United States
        Environmental Protection
        Agency
 Office of Air Quality
 Planning and Standards
 Research Triangle Park NC 27711
EPA-450/3-P2-013
April 1992
        Air
EPA  CONTROL OF VOC EMISSIONS
       FROM INK AND PAINT
       MANUFACTURING PROCESSES
       control
technology center

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                                            EPA-450/3-92-013
     CONTROL OF VOC EMISSIONS FROM
INK AND PAINT MANUFACTURING PROCESSES
      CONTROL TECHNOLOGY CENTER

               SPONSORED BY:

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

  Air and Energy Engineering Research Laboratory
       Office of Research and Development
      U.S. Environmental Protection Agency
   Research Triangle Park, North Carolina 27711
                          U.S. E'tji':f:':r'''"!""
                          R--:.'"' ~'.'-:-.''   ,        1-' h floor
                  April 1992

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                                              EPA-450/3-92-013
                                                    April 1992
     CONTROL OF VOC EMISSIONS FROM
INK AND PAINT MANUFACTURING PROCESSES

                 Prepared by:

                 B.W. McMinn
                PJ. Marsosudiro
        Alliance Technologies Corporation
           100 Europa Drive, Suite 150
        Chapel Hill, North Carolina 27514
          EPA Contract No. 68-DO-0121
           Work Assignment No. 1-29
            (Alliance No. 1-638-029-1)
                Project Officer

               Joseph Steigerwald
           Emission Standards Division
      U.S. Environmental Protection Agency
   Research Triangle Park, North Carolina 27711
                 Prepared for:

           Control Technology Center
      U.S. Environmental Protection Agency
   Research Triangle Park, North  Carolina 27711
                    CH-92-02

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                                   DISCLAIMER

     This final report was prepared for the Control Technology Center, U.S. Environmental
Protection Agency, by Alliance Technologies Corporation, 100 Europa Drive, Chapel Hill, NC
27514, in partial fulfillment  of Contract No. 68-DO-0121, Work Assignment No 1-29.  The
opinions, findings and conclusions expressed are those of the authors and not necessarily those
of the Environmental Protection Agency.
CH-92-02       .                             Ill

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                                     PREFACE

     This report was prepared for and funded by the Control Technology Center (CTC), U.S.
Environmental Protection Agency. The CTC was established by EPA's Office of Research and
Development (ORD) and Office  of Air Quality Planning and Standards (OAQPS) to provide
technical assistance to State and local air pollution control agencies. Several levels of assistance
are available through the CTC:  a CTC HOTLINE provides telephone assistance  on matters
relating to air pollution control technology; in-depth engineering assistance  is provided when
needed  by  EPA and its contractors; and the CTC can  provide technical  guidance through
publication of technical guidance documents, development of personal computer software, and
presentation of workshops on control  technology matters.  The fourth assistance program
sponsored by the CTC is the  CTC Bulletin Board System (BBS), a part of the EPA OAQPS
Technology Transfer Network. Users of the BBS can retrieve CTC information through one of
four major  area  menu  selections.   The  four  areas  included  are Utilities,   Help Center,
Documents/Software, and CTC Projects.
     Technical guidance projects, such as this one, focus on.topics of national  or regional
interest that are identified through contact with State and local agencies.  In this case, the CTC
received a number of calls on controlling volatile organic compound  (VOC) emissions from
processes used to manufacture ink and paint. Controlling VOC emissions at various source types
that have not been addressed by Control Techniques Guidelines (CTG's) is of interest to many
States and local air  pollution  control  agencies due to ongoing ozone nonattainment problems
(VOC is a precursor of ozone) and requirements in Title I of the Clean Air Act Amendments of
1990. This report presents the results  of a study to identify and collect information on paint and
ink manufacturing processes and  the VOC emissions generated  during these  operations.
CH-92-02                                     IV

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                                TABLE OF CONTENTS

Section                                                                            Page

Disclaimer  	iii

Preface	iv

List of Tables  	viii

List of Figures	ix

Executive Summary	  x

1.0    Introduction  	1-1

2.0    Industry Structure and Process Description	2-1
2.1    General  	2-1
2.2    Paint Manufacturing Industry  Structure  	2-1
       2.2.1     Introduction  	2-1
       2.2.2     Market, Raw Materials, and Products   	2-1
       2.2.3     Paint Product End-Uses	2-4
2.3    Ink Manufacturing Industry Structure	2-8
       2.3.1     Introduction  	2-8
       2.3.2     Market, Raw Materials, and Products   	2-8
       2.3.3     Ink Product End-Uses  	2-11
2.4    Manufacturing Process  Description  	2-14
       2.4.1     Introduction	2-14
       2.4.2     Preassembly  and Premix	2-14
       2.4.3     Pigment Grinding or Milling  	2-17
       2.4.4     Product Finishing  	2-28
       2.4.5     Product Filling  	2-29
2.5    References  	2-31

3.0    Volatile Organic Compound Emissions, Regulations, and Permits	3-1
3.1    General  	3-1
3.2    Source Identification and Characterization  	3-1
       3.2.1     Introduction  	3-1
       3.2.2     Preassembly  and Premix  	3-2
       3.2.3     Pigment Grinding or Milling  	3-2
       3.2.4     Product Finishing  	3-4
       3.2.5     Product Filling  	3-4
       3.2.6     Equipment Cleaning  	3-5
3.3    Emission Factor Data	3-6
CH-92-02

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                         TABLE OF CONTENTS (continued)
Section                       .                                                  Page

       3.3.1     Introduction		3-6
       3.3.2     Current Regulations	3-8
       3.3.3     Permits  	3-9
       3.3.4     Plant Trips	3-15
3.4    References  	3-17

4.0    Emission Control Techniques 	4-1
4.1    Introduction  	4-1
4.2    Voc Emission Reduction Methods	4-1
       4.2.1     Equipment or Process Modifications  	4-2
       4.2.2     Improved Operating Practices	4-6
       4.2.3     Recycling Techniques  	4-7
4.3    Product Reformulation	4-7
       4.3.1     Powder Coatings	4-10
       4.3.2     Waterborne Paints and Inks  	4-10
       4.3.3     Radiation-Curable Paints and Inks	4-11
       4.3.4     High-Solids Paints and Inks	4-11
4.4    VOC Emissions Reduction by Control  Systems	4-12
       4.4.1     Capture Devices	4-12
       4.4.2     Recovery Techniques	4-14
       4.4.3     Combustion Techniques	4-19
4.5    References  	4-25

5.0    Control Cost Analysis	5-1
5.1    Introduction	5-1
5.2    Thermal Incineration  	5-1
       5.2.1     Equipment Tank Lids	 ..." 5-1
       5.2.2     Horizontal Media Mills 	5-4
       5.2.3     Equipment Cleaning Devices 	5-6
5.3    VOC Emissions Reduction Methods 	5-6
5.4    Product Reformulation	5-8
5.5    Capture Devices  	5-8
5.6    Thermal Incineration  		5-8
5.7    References	5-11
CH-92-02                                    VI

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                       TABLE OF CONTENTS (continued)






Section                                                                      Page



Appendix A     Lists of Facilities with Annual Sales Greater Than $1 Million  	A-1




Appendix B     Permit Requirements from Several States	B-l




Appendix C     Trip Reports	C-l
CH-92-02                                  Vll

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                                 LIST OF TABLES

Number                                                                        Page

2-1    Paint Raw Materials Consumed in 1987	2-3
2-2    Paint Categories By Use	2-5
2-3    Ink Raw Materials Consumed in 1987	2-9
2-4    Ink Categories By Use	2-12

3-1    Uncontrolled Emission Factors for Paint, Varnish, and Printing Ink
       Manufacturing	3-7
3-2    State Regulations for Paint and Resin Manufacturing Facilities	3-10
3-3    State Regulations for Coatings and Ink Manufacturing Facilities	3-13
3-4    Emissions for 1990 	3-16

5-1    Applicability and Use of VOC Emission Reduction Methods in Paint
       and Ink Facilities	5-2
5-2    Equipment Cover Cost Figures 	5-5
5-3    Horizontal Media Mill Cost Figures	5-7
5-4    Cleveland'Facility Thermal Incineration Cost Figures  	5-10

A-l    Paint and Allied Products Facilities (SIC 2851) with Annual Sales
       Greater Than $1 Million	A-2
A-2    Printing Ink Facilities (SIC 2893) with Annual Sales Greater
       Than $1 Million  	A-14

B-l    Selection of Ohio Permit Information	B-2
B-2    State of California Permit Information	,	B-3.
B-3    State of Illinois Permit Information	B-4
B-4    State of Texas Permit Information	B-7
B-5    Permit Information for Other States	;	B-23
CH-92-02                                    Vlll

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                                LIST OF FIGURES

Number                                                                       Page

2-1   Flow Diagram of the Paint and Ink Manufacturing Process	2-15
2-2   Schematic Diagram of a Three-Roll Mill 	2-18
2-3   Schematic Drawing of Conventional Sand Mill	2-22
2-4a  Schematic Drawing of the Stator/Rotor Assembly in a High-Speed Stone Mill  . .  2-24
2-4b  Schematic Drawing of the Stator/Rotor Assembly in a Colloid Mill	2-24
2-5   Schematic Drawing of the Milling Head of a High-Speed
      Impingement (Kinetic Dispersion Mill)  	2-27

4-1   Typical Flat Mix Tank Cover	4-4
4-2   Recycling and Reusing Cleaning Solvent	4-8
4-3   Production Trends in Coating Systems	4-9
4-4   Catalytic Incinerator	4-20
4-5   Thermal Incinerator	4-20
CH-92-02                                    IX

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                               EXECUTIVE SUMMARY

     In the United States today there are approximately 1,123 companies operating 1,426 paint
plants and  224 companies operating 504 ink facilities.  Many of these manufacturing facilities
produce solvent-based products. Together the two industries consume an estimated 2,750 million
pounds of organic solvent which accounts for 0.05 percent of total volatile organic compound
(VOC) emissions. The application of. these paints and inks accounts for an additional 13 percent
of VOC emissions.
     The products of the paint manufacturing industry include architectural  coatings, product
coatings for original equipment manufacturers (OEM), and special-purpose coatings.  The four
primary types of inks are letterpress  inks, lithographic and  offset  inks, gravure  inks, and
flexographic inks. All of these products are made with the same basic raw materials:  pigments,
solvents, resins (or binders),  and other additives.  In most cases, the  manufacturing facilities
purchase these raw materials and then formulate or blend, rather than react, to produce a finished
product.  The batch process production  of paint and ink involves four major steps: preassembly
and premix, pigment grinding/milling, product finishing/blending, and product filling/packaging.
Some of the equipment used to accomplish these manufacturing steps include roller mills; ball
and pebble mills; attritors; sand, bead, and shot mills; horizontal media mills; and high-speed disk
dispersers.
     Releases of volatile  organic compounds from paint and ink manufacturing include those
from the process steps and from cleanup operations. However, very little information is available
which quantifies these emissions.  Many paint and ink manufacturing facilities  calculate total
plant VOC emissions based on raw material consumption rather than calculating emissions from
processes or equipment by an alternative method. Emission values therefore reflect solvent losses
from manufacturing, cleaning, and  storage. Because  emissions have not been quantified, there
are no publicly available emission factors for paint and ink manufacturing processes.  Emission
factor data contained in facility permits is most likely based on theoretical equations rather than
on actual test data.  These values vary  significantly from State to State.
     Similarly, regulatory requirements vary from State to State as paint and ink facilities are
not identified by any  current  Control Technique Guideline (CTG).  In many States only those
non-CTG facilities emitting more than 100 tons per year are controlled,, while in other States the

CH-92-02                                      X

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VOC limit may be 15 pounds per day. Several of the requirements common to the States with
rules regulating VOC emissions from paint and ink facilities include the following: covers must
be used on all open equipment and equipment must be monitored and inspected regularly for
leaks.  Most States also exclude from regulation those facilities emitting less than 100 tons per
year VOC and those plants manufacturing primarily water-based products.
     Regardless of State regulations, paint and ink  facilities must use some method to control
the VOC emissions that are generated throughout the  manufacturing process. If left uncontrolled,
these emissions can cause high concentrations of VOC in the work area compromising worker
health, safety, and productivity. Some of the methods used by paint and ink facilities in reducing
emissions are tank lids, horizontal media mills, equipment cleaning devices, recycling techniques,
and improved operating practices.  Many facilities have also invested research and development
time and  dollars  in  new product lines  with  lower VOC concentrations.  Powder coatings,
waterborne paints and inks, radiation-curable paints and inks, and high-solids products are slowly
replacing some of the markets once dominated by solvent-borne formulations.
     Few facilities  use  VOC  reduction  methods  other than  those previously mentioned.
However,  control systems including capture  devices  and  thermal  incinerators are technically
feasible for the low VOC concentrations and the wide variety of contaminants found in paint and
ink waste  streams.
     Before a thorough assessment of control systems can be conducted, more emissions data
must be accumulated or generated. There  is  a general lack of data presented in literature and
State permit information concerning the quantity, composition, and breakdown of the emissions
generated  by the various stages in the paint and ink manufacturing process.
CH-92-02                                     XI

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                                     CHAPTER 1
                                  INTRODUCTION

     This report presents the results of a study to collect and report information on processes
used to manufacture paint and ink, volatile organic compound (VOC) emissions generated during
these operations, emission control techniques and their effectiveness, and costs associated with
process changes and emission control options.  State agencies and other government-sponsored
programs, as well as equipment manufacturers, professional and trade organizations, and paint
and  ink  manufacturers  were contacted  to  assess  production methods,  available control
technologies, and current emission rates from the manufacturing processes.
     Many paint and ink manufacturing facilities produce solvent-based products. In the United
States  today, there are approximately  1,123 companies operating  1,426 paint plants and 224
companies operating 504 ink facilities.  Almost half of these plants are small, employing fewer
than 20  people.  Most  of  the facilities are  located  in  population centers because  of high
transportation costs. It is also estimated that more than half of these plants are located in ozone
nonattainment  areas.
     This report is divided into five chapters and three appendices.  Chapter  2 characterizes the
two areas of primary focus, the paint manufacturing industry and the ink manufacturing industry,
and also provides a general description of the raw materials these facilities use, the products they
make,  and the markets they  serve.  Chapter 2 also provides  a description of the manufacturing
process and processing equipment common to both ink and paint manufacturers.
     The sources of process VOC emissions are identified and characterized in Chapter 3.  Also
included  in this section are  emission factor data  which are divided  into  three sections:
information retrieved from current State regulations, information obtained from State permit files,
and data  received from plant trips.
     Chapter 4 discusses methods of reducing and controlling VOC emissions resulting from the
ink  and  paint manufacturing  process.   Areas addressed  include  equipment  and process
modifications,  improved  operating practices, recycling techniques, product reformulations, and
add-on control techniques.  Chapter  5 estimates  the costs associated with several of  these
reduction and control methods.
CH-92-02
                                          1-1

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     The report also includes three appendices.  Appendix A lists paint and ink facilities with
annual sales greater than one million dollars.  Appendix B contains tables which have a selection
of permit requirements from several States.  Appendix C contains copies of the trip reports for
the two paint and two ink facilities visited during the  course of this work assignment.
 CH-92-02
                                            1-2

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                                    CHAPTER 2
              INDUSTRY STRUCTURE AND PROCESS DESCRIPTION

2.1 GENERAL

     This chapter gives an overview of the paint and ink manufacturing industries.  The chapter
is  divided into three sections:  Paint Manufacturing  Industry Structure,  Ink Manufacturing
Industry  Structure, and Manufacturing Process Description.   Both of the industry structure
sections address the current market, materials used in the manufacturing process, products
manufactured, and product end-uses.  The last section in this chapter focuses on the four steps
in  both the paint and ink manufacturing processes with  emphasis on equipment and procedure.

2.2 PAINT MANUFACTURING INDUSTRY STRUCTURE

2.2.1  Introduction

     This section gives an overview of the paint manufacturing industry, including geographic
distributions, production trends, industry issues, and the major subdivisions  within the industry.
Also included in this section is information relating to manufacturing raw materials,  finished
products, and  product  end-uses.   Much of  the  data is based on the Standard Industrial
Classification (SIC) 2851.

2.2.2  Market, Raw Materials, and Products

     The paints and allied products industry, as defined by SIC 2851, consists of firms that
manufacture paints, varnishes, lacquers, enamels, shellacs, putties, wood fillers and sealers, paint
and varnish removers,  paint  brush  cleaners, and allied paint products.   Facilities which
manufacture pigments, resins, printing inks, adhesives and sealants, and artists' paints are not
included under SIC code 2851.  According to the 1987 Census of Manufactures, the paints and
allied products industry employed 55.2 thousand people  with nearly 40 percent of the industry's
employment in  the States of California, Ohio, Illinois, and New Jersey.  In 1987, SIC 2851
                                                              V
CH-92-02                                   2-1

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facilities were composed of 1,123 companies operating 1,426 plants, two-thirds of which were
located in ten states. Over 50 percent of paint manufacturing plants are small, privately owned
facilities employing less than 20 people and specializing in a limited product line marketed within
a small geographic region. Some companies, however, own multiple manufacturing facilities and
distribute products nationwide.  Regardless of ownership, the paint manufacturing industry tends
to concentrate in population centers because of high transportation costs.   An estimated 50
percent of the manufacturing facilities are located in ozone nonattainment areas.
     The raw materials used in the paint manufacturing process include pigments, solvents, and
resins.   Some commonly used paint raw  materials are listed in Table 2-1.  The chemical
composition of paint varies depending on the desired paint properties.  Pigments provide the
coating with color, opacity, and a degree of durability.  Pigmented coatings are more weather-
resistant  than unpigmented paints.  In the case of metal primers, pigments are used to check or
inhibit corrosion of the metal. Pigments may be either organic or inorganic.  Almost all of the
organic pigments used today  are manufactured, while inorganic pigments  may be either natural
or manufactured.  Most natural pigments  are oxides or hydroxides of iron.  Manufactured
pigments span the entire color spectrum with a wide range of brilliance and opacity.
     The fluid component of a coating, consisting of nonvolatile binders  and volatile solvents,
is called  the vehicle.  Binders are those components which form a continuous phase, hold the
pigment  in the dry film, and cause it to adhere to the surface to be coated.. The majority of
binders in  modern paint  films are  composed of resins and drying oils which are  largely
responsible for the protective and general mechanical properties of the film. Most resins and oils
used in paint manufacturing  are organic, although some  are inorganic.  Alkyds, acrylics, and
                                                2 ^
vinyls are three of the more commonly used resins.
     The vehicle solvents are used to keep paints in liquid form so they can  be applied easily.
When a coating is deposited on a substrate, the solvent should evaporate completely. It is used
to transfer the pigment/binder mixture to a surface in a thin, uniform film and plays no role in
film formation. Materials used as solvents include aliphatic hydrocarbons (white spirit and the
Special Boiling Point (SBP) solvents), aromatic hydrocarbons (toluene, xylene, and the trimethyl
benzenes), alcohols, esters, ketones, esters and ether-esters of propylene  glycol.  Water is the
solvent in water based and emulsion paints.  >3

CH-92-02                                      2-2

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                TABLE 2-1.  PAINT RAW MATERIALS  CONSUMED IN 1987
                                           Material
                                            Quantity1
     Vegetable oils	mil Ib

     Pigments:
                    Titanium dioxide, composite and pure (100% TiO2)  	mil Ib
                    Other inorganic pigments, including chrome colors, whiting,
                      white and red lead, litharge, lithopone, zinc oxide,
                      calcium carbonate precipitated, etc	
                    Organic color pigments, lakes, and toners	

     Solvents:
                    Hydrocarbons (toluene, xylene, etc.)  	mil Ib
                    Alcohols (butyl, ethyl, isopropyl, etc.)	do
                    Ketones and esters (methyl ethyl ketone, ethyl acetate,
                      etc.)	do
                    Other	do

     Plastics resins:
                    Alkyds	mil Ib
                    Acrylics	do
                    Vinyl	do
                    Other plastics resins	do

     Petroleum winners (naphtha)	  mil gal

     Nonmetallic minerals and earths, ground or otherwise treated (calcium
       carbonate, talc, silica, kaolin, mica, barite, soapstone, clay,
       and other clay minerals) for use as extenders	

     All other organic and inorganic  chemicals, n.e.c	
                                                *183.0


                                                  763.7
                                                 (NA)
                                                 (NA)


                                               **818.2
                                                *283.6

                                                 435.2
                                                *382.5


                                                626.3
                                                 627.9
                                               **595.0
                                                *764.5

                                                   (S)
                                                 (NA)

                                                 (NA)
   'For some establishments, data have been estimated from central unit values which are based on quantity-cost
    relationships of the data reported by the establishmenl. The following symbols are used when the percentage
    of each quantity figure estimated in this manner equals or exceeds 10 percent of the figure published in this
    table: *10 to 19 percent estimated; **20 to 29 percent estimated. If 30 percent or more is estimated, figure
    is replaced by (S).

    Source: Adapted from Reference 1
    do - Ditto
    n.e.c. - Not elsewhere classified
    (NA) - Not available
    (S) - Withheld because estimate did not meet publication standards
CH-92-02 '
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      Another category of paint raw materials, present only in small concentrations in the 0.2 to
ten percent range, is additives.  These chemicals perform a special function or impart a certain
property to the coating.  Additives include driers,  thickeners, biocides, surfactants, dispersing
                              5
agents, antifoams, and catalysts.
      The products of the paint manufacturing industry are categorized according to their use, the
type of vehicle or carrier used in manufacture, and the method of curing. The use categories are
architectural coatings, product coatings for original equipment manufacturers (OEM), and special
purpose coatings.  Architectural coatings are products used to coat interior and exterior surfaces.
OEM coatings include finishes which provide the first coating on newly manufactured equipment
and products.  Special purpose coatings are products formulated to meet specific use requirements
such as extreme  temperatures or heavy wear.  A summary  of the paint use divisions by  use
category and subcategory is found in Table 2-2.  In 1987, the  value of all coating shipments was
$9.91 billion dollars ($4.25 billion for architectural  coatings,  $3.64 billion for product coatings,
and $2.02 billion for special purpose coatings).   Ward's Business Directory lists 364 paint  and
allied products facilities in SIC 2851 with  1990 sales greater than $1,000,000.  This list is given
in Appendix A, Table A-l.
      Paint products may also be classified by the type of vehicle or carrier incorporated in the
paint formulation. This classification normally refers to the volatile solvent portion of the vehicle
rather than to the combined solvent and binder.   The  volatiles, typically water or solvent,
evaporate after the paint has  been applied'to the substrate.  The total annual production of the
average paint plant in the United States consists of 60 percent solvent based product, 35 percent
water based paint, and 5 percent allied products. While  more than 70 percent of architectural
coatings are water based, the majority of product and special purpose coatings are solvent based.1
      The third method used to categorize coatings is curing.  This system applies to nonvolatile
coating systems which do not rely on the evaporation of solvent or water to achieve the desired
finish. Coatings  included in  this category  are powder coatings, radiation-curable coatings,  and
two-part catalyzed paints.
CH-92-02
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                        TABLE 2-2.  PAINT CATEGORIES BY USE
                                                                       1987 Product Shipments
                            Product
Quantity
     Value
(million dollars)
 ARCHITECTURAL COATINGS	mil gal       527.0

     Exterior, solvent-type:
        Solvent thinned paints and tinting bases, including
          barn and roof paints	mil gal        20.2
        Solvent thinned enamels and tinting bases,
          including interior-exterior floor enamels	  do        14.5
        Solvent thinned undercoaters and primers	  do         8.2
        Solvent thinned clear finishes	do        10.3
        Solvent thinned stains, including shingle and
          shake	  do        17.8
        Other exterior solvent thinned  coatings, including
          bituminous paints	  do        11.6

     Exterior, water-type:
        Water thinned paints and tinting bases, including
          bam and roof paints	mil gal        95.9
        Water thinned undercoaters and primers	do         7.7
        Water thinned stains  	  do         9.2
        Other exterior water thinned coatings  	; ...  do        11.4

     Interior, solvent-type":
        Flat solvent thinned wall paints and tinting
          bases, including mill white paints  	mil gal         8.3
        Gloss and quick drying enamels and other gloss
          solvent thinned paints and enamels  	  do         4.4
        Semigloss, eggshell, satin solvent thinned
         paints, and tinting bases	do        15.0
        Solvent thinned undercoaters and primers	  do         7.0
        Solvent thinned clear finishes	do         8.6
        Solvent thinned stains 	do         7.6
        Other interior solvent thinned coatings	do         5.8

     Interior, water-type:
        Flat water thinned paints and tinting bases	mil gal       125.5
        Semigloss, eggshell, satin, and other gloss
          water thinned paints and tinting bases  	  do        81.3
        Water thinned undercoaters and primers	do        10.2
        Other Interior water thinned coatings	do        15.9


     Architectural lacquers	do        10.5

     Architectural coatings, n.sJc	do        19.9
                        4,245.4



                         216.5

                         152.7
                          78.3
                          83.6

                         165.4

                         120.3
                         732.0
                           58.7
                           61.9
                         100.1
                           81.5

                           53.6

                          155.7
                           64.3
                          100.7
                           83.7
                           63.6


                          834.3

                          614.1
                           64.9
                          106.8


                           81.7

                          170.9
                                              (continued)
CH-92-02
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                 TABLE 2-2.  PAINT CATEGORIES BY USE (continued)
                                                                    1987 Product Shipments
                           Product
                 Quantity
     Value
(million dollars)
 PRODUCT FINISHES FOR ORIGINAL EQUIPMENT
     MANUFACTURERS (OEM), EXCLUDING MARINE
     COATINGS	mil gal      327.1               3,637.0

     Automobile finishes	  do        55.4                987.7
     Truck, bus, and recreational vehicle finishes	  do        14.9                280.3
     Other transportation equipment finishes,
        including aircraft and railroad	  do         3.2                 54.3
     Appliances, heating equipment, and air-conditioner
        finishes		do         5.8                 70.1
     Wood  furniture, cabinet, and fixture finishes	  do        43.1                276.6
     Wood  and composition board flat stock finishes  	  do         7.3                 53.2
     Sheet,  strip, and coil coatings, including
        siding  	  do        20.3                303.4
     Container and closure finishes	  do        60.2                413.1

     Machinery  and equipment finishes, including road
        building equipment and farm implement  	  do        16.2                181.3
     Nonwood furniture and fixture finishes, including
        business equipment finishes	  do        14.3                187.7
     Paper,  paperboard, film, and foil finishes,
        excluding pigment binders	-.	do        11.0                 66.7
     Electrical insulating coalings	do         3.6                 34.1
     Powder coatings	do        19.11               193.2
     Other industrial product finishes, excluding
        semimanufactured products, such as pigment dispersions
        and ink vehicles	  do        27.6                333.0
     Product finishes for original equipment manufacturers
        (OEM), excluding marine coatings, n.sJc	  do        24.9                202.4

 SPECIAL PURPOSE COATINGS, INCLUDING ALL
     MARINE COATINGS  	mil gal      1373               2,018.6

 Industrial new construction and maintenance paints
        (especially formulated coating for special conditions of
        industrial plants and/or facilities requiring protection against
        extreme temperatures, fungi, chemicals, fumes, etc.):
         Interior	do        13.0                169.8
         Exterior	do    .    28.5                323.6
                                            (continued)
CH-92-02
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               TABLE 2-2. PAINT CATEGORIES BY USE (continued)
                                                             1987 Product Shipments
                        Product
Quantity
    Value
(million dollars)
 SPECIAL PURPOSE COATINGS, INCLUDING ALL
    MARINE COATINGS, Continued
Traffic marking paints (all types, shelf goods, and highway
department) 	
Automotive, other transportation, and machinery refinish
paints and enamels, including primers 	
Marine paints, ship and offshore facilities and shelf goods
for both new construction and marine refinish and
maintenance, excluding spar varnish 	
Aerosol-paint concentrates produced for packaging in
aerosol containers 	
Special purpose coatings, n.sJc 	

do

do


do

do
. do

19.8

44.3


9.1

12.8
9.9

98.7

903.8


144.1

239.8
138.9
'In 1987, quantity was collected in pounds and converted to gallons using a conversion factor of 3 lb:l gal.
 Source: Adapted from Reference 1
 do - Ditto
 n.sJc. - Not specified by kind
CH-92-02
                                          2-7

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2.2.3 Paint Product End-Uses

      Paint is a suspension of finely separated pigment particles in a liquid, which when spread
over a surface in a thin layer will form a solid, cohesive, and adherent film.  Paints have been
used for many centuries for decorative purposes.  The Industrial Revolution expanded the end-
uses of paint and can be thought of as the beginning of the modem paint industry.^   Today,
paints are used to solve both aesthetic and protective problems on a variety of surfaces which
include wood, masonry, metal, plastics, and fiberglass. The end-uses of paint are defined by the
markets served (See Table 2-2).

2.3  INK MANUFACTURING INDUSTRY STRUCTURE

2.3.1 Introduction

      This section gives an overview of the  ink manufacturing industry, including geographic
distributions, production trends, industry issues, and the major subdivision's within the industry.
Also  included in this section is information  relating to manufacturing raw materials, finished
products,  and product end-uses.   Much  of the data  is  based on  the  Standard Industrial
Classification (SIC) 2893.

2.3.2 Market, Raw Materials, and Products

      The ink manufacturing industry includes those facilities  classified under SIC code 2893
which manufacture letterpress, lithographic and offset inks, gravure, and flexographic inks. This
category does not include the addition of solvents to inks by printers to reduce ink viscosity (i.e.,
press side reduction). The 1987 Census of Manufactures shows that the 504 ink manufacturing
facilities in  the United States are owned by 224 companies which employ  a total of  11,100
people  in nineteen States  and the District of  Columbia.   More than  60  percent  of  the
manufacturing facilities employ fewer than 20 people.6 Like paint manufacturing facilities, ink
                                                                X
CH-92-02                                    2-8

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plants concentrate in population centers.  Nearly 60 percent of all ink facilities and 75 percent
of all persons employed by ink facilities are located in ozone nonattainment areas.6
     Printing inks are a mixture of pigments, oils, resins, solvents, and driers.  Some commonly
used ink raw materials are listed in Table 2-3. The fluid component of the ink, made of binders
(oils and resins) and solvents, is called the vehicle.  The vehicle serves as the dispersing and
carrying agent for the pigment particles and gives the ink the required Theological properties of
flow and plasticity. Vehicles carry pigments through printing presses  and transfer and bind the
                              7 8
ink to the surface to be printed. '
     Pigments are the solid,  colored part of printing inks which are visible  to  the eye when
viewing printed material.  As in paints, pigments provide inks with color, opacity, durability, and
body or consistency.  Pigments, as well as binders, determine whether or not a print will bleed
in water, oil, alcohol, fats,  acid, or  alkali.   Thus,  pigments are  partially responsible  for
determining the end use of the ink.  Ink pigments, like paint pigments, may  be classified as either
                                               7 R
organic or inorganic and natural or manufactured. '
     Oils serve as one of the film-forming  agents in letterpress, lithographic, and offset inks.
Most oils used in the manufacture of printing inks are classified  by their origin as mineral oils,
vegetable oils, animal oils, and synthetic oils.  Vegetable oils are further categorized into  the
drying oils and  the non-drying oils.   Non-drying  oils are used in vehicles which dry by  the
absorption of the vehicle into the paper. These oils penetrate the substrate, soft absorbent papers
such as news and comic paper, rather than evaporate from the substrate's surface.  Drying oils
dry by  oxidation.**  Vegetable drying oils are most often used in printing inks.  The primary
vegetable drying oils are linseed oil, chinawood oil,  perilla oil, and soya bean  oil.   Steadily
replacing the natural oils  are  synthetic oils such as dehydrated castor oil, re-esterified fish oil
acids, and long-oil alkyds.
     Resins  are one of the primary components in printing ink vehicles.  Along with oils, they
serve as film-forming ingredients (binders) and impart to the ink gloss, drying speed,  improved
hardness, toughness, and scuff-resistance.  Resins are divided into two classes:  natural resins and
synthetic resins.  All natural resins, with the exception of shellac, are formed by solidifying the
viscous sap of trees.   Fresh sap contains both resins  and volatile oils.   Although  the oils  are
normally removed by distillation or evaporation, residual volatiles may remain in the treated resin
and eventually contribute  to the volatile  content of the ink product.  Several synthetic resins
CH-92-02
                                            2-9

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                 TABLE 2-3.  INK  RAW MATERIALS CONSUMED IN 1987
                                           Material
Quantity
    Materials, containers, and supplies	,,.	
    Organic and inorganic pigments	mil Ib
    Carbon black	do
    Plastics resins consumed in the form of granules, pellets, powders,
                    liquids, etc., but excluding sheets, rods, tubes, and shapes  	do
    Paints, varnishes, lacquers, shellacs, japans, enamels, and
                    allied products (includes all ink vehicles and varnishes)	1,000 Ib
    Wood rosin, turpentine, and other wood chemicals	mil Ib
    Hydrocarbon oils and solvents	  mil gal
    Oxygenated  solvents	do
    Metal containers  	
    All other materials and components, parts, containers, and supplies	
    Materials, containers, and supplies, n.s.k.'
     (NA)
     228.6
    *283.0

     *60.7

    *457.6
       85.1
    **92.7
    **24.9
     (NA)
     (NA)
     (NA)
    For some establishments, data have been estimated from central unit values which are based on quantity-cost
    relationships of the data reported by the establishment. The following symbols are used when the percentage
    of each quantity figure estimated in this manner equals or exceeds 10 percent of the figure published in this
    table: * 10 to 19 percent estimated; **20 to 29 percent estimated.  If 30 percent or more is estimated, figure
    is replaced by (S).
   2Total cost of materiak of establishments that did not repon detailed materials data, including establishments that were not mailed a form.
    Source: Adapted from Reference 6
    do -  Ditto
    n.s.k. - Not specified by kind
    (NA) - Not available
CH-92-02
                                                     2-10

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                                                                                      1
include phenol formaldehyde resins, alkyds, polyesters, vinyls, silicones, and polyurethanes.
      The ink industry refers  to solvents as  any organic liquid used to dissolve film-forming
materials and keep them in solution until the ink is applied to the surface to be printed.  When
the ink has  been applied, the  solvent should be removed quickly to allow the ink to dry.  Ink
formulators  use a number of different solvents including ketones, ethers, esters, alcohols, alcohol-
ethers, chlorinated compounds (methylene chloride, carbon tetrachloride, and trichloroethylene),
and some aromatic hydrocarbons such as toluene and xylene.
      Driers are used  in inks  which contain oxidizable oils or vehicles which  form films by
oxidation.  The driers, most often organic salts of metals such as lead, manganese, and cobalt,
act as catalysts and  are added to drying oils to increase their normal drying rate.   The metal
constituent imparts the drying  action, while the organic portion of the salt carries the metal into
solution, or  dispersion, with the oil.  Too much drier causes the ink to skin and dry on the press,
                                                                7 8
fill in halftones, and causes the sheets  to stick and offset in  the pile. '
      Inks,  like  paints, may contain small concentrations of additives.  Additives  perform a
special function  or  impart a  certain  property  to the  coating.   Additives  include biocides,
surfactants,  antifoams, and waxy or greasy components.  The waxy and greasy components are
used to improve the working and setting qualities of the ink, and to eliminate offsetting, sticking,
and picking problems.  Waxes may  be cooked  directly into the vehicle,  or  prepared as a
                              7 8
compound and added to the ink. '
      Inks may  also be classified  by  use and according to  the type  of vehicle used in the
formulation. The four primary types of inks are letterpress inks, lithographic and offset inks,
gravure inks, and flexographic inks.  Typically, flexographic  and  rotogravure inks employ a
solvent carrier, while letterpress, lithographic, and offset inks are of an oil or paste base. A
summary of the ink  classifications by  use category and subcategory is found  in Table 2-4. In
1987, the value of all ink shipments was $2.36 billion dollars ($164.1 million for letterpress inks,
$987.3 million for lithographic and offset inks, $414.5 million  for gravure inks, $424.8 million
for flexographic  inks  and $370.1  million for otherwise classified inks).    Ward's Business
Directory  lists  56 ink manufacturing  facilities  in SIC 2893 with  1990 sales greater than
$1,000,000.   This list is given in Appendix A, Table A-2.5
CH-92-02                                    2-11

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                           TABLE 2-4.  INK CATEGORIES BY USE
                                                                          1987 Product Shipments1
                              Product
                  Quantity2
     Value
(million dollars)
 TOTAL	        (NA)
     Letterpress inks	        (NA)
        New inks	mil Ib        203.1
        Publication inks	 do         (S)
        Packaging inks	do         12.1
        Other letterpress inks	 do         16.5
        Letterpress inks, n.s.k	        (NA)
     Lithographic and offset inks	        (NA)
        News inks	mil Ib        314.3
        Publication inks:
           Web types  	mil Ib       *179.9
           Sheet types	do       **20.0
        Packaging inks	do         18.2
        Web commercial type  	do         39.3
        Other lithographic and offset inks, including sheet
           commercial  type  	mil Ib        *50.8
        Lithographic and offset inks, n.s.k	        (NA)
     Gravure inks	        (NA)
        Packaging inks	mil Ib        111.3
        Publication inks  	 do        293.8
        Other gravure inks  	do         *0.9
        Gravure inks, n.si	        (NA)
     Fiexographic inks	        (NA)
        Packaging inks:
           Solvent types  	mil Ib        117.7
           Water typeg	do        125.0
        Other flexographic inks:
           Solvent types  	mil Ib          5.2
           Water types	 do         19.8
        Flexographic inks, n.s.k	        (NA)
     Printing inks, n.e.c.	        (NA)
        Textile printing inks  	mil Ib         36.0
        Screen  printing inks	do         (S)
        Other printing  inks, including stencil inks  	do         (S)
        Printing inks, n.e.c., n.s.k	        (NA)
     Printing ink, n.s.k	        (NA)
        Printing inks, n.sJc., typically for establishments with
           10 employees or more (see note)	        (NA)
        Printing inks, n.sJc., typically for establishments with less
           than  10 employees (see note)  	        (NA)
                                           2360.7
                                             164.1
                                             100.7
                                               9.8
                                              27.4
                                              20.9
                                               5.2
                                             987.3
                                             256.9

                                             311.0
                                              68.5
                                              77.7
                                              73.0

                                             162.8
                                              37.4
                                             414.5
                                             153.6
                                             248.2
                                               1.4
                                              11.2
                                             424.8

                                             189.3
                                             172.4

                                               8.9
                                              31.0
                                              23.1
                                             140.4
                                              45.3
                                              59.6
                                              34.0
                                               1.4
                                             229.7

                                             160.5

                                              69.2
'Data reported by all producers, not just those with shipments of $100,000 or more.

"For some establishments, data have been estimated from central unit values which are based on quantity-cost
 relationships of the data reported by the establishment. The following symbols are used when the percentage
 of each quantity figure estimated in this manner equals or exceeds 10 percent of the figure published in this
 table: *10 to 19 percent estimated; "20 to 29 percent estimated. If 30 percent or more is estimated, figure
 is replaced by (S).

