doors to rooms with other solvent
sources were closed to prevent VOC leakage into or out of the print room
from other areas of the plant.
The test program consisted of two phases: Phase 1, determination
of capture efficiency and Phase 2, determination of carbon adsorption
control device efficiency.
During Phase 1, emissions were measured continuously at three
sites: carbon adsorber inlet, wall fan exhaust, and embosser exhaust.
During the first few days of testing, preliminary data indicated the
wall exhaust fan disrupted air distribution much like the room air
supply fan during the 1980 test. Therefore, plant management agreed to
limit the use of this fan during the test days, to periods when the
print head fans were off. The print line was always down during such
periods.
Periodic measurements at the embosser air intake were taken to
determine the ambient room VOC emissions that were exhausted through the
embosser exhaust fan. Because the embosser is not part of the affected
facility, any emissions generated within the embosser are not considered
C-4
-------
under the vinyl NSPS. The embosser generated emissions along with the
print line room ambient VOC emissions are both exhausted through the
embosser exhaust fan, therefore, these ambient VOC emissions must be
quantified to determine capture efficiency. Since there is very little
data characterizing embosser VOC emissions, VOC measurements were also
taken at the embosser exhaust to further characterize these emissions.
During Phase 2, VOC measurements were made at both the inlet and
outlet to the carbon adsorber. Ambient VOC concentrations around the
embosser inlet were continued to obtain further data on capture efficiency.
During both phases of the test, ambient VOC concentrations throughout
the print room were monitored. Threshold Limit Values (TLV-TWA) were
not exceeded.
C.3 SUMMARY OF RESULTS
A summary of the capture efficiency results obtained during the
1981 GTR test is shown in Table C-l. Capture efficiency was calculated
by comparing the VOC emissions directed to the carbon adsorption system
with the ambient roon VOC emissions exhausted through the embosser. The
longest continuous run for a product, lasting at least thirty minutes
but not more than three hours, was designated as a test run. It was
desired to keep the test run of reasonably short duration since the
printing periods are frequently short due to planned and unplanned
interruptions. A sufficient period of time is needed to allow the print
line to reach reasonably steady state process conditions. Based on a
general understanding of the printing equipment and process, a minimum
thirty minute test run was selected.
C-5
-------
TABLE C-l. SUMMARY OF CAPTURE EFFICIENCY DATA FROM 1981 GTR TEST
r>
i
Date
3/18/81
3/19/81
3/20/81
3/23/81
3/25/81
3/26/81
a
Caoture Ff
Production Order Run Time
Number Start End
T-14582
T- 15523
T-15521
T-15516
T-15519
T-15511
T- 15508
T-15507
'ficiencv (%} = =— r-
1401
1420
1256
0909
1351
0942
1126
1439
1607
1610
1402
1025
1413
1047
1222
1540
CA
Run Length
(minutes)
126
110
74
76
32
65
56
61
Inlet Emissions
VOC Emissions Capture Efficiency1
(Kg) (%)
Embosser Wall CA
Air Intake Fan Inlet
4.
3.
2.
2.
0.
2.
1.
1.
(kg)
8
2
9
3
6
5
7
6
Ob 66
6.9 21
flb 27
(r1 22
Qb 6
Ob 35
O5 21
flb 21
.4
.6
.0
,3
.0
.5
.6
,5
- (-\f\r\v\
93
Nff
90
91
91
94
93
93
Wall fan not operating properly.
"Not meaningful because of poor air management during this test run.
-------
In order to measure ambient VOC drawn into the embosser air intake,
ambient concentration measurements around the embosser were made periodically
during each test day. Embosser air intake emissions values are based on
the average concentration measurements taken during each test run. The
capture efficiencies for the eight test runs ranged from 90 percent to
95 percent and averaged 92 percent.
A summary of the carbon adsorption control device efficiency data
from the 1981 GTR test is presented in Table C-2. Again, a test run was
designated as the longest continuous run, lasting at least 30 minutes
but not more than 3 hours, for each product. Carbon adsorption control
device efficiencies averaged 99 percent. However, the GTR adsorption
system was not operating at design conditions during the 1981 test. The
system, which had been on stream for only a week prior to the test,
operated only eight hours a day. At the end of each day, the beds were
regenerated twice to mininize the possibility of bed fires during the
next day's start up. Therefore, these carbon adsorption efficiencies
may be somewhat higher than would be expected under design conditions.
Table C-3 is a summary of the VOC measurements taken during the
1981 test. As mentioned earlier, the embosser exhaust emissions shown
in Table C-3, include embosser generated emissions which are not subject
to the NSPS.
Figure C-2 is a graphical presentation of ambient VOC data taken on
March 18, 1981. Because the VOC vapors are heavier than air, it was
thought that the vapors might accumulate near the print room floor. On
March 18, 1981 ambient readings were taken throughout the print room at
C-7
-------
TABLE C-2. SUMMARY OF CARBON ADSORPTION EFFICIENCY DATA FROM 1981 GTR TEST
Production Order
Date
3/25/81
3/26/81
Number
T-15511
T- 15508
T-15507
Run Time
Start
0942
1126
1439
End
1047
1222
1540
Run Length
(minutes)
65
56
61
VOC Emissions Carbon Adsorption
(Kg)
CA Inlet
35.5
21.5
21.5
CA Outlet
0.13
0.32
0.22
Efficiency
99.6
98.5
,99.0
o
I
CO
-------
Table C-3. Summary of VOC Measurement Data
of Second GTR Test
o
ID
production
Date Order Number Process Operations
3-18-81 T-14582 Preparation
Leader Threading
Color Matching
1000 Yards Printing
1000 Yards Printing
1000 Yards Printing
1000 Yards Printing
1000 Yards Printing
Completion of Run
Threading New Leader
Clean Up
Clean Up
TOTAL PRINT TIME
TOTAL RUN TIME
Time Interval
Start3 End
0915
1035
1043
1401
1423
1445
1507
1529
1551
1607
1613
1618 .
1401
1043
1035
1043
1401
1423
1445
1507
1529
1551
1607
1613 "
1618
1640
1607
1613
Total
Minutes
80
8
198
22
22
22
22
22
16
11
5
22
126
330
VOC Emissions (Pounds as MEK)
Embosser' uaii c*a** /•*» v i — *_ •«._ *
NM
0.15
39.20
2.74
2.55
2.32
2.33
2.49
1.73
0.69
0.58
2.23
14.2
54.0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
v-n J.UJ.BT;
2.57
0.60
76.5
34.8
23.5
24.4
23.8
23.2
16.5
4.27
3.56
NM
146.2
230.5
rotao.
0.75
115.7
37.5
26.0
26. 7
26.1
yc. i
18.2
4 .96
4 .14
160.4
281.0
NM: Not measured - analyzer problems or calibrations in progress.
Start time for the initial time interval is the time when FID monitoring began that day,
-------
Table C-3. Summary of VOC Measurement Data
of Second GTR Test (Continued)
o
I
Production
Date Order Number Process Operations
3-19-81 T-15626 Printing in Progress
Printing
Stop and Start
1000 Yards Printing
Stop and Start
1000 Yards Printing
TOTAL PRINT TIME
.TOTAL RUN TIME
T-15523 Preparations for Next Run
_ Color Matching
Embosser Repairs. Wall
Fan On
1000 Yards Printing
1000 Yards Printing
1000 Yards Printing
1000 Yards Printing
Run Completed
Clean Up
Clean Up
Clean Up
TOTAL PRINT TIME '
TOTAL RUN TIME
Time Interval
Start3
0734
0848
0854
0908
0930
0945
0848
0846
1007
1230
1332
1420
1442
1504
1526
1550
1610
1628
1632
1230
1420
'*
End
0848
0854
0908
0930
0945
1007
1007
1007
1230
1332
1420
1442
1504
1526
1550
1610
1628
1632
1634
1610
1610
Total
Minutes
74
6
14
22
15
22
79
79 -
143
62
48
22
22
22
24
20
18
220
110
VOC Emissions (Pounds as MEK)
Embosser
8.53
0.902
1.50
2.65
0.781
2.47
8.30 .
