United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-00-002
April 2000
vvEPA
NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS FOR SOURCE
CATEGORIES: PAPER AND OTHER WEB
COATING OPERATIONS - BACKGROUND
INFORMATION FOR PROPOSED STANDARDS
U.S. Environmental Protection Agency
Region 5. Library (PL-12J)
77 West Jackson Boulevard, 12th F)M
Chicago, IL 60604-3590
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EPA-453/R-00-002
National Emission Standards for
Hazardous Air Pollutants for Source Categories
Paper and Other Web Coating Operations -
Background Information for Proposed Standards
Emission Standards Division
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
April 18, 2000
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Bpulevard, 12th Floor
Chicago, IL 60604-3590
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Disclaimer
This report has been reviewed by the U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards,
Emission Standards Division and approved for publication.
Mention*of trade names of commercial products does not constitute
endorsement or recommendation for use.
Copies of this report are available through the
U.S. Environmental Protection Agency
Library Services Office (MD-35)
Research Triangle Park, North Carolina 27711
or it may be ordered from the
National Technical Information Services
5285 Port Royal Road
Springfield, Virginia 22161
Telephone: (703) 487-4650.
11
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION . . 1-1
1.1 OVERVIEW 1-1
1.2 PROJECT HISTORY 1-2"
> ^ 1.2.1 Background 1-2
1.2.2 Data Gathering 1-5
1.2.3 Emissions and Control Data 1-6
1.3 DOCUMENT ORGANIZATION 1-6
1.4 REFERENCES 1-8
2.0 THE PAPER AND OTHER WEB COATING INDUSTRY 2-1
2.1 INTRODUCTION 2-1
2.2 OVERVIEW OF THE COATING PROCESS 2-3
2.2.1 Coating Operations 2-3
2.2.2 Coating Process 2-4
2.2.2.1 Coating Applicators 2-4
2.2.2.2 Coating Ovens 2-16
2.2.2.3 Inert Ovens 2-20
2.2.3 Coating Types 2-20
2.2.3.1 Solventborne Coatings 2-21
2.2.3.2 Waterborne Coatings 2-21
2.2.3.3 Hot-melt Coatings 2-22
2.2.3.4 Reactive Coatings 2-23
2.2.3.5 Radiation-Cure Coatings 2-23
2.3 INDUSTRY PROFILE 2-25
2.3.1 Pressure-sensitive Tapes and Labels . . 2-28
2.3.1.1 Baseline Emissions 2-29
2.3.1.2 Types of Coatings and Applicators
Used 2-31
2.3.1.3 Pressure-sensitive Tapes and Labels
Coating Process 2-33
2.3.2 Flexible Vinvl 2-35
2.3.2.1 Baseline Emissions 2-36
2.3.2.2 Types of Coatings and Applicators
Used 2-37
2.3.2.3 Flexible Vinvl Coating Process . . 2-28
2.3.3 Photographic Film 2-41
2.3.3.1 Baseline Emissions 2-41
2.3.3.2 Types of Coatings and Applicators
Used 2-42
2.3.3.3 Photographic Film Coating Process . 2-43
111
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2.3.4 Decorative and Industrial Laminates . . 2-44
2.3.4.1 Baseline Emissions 2-45
2.3.4.2 Types of Coatings and Applicators
Used 2-46
2.3.4.3 Decorative and Industrial Laminate
* * Coating Process 2-47
2.3.5 Miscellaneous Coating Industries . . . 2-49
2.3.5.1 Baseline Emissions 2-50
2.3.5.2 Abrasive Products 2-50
2.3.5.3 Specialty Paper Coating 2-53
2.4 REFERENCES 2-56
3.0 EMISSION CONTROL TECHNIQUES 3-1
3.1 INTRODUCTION 3-1
3.2 CAPTURE SYSTEMS 3-1
3.3 CONTROL DEVICES 3-5
3.3.1 Oxidizers 3-9
3.3.1.1 Thermal oxidizers 3-9
3.3.1.2 Catalytic oxidizers 3-12
3.3.2 Adsorption 3-13
3.3.3 Condensation 3-16
3.4 PREVENTIVE MEASURES 3-19
3.4.1 Product Substitution/Reformulation . . 3-19
3.4.2 Work Practice Procedures 3-21
3.5 REFERENCES 3-23
4.0 MODEL PLANTS, CONTROL OPTIONS, AND ENHANCED MONITORING . 4-1
4.1 INTRODUCTION 4-1
4.2 MODEL PLANTS 4-1
4.3 CONTROL OPTIONS 4-3
4.4 ENHANCED MONITORING ....4-8
4.5 REFERENCES 4-11
5.0 ENVIRONMENTAL AND ENERGY IMPACTS OF CONTROL OPTIONS . .5-1
5.1 INTRODUCTION 5-1
5.2 ENERGY IMPACTS 5-2
5.3 AIR IMPACTS 5-6
5.4 WATER IMPACTS 5-9
5.5 SOLID WASTE IMPACTS 5-9
5.6 REFERENCES 5-11
6.0 MODEL PLANT CONTROL OPTION COSTS 6-1
6.1 INTRODUCTION 6-1
iv
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6.2 CAPTURE AND CONTROL APPROACH 6-3
6.3 MODEL PLANT CAPITAL AND ANNUAL COSTS - EXISTING SOURCES
6-6
6.3.1 Permanent Total Enclosures--Cost Related
Background 6-6
* x 6.3.2 PTEs for the Model Plants 6-9
6.3.3 New Thermal Oxidizers 6-11
6.3.4 Increasing Destruction Efficiency of
Existing Thermal Oxidizers 6-11
6.3.5 Monitoring. Reporting, and
Recordkeeping 6-17
6.4 TOTAL COSTS AND COST EFFECTIVENESS 6-17
6.5 MODEL PLANT CAPITAL AND ANNUAL COSTS - NEW SOURCES 6-22
6.6 REFERENCES 6-25
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LIST OF TABLES
Page
Table 2-1. Types of Coating Applicators Used by
Respondents of the POWC Survey 2-5
Table *2-2. The 18 SIC Codes of the Paper
and Other Web Coating Industry 2-27
Table 2-3. Primary Products of the Pressure-sensitive
Tapes and Labels Survey Respondents 2-30
Table 2-4. Types of Coating Applicators Used by Survey
Respondents in the Pressure-sensitive Tapes and
Labels Industry Segment 2-34
Table 2-5. Types of Coating Applicators Used by Survey
Respondents in the Flexible Vinyl Film Industry
Segment 2-38
Table 2-6. Types of Coating Applicators Used by Survey
Respondents in the Photographic Film Industry Segment 2-43
Table 2-7. Types of Coating Applicators Used by Survey
Respondents in the Decorative and Industrial
Laminates Industry Segment 2-47
Table 2-8. 1996 TRI Facilities and Emissions for the
Miscellaneous POWC Industry Segment 2-51
Table 3-1. Common Control Devices and Associated
HAP Control Device Efficiency Ranges 3-7
Table 3-2. Examples of Work Practice Standards 3-22
Table 4-1. Specifications for Model Plants Representing
the POWC Industry 4-4
Table 4-2. Control Options for the POWC Industry 4-5
Table 5-1. POWC Model Plants and Their Estimated
Correspondence to the National POWC Industry 5-2
Table 5-2. Energy Impacts of Control Option 1
for the POWC Model Plants 5-3
Table 5-3. Total Estimated Energy Impacts of
Control Option 1 for the National POWC Industry . . . .5-4
Table 5-4. Air Impacts of Control Option 1
for the POWC Model Plants 5-8
Table 5-5. Total Estimated Air Impacts of Control Option 1
for the National POWC Industry 5-8
Table 6-1. Specifications for Model Plants Representing
the POWC Industry 6-4
Table 6-2. Capture and Control Approach for the POWC Model
Plants with Control Option 1 6-5
VI
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Table 6-3. Capital Costs of Permanent Total Enclosures
for the POWC Model Plants 6-12
Table 6-4. Annual Costs Associated with Installation
and Operation of Permanent Total Enclosures (PTE)
for the POWC Model Plants 6-13
Table*6*5. Regenerative Thermal Oxidizer Capital and
Annual Operating Costs for POWC Model Plants 6-14
Table 6-6. Capital and Annual Costs of Increasing
Destruction Efficiency of Existing T.O.s in the POWC
Industry 6-15
Table 6-7. Capital and Annual Operating Costs Associated
with Monitoring, Recording, and Recordkeeping (MR&R)
Requirements for the POWC Model Plants 6-18
Table 6-8. Total Model Plant Capital Costs for Complying
with Control Option I 6-19
Table 6-9. Total Model Plant Annual Costs for Complying
with Control Option 1 6-20
Table 6-10. Cost Effectiveness of Capture and Control
Approaches to Control Option 1 for the POWC Model
Plants 6-21
Table 6-11. Annual and Capital Costs of Achieving New Source
MACT Floor level of Control 6-23
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LIST OF FIGURES
Figure 2-1.
Figure 2-2.
Figure 55-3.
Figure 2-4.
Figure 2-5.
Figure 2-6.
Figure 3-1.
Figure 3-2.
Figure 3-3.
Page
Gravure coating unit 2-6
Three-roll reverse-roll coater 2-8
'Knife coater 2-11
Dip and squeeze coater 2-14
Extrusion coater -2-15
Calendering process 2-17
Thermal recuperative oxidizer 3-10
Two-bed carbon adsorber 3-15
Shell-and-tube surface condenser 3-18
Vlll
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1.0 INTRODUCTION
1.1 OVERVIEW
Section 112 of the Clean Air Act (Act) requires that the
U.S. Environmental Protection Agency (EPA) establish emission
standards for all categories of sources of hazardous air
pollutants (HAP). These national emission standards for
hazardous air pollutants (NESHAP) must represent the maximum
achievable control technology (MACT) for all major sources. The
Act defines a major source as:
...any stationary source or group of stationary sources
located within a contiguous area and under common
control that emits or has the potential to emit, in the
aggregate, 10 tons per year or more of any hazardous
air pollutant or 25 tons per year or more of any
combination of hazardous air pollutants.
In July 1992, the initial list of source categories for
regulation under section 112 of the Act was published. "Paper
and Other Webs (Surface Coating)" was included as a source
category. To more clearly define the source category, the EPA
subsequently decided to call the source category "Paper and Other
Web Coating Operations." The NESHAP for the paper and other web
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coating (POWC) industry will establish standards for major-
sources in this source category.
The POWC source category can be described as processes
apply a uniform layer of material (coating) across essentially
the entire length and/or width of a continuous substrate (web) to
provide a covering, finish, or functional or protective layer to
a substrate, to saturate a substrate or to provide adhesion
between two substrates for lamination. This definition serves to
distinguish the POWC source category from the printing and
publishing source category, which can be described as processes
that apply words, designs, or pictures to a substrate. Web
coating is done in the manufacture of some major product types
such as: pressure-sensitive tapes and labels; photographic film;
industrial and decorative laminates; flexible vinyl products;
flexible packaging; abrasive products; and folding paperboard
boxes. Because this source category is defined by the broad web
coating operation, other product types may be included under the
POWC source category.
The purpose of this document is to summarize the background
information gathered during the development of the POWC NESHAP.
1.2 PROJECT HISTORY
1.2.1 Background
The POWC industry can be divided by technology, substrate,
or type of product. Further divisions and industry segments can
be identified in each of the major industry divisions. Many
manufacturing processes include web coating operations as one
step in the production process. It is estimated that more than
400 establishments in the U.S. have web coating operations.
1-2
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Surface coatings usually provide a covering, a finish, or
decorative, functional, or protective layer to a substrate.
Coatings for lamination purposes provide adhesion for the case
where two substrates are pressed together. For example,
polyvinyl chloride film may be coated with an adhesive and then
laminated to (pressed onto) fabric to manufacture wall coverings.
In some processes, the web is formed on the coating line where it
is then coated and wound.
The coating industry can be divided by technology into
segments, such as gravure coaters, roll coaters, dip coaters,
extrusion coaters, etc. While the industry manufactures a wide
range of products, the manufacturing process varies little by
product. The coating industry can also be divided by the type of
substrate coated. The primary substrates coated by the industry
are paper, film, and foil. The industry uses a range of films
including polyester, polyethylene, polypropylene, polyvinyl
chloride, and cellulose acetate. Other substrates coated by the
industry include foam and fabric.
The coating industry can additionally be divided by the type
of product. The types of products manufactured by the industry
include but are not limited to: pressure-sensitive tapes and
labels; photographic film; coated vinyl; wall coverings;
sandpaper and other abrasives; paperboard boxes; vinyl flooring;
industrial and decorative laminates; carbon paper and carbonless
paper; circuit boards; and business forms.
The development of NESHAP for the POWC industry must take
into account areas of overlap with other industries and NESHAP
for other source categories. Potential areas of overlap are
printing, fabric coating, and coil coating.
1-3
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Many products manufactured by the POWC industry are printed
and coated, often on the same production line. The printing and
publishing NESHAP,1 promulgated in May 1996, allows facilities
that print and coat different materials on the same line, or
print and coat the same substrate on different lines, to cover
their coating operations under the printing and publishing
NESHAP. Stand-alone coating equipment can be included as part of
the affected source under the printing and publishing NESHAP if
it is similar to the printing presses in any of the following
ways: it applies solids-containing materials to the same web or
substrate; it applies a common sol ids-containing material; or it
uses a common control device for control of organic HAP
emissions. Therefore, many facilities whose coating operations
could be covered under the POWC NESHAP may instead opt to cover
their coating operations under the printing and publishing
NESHAP, Also, although facilities coating fabric will be
primarily covered under fabric coating, printing and dyeing
NESHAP, facilities will likely be given the option of covering
their fabric coating operations under the POWC operations NESHAP.
Some segments of the POWC industry are already subject to
regulations limiting their volatile organic compound (VOC)
emissions. In 1978, the EPA developed a control technique
guidelines (CTG) document for surface coating of paper and
fabric.2 The EPA promulgated new source performance standards
(NSPS) for pressure-sensitive tape manufacturers, flexible vinyl
coating and printing operations, and polymeric coating of
supporting substrates.3>4<5 While none of these regulations were
specifically directed at reducing HAP emissions, many HAP used by
the POWC industry are also VOC. Examples of HAP that are
1-4
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frequently used by this industry and are also volatile organic
compounds (VOC) are formaldehyde, methyl ethyl ketone, methanol,
toluene, and xylene. Therefore, many control devices installed
by the industry to reduce VOC emissions also reduce HAP
emissions.
1.2.2 Data Gathering
The POWC NESHAP project began in March 1996. In late 1996,
a questionnaire was developed and distributed by the EPA, with
the help of the Pressure Sensitive Tape Council (PSTC), to
determine HAP use and control in the pressure-sensitive tape and
label segment of the POWC industry. In 1997, the EPA developed
and distributed a questionnaire, with the help of the Chemical
Fabrics & Film Association (CFFA) and the National Association of
Photographic Manufacturers (NAPM), to determine HAP use and
control by film formation and coating operations. Also in 1997,
the EPA developed and distributed a questionnaire to determine
HAP use and control in the manufacture of industrial and
decorative laminates, with the help of the Laminating Materials
Association (LMA), the National Electrical Manufacturers
Association (NEMA), and the Association of Industrial
Metallizers, Coaters, and Laminators (AIMCAL).
The EPA questionnaires were designed to evaluate HAP
emissions from the industry and the current level of control of
HAP emissions by the industry. The questionnaires were included
with information collection requests (ICR) sent out under the
authority of section 114 of the Act. Questionnaire responses
were solicited from 104 companies that manufacture pressure-
sensitive tapes and labels, 40 companies that operate film
1-5
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formation and coating equipment, and 49 companies that
manufacture industrial or decorative laminates.
Besides information obtained from these questionnaires, the
EPA made several site visits to POWC facilities. Also, the EPA
met and/or conversed with many trade associations and industry
representatives. Other sources of information obtained for the
project include emission data from the 1996 Toxic Release
Inventory6 (TRI) database, trade organization surveys, the
Aerometric Information Retrieval System7 (AIRS) database, and the
literature.
1.2.3 Emissions and Control Data
The available emissions and control information for the POWC
industry are summarized in Chapters 2 and 3. Most of the
information collected from POWC surveys is based on calendar year
1996, but represents current practices in the industry. Control
efficiency data are also representative of current conditions.
In some segments of the industry, there has been a shift away
from HAP use to either nonHAP VOC or waterborne materials.
1.3 DOCUMENT ORGANIZATION
This document is organized into six chapters designed to
explain the background information collected for the paper and
other web coating NESHAP. Following this introduction, Chapter 2
presents a profile of the paper and other web coating processes
and industry. Chapter 3 describes the emission control
techniques used by the POWC industry. Model plants developed to
represent major sources in the POWC industry are presented in
Chapter 4, along with control options and enhanced monitoring for
the industry. In Chapter 5, the environmental and energy impacts
of the control options for the POWC industry are presented. The
1-6
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cost impacts of these control options developed for the model
plants are presented in Chapter 6.
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1.4 REFERENCES
1. U.S. Environmental Protection Agency. National Emission
Standards for the Printing and Publishing Industry. 40 CFR
63, Subpart KK, May 1996.
2. U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Existing Stationary Sources -Volume
II: Surface Coating of Cans, Coils, Paper, Fabrics,
Automobiles, and Light-Duty Trucks. EPA-450/2-77-008.
Research Triangle Park, North Carolina. May 1977.
3. U.S. Environmental Protection Agency. Standards of
Performance for Pressure Sensitive Tape and Label Surface
Coating Operations. 40 CFR 60, Subpart RR (48 FR 48375),
October 18, 1983.
4. U.S. Environmental Protection Agency. Standards of
Performance for Flexible Vinyl and Urethane Coating and
Printing. 40 CFR 60, Subpart FFF (49 FR 26892), June 29,
1984.
5. U.S. Environmental Protection Agency. Standards of
Performance for Polymeric Coating of Supporting Substrates.
40 CFR 60, Subpart VW (54 FR 37551). September 11, 1989.
6. U.S. Environmental Protection Agency. Toxic Release
Inventory System (TRI) Database. Office of Pollution
Prevention and Toxics, Washington, DC. 1996.
7. U.S. Environmental Protection Agency. Aerometric Information
Retrieval System (AIRS) Database. Office of Air Quality
Planning and Standards, Research Triangle Park, North
Carolina. 1997.
1-8
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2.0 THE PAPER AND OTHER WEB COATING INDUSTRY
2.1 INTRODUCTION
The paper and other web coating (POWC) industry consists of
the application of various coatings onto web substrates to
manufacture a wide range of products, including, but not limited
to, pressure-sensitive tapes and labels, vinyl film, photographic
paper and film, flexible packaging, industrial and decorative
laminates, sandpaper and other abrasives, and wall coverings.
Although the industry manufactures an extensive list of
products, the coating processes used by the different segments of
the industry are very similar. Typically, the substrate (web) is
unwound, coated, rewound and/or cut to size, and packaged.
Alternatively, a web may be unwound, coated, and then combined
with another material by lamination (either before or instead of
being rewound).
Emission sources are also similar throughout the different
industry segments. Coating application and drying/curing are the
largest emission sources for all segments of the industry, with
minimal HAP emissions from cleaning, coating mixing, coating and
solvent storage, and wastewater. Coating line emissions can
represent up to 96 percent of the total HAP emissions from
coating operations.1 Some segments of the industry also
manufacture substrates onsite. In the flexible vinyl industry
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segment of the POWC industry, 38 percent of the facilities
responding to an EPA survey stated that flexible vinyl substrates
were formed onsite.2 In the photographic film industry segment,
20 percent of the respondents indicated that they formed flexible
vinyl substrates onsite.3
Many industrial facilities perform both coating and printing
operations. Within the printing industry, the rotogravure and
wide-web flexography product and packaging printing industry
segment (that includes the flexible packaging industry as a major
subsector) does the most coating, with material use distributed
almost equally between inks and coatings.4-5 Printing operations
are covered under EPA's promulgated National emission standards
for hazardous air pollutants (NESHAP) for the printing and
publishing industry.6 The printing and publishing NESHAP covers
all types of printing operations and includes an option for
facilities that perform both printing and coating to cover
certain coating operations under the printing and publishing
NESHAP. Therefore, many of the facilities whose coating
operations could be covered under the NESHAP for the POWC
industry may opt to cover these operations under the printing and
publishing NESHAP. A detailed discussion of the printing and
publishing industry is included in the background information
document for that industry.7
In the responses from the POWC survey of the pressure
sensitive tape and label, flexible vinyl, photographic film, and
decorative and industrial laminates industry segments, 8 percent
of all (824) coating application stations were printing stations.
In the individual segments, the flexible vinyl industry segment
had the highest percentage of printing stations at 30 percent.
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The other industry segments had much lower percentages of
printing stations: decorative and industrial laminates and
photographic film both had 2 percent, and pressure-sensitive
tapes and labels had 0.7 percent.8
Section 2.2 includes a discussion of the typical coating
processes used by the POWC industry. Section 2.3 contains a POWC
industry profile that includes a discussion of the major segments
of the POWC industry, and the types of coatings and operations
that are specific to those segments of the industry. References
may be found in Section 2.4. Appendix A lists the facilities
that responded to the EPA survey of the POWC industry.
