United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-00-006
September 2000
Air
SEPA National Emission Standards for
Hazardous Air Pollutants (NESHAP) for
Source Category: Large Appliances
Surface Coating Operations - Background
Information for Proposed Standards
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EPA-453/R-00-006
National Emission Standards for
Hazardous Air Pollutants (NESHAP) for
Source Category: Large Appliances
Surface Coating Operations - Background
Information for Proposed Standards
Emission Standards Division
U.S. Environmental Protection Agency
Office of Air And Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 2000 RnT Pr°tectlon A«enc>
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DISCLAIMER
This report has been reviewed by the Emission Standards Division of the Office of Air Quality
Planning and Standards, EPA, and approved for publication. Mention of trade names or
commercial products is not intended to constitute endorsement or recommendation for use.
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ENVIRONMENTAL PROTECTION AGENCY
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
FOR SOURCE CATEGORY: LARGE APPLIANCES SURFACE COATING OPERATIONS -
BACKGROUND INFORMATION FOR PROPOSED STANDARDS
1. The standards regulate organic hazardous air pollutant (HAP) emissions from the surface
coating of large appliances. Only those large appliances surface coating operations that
are part of major sources under section 112(d) of the Clean Air Act (Act) will be
regulated.
2. For additional information contact:
Dr. Mohamed Serageldin, PH.D.
Coatings and Consumer Products Group
U.S. Environmental Protection Agency (MD-13)
Research Triangle Park, NC 27711
Telephone: (919) 541-2379
E-MAIL: SERAGELDIN.MOHAMED@EPAMAIL.EPA.GOV
3. Paper copies of this document may be obtained from:
U.S. Environmental Protection Agency Library (MD-36)
Research Triangle Park, NC 27711
Telephone: (919) 541-2777
National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Telephone: (703) 487-4650
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4. Electronic copies of this document may be obtained from the EPA Technology Transfer
Network (TTN) over the internet by going to the following address:
http://www.epa.gov/ttn/uatw/coat/lgapp/ (Select large_app.html)
5. Electronic copies of this document may be obtained from the EPA TTN electronic
bulletin board system which is free, except for the normal long distance charges. To
access the Background Information Document:
• Set software communication setting to 8 bits, no parity, and 1 stop bit
Set a terminal emulation of either VT100, VT102, or ANSI
Baud rates of 1200, 2400, 9600, 14,400 are accepted
• Use access number (919) 541-5742; access problems should be directed to the
system operator at (919) 541-5384
• Register online by providing a personal name and password
• Specify TTN Bulletin Board: Clean Air Act Amendments
• Select menu item: Recently Signed Rules
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TABLE OF CONTENTS
age
1.0 INTRODUCTION 1-1
1.1 Purpose of This Document 1-1
1.2 Regulatory Authority 1-1
1.3 Data Gathering Efforts 1-2
1.4 References 1-11
2.0 THE LARGE APPLIANCES SURFACE COATING OPERATIONS SOURCE
CATEGORY 2-1
2.1 Source Category Description 2-1
2.2 Large Appliances Surface Coating Methods 2-4
2.3 Facility Operations and Current Industry Practices 2-12
2.4 Emissions 2-14
2.5 References 2-19
3.0 EMISSION REDUCTIONS FROM COATING APPLICATIONS 3-1
3.1 Air Pollution Control Techniques 3-1
3.2 Pollution Prevention (Source Reduction) 3-3
3.3 Equipment Changes 3-3
3.4 Design and Operational Changes 3-3
3.5 Work Practices 3-4
3.6 References 3-6
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TABLE OF CONTENTS (Concluded)
Page
4.0 MODEL PLANTS AND COMPLIANCE OPTIONS 4-1
5.0 REGULATORY APPROACH 5-1
5.1 Background 5-1
5.2 MACT Floor Approach 5-1
5.3 Existing Sources 5-4
5.4 New Sources 5-7
5.5 Beyond the Floor , . 5-8
5.6 References 5-15
6.0 ENVIRONMENTAL, HEALTH, AND ENERGY IMPACTS 6-1
6.1 Approach to Estimating Impacts 6-1
6.2 Estimated HAP Emission Reductions 6-1
6.3 Non-Air Quality Health and Environmental Impacts , 6-2
6.4 Energy Requirements 6-3
7.0 COST IMPACTS 7-1
7.1 Approach to Estimating Costs .7-1
7.2 Estimated Cost Impacts 7-6
7.3 References . 7-8
8.0 ECONOMIC IMPACTS AND SBREFA 8-1
APPENDIX A A-l
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LIST OF TABLES
Table Title Page
1-1 Product Description, SIC Codes, and Corresponding NAICS Codes 1-3
1-2 Number of Large Appliances Surface Coating Operations by SIC Code
Found in TRIS and AIRS 1-4
1-3 Facilities For Which Air Permit Data Have Been Collected 1-4
1-4 Site Visit Facilities 1-10
2-1 Examples of Large Appliances 2-2
2-2 Large Appliances Surface Coating Operations Location Distribution by State . 2-3
2-3 Large Appliances Surface Coating Operations Employee Distribution 2-4
2-4 HAP Emissions From Potential Major Source Facilities 2-16
4-1 Coating Application Methods Versus SIC Category 4-2
4-2 Coating Type Versus SIC Category 4-2
4-3 Model Plant Number 1 (Up to 10,000 Liters of Coating Solids) 4-6
4-4 Model Plant Number 2 (10,001 to 50,000 Liters of Coating Solids) 4-7
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LIST OF TABLES (continued)
Table Title
4-5 Model Plant Number 3 (50,001 to 200,000 Liters of Coating Solids) 4-8
4-6 Model Plant Number 4 (Greater Than 200,000 Liters of Coating Solids) 4-9
4-7 Data for Model Plant Number 1 4-10
4-8 Data for Model Plant Number 2 4-11
4-9 Data for Model Plant Number 3 4-12
4-10 Data for Model Plant Number 4 4-13
5-1 Surface Coating Emission Data Used in Developing the MACT Floors 5-11
5-2 Default Densities Used for Unit Conversions 5-14
6-1 Summary of Estimated Environmental Impacts 6-3
6-2 Facilities Switching to Powder Coatings 6-4
7-1 Model Plant Number 1 Cost Impacts
(Up to 10,000 Liters of Coating Solids) 7-9
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LIST OF TABLES (concluded)
Table Title Page
7-2 Model Plant Number 2 Cost Impacts
(10,001 to 50,000 Liters of Coating Solids) 7-10
7-3 Model Plant Number 3 Cost Impacts
(50,001 to 200,000 Liters of Coating Solids) 7-11
7-4 Model Plant Number 4 Cost Impacts
(Greater Than 200,000 Liters of Coating Solids) 7-12
7-5 Summary of Cost Impacts for Existing Sources 7-13
7-6 Summary of Estimated Monitoring, Recordkeeping, and Reporting Costs -
Years 1-5 7-14
7-7 Total Estimated Cost of Proposed Standards - Years 1-5 7-15
A-l Large Appliance Potential Major and Synthetic Minor Facilities A-2
A-2 Summary of Regulations by State A-6
LIST OF FIGURES
Figure Title Page
1-1 Liquid Coating UOS 1-7
1-2 Unit Operations Included in Affected Source 1-8
5-1 HAP Emission Rate (Normalized Emissions) Versus SIC Code 5-6
10
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1.0 INTRODUCTION
1.1 PURPOSE OF THIS DOCUMENT
The Background Information Document (BID) provides background information on, and
rationale for, decisions by the Environmental Protection Agency (EPA) related to the proposed
standards for the reduction of hazardous air pollutants (HAP) emitted from large appliances
surface coating operations. The BID supplements the preamble for the proposed standards.
This document is separated into seven chapters providing a combination of background
information and EPA rationale for decisions made in the standards development process.
Chapters 2, 3, and 4 provide background information including: an industry description in
Chapter 2, a description of the control techniques used by the industry in Chapter 3, and the
model plants developed for this industry in Chapter 4. Chapter 5 provides the determination of
the Maximum Achievable Control Technology (MACT) "floors", and an evaluation of control
beyond the MACT Floor. Chapters 6 and 7 present the predicted HAP emission reductions and
cost impacts associated with the proposed standards. Appendix A provides a listing of major and
synthetic minor facilities thought to be subject to the standards. Appendix A also contains
factors for converting Metric units to English units. Supporting information and more detailed
descriptions for technical and rationale chapters are provided in the items referenced in this
document and located in the project docket.
1.2 REGULATORY AUTHORITY
Section 112 of the Clean Air Act (CAA), as amended in 1990 (1990 Amendments)
provides the EPA with the authority to establish national standards to reduce air emissions from
sources that emit one or more of 188 hazardous air pollutants. Section 112(b) of the Clean Air
Act contains a list of HAP to be regulated by National Emission Standards for Hazardous Air
Pollutants (NESHAP), and Section 112 (c) directs the EPA to use this pollutant list to develop
and publish a list of source categories for which NESHAP will be developed. The EPA must list
all known source categories and subcategories of "major sources" that emit one or more of the
listed HAP. A major source is defined in Section 112 (a) as any stationary source or group of
1-1
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stationary sources located within a contiguous area and under common control that emits, or has
the potential to emit considering controls, in the aggregate, 10 tons (9.07 Mg) per year of any one
HAP or 25 tons (22.7 Mg) per year of any combination of HAP. The list of source categories
was first published in the Federal Register on July 16, 1992 (57 FR 31576). This published list
of source categories included the large appliances surface coating operations source category.
1.3 DATA GATHERING EFFORTS
Data were collected from the following sources in the development of a database of
information for the large appliances surface coating operations source category: (1) the Toxic
Release Inventory System (TRIS), (2) the Aerometric Information Retrieval System (AIRS), (3)
State and local agencies, (4) Federal and State rules and guidance documents, and (5) site visits.
Most of the information gathered from these sources was used to develop an extensive mailing
list of large appliance manufacturers and detailed questionnaires to be submitted to the industry
under the authority of Section 114.
In order to begin the task of characterizing the industry and to provide a basis from which
data could be requested from States, a list of product descriptions was developed. The Standard
Industrial Classification (SIC) codes and corresponding North American Industry Classification
System (NAICS) codes relevant to the large appliances surfaces coating operations industry were
also used to identify these products. This information is presented in Table 1-1.