 Source:  Adapted from Reference 6
 do - Ditto
 n.e.c. Not elsewhere classified
 n.s.k. - Not specified by kind
 (NA) - Not available
 (S) - Withheld because estimate did not meet publication standards
CH-92-02
2-12

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2.3.3 Ink Product End-Uses

      The end-uses of ink correspond to the use categories (i.e., the type of printing process for
which the ink is manufactured):  letterpress inks, lithographic and offset inks, gravure inks, and
flexographic inks.  Letterpress, relief, or typographic inks (except flexographic inks) are those
inks used in printing processes employing raised characters or plates. Letterpress printing is the
oldest printing  method,  and until the mid 1970s, it was the major consumer of printing inks.
Now, ink facilities manufacture more of both gravure and lithographic inks.  The primary uses
of letterpress inks  include  high-speed, long-run magazine and  newspaper  printing.  Other
letterpress inks  are used in the packaging industry, particularly on corrugated containers. Many
                                                                                     7 8
letterpress inks  are black:  almost all black inks use carbon black as the pigmenting agent.
The majority  of letterpress inks dry by absorption or penetration and are,- therefore, oil based.6'

      According to  the  1987 Census, lithographic ink  accounts for almost 40 percent of ink
shipments in the United States  and  slightly over 40  percent of product shipment value.6
Lithographic  printing processes include all processes of printing from  flat, or slightly etched,
surfaces, such as stone lithography, offset lithography, dry offset printing, and offset tin printing.7
Lithographic inks are used in the newspaper, publication, and packaging industries.  The vehicle
in lithographic inks normally consists of one or more lithographic varnishes (linseed oil that has
                                                                             7 8
been bodied by heat alone) or high-boiling solvents combined with oils and resins. >0
      Gravure inks, and  the gravure processes, are used in the  production of fine, engraved
stationery and announcements, postage stamps, paper money,  and illustrations in some books.
Gravure printing is also  used in newspaper, magazine, and booklet supplements, and on a wide
range of packaging materials such as plastic films and foil.  Ink is transferred from an etched flat
or cylindrical plate to the stock.  Gravure inks consist of pigments, binders, and solvents.   The
solvents incorporated in gravure  inks are very volatile,  allowing them to evaporate completely
from the ink film. The most important branches of gravure printing are the copper and steel plate
processes, the  steel die stamping  process,  and the  photogravure and rotary  photogravure
                     7 8
(rotogravure)  processes/'0
CH-92-02                                     2-13

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      Flexography, a branch of rotary letterpress printing, uses flexible, rubber relief plates with
fluid, volatile inks.  As of 1987, water has acted as the solvent in slightly more than 50 percent
of flexographic  inks.   The remaining  inks use volatile alcohols and glycol ethers.6'7  The
flexographic printing process was developed in Germany in the  1920s primarily for printing
grocery bags during their manufacture.  Since that time, flexography has spread  to other
packaging areas and has  been adapted to print on cellophane, foil, Mylar,  polystyrene,  and
polyethylene. Flexographic inks also print well on glassine, tissue, sulphite, kraft and other paper
stocks, paperboard, corrugated liners, bags, paper labels, box coverings, folding cartons, gift and
trademark wrappings, corrugated  boxes, paper cups and  containers.   Flexographic  printing
provides attractive,  economical packaging  materials and is  seen in all  grocery stores  on
prepackaged items from snack foods to clothing, cigarettes, toiletries, and industrial products.  '  '
      In addition to  the conventional inks (i.e., letterpress inks, lithographic and  offset inks,
gravure inks, and flexographic inks), there  are several other  types of specialty ink  products
including textile and  silk screen inks, invisible inks, powdered inks, and carbon paper, typewriter,
and duplicating inks.

2.4 MANUFACTURING PROCESS DESCRIPTION

2.4.1  Introduction

      Paint and  ink facilities use similar manufacturing processes to produce their respective
products.  Most  small plants (i.e., facilities employing less than 20 people) produce paint in 10
to 500 gallon batches, while larger facilities  produce paint in 200 to 3,000 gallon batches with
stock items made in 10,000 gallon runs.  '    Inks are produced in batches ranging from one
gallon to over 1000 gallons.
      The raw materials used in the manufacture of paints  and inks include  pigments,  solvents,
resins (or binders), and other additives. In most cases, the manufacturing facilities purchase these
raw materials and then formulate, or blend, a finished product.  Normally, no chemical reactions
take place during the process.  Batch process production  of paint and ink involves four major
steps:9-12'13'14
                preassembly and premix
CH-92-02                                    2-14

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               pigment grinding/milling
               product finishing/blending
               product filling/packaging
The manufacturing process is summarized in Figure 2-1.

2.4.2  Preassembly and Premix

     The first step in the manufacturing process is preassembly and premix.  In this step, the
liquid raw materials (e.g., resins, solvents, oils, alcohols, and/or  water)  are "assembled" and
mixed in containers to form a viscous material to which pigments are added.  The pigment and
liquid mixture forms a thicker material, which is then sent to the grinding operations.  At this
stage, the particles in the concentrate are rather large (250 urn) and not consistently mixed.  The
premix stage results in the formation of an intermediate product which is referred to as the base
or mill base.  With further processing, this base with high pigment concentration may become
                                           9 12
any one of a variety of specific end products. '

2.4.2.1  Resin production and cooking
     Resin production is  typically considered the first step in  the manufacturing process.
However, few paint facilities, and even fewer ink plants, currently manufacture their own resins.
This step is now being accomplished in closed reactors in chemical plants. Once the resin has
been manufactured, it must be cooked and then converted to a usable  vehicle.   Over the last
decade, this step, like resin production, has become increasingly performed by chemical plants.
Chemical facilities cook resins with oils, fatty  acids, or alcohols in indirectly  heated, closed
stainless steel vessels.    These reactors are normally vented through  a  fractional distillation
column and a condenser, so that vaporized compounds are recycled back into the reactor. After
the resin has been cooked and then cooled, it is thinned with solvent to produce the vehicle.15'16
The thinning stage is often the point  at which  paint and ink plants  begin their  manufacturing
process.
CH-92-02                                     2-15

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                                                     91-1
                                                                               Pigment
                                                                               Resin
                                                                               Solvent
                                                                               Additives
re
<

5'
                                                                              Pigment
                                                                              Resin
                                                                              Solvent
                                                                              Additives
 re
a
 a
 5'
 is
7T
3
Si
3
                                                                              Tinter
                                                                              Resin
                                                                              Solvent
 3
era
 c
 n
 re

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2.4.2.2  Equipment selection
      Premixing is necessary to keep the pigment in suspension in the resin, alcohol, solvent, and
oil mixture and to supply the dispersion equipment with a consistently mixed material. A wide
variety of equipment may be used in the premix process. Choosing which to use depends in part
on batch size.  Drum-sized batches made in the drum itself may be blended with a portable mixer
which clamps onto  the rim of the drum.  These  mixers normally have a three or four blade
impeller and may be either hydraulic or electric.    Other materials made  in portable mix tanks
may be blended using larger, permanent  high-speed dispersers or variable-speed mixers fitted
with paddle, propellor, turbine, or disc-type agitators.    In some cases, a paint or ink will be
moved to a dispersion  mill for grinding and milling, and then transferred back to the same premix
                            Q
mixer for blending operations.
      Other facilities use typical grinding equipment to accomplish premix operations. One paint
manufacturing plant uses dispersers and mixers to achieve high-sheared mixing when working
with insoluble powders (i.e., pigments and additives).  The same plant uses ball/pebble mills or
Kady mills when mixing soluble powders.  In this case, the facility may  eliminate the need to
transfer the material to another type of grinding equipment as the premix  and milling steps are
accomplished in one piece of equipment.

2.4.3 Pigment Grinding or Milling

      The incorporation  of the pigment into  the  paint or  ink  vehicle to yield a fine particle
dispersion is referred to as pigment grinding or milling.  This process occurs in three stages (i.e.,
wetting, grinding, and dispersion)  which  may overlap  in any grinding operation.  To wet the
pigment particles, the  wetting agent, normally a surfactant, must displace all contaminants (e.g.,
air, moisture, and gases) adsorbed on the surface of the pigment particles. The wetting process
                                                                                   1 f\ 1 8
actually begins in the premix step, when the pigment is  charged to the liquid vehicle.  '
Grinding is the mechanical breakup and separation of the pigment particle clusters into isolated
primary particles. Dispersion is the movement of the wetted particles into the body of the liquid
                                                18
vehicle to produce a permanent particle separation.10
CH-92-02                                     2-17

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     The goal of pigment grinding is to achieve fine, uniformly-ground, smooth, round pigment
particles which are permanently separated from other pigment particles. The degree to which this
is realized determines the coating effectiveness and permanency of the paint or ink. Grinding
equipment must work effectively with the vehicle to accomplish this  end.  Just as there is a
variety of pigment vehicles, so there is an array of dispersion (milling) equipment. Some of the
more common equipment is described in the following nine sections.

2.4.3.1  Roller mills
     Roller mills  may have from one  to five rolls which grind pigments into vehicles.  Most
paint and ink facilities that use roller mills operate  with conventional three-roll  mills.  A
schematic diagram of a three-roll mill is shown in Figure 2-2.  The premixed pigmented paste
is charged to the  space between the feed  and center rolls called the  feed  bank.   End plates
prevent the material in the feed bank from  spilling out the sides. The mill base is carried into
the  feed nip region by  the inward rotation of the feed and center rolls which  are  turning at
different speeds.  Some of the material  remains in the feed bank while another portion transfers
through the feed nip to the underside of the rolls.  Here the material splits. Part transfers to the
center roll while the remaining portion  stays  on the  feed roll to return to the feed bank.  The
material that was transferred to the center roll  passes through the apron nip, after which a second
split takes place.  One amount remains with the center roll, returning to the feed nip, while the
other transfers to the apron roll where  it is removed from the roller mill by the takeoff apron.
As  the material moves through both the feed  and apron nips, it is subjected to very high shear.
This shearing action serves to disperse  the pigment throughout the vehicle, while the nip space
                                      91618
determines the degree of this dispersion. 'D>
     Roller mills are labor intensive, requiring highly skilled operators. Their lack of speed and
high operating cost make  them unsuitable for large-volume production.  The use of roller mills
is confined  to the manufacture of very high-quality paints and inks  and viscous pigmented
products which require fine dispersion  and clean color.

2.4.3.2  Ball and pebble mills
     Ball and pebble mills, probably the oldest pigment  dispersion equipment,  are cylindrical
containers mounted horizontally and partially filled with either pebbles or ceramic, glass, or
CH-92-02
                                          2-18

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                        Back
to
                                                  Feed
                                                  bank
                                                                                                      Front
                                                                                                           Knife edge
                                           Figure 2-2.  Schematic diagram of a three-roll mill.

-------
metallic  balls which serve as the grinding media.  Paint  and ink components,  either in  raw
material  or in premix form, are charged to the mill through a top chute.  The ball mill and its
contents  then rotate about the horizontal axis at a rate sufficient to lift the grinding media to one
side and  then cause them to cascade to the lower side.  The tumbling action results in pigment
dispersion.2'16'18
      Ball and pebble mills are distinguished only by their interior lining and grinding media.
The paint and ink  industries conventionally define pebble mills  as  those mills containing a
nonmetallic grinding media such as ceramic, porcelain, silica balls and flint pebbles, and having
an inside surface lined with a nonmetallic liner such as burrstone, porcelain block, or rubber.
Ball mills,  on the other hand, contain steel, alumina, iron,  or nickel balls and have an interior
surface of alloy  steel or  another metallic liner. Because of these minor differences, the terms
"ball mill" and "pebble mill" are used rather loosely and the  former is often used to describe both
types of  mills.2'16'18
      The size and type of the  grinding  media  will  determine the type  of  paint or ink
manufactured. Small, dense grinding media tend to be more efficient at dispersing pigment than
larger, more porous media.  Steel-lined mills charged with steel balls can be used only for dark
colors, as erosion results  in the discoloration of whites and pale shades. Normally, lighter colors
                                            9 1 f\ 1R
are made in pebble mills using ceramic media. ''
      Ball mills offer paint and ink manufacturers the following advantages:
           Normally no product premixing is required.  The'vehicle is often charged directly to
           the mill  followed by the pigment charge.   This offers an economic advantage as
           many grinding processes require premixing.
           The milling process  does not require skilled  attention  or supervision,  yielding
           minimal  labor  costs.   Ball  mills  can operate  on  a timer, thus  completing the
           dispersion  process  outside  of  normal  working   hours (i.e.,  at  night or  on
           weekends).9-13'18
                                  18
           Low maintenance costs.
           Ball mills are adaptable to the grinding of most paint dispersions and of all pigments.
                                                               nill
                                                                18
                                                                 18
Only highly viscous products are not amenable to ball mill grinding.
           Ball mills offer product standardization and consistency.
CH-92-02                                    2-20

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           Ball mills  have the capability of providing substantial physical  size reduction of
           oversized particles, thereby upgrading pigment opacity and/or color development.
 Several disadvantages of ball mills include relatively long processing times ranging from 8 to
more than 36 hours and lengthy cleaning times requiring considerable amounts of solvents.

2.4.3.3  Attriiors
      An attritor is a stationary, vertical,  cylindrical grinding  tank fitted with a centralized,
rotating agitator shaft to which are  attached evenly-spaced spokes.  The spokes extend into the
ball  media and  mill base mixture  which fills the attritor during the milling process.  As the
spokes rotate  through the attritor tank contents, they agitate the  ball charge.  The agitation
                                                                                     1 f\ 1R
provides the required shear and impact to effectively disperse the pigment into the vehicle.  ' 
      Attritors are available in sizes up to approximately 100 gallons total capacity.   They may
operate on  a batch or on a continuous process basis and usually contain small ceramic or steel
balls (i.e., 1/4 inch diameter). Raw materials may be added by  hand or by a manifold system.
An attritor achieves pigment dispersion approximately  three times faster than a ball mill, but
requires constant supervision.  Attritors can also handle higher viscosity materials  than  a ball
mill.16'1'8

2.4.3.4  Sand mills
      Sand mills, vertical  cylinders  filled with grinding media, operate on the principle that the
dispersion efficiency increases with the decreasing diameter of grinding media.  These mills attain
dispersion by rapidly stirring small  spheres in the presence of the pigment slurry. Paint and ink
manufacturers have used sand mills for the dispersion of pigmented mill bases since the early
1950s.  Originally, manufacturers used fine-grained Ottawa sand as the grinding media.  Now,
however, many facilities use small beads or balls ranging from 1/32 to 1/8 of an inch. Because
the size of sand mill media approaches that of bead,  shot and ball  mill media, the terms  "sand
mill," "ball mill," "shot mill," and "bead mill" are often used interchangeably.  Sand, bead, and
                                          *? 1 ft 1 
shot mills are frequently called media mills.   '
      In vertical sand mills, the premixed slurry is pumped in at the bottom of the cylinder and
rises through the sand, which is kept fluid by  the quickly rotating shaft impeller.  Dispersion
                                                                  *v
CH-92-02                     '                2-21

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takes place as a result of pigment shearing as it rises through the chamber.  Most pigments are
sufficiently dispersed when they reach the top of the  chamber. The dispersed product is then
allowed to filter from the mill through a mesh which retains the sand.  Older sand mills operate
with an exposed filtering screen which often becomes encrusted with dry mill base. Many newer
mills, however,  have a  submerged screen that eliminates plugging problems.  With an ample
supply of premixed material, the sand milling process can be continuous.2.16,18  Figure 2-3 is
a schematic of a vertical sand mill.

2.4.3.5 Bead and shot mills
      Bead mills look and operate like sand mills.  The only difference between  the two is the
type of grinding media  employed.  While conventional sand mills  ordinarily use Ottawa sand,
bead mills use a wide variety of synthetic media including glass, ceramic, and zirconium oxide
or zirconium silicate beads.   '    The  term  "beadmilling"  developed in the  1960s  when
manufacturers started using synthetic grinding media rather than sand.  Many former "sand" mills
are now "bead" mills.16  .
      The latest  bead mills  are closed agitated ball mills with a stationary horizontal cylindrical
grinding container enclosing a driven shaft which agitates 1 to 3 mm diameter grinding beads.
The small size of the grinding media necessitates that panicle size in the mill base feedstock be
ground and dispersed to below  250 pm.  A properly set up bead mill can disperse to below 20
urn in a single pass through the mill.    Bead milling systems are available in sizes ranging from
1.5 to 1,900 gallons.    Most bead mill manufacturers, with few exceptions, use glass, zirconium
oxide or zirconium silicate, ceramic, alumina, and in certain cases, steel ball grinding media.
They may be used either for batch or continuous processing. *'
      Shot mills are also similar to sand mills.  These rugged units have a narrow, upright,
cylindrical tank  equipped with  a rotating vertical shaft that sustains a series of evenly spaced,
stainless alloy, circular  platforms.  The platforms rotate through the media/mill  base mixture.
High-speed shot mills work best with small steel or ceramic grinding media. The mill operates
under internal pressure and therefore is able to grind materials with high viscosities. The mill
                                                                            18
also  has a variable-speed pump and submerged filter which rotates  with the shaft.
CH-92-02                                    2-22

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                                                             Rotating shaft
    Screen for  holding
   back  sand particles
    while  allowing free
      flowthrough of
   dispersed mill base
  Typical flow  pattern
     for mill base
   sandwich between
   two impeller disks
(rolling double-doughnut
    grinding action)
        Water jacket
Valve  controlling  rate
of flow  of  mill  base
Exit port for discharge
     of  dispersed
  mill  base to  apron
                                                                                Impeller  disks
                                                                              50/50  volume mix of
                                                                               mill base and  sand
                                                           Bottom entry  for introducing homogeneous
                                                                 premix  of  mill base paste or
                                                                    slurry to sand  grinder
                Figure 2-3.  Schematic drawing of conventional sand mill.
                                               2-23

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2.4.3.6  High-speed stone and colloid mills
      High-speed stone and colloid mills, although not as common as many of the other pigment
grinding mechanisms, are another method  of achieving  pigment dispersion.  Modem stone
(Carborundum) mills consist of two precisely shaped Carborundum stones working against each
other, as illustrated in Figure 2-4a.  One stone, the stator, is held stationary while the other stone,
the rotor, is rotated at high speed from 3,600 to 5,400 rpm. The premixed mill base is fed by
gravity or under pressure into the charge area above the rotor.  A viscous laminar flow, yielding
pigment dispersion, results as  the material moves through the grinding  gap or the small space
separating  the two  stone  surfaces.  Because the material spends only  a fraction of a  second
between the stones, the dispersing action of the stone mill serves to refine rather than as a pure
mixing and grinding operation. Stone mills produce the best quality product when they  are fed
                            18
a well-mixed, viscous premix.
      Colloid mills differ from stone mills  in their  material of construction and their  gap
configuration.  Figure 2-4b illustrates the truncated cone arrangement  distinguishing the  two
mills. The rotor and stator are designed with smooth, ground, and lapped faces which ensure a
uniform cross section in  the material in  the grinding gap.  Mill base consistency results in
maximum shear and efficient milling. The rotor and stator -in colloid mills may be constructed
of Carborundum stones, high-nickel alloys, or Invar, an alloy with a low coefficient of expansion.
                                                                                    1 o on
Like stone mills, colloid mills must be provided with a well-mixed, viscous material feed.  '
      Both the stone mills and the colloid mills traditionally operate as open systems.  However,
both may be convened to closed systems using an accessory pump to provide the material  feed.18

2.4.3.7  High-speed disk dispersers
     High-speed disk dispersers are the most universally used method of dispersion in the paint
and ink manufacturing industry.  Their popularity continues  to increase as compact, efficient,
heavy-duty power sources and readily dispersible pigments become more available. Some paint
and ink blends are manufactured entirely in one piece of equipment using high-speed disk-type
impellers.  Essentially, the high-speed disk disperser consists of a circular, steel, saw-blade-type
impeller attached to the end of a steel shaft.   The disk is suspended in a mixing pot which may
be jacketed for water-cooling.  Because there  is no grinding media present in the mixing vat, the
CH-92-02
                                          2-24

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                                Y//////////////////////A
                          Peripheral velocity
                            13.000 ft/min
Figure 2-4.    (a) Schematic drawing of the stator/rotor assembly in a high-speed stone mill
                    (grinding region has the shape of a flat annular ring).
              (b) Schematic drawing of the  stator/rotor assemblynn a colloid mill
                    (grinding region has the shape of a truncated  cone).

                                         2-25

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pigment  disperses on itself and against  the  surfaces  of the  rotor.   While  high-speed disk
dispersion may work well with some products such as undercoats and primers, it may not be
appropriate for high-quality paints and inks. It can, however, be used for premix operations of
high-quality paints, thus reducing the number of passes in a media mill or reducing the amount
of time spent in a ball mill.2'16'18'21
     High-speed  dispersers provide  a simple, quick, and relatively inexpensive  means of
distributing  easy-to-disperse pigments in  conventional vehicles on a  batch processing basis.
These dispersers are also  capable of handling  all phases in the preparation of some paints and
inks (i.e., preassembly and premix, pigment grinding and dispersion, and product finishing) in
one piece of equipment.   In addition to its dispersion abilities, the high-speed disperser can be
used in premix and blending (postmix) operations.  Another advantage is the comparatively low
initial capital investment and low maintenance costs. The primary disadvantage of the high-speed
                                                   18
disperser is its inability to disperse hard agglomerates.
     A modification of the high-speed disperser is a variable speed disperser. Variable speed
systems allow the incorporation of dry powders into a liquid medium at low speed with minimum
dusting.  The speed is increased once initial wetting  is complete.
     A second variation of the high-speed disperser is a rotor stator type machine similar to the
set-up found in stone and colloid mills. Instead of disk type impellers, this disperser operates
with a rotor stator unit. The stator is mounted on  several shafts extending  from the equipment
housing, while the rotor is attached to a center  disperser shaft which would typically hold a disk
type impeller.  The rotor  stator unit may  be either high-speed or variable-speed.  In addition,
                                                                              22 2^
newer models are  quiet and more efficient than conventional high-speed dispersers.  '
     Another variation of the high-speed disperser/portable mix tank operation is the Kady mill.
This mill consists of a high-speed disperser or agitator in combination with a fixed mix tank.
The tank is jacketed, allowing for heating capability.  It is also equipped with a permanent lid
which  can be  opened during product filling  operations and  sealed  during  the mixing and
dispersion process. As with disperser/portable tank operations, Kady mills  contain no grinding
media in the mix tank allowing the pigment to disperse on itself and against the surfaces of the
rotor.  Kady mills are often used in the production of high-gloss paints and inks which  require
heat to develop the gloss  characteristics.   '
CH-92-02
                                          2-26

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2.4.3.8  High-speed impingement mills
      High-speed impingement mills or kinetic dispersion mills disperse pigment agglomerates
by impact. This mill consists of a slotted rotor and stator as shown in Figure 2-5.  Material is
sucked in at both the top and the bottom of the mill and is thrown outward by the rotating slots
on the rotor against the close-fitting stator.  The high velocity and forceful impact of the particles
results in dispersion.18
      Impingement mills  are  most  efficient  when they  are fed  with a low-viscosity, easily
dispersible pigment/vehicle mixture.  As impingement mills are a batch process operation, no
material premixing is required. The fluid vehicle (low solids content) is placed in the mill tank
prior to starting the milling process.  Once the rotor has started, pigment is rapidly fed into the
                                                      to
tank. Batch grinding time averages less than 25 minutes.

2.4.3.9  Horizontal media mills
      The horizontal media mill is basically a vertical mill  turned 90 degrees. This configuration
improves the performance of the mill by creating better material flow  and by increasing the
media loading capacity from 85 to 90 percent of the chamber  volume. The increase in media
loading from 50 percent in vertical mills  to 90 percent in horizontal  mills provides increased
milling efficiency.24  When provided with the proper premix feed, a standard horizontal media
mill offers the most efficient one-pass operation.   Properly equipped  horizontal mills provide
                                                                                     2<
three times the productivity on an equal volume basis as the open-top  sand and bead mills.
      Horizontal media mills are closed systems.   The filtering screen is enclosed by a sheet
metal cover which controls  solvent  losses  and expands the  range of products  that can be
processed.  Although the mill base moving through the chamber should be  of low viscosity  to
allow the grinding media to move with maximum velocity, manufacturers using horizontal mills
are  no longer concerned  about solvent evaporation  and the mill base drying on the  screen
                             OA O/C
(causing  the mill to overflow).   '
      Horizontal mills range in size from 1.5 liters (0.4 gallons) to 500 liters (132 gallons). Most
mills are equipped with a  secondary jacket which allows for water cooling.  The mills are able
to use any of the common media currently manufactured  including glass beads, ceramic beads,
zirconium silicate beads, and steel shot.
CH-92-02                                     2-27

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Figure 2-5. Schematic drawing of the milling head of a high-speed
             impingement (kinetic dispersion) mill.
                            2-28

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2.4.4  Product Finishing

     Final product specifications are achieved in the product finishing step which consists of
three intermediate stages:  thinning, tinting and blending.

2.4.4.1  Thinning (letdown)
     Material letdown, or thinning, is the process by which a completed mill base dispersion is
let down or reduced with solvent and/or binder to give a coating which is designed to provide
a durable, serviceable film that is easily applied to the substrate.18  The volume of the paint or
ink may increase significantly at this point depending on the final product specifications.

2.4.4.2  Tinting
     Tinting is the process of adjusting the color of completed mill base dispersions.  Normally,
an operator will collect a sample of the paint or ink once it exits the milling equipment.  This
sample  will be taken to  the  laboratory  and compared to the desired color standard.  Various
combinations of pigments, solvents, resins, and pastes are added to the material to meet the color
            Q 12 i^
requirements.  '  '

2.4.4.3  Blending
     Blending operations occur once the necessary  additions  have  been made to the completed
mill base dispersion.  Blending is the process of incorporating the additions into the material in
order to meet the desired product specifications.  In the case of batch operations, blending may
simply consist of additional milling in a ball mill or added mixing and dispersing in a portable
mix tank/high-speed disperser set-up. In other cases, the mill base dispersion is transferred to
fixed agitated blend tanks or additional mix tank/disperser operations.  In each case, material
adjustments for thinning and tinting are added through top openings, agitated, and gravity fed or
pumped out bottom or side spigots  for filling operations.9' '13'14
CH-92-02
                                          2-29

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2.4.5 Product Filling

     The final step in paint and ink manufacturing is product filling operations.  After the
material  has  been blended,  it is transferred from the blend tanks into containers for product
shipment. The transfer step normally involves product filtration.

2.4.5.1 Filtering
     Filtering acts to screen out impurities (e.g., dust, gelled resin, and pigment aggregates) and
to enhance the quality and uniformity of the product.  In the case of media mills, filters prevent
the  grinding media from exiting the mill and entering shipment containers.  
     Paints and inks  may be filtered in a variety of ways.  Some facilities simply attach cheese
cloth or cloth socks to the exiting blend tank spigot.    '   Other plants use filtering equipment
such as strainers or sieves. The Russel Finex strainer consists of a vibrated screen and hopper
through which product flows prior to entering shipment containers.  The screens may be either
                                                               i,
metal mesh, supported nylon, or another synthetic fiber.  Another strainer, the Jenag strainer, has
a vertical chamber holding fiber filters.  The paint is fed by gravity or pump to the chamber and
drawn  through by vacuum.2  High  quality finishes,  such as those used for automobiles and
industrial products, may be  pumped through wound polypropylene or other  resin  cartridge
filters.        Bag filters,  made  from  felts  (rayon, polypropylene*  or  nylon)  or gauzes
(polypropylene, nylon, or polyester), can be attached to the flanged end of a supply line and
supported by a vibrating wire basket. These bags are usually washable and used only for small
batches.2'13

2.4.5.2 Material transfer
     Once the material has been filtered, it can be transferred into pails, drums, tote tanks, tote
wagons,  or another container for shipment.   Although  most paints are sold by volume,  most
manufacturing facilities find it more convenient to fill the shipping containers by weight using
the  specific gravity of the paint or ink.  Filling  may be accomplished  either manually or
                                                                        2 12
mechanically depending on the number and size of  the containers to  be filled.  '


CH-92-02                                     2-30

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2.5 REFERENCES

1.    1987  Census of Manufactures.   Industry  Series.   Paints and  Allied Products.   U.S.
     Department of Commerce. Washington, D.C.

2.    Morgans, W.M., Outlines of Paint Technology, Third edition, Halsted Press, John Wiley
     & Sons, New York, NY. 1990.

3.    "Paint Manufacture and Painting," IARC Monographs, 47: 329-442, 1989.

4.    Lorton, Gregory A., "Waste Minimization in the Paint and Allied  Products Industry,"
     JAPCA, 38(4): 422-427, 1988.

5.    Gale  Research, Inc.  Ward's Business Directory of U.S. Private  and Public Companies-
     1991, Volume 4. Detroit, MI.  1991.

6.    1987  Census of Manufactures.  Industry Series. Miscellaneous Chemical Products.  U.S.
     Department of Commerce.  Washington, D.C.

7.    Wolfe, Herbert Jay, Printing and Litho Inks, Sixth edition, MacNair-Dorland Company,
     New  York, NY. 1967.
                                                                                    .
8.    Printing Ink Handbook,  compiled by Technical and Education Committees, National
     Association  of Printing Ink Manufacturers, Inc. and  the National Printing Ink Research
     Institute, National Association of Printing Ink Manufacturers, New York, NY.  1967.

9.    ICI trip report.

10.  U.S.  Environmental Protection  Agency. Guides  to  Pollution  Prevention:   The Paint
     Manufacturing Industry,  EPA-625/7-90-005.   Risk  Reduction Engineering Laboratory.
     Cincinnati, OH. 1990.                                                      .

11.  Berlow, James R., Howard D. Feiler, and Paul J. Storch, "Paint and Ink Industry Toxic
     Pollutant  Control,"  reprinted for  the  Pollution Prevention  Pays  Program, Pollution
     Prevention Pays Library,  C&AP 88. Raleigh, NC.

12.  PPG  trip report.

13.  Perry & Derrick trip report.

14.  Borden trip report.

15.  U.S. Environmental Protection Agency. Control Techniques for Volatile Organic Emissions
     from  Stationary  Sources.  EPA-450/2-78-022.   Office of Air  Quality  Planning and
     Standards.  Research Triangle Park, NC.  1978.
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                                         2-31

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16.  Lamboume,  R., ed., Paint and Surface Coatings, John Wiley & Sons, New York, NY.
     1987.

17.  MixMor product brochure.  "Mixers and Agitators for Industry," Mixmor, King of Prussia
     PA.  1989.

18.  Patton, Temple  C, Paint Flow and Pigment Dispersion, Second edition, John  Wiley &
     Sons, New York, NY. 1979.

19.  Denison, B., "Bead milling - a practical guide," Journal of the Oil and Colour Chemists'
     Association,  73(6): 256-260, 1990.

20.  Premier Colloid Mills product brochure. "The Ultimate in Dispersing and Emulsifying,"
     Premier Mill, Corp., Reading, PA.  1988.

21.  Tippett, Jerome P., "Selecting Dispersion Equipment," reprinted from Modern Paint and
     Coatings, by Schold Machine Company, St. Petersburg, FL. May 1980.

22.  Wagman, Scott and Alan E. Hodel, "Rotor stator yields uniform dispersion in 1/4 the time,"
     reprinted by Schold Machine Company, St. Petersburg, FL, from Chemical Processing,
     50(8): 44-46, 1987.

23.  Whitlock, Robert  and  Alan E.  Hodel,  "Disperser Cuts  Processing Time  80%  Produces
     Smoother Flowing Product," reprinted by Schold Machine Company, St. Petersburg, FL,
     from Chemical Processing, July 1989.

24.  Zoga, Christ, "Horizontal Media Milling With Computer Controls," reprinted from Modern
     Paint and Coatings, by Premier Mill Corporation, New York, NY. .June 1984.

25.  Zoga, Christ, "Dispersion and Milling Methods to Increase Plant Productivity,"  reprinted
     from Modern Paint and Coatings, by Premier Mill Corporation, New York, NY. May 1989.

26.  Sneeringer, John R., "Consider  the Horizontal Mill," reprinted from CPIIOO, by Premier
     Mill Corporation,  New York, NY May/June 1986.
CH-92-02                                   2-32

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                                   CHAPTER 3
                 VOLATILE ORGANIC COMPOUND EMISSIONS,
                         REGULATIONS, AND PERMITS
3.1 GENERAL
     This chapter  describes the potential  sources  of VOC  emissions  in  ink  and paint
manufacturing facilities.  Potential emission sources arc identified and characterized based on
available literature and plant visit results. This chapter also discusses current industry emissions
as defined  and described by  published documents, State  permit  information, State VOC
regulations, and individual industry sites.
     In 1987,  the paint and ink industries consumed an estimated 2,750  million  pounds  of
solvent.1'2 Although this number is expected to decrease as paint and ink manufacturers continue
to move toward products with lower VOC contents, it still accounts for 0.05 percent of total VOC
emissions.  Other statistics indicate  that  the  application of paints is the fourth-largest VOC
source.3 The United Kingdom attributes solvent emissions of 94,000 tons per year to the paint
and paint application industries.
     The primary factors affecting the emission of organic compounds are the types of solvent
used in the manufacturing process, the temperature at which these compounds are mixed, and the
methods and materials used during cleanup operations.  According to EPA publication AP-42,
even under well controlled conditions, approximately 1 to 2 percent of the solvent brought into
the facility is lost during manufacturing operations.

3.2  SOURCE  IDENTIFICATION AND CHARACTERIZATION

3.2.1  Introduction

     Volatile organic compounds are released from several types  of equipment and handling
operations throughout the paint and ink manufacturing process and during cleanup operations.
Emissions can be categorized according to the four manufacturing processes (i.e., preassembly
                                                             "v
CH-92-02                                   3-1

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and premix, pigment grinding or milling, product finishing, and product filling) and cleaning
operations.

3,2,2  Preassembly and Premix

     The vast majority of paint and ink facilities begin the manufacturing process by thinning
resins with solvents, alcohols, oils, and/or water.  The equipment items most often used in this
premix and preassembly operation are drums and portable tanks in combination with mixers.
Emissions from other premix equipment, such as grinding and milling devices, will be discussed
in Section 3.2.3.
     Portable mix tanks, either alone  or  in  combination with an  agitator, are a  common
emissions source.   Portable mix tanks are  used to mix product and to keep the pigment in
suspension. They  are also used to transfer material from one manufacturing stage to the next.
While they are being used for mixing, the tanks are often, but not always, covered with lids.  If
a cover is used on a mix tank during mixing,  it will have a small  opening  through which the
agitator shaft extends.  In some cases, only a splash guard is used to cover the back half of the
mix tank.  If mix tanks are used for temporary storage, they are often covered with a solid lid.
None of the lids seal with the mix  tanks.
     In some cases, products are premixed in 55 gallon drums.  Like the portable mix tanks, the
drums are often covered with non-sealing lids. If a cover  is used on a drum during mixing, it
will have a small opening for the agitator shaft6'9
     Emissions occur during material loading when the tank or drum is  uncovered or when the
lid is open. VOCs may also be released through the agitator shaft opening and from around the
edges of the lid during the mixing  process.   The quantity of material released varies with type
of solvent, agitator mixing speed, material temperature, and type of cover.  More organics will
be released with highly volatile solvents, increased agitator speed, and warmer temperatures.

3.2.3  Pigment Grinding or Milling

     The equipment used in grinding operations  includes  roller mills, ball and pebble mills,
attritors, sand mills,  bead and  shot mills, stone  and  colloid  mills,  high-speed dispersers,
CH-92-02
                                          3-2

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impingement mills, and horizontal media mills.  Emissions  of VOCs from dispersers were
discussed in the previous section.
     Roller mills are used to manufacture high-quality paints and inks with a high solids content.
The mill base vehicles used on roller mills normally contain  from zero to 40 percent volatile
content.  Because the rolling cylinders on roller mills are exposed to the atmosphere, the majority
of the volatile content in the mill base vehicle is expected to evaporate during the course of the
                Q in
grinding process. '
     Grinding with  ball and pebble mills approaches a closed system operation.   The only
opening in  these mills is the chute through which raw materials or premixes are added and the
spigot  which  is used  for product filling operations.  VOC emissions  occur during  these
         f. 0 Q
processes.  ' '
     Attritors also approximate closed systems.   Emissions may  occur from  the opening
surrounding the agitator shaft and/or at product outfall.7
     Older vertical media mills (i.e., sand mills, bead mills,  and shot mills) operate with an
exposed filtering screen.  As the mill base rises through  the chamber and  becomes exposed to
the air, the solvent constituent evaporates, often leaving the screen encrusted with dry mill
base.10'11  Media  mill operators may apply solvent to unclog the screen or they may  scrape
down the filter with a coarse, dry brush.6"8 Fewer emissions occur from newer vertical media
mills which have submerged filtering screens.10  Additional  emissions of VOCs result from
adding raw materials and from product filling operations.
     Both  the stone and the colloid mills traditionally  operate as open  systems.  Emissions
normally occur as the mill base feedstock is added to the charge chute on top of the rotor/stator
arrangement. Similarly, emissions may occur after grinding as the material exits through the mill
spillway. Enclosing the spillway and using a closed charge chute with an  accessory pump will
reduce overall emissions.  '
     One variation of the high-speed disperser is the  Kady mill.  As with the emissions from
other dispersers,  emissions from Kady mills occur during material additions and product filling.
However, unlike other  dispersers, the Kady mill may be  heated, resulting  in additional solvent
volatilization.
      The  majority of the emissions from  impingement mills also occur during the addition of
raw materials and while emptying the mill of product. Impingement  mills are potentially high-
CH-92-02
                                          3-3

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emission processing equipment because they require low-viscosity (low solids) vehicles. Ideally,
the first vehicle addition would contain only ten percent by weight solids. Subsequent additions
might contain a higher solids content.
     Horizontal media mills are efficient, closed-system milling devices. The filtering screen
is  enclosed by  a sheet metal cover  which controls solvent losses and  expands the range  of
products that can be processed.  Although the mill base used in a  horizontal mill should be of
low viscosity, paint and ink manufacturers do not have to worry about VOC emissions during
the grinding process.  The mill  base for most horizontal mills  is pumped from containers  or
premix  equipment through  an enclosed  piping system.  Material discharge is also through
                      f\ T?
enclosed pipes or hoses. '

3.2.4  Product Finishing

     The emissions that occur during the product finishing  step are mainly a result of material
additions during the tinting and thinning stages.  If a product is finished in a mix tank/disperser
set-up, emissions are similar to those mentioned in Section 3.2.2. When material is finished in
a fixed blend tank, releases occur during product additions through the top hatch, which normally
                               7 8
does not seal with the blend tank. '

3.2.5  Product Filling6'9

     Emissions occur during almost all product filling operations. The extent of these emissions
is  determined by the volatility of the solvent in the paint or ink formulation, the temperature at
which the product enters the shipment container, the method  of material transfer, and the method
of filling. Emissions increase with temperature and highly volatile solvents.
     One source of emissions  is scale  systems, where  solvent and resin raw materials are
measured and transferred from storage tanks to the process tanks, between process tanks, or from
process tanks to  shipment containers. Emissions may occur  during transfer and hose connecting
and disconnecting.  Another type of scale system consists of a floor  scale, a drum, a drum
dispenser, and a receiving  container.  Material is pumped  out of the drum  into the receiving
container.  Emissions occur during material transfer and  free-fall  into the receiving container.
                                                                 *v
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In some cases, material is transferred by bucket and dip method.  Here, emissions occur while
the product is exposed to the air and while it is being scooped and transferred to the second
container.
     Another emission source is product filtering.  As product flows through a filtering device,
it is often exposed to the air, resulting in releases of VOCs.
     Filling operations  also result in VOC emissions.  In one plant, portable mix tanks are
mechanically lifted and tilted, allowing the finished product to gravity feed into containers for
shipment.  Some facilities allow product  to gravity feed from processing equipment through
filters into shipment containers.  Emissions result from product free-fall and material splashing.

3.2.6  Equipment Cleaning

     In addition to emissions from process operations, VOCs are also released from a variety
of cleaning operations.  Solvent based materials are used to clean equipment in which solvent
based products are manufactured, while water based supplies are used to clean after water based
production. Emissions occur during solvent addition and removal as well as during the cleaning
process.
     In many facilities, manufacturing equipment is cleaned manually on the production floor
on an as-needed basis. In some cases, cleaning is performed after each batch, and in other cases
equipment is cleaned after a series of batches.  The cleaning frequency depends on the number
and size of batches processed, the size of  the equipment to be cleaned, and the color and type
of product manufactured.   The  standard method of  cleaning grinding equipment involves
emptying the mill of product and then adding solvent to the vessel  to capture remaining product
residue. The wash solvent is normally drained from the tank and either disposed of as hazardous
waste or recycled.6"9   Mix tanks and agitator blades may be cleaned with solvents, brushes,
and/or rags.6  Roller mills are often cleaned by hand using rags and solvent.
     Larger facilities  may have areas designed specifically for cleaning operations.   In these
facilities, equipment cleaning may be more automated  (i.e., automatic tank washers and spray
guns), but emissions still occur during the  process.7
CH-92-02                                     3-5

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     Equipment cleaning operations account for over 80 percent of the paint industry's waste.
Although solvents are not the only waste generated during cleaning processes, they are a major
contributor.