2.2 OVERVIEW OF THE COATING PROCESS
Section 2.2.1 provides a definition of a "web coating
operation." In Section 2.2.2, the typical components of the
coating process are explained with detailed descriptions of
coating applicators and ovens. The types of coatings used in the
POWC industry are described in Section 2.2.3.
2.2.1 Coating Operations
A web coating operation may be defined as a process that
applies a uniform layer of material (coating) across essentially
the entire length and/or width of a continuous (web) substrate to
provide a covering, finish, or functional or protective layer to
a substrate, to saturate a substrate or to provide adhesion
between two substrates for lamination. Some coatings actually
form part of all of the substrate, such as photographic, x-ray,
and microfiche film; vinyl for wall and window coverings; the
back side of carbonless paper; and reactive resins used in the
manufacture of decorative and industrial laminates.9 These
materials may or may not be further coated, printed, or
2-3
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processed. Coatings for lamination can also provide adhesion
between two substrates.10
The distinction between a printing operation and a coating
operation may not always be obvious. Printing may be described
as a process that applies words, designs, or pictures to a
substrate. Although printing and coating are distinct operations
for regulatory purposes, they have many similarities.
2.2.2 Coating Process
Components of a typical coating line in the POWC industry
include an unwind roll, one or more coating applicators and
drying ovens, a rewind roll or cutting/slitting operation, and
flash-off area. Each coating application station may use the
same type of coating applicator or different types of
applicators. Typically, an oven immediately follows each
application station. The coating applicator and the oven are the
main emission sources on the coating line.
2.2.2.1 Coating Applicators. Several different types of
applicators may be used to apply the coatings. The most common
types of applicators used by the industry include (roto)gravure,
reverse roll, slot die, knife, flexography, Mayer rod, dip and
squeeze, and extrusion/calendering. Other types of applicators
may be used for selected coating operations, but these are the
primary types of applicators used by the POWC industry.
Table 2-1 shows the breakdown of coating applicators used by
respondents of the POWC survey.11 From these data it can be seen
that gravure coating applicators were used the most (at 32
percent of the coating stations) , with roll and/or reverse roll
coaters used second most (at 20 percent) , and slot die used third
most (at 10 percent), together accounting for almost two-thirds
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Table 2-1. Types of Coating Applicators Used by
Respondents of the POWC Survey
Application Method
Gravure
Roll, Reverse Roll
Slot Die
Knife
Flexography
Mayer Rod
Dip
Extrusion/calendering
Rotary Screen
Printing
Flow
Total
Percentage of
Application Stations
32
20
10
9
8
7
5
3
3
2
1
100
of the coating application stations. The eight remaining coating
applicator types together account for approximately one-third of
the coating applicators in the surveys.
2.2.2.1.1 Rotogravure. Rotogravure (web-fed gravure)
coaters are used extensively by the printing industry, but they
are also used for coating. The coating materials (or inks) are
picked up in the recessed areas of the roll and transferred
directly to the substrate. The gravure coater can print patterns
on the substrate or coat some or all of the substrate.
Figure 2-1 shows a diagram of a gravure coating unit; several of
these may be combined on one coating line.
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In gravure coating, the coatings include both solvent and
waterbased systems, with the solvents including aromatic,
aliphatic, and oxygenated hydrocarbons. About 60 percent of the
coatings are petroleum-based waxes and hot melts, 35 percent are
extrusion coatings, and 5 percent water-based.12
Among the POWC survey respondents, gravure was the most
common type of coating application station, at 32 percent of all
coating stations, and also the most common coating technique in
the pressure-sensitive tapes and labels industry segment (at
33 percent) and flexible vinyl industry segment (at 40 percent).
In the decorative and industrial laminates industry segment,
gravure coating was the second-most common (after dip), at
34 percent of the coating stations.
2.2.2.1.2 Reverse Roll. The reverse roll coater applies a
constant thickness of coating to the substrate, usually by means
of three rollers--a metering roller, a backing roller, and an
applicator (transfer) roller. A metering roller picks up the
coating solution from a trough and transfers it to an applicator
roller. (Sometimes there is no metering roller and the coating
is pumped directly onto an applicator roller.) The web is
supported by a backing roller where the applicator roller
contacts the paper. The applicator roller then transfers the
coating to the substrate, as the web passes between the backing
roller and the applicator roller. The applicator roller turns in
a direction opposite to that of the paper, hence the name reverse
roll coater. This reverse direction of the applicator roller
reduces striations in the coating that can form if the applicator
roller is turned in the same direction as the paper web.
Figure 2-2 depicts a three-roll reverse roll coater.
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Among the POWC survey respondents, roll and/or reverse roll
was the second-most common type of coating application station,
at 20 percent of all coating stations, with 28 percent of the
photographic film stations, 26 percent of the pressure-sensitive
tapes and labels coating stations, and 20 percent of stations in
the decorative and industrial laminates industry segment using
roll and/or reverse roll coater coaters.
2.2.2.1.3 Slot Die. The slot die coater is similar to an
extruder but is less heavy-duty than an extruder since less
viscous materials are used with a slot die coater (see
Section 2.2.2.1.8 for a discussion of extruders). In a slot die
coater, the coating is extruded through an adjustable-width
orifice onto the substrate and is sometimes followed by a
smoothing roller. Slot die coaters are typically used for
application of hot-melt coatings and adhesives, but may also be
used to apply aqueous coatings.14
Among the POWC survey respondents, slot die coating was the
third-most common coating technique, at 10 percent of all coating
stations; and was the most common technique in the photographic
film industry segment (at 44 percent). It was also a common
technique in the pressure-sensitive tapes and labels industry
segment (at 12 percent). No decorative and industrial laminates
facilities among the survey respondents used slot die coaters.
2.2.2.1.4 Knife. A knife coater consists of a blade that
scrapes off excess coating from the substrate. The tray or
trough of coating is located behind the knife blade. A
continuous sheet of substrate is drawn between the knife blade
and the support roller. As coating is deposited on the
substrate, the knife blade spreads it across the substrate to the
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desired thickness. The position of the knife relative to the
substrate surface can be adjusted to control the thickness of the
coating. Some knife coaters use high velocity air as the knife
blade, these are known as air-knife coaters. A diagram of a
floating knife coater is shown in Figure 2-3.
Knife coaters can apply solutions of much higher viscosity
than roll coaters, thus less solvent is emitted per pound of
coating applied. Knife coaters handle coatings with viscosity up
to 10,000 centipoise (cp), while reverse roll coaters operate
best with coatings that have a viscosity ranging from 300 to
1500 cp. Knife coaters, however, usually operate at lower speeds
than roll coaters and show a greater tendency to break the web.16
Among the POWC survey respondents, knife coating was the
fourth-most common type of coating application station at
9 percent of all coating stations, with 11 percent of the
flexible vinyl coating stations, 11 percent of the photographic
film coating stations, 9 percent of the pressure-sensitive tapes
and labels coating stations, and 5 percent of the decorative and
industrial laminates industry stations having knife coaters.
2.2.2.1.5 Flexography. In flexographic coating, the area to
be coated is delineated by a raised surface on a flexible plate
that is usually made of rubber or other elastomeric materials.17
Because of the ease in plate preparation, flexography is more
suited to short production runs than gravure.18
Coating materials applied with flexography must be very
fluid to work properly and include waterborne and solvent-based
systems. The solvents used must be compatible with the rubber or
polymeric plates; thus aromatic solvents are not used. Some of
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COATING KNIFE
TURN ROLL
SUPPORT
ROLL
SUPPORT
CHANNEL
Figure 2-3. Knife Coater.19
2-11
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the components of solvent-based flexographic coatings include
ethyl, n-propyl, and isopropyl alcohol; glycol ethers; aliphatic
hydrocarbons; and esters.20 Flexography is performed both on
wide web (<18 inches) and narrow web (<18 inches) , and on sheets
as well as web.21
Among the POWC survey respondents, flexographic coating was
the fifth-most common type of coating application station at
8 percent of all coating stations, with 20 percent of the
flexible vinyl industry segment and 4 percent of the pressure-
sensitive tapes and labels industry segment coating stations
having flexographic coaters. No decorative and industrial
laminates facilities among the survey respondents used
flexographic coating applicators.
2.2.2.1.6 Mayer Rod. The Mayer rod (or wire-wound rod)
coater is a metering device used to control the thickness of an
applied coating. Typically, the coating is applied via a roller,
and the excess coating is removed by a rod covered by a spiral-
wound stainless steel wire. The rod wipes the coating off the
substrate except for the portion which escapes through the spaces
between the wires. Larger wire diameters result in larger
spaces, and therefore heavier coatings.22
Among the POWC survey respondents, Mayer rod coating was
used most often in the pressure-sensitive tapes and labels
industry segment, with 11 percent of the coating stations having
Mayer rod coaters, and was used by 5 percent of the decorative
and industrial laminates, 3 percent of the flexible vinyl, and
2 percent of the photographic film industry segment coating
stations.
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2.2.2.1.7 Dip and Squeeze. The dip and squeeze coater, also
called a dip coater, impregnates or saturates the substrate
rather than applying a coating to the web surface.23 Figure 2-4
shows a diagram of a dip and squeeze coater. The substrate is
fed and dipped into a coating-filled pan by a system of rollers.
The saturated web is then passed through nip rollers that squeeze
off any excess coating.
Among the POWC survey respondents, dip and squeeze coating
was the most-common coating station in the decorative and
industrial laminates industry segment, at 36 percent of the
coating stations. Overall, only 5 percent of the coating
stations from the entire survey respondents used dip and -squeeze,
with 3 percent of the flexible vinyl industry segment and
1 percent of the pressure-sensitive tapes and labels industry
segment.
2.2.2.1.8 Extrusion/calendering. The extrusion coater
creates a web substrate or applies coating materials to a
preformed web substrate by forcing it through a die. A typical
extrusion coater forms a plastic film or coating of the hot-melt
type by forcing a molten polymer resin through a die as the web
or conveyor passes below the die. The extruded web is then
cooled to restore the coating to a solid state.25 Nearly all
extrusion coatings are made of low-density polyethylene (LDPE).
They account for a large portion of the coatings used in the
printing product and packaging industry, divided about evenly
between cartons/cardboard and flexible materials.26 Figure 2-5
shows a diagram of an extrusion coater.
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In calendering, a process similar to extrusion, material is
pressed by a roller or between rollers to form a web such as
vinyl sheeting. Calendering may also be used to apply a coating
to a substrate, as in the manufacture of duct tape.27 Prior to
calendering, resins, plasticizers, and pigments are blended
together in a series of blenders, mixers, and mills.
Plasticizers are used to improve the flexibility of the
coating/material.28 After mixing, the mixture is conveyed to the
calender. In a typical four-roll calender, the molten coating is
rolled into a continuous sheet, which is then cooled. Figure 2-6
shows the calendering process.
Among the POWC survey respondents, extrusion/calendering was
used most often in the pressure-sensitive tapes and labels
industry segment, at 3 percent of the coating stations, with
2 percent of the coating stations in the photographic film
industry segment using extrusion/calendering occurring. No
coating stations were reported to use extrusion/calendering in
the decorative and industrial laminates industry segment.
2.2.2.2 Coating Ovens. Like the applicator, the oven is a
primary piece of equipment on the coating line. The major
functions of the oven are to dry the coating by evaporating the
solvent and/or finish the curing of a polymeric coating.31 The
oven exhaust is the largest source of HAP emissions in the
coating process.
The important properties of a drying/curing oven include the
source of heat, operating temperature, residence time, allowable
hydrocarbon concentration, and oven air circulation.32 There are
two basic types of heating used in drying ovens, direct and
indirect. Direct heating routes the hot products of combustion
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ompounded Plastic
Rolters
Figure 2-6. Calendering process.30
2-17.
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(blended with ambient air to the proper temperature) directly
into the drying zone. The fuels used for a direct-fired oven are
usually limited to natural gas or propane because of the
requirements for clean burning. Fuel oil, or other heavier
fuels, can produce enough soot and other particulates to
adversely affect the coating.
In an indirect-heated oven, the incoming air stream
exchanges heat with steam or combustion products but does not
physically mix with them. The heat transfer may occur in any of
several types of heat exchangers, such as shell-and-tube or plate
type.
Direct-fired ovens are more common because of their higher
thermal efficiency. Indirect-heated ovens lose efficiency both
in the production of steam and in the heat transfer from steam to
oven air.33 Indirect heating is usually limited to small ovens,
cases where product contamination cannot be tolerated, and where
surplus steam is available.
The average oven temperature is important to both the
process and the costs of installing add-on control equipment.
For drying purposes, the oven must be at a temperature above the
boiling point of the solvent(s). If the coating cures by
polymerization rather than solvent evaporation, the temperature
may have to be even higher. The average temperature affects the
amount of cooling required if the exhaust stream is directed to a
carbon adsorber and the amount of preheating required if the
exhaust stream is directed to a thermal oxidizer.
The oven temperature profile is also important to product
quality. If the initial drying is too fast, flaws in the coating
such as craters or fish-eyes may result.34 If the drying is too
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slow at lower temperatures, a longer oven will be needed to dry
the coating. The solution to this problem is multizoned ovens,
where the oven is physically divided into several sections, each
with its own hot air supply and exhaust. By using a lower
temperature in the first zone and then gradually increasing the
temperature in subsequent zones, uniform drying can be achieved
in a reasonably sized oven.35
For safety, most facilities in the industry try to maintain
air flow through their ovens so that the solvent concentration is
no greater than 25 percent of the lower explosive limit (LEL).
However, newer oven styles safely allow higher solvent
concentrations, up to 40 to 50 percent of the LEL. The higher
solvent concentrations are allowable due to the increasing use of
continuous LEL monitors that sound alarms or shut down the line
if the LEL reaches too high a level. With the higher allowable
solvent concentrations, the amount of air flow needed through the
oven is decreased, resulting in lower energy costs. The higher
solvent concentrations also reduce the costs of add-on control
devices, which increase in cost as the air flow increases. The
exhaust flow rates from ovens used by the industry vary from
5,000 to 35,000 standard cubic feet per minute (scfm). Typical
oven exhaust rates are 10,000 to 20,000 scfm.36
2.2.2.3 Inert Ovens. An inert oven is a coating drying method
that uses an inert gas (e.g., nitrogen) to replace oxygen in the
air space in the oven. In an inert oven, solvent vapors can be
concentrated at levels higher than the LEL to enable efficient
collection via condensation. The ovens are also found to be
useful with coatings that otherwise would be difficult to apply
without forming air bubbles under the coating surfaces.37
2-19
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There is no oven vent to the atmosphere in an inert oven.
Instead, a small diameter pipe conducts superconcentrated exhaust
at flow rates of only 100-200 ftVmin to condensation coils.
Solvent concentrations may be 100,000 to 200,000 ppm in an inert
oven's exhaust, which is above the upper explosive limit (UEL)
for most/all solvents. After the solvent condenses out of the
gas in the coils, the cleaned gas is returned to the oven; this
cycle is a closed loop in terms of the oven gas.38
For proper operation, there must be an oxygen-free dead-zone
of air space after the inert oven and before the condenser, where
the air flow is balanced between the air pulled in vs. the air
pushed out. This situation complicates the use of total
enclosures around a coating line with an inert oven.
Unfortunately, air flow as little as 200 ft/min can disturb the
web in an inert oven and cause a web to break, especially one
made of paper. Because of issues such as solvent concentrations
above the UEL and static electricity in film coating, safety is
another concern with totally enclosing the air space around inert
ovens.39
2.2.3 Coating Types
The basic coating types, by composition, used in the POWC
industry are solventborne, waterborne, hot-melt, and radiation-
cure coatings. These coating types are described in this
section, below.
Coatings typically consist of a fluid portion (i.e.,
solvent(s)), resins, pigments, and additives. The solvents and
resins together form the vehicle, which maintains the coating in
liquid form for application; once the coating is deposited on the
substrate, the solvents of the vehicle evaporate leaving the
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resin, and the pigments and additives. The solvent portion of
the vehicle transfers the solid portion of the coating to the
substrate surface in a uniform layer and typically plays no role
further role in the coating process.40 Coatings can range from 0
to 99 percent solvent. The nonsolvent portions of coatings are
called "solids."
The HAP from the coatings may be emitted as fugitive
emissions (unless the facility is equipped with a permanent total
enclosure) at the point of application and in flash-off areas.
The HAP from the coatings are also emitted via exhaust
stacks/vents from the ovens used to dry the coatings.
2.2.3.1 Solventborne Coatings. Solventborne coatings are
widely used in the POWC industry.41 The content of the coating
vehicle is highly variable in Solventborne coatings, and depends
primarily on the type of coating applicator used. For
Solventborne coatings, coating formulations typically range from
40 to 80 percent solvents by weight, as supplied. For use, the
Solventborne coatings may be diluted with additional solvents.
The primary solvents in solyentborne coatings that are HAP
include methanol, methyl ethyl ketone, toluene, and xylene.
Other primary solvents (not HAP) include acetone and ethanol.
Knife coaters, reverse roll coaters, and gravure coaters are
commonly used to apply Solventborne coatings.42
2.2.3.2 Waterborne Coatings. In waterborne coatings, a
significant part of the fluid is made up of water, although some
organic solvents may be used at up to 30 percent of the fluid.
The EPA Reference Test Method 24 considers a waterborne coating
to be one with more than 5 percent water by weight in its
volatile fraction.43 Most coating equipment used for
2-21
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solventborne coatings can also be used for waterborne coatings.
However, troughs or trays containing waterborne coatings may have
to be mixed more often than with solventborne coatings because
waterborne coatings are more susceptible to coagulation or
agglomeration of their solids.44 Knife coaters and gravure
coaters are also particularly well suited to application of
waterborne coatings.45
Oven temperatures are typically higher with waterborne
coatings because water has a higher boiling point and higher heat
of vaporization than most organic solvents. However, energy
usage may still be lower for waterborne coatings because less
dilution air is required.46
2.2.3.3 Hot-melt Coatings. Hot-melt coatings are probably the
most environmentally friendly of all the coating formulations
used by the POWC industry because they contain no solvent, being
100 percent solids in composition.47 Unlike solventborne
coatings and waterborne coatings, which typically are formulated
with some organic solvent, hot-melt coatings emit no volatile
organic compounds (VOC). Energy usage with hot-melt coatings is
substantially lower than with either waterborne or solventborne
coatings. Fire and explosion dangers are also minimized because
there are no volatile hydrocarbons.48
The application of hot-melt coatings is fairly simple. The
solid coating material is heated and delivered to the coater head
in a molten state. It is then metered onto the web by a heated
gravure coater, a heated roll coater, or an extrusion coater.
The coated web is then chilled and the coating restored to its
solid state.49 However, despite its simplicity, application of
hot-melt coatings may have several problems. Controlling the
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coating weight can be difficult with hot-melt coatings. The
coater head is more susceptible to streaking due to plugging or
dirt accumulation. Cleaning the coater head with hot-melt
coatings is also more difficult and time consuming.50
The use of hot-melt coatings, although growing, is still
limited by several factors. Hot-melt adhesives do not have the
strength or resistance to environmental stresses such as heat or
cold as do solventborne adhesives.51 The hot-melt adhesives are
typically a darker color and, therefore, are not used on
transparent surfaces. Hot-melts also cannot be used on film
substrates that are sensitive to heat because the substrate could
melt during the coating process.52
2.2.3.4 Reactive Coatings. Reactive coatings are coatings that
cure via a chemical (usually polymeric) reaction which forms
other compounds that are either not HAP's and/or stay with the
substrate as a residual HAP which is not emitted with or without
drying.
Reactive coatings are frequently used in the decorative and
industrial laminates industry segment of the POWC industry and
the abrasive subsector of the miscellaneous industry segment, and
include styrene formaldehyde, phenolic, melamine, and epoxy
resins. In the POWC survey responses in the decorative and
industrial laminates industry segment, seven facilities provided
test or engineering data on the amount of residual HAP left in
the substrate with the use of reactive coatings. These data
indicate that anywhere from zero to 50 percent of the coating (by
weight) reacts and stays with the substrate/product.53
2.2.3.5 Radiation-Cure Coatings. A special case of reactive
coatings, radiation-cure coatings (also called prepolymer
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coatings54) include coatings that are cured by exposure to
electron beam (EB) or ultraviolet (UV) radiation. Radiation-cure
coatings are solventless and are almost entirely composed of the
resins that make up the coating. They are applied in a liquid
state via some typical coating application methods (e.g., gravure
and flexography), and polymerize into a solid state upon exposure
to UV or EB radiation. Ultra-violet-cured coatings require
addition of a photoinitiator to catalyze the polymerization
reaction; EB-cured coatings do not, because the highly exited
electrons emitted by the EB source are capable of initiating the
polymerization reaction.55
Benefits of radiation-cured coatings extend beyond decreased
solvent usage and the associated emission reductions. The
instantaneous nature of the curing process eliminates the need
for drying ovens on the production line, which often leads to
production increases56 and may allow direct integration of
ancillary operations (e.g., cutting, slitting, folding) into the
production line.57 Because no drying ovens are used, energy
usage is greatly reduced as is the space required for a coating
line.58 Since the coatings will not cure unless exposed to the
proper type of UV or EB radiation, they will not cure on the
production equipment during operation or during process downtime.