1.3.1 Data Obtained from States
State and local air pollution control agencies provided information (i.e., permits or
emissions inventory data) pertinent to the large appliances source category. A query of the States
with the most large appliances surface coating operations was generated through the use of the
TRIS and AIRS databases. Using the SIC/NAICS codes listed in Table 1-1, the number of
facilities in each of the product categories was found. The results from the TRIS and AIRS
searches are presented in Table 1-2.
In addition to the questionnaire and site visit data, the EPA has collected some air quality
permit data. The permits provided information useful to this rule development on coating usage,
coating HAP content, facility configuration, production technologies, implemented emission
1-2
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reduction techniques, and add-on emission controls. The facilities for which permit data have
been collected are listed in Table 1-3.
TABLE 1-1 PRODUCT DESCRIPTION, SIC CODES AND
CORRESPONDING NAICS CODES
SIC Product Description
Household Cooking Equipment
Household Refrigerators and Home
and Farm Freezers
Household Laundry Equipment
Household Appliances; not
elsewhere classified
- Other Household Appliance
- Floor Waxing and Floor Polishing
Machines
Air Conditioning and Warm Air
Heating Equipment and
Commercial Industrial
Refrigeration Equipment
- Except Motor Vehicle Air
Conditioning
- Motor Vehicle Air Conditioning
Service Industry Machinery; not
elsewhere classified
SIC
Code
3631
3632
3633
3639
3585
3589
Corresponding NAICS Product
Description
Household Cooking Appliance
Manufacturing
Household Refrigerator and Home
Freezer Manufacturing
Household Laundry Equipment
Manufacturing
Corresponding
NAICS Code
335221
335222
335224
Other Major Household Appliance
Manufacturing
Household Vacuum Cleaners
Manufacturing (pt)
Air Conditioning and Warm Air
Heating Equipment and Commercial
and Industrial Refrigeration
Equipment Manufacturing
Motor Vehicle Air Conditioning
Manufacturer
Other Commercial and Service
Industry Machinery Manufacturing
(pt)
335228
335212
333415
336391
333319
NOTE: (pt) indicates that the NAICS code includes additional SIC codes or product codes
beyond corresponding SIC codes shown in the table.
1-3
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TABLE 1-2. NUMBER OF LARGE APPLIANCES SURFACE COATING OPERATIONS
BY SIC CODE FOUND IN TRIS AND AIRS DATABASES
Product Category
Air-Conditioning and Warm Air Heating Equipment and
Commercial and Industrial Refrigeration Equipment
Service Industry Machinery, Not Elsewhere Classified
Household Cooking Equipment
Household Refrigerators and Home and Farm Freezers
Household Laundry Equipment
Household Appliances, Not Elsewhere Classified
SIC Code
3585
3589
3631
3632
3633
3639
Number of Facilities
38
3
5
6
6
6
TABLE 1-3. FACILITIES FOR WHICH AIR PERMIT DATA HAVE BEEN COLLECTED
Facility
Maytag, Herrin, Illinois
Frigidaire, Kinston, North Carolina
A.O. Smith Water Products, McBee, South
Carolina
Maytag, Galesburg, Illinois
Products Manufactured
Washers & Dryers
Dishwashers
Water Heaters
Refrigerators
SIC Code
3633
3639
3639
3632
1.3.2 Federal and State Rules and Guidance Documents
A Control Techniques Guideline (CTG) for the large appliances surface coating industry,
Control of Volatile Organic Emissions from Existing Stationary Sources Volume V: Surface
Coating of Large Appliances (EPA-450/2-77-034), was published in December 1977. This
guidance document recommended a limitation of 0.34 kilogram of organic solvent emitted per
liter of coating (minus water and exempt solvents) [2.8 pounds of organic solvent emitted per
gallon of coating (minus water and exempt solvents)] for reduction of VOC from existing
stationary sources [ 1 ].
1-4
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A New Source Performance Standard (NSPS) with a different VOC emission limit was
published in October 1982. In the NSPS for the large appliances surface coating industry (40
CFR Part 60 Subpart SS--Standards of Performance for New Stationary Sources; Industrial
Surface Coating: Appliances'), VOC emissions are limited to 0.90 kilogram of VOC per liter of
coating solids applied [7.5 pounds of VOC per gallon of coating solids applied] [2]. This limit is
based on the solids (nonvolatiles) that land on the substrate.
The Bureau of National Affairs (SNA) Environmental Library was searched for State
regulations pertaining to surface coating of large appliances. Most States generally follow the
guidelines or requirements established in the CTG and/or NSPS as described above. Some States
have different limits for individual coating type and curing method (e.g., specialty coatings, air-
dried general coatings, baked general coatings, enamels, etc.). Several State/local agencies have
established guidance for determining Best Available Control Technology (BACT) and
Reasonable Available Control Technology (RACT) for surface coating of large appliances [3]. A
tabular summary of these regulations is presented in Table A-2 [3, 4].
1.3.3 Questionnaires
To obtain the most up-to-date data from the industry, EPA mailed preliminary
questionnaires under the authority of Section 114 of the Clean Air Act to selected industry
stakeholders in June 1997. Nine companies were selected by EPA to receive questionnaires.
The purpose was to compile detailed information on quantities of HAP and VOC emissions and
on current emission control techniques. In addition, data were needed to analyze the
environmental, energy, and economic impacts associated with implementing feasible emission
control techniques.
The selection process for facilities to receive questionnaires issued under the authority of
Section 114 was intended to obtain information from the major manufacturers of each of the
product groups under consideration for the large appliances surface coating operations
rulemaking effort. The companies were selected for identifying the major technologies in use
and for quantifying emissions from these manufacturing systems.
As a means of identifying and quantifying the possible sources of pollution, the
questionnaires used the Unit Operation System (UOS) as the basis for data reporting. A plant (or
1-5
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facility) consists of several levels of production activity, which are divided into work areas that
are composed of one or more UOS. The term UOS refers to a formalized concept for performing
a material balance. A UOS system is the ensemble on which the material balance is performed
and includes all sources that contribute to emissions [5]. Furthermore, the facilities were asked
to provide a flow diagram of the manufacturing process, which identifies the different unit
operations. They were also asked to describe the coating specifications, type of parts and
substrate material coated, waste handling procedures, control measures, applicable regulations,
and collocated sources.
As illustrated in Figures 1-1 and 1-2, the boundary defines the UOS in which the HAP
content of coating equals the HAP content of coating waste plus emissions. Facilities do not
need to measure emissions from each of the individual unit operations (Coating Application,
Flashoff, and Oven) in order to calculate the total emissions within the boundary. This
information can be determined if the HAP contents in the coating and in the coating waste
leaving a unit operation are known. The total emissions from each of the unit operations will
vary depending on the type of coating applied, the application method, the length of the flashoff
area, and other factors that are specific to each facility. In powder coatings systems, most waste
coating material may be recirculated into the Coating Application, and there is no flashoff area.
For powder coating operations, no HAP or VOC emissions were reported. Figure 1-2 shows all
of the UOS examined in the large appliances surface coating operations rulemaking effort.
In June 1998, EPA sent out an additional Section 114 questionnaire designed using
information learned from the June 1997 questionnaire. The questionnaire focused on more
specific information about the unit operations within a facility, and contained sections concerned
with general facility information, material data, add-on control devices, coating application,
surface preparation, storage, mixing operations, cleaning operations, and waste and wastewater.
The questionnaire also included components that relate data to the UOS. Data collected from
1-6
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this questionnaire included the amount of coatings, organic solvents, adhesives, and cleaners
used as well as information on HAP emissions, coating solids, and major source classification.
These data were used to calculate the MACT floor and resulting HAP emissions limit.
1.3.4 Site Visits
The EPA made site visits to four large appliances surface coating operations in June and
July of 1997 and to four additional facilities in August 1998. These facilities are listed in Table
1-4. The types of information requested during site visits included:
• Description of the plant: size, hours of operation, layout of the unit operations,
types of products coated, products manufactured, and production rate.
• Detailed descriptions of the surface coating operations, including the application
equipment and coating technology used (e.g., dip coating, flow coating,
electrostatic spray, powder coating), the spray booth or application area, and oven.
• Information regarding each material containing any HAP or VOC that is used in
or emitted by any operation at the facility (e.g., coatings, parts cleaners, etc.).
• Descriptions of any control measures or add-on devices used to reduce HAP or
VOC emissions from surface coating processes or any emitting source.
• Available cost information concerning the materials and equipment used in the
surface coating operation, and costs of any HAP or VOC control strategies in
place or planned.
TABLE 1-4. SITE VISIT FACILITIES
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Facility
AAA Plating, Inc.
Denver, Colorado
Amana Refrigeration, Inc.
Florence, SC
Amana Refrigeration, Inc.
Amana, LA
Decorative Coating Systems
Denver, Colorado
Lennox Industries
Marshalltown, LA
Maytag Appliances
Newton, LA
The Trane Company
Pueblo, Colorado
Windsor Industries, Inc.
Englewood, Colorado
Products Manufactured
Metal Plating Only
Residential Ranges, Cook Tops, Wall Ovens
Residential Freezers, Refrigerators, Microwaves,
Commercial & Industrial Ovens and Microwaves
Contract Paint Shop (no manufacturing)
Residential Heating (Furnaces & Combination
Furnace/Water Heater) and Cooling (Air Conditioners, Heat
Pumps, Coil Boilers) Products
Residential Washers and Dryers
Chillers
Service Machinery, NEC (Floor Maintenance Equip.,
Vacuum Equip.)
SIC Code
Not available
3631
3632(3631
&358S)
Not available
3585
3633
3585
3589
1-10
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1.4 REFERENCES
1. Control of Volatile Organic Emissions from Existing Stationary Sources Volume V:
Surface Coating of Large Appliances. U. S. Environmental Protection Agency, Office of
Air and Waste Management, Office of Air Quality Planning and Standards, Research
Triangle Park, NC, EPA-450/2-77-034. December 1977.
2. Industrial Surface Coating: Large Appliances - Background Information for Promulgated
Standards. U. S. Environmental Protection Agency, Office of Air Quality Planning and .
Standards, Research Triangle Park, NC, EPA-450/3-80-037b. October 1982.
3. Beyond VOC RACT CTG Requirements. U. S. Environmental Protection Agency, Office
of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-453/R-95-010.
April 1995.