8.30
2.49
4.14
4.41
4.05
3.85
3*99
4.25
3.58
1.14
0.18
0.09
28.3
19.7
Wall Fan
0
0
0
0
0
0
0
0
0
0
6.24
2.43
2.96
3.20
3.49
3.14
2.25
0.48
NM
21.5
15.2
CA Inlet
NM
4.09
6.22
8.36
3.04
- 11.6
33.3
3i^
7.28
10.6
15.1
9.22
10.3
10.0
10.9
7.09
10.2
NM
NM
73.2
47.5
Total
4.99
7.72
11.0
13.8
14.1
41.6
41.6
9.77
14.7
25.7
15.7
17.2
17.2
18.7
13.8
13.6
123.0
82.4
NM: Not measured - analyzer problems or calibrations in progress.
a Start time for the initial time interval is the time when FID monitoring began that day.
-------
Table C-3. Su/nrwry ef VOC Measurement Data
of Second GTR Test (Continued)
o
I
Production
Date Order Number Process Operations
3-20-81 T-15521 Completing Previous Run
Completing Previous Run
Preparation for T-15521
^ Color Matching
Printing Start/Stop
for Repairs
Printing Embosser on
1000 Yards Printing
Printing Start/Stop
for Repairs
1000 Yards Printing
1000 Yards Printing
1000 Yards Printing
Run Completed
Cleaning Print Heads
Clean Up
TOTAL PRINT TIME
TOTAL RUN TIME
•^
Time Interval
Start3 EnrJ
0740
0744
0814
0958
1019
1148
1150
1212
1256
1318
1340
1356
1410
1426
1019
0958
0744
0814
0958
1019
1148
1150
1212
1256
1318
1340
1356
1410
1426
1532
1410
1410
Total
Minutes
4 '
30
104
21
89
2
22
44
22
22
16 •
14
16
66
231
252
VOC Bnissions (Pounds as MEK)
Embosser
0.67
3.42
4.56
1.91
7.97
0.233
4.32
6.76
4.27
4.25
3.22
2.41
2.09
6.06
33.4
35.3
waij. ran
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CA inlet
MM
19.4
14.7
31.2
35.6
1.16
18.2
29.5
17.27
17.6
13.6
10.91
7.49
NM
143.8
175.0
Total
—
22.8
19.3
33.1
43.6
1.39
22.5
36.3
21.5
21.8
16.8
13.3
9.58
177.2
210.3
NM: Not measured - analyzer problems or calibrations in progress.
Start time for the initial time interval is the time when FID monitoring began that day.
-------
TaBle C-3. Summary of VOC Measurement Data
of Second GTR Test (Continued)
o
I
ro
Production
Date Order Number Process Operations
3-23-81 T-15516 Printing in Progress
1000 Yards Printing
1000 Yards Printing
1000 Yards Printing
Run Completed
TOTAL PRINT TIME
TOTAL RUN TIME
T-15519 Threading Leader
Cleaning. PH Fans off.
Wall Fan on
Color Matching,
Web Alignment
Wall Fan Off.
Color Matching
Printing Line Down Once
1000 Yards Printing
Line Up and Down.
Trimming Problems
r-~ Problems Persist.
Run Ended
Repairs
Repairs
TOTAL PRINT TIME
TOTAL RUN TIME
Time Interval
Start3
0850
0909
0931
0953
1015
0850
0850
1025
1037
1239
1244
1324
1351
1413
1605
1628
1633
1324
1239
End
0909
0931
0953
1015
1025
1025
1025
1037
1239
1*244
1324
1351
1413
1605
1628
1633
1636
1605
1628
Total
Minutes
19
22
22
23
10
95
95
12
122
5
40
27
22
112
23
5
3
161
229
VOC
Embosser
1.92
2.60
2.78
3.12
1.48
11.9
11.9
1.41
5.25
0.070
0.85
1.88
1.56
6.71
1.14
0.27
NM
10.2
12.2
Emissions (Pounds as MEK)
Wall Fan CA Inlet .
Sampling 10.51
Discontinued 13.06
14.70
14.20
7.15
59.6
59.6
24. 60
4.17
0.180
10.3
9.90
9.02
40.0
10.5
1.16
1.93
58.9
69.6
Total
12.43
15.7
17.5
17.3
8.63
71.5
71.5
26.0
9.42
0.250
11.2
11.8
10.6
AC •»
11.6
1.43
69.1
81.8
NM: Not measured - analyzer problems or calibrations in progress.
a Start time for the initial time interval is the time when FID monitoring began that day,
-------
Table C-3. Summary of VOC Measurement Data
of Second GTR Test (Continued)
o
H-«
CO
Production Time Interval
Date
3-24-81
3-25-81
Order No. Process Operations Start"
Embossing Entire Day
T-15511 Color Hatching
Printing in Progress
Printing
1000 Yards Printing
1000 Yards Printing
1000 Yards Printing
Run Completed
Leader Threading
Wall Fan on Preparation
For Next Run
Hall Fan on Preparation
For Next Run
TOTAL PRINT TIME
TOTAL RON TIME
0859
0900
0922
0942
1003
1020
1037
1047
1108
1217
0922
0922
End
0900
0922
0942
1003
1020
1037
1047
1108
1217
1230
1047
1108
Total
Minutes
1
22
20
21
17
17
10
21
69
13
85
106
VOC Emissions
(Pounds As MEK)
CA Inlet
0.66
20.1
21.8
53.5
21*2
22.7
10.7
15.7
7.69
NM
130
146
Ca Outlet
NM
NM
0.048
0.071
0.067
0.093
0.065
0.114
0.317
0.053
0.344
0.458
CA Unit
Control
Efficiency <»)h
99.8
99.9
99.7
99.6
99.4
99.3
95.9
99.7
99.7
Carbon Bed
In Operation Time of B*d
(Adsorbing) Switch0
3
3
1 0922*
1
1
3
3
3
3/1 1117"
3
•Beginning time of 0922 was estimated, based on observed end time of 1020
••Bed No. 1 began adsorbing 1117 and continued to 1217.
• Start time for the Initial time Interval is the time when FID monitoring began that day.
b 100 (l-
-------
Table C-3. Summary of VOC Measurement Data
of Second GTR Test (Continued)
o
Production
Date Order Ho. Process Operations
3-26-81 T-1550B Preparation
Preparation
Color Hatching
Printing
100 Yards Printing
100 Yards Printing
Run Completed
Enboaser off. Clean up
TOTAL PRINT TIME
TOTAL RUN TIME
T -15 507 Preparation
Color Matching
Printing. Line Down
Once
1000 Yards Printing
1000 Yards Printing
Run Completed
Line Down. Preparation
for next run
Line Down- Preparation
for next run
TOTAL RUN TIME
TOTAL RUN TIME
Tine Interval
Start"
0856
0936
0939
1059
1126
1151
1216
1222
1059
0939
1229
1326
1420
1439
1S01
1523
1540
1612
1420
1326
End
0936
0939
1059
1126
1151
1216
1222
1229
1222
1229
1326
1420
1439
1501
1523
1540
1612
1614
1540
1540
Total
Minutes
40
3
eo
27
25
25
4
7
83
163
57
54
19
22
22
17
32
2
80
134
VOC Emissions
(Pounds As NEK)
CA
NH
0
37
21
20
21
5
S
7?