As a result, it is not necessary to clean application devices at
the end of each shift or during breaks, and cleaning is easier
when it is performed.59
Although industry generally perceives UV coating usage as
expensive because it may be costly to switch a coating line from
solvent-based coating equipment to radiation-cured systems, there
2-24
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are often savings with the use of radiation-cured coatings due to
the above-mentioned benefits that can offset capital costs.
Another industry perception is that the coatings themselves are
more expensive. This may be true on a volume-to-volume basis
comparison, however, a radiation-cured coating will cover a much
greater area of substrate (2 to 4 times) than an equal volume of
a solvent-based coating because the radiation-cured coating is
100 percent solids and has no loss of volume due to evaporation
of solvent. fi°
There are, however, several real limitations to the use of
radiation-curable systems. The extent of cure penetration can be
a problem if the coating is very thick or heavily pigmented.61
Because low viscosity solvents are not used, application of the
relatively higher viscosity radiation-cured coatings can be
problematic; this factor is less important in the application to
web substrates than in spray coating.62 Also, skin contact with
UV-cured coatings should be minimized by the use of gloves
because of the potential for irritation and/or allergic reaction
with the use of these coatings.63 This is especially true when
cleaning is performed, since the combination of cleaning solvents
and inks and coatings increases dramatically the level of
irritation to the skin."
2.3 INDUSTRY PROFILE
The POWC industry includes the manufacture of a wide range
of products. Table 2-2 presents a listing of 18 Standard
Industrial Classification codes (SIC) codes for industries that
include products or processes that are likely to be manufactured
or used, respectively, by the POWC industry. As shown in the
table, the POWC industry is thought to encompass a large number
2-25
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of SIC codes. However, there may be facilities operating under
other SIC codes not included in Table 2-2 that also apply coating
to web substrates, such as paper, plastic, film, foil, and foam.
In addition, all facilities operating under these SIC codes are
not necessarily members of this source category; many of the
18 SIC codes cover only one or two products that are manufactured
with web coating. Some of the 18 SIC codes include facilities
that primarily print rather than coat the substrate, that may
choose to cover their limited coating operations under the
printing and publishing NESHAP. Consequently, while the list of
SIC codes presented in Table 2-2 can serve as a guide to
identifying many of the facilities in the POWC industry, it
should not be used to completely define the industries subject to
the POWC NESHAP.
Based on emissions estimates from the Toxic Release
Inventory (TRI) system65 for these SIC's, the POWC data gathering
efforts focused on the four largest segments of the POWC industry
that were defined by their product and process types: pressure-
sensitive tapes and labels (SIC 2672), flexible vinyl (SIC 3081),
photographic film (SIC 3861), and decorative and industrial
laminates (SIC 3083). Therefore, much of the information in this
section focuses on these four industry segments. A fifth
segment, called "Miscellaneous Coating," is also discussed that
includes a number of industries that are identifiable as having
some web coating operations associated with their product
manufacturing, such as those facilities that do both printing and
coating.
Within 1996 TRI data for the 18 POWC SIC's, the four major
POWC SIC's (2672, 3081, 3861, 3083) had the greatest percentages
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Table 2-2. The 18 SIC Codes of the Paper
and Other Web Coating Industry
SIC Code
2653
2657
2671
2672
2673
2674
2675
2679
2754
2761
3074
3081
3083
3291
3497
3861
3955
3996
Description
Corrugated and solid fiber boxes
Folding paper board boxes, including sanitary
Packaging paper and plastics film, coated and
laminated
Coated and laminated paper, not elsewhere
classified
Plastics, foil, and coated paper bags
Bags : uncoated paper and multi wall
Die -cut paper and paperboard and cardboard
Converted paper and paper board, not elsewhere
classified
Commercial printing, gravure
Manifold business forms
Plastic aseptic packaging
Unsupported plastics film and sheet
Laminated plastics plate, sheet, and profile
shapes
Abrasive products
Laminated aluminum (metal) foil and leaf,
flexible packaging
Photographic equipment and supplies
Carbon paper and inked ribbons
Linoleum, asphalted-felt-base, and other hard
surface floor coverings, not elsewhere
classified
Note: There are likely a number of facilities in each SIC that do not do
coating and these 18 SIC's are not necessarily an exhaustive list of
facilities that may do coating.
2-27
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of major source HAP emissions, and together represent 79 percent
of the TRI emissions and 82 percent of the facilities (if the six
Printing and Publishing SIC codes are excluded from the
analysis) .
The POWC data gathering efforts focused on identifying the
activities within the major industry segments that generated HAP
and on variations in the coating processes and control
techniques. It was found that the web coating operations
(described in Section 2.2) and control techniques (described in
Chapter 3) do not vary significantly among the segments of the
POWC industry.
Most segments of the industry have some operations that are
unique to those segments. The discussion below includes
information on the types of coatings and coating applicators used
by each major segment, and the primary HAP emitted by each
industry segment. It also includes a discussion of operations
that are specific to each industry segment.
2.3.1 Pressure-sensitive Tapes and Labels
The pressure-sensitive tape and label industry segment is
one of the largest segments of the POWC industries, based on 1996
TRI emissions.66 It includes the manufacture of all types of
tapes and labels, including masking tape, strapping tape, duct
tape, transparent tape, electrical tape, and medical tapes and
labels. It also includes the manufacture of metallized labels
and self-adhesive labels.67 Demand for pressure-sensitive labels
has increased as the demand for glue-applied labels has
decreased. One pressure sensitive label product, blank roll
labels (such as for computer data processing), is viewed as a
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fast-growing label market. As of 1989, pressure-sensitive labels
accounted for as much as 22 percent of all labels.68
Survey responses from the pressure-sensitive tapes and
labels industry segment, showed that in terms of primary
products, bonding and mounting tapes and labels were reported
most often (18 percent), with carton sealing, abrasion resistant,
and application/pre-mask tapes and/or labels next highest (at 12,
10, and 10 percent, respectively).S9 Table 2-3 shows the
29 primary products listed in the pressure-sensitive tapes and
labels survey responses.70
In a survey conducted by the Pressure Sensitive Tape Council
in 1994, 39 percent of the responding facilities indicated they
manufactured film tape, 25 percent label stock, 15 percent paper
tape, 5 percent cloth tape, 2 percent filament tape, and
15 percent other types of tape.71 Backing materials (substrates)
used by the pressure-sensitive tape and label industry segment
include paper, a variety of films, foam, metal foil, and fabric.
Medical tapes and duct tapes are made with fabric backings.72
2.3.1.1 Baseline Emissions. In the POWC data gathering
effort, information was collected from 91 facilities in the
pressure-sensitive tapes and labels industry segment, of which 44
were determined to be major sources of HAP. The total number of
facilities and HAP emissions in the pressure-sensitive tapes and
labels industry segment were estimated to be 96 facilities and
8,063 tons per year (tpy) HAP emissions, representing 22 percent
of the total number of facilities and 17 percent of total HAP
emissions estimated for the POWC source category.73
The total number of major sources and HAP emissions in the
pressure-sensitive tapes and labels industry segment were
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Table 2-3. Primary Products of the Pressure-sensitive
Tapes and Labels Survey Respondents
Primary Product
bonding and mounting
carton sealing
abrasion resistant
application/pre-mask
double side
identification/safety, warning
ant i- skid
anti-stick
book binding
bundling
label
coated textile for care labels
correct ion/cover -up
electrical
electronic applications
fastening
freezer
office/stationery
packaging
printable
protective - long term
pressure -sensitive adhesive -coated films
silicone
specialty fabric tapes
surface protection
trainer tapes - cotton based
transfer
vibration/ sound damping
vinyl graphics film
Total
Percent of
Respondents
18
12
10
10
9
4
3
3
3
3
3
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
100
2-30
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estimated to be 47 facilities and 7,780 tpy HAP emissions,
representing 11 percent of the total number of facilities and
16 percent of the total HAP emissions estimated for the POWC
source category.
The primary HAP emitted by the pressure-sensitive tapes and
labels industry segment are toluene, xylene, methyl ethyl ketone,
and methanol.
2.3.1.2 Types of Coatings and Applicators Used. The pressure-
sensitive tape and label industry segment primarily uses five
classes of coatings: adhesives; release coatings; primers;
coloring agents; and saturants. Adhesives are used on all
pressure-sensitive tapes and labels.
The pressure-sensitive tape and label industry segment uses
a range of coating formulations. According to a survey conducted
by the Pressure Sensitive Tape Council,74 84 percent of the
facilities responding to the survey indicate they used
solventborne coatings, 60 percent waterborne coatings, 43 percent
hot-melts, 13 percent calendered adhesives, 8 percent radiation-
cured coatings, 8 percent two-part reactive coatings, and
6 percent other types of coating formulations.
Solventborne coatings are used as adhesives, release
coatings, primers, coloring agents, and saturants. They can also
be used on all types of backing materials. For some
applications--particularly special purpose applications requiring
high performance from the adhesive, or applications where the
tape is exposed to extreme environmental conditions--solventborne
coatings are often the only coatings available that can achieve
the performance and durability required.
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Waterborne coatings are also used by the pressure-sensitive
tape and label industry segment for adhesives and release
coatings. Waterborne adhesives are comparable in performance to
many solventborne adhesives. They are currently being used for
many applications within the industry segment and, as technology
continues to improve, the number of waterborne coating
applications in the pressure-sensitive tapes and labels industry
should increase. In some applications where high performance is
required or in extreme environmental conditions, solventborne
adhesives may still be required, but eventually waterborne
adhesives may also be able to be used for these applications.
Drawbacks of using water-based adhesives may include what
one company75 found was that waterbased adhesives need closer
control of process variables and coater conditions, which can
lower line speeds and raise cost to the consumer. Waterbased
adhesives are thought to be more suited to gravure or slot die
coating application techniques than reverse roll in this aspect.
Clean-up operations are also reportedly more difficult with
waterbased adhesives. In addition, waterbased adhesive-coated
products may need to be remoisturized after drying to reduce curl
and to ease laminating, top coating, and finishing operations.
Waterbased release coatings are already being used
extensively by the pressure-sensitive tape and label industry
segment.76 In most cases, the performance of the release coating
is not as critical as that of the adhesive, so the pressure-
sensitive tape and label industry segment has made more progress
in converting to waterborne release coatings.
Hot-melt coatings, especially, adhesives, are used
extensively by the pressure-sensitive tape and label industry
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segment.77 Hot-melt coatings are generally considered to be
100 percent solids, and essentially pollution free. The POWC
survey responses indicate that of the 21 coatings identified as
hot-melt adhesives, 17 were 100 percent solids.78 The remaining
four hot-melt adhesive coatings had solids contents ranging from
99.90 to 99.96 percent. Only one of these four, however,
contained any HAP (naphthalene), at a concentration of 0.04
weight percent.
Although hot-melt adhesives are solvent-free, the
possibility exists for the evaporative loss of some of the
lighter components in the coating formulation. Most of the
applicable coatings are high molecular weight polymers, which may
contain trace amounts of unreacted monomers and/or low molecular
weight polymers. Some of these may be volatilized at the coating
temperatures experienced in hot-melt coating operations. The EPA
conducted limited tests to measure evaporative losses from hot-
\
melt coatings. Weight losses of from 0.1 to 12.6 percent
occurred.79
The types of coating applicators used by survey recipients
in the pressure-sensitive tapes and labels industry segment are
shown in Table 2-4.80 This table shows that 33 percent of the
coating stations in the pressure-sensitive tapes and labels
survey industry segment use gravure coaters, 26 percent use roll
and/or reverse roll, 12 percent use slot die, and 11 percent use
Mayer rod, with the remaining 19 percent of the stations using
five other applicator types.
2.3.1.3 Pressure-sensitive Tapes and Labels Coating Process.
The coating of pressure sensitive tapes and labels is called
a "converting" operation, in which some backing material (paper,
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Table 2-4. Types of Coating Applicators Used by Survey
Respondents in the Pressure-sensitive Tapes and
Labels Industry Segment
Application Method
Gravure
Roll, Reverse Roll
Slot Die
Mayer Rod
Knife
Flexography
Extrusion/calendering
Dip
Flow
Total
Percentage of
Application Stations
33
26
12
11
9
4
3
1
1
100
Note:
Seventy-five percent of the flexography coating stations are
flexography printing.
cloth, cellophane, etc.) is coated one or more times to create a
tape or label that will stick on contact for the consumer's
purposes. In the pressure-sensitive tape process, the web is
unrolled, coated, dried, chilled, and then rolled up. The
coating processes may add pre-coats, adhesives, or release
coatings.81
Each pressure sensitive tape and label coating line
typically undergoes a minimum of two coating operations. These
may be done separately on discrete coating lines, or a single
tandem coating line may be used where the web undergoes a
sequence of coating and drying steps without being rewound
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between steps. Tandem coating lines are usually used for large
volume products with relatively long runs times, since the
flexibility of a coating line is reduced with a tandem set-up.82
With most pressure-sensitive tapes and labels, release
coatings are applied to the backside of the tape or the mounting
paper for labels. The labels may be pre-printed. The function
of the release coating is to allow smooth and easy unrolling of
the tape or removal of the label from the mounting paper. In
some cases, primers are applied to the backing material before
the adhesive is applied. The primer improves the bond between
the backing material and the adhesive. Coloring agents may be
coated onto the backing or in some cases may saturate the backing
for decorative purposes. For some applications, the backing may
be saturated with various materials to modify the properties of
the backing. For example, a paper backing may be saturated with
synthetic rubber to increase its tensile strength and
flexibility.
2.3.2 Flexible Vinvl
This segment of the POWC industry includes facilities
manufacturing a range of products from flexible vinyl. Polyvinyl
chloride (PVC) is the primary substrate used to manufacture
flexible vinyl products. Products manufactured by the flexible
vinyl products industry segment include wall coverings,
automotive upholstery, furniture upholstery, tablecloths,
luggage, and shower curtains.83 Most products are manufactured
from PVC film supported by fabric, paper, or foam. The PVC is
used as a substrate and as a dispersion coating layer in the
manufacture of wall coverings. Unsupported vinyl products
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include shower curtain liners, pool liners, and some window
shades.84
According to an estimate by the Gravure Association of
America, nearly 50 percent of the 1981 value of supported vinyl
products was attributable to wall coverings. According to the
Adhesives and Sealant Council, more than 75 percent of
residential wall coverings are pre-pasted strippable products.
Another 20 percent are fabric-backed vinyl, and the remaining
5 percent are specialty items (metallics, grass cloth, rice
paper, or other unusual substrates).8S Production of vinyl
products has been declining since the 1980s, especially for
automotive upholstery and trim. A further decline in automotive
vinyls production is likely.86
In the responses to the EPA POWC survey, among 47 flexible
vinyl segment facilities, 38 percent indicated that they perform
substrate formation at their facility.
2.3.2.1 Baseline Emissions. In the POWC data gathering effort,
information was collected from 47 facilities in the flexible
vinyl industry segment, of which 20 were determined to be major
sources of HAP's. The total number of facilities and HAP
emissions in the flexible vinyl industry segment were estimated
to be 112 facilities and 13,878 tpy HAP emissions, representing
26 percent of the facilities and 28 percent of the total HAP
emissions estimated for the POWC source category.87
The total number of major sources and HAP emissions in the
flexible vinyl industry segment were estimated to be
49 facilities and 13,257 tpy HAP emissions, representing 11
percent of the total facilities and 27 percent of the total HAP
emissions estimated for the POWC source category.88
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2.3.2.2 Types of Coatings and Applicators Used. The flexible
vinyl industry segment primarily uses a number of functional
types of coatings: base coats, primers, topcoats, photo-reactive,
laminating (for support), adhesion, and substrate forming. The
flexible vinyl industry segment uses a range of coating
formulations: solventborne, waterborne, hot melt, and UV-cured.
Solventborne, waterborne, and high-solids coatings are used
for laminating flexible vinyl products where adhesives are
required. However, in some cases, an adhesive is not used for
bonding the vinyl to fabric; instead, the vinyl sheet is bonded
to the fabric by either compression between two rollers or by
casting directly onto the fabric.
The use of waterborne and high-solids primers and topcoats
is still limited in the flexible vinyl industry. For example,
waterborne topcoats cannot be used for automotive parts such as
dashboards and vinyl roofs that are exposed to the sun as they
do not provide the same resistance to ultraviolet light as
solventborne topcoats.89-90 Most of the coatings and inks used to
coat a PVC web are solvent solutions of vinyl chloride/vinyl
acetate copolymers and PVC resins. A typical ink or coating used
in the manufacture of flexible vinyl products is 85 percent
solvent and 15 percent solids.91
The types of coating applicators used by survey recipients
in the flexible vinyl industry segment are shown in Table 2-5.92
Table 2-5 shows that for the flexible vinyl industry segment,
40 percent of the coating stations used gravure coating, 20
percent used flexographic coating, 11 percent use knife or air
knife, 9 percent used a roll or reverse roll coater, and
7 percent used rotary screen coating. The remaining 13 percent
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Table 2-5. Types of Coating Applicators Used by Survey
Respondents in the Flexible Vinyl Film Industry Segment
Application Method
Gravure
Flexography
Knife/Air Knife
Roll/Reverse Roll
Rotary screen
Dip
Die
Mayer Rod
Other3
Total
Percentage of
Application Stations
40
20
11
9
7
3
3
3
4
100
a Including flow coater, spray, squeeze, calender, and electrostatic.
are distributed among ten different coating application types.
2.3.2.3 Flexible Vinyl Coating Process. The process used to
produce flexible vinyl products consists of web formation,
finishing (which may include both printing and coating), and
embossing.
The vinyl web formation process consists of vinyl coating
preparation, vinyl coating formation or application to the web,
and, in some cases, expansion of the web. Vinyl substrates are
formed by calendaring, extruding, casting, and knife/roll
coating.93 All except knife/roll coating use plasticizers, which
improve the flexibility of the coating/material.
Extruding, calendaring, and knife/roll coating techniques
were discussed above in Section 2.2.2. In the casting process, a
vinyl web is cast or coated onto a paper carrier web using roll
coating or knife coating. This paper is ultimately removed and
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reused. The vinyl web surface next to the paper becomes the
finished product surface. The paper carrier may impart a mirror-
like finish or a textured surface to the vinyl web.
Most resins used in vinyl web formation are composed
primarily of polymers of high molecular weight. These polymers
are generally not volatile, and, therefore, VOC and HAP emissions
are negligible.94 Traces of solvent may be emitted from the
ovens; some of these vapors are captured by the ovens and
controlled.
The emissions from vinyl web formation are mostly high
molecular weight organic compounds which condense into aerosols.
These compounds are primarily vaporized plasticizers from the
heated materials as it is blended, mixed, conveyed, calendared,
and cooled. Some of these plasticizers may be HAP. The compound
DEEP, which is a HAP, is often used as a plasticizer. For the
reasons discussed above, emissions from vinyl web formation
processes, which are primarily aerosol, were not considered in
the flexible vinyl NSPS.95 In the POWC survey responses, HAP
emissions were zero or low in substrate formation in the flexible
vinyl industry.96
The primer used in the flexible vinyl industry provides an
extra-smooth surface for the printing step which often follows.
After primer application, the web may be printed, and then a
final topcoat is applied. The topcoat provides protection
against wear.
Flexible vinyl products are sometimes embossed to improve
their appearance or wearability. Most flexible vinyl substrates
are embossed as part of the finishing operation that may include
laminating or printing. The exception is calendared products,
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which are embossed as they exit the calendar. The embossing line
consists of a support roller and an embossing cylinder. The
image pattern is formed in the surface of the cylinder by
mechanical or chemical means. The web is heated and continuously
drawn between the embossing and supporting rollers. As it passes
through the cooled roller, the image or pattern is set in the hot
web surface.97
Volatile emissions from the process of embossing are likely
to be relatively low. The emissions from the embossing process
depend primarily on the type of material and coatings on the web
being heated. In embossing of a newly-calendared flexible vinyl
substrate, the emissions are high molecular weight organic
compounds which condense as they exit the stack gases. These
emissions are primarily plasticizers from the heated web. Based
on information collected by the EPA from 100 plants in 1980,
aerosol emissions from the embossing operation of an average
plant were estimated to by 8 tpy; VOC emissions from embossing
were estimated to be 10 tpy, or 1.3 percent of the total plant
VOC emissions.98
A PVC web may be coated, printed, or both. Both coating and
printing are typically done with gravure coaters. In the
production of vinyl products, printing, coating, embossing, and
other finishing processes are almost always performed on a single
line (often referred to as "imaging equipment"). Some products
are printed by flexography or screen printing and then coated by
gravure." In the manufacture of flexible vinyl products, there
is little distinction between the printing and coating
operations.
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2.3.3 Photographic Film
The photographic film industry segment manufactures film for
diverse products such as still cameras and moving pictures,
microfiche film, x-ray film, intensifying screens, and decorative
window coverings.100 Both cellulose acetate film and polyester
film are used for photographic film, although cellulose acetate
is used more than polyester. Facilities manufacturing
photographic film may also coat paper for use as photographic
paper or as backing material for photographic film.101 These
facilities may also coat some pressure-sensitive tape, which is
used at the end of a film roll to hold the roll in place.