4. BNA's ENVIRONMENTAL LIBRARY on CD. Windows 3.97. Environmental
Compliance Series, The Bureau of National Affairs, Inc., Copyright 1996.
5. "Standardized Accounting for a Formal Environmental Management and Auditing
System," Waste Minimization through Process Design. Chapter 20, A. P. Rossiter, ed.,
McGraw-Hill, Inc., 1995. Pages 289-303.
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2.0 THE LARGE APPLIANCES SURFACE COATING OPERATIONS
SOURCE CATEGORY
This chapter presents a description of the large appliances surface coating operations
source category and identifies types of surface coating operations that would potentially be
subject to the proposed standards. Also included in this chapter is a summary of current
facility operations and industry practices that contribute to the emission of HAP.
2.1 SOURCE CATEGORY DESCRIPTION
The large appliances surface coating operations source category includes any operation
engaged in the surface coating of any large appliance part or product. There are several
industries that coat items considered large appliances. These industries coat products such as
heating and air conditioning units and parts, chillers, refrigerators and home and farm freezers,
laundry equipment, cooking equipment, dishwashers, floor waxers and polishers, garbage
disposal units, trash compactors, and water heaters. See Table 2-1 for a listing of examples of
large appliances.
The large appliances surface coating operations source category is primarily represented
by the following six SIC codes:
3631 Household Cooking Equipment
3632 Household Refrigerators and Home and Farm Freezers
3633 Household Laundry Equipment
3639 Household Appliances, Not Elsewhere Classified
3585 Air Conditioning And Warm Air Heating Equipment and Commercial and
Industrial Refrigeration Equipment
3589 Service Industry Machinery, Not Elsewhere Classified
Products manufactured under these six SIC codes are considered large appliances for purposes of
the rule. However, the large appliances surface coating operations source category also
encompasses facilities coating similar products under other SIC codes. Therefore, a facility may
be operating under a different SIC code but can still be subject to the rule because they coat a
product that is a large appliance.
2-1
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TABLE 2-1. EXAMPLES OF LARGE APPLIANCES
heating and air conditioning
units (including home, motor
vehicle, industrial)
household refrigerators,
iceboxes, and home and farm
freezers
household floor waxers and
polishers, janitor's carts, mop
wringers, floor sanding
machines
chillers, heating and air-
conditioning parts and
equipment (coils, fin plates,
compressors, etc.)
refrigerated cabinets, cases, and
lockers
household sewing machines and
buttonhole and eyelet machines
condensers, electric non-
portable dehumidifiers, electric
and gravity flow furnaces
household laundry/dry-cleaning
equipment, including coin-
operated (washers, dryers,
wringers, etc.)
snow making machinery
non coin-operated cold drink
dispensing equipment, beer
dispensers, electric water and
milk coolers, refrigerated
drinking fountains
cooking equipment (ovens,
ranges, stoves, microwaves,
grills, barbecues, etc.)
sewage treatment and sewer
cleaning equipment, sludge
processing equipment
non-household vacuum cleaners
and sweepers
dishwashers
industrial water treatment
equipment, water conditioners
for swimming pools
non-household pressure cookers,
steam cookers, com poppers,
and fryers
garbage disposal units and trash
compactors
household water filters and
softeners, water purification
equipment
ice making machinery
water heaters, electric heat
pumps
car washing machinery
(including coin-operated)
'These are only examples of large appliances. This table does not include the entire large appliances industry and is
meant to only provide examples of the types of products considered large appliances.
2.1.1 Number of Sources
The questionnaire sent to industry by EPA in 1998 requested data from the 1997 calendar
year. Results from the questionnaire indicate there are 222 facilities that perform large
appliances surface coating operations. Large appliance surface coating operations are distributed
across 38 States and Puerto Rico. Based on data received from the questionnaires, the states with
the largest numbers of large appliances surface coating operations are Ohio (19), Tennessee (16),
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Illinois (15), Texas (14), Wisconsin (13), and Georgia (10). Table 2-2 presents the distribution
of large appliances surface coating operations per state. The size of the facilities and the number
of employees represented in the questionnaire vary, ranging from 11 to 5,500. Based on
responses to the EPA's Section 114 questionnaire, an average plant employs about 640 people.
Table 2-3 presents the total number of employees and the average number of employees per plant
for different types of large appliances. For each type of large appliance, the total number of
employees reported by the questionnaire respondents was divided by the number of respondents
that provided employment data. Of the 222 facilities, 95 are considered potential major sources
based on potential facility HAP emissions (see Table 2-4 for those facilities considered major
sources).
TABLE 2-2. LARGE APPLIANCES SURFACE COATING OPERATIONS
LOCATION DISTRIBUTION BY STATE
State
Alabama
Arkansas
Arizona
California
Colorado
Connecticut
Delaware
Florida
Georgia
Idaho
Illinois
Indiana
Kansas
Kentucky
Number of
Facilities
5
7
2
6
3
1
1
4
10
7
15
5
1
7
State
Mississippi
Nebraska
New Hampshire
New Jersey
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
Tennessee
Number of
Facilities
6
1
1
3
3
9
19
5
1
8
2
1
8
16
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State
Louisiana
Massachusetts
Maryland
Michigan
Minnesota
Missouri
Number of
Facilities
1
1
6
4
7
8
State
Texas
Virginia
Vermont
Washington
Wisconsin
Number of
Facilities
14
6
1
3
13
TABLE 2-3. LARGE APPLIANCES SURFACE COATING OPERATIONS
EMPLOYEE DISTRIBUTION
Appliance Type
Cooking Equipment
Refrigerators and
Freezers
Laundry Equipment
Miscellaneous
Household Appliances
Air Conditioning,
HVAC, Industrial
Refrigeration, etc.
Miscellaneous Service
Equipment
Other Miscellaneous
Total Employees
12,766
15,344
12,734
17,797
58,969
6,407
8,098
Average Employees
per Plant
799
1,180
1,415
890
627
279
253
2.2 LARGE APPLIANCES SURFACE COATING METHODS
The large appliances surface coating operations industry is diverse and uses a range of
coating application technologies. The methods used most frequently are typical of surface
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coating operations in any industry. The following paragraphs provide a brief discussion of the
most common application technologies. Facilities often use several of these methods.
2.2.1 Air and Airless Spray Guns
The processes of air spraying and airless spraying of coatings involve the atomization of a
liquid coating in order to apply it to a substrate. Air spraying achieves atomization by the use of
compressed air. Airless spraying uses an airless pump system to force a coating through a nozzle
designed to atomize the coating [1].
Air spraying offers good coating quality with a wide range of coating systems and a high
application rate. Also, the air spray can coat irregular shapes with recessed areas effectively.
This technology can provide transfer efficiencies of up to 40 percent. Excessive overspray is the
major drawback of an air spray system, which results in high material waste and high cleanup
costs [2].
Airless spray systems offer comparable spray characteristics to air spray systems.
However, the airless spray system typically has a higher transfer efficiency (50-60 percent) than
air spray system (30-40 percent) [3]. Airless systems can also atomize coatings at high flow
rates. However, with airless spray the spray nozzles are prone to clogging and wear. Also, stiff
high pressure fluid hoses are required with airless systems. Problems with high pressures have
been alleviated through the use of the air-assisted airless spray gun. This system uses some air to
help atomize the coating and therefore allows for lowering of the pumping pressure [1].
The high-volume low-pressure (HVLP) system is a newer technology which further
reduces overspray because it propels the atomized coating at a lower velocity than the air or
airless system [2]. However, there are some difficulties with applying coatings with low solvent
content and certain water-based coatings using an HVLP system when the flow viscosity is high.
In this case proper atomization may not be achieved with high flow rates.
The EPA recently completed an Environmental Technology Verification for a laser-
guided targeting device designed to improve the transfer efficiencies of spray guns. The device
attaches easily to a regular manual spray gun and enables a precise painting technique. The
EPA's Environmental Technology Verification Statement reports that the system increases
relative transfer efficiency at an average of 11.1 percent. This would result in a corresponding
reduction in material usage and volatile HAP emissions. The EPA's Verification Statement can
2-5
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be found at http://www.epa.gov/etv/verifipt.htmftprevention under "P2 Innovative Coatings and
Coating Equipment Systems Pilot."
2.2.2 Dip Coating
The dip coating operation involves the immersion of a part into a tank containing the
coating. Typical transfer efficiencies are near 85 percent [4]. The high transfer efficiency is due
to the fact that there is no atomization and excess coating can be returned to the dip tank as it
drips off [5].
Dip coating is advantageous because it is simple and provides a quick and inexpensive
way of applying a coating to coat large numbers of substrates. Potential problems with dip
coating involve the large amounts of coating required and fire risk in large installations. The fire
risk can be eliminated by using water-based coatings [5].
Dip coating is feasible using solvent-based or water-based coatings. However, with
either coating type extensive attention must be given to maintaining proper mix characteristics
(coating viscosity) in the tank because of evaporative losses [5].
2.2.3 Electrodeposition
Electrodeposition is a dip coating method in which an electric field is used to facilitate
the deposition of the coating on the substrate. The substrate to be coated acts as an electrode that
is oppositely charged from the coating (particles) in the dip tank [1]. Electrodeposition has the
same advantages as dip coating, and, in addition, the transfer efficiency for an electrostatic dip
coat operation is closer to 95 percent [4]. Many types of polymers can be used in the
electrodepositon process if they are used with solubilizers, which charge the polymer electrically.
Early electrodeposition processes were anodic, but due to problems with electrolysis, cathodic
systems are now preferred [6].
Like the dip-coating operation, the electrodeposition operation requires close monitoring
and recirculation of the coating in the tank [6]. One consideration with electrodeposition is that
the use of water-based coatings requires the equipment to be electrically isolated [7].
2.2.4 Electrostatic Spraying
An electrostatic spray can be generated using an air or an airless gun system. In such
systems, the transfer efficiency is improved because electrostatic principles are used to attract the
coating to the substrate (85 percent transfer efficiency) [1,4]. Coating droplets are injected into
2-6
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an electrostatic field set up by several electrodes that impart a charge to the coating. Negatively
charged atomized coating droplets are propelled to the substrate to be coated and deposit
themselves through electrostatic attraction [5].