3.3 EMISSION  FACTOR DATA

3.3.1  Introduction

     There is little emission factor information available for the manufacture of paints and inks.
Figures range from process solvent losses of one to two percent under well controlled conditions
to losses of 100 percent for specific volatile organic compounds.5'15 The 100 percent loss figure
is obviously a "worst case" estimate, as enough volatile  components remain in the paint or ink
to allow  it to remain fluid and workable. Some studies indicate that a coating film which is dry
to the touch may  retain five to ten weight percent solvent for several years because of the slow
diffusion rates encountered at  the  air-film interface.    Many  paint and ink  manufacturing
facilities calculate total  plant VOC  emissions  based on raw material consumption rather than
calculating emissions from processes or equipment by an alternative  method. Total emissions
therefore reflect solvent losses during manufacturing, cleaning operations, and storage.
     Emission factors for specific equipment could be  developed using  theoretical equations,
mass balance, or emission testing. The development of a theoretical equation could be based on
solvent volatility, vapor pressure, equipment size, and degree of agitation.  Other variables to be
considered include equipment  heating/cooling capabilities, ambient conditions, and exposed
surface area and tank cover efficiency (in the case of mixing vats  and/or drums).  Both the mass
balance  and the emission testing methods would require industry trials.
      Much of the currently available emission factor data is based on U.S. EPA's Compilation
of Air Pollutant Emission Factors (AP-42). Data for paint and ink manufacturing are found in
Table 3-1.   The  table indicates that the majority of the VOC emissions result from varnish
production (for paints) and vehicle cooking (for inks).  Because these processes are typically
performed in chemical  facilities rather than  in  paint and ink  manufacturing  facilities, their
emissions are not addressed in  this report.
 CH-92-02
                                           3-6

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          TABLE 3-1.  UNCONTROLLED EMISSION FACTORS FOR PAINT,
                 VARNISH, AND PRINTING INK MANUFACTURING8'5
Type of
Product/Process
Paintc
Varnish0
Bodying Oil
Oleoresinous
Alkyd
Acrylic
Ink Vehicle Cookingd
General
Oils
Oleoresinous
Alkyds
Nonmethane VOC
Emission Factor
Ratine kg/Mg of product Ib/ton
C 15
C
20
75
80
10
E
60
20
75
80

of product
30

40
150
160
20

120
40
150
160
    Source: Reference 3
    alnk manufacturing data is based on paint & varnish information
    bAfterbumers can reduce VOC emissions by 99%
    Expressed as undefined organic compounds whose composition depends upon the type of
    solvents used in the manufacture of paint & varnish
    dlnk nonmethane VOC emissions are a mix of volatilized vehicle components, cooking
    decomposition products and ink solvent

  A =  Ten or more tests at different plants with a single, standard method. These tests are not necessarily EPA
        reference method tests, although such reference methods are certainly to be used as a guide.

  B =  Several test results using an accepted method  that reflect a large portion of the population.

  C =  A small number of tests or tests employing several different or nonstandard methods.

  D =  A few or a single source test that may  be of questionable quality; or a factor derived for a different
        source type that has been "transferred."

  E =  Engineering judgment
CH-92-02
                                              3-7

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      Also included in the Table 3-1 is an emission factor data quality rating which may range
from A to E, with A being most reliable. AP-42 indicates that high quality ratings are given to
emission factors based on multiple observations at many different plants, while low ratings are
given to  emission factors based on single observations of questionable quality or extrapolated
from other emission factors for similar processes.  The ratings given in AP-42 are considered a
general indicator of the accuracy and precision of a given factor used to estimate emissions from
a large number of sources. The rating system for a particular emission factor test data set is
based on the data standards developed by the U.S. EPA's Office of Air Quality Planning and
Standards for inclusion in AP-42.  The rating system is included in Table 3-1.

3.3.2  Current Regulations7'18'25

      Regulatory requirements for  VOCs vary from State to State and within some jurisdictions
of certain States. At the very least, VOC regulations should be in place in non-attainment areas
where source size may be a basis for control.  VOC emission limits are often determined by end
use categories commonly called EPA Control Technique Guideline (CTG) Sources and by EPA
established Reasonably Available Control Technology (RACT) Limits.   Because paint and ink
manufacturing  facilities are not identified by any current CTGs, individual States may develop
RACT limits. In many States only  those non-CTG facilities emitting more than 100 tons per year
are controlled,  while in other States  the limit may  be 15 pounds  per day. Plants releasing less
than the specified limit are exempt.  The Clean Air Act Amendments of 1990 will require non-
CTG sources in ozone non-attainment areas to control VOC sources that emit 10, 25, 50, or 100
tons per year VOC depending on the severity of the problem.
      Several States currently  have rules  regulating   VOC emissions  from paint and  ink
manufacturing facilities.  Most of these regulations have the following common requirements and
exemptions:
           Covers must be used on all stationary and portable mix tanks, dispersion mills, and
           tanks containing VOC used for cleanup.
           Grinding mills installed after the date of regulatory enactment must be equipped with
           fully enclosed screens.
CH-92-02                                     3-8

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          Equipment must be monitored and inspected for leaks on a regular basis.
          Facilities emitting less than 100 tons per year VOC are exempt from regulation.
         Facilities manufacturing primarily water based paints and inks are exempt.

     The State of Ohio is one State that has developed an RACT case-by-case regulation.  In
1988, Ohio enacted Ohio Air Pollution Control (OAC) rules 3745-21-01 and -09, which subjected
the Cleveland PPG  Industries,  Inc.  (PPG),  paint  manufacturing  facility  to  site-specific
requirements  for  VOC  emissions  based  on  RACT.    Because the  emissions  from the
manufacturing facility and the paint laboratory met or exceeded 100 tons of VOC annually prior
to rule enactment, the facility (manufacturing and laboratory) was classified as a "major" source.
As such, Ohio wrote non-CTG rules for the paint manufacturing operations and paint laboratory
operations specifically  for  PPG.   Ohio's  paint  manufacturing RACT rules and the paint
manufacturing rules from other States are  summarized in Table 3-2.  Table 3-3 summarizes
similar rules for the ink manufacturing industry.

3.3.3  Permits26'30

     Selected permits for equipment at paint and ink manufacturing facilities were retrieved from
the State of Ohio.  Many pieces of manufacturing  equipment (e.g., mixers, grinding mills,
dispersers, and filling equipment) are classified as stationary sources which are subject to the Best
Available Technology  (BAT)  requirement of OAC Rule  3745-31-07 (G)(2), "The control  of
emissions of organic materials from stationary sources."  This rule limits VOC emissions from
stationary sources to 8 pounds per hour and 40  pounds per day.   In addition to these emission
                                                                                    rjf
limits, some equipment is  subject to other special terms and conditions including the following:

          Bottom fill requirements: All solvent additions to  the designated equipment (mainly
          tanks) shall be accomplished by bottom fill, with the exception of a small amount of
          solvent per batch (i.e., 50 gallons) for making adjustments for product specifications.
          Operational limits:  Some sources  are limited to processing time each day where
          processing includes all periods in which the tank is being filled, materials are being
          added,  mixing is  occurring and/or cleaning  of  the tank.   Holding time is not
CH-92-02
                                         3-9

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TABLE 3-2.  STATE REGULATIONS FOR PAINT AND RESIN MANUFACTURING FACILITIES

EPA
Region
III

III









IV


o
A
3





V
f





Slate
PA

MD









AL









MI





Regulation
No.


26.11.15









8.29









6-336.1630




State EPA
Approval
Status/Date
Under
development
Approved









Approval
pending








Approved






State Limit or Requirement


(a) Covers on all open top vessels and lanks used to mix paint,
disperse pigment, and adjust viscosity and color.

(b) Covers used on tanks and vessels must be VOC impermeable and-
must be kept closed at all times except to permit operator access.
(c) Clean manufacturing vessel] and tanks with detergent, hot alkali.
high pressure water, or other precautions which minimize VOC
emissions.
(d) Use submerged filling when transferring VOC containing
materials.
(e) Visually inspect equipment for leaks on monthly basis.
(a) Equip storage vapor tanks of >10 kPa vapor pressure with
pressure/vacuum conservation vents set at 0.2 kPa.
(b) Tanks >250 gallons must use submerged fill-pipe, bottom-fill.
(c) Coven on open-top tanks where non-water based coating
produced, and on tanks storing VOC-containing cleaning substances.
(d) Operate and maintain grinding mills according to manufacturer's
specifications.
(e) Visually inspect pumps weekly; repair 515 days.
(f) Collect gases and vapors from varnish cooking operations and
control by 85% before discharge.
(a) .Covers on all stationary and portable mix tanks and high-speed
dispersion mills, and on all lanks containing VOC used for cleanup.
(b) Clean print manufacturing equipment and paint shipping
containers by methods and materials which minimize VOC emissions.





Exemptions/Cutoffs


(a) Applicable only in Areas HI and
IV.

(b) Facilities emitting 5100 Ipy VOC.







(a) Facilities emitting 5100 tpy VOC.
(b) Tanks where more effective
control used.







(a) lanks used in manufacturing paint
with a volume of less than 56 gallons.
(b) Tanks used only for the purpose of
storing resins.
(c) Equipment used at a stationary
source having a total paint production
of 5500,000 gpy.


Comments


(a) Applies to manufacture of paints,
resins, adhesive! and adhesive
applications








(a) Jefferson County, AL regulation.
(b) Applies lo manufacture or
processing of paints, varnishes,
lacquers, enamels, and other allied
coating products.






(a) Applies to manufacture of paint by
existing facilities.
(b) Separate rule covering resin
manufacturing.



                                   (continued)

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          TABLE 3-2.   STATE  REGULATIONS FOR  PAINT  AND  RESIN  MANUFACTURING FACILITIES (continued)
 EPA
Region
State
        Regulation
           No.
 State EPA
 Approval
Status/Date
                 State Limit or Requirement
        Exemptions/Cutoffs
                                                                                                                Comments
          WI
                 421.06
                    Approved
              (a) Covers on all stationary and portable mix tanks.

              (b) Clean all portable tanks, stationary vats, high-speed dispersion
              mills, grinding mills, and roller mills by methods which minimize
              VOC emissions.

              (c) Equip any grinding mill installed after 10/1/86 with fully enclosed
              screens.

              (d) Monitor valves, pumps, sealed agitators, compressors, flanges, and
              relief valves each quarter or year (as specified).

              (e) Visually inspect valves, pumps, scaled agitators, compressors,
              flanges, and relief valves bimonthly; repair 15 days.
                                                                (a) Facilities emitting 5100 tpy VOC.

                                                                (I)) Tanks where more effective
                                                                control used.
                                    (a) Applies to manufacture of paints,
                                    varnishes, lacquers, enamels, and other
                                    allied surface coating products.

                                    (b) Applies to facilities in Kenosha,
                                    Milwaukee, Ozaukee, Racine,
                                    Washington,  and Waukesha counties.
           IL
        35-B-AA
        Section
        215.620
Approved
(a) Coven on all stationary and portable mills, tanks, vats, and
vessels and on all equipment being cleaned with VOCs.

(b) Operate grinding mills in accordance with manufacturers
specifications which must be kept on file and made available upon
request.

(c) Equip any grinding mill installed after 4/1/89 with fully enclosed
screens.

(d) Visually inspect pumps each week for leaks; repair 15 days.

(e) Identify leaking pumps, valves, pressure relief valves, sampling
connections, open-ended valves, and flanges and repair in 15 days;
maintain records for two years.

(f) Store organic wash solvent in closed containers.
(a) Facilities emitting <100 tpy VOC.

(b) Facilities producing 2,000,000
gpy of paints or ink formulations with
>10 percent (wt) water.

(c) Equipment used to produce paint
or ink formulations with 10% (wt)
water or inks containing Magie oil
and glycol as the primary solvent.
(a) Applies to facilities in Cook.
DuPage, Kane, Lake, Macoupin,
Madison, McHenry, Monroe, St. Clair,
and Will Counties.

(b) Applies to mixing, blending, and
compounding of enamels, lacquers,
sealers, shellacs, stains, varnishes, or
pigmented surface coalings.

(c) Applies to ink manufacturing
facilities.
          OH
        3745-21-09
        (MM)
              (a) VOC emissions from mixing tanks, grinding mills, thinning tanks,
              filling equipment, cleaning equipment, solvent recovery equipment,
              and paint laboratory equipment shall be vented to control equipment
              which shall be maintained as described.

              (b) Covers on all  stationary and portable mixing and blending tanks.
                                                                (a) Rule requirements do not apply to
                                                                specific equipment during periods of
                                                                no production activity or during
                                                                periods of water-based paint
                                                                production.
                                    (a) Slate has developed RACT rules
                                    on a case by case basis.
                                                                                 (continued)

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             TABLE 3-2.  STATE  REGULATIONS FOR PAINT  AND  RESIN  MANUFACTURING FACILITIES  (continued)
    EPA
   Region
State
        Regulation
           No.
             State EPA
              Approval
             Status/Date
                                State Limit or Requirement
                                                                        Exemptions/Cutoffs
                                                                                                                              Comments
    VII
 MO
(KC)
IOCSR
10-2.300
Approved
(a) Pressure/vacuum conservation vents set at 0.2 kPa on tanks
storing VOC with vapor pressure >10 kPa.

(b) Submerged-fill pipe or bottom fill for stationary VOC storage
containers with capacity >2SO gallons.

(c) Covers closed on open-top tanks used in production of non-
waterbase coating products, and on all tanks containing VOC used for
cleanup.

(d) Collect gases and vapors from varnish coating operations and
control by 85% before discharge.

(e) Operate and maintain grinding mills according to manufacturers'
specifications.

(f) Polymerization of synthetic varnish or resin to occur in enclosed
operation using surface condenser exit stream  temperature at which
vapor pressure is 3.5 kPa for any organic component.	
(a) Installations with potential to emit
<250 kg/day or $100 tpy VOC.

(b) Tanks where more effective
control used.
(a) Applies to manufacture of paints,
varnishes, lacquers, enamels, and other
allied surface coating products.
     VII
 MO
(St.L)
IOCSR
10-5.390
Approved
U)
(a) Pressure/vacuum conservation vents set at 0.2 kPa on tanks
storing VOC with vapor pressure )0 kPa.

(b) Submerged-fill pipe or bottom fill for stationary VOC storage
containers with capacity >250 gallons.

(c) Covers closed on open-top tanks used in production of non-
waterbase coating products, and on all tanks containing VOC used for
cleanup.

(d) Collect gases and vapors from varnish coaling operations and
control by 85% before discharge.

(e) Operate and maintain grinding mills according to manufacturers'
specifications.

(f) Polymerization of synthetic varnish or resin to occur in enclosed
operation using surface condenser exit stream  temperature at which
vapor pressure is 3.5 kPa for any organic component.	
(a) Installations with potential to emit
250 kg/day or S100 tpy VOC.

(b) Tanks where more effective
control used.
(a) Applies to manufacture of paints.
varnishes, lacquers, enamels, and other
allied surface coating products.

(b) Applies to South St. Louis area.
     IX
 CA
 (SC)
                    1141.1
            Approved
              (See Coatings and Inks Manufacture)
     IX
 CA
 (BA)
                    8-35
            Approved
              (See Coatings and Inks Manufacture)

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          TABLE 3-3.   STATE REGULATIONS FOR COATINGS AND INK MANUFACTURING FACILITIES

EPA
Region
IV
V
V
V
VII
VII
DC
o
t
o

DC
r

Stale
AL
IL
MI
Wl
MO
(KG)
MO
(St.L)
CA
(BA)



CA
(SC)


Regulation
No.
8.29
35-U-AA
215.620


IOCSR
10-5.300
IOCSR
10-5.390
8-35



1141.1

State EPA
Approval
Status/Date
Approval
Pending
Approved
Approved
Approved
Approved
Approved
Approved



Approved
i


Stale Limit or Requirement
(See Paints and Resin Manufacturing)
(See Paints and Resin Manufacturing)
(See Paints and Resin Manufacturing)
(See Paints and Resin Manufacturing)
(See Paints and Resin Manufacturing)
(See Paints and Resin Manufacturing)
(a) Cover all portable mixing vats with lids as described and cover all
stationary mixing operations.
*(b) Minimize VOC cleaning emissions from portable mixing vats,
high speed dispersion mills, grinding mills & roller mills by one or
more of the following methods: (1) cleaning materials containing <
1% VOC, (2) an approved closed system cleaning system, (3)
collection & venting of equipment cleaning emissions to an approved
emission control system.
(c) Fully enclosed screens on grinding mills installed after 11/1/85.
*(d) <15 Ib VOC/day from stationary vat unless emissions controlled
with overall efficiency of 85% (w) or where > 90% of organic carbon
is oxidized to carbon dioxide by incineration.
(a) Cover portable mixing vats with lids as described and cover
stationary mixing vats.
(b) Minimize reactive organic gases when cleaning portable and
stationary mixing vats, high speed dispersion mills, grinding mills,
and roller mills.
(c) Grinding mills installed after 1/1/85 shall have fully enclosed
screens.

Exemptions/Cutoffs






(a) Manufacturer producing <500
.gal/day.
*(b) Equipment being used for water-
based coatings, paste inks, and low
VOC coatings, inks or adhesives
(<1% VOC wt).
(c) Vats S 12 gal volume.


(a) Manufacturers of <500 gal/day.
(b) For limit (a), equipment producing
water-based coatings and/or paste
inks.
(c) For limits (a) and (b), equipment
used to produce coating in vats 12
gallons.

Comments






*(a) Includes adhesive manufacturing
facilities
*(b) Cleaning requirements effective
1/1/93.


(a) Includes establishments under SIC
2851.

'Proposed amendments/changes

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           considered to be processing time.  Solvent use per  day or quarter may also be
           limited.

           Recordkeeping and reporting: Some facilities are required to maintain daily records
           of individual source processing time with product identified and batch start and stop
           times indicated. Other recordkeeping requirements include tracking daily solvent use
           with amount and type indicated.  In addition, a facility may be required to conduct
           routine inspections of equipment and record the results of the inspections and any
           necessary repairs.

           New product notification:  Prior to manufacturing any new products, for other than
           process development and/or testing, some facilities must submit written notification
           to the Ohio EPA.

           Equipment modifications:  In most facilities equipment is required to be covered or
           enclosed during manufacturing operations.
     Additional requirements will apply if a given facility operates add-on air pollution control

equipment.  The Cleveland PPG  manufacturing facility, which is mentioned in Section 3.3.2,
controls VOC emissions by venting fumes from individual sources to a REECO (Regenerative

Environmental Equipment Company) thermal incinerator. PPG's permits (and the RACT rule)

name the following requirements:
     "... the VOC emissions from the equipment included within the paint manufacturing
     operations shall be vented either directly or by means of a building or local area
     exhaust to a control  system  which  shall maintain  compliance with  any  of the
     following requirements:  '

     (a)   A minimum control efficiency of 98.0 percent by weight for the VOC emissions;

     (b)   A maximum outlet VOC concentration of twenty parts per million by volume (dry
           basis); or

     (c)   A  minimum  incineration  temperature  of one  thousand five  hundred degrees
           Fahrenheit."


Similar permit requirements apply  to other facilities operating air pollution control devices.
Appendix B contains tables which have a selection of permit requirements from several  States.

The States included are Ohio (Table B-l), California (Table B-2), Illinois (Table  B-3), Texas
CH-92-02
                                         3-14

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(Table B-4), and other States (Table B-5).  The information included in these tables gives a
general idea of the quantity of VOC emissions occurring at different size facilities.  In some
cases, the emission data is divided by source category (Tables B-l, B-4, and B-5). The emission
data listed in the tables is most likely based on theoretical equations rather than on actual test
data.
     Information retrieved  from the State of Ohio lists vessel capacity, vessel size, abatement
methods, VOC emission limits,  control efficiencies,  and applicable operational limits.  Two
methods  of abatement used to  control  VOC  emissions  are carbon  absorption  and carbon
adsorption. Both the adsorbers and the absorbers operate at 95 percent efficiency.
     California information lists facility size and organic emission limits in both tons per year
and pounds per day. The data indicate facilities with applicable abatement devices, but does not
describe the type of device.
     Information included in the Illinois table indicates estimated organic emissions in tons per
year.   The abatement devices in  this table include  control techniques for both VOCs and
particulate matter.
     Texas data includes facility size, emission sources, speciation data, organic emissions in
tons per year, and  abatement devices.  Like Illinois, Texas includes information on both VOC
and  paniculate controls.   Some of the methods  used to  control VOC emissions  are vapor
condensers and scrubbers.
     The information included in the final table, Table B-5, lists emission sources, emissions,
and abatement devices for several States.

3.3.4 Plant Trips

     The trip reports for the four facilities visited during the course of this project are located
in Appendix C. All of the manufacturing facilities visited calculate total plant VOC emissions
based  on raw material  consumption rather  than calculating emissions  from processes or
equipment by an  alternative method.  Total emissions therefore reflect  solvent losses during
manufacturing, cleaning operations, and  storage.
     Each of the four facilities visited is required to submit annual emission reports under the
Superfund Amendments and Reauthorization Act of 1986  (SARA)  Section 313.  In 1990, the
CH-92-02
                                          3-15

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                                                f\ R Q
facilities reported releases as indicated in Table 3-4. ''  Please note that the term fugitives as
used in  this table indicates primarily evaporative losses.  These emissions may be controlled if
they occur within a structure or enclosure.

                         TABLE 3-4. EMISSIONS FOR 1990
Facility
The Perry & Derrick Company







ICI Specialty Inks
(Regent Drive Facility)
Borden Packaging and Industrial
Products




Chemical
n-Butanol
Ethyl Benzene
Ethylene Glycol
Glycol Ethers
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Toluene
Xylene
Toluene
Glycol Ethers
Methyl Ethyl Ketone
1,1,1 -Trichloroethane
Toluene
1990
Fugitive
1600
11-499
1M99
500-999
13,000
2,000
19,000
1,100
11-499
1,100
500-999
7,830
11-499
Releases (Ibs)
Point Sources
1-10
-
-
11-499
1-10
1-10
11-499-
11-499
11-499
500-999
7,800
-
500-999
     Section 313 submissions for the PPG Industries, Inc., site are found in the facility trip
report located in Appendix C.
CH-92-02
                                          3-16

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3.4 REFERENCES

1.    1987  Census of Manufactures.  Industry  Series.   Paints  and Allied  Products.   U.S.
     Department of Commerce. Washington, D.C.

2.    1987 Census of Manufactures.  Industry Series.  Miscellaneous Chemical Products.  U.S.
     Department of Commerce. Washington, D.C.

3.    Reitter, Chuck, "VOCs, ozone still major problems, and paint is right in the middle (Part
     1)," American  Paint & Coatings Journal July 7:15-18, 42-43, 1986.

4.    Hart, Judith, "Painting the Town Green," Chemistry & Industry, 20:638, 1990.

5.    U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors. AP-
     42, Fourth Edition and  Supplements.   Office of Air Quality Planning and Standards,
     Research Triangle Park, NC. September 1985.

6.    ICI trip report  and facility information

7.    PPG trip report and facility information

8.    Perry & Derrick trip report and facility information

9.    Borden trip report and facility information

10.  Patton, Temple C., Paint Flow and Pigment Dispersion, Second edition, John Wiley &
     Sons, New York, NY. 1979.

11.  Lamboume,  R., ed., Paint and Surface Coatings, John Wiley & Sons, New York, NY.
     1987.

12.  Premier Colloid Mills product brochure.  "The Ultimate in Dispersing and Emulsifying,"
     Premier Mill, Corp., Reading, PA. 1988.

13.  Zoga, Christ, "Horizontal Media Milling With Computer Controls," reprinted from Modern
     Paint and Coatings, by Premier Mill Corporation, New York, NY. June 1984.

14.  Lorton, Gregory A., "Waste Minimization in the Paint and  Allied Products Industry,"
     JAPCA, 38(4):422-427, 1988.

15.  U.S. Environmental  Protection  Agency.  Toxic  Air Pollutant Emission  Factors - A
     Compilation for Selected Air Toxic Compounds and Sources, EPA-450/2-88-006a. Office
     of Air Quality Planning and Standards.  Research Triangle Park, NC.  1988.

16.  Storfer, Stanley J. and Steven A. Yuhas, Jr.,  "Mechanism of Blister Formation in Organic
     Coatings; Effect of Coating Solvents," Paint & Resin, 57(5):8-12,33, 1987.

CH-92-02                                    3-17

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17.  Memo from McMinn, B.,  Alliance Technologies  Corporation, to Blaszczak,  B., U.S.
     Environmental Protection Agency, Office of Air Quality Planning and Standards, Control
     Technology Center.  January 7, 1991.  Request for emission factor development.

18.  Exxon Chemical, "Guide to  State Volatile Organic Compound  Control Regulations,"
     produced by Modern Paint and Coatings, April, 1991.

19.  U.S. Environmental Protection Agency. Summary of State VOC Regulations - Volume 2.
     Group III CTG and Greater Than 100 Ton Per Year Non-CTG VOC Regulations, EPA-
     450/2-88-004.  Office of Air Quality Planning and Standards. Research Triangle Park, NC.
     May 1988.

20.  Regulation 1141.1. Coatings and Ink Manufacturing, Rules and Regulations, South Coast
     Air Quality Management District (California).

21.  Regulation B, Rule 35.  Coatings and Ink Manufacturing, Rules and Regulations, Bay Area
     Air Quality Management District (California).

22.  Title 35: Environmental Protection, Subtitle B: Air Pollution, Chapter I: Pollution Control
     Board, Subpart AA:  Paint and Ink Manufacturing,  Section 215.620, 215.621,  215.623,
     215.624,   215.625,  215.628,  215.630,  215.636.    Rules  and  Regulations,  Illinois
     Environmental Protection Agency.

23.  Chapter  NR  421.06.   Coatings Manufacturing,  Rules  and Regulations, Wisconsin
     Department of Natural Resources.

24.  Part 6, Rule  336.1630.   Emission of volatile organic compounds  from  existing paint
     manufacturing processes.  Rules  and Regulations,  Michigan  Air Pollution Control
     Commission.

25.  Rules  3745-21-01 (Q)  and  -09(MM).   PPG Industries, Inc.,  RACT  rules.  .Ohio
     Environmental Protection Agency.

26.  Permit information retrieved from the  State of Ohio Environmental Protection Agency.

27.  Permit information received from the State of Illinois Environmental Protection  Agency.

28.  Permit information received from the State of Texas Air Control Board.

29.  Permit information retrieved  from  the  Bay  Area Air  Quality  Management District
     (California).

30.  U.S. Environmental Protection Agency. AIRS Facility Subsystem Source Classification
     Codes and Emission Factor Listing for Criteria Air Pollutants Database, EPA-450/2-88-
     004.  Office of Air Quality Planning and Standards.  Research Triangle Park, NC. May
     1988.

(31-92-02                                   3-18

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                                    CHAPTER 4
                        EMISSION CONTROL TECHNIQUES
 4.1  INTRODUCTION
      In paint and ink facilities, VOC vapors arc generated throughout the manufacturing process.
 If these emissions are  left uncontrolled, high concentrations of VOC can build up in the work
 area, compromising workers' health, safety, and productivity. Release of VOC to the atmosphere
 can result in increased levels of tropospheric ozone (O3), a pollutant that causes negative health
 effects in the human pulmonary system.
      The amount of VOC present in the indoor and outdoor atmospheres can be reduced in the
 following ways:  minimizing the manufacture and use of products containing VOC, reducing the
 amount of VOC emitted during the manufacturing process, and removing VOC from the air once
 it has been emitted.  Paints and inks may be reformulated to eliminate or minimize the amount
 of VOC contained in the product.  Reductions in process VOC emissions may be achieved by
 equipment and process modifications, improved operating practices, and recycling.  Reduction
 of VOC emissions to  the indoor and outdoor atmospheres can be achieved by ventilating the
 manufacturing area through use of well-designed capture devices and subsequently removing
 VOC from the ventilation air by appropriate control devices.
     The concentrations of organics found in the emission streams from the process equipment
 are often very low.  The organics in these  streams consist of  alcohols, ketones, cellosplves,
 acetone,  toluene, xylene, and others.1"2 The low organic concentrations, the  variety of organic
 constituents, and the paint and ink batch process operations often make add-on control devices
 for individual sources  unattractive.  The following sections describe more effective emission
 reduction and removal  methods.

 4.2 VOC EMISSION REDUCTION METHODS

     Paint and ink manufacturing facilities can take several steps to minimize  VOC emissions
 without employing add-on controls. The methods discussed in this section will  reduce waste in
 addition to reducing emissions. These VOC-minimizing methods include process and equipment
CH-92-02                                   4-1

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modifications, improved operating practices, and recycling.  Source reduction through product
reformulation  is covered in Section 4.3.  It  is difficult, however, to  determine the overall
efficiency or impact of these VOC-minimizing methods on individual emission sources because
many paint and ink manufacturing facilities estimate total plant emissions rather than estimating
or testing emissions by process of source (i.e., filling operations, grinding operations, cleaning
processes).

4.2.1  Equipment or Process Modifications

      Two stages which are amenable to equipment and process modifications are paint and ink
manufacturing and equipment cleaning.

4.2.1.1  Tank Lids
      Tank lids are the most common equipment modification used during the manufacturing
process to control VOC emissions.  Mix and blend tanks are a primary source of manufacturing
VOC  emissions because the solvent-containing materials spend a significant amount of time in
this equipment. All of the States that regulate paint and ink manufacturers require that all open-
top equipment be covered during the manufacturing process (See Tables  3-2 and 3-3).  Illinois,
like most of the States, requires the following of equipment lids:3
      1.     The mill, tank, vat, or vessel  is equipped with a cover which completely covers the
           mill, tank, vat, or vessel  opening, except for an opening  no larger than necessary to
           allow for safe clearance for a mixer shaft. Such a cover shall extend at least 1/2 inch
           beyond the outer rim  of the opening or be attached to the rim.
      2.     The cover remains  closed, except when production, sampling,  maintenance, or
           inspection procedures require access.
      3.     The cover is  maintained in good condition, such that when in place, it maintains
           contact with the rim of  the opening for at least 90 percent of the circumference of
           the rim.

      Many of the lids currently used in industry are flat and some are conical. Flat lids control
emissions relatively well, but they do have some inherent flaws. The  lids do not form a seal with
the mix  tank and the hinged door product add chute does not always remain closed.  A typical
                                                               *v
CH-92-02                                   4-2

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flat lid is illustrated in Figure 4-1.  Conical lids, a better engineering design, are considered a
more efficient means of controlling emissions.  However, they too have associated difficulties
caused by added weight and bulky shape.   The conical lids are more difficult to handle and
damage more easily than the flat lids.
      Lids may be constructed of either plastic, wood, aluminum, or stainless steel.     Plastic
and  wooden lids are normally  one piece except for the center  agitator shaft opening, while
aluminum and stainless steel lids normally have hinged  openings  for product  additions and
sampling.   Some  facilities currently using aluminum lids question their safety.   A study
conducted in Germany indicates that having steel (e.g., carbon steel  mix tank) scraping against
aluminum containing silicon (e.g., mix tank cover) could be a potential source of sparks.  A fire
may break out if the sparks contact possible flammable vapors from solvent-containing paints and
inks.8
      The control efficiency of covers on mix tanks ranges from 40 to 96 percent depending on
the method used to determine emissions.4'9'10 These values represent the ratio of the emission
reduction to the uncontrolled emissions. They do not account for  any  subsequent  venting to
control  devices.  The 96 percent value arose from studies conducted with mix tanks  in the
polymeric coating industry.  In this case, the demonstrator considered only evaporative losses
during the mixing process.  This method of emission determination fails to include the working
losses that occur during filling and emptying a vessel containing a solvent-saturated air space.
      A study of the efficiency of covers  used in the magnetic  tape manufacturing industry
indicated an efficiency of 40 percent. This study, which is considered representative of the paint
and  ink manufacturing industries, accounted for both evaporative  and  working losses.  The
analysis indicated that the covered tank would release almost no evaporative losses.  The study
also stated that working losses  would be 75 percent of those calculated  for an open tank (i.e.,
when the covered tank is filled, only 75 percent of the solvent-saturated air is pushed out into
the surrounding air).  As described  by the magnetic tape study, the  total emission reduction is
determined to  be the difference between the emissions of the open and covered tanks.
      A description of a third  study on mix tank covers is found in the  ICI  trip report in
Appendix C. This study, which  accounts only for evaporative losses, indicates a cover efficiency
of 88.6 percent.
CH-92-02                                    4-3

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Hinged Door
Allowing Agitator
Shaft  Entry
                                                                    Opening for
                                                                    Agitator Shaft
                                                                              Hinged Door
                                                                              for Material
                                                                              Additions
                            Figure 4-1.  Typical flat mix tank cover.


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      Studies conducted by the polymeric coating industry indicate that no significant increase
 in cover efficiency is achieved by using vapor-tight covers with conservation vents rather than
 tight-fitting covers. The primary benefit of conservation vents is the control of breathing losses
 which result from diurnal temperature changes.  Mix tanks in paint and ink manufacturing, like
 mix tanks in the polymeric coating industry,  are not normally exposed to  these temperature
 changes.10

 4.2.1.2 Modified Milling Equipment
      In some cases paint and ink manufacturers could reduce total VOC emissions by converting
 some of their older milling equipment to newer, more efficient closed-systems such as horizontal
 media mills. Although a wide range of products can be processed in the  horizontal mills, some
 cannot.  The mill  base  must be of  a low viscosity  to allow  the grinding media to move  with
 maximum velocity. The low viscosity requirement  prevents  some materials  currently made in
 other types of milling equipment from being manufactured in horizontal mills. The viscosity of
 a product, along with other characteristics such  as color, gloss, type of raw  materials, and
 processing time, often determines the appropriate type of milling equipment.11'12

 4.2.1.3  Equipment Cleaning
      Equipment cleaning generates  a high percentage of the waste associated with paint and ink
 manufacturing.  Because much of this cleaning is performed with solvents, equipment cleaning
 is also a major source of VOC emissions. Any methods that reduce the need or frequency  of
 tank cleaning will also reduce emissions.  Several process and equipment  modifications follow.

           Rubber wipers:  Facilities can use rubber wipers  to scrape the sides  of the tank  to
           reduce  the amount of clinging paint or ink, therefore reducing the amount of solvent
           needed to  clean the tank. Wipers can be either manual or automatic.13'14
           High-pressure spray heads: High pressure spray heads can be used to clean process
           tanks.  These heads can  reduce cleaning  material use by 80 to 90 percent.13'14
           Teflon" lined tanks:  Teflon lined tanks will reduce the amount of paint  and ink
           clinging to the side of the tank and will make cleaning easier.13'14
           Plastic pigs:  Plastic or foam "pigs"  may be used to clean paint and ink from process
           pipes.  The "pig" moves through the pipes and pushes ahead  paint from a previous
                         *
CH-92-02                                    4-5

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           batch which has been left clinging to the pipe walls.  This process reduces solvent
           needed to clean the pipes and increases product yield.13'14

           Automatic tub washers: Some facilities have successfully used automatic tub washers
           to clean process tanks.  These washers form a seal with the tank, pull a vacuum, and
           circulate cleaning solvent on a timed schedule.4

      Another method to reduce emissions from solvent cleaning operations is to use larger media
in milling equipment. Larger media rinses more easily than small media, and therefore requires
less cleaning solvent.15  Glass and ceramic media and sand are also easier to clean than steel
shot.16
4.2.2 Improved Operating Practices


      In addition to process and equipment modifications, VOC emissions may be reduced by

following good operating procedures. Several paint manufacturing facilities in Ohio are required

by permit to abide by the following good housekeeping procedures:17


      1.    All open-ended paint manufacturing vessels shall be securely covered during periods
           of operation, except when adding raw materials.

      2.    During the transfer of material to different containers, steps shall be taken  to reduce
           and prevent  splashes and spills.  Any liquid or dry material spilled shall be cleaned
           as expeditiously as possible, but not later than the end of the daily work shift.

      3.    Waste  solvent  shall be collected and stored in closed containers.  The  closed
           containers may contain a device that would allow pressure relief, but would  not allow
           liquid solvent to drain from the container prior to disposal.

      4.    The permitted facility  shall provide  a  permanent sign  or signs for  the paint
           manufacturing equipment which states the required work and operating practices.
           The sign or  signs shall be placed in a prominent location  and be kept visible  and
           legible at all times.
     Another good operating procedure which can reduce emissions is dedicating process lines

and  equipment.   Equipment dedication  eliminates cleaning between each  product  batch.

Scheduling compatible batches or batches from light to dark colors also reduces the need for

equipment cleaning.  Production scheduling and dedicating equipment may be impossible,
                                                                "v.

CH-92-02      .                               4-6

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however, in small paint and ink facilities that operate on a batch  schedule in order to  meet
customer demands.  In some cases, facilities operate on a same-day  shipment schedule.4"7

4.2.3  Recycling Techniques

     One common recycling  technique  among  paint and  ink manufacturers is using spent
cleaning solvent in subsequent compatible batches.  After a mill  or tank has been emptied of
product, solvent is added to the vessel to capture remaining product  residue.  The wash solvent
is drained from the tank, staged, and recycled into the next compatible product batch.  Mills may
be cleaned by replacing the residual heel of the exiting product with an equivalent  amount of
solvent  which is compatible with both the preceding and the ensuing batches.4'6'7
     Another recycling technique which reduces total solvent consumption and VOC emissions
is using countercurrent rinsing sequences. This method uses recycled "dirty" solvent  to initially
clean the tank.  Following  this  step, "clean" recycled or virgin solvent is used to rinse away the
"dirty" solvent.  The countercurrent sequence, as illustrated in  Figure  4-2, extends  the life of
cleaning solvents.4'6'14

4.3 PRODUCT REFORMULATION

     Eliminating or minimizing  the manufacture and use of products containing VOCs is the
most effective  way to reduce VOC  emissions.  In many cases, alternatives  to  high-solvent
containing paints and inks  do exist. However, because many end users (i.e., finishing facilities)
are reluctant to invest the  time and effort required to change to these new and developmental
technologies, manufacturers continue to make the higher solvent products.  As more technically
feasible low-VOC coatings become available, regulations covering their use will be developed.
For instance, a Control Technique Guideline (CTG) is currently being developed for architectural
and industrial maintenance coatings.   The production trends for  these lower  solvent product
formulations are illustrated in Figure 4-3. The following sections briefly discuss several coatings
which have been successfully manufactured and applied by end-users.
CH-92-02                                     4-7

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   Fresh  solvent makeup
                                                               Reclaimed  solvent
oo
                             Reclaimed  Solvent
                               Storage  Tank
 Solvent
in  Drums
                                                Periodic reclaim to still
                                         Reclaimed solvent
                                                                     Solvent
                                                                      Still
  Equipment
to be  Cleaned
                                  -* Solvent still bottoms
                                     to  blending  (as  rework)
                                         Figure 4-2. Recycling and reusing cleaning solvent.

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             100 K-
              80
              60
 Production
  Volume
 (Millions of
Dry  Gallons)
              40
              20
                                      High-solids solvent-based
                                                                                              Powder
                                                                                   Radiation cured

                                                                                        I _
               1983
                                                   1987
                                                                                                         1993
                                 Figure 4-3. Production trends in coating systems.

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4.3.1 Powder Coatings

      Powder coatings are mixtures of dry synthetic resins, pigments, solid additives, and from
zero to ten percent entrapped volatiles.  Because these coatings contain no liquid solvents, they
do  not  emit VOC.   Powder coatings are of two general  resin types: thermoplastic  and
thermosetting. Thermoplastic powders are comprised mainly of vinyl, nylon or fluoroplastics.
Thermosetting coatings are normally epoxy, polyester or acrylic powders.18'19
      Powder coatings currently account for 15 percent, or an estimated 118 million pounds, of
the coatings market, and future growth is expected particularly with thermoset powder coatings.20
Epoxy systems,  because  of their versatility  in  both decorative  and functional  areas,  have
anticipated expansion of 14 percent per year to 105 million pounds by  1995.21
      Powders can now  be used in many paint end-user industries because of the technological
advances in the powder  coating industry and because powder coating suppliers have developed
custom-formulated powders. They are  a feasible alternative to many OEM paints, although they
are less  viable in architectural and special-purpose markets.

4.3.2 Waterborne Paints and Inks

      Waterbome paints  and inks  contain water as the main solvent  or dispersant, although most
contain  5 to 20 percent  organic solvent to aid  in  wetting,  viscosity control, and  pigment
dispersion.22
      Waterbome paints are of several types:  latex or emulsion  paints,  partially solubilized
dispersions and water soluble coatings.  Emulsions are the most commonly used coatings because
they can form relatively thick films without blistering.  Emulsions are  particularly common in
the consumer architectural market.18
      Waterbome inks are also penetrating solvent markets.  The traditional solvent categories
(flexographic and gravure  inks) are seeing increasing production of waterborne formulations.23
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4.3.3 Radiation-Curable Paints and Inks24

      Radiation-curable coatings are coatings formulated to cure at room temperature with the
assistance of a radiation source, either an ultraviolet (UV) light or an accelerated electron beam
(EB). The electromagnetic radiation energy effects a chemical and physical change in the coating
materials by forming cross-linked polymer networks.  Radiation-curable coatings typically have
higher solids contents than their conventional solventborne counterparts. The majority of current
radiation-curable systems contain none of the organic  solvents found in conventional paints and
inks. The film-forming components  in  a radiation-curable system may approach  100 percent
reactivity, which means that most (i.e., 98 to 99 percent) of the material is converted into the
polymer network and very little evaporates before the coating or ink is considered  dry.
      Radiation-curable paints and inks have been used successfully  in several areas.  The graphic
arts  industry, a large user of UV-curable inks and varnishes, accounts for almost 50 percent of
the radiation-curable market.  For  1985, it is  estimated that the graphic arts industry used 13
              .
million  pounds of UV-curable materials.