110
28
31
13
' 16
17
12
15
NM
61
92
Inlet
.880
.0
.1
.7
.6
.15
.11
-6
.7
.8
.6
.8
.9
.7
.8
.0
.2
.8
Ca Outlet
0.
0.
1.
0.
0.
0.
0.
0.
j .
2.
0.
0.
0.
0.
0.
0.
0.
0.
0.
1.
194
036
26
356
313
313
072
156
05
47
588
438
158
211
160
116
217
014
645
08
CA Unit
Control
Efficiency (»)*»
95.
96.
98.
98.
96.
98.
96.
9
6
3
5
6
6
9
Carbon Bed
In Operation Tine of Bed
(Adsorbing) Switch"
1/3 0928
3
3/1 1028
1
1/3 1120
3
3
3
38. G
97.
98.
98.
98.
98.
99.
99.
90.
98.
98.
8
0
6
9
8
1
1
6
9
8
3/1 1233
1/3 1334
3/1 1435
1
1
1/3 1S14
*r «* L j J«l
3
3
• Start tine for th« initial time Interval is the time when FID monitoring began that day
b 100 (1-(OUTLET/INLET)|
c Nominal bed cycle Udsorption/desorption) is about 120 minutes.
-------
1 foot, 5 feet and 8 feet from the floor. As demonstrated in Figure
C-2, no stratification occurred within the room.
As previously discussed, the operation of the wall fan, during the
1981 GTR test, affected capture efficiency of the print line. The use
of this fan was therefore limited to periods when the print head fans
were off. When the wall fan was off, a slight reduction in air flow
occurred. The air flow decreased from 13,300 SCFM (wall fan plus embosser
fan) to 11,700 SCFM (print head fans plus embosser fan). If, with the
wall fan off, the ventilation of the print room were insufficient, then
accumulation of ambient VOC in the print room would occur. Any such
accumulations occurring during the test runs would affect the capture
efficiency calculations. Also, any accumulation might lead to exceeding
the Threshold Limit Value - Time Weighted Average (TLV-TWA) for worker
exposure to solvents.
Figure C-3 shows a portion of the ambient VOC measurements taken
during the 1981 test program. These ambient measurements seen in the
figure were taken in the locations shown in Figure C-l. Also shown in
Figure C-3 are the test runs and the times when the wall fan was operating.
The double lines separating the test days represent non-test times, such
as weekend and evening shifts, for which no information is available.
Referring to Figure C-3, testing began on March 18th. The wall fan
was on throughout the day but because of a loose fan belt, no flow was
measured at its exhaust. At 14:01 the print line operated continuously
for 126 minutes. During this continuous run period or test run, one
ambient survey was taken.
C-15
-------
Figure C-2. Ambient VOC Concentration Data for 3/18/81
• 1 foot from floor
• 5 feet from floor
• 8 feet from floor
Various Locations in GTR Print Roon
Hour
Date
8 9 10 11 12 13 14 15 16
3/18/81'
C--16
-------
Wall Fan On
(no measurable flow)
Wall Fan I 1 Test Run
Off
Wall Fan
(10,000 SCFM)i
Various Points in GTR Print Room
200
E
O
o
c
£ 150
(X
c
0 CtL
•r- H-
•4J CJ3
i. C
•4— ' *r—
1 O) I/I
l-1
~sl C C
O -i-
O O
Q.
O 10
^ g 50
C i.
0) rt)
-Q
E 4->
0
Hour
_
m
—
A
—
1 1
- 1 1 1 I I 1 I i_L
8 10 12 14 16
Date 3/18
Wall Fan
rlCI 1 1 lull
Operation
^^^^^^^
4
M
A
*
•
,1,1,1.!
8 10 12 14 16
3/19
™
^
A
* _
• t*
9 •
A
•
M
I , ! . i , i , I
8 10 12 14 16
3/20
^S88888S
*
A A
t
• A
^ •
•
* „
•
H H
1 , I , I , 1 , !
8 10 12 14 16
3/23
^^B^^Sl
9
* •
A A
4
0
m »
*
_
A w
M
1 , 1 , ! , 1 , !
-•--•--•- • i • • • •
8 10 12 14 16
3/25
^0
A
• A
,
X .• *
• A
" *
H H
1 i 1 i 1 i 1 i 1
j — , — i — i — , — , — i * *
8 10 12 14 16
3/26
|
Figure C-3. Ambient VOC Concentration Data for 1981 GTR Test.
-------
Testing continued on March 19th. In the morning, the wall fan was
operating but no flow was measured at its exhaust. No test runs were
completed during the morning. An ambient survey of the print room was
taken at approximately 9:00. At approximately 12:00 the fan belt of the
wall fan was adjusted and the wall fan exhaust increased to 10,000 SCFM.
This large volume of air was exhausted from almost directly over the
print heads. The effect of this poor air management on capture efficiency
was dramatic. Capture efficiency was at once reduced below design
expectations as evidenced in Table C-l. The test data was not valid
during the afternoon of March 19th because of this poor air management.
On March 20th, the wall fan weis turned off at 9:55. Test data were
taken throughout the day. Ambient data were taken periodically while
the wall fan was off. At 12:56 the print line operated continously for
seventy-four minutes, thereby completing the second test run of the 1981
test program. At 14:52, the print line went down for cleaning and the
print head fans were turned off. The wall fan was then turned back on.
On the next two test days, March 23rd and 25th, two different
colors or patterns were printed each day. These changes in patterns or
colors required the print line as well as the print head fans to be
turned off while the changes were made. Therefore these test days,
March 23rd and 25th, were interrupted by periods when the wall fan was
on. Only a limited amount of ambient data is available for the test
runs of March 23rd and 25th.
C-18
-------
The final test day, March 26th, proceeded niuch like March 20th.
Two test runs were completed and ambient data were taken periodically
throughout the test day.
On both March 20th and 26th, there was a long continuous period of
time when the wall fan was off. Several ambient surveys were conducted
during these long periods. The results demonstrate that no noticeable or
significant build-up of VOC occurred in the print room. On the other
test days (March 18, 19, 23, and 25) only a few ambient surveys were
conducted, or the wall fan was turned on in between production runs.
Thus, alone, the data from these days (March 18, 19, 23, and 25) are
inconclusive in assessing a build-up of VOC in the print room. However,
the ambient levels on these days are similar to the levels on March 20th
and 26th, thus it is assumed that the ventilation system was operating
in the same manner and no accumulation occurred during these days
(March 18, 19, 23 and 25).
Table C-4 contains a summary of the data obtained from the first
GTR test. As stated previously, the purpose of the test was to determine
capture efficiency based on the ratio of the mass of gaseous VOC sent to
the carbon adsorber to the mass of liquid VOC applied at the print line.
It was very difficult to accurately characterize the net mass flow of
solvent to the print head and the material balance between the liquid
VOC in and gaseous VOC out could not be closed. Also the mass flow of
solvent through the doorways was higher than expected due to the room
air supply fan. The test results were inconclusive and therefore no
data analysis is presented.
C-19
-------
TABLE C-4. SUMMARY OF DATA FROM FIRST GTR TEST
1
O
I
ro
o
Time Liquid
Production Order VOC Applied
Date Number Start End (kg)
9/30/80
10/1/80
10/2/80
10/3/80
10/6/80
10/7/80
10/8/80
10/9/80
* r\ 1 1 f\ * *"\ **i
lU/iU/OU
T-178
T-164
T-169
T-152
T-131
T-196
T-200
T-203
MEK
••• S\ fl S\
\-Lse.