A unique advantage of applying coatings in the form of an electrostatic spray is the
"wraparound effect." Due to the wraparound effect, an entire product can be coated from one
side. This is a result of the electrostatic attraction of the coating to the substrate [5]. The
advantages of using an electrostatic spray include high transfer efficiencies (90 percent for
automatic systems and 60 percent for manual systems), as well as applicability to coatings
containing a high amount of nonvolatiles (coating solids). If water-based coatings are to be used,
the system must be electrically isolated to avoid electric shocks [2].
2.2.5 Electrostatic Bell and Disk Gun Systems
The electrostatic bell and disk systems are similar in many respects. They use the rapid
rotation of either a bell or disk shaped applicator to mist the coating. The use of oppositely
charged substrate and coating allows for higher transfer efficiencies and better coating uniformity
[1]. The transfer efficiency of the bell or disk system is close to 90 percent [4].
Electrostatic bell and disk systems can also be used with almost any liquid coating from
the thinnest up to 80 percent nonvolatiles [6]. The electrostatic system helps carry the coating to
the substrate and causes it to adhere to the surface of the substrate. Hence, the result is a coating
of good quality and finish characteristics. Due to the design and purpose of the bell application
systems, they are best used on automated large volume coating lines to coat parts that have
similar characteristics (size, shape, and material) [2].
2.2.6 Carbon Dioxide Spray System
The carbon dioxide spray application technology was introduced in 1990 as a new
pollution prevention (source reduction) technology to reduce the amount of organic solvent
needed before the coating is sprayed. The technology was used to apply conventional solvent-
based formulations and the higher coating solids formulations [8, 9]. The equipment is a
modified airless spray system that makes it possible to mix carbon dioxide, a solvent under
certain conditions, with the coating [8]. To dissolve the carbon dioxide in the coating, the
mixture is pressurized to supercritical pressures ranging from 1,200 to 1,700 psig, which are
well within the capacity of current airless spray application systems. In addition, the solution
2-7
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is heated to a temperature ranging from 40 to 70 degrees Celsius to make the carbon dioxide
supercritical and to offset the cooling that occurs as the carbon dioxide diffuses from the
solution as a free gas in the spray.
Even though the carbon dioxide spray is airless in nature, it has all the desirable traits of
air spray, without high air volumes [8]. The carbon dioxide spray produces a high quality
uniform film which has both good appearance and high transfer efficiency [10]. This
technology has been used to apply urethane clear topcoat to exterior plastic automotive
components, acrylic clear topcoat to automotive bumpers, adhesion promoter to automotive
components, acrylic lacquer to automotive sport wheels, alkyd lacquer to heavy equipment
chassis and components, and nonstick silicone coating to metal bakeware [8].
The carbon dioxide spray system appears to have economic, performance, and
environmental advantages over conventional spray systems. Using a carbon dioxide spray
system also has a number of environmental and safety benefits. The carbon dioxide spray
system reduces solid waste, lowers volatile emissions, and reduces flammable solvent
inventory. The carbon dioxide used for this application is a by product from other sources,
hence it helps reduce greenhouse gas inventory [8].
A few deterrents exist for switching to a carbon dioxide spray system. The system is
new relative to more established technologies. Some minor equipment modifications and
purchases are required. Coating reformulation in some cases may be required [8],
2.2.7 Powder Coating Technology
Powder coatings (dry resin) are applied to a substrate in a dry form. The resin is typically
a thermosetting (polvurethane, acrylic, epoxy, etc.) or thermoplastic (nylon, vinyl, etc.) resin
which is electrostatically applied to the surface of a part. Application is done with a spray gun or
fluidized bed (powder which has been fluidized by compressed air adheres to the surface of a
heated metal part as it passes through the fluidized bed of powder). The powder-coated part is
then cured in an oven where the powder fuses to form a continuous, uniform coating [10].
Powder coatings have been used by numerous industries to coat parts such as lawn and garden
equipment, appliances, playground equipment, patio furniture, and automotive parts [11].
2-8
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Powder coating has some distinct advantages over conventional coating operations. First,
no organic solvents are normally added to powder coatings. A negligible HAP (less than
approximately one percent by mass volatiles [10,12] are released during curing stage compared
to e.g., 15 percent for water-based coatings and e.g., 66 percent for conventional solvent-based
coatings) [10]. Because organic solvents are not normally added to powder coatings, worker
safety is improved, ventilation and pollution control requirements in the workplace are reduced,
and permitting and regulatory compliance is more cost effective [11]. Another advantage of
using powder coatings is that the overspray can be collected using a vacuum cleaner or
compressed air. If the retrieved powder is reused, the overall coating costs and hazardous
disposal costs will be reduced [10]. Powder coated surfaces are more resistant to chipping,
scratching, fading, and wearing than other finishes [13].
Uncertainty exists as to the validity of testing powder coatings by the same methods as
liquid coatings. The Powder Coating Institute recommends an alternative method which
involves weighing the powder coating before and after placing it in an oven set to similar
conditions as production curing. The difference in mass is the volatile content. Some other
concerns associated with powder coating involve storage of powder coating and cleaning of the
application equipment. Temperature and humidity must be monitored closely in the areas where
the powder coating is stored and applied. Moisture in the powder must be kept at a reasonably
low level to prevent cohesion problems (clumping of powder particles) during spraying. Because
there are no organic solvents in the dry powder to absorb or disperse contaminants, the air
delivery system to the powder spray guns must not deliver significant amounts of water or oil [2].
Cleaning the application equipment can be very time consuming when color changes are
required. All of the first color powder must be removed from the system before the second color
powder can be started. Equipment duplication may be a cost-effective solution to this problem
{10].
2.2.8 UV/EB Coating Technologies
Radiation-cured coatings are specially formulated adhesives, inks, and coatings
materials that cure with exposure to either UV light (UV-cured) or focused electrons (EB-
cured) rather than heat [14]. All of the material in these coatings enter into the curing reaction
and become part of the final solid coating film rather than being volatilized. This UV/EB
coating technology is particularly useful for products such as paper, foil, wood, and plastic that
can not be exposed to the high temperatures of traditional coating ovens. Some products that
2-9
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are currently being coated using radiation technology include fiber optics, toiletry bottles,
sporting equipment, medical equipment, headlight assemblies, wood trim, windshields,
magazines, labels, cereal boxes, milk/juice cartons, CDS, DVDs, and circuit boards [15].
There are several components that are used in the UV/EB cured coatings. These
include an oligomer or prepolymer containing double-bond unsaturation, monomers (with
varying degrees of unsaturation), a photoinitiator to absorb the UV light radiation (this is not
needed for EB curing), and pigments/dyes or other additives. Essentially, the curing process is
dependent on the availability of extra electrons to form the bonds with the unsaturated
components. This creates a material that has saturated bonds (i.e., the final product or film).
The extra electrons come from either the photoinitiator in the UV coating or from the electron
beam that is applied in EB coatings.
Unlike conventional coatings, UV/EB coatings emit few or no VOC/HAP. The only
HAP expected to be present in the UV/EB coatings as they are applied would be solvents that
may be added by the user. Approximately 98 percent of UV and EB coatings are applied as
supplied by the coating manufacturer [16]. Other benefits of using radiation-cured UV and EB
coatings include: (1) elimination or reduction of solvent use, (2) very rapid curing, (3) high
productivity from rapid curing and instant startup and shutdown, (4) low-temperature
processing, which allows for the use of heat sensitive substrates such as plastic, (5) good film
properties and performance, such as hardness; and improved solvent, stain and abrasion
resistance, (6) higher non-volatile content that results in higher gloss, better build, and lower
shrinkage, (7) lower energy use because of high efficiency UV/EB systems when compared to
thermal ovens, and (8) lower space requirements than conventional coating systems [17].
Radiation-cured coating systems also have a number of limitations, which include: (1)
higher cost coating formulations because of expensive raw materials and smaller volume, (2)
line-of-sight curing is limited to flat or cylindrical materials that can be directly exposed to the
radiation source. Radiation systems for three dimensional substrates are being developed to
overcome this limitation, (3) the presence of pigments reduces penetration by UV light,
limiting use in high-build applications, (4) many polymers used in radiation-cured coatings are
allergens and can cause skin irritation and sensitization, (5) UV/EB curing is not always
suitable for porous materials, and (6) EB systems generally require an inert environment
because atmospheric oxygen can interfere with the curing of resins [17].
2.2.9 Flow Coating
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Flow coating is a method that involves the application of the coating directly onto the
substrate without atomizing the coating [1]. Small streams of liquid coating are applied to a flat,
horizontally-oriented substrate and allowed to spread to form a continuous film. The typical
transfer efficiency for flow coating is 85 percent [4]. Flow coating does not require the large
coating volumes that dip coating does. However, the maintenance of mix characteristics is
equally important. Flow coating also allows for low ventilation rates and a variety of substrate
shapes [6].
For many applications, electrostatic de-tearing is required to control droplet formation in
flow coating operations. De-tearing uses electrostatic currents to remove excess paint droplets
from the part. Also, if the coating cures too quickly the coating will skim (the surface of the
coating will dry before the rest of the coating). Therefore, it is sometimes necessary to place the
coated substrate in a solvent-rich environment to slow the curing process and prevent skimming.
While flow coating allows for reduced solvent emissions, if a solvent rich environment is
maintained emissions rise considerably [6].
2.2.10 Final Touch-up/Reinforcement of Coated Pieces
The majority of touch-up operations are performed by using manual air spray guns and a
lacquer based coating. This is because the lacquer coating has good drying characteristics that
Callow for shorter drying times. In some cases, touch-up might include recoating a product
•entirely, but the majority of touch-up lines consist of manual coating application to a small
portion of the product surface [2].
2.2.11 Coating Type & Composition
Several types of coatings were represented in the questionnaire responses, including
powder coatings, organic solvent-based coatings, and water-based coatings. Organic solvent-
based coatings are considered to be the more traditional coatings. High nonvolatiles, medium
*nonvolatiles, and low nonvolatiles coatings fall into this coating category [4]. All three are
-comprised of some amount of paint nonvolatiles including the pigments, with the balance of their
composition being some type of organic solvent. High nonvolatiles formulations of coatings
appear to be a principal method of choice for controlling HAP emissions in large appliances
surface coating operations. High nonvolatiles formulations simply have a higher nonvolatiles to
volatiles ratio than conventional coatings, typically greater than 60 percent nonvolatiles by
volume. Medium nonvolatiles formulations typically have 50 to 60 percent nonvolatiles by
volume, and low nonvolatiles formulations have less than 50 percent nonvolatiles by volume [1].