4.3.4 High-Solids Paints and Inks

      The normal, solids content for conventional coatings  ranges  from 8 to 30 percent,  while
high-solids coatings typically contain greater  than  60  percent  solids by volume.25"27   The
contributing solids' components in high-solids coatings are pigments and  binders (resins).26'28
Because high-solids  coatings contain  less solvent and more solids, they help to  lower  VOC
emissions.  Some high-solids materials are used in almost all of the paint and ink markets.
      High-solids coatings are modifications of their solvent-based counterparts and are classified
into two general groups: two-component/ambient cured and single-component/heat converted.18'28
Both groups are chemically composed of synthetic resins, pigments, additives and a reduced
quantity of solvent. Epoxy, acrylic, polyester and alkyd resins have been developed for single-
component systems;  acrylic, polyester, epoxy  and urethane resins  are  used in two-component
coatings. The two-component systems offer the advantage of ambient curing, thereby eliminating
the need for an oven. When mixed  shortly before application, the components crosslink to form
a solid film.18
CH-92-02                                   4-11

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4.4 VOC EMISSIONS REDUCTION BY CONTROL SYSTEMS

      VOC emissions can be removed from  the  atmosphere  by an add-on  control system
consisting of a capture device and a removal device.  The capture device (such as a hood or
enclosure) captures the VOC-laden air from the emission area and ducts the emission stream to
removal equipment such as a recovery device (e.g., an adsorber) or a combustion device (e.g.,
an incinerator) which removes the VOC from the air. The overall efficiency of a control system
is calculated  by  multiplying  the capture system  efficiency by  the removal device efficiency.
Thus, the combination of a capture device which captures  80 percent of the VOC emissions at
the emission source ducted to a removal device which removes 90 percent of the VOC in the
emission stream would yield an 72 percent overall efficiency.
      Many removal devices (such as adsorbers or incinerators) have removal efficiencies well
above 90  percent.   Capture devices,  in comparison, have a  much larger range  of capture
efficiencies.
                         c,
      Designing a capture system for a facility can be a more complex  task than designing a
removal system.  A capture system must be designed around equipment functions and layout that
can vary significantly from plant to plant. In contrast, removal systems are typically "packagedjl
systems designed by  the removal device  manufacturer and placed away from  the process
equipment, thereby reducing facility-specific demands.

4.4,1  Capture Devices

      Several capture devices such as enclosures, hoods, and other devices may be used in the
paint and ink manufacturing industry to remove vapor and liquid VOC from the manufacturing
area and to transport them to an appropriate removal device.29
      Several factors are important in the design of a good capture system. A primary capture
system criterion  is  that the  system should maximize VOC capture at  the  minimum cost.
Optimum cost effectiveness is generally achieved by increasing the degree of closure around the
emission area, because airflow volume  is the primary  factor influencing capture system cost.29
                                                              "v,
CH-92-02                                  4-12

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      Other necessary considerations in addition to airflow and cost include fire and explosion
 hazards, and visibility requirements.29  To prevent the risk of fire or explosion, the maximum
 VOC concentration within capture and removal systems should be kept below 25 percent of the
 VOC's lower explosive limit (LEL). Visibility must be maintained so that operators can clearly
 observe the manufacturing equipment when necessary.29
      A "total enclosure" device is defined as a structure that is constructed around a source of
 emissions so that all  VOC emissions are collected and  exhausted through a stack or duct to a
 control device.   With a total  enclosure, there will be  no fugitive  emissions, only stack
 emissions.10  A paint or ink manufacturing facility may be well-suited to using the "total
 enclosure" approach to VOC capture. The mixing tank lid could be constructed with a surficial
 flange which could be connected to a second flange at the  end of  flexible  ductwork.  The
 ductwork,  which is connected to a combustion or recovery device, is installed at the mixing
 station and is attached to the mix tank lid during mixing operations.  Although it is infeasible to
 duct emissions from a portable tank while it is being temporarily stored or staged, it is  feasible
                                                   .
 to duct emissions from this equipment when it is  being held stationary during manufacturing
 operations.   This technique can be applied to lids fitting mix tanks and drums of all sizes.
 Employing this  arrangement allows the covered tank to become, in  effect, a  total  enclosure
 capture device.  Exhausting the tank  emissions to a removal devices completes the control
 system.
      A second option is to use  a room-type total enclosure or a small-process total enclosure.
 In the paint and ink manufacturing industry, it may be possible to enclose defined areas within
 the production facility and vent  the area emissions to a combustion or recovery  device.  The
 capture efficiency for complete enclosures can be close to 100 percent.10  Total enclosures may
 be used in areas housing  automated equipment and where personnel activities are minimized.
 Although partial enclosures, such as hoods installed over processing equipment, can be used in
 more  areas than  total  enclosures, their efficiencies are not as great.
      The following points summarize  the design and operational criteria set forth by EPA for
 total enclosures in the polymeric coating industry:
      1.    The only opening in the enclosure shall  be forced makeup air and exhaust ducts and
           natural draft openings such as those through which raw materials enter and  exit the
           coating operation.
                                                                'v
CH-92-02                                    4-13

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     2.    The total area of all natural draft openings shall not exceed 5 percent of the total
           surface area of the total enclosure's walls, floor, and ceiling.
     3.    All  access doors and  windows  shall be closed during normal operation of the
           enclosed coating operation, except for brief, occasional openings to accommodate
           process equipment adjustments. If such openings are frequent, or if the access door
           or  window remains open  for a  significant amount  of time during the process
           operation, it must be considered a natural draft opening.
     4.    Average inward face velocity (FV) across all natural draft openings is a minimum of
           3,600 meters per hours (200 feet per minute) and demonstrably inward at all times.
     5.    All sources of emissions within the enclosure shall be a minimum of four equivalent
           diameters away from each natural draft opening.

Although the criteria listed above  were included in the polymeric coating and magnetic tape
coating new source performance standards, they  may be considered a guide to the appropriate
design of a tank-and-lid total enclosure capture device.
4.4.2 Recovery Techniques                                    

     Recovery devices are those which physically remove a compound from an emission stream
and convert the compound  into a form  (normally  a liquid) for  future use.   The  removal
efficiencies of recovery techniques normally depend on the chemical and physical characteristics
of the compound to be removed.  Some of the recovery control devices  used in industry include
carbon adsorbers, absorbers, and condensers.

4.4.2.1  Carbon Adsorption
     In the carbon adsorption process, VOC emission streams are passed through a bed of
activated carbon in which the VOC molecules are captured on the porous carbon surfaces by non-
chemical Van der Waals forces. The adsorptive capacity of the carbon bed tends to increase with
the gas phase VOC concentration, molecular weight, diffusivity, polarity, and boiling point of the
VOC.30 After the  working VOC capacity of the carbon is reached, the VOC can be desorbed
from the carbon  and collected for reuse.
CH-92-02                                    4-14

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      Desorption of the solvent VOC from the used carbon bed is typically achieved by passing
 low-pressure steam through the bed.31 In the regeneration cycle, heat from the steam forces the
 VOC to desorb from the carbon, where it is entrained in the steam. After the carbon bed has
 been sufficiently cleared of VOC, it is cooled and replaced on-line with the emission stream.
 Meanwhile, the VOC-laden steam is condensed, and the VOC is separated from the water by
 decanting or, if necessary, by distillation; if the VOC is not recovered for reuse or reprocessing,
 it may be incinerated.32
      Carbon adsorbers are commonly used for air pollution control and/or solvent recovery from
 dilute (less than 10,000 ppmv) streams of VOC  in air.  Adsorption provides a  very low outlet
 concentration as well as the opportunity to recover the VOC. Removal efficiencies range from
 95 to 99 percent for well-operated systems, and outlet concentrations of 50 to 100 ppmv can be
 routinely achieved.  Packaged systems are available with flow rate capacities beyond 100,000
 scfm.33
      The principal advantage of carbon adsorption is  that it is very  cost effective with low
 concentrations of VOCs. VOC recovery may offset operation costs.  Operation of the adsorber
 is relatively simple for both continuous and intermittent use. However, at concentrations below
 the 500 to 2,500 ppm range, adsorption may become uneconomical.34
      Certain types of VOCs, such as those which are difficult to  strip  from carbon or those
 which are miscible with water, do present disadvantages.  If the VOC involved is miscible with
 water, additional distillation measures are necessary to recover the VOC.  If steam-stripping is
 conducted with chlorinated hydrocarbons, corrosion and wastewater treatment problems may
 occur.35  Also,  carbon adsorption  is relatively  sensitive to  emission stream  humidity  and
 temperature. Dehumidification is necessary if the emission stream has a high humidity (relative
 humidity > 50 percent) and cooling may be required if the emission stream temperature exceeds
 120 to 130F.33
     Two carbon adsorption systems currently in use are the fixed-bed system and the fluidized-
 bed system.  In the fixed-bed  system, non-moving beds of carbon are alternately placed on-line
 and regenerated. When a continuous emission stream is being treated, at least one bed is on-line
 and one bed is regenerating at any given time. In the fluidized-bed system, loose, clean carbon
 is constantly metered into the bed while loose, VOC-laden carbon is removed for regeneration.33
                                                                *v
CH-92-02                                    4-15

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4.42.1.1  Fixed-Bed Systems.  In a continually operating fixed-bed system, the VOC emission
stream is passed through two or more non-mobile carbon beds.  In a two-bed system, one bed
is on-line with the emission stream  while the other bed is being regenerated or on standby.
When the first bed reaches its working VOC capacity, the emission stream is redirected to the
second bed, and the first bed is regenerated.  While two beds are common, three or more  beds
can be used in a variety of configurations, with more than one bed on-line at a time.31

4.4.2.12  Fluidized-Bed Systems.  The fluidized-bed adsorber system contains one or more  beds
of loose, beaded activated carbon. The VOC emission stream is directed upward through the bed
where the VOCs are adsorbed onto the carbon. The flow of the emission stream stirs the carbon
beads, causing them to "fluidize" and flow within the adsorber. The VOC-cleaned air exiting the
adsorber is passed through a dust collector, then released into the atmosphere.31  Fresh  carbon
is continually metered into the bed while VOC-laden carbon is removed for regeneration.
      Fluidized-bed adsorbers can capture  more VOC with a given quantity of carbon because
the fluidized bed mixes  newly regenerated carbon and VOC more thoroughly, and because the
system continually replaces used carbon with regenerated carbon.  This increased VOC-capacity
reduces costs for steam regeneration.  Fluidized-bed adsorbers are less common than fixed-bed
adsorbers because fluidized-bed adsorption  technology has been commercially feasible only since
the early 1970s.36
      Because VOC concentrations in the  paint and ink industry are generally lower than the
acceptable range for economically feasible control by carbon adsorption, it is unlikely that the
carbon adsorber is  a viable choice for the industry.  Also, the wide mixture of organics that may
be emitted at a paint and ink facility  will tend  to reduce the  control efficiency of  carbon
adsorption.34

4.4.2.2  Absorption (Scrubbing)
      In  the physical  absorption  process,  VOCs  are removed from the emission stream by
absorption in  a liquid solvent such  as  a  high molecular weight oil.  Spray towers, venturi
scrubbers, or other methods are used to bring the absorbent into contact with  the emission stream.
After the VOCs dissolve into the solvent, the cleaned gas is released from the absorber.31  After
                                                                'v
CH-92-02                                    4-16

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the VOCs have been captured in the absorbent, fractional distillation or some other method can
be used to recover the VOC from the absorbent.37
      Absorption is most efficient when the VOC is soluble in the absorbent, and when the
absorbent's boiling point is significantly higher than the VOC to be  absorbed.  Absorbers have
been shown to remove from 86 to greater than 99 percent of the waste stream VOC for various
species.32'35
      Absorbers can be used with a wide variety of organic compounds without many of the
problems associated with other VOC removal devices such  as the carbon adsorber, incinerator,
or condenser.  A closed-loop system has  been developed that demonstrates no deterioration with
use and does not generate steam, or wastewater or cause corrosion.35
      Despite  its  advantages, the closed-loop adsorption system is not cost effective with very
low inlet concentrations of VOCs or with airflows less than 1,000 cfm.35 These restrictions make
the absorber a less-frequently used option for VOC  control.  For  most industrial  processes,
including paint and ink manufacturing, the waste  stream VOC concentrations are generally low,
making absorption less desirable than adsorption or incineration  unless the  absorbent is easily
regenerated or the solution can be used as a process make-up stream.31

4.4.2.3  Condensation
      Condensers remove VOCs from the emission stream by causing the VOC to condense and
separate from  the gas.  The VOC  can be condensed by decreasing or increasing the pressure at
a given temperature.  Surface condensers and contact condensers are two common systems that
condense VOCs by cooling the emission stream at atmospheric pressure. The removal efficiency
of a condenser is dependent on the VOC characteristics, concentration, and airflow design.33
     In the  surface condenser, the emission stream is passed by a tube or manifold containing
a chilled liquid. When the emission stream contacts the chilled surface, the VOCs condense, then
drain to storage or disposal.31 No contact occurs  between the coolant and the emission stream,
thus the condensate is strictly composed of the species condensing on its surface.
     Contact condensers typically condense the VOC by spraying a  liquid (such as  water) that
is at ambient temperature or slightly chilled liquid directly into the gas stream in a simple spray
chamber  or  similar device/1   In contrast to  the  surface  condenser, the  contact  condenser
                                                                *\
CH-92-02                                    4-17

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intimately mixes the cooling agent with the VOC to be removed. The VOC and coolant mixture
is collected for reprocessing or disposal.
     Condensers are widely used as raw material  and/or product recovery devices.33  Often,
condensers are not used alone but are used in conjunction with other VOC removal devices.
Condensers  may be  placed upstream of absorbers, adsorbers, or incinerators  to reduce the
material  load  entering these more  expensive  or sensitive  devices.   Used in  this way, the
condenser can remove components harmful to the other devices (such as chlorine  or sulfur) or
remove valuable components that would  otherwise be destroyed.
     Condensers can  be  used  alone for controlling  waste  streams containing high VOC
concentrations (>5,000 ppmv).  In these cases, condenser VOC removal efficiencies usually vary
between 50 and 95 percent.33 Row rates  up to about 2,000 scfm are typical for condensers used
as emission control devices. At larger flowrates, prohibitively large heat transfer areas become
required.33
     Surface and contact condensers each have merits relative to the other. Surface condensers
may more easily recover  marketable condensate while minimizing waste disposal problems.
However, surface condensers are more expensive to operate than contact condensers.31  Contact
condensers are generally less expensive, more flexible, and more efficient in removing VOC than
are  surface condensers. Condensate  from contact condensers cannot be reused and may require
wastewater treatment prior to disposal.31
     The condenser does not remove VOCs as efficiently as other VOC control devices  such as
the  incinerator, adsorber, or absorber. As the sole method of VOC control, the condenser may
not  be  sufficient for removing VOCs from the waste stream, particularly at high airflows. The
condenser may be best applied as an  auxiliary VOC removal device placed upstream from other
removal devices and used  to remove moisture,  substances (such as chlorine or sulfur)  harmful
to other devices, or to recover easily  captured materials that would  be destroyed if an incinerator
were used downstream.
     A disadvantage of the condenser is that VOC outlet concentrations below 10,000 to 20,000
ppmv are difficult to achieve due to saturation conditions. If extremely low outlet concentrations
are  necessary, condensation will usually be economically infeasible.33
CH-92-02                                    4-18

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      Because much of the process equipment in paint and ink manufacturing facilities handles
a variety of substances with a wide range of VOC concentrations and components, condensers
would not be a feasible control device.34

4.4.3  Combustion Techniques

      The most common combustion technique is incineration.  Incinerators remove VOCs from
the emission stream by combustion, converting the VOCs into carbon dioxide, water vapor,  and
small amounts of  other compounds.   The VOC-laden emission stream enters the incinerator
chamber where the VOCs are burned, sometimes with the assistance of a catalyst. Incinerator
performance is a function of the waste gas heating value, inert content, waste gas water content,
and the amount of excess combustion air.31  Other design variables include degree of mixing,
residence time, and the type of auxiliary burning used.
      In contrast to adsorbers, absorbers, or condensers, incinerators do not recover the VOC for
reuse; however, heat is generated during the combustion reaction, and this heat may be recovered
for use elsewhere  in  the  plant.   The two most  common means of  incineration are thermal
incineration and catalytic incineration, in which the emission streams are ducted to a combustion
device primarily designated for control of organic  emissions.  The thermal incinerator  and
catalytic incinerator are illustrated in Figures  4-4 and 4-5.  In a third means of incineration, the
emission stream can be vented  to the combustion chamber  of an industrial boiler or process
heater. The destruction method  efficiency of a boiler or process heater is similar to that of the
thermal incinerator. The distinction between the two  devices is that the boiler or process heater
is designated primarily as a heat source, and  secondarily as a control device.
      Both thermal and catalytic incinerators are often well-suited for removal of VOCs from
emission streams. Heat recovery is readily attained with both thermal and catalytic incinerators,
and this feature enhances the economy of using an incinerator rather than another VOC removal
device.32
      There  are some disadvantages to using incinerators.  Incinerators destroy the VOCs rather
than recovering them; in some cases, the energy benefit may not be as great as the lost value of
the  VOC.  Incinerators may not be practical choices for VOC removal if certain types  of VOCs
or other materials are burned. Incineration of VOCs that contain halogens or sulfur will produce
CH-92-02                                   4-19

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Gas In 
                                                               Catalytic  Bed
                    N
                    A
                    L
                                                         Gas Flow
                       Auxiliary Fuel Burner
                                                                                         	" Gas Out

                                                                                        To Heat Recovery
                                                                                           and Exhaust
Gas In 
                                  Figure 4-4.  Catalytic incinerator.
                           Burner  Plate-
                                                         Gas Flow
                            Fuel Supply
Gas Out
                                   Figure 4-5.  Thermal incinerator.


                                                  4-20

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 acidic compounds such as HCI or t^SO^  These streams are likely to require removal of the acid
 components by a scrubber unit, greatly adding to the cost of the VOC control system.30 Catalytic
 incinerators are very sensitive to materials  that can reduce the effectiveness of the catalyst.
 Phosphorous, lead, sulfur, and halogens can poison typical catalysts and severely affect their
 performance.33 If it is necessary to use catalytic incineration to control waste streams containing
 these materials, special catalysts or other measures must be employed. Liquid or solid particles
 that deposit on the catalyst and form a coating also reduce the catalyst's usefulness by preventing
 contact between the  catalyst and the VOC.3W3
      For safety reasons, both thermal and catalytic  incinerators may require large amounts of
 dilution air to reduce the VOC concentration in the emission stream.  Heating the dilution air to
 the ignition point of the VOC may be prohibitively expensive, particularly if a waste gas contains
 entrained  water  droplets  which must be  vaporized and  raised  to  combustion chamber
 temperatures.  However, it is unlikely that dilution air would be necessary at a paint and ink
 facility due to the relatively low VOC concentrations typically encountered.

 4.4.3.1  Thermal Incinerators
      Thermal incinerators pass the  emission stream through a combustion chamber where the
 VOCs are burned at temperatures typically ranging from 700 to  1,300C (1,300 to 2,370F).31
 Initially, burning is started with the assistance of a natural gas flame  or similar heat source. If
 the VOC in  the  emission stream has  a  sufficient heating value and concentration, ignition
 temperatures  can be  sustained by the combustion of the VOC,  and  the auxiliary heat can be
 turned off. If the ignition temperature cannot be maintained by combustion only, the auxiliary
 heat must be left on.  Auxiliary heat can be provided by fuels such as  natural gas,  and from
recovery of heat released during combustion. The waste gases from the thermal incinerator are
usually vented to  the atmosphere.
     Thermal incineration is widely used to control  continuous, dilute VOC emission streams
with constituents from a number of compounds.  Thermal incinerators can achieve VOC removal
efficiencies of 98 percent or greater depending on  the  design  of the equipment.   These
efficiencies may  not be  possible in cases  where the inlet VOC concentration is  less than
approximately 2,000  ppm.  For inlet concentrations lower than 2,000 ppm, the  performance of
an incinerator is more appropriately  indicated as  a maximum exit concentration of 20 ppmv.31
CH-92-02                                    4-21

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For safety considerations, VOC concentrations are usually limited to 25 percent of the lower
explosive limit (LEL) for the VOC. If the VOC concentration is higher in the waste gas, dilution
may be required.  Packaged, single-unit thermal incinerators  are available to control emission
streams with flow rates up to about 100,000 scfm.33
      Thermal incinerators, via combustion, remove particulates and other organics in addition
to VOCs, thus enhancing their utility.32
      One paint manufacturing facility currently uses regenerative thermal incineration to control
odors and VOC emissions.5 The contaminated gases enter the  system through an  upper ring-
shaped manifold. The air from this manifold is directed into inlet stoneware (i.e., ceramic) beds
which act as energy recovery chambers. As the gases pass through the ceramic beds  towards the
incineration chamber, they are heated to a temperature nearing that of incineration.  The VOC
present  in the fumes will autoignite  in  the  beds.   Oxidation is  completed in  the central
incineration chamber where a gas or oil burner maintains a preset temperature.  The purified air
then passes through a second set of ceramic beds which absorb much of the gas's internal heat.
The flow is periodically reversed to continually feed the inlet stream to the hot bed.  The energy
which is stored in the stoneware bed during the outlet mode is subsequently used to preheat inlet
gases. Thermal efficiencies can exceed 95 percent.  Although capital costs  are high, they are
generally offset by a decreased need for auxiliary fuels.5'38

4.4.3.2  Catalytic Incinerators
      Catalytic incinerators are similar to thermal incinerators in that they eliminate  VOCs from
the waste stream via combustion. The distinguishing feature of a catalytic incinerator is the
presence of a catalyst (such  as platinum  or copper oxide) that allows the  VOC  combustion
reaction to take place at a temperature lower than the normal ignition temperature exhibited by
the VOC in air.31'33 By allowing the combustion reaction to take place at lower temperatures than
required for a thermal incinerator, less preheating of the emission stream from  auxiliary heat is
necessary, and significant fuel  savings are  achieved.
      In the  catalytic incinerator,  the emission  stream is preheated to approximately 320C
(600F) by recovered incinerator heat or by auxiliary burners.31  The preheated emission stream
is  passed  through the catalyst bed where combustion takes  place  on the activated  catalytic
surface.  The incinerators are operated from 320 to 650C (600 to l,2pOF), significantly lower
CH-92-02                                    4-22

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 than operating temperatures for thermal incinerators.  Higher temperatures can shorten the life
 of the catalytic bed. Properly operated catalytic converters can be satisfactorily operated for three
 to five years before replacement of the catalyst is necessary.33
      Catalytic incinerators have been applied to emission streams in many industries. Packaged,
 single-unit catalytic incinerators are available to control emission streams with flow rates up to
 about 100,000 scfm at efficiencies greater than 98 percent.32
      Low energy costs make the catalytic incinerator an important option for removal of VOC
 from emission streams; however, the catalytic incinerator cannot be used in as many applications
 as the thermal incinerator.  Catalytic materials can be quickly degraded by  many elements or
 compounds present in industrial emissions such as sulfur or particulates. Many of these materials
 are burned without difficulty in thermal incinerators.
      Some of the  issues which must be addressed when  applying  catalytic  incineration
 techniques are the incinerator's ability to handle the large variety of vapor phase organics that
 would be emitted from a paint and ink facility,  the wide variety of organic concentrations in
 process waste streams, and the changing speciation of organic emissions that would occur with
 adjustments of paint  and ink product formulations over  time.34   In many cases, one catalyst
 cannot handle all of the waste stream  variations encountered  in paint and ink manufacturing
 facilities.

 4.4.3.3  Industrial Boilers and Process Heaters
      In  industrial boilers and process heaters, hot combustion gases (typically from natural  gas
 or fuel oils) are placed into contact with heat transfer tubes that contain water or process liquids.
 Heat from the combustion gases is transferred across the tube to the liquids to produce steam or
 to heat  the  process material.   In addition to their function as steam generators and heaters,
 industrial boilers  and process heaters are currently used in industry to control organic emissions
 from manufacturing operations.  Both devices are most  applicable where high heat recovery
 potential exists.31
     Because the combustion of organic emissions can affect the performance of a boiler,  the
emission characteristics must be considered.  Such factors as variable flow rates, variable heat
contents, pressure, and the presence of corrosive compounds may require changes in the operation
of the boiler or heater.  Boilers currently operating in a facility may nc*t be able to control all of
CH-92-02                                      4-23

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the emissions from the plant, and an  additional incineration device may  be required.  When a
new boiler or other incineration device is to be purchased, the operating and design parameters
can be calculated to fit specific facility needs.31'38
      If a boiler or process heater is applicable and available  for use as a control device, they
may provide excellent control efficiencies comparable to a thermal incinerator, while reducing
capital and operating costs.   The only capital  investments involved are  those associated with
capture system ductwork, fans, and boiler or  process heater modifications required to direct
emissions to the boiler/process heater.  One difficulty associated with boilers and process heaters
is that they must operate continuously and concurrently  with  the emission  source unless other
control devices or strategies  are available.31'38
CH-92-02                                     4-24

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4.5 REFERENCES

1.    1987 Census  of Manufacturers. Industry  Series. Paints  and Allied Products.   U.S.
     Department of Commerce. Washington, D.C.

2.    1987 Census of Manufacturers. Industry Series. Miscellaneous Chemical Products.  U.S.
     Department of Commerce. Washington, D.C.

3.    Title 35: Environmental Protection, Subtitle B: Air Pollution, Chapter I: Pollution Control
     Board, Subpart AA: Paint and Ink Manufacturing, Section 215.624.  Rules and Regulations,
     Illinois Environmental Protection Agency.

4.    ICI trip report and facility information.

5.    PPG trip report and facility information.

6.    Perry & Derrick trip report and facility information.

7.    Borden trip report and facility information.

8.    Titman, H., "A review of Experiments on the Ignition of Inflammable Gases by Frictional
     Sparking,"  Transactions of the Institution of Mining Engineers, 115(7):536-557, 1956.

9.    Memo from Glanville, J. and S. Edgerton,  Midwest Research Institute, to Magnetic Tape
     Project File, Project 83/18, U.S. Environmental Protection Agency, Emission Standards
     Division, Office of Air Quality Planning and Standards. December 17, 1986.  Calculated
     Control Efficiency of Covers on Mix Tanks.

10.  U.S. Environmental Protection Agency. Polymeric Coating of Supporting Substrates-
     Background Information for Promulgated Standards, EPA-450/3-85-022b.  Office of Air
     Quality Planning and Standards. Research Triangle Park, NC. 1989.

11.  Zoga, Christ, "Horizontal Media Milling With Computer Controls," reprinted from Modern
     Paint and Coatings, by Premier Mill Corporation, New York, NY.  June  1984.

12.  Sneeringer, John R., "Consider the Horizontal Mill," reprinted from CPI100, by Premier
     Mill Corporation, New York, NY May/June 1986.

13.  U.S. Environmental Protection  Agency.   Guides to Pollution Prevention:   The Paint
     Manufacturing Industry, EPA-625/7-90-005.   Risk Reduction Engineering  Laboratory.
     Cincinnati,  OH.  1990.

14.  Jacobs Engineering Group,  Inc.  Waste Audit Study: Paint Manufacturing Industry,
     prepared for Toxic Substances Control Program, California Department of Health Services.
     April 1989  revision of original study report.
01-92-02                                   4-25

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15.   Quackenbush, Ivan C, "Points on Picking the Right Media for Small-Media Mills,"
     reprinted from American Paint  & Coatings Journal for the Quackenbush  Company.
     December 13, 1982.

16.   "Bugs? In your Bead Mill," eleventh printing.  Pamphlet from the Quackenbush Company,
     Palatine, IL, 1985.

17.   Permit information retrieved from the State of Ohio Environmental Protection Agency.

18.   U.S. Environmental Protection Agency. Surface Coating of Metal Furniture-Background
     Information for Proposed Standards.  EPA-450/3-80-007a. Office of Air Quality Planning
     and Standards. Research Triangle Park, NC.  1980.

19.   "Powder Coatings," pamphlet prepared for The Powder Coating Institute, Alexandria, VA,
     1990.

20.   Bocchi,  Greg, "Powder Coating Advantages," reprinted from: Products Finishing for The
     Powder  Coating Institute, Gardner Publications, Inc, 1991.

21.   "Powder Coatings Bloom," Chemical Marketing Reporter, 240(8): 9,12, 1991.

22.   "Coating Materials," pamphlet no.: TD 100-5, BUSfKS Training Division, Franklin Park, IL.

23.   Pennsylvania Department of Environmental Resources.  Hazardous Waste Minimization
     Guidance Manual for Pennsylvania's Vehicle Maintenance Industry. Center for Hazardous
     Materials Research.  Pittsburgh, PA.  1987.

24.   -U.S. Environmental Protection Agency. Radiation-Curable Coatings. EPA-600/2-91-035.
     Control Technology Center. Research Triangle Park, NC. 1991.

25.   Kohl, Jerome, Jeremy Pearson, Michelle Rose,  and Philip Wright, "Managing and
     Recycling Solvents in the Furniture  Industry," reprinted for Pollution Prevention Pays
     Program, January 1988.

26.   Brantley,   Michael,   "Volatile  Organic  Compound  (VOC)   Emission   Reduction
     Implementation,"  from  the  Proceedings  of  Finishing  '89 Conference,  Society  of
     Manufacturing Engineers, Oct. 16-19, Cincinnati, OH, 1989.

27.   U.S. Environmental Protection Agency.  Glossary for Air Pollution Control of Industrial
     Coating Operations, EPA-450/3-83-013R. Second Edition.  Office of Air Quality Planning
     and Standards. Research Triangle Park, NC.  1983.
CH-92-02                                  4-26

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28.  Ross, Vincent, "Waste Reduction-Pollution Prevention in the Furniture Industry:  New
     Technologies for Reducing Finishing Wastes and VOC Emissions," Proceedings of the
     Conference "Waste Reduction-Pollution Prevention:  Progress and Prospects within North
     Carolina." North Carolina Department of Natural Resources and Community Development.
     1990.

29.  Roos, R.A., G.P. Fenton,  and R.W. Penyman.   "Containment of Fumes  and Vapors
     Generated in the Aluminum Rolling Process" in Lubrication Engineering, Volume 40., No.
     10. pp.  621-626.   American Society of-Lubrication Engineers.  October 1984.

30.  OAQPS Control Cost Manual. EPA-450/3-90-006.  Fourth Edition.  Office of Air Quality
     Planning and Standards, Research Triangle Park, NC.  January 1990.

31.  Control  Techniques for Volatile Organic Compound Emissions from Stationary Sources.
     EPA-450/3-85-008.  Third  Edition. Office of Air and Radiation  and the Office of Air
     Quality  Planning and Standards.  Research Triangle Park, NC.  1986.

32.  Radanof, R.M. "VOC Incineration and Heat Recovery-Systems and Economics" in Third
     Conference on Advanced Pollution Control for the Metal Finishing Industry.  EPA-600/2-
     81-028.   U.S. Environmental Protection Agency, Industrial Environmental Research
     Laboratory.  Cincinnati, OH.  February 1981.

33.  Handbook:  Control Technologies for Hazardous Air Pollutants.  EPA-625/6-86-014.  Air
     and Energy Engineering Research Laboratory. Research Triangle Park, NC.  September
     1986.

34.  Cleveland RACT Document, PPG Industries, Inc., Cleveland, OH.  July 1987.

35.  Ehrler, A.J.  "Closed-Loop Absorption for Solvent Recovery" in Metal Finishing, Volume
     85, No.  11. pp. 53-56. November  1987.

36.  Heim, C.J., "Volatile Organic Emission Control in the Aluminum Industry Using Fluidized
     Bed Carbon Adsorption," Proceedings of the Workshop on Characterization  and Control
     of Aluminum Cold Rolling Mill Emissions, The Aluminum Association. 1983.

37.  Barten, A.E.  "A New System for Separation and Recycling of Mineral Oils from Process
     Fumes," in Lubrication Engineering, Volume 38, No. 12. pp. 754-757. American Society
     of Lubrication Engineers.  December 1982.

38.  U.S. Environmental Protection Agency. Control of VOC Emissions from Polystyrene Foam
     Manufacturing, EPA-450/3-90-020.  Office of Air  Quality Planning and Standards.
     Research Triangle Park, NC. 1990.
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                                    CHAPTER 5
                            CONTROL COST ANALYSIS

5.1 INTRODUCTION

     This chapter presents the estimated costs for controlling VOC emissions from paint and ink
manufacturing facilities.  The VOC reduction methods discussed in Chapter 4 are summarized
in Table 5-1, along  with their applicability and current use in paint  and ink manufacturing
industries.  Of the methods presented in Table 5-1, the following are both applicable and used
by paint and ink manufacturing plants for reducing emissions: tank lids, horizontal media mills,
equipment  cleaning devices,  improved operating  practices,  recycling techniques,  product
reformulation, capture devices, and thermal incinerators.  These methods are presented with their
available associated costs in subsequent sections in this chapter.

5.2 EQUIPMENT OR PROCESS MODIFICATIONS

     Tank lids,  horizontal  media mills, and equipment  cleaning devices  all  reduce VOC
emissions by modifying manufacturing equipment.

5.2.1  Equipment Tank Lids

     The  most common method of controlling VOC  emissions during the paint and ink
manufacturing process is the use of equipment tank lids.   Mix and blend tanks are a primary
source  of manufacturing VOC emissions  because  the solvent-containing materials spend a
significant amount of time in this equipment.  All of the States  that regulate paint and ink
manufacturing facilities require that all open-top equipment be covered during the manufacturing
process. In most cases, the State or local agencies have adopted rules defining process controls,
such as lids, as RACT for paint and ink manufacturing industries (See Tables 3-2 and 3-3).
     Lids reduce VOC emissions by retaining the solvent in the product in the mix tank.  This
action serves to keep the product fluid and workable, thus  preventing future  solvent  additions.
                                                             "v
CH-92-02                                   5-1

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   TABLE 5-1.  APPLICABEL1TY AND USE OF VOC EMISSION REDUCTION
                  METHODS IN PAINT AND INK FACILITIES
Reduction Method
Applicability to Industry
Current Use in Industry
Tank Lids
Horizontal Media Mills
Equipment Cleaning
Devices (rubber wipers,
high-pressure spray heads,
Teflon lined tanks, pigs,
automatic tub washers)


Improved Operating
Practices

Recycling Techniques

Product Reformulation
 Used extensively
 Considered by States as
 RACT
 Not normally vented to
 control devices

 Require low viscosity
 products
 Highly efficient, closed
 milling system

 Efficiency of use depends on
 product manufactured and
 level of employee training
 Some installations may
 require equipment
 modifications

 Used extensively


 Used extensively

 Applicability depends on end
 use and customer
 requirements
 Some States have regulations
 requiring lower VOC
 coatings
  Reformulation requires
 extensive research and
 development
Most facilities
Some facilities
Some facilities
Most facilities

Most facilities
Many facilities
Capture Devices
  Applicable according to data
  collected from other similar
  industries
  Capture devices are
  commonly used for
  particulate control
Extent of use is unknown.
Only one facility with
documented use.
                                   (Continued)
                                       5-2

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     TABLE 5-1. APPLICABILITY AND USE OF VOC EMISSION REDUCTION
                  METHODS IN PAINT AND INK FACILITIES (continued)
 Reduction Method
Applicability to Industry
Current Use in Industry
 Carbon Adsorbers
 Absorbers
  Not applicable to industry
  because of low VOC inlet
  concentrations and variety
  of contaminants in
  wastestream

  Not applicable to industry
  because of costs  associated
  with low VOC inlet
  concentrations
  May be used by  very
  specialized plants
Few facilities*
Few facilities*
 Condensers
 Thermal Incinerators
 Catalytic Incinerators
 Industrial Boilers and
 Process Heaters
 Not applicable to industry
 because of efficiency and
 costs associated with waste-
 stream concentration and
 composition variability
 May be used in very
 specialized plants

 Applicable, capable of
 destroying contaminants in
 process wastestreams

 Not applicable to industry
 because of low VOC inlet
 concentrations and variety
 of contaminants in
 wastestream

 Applicable according to data
 collected from other similar
 industries
Few facilities*
Few facilities*
No documented use found
No documented use found
"Few - Documentation shows use by less than 20 facilities.
                                        5-3

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Lids also reduce excess VOC emissions entering the work area.  Because the primary objective
of tank lids is to keep the solvent in the product, ducting lids to control devices is uncommon.
     The lids that are currently  used in industry for covering process mix tanks can be either
plastic, wooden, aluminum, or stainless  steel.1"4  Plastic lids consist of a thin sheet of plastic
which is placed across the tank in question and then taped or otherwise attached to the side of
the tank.  Normally, plastic lids are used for one product batch and then are thrown away. Other
facilities use homemade plywood lids. After several uses, the underside of the plywood becomes
saturated with product and the lid must be discarded.  The most frequently used lids are those
constructed of either aluminum or stainless steel. Flat aluminum lids, which are made by a sheet
metal contractor, cost $20 to $25  for drums and $300 for  a 250 gallon mix tank.   Similar
stainless steel lids often cost twice as much as the aluminum lids.2  The efficiency of mixer lids
has been estimated to be approximately 40 percent  (See discussion of lid efficiency in  Chapter
4).5  This value represents the ratio of the emission reduction to  the uncontrolled emissions.
     Using the lid efficiency of 40 percent, assuming an average batch size of 250 gallons, and
employing some additional data from the PPG RACT study (discussed below), the cost efficiency
of equipment lids can be determined as indicated in Table 5-2.
     As part of their RACT  determination, the PPG facility determined total VOC emissions
released from each of their manufacturing buildings.6  In 1983, Building 19  used nine portable
mix  tanks with agitators to accomplish premix operations.  During that year, the tanks emitted
25 tons of VOC to the atmosphere.  Assuming a normal operating schedule of 24  hours a day,
5 days per week, and 52 weeks per year, this calculates to approximately 0.89 pound of VOC
per hour from each tank.1'6   This factor is specific to the PPG facility and its  products, as
emission rates will vary with many factors including the type of product manufactured,  the type
of solvent used, and the capacity of the manufacturing equipment.

5.2.2 Horizontal Media Mills

     Installing horizontal media mills is a second way to reduce VOC emissions generated
during the manufacturing process.  Although these mills are more efficient milling devices than
mix  tanks and can be considered nearly 100 percent effective in controlling VOC emissions, they
cannot be used to manufacture every type of paint and ink.
                                                                 V
CH-92-02                                     5-4

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               TABLE 5-2. EQUIPMENT COVER COST FIGURES'
   Cost Item (in dollars)            Number         Cost             Total Cost

   Aluminum equipment covers       9               300              2,700
   (replaced annually)

   Cost Efficiency
    Total Annualized Operating Cost for Equipment Lids                  2,700

   Total Emissions
    25 tons/year at 40% control efficiency = 10 tons/year

   Cost Efficiency                                                    $270/ton
   'Cost figures and were taken from References 1, 2, and 6 and are assumed to be current dollars.
CH-92-02                                   5-5

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     A typical 15 liter horizontal media mill with a 20 horsepower motor can produce 13 to 78
gallons  of product per hour depending on the type of product produced.7  With an average
production capacity of 50 gallons per hour, a horizontal mill will produce 250 gallons of product
in 5 hours.  Similar production quantities in other equipment may take 15 hours of processing
time.  These numbers would indicated that horizontal media mills are approximately three times
as efficient as other equipment (e.g., a 250 gallon mix tank equipped with a high-speed disperser
or a 15  liter open-top sandmill).1'2'8
     Table 5-3 presents cost information  for a horizontal media mill.  To determine the cost
effectiveness of the process change as a control measure, the annual cost of the control equipment
(or mills) it replaces must first be subtracted from  the cost of a horizontal mill. This incremental
cost divided by the amount of VOC emissions reduced would indicate the cost effectiveness of
the process change.

5.2.3  Equipment Cleaning Devices

     Many equipment cleaning processes performed in the paint and ink manufacturing industry
use organic solvents as the cleaning agent. Although equipment cleaning is a major source of
VOG  emissions, it is difficult to determine the overall  efficiency or impact that equipment
cleaning devices have on reducing VOC emissions from equipment cleaning processes because
no data is available which quantifies these process emissions.  Therefore, an equipment cost
efficiency cannot be calculated.
5.3 VOC EMISSION REDUCTION METHODS

     Two  additional  methods which may be  used to reduce VOC emissions during the
manufacturing process are improving operating practices and recycling.  Discussions of both of
these methods are included in Chapter 4. Both of these techniques are very popular within the
paint and ink manufacturing industry because they are easily implemented at low cost. The only
costs involved with either of these techniques are those for operator training.  In return, solvent
emissions and waste can  be significantly decreased.  One manufacturer of trade sales paints in
CH-92-02
                                          5-6

-------
               TABLE 5-3.  HORIZONTAL MEDIA  MILL COST FIGURES
    Cost Item (in dollars)
Factor
Cost
    Capital Costs:
     Equipment, Installation, and Indirect
     Cost Totals (Not included in total
     below)
    Annualized Costs:
     Annual Capital Cost Recovery
     (15 year life, 10% effective
     interest rate)
    Direct Operating Costs:
     Utilities
     Operating Labor
     Operating Supervision
As estimated
As estimated
0.059/kWhr
12.96/hr
15% of operator labor
  180,000
   23,670
    1,830
   10,110
    1,520
     Maintenance
       Labor
       Materials
12.96/hr                        3,370
100% of maintenance labor       3,370
    Indirect Operating Costs:
     Overhead

     Property Tax
     Insurance
     Administration
    GRAND TOTAL (Annualized Cost)
0.60 (operating labor +
maintenance)
1% of capital cost
1% of capital cost
2% of capital cost
   11,020

    1,800
    1,800
    3,600
   62,090
   'Original cost figures were taken from References 2 and 6 and are in current dollars. Factors are adapted from
   Reference 9 (fabric filters).
CH-92-02
                                                5-7

-------
North Carolina reduced waste solvent production from 25,000 gallons to 400 gallons in the
course of a year by implementing a recycling program.  In  addition to reducing  ultimate
hazardous waste disposal costs, the facility also reduced the amount of virgin solvent purchased.10
These actions, in turn, will reduce overall emissions.