In the responses to the EPA POWC survey, among the
15 facilities that responded in the photographic film industry
segment, 20 percent reported that they perform film substrate
formation on site.
2.3.3.1 Baseline Emissions. In the POWC data gathering effort,
information was collected from 15 facilities in the photographic
film industry segment, of which 11 were determined to be major
sources of HAP's.102
The total number of facilities and HAP emissions in the
photographic film industry segment were estimated to be
36 facilities and 5,306 tpy HAP emissions, representing 8 percent
of the total facilities and 11 percent of the total HAP emissions
estimated for the POWC source category.103 The total number of
major sources in the photographic film industry segment were
estimated to be 27 facilities and 5,254 tpy HAP emissions,
representing 6 percent of the total facilities and approximately
11 percent of the total HAP emissions estimated for the POWC
source category.
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The primary HAP's emitted by the (photographic) film
manufacturing industry segment are methyl ethyl ketone, methylene
chloride, and methanol. Methylene chloride is primarily emitted
from the formation and coating of cellulose acetate film and
polyester film.104
2.3.3.2 Types of Coatings and Applicators Used. The
photographic film industry segment primarily uses a number of
functional types of coatings: base coats, primers, topcoats,
photo-reactive, laminating (for support), adhesion, and substrate
forming. The photographic film industry segment uses a range of
coating formulations: solventborne, waterborne, hot melt, and UV-
cured.
The base coatings, or sublayers, of photographic film are
typically solventborne coatings. These coatings act as an
antistatic and provide lubricity. The coatings are formulated
with a number of solvents, but methanol is the most commonly used
solvent.105 Some formaldehyde and dimethyl formamide are also
used.106 The number of layers of photosensitization materials
that are applied varies according to the complexity of the film.
Twelve or more layers may be applied to the more complex films.107
Unlike most coating processes, multiple layers may be applied
simultaneously at the same coating station to photographic film.
At some facilities, multiple waterbased coating layers are
applied at the same station. The coatings do not mix because
each coating has a different viscosity.108 All coating of
photosensitization materials is done in the absence of light.109
The coatings used in the photosensitization process are
waterborne emulsions. Some of these coatings may contain small
concentrations of methanol, but water is the primary solvent.
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In coatings used for x-rays and intensifying screens,
acetone (not a HAP) , methylene chloride, and tnethanol are the
primary solvents.110 As with photographic film production,
waterborne coatings are used in the photosensitization coating
process.
The types of coating applicators used by survey recipients
in the photographic film industry segment are shown in
Table 2-6.1U Table 2-6 shows that for the photographic film
industry segment, 44 percent of the coating stations used a die,
28 percent used roll or reverse roll coating, 12 percent used
gravure coating. The remaining 16 percent are distributed among
four different coating application types.
Table 2-6. Types of Coating Applicators Used by Survey
Respondents in the Photographic Film Industry Segment
Application Method
Die
Roll /reverse roll
Gravure
Knife/Air knife
Mayer Rod
Calender
Flow
Total
Percentage of
Application Stations
44
28
12
11 '
2
2
1
100
2.3.3.3 Photographic Film Coating Process. The coating process
for photographic film is similar to that for other segments of
the industry. The web is unwound, coated, and then rewound.
However, different types of coatings may be applied on different
lines. For example, base coatings are applied on one line, and
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the web is then rewound and moved to another line where the web
is unwound, coated with photosensitization materials, and then
rewound. The coating process for x-rays and for intensifying
screens, which are often used in place of the traditional x-rays,
is similar to that for photographic film. The intensifying
screens are first coated with three types of solventborne
coatings overcoat for protection; and an anti-curl layer. The
substrate is then rewound and transferred to another line for the
application of the photosensitization materials.112
Some film facilities manufacture their film onsite. In the
formation of cellulose acetose film, cellulose acetate is
dissolved in methylene chloride and cast onto a wheel. As the
methylene chloride is driven off, this wheel becomes the unwind
reel for the coating line. The formed film is unwound from the
wheel, coated, and then rewound; therefore, formation of the
substrate can be considered a part of the coating line, as in
vinyl film formation.113 Film formation itself is not likely to
be a significant source of HAP emissions at film manufacturing
facilities. In the POWC survey responses, facilities had little
or no HAP emissions solely from the formation of the film.114
2.3.4 Decorative and Industrial Laminates
Decorative laminates provide an aesthetically pleasing
surface used in products such as kitchen counter tops, and store
display shelving. Laminates may also be used in the manufacture
of such products as floor coverings and finished particle
boards.115 Industrial laminates provide a functional surface with
special properties such as fire, electrical, or chemical
resistance,116 and are used to manufacture products such as rigid
laminates used in furniture manufacturing, interior building
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construction, printed wiring board (PWB) blanks, industrial
tubes, yoke bars, and molded bearings. Flexible laminates are a
type of laminate that is bendable, often in cable form, and is
used by some electronics manufacturers in automobiles, computers,
and radios.
Laminate production facilities may also manufacture
adhesives, release coatings, and resins. These facilities may
also perform coating operations for production of release paper
and printing operations for production of the decorative paper.
Sources of HAP emissions from the manufacture of decorative
and industrial laminates include mixing/compounding, coating,
drying, curing, pressing, and finishing operations; however, the
predominant emission points are from coating, drying, and curing.
2.3.4.1 Baseline Emissions. In the POWC data gathering
effort,117 information was collected from 41 facilities in the
decorative and industrial laminates industry segment, of which 17
were determined to be major sources of HAP's. The total number
of facilities and HAP emissions in the decorative and industrial
laminates industry segment were estimated to be 68 facilities and
8,798 tpy HAP emissions, representing 16 percent of the total
facilities and 18 percent of the total HAP emissions estimated
for the POWC source category.118 The total number of major
sources and HAP emissions in the decorative and industrial
laminates industry segment were estimated to be 28 facilities and
8,489 tpy HAP emissions, representing 7 percent of the total
facilities and 17 percent of the total HAP emissions estimated
for the POWC source category.119
The primary HAP emitted by the decorative and industrial
laminates industry segment are methanol, phenol, and toluene.
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Although release coatings in the past contained chromium, the
POWC survey responses indicate this may no longer be true.120
2.3.4.2 Types of Coatings and Applicators Used. The decorative
and industrial laminates industry segment uses many functional
types of coatings: primers, topcoats, lacquers, substrate
forming, laminating, fire resisting, chemical resisting,
releasing, decorative, and saturating. The coating formulations
used are: solventborne, reactive (resins), release coats, and
adhesives.121
Resins used in the laminating process include epoxy,
melamine, phenol-formaldehyde, polyester, polyvinyl acetate
(PVAC), polyvinyl acrylate (PVA), silicone, styrene-formaldehyde,
and urea-formaldehyde.122'123-124-125 Laminate producers generally
distinguish resins from adhesives by defining a resin as a
substance that impregnates or saturates the substrate, while an
adhesive is a substance applied to the substrate surface.126 The
HAP emitted in largest amounts are methanol, phenol, and
formaldehyde.
The types of coating applicators used by survey recipients
in the decorative and industrial laminates industry segment are
shown in Table 2-7.127 This table shows that 36 percent of the
coating stations are dip, 34 percent are gravure, and 20 percent
are roll and/or reverse roll, with the remaining stations being
Mayer rod and knife applicators (5 percent of the stations,
each) .
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Table 2-7. Types of Coating Applicators Used by Survey
Respondents in the Decorative and Industrial
Laminates Industry Segment
Application Method
Dip
Gravure
Roll, Reverse Roll
Mayer Rod
Knife
Total
Percentage of
Application Stations
36
34
20
5
5
100
2.3.4.3 Decorative and Industrial Laminate Coating Process.
In the manufacture of the decorative and industrial
laminates, the first operation is known as "compounding," and
involves activation of the resins by mixing together precise
amounts of the varnish components in a batch tank. This
compounding process is referred to as the "A-stage." The amount
of each component used is generally controlled by weight; and
precise adherence to specified amounts, temperatures, mixing
times, and sequence is necessary for a good quality resin. At
this point, the varnish is held for a digestion period so the
reactivity can stabilize it to a consistent and prescribed level
appropriate to the next operation.128
After the digestion period, web substrates (e.g., paper or
woven fiberglass) are loaded on the coating line (or treater).
The web is dipped into a resin tank equipped with metering
apparatus, and then to an oven to evaporate the solvent and
achieve partial cure of the resin. This process is called the
"B-stage." Any decorative or overlay paper used in the product
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is also treated in the B-stage, usually by impregnation with
resins. Release paper used in the product, if not purchased pre-
coated, is dip coated in the B-stage as well.129
The next stage, or WC-stage" is a press lamination
operation. First, some B-stage products are cut into sheets, anri
then multiple plies of the sheets are collated according to the
ultimate core thickness. With decorative laminates, a decorative
overlay (printed or solid pigmented pattern sheet) is also added
used. The laminate may also include layers of release paper
(paper treated with a release coating) applied during pressing.
The release paper allows separation of layers after pressing, so
that several sheets of laminate can be produced together.
Alternatively, some B-stage products are left uncut to produce
continuous laminates. The C-stage operations are done in batch
pressings.130
The collated laminates are then laid between press plates
with copper foil on the surface of the stack. These "books" or
packages of laminates undergo high temperature and pressure
pressing to cure it to its final form. High-pressure laminates
are subject to pressures of between 1,000 and 1,400 pounds per
square inch (psi) during manufacture.131
After the pressed books are removed from the C-stage press,
they are transported to a tear down station where the laminate is
separated from the press plates. Continuous laminates can be
rolled at this point, but only into large-diameter rolls. The
C-stage products from PWB manufacture may be left in a roll and
sold as pre-preg bonding;132 it may undergo additional lamination
at other facilities to produce multilayer laminate.133 Other C-
stage products may undergo several finishing steps to prepare
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them for shipment. Preparation for delivery includes labeling
and packaging.134
Laminates are also produced by application of an adhesive-
coated roll of paper or vinyl film to panel substrate. The paper
or vinyl film is unwound, coated with a liquid adhesive, and then
combined with a substrate at a combining station. The substrate
may be panels of particle board, fiberboard, hardboard, etc., fed
into the line continuously end to end. Following lamination, the
panels are individually stacked.
The flexible laminate manufacturing process is somewhat
different than that used by rigid laminate manufacturers.
Generally, flexible laminate manufacturers purchase the plastic
substrate, which is manufactured elsewhere, and use adhesive to
attach copper foil. The adhesive application process is
performed on a web, and often the shipped product is still in a
web form when it is delivered to the circuit board manufacturer.
2.3.5 Miscellaneous Coating Industries
This industry segment was created primarily to represent the
remaining sectors of the POWC, such as the major subsectors of
abrasive coating, specialty coaters that coat paper to customer
specifications as it is obtained from paper manufacturers, and
rotogravure and wide-web flexography coating (primarily in the
packaging and product subdivision that produces flexible
packaging for food). Other, minor subsectors of the POWC
industry produce the following products: corrugated and solid
fiber boxes; folding paperboard boxes, including sanitary; die-
cut paper and paperboard and cardboard; converted paper and
paperboard, not elsewhere classified; manifold business forms and
related products; plastic aseptic packaging; and carbon paper and
2-49
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inked ribbons. Because rotogravure and wide-web flexographic
coating has been previously researched and studied under the
printing and publishing NESHAP, this subsector is not further
discussed here.135
The 1996 TRI emissions for the Miscellaneous POWC industries
are shown in Table 2-8. From the information in Table 2-8, it
can be seen that the abrasives products subsector has the
greatest number of facilities among this group (at 32 percent),
and the converted paper and paperboard products not elsewhere
classified (gift wrap, paper wall paper, cigarette paper)
subsector has the highest per-facility emissions (86 tpy) and
highest portion of the emissions (42 percent).
2.3.5.1 Baseline Emissions. Using TRI data from 1996 -for SIC
codes 2653, 2657, 2675, 2679, 2761, 3074, 3291, and 3955, the
total number of facilities and HAP emissions in the miscellaneous
industry segment were estimated to be 117 facilities and 13,174
tpy HAP emissions, representing 27 percent of the total
facilities and 27 percent of the total HAP emissions estimated
for the POWC source category. The total number of major sources
and HAP emissions in the miscellaneous industry segment were
estimated to be 52 facilities and 12,714 tpy HAP emissions,
representing 12 percent of the total facilities and 26 percent of
the total HAP emissions estimated for the POWC source category.136
2.3.5.2 Abrasive Products. Many abrasive products such as
sandpaper are coated products. Paper, film, cloth, and heavy
fiber are all substrates used in the manufacture of abrasive
products. In particular, the use of films, especially polyester
films, is growing. If cloth is used as an abrasive product
2-50
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substrate, the cloth is pretreated to give it body; abrasive
cloths are called finishing cloths.137
The coating process for abrasive products includes up to
three coatings that are applied to the substrate. For a cloth
abrasive, a seal coat is applied to the cloth. An adhesive
coating is then applied to bind the abrasive to the substrate.
The abrasive is applied, and, in some cases, another protective
coating is applied over the abrasive. Adhesives are applied with
a roll coater, while the abrasive is typically applied
electrostatically. For some applications, a pressure-sensitive
adhesive backing is applied to the abrasive product. Printing is
also used.with abrasives manufacturing to place the company name
on the back of products that include sandpaper. Grit is
applied/printed onto the sandpaper backing with a flexography
roller.138
Most of the coatings and adhesives used by the abrasive
products industry segment are waterborne. Some special purpose
products may still require solventbome coatings and adhesives,
but even these are being reformulated to waterborne. UV-cured
coatings are used in the manufacture of ophthalmic abrasives,
that are used to grind ophthalmic lenses. This product is
amenable to the UV process because of the thinness of the
substrate that allows for complete penetration and curing of the
coating by the UV radiation.139
A phenol-formaldehyde resin is used to bind the abrasive to
the substrate. These resins are a source of formaldehyde
emissions because they are formulated with excess formaldehyde.
However, the amount of excess formaldehyde has decreased
dramatically over the years. The resins used to contain as much
2-52
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as 20 percent excess formaldehyde, but they now have less than
I percent excess formaldehyde.140 Phenol and formaldehyde are the
primary HAP emitted by the abrasive products industry segment.
Based on 1996 TRI data for SIC 3291, the abrasive coating
industry subsector has 46 facilities and emits approximately
1,400 tpy HAP.141 The abrasive coating industry consists of only
five corporations (of which two are the primary participants),"
each having facilities at multiple locations. The industry is
represented by the Coating Abrasives Manufacturing Industry
(CAMI) trade association.142
2.3.5.3 Specialty Paper Coating. The term "specialty coating"
evolved as a means to distinguish traditional paper
manufacturers, who use mostly waterbased coatings in the paper
making process, from those facilities (some closely associated
with paper manufacturers) that apply solventbased coatings to
paper in order to generate products, often for other paper
converters who interface with the customers (i.e., consumers or
end users). Specialty coating, then, connotes solvent-based web
coating by the latter group of facilities.143 Specialty-coated
products may include some of the products presented above in the
discussion of the pressure-sensitive tape and label, flexible
vinyl, and photographic film industry segments. However, what
differentiates the subset of specialty-coated products from the
broad class of web-coated products is the great extent to which
their manufacture depends on customer specifications.
The American Forest & Paper Association (AF&PA) represents
the majority of the members of the paper industry and has a
constituency of twelve companies classified as specialty coaters.
Information in this section is largely based on site visits to
9
2-53
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some of these specialty coating facilities performed with the
cooperation and coordination of the AF&PA.
Specialty coaters coat paper, in grades varying from tissue
paper to heavy kraft paper, as well as paper/foil laminates,
polyester and other films, aluminum foil, vinyl, canvas and other
fabrics, and possibly other substrates. Specialty-coated
products and/or end-uses include thermal imaging papers (i.e.,
fax paper, paper for register receipts), pressure-sensitive
labels, microfilm for data storage, graphic arts papers, paper
for finished stationery products (i.e., notepads, diaries), gift
wrap (for sale to distributors), electronic equipment,
photography, and printed circuit boards. Thus, as previously
mentioned, specialty coated products are not necessarily products
absent from the other web coating industry segments.
Specialty coating facilities are not necessarily small, with
some having over 10 coating lines. Facilities that conduct more
printing than coating may have longer setup and breakdown periods
than facilities that produce only a few products, because the
print plates are more likely to need to be switched out between
different product runs than coating lines, which can be dedicated
to one type of coating process applying a uniform layer across
the web.
The types of coating applicators used by the specialty
coaters include gravure, roll, rod, slot die, and knife. The
types of coatings include solventbased ,waterborne, UV-cured, and
100 percent solids. The HAP's used by specialty coaters include
vinyl acetate, methanol, toluene, glycol ethers, and methyl ethyl
ketone (MEK).
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Safety issues at specialty coating facilities arise with the
use of some low-HAP coatings, such as the need to use corona
dischargers (which generate ozone) to treat film surfaces before
applying waterbased coatings, and the allergic reactions in some
individuals as a result of working with 100 percent solids,
radiation-cured coatings. Technical issues with regard to
replacing solventborne coatings .in specialty coating include the
inability to replace solventborne formulations for applications
such as the metallized coating of paper and the manufacture of
microfilm, both of which currently require solventbased coating
chemistries.
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2.4 REFERENCES
1. Docket No. A-99-09. U.S. Environmental Protection Agency,
Washington, DC. 1999. Responses from the paper and other web
coating NESHAP survey.
2. Reference 1.
3. Reference 1.
4. Profile Survey of the U.S. Gravure Industry. Gravure
Association of America, New York, New York. 1996.
5. Docket No. A-92-42. U.S. Environmental Protection Agency,
Washington, DC. 1995. Responses from the printing and
publishing NESHAP survey.
6. National Emission Standards for the Printing and Publishing
Industry. Title 40, Code of Federal Regulations, Part 63,
Subpart KK. U.S. Office of the Federal Register. Washington,
DC. May 1996.
7. National Emission Standards for Hazardous Air Pollutants:
Printing and Publishing Industry, Background Information for
Proposed Standards (EPA-453/R-95-002a). U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
February 1995.
8 . Reference 1.
9. Reference 1.
10. Source Category Survey Report for Paper, Film & Foil
Converting Industry (Draft). Radian Corporation, Research
Triangle Park, North Carolina. November 1984. p. 4-26.
11. Reference 1.
12. Reference 7, p. 2-19.
13. Reference 10, p. 4-48.
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14. The Wiley Encyclopedia of Packaging Technology. Marilyn
Bakker, Ed. John Wiley and Sons, Inc., New York, New York,
1996. p. 189.
15. Reference 10, p. 4-63.
16. Control of Volatile Organic Compound Emissions from Existing
Stationary Sources - Volume II: Surface Coating of
Cans,Coils, Paper, Fabrics, Automobiles, and Light-duty
Trucks (EPA-450/2-77-008). U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. 1977.
pp. 5-1, 5-28.
17. Documentation for Developing the Initial Source Category
List (EPA-450/3-91--030). U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. December
1991.
18. Reference 7.
19. Reference 10, p. 4-62.
20. Printing Ink Handbook (fifth edition). National Association
of Printing Ink Manufacturers, Inc., Harrison, New York.
1998. p. 38.
21. Reference 7.
22. Reference 10, p. 4-62.
23. Reference 14, p. 189.
24. Reference 10, p. 4-59.
25. Reference 10, p. 4-64.
25. Reference 10, p. 4-68.
26. Reference 4, p. INK-13.
27. Improved Equipment Cleaning in Coated and Laminated
Substrate Manufacturing Facilities (Phase I) (EPA-600/R-94-
2-57
-------
007). U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina. January 1994. p. 2-33.
28. Reference 10, p. 4-59.
29. Reference 10, p. 4-69.
30. Adapted From a graphic at http://www.
scana.com/sce&g/business_solutions/technology/ezirpca. htm.
Permission granted by Apogee Graphics -
http://www.apogee.net.
31. Reference 27, p. 2-25.
32. Reference 27, pp. 2-25,2-28.
33. Reference 27, p. 2-28.
34. Compilation of Air Pollutant Emission Factors (AP-42).
Volume I (Fifth Edition). U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. January
1995. p. 4.2.2.9-3.
35. Reference 27, p. 2-29.
36. Reference 1.
37. Memorandum from Sutton, L., EC/R, Inc., Durham, North
Carolina to D. Brown, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. December 2,
1998.Minutes of October 13, 1998, meeting with the Pressure
Sensitive Tape Council.
38. Reference 37.
39. Reference 37.
40. Reference 27, p.2-7.
41. Reference 1.
42. Reference 10, p. 4-59.
2-58
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43. EPA Test Method 24-Determination of Volatile Matter
Content, Water Content, Density, Volume Solids, and Weight
Solids of Surface Coatings. U.S. Office of the Federal
Register. Washington, DC. Code of Federal Regulations,
Title 40, Chapter 1, Pt. 60, Appendix A. July 1, 1997. pp.
930-932.