2-11
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The questionnaire responses report that approximately 15,800,000 liters of coating solids were
used in 1997 to coat large appliances. Powder coatings make up 65% (10,570,000 liters coating
solids) of the total coatings used, waster-based coatings 15% (2,270,000 liters coating solids),
and solvent-based coatings 20% (2,970,000 liters coating solids).
Powder coatings are comprised primarily of various types of plastic resin. These coatings
produce very low organic emissions relative to solvent-based coatings. Some references state
that in some cases, powder coatings may possibly emit up to 6 percent by mass E-caprolactam;
however, this substance is not a HAP[ 1,18].
Water-based coatings contain at least 5 percent water by mass in the volatile (liquid)
fraction. These coatings offer some advantages over conventional solvent-based coatings
because they contain significantly less organic solvent, and water-based coatings represent less of
a fire risk than solvent-based coatings. However, water-based coatings have longer drying times
because water evaporates more slowly than the organic solvents (which can have production
impacts), and the water content may present a corrosion problem for the application equipment
[1,4].
2.3 FACILITY OPERATIONS AND CURRENT INDUSTRY PRACTICES
There are several activities that take place to support the coating application process that
may contribute to HAP emissions. These activities include cleaning and pretreatment, mixing of
paints and thinners, storage of coatings and other solvents, wastewater, and adhesive usage, The
following section describes these activities in more detail.
2.3.1 Cleaning and Pretreatment
One of the most important activities in the surface coating industry is cleaning and
pretreatment. Proper cleaning removes all organic and inorganic soils from the substrate prior to
coating, which is critical for achieving maximum performance from the coating, especially with
powder coating. Cleaning and pretreatment can consist of numerous stages that include several
types of chemical washes, such as solvent cleaning, an acid wash, a phosphate wash, and a
deionized water wash. Facilities use various combinations of these stages. Except fot solvent
cleaning and wetting oil treatment, most stages do not emit any HAP or VOC emissions,
Pretreatment and cleaning requirements vary depending on the type of coating application and
curing, as well as the type of metal to be coated.
2.3.2 Mixing
2-12
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Paint mixing may be performed in an agitated 208 liter (55 gallon) drum, or it may be
performed by merging two different coating lines into one. Coating mixing is typically
performed by the coating manufacturer prior to shipment to a large appliances manufacturer's
facility. Some facilities add water or solvent to the coating, which may be performed in a small
mixing booth or it may be automated. Some facilities combine reclaimed coatings from various
coating applications and mix the different coatings together in a 208 liter (55 gallon) drum.
Mixing also varies depending on the type of coating and usage requirements.
2.3.3 Coating Storage
Storage demands vary based on the type of coating and usage requirements. Container
size and type vary depending on coating manufacturer and end user needs. Most coatings are
stored in 208 liter (55 gallon) drums. Powder coatings can also be stored in 208 liter (55 gallon)
drums, as long as the temperature and the humidity are controlled. To prevent moisture
absorption, most facilities store powder coatings in 23 kilogram (50 pound) cardboard boxes that
are lined with plastic, but the size of the container can vary from 1.4 to 136 kilograms (3 to 300
pounds) [19].
2.3.4 Wastewater Treatment
Since many of the operations employed by the large appliances surface coating
operations produce wastewater, some facilities have wastewater treatment systems on-site.
vSome of the activities that produce wastewater include pretreatment, molten salt baths, some
electrodeposition systems, and many primer and topcoat systems. The effluent from their
wastewater handling or treatment systems must be acceptable to discharge either back into a
body of water, or to the Publicly Owned Treatment Works (POTW). Otherwise, they must
perform some degree of wastewater treatment in order to reach the levels specified by
regulations. The effluent limitations for existing indirect discharges are imposed by the EPA
.through National Pollution Discharge and Elimination Systems (NPDES) permits [20].
2.3.5 Adhesives
Based on data obtained from the questionnaires, the typical application for large
quantity adhesive usage in the large appliances surface coating operations industry is attaching
insulation to metal substrates. Adhesives are also used to attach brake hubs in products such as
washing machines. Small usage of adhesives include thread-lockers, PVC/CPVC adhesives,
and other usages. Adhesives are applied using spray guns, rollers, or by brush. Pressure
sensitive adhesives, which are characterized by a peel-off, self-stick backing, are also used.
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2.4 EMISSIONS
Surface coating activities are a source of both VOC and HAP emissions. Because this
regulation only addresses volatile HAP emissions, they will be the only emissions discussed in
this section.
2.4.1 General
The typical unit operations at a large appliance surface coating operations that may result
in HAP emissions include:
•metal cutting and forming steps using cutting oils and lubricants
•metal surface cleaning and pretreating steps
•bonding of some component parts with adhesives
•application of one or more layers of coatings
•cleaning of coating application areas, conveyors, and coated parts
•storage of coatings and thinners in mix areas
•collection and disposal of waste materials
The coating application unit operation is by far the largest source of HAP emissions, accounting
for an estimated 80 percent of emissions from all of the listed activities.
The major HAPs emitted from large appliances surface coating operations are xylene
(27% of total HAPs), glycol ethers (21%), toluene (13%), methyl diphenyl diisocyanate (12%),
and methyl ethyl ketone (9%). While some HAPs, such as xylene or toluene, may be used as a
single component solvent, many are components of solvent blends [21].
2.4.2 Baseline Emissions
To determine the magnitude of the potential HAP reductions that may be achieved by
the proposed standards, the current level of emissions must first be determined. The HAP
emissions level that exist currently, in the absence of the proposed standards, is referred to as
the baseline emission level. Because the proposed standards only affect major sources (as
defined in Chapter 1), baseline emissions were calculated for the subset of the 1997 and 1998
industry questionnaire responses that were believed to be potential major sources.
Potential major sources were identified as: (1) those facilities that listed "major source"
or "synthetic minor source" as their Title V status on their questionnaire response, (2) those
facilities that reported their HAP emissions under "maximum design capacity" as greater than
9.1 Mg/yr (10 tpy), and (3) other facilities that we judged to have the capacity to increase their
2-14
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HAP emissions to above 9.1 Mg/yr, even though they did not identify themselves as major or
synthetic minor sources.
Synthetic minor sources are defined as sources whose emissions are limited to levels
below the definition of a major source by their operating permits or other Federally enforceable
commitments. Although these sources were included in the determination of the baseline
emission level, no emission reductions from these facilities is projected.
The final group of facilities (criteria 3, above) were included because they reported
actual HAP emissions of greater than 3 Mg (3.3 tons) during the reporting year and did not
report a "maximum design capacity."
The database that resulted from applying these criteria contained 95 facilities and
baseline HAP emissions of approximately 2,400 Mg. Table 2-4 presents each potential major
source facility and its corresponding HAP emissions. Table A-l provides a list of the 95
potential major source facilities and the names of the states in which "they are located.
2-15
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TABLE 2-4 HAP EMISSIONS FROM POTENTIAL MAJOR SOURCE FACILITIES
Facility
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
SIC Codes
3631
3585
3585
3585
3585
3585
3634
3589
3585
3585
3585
3585
3585
3632
3585
3556
3632
3585
3585
3585
3585
3585
3585
3585
3585
3585
3589
3589
not provided
3585
3585
3589
3585
3589
3639
3632
3585
3585
3639
Activity
gas and electric ranges
air conditioner units
mix dispensing equip./vending machines
air conditioners
air conditioning, refrigerators, heating
equip.
hermetric compressors
small kitchen appliances
water purification systems
commercial HVAC equipment
commercial refrigeration display cases
air conditioner units
large commercial HVAC
heat exchangers/air handling equipment
refrigerators and freezers
remanufactured refrigerant compressors
soft serve ice cream/slush machines, gas
grill
refrigerators and freezers
air conditioners
heating/cooling units
chiller refrigeration equipment
refrigeration compressors
evaporators, coolers, condensers, cooling
towers
air handling equipment
refrigerator display cases
industrial refrigeration pressure vessels
compressors, motors
water filters
food machines, mixers, scales
not provided
industrial refrigerators and heat exchangers
hermetric compressors
floor scrubber/sweeper
commercial refrigerators
various tanks
ranges
refrigerator compressors
absorption units, chillers, compressors
commercial and industrial air handler units
air conditioning compressors
Total 1997
Coating solids
Usage (L)
167,606
18,110
18,419
109,954
2,085
11,634
7,485
677
160,593
64,850
8,247
730
6,059
26,351
4,162
6,326
57,559
4,443
157,622
5,677
8,197
1,807
5,029
136,836
3,682
1,562
4,289,470
11,281
12,446
6,446
43,312
12,379
105,150
3,728
722
15,144
26,411
10,971
9.512
Total ! 997 HAP
Emissions (kg)
4
114
117
316
449
458
817
932
983
997
1,018
1,087
1,416
1,493
1,515
1,632
1,793
1,891
2,069
2,616
2,617
2,821
3,027
3,036
3,065
3,401
3,602
3,872
3,890
4,199
4,535
4,609
4,695
5,077
5,314
5,552
5,677
5,767
6,036
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TABLE 2-4 HAP EMISSIONS FROM POTENTIAL MAJOR SOURCE FACILITIES
(Concluded)
Facility
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
SIC Codes
3585
3585
3585
3585
3589,3631
3589
3639
3585
3585
3639
3585
3585
3631
3633
3585
3585
3585
3632
3585
3631
3632
3585
Unk
3631
3585
3585
3639
3585
3631
3585
3589
3632
3585
3585
3585
3632
3585
3585,3632,
3639
3585
3639
Activity
air handling equipment
condensers, chillers
refrigerant compressors
air handling systems
grills, broilers, griddles
food service equip., gas combustion equip.