5.4 PRODUCT REFORMULATION

     It is extremely difficult to assess the costs associated with product reformulation.  The
primary cost is the research and development that is  required by each facility to reformulate
current products using lower VOC raw materials.  Although waterbornes, powders, radiation-
curables, and higher-solids formulations are currently available, they may not meet the specific
end-user requirements and needs.  In addition to absorbing development costs, industries wishing
to reformulate must also invest in pilot studies, product testing, and additional operator training.
Reformulated coatings often act differently than solvent based products and require increased
levels of process control.10

5.5 CAPTURE DEVICES

     According to data collected from the polymeric coating industry and from the Cleveland
PPG facility, capture devices are expected to be applicable to the paint and ink manufacturing
industry.6'11  However, only one paint facility is known to have a plant-wide capture system and
the capital and operating costs for this facility are unavailable.6 The costs  associated with a
complete capture system are relatively inexpensive when compared to  those of a control device.

5.6 THERMAL INCINERATION1'6

     The costs associated with thermal incineration presented here are based on actual costs
incurred by one facility known to employ thermal incineration as their control technique.  The
costs  are  based on purchase, installation, and operation  of  two thermal incinerators  at the
Cleveland PPG Industries, Inc., facility.  One incinerator, the REECO I, controls VOC emissions
from the manufacturing facility.  A second REECO incinerator, REECO n, controls emissions
CH-92-02                                     5-8

-------
from the PPG paint laboratory also located at the Cleveland site.  Both of the nine-chamber fume
incinerators were originally installed as odor control devices.
     The 95 percent destruction and removal efficiency of the incinerators depends  on the
capture efficiency of the ventilation system.  A study conducted in 1983 indicated that plantwide
emissions for the Cleveland facility are 1,085.9 tons per year. Of these releases, 25 tons per year
are lost to  the  atmosphere.    This  represents  a fugitive  emission  capture efficiency  of
approximately 96 percent   The capital and operating  costs and cost efficiency for thermal
incineration at the Cleveland PPG facility are presented  in Table 5-4.
 CH-92-02
                                            5-9

-------
          TABLE 5-4. CLEVELAND FACILITY THERMAL INCINERATION
                                      COST FIGURES1
   Cost Item (in dollars)
REECOI
REECOn
Total
   Capital Costs:

     Equipment, Installation, and Indirect     7,071,760
     Cost Totals (Not included in total
     below)

   Annualized Costs:

     Annual Capital Cost Recovery          1,150,897
     (10 year life, 10% effective
     interest rate)

   Direct  Operating Costs:
                   5,407,975
                     880,123
    Cost Efficiency:
     Total Annualized Operating Cost for Incinerators

    Total Emissions:
     1085.9 tons/year at an overall efficiency of 91.2% = 990.3 tons/year

    Cost Efficiency:
                    12,479,735
                     2,031,020
Utilities
Operating Labor
Operating Supervision
(based on 15% of operator
labor)
Maintenance - Contracted:
Labor
Materials
Indirect Operating Costs:
Overhead
Property Tax (pollution
abatement equipment is
exempt)
Insurance (1% of capital cost)
Administration (2% of capital
cost)
GRAND TOTAL
522,888
25,666
3,827
16,886
16,886

20,488
-0-
70,700
141,400
1,969,638
530,430
25,666
3,827
16,886
16,886

20,488
-0-
54,000
108,200
1,656,506
1053,318
51,332
7,654
33,772
33,772

40,976
-0-
124,700
249,600
3,626,144
                                        3,626,144
                                        S3,662/ton
  'Original cost figures were taken from Reference 1 and are assumed to have been 1987 dollan.  The costs were then  adjusted to 1992
  dollan using published Chemical Engineering cost indices.
CH-92-02
                                              5-10

-------
5.7 REFERENCES


1.    PPG trip report and facility information.

2.    ICI trip report and facility information.

3.    Perry & Derrick trip report and facility information.

4.    Borden trip report and facility information.

5.    Memo from Glanville, J. and S. Edgerton, Midwest Research Institute, to Magnetic Tape
     Project File, Project 83/18, U.S. Environmental Protection Agency, Emission Standards
     Division, Office of Air Quality Planning and Standards. December 17, 1986. Calculated
     Control Efficiency of Covers on Mix Tanks.

6.    Cleveland RACT  Document, PPG Industries, Inc., Cleveland, OH.  July  1987.

7.    "Supermill."  Product pamphlet from the Premier Mill  Corporation, New York, NY.

8.    Zoga, Christ, "Dispersion and Milling Methods to Increase Plant Productivity," reprinted
     from Modern Paint and Coatings, by Premier Mill Corporation, New York, NY. May 1989.

9.    U.S.  Environmental Protection Agency. Handbook: Control Technologies for Hazardous
     Air Pollutants, EPA-625/6-91-014.  Office  of Research and Development.  Washington,
     DC.  June 1991.

10.  Kohl, Jerome,  Phillip Moses,  and  Brooke Triplett. Managing and Recycling Solvents.
     North Carolina Practices, Facilities, and Regulations.  December 1984.

11.  U.S.  Environmental Protection Agency.  Polymeric Coating of Supporting  Substrates--
     Background Information for Promulgated Standards, EPA-450/3-85-022b. Office of Air
     Quality Planning  and Standards. Research Triangle Park, NC.  1989.
 CH-92-02                                   5-11

-------
                          APPENDIX A
             LISTS OF FACILITIES WITH ANNUAL SALES
                   GREATER THAN $1 MILLION
CH-92-02                          A-1

-------

-------
    TABLE A-l. PAINT AND ALLIED PRODUCTS FACILITIES (SIC 2851) WITH
                  ANNUAL SALES GREATER THAN $1  MILLION

                                                                                     Sales in
                 Name                                   Address                    $ Millions
 Aervoe-Pacific Co. Inc.
 AExcel Corp.
 Agri-Blend Inc.
 Akron Paint & Varnish Inc.
 Akzo Coatings Inc. Reliance Universal Inc.
 Akzo Coatings Inc. Akzo Resins & Vehicles
 Akzo Coatings Inc.
 Allentown Paint Manufacturing Co.
 Also Indus Inc. Morton Paint Co.
 Ameritone Paint Corp.
 Ameron Inc. Enmar Finishes Div.
 Ameron Inc. Ameron Protective Coatings
   Div.
 Amsterdam Color Works Inc.
 Aspen Paints
 Atlas Coating Corp.
 Automotive Finishes Inc.
 Baker Sealants & Coating
 Barrett Varnish Co.
 Bee Chem Co.
 Behr Process Corp.
 Benjamin Moore & Co.
 Bennette Paint Manufacturing Co.
 Best Bros Paint Manufacturing Co.
 Beverly Manufacturing Co. (Los Angeles)
 Birk Paint Manufacturing Inc.
 Blue Ridge Talc Co. Inc.
 Brewer Chem Corp.
 Brod-Dugan Co.
 Bruning Paint Co.
 Burkes Paint Co. Inc.
 Buten Paint & Wallpaper
 Cabot Stains
 Cal Western Paint Corp.
 Calbar Inc.
 California Products Corp.
 Carbit Paint Co.
 Carboline Co.
 Cardinal Color Co.
 Cardinal Indus Finish Inc.
 Century Chem Co.
PO Box 485, Gardnerville NV 89410
7373 Production Dr, Mentor OH 44060
PO Box 957, Rowlett TX 75088
1390 Firestone Parkway, Akron OH 44301
1930 Bishop Ln, Louisville KY 40218
21625 Oak St, Matteson EL 60443
1600 Watterson Towers, Louisville KY 40218
PO Box 597, Allentown PA 18105
Box 6208, Canton OH 44706
PO Box 190, Long Beach CA 90801
PO Box 9610, Little Rock AR 72219
201 N Berry St, Brea CA 92621

1546 Stillwell Ave, Bronx NY 10461
1128 SW  Spokane St, Seattle WA 9J3134
820 E 140th St, Bronx NY 10454
6430 Wyoming Ave, Dearborn MI 48126
234 Suydam Ave, Jersey City NJ 07304
1532 S 50th Ct, Cicero EL 60650
2700 E 170th St, Lansing IL 60438
PO Box 1287, Santa Ana CA 92702
51 Chestnut Ridge Rd., Montvale NJ 07645
PO Box 9088, Hampton VA 23670
PO Box 2056, Sinking Spr PA 19608
9118 S Main St, Los Angeles CA 90003
230 Kearny Ave, Jersey City NJ 07305
PO Box 39, Henry VA 24102
PO Box 48, Honolulu ffl 96810
2145 Schuetz Rd, St. Louis MO 63146
601 S Haven, Baltimore, MD 21224
727 S 27th St, Washougal WA 98671
5000 Ridge Ave, Philadelphia PA 19128
100 Hale St, Newburyport MA 01950
11748 Slauson Ave, Santa Fe Spr CA 90670
2626 N Martha St, Philadelphia PA 19125
PO Box 569, Cambridge MA 02139
927 W Blackhawk St, Chicago EL 60622
350 Hanley Indus Ct, St. Louis MO 63144
50-56 1st  St, Paterson NJ 07524
1329 Potrero Ave, South El Mon CA 91733
5 Lawrence St, Bloomfield NJ 07003
  11
  20
  1*
  4*
300
  13
550*
  4
  3
  40
  15
112

  7
  4
  7*
  4
  5
  3
  66
 33*
370*
  5
  1
  2
  2
  9
  50
  15
  30
  3
  40
  30
  5
  4
  32
  5
  65
  7
  18
  5
                                          (continued)
CH-92-02
                                             A-2

-------
   TABLE A-l.  PAINT AND ALLDZD PRODUCTS FACILITIES (SIC 2851) WITH
                  ANNUAL SALES GREATER THAN $1 MILLION (continued)
                Name
                 Address
 Sales in
$ Millions
Certified Coating Products
CF Jameson & Co. Inc.
Charles A Crosbie Labs Inc.
Chemical Technology Labs Inc.
Chemical Coating Corp.
Ciba-Geigy Corp. Drakenfeld Colors
Clement Coverall Inc.
CM Athey Paint Co.
Coatings & Chems Corp.
Colonial Refining & Chem Co.
Columbia Paint Corp.
Columbia Paint Co.
Colwell Gen Inc.
Commercial Chem Co. Inc.
Con-Lux Coatings Inc.
Cook & Dunn Paint Corp. Pure All Paint
   Coatings Co.
Cook & Dunn Paint Corp.
Cook & Dunn Paint Corp. Adelphi
   Coating
Cook Paint & Varnish Co.
Coronado Paint Co. Inc.
Cosan Chem Corp.
Cotter & Co. Gen Paint & Chem Co.
Courtlaulds Coatings USA Inc.
Cowman & Campbell
CP Inc.
Crest Chem Indus Ltd.
Crosby Coatings  Inc.
CWC Indus Inc.
Dalys Inc.
Dampney Co. Inc.
Daniel Products Co.
Davis Paint Co.
Davlin Paint Co. Inc.
DC Franche & Co.
De Boom Paint Co.
Dean & Barry Co.
Decratrend Paints
Deft Inc.
2414 S Connor Ave, Los Angeles CA 90040
PO Box 197, Bradford MA 01835
PO Box 3497, Van Nuys CA 91407
12150 S Alameda St, Lynwood CA 90262
7300 Crider Ave, Pico Rivera CA 90660
PO Box 519, Washington PA 15301
PO Box 557, Camden NJ 08101
1809 Bayard St, Baltimore MD 21230
3067 N Elston Ave, Chicago IL 60618
20575 Ctr Ridge Rd, Cleveland OH 44116
PO Box 2888, Huntington WV 25728
PO Box 4569, Spokane WA 99202
PO Box 329, Fort Wayne IN 46801
PO Box 2126, Santa Ana CA 92707
PO Box 847, Edison NJ 08818
700 Gotham Ave, Carlstadt NJ 07072

700 Gotham Parkway, Carlstadt NJ 07072
700 Gotham Parkway, Carlstadt NJ 07072

PO Box 419389, Kansas  City MO 64141 
PO Box 308, Edgewater FL 32032
400 14th St, Carlstadt NJ 07072
201 Jandus Rd., Gary JL  60013
PO Box 1439, Louisville, KY 40201
PO Box 70328,  Seattle WA 98107
PO Box 333, Connersville IN 47331
PO Box 85, New Lenox IL 60451
PO Box 1038, Chico CA 95927
2686 Lisbon Rd, Cleveland OH 44104
3525 Stone Way N, Seattle WA 98103
85 Paris St, Everett MA 02149
400 Clarcmont Ave, Jersey City NJ 07304
1311 Iron St, Kansas City MO 64116
700 Allston Way, Berkely CA 94702
1401 W Wabansia Ave, Chicago EL 60622
645 Texas St, San Francisco CA 94107
296 Marconi Blvd, Columbus OH 43215
251 Mason Way, City of Indu CA 91746
17451 Von Karman Ave, Irvine CA 92714
    1
    1
    1
    3
    3
   28
    4
    6
    5
    3
    5
   17
   20
    4
   25
   20
    3

   100
   28
   10*
   120
   160*
    3
    5
    1*
    6
    5
    5
    4
   20
    13
    3*
    3
    5
    15
    17
    15
                                         (continued)
CH-92-02
                                            A-3

-------
   TABLE A-l.  PAINT AND ALLIED PRODUCTS FACILITIES (SIC 2851) WITH
                  ANNUAL SALES GREATER THAN $1 MILLION (continued)
                Name
                  Address
  Sales in
. $ Millions
Del Paint Corp.
Delrac Manufacturers of Bisonite Products
  Co. Inc.
DeSoto Inc.
Devoe & Raynolds Co.
Dexter Corp. Dexter Specialty Coatings Div.
Diamond Products Co. Inc.
DJ Simpson Co.
Dover Sales Co. Inc.
Duncan Enterprises
Dunn Edwards Corp.
Dupli-Color Products Co.
Duralac Inc.
Duron Inc.
Dye Specialties Inc.
Egyptian Lacquer Manufacturing
Ellis & Everard (US Holdings) Inc.
  Prillaman Chem Corp.
Elpaco Coatings Corp.
Emco Finishing Products Inc.
Empire State Varnish Co.
Environmental Coatings Inc.
Epoca Co.
Epoxy Coatings Co.
Evans Paint Inc.
Everseal Manufacturing Co. Inc.
Fabrionics Inc.
Parboil Co.
Farwest Paint Manufacturing Co. Inc.
Federated Paint Manufacturing Co.
Ferro Corp. Coatings Div.
Fiber-Resin Corp.
Fine Line Paint Corp.
Finishes Unlimited Inc.
Finnaren & Haley Inc.
Flecto Co. Inc.
Frank W Dunne Co.
Frazee Indus Inc.
Fredericks-Hansen Paint
Fuller O'Brien Corp.
3105 E Reno St, Oklahoma City OK 73117
PO Box 764, Tonawanda NY 14151

PO Box 5030, Des Plaines IL  60017
PO Box 7600, Louisville KY 40207
1 E Water St, Waukegan IL 60085
709 S 3rd Ave, Marshalltown IA 50158
PO Box 2265, South San Francisco CA 94080
PO Box 2479, Berkeley CA 94702
PO Box 7827, Fresno CA 93747
PO Box 30389, Los Angeles CA 90039
1601 Nicholas Blvd, Elk Grove Vi IL 60007
84 Lister Ave. Newark NJ 07105
10406 Tucker St, Beltsville MD 20705
PO Box 1447, Secaucus NJ 07096
PO Box 4449, Lafayette IN 47903
PO Box 4024, Martinsville VA 24112

PO Box 447, Elkhart IN 46515
470 Cresent St, Jamestown NY 14701
38 Varick St, Brooklyn NY 11222
6450 Hanna Lake  SE, Caledonia MI 49316
5 Lawrence St, Bloomfield NJ 07003
PO Box 1035, Union City CA 94587
PO Box 4098, Roanoke VA 24015
475 Broad Ave, Ridgefield NJ 07657
Route 130 S, Camargo IL 61919
8200 Fischer Rd, Baltimore MD 21222
PO Box 68726, Tukwila WA 98168
1882 S Normal St, Chicago IL 60616
PO Box 6550, Cleveland OH 44101
PO Box 4187, Burbank CA 91503
12234 Los Nietos  Rd, Santa Fe Spr CA 90670
PO Box 69, Sugar Grove IL 60554
2320 Haverford Rd,  Ardmore PA 19003
PO Box 12955, Oakland CA 94608
1007 41st St, Oakland CA 94608
PO Box 2471, San Diego CA  92112
PO Box 5638, San Bemardi CA 92408
450 E Grand Ave, South San Francisco CA 94080
     4
     3*

   408
   120*
    80
    18*
     5
     3*
    30
   150*
    50
     4
   150
     8
    10
    96*

     8
     2
     5
     5
     1
     1
     4*
    12
    13
    11
     3
     8*
    73*
    10
     5
     3
    25*
    20
     7
   100
    12
   140
                                          (continued)
CH-92-02
                                            A-4

-------
   TABLE A-l.  PAINT AND ALLIED PRODUCTS FACILITIES (SIC 2851) WITH
                  ANNUAL SALES GREATER THAN $1 MILLION (continued)
                                                                                    Sales in
                Name                                    Address                    $ Millions
Gilbert Spruance Co.
Given Paint Manufacturing Co. Inc.
GJ Nikolas & Co. Inc.
Glidden Co. Eastern Region
Glidden Co. Southwest Region
Glidden Co. Resin Div.
Gloss-Flo Corp.
Glyptal Inc.
Gordon Bartels Co.
Graham Paint &  Varnish Co.
Grow Group Inc. US Paint Div.
Grow Group Inc. Natl Aerosol Products Co.
Grow Group Inc.
Guardsman Products Inc.
Guardsman Chems Inc.
H Behlen & Brother Inc.
Hancock Paint & Varnish
Hanna Chem Coatings Inc.
Harco Chem Coatings Inc.
Harrison Paint Corp.
Hartin Paint & Filler
Hempel Coatings USA
Hentzen Coalings Inc.
Heresite Protective Coatings Inc.
Hoboken Paint Co. Inc.
Hoffers Inc.
Hy-Klas Paints Inc.
Hydrosol Inc.
ICI Americas Inc. ICI Paints
Illinois Bronze Paint Co.
Indurall Coatings Inc.
Industrial Coatings Intl.
Insilco Corp. Sinclair Paint Co.
International Paint Co. USA Inc.
International Paint Co. USA Inc. Southwest
   Div.
International Coatings Co.
Irathane Syss Inc.
IVC Indus Coatings Inc.
J Landau & Co. Inc.
Richmond St & Tioga St, Philadelphia PA 19134
111 N Piedras St, El Paso TX 79905
2810 Washington Blvd, Bellwood EL 60104
PO Box 15049, Reading PA 19612
PO Box 566, Carrollton TX 75011
1065 Glidden St NW, Atlanta GA 30318
135 Jackson St, Brooklyn NY 11211
305 Eastern Ave, Chelsea MA 02150
2600 Harrison Ave, Rockford IL 61108
4800 S Richmond St, Chicago IL 60632
831 S 21st St, St. Louis MO 63103
2193 E 14th St, Los Angeles CA 90021
200 Park Ave, New York NY 10166
3033 Orchard Vista Dr, Grand Rapids  MI 49501
13535 Monster Rd, Seattle WA 98178
Route 30 N Perth Rd, Amsterdam NY 12010
109 Accord Dr, Norwell MA 02061
PO Box 147, Columbus OH 43216
208 DuPont St, Brooklyn NY 11222
PO Box 8470, Canton OH 44711
PO Box 116, Carlstadt NJ 07072
201 Route 17 N, Rutherford NJ 07070
6937 W Mill Rd, Milwaukee WI 53218
PO Box 250, Manitowoc WI 54221
40 Indus Rd, Lodi NJ 07644
PO Box 777, Wausau WI 54401
1401 S 12th St, Louisville KY 40210
8407 S 77th Ave, Bridgeview IL 60455
925 Euclid Ave, Cleveland OH 44115
300 E Main St, Lake Zurich IL 60047
PO Box 2371, Birmingham AL 35201
7030 Quad Ave, Baltimore MD  21237
6100 S Garfield Ave, Los Angeles CA 90040
6001 Antoine, Houston TX 77091
PO Box 920762, Houston TX 77292

 13929 E 166th St, Cerritos CA 90701
PO Box 276, Hibbing MN 55746
PO Box 18163, Indianapolis IN 46218
PO Box 135, Carlstadt NJ 07072
 10
 7*
  2
140
 59
 30
  4
  5
  7
 10*
 30*
  5
413
190
  6
 10
 10
 25
  6
 20
  3
 15
 12
 15
 17
 47
  6
 30
 843
 25
  8
 14*
 100*
 50
  18

   5
  8*
   9
   4
                                          (continued)
CH-92-02
                                             A-5

-------
   TABLE A-l.  PAINT AND ALLDZD PRODUCTS FAdLITDZS (SIC 2851) WITH
                  ANNUAL SALES GREATER THAN $1 MILLION (continued)
                                                                                     Sales in
                Name           .                         Address                    $ Millions
James B Day & Co.
James Bute Co.
Jasco Chem Corp.
John L Armitage & Co.
Johnson Paints Inc.
Jones Blair Co. Oilman Paint &
   Wallcovering Div.
Kalcor Coatings Co.
Kaufman Products Inc.
Keeler & Long Inc.
Kelly-Moore Paint Co. Inc. Hurst Div.
Kelly-Moore Paint Co.
King Fiber Glass Corp. Fiber Resin
   Supply Div.
Komac Paint Inc.
Kop-Coat Co. Inc.
Kop-Coat Co. Inc. Pettit Paint Co.
Kurfees Coatings Inc.
Kwal-Howells Inc.
L & H Paint Products Inc.
Lasting Paints Inc.
Lenmar Inc.
Lilly Chem Products Inc.
Lilly Industrial Coatings Inc.
Lily Co. Inc.
Linear Dynamics Inc.
Lyle Van Patten Co. Inc.
MA Bruder & Sons Inc.
Maas & Waldstein Co.
MAB Paints Inc.
Magruder Color Co. Inc. Radiant Color Div.
Major Paint Co.
Mansfield Paint Co. Inc.
Martec Inc.
Martin-Senour Co.
Mautz Paint Co.
McCormick Paint Works Co.
McWhorter-McCloskey Inc.
Mercury Paint Co. Inc.
Mid-States Paint Co.
Day Ln, Carpentersville IL 60110
PO Box 1819, Houston TX 77251
PO Drawer J, Mountain View CA 94040
1259 Route 46 E, Parsippany NT 07054
PO Box 061319, Fort Myers FL 33906
PO Box 1257, Chattanooga TN 37401

37721 Stevens, Willoughby OH 44094
1326 N Bentalov St, Baltimore MD 21216
PO Box 460, Watertown CT 06795
301 W Hurst Blvd. Hurst TX 76053
987 Commercial St, San Carlos CA 94070
366 W Nickerson St, Seattle WA 98119

1201 Osage  St, Denver CO 80204
480 Frelinghuysen Ave, Newark NJ 07114
36 Pine St, Rockaway NJ 07866
201 E Market St, Louisville KY 40202
PO Box 39-R, Denver CO  80239
PO Box 7311, San Francisco CA 94120
PO Box 4428, Baltimore MD 21223
150 S Calverton Rd, Baltimore MD 21223
PO Box 188, Templeton MA 01468
733 S West  St, Indianapolis, IN 46225
PO Box 2358, High Point NC 27261
400 Lanidex Plz, Parsippany NJ 07054
321 W 135th St, Los Angeles CA 90061
PO Box 600, Broomall PA 19008
2121 McCarter Highway, Newark NJ 07104
630 N 3rd St, Terre Haute  IN 47808
PO Box 4019, Richmond CA 94804
4300 W 190th St, Torrance CA 90509
169 W Longview Ave, Mansfield OH 44905
760 Aloha St, Seattle WA 98109
101 Prospect Ave, Cleveland OH 44115
PO Box 7068, Madison WI 53707
2355 Lewis Ave, Rockville, MD 20851
5501 E Slauson Ave, Los Angeles CA 90040
14300 Schaefer Highway, Detroit MI 48227
9315 Watson Indus Park, St. Louis MO 63126
  8
  3*
  7
  8*
  9
 38

  6
  1*
 10
 15
230*
  2

 10
 15
 11
 16
 23
  4
  6
 13
 11
212
 30
 30
  3
140*
 15
 32
 30
 65
  2
  3
 44*
 19
 18*
  5
 18
  3
                                          (continued)
CH-92-02
                                             A-6

-------
   TABLE A-l.  PAINT AND ALLIED PRODUCTS FACILITIES (SIC 2851) WITH
                  ANNUAL SALES GREATER THAN $1 MILLION (continued)
                Name
                  Address
 Sales in
$ Millions
Midwest Lacquer Manufacturing Co.
Midwest Paint Manufacturing Co.
Millmaster Onyx Group Inc. Mantrose-
  Haeuser Co.
Mobile Paint Manufacturing Co.
Mohawk Finishing Products
Moline Paint Manufacturing Co.
Moling Paint Manufacturing
Monarch Paint Co.
Morton Intl Inc. Norris Paint/TMT
Muralo Co. Inc.
Muraio Co. Inc. Olympic Paint &. Chem Co.
N Siperstein Inc.
National Paint Co. Inc.
National Lacquer & Paint Co.
Nelson Tech Coatings Inc.
New York Bronze Powder Co. Inc.
Niles Chem Paint Co.
Norton & Son Inc.
Nu-Brite Chem Co. Inc. Kyanize Paints
O'Brien Corp.
O'Brien Corp. Powder Coatings Div.
O'Brien Corp. Southeast Region
Old Quaker Paint Co.
Orelite Chem Coatings
Pacific Coast Lacquer Co.  Inc.
Palmer Paint Products Inc.
Pan Chem Corp.
Paragon Paint & Varnish Corp.
Parker Paint Manufacturing Co.
Parks Corp.
Parks Paint & Varnish Co. Inc.
Passonno Paints
Pave-Mark Corp.
PavePrep Corp.
Penn Color Inc.
Pentagon Chem & Paint Co.
Perfection Paint & Color Co.
Performance Coatings Inc.
Perry & Derrick Co.
9353 Seymour Ave, Schiller Par IL 60176
2313 W River Rd N, Minneapolis MN 55411
500 Post Rd E, Westport CT 06880

4775 Hamilton Blvd. Theodore AL 36582
Route 30 N, Amsterdam NY 12010
5400 23rd Ave, Moline IL 61265
5400 23rd Ave, Moline IL 61265
PO Box 55604, Houston TX 77255
PO Box 2023, Salem OR 97308
PO Box 455, Bayonne NJ 07002
5928 S Garfield Ave, Los Angeles CA 90040
415 Montgomery St, Jersey City NJ 07302
3441 E 14th St, Los Angeles CA 90023
7415 S Green St, Chicago IL 60621
2147 N Tyler Ave, South El Mon CA 91733
519 Dowd Ave, Elizabeth NJ 07201
PO Box 307, Niles MI 49120
148 E 5th St, Bayonne NJ 07002
2nd & Boston St, Everett MA 02149
450 E Grand Ave, South San Francisco CA 94080
5300 Sunrise Rd, Houston TX 77021
PO Box 864, Brunswick GA 31521
2209 S Main St, Santa Ana  CA 92707
62 Woolsey St, Irvington NJ 07111
3150 E Pico Blvd, Los Angeles CA 90023
PO Box 1058, Troy MI 48099
1 Washington Ave, Hawthorne NJ 07506
5-49 46th Ave, Long Island NY 11101
PO Box 11047, Tacoma WA 98411
PO Box 5, Somerset MA 02726
660 TonneUe Ave, Jersey City NJ 07307
500 Broadway, Watervliet NY 12189
PO Box 94108, Atlanta GA 30318
141 Central Ave, Westfield NJ  07090
400 Old Dublin Pike, Doylestown PA 18901
24 Woodward Ave, Ridgewood NY 11385
715 E Maryland St, Indianapolis IN 46202
PO Box 1569, Ukiah CA 95482
2510 Highland Ave, Cincinnati OH 45212
    5
    2
    15

   45
   35*
    17
   125
   29*
    5
   42
    2*
   40
    3
    2
    2
    30
   16*
   15*
    20
   150*
    40
   11*
    31
    4
    3
    7
    5
    14*
    26
    20
    3*
    10
    20
    14*
    40
    16*
    6*
     3
    15
                                          (continued)
CH-92-02
      A-7

-------
   TABLE A-l.  PAINT AND ALLIED PRODUCTS FACILITIES (SIC 2851) WITH
                  ANNUAL SALES GREATER THAN $1 MILLION (continued)
                                                                                    Sales in
                Name                                    Address       .            $ Millions
Pervo Paint Co.
PFI Incoiporated-Paints for Industry
Pierce & Stevens Corp.
Plasti-Kote Co. Inc.
Plasticolors Inc.
Plextone Corp. of America
PMC Inc. Gen Plastics Div.
Ponderosa Paint Manufacturing Co. Inc.
Porter Paint Co.
Potter Paint Co. Inc.
PPG Indus Architectual Finishes Inc.
PPG Indus Inc. Automotive Products Group
Pratt & Lambert Inc.
Pratt & Lambert Inc. Western Div.
Premier Coatings Inc.
Preservative Paint Co.  Inc.
Pro-Line Paint Manufacturing Co. Inc.
Proctor Paint & Varnish
Progress Paint Manufacturing Co.
Pruett-Schaffer Chem Co.
Pyrolac Corp.
Quality Coatings Inc.
Raffi & Swanson Inc.
Randolph Products Co.
Red Spot Paint Varnish Co. Red Spot
   Westland Inc.
Red Spot Paint Varnish Co.
Reliable Coatings Inc.
Republic  Clear Thru Corp.
Republic  Powdered Metals Inc.
Riley Bros Inc.
River Valley Coatings Inc.
Riverside Labs Inc.
RJ McGlennon Co. Inc.
Roymal Inc.
RPM Inc.
Rudd Co. Inc.
Rust-Oleum Corp.
Rutland Fire Clay Co.
Sampson Paint Manufacturing Co.
6624 Stanford Ave, Los Angeles CA 90001
921 Santa Fe Springs Rd, Santa Fe Spr CA 90670
710 Ohio St, Buffalo NY 14203
PO Box 708, Medina OH 44258
2600 Michigan Ave, Ashtabula OH 44004
2141 McCarter Highway, Newark NJ 07104
55-T La France Ave, Bloomfield NJ 07003
PO Box 5466, Boise ID 83705
PO Box 1439, Louisville KY 40201
PO Box 265, Cambridge Ci IN 47327
2233 112th Ave ME, Bellevue WA 98004
PO Box 3510, Troy MI 48007
75 Tonawanda St, Buffalo NY 14207
PO Box 668, Marysville CA 95901
2250 Arthur Ave, Elk Grove Vi IL 60007
5410 Airport Way S, Seattle WA 98108
2646 Main St. San Diego CA  92113
38 Wells Ave, Yonkers NY 10701
PO Box 33188, Louisville KY 40232
PO Box 4350, Pittsburgh PA 15204
55 Schoon Ave, Hawthorne NJ 07506
1700 N State, Chandler IN 47610
100 Eames St, Wilmington MA 01887
Park Place E, Canstadt NJ 07072
550 S Edwin St, Westland MI 48185

PO Box 418, Evansville IN 47703
13108 Euless St, Euless TX 76040
211 63rd St, Brooklyn NY 11220
PO Box 777, Median OH 44258
860 Washington Ave, Burlington IA 52601
PO Box 580, Aurora IL 60507
411 Union St, Geneva IL 60134
198 Utah St, San Francisco CA 94103
Route 103, Newport NH 03773
PO Box 777, Medina OH 44258
1630 15th Ave W, Seattle WA 98119
11 Hawthorne Parkway, Vernon Hills EL 60061
PO Box 340, Rutland VT 05702
1900 Ellen Rd,  Richmond VA 23224
 13
  2
 50
 50
 17
  3
  4
 10
121
  2*
110*
 20*
246
 10
 20
 13
  7*
 20
 10
  4
  4*
  2
 15
  9
 15

 56
 14*
  6
 15
  3
  2*
  3*
  3
  4
380
 10
 89
  2
 42
                                          (continued)
CH-92-02
                                             A-8

-------
   TABLE A-l.  PAINT AND ALLDZD PRODUCTS FACILITIES (SIC 2851) WITH
                  ANNUAL SALES GREATER THAN $1 MILLION (continued)
                Name
                  Address
 Sales in
$ Millions
Sampson Coatings Inc.
Sandstrom Products Co.
Saxon Paint & Home Care Centers Inc.
  Dreeblan Paint Co.
Schalk Chems Inc.
Scott Paint Corp.
Seagrave Coatings Corp. Clover Leaf Paint
  & Varnish
Seaside Inc.
Seibert-Oxidermo Inc.
SEM Products Inc.
Sentry Paint Technologies Inc.
Seymour of Sycamore Inc.
Sheboygan Paint Co.
Sheffield Bronze Paint Corp.
Sherwin-Williams Co.
Sherwin-Williams Co. Automotive Div.
Sherwin-Williams Co. Consumer Div.
Sherwin-Williams Co. Oakland
Sherwin-Williams Co. Chem Coatings Div.
Sigma Coatings Co.
Smiland Paint Co.
Snyder Bros Co.
Southern Coatings Inc.
Southwestern Petroleum Corp.
Spatz Paints Inc.
Specialty Coating & Chem
Spectra-Tone Paint Corp.
Spraylat Corp. Los Angeles
Stanchem Inc.
Standard Detroit Paint Co.
Standard T Chem Co. Inc.
Star Finishing Products Inc.
Star Bronze Co.
STD Coating Corp.
Steelcote Manufacturing Corp.
Sterling Twelve Star Paint
S terling-Clark-Lurton
Stevens Paint Corp.
Stonhard Inc.
PO Box 6625, Richmond VA 23230
218 S High, Port Byron IL 61275
3729 W 49th St. Chicago IL 60632

2400 Vauxhall Rd, Union NJ 07083
5940 Palmer Blvd. Sarasota FL 34232
320 Paterson Plank Rd, Carlstadt NJ 07072

PO Box 2809, Long Beach CA 90801
6455 Strong Ave, Detroit MI 48211
120 Sem Ln, Belmont CA 94002
237 Mill St,.Darby PA 19023
917 Crosby Ave, Sycamore IL 60178
PO Box 417, Sheboygan WI 53082
17814 S. Waterloo Rd, Cleveland OH 44119
101 Prospect Ave NW, Cleveland OH 44115
101 Prospect Ave NW, Cleveland OH 44115
101 Prospect Ave NW, Cleveland OH 44115
1450 Sherwin Ave, Oakland CA 94608
11541 S Champlain Ave, Chicago IL 60628
PO Box 816, Harvey LA 70059
620 Lamar St, Los Angeles CA 90031
PO Box 760, Toccoa GA 30577
PO Box 160, Sumter SC 29151
PO Box 961005, Fort Worth TX 76161
1439 Hanley Industrial Ct, St. Louis MO 63144
7360 Varna Ave, North Hollywood CA 91605
9635 Klingerman St, South El Mon CA 91733
3465 S La Cienega, Los Angeles CA 90016
401 Berlin St, East Berlin CT 06023
8225 Lyndon Ave, Detroit MI 48238
290 E Joe Orr Rd, Chicago Heights IL 60411
360 Shore Dr, Hinsdale IL 60521
PO Box 2206, Alliance OH 44601
461 Broad Ave, Ridgefield NJ 07657
3418 Gratiot St, St. Louis MO 63103
PO Box 791, Little Rock AR 72203
184 Commercial St, Maiden MA 02148
38 Wells Ave, Yonkers NY 10701
PO Box 308, Maple Shade NJ 08052
    9
    7
   15*

    7
   16*
   14*

    3
   11
    7
   10
   10
   12
    3
 2,124
   160
   170*
   32*
   250
   15
   10
    7
   40
   26
    5
    3
    7
    5
    10
    8
   14*
    15
    11
     3
    4
    15
     9
    15
    62
                                          (continued)
CH-92-02
      A-9

-------
   TABLE A-l.  PAINT AND ALLIED PRODUCTS FACILITIES (SIC 2851) WITH
                  ANNUAL SALES GREATER THAN $1 MILLION (continued)
                                                                                    Sales in
                Name                                    Address                   $ Millions
Strathmore Products Inc.
Sullivan Coatings Inc.
Sunnyside Corp
Superior Varnish & Drier Co.
Superior Sealants Inc.
Supro Corp.
Technical Coatings Laboratory Inc.
Technical Coatings Inc.
Technical Coatings Co.
Tenax Finishing Products
Tera Lite Inc.
Tester Corp.
Thompson & Formby Inc.
Ti-Kromatic Paints Inc.
Tnemec Co. Inc.
Touraine Paints Inc.
Tower Paint Manufacturing
Trail Chem Corp.
Triangle Coatings Inc.
United Paint  & Cherh Corp.
United Coatings  Inc.
United Paint  Co.
United Gilsonite Labs
Universal Paint Corp.
Universal Chems & Coatings Inc.
Universe Paint Co.
Valspar Corp. MCI Quality Coatings
Valspar Corp. Colony Paints Div.
Valspar Corp.
Valspar Corp. Masury Paint Co.
Vanex Color Inc.
VJ Dolan & Co. Inc.
Vogel Paint & Wax Inc. Marwin Paints Inc.
Vogel Paint & Wax Inc.
Voplex Corp. Allerton Chem Div.
Waterlox Chem & Coatings Corp.
Watson-Standard Co.  Jordan Paint
   Manufacturing Co.
Watson-Standard Co.
Wattyl Group Precision Paint Group
1970 W Fayette St, Syracuse NY 13204
410 N Hart St, Chicago IL 60622
225 Carpenter Ave, Wheeling IL 60090
PO Box 1310, Meichantville NJ 08109
1135 Sylvan SW, Atlanta GA 30310
2650 Pomona Blvd. Pomona CA 91768
PO Box 565, Avon CT 06001
PO Box 3337, Austin TX 78764
1000 Walsh Ave, Santa Clara CA 95050
390 Adams St, Newark NJ 07114
1631 S 10th St, San Jose Ca 95112
620 Buckbee St, Rockford IL 61106
825 Crossover Ln, Memphis TN 38117
2492 Doswell Ave, St. Paul MN 55108
PO Box 411749, Kansas City MO 64141
1760 Revere Beach Parkway, Everett MA 02149
620 W 27th St, Hialeah FL 33010
9904 Gidley St, El Monte CA 91731
1930 Fairway Dr, San Leandro  CA 94577
24671 Telegraph Rd, Southfield MI 48034
2850 Festival Dr, Kankakee IL  60901
404 E Mallory,  Memphis TN 38109
PO Box 70, Scranton PA 18501
PO Box 1218, La Puente CA 91749
1975 Fox Ln, Elgin EL 60123
PO Box 668, Marysvffie CA 95901
6110 Gunn Highway, Tampa FL 33625
PO Box 418037, Kansas City MO 64141
1101 S 3rd St, Minneapolis MN 55415
1401 Severn St, Baltimore MD 21230
1700 Shawnee St, Mount Vemon IL  62864
1830 N Laramie Ave, Chicago  IL 60639
2100 N 2nd St, Minneapolis MN 55411
Industrial Air Park Rd., Orange City  IA 51041
763 Linden Ave, Rochester NY 14625
9808 Meech Ave, Cleveland OH 44105
7250 Franklin St, Forest Park IL 60130

PO Box 11250, Pittsburgh PA  15238
5275 Peachtree, Atlanta GA 30341
  6
 2*
 14
 7*
 11*
  4
  6
  8
  6
 6*
  3
 43*
 44*
  3
 50
 17
 10
  4
  5
 11*
 65
 25
 22*
 20
 10
  3*
 12
 15
527
  8
  4
  5
  8*
 100
  1
  4
  4