44. Solvent-Based to Waterbased Adhesive-Coated Substrate
Retrofit, Volume II: Process Overview (EPA-600/R-95-Ollb)
U.S. Environmental Protection Agency, Research Triangle
Park, North Carolina. January 1995. p. 5-2.
45. Reference 10, p. 4-67.
46. Reference 44, p. 5-6.
47. Reference 10, p. 4-68.
48. New Source Performance Standards for the Pressure-sensitive
Tape and Label Surface Coating Industry, Background
Information for Proposed Standards (EPA-450/3-80-003a).
U.S. Environmental Protection Agency, Research Triangle
Park, North Carolina. September 1980. p. 3-29.
49. Reference 10, p. 4-68.
50. Reference 48.
51. Docket No. A-99-09. U.S. Environmental Protection Agency,
Washington, DC. February 14, 1997. Response to paper and
other web coating NESHAP survey from 3M Bedford Park,
Bedford Park, Illinois.
52. Reference 48, p. 3-31.
53. Memorandum from Bhatia, K., EC/R, Inc., Durham, North
Carolina, to D. Brown, U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. August 20,
1998. Coating residual HAP data from decorative and
industrial laminates surveys.
54. Reference 34.
2^59
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55. Radiation Curable Coatings (EPA-600/2-91-035; PB91-219550)
U.S. Environmental Protection Agency, Control Technology
Center, Research Triangle Park, North Carolina. 1991.
56. Reference 55.
57. Griese, E.W. UV, BE, and Aqueous Coatings: Technical
Basics. Graphic Arts Technical Foundation, Pittsburgh,
Pennsylvania. GAFF World Magazine. Vol. 10 (3). May/June
1998.
58. Reference 55.
59. Reference 55.
60. Reference 55.
61. Reference 55.
62 . Reference 55.
63 . Reference 55.
64. Kershner, P. UV Flexo in the Label Industry--Equipment
Suppliers' Experiences: Issues in Implementing UV Flexo.
Presented at the WUV Flexo--The New Printing Technology for
Packaging and Labels" meeting, Chicago, Illinois. February
22 and 23, 1995.
65. Memorandum from Sutton, L., EC/R, Inc., Durham, North
Carolina, to D. Brown, U.S. Environmental Protection
Agency, Research Triangle park, North Carolina. December
14, 1998. Paper and Other Web Coating NESHAP: Summary of
toxic release inventory data of 1996 for selected standard
industrial classification codes.
66. Reference 65.
67. Reference 10, p. MAR-68.
68. Reference 10, p. MAR-71.
69. Reference 1.
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70. Reference 1.
71; Letter from Owens, T., MACtac, Stowe, Ohio, to D. Brown,
U.S. Environmental Protection Agency, Research Triangle
Park, North Carolina. July 3, 1996. Overheads used in
meeting of April 23, 1996.
72. Reference 27, p. 2-7.
73. Memorandum from Jones, D., EC/R, Inc., Durham, Norht
Carolina, to D. Brown, U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. March 25,
1999. Paper and other web coating national estimates.
74. Reference 71, p. 4.
75. Reference 44, pp. 3-6 to 3-7.
76. Reference 71, p. 4.
77. Reference 48.
78. Reference 1.
79. Reference 48.
80. Reference 1.
81. Reference 48.
82. Reference 1.
83. Reference 10, p. SUM-12.
84. Reference 10, p. MAR-93.
85. Reference 10, p. MAR-95.
86. Reference 10, p.MAR-117.
87. Reference 73.
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88. Reference 73.
89. Memorandum from Rasor, S., Midwest Research Institute,
Gary, North Carolina, to POWC Project File. Meeting minutes
of June 27, 1996 meeting with Chemical Fabrics and Film
Association (CFFA) July 17, 1996. p. 2.
90. Flexible Vinyl Coating and Printing Operations Background
Information for Proposed Standards (EPA-450/3-81-016a) .
U.S. Environmental Protection Agency, Research Triangle
Park, North Carolina. 1981. pp. 3-1 to 3-31.
91. Reference 90, pp. 3-1 to 3-31.
92. Reference 1.
93. Reference 90, p. 3-5.
94. Reference 10, p. 4-68.
95. Reference 90, Ch. 3.
96. Reference 1.
97. Reference 90, Ch.3
98. Reference 90, Ch. 3.
99. Reference 10, p. MAR-97.
100. Reference 1.
101. Memorandum from Shrager, B., Midwest Research Institute,
Gary, North Carolina, to D. Brown, U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
October 14, 1996. Report of July 16, 1996, site visit to
Eastman Kodak Company, Rochester, New York. p. 6.
102. Reference 1.
103. Memorandum from Jones, D., EC/R, Inc., Durham, North
Carolina, to D. Brown, U.S. Environmental Protection
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Agency, Research Triangle Park, North Carolina. March 25,
1999. Paper and other web coating national estimates.
104. Memorandum from Shrager, B., Midwest Research Institute,
Gary, North Carolina, to D. Brown, U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
October 14, 1996. Report of July 16, 1996, site visit to
Eastman Kodak Company, Rochester, New York.
105. Reference 104, p. 4.
106. Reference 104, p. 5.
107. Reference 104, p. 5.
108. Reference 104, p. 5.
109. Reference 104, p. 5.
110. Reference 104, p. 6.
111. Reference 1.
112. Reference 104, p. 6.
113. Reference 104, p. 4.
114. Reference 1.
115. Memorandum from Sutton, L., EC/R, Inc., Durham, North
Carolina, to D. Brown, U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. July 21,
1997. Report of May 13, 1997, trip to Wilsonart
International Inc., Fletcher, North Carolina.
116. Reference 10, p. SUM-17.
117. Reference 1.
118. Reference 73.
119. Reference 73.
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120. Reference 1.
121. Reference 1.
122. Laminating Materials Association, Inc. Glossary printed out
May 5, 1997, from computer website. Flat panel laminating
equipment.
123. Laminating Materials Association, Inc. Glossary printed out
May 5, 1997, from computer website. Coating equipment.
124. Telecommunication. Dunston, W., U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina
with R. Greenwood, Iten Industries, Ashtabula, Ohio. August
4, 1995.
125. Laminating Materials Association, Inc. Glossary printed out
May 5, 1997, from computer website. Low pressure press.
126. Telecommunication. Button, L., EC/R, Inc., Durham, North
Carolina with G. Carter, Laminating Materials Association.
November 24, 1997.
127. Reference 1.
128. Docket No. A-95-52. U.S. Environmental Protection Agency,
Washington, DC. 1993. Letter to Bruce Jordan, U.S.
Environmental Protection Agency, from Allied Signal
Laminate Systems, Inc. Response to information request for
the reinforced plastics composites NESHAP.
129. Reference 115.
130. Reference 128.
131. Laminating Materials Association, Inc. Glossary printed out
May 5, 1997, from computer website. High pressure
laminates.
132. Reference 128.
133. Telecommunication. Caldwell, M.J., Caldwell Environmental,
Inc., Raleigh, North Carolina, with D. Talbot, GE
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Electromaterials, Coshocton, OH. December 9, 1998. Circuit
board laminate manufacturing process.
134. Reference 128.
135. Reference 7.
136. Reference 73.
137. Telecommunication. Jones, D., EC/R, Inc., Durham, North
Carolina, with K. Fogarty, Norton, Inc., Worcester,
Massachusetts. November 25, 1998. CAMI's interest in the
POWC NESHAP.
138. Reference 137.
139. Reference 137.
140. Reference 137.
141. Reference 73.
142. Telecommunication. Jones, D., EC/R, Inc., Durham, North
Carolina, with S. Young, Coating Abrasives Manufacturing
Industry (CAMI), Cleveland, Ohio. November 17, 1997.
143. Memorandum from Bhatia, K., and D. Jones, EC/R, Inc.,
Durham, North Carolina, to D. Brown, U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
March 15, 1999. Summary of specialty coating operations
derived from American Forest & Paper Association trips.
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3.0 EMISSION CONTROL TECHNIQUES
3.1 INTRODUCTION
Emission control techniques applicable to the paper and
other web coatings (POWC) industry can be categorized as either:
(1) prevention of emissions (pollution prevention measures); or
(2) control of captured emissions by a control device.
Sections 3.2 and 3.3 describe capture systems and control
devices, respectively. Section 3.4 describes pollution
prevention measures.
3.2 CAPTURE SYSTEMS
Capture systems are used in this industry to collect
solvent-laden air containing HAP and direct it to a control
device. Often, facilities combine solvent-laden air captured
from several coating operations, each with its own capture
method, and duct it to a single control device. In heatset
coating processes, solvent is removed from the coated substrate
by evaporation in a dryer. The exhaust from the dryer can be
easily ducted to a control device without additional capture
systems in place. Additional capture systems are often used to
collect fugitive emissions from solvents that evaporate from
other parts of the coating line, such as the coating application
3-1
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and flash-off areas, and exhaust them to a vent or control
device.
The design of the capture system, and the choice of control
devices, can greatly contribute to the overall HAP control
efficiency, which is a combination of both capture and control
efficiencies.
Capture methods in use by the POWC industry are generally
either hoods or enclosures. They include canopy hoods, floor
sweeps, partial enclosure of coating stations, room enclosures,
permanent total enclosure (PTE), and ovens operated at negative
pressure.1-2 Permanent total enclosures (which may include room
enclosures) can achieve 100 percent capture. A HAP capture
efficiency of 100 percent is assumed for systems meeting the
EPA's criteria for PTEs described in EPA test method 204. The
other capture methods are not generally associated with a
specific capture efficiency. An efficient vapor collection
system will maximize the capture of fugitive emissions while
minimizing the capture of dilution air.
In responses to POWC surveys sent to the pressure-sensitive
tape and label (PST), flexible vinyl, photographic film, and
decorative and industrial laminates industry segments, estimates
of HAP capture ranged from zero to 100 percent capture, with the
average HAP capture efficiency per process greater than
90 percent for operations with control devices.3
Capture systems can be improved to collect previously
fugitive solvent in the air surrounding coating lines by
construction of additional hooding and/or coating line
enclosures. In theory, capture can be improved to 100 percent
for any coating line or coating area by retrofitting walls and
3-2
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increasing capture to meet the requirements of a PTE; in
practice, retrofitting some existing facilities may be
prohibitively expensive.* The installation of a PTE on an
existing line, if not designed properly, could increase
evaporative losses from a coating line through increased airflow
and force the need for additional control devices.5
It may be economically advantageous to pretreat air
collected by capture systems with solvent concentrator systems.
Concentrator systems are designed to adsorb solvents from dilute
air streams. The sorbent (activated carbon or zeolite) is
regenerated with hot air. The regeneration air requirement is
only about 10 percent of the air treated. Thus, the dilute
solvent-laden air stream is converted to a concentrated
regeneration air stream, which is exhausted to another control
device. If the exhaust from the concentrator system is ducted to
ar. existing solvent recovery system, then some increase in
capacity of the existing solvent recovery systems may be
required.
A widely used source of information on designing industrial
ventilation systems is the Industrial Ventilation manual
published by the American Conference of Governmental Industrial
Hygienists (ACGIH).6 This manual, revised every few years,
provides guidance on designing hoods to ventilate many general
operations, including open surface tanks (e.g., dip tanks),
painting (e.g., spray booths), and miscellaneous operations such
as a Banbury mixers and calender rolls. The ACGIH manual also
addresses sizing of ducts, selection of fans, and calculation of
exhaust system pressure loss.
3-3
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To determine volatile organic compound (VOC) capture
efficiency (i.e., the ratio of VOCs entering the control device
to the total VOCs emitted by the process) , the EPA has developed
a testing procedure that samples both captured VOC emissions and
fugitive emissions in the gas phase. Captured VOC emissions are
sampled from the process exhaust leading to the control device,
and fugitive emissions samples are taken from the exhaust of an
enclosure surrounding the process.
Three types of enclosures are recommended by the EPA to
isolate VOC sources for capture efficiency testing: temporary
total enclosures; building enclosures; and PTEs. During the last
several years, PTEs have become more popular as a viable, cost-
effective method of demonstrating VOC capture efficiency.7 A
case study involving construction of a PTE at a printing facility
to contain VOC emissions from two existing flexography presses
and a future additional press was presented at the annual meeting
of the Air & Waste Management Association in 1997.8
A common misconception concerning the installation of PTEs
is the assumption that increased air volumes will need to be
handled, and, therefore, the control device will need to be up
sized to handle the increased airflow. While this is true for
some PTE configurations, a well-designed enclosure can be
adequately ventilated using the existing process exhaust air
flow.9-10-11'12'13 By incorporating airflow reduction techniques,
such as cascading the exhaust air from a lower concentration
source to a higher concentration source, lowering the
ceiling/raising the floor, and the use of closed-loop systems,
airflows can be sometimes decreased over those associated with
the process before the installation of the pTE.14-15-16 One company
3-4
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that has retrofitted PTEs at more than 50 plant sites in ten
different industries has found that air flows from the workplace
can be reduced by 25 to 50 percent while simultaneously enhancing
the air quality in the working environment.17
The EPA has published seven test methods for capture
efficiency: Method 204 and Methods 204A through F.18 Following
construction of a temporary or permanent total enclosure, the
enclosure must be tested using EPA Method 204 to verify that it
meets EPA design criteria. If the enclosure meets the test
criteria, no further capture efficiency tests are required
because the VOC capture has been established at 100 percent.
In an EPA technical document entitled, "Guidelines for
Determining Capture Efficiency,n19 details are provided for the
EPA-approved test methods for determining capture efficiency
performance of VOC emission control systems. The guidance also
presents two alternative methods, the data quality objective and
lower confidence limit test methods, which do not require use of
a total enclosure.
3.3 CONTROL DEVICES
Add-on control devices can be of two types: combustion
(destruction) and recovery. Combustion devices (e.g.,
oxidizers/incinerators) are more commonly used, because they are
capable, of high removal efficiencies for almost any type of
organic vapor. Recovery devices include condensers and
adsorbers.20 Design specifications and limitations of these
control devices are provided in an EPA handbook of control
technologies for hazardous air pollutants.21 Without actual
source test data for a specific control system and emission
3-5
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stream, HAP removal efficiency of the control devices can be
assumed to be equal to VOC removal efficiency.22
The most common HAP control devices used in the POWC
industry are thermal oxidizers (also called oxidizers) and, to a
lesser extent, carbon adsorbers. Based on survey responses,
condensers for solvent recovery are also used at some POWC
facilities. These control devices are discussed in more detail
below.
In the POWC survey responses, 387 control devices or
recovery methods were cited; oxidizers (both catalytic and
thermal), carbon adsorbers, and condensers accounted for
92 percent of these devices or recovery methods.
Liquid absorbers and biofilters were found in use by some
facilities in the POWC surveys. Liquid absorbers take advantage
of the solubility of the HAP in a liquid (such as water). In a
liquid absorber, the gas effluent contacts a circulating
absorbing liquid, in usually a counter-current flow direction, as
the liquid passes through a tower packed with variously-shaped
material or divided by flat plates. The tower's internal
configuration is designed to maximize gas contact with the
liquid. Efficiencies of these devices are generally controlled
by the following: concentration of the HAP in the air stream;
solubility of the HAP in the liquid; HAP absorption rate; and
absorber design and operating conditions (e.g., tower height
and/or diameter, number of plates, liquid flow rate)."
Biofilters are control devices made up of microbiological filter
media that use hydrocarbons, such as the HAP, for food and emit
carbon dioxide as waste products.
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Other control devices in use by this industry, such as wet
scrubbers and cyclones, are believed to be primarily used for
control of particulate matter and may not affect HAP emissions.
Table 3-1 presents HAP control efficiency ranges for each of
these control devices, both reported in EPA literature and
reported in POWC survey responses from the POWC industry. Thirty
percent of POWC facilities responding to the POWC survey operate
one or more coating lines without add-on control devices, which
corresponds to 29 percent of the coating lines without add-on
control devices.
Table 3-1. Common Control Devices and Associated
HAP Control Device Efficiency Ranges (Percent)
Control Device
Thermal oxidizer
Catalytic oxidizer
Carbon adsorber
Condenser
HAP Control Device
Efficiency Reported
in EPA Literature
98 - 99+24-25
95 - 9926
95 - 9927
50 - 902B
HAP Control Device
Efficiency Reported
in POWC Survey
Responses
86 - 99.96
25 - 99.5
40 - 99.9
50 - 99.9
The high control efficiencies from the POWC surveys and
literature are not necessarily indicative of the overall
performance of control devices in the POWC industry. The high
efficiencies in the surveys are for short term performance tests
only and do not necessarily reflect longer term evaluations; such
tests are more appropriately used to evaluate whether the control
device has been designed and installed properly. Long term
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performance depends on a number of additional considerations.
Depending on the conditions of operation during performance
tests, e.g., inlet HAP loading to the control device and ambient
temperature, control efficiencies may not represent overall
control device performance. When facilities report short term
efficiency based on testing, the test is often conducted at
maximum operating conditions that result in measurement of the
highest control efficiencies.
Also, the batch nature of the coating process (i.e.,
different products with different coating specifications produced
on the same line throughout the day) would make it difficult to
achieve the high control levels reported in the surveys all the
time. Emission stream characteristics (flow rate, concentration,
temperature) are often not constant in batch processes and
control devices are often designed only for maximum flow rates
and concentrations.29 High control device efficiencies reported
for this industry are usually for short term performance tests
only and do not necessarily reflect longer term evaluations.
Such tests are more appropriately used to evaluate whether the
control device has been designed and installed properly; long
term performance depends on a number of additional
considerations, as discussed above.
Information on the specific test conditions for the control
efficiency data collected through the surveys was not available.
Real-time emission data from a POWC facility does show that
coating process variabilities contribute to the inability of a
facility to show consistently high levels of control.30 For the
reasons described above, the likelihood that the POWC survey
responses included only initial compliance determination data
3-8
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should be considered, and that the data do not necessarily
reflect control levels achievable during all 6f the various
coating operations.
Many factors are known to affect the performance of carbon
adsorption31 and thermal oxidizer32 control devices. These
factors are discussed in more detail below.
3.3.1 Oxidizers
3.3.1.1 Thermal oxidizers. Thermal oxidizers are control
devices in which solvent-laden air is preheated and then passed
to a combustion chamber. In the combustion chamber, volatile
organics in the inlet air stream are ignited and combusted to
carbon dioxide and water. Dilute gas streams require auxiliary
fuel (generally natural gas) to sustain combustion. Also,
because the oxidizer must be in operation at times when HAP
emissions are very low (e.g., when coating operations are on
standby between jobs), supplemental fuel requirements will vary.
The two main types of thermal oxidizers used in this
industry are recuperative and regenerative. The recuperative
oxidizer employs a heat exchanger to preheat the inlet air
stream. Regenerative oxidizers operate in a cyclic mode,
employing ceramics to obtain greater energy recovery.33-34
Figure 3-1 is a schematic diagram of a thermal recuperative
oxidizer.
Thermal oxidizers can be operated at a wide range of control
device efficiencies, with efficiencies ranging from 98 to 99
percent.35-36 In the POWC survey responses, 278 out of the 387
control devices (or 72 percent) were thermal oxidizers, with
destruction efficiencies ranging from 86 to 99.96 percent.
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cc
I
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Design parameters critical to successful combustion are
turbulence, temperature, and residence time. The combustion
chamber must be designed to provide sufficient turbulence to mix
the inlet air with any auxiliary fuel. Air temperature and
residence time in the combustion chamber must be sufficiently
high and long, respectively, to ensure complete combustion.
Test results show that thermal oxidizers can achieve
98 percent destruction efficiency for most VOCs at combustion
chamber temperatures ranging from 700 to 1300°C (1300 to 2370°F)
and residence times of 0.5 to 1.5 seconds.37 In order to achieve
98 percent destruction of nonhalogenated VOC (and organic HAP),
the operating temperature of a thermal oxidizer must be greater
than 870°C (1600°F),38 In this temperature range, a residence
time of more than 0.75 seconds must be used to ensure 98 percent
destruction of nonhalogenated organics.39 The maximum achievable
VOC destruction efficiency decreases with decreasing inlet
concentration because of the much slower combustion reaction
rates at lower inlet VOC concentrations.41
Oxidizers are equipped with controllers for start-up, to
allow the combustion chamber to reach the proper temperature.
These controllers can be designed to prevent operation of the
emission source (e.g., coating operation) until the oxidizer
temperature is adequate to ensure destruction of volatile
organics.
To avoid a fire hazard, the inlet air stream to an oxidizer
is monitored to ensure that its organic concentration is below
the lower explosive limit (LEL). The LEL defines the minimum
concentration of a compound that at ambient conditions can
produce more energy than is needed to raise its temperature to
3-11
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the ignition point.42 The concentration of VOC in the inlet air
stream to an oxidizer is typically limited by insurance companies
to 25 percent of the LEL for a specific VOC.43
3.3.1.2 Catalytic oxidizers. Catalytic oxidizers, like
thermal oxidizers, are control devices in which solvent-laden air
is preheated and then passed to a combustion chamber. In the
combustion chamber, volatile organics in the inlet air stream are
ignited and combusted to carbon dioxide and water. In the
presence of a catalyst, combustion will take place at a lower
temperature than that required for thermal oxidizers.