metal tanks
refrigerated display cases
refrigeration equipment
food waste disposers, hot water dispensers
air conditioners
refrigeration equipment
household cooking equipment
washers and dryers
commercial refrigeration
chillers
refrigerators
refrigerators
waste chillers
gas and electric ranges
refrigerators, cooking equip., ovens,
microwaves
compressors, coils, industrial chillers
unknown
metal fabrication
refrigerated display cases
air conditioners, heating equipment
range hoods, bath fans, garbage compactors
water heaters
microwaves
evaporators, coolers, condensers, cooling
towers
floor maintenance equipment
refrigerator
motor vehicle air conditioning
dehumidifiers
air conditioners, air cleaners
household refrigerators
air conditioners, gas heaters
air conditioners, refrigerators,
dehumidifiers
furnaces, heat pumps, gas grills
water heaters
Total 1997
Coating solids
Usage (L)
3,984
3,070
43,160
6,590
2,188
341
48,670
31,783
11,286
63,105
4,169
20,438
51,919
118,423
21,573
12,043
30,379
6,615
9,093
138,263
417,969
30,755
1,633
32,657
29,310
12,897
58,278
156,444
167,238
5,212
25,509
33,069
7,324
68,656
66,278
80,253
346,102
105,966
36,226
267.894
Total 1997 HAP
Emissions (kg)
7,423
7,788
7,951
8,029
8,551
8,774
9,133
9,188
9,670
10,551
11,523
11,688
13,081
13,701
14,721
14,796
15,340
16,323
16,604
16,622
17,344
17,685
19,005
19,971
20,635
22,553
22,757
24,231
24,558
25,409
25,527
26,739
26,780
26,994
31,856
32,401
43,450
64,947
76,197
89.014
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TABLE 2-4 HAP EMISSIONS FROM POTENTIAL MAJOR SOURCE FACILITIES
(Concluded)
Facility
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
SIC Codes
3633
3633
3639
3633
3633
3585
3633
3632
3639
not provided
not provided
not provided
3585
3631
3633,3631,
3632,3639
3635
Activity
laundry products
clothes dryers
dishwashers
household laundry equipment
washers and dryers
heat transfer coils, coolers, ice machines
household and commercial laundry
refrigerators and trash compactors
water heaters and water storage tanks
not provided
not provided
not provided
air handlers and furnaces
gas and electric ranges
laundry, ranges, refrigerators, dishwashers
central vacuums
Total 1997
Coating solids
Usage (L)
226,438
1,112,454
515,602
1,078,668
536,632
78,179
580,521
133,146
629,607
77,912
__b
__b
__b
b
__b
b
Total 1997 HAP
Emissions (kg)
89,122
102,025
116,031
136,567
141,851
142,143
190,521
295,256
Oa
Oa
_b
__b
__b
__b
__b
__b
"These facilities reported only powder usage and no other operations were reported (i.e., surface preparation,
cleaning, etc.).
"These facilities did not provide sufficient data to determine the HAP emissions; however, because these facilities are
considered potential major sources on the basis of a facility's statement or its potential to emit, the facilities were
counted as part of the potential major source population when determining the number that represented the top 12%
performing facilities.
Multiply Liters by 0.264 to obtain gallons
Multiply kilograms by 2.205 to obtain pounds
2-18
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2.5 REFERENCES
1. Glossary for Air Pollution Control of Industrial Coating Operations. Second Edition,
U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC, EPA-450/3-83-013R. December 1983.
2. Finishing Systems Design and Implementation. Society of Manufacturing Engineers,
Dearborn, Michigan, J. L. Stauffer, Copyright 1993.
3. W. J. Fabini, "Back to Basics: A General Overview of Coatings Technology," Paint
& Application: Industrial and Architectural 1996 FSCI International Coatings
Technology Conference. Federation of Societies for Coatings Technology, Blue
Bell, PA. 1996.
4. Compilation of Air Pollutant Emission Factors. Volume I: Stationary. Point, and Area
Sources. Fifth Edition (AP-42), U. S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Office of Air and Radiation, Research Triangle Park,
NC. January 1995.
5. Outlines of Paint Technology. Third Edition, W. M. Morgans, Halsted Press, 1990.
6. Industrial Paint Finishing Techniques and Processes. Gene F. Tank, Ellis Horwood
Publishers, NY, 1991.
7. Industrial Surface Coating: Large Appliances - Background Information for Proposed
Standards. U. S. Environmental Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, NC, EPA-450/3-80-037a. November 1980.
8. J. Lewis, J.N. Argyropoulos, and K.A. Nielson, "Supercritical Carbon Dioxide Systems",
Metal Finishing. April 1997. pp. 33-41. Docket No. A-97-41, Item No. H-I-1.
9. A. Wojciechowski and J. Lewis, "Development of a Low VOC Chemical Agent Resistant
Coating (CARC) for use with Supercritical CO2," International Waterborne. High-Solids.
2-19
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and Powder Coatings Symposium. New Orleans, LA, February 1999. Docket No.
A-97-41,ItemNo. H-I-2.
10. "Powder Coating. Article downloaded from Georgia Department of Natural Resources
Pollution Prevention Assistance Division website http://www.ganet.org/dnr/p2ad. 2 pp.
Docket No. A-97-41, Item No. H-I-5.
11. The Powder Coating Institute. Powder Coating: The Complete Finisher's Handbook.
C. J. Krehbiel Company, Cincinnati, OH, 1994.
12. Correspondence from F. Lettice, South Coast Air Quality Management District, to K.
Summers, PES, Inc. Facsimile transmitting draft information about SCAQMD Method
316C - Determination of Volatile Organic Content of Powdered Coatings. June 14,
2000. 16 pp. Docket No. A-97-41, Item No. H-D-436.
13. "The Benefits of Powder Coating - What Are Its Advantages?" Powder Coating Institute.
Article downloaded from Powder Coating Institute website
http://www.powdercoating.org. 1 p. Docket No. A-97-41, Item No. n-I-4.
14. "Pressure Sensitive Tapes and Labels: The Clean Air Act Amendments of 1990 and
Pollution Prevention Opportunities." A study from NEWMOA, NESCAUM and the U.S.
EPA. Article downloaded from Radtech International North America website
http://www.radtech.org/publications/publications.htmi 3pp. Docket No. A-97-41, Item
No. H-I-6.
15. A. Ross. "Eliminating Air Pollution (VOC & HAP) at the Source Through the Use of
Ultraviolet or Electron Beam Polymerization." Radtech International North America.
Article downloaded from Radtech International North America website
http://www.radtech.org. 5 pp. Docket No. A-97-41, Item No. D-I-3.
2-20
-------
16. Telecon from K. Summers, PES, to A. Ross, RadTech. Discussion of volatile
emissions information on UV/EB coating. May 8, 2000. 2pp. Docket No. A-97-41,
Item No. H-E-14.
17. The US EPA Website, es.epa.gov/program/epaorgs/ord/org-coat.html, "Guide To
Cleaner Technologies Organic Coating Replacements."
18. Control of Volatile Organic Emissions from Existing Stationary Sources Volume V:
Surface Coating of Large Appliances. U. S. Environmental Protection Agency, Office
of Air and Waste Management, Office of Air Quality Planning and Standards, Research
Triangle Park, NC, EPA-450/2-77-034. December 1977.
19. The Powder Coating Institute, Powder Coating. The Complete Finisher's Handbook. First
Edition, C. J. Krehbiel Company, Cincinnati, OH, 1997.
20. B. T. Ray, "Regulations," Environmental Engineering. PWS Publishing Company,
Boston, MA, 1995. pp. 300-307.
21. Memorandum from P. Almodovar, EPA:CCPG, to CCPG Project Teams. "Petroleum
Solvent Blends and Associated HAP Contents", (undated). 4 pp. Docket No. A-97-41,
ItemNo.H-B-14.
2-21
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3.0 EMISSION REDUCTIONS FROM COATING APPLICATIONS
This chapter presents information about the various methods of emission reduction and
control that are currently in use, or are available for use, at large appliances surface coating
operations.
3.1 AIR POLLUTION CONTROL TECHNIQUES
There are many types of emission control technologies that could be used to reduce
emissions from large appliances surface coating operations. The most common method of
volatile HAP emission reduction utilized in surface coating operations is the reformulation of
coating materials. Reformulation refers to basic changes in the raw coating materials that allow
them to perform their desired function while containing a lower than typical percentage of HAP
ingredients. Reformulation is a desirable method of HAP emission reduction because it is a
pollution prevention option that often achieves many performance and cost benefits. While
volatile HAP emissions are the primary concern in the proposed standards, this chapter also
presents brief descriptions of some of the most common particulate and VOC control techniques.
3.1.1 Reformulation of Materials
3.1.1.1 Coating Solids (nonvolatiles)
A coating is composed of a volatile and nonvolatile portion. The nonvolatiles will also
be referred to as coating solids to mean the portion of the coating material remaining after a
coating dries on the substrate. One method of emission control employed by the coating industry
is to increase the ratio of the nonvolatiles to volatiles in a particular coating. The goal is to use
less organic solvent per volume of nonvolatiles used for a job. This reduces the amount of
organic solvent that is emitted in the process. Coating formulations may be classified as high,
medium, or low nonvolatiles. High nonvolatiles coatings would be considered, for our purpose,
to be any coating with a nonvolatiles content above 60 percent nonvolatiles by volume. Medium
nonvolatiles coatings are considered to be between 50 percent and 60 percent nonvolatiles by
volume. A low nonvolatiles coating is considered to contain less than 50 percent nonvolatiles by
volume. With all other variables held constant, increasing the nonvolatiles in a coating
formulation should produce lower HAP and lower VOC emissions per unit volume of coating
used [1].
3-1
-------
For the existing industry, the primary short-term, and in some cases the long-term,
solution to reduce emissions is to switch from a lower nonvolatiles coating to a coating with a
higher nonvolatiles content. This solution is probably the most cost effective means of reducing
emissions. In calculating emissions from a coating, any cure volatiles that are HAP or VOC will
need to be counted.
3.1.1.2 Water-based Coatings
A water-based coating uses water as the organic solvent rather than a traditional organic
solvent. This does not mean that a water-based coating has no organic solvent, it just means that
there is less organic solvent than if it were a traditional organic solvent-based coating. A water-
based coating is considered to be a coating that contains more than 5 percent by mass water in its
volatile fraction. Water-based coatings can have VOC contents less than 120 grams per liter (1.0
The most commonly available water-based coatings include water-reducible alkyds and
modified alkyds, acrylic latexes, and acrylic/epoxy hybrids. Water-reducible coatings are
available in a wide range of colors and gloss levels. Typical applications include dipping primers
and topcoats, general purpose primers, and spray enamels [2].