 29*
 15
                                          (continued)
CH-92-02
     A-10

-------
   TABLE A-l. PAINT AND ALLIED PRODUCTS FACILITIES (SIC 2851) WITH
                 ANNUAL SALES GREATER THAN $1 MILLION (continued)
                Name
                 Address
 Sales in
$ Millions
WC Richards Co. Inc.
Welco Manufacturing Co. Inc.
Wellborn Paint Manufacturing Co.
Western Automotive Finishes
Westfield Coatings Corp.
Westinghouse Elec Corp. Insulating
  Materials Div.
Whittaker Corp. Whittaker Decatur Coatings
William Zinsser & Co.
Wiltech Corp.
Wisconsin Protective Coatings Corp.
WM Barr & Co. Inc.
Yenkin Majestic Paint Corp.
Zehrung Corp
Zolatone Process  Inc.
ZPC Indus  Coatings Inc.
Zynolyte Products Co.
3555 W 123rd St, Blue Island IL 60406              15*
1225 Ozark St, North Kansas MO 64116             10
215 Rossmoor Rd SW, Albuquerque NM 87102        15
1450 Ave R, Grand Prairi TX 75050                 17*
PO Box 815, Westfiled MA 01086                   7
Route 993, Manor PA 15665                       15

PO Box 2238, Decatur AL 35602                   12*
31 Belmont Dr, Somerset NJ 08873                  16
PO Box 517, Longview WA 98632                   2
PO Box 216, Green Bay WI 54305                  10
PO Box 1879, Memphis TN 38113                  95
PO Box 369004, Columbus OH 43236               80
3273 Casitas Ave, Los Angeles CA 90039             2*
3411 E 15th St, Los Angeles CA 90023               6
120 E Minereal St, Milwaukee WI 53204              2
PO Box 6244, Carson CA 90749                    25
* Indicates an estimated financial figure.
 Source: Reference 5, Chapter 2.
CH-92-02
                                           A-ll

-------
    TABLE A-2.  PRINTING INK FACILITIES (SIC 2893) WITH ANNUAL SALES
                   GREATER THAN $1 MILLION

                                                                                      Sales in
                 Name                                    Address                    $ Millions
 Acme Printing Ink Co. Packaging Inc. Corp.
 Acme Printing Ink Co.
 AJ Daw Printing Ink Co.
 American Inks & Coatings Corp.
 Autoroll Machine Corp.
 BASF Corp. Coatings & Colorants Div.
 Bomark Inc.
 Borden Inc. Coatings & Graphics Group
 Braden  Sutphin Ink Co.
 Celia Corp.
 Central Ink & Chem
 Colonial Printing Ink Corp
 Converters Ink Co.
 Croda Inks Corp.
 Custom Chem Corp.
 Del Val Ink & Color Co. Inc.
 Excello Color & Chem
 Flint Ink Corp.
 Hint Ink Corp. Capitol Printing Ink
 Flint Ink Corp.
 Gans Ink & Supply Co. Inc.
 Gotham Ink & Color Co. Inc.
 Graphic Color Corp.
 Handschy Ink & Chems Inc.
 Ink Masters Inc.
 James River Corp. of Virginia CZ Inks Div.
 JM Huber Corp. Carbon Div.
 Kerley Ink Engineers Inc.
 Kohl & Madden Printing Ink Corp.
 Lakeland Laboratory Inc. Alfa Ink Div.
 Lakeland Laboratory Inc.
 Lawter Intl Inc.
 Merit Printing Inc. Co.
 Midland Color Co.
 Miller-Cooper Co.
 Morrison Printing Ink Co.
 Naz-Dar Co.
5001 S Mason Ave, Chicago DL 60638
165 Bond St, Elk Grove Vi IL 60007
3559 S Greenwood Ave, Los Angeles  CA 90040
PO Box 803, Valley Forge PA 19482
11 River St, Middleton MA 01949
1255 Broad St, Clifton NJ 07015
601 S 6th Ave, City of Indu CA 91746
630 Glendale -  Milford, Cincinnati OH 45215
3650 E 93rd St, Cleveland OH 44105
320 Union St, Sparta MI 49345
1100 N Harvester Rd, West Chicago IL 60185
180 E Union Ave, East Rutherford NJ 07073
1301 S Park Ave, Linden NJ 07036
7777 N Merrimac, Niles IL 60648
30 Paul Kohner PI, ElmwoodPark NJ  07407
1301 Taylors Ln,  Riverton NJ 08077
1446 W Kinzie St, Chicago IL 60622   .
25111 Glendale Ave, Detroit MI 48234
806 Charming PI NEi Washington DC  20018
1404 4th St, Berkeley CA 94710
1441 Boyd St, Los Angeles CA 90033
5-19 47th Ave,  Long Island NY 11101
750 Arthur Ave, Elk Grove Vi IL 60007
120 25th Ave, Bellwood JL 60104
2842 S 17th Ave, Broadview IL 60153
4150 Can Ln, St. Louis MO 63119
9300 Needlepoint Rd, Baytown TX 77521
2839 19th Ave, Broadview JL 60153
222 Bridge Plz  Sq, Hackensack NJ 07601
655 Washington Ave, Carlstadt NJ 07072
655 Washington Ave, Carlstadt NJ 07072
990 Skokie Blvd,  Northbrook IL 60062
1451 S Lorena St, Los Angeles CA 90023
651 Bonnie Ln, Elk Grove Vi IL 60007
1601 Prospect Ave, Kansas City MO 64127
4801 W 160th St, Cleveland OH 44135
1087 N Northbranch St, Chicago IL 60622
100
140*
 13
 15
 12
105*
  3
 17*
 25
 15
  9
 17
 16*
 32*
 40
  5
 84*
235
 23
 30*
 18
  4
 18
 30
  3
 28
 18*
 4*
 45
 2*
  3
136
 4*
 85
  6
 14*
 15*
                                           (contined)
CH-9Z-02
     A-12

-------
    TABLE A-2. PRINTING INK FACILITIES (SIC 2893) WITH ANNUAL SALES
                  GREATER THAN $1 MILLION (continued)
                Name
                  Address
 Sales in
$ Millions
Nor-Cote Intl Inc.
North American Printing Ink
Northern Printing Ink Corp.
Polyporc Inc.
Polytex Color & Chem
PPG Indus Inc. PPG Ink Products Co.
Rexart Chem Corp.
Ron Ink Co. Inc.
Sicpa Indus of America Inc.
Sinclair  & Valentine LP
Sun Chem Corp.
Sun Chem Corp. Gen. Printing Ink Div.
Superior Printing Ink Co. Inc.
United States Printing Ink Corp. Leber Ink
   Div.
United States Printing Ink Corp.
Van Son Holland Corp. of America
Vivitone Inc.
Walter W Lawrence
PO Box 668, CrawfordsvUle IN 47933                 5
1524 David Rd, Elgin IL 60123                     14
8360 10th Ave N, Minneapolis MN 55427              8
4601 S 3rd Ave, Tucson AZ 85714                  10
820 E 140th St, Bronx NY 10454                     3
1835 Airport Exchange Blvd, Covington KY 41018     15
1183 Westside Ave, Jersey City NJ 07306              6*
61 Halstead  St, Rochester NY 14610                  7
8000 Research Way, Springfield VA 22153            25
2520 Pilot Knob Rd, St. Paul MN 55120             186
PO Box 1302, Fort Lee NJ 07024                  1,100
135 W Lake St, Northlake IL 60164                410*
70 Bethune St, New York NY  10014                 50
PO Box 88700, Seattle WA 98138                    6

343 Murray  Hill Pkwy, East Rutherford NJ 07073      65
92 Union  St, Mineola NY 11501                     42
110 E 27th St, Paterson NJ 07514                  "   8
9715 Alpaca St, South El Mon CA.91733              1
 Wikoff Color Corp.

"Indicates an estimated financial figure.
 Source: Reference 5, Chapter 2.
PO Box W, Fort Mill SC 29715
   45"
CH-92-02
                                            A-13

-------
                          APPENDIX B
           PERMIT REQUIREMENTS FROM SEVERAL STATES
CH-92-02
                              B-l

-------
                          TABLE 13-1. SELECTION OF OHIO PERMIT INFORMATION
ta
Capacity
5000 gal

2250 gal

2000 gal

1000 gal

Igal
5 gal
750 gal

All Sizes







550 gal





/








Equipment
Paint Thindown
Tank
Paint Mix Tank

Paint Thindown
Tank
Paint Thindown
Tank
Paint Filler
Paint Filler
Paint Mix Tank

Paint Batch
Mixers, Mills,
Filter and Fill
Equipment
Paint with
Agitator Process
Tank
Paint Mixer
Paint Portable
Agitators Mixers

Paint Mixer
Ink Mixer
Ink Sandmill
Ink Shotmill
100 HP Traffic
Paint Disperser
60 HP Traffic
Paint Disperser
50 HP Traffic
Paint Disperser
60 HP Industrial
Paint Disperser
Method of Abatement
Carbon Absorption

N/A

Carbon Adsorption

Carbon Adsorption

N/A
N/A
N/A

N/A



N/A


N/A
N/A
VOC Emission Limit

Ib/ hr Ib/day tons/yr Control Efficiency Operational Limits
0.5

8.0 40

0.5

0.5

8.0 40
8.0 40
8.0 40

8.0 40



8.0 40 2


8.0 40 2
1.0 5
95

N/A

95

95

N/A
N/A
N/A

N/A



N/A


N/A
N/A


 bottom fill of solvents
 9 hrs/day processing






 bottom fill of solvents
 9 hrs/day processing
 keep lids closed







 covers at all times





















 vapor return system when filling totes
 agitators should be color dedicated
Fabric Filter
N/A
N/A
N/A
N/A

N/A

N/A

N/A

3.6 40 5
8 40
8 40
0.46 2.02
38 30.7

16.75 13.4

3.2 3.2

3.1 3.2

N/A
N/A
N/A
N/A
N/A

N/A

N/A

N/A



 maximum production in

 solvent usage limited to

 solvent usage limited to

 solvent usage limited to

 solvent usage limited to



mill <8000 Ibs/day

1633.5 tons/quarter

726 tons/quarter

321.6 ions/quarter

312.8 tons/quarter


-------
        TABLE B-2. STATE OF CALIFORNIA PERMIT INFORMATION
Plant
Number
CA-01
CA-02
CA-03
CA-04
CA-05
CA-06
CA-07
CA-08
CA-09
CA-10
CA-11
CA-12
CA-13
CA-14
CA-15
CA-16
CA-17
CA-18
CA-19
CA-20
CA-21
CA-22
CA-23
CA-24
CA-25
CA-26
CA-27
CA-28
CA-29
CA-30
CA-31
CA-32
CA-33
CA-34
CA-35
CA-36
CA-37
CA-38
SIC
2893
2893
2893
2893
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
Number of
Employees
160
22

2
55
239
244

160
10
62
28
300
34

30

- 18
125
50
100
25 .

12

6
6
14
3
20
35
45
8
27
8
3
30
115
Organic Emissions
tons/yr Ib/day Abatement Devices
90.69
13.66
0.00
5.39
67.49
28.90
27.12
0.18
90.69
0.00
30.65
12.24
62.52
9.12
1.01
11.83
0.72
8.57
99.41
4.96
4.86
16.14
0.00
20.96
4.77
5.13
0.00
1224
0.28
0.00
43.15
6.70
0.04
6.81
1.21
0.00
1.57
879.52
496.94
74.85
0.00
29.55
369.79
158.37
148.59
1.01
496.94
0.00
167.94
67.04
342.56
49.96
5.56
64.81
3.96
46.97
544.74
27.16
26.65
88.43
0.02
114.86
26.16
28.11
0.00
67.06
1.54
0.00
236.44
36.74
0.20
37.29
6.62
0.01
8.60
4819.30
YES
NO
NO
NO
YES
YES
YES
NO
YES
NO
YES
YES
YES
YES
YES
NO
NO
NO
YES
NO
YES
YES
NO
NO
NO
NO
NO
NO
NO
YES
NO
YES
NO
NO
NO
YES
YES
YES
CH-92-02
                                B-3

-------
         TABLE B-3. STATE OF ILLINOIS PERMIT INFORMATION
Plant
Number
IL-01
IL-02



IL-03
IL-04


IL-05
IL-06
IL-07
IL-08
IL-09
IL-10
IL-11


EL-12
EL-13
IL-14
IL-15
IL-16


IL-17
IL-18
IL-19
IL-20
BL-21
IL-22


EL-23
IL-24
IL-25
IL-26
IL-27
IL-28
Number of
SIC Employees
2851
2851



2851
2893


2893
2893
2851
2893
2893
2893
2851


2851
2851
2851
2851
2851


2893
2893
2851
2893
2851
2893


2851
2851
2851
2851
2851
2851
Organic Emissions
tons/yr Ib/day
6.1620
8.9677



82.1184
14.2071


8.1484
0.0000
27.9200
0.0000
0.0000
0.0000
39.8964


3.9000
0.0000
0.0000
64.4000
56.8817


0.0000
24.9061
180.6560
1.9520
0.0000
0.0008


7.7103
0.0000
7.9592
1.3632
14.1180
33.6365
Abatement Devices

VENTURI SCRUBBER
KNOCK OUT TANKS
CONDENSOR
CATALYTIC AFTERBURNER

CARTRIDGE FILTER
CONDENSOR
SCRUBBER


CYCLONE



CONDENSOR & SCRUBBER
CONDENSORS
(PRDfrARY & SECONDARY)
CYCLONE



CONDENSORS
SCRUBBERS
CHILLER

CONDENSORS
CONDENSORS


SCRUBBERS
CYCLONE & BAGHOUSE
KNOCKOUT TANKS


VAPOR RECOVERY SYSTEM
CARBON ADSORBERS


(continued)
CH-92-02
                                 B-4

-------
     TABLE B-3.  STATE OF ILLINOIS PERMIT INFORMATION (continued)
Plant
Number
IL-29


IL-30

E.-31
EL-32
IL-33
IL-34

EL-35
IL-36

IL-37
IL-38
IL-39
IL40
IL-41
IL-42
IL-43
IL-44
IL-45
IL-46
IL-41
IL^8

IL-49
IL-50
DL-51


IL-52



IL-53
IL-54
IL-55
IL-56
SIC
2893


2851

2893
2893
2851
2851

2851
2851

2851
2851
2893'
2851
2851
2851
2893
2851
2851
2851
2851
2851

2851
2851
2893


2851



2851
2851
2851
2851
Organic Emissions
Number of
Employees tons/yr Ib/day
280.9783


45.2446

0.0000
0.0000
49.4400
15.4713

0.0000
11.3100

6.2400
12.2460
13.3120
3.9610
0.0000
43.8604
17.3750
15.6600
0.0000
18.9280
34.9440
3.5569

94.1300
9.8000
17.4985


9.0892



0.0000
0.0000
2.6208
17.2680
Abatement Devices
FUME SCRUBBER
CONDENSOR/ELIMINATOR
PLATE SCRUBBER
CONDENSORS
SCRUBBERS

CONDENSORS
SCRUBBERS
CONDENSORS
SEPARATORS

CHARCOAL ADSORBER
CHARCOAL FILTER
ROTOCLONE
SCRUBBER


ROTOCLONE
AFTERBURNER



RECYCLING STILL

VENTURI EDUCTOR
CARBON ADSORBERS

CONDENSORS
SCRUBBER
CONDENSORS
VACUUM PUMPS
SCRUBBERS
KNOCKOUT TANKS
CATALYTIC AFTERBURNER
CONDENSORS
SCRUBBERS



                                 (continued)
CH-92-02
                                   B-5

-------
     TABLE B-3.  STATE OF ILLINOIS PERMIT INFORMATION (continued)
Organic Emissions
Plant
Number

SIC
Number of
Employees

tons/yr

Ib/day

Abatement Devices
  DL-57


  IL-58
  IL-59

  IL-60
  IL-61
  IL-62
  IL-63
  IL-64

  IL-65
  IL-66


  IL-67
2851
2893
2851

2851
2851
2851
2851
2851

2851
2851
2851
143.2435


 86.8543
200.5087
  8.3956
 83.5848
 30.2640
 28.2880

 37.5000
217.1960
  1.9207
SCRUBBERS
CONDENSOR
SOLN-ABSORBER
CONDENSORS
CONDENSORS
SCRUBBERS
SETTLING CHAMBERS
CENTRIFUGAL COLLECTOR

SCRUBBERS
CONDENSORS
VAPOR RECOVERY
SPEED REDUCTION
EQUIPMENT
CH-92-02
                           B-6

-------
                      TABLE B-4. STATE OF TEXAS PERMIT INFORMATION
W
-L.
Plant Number of
Number SIC Employees Source Type
TX-01 2851 10 CTGMFG NONMETHANE
METH. CHLORIDE
TCE
TX-02 2851 17 PRO. FUG. NONMETHANE
ALCOHOLS
TOLUENE
XYLENE
ALKYL ACET.
ETHYL ACET.
GLYCOLETH.
CELLOSOLVE
1,1,1 TRICH.
KETONES
MEK
M1BK
2-NITROPRO.
NAPHTHA
TX-03 2851 FAN STACK NONMETHANE
FAN STACK NONMETHANE
TANK STACK NONMETHANE
TX-04 2851 18 TANK STACK AROMATICS
TOLUENE
XYLENE
MINERAL SPR.
NAPHTHA
EXH. STACK AROMATICS
ROOF STK. AROMATICS
EXH. STACK AROMATICS
Organic Emissions Abatement
tons/yr Ib/day Devices
14.6000
9 9000
8.4000
0.0000
0.0100
2.2000
19.5000
0.0000
0.1200
0.0000
0.0300
2.9000
0.0000
0.1300
4.7500
0.0000
0.1100
2.0000
2.0000
1.7000
0.3500
1 .0000
1. 0000
1 .0000
1 .0000
2.7600
5.5800
5.5800

-------
                   TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
ta
oo
Plant Number of
Number SIC Employees Source Type
TX-05 2851 100 BAG. VENT TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
EXHAUST FAN TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
PAINT CONT. TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
MFG.EXH.FAN TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
MFG.EXH.FAN TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
BACH. VENT ISOPROPANOL
TOLUENE
XYLENE
Organic Emissions Abatement
tons/yr Ib/day Devices
0.0008 FILTERS BAGHOUSE (FABRIC)
0.0004
. 0.0005
00008
0.0006
0.0019
0.0015
0.0030
0.0417
0.0180
0.0005
0.0015
0.0030
0.0417
0.0180
0.0005
0.0015
00030
0.0417
0.0180
0.0005
0.0015
0.0030
0.0417
0.0180
0.0005
0. 1247 FILTERS BAGHOUSE (FABRIC)
0.2526
0.0969

-------
                   TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
W
vb
Plant Number of
Number SIC Employees Source Type
TX-05 BAGH.VENT MHK
MIBK
MINER. SPIRT
NAPHTHA
BAGH.VENT ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
BAGH.VENT ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
BAGH.VENT ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
Organic Emissions
tons/yr Ib/day
0.1810
0.2163
. 0.1196
0.4975
0.0904
0.1178
0.0663
0.1296
0.1479
0.0891
0.3371
0.4577
0.8262
0.2913
0.6207
0.6508
0.1702
1.4563
0.0235
0.0480
0.0177
0.0353
0.0394
0.0234
0.0317
Abatement
Devices
FILTERS BAGHOUSE (FABRIC)



FILTERS BAGHOUSE (FABRIC)
SINGLE CYCLONE





FILTERS BAGHOUSE (FABRIC)






FILTERS BAGHOUSE (FABRIC)
SINGLE CYCLONE






-------
                    TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
td

(
o
Plant Number of
Number SIC Employees Source Type
TX-05 BAGH.VENT ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
BAGH.VENT ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
EXHAUST FAN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
PAINT CONTA. ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
Organic Emissions Abatement
tons/yr Ib/day Devices
0.0279 FILTERS BAGHOUSE (FABRIC)
0.0552
0.0206
0.0402
0.0406
0.0278
0.1050
0.0261 FILTERS BAGHOUSE (FABRIC)
0.0926
0.0352
0.0404
0.0786
0.0484
0.1802
0.0280
0.0880
0.0364
0.0570
00128
0.0970
0.4200
0.0280
00880
0.0364
0.0570
0.0128
0.0970
0.2099

-------
                    TABLE B-4. STATE OF T.EXAS PERMIT INFORMATION, Continued
W
Plant Number of
Number SIC Employees Source Type
TX-05 EXHAUST FAN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
PAINT CONT. ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
EXHAUST FAN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
PAINT CONT. ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
Organic Emissions Abatement
tons/yr Ib/day Devices
0.0561
0.1174
0.0377
0.0877
00853
0.0195
0.2091
0.0561
0.1174
0.0377
0.0877
0.0853
0.0195
0.2091
0.1651
0.3729
0.1280
0.2750
0.2200
0.1318
0.7189
0.1651
0.3720
0.1280
0.2750
0.2200
0.1318
0.7180

-------
                    TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
W
ii
to
Plant Number of
Number SIC Employees Source Type
TX-05 TANKTRKLD XYLENE
' M1BK
ROOF VENT 7 MEK
ROOF VENT 8 MEK
ROOF VENT 7 MEK
ROOF VENT 8 MEK
MFG.EXH.FAN TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
MFG.EXH.FAN TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
BAGH. VENT ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
BAGH. VENT ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
Organic Emissions Abatement
tons/yr Ib/day Devices
0.0015
0.0006
0.0064
0.0064
0.0074
0.0074
0.0102
0.0170
0.3137
0.0905
0.0017
0.0102
0.0170
0.3137
0.0905
0.0017
0.0278 FILTERS BAGHOUSE (FABRIC)
0.0461 SINGLE CYCLONE
0.0073
0.0332
0.0497
0.0210
0.0760
0.0284 FILTERS BAGHOUSE (FABRIC)
0.0471 SINGLE CYCLONE
0.0172
0.0340
0.0590
0.0326
0.08

-------
                    TABLE B-4. STATE OF TEXAS PERMIT INFORMATION. Continued
W
Plant Number of
Number SIC Employees Source Type
TX-05 BAGH. VENT ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
BAGH. VENT ISOPROPANOL
TOLUENE
XYLENE
. MEK
MIBK
MINER. SPIRT
NAPHTHA
BAGH. VENT NONMETHANE

PAINT & CAN NONMETHANE
TOLUENE
MEK
MIBK
MINER. .SPIRT
EXHAUST FAN NONMETHANE
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
Organic Emissions Abatement
tons/yr Ib/day Devices
0 0494 FILTERS BAGHOUSE (FABRIC)
00819 SINGLE CYCLONE
. 0.0299
0.059L
0.0884
0.0374
0.1353
0.0242 FILTERS BAGHOUSE (FABRIC)
0.0402
0.0147
0.0290
0.0403
0.0183
0.0644
3.3000 FILTERS BAGHOUSE (FABRIC)
SINGLE CYCLONE
0.0000
0.2500
0.6000
0.2400
0.0100
0.0000
0.3100
0.4000
0.2300
0.1500
0.1800
0.7100

-------
                   TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
W
Plant Number of
Number SIC Employees Source Type
TX-05 PAINT CONT. NONMETHANE
. TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
TANK STACK XYLENE
TANK STACK TOLUENE
XYLENE
BAGH. VENT TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
' NAPHTHA
MIX & THIN 1SOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
TANK MINER. SPIRT
MIXING ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
Organic Emissions Abatement
tons/yr Ib/day Devices
0.0000
0.3100
. 0.4000
0.2300
0.1500
0.1800
0.7000
0.0000
o.ooo'o
0.0000
0.0003 FILTERS BAGHOUSE (FABRIC)
0.0001
0.0021
0.0003
0.0003
0.0030
0.0166
0.0323
0.0122
0.0238
0.0271
0.0141
0.0615
0.0150
0.0575
0.1120
0.0424
0.0826
0.0941
0.0563
0.2138

-------
                    TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
W
Plant Number of
Number SIC Employees Source Type
TX-05 TANK MINER. SPIRT
MIX & THIN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
TANK MINER. SPIRT
TANK STOR. NAPHTHA
TANK N-BUTYL ALC.
TOLUENE
XYLENE
ACETONE
MEK
MIBK
MINER. SPIRT
TANK MIBK
TANK TOLUENE
XYLENE
ACETONE
MEK
MIBK
MINER. SPIRT
MIX & THIN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
Organic Emissions Abatement
tons/yr Ib/day Devices
0.0150
0.0190
0.0395
0.0156
0.0284
0.0347
0.0244
00795
0.0150
0.0410
0.0090
0.0380
0.0180
0.1120
0.0700
0.0340
0.0200
0.0250
0.0380
0.0180
0.1120
0.0700
0.0340
0.0200
0.0108
0.0128
0.0085
0.0158
0.0188
0.0118
0.0430

-------
TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
Plant Number of
Number SIC Employees Source Type
TX-05 TANK STOR. MEK
TANK VENT MIBK
MIX & THIN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
MIX & THIN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
MIX & THIN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
MIX & THIN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
Organic Emissions Abatement
tons/yr Ib/day Devices
0.0420
0 0250
0.0306
0.0648
0.0259
0.0462
0.0575
0.0378
0.1323
0.0535
0.1134
0.0454
0.0810
0.1007
0.0663
0.2314
0.0082
0.0151
0.0055
0.0113
0.0122
0.0175
0.0274
0.0176
0.0365
0.0139
0.0260
0.0240
0.0087
0.0708

-------
                    TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
w
I>
-J
Plant Number of
Number SIC Employees Source
TX-05 STOR.TK.
STOR.TK.
STOR.TK.
TANK 35
TANK 36
TANK 43-46

TANK 43-46

TANK
TANK
MIX & THIN






MIX & THIN






TANK
TANK
TANK
Type
TOLUENE
TOLUENE
TOLUENE
NAPHTHA
NAPHTHA
XYLENE
M1BK
XYLENE
MIBK
MINER. SPIRT
XYLENE
ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
XYLENE
TOLUENE
MINER. SPIRT
Organic Emissions Abatement
tons/yr Ib/day Devices
00050
0.0050
0.0050
0.0020
0.0020
0.0010
0.0030
0.0010
0.0030
0.0140
0.0030
0.0517
0.0978
0.0361
0.0729
0.0803
0.0433
0.1342
0.0194
0.0367
0.0135
0.0274
0.0301
0.0162
0.0503
0.0270
0.0660
0.0110

-------
                    TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
03
i
i
oo
Plant Number of
Number SIC Employees Source Type
TX-05 TANK MINER. SPIRT
PAINT & CAN MINER. SPIRT
TANK XYLENE
PAINT MIX ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
MIX & THIN ISOPROPANOL
TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
NAPHTHA
MIX & THIN MEK
MIX & THIN MEK
TANK 84 MINER. SPIRT
WASTE SOL. TOLUENE
XYLENE
MEK
MIBK
MINER. SPIRT
Organic Emissions Abatement
tons/yr Ib/day Devices
0.0120
0.0050
. 0.0030
0.0308
0.0604
0.0229
0.0444
0.0509
0.0306
0 1157
0.0088
0.0173
0.0065
0.0127
0.0145
0.0088
0.0330
0.0080
0.0060
0.0010
0.0340
0.0180
0.0790
0.0370
0.0090

-------
TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
Plant Number of
Number SIC Employees Source Type
TX-06 2851 225 PAINT PROC. AROMATICS
S-2 AROMATICS
XYLENE
S-l NONMETHANE
AROMATICS
RESIN PLANT AROMATICS
POLYNUCL. AR.
PHTHALIC ANHY.
RESIN CONDE. AROMATICS
RT-1 AROMATICS
VENT. SCRUB AROMATICS
POLYNUCL. AR.
_ PHTHALIC ANHY.
Co
^ TX-07 2851 PAINT PROC. NONMETHANE
" TOLUENE
XYLENE
MINER. SPIRT.
TX-08 2851 FUGITIVE EM. NONMETHANE
TX-09 2851 80 AREA STACK METHY.CHLORIDE
TX-10 2851 122 DISPER. FUG. NONMETHANE
XYLENE
MINER. SPIRT.
NAPHTHA
THIN/TINT ETHYLENE GLY.
PROPYLENE GLY.
XYLENE
MINER. SPIRT.
NAPHTHA
Organic Emissions Abatement
tons/yr Ib/day Devices
0.6700
0.0000 MISC. METHODS
. 0.2500
0.1110
0.0000
2.0000
0.0000
0.0100
0.0500 VAPOR CONDENSORS
1 .0000 VAPOR CONDENSORS
0. 1000 SCRUBBERS - CYCLONE VENT
0.0000
0.0100
0.0000 FABRIC FILTER
26.2000
30.7000
967.1000
16.9000
2.1600
0.0000 FABRIC FILTER (BAGHOUSE)
0.0300
0.3800
0.5500
0.0020
0.0020
0.0300
0.3800
0.5500

-------
                   TABLE B-4. STATE OF TEXAS PERMIT INFORMATION. Continued
w
^
o
Plant Number of
Number SIC Employees Source Type
TX-10 PACKAGING ETHYLENE GLY.
PROPYLENE GLY.
XYLENE
MINER. SPIRT.
NAPHTHA
BULK STOR. ETHYLENE GLY.
PROPYLENE GLY.
XYLENE
MINER. SPIRT.
NAPHTHA
TX-11 2851 COLL. STACK AROMATICS
DUST COL. AROMATICS
DUST COL.3 AROMATICS
FUME STK AROMATICS
ROOF STK AROMATICS
TANK FUG. AROMATICS
TX-12 2851 16 MIXER N-BUTYL ALC.
PROP. GLY.
ISOPROP.
METHANOL
AROMATICS
TOLUENE
XYLENE
ETHYL PROPION.
CELLOSOLVE
MEK
M1BK
MIAK
MINER. SPIRIT.
NAPHTHA
SOLV. FUG. NONMETHANE
Organic Emissions Abatement
tons/yr Ib/day Devices
0.0020
0.0020
0.0300
0.3800
0.5500
0.0020
0.0020
0.0300
0.2300
0.2700
5.7200
4.9800
0.9400
2.8800
18.9200
4.0000
4.3700
0.0800
0.0800
0.0800
0.0000
9.8600
13.4900
1.5700
0.4200
2.1700
3.5100
0.2800
1.1700
1 .2800
7.0000

-------
                   TABLE B-4.  STATE OF TEXAS PERMIT INFORMATION, Continued
W
Plant
Number
TX-13



TX-14



TX-15














TX-16




Number of
SIC Employees Source
2851 50 GRIND. MILL
PAINT MIX.
PROCESS TK
PREMIX UNIT
2851 PAINT&DEG.
STORE.TANK
STORE TANK
GAS TK LOAD.
2851 125 DUST COL.
DUST COL.

DUST COL.


DUST COL.


DUST COL.
DOORS


DISPERS.FUG.

2851 50 PAINT MIX




Type
NONMETHANE
NONMETHANE
NONMETHANE
NONMETHANE
NONMETHANE
GASOLINE
GASOLINE
GASOLINE
NONMETHANE
NONMETHANE
ETHYLENE GLY.
NONMETHANE
NAPHTHA
STOOD SOLVENT
NONMETHANE
NAPHTHA
STOOD SOLVENT
NONMETHANE
NONMETHANE
NAPHTHA
STOOD SOLVENT
ALCOHOLS
ETHYL. GLYC.
NONMETHANE
ALCOHOLS
N-BUTANOL
ETHANOL
ISOPROPANOL
Organic Emissions
tons/yr Ib/day
2.9800
1.3500
.. 0.1900
0.1900
74.0000
0.0500
0.8400
0.6500
0.0000
0.0200
0.0400
0.0000
0.5000
0.4500
0.0000
0.6200
0.5500
0.0200
0.0500
0.6000
0.5500
0.0000
0.0200
4.2900
0.0000
0.3400
0.0100
0.8100
Abatement
Devices



FILTERS FABRIC (BAGHOUSE)





FILTERS FABRIC (BAGHOUSE)




FILTERS FABRIC (BAGHOUSE)


FILTERS FABRIC (BAGHOUSE)
COLLECTOR-DRY, INTERTL










-------
                    TABLE B-4. STATE OF TEXAS PERMIT INFORMATION, Continued
W

to
N)
Plant
Number
TX-16
















TX-17
TX-18
Number of
SIC Employees Source Type
METHANOL
AROMATICS
TOLUENE
XYLENE
ALKYL ACETATES
AMYL ACETATE
PROPYL ACETATE
BUTYL ACETATE
ISOBUT. ACETATE
GLYCOL ETHERS
BUTYL CELLOS.
BUTYL CELL. ACE
CELLO. SOLVENT
KETONES
ACETONE
MEK
MIBK
MINER. SPIRITS
NAPHTHA
2851 50 PAINT MFG. NONMETHANE
NAPHTHA
2851 PROD. STACK NONMETHANE 
Organic Emissions Abatement
lons/yr Ib/day Devices
0.1000
0.2000
3 8200
3.3200
0.2800
0. 1 100
0.0300
0.1300
0.5900
0.0000
0.1300
0.0100
0.0100
0.3000
0.5400
0.8500
1.3400
0.6500
0.6000
0.0000 FABRIC FILTERS (BAGHOUSE)
1.5000 MECHANICAL SHAKING
1.5000

-------
                          TABLE B-5.  PERMIT INFORMATION FOR OTHER STATES
w
K)
State
INDIANA

OHIO

VIRGINIA
ALABAMA
ARKANSAS
CALIFORNIA
COLORADO







GEORGIA

INDIANA






,*
KANSAS

KENTUCKY
MARYLAND



Plant
Number
IN-01

OH-01

VA-01
AL-01
AR-01
CA-39
CO-01

CO-02
CO-03

CO-04
CO-05
CO-06
GA-01
GA-02
IN-02
IN-03
IN-04
IN-05
IN-06
IN-07

IN-08
KS-01
KS-02
KY-01
MD-01
MD-02
MD-03
MD-04
SIC
2893

2893

2893
2851
2851
2851
2851

2851
2851

2851
2851
2851
2851
2851
2851
2851
2851
2851
2851
2851

2851
2851
2851
2851
2851
2851
2851
2851
Source
COOKING OIL
PIGMENT MIX
COOKING GEN.
PIGMENT MIX
COOKING GEN.
MIXING & HAND.
MIXING & HAND.
MIXING & HAND.
MIXING & HAND.
MIXING
MIXING
MIXING
OTHER OPER.
MIXING
MIXING
MIXING
MIXING
MIXING
MIXING
MIXING
MIXING
OTHER OPER. *
MIXING
MIXING
OTHER OPER.
MIXING
MIXING
MIXING
MIXING
MIXING
MIXING
MIXING
MIXING
Type
VOC
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
Organic Emissions
tons/yr Ib/day
483.577
15.422
.33.280
1.719
131.000
215.000
42.000
92.076
12.000
83.000
4.000
22.000
1.000
17.000
10.000
7.000
41.000
28.000
17.000
88.000
46.000
1.000
30.000
97.500
' 0.550
14.000
240.000
2.000
245.000
28.000
63.000
9.000
16.000
Abatement Devices


PROCESS CHANGES



























VENTURI SCRUBBER


                                               (continued)

-------
                     TABLE B-5. PERMIT INFORMATION FOR OTHER STATES (continued)
td
to
Plant
State Number
MICHIGAN MI-01
MI-02
MI-03
MI-04
MISSOURI MO-01
MO-02

MO-03

MO-04
MO-05

NORTH CAROLINA NC-01
NC-02
NC-03
NC-04
NEW JERSEY NJ-01

SIC
2851
2851
2851
2851
2851
2851

2851

2851
2851

2851
2851
2851
2851
2851

Source
MIXING
MIXING
MIXING
MIXING
MIXING
MIXING
OTHER OPER.
MIXING
OTHER OPER.
MIXING
MIXING
OTHER OPER.
MIXING
MIXING
MIXING
MIXING
MIXING
OTHER OPER.
Type
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
Organic Emissions
tons/yr Ib/day
203.000
206.000
175.000
76.000
144.000
73.000
28.000
309.000
9.000
257.000
62.000
37.000
138.000
498.000
319.000
181.000
30.000
10.000
Abatement Devices
















CONSERVATION

















SUBMERGED FILLING
REFRIG. CONDENSOR
NJ-02


OHIO OH-01
OH-02
OH-03

OH-04
PENNSYLVANIA PA-01
PA-02

PA-03
PA-04
SOUTH CAROLINA SC-01
VIRGINIA VA-01
2851


2851
2851
2851

2851
2851
2851

2851
2851
2851
2851
PIGMENT HDLG.
MIXING

OTHER OPER.
MIXING
MIXING
OTHER OPER.
MIXING
MIXING
MIXING
OTHER OPER.
MIXING
MIXING
MIXING
MIXING
voc
voc

voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
voc
81.000
6.000

1.000
44.000
204.000
14.000
675.000
79.000
353.000
88.000
 34.000
56.000
149.000
259.000
CONDENSOR
CYCLONE
SEPARATOR


VAPOR RECOVERY
SPRAY TOWER







SYSTEM



CARBON ADSORPTION











-------
                            APPENDIX C
                           TRIP REPORTS
CH-92-02                            C-l

-------
          ALLIANCE
          Technologies Corporation
Date:         6 January 1992

Subject:      Site Visit-ICI Specialty Inks
             Ink Manufacturing
             EPA  Contract 68-DO-0121; Work Assignment 1-29
             Alliance Reference No.  1638029

From:        Beth W. McMinn
             Alliance Technologies Corporation

To:          Joseph Steigerwald
             OAQPS/ESD/CTC (MD-13)
             U.S.  Environmental Protection Agency
             Research Triangle Park, NC 27711
I.      Purpose

       The purpose of the visit was to gather information on the ink manufacturing process
including  information necessary  to  characterize the process  parameters, emissions,  control
techniques, and control costs.
II.     Place and Date

       ICI Specialty Inks
       120 Regent Drive
       Winston-Salem, NC  27103
       (919) 760-1011

       December 18, 1991
TIL    Attendees

       ICI Specialty Inks

       Randy Besaw, Plant Superintendent
       Templeton A.  Elliott,  Jr.,  Vice President/Director Safety, Health, & Environmental
             Affairs
              '00 Eurooa Drive. Suite 150, Chanel Hill, North Carolina 27514 919-968-9900

-------
       Tony Martin, Branch Manager
       Stephen W. Paine, Environmental Engineer

       U.S. Environmental Protection Agency (EPA)

       Joseph Steigerwald, CTC

       Alliance Technologies Corporation (Alliance)

       Beth W. McMinn
IV.     Discussion

       A meeting  was held with the personnel from  ICI  Specialty Inks to discuss  the  ink
manufacturing process.   The discussion focused on market  profile, manufacturing supplies,
manufacturing process parameters, volatile organic compound (VOC) control experience, and
emission characterization.  This discussion was followed by a  tour of the production facility in
Wirtston-Salem, North Carolina, and then by a short closing  meeting.

       A.    ICI Specialty Inks Market Profile

       The  ICI Specialty Inks  facility in Winston-Salem  manufactures  flexographic and
rotogravure  inks for the packaging  industry.  Many  of their  inks are  used in the  printing of
packages for food and snack food products such as Frito Lay, Lance, Hershey, and Mars.  ICI
Specialty Inks also produces ink used on the packaging of RJ. Reynolds cigarettes and textile soft
goods packaging such as that used to package pantyhose.  The facility places  a heavy emphasis
on inks for lamination (i.e., ink printed between two layers of film).   Approximately 99 percent
of the  inks  manufactured  by this location of ICI Specialty Inks are solvent based, while the
remaining one percent is water based. This location of ICI Specialty Inks produces colored, clear,
and white inks.  All of their water based inks are flexographic white inks and top lacquers.  In
the flexible packaging industry, white inks are high-volume, low profit margin products.  They
are, consequently, the first type of ink to be converted from solvent based ink because the high
volume usage by printers results in  the largest reduction on VOC emissions by the  printers for
switching a single ink.

       Very few of the ICI  Specialty Inks printed products come in direct contact with food,
therefore, approval from the Food and Drug Administration (FDA) is not a major concern. Food
packagers are, however, sensitive about the inks used in packaging and restrict ink manufacturers
from using heavy metal pigments (i.e., lead, hexavalent chromium, cadmium, and mercury).

       The printing/packaging operations that the Winston-Salem ink facility services are located
within a 300 to 400 mile radius. Some of these packaging facilities supply products to a regional
area while others service  the nation.  ICI Specialty Inks takes pride in the quality of its final
product and its  "Just In Time" manufacturing policy. In many cases customers like the Charlotte,
  CH-92-02

-------
North Carolina based Venture Packaging and Package Products will receive same day shipment
of ink orders.