0924
0945
0745
1342
0914
1140
1101
0955
1016
1318
1836
1709
1342
1728
1406
1805
1413
1503
1202
1552
143.7
202.0
214.6
166.6
96.8
146.4
121.2
133.9
12.3
A~l f\
H/ . y
Gaseous VOC Emissions
(kg)
Carbon Adsorber Wall Embosser
Inlet Fan Exhaust
98.2
140.9
142.6
84.6
47.1
100.5
57.4
65.1
10.6
30.4
13.8
14.2
16.2
8.0
8.9
11.1
4.1
7.6
3.9
6.1
16.8
8.1
15.1
6.4
6.6
18.9
12.7
13.5
0.8
1.5"
2 VOC Retained
Door in Product
Fugitives (kg)
16.8
13.6
9.7
6.4
7.9
11.8
4.4
9.9
O4
A
O1
ND5
2.4
1.1
2.3
0.6
2.3
1.9
ND5
0.2
1.3
Air from a supply fan, designed to supply air for 3 print lines, was directed down through the print
stations. This poor air distribution disturbed air management around the print heads. Capture efficiency
during these tests is not meaningful and is not presented.
2
These figures are based on estimated air flows and ambient VOC concentrations in the process room.
Embosser heat was off.
4
Room air supply fan was turned off.
5No data.
-------
APPENDIX D - EMISSION TESTING AND MONITORING
D.1 PERFORMANCE TEST METHODS
For the standard for the flexible vinyl coating and printing (FVC&P)
industry, performance test methods and procedures are needed in two
areas: determination of the organic solvent content of the ink or
coating, and determination of the overall control efficiency of the add-
on pollution control system.
D.I.I Analysis of Inks
1J'1 Volatile Organic Compound Content of thejnk. The organic
content of the ink may be obtained either from the ink manufacturer's
formulation or from Reference Method 24, "Determination of Volatile
Matter Content, Water Content, Density, Volume Solids, and Weight Solids
of Surface Coatings." This method combines several American Society of
Testing and Materials (ASTM) standard methods to determine the volatile
matter content, density, volume of solids, and water content of the inks
and related surface coatings.
If the FVC&P emission limit is in units of mass of volatile organic
compound (VOC) per mass of ink solids, only portions of Reference Method
24 need to be used. For non-aqueous inks, the procedure to be used is
ASTM D 2369-81, "Provisional Test Method for Volatile Content of Paints."
For aqueous inks, the previously mentioned procedure (ASTM D 2369-81) is
combined with a second procedure which determines the water content ot the
inks. There are two acceptable procedures for this: (1) ASTM D 3792-80,
"Standard Test Method for Water in Water Reducible Paint by Direct Injection
into a Gas Chromatograph," and (2) ASTM "Provisional Test Method for Water
in Paint or Related Coatings by the Karl Fischer Titration Method." The
results from these procedures are the non-aqueous volatile content of the
D-l
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ink (as a weight fraction) and the water content (as a weight fraction).
The weight fraction solids content in the ink is then easily determined
from these results by subtraction. The VOC content in the ink, in units
of mass of VOC per mass of ink solids, is determined by dividing the
weight fraction of non-aqueous volatiles by the weight fraction of solids,
The estimated cost of analysis per ink sample is $50 for the total
volatile content procedure (ASTM D 2369-81). For aqueous inks, an
additional $100 per sample is required for water content determination.
Because the testing equipment is standard laboratory apparatus, no
additional purchasing costs are expected.
D.I.1.2 Density of the Ink. The density of the ink may need to
be determined in some cases. This value may be obtained either from the
ink manufacturer's formulation or from a procedure in Reference Method
24. The procedure to be used is ASTM D 1475-60, "Standard Test Method
for Density of Paint, Varnish, Lacquer, and Related Products."
The estimated cost of analysis per ink sample is $25. Because the
testing equipment is standard laboratory apparatus, no additional pur-
chasing costs are expected.
D.I.1.3 Sampling of Inks. For Method 24 analysis of an ink, a 1-
liter ink sample should be obtained and placed in a 1-liter container.
The head-space in the container should be as small as possible so that
organics in the ink do not evaporate and escape detection. The ink
sample should be taken at a place that is representative of the ink
being applied. Alternatively, the ink may be sampled in the mixing or
storage area while separate records are kept of dilution solvent being
added at the print heads.
D-2
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D.I.1.4 Weighted Average VOC Content. If a FVC&P plant uses all
low-solvent inks, then each ink simply needs to be analyzed as described
in Section 1.1.1. If the VOC content of each ink is below the standard,
calculation of a weighted average is not needed. However, if a plant
uses a combination of low and high-solvent inks, the weighted average
VOC content of all the inks used over a specified time period needs to
be determined. This is essentially a mass weighted average; thus, in
addition to the Method 24 (or manufacturer's formulation) information,
the amount (weight) of each ink used must be determined. Most plants
already keep detailed records of amounts of inks used. Thus, it is
expected that no additional effort will be needed to determine ink
usage. If a plant keeps its inventory records on a volume basis, then
the density of the ink (Section 1.1.2) needs to be determined to put the
inventory on a mass basis.
D.I.2 Overall Control Efficiency
Performance test methods and procedures are used to determine the
overall control efficiency of the add-on pollution control system. The
add-on control system is composed of two parts: a vapor capture system,
and a vapor processing device (carbon adsorber or incinerator). The
control efficiency of each component is determined separately and the
overall control efficiency is the product of the capture system and
processing device efficiencies.
The performance test procedure in the proposed regulation defines
the test length and the conditions under which testing is acceptable, as
well as the way the reference test method measurements are combined to
attain the final result.
D-3
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D.I.2.1 Processing Device Efficiency. Two types of processing
devices are expected in the FVC&P industry: carbon adsorbers and
incinerators. The test procedure to determine efficiency is the same
for each control technology.
To determine the efficiency of the emission processing device, the
VOC mass flow in the inlet and outlet gas streams must be determined.
The recommended test procedure for determining the mass of VOC in a gas
stream combines several standard methods, EPA Reference Methods 1, 2, 3,
4, and proposed Method 25A. Thess methods and the reason for their
selection are discussed later.
D.I.2.2 Capture System Efficiency. The efficiency of the vapor
capture system is defined as the ratio of the mass of gaseous VOC
emission from the flexible vinyl printing line. In order to determine
the total mass of VOC emitted fron a line, all fugitive VOC emissions
from the printing area must be captured and vented through stacks
suitable for testing. A total enclosure around the print line is needed
to direct all other fugitive VOC emissions through suitable testing
stacks. If a permanent total enclosure or its equivalent exists on the
line prior to the performance test and the enclosure is capturing all
fugitive emissions, the construction of a temporary enclosure would not
be necessary. Otherwise, prior to the performance test, a temporary
total enclosure would need to be constructed around the print line for
the purpose of containing fugitive VOC emissions. In both cases, all
doors and other openings through which fugitive VOC emissions might
escape should be closed or properly vented to stacks suitable for testing.
If an embosser is operated in the print line, the performance test
would be conducted either with the embosser heat turned off and the
D-4
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embosser exhaust tested in the same manner as a room exhaust stack or by
separating the embosser from the print line by a total enclosure around
the print line. An alternative to isolating embosser would be to provide
a VOC allowance in the regulation to account for embosser emissions.
The mass flow of VOC in each applicable vent is determined by
Reference Methods 1, 2, 3, 4, and 25A.