Temperatures between 350 and 500°C are common. The catalysts,
supported on ceramic or metallic substrates, are metal oxides or
precious metals.
Catalytic oxidizers in use by the POWC industry are of the
fixed-bed type, using either a monolithic or packed-bed catalyst.
The tray type of packed-bed catalytic oxidizer, which uses a
pelletized catalyst, is advantageous where large amounts of
phosphorus or silicone compounds are present.44
Catalytic oxidizers can achieve control device efficiencies
of 95 to 99 percent.45 In the POWC survey responses, 20 out of
the 387 control devices (or 5 percent) were catalytic oxidizers,
with destruction efficiencies ranging from 25 to 99.5 percent.
Compared with a thermal oxidizer, the lower operating
temperature of a catalytic oxidizer can reduce or eliminate the
need for supplemental fuel during normal operation. Also, the
nitrogen oxides formed is reduced at the lower operating
temperature of a catalytic oxidizer.
Chlorinated solvents and some silicone additives in coating
formulations will poison or deactivate certain catalysts.
3-12
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However, catalysts now exist that are tolerant of chlorine,
sulfur, and other compounds.46 The use of chlorinated solvents,
however, has decreased dramatically in recent times so that they
are now seldom used.*7
The exhaust from adhesive drying ovens can potentially
contain nonvolatile organic matter such as particles of adhesive
resins, additives, release compounds, etc. An oxidizer designed
to combust volatile organics may not have sufficient residence
time to destroy the particles. The emission rate of these
particles is usually very low. However, particulate matter can
reduce combustion efficiency by blinding the pores of the
catalyst, inhibiting contact between the catalyst active sites
and the pollutant gases due to a particulate buildup on the
catalyst bed. Also, pressure drop is increased when a
particulate buildup occurs, increasing energy requirements of the
blower.48
3.3.2 Adsorption
Adsorbers in use by this industry use activated carbon as
the adsorptive material in a regenerable fixed bed. In a typical
carbon adsorber, solvent-laden air is passed through a fixed bed
of granular activated carbon. Volatile organics in the entering
air stream are adsorbed onto active sites on the surface area of
the carbon, until at some point the capacity of the carbon is
exhausted, allowing organics to pass'through unadsorbed (called
breakthrough). Adsorber beds are typically operated in parallel
so that when the adsorption capacity of one bed is exhausted, it
can be removed from service and a second adsorber bed can be put
into service. The spent carbon in the first adsorber bed is then
regenerated. A changeover from one adsorber bed to another is
3-13
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automatically initiated either at a preset interval or when an
outlet concentration of VOC exceeds the breakthrough setpoint
according to a gas monitor on the adsorber outlet. Figure 3-2 is
a schematic diagram of a two-bed carbon adsorber.
Carbon adsorption systems can achieve control device
efficiencies between 95 and 99 percent for some organic HAP.49
In the POWC survey responses, 39 out of the 387 control devices
(or 10 percent) were carbon adsorbers, with control device
efficiencies ranging from 40 to 99.9+ percent.
In contrast to combustion, carbon adsorption does not
destroy the HAP it removes from the air stream. Carbon adsorbers
in this industry are thermally regenerated, usually by passing
steam through the carbon beds.50 The HAP is thereby removed from
the carbon (desorbed) and transferred to the steam. The HAP-
containing steam is then condensed, and the solvent separates
from the water. The solvent can then be decanted for sale or
reuse. Regeneration can also be achieved with hot air. Hot-air
regeneration can be quite attractive when dealing with water
soluble solvents.51 Carbon adsorption is most easily adaptable
to coating lines that use a single solvent; if solvent mixtures
are collected by adsorbers, they usually are distilled for
reuse.52
There are two options for disposing of recovered solvent
that cannot be reused. The first is to sell the material back to
the solvent supplier or an independent firm that specializes in
reclaiming contaminated solvents. The other option is to use the
recovered solvent as a fuel in coating ovens or in" boilers.
However, many coating ovens and boilers are gas-fired and would
require burner modifications to burn solvent. Carbon adsorption
3-14
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is generally economically attractive only if the recovered
solvent can be reused directly.53
Carbon adsorbers are most suitable for solvent systems that
are immiscible with water, such as toluene and xylene, but are
not recommended for ketones such as methyl ethyl ketone and
methyl isobutyl ketone.
.The presence of solid particles or polymerizable substances
in the inlet air stream to a carbon adsorber may require
pretreatment of the inlet air. Cooling and dehumidification may
also be required as pretreatment in some cases.55
The concentration of VOC in the inlet air stream to a carbon
adsorber is typically limited by insurance companies to
25 percent of the LEL. If proper controls and monitors are used,
LEL levels of up to 50 percent may be allowed.56
3.3.3 Condensation
Condensation is a control technique in which one or more
volatile components of a solvent-laden air stream are separated
from the remaining vapor through saturation followed by a gas-to-
liquid phase conversion (i.e., condensation). The recovered
organic components can be reused or sold. The more volatile a
compound, the lower the temperature required for condensation, so
refrigeration is often employed to obtain the low temperatures
required for acceptable removal efficiencies.57 Removal
efficiencies obtained by condensers usually range from 50 to
90 percent.58 In the POWC survey responses, 15 out of the 387
control devices (or 4 percent) were condensers, with removal
efficiencies ranging from 50 to 99.9 percent.
The most common types of condensers used are surface and
contact condensers. In surface condensers, the coolant does not
3-16
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contact the gas stream. Most surface condensers in refrigerated
systems are of the shell-and-tube type, where coolant is
circulated through tubes and the volatile organics condense on
the outside of the tubes. Surface condensers allow for direct
recovery of volatile organics from the gas stream.59 Figure 3-3
is a schematic diagram of a shell-and-tube surface condenser.
Contact condensers, unlike surface condensers, cool through
direct contact of the coolant with the gas stream. The contact
condenser coolant is a liquid, at ambient or chilled temperature,
sprayed into the gas stream. In a contact condenser, the
condensed volatile organics are contaminated with coolant, so
they cannot usually be reused directly or recovered without
further processing.61
Based on the survey responses, condensers with solvent
recovery units are used more commonly by manufacturers of
pressure-sensitive tapes and labels than by other industry
sectors. Most if not all condensers used in the pressure-
sensitive tapes and labels industry sector are surface
condensers."
To achieve extremely low outlet organic concentrations,
condensation alone is usually inadequate.63 In the POWC survey
responses, one facility used a condenser in combination with
carbon adsorbers to achieve >99 percent control of HAP.
Condensers can usually be used alone successfully if emission
streams contain high inlet concentrations of volatile organics.
Condenser removal efficiencies greater than 85 percent usually
require volatile organics concentrations of 10,000 ppmv
or greater.64 In the POWC survey responses, there were three
facilities that used condensers alone to achieve greater than
3-17
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Coolant
Inlet
Vapor
Outlet
Vapor
Condensed
VOC
Coolant
Outlet
Figure 3-3. Shell-and-tube surface condenser
60
3-18
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90 percent control efficiency; all three of these facilities were
in the pressure-sensitive tape industry segment. Condensers are
also used with coating lines that use inert ovens. An inert oven
is a coating drying method that uses an inert gas (e.g.,
nitrogen) to replace oxygen in the air space in the oven. Inert
ovens are used with coatings that otherwise would be difficult to
apply without forming air bubbles under the coating surfaces.65
There is no oven vent to the atmosphere in an inert oven.
Instead, a small diameter pipe conducts superconcentrated exhaust
at flow rates of only 100-200 ft3/min to condensation coils.
Solvent concentrations may be 100,000 to 200,000 ppm in an inert
oven's exhaust, which is above the upper explosive limit (UEL)
for most/all solvents. After the solvent condenses out of the
gas in the coils, the cleaned gas is returned to the oven; this
cycle is a closed loop in terms of the oven gas.66
For proper operation, there must be an oxygen-free dead-zone
of air space after the inert oven, where the air flow is balanced
between the air pulled in vs. the air pushed out. This situation
complicates the use of total enclosures around a coating line
with an inert oven. Also, air flow within the oven would need to
be increased to achieve total enclosure. Unfortunately, air flow
as little as 200 ft/min can disturb the web in an inert oven and
*
cause a web, especially one made of paper, to break. Because of
issues such as solvent concentrations above the UEL and static
electricity in film coating, safety is another concern with
totally enclosing the air space around inert ovens.67
3.4 PREVENTIVE MEASURES
3.4.1 Product Substitution/Reformulation
3-19
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Many facilities in the POWC industry have adopted air
pollution control strategies that have included substitution of
lower-solvent coatings for higher-solvent coatings, or a
conversion from solventborne coatings to waterborne coatings.
For some products, substitute coatings have not been developed to
meet performance requirements, therefore, substitution or
reformulation of coatings is not presently an option. Also, it
may be the case that a single coating line could be used with a
low-solvent coating for one product, but may need to use a
higher-solvent coating for another product because an alternative
coating is not available for this end use.
In the POWC surveys, the use of low-HAP coatings, such as
waterborne, ultraviolet cured, hot-melt, and reactive resins were
reported in use by many facilities. In the flexible vinyl and
film industry segment, 74 percent (40 out of 58) of the
facilities cited the use of low-HAP coatings. In the pressure-
sensitive tape industry segment, low HAP coatings were used in 54
percent (49 out of 91) of the facilities. In the decorative and
industrial laminates sector, 12 percent (5 out of 41) of the
facilities cited the use of low-HAP coatings.
One problem with lower-solvent coatings is that, although
there are nonzero HAP emissions from these coatings, the
concentration of HAP in the coating oven/area exhaust is too low
to be efficiently controlled in a normally-sized add-on control
device. Also, since the exhaust contains a relatively high water
content along with a low HAP concentration, there is too little
heat value for combustion of the exhaust. Consequently, HAP
standards developed for the industry will provide alternatives to
a percentage emission reduction; otherwise, a facility might be
3-20
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prevented from switching from a solventborne coating to a
waterborne coating when the substitution is possible.
3.4.2 Work Practice Procedures
Work practice procedures are physical actions intended
directly to affect emission reductions.' Because work practice
procedures are specifically tailored to an industry, they may
vary from a few manual operations to a complex program.
For situations where an emission standard for control of a
HAP is not feasible, then design standards, equipment standards,
operational standards, and/or work practice standards can be
promulgated instead of an emission standard. As described in
section 112(h) of the CAA, situations where an emission standard
is not feasible are when a HAP cannot be directed through a
capture device (or when use of the capture device would be
inconsistent with Federal, State, or local law) or when the
application of measurement methodology to a class of sources is
not practicable due to technological and economic limitations.
For the POWC industry, work practice procedures may be
appropriate for some activities, such as the following: solvents
in maintenance operations; solvent handling and transfer;
spraying operations and booths; drying and squeegee operations;
and open vessels. Examples of such work practice standards are
provided in Table 3-2.
3-21
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Table 3-2. Examples of Work Practice Standards
Activity
Example Work Practice Standard
Solvents use in
cleaning
--Used cleaning solvents must be put into
an enclosed container.
--During atomized cleaning of a spray
gun, the cleaning solvent must be
directed into a waste container fitted
with a capture device.
Solvent handling and
transfer
--Handling and transfer of solvents must
be conducted in such a manner to reduce
spills. Spills must be wiped up
immediately and the wipe rags stored in
covered containers.
Open vessels
--Waste solvent will be stored in closed
containers that may have an opening for
pressure relief but do not allow for
liquid to drain.
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3.5 REFERENCES
1. Docket No. A-99-09. U.S.'Environmental Protection Agency,
Washington, DC. 1999. Responses from the paper and other web
coating NESHAP survey.
2. Pressure Sensitive Tape and Label Surface Coating Industry--
Background Information for Proposed Standards (EPA-450/3-80-
003a). U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina. September 1980. pp. 3-14 to
3-15.
3 . Reference 1.
4. National Emission Standards for Hazardous Air Pollutants:
Printing and Publishing Industry--Background Information for
Proposed Standards (EPA-453/R-95-002a). U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
February 1995. p. 3-2.
5. Memorandum from Sutton, L., E.C./R, Inc., Durham, North
Carolina to D. Brown, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. February 9, 1998.
Minutes of January 28, 1998, meeting with tie Pressure
Sensitive Tape Council.
6. Industrial Ventilation: A Manual of Recommended Practice.
18th ed. American Conference of Governmental Industrial
Hygienists, Cincinnati, Ohio. 1984.
7. VOC Capture Efficiency Testing Using Permanent Total
Enclosures. The Air Pollution Consultant: November/December
1997. Elsevier Science, Inc. pp. 1.13 through 1.17.
8. D. Bemi, et al. Demonstrating VOC Capture Efficiency Using
Permanent Total Enclosure Technology: Common Practices,
Challenges and Rewards. Proceedings of the Air & Waste
. Management Association's 9-Oth Annual Meeting and Exhibition,
Toronto, Canada. June 1997.
9. Bemi, D. "Demonstrating VOC Capture Efficiency using
Permanent Total Enclosure Technology: Common Practices,
Challenges and Rewards."Paper No. 97-TA4B.04. Presented at
3-23
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Air and Waste Management Association 1997 Annual Meeting,
Toronto, Ontario, Canada. June 8-13, 1997. pg. 7.
10. Lukey, M. "Permanent Total Enclosures needed in Response to
Subpart KK and Changes in Test Procedures." Paper No. 97-
TA4B.05. Presented at Air and Waste Management Association
1997 Annual Meeting, Toronto, Ontario, Canada. June 8-13,
1997. pg. 3.
11. Lukey, M. "Five Design Options for Permanent Total
Enclosures." Paper No. VIP-69. Presented at Air and Waste
Management Association Specialty Conference "Emerging
Solutions to VOC and Air Toxics Control," San Diego,
California. February 26-28, 1997. pg. 281.
12. Turner, T. "Local capture or Total Enclosure? The Answer is
Yes!" Paper No. 94-RA111.01. Presented at Air and Waste
Management Association 1994 Annual Meeting, Cincinnati,
Ohio. June 19-24, 1994. pg. 7.
13. Oiestad, A. "Fugitive VOC Capture Systems Using the *Total
Permanent Enclosure Concept'." Paper No. 93-TA-33.0.
Presented at Air and Waste Management Association 1993
Annual Meeting, Denver, Colorado. June 13-18, 1993. pg. 2.
14. Reference 12, pg. 6.
15. Reference 10, pg. 3.
16. Reference 13, pg. 2.
17. Reference 13, pg. 2.
18. Appendix M, Test Methods 204, 204A-204F: Preparation,
Adoption, and Submittal of State Implementation Plans, Final
Rule. Federal Register. 40 CFR Part 51, Volume 62, Number
115. June 16, 1997. pp. 32500-32536.
19. Guidelines for Determining Capture Efficiency. U.S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards, Emission Monitoring and Analysis
Division, Research Triangle Park, North Carolina. January
9, 1995.
3-24
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20. Handbook: Control Technologies for Hazardous Air Pollutants
(EPA-625/6-91-014). U.S. Environmental Protection Agency,
Cincinnati, Ohio. June 1991. p. 3-1.
21. Reference 20.
22. Reference 20, p. 3-3.
23. Reference 20, p. 4-44.
24. Guideline Series: Control of Volatile Organic Compound
Emissions from Reactor Processes and Distillation Operations
Processes in the Synthetic Organic Chemical Manufacturing
Industry (EPA-450/4-91-031). U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. August
1993. p. 3-12.
25. Reference 20, p. 3-3.
26. Reference 20, p. 4-11.
27. Reference 20, p. 3-4.
28. Reference 20, p. 3-3.
29. Control of Volatile Organic Compound Emissions from Batch
Processes - Alternative Control Techniques Information
Document (EPA/R-94-020). U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. February
1994.
30. Memorandum from Bhatia, K. and D. Jones, E.C./R, Inc.,
Durham, North Carolina, to D. Brown, U.S. EPA, Research
Triangle Park, North Carolina. September 30, 1998. Summary
of Continuous Emission Monitoring Study for the EPA's
Coatings and Consumer Products Group.
31. Carbon Adsorption for Control of VOC emissions: Theory and
Full Scale System Performance (EPA-450/3-88-012). U.S.
Environmental Protection Agency, Research Triangle Park,
North Carolina. June 1988.
3-25
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32. Memorandum (and attachments) from Farmer, J. R., U.S.
Environmental Protection Agency, Research Triangle Park,
North Carolina, to distribution. August 22, 1980. Thermal
incinerator and flare removal efficiency.
33. Reference 20, p. 4-2.
34. OAQPS Control Cost Manual, 4th ed. (EPA-450/3-90-006). U.S.
Environmental Protection Agency, Research Triangle Park,
North Carolina. January 1990. p. 3-7.
35. Reference 24, p. 3-12.
36. Reference 20, p. 3-3.
37. Reference 24, p. 3-12.
38. Reference 29, p. 4-31.
39. Reference 34, p. 3-8.
40. Reference 34, pp. 3-5 to 3-6.
41. Reference 20, p. 3-3.
42. Reference 34, p. 3-16.
43. Reference 20, p. 4-11.
44. Reference 2, p. 4-14.
45. Reference 24, p. 3-12
46. Reference 34, p. 3-14.
47. Reference 2, p. 4-22.
48. Reference 2, pp. 4-22, 4-23.
49. Reference 20, p. 3-4.
50. Reference 2, pp. 4-3, 4-6.
3-26
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51. Reference 2, p. 4-6.
52. Compilation of Air Pollutant Emission Factors (AP-42),
Volume I (Fifth Edition). U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. January
1995. p. 4.2.2.6-3.
53. Reference 2, p. 4-8.
54. Reference 2, p. 4-4.
55. Handbook: Control Technologies for Hazardous Air Pollutants
(EPA-625/6-91-014). U.S. Environmental Protection Agency,
Cincinnati, Ohio. June 1991. pp. 3-4 to 3-5.
56. Reference 20, p. 3-5.
57. Reference 34, p. 8-3.
58. Reference 20, p. 3-5.
59. Reference 34, p. 8-5.
60. Reference 34, p. 8-5.
61. Telecommunication. Sutton, L., E.C./R, Inc., Durham, North
Carolina, with T. Godonis, American Biltrite, Inc.,
Moorestown, New Jersey. March 19, 1998. Question regarding
condensers.
62. Reference 20, p. 3-5.
63. Reference 20, p. 3-5.
64. Reference 34, p. 8-7.
65. Memorandum from Sutton, L., E.C./R, Inc., Durham, North
Carolina to D. Brown, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. December 2, 1998.
Minutes of October 13, 1998, meeting with the Pressure
Sensitive Tape Council.
66. Reference 65.
67. Reference 65.
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[This page intentionally left blank.]
3-28
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4.0 MODEL PLANTS, CONTROL OPTIONS, AND ENHANCED MONITORING
4.1 INTRODUCTION
This chapter describes model plants, control options, and
enhanced monitoring options for the paper and other web coating
(POWC) industry. Model plants were developed to evaluate the
effects of the control options on major sources in the POWC
source category. Control options were selected based on the
application of currently available control devices and levels of
capture consistent with the levels of overall achievable control.
Enhanced monitoring options are specified to ensure the
consistent performance of control devices.
4.2 MODEL PLANTS
Model plants have been specified to represent the range of
capacity and overall control efficiency (OCE) at major sources in
the POWC industry, as determined primarily by responses to EPA
surveys of four POWC industry segments: pressure sensitive tapes
and labels; flexible vinyl; photographic film; and decorative and
industrial laminates industries. According to one estimate,
based on a comparison of POWC survey efforts and Toxic Release
Inventory (TRI) data, these four industry segments represent
4-1
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approximately 80 percent of the major sources and HAP emissions
of the TRI facilities in the nonprinting portion of the POWC
industry.1
In the POWC survey responses, it was found that HAP OCE was
a function of control device operation and capture efficiency.
The overall level of control was distributed in the surveyed
facilities from zero to more than 95 percent, with approximately
20 percent of the facilities reporting zero control, 50 percent
reporting between zero and 90 percent, and the remaining
30 percent reporting more than 90 percent control.
It was also found in the POWC survey responses that HAP
usage varied widely among facilities. Six facilities reported
zero HAP usage. On the average in the surveyed facilities, more
than 80 percent of the HAP emitted was from the coating lines and
associated processes. The other sources of HAP emissions include
mixing, cleaning, and storage. These sources are mostly
uncontrolled, with the unenclosed processes not as amenable to
capture and control as enclosed processes. Little data were
available on the control of these sources. Consequently, HAP
usage for sources of HAP other than coating lines was not
addressed in the model plants.
Model plants were developed from the 89 identifiable major
sources in the POWC survey responses. While these model plants
represent the sources that will be regulated, they are not
necessarily representative of all plants in the entire industry,
since major sources are only the highest emitters of HAP
emissions by the industry.
The two parameters used to develop the model plants were the
coating line HAP OCE and the coating line HAP emissions after
4-2
-------
control. These parameters were chosen because they were the
plant parameters that best differentiated the plants into groups,
and because they are the most important parameters in cost and
impact analyses.