       The Regent Drive ICI Specialty Ink facility was known as Converters Inks until January
1, 1992.  Throughout its history, the former Converters Ink has manufactured solvent based
flexographic and rotogravure inks for the packaging industry. Carl Bear founded the Converters
Ink Company in the 1950's.  During the next thirty years, Converters Ink expanded to a total of
12 manufacturing plants,  of which nine are located in the United States and three in Canada.  In
1971, Beatrice Foods purchased the Converters Ink facilities.  The plants were purchased a second
time in late 1984 by ICI Americas, Inc. (ICI).  Shortly after the 1984 buyout, ICI constructed the
current Converters Ink facility. Production in the new 12,000 square feet manufacturing facility
began in early 1985. Eventually, a 5,000 to 6,000 square feet addition was added. In  1988, ICI
bought five Thiele-Engdahl ink manufacturing plants. The Winston-Salem based Thiele-Engdahl
plant concentrates its production efforts in gravure inks used  in box and cardboard packaging.
Converters Ink and Thiele-Engdahl merged in early 1992 and are now called ICI Specialty Inks.
       B.    Manufacturing Supplies

       ICI Specialty Inks uses more than 200 raw materials in their manufacturing processes.  In
addition to the solvents described in Attachment 1, ICI Specialty Inks also purchases and uses a
variety of resins, pigments, and additives.  Corporate headquarters regularly determines product
ink VOC content based on raw material safety data sheets and finished good calculations.  Some
finished goods are tested for flashpoint determination.

       C.    Manufacturing Process Parameters

       The ink manufacturing process at the Winston-Salem facility is basically a batch process
materials handling operation.  Products are formed by mixing and blending rather than by reacting
materials chemically.  No heating of materials is necessary during the processing. A process
description and simplified flow diagram are found in Attachment 2.  The main manufacturing
operations are completed in the following order:

                   premix
                   pigment grinding/milling
                   product blending
                   product filtering
                   product filling/packaging

       The first step in the manufacturing process is material premix. This is the production of
an intermediate product  referred to as the base. The base or premix  is made by combining
vehicles (e.g., solvents,  alcohols, resins, and/or water) with pigments and any other necessary
additives.  The  materials are mixed in portable containers to form a viscous material which acts
as a concentrate. At this stage, the particles in the concentrate are rather large (250 pm) and not
consistently mixed.  With further processing, the concentrate may become any one of a variety
of specific end products.                                            ,v

  CH-92-02                                     3

-------
       The grinding or milling stage serves to further disperse the pigment throughout the base
by pumping it through dispersion equipment.  Once the customer-requested grind specifications
are met, the resulting base is transferred to the product blending tanks.

       Final product specifications are achieved in the blending or product finishing step.  The
base from the dispersion operation is mixed with other intermediates and raw materials to produce
a finished ink. Blending may occur in the same or in a different tank used for premix.

       Once the ink has been blended, it is filtered through various filter media to enhance the
quality and uniformity of the product Filtering also acts to screen out impurities.

       After the ink has been filtered, it is pumped or emptied into shipping containers. Whites
are normally shipped in  400 gallon tote bins while most other products are shipped in 55 gallon
drums.

       The  ICI  Specialty  Inks  facility currently  manufacturers over 200  blended  products.
Formulas change daily, so ICI Specialty  Inks keeps a computerized database of several thousand
active  product formulations.  Because of the. wide variety of products and because  65 to 70
percent of business is same day  shipments, ICI  Specialty Inks does  not dedicate manufacturing
equipment to specific products.   Some equipment is dedicated to certain colors (e.g., whites  and
clears) while other equipment is  dedicated to ink type (i.e., water or solvent) products.

       ICI Specialty Inks uses a variety of equipment during the premix and blending stages. The
facility has many mixers, which  are used depending in part on batch size. Drum-sized batches
made in the drum itself may be  blended with a portable  mixer called a Lightning Mixer. Other
materials made  in portable mix tanks may be  blended  using larger, permanent high-speed or
variable-speed mixers.  In some cases, an ink  will be premixed with one mixer,  moved to a
dispersion mill for grinding and  milling, and then transferred back to the same premix mixer for
blending operations.

       ICI Specialty Inks operates several types of dispersion mills  including three ball mills, a
sand mill, horizontal small media mills, and mix tanks.  ICI Specialty Inks makes solvent based
inks in the ball  mills.  Two ball mills are dedicated to the manufacture of black and blue inks
while the other mill is used for colored ink production.  Ball mills are rotating cylinders, mounted
horizontally, and filled with grinding media.  Because these mills  are used to make solvent based
inks, they contain steel ball media used to disperse pigment.  These mills generate heat during the
grinding process, so they are jacketed and water cooled.  Production personnel manually load raw
materials (i.e., premix liquids, powders/pigments,  and additives) into the mills from  a catwalk
through a top chute.  Solvents are either pumped from drums or from bulk storage tanks through
a manifold system into the ball mills.  Other materials are added directly from bags or drums into
the mill.  In some cases (e.g., material adjustment), material is dispensed with buckets. Material
loading is done during the day and the grinding process, which is noisy, is done  during the night
and  is controlled by a timer.  The following day, the product is inspected, properly adjusted, and
then unloaded by gravity feed, filtered, and packaged into containers for shipment or for further
use  as intermediates in  the facility.  Ball mills approach a closed system as they are open only
during addition  of raw material  and product filling operations.         v
   CH-92-02

-------
       Horizontal mills are similar to ball mills except that they are much smaller and operate
continuously rather than by batch although they are fed by batches. Rather than using steel balls,
ICI Specialty Inks's horizontal shot mills use tiny various grinding media.  Rather than having
a rotating hollow cylinder tumble media as in the case of the ball mills, the shot mills feature a
stationary hollow cylinder with a rotating internal shaft which has pegs affixed to vigorously
agitate the  media.  The Winston-Salem facility manufactures water based inks in one mill and
solvent based inks in the other.  Some of the products manufactured in the water based shot mill
are shipped to customers while other products are sent to sister  ICI Specialty Inks facilities. ICI
recently chose the Winston-Salem facility to begin producing waterborne base concentrates for
use in other ICI owned ink plants.

       ICI Specialty Inks also operates a sand mill to manufacture solvent based inks.  This mill
uses fine-grained Ottawa sand to accomplish pigment dispersion.  Material enters through the
bottom of the mill and is forced up through the sand to an open-top filtering screen.  The screen
often clogs as the material filters out of the  mill and into a receiving hopper.  Because the mill
must be scraped down regularly, enclosing the filter would create processing difficulties.

       In addition to  the  mills, ICI  Specialty Inks operates a  number of fixed mix tanks with
agitators which are  used  for mixing, milling, and blending both water and solvent based white
inks and varnishes:   Two of these  mix  tanks are dedicated  to the production of white  inks.
Material is added through the top, agitated, and gravity fed out the bottom.  The top openings on
the mix  tanks are covered with permanent aluminum lids which  are opened only during the
addition  of product components.  The lids contain a center opening through which the agitator
shaft extends.  The lids also have a small hinged opening to allow for gradual product additions.

       The ICI Specialty Inks facility operates 9 hours per day, 5 days per week,  52 weeks per
year. A typical batch can take 3 to 20 hours to complete.  More time is required to manufacture
colored rotogravure inks  than other inks.   Viscous or dry materials take  longer to grind and
achieve proper dispersion than less  viscous materials.  Batch  sizes range from five gallons to
1,100 gallons.

       Equipment is cleaned manually on an as-needed basis.   Cleaning frequency depends on
the number and size of batches processed, the size of the equipment to be cleaned, and the  color
and type of ink manufactured.  After a mill or tank has  been emptied,  solvent is added to the
vessel to capture remaining product residue.  The wash solvent is drained from the tank and
recycled into  the next product batch of that particular product whenever possible.   Disperser
blades are cleaned with ethanol and n-propyl-acetate, which is used repeatedly until it is pigment
saturated.  Once becoming unusable as a cleaning solvent, the wash material is sent off-site as
hazardous waste. Mills are cleaned by replacing the residual heel of the  exiting product with an
equivalent amount  of solvent which is compatible  with both the preceding and the ensuing
batches.  Some base raw materials and solvents are handled via a manifold system using dedicated
process lines.  Therefore, cleaning  of these lines is limited.  ICI  Specialty Inks is  unable to
schedule consecutive  production batches  of similar products to reduce  equipment  cleaning
frequency because they operate on a same day shipment schedule.
   CH-92-02

-------
       D.    Volatile Organic Compound Control Experience

       The ICI  Specialty Inks facility  has  no add-on control devices for the capture and
destruction of VOCs. Volatile organic compounds emitted from the manufacture of solvent based
inks are controlled through equipment modifications such as tank covers.

       Drop hoses are used around all mixing and some milling equipment to capture and remove
VOC material from the work area.  Captured  emissions are routed through the hoses to a central
ventilation system and eventually to the outside. The facility also uses fans operating at 6000 cfm
to achieve approximately six air exchanges per hour in the manufacturing area.

       ICI Specialty Inks operates under permit no. 00758-001-P in accordance with Section 3-
166 of the Forsyth County Air Quality Technical Code, which restricts the ink facility from
emitting  more than 40 pounds of photochemically reactive compounds in a 24-hour day. This
permit also requires that all ink manufacturing vessels be covered at all times  while mixing,
storing, transferring,  and handling.

       Because the facility's VOC control emphasis has been on lids, ICI Specialty Inks has tried
several different types. Initially, the facility used homemade plywood covers on both drums and
mix tanks. The wooden covers were difficult to clean, so ICI Specialty Inks stapled plastic to the
bottom.  The plastic frequently came loose  and would be pulled into the mix tank, tangling with
the mixing blade.  ICI Specialty Inks then tried using Kraft paper in hopes that the lighter weight
would prevent the staples  from pulling away from the wood. The paper did remain attached to
the wood, but it became saturated with ink.

       ICI Specialty Inks then, moved to aluminum lids.  Flat lids, which are made by a sheet
metal contractor, cost $20 to  $25 dollars for drums and $300 dollars for a 250 gallon mix tank
(see Attachment 3).  The  flat lids have worked relatively well, but they do have some inherent
flaws.  The lids do not form a complete seal with the mix tank and the hinged door product
addition chute does not always remain closed.  For these reasons,  ICI Specialty  Inks moved to
conical lids which are a better engineering design. The conical aluminum lids cost $1500 dollars.
The added weight and bulky shape led to' worker ergonomic difficulties. Because  these lids were
difficult to handle, they were  damaged more often than the flat lids. The increased replacement
and upkeep costs prompted ICI Specialty Inks to return to flat lids.

       ICI Specialty Inks may now change to stainless steel lids because of the recent information
released by die Bureau of Mines in England dealing with the reactions of aluminum and steel.
Many of the facility's portable mix tanks and permanent  blend vessels are carbon  steel.  In
addition, almost all of the 55 gallon drums are steel.

       Attachment 4 contains a description of a cover efficiency test conducted at one of the ICI
Specialty Inks's sister facilities. Although the test proved sensitive to weigh scale calibration (one
of two tests done in 1991 proved unrepresentative), it does provide a lid testing methodology and
initial results comparing an uncovered mix tank and a tank covered with a sealing conical lid.
   CH-92-02

-------
       E.     Emission Characterization

       The ICI Specialty Inks facility uses ball mills, a sand mill, shot mills, mix tanks and drums
with mixers in the manufacture of solvent based inks.  Releases of VOCs come from several types
of equipment used in the ink manufacturing process.

       Some solvent ink production is accomplished by blending in 55 gallon drums. The drums
are used to mix product and to keep the pigment in suspension.  Covers are used on the drums
during the mixing process but emissions still occur from the small  opening through which the
agitator shaft extends and from around the edges of the lid. All of the solvent based inks that are
made  in mix tanks are made in tanks  covered with lids.  These lids have a  four to six inch
opening through  which the  agitator shaft extends and a hinged opening for  delayed  product
additions.  Emissions can result from both areas.

       Ball mills  are also used in the manufacture  of solvent based inks.  These mills approach
a closed system, as they are open only  during raw material adds and product filling operations.
It is during these  operations that VOC  emissions can occur.

       Sand mills are used to disperse  pigment throughout the ink. Emissions result from the
exposed screen through which warm product filters, often clogging the screen.  The open screen,
warm product, and scraping down of the filter with a solvent-ladened brush add to total emissions.

       Both of the horizontal shot mills  are closed systems, thus significantly reducing VOC
emissions from processing equipment.  Purchasing these mills, however, is-rather expensive.  ICI
Specialty Inks's 15 liter continuous feed mill cost approximately $160,000.  The smaller five liter
mill, was almost $80,000.  Both mills are jacketed for cooling.

       Another source of emissions is  the manifold system, where solvents are weighed and
transferred from storage tanks to mix tanks, mills, or drums. Emissions may occur during transfer
and hose connecting and disconnecting.

       In addition to emissions from process operations, VOCs are also released from a variety
of cleaning operations.  Emissions occur during  cleaning solvent addition and removal, as well
as during manual  cleaning of tanks and mixing blades with solvents and brushes. ICI Specialty
Inks has tried to use automatic tub washers which seal with a tank, pull a vacuum, and circulate
cleaning solvent on a timed schedule. The washers have not worked well at the Thiele-Engdahl
Winston-Salem facility. The washer did not seal with the tank, and consequently did not attain
the required vacuum.  The timer did not work correctly, resulting in  insufficient cleaning.  In
addition, the  automatic washer required a large air supply to operate the pumps and produced a
high noise level.

       The Regent Drive  Site calculates SARA Section 313 releases  based  on consumption
figures, and only  limited studies have been done to determine emission breakdown by specific
process or product.  The facility has not examined emission contribution from janitorial supplies.
  CH-92-02

-------
Attachment 1
               TOTAL 1991 VOC PURCHASES
       TOLUOL
       ETHANOL
       ISOPROPYL-ACETATE
       LACTOL SPIRITS
       BUTYL CARBITOL  .
       ETHYL ACETATE
       IS OPROPYL-ALCOHOL
       N PROPYL-ALCOHOL
       VM&P NAPTHA
       DOWANOL PM
       MEK
       HEPTANE
       N PROPYL-ACETATE
       TOTAL POUNDS IN INTERMED.
       VARNISHES
       TOTAL PURCHASES OF VOC'S/1991
(IN POUNDS)
     53433
    711650
    112530
       669
     11004
     17272
     13600
    197950
      8909
      5550
       366
    142175
    281575

    444175
    2000858
  CH-92-02

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                        INK MAiNUFACTURJNG OVERVIEW

       Raw Material Receiving/Storage.  Liquid materials are  received in drums or in bulk:
       solvents used in large quantities are stored in above or below ground storage tanks and/or
       in portable "tote" tanks.  Dry  materials are received and stored in bags or drums.

2.     Dispersing.  This is the production of an intermediate product, usually referred  to as a
       base.  A 'premix' is performed in which vehicles (i.e., solvent, alcohol and/or water) are
       added to a mixing vessel, along with any dry pigments and other chemicals. The batch
       is mechanically mixed with a  special slotted blade. Typically the mixing vessel has a
       cover with an orifice which the mixer shaft goes through, and a small hinged opening to
       allow delayed addition of certain raw materials,  after mixing has already commenced.
       The result of the dispersion/mixing operation is a raw concentrate which has the potential
       to become any  of a family of specific end products (inks), but  which requires  further
       processing to do so.

3.     Grinding/Milling.  This is the  step of taking a raw base, which still contains fairly large
       particles (250 /im) and incompletely mixed pigment,  and grinding  it.  The premix is
       pumped through a chamber containing sand, steel shot or other  small  spherical  media.
       Mechanically driven discs,  or a rotor,  is used to churn the media and  break  up the
       pigment agglomerates. The result is a more homogeneous product with improved gloss
       and other physical properties.  Tne operation is a batch one, in which a pre-mixed base
       is pumped through the mill and  into a receiving vessel.  Using a 4,000 Ib. batch as an
       example,  the process can  take  from 3-4 hours  up to 20,  depending on whether re-
       grinding is needed.  Mill types include semi-closed (as in the attached flow diagram) and
       closed units.   Ball mills are a special type  of closed  unit which does not-  feature
       continuous product feed.  Instead, raw materials are added to a hollow vessel containing
       approximately 1" diameter  spheres; the  vessel is closed and slowly turns, tumbling the
       contents to mix them. Tne result is usually an  intermediate (base) rather than a finished
       product.

4.     Blending.  Intermediates and  any raw  materials not needing previous processing are
       mixed in specific quantities to produce a finished ink.  The blending occurs in the same
       vessel, or a vessel similar to that used in the dispersing/premix step.

5,     Filtering.  Finished product is strained through cloth or other filters to enhance quality
       and uniformity  of the product.

6.     Packaging.  After filtration, finished product is  pumped or emptied into  the final shipping
       container:  pails, drums,  portable tanks  or occasionally tank trucks.

7.     Cleaning. Blending vessels, mills, filter  screens and other equipment is  routinely cleaned
       with solvent after production of an ink formulation. In a few plants, only one color or
       a limited number of colors are produced, eliminating the need for cleaning between color
       changeovers.  With  mixers, the vessel  will be completely cleaned and emptied; with
       mills, typically  a residual 'heel' of finished product is replaced by an equivalent quantity
       of clean solvent which is compatible with both the preceding and ensuing batches.

-------
00'       DO
^saz^fcsoSTJZzsaan	
^CE^fj
                                    D
 RAW MATERIAL RECEIVING
          Ink Manufacturing
           Flow Diagram.
    /ID
p-3C3Z=SC?3fc3CZ2J
rrj
               U'OO
    ./in
                 DO
      FINISIIEU GOODS SI IIPMEU F
                          MAW MATERIAL STORAGE
                                           .	
                                       9o1tfnU  i..	. ,.\
                                       P..IMI  || \~ I
                                                           lotvnU
                                             La
                                                 DISPERSINQ (PREMIX)
                                                                CUTTING
                   DASE MILIMIGJDA11_M!LLSL
                                     DISPERSING (GRINDIflG)
                                     FILTRATION
                                                                 DLENDING
                  FINISHED GOODS STORAGE

-------
ttactunent
                      Typical  Fiat  Mix  Tank  Cover
   Hinged  Door
   Allowing Agitator
   Shaft Entry
                                                       Opening for
                                                       Agitator Shaft
                                                               Hinged Door
                                                               for Material
                                                               Additions

-------
                                                                                     Attacnment  4
  September 23, 1991
Thiele-Engdahl
7830 North Point Siva.
Suite 101
Winston-Saiem
Nonh Carolina 27106-2209
Telephone (919) 759-025J.
Fax '(919) 759-0381
   Mr. Mike Kirkland
   Engineer
   Forsyth Counry Environmental Affairs Department
   539 N. Spruce Street
   Winston-Salem, NC  27105

   Dear Mr. Kirkland:
   This is to report to  you concerning the results of the emission test observed by you at our
   Fairchiid Road Plant on September 16. 1991. For your information, spread sheets are attached
   for both this test and the August 19, 1991 run (which proved to be unrepresentative due to weigh
   scale calibration problems).

   Tne processing sequence, in review, can be described as follows:

          a)  Empty mix tank weighed

          b) Pre-mix ingredients added to mix tank (to achieve respective proportions in batch),
             while tank is still on weigh scales:

             1)  Toluene
             2)  Liquid and dry ingredients, designated 'A',  'B', and 'C'

          c) Transfer mix tank to work station,  start mix

          d) Determine weight of additives to be introduced at mixer

              1)  Weigh pallet of additives #1 and *1
             2)  Hand carry bags of additive #1  to mixer, add, and return empty bags to pallet
             3)  Record weight of pallet after target weight of additive #1 achieved in mix tank
             4)  Hand carry bags of additive #2 to mixer, add, and return empty bags to pallet
             5)  Sweep  up any  spillage of additives #1 and #2 and return to pallet
              6)  Record weight of pallet including unused bags of product, subtract (d)(l), above
Chicago   Cleveland    Richmond   Winston-Salem    Chattanooga   New York   Cincinnati   West Monroe   Berkeley
Part at 101 Specialties   A Business Unit of 1C! Americas Inc.

-------
                                                                                 Attachment 4
Mr. Mike Kirkland
September 23, 1991
Page 2


          7) Add net weight of any quantity of additive #1 or additive #2 not included on the
             original pallet, i.e., if it did not have enough of one of these and it was necessary
             to supplement from a bag not on the original pallet, etc.

       e)  Complete mix cycle, take samples for quality control

       f)  Record weight of full mixing vessel at scales*

This concludes the process cycle for batch mixing, the operation for which the control equipment
effectiveness is being measured. As you observed, an ancillary operation,  drum-off of a finished
batch,  occurs immediately after the mixing.  The data associated with this is appended for
completeness.

However, it is emphasized  that the drum-off data should not  be considered applicable  in
evaluating the effectiveness of the mixing vessel covers.  As you may recall, the staging of the
mixing vessel during drum-off required the vessel to be tilted, so that the cover was  only
partially in place  (the material  charging hatch was open).  More importantly, the solvent loss
during drum-off came, in large part, from the open drums during the fill.  Also contributing was
the operation and manipulation of  the filter bags attached  to the tap near the bottom of the
vessel.  Neither the drums nor the filter bags were able to be affected by the mixer cover - only
the mixing operation  was.   For this reason, the percent emissions reduction achieved by this
control equipment is evaluated  for the process steps during  which it is "doing something", (b)
through (f), above.

Reviewing the results of the September 16,  1991  test, the total weight of all batch ingredients
and of the 10 drum mix vessel was  4789.5 Ibs., using the cover.  The weight immediately after
the mix was completed was 4787.5  Ibs; after waiting on the scales due to QA/QC approval and
to a rush order being run, it was 4786.5 Ibs.  Allowing for two (2) 4 oz. quality  control samples
that were withdrawn,  the net loss during the test was (4789.5 - 4786.5 + 0.25  + 0.25), or 2.5
Ibs.

For the test without a cover, the weight of the mix vessel and of all ingredients was 4,702 Ib.
The weight after the mix and after a waiting period approximately the same as that following
the covered-mixer test was 4679.5 Ibs. Allowing for the 0.5 Ib.  withdrawal for quality control
samples, the net loss  was (4702 - 4679.5 + 0.25 + 0.25),  or 22.0 Ibs.
       May be done either before or after QA/QC clearance, but should be consistent for both
       covered and uncovered mixing vessels.

-------
                                                                                ACtacumeuL
Mr. Mike Kirkiand
September 23, 1991
Page 3
Based on the above, the control efficiency of the mixer cover is 22.0 - 2.5 x 100%, or 88.6%.
                                                           22.0
This is consistent with previous data, though we would not have been surprised  by higher
numbers given improvements in the cover design.

We  believe this  data indicates  compliance with Forsyth County Environmental Affairs
Department regulations.  Please let us know if you have any questions regarding the report.
Thanks for your time and attention.

Sincerely,
Stephen W. Paine
Environmental Engineer
 cc:    (with attachments)

       T. A. Elliott
       Scott Trethaway
       John Tanner
       Steve Sutton
       Bruce Gammon
       Hank Greenwood

-------
                                                                                     Attachment 4
              MIX VESSEL COVER TEST - SEPTEMBER 16. 1991
                  VESSEL wrra COVER

Tank
Toluene
Ingredient A
Ingredient B
Ingredient C
(Stan Mix)
Pallet inci. mix
additives
: #1 
Pallet less mix
additive if I
Pallet less mix
additive #2
Partial bag
sunplcment
Mix complete;
Quality control
sample taken
Weight after
mix
Weight after
j QA/QC holding
Time & wait
on scales
Item Wt.
Pounds
930.5
2753.5
151.0
76.5
38.0

988.0
537.5
148.5
N/A
(0.5)


Batch
Total
Lb.
930.5
3684.0
3835.5
3912.0
3950.0


4400.5
4789.5
N/A
4789.0
assumed)
4787.5
4786.5
Time *
9:41 a.m.
10:02 a.m.
10:06 a.m.
10:11 a.m.
10:17 a.a.
10:29 a.m.

10:25 a.:n.
10:44 a.m.
N/A
11:34 a.m.
11:39 a.m.
1:58 p.m.
    Net loss with cover
4789.0
4786.5
   2.5
                             VESSEL WITHOUT COVER
Item Wt.
Pounds
848.0
2756
151.0
76.0
38.0

991.5
538.5
178.5
20.0
(0.5)


Batch
Total
Lb.
848.0
3604.0
3755.0
3831.0
3869.0


4322.0
4682.0
4702.0
4701.5
(assumed)
m4688.5
(extrapolated)
4679.5
Time
10:54 a.m.
11:19 a.m.
11:25 a.m.
11:29 a.m.
ll:32a.m.
11:42 a.m.

11:41 a.m.
11:50 a.m.
11:52 a.m.
12:52 p.m.
N/A"
3:23 p.m.
Net loss without cover
4701.5
4679.5
  22.0
    Control efficiency of covers = 22.0 - 2.5 x 100% = 88.6%
                               22.0
    *      When one time recording is  made for an activity, the time indicates completion.
Vessel not weighed immediately after mix due to employee lunch break. Solvent loss between completion of mixing and
later weighing of vessel assumed proportional to total loss during mixing and waiting times, combined. It is emphasized
that a 2 + hour wait for drumming-off b unusual and was caused by trying to fit this test into a given time slot, then having
a rush order come up from a customer, tying up the scales.

-------
                                    DRUM OFF OPERATION - 9/16791
                FROM BATCH MIXED WITH
                VESSEL COVER
                                              FROM BATCH MIXED WITHOUT
                                              VESSEL COVER
        ITEMWT.
        POUNDS
Empty   51
Drums   51
(Net)    48
        51
        48
        59
        51
        49
        51
        49
        508
        TOTAL    TIME
        POUNDS

        4,786.5 ** 1:58 p.m.
                4358
                508
                3,350
        ITEM WT
        POUNDS
Empty  .49
Drums   50
(Net)    50
        50
        50
        51
        51
        49
        51
        50_
        501
TOTAL
POUNDS

4,679.5 
TIME
3:23 p.m.
                       936.5
Vessel weight
inci. final
ciingagc
(0.5 Ib)

solvent retained
by filter *"*
931


1

932~     (932)       2:49 p.m

4.5 Actual loss during drumoff
Vessel weight    848.5
inch final
ciingagc
(0.5 Ib)

Solvent retained
by filter "**    0.25
                                                              848/75     (848.75)     4:08 p.m.

                                                              9.25 arena 1 loss during drumoff
                Time of completion, if not otherwise indicated
                At end of mixing time and QA/QC wait time
                Extrapolated from batch measurements after mix cycle, and after drum off.
                to nearest 0.25 Ib.

-------
          ALLIANCE
          Technologies Corporation
Date:

Subject:
From:
To:
            6 January 1992

            Site Visit-The Perry & Derrick Company
            Paint Manufacturing
            EPA Contract 68-DO-0121; Work Assignment 1-29
            Alliance Reference No. 1638029

            Beth W. McMinn
            Alliance Technologies  Corporation

            Joseph Steigerwald
            OAQPS/ESD/CTC (MD-13)
            U.S. Environmental Protection Agency
            Research Triangle Park, NC 27711
I.
      Purpose
      The purpose of the visit was to gather information on the paint manufacturing process
including information necessary  to characterize the process parameters,  emissions,  control
techniques, and control costs.
II.    Place and Date

      The Perry & Derrick Company
      2510 Highland Avenue
      Cincinnati, OH  45212
      (513) 351-5800

      December 13, 1991
IE.    Attendees

      The Perry & Derrick Company (Perry & Derrick)

      John J. Jones, Plant Manager
      Hugh W. Lowrey, Technical Director
      Gregory P. Schott, Production Manager
                                        i Mil

-------
       U.S. Environmental Protection Agency (EPA)

       Joseph Steigerwald, CTC

       Alliance Technologies Corporation (Alliance)

       Beth W. McMinn
       Stephen A. Walata
IV.     Discussion

       A meeting  was held with the personnel  from Perry & Derrick to  discuss the paint
manufacturing process.  The discussion focused  on market profile,  manufacturing  supplies,
manufacturing process parameters, volatile organic compound (VOC) control experience, and
emission characterization.  This discussion was followed by a tour of the production facility in
Cincinnati,  Ohio, and then  by a short closing meeting.

       A.    Perry & Derrick's Market Profile

       The Cincinnati facility produces both water (latex) and solvent (oil) based industrial and
consumer paints. Perry & Derrick's industrial coatings are used in many markets including metal
cans and containers, metal furniture, general metal, machinery and equipment, and electronics.
Perry & Derrick does not  sell paints into coil coating, exterior car coating, wood finishing, or
major appliance coating areas. The company's consumer paints are sold over the counter under
manufacturer and private labels to customers for interior and exterior painting needs.

       Perry & Derrick began manufacturing resins and solvent based  consumer paints in 1913
in Dayton, Kentucky, with sales offices in Cincinnati, Ohio. The family-owned business gradually
expanded into the industrial market.  In the late  1950's, a fire in the Dayton facility raw material
warehouse caused the company to move paint manufacturing operations to Cincinnati. This move
also prompted Perry & Derrick to begin manufacturing latex consumer paints. The resin facility
remained in  Dayton.  As  environmental and  Occupational  Safety and  Health Administration
(OSHA) rules became more stringent, Perry & Derrick  made the decision  to leave  the resin
manufacturing business.  Since  1987, Perry & Derrick has manufactured only consumer  and
industrial paints.

       Water based paints  currently  account for 59 percent of total production with 55 percent
being consumer products and 4 percent being industrial products.  The remaining 41 percent of
manufacturing is solvent (oil) based; 17 percent  of this market is for consumer use  while 24
percent is for industrial use. Two years ago the Perry & Derrick sales team asked thier industrial
solvent based paint  customers  to  move to water based coatings.   Although the customers
demanded,  and some still require, solvent based products,  Perry & Derrick has concentrated new
product development in the area of waterborne coatings. Some product development still occurs
in the area of solvent based products.  The majority of Perry & Derrick's consumer  products
contain less than one pound per gallon VOC, but some gloss and semi-gloss latex paints contain
                                                                 X

  CH-92-02                                   2

-------
nearly three pounds. Industrial coatings range from water thinned products with almost zero VOC
to conventional lacquer-type coatings (manufactured for unregulated customers) with as much as
six pounds per gallon VOC.

       The Perry & Derrick facility produces just under  1,000,000 gallons of paint annually.
They also employ a total of 77 people, 48 of whom are production employees.

       B.    Manufacturing Supplies

       Perry  & Derrick uses approximately  700 raw materials in their  paint manufacturing
processes.  In addition to the solvents and alcohols described in Attachment 1, Perry & Derrick
also purchases and uses a variety of resins, pigments, and  additives. Perry & Derrick regularly
calculates VOC content using a finished product rather than a raw material standpoint.

       C.    Manufacturing Process Parameters

       Since Perry & Derrick left the resin production business in 1987, the paint manufacturing
process at the Cincinnati based facility has been a batch process materials handling operation.
The method  of product formation is by mixing and blending rather than by reacting materials
chemically.  The four main manufacturing operations are completed in the  following order:

                    preassembly and premix
                    pigment grinding/milling
                    product finishing/blending
                    product filling/packaging

       The first step in the manufacturing process is preassembly and premix. In this step, the
liquid raw materials (e.g., resins, solvents, alcohols, and/or water) are mixed  in portable containers
to form a honey-like material to which pigments are added.  The pigment and liquid mixture form
a viscous material which is  then sent to  the grinding operations.

       The grinding or milling stage serves to further disperse the pigment throughout the paste.
Once the customer-requested grind specifications are met,  the paint mixture is transferred to the
product  finishing tanks.  Normally,  this step  serves to disperse insoluble solid materials.  If
insoluble materials are not present, the grinding/milling stage may  be  omitted as sufficient
blending will have occurred in premix.

       Final  product specifications are achieved in the blending or product finishing step. Here,
the paint mixture from the  dispersion operation is tinted, if necessary, and further reduced, or
letdown, with resins,  solvents, and alcohols or water in agitated tanks.

       Once the paint has been "finished," it can be transferred from the finishing tanks into pails,
drums, tote tanks or tank wagons for shipment.  The paint is normally filtered during the transfer
step.
   CH-92-02

-------
       Perry & Derrick offers their customers more than 1000 different products.  Many of these
products are manufactured for specific customer needs.  Paint formulations change as customer
requirements change.   New  product development and product revisions typically occur several
times per week.   One base  product may have  several different variations which  may  be
manufactured in a variety  of equipment.  Because of this, Perry & Derrick is unable to  dedicate
manufacturing equipment to specific products. Most of the equipment is, however, dedicated to
paint type (i.e., water/latex or solvent/oil).  In several cases, equipment is further reserved for
industrial solvent  based paints or consumer latexes.

       Perry & Derrick uses high speed dispersers, mixers, Kady mills and ball/pebble mills in
the preassembly and premix stage. The agitation keeps  the pigment in suspension  and  supplies
the dispersion equipment with a consistently mixed material. Dispersers and mixers are used with
insoluble powders prior to the milling stage.  If the dry materials are soluble, transfer to another
type of dispersion equipment is unnecessary. Product milling, Step 2, and premix, Step 1, may
be accomplished in a  single process.

       Perry & Derrick currently operates four types of dispersion equipment: Kady mills, media
mills,  ball/pebble mills, and high speed dispersers.  Ball/pebble  mills are rotating cylinders,
mounted horizontally, and filled with grinding media.  The company operates one steel  ball mill
which  is used to  disperse pigment in solvent based paints.   The pebble mills, which  use flint
pebbles as grinding media,  disperse  both oil and water based products.  Certain paints can be
made in entirety in ball mills and packaged directly into containers.  The mills are  loaded through
a top chute with raw materials (i.e., premix liquids, powders/pigments, and additives) during the
day and the grinding  process is completed during  the night.  The  following day the product is
inspected, properly adjusted, and  then unloaded by gravity  feed,   filtered, and packaged into
containers for shipment. The mills run at night because of the noise  generated during the grinding
process. They approach a closed system as they are open only during additions of raw materials
and product filling operations.

       The media mill at the Perry & Derrick facility is a sand mill. Rather than using sand, this
vertical  mill uses tiny glass, ceramic, or  zirconia media to accomplish pigment dispersion.
Material enters through the bottom of the mill and is forced up through the media to an  open-top
filtering screen.

       Kady mills are unlike most of the other dispersion mills in that they are jacketed  allowing
for heating capability. These mills have permanent lids which allow them to be  covered during
grinding operations.   Perry & Derrick uses Kady mills for the  production of solvent based
material. The largest  of the  facility's three Kady mills is used in the manufacture  of a high-solids
paint.

       The Perry & Derrick facility  also uses high speed dispersers to grind pigment into paint.
These  dispersers  are  adjustable and are used with portable mix tanks.  The portable  tanks are
covered during the manufacture of solvent based products.  Covers are normally made of stainless
steel with openings for the agitator shaft.
   CH-92-02

-------
       Some products manufactured by Perry & Derrick are finished in the equipment in which
they completed the dispersion process.  Others are transferred to permanent blend vessels for
product adjustment and letdown.  In the permanent vessels, material is added through the top,
agitated, and gravity fed out  the bottom.  The top  openings on the tanks are covered with
permanent lids, which are opened only during the addition of product components.  When the
product is ready to be packaged, it is transferred to the filling department where it is filtered using
a Vorto-Siv, a nylon mesh or felt bag, or a cartridge filter.

       The Cincinnati based facility operates eight hours per day, 298 days per year.  Batch sizes
range from less than one gallon to 1600 gallons, with most of the production volume coming from
batches in the 300 to 1600  gallon range.  Process tanks range from  a 270 gallon ball mill to a
1600 gallon mix tank.

       Equipment is cleaned after each batch.  The  degree of cleaning depends on the size of
batches processed, the size of the equipment to be cleaned, and  the color and type of product
manufactured.  Every effort is  made to minimize equipment cleaning. The Production Manager
attempts to  schedule  similar  product batches  while Perry  & Derrick's in-house  laboratory
determines the degree of cleaning required based on the  compatibility of consecutive batches.
Equipment used to manufacture water based products is cleaned with a water based cleaner while
equipment used to manufacture solvent based products  is cleaned with solvent.  In most cases,
the spent cleaning liquid is retained and used as a vehicle or thinner in the next similar product
batch.  Filter bags and other  straining equipment used in  product filling operations are also
cleaned with the recyclable wash liquid.  Process lines are dedicated to certain raw materials and
therefore are cleaned only on a limited basis.  The amount of wash solution used for equipment
cleaning ranges from 2 to 50 gallons.

       D.    Volatile Organic Compound Control Experience

       The Perry & Derrick facility has no add-on control devices for the capture and destruction
of VOCs. Volatile organic compounds emitted from the manufacture of solvent based paints are
controlled through equipment  modifications  such as tank covers.   In addition to  modifying
equipment to reduce solvent emissions, the company has altered their cleaning procedures and
focused much  of their new product development in the  area of waterbornes.

       Although management at the Cincinnati based Perry & Derrick facility feels that they have
significantly reduced VOC emissions over the past few years, they will have difficulty proving
this if they are required to  do so.  As with many small paint and ink manufacturing facilities,
Perry & Derrick has not performed any VOC measuring or testing of stacks primarily because of
the cost involved with conducting EPA-approved test methods.

       Drop hoses are used around  mixing and milling equipment to capture particulate matter.
These hoses are routed to a dust collector and then to dust collection drums. Pigment particles
transferred to drums are accumulated and are eventually recycled back into similar paint batches.
       E.     Emission Characterization
  CH-92-02

-------
       The Perry & Derrick facility uses ball/pebble mills, Kady mills, vertical media mills, mix
tanks, and blend vessels in the manufacture of solvent based paints.  Releases of VOCs come
from several types of equipment used in the paint manufacturing process.

       Ball/pebble mills  are  used in  the  manufacture of solvent based  paints.  These  mills
approach a closed system, as  they are open only during additions of raw materials and product
filling operations.  It is during these operations that VOC emissions can occur.

       VOCs may be emitted during solvent based paint blending and milling operations in the
Kady mills.  The mixing  operations generate friction  which causes product temperatures to rise
resulting in the volatilization of organics in the paint formulation. Emissions may also be released
during material additions  when the mill covers are open.

       Vertical media mills, or sand mills, are used  to disperse pigment  throughout the paint.
Emissions result from the exposed screen, through which warm product filters, possibly clogging
the screen.  An operator might apply solvent to unclog the screen, adding  to total emissions.

       Another emission  source is portable mix tanks and blend vessels. Portable mix tanks are
used to mix product and to keep the pigment in suspension.  They are  also used  to transfer
material from one manufacturing stage or area to the next.  While they are being used for mixing,
the tanks are often, but not always, covered. If a cover is used on a mix tank during mixing, it
will have a four to six inch opening through which the agitator shaft extends. In some  cases (e.g.,
water based paint manufacturing), only a splash guard is used to cover the back  half of the mix
tank.  When mix tanks are  used for temporary storage, they are covered with a solid lid.  None
of the lids seal with the mix tank. Blend vessels not equipped with sealing lids are another so.urce
of VOC emissions.  Emissions may occur during product  addition through the  top opening.
Because the lids do not form a seal with the tank, gradual emissions  during paint processing are
possible.

       Emissions are also possible from the scale systems where solvent and resin raw materials
are measured and transferred from storage tanks to mix tanks or other containers.  Emissions may
occur during transfer and hose connecting and disconnecting.