D.I.2.3 Time and Cost. It is recommended that the performance test
consist of three runs. Each run may last from 1/2 to 3 hours for a
total of 1-1/2 to 9 hours of actual data gathering. However,
print line operations are intermittent; there are often long time periods
between print runs for cleanup, setup, and color matching, so the total
length of the performance testing varies. It is estimated, that for
most operations, the field testing could probably be completed in 2 days
(i.e., two 8-hour work shifts) with an extra day for setup, instrument
preparation, and cleanup.
The cost of the testing varies with the number of sites to be
tested: inlet, outlet, and fugitive vents. The cost is estimated at
$6,000 per test site.
D.I.2.4 Details on VOC Concentration Measurement Method. The
recommended VOC measurement method is proposed Reference Method 25A,
"Determination of Total Gaseous Organic Concentration Using a Flame
lonization Analyzer," (proposed in the Federal Register on December 17,
1980). This method was selected because it measures the expected solvent
emissions accurately, is practical for long-term, intermittent testing,
and provides a continuous record of VOC concentration. A continuous
record is necessary because of print line and control device fluctuations.
Measurements that are not continuous would not give a representative
indication of emissions. The print lines in this industry operate
D-5
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intermittently, and the vent concentrations may vary significantly.
Continuous measurements and records are easier to use for intermittent
processes, and the short-term variations in concentration can be noted.
The continuous records are averaged or integrated as necessary to obtain
an average result for the measurement period.
Method 25A applies to the measurement of total gaseous organic
concentration of vapors consisting of alkanes, and arenes (aromatic
hydrocarbons). The instrument is calibrated in terms of propane or
another appropriate organic compound. A sample is extracted from the
source through a heated sample line and glass fiber filter and routed to
a flame ionization analyzer (FIA). (Provisions are included for elimina-
ting the heated sampling line and glass filter under some sampling
conditions.) Results are reported as concentration equivalents of the
calibration gas organic constituent or organic carbon.
Instrument calibration is based on a single reference compound.
For this standard, propane is the recommended calibration compound. As
a result, the sample concentration measurements are on the basis of that
reference compound and not necessarily true hydrocarbon concentrations.
The solvents commonly used in inks in this industry are methyl-ethyl
ketone (MEK), methyl-iso-butyl ketone (MIBK), and toluene. MEK is the
principle solvent. Because the industry uses solvent mixtures which
vary from plant to plant, there is no standard solvent mixture to use
for calibration.
Gas chromatograph (GC) analysis on bag samples was considered
because results would be on the basis of true hydrocarbon concentra-
tions. However, the GC/bag sample technique is not a continuous measurement
and would be cumbersome and impractical because of the length of the
D-6
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testing. Furthermore, there is little advantage or extra accuracy
gained from the GC approach. Propane was selected as the calibration
gas species because it has close to a 1:1 response to MEK for an FIA.
Thus measured concentrations are close to the true hydrocarbon con-
centrations.
The VOC analysis technique using an FIA measures total hydrocarbons
including methane and ethane, which are considered nonphotochemically
reactive, and thus not VOC's. Due to the ink solvent composition,
little methane or ethane is expected in the gas streams; thus, chromato-
graphic analysis is not needed nor recommended to adjust the hydrocarbon
results to a nonmethane-nonethane basis.
Besides GC techniques, two other VOC concentration measurement
methods were considered (and rejected) for this application: proposed
Method 25B and Method 25.
Proposed Method 25B, "Determination of Total Gaseous Organic
Concentration Using a Nondispersive Infrared Analyzer," (Federal Register,
December 17, 1980) is identical to Method 25A except that a different
instrument is used. Method 25B applies to the measurement of total
gaseous organic concentration of vapor consisting primarily of alkanes.
The sample is extracted as described in Method 25A and is analyzed with
a nondispersive infrared analyzer (NDIR). Method 25B was not selected
because NDIR analyzers do not respond as well as FIA's to the solvents
used in this industry. Also, NDIR's are not sensitive in low concen-
tration ranges (<50 ppm), and the outlet concentrations from incinerators
and carbon adsorbers are often below 50 ppm.
D-7
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Method 25, "Determination of Total Gaseous Nonmethane Organics
Content" (TGNMO), was also considered. A 30- to 60-minute integrated
sample is collected in a sample train, and the train is returned to the
laboratory for analysis. The collected organics are converted in several
analytical steps to methane and the number of carbon atoms is measured.
Results are reported as organic carbon equivalent concentration. The
TGNMO procedure is not recommended for the FVC&P standard because it is
awkward to use for long test periods, and it does not continuously
measure and record concentration. Concentration variations would be
masked with a TGNMO time-integrated sample.
D.I.2.5 Details on Volume Measurement Method. Reference Methods
1, 2, 3, and 4 are recommended for determination of the volumetric flow
rate of the gas streams. Reference Method 1 is used to select the
sampling site, and Reference Method 2 measures the volumetric flow rate
using a pi tot tube velocity traverse technique. Methods 3 and 4 provide
gas analysis and moisture content, which are used to determine the gas
stream molecular weight in Method 2. The results are in units of standard
cubic meters per hour. The results do not need to be adjusted to dry
conditions (using Method 4 for moisture) because the VOC concentrations
are measured in the gas stream under actual conditions. The VOC con-
centrations results from the FIA detector are reported as parts of VOC
per million parts of actual (wet) volume (ppmv).
D.2 EMISSION MEASUREMENT TEST PROGRAM
During the standard support study for the FVC&P industry, the EPA
conducted two source tests for VOC emissions at one plant. Testing for
D-8
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each test series occurred continuously during the daytime shift for 5 to
8 days.
D.2.1 Purpose of Test Program
Field testing was conducted to evaluate various testing approaches
and methods, and to gather auxiliary useful information to understand
better the process operation. The purpose of the testing program was to
characterize not only the VOC emissions to the atmosphere, but the
usage, end distribution, and material balance of the VOC/solvent throughout
the entire printing process.
D.2.2 Comparison of the Two Test Series
The process operation was somewhat different for the two test
series. During test series one, the carbon adsorber was not on line
(although the carbon adsorber fans were operating); the wall exhaust fan
and the embosser exhaust fan were both running; a ceiling makeup air/ventilation
fan was operating; and several doorways to the print-room were open.
During test series two, the carbon adsorber was on-line and operating;
the wall exhaust fan and ceiling makeup air fan were turned off; the
embosser exhaust fan was still operating; and all doorways to the room,
except one, were closed. Thus, the air flow distribution in the printroom
was different for the two test series. Other process operations and
ambient conditions were similar for both test series.
The intent of the testing and the test procedures were also somewhat
different for the two test series. For the first test series, VOC mass
D-9
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flow rate was determined at the carbon adsorber inlet, wall fan exhaust,
and embosser exhaust. This provided information on VOC emissions to the
atmosphere, and capture efficiency of the vapor control system. For the
second test series, VOC mass flow rate was determined at the carbon
adsorber inlet, carbon adsorber outlet, embosser exhaust, and embosser
intake. This provided information on VOC emissions, carbon adsorber
control efficiency, gaseous capture efficiency, and an estimate of the
printroom VOC's that were drawn into the embosser. During both test
series, ambient room concentration surveys and doorway flow surveys were
made. These tests were much more detailed and frequent during the
second test in order to get a firmer grasp on the air flow and VOC
distribution in the printroom, and to ensure OSHA ambient VOC levels
were not exceeded. A solvent material balance was tried during the
first test only, relating solvent used to VOC emissions measured. This
required monitoring ink and dilution solvent usage for each print run,
as well as sampling and analyzing inks for organic content. On the
other hand, in the second test, samples of wastewater and distillation
column bottoms were taken from the carbon adsorber distillation/solvent
recovery system and analyzed for solvents, providing information on the
operation and efficiency of the solvent recovery system. Vinyl wall
covering product samples were also obtained before and after the embosser
and analyzed for solvent content, giving further information on the
solvent material balance distribution and embosser operation.