Five separate coating line OCE groups corresponding to 0,
50, 80, 90, and 95 percent OCE are represented by the POWC model
plants. Within each OCE group, the controlled coating line HAP
emissions were examined and subcategories were created where the
HAP emissions within each OCE group covered too wide a range to
be represented by a simple average. For model plants with OCE's
of 0, 50, and 80 percent OCE (Model Plant groups 1, 2, and 3),
two subcategories were created for this purpose. In each case,
the "a" group had controlled HAP emissions less than 200 tons per
year (tpy) and the wb" group had HAP emissions greater than 200
tpy. It was also the case that the na" groups had fewer coating
lines than the wb" groups, with the "a" groups having five or
fewer coating lines. For Model Plant group 1, a third nc"
category was created to represent the facilities that are likely
using compliant coatings; facilities in this group had coating
HAP emissions less than or equal to 0.2 pounds (Ib) HAP emitted
per Ib of coating solids applied. Specifications for the POWC
model plants are given in Table 4-1.
4.3 CONTROL OPTIONS
Table 4-2 presents the three control options for the POWC
industry that include ranges in capture system and add-on control
performance, and the use of low-HAP coatings. For add-on
controls, any combination of capture and control device
efficiency that produces an OCE of 95 percent is equivalent to
4-3
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Table 4-2. Control Options for the POWC Industry
Control
Option
I
2
3
Overall Facility Coating Line Average
HAP Capture
Efficiency,
percent
95-100
95-99
NA
HAP Collection/
Destruction
Efficiency,
percent
95-100
95-100
NA
Type of Control
ihermal oxidizer,
carbon adsorber/
solvent recovery
Inert oven/
condensation
Low-HAP coatings
U0.2 Ib HAP per
Ib coating
solids)
Dverall HAP
Control
Efficiency
, percent
95
95
NA
Note: NA = Not applicable.
the control option. For low-HAP coatings, the control option is
a level of 0.2 pounds (Ib) of HAP emitted per Ib of coating
solids applied.
The add-on control systems of demonstrated control
effectiveness in the POWC industry are composed of a HAP capture
system achieved by permanent total enclosures (PTEs) and a HAP
destruction or recovery system achieved by thermal or catalytic
oxidizers, or carbon adsorbers, condensers, and other solvent
recovery systems. These devices are discussed in Chapter 3.
Improved capture involves containment of previously
uncollected HAP emissions. Capture technologies include canopy
hoods, floor sweeps, partial enclosure of coating stations, room
enclosures, and PTEs (which may include room enclosures).
4-5
-------
Control options involving air handling can be specified as
varying degrees of air collection, up to and including
construction of (or conversion of existing coating operation
rooms to PTEs), with many gradations existing between current
capture systems and PTEs. The specifications of ventilation,
hooding, and ducting for incremental improvements to existing
systems are site-specific.
Substitution of coatings with lower HAP content may be an
important pollution prevention control technique at some
facilities. A reduction in HAP emissions through substitution of
nonHAP solvents for some HAP solvents in the coatings can achieve
the same reduction in HAP emissions as that of the add-on control
techniques. Facilities that operate efficient HAP add-on control
systems, however, may have little incentive to reduce the HAP
content of their coatings.
Reducing the HAP content of coatings also may not be
appropriate for all facilities or product types. From the
available information, it appears that the cost and effects on
output quality resulting from substitution of nonHAP solvents for
HAP solvents are product-specific, with notable success in some
areas and notable lack of success in others.2 Existing control
devices (which are usually designed and operated for volatile
organic compounds (VOC) control) may not be compatible with low-
HAP formulations, because of the potential for low HAP/VOC inlet
concentrations.
While substitution of nonHAP solvents for HAP should be
encouraged as a pollution prevention option, it may affect VOC
emissions if VOC solvents are substituted for HAP solvents. Some
plants have adopted waterborne or radiation-cured coating
4-6
-------
technologies to reduce VOC emissions. Some of these formulations
are totally HAP-free, although many low-VOC waterborne coating
systems do contain small percentages of HAP (typically glycols,
glycol ethers, or alcohols), with or without a small amount of
nonHAP VOC as well. Usually, low-VOC, low-HAP coating
formulations are used with no control devices.
Control strategies for the POWC industry are influenced by
the composition of coatings and other materials applied on the
coating line and by regulatory requirements. Often, regulations
presently in effect limit emissions of VOC. Existing control
devices are, for the most part, currently specified and operated
to meet VOC emission requirements. However, most of the organic
HAP are VOC and, therefore, the control efficiency for HAP is
expected to be the same as for VOC.3
New control devices can be selected based on the coating
system in use or, if more than one type of device is potentially
suitable, based on cost or requirements of other regulations, if
also applicable. Usually, if capture efficiency is maximized at
100 percent with PTEs, greater flexibility of control device
operation can be realized to meet the needs of daily operations.
As noted in Chapter 3, all control devices currently in use
in the POWC industry can achieve efficiencies of at least
95 percent. Although higher efficiencies are achievable,
consistent high inlet concentrations of HAP are needed;
therefore, reaching high efficiencies at lower inlet HAP
concentrations may be difficult and not possible all of the time
because of the batch nature of the POWC processes (i.e.,
different products with different coating specifications produced
on the same line throughout the day). Emission stream
4-7
-------
characteristics (flow rate, concentration, temperature) are often
not constant in batch processes and control devices are often
designed only for maximum flow rates and concentrations.4 High
control device efficiencies reported for this industry are
usually for short term performance tests only and do not
necessarily reflect longer term evaluations. Such tests are more
appropriately used to evaluate whether the control device has
been designed and installed properly. Long term performance
depends on a number of additional considerations, as discussed
above.
The one exception to achieving 100 percent capture is where
the particular product or substrate requires the use of a
nitrogen-blanketed inert drying oven. These devices allow for
coating operations within a low air flow/high solvent vapor zone
without risk of an explosion with high nitrogen and low oxygen
levels within the oven. For proper operation and safety, there
must be an oxygen-free dead-zone air space after the inert oven.5
This precludes the use of a PTE, where air is continuously
exhausted throughout the coating area.
4.4 ENHANCED MONITORING
Facilities in the POWC industry that operate thermal
incinerators or catalytic incinerators usually continuously
monitor control device operating parameters, since variations in
combustion temperature affect, and are directly related to,
performance of the control devices. In this situation, the
operators of thermal and catalytic incinerators install,
calibrate, operate, and maintain the temperature monitoring
devices following manufacturers' specifications. The temperature
of the control device is maintained at a level equal to or higher
4-8
-------
than the temperature at which compliance was demonstrated.
Continuous emission monitoring systems (CEMS) may not be reliable
for the coating industry, where the HAP in the emission streams
may comprise only a small percentage of the VOC present. Also,
the output of CEMS may not accurately reflect the HAP
concentration of the emission stream due to differences in
responses among the HAP, nonHAP VOC, and products of incomplete
combustion, and the presence of reactive and/or condensable
emissions. How to integrate CEMS software with existing facility
software and provide reports are other challenges in the use of
CEMS for any facility in the coating industry, where starts,
stops, and process variations occur regularly in job shops that
coat many and different product types. Accommodations in
reporting requirements are also needed for the inevitable
problems at coating facilities, such as: automatic shutdowns;
back pressure and valve venting; and outages due to regular on-
line maintenance, such as carbon replacement.6
Facilities in the POWC coating industry that operate solvent
recovery systems monitor control system performance using liquid-
liquid mass balances. These mass balances provide recovery data
averaged over the reporting period. Because the HAP emissions
are recovered rather than destroyed, a mass balance at any point
in time within the reporting period will reflect any intermittent
system failures or fluctuations in control device efficiency.
Since the efficiency of the solvent recovery system during the
reporting period is not based on the average of discrete
measurements of efficiency, any individually measured control
efficiency during the reporting period may not agree with the
overall efficiency calculated at the end of the reporting period.
4-9
-------
Facilities in the POWC industry that control HAP emissions
with low-HAP coating formulations need to maintain documentation
confirming the HAP content of the materials applied. If
specifications provided by coating suppliers are inadequate to
establish the HAP content, additional compositional analyses need
to be conducted by the facility.
4-10
-------
4.5 REFERENCES
1. Memorandum from Sutton, L., EC/R, Inc., Durham, North
Carolina, to Brown, D., U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. December 14,
1998. Paper and other web coating NESHAP: Summary of toxic
release inventory data of 1996 for selected standard
industrial classification codes.
2. Memorandum from Koman, T., U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina to
Stakeholders and Meeting Attendees. July 10, 1998. Minutes
from June 4, 1998 stakeholder meeting.
3. Handbook: Control Technologies for Hazardous Air Pollutants
(EPA-625/6-91--014). U.S. Environmental Protection Agency,
Cincinnati, Ohio. June 1991. p. 3-3.
4. Control of Volatile Organic Compound Emissions from Batch
Processes - Alternative Control Techniques Information
Document (EPA/R-94-020). U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. February
1994.
5. Memorandum from Sutton, L., EC/R, Inc., Durham, North
Carolina, to Brown, D., U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. December 2,
1998. Meeting of October 13, 1998, with the Pressure
Sensitive Tape Council.
6. Memorandum from Bhatia, K. And D. Jones, EC/R, Inc., Durham,
North Carolina, to T. Koman, U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina (draft).
September 30, 1998. Summary of continuous emission
monitoring study for the EPA's Coatings and Consumer
Products Group.
4-11
-------
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4-12
-------
5.0 ENVIRONMENTAL AND ENERGY IMPACTS OF CONTROL OPTIONS
5.1 INTRODUCTION
The impact analyses in this chapter are based on the
application of Control Option 1 to the model plants developed to
represent the paper and other web coating (POWC) major sources.
As discussed in Chapter 4, Control Option 1 corresponds to an
overall control efficiency (OCE) of 95 percent. Thermal
oxidation was selected as the control device used to estimate the
worst-case environmental and energy impacts, since oxidation
would generate the greatest secondary emissions. Also discussed
in this chapter are qualitative assessments of the impacts of
using the other two control options discussed in Chapter 4, which
involve the use of inert ovens with solvent recovery (Control
Option 2) and the use of coatings with low levels of hazardous
air pollutants (HAP) as in Control Option 3. The use of solvent
recovery via carbon adsorption instead of thermal oxidizers in
Control Option 1 is also discussed.
Table 5-1 shows the nine POWC model plants and the estimated
number of facilities nationwide represented by each model plant
category.1 Note that although Model Plant Ic corresponds to an
OCE of 0 percent, the model plant group corresponds to facilities
5-1
-------
using low-HAP coatings with less than or equal to 0.2 pounds
(Ib)HAP per Ib of solids emitted or applied. Accordingly, no
energy and emissions impacts for Model Plant Ic are expected.
Similarly, since Model Plant 5 has an OCE of 95 percent that is
equal to Option 1, no energy and
Table 5-1. POWC Model Plants and Their Estimated
Correspondence to the National POWC Industry
Model
Plant
la
Ib
lca
2a
2b
3a
3b
4
5
Total
Coating
Line
OCE,
percent
0
0
0
50
50
80
80
90
95
HAP
Capture
Efficiency,
percent
0
0
0
55
53
89
84
95
97
HAP
Destruction
Efficiency,
percent
0
0
0
90
95
90
95
95
98
Number
of Major
Sources
in POWC
Database
18
3
9
22
1
10
1
21
4
89
Percent
of
Database
Major
Sources,
percent
20
3
10
25
1
11
1
24
5
100
Estimated
Number of
U.S.
Facili-
ties
41
7
21
50
2
23
2
48
9
203
a Model Plant Ic consists of facilities using low-HAP coatings that meet
the criteria of s 0.2 Ib HAP per Ib solids (Option 3).
emissions impacts were estimated for this model plant group as
well.
5.2 ENERGY IMPACTS
5-2
-------
The energy requirements for implementation of Option 1 for
the POWC industry include electricity to collect and process
ventilation air and natural gas for thermal oxidizer fuel. The
energy impact estimates are based on the installation of new
capture systems for all model plants except Model Plants Ic and
5, new thermal oxidizers for Model Plants la and lb, and improved
destruction efficiency of existing oxidizers for Model Plants 2a
and 3a. Table 5-2 shows the energy impacts for the POWC model
plants in terms of incremental increases in power consumption
(fan electricity) in kilowatt-hours per year (kW-hr/yr) and
natural gas in standard cubic feet per year (scf/yr).
Table 5-2. Energy Impacts of Control Option 1
for the POWC Model Plants
Model
Plant
la
lb
Ic
2a
2b
3a
3b
4
5
Energy Impacts of Control
Option 1
Fan Power,
10s kW-hr/yr
2.2
7.5
0
1.1
16.4
1.1
2.2
1.1
0
Natural Gas,
10s scf/yr
43.5
92.5
0
17.8
0
16.7
0
0
0
Note: This analysis assumes the use of thermal
oxidizers for Control Option 1.
5-3
-------
Average electricity and gas consumption factors were
calculated for the model plants from the energy impacts. For
Model Plants 2b, 3b, 4, and 5, that have oxidizers with
destruction efficiencies of 95 percent or above, the average
amount of electricity consumed for improved capture systems is
4.8 kW-hr/yr per Ib of incrementally controlled HAP. For Model
Plants la, Ib, 2a, and 3a, the average amounts of electricity and
natural gas consumed for new capture and control systems are
5.6 kW-hr/yr and 100 scf/yr per Ib of incrementally controlled
HAP, respectively.
Table 5-3 shows the estimated national energy impacts of the
application of control option 1 to the POWC industry. This
estimate was developed by scaling up the model plant energy
impacts to the estimated 203 POWC major sources in the U.S.
Scale-up factors were developed from the proportion of major
sources in the POWC database represented by each model plant
group (see Table 5-1) applied to the estimated total number of
POWC major sources in the U.S.
Table 5-3. Total Estimated Energy Impacts of
Control Option 1 for the
National POWC Industry
Energy Impacts
Fan Power,
10s kW-hr/yr
Natural Gas,
109 scf/yr
Total U.S.
Impact for
Control Option 1
313
3.7
Note: This analysis assumes the use of thermal oxidizers for
Control Option 1.
5-4
-------
The use of Option 1 with carbon adsorption is expected to
entail lower incremental energy consumption. According to an EPA
study, electricity consumption for a regenerable, fixed bed
carbon adsorber was estimated to be between 14 and 30 percent of
the electricity demand for a regenerative thermal incinerator,
for equivalent process stream compositions and flowrates.2 No
natural gas use is expected for carbon adsorption, assuming that
steam for desorption (carbon regeneration) is available on-site.
Moreover, carbon adsorption as part of a solvent recovery system
may provide solvent for reuse in the manufacturing process. At
minimum, solvent recovery is expected to yield fuel that can be
burned on-site, resulting in energy savings.
Option 2 is expected to have incremental electricity
consumption similar to Option 1 with carbon adsorption. Also,
Option 2 would correspond to lower incremental natural gas
consumption, since oxidizers would not be operated. The source
reduction benefit of recovered solvent and energy savings of
usable fuel are expected with this control option as well.
Conversion to low-HAP coatings (Option 3), usually, would
represent a decrease in the total energy requirement associated
with HAP control, since the energy associated with stream capture
and control would not be needed. However, special cases in which
the full energy savings may not be realized include: (1) tandem
coating operations, in which water-based coatings and solvent-
based coatings are applied on the same coating line to the same
products; (2) reformulation involving the substitution of HAP
components with volatile organic compounds (VOC) that are not
HAP; and, (3) water-based coatings for film coating. The first
5-5
-------
case may involve higher natural gas consumption by add-on
controls on the coating line because of a lower exhaust inlet
temperature due to drying high-moisture coatings. Higher
electricity consumption may also be associated with greater dryer
airflow to dry high-moisture coatings.3 In the second case, the
facility may not be able to discontinue the use of add-on
controls because of State regulations for VOC control and
emissions. In the third case, corona treaters may be needed to
be operated to treat surfaces of films so that they accept water-
based formulations.
5.3 AIR IMPACTS
The primary air impact of implementing the control options
is reduced emissions of HAP to the atmosphere. Based on POWC
survey responses,4 similar reductions are expected for VOC.
Emissions of other pollutants are generated with Option 1 due to
the burning of fuel and the production of electricity required
for fan power. Secondary emissions were estimated for the
following pollutants: nitrogen oxides (NOX) , sulfur
dioxide (S02) , carbon monoxide (CO), carbon dioxide (CO2) , and
particulate matter (PM). Complete combustion of hydrocarbons
generates CO2/ water, and PM; incomplete combustion generates, in
addition, CO and SO2. All types of combustion in air generate
NOX, with more generated during incomplete combustion.
Table 5-4 shows the emissions impacts of Option 1 with
thermal oxidation, in terms of incremental HAP reduced and
secondary pollutant emissions for each of the POWC model plants.
Secondary emissions from natural gas combustion in thermal
oxidizers were calculated using the following emission factors:
100 Ib NOX per million scf of natural gas, 0.6 Ib SO2 per
5-6
-------
million scf, 84 Ib CO per million scf, 120,000 Ib C02 per million
scf, and 7.6 Ib PM per million scf.5 Secondary emissions from
electric power production were calculated using the following
emission factors: 1.9 Ib NOX per thousand kW-hr, 4.25 Ib SO2 per
thousand kW-hr, 702 Ib C02 per thousand kW-hr,6 0.078 Ib CO per
thousand kW-hr, and 0.081 Ib PM per thousand kW-hr.7 Electricity
production was assumed to be entirely from coal combustion to
correspond to a worst-case estimate; electricity production via
"cleaner" methods (i.e., hydroelectric or nuclear power) would
result in lower pollutant emissions.
Table 5-5 shows the estimated national emissions impacts of
the application of Option 1 with thermal oxidation. This
estimate was developed by scaling up the model plant energy
impacts to the 203 estimated major sources in the U.S. Scale-up
factors were developed from the proportion of major sources in
the POWC database represented by each model plant group (see
Table 5-1) applied to the estimated total number of POWC major
sources in the U.S.
Selection of other control options could result in
equivalent HAP/VOC reductions. However, other control options
would generate different incremental changes in secondary
pollutant emissions. The use of Option 1 with carbon adsorption
is expected to correspond to lower incremental secondary
emissions from electricity production, since carbon adsorption
has lower electricity consumption as compared with thermal
oxidation, as previously discussed. Option 2 is expected to
correspond to similar incremental secondary pollutant emissions
from electricity production as with carbon adsorption. Secondary
5-7
-------
Table 5-4. Air Impacts of Control Option 1
for the POWC Model Plants
Model
Plant
la
Ib
1C
2a
2b
3a
3b
4
5
Air Impacts of Control Option 1, tons per year
HAP/VOC
Reduced
94
1,677
0
124
1,135
137
1,034
50
0
NO,
Emitted
4.3
11.8
0
2.0
15.6
1.8
2,1
1.0
0
SO,
Emitted
4.7
16.1
0
2.4
34.8
2.2
4.6
2.3
0
CO
Emitted
1.9
4.2
0
0.8
0.6
0.7
0.1
0.04
0
CO,
Emitted
3,382
8,194
0
1,459
5,739
1,370
755
386
0
PM
Emitted
0.3
0.7
0
0.1
0.7
0.1
0.1
0.04
0
Note: This analysis assumes the use of thermal oxidizers for
Control Option 1.
Table 5-5. Total Estimated Air Impacts of Control Option 1
for the National POWC Industry
Air Impact
HAP/VOC Reduced
NOX Emitted
S02 Emitted
CO Emitted
C02 Emitted
PM Emitted
Total
U.S. Impacts
of Control Option 1,
tons per year
31,673
484
666
168
331,986
27
Note: This analysis assumes the use of thermal oxidizers for
Control Option 1.
5-8
-------
emissions from natural gas use are not expected, since oxidizers
would not be operated.
Conversion to low-HAP coatings (Option 3) is a pollution
prevention measure, with capture and control systems generally
not needed. However, in the previously discussed exception where
low-HAP coatings and solvent-based coatings are applied on the
same coating line to the same products, more secondary emissions
due to natural gas combustion may be generated due to a lower
exhaust inlet temperature from the drying of high-moisture
coatings.8 Also, when HAP chemicals are replaced with VOC
chemicals in coating formulations, add-on controls may not be
discontinued because of State regulations for VOC control and
emissions. Little change in the amount of secondary emissions
from existing control systems are then expected.
5.4 WATER IMPACTS
Water impacts resulting from the implementation of the
control options at POWC plants are expected to be small. No
significant amount of liquid waste is generated from the use of
thermal oxidizers.9 Incremental increases in wastewater may
result from the following: (1) plants that use steam for carbon
bed desorption in new or improved solvent recovery systems; and,
(2) plants that reformulate to water-based coatings. In the
latter case, there may be some increase in wastewater generated,
since cleaning operations are more likely to involve water.
5.5 SOLID WASTE IMPACTS
Solid waste impacts resulting from the implementation of the
control options at POWC plants are not expected to be
significant. No solid or hazardous wastes are generated from the
5-9
-------
use of thermal oxidizers.10 Cases that could involve incremental
increases in solid waste include: (1) plants that use new or
improved catalytic oxidizers and, (2) plants that upgrade carbon
adsorbers for existing or new solvent recovery systems. In the
first case, spent catalysts may require disposal as hazardous
waste. However, due to the cost of the catalyst, it is expected
that the incinerator would be operated in a way that maximizes
the catalyst life (expected to be more than 10 years). In the
second case, although most of the spent carbon could be sold for
reprocessing, the remainder would become solid waste.