       In addition to emissions from process operations, VOCs are  also released from a variety
of cleaning  operations. Solvents are used to clean the Kady mills and other  equipment used  to
manufacture solvent based paints. Emissions occur during cleaning solvent addition and removal.
       Perry & Derrick calculates SARA Section 313 releases based on consumption figures, so
no studies have been done to determine emission breakdown by process.  The facility has not
examined emission contribution from janitorial supplies.
  CH-92-02

-------
Attachment 1
                           SOLVENTS
               TOLUOL OR TOLUENE
               NORMAL BUTYL ALCOHOL
               BUTANOL NORMAL
               BUTYL ACETATE
               BUTYL ACETATE NORMAL
               METHYL ETHYL KEYTONE
               METHANOL
               LACOLENE
               LACTOL SPIRITS
               ANHYDROL ANHYDROUS (PM4081)
               TEXOL A-2 ANHYDROUS
               ANHYDROUS ISOPROPANOL 99%
               TEXOL A-2 ANHYDROUS
               ANHYDROUS ISOPROPANOL 99%
               ISOPROPYL ALCOHOL ANHYDROUS
               ETHYLENE GLYCOL REG. SP
               HI-INITIAL V.M.&P. (R-66)
               SC SOLVENT NO. 150
               HI SOL 15F
               EXKIN NO. 2
               SKINO
               TROYKD ANTI SKIN B
               METHYL ISOBUTYL KETONE
               BUTYL CARBITOL-GLYCOL ETHER DB
               LOW ODOR BASE SOLVENT R66
               TURPENTINE
               MINERAL  SPIRITS (R-66)
               SOLVENOL NO. 3
               SC SOLVENT #28
               ffl SOL #70
               KWIK DRI OHIO APC R-66
               HI SOL 10
               140 SOLVENT (R-66)
               XYLOL OR XYLENE
 CH-92-02

-------
             GLYCOL ETHER EB
             UCAR FILMER IBT
             TEXANOL
             PROPYLENE GLYCOL IND.
             ETHYL BENZENE
             METHYL NORMAL ANYL KETONE
             AMYL ALCOHOL
             #2 ETHYL HEXANOL
             GYLCOL ETHER PM ACETATE
             GLYCOL ETHER PM
             DI PROPYLENE GLYCOL
             NIPAR S-10
             GLYCOL ETHER EP (EKTASOLVE)
             METHYL CARBITOL
             GLYCOL ETHER DM
             SUNTHENE 410
             HEXYL ACETATE (MIXED ICOMERS)
             ISOPRQPYL ACETATE
             MAGIE EXK 385 (SP 6325)
             NIPAR 640
             RECLAIMED SOLVENT
CH-92-02

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r
                                  12-12-91
DESCRIPTION OF PAINT MANUFACTURING PROCESS
      AT THE PERRY ,k DERRICK COMPANY
AJ1  paints and coatings  m&mn'sctured  by  Perry  & Derrick  are  made  by  t h?  .*. ?!.
batch  process, with batch  sizes  covering the range  from  one  gallon  or  Ks  t 
1600 gallons, but with most  of  the  production  volume  coming  from  batches  in I he
range  of  300  to  1600  gallons.   The  number  of products  offered  by  the rnmp:mv_nt
any  one  time  Is  of the order  of  one thousand.   The  number  of ingredients  used
at any one time,  Including equivalent materials purchased  from different
suppliers, is probably in  the  range of 1500  to 2000.   Many products  are-
manufactured  to  meet  the specific needs  of  Individual  industrial  cus I omi-r.-; .
New  product  developments and  product  revisions occur  several times  in a  tvplml
week.  Because different kinds  of equipment  may be  used  for  the same purport.-
and  because  the  potential  number of products requiring slightly different
variations of the process  Is  virtually without limit,  the  number  of  process
variations  Is too large  t  permit a detailed description of  each  one.

Liquid storage  of paint  ingredients is In bulk tanks  of  2500 to 8000 gallon.-,.
in tote  tanks of 200-300 gallons, In 55  gallon drums  and to a minor  dpgrpo  IM
smaller  containers.   Measurement of liquids  is by metering or weighing.
Soluble  solid  Ingredients  are  stored In  flaked, prilled, solid or powdr-r form
In paper  bags or fiber or  stpel drums of 50  to 500  pounds  net weight.
Measurement  is  by weight or by counting  prewelghed  packages.  Insoluble  dry
pjowder ingredients are stored  in paper bags  or fiber  drums of 10  to 200  pounds
net  weight.   Measurement is by the same  methods as  for soluble solids.

Production scheduling and  control are exercised by  Issuing a factory batd)
ticket and  a separate filling ticket for each  batch prior  to manufacture.
These  documents  accompany  the batch through  the factory.  They identify tli=-
product  and  the  quantity to be manufactured,  the amount  of each  ingredient.
equipment to be  used, and  they carry any special instructions, saf et v/bal  Mi
information  and  packaging  Instructions.   Pertinent  Information is recorded on
them during  manufacturing, and they become permanent  records of  the production
of  the batch.  When  a batch requiring paper  labels  is scheduled,  a  separate
written  instruction  goes to the  print shop where the required number of labels
  s printed.  For non-consumer products, a separate written instruction zoes I
  he regulatory computer operator, where the required number of hazard
  ommunication labels Is printed.
 The initial manufacturing step Is to transfer material from storage  to a  lank
 or mill, premix liquids and Insoluble powders and dissove soluble solids.   The
 equipment used may be a mixer, high speed dissolver/diaperser, KD mill or
 ball/pebble mill.  If insoluble  powders are present,  the next  step  Is  to
 disperse the powder to the desired degree using a high speed  disperser. KD
 mill, media mill or ball/pebb]e  mill.  Satisfactory  dispersion is confirmed by
 laboratory test.  If Insoluble powders are not present, the dispersion stip Is
 omitted, and in either case the  next step is to- reduce the batch  with  n\*
 balance of the liquids to be  used, with small amounts withheld in somp cas.s
 for later adjustment, of physical  properties.  If color adjustment Is rpqnir<1.
 concentrated dispersions of dry  color are added as necessary.   Each batrh Is
 then sampled and the sample is laboratory tested for  physical  properties.
 composition and performance according to a test protocol established si-pnml  I y
 for each product.  If test results do not show the batch to be within  .-.p'-ft f I H-.I
 limits, adjustments are made  under laboratory direction by adding small  amount.'-.
 of ingredients to the batch.  Straining instructions  are confirmed  or  revised
 by the  laboratory.

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The batch then  an* 5  to  I he  fill Ins department where it  15  strained  n*;-"* -
Vi'n11 i'i-S'i v, a  nyl.ni)  me-?!)  '>  OU hag.  or a cartridge filter.   The  mesh r min
are then  transferred to  t IIP warehouse/shipping department, where  add Mi nun I
labeling  Is done  1C  r.'qnlr*d Cor transportation.

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          ALLIANCE
          Technologies Corporation
Date:         6 January 1992

Subject:      Site Visit--Borden Packaging and Industrial Products
             Ink Manufacturing
             EPA Contract 68-DO-0121; Work Assignment 1-29
             Alliance Reference No. 1638029

From:        Beth W. McMinn
             Alliance Technologies Corporation

To:          Joseph Steigerwald
             OAQPS/ESD/CTC (MD-13)
             U.S. Environmental Protection Agency
             Research Triangle Park, NC 27711
I.      Purpose

       The purpose  of the visit was to  gather information on the ink manufacturing process
including  information  necessary  to  characterize the process  parameters, emissions,  control
techniques, and control costs.
II.    Place and Date

      Borden Packaging and Industrial Products
      630 Glendale-Milford Road
      Cincinnati, OH 45215
      (513) 782-6384

      December 12, 1991
III.   Attendees

      Borden Packaging and Industrial Products (Borden)

      A. A. (Tony) Stambolos, Director of Manufacturing - Coatings
      John Edelbrock, Plant Manager - Coatings
                       r>'.,,r, C ,.-^ -i en Phanp! M<:'  M^r*h P^-rnnp 07^14 Q1Q.

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      U.S. Environmental Protection Agency (EPA)

      Joseph Steigerwald, CTC

      Alliance Technologies Corporation (Alliance)

      Beth W. McMinn
      Stephen A. Walata
IV.     Discussion

       A meeting was held with the personnel from Borden Packaging and Industrial Products
to discuss the  ink  manufacturing  process.   The discussion focused  on  market  profile,
manufacturing supplies, manufacturing process parameters, volatile organic compound (VOC)
control experience, and emission characterization. This discussion was followed by a tour of the
production facility in Cincinnati, Ohio, and then by a short closing meeting.

       A.     Borden's Market Profile

       The Borden Cincinnati facility acts as both a base manufacturing plant and a local service
facility. The base plant manufacturers waterborne ink bases and acrylic polymers. The bases and
the polymers may  or may not be pigmented. These "finished products" are then sent to smaller
Borden facilities which act as local blend houses. The plants receive the bases and'polymers and
blend them to the specifications of local customers.

       The second manufacturing  area at the Borden facility is a blend house to  service local
customers. The products from the base plant are used  as raw materials and are blended with
additional raw materials, pigments, resins, solvents, and  additives to form a finished ink.

       Borden manufactures water based inks for the corrugated market, high-gloss solvent based
paste inks for folding packages (e.g., Mrs. Smith's pies), and some .rotogravure products such as
those inks used for Christmas packaging. The facility also does some carbon black dispersion for
non-Borden facilities. Approximately 90 percent of the products manufactured are water based,
while the remaining ten percent are solvent based. The majority of the water based products are
inks for the corrugated market.

       The  Cincinnati Borden facility was originally  established as a solvent based gravure
manufacturing plant. Production was entirely solvent based until the mid-1980s. In  1985, Borden
decided to leave the gravure market and concentrate on water based products. Making this change
involved some process modifications. Borden relined most of their stainless steel tanks with
epoxy coatings to prevent the new water based products from rusting the metal. The facility also
purchased new media for the  ball mills.  Solvent based products  had been manufactured using
small steel ball media.  Water based products required larger ceramic or zirconium balls.
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       Borden's annual sales are in the $50 to $100 million dollar range, classifying the company
as a large ink manufacturer.

       B.    Manufacturing Supplies

       Borden uses between  1200 and 1500 raw materials in their manufacturing processes.  Some
of the solvents used include methyl ethyl ketone (MEK), 1,1,1-Trichloroethane, toluene, methanol,
xyiene, and acetone. Borden also  uses many alcohols, although plant officials say that there is
a general push in  the printing industry to move away from inks with a high alcohol content (i.e.,
high volatility).  For this reason, Borden has replaced some of their alcohols with glycol ether
products. In .addition to solvents and alcohols, Borden also purchases and uses a variety of resins,
pigments, and additives.  Borden addresses  VOC  content from a raw material  rather than  a
finished product  standpoint.   Borden calculates  VOC  content in  finished products based on
component composition.

        C.     Manufacturing Process  Parameters

        The ink manufacturing process  at the Cincinnati facility  is basically a batch process
materials handling operation. Products are formed by mixing and blending rather than by reacting
materials chemically.  The main manufacturing operations are completed in the following order:

                    premix
                   pigment grinding/milling
                    product blending
                    product filtering
                    product filling/packaging

        The first step in the manufacturing process is material premix. This is the production of
 an intermediate product referred  to as the base. The base or premix  is made  by  combining
 vehicles (e.g., solvents, alcohols, and/or water) with pigments and any other necessary additives.
 The materials  are mixed in portable containers to form  a viscous  material which acts as a
 concentrate. At  this stage,  the particles in the concentrate are rather large and not consistently
 mixed.  With further processing, the concentrate may become any one of a variety of specific end
 products.

        The grinding or milling stage  serves to further disperse the pigment throughout the base
 by pumping it through dispersion  equipment.  Once the customer-requested grind specifications
 are met, the resulting base is transferred to the product  blending tanks.

        Final product specifications are achieved  in the  blending or product finishing step.  The
 base from the dispersion operation is mixed with other intermediates and  raw materials to produce
 a finished ink. Blending may occur in the same  tank or in a different tank used for  premix.

        Once the  ink  has been blended, it is filtered through cheese  cloth or other  filters  to
 enhance the quality and uniformity of the product.  Filtering also acts to screen out impurities.
 CH-92-02

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       After the ink has been filtered, it is pumped or emptied into the shipping container.

       With over 10,000 blended products, Borden does not dedicate manufacturing equipment
to specific products except for large quantity materials.  Some  equipment may be dedicated
periodically to seasonal products,  such as during the fall, when Christmas reds and greens are in
high demand. Different equipment is used for the manufacture of water based inks, solvent based
inks, and paste  inks, so certain equipment may be reserved for these  product families.

       Borden  uses a  variety of equipment during the premix and blending stages.  The "icility
has many mixers, and choosing which to use depends in part on batch size. Drum-sized Dutches
made in the drum itself may be blended with a portable mixer called a Lightning Mixer. Other
materials made in portable mix tanks may be blended using larger permanent mixers.  In  some
cases,  an  ink will be premixed with one mixer, moved to  a  dispersion mill for grinding and
milling, and then transferred back to the same premix mixer for blending operations.

       Borden  operates several  types of dispersion mills including two roll mills, three roll mills,
ball mills, kady mills,  shot mills, and pebble mills.  The three roll mills are used to grind pigment
into water based paste inks. All three rollers are exposed to the air.

       Borden  makes both water  and solvent based inks in ball mills. These mills are rotating
cylinders, mounted horizontally, and filled  with  grinding media.  Typically, steel balls are used
to disperse pigment in solvent based inks and ceramic or zirconium balls are used for water based
materials.  Certain  inks can be manufactured entirely in  ball  mills and  packaged directly into
drums for shipment.   These mills approach  a closed system, as they  are  open  only during
additions  of raw materials and product filling operations.

       Pebble mills are identical  to ball mills except for the grinding media.  Originally, pebble
mills used flint pebbles while ball mills used steel balls. The pebble  mills at the Borden facility
use ceramic beads to  disperse white and clear inks.

       Shot mills are similar to ball mills, except that they are vertical.  Material enters through
the bottom of the mill and is forced up through  the media to a submerged filtering  screen. The
upward action results  in wear on the internal rotor and on the filtering media, which are normally
glass,  ceramic  or steel.  At the Borden facility, shot mills are used primarily in the  manufacture
of light-colored water-based inks.

       Both the Kady mills and the two roll mills are used in the production of high-gloss solvent
based paste inks for folding packages. Two roll mills operate in the same fashion as three roll
mills.  The Kady mill is unlike most of the other dispersion mills, as it is jacketed, allowing for
heating capability.  This mill has a permanent  lid which allows the mill to be covered during
grinding operations.

       In addition to  the mills, Borden operates a number of fixed mix tanks which are used for
mixing, milling, and blending both solvent and water based inks. Material is added through the
top, agitated, and gravity fed out the bottom.  The top of the mix tank may be either open or
covered with lids.
 CH-92-02

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       The Borden facility normally operates 24 hours per day, five days per week, 52 weeks per
year.  A typical batch  can  take eight to twenty hours to complete.  More time is required to
manufacture black inks than other colored inks.  Viscous or dry materials take longer to grind and
achieve proper dispersion than less viscous materials.  Batch sizes  range from five gallons (50
pounds) to 2,500 gallons (20,000 pounds), and process tanks range from pails and drums to 4,100
gallon (33,000 pounds) ink mixers.  The larger batches are normally black inks for the corrugated
packaging market, while the smaller batches are typically solvent based specialty inks.

       Equipment is cleaned on an as-needed basis. Cleaning frequency depends on the number
and size of batches processed, the  size of the equipment to be cleaned, and the color and type of
ink manufactured. Equipment used to manufacture water  based inks is cleaned with water. After
a mill or tank has been emptied, water is added to the equipment to capture remaining product
residue.  The wash  water is drained from  the  tank and  recycled into  the next product batch.
Equipment used to manufacture solvent based products is cleaned with solvent which is  captured
and reused.  The three roll mills are cleaned by hand, using rags and  1,1,1-Trichloroethane, while
the Kady mills are cleaned with a  petroleum distillate which is  also captured and reused.  Some
base raw materials and all solvents are handled via a manifold system using dedicated process
lines. Therefore, cleaning of these lines is limited.  Borden also schedules consecutive production
batches of similar products  to reduce equipment cleaning frequency.

       D.    Volatile Organic Compound  Control Experience

       The Borden facility has no add-on control devices for the capture and destruction of VOCs.
Volatile organic compounds emitted from the manufacture of  solvent based inks are controlled
through equipment modifications such as tank covers.  Drop hoses are also used around mixing
tanks to capture both particulate matter and VOCs. These hoses are then routed to a baghouse.
In the -area where solvent  based  paste  inks are ground on  the two roll mills, emissions are
captured through exhaust  hoods and  then  vented to  a  fabric filter (i.e., baghouse).   Borden
operates a venturi scrubber  in addition to fabric filters for the capture of particulate matter.

       E.     Emission Characterization

       The Cincinnati Borden facility uses ball mills, pebble mills, Kady mills, two roll mills, and
some mix tanks and drums with mixers  in the  manufacture of solvent based inks. Releases of
VOCs come from several types of equipment used in the ink manufacturing process.

       Some solvent color work is accomplished by blending in 55 gallon drums. The drums are
used to mix product and to keep the pigment in suspension.  While they are being  used for
mixing, the drums are often open to the atmosphere. If a  cover is used on a drum during mixing,
it will have a small opening through which  the agitator shaft extends.  Most of the solvent based
inks that are made in mix tanks are made in tanks covered with metal lids. These lids have a four
to six inch  opening  through which the agitator shaft extends.

       Both ball and pebble mills are used in the manufacture of solvent based inks.  These mills
approach a closed system, as they are open only during  additions of raw materials and product
filling operations. It is during these operations that VOC emissions can occur.

CH-92-02                                      5

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       The two roll mills, used to disperse pigment in solvent based paste ink, are another source
of VOC emissions.  Because they are exposed to the atmosphere, solvents are emitted during the
rolling process.  The material exiting the two roll mill is a sheet of flexible  ink.  This sheet is
folded into a transport bin for temporary storage. While  in the staging bin, the sheet may cause
further emissions of organic compounds.

       VOCs may be emitted during solvent based paste ink chip melting and blending operations
in the Kady mills. These tanks can be heated, resulting in the volatilization of organics in the ink
chips.  Emissions may also be released during material additions when the mill covers are open.

       Another source of emissions is the manifold system  where solvents are weighed and
transferred from storage containers to mix tanks, mills or other containers. Emissions may occur
during transfer and  hose connecting and disconnecting.

       In addition to emissions from process operations, VOCs are also released from a variety
of cleaning operations.  Solvents are used to clean the Kady mills and other  equipment used to
manufacture solvent based inks.  Emissions occur during cleaning solvent addition and removal.
The solvents are collected and reused, reducing overall emissions  from virgin  solvent.  The three
roll mills are cleaned by hand, using rags and 1,1,1-Trichloroethane. During cleaning procedures,
some 1,1,1-Trichloroethane is released.

       Most of the  emission areas, with the exception of the staging of drums and storage bins,
are equipped with  exhaust fans or drop hoses  connected  to headers which  lead to particulate
control devices.

       Borden calculates SARA Section 313 releases based on mass balance and consumption
figures, so no studies have been done to determine emission breakdown by  specific process or
product.   The facility has not examined emission contribution  from janitorial supplies.   The
Cincinnati facility is engaging in pollution prevention activities and succeeded in reducing overall
emissions by 43 percent from 1989 to 1990.
 CH-92-02

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  jfk   ALLIANCE
          Techrologies Corporation
Date:         10 January 1992

Subject:      Site Visit--PPG Industries, Inc.
             Paint Manufacturing
             EPA Contract 68-DO-0121; Work Assignment 1-29
             Alliance Reference No. 1638029

From:        Beth W. McMinn
             Alliance Technologies Corporation

To:          Joseph Steigerwald
             OAQPS/ESD/CTC (MD-13)
             U.S. Environmental Protection Agency
             Research Triangle Park, NC 27711
I.     Purpose

      The purpose of the visit was to gather information on the paint manufacturing process
including  information  necessary to characterize the process  parameters,  emissions, control
techniques, and process and control costs.
II.    Place and Date

      PPG Industries, Inc.
      3800 W.  143rd Street
      Cleveland, OH 44111
      (216) 464-5710

      December 10, 1991
III.   Attendees

      PPG Industries. Inc. (PPG)

      Dennis A. Kovalsky, Plant Manager
      David P.  Mazzocco, Environmental Engineer - Air Programs

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      John C. Richter, Plant Superintendent
      Maura C. Tinter, Environmental Engineer

      U.S. Environmental Protection Agency (EPA)

      Joseph Steigerwald, CTC

      Alliance Technologies Corporation (Alliance)

      Beth W. McMinn
      Stephen A. Walata
IV.     Discussion

       A meeting was held with the personnel from PPG Industries, Inc.  to discuss  the paint
manufacturing process.   The discussion focused on market profile, manufacturing  supplies,
manufacturing process parameters, and  volatile  organic compound control experience.   This
discussion was followed by a tour of the production facility in Cleveland, Ohio, and then by a
short closing meeting.

       A.    PPG's Market Profile

       The Cleveland facility produces automotive coatings for automotive Original Equipment
Manufacturers (OEM). The three families of products PPG produces are cationic electrocoats ("E"
coats), solvent based topcoats, and  water based topcoats.  The "E" coats account for 47 percent
of the facility's production and 24 percent of its business.  Solvent based topcoats account for 51
percent of production and 70 percent of business, while water based coatings account for 2 percent
of production and 6 percent of business. Annually, the PPG Cleveland facility produces 4,000,000
gallons of both solvent based topcoat and cationic electrocoat and manufacturers 250,000  gallons
of water based paints. PPG expects the demand for water based coatings to increase in the future.

       The  Cleveland PPG facility was originally established in  1907 as the Banner Varnish
Company under the guidance of C.J. Forbes.  During the next forty years, the facility operated
as the Forbes Varnish Company, a producer of varnish for the carriage trade.  PPG Industries,
then Pittsburgh Plate Glass, purchased the original seven acre operation in 1947, operating under
the Forbes Finishes  Division title.  Major building  expansions and local property acquisitions
followed during the  1960s and  1970s to reach the current 17 acre complex.  Today the facility
produces 8 to 12 million gallons per year of original automotive coatings, a great increase over
the 2 million gallons produced in 1948.
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       B.     Manufacturing Supplies

       PPG uses more than 400 raw materials in their manufacturing processes.  In addition to
the solvents and alcohols described in Attachment  1, PPG also purchases and uses a variety of
resins, pigments,  and additives.  The company regularly calculates VOC content in  finished
products.

       C.     Manufacturing Process Parameters

       The paint manufacturing process at the Cleveland facility  is basically a batch process
materials handling operation. The method of product formation is by mixing and blending rather
than by reacting materials chemically. The four main manufacturing operations are completed in
the following order:

                    preassembly  and premix
                    pigment grinding/milling
                    product finishing/blending
                    product filling/packaging

       The first step in the manufacturing process is preassembly and premix.  In this step, the
liquid raw materials (e.g., resins, solvents, alcohols, and/or water) are mixed in portable containers
to form a honey-like material to which pigments are  added. The pigment and liquid mixture
forms a paste, which is then sent to the  grinding operations.

       The grinding or milling  stage serves to further disperse the pigment throughout the paste.
Once the customer-requested grind specifications are met, the paint mixture is transferred to the
product finishing tanks.

       Final product specifications are achieved in the blending or product finishing step.  Here,
the paint mixture from the dispersion operation is tinted, if necessary, and further reduced, or
letdown, with resins, solvents, and alcohols in agitated tanks.

       Once the paint has been  "finished," it can be transferred from the finishing tanks into pails,
drums, tote tanks or  tote wagons for shipment. The paint is normally filtered during the transfer
step.

       The Cleveland PPG facility has three manufacturing lines which correspond to the three
families of products: solvent based topcoat, water based topcoat, and "E" coat.  The equipment
in each of these lines is dedicated both to product  family and to color. Equipment dedication
prevents product contamination and allows for fewer equipment cleanings (i.e., less solvent use).
The equipment for each manufacturing operation for each family is located in a separate building
(i.e., solvent based grinding occurs  in one building while "E" coat filling occurs in another).  This
segregation of family manufacturing operations requires that material  be transferred from  one
building  to another in  portable tanks.  During the  transfer process, the tanks are covered with
either plastic or stainless steel covers.
CH-92-02

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       PPG uses portable mixers and agitators in the preassembly and premix stage.  In some
cases, premix equipment is combined with dispersion equipment. The product circulates between
mixer and disperser.  The agitator keeps the pigment in suspension and supplies the dispersion
equipment with a consistently mixed material.

       PPG currently  operates  three  types  of  dispersion  equipment (vertical media  mills,
horizontal media  mills, and attritors) with the goal of reducing  to two  (horizontal  mills and
attritors). The reasons  for limiting equipment types to two are many.  Vertical mills are an older
technology.  Material enters through the bottom of the mill and is forced  up through the media
to an exposed filtering screen. The upward action results in wear on the internal rotor and on the
filtering media. It also generates heat which causes the material to become  warm. As the product
filters through the screen it may be 150F, frequently causing the screen  to clog.   An operator
might brush on solvent to unclog the screen.  The  older mills are also noisy and  may require
hearing protection for workers.   In contrast, horizontal mills are closed systems. Because they
are closed, they have fewer emissions and less yield loss. The horizontal position  makes these
mills more efficient than their vertical counterparts.  There is less wear on the grinding media and
rotor and therefore the  horizontal mills produce a cooler product (100F).  In addition, horizontal
mills produce a more consistent product for fewer manhours.

       PPG also  has begun to replace some of their rectangular blend vessels with cylindrical
tanks.  The vessels being replaced require that material additions be made through the top.  Resins
and pigment pastes  are added manually while solvent is piped into the tank.  In the past, the
hatches through which material is added were left uncovered during blending operations.  PPG
has since purchased covers which are removed only  during add times.  The rectangular tanks are
difficult to clean  because of their shape.  Product accumulates in corners, requiring  additional
wash solvent and  generating more waste.  Similarly, agitation is not as efficient in the rectangular
vessels as  it is in the cylindrical tanks. The addition of material  into cylindrical tanks is also
through the top.  Material is added through the top, agitated, and gravity fed out the bottom. The
top openings on the cylindrical tanks are covered with sealing lids.  The stainless steel design and
cylindrical shape  makes cleaning more efficient both in terms of required  labor and generated
waste.

       The Cleveland  PPG facility normally operates 24 hours per day, five days per week, 365
days per year, with a potential for operating seven days a week.  On average, it takes five days
to complete one product batch and follow it from scheduling through the filling operations.  Each
batch in each family of products spends approximately 24 hours  in grinding operations and 16
hours in blending operations. The remaining time is  spent in adding, transferring, color matching,
filtering, and filling  material and in dead time.  More labor hours are required to produce the
colored topcoats than the primers or clearcoats. The  average batch size is 200 gallons, but process
tanks range from 500 gallon rectangular vessels to a 14,000 gallon rectangular vessel.  All of the
solvent based topcoats that PPG produces are considered to be high-solids, with a solids content
greater than 50 percent and a VOC content less than five percent.   The water based products are
three percent organic.

        Equipment is cleaned on an as-needed basis.  Cleaning frequency depends on the number
and size of batches processed, the size of the equipment to be cleaned, and the color and type  of

 CH-92-02                                      4

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product manufactured.  Equipment used to manufacture water based products is cleaned with a
water based cleaner, while equipment used to manufacture solvent based products is cleaned with
wash solvent.  Process lines are dedicated to certain raw materials and therefore are cleaned only
on a limited basis.  The amount of wash solvent used for equipment cleaning ranges from 1 to
100  gallons.  PPG cleans equipment such  as tote tanks,  filter presses,  portable mix tanks, and
grinding mills with wash solvent recycled on site using a rototherm distillation unit and two Luwa
thin film evaporators. This continuous operation recovers from 3,000 to 12,000 gallons of solvent
per day at an average cost of $2.00 per gallon, as compared to an average cost of $2.80 for virgin
solvent.   Wash solvent consists of a mixture of solvents with  methyl ethyl ketone (MEK)
predominating at a concentration of 50 to 60 percent. Waste generated by the solvent recovery
system (i.e., still bottoms  with a solids content of approximately 60 percent) is sent off site to the
PPG coatings and resins incinerator in Circleville, Ohio.

       D.    Volatile Organic Compound  Control Experience

       Volatile organic compound emissions from the Cleveland PPG manufacturing facility are
controlled by a REECO (Regenerative Environmental Equipment Company) thermal incinerator,
REECO I.  A second  REECO  incinerator, REECO  II, controls emissions from the PPG paint
laboratory also located at the Cleveland site. The nine chamber fume incinerators were installed
in 1984 and 1985 as odor control devices.  The primary purpose of the incinerators changed in
1988 with the enactment of Ohio Air Pollution Control (OAC) rules 3745-21-01 and -09, which
subjected  the Cleveland PPG facility to site-specific  requirements for VOC emissions based on
reasonably available control  technology (RACT).   Because  combined  emissions  from the
manufacturing  facility and the paint laboratory met or exceeded 100 tons of VOC annually prior
to rule enactment, the facility (manufacturing and laboratory) was classified as a "major" source.
As such, Ohio  wrote non-CTG rules for the paint manufacturing operations and paint laboratory
operations specifically for PPG (Attachment 2).  The rule requires that "...  the VOC emissions
from the equipment included  within the paint manufacturing operations shall  be vented either
directly or by means of a  building or local area exhaust to a control system which shall maintain
compliance with any of the following requirements:

       (a)    A minimum control efficiency of 98.0  percent by weight for the VOC emissions;
       (b)    A maximum outlet VOC concentration of twenty parts per million by volume (dry
             basis); or
       (c)    A minimum incineration temperature of one thousand five  hundred degrees
             Fahrenheit."

PPG has chosen to comply with the 1500F incineration temperature.  Process emissions are
supplemented by natural  gas with the option to burn fuel oil.  Results  from recent compliance
tests are included in Attachment 3.

       OAC originally included a control device capture efficiency clause in the PPG rule.
However,  after receiving and reviewing  PPG's comments addressing the difficulty in measuring
capture  efficiency, OAC removed these requirements.

       Following is a schedule of current installation and annual costs:
CH-92-02

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       Installation Cost:
             Base Unit                 $2,400,000.00
             Ductwork and Interfacing    3,800,000.00
             Control

       Annual Costs:
             Maintenance                  $50,000.00
             Media Topoff                  3,000.00
             Fire Protection                 14,000.00
             Gas                          250,000.00  @ $5.20/thousand cubic feet
             Electricity                    183,000.00  @ $8.13/kilowatt hour

       In addition to add-on control technology, PPG has implemented the following techniques
to reduce solvent evaporation:

       1.     Retrofit of manufacturing  facilities with  closed process equipment and tanks.
             (Each closed system 45 liter horizontal grinding mill costs $65,000  to $70,000.)
       2.     Clean process equipment by purging with resin from the next batch.
       3.     Develop of water based line with reduced  VOC content.

       PPG has calculated VOC emissions based on compliance testing to be 921  tons per year
before control and 92.1 tons per year after control. Releases for Section 313 reporting under the
Superfund  Amendment and Reauthorization Act (SARA)  of 1986  are calculated based on
consumption figures.   Rather than breaking emissions into fugitive and point  source categories,
PPG reports total air releases according to the following  formula:

             % loss = In vapor pressure of  VOC X  Consumption
                                      100

Final releases are calculated using a  90 percent destruction/removal  efficiency (DRE).  Actual
compliance testing has shown a 98.2  percent DRE.

       E.    Emission Characterization

       The Cleveland PPG facility releases VOCs from  several types of equipment used in the
manufacturing process.

       Portable mix tanks, either alone or in combination with an agitator, are a common emission
source. Portable mix tanks are used to mix product and to keep the pigment in suspension. They
are also used to transfer material from one manufacturing stage to the next. While they are being
used for mixing, the tanks are often, but not always, covered with either plastic or stainless steel
lids.  If a  cover is used on a mix tank during mixing, it will  have a  four to six inch opening
through which the agitator shaft extends.  In some cases,  only a splash guard is used to cover the
back half of the mix tank.  When mix tanks are used for temporary storage, they are covered with
a solid lid, either plastic or stainless steel. None of the lids seal with the mix tanks.
 CH-92-02

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       Vertical media mills, or sand mills, are used to  disperse pigment throughout the paint.
Emissions result from the exposed screen through which warm product filters, possibly clogging
the screen. An operator might apply solvent to unclog the screen, adding to total emissions.

       Attritors are vertical, stationary, cylindrical grinding tanks also used to disperse pigment
throughout the product mixture. Emissions may occur from the opening surrounding the agitator
shaft and/or at product outfall.

       Rectangular blend  vessels not equipped  with sealing lids are another source of VOC
emissions.  Emissions may occur during product adds through the top hatch.

       Another source of emissions is the scale system, where solvent and resin raw materials are
measured and transferred from storage tanks to portable mix tanks or other containers. Emissions
may occur during transfer and hose connecting and disconnecting. A second scale system consists
of a floor scale, a drum, a  drum dispenser, and  a receiving container.  Material is pumped out of
the drum into the receiving container. Emissions occur during material transfer and free-fall into
the receiving container.

       Emissions may also occur from process tanks used for final letdown and tinting prior to
filling operations.

       During some product filling operations, portable mix tanks are mechanically lifted  and
tilted, allowing a finished product to gravity feed into containers for shipment (i.e., pails, drums,
and tote bins).

       In addition to emissions from process operations, VOCs are also released from a variety
of cleaning operations.  The areas where portable mix tanks, mix tank lids, and portable pumps
are washed are sources of VOC emissions.  The tote bin cleaning area and  filter cleaning station
also contribute to plant releases, as does the still itself.

       All of the areas, with the exception of  the temporary storage of portable mix tanks, are
equipped  with exhaust ducts  connected to  headers and/or the central  ventilation system.
Emissions captured by the  ducts in the manufacturing area are burned in the REECO I incinerator.

       PPG calculates SARA Section 313 releases based on consumption figures, so no studies
have been done to determine emission breakdown by process.  Attachment 4 contains SARA
Section 313 air releases for 1988 to 1990. The facility has not examined emission contribution
from janitorial supplies.
CH-92-02                                      7

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                                                                    Attachment 1
                      TYPICAL PRODUCTION SOLVENTS
SOLVENT BASE TOPCOAT   WATER BASE TOPCOAT
                              CATIONIC PRI.
Toluene
Xylene
Ethyl Alcohol
Isobutyl Alcohol
Ethylene Glycol

Methyl Isobutyl Ketone
Heptane
Isobutyl Acetate
Isopropyl Alcohol
Butyl Acetate
Methyl Ethly Ketone
Hexyl Cellosoive             Butyl Cellosolve
Mineral Spirits               Methyl Isobutyl K
Propylene Diisopropyl Amine  Deionized Water
Dimethyl Ethanolamine
Propylene Glycol
Monomethyl Ether
Methyl Ether
Isobutyl Alcohol
Ethylene Glycol
Xylene
Deionized Water
CH-92-02

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3*745-21-09
              "PPG Industries, Inc." or any subsequent owner or operator of the
              "PPG Industries, Inc." facility located at 3800 West 143rd street,
              Cleveland, Ohio shall comply, on and after May 25, 1988, with the
              following requirements for the VOC emissions from the paint
              manufacturing operations and associated paint laboratory
              operations:

              (1)  The paint manufacturing operations shall include the
                   following equipment:  mixing tanks for paint liquids and
                   pigments, grinding mills, paint thinning and tinting tanks,
                   paint filling  equipment for shipping containers, cleaning
                   equipment for  paint processing equipment, and recovery
                   equipment for  the cleaning solvents.  The paint laboratory
                   operations  shall include the following equipment:  paint
                   spray booths and associated ovens within the paint
                   manufacturing  quality control laboratory and the paint
                   research'laboratory.

               (2)  Except  as otherwise provided in paragraph  (MM)(4)  of this
                   rule, the VOC  emissions from the  equipment  included within
                   the  paint manufacturing operations shall be vented either
                   directly  or by means  of a  building or  local  area exhaust to a
                   control  system which  shall maintain  compliance  with any of
                   the  following  requirements:

                    (a)   A  minimum control  efficiency of 98.0  per  cent by  weight
                         for the VOC emissions;

                    (b)   A  maximum outlet VOC  concentration  of twenty  parts  per
                         million by volume  (dry  basis);  or

                    (c)   A minimum incineration  temperature of one thousand  five
                         hundred degrees  Fahrenheit.

               (3)  Except as otherwise provided in paragraph  (MM)(4)  of this
                    rule, the VOC emissions from the equipment included  within
                    the paint laboratory operations shall  be vented to a control
                    system which shall  maintain compliance with 'a minimum control
                    efficiency of ninety per cent by weight for the VOC  emissions
                    or a maximum outlet VOC concentration  of twenty parts per
                    million by volume (dry basis). .

               (4)  The requirements of paragraphs (MM)(2) and (MM)(3) of this
                    rule shall not apply to any specific piece of equipment
                    included within the paint manufacturing operations or the
                    paint laboratory operations during  each of the following
                    situations:

                    (a)  During any period in which there is no production
                         activity or laboratory activity at said equipment; and
                                         130

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     (b)   During the processing  or  use  of  a  waterbased  paint
          material  in -said  equipment, provided  the following two
          conditions are  met:

          (i)   The VOC  content of the waterbased paint  material is
               less than  or equal to  12.0  per cent VOC  by  weight,
               as determined under  paragraph (B) of rule
               3745-21-10 of the Administrative Code;  and

         (ii)   Any VOC  emissions from the  processing or use of the
               waterbased paint material  that are not  vented to
               the control  systems  specified in paragraphs (MM)(2)
               and (MM)'(3)  of this  rule are included (accounted
               for) in  a permit to  install issued by the director
               after the effective  date of this rule pursuant  to
               Chapter 3745-31 of the Administrative Code.

(5)  The VOC control efficiency or outlet VOC concentrations shall
     be determined in accordance with paragraph (C) of rule
     3745-21-10 of the Administrative Code.

(6)  For a control system identified in paragraph  (MM)(2) or
     (MM)(3) of this rule that employs incineration, the
     incineration  temperature shall be determined  by means of a
     continuous measurement and  recording of such  temperature.

(7)  Any mixing or blending tank containing  a  paint material  shall
   '  be equipped with  a  cover or lid that completely covers the
     opening of the  tank,  except for an opening no larger  than
     necessary  to  allow  for safe clearance  for the mixer's shaft.
     Such  tank  shall be  covered  at all times  in which  the  tank
     contains  a  paint  material  except  when  operator access  is
     necessary  to  add  ingredients  or take  samples.

 "Midwest  Mica  and  Insulation  Company"  or  any subsequent  owner or
 operator  of the "Midwest Mica and  Insulation Company"  facility
 located  at 4853 West 130th street, Cleveland,  Ohio shall  not
 cause, allow  or permit the discharge into the ambient  air of  any
 VOC  from  any  mica coating  or  laminating  line after the date
'specified in  paragraph (C)(48)  of  rule 3745-21-04 of  the
 Administrative Code unless the VOC emissions from the associated
 oven are  vented to a control  system  that  is designed  and operated
 to achieve a  control efficiency which  is  at least ninety-eight per
 cent by weight or.an outlet VOC concentration which is less than
 or equal  to twenty parts per million by volume (dry basis), either
 of which is determined under paragraph (C) of  rule 3745-21-10 of
 the Administrative Code.  This requirement shall   not apply to any
 mica coating or laminating line which  employs  less than five tons
 of VOC per year.
                          131

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                                                                  Attachment 3
                REECO I AND O COMPLIANCE TEST RESULTS
REECO I
7/13/84
1400F

REECO II
1/26/87
L500F

REECO II
1/27/87
1400F
Test 1
Test 2
Test 3
Test 1
Test 2
Test 3
Test 1
Test 2
Test 3
                                    Inlet
                                Concentration
                                   Outlet
                                Concentration
 920.4 ppm
 899.0 ppm
1208.0 ppm
  91.0 ppm
  88.0 ppm
  89.0 ppm
  60.0 ppm
  98.0 ppm
  97.0 ppm
27.8 ppm
63.3 ppm
59.6 ppm
 6.0 ppm
 6.0 ppm
 4.0 ppm
 7.0 ppm
12.0 ppm
10.0 ppm
                                Reduction
                                Efficiency
REECO I
7/12/84
1500F
Test 1
Test 2
Test 3
872.0 ppm
749.8 ppm
1080.0 ppm
11.7 ppm
26.5 ppm
52.4 ppm
98.7%
96.5%
95.2%
97.0%
93.0%
95.1%
93.0%
92.8%
95.1%
88.4%
88.2%
89.3%
CH-92-02

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                                        '.itachment 4
SARA 313 REPORTED AIR RELEASES
Chemical
Acetone
Ethylbenzene
Formaldehyde
Glycoi Ethers
Methanol
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Butyl Alcohol
Toluene
Xylene
Barium
Chromium
Copper 
Lead
1988
200
1000
0
69
2700
4843
664
0
1334
5000
933
140
0
677
1989
301
920
20
58
2711
3704
571
67
1023
4603
579
215
41
454
1990
214
754
124
45
3367
2152
494
41
1132
2447
573
47
50
489

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         TECHNICAL REPORT DATA
/'.'case rcaa Inunctions on me reverse oetore tomnietingi
k.

A
1 REPORT NO ! 2.
EPA-450/ 3-92-0 13
4. TITLE AND SUBTITLE
Control of VOC Emissions from Ink and Paint
Manufacturing Processes
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Alliance Technologies Corporation
100 Europa Drive, Suite 150
Chapel Hill, NC 27514
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. EPA
Emissions Standards Division
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
'3. RECIPIENT'*: ACCESSION NO
5. REPORT DATE
Aoril 1992
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
1
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-DO-0121
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
EPA Work Assignment Manager: Joseph Steigerwald, 919-541-2736
16. ABSTRACT
This document presents the results of a study to collect and report information
on processes used to manufacture paint & ink, volatile organic compounds (VOC)
emissions generated during these operations, emission control techniques and
their effectiveness, and costs associated with process changes and emission
control options.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.lDENTIF
Paint Manufacturing
Ink Manufacturing
Volatile Organic Compounds
Emission Control
18. DISTRIBUTION STATEMENT 19. SECUR
Release Unlimited Uncla.
20. SECUR
Uncla
ERS/OPEN ENDED TERMS C. COSATI Field/Group

TY CLASS /Tins Report I 21. NO. OF PAGES
ssified
TY CLASS iTlns patfei ,22. PRICE
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