D-10
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D.2.3 The VOC Mass Flow Measurements
During the field tests, the VOC mass flow rate was determined at
several gas stream vents: carbon adsorber inlet, carbon adsorber outlet,
wall fan exhaust, and embosser exhaust. Both VOC concentration and
volumetric flow rate were determined at each location. The vents were
tested continuously each day during the daytime shift (except for the
carbon adsorber outlet which was only tested for 2 days.)
Continuous VOC concentration was determined with a flame ionization
detector according to proposed Method 25A. The instrument was cali-
brated to both propane and MEK each morning and evening, with span
checks periodically during the day. Certified gas cylinders were used
for propane standards; MEK standards were prepared in the field according
to proposed Method 110. The response ratio of MEK versus propane was
similar on all instruments. Independent propane and MEK audit cylinders
were analyzed as a quality assurance check.
During the second test series, VOC concentrations were also measured
(for part of the test period) with Reference Method 25 (TGNMO). Three
1-hour samples were taken at each test site. Duplicate trains were run
in all cases. The Method 25 results were inconsistent and did not
compare well with the Method 25A results, probably due to laboratory
analysis problems.
Volumetric flow rate measurements were conducted at each test site
two or three times per day. Method 1 was used to select the sampling
location, and Method 2 to determine the flow rate. Gas analysis by
Method 3 was not performed. Instead, the molecular weight of the vent
-------
gases was assumed to be the same as ambient air,, This was a valid
assumption since no combustion sources were involved and the hydrocarbon
concentrations in the sampled streams were low. Moisture content was
measured with a wet bulb/dry bulb instead of Method 4, but this should
not significantly affect the results. Gas stream moisture for this
process was not expected to differ from ambient. Also, moisture determination
is not an important parameter in this test procedure. The moisture
content is only used to adjust the molecular weight in a calculation
step in Method 2; since actual volumes are used, the volumes do not need
to be adjusted to a dry basis.
For this standard, Reference Methods 1, 2, 3, 4, and 25A are
recommended for VOC mass flow measurements, and these methods or equivalent
were followed during the field testing. Thus, the results can be used
to support the standard.
D.2.4 Ambient Measurements
Ambient measurements were conducted during both test series, but
more comprehensively during the second test. Open doorways were monitored
periodically (^3 times per day) to estimate the flux of VOC into and out
of the printroom. The flow rate through the doorways was measured with
a hand-held velometer (6 to 9 points were sampled per doorway). Con-
centration was measured with a portable combustible gas detector which
was calibrated with MEK standard.
D-12
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Ambient VOC concentration levels in the printroom were measured
periodically during the test period. The surveys were conducted throughout
the room at various heights (I1, 5', 8' from floor).
Detailed, frequent surveys were made of the VOC concentration and
flow rate into the embosser intake from the printroom, in order to
estimate and characterize the print line fugitive VOC's which were drawn
into the embosser exhaust stack. The VOC concentration and flow measure-
ments were made at representative sites around the perimeter of the
embosser intake hood as close to the intake as the physical equipment
setup permitted.
Eight-hour exposure sampling was performed on 3 days at four locations
in the printroom. Following a NIOSH ambient sampling procedure, ambient
air samples were drawn through carbon tubes. Analysis consisted of
extraction in carbon disulfide and liquid analysis by gas chromatograph.
The MEK, MIBK, and toluene were measured.
D.2.5 Wastewater Samples
Wastewater samples from the carbon adsorption/distillation system
were collected periodically for 2 days. The water samples were analyzed
for MEK, MIBK, toulene, and total organic carbon using standard water
analysis laboratory procedures.
D.2.6 Product Samples
Product samples of the vinyl wall covering were obtained before and
after the embosser and analyzed for solvent content. The analysis
procedure was an adaptation of NIOSH ambient carbon tube measurement
techniques. The product samples were put in a container and air was
D-13
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drawn across them and then through a carbon tube, which collected the
organics. The carbon tubes were analyzed in the same manner as the
ambient sample carbon tubes, for MEK, MIBK, and toluene. The product
sampling and analysis was a preliminary procedure. The results were in
a lower range than expected, but there is no way to independently verify
the results.
D.2.7 Liquid Solvent Usage Measurement
During the first test series, a liquid material balance test approach
was attempted. The purpose of this part of the testing was to determine
the total amount of solvent used for each print run arid to compare it to
the gaseous emissions that were measured.
All ink drums were weighed before and after the print run. Also,
during the run, the ink level in the print-head tanks was monitored
periodically with a dip stick, fnk samples were collected before and
after each run and analyzed for solvent content according to Reference
Method 24. Plant records and formulation data were also used as a cross
check. Dilution solvent used during a print run was directly measured
by volume.
After evaluating the field procedure and test results, it was
decided that this was not a good approach. It was very difficult to
accurately keep track of all the inks and dilution solvents used,
especially for multi-colored runs. The recordkeeping required was
quite extensive. Many Method 24 analyses were required. Small errors
in the volume or weight determinations of the liquid ink would lead
to large discrepancies with the gaseous part of the material balance.
The results from this liquid material balance part of the test were
inconsistent, and the approach is not recommended.
D-14
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to large discrepancies with the gaseous part of the material balance.
The results from this liquid material balance part of the test were
inconsistent, and the approach is not recommended.
D.3 MONITORING SYSTEMS AND DEVICES
The recommended performance test for this regulation includes the
determination of VOC control system efficiency. The overall VOC control
system is composed of two parts: vapor capture system, and vapor processing
device. The two types of processing devices that are expected to be
used in this industry are carbon adsorbers and incinerators. Possible
monitoring approaches and philosophy for each part of the VOC control
system are discussed below.
The purpose of monitoring is to ensure that an emission control
system is being properly operated and maintained after the performance
test. One can either directly monitor the regulated pollutant, or
instead, monitor an operational parameter of the emission control
system. The aim is to select a relatively inexpensive and simple method
that will indicate that the facility is operating as it did during the
last successful performance test.
D.3.1 Monitoring of Vapor Processing Devices
There are presently no demonstrated continuous monitoring systems
commercially available which monitor vapor processor operation in terms
of efficiency. This monitoring would require measuring not only inlet
and exhaust VOC concentrations, but also inlet and exhaust
volumetric flow rates. An overall cost for a complete monitoring
D-!5
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is difficult to estimate due to the number of component combinations
possible. The purchase and installation cost of an entire monitoring
system (including VOC concentration monitors, flow measurement devices,
recording devices, and automatic data reduction) is estimated to be
$25,000. Operating costs are estimated at $25,000 per year. Thus,
monitoring in terms of efficiency is not recommended due to the potentially
high cost and lack of a demonstrated monitoring system.
Monitoring equipment, however, is commercially available to monitor
the operational or process variables associated with vapor control
system operation. The variable which would yield the best indication of
system operation is VOC concentration at the processor outlet. Extremely
accurate measurements would not be required if the purpose of the monitoring
is to indicate operational and maintenance practicies regarding the
vapor processor. Thus, the accuracy of FIA (Method 25A) type instrument
would not be needed. Less accurate, less costly instruments which use
different detection principles are acceptable. Monitors for this type
of continuous VOC measurement, including a continuous recorder, typically
cost about $6,000 to purchase and install, and $6,000 annually to
calibrate, operate, maintain, and reduce the data. To achieve repre-
sentative VOC concentration measurements at the processor outlet, the
concentration monitoring device should be installed In the exhaust vent
at least two equivalent stack diameters from the exit point, and protected
from any interferences due to wind, weather, or other processes.