3.1.1.3 Powder Coatings
The use of powder coatings, where applicable, provides an opportunity for significant
emission reduction. There are practically no organic HAP or VOC emissions during the
application of powder. However, small amounts of cure volatiles are emitted from powder
coatings during the oven cure stage. The information on cure volatiles is sparse in the literature.
However, there are data showing that E-caprolactam (not a HAP or VOC) is emitted from certain
powder coatings [3]. Formaldehyde may also be emitted from certain powder coatings. The
nature of the cure volatiles can be determined through testing. Other emissions from powder
coating result during cleaning of part hangers used to move the parts along the coating line. Even
considering these emissions, the powder coating system offers emission reductions that can only
be matched by the best performing add-on control devices [3].
3.1.1.4 Add-on Control Devices
There are many types of emission control technologies that could be used to reduce
emissions from large appliances surface coating operations. While the most common method of
volatile HAP emission reduction utilized in surface coating operations is the reformulation of
coating materials, add-on control devices are another technique available for use in reducing
3-2
-------
HAP emissions. The responses to the industry questionnaires provided information on seven
such devices located at five facilities. Add-on control devices are discussed in the
memorandum entitled "Available Add-on Control Devices for Use in the Large Appliances
NESHAP" (Docket No. A-97-41, Item No. H-B-11). The memorandum describes the types of
add-on control devices and presents the monitoring requirements for these devices and the
rationale for selecting these monitoring parameters.
3.2 POLLUTION PREVENTION (SOURCE REDUCTION)
Steps that can be taken to eliminate the generation of pollutants at the source are the
preferred approach to reducing HAP emissions, hi surface coating operations, there are
numerous opportunities to implement pollution prevention measures. In addition to the use of
lower-HAP coatings, the use of non-HAP or lower-HAP surface preparation materials and
cleaning materials results in the generation of less HAP emissions. Likewise, the conversion of
conventional organic solvent-based coating operations to water-based or powder coatings reduces
the generation and release of HAP emissions. The increased use of technologies that reduce the
overall amount of organic solvents in coating materials can serve as pollution prevention
measures. The EPA welcomes comments and recommendations from the industry and the public
on additional pollution prevention measures that may be implemented within large appliances
surface coating operations.
3.3 EQUIPMENT CHANGES
One of the major factors in making changes to application equipment as a control
measure is transfer efficiency. With higher transfer efficiencies less coating is used to coat the
same amount of product, resulting in less emissions. Transfer efficiency itself is not simple to
quantify. However, some application equipment clearly has a better transfer efficiency than other
equipment. For example, a rotational electrostatic spray system typically has a higher transfer
efficiency than a simple manual spray gun [2,4], A description of the major coating application
technologies and their associated transfer efficiencies is presented in Section 2.2.
3.4 DESIGN AND OPERATIONAL CHANGES
Air recirculation can be used to reduce capital and operating costs of the air handling
system. Recirculation can also reduce air flow streams to oxidizers, allowing a smaller control
3-3
-------
system to be installed. Typical air recirculation systems filter, dehumidify, and return 10 to 80
percent of exhausted air to the supply air stream of a spray system. The remaining air is sent to
the HAP/VOC control system [2].
This type of system is most viable for automated systems because it can be hazardous to
personnel in manual spray areas. It can only be used for manual spray systems if the personnel
are very well protected from the high organic solvent concentrations [2].
Air cascading systems can alleviate the employee risk problems concerning manual spray
areas. In this type of scenario, exhausted air from a manual spray system can be used as supply
air for an automated system (after particulate and humidity control). Therefore, the organic
solvent rich air is cascaded to an automated coating line where there are no employees to be
harmed by the air [2].
3.5 WORK PRACTICES
3.5.1 Material Storage and Handling
Storage demands vary based on the type of coating and usage requirements. Container
size and type vary depending on coating manufacturer and end user needs. Most coatings are
stored in 208 liter (55 gallon) drums. Powder coatings can also be stored in drums, as long as the
temperature and the humidity are controlled. Most facilities store powder coatings in 23
kilogram (50 pound) cardboard boxes that are lined with plastic to prevent moisture absorption,
but the size of the container can vary from 1.4 to 136 kilograms (3 to 300 pounds) [2].
These containers should be well maintained to prevent leakage and excessive spillage or
material loss during transfer to other containers or coating equipment. They should also remain
sealed except when it is necessary to remove material from the containers, after which they
should be promptly closed again.
3.5.2 Fluid Handling Equipment
All fluid handling equipment such as coating lines, holding tanks, coating storage
containers, or any fluid handling equipment that contains a VOC or HAP containing coating
should be well maintained to prevent spills, leaks, or other problems that would release some of
the contents of the fluid handling system.
3.5.3 Mixing Operations
Coating mixing may be performed in an agitated 208 liter drum, or it may be performed
by merging two different coating lines into one. Coating mixing is typically performed at the
3-4
-------
coating manufacturer prior to shipment to a large appliances surface coating operation. Some
operations add water or organic solvent to the coating, which may be performed in a small
mixing booth or it may be automated. Some operations combine reclaimed coatings from
various coating applications and mix the different coatings together in a 208 liter drum. Mixing
also varies depending on the type of coating and usage requirements [2].
3.5.4 Spraying Operations and Cleaning
Nozzle maintenance, although often overlooked, is a critical component of any metal
pretreatment system. In order to keep the system running at maximum efficiency to produce the
highest-quality finished product, nozzle maintenance must become a regular part of system
operation [5].
Improperly maintained nozzles decrease spray impact and distort spray patterns, reducing
cleaning efficiency. As a result, more time will be spent and more chemicals will be used to
accomplish cleaning tasks [2].
Learning to identify, solve, and prevent spray nozzle performance problems in a parts
washer can cut spray liquid and energy waste, assure better washer performance, and reduce
chances of equipment damage. The same holds true for coating spray nozzles [2].
Typical cleaning activities involve organic solvent wipes, dips, and spraying of pure
organic solvent which can contribute to the emissions from a facility. The amount of organic
solvent released in this manner should be minimized to reduce emissions [2].
3-5
-------
3.6 REFERENCES
1. Glossary for Air Pollution Control of Industrial Coating Operations. Second Edition,
U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC, EPA-450/3-83-013R. December 1983.
2. '97 Organic Finishing Guidebook and Directory Issue. Volume 95, Number 5A, Metal
Finishing, Tarrytown, NY, May 1997.
3. "VOC's in Powder Coatings." Technical Brief. Morton Powder Coatings. Article
downloaded from Morton Powder Coatings website
http://www.mortonpowder.com/morton_pages/learn_more/techbriefs.vocs.htm. 2 pp.
Docket No. A-97-41, Item No. H-I-7.
4. Compilation of Air Pollutant Emission Factors. Volume I: Stationary, Point, and Area
Sources. Fifth Edition (AP-42), U. S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Office of Air and Radiation, Research Triangle Park,
NC. January 1995.
5. The Powder Coating Institute, Powder Coating. The Complete Finisher's Handbook. First
Edition, C. J. Krehbiel Company, Cincinnati, OH, 1997.
3-6
-------
4.0 MODEL PLANTS AND COMPLIANCE OPTIONS
The model plants that have been developed for the large appliances NESHAP project are
presented in Tables 4-3 through 4-6. Four model plants were developed to represent the facilities
in the database that have been projected to be potential major sources, and thus, subject to this
rulemaking. The following paragraphs present the methodology used to develop the model
plants and the rationale for the assumptions that were made. A model plant does not represent
any single actual facility, but rather it represents a range of facilities with similar characteristics
that may be impacted by a standard. Each model plant is characterized in terms of facility size
and other parameters that affect the estimates of emissions, control costs, and secondary
environmental impacts. The model plants developed for this source category incorporate the
baseline characteristics presented in this chapter.
The reductions in HAP emissions that will be required by these standards is expected to
be achieved through the use of a combination of low-HAP and zero-HAP liquid coatings,
thinning solvents, cleaning materials, and powder coatings. As described in Chapter 5 and the
memorandum documenting the development of the MACT floor (Docket Item No. II-B-9), these
low-HAP materials are in use at some facilities within the source category now, and are believed
to be available for use by the entire source category. Because complying low-HAP material
technology is believed to be available, none of the model plants are assumed to use add-on
control devices.
The first step in developing the model plants was to decide on an approach to characterize
the facilities in the database. Because this project focuses on the surface coating and related
operations, it was decided that parameters related to the surface coating performed at each facility
was the best way to characterize the model plants. Our analysis of the questionnaire responses,
site visit reports, and other data available to us did not reveal patterns in the types of coatings or
cleaning materials used, the application methods used, or the overall emissions that could be used
to group the facilities into subsets for modeling. Tables 4-1 and 4-2 present information showing
the distribution of coating application methods and coating types across the source category. The
quantity of coating solids (nonvolatiles) annual usage appeared to be the most logical parameter
to use to define the models because it relates directly to the level of production. Therefore, liters
of coating solids used was chosen as the parameter by which the model plants would be defined.
4-1
-------
TABLE 4-1. COATING APPLICATION METHODS VERSUS SIC CATEGORY
Coating
Application
Method
Dip coating
Air spray
Airless spray
Air-assisted
airless spray
Electrostatic
spray
Rotary bell/
disk
HVLP
Totals
Number of Facilities Using Each Application Method3
SIC 3585
13
24
8
17
30
2
17
111
SIC 3589
2
3
2
2
5
NR
7
21
SIC 3631
4
6
NR
1
7
NR
2
20
SIC 3632
3
1
NR
2
3
1
10
SIC 3633
6
2
1
NR
6
3
1
19
SIC 3639
6
2
1
2
8
2
2
23
Totals
34
38
12
24
59
8
29
204
"Facilities reporting more than one method are listed under each of the methods that they use.
Note: NR means this technology was not reported in the SIC category.