5-10
-------
5.6 REFERENCES
1. Memorandum from Jones, D., EC/R, Inc., Durham, North
Carolina, to D. Brown, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. March 25, 1999.
Paper and other web coating national estimates.
2. Survey of Control Technologies for Low Concentration Organic
Vapor Gas Streams (EPA-456/R-95-003). U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
May, 1995. Tables B-5 to B-8, B-13 to B-16.
3. Memorandum from Bhatia, K. And Jones, D., EC/R Inc.,Durham',
North Carolina, to D. Brown, U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. March
15,1999. Summary of specialty coating operations derived
from AF&PA trips.
4. Docket No. A-99-09. U.S. Environmental Protection Agency,
Washington, DC. 1999. Response to paper and other web
coating NESHAP survey.
5. Compilation of Air Pollutant Emission Factors (AP-42).
Volume I (5th edition). U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina. March,
1998. pp. 1.4-5 to 1.4-6.
6. Data from EPA's Acid Rain program ()
7. Data from EPA's National Pollutant Emission Trends Update,
1970-1997 on EPA's TTN CHIEF site ()
8. Reference 3.
9. Stationary Source Control Techniques Document for Fine
Particulate Matter (EPA-452/R-97-001). U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
October, 1998. pp. 5.5-19.
10. Reference 9.
5-11
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5-12
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6.0 MODEL PLANT CONTROL OPTION COSTS
6.1 INTRODUCTION
This chapter presents the estimated costs of applying
Control Option 1 with the use of thermal oxidizers to the paper
and other web coating (POWC) model plants. This control option
involves the use of permanent total enclosures (PTEs) and thermal
oxidizers to achieve an 95 percent HAP overall control efficiency
(OCE). The model plants and the criteria used to choose them
were described in Chapter 4. Control options applicable to the
POWC industry were also described in Chapter 4. Costs are
presented for both existing and new facilities.
Control Option 1 with thermal oxidizers was chosen because
this option was expected to be the worst-case for costs and
impacts. All other control options, therefore, are expected to
have lower costs (and less energy impacts).
Sometimes, catalytic incineration may be more appropriate
for the solvents in use at POWC facilities. Catalytic
incineration systems would have lower operating costs and may
have total annualized costs less than the estimates for thermal
oxidation systems. Concentrator systems may be used to reduce
6-1
-------
the size and, therefore, the capital and operating costs of the
catalytic oxidizer.
Similarly, solvent recovery may be more appropriate as a
control method. As discussed in Chapter 5, the electricity
consumption is expected to be lower for a solvent recovery system
than for a thermal oxidizer.1 In addition, the associated
natural gas use is expected to be no more than that required for
the thermal oxidizer, and the recovered solvent would have some
additional fuel value. Thus, overall costs for a solvent
recovery system are expected to be lower.
Alternatively, some facilities may choose to switch to low
HAP coatings. Switching to low HAP coatings could, sometimes,
represent a net savings over baseline levels of control. The
applicability of this option depends largely on the type of
coating and the performance requirements of the product. Where
feasible, conversion to low HAP coatings could result in
substantial reductions in operating costs, compared with the use
of add-on controls. Note that low HAP coatings may still require
operation of a control device to meet volatile organic compound
(VOC) emissions standards established by other regulations if VOC
has been substituted for the HAP eliminated.
New source costs were based on upgrading to the new source
MACT level of control (98 percent OCE) a facility with an
emission control configuration that would be expected in the
absence of any new regulation. This emission control
configuration was assumed to be a PTE and a thermal oxidizer
operating at 95 percent destruction efficiency. The upgraded
facility was based on the same control configuration, but the
thermal oxidizer destruction efficiency was increased to 98
6-2
-------
percent. Model plant 4 was chosen as the best representation of
this facility for costing purposes.
6.2 CAPTURE AND CONTROL APPROACH
The POWC model plants are presented in Table 6-1. The
capture and control approaches to implementing Control Option 1
for the model plants are summarized in Table 6-2.
As shown in Table 6-1, Model Plants la and Ib do not have
any capture or control devices. To implement Control Option 1,
it was assumed that a PTE would be installed to increase the
capture efficiency to 100 percent, and a new thermal oxidizer
(T.O.) with a destruction efficiency of 95 percent would be
added, to produce an overall control efficiency of 95 percent.
Model plant Ic uses compliant coatings equal to an OCE of 95
percent and, thus, no additional control was needed to meet the
requirements of Control Option 1.
Model Plants 2a and 3a have less than 100 percent capture
and destruction efficiencies of 90 percent. The approach to
implement Control Option 1 for these model plants included
installing a permanent total enclosure, and increasing the
destruction efficiency of the existing thermal oxidizers from 90
to 95 percent.
Three of the remaining model plants (2b, 3b, and 4) have
destruction efficiencies equal to 95 percent and capture
efficiencies less than 100 percent. Therefore, it was assumed
that a PTE would be installed at these facilities to implement
Control Option 1, increasing the capture efficiency to
100 percent and the corresponding OCE to 95 percent. Since Model
Plant 5 has an OCE of 95 percent, no increase in capture or
destruction efficiency was needed to implement Control Option 1.
6-3
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solely with safety in mind could result in several operational
and economic deficiencies.5-6
The regulatory issues consist primarily of meeting the five
criteria established for PTEs in Method 204 as mentioned above.
Operational considerations include material selection and
process/operator needs. Common PTE materials of construction are
plastic over frame, frame and drywall, sheet metal, prefabricated
panels, plywood, and cinder block. Important process/operator
needs include optimum product flow, operator access, maintenance
accessibility, and expansion capability.7-8 .
Safety and health considerations have a significant impact
on all the other areas of PTE design consideration. Room
ventilation and air changes must be considered for their effect
on health and safety. There is no specific ventilation or air
change requirements established by the EPA for PTE design. The
Occupational Safety and Health Administration (OSHA) does
recommend four air changes per hour in dusty environments, but
does not address gaseous environments. Some industry experts
recommend between four and twelve air changes for gaseous
environments, depending on the application.9 One recognized PTE
expert who has been involved with more than 100 PTE
installations, believes PTEs with less than four room air changes
per hour are uncomfortable for workers and may result in product
quality problems for facilities; further, all PTEs should be
designed for at least ten room air changes per hour, whenever
possible.9 The airflow characteristics of the PTE are important
to insure that a steady flow of fresh air is supplied around or
past operator work stations. Odors and explosion potential are
6-7
-------
additional health and safety concerns that must be considered in
the design of a PTE.10
There are also economic considerations involved in designing
a PTE. The costs associated with PTE installations vary with the
scope of the project. The construction cost of a PTE is
dependent upon how much cutting is needed to place walls or
ceilings, the type of doors used, the amount of duct work that
has to be modified to meet the Method 204 criteria, how much air
conditioning is needed (if any), and the degree to which
modifications to the make up air system are required.11 One
consulting firm with experience in more than 100 PTE
installations reports that total PTE installation costs can range
from $8,000 to $200,000, depending on the size and scope of the
work involved.12'13 Costs for a PTE can be higher where
substantial air-conditioning changes are required, or cuts are
needed for conduits, ducts, pipes, electrical switchgear, etc.14-15
A common misconception concerning the installation of PTEs
is the assumption that increased air volumes will need to be
handled, and, therefore, the control device will need to be
bigger to handle the increased airflow. While this is true for
some PTE configurations, a well-designed enclosure can be
adequately ventilated using the existing process exhaust air
flow.16-17'18-19'20 By incorporating airflow reduction techniques,
such as cascading the exhaust air from a lower concentration
source to a higher concentration source, lowering the
ceiling/raising the floor, and the use of closed-loop systems,
air flows can be sometimes decreased over those associated with
the process before the installation of the pTE.21-22-23 One company
that has retrofitted PTEs at more than 50 plant sites in ten
6-8
-------
different industries has found that air flows from the workplace
can be reduced by 25 to 50 percent while simultaneously enhancing
the air quality in the working environment.24
Another popular misconception concerning PTE use is that the
operator's environment is necessarily compromised due to the
concentration of contaminants in the reduced work area. In a
well-designed PTE with appropriate room air changes, well-
designed ventilation pattern, and sometimes, addition of a
closed-loop air-conditioning system, the air quality within the
enclosure is often far better than pre-PTE conditions.25>26'27'28
There are five basic designs for the PTEs built over the
last ten years. These include: (1) large room/building PTE using
existing walls; (2) PTE for one or more sources using newly
constructed walls; (3) PTE around the wet end of equipment
(manned); (4) PTE attached to or made part of the equipment
(unmanned); and (5) PTE within a PTE (for use of compliant and
noncompliant materials),29 One firm with extensive PTE
installation experience has found that most facility
owners/operators initially desire that the entire room be the
enclosure with little modification and little disruption to their
existing operations. Worker comfort and lower explosive limit
evaluations lead to other decisions on PTE designs.30 This
costing analysis assumes that the PTE would consist of either the
entire coating room or completely cover each of the coating
lines.
6.3.2 PTEs for the Model Plants
The costs of the PTEs for the model plants were based on
case study information from the literature,31 adjusted to reflect
the estimated relative size of the coating rooms and anticipated
6-9
-------
difficulty of installation (number of cuts needed, etc.).32
Since the PTEs must be custom-designed for each facility, it was
not clear if these engineering/design costs were fully accounted
for in the case study costs. Therefore, an additional
engineering cost, equal to 10 percent of the cost of the PTE, was
assumed for the model plants. Further, it was assumed that spot
air conditioning (AC) would be installed along with the PTE, with
the cost of the AC estimated based on the exhaust flowrates for
each model plant.33 The total model plant capital costs of the
PTE-related components varied from $110,000 to $1.7 million. The
capital costs associated with the design and installation of a
PTE for the POWC model plants are presented in Table 6-3.34
The annual PTE costs are presented for each of the model
plants in Table 6-4. These costs include the capital recovery
costs associated with the capital investment, plus the
electricity required to operate the spot air conditioning. The
annual model plant costs of the PTEs range from approximately
$37,000 to $873,000.35
6.3.3 New Thermal Oxidizers
For Model Plants la and Ib, which have no capture or control
systems, costs for new thermal oxidizers were estimated, along
with the costs associated with the installation and operation of
PTEs. Because of the relatively high air flows associated with
these two model plants, it was assumed to be reasonable that
regenerative thermal oxidizers would be chosen. The costs
associated with the new regenerative thermal oxidizers were
estimated using costing spreadsheets developed by the EPA.36
The capital costs associated with installation of new
thermal oxidizers and associated PTEs at model plants la and Ib
6-10
-------
are presented in Table 6-5. The capital costs are those
associated with (1) the new regenerative thermal oxidizer, and
(2) the PTE. The capital costs for Model Plants la and Ib were
estimated at approximately $2.5 million and $6.8 million,
respectively.
The annual costs associated with installation of new thermal
oxidizers and associated PTEs at model plants la and Ib are also
presented in Table 6-5. Besides capital recovery costs, these
annual costs also include annual costs for labor and maintenance
materials; natural gas for the thermal oxidizer; electricity for
the thermal oxidizer and the PTE air conditioning; annual
monitoring, reporting, and recordkeeping costs; and overhead and
other miscellaneous costs. The annualized costs of new thermal
oxidizers and associated PTEs for Model Plants la and Ib were
approximately $725,000 and $1.9 million, respectively.
6.3.4 Increasing Destruction Efficiency of Existing Thermal
Oxidizers
To meet the requirements of Control Option 1 with Model
Plants 2a and 3a, the destruction efficiencies of the existing
thermal oxidizers were increased from 90 to 95 percent and a PTE
was used to increase the capture efficiency to 100 percent. The
capital costs of this capture and control approach are presented
for Model Plants 2a and 3a in Table 6-6. The capital costs
associated with any capital improvements to the existing thermal
oxidizers that may be needed were estimated as 10 percent of the
cost of a new regenerative thermal oxidizer. The capital costs
of PTE and monitoring, reporting, and recordkeeping requirements
were calculated as described for the other model plants, above.
6-11
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c T.O. = thermal oxidizer, PTE = permanent total enclosure,
MR&R = monitoring, recording, and recordkeeping
Assumptions:
1) Permanent total enclosure (PTE) costs estimated based on case studies
and engineering judgement .53>54i5S
2) PTE costs assume engineering = 10 percent PTE cost; spot air
conditioning, 10-year life, 7 percent interest rate.5*-57'5*-59
3) Because regenerative thermal oxidizers are field built, it was assumed
that ductwork costs are included in the Total Capital Investment
estimate. SO'S1
4) Assumes 95 percent heat recovery, 20 inch pressure drop, 6,600 operating
hours per year."
5) Operator labor rate = $37.61/hr, maintenance labor rate = l.l*operator
rate =$41.37/hr. Both based on escalated Bureau of Labor Statistics
data for 1998."
6) Electricity cost $0.0451/kWh, natural gas cost $3.099/mscf, both based
on information from Energy Information Administration for 1998. "
-------
MR&R = monitoring, reporting, and recordkeeping
Assumptions:
1) Overall control efficiencies of existing oxidizers were increased to 95
percent by a) adding a PTE, b) increasing combustion temperature, and c)
making any necessary capital improvements to the existing oxidizers to
allow increased destruction efficiency to be achieved.
2) Cost of capital recovery calculated based on a 10-year equipment life
and 7 percent interest rate (according to OMB guidance) .6S'S7-8B
3) Increased fuel and electricity costs for thermal oxidizer were
calculated (using the EPA regenerative thermal oxidizer spreadsheet) as
the difference in fuel and electricity costs for an oxidizer of the
appropriate size operating at combustion temperatures of 1300°F and
1600°F.S9
4) Operator labor rate = $37.61/hr, maintenance labor rate = l.l*operator
rate =$41.37/hr. Both based on escalated Bureau of Labor Statistics
data for 1998.70
5) Electricity cost $0.0451/kWh, natural gas cost $3.099/mscf, both based
on information from Energy Information Administration for 1998.71<72
reporting, and recordkeeping, were approximately $531,000 and
$473,000 for Model Plants 2a and 3a, respectively.
The annual costs of increasing the destruction efficiency of
the existing thermal oxidizers at Model Plants 2a and 3a,
including those associated with the PTE and monitoring,
reporting, and recordkeeping, are also presented in Table 6-6.
The increased natural gas and electricity usage associated with
increasing the destruction efficiency from 90 to 95 percent was
calculated (using the EPA costing spreadsheets) as the difference
in fuel and electricity use for an appropriately-sized
regenerative thermal oxidizer operating at 1300°F and 1600°F.73
The costs of capital recovery were added to these increased fuel
6-16
-------
and electricity costs to estimate the annualized costs for Model
Plants 2a and 3a as approximately $186,800 and $173,000,
respectively. The capital costs of increasing the destruction
efficiency from 90 to 95 percent, including the associated PTE
and monitoring,
6.3.5 Monitoring. Reporting, and Recordkeeping
There will be monitoring, reporting, and recordkeeping
requirements for all affected POWC facilities, and therefore, for
all of the model plants. In addition, the model plants with
capture and control devices will require parameter monitoring
devices for the capture and control systems, such as pressure
and/or temperature monitors. Because such monitoring devices are
typically included in the cost of the control device, no
additional capital costs were included here.
The annual monitoring, reporting, and recordkeeping costs
for each of the model plants are presented in Table 6-7. The
model plant total annual monitoring, reporting, and recordkeeping
costs were $14,322 for all model plants except for Ic. This
model plant was the only one using all compliant coatings,
resulting in an increased MR&R burden. The total annual MR&R
costs for Model Plant Ic were $17,231. These costs reflect the
requirements specified in the proposed regulation and for which
detailed labor hour and cost estimates were developed in the
Standard Form 83-1 Supporting Statement.74
6.4 TOTAL COSTS AND COST EFFECTIVENESS - EXISTING SOURCES
The total capital investment (capital cost) for each capture
and control approach for the nine model plants with Control
Option 1 is summarized in Table 6-8. Depending on the capture
and control approach taken, these capital costs include the costs
6-17
-------
of new thermal oxidizers or improvements to existing thermal
oxidizers, and PTEs. Because Model Plant Ic uses all compliant
coatings and Model Plant 5 is already achieving 95 percent OCE
through the use of controls, there were no capital costs for
Table 6-7. Capital and Annual Operating Costs Associated with
Monitoring, Recording, and Recordkeeping (MR&R) Requirements
for the POWC Model Plants
Model Plant
la
Ib
Ic
2a
2b
3a
3b
4
5
MR&R Annual Operating
Cost
$14,322
$14,322
$17,231
$14,322
$14,322
$14,322
$14,322
$14,322
$14,322
Assumptions:
1) All costs 1998 dollars.
2) Annual operating costs are detailed in the Standard Form 83-1 Supporting
Statement.7S
these model plants. The total capital costs for the remaining
model plants ranged from approximately $147,000 to $6.8 million.
The total annual costs of the capture and control approach
to Control Option 1 for the nine model plants are presented in
Table 6-9. These total annual costs include capital recovery
costs and operating costs such as labor, fuel, and electricity,
as well as MR&R costs. The total annual costs for the model
plants ranged, from approximately $12,000 to $1.9 million.
6-18
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oxidizer to increase its destruction efficiency to 98 percent.
The costing methodology presented in Section 6.3 was used for the
annual costs of operating the PTE. The improvements in the
operation of the thermal oxidizer were assumed to require 10
percent of the capital cost of a new thermal oxidizer. The
estimated annual cost for the operation of the thermal oxidizer
was based on the increased cost of operation at 1800°F versus
1600°F. Total annual costs also include MR&R costs.77
The new source annual and capital costs were estimated to be
approximately $5.2 million and $12 million, respectively. These
costs are summarized in Table 6-11.
Table 6-11. Annual and Capital Costs of Achieving New Source
MACT Floor Level of Control
POWC Costs
Annual Costs Associated with. . .
Operation of Permanent Total
Enclosure (PTE)
Monitoring, Reporting, and
Recordkeeping (MR&R) Requirements
Capital Improvements and
Operation of New Thermal
Oxidizers (TO)a
Total Annual Cost of Complying
with 98 Percent OCE
Capital Costs Associated with. . .
Purchase of Permanent Total
Enclosure (PTE)
Capital Improvements to New
Thermal Oxidizers (TO) Operating
at 1800 degrees F
Facility
Costs
$61,437
$11,827
$89,725
$162,989
$0
$376,753
Number of
New
Facilities
32
32
32
32
32
32
Total
Annual Cost
$1,965,984
$378,464
$2,871,200
$5,215,648
$0
$12,056,096
6-23
-------
POWC Costs
Equipment for Monitoring,
Reporting, and Recordkeeping
(MR&R) Requirements of POWC Rule
Total Capital Investment for
Complying with 98 Percent OCE
Facility
Costs
$0
$376,753
Number of
New
Facilities
32
32
Total
Annual Cost
$0
$12,056,096
a Annual Costs of Capital Improvements and Operation of New Thermal Oxidizers
include: 10 percent of the capital costs of purchasing a new TO operating at
1800 degrees F plus the increase in electricity and natural gas costs from
1600 to 1800 degrees F.
6-24
-------
6.6 REFERENCES
1. U.S. Environmental Protection Agency. Survey of Control
Technologies for Low Concentration Organic Vapor Gas Streams
(EPA-456/R-95-003). May 199S. Tables B-5 to B-8, B-13 to B-
16.
2. Lukey, M. "Permanent Total Enclosures needed in Response to
Subpart KK and Changes in Test Procedures." Paper No. 97 -
TA4B.05. Presented at Air and Waste Management Association
1997 Annual Meeting, Toronto, Ontario, Canada. June 8-13,
1997. p. 4.
3. Bemi, D. "Demonstrating VOC Capture Efficiency using
Permanent Total Enclosure Technology: Common Practices,
Challenges and Rewards."Paper No. 97-TA4B.04. Presented at
Air and Waste Management Association 1997 Annual Meeting,
Toronto, Ontario, Canada. June 8-13, 1997. p. 2.
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77. Memorandum from Hendricks, D., and Lee-Greco, J., EC/R
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6-30
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO.
EPA^53/R-00-002
2.
4. TITLE AND SUBTITLE
National Emission Standards for Hazardous Air Pollutants for
Source Categories: Paper and Other Web Coating Operations -
Background Information for Proposed Standards
7. AUTHOR®
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Standards Division (Mail Drop 13)
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
April 2000
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D6-0010
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document contains a summary of the EPA's current level of knowledge on hazardous air pollutants and
their emission points at paper and other web coatings production facilities. This document presents
descriptions of representative processes and operations, hazardous air pollutant emission sources and
estimated emissions, and applicable air emission control technologies. The capital and annual costs of air
emission controls are also presented in this document.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Hazardous air pollutants
Paper and Other Web Coatings Operations
18. DISTRIBUTION STATEMENT
Release unlimited
b. IDENTIFIERS/OPEN ENDED TERMS
Air pollution control
19. SECURITY CLASS (Report)
Unclassified
20. SECURITY CLASS (Page)
Unclassified
c. COSATI
Field/Group
21. NO. OF PAGES
22. PRICE
6-31
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