D-16
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For carbon adsorbers, the recommended monitoring approach is the
use of a continuous VOC exhaust concentration monitor as discussed above.
The EPA does not currently have any experience with continuous monitoring
of VOC exhaust concentration of carbon adsorbers in the FVC&P industry.
Therefore, performance specifications for the sensing instruments cannot
be recommended at this time. Examples of such specifications that were
developed for sulfur dioxide and nitrogen oxides continuous instrument
systems can be found in Appendix B of 40 CFR 60 (Federal Register.
September 11, 1974).
For some vapor processing systems, monitoring of another process
parameter may yield as accurate an indication of system operation as
the exhaust VOC concentration. Because control system design is
constantly changing and being upgraded in this industry, all acceptable
process parameters for all systems cannot be specified. Substituting
the monitoring of vapor processing system process parameters for the
monitoring of exhaust VOC concentration is valid and acceptable if
it can be demonstrated that the value of the process parameter is
indicative of proper operation of the processing system. Monitoring of
any such parameters would have to be approved by enforcement officials
on a case-by-case basis. Parameter monitoring equipment would typically
cost about $3,000 plus $3,000 annually to operate, maintain, periodically
calibrate, and reduce the data into the desired format.
For incineration devices, the exhaust concentration is quite low
and is difficult to measure accurately with the inexpensive VOC monitors.
D-17
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Instead, the firebox temperature has been identified and demonstrated to
be a process parameter which reflects level of emissions from the
device. Thus, temperature monitoring is the recommended monitoring
approach for incineration control devices. Since a temperature monitor
is usually included as a standard feature for incinerators, it is
expected that this monitoring requirement will not incur additional
costs for the plant. The cost of purchasing, installing, and operating
an accurate temperature measurement device and recorder is estimated at
$1,500.
The use of monitoring data i; the same regardless of whether the
VOC outlet concentration or an operational parameter is selected to
be monitored. Continual surveillance is achieved by comparing the
monitored value of the concentration or parameter to the value which
occurred during the last successful performance test, or alternatively,
to a preselected value which is indicative of good operation. A high
monitoring value does not positively confirm that the facility is out
of compliance; instead, it indicates that the emission control system is
operating in a different manner than during the last successful
performance test.
The averaging time for monitoring purposes should be related to
the time period for the performance test. Since the recommended per-
formance test for the FVC&P industry consists of three runs, each lasting
from 1/2 to 3 hours, the length of an entire performance test may vary
from 1-1/2 to 9 hours. Thus, 3 hours is recommended as the averaging
time period for monitoring purposes.
D-18
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D.3.2 Monitoring of Vapor Capture Systems
Monitoring the efficiency of a vapor capture system would be a
difficult and costly procedure. This would require measuring the VOC
concentration and volumetric flow rate in the inlet to the control
device and in each fugitive VOC vent. Such a monitoring system has not
been commercially demonstrated. The purchase and installation of an
entire monitoring system is estimated at $12,500 per stack, with an
additional $12,500 per stack per year for operation and maintenance.
Thus, monitoring hood efficiency is not recommended.
As an alternative, an operational parameter could be monitored.
The key to a good capture system is maintaining proper flow rates in
each vent. Monitoring equipment is commercially available which could
monitor these flow rate parameters. Flow rate monitoring equipment for
each vent would typically cost about $3,000 plus $3,000 annually to
operate, maintain, periodically calibrate, and reduce the data into the
desired format.
Proper flow rates and air distribution in a vapor system could also
be ensured by an inspection and maintenance program, which generally
would not create any additional cost burden for a plant. The additional
value of information provided by flow rate monitors would probably be
minimal. Thus, it is recommended that no formal monitoring of the air
distribution system be required. Instead, routine visual inspections of
the fan's operation would indicate whether or not capture efficiencies
remain at the performance test level.
-------
D.3.3 Monitoring of Inks
If a plant elects to use low-solvent content inks in lieu of
control devices, then the VOC content of the inks should be monitored.
There is no simplified way to dD this. The recommended monitoring
procedure is to keep records of the VOC content and amount of each ink
used and calculate the weighted average VOC content over the time period
specified in the regulation.
D-20
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Appendix E
MANUFACTURERS IDENTIFIED THAT POTENTIALLY COAT OR PRINT
FLEXIBLE VINYL SHEET MATERIAL
Company Name
Plant Location
ABC Backing Corp.
Acme Backing Corp.
Aladan Plastics Company, Inc.
Alltex Laminating Corp.
Alpha Associates Inc.
ALU Textile Combining Corp.
American Waterproofing
Apex Plastics Industries
Armco, Inc.
Athol Manufacturing Corp.
Barley Earhart Corp.
B.F. Goodrich
Biddeford Industries
BLP Inc.
Borden Coated Fabrics
Breneman, Inc.
Bryant Industries Inc.
Buckeye Fabric Finishing
Carrier Corp.
Chelsea Industries Inc.
Chrysler Plastic Products
Cinderella Clothing Ind.
Coaters, Inc.
Colorama, Inc.
Columbia Leather & Coating
Commercial Vinyls, Inc.
Compo Industries
Craft Laminating & Backing Co.
Custom Coating Products, Inc.
Custom Laminations, Inc.
St. Louis, MO
Stamford, CT
Philadelphia, PA
Mt. Vernon, NY
Woodbridge, NC
Hoboken, NJ
New Haven, MO
Hauppauge, NY
Middletown, OH
Butner, NC
Portland, MI
Akron, OH
Biddeford, ME
Pulasi, VA
Columbus, OH
Oswego, NY
Paterson, NJ
Coschocton, OH
Syracuse, NY
Boston, MA
Sandusky, OH
King of Prussia, PA
New Bedford, MA
Paterson, NJ
Kenilworth, NJ
New Castle, IN
Waltham, MA
Sowyersville, PA
Paterson, NJ
Paterson, NJ
E-l
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Appendix E
(Continued)
Company Name
Plant Location
Dal Bac Manufacturing
Dayco Inc.
Detroit Body Products Co.
Duracote Corporation
Engineered Yarns
Excello Fabric Finishes
FAB Industries, Inc.
Farrington Texol Corp.
Ferro Corporation
Flexfirm Products
Flexicota Processing Company
Flex Tex Corp.
Ford Motor Company
Garden State Laminating Co.
General Tire & Rubber Company
General Motors
Georgia Bonded Fibers
Graniteville Company Woodhead
greater City Textile Company
Great Lakes Paper Compnay, Inc.
Griffolyn Feef Industries
Gui1 ford Mills, Inc.
Gustave Rubber Inc.
Haartz Auto Fabric Company
Hardwick Laminators
Harte & Co. -Diamond Shamrock
Hub Fabric Leather Company
Jewell-Sheen Coating Inc.
Joanna Western Mills Company
Forney, TX
Dayton, OH
Wixom, MI
Ravenna, OH
Coventry, RI
Coshocton, OH
New York, NY
Wai pole, MA
Norwalk, CT
El Monte, CA
Clifton, NJ
Chelsea, MA
Dearborn, MI
Paterson, NJ
Reading and Lawrence,
MA; Toledo, OH; Colum-
bus, MS; Salem, NH; and
Jeannette, PA
Dearborn, MI
Buena Vista, VA
Graniteville, SC
Long Island City, NY
Chicago, IL
Houston, TX
Greensboro, NC
Bronx, NY
Action, MA
Harkwick, MA
New Yrok, NY
Everett, MA
Long Island City, NY
Chicago, IL
E-2
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Appendix E
(Continued)
Company Name
Plant Location
John Boyle & Compnay Inc.
John Schneller & Associates
Kellwood Company
Lakeville Laminating
Lockwood Industries
Manning Fabrics Inc.
Masland Duraleather Co.
McGrew Color Graphics
Micro-fibres Inc.
Oak Industries Inc.
Pacesetter Products Inc.
Pandel-Bradford
Pantasote
Perforating Industries Inc.
Pervel Idustries, Inc.
Plever Industries, Inc
PRF Corporation
Pyrotex Corporation
Real span Corporation
Reliable Coated Fabrics Company
R.J.Liebe Athletic Lettering
Rock!and Bamberg Industries
Rudd Plastic Fabrics Corp.
Selecta Finishing
Seton Company
Shelter-Rite
Silver Star Fabrics Corp.
Sourthbridge Plastics
Sourthern Bonded, Inc.
S and S Backing Inc.
Standard Coated Products
Statesville, NC
Kent, OH
St. Louis, MO
Fairfield, NJ
Van Nuys, CA
St. Pauls, NC
Mishawaka, IN
Kansas City, MO
Pawtucket, RI
Crystal Lake, IL
Salem, MA
Lowell, MA
Greenwich, CT
Linden, NJ
Stratford, CT
Carlstadt, NJ
New York, NY
Leombusterm, MA
Hickory, NC
New York, NY
St. Louis, MO
Bamberg, SC
Brooklyn, NY
Calhoun, GA
Newark, NJ
Millersburg, OH
Clifton, NJ
Clifton, NJ
Henderson, NC
St. Louis, MO
Haxelton, PA
E-3
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Appendix E
(Continued)
Company Name
Plant Location
Standard Shade Roller
Star-Tex Industries, Inc.
Stauffer Chemical Company
Stedfast Rubber Co., Inc.
Synthon, Inc.
Texon, Inc.
Thermopatch Corporation
Tuff Kote Inc.
Uniroyal, Inc.
United Chemicals Inc.
United Processing Corporation
U.S. Plymeric Chemicals
Vulpex Inc.
Wall Mates Vinyl, Inc.
Wendell Testiles Shirt Hug
Weymouth Art Leather Company
Whitman Products Limited
Ogdensburg, NY
Newburgport, MA
Newburgh, NY
Westport, CT
North Easton, MA
Cambridge, MA
Sourth Had ley, MA
Bronx, NY
Warren, MI
Mishawaka, In
Port Clinton, OH
Stoughton, WI
Providence, RI
Hawthorne, NJ
Santa Ana, CA
Bellmore, NY
Bellmore, NY
Essex, NJ
Braintree, MA
West Warwick, RI
Sources: The 1980 Thomas Register; Economic Information System Plants Data
Base; Chemical Fabrics and Film Association.
E-4
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Appendix F
COMPUTATION OF GROWTH RATE
The growth rate for the value of shipments of supported vinyl materials
over the 1971-1979 period may be obtained by employing the following methodo-
logy:
1. Compute a trend line for the value of shipments:
Value OT shipments ' — —
Year
(N)
1971
1973
1975
1977
1979
(In Millions)
(YJ
$ 488.90
664.60
607.20
760.50
702.10
£Y = 3,223.30
Time Period
(X)
-2
-1
0
+1
±2
IX = 0
XY
- 977.8
- 664.6
Q
760.5
1,404.2
£XY = 522.3
X2
4
1
1
4
1X2 - 10
_ ZY _ 3,223.30 ,... ...
~~N 5 = "44.66
a =
b » HI » 522^3 _
ZX2 10 "
Y = 644.66 + 52.23 X
Base Year: 1975
Y = value of shipments of supported vinyl materials in millions of
do If ars
X unit = two years
F-l
-------
2. Compute the estimated values (Y) for 1971 and 1979:
A
Y1971 = 644.66 + 52.23(-2) - 540.20
Y1979 = 644.66 + 52.23(+2) = 749.12
3. Compute the compound growth rate for the 1971-1979 period implied by
the trend line:
G =
'Ar
where G = compound growth multiplier
Xn = the value of X in time period n
Xi = the value of X in time period 1
n = the length of the time period*
The compound growth rate (C) can then be found by:
C - G - 1
For example,
j.
G = ("540'.20)
1
G = (1.3867)9"
*The length of the time period 1971-1979 is nine (9) years rather than eight
(8) years because the start of the period is January 1971, so that the
entire year 1971 is included.
F-2
-------
Log G = 1 (Log 1.3867)
= -g (0.141997)
= 0.015777
G = Antilog 0.015777
= 1.03699
and
C = 1.03699 - 1
= 0.03699 or 3.7% per annum
Figure F-l graphically portrays the estimated trend line along
with the actual observations, which are denoted by an
F-3
-------
Figure F-1.
Trend Line for the Value of Shipments of Supported Vinyl
Materials in Millions of Dollars, 1971-1979.
800-
w
c 750
o
700 H
650-
600-
to
Z
LLJ
2
a.
I
w
u.
O 550
LU
< 500
450
1971
1973
—1
1975
1977
1979 YEAR
r
-2
~T
-1
F-4
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Appendix G
FORMULA FOR DETERMINING THE PERCENTAGE CHANGE
IN REAL OUTPUT
TRo= Po QO
where TR = total revenue in some base period
PQ = price
Q = quantity
TR + ATR = (P + AP) (Q + AQ)
0 0 0
TRn + ATR _ (P + AP) (Q0 + AQ)
TRO ; TRO
1 + ALE. = (Pn + AP) (Qo + AQ)
""
ATR
% change in real output = 71 = TRn
Qo ,
0
Example:
Given that supported vinyl materials (excluding wall coverings)
experienced a 3.7% annual growth rate in value of shipments over the 1971-
79 period and that the price index for apparel experienced a 4.2% annual
advance, then the percentage change in real output over the period was:
G-l
-------
i +
Qo
ATR
TR0
- 1
- 1-037
1.042
= 0.9952
= -.0048
R-2
-------
TECHNICAL REPORT DATA
(I'lcasc read IniLnictttins on llie wcvte bcfnic completing)
1 REPORT NO
EPA-450/3-81-016a
2.
4. TITLE AND SUBTITLE
Flexible Vinyl Coating and Printing Operations
Background Information for Proposed Standards
3, RECIPICNT'3/VCCbS'JIOfVNO.
5. REPORT DATE
January 1983
6. PERFORMING OnGANI^AI ION COOb
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
. PERFORMING ORGANIZATION NAME AND ADORE3S
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3058
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of Performance for the control of emissions of volatile organic compounds from
flexible vinyl coating and printing operations are being proposed under the authority of
Section 111 of the Clean Air Act. The standard would apply to flexible vinyl printing
lines for which construction or modification began on or after the date of proposal of
the regulation. This document contains background information and environmental and
economic impact assessments of the regulatory alternatives considered in developing the
proposed standard.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Air Pollution
Pollution Control
Standards of Performance
Vinyl Coating and Printing
Industrial Fabric Coating
Volatile Organic Compounds
3. DISTRIBUTION STATEMENT
Unlimited
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI I Ickl/Croup
Air Pollution Control
19. SECURITY CLASS (This Report)
Unclassified
20. SECURITY CLASS (Tinspage)
Unclassified
13-B
21. NO. OF PAGLS
258
22. PRICE
EPA Form 2220-1 (9-73)
-------
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•£"•
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q
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