TABLE 4-2. COATING TYPE VERSUS SIC CATEGORY
Coating
Type
Solvent-based
Water-based
Powder
SIC CODE
SIC 3585
10.90%
47.90%
41.20%
SIC 3589
0.00%
1.20%
98.80%
SIC 3631
27.50%
13.60%
58.90%
SIC 3632
2.00%
98.00%
0.00%
SIC 3633
28.90%
25.10%
45.90%
SIC 3639
48.80%
20.20%
31.00%
The MACT floor database contains questionnaire responses from 95 potential major
source facilities. To determine the size characteristics of the model plants, the 95 facilities in the
database were sorted by total volume of coating solids used, with reported values ranging from
less than 100 liters to over 1,000,000 liters. An evaluation of various size ranges that could be
4-2
-------
created from the database resulted in a decision to develop four groups of facilities, each to be
represented by a model plant. The groups were characterized by total coating solids used, as
follows: (1) up to 10,000 liters of solids represented by a model plant using 5,000 liters; (2)
10,001 to 50,000 liters of solids represented by a model plant using 25,000 liters; (3) 50,001 to
200,000 liters of solids represented by a model plant using 100,000 liters of solids; and (4)
greater than 200,000 liters of solids represented by a model using 625,000 liters. Key parameters
used to define each model plant were derived from an analysis of the actual facilities within the
size range represented by the model. Because many of the questionnaire responses were
incomplete, a subset of the database consisting of 66 facilities was used to calculate the average
values used as parameters to define the model plants. These 66 facilities were believed to
provide an adequate representation of the entire database of potential affected facilities. The 66
facilities cover the manufacturing of all major product types found within the source category,
they include facilities that use small amounts of surface coating materials and 2 of the 3 largest
users of surface coatings, they include all types of coating materials and application techniques
reportedly used in the source category, and they include facilities covering all NAICS/SIC codes
within the source category. Table 1-1 presents a listing of the products and the corresponding
NAICS and SIC codes.
Tables 4-7 through 4-10 present the data used for the development of the model plants.
Each row of data in these tables lists the HAP content and coating solids derived from the
material usage and formulation information provided by one facility. The HAP emission rate for
a facility, kg HAP/L coating solids (the last column in Tables 4-7 through 4-10), was determined
by first adding all the HAP content shown in a row and dividing that value by the sum of the
coating solids values. The rows were sorted and arranged in order of increasing coating solids
usage. Table 4-7 contains information for all facilities that reported up to 10,000 liters of solids
usage, which was used as the basis for defining model plant number 1. Tables 4-8 through 4-10
present the information used to define model plants 2 through 4, respectively. The HAP and
coating solids values in each column were summed and divided by the number of facilities to
generate an average value that is characteristic of the model plant. The average total coating
solids usage value was then rounded for use in defining each model plant. All other HAP and
4-3
-------
coating solids usage values were adjusted (scaled up) by the ratio of the average total coating
solids to the rounded total coating solids. [For example, the average total coating solids usage for
the facilities in Table 4-7 is 4,254 liters, which was rounded to 5,000 liters. The average HAP
content of the water based coatings used by these facilities is 241 kg, which was scaled up to 283
kg (241 kg * 5,000 L / 4,254 L) for model plant number 1. Each of the other parameters were
calculated by the same procedure.] The characteristic parameters for model plants 1 through 4
are shown in Tables 4-1 through 4-4, respectively.
Each of the four model plants has some level of material usage, and some HAP
emissions, for all of the coating operations included within our affected-source-wide MACT
floor approach. Therefore, each model plant has values for coatings, thinning, surface
preparation, cleaning, and adhesives. While it is clear that in actual practice not every facility
will employ all types of materials, the use of these materials is widespread within each size
grouping of facilities. However, the coating technologies used within the four size groupings
does exhibit a pattern that was included in the model plants. Water based coatings and solvent
based coatings are used extensively in all sizes of facilities, but the use of powder coatings is
much more common in larger facilities. For this reason, the two smallest model plants use only
water based and solvent based coatings, while the two largest model plants use all three types of
coatings.
To summarize, there are currently 95 potential major source facilities in the database that
were used to develop the MACT floor. Data from 66 of these facilities were used to develop the
characteristics of the 4 model plants because these facilities provided the most complete
information. The characteristics of the 66 facilities that provided the most complete information
are representative of the other 29 facilities in the database. Of the 95 facilities in the database, 21
facilities are classified as "synthetic minor sources" and, therefore, 74 facilities were assumed to
be the population of affected sources. Model plant number 1, using 5,000 liters of solids,
represents 26 facilities. Model plant number 2, using 25,000 liters of solids, represents 19
facilities. Model plant number 3, using 100,000 liters of solids, represents 17 facilities. Model
plant number 4, using 625,000 liters of solids, represents 12 facilities.
4-4
-------
TABLE 4-3. MODEL PLANT NUMBER 1
(UP TO 10,000 LITERS OF COATING SOLIDS)
Water-based Coatings
Solvent-based Coatings
Powder Coatings
Thinning Solvents
Surface Preparation
Cleaning Solvents
Adhesives
Total
Plant Definition
HAP
(kg)
283
1,872
0
630
378
721
3
3,887
Density
(g/1)
1,186
1,189
876
991
991
954
Coating
Solids
(liters)
793
3,794
0
0
0
0
413
5,000
% Coating
Solids
31
42
100
0
0
0
47
Total
Usage
(liters)
2,558
9,011
0
719
381
728
886
14,284
Total Usage
(gallons)
676
2,381
0
190
101
192
234
3,774
kg HAP/L coating solids =0.777
Notes:
Thinning and cleaning solvents are considered 100% HAP
Total Usage for coatings and adhesives= Coating Solids/(% Coating Solids/100)
Total Usage for solvents = HAP/(density/1000)
4-6
-------
TABLE 4-4. MODEL PLANT NUMBER 2
(10,001 TO 50,000 LITERS OF COATING SOLIDS)
Water-based Coatings
Solvent-based Coatings
Powder Coatings
Thinning Solvents
Surface Preparation
Cleaning Solvents
Adhesives
Total
Plant Definition
HAP
(kg)
708
8,357
0
1,955
324
3,242
648
15,234
Density
(g/1)
1,186
1,189
876
991
991
954
Coating
Solids
(liters)
4,741
19,612
0
0
0
0
647
25,000
% Coating
Solids
31
42
100
0
0
0
47
Total Usage
(liters)
15,294
46,584
0
2,232
327
3,271
1,388
69,096
Total
Usage
(gallons)
4,041
12,308
0
590
86
864
367
18,255
kg HAP/L coating solids = 0.609
Notes:
Thinning and cleaning solvents are considered 100% HAP
Total Usage for coatings and adhesives= Coating Solids/(% Coating Solids/100)
Total Usage for solvents = HAP/(density/1000)
4-7
-------
TABLE 4-5. MODEL PLANT NUMBER 3
(50,001 TO 200,000 LITERS OF COATING SOLIDS)
Water-based Coatings
Solvent-based Coatings
Powder Coatings
Thinning Solvents
Surface Preparation
Cleaning Solvents
Adhesives
Total
Plant Definition
HAP
(kg)
4,102
11,212
0
6,500
229
7,340
53
29,436
Density
(g/1)
1,186
1,189
876
991
991
954
Coating
Solids
(liters)
30,299
42,079
26,918
0
0
0
704
100,000
% Coating
Solids
31
42
100
0
0
0
47
Total
Usage
(liters)
97,739
99,950
26,918
7,420
231
7,407
1,511
241,175
Total Usage
(gallons)
25,823
26,407
7,112
1,960
61
1,957
399
63,719
kg HAP/L coating solids = 0.294
Notes:
Thinning and cleaning solvents are considered 100% HAP
Total Usage for coatings and adhesives= Coating Solids/(% Coating Solids/100)
Total Usage for solvents = HAP/(density/1000)
4-8
-------
TABLE 4-6. MODEL PLANT NUMBER 4
(GREATER THAN 200,000 LITERS OF COATING SOLIDS)
Water-based Coatings
Solvent-based Coatings
Powder Coatings
Thinning Solvents
Surface Preparation
Cleaning Solvents
Adhesives
Total
Plant Definition
HAP
(kg)
24,460
31,544
0
42,992
122
15,408
10,709
125,235
Density
(g/1)
1,186
1,189
876
991
991
954
Coating
Solids
(liters)
162,884
160,112
292,908
0
0
0
9,096
625,000
% Coating
Solids
31
42
100
0
0
0
47
Total
Usage
(liters)
525,432
380,314
292,908
49,078
123
15,548
19,519
1,282,922
Total Usage
(gallons)
138,820
100,479
77,387
12,966
33
4,108
5,157
338,949
kg HAP/L coating solids = 0.200
Notes:
Thinning and cleaning solvents are considered 100% HAP
Total Usage for coatings and adhesives= Coating Solids/(% Coating Solids/100)
Total Usage for solvents = HAP/(density/1000)
4-9
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5.0 REGULATORY APPROACH
This chapter presents the approach used to determine the MACT floor level of control for
new and existing facilities in the large appliances surface coating source category.
5.1 BACKGROUND
Section 112 of the CAA requires that we establish NESHAP for the control of HAP from
both new and existing major sources. The CAA requires the NESHAP to reflect the maximum
degree of reduction in emissions of HAP that is achievable. This level of control is commonly
referred to as the MACT.
The MACT floor is the minimum control level allowed for NESHAP and is defined
under section 112(d)(3) of the CAA. In essence, the MACT floor ensures that the standard is set
at a level that assures that all major sources achieve the level of control at least as stringent as
that already achieved by the better-controlled and lower-emitting sources in each source category
or subcategory. For new sources, the MACT floor cannot be less stringent than the emission
control that is achieved in practice by the best-controlled similar source. The MACT standards
for existing sources can be less stringent than standards for new sources, but they cannot be less
stringent than the average emission limitation achieved by the best-performing 12 percent of
existing sources in the category or subcategory (or the best-performing five sources for categories
or subcategories with fewer than 30 sources).
In developing MACT, we also consider control options that are more stringent than the
floor. We may establish standards more stringent than the floor based on the consideration of the
cost of achieving the emission reductions, any non-air quality health and environmental impacts,
and energy requirements.
5.2 MACT FLOOR APPROACH
Within the large appliances industry, organic HAP emission control for cleaning and
surface coating operations is accomplished primarily through the use of lower-HAP coatings,
thinners, and cleaning materials. Add-on capture and control systems for organic HAP are rarely
used by the industry. While lower organic HAP materials have achieved broad use throughout
the industry, each particular coating technology is not used at every facility. Rather, facilities use
various combinations of low-HAP coatings, thinning solvents (thinners), and cleaning materials.
5-1
-------
Thus, we judged the most reasonable approach to establishing a MACT floor to be the evaluation
of a facility's organic HAP emissions from all coating-related operations. To account for
differences in production levels from one facility to another, we normalized the organic HAP
emissions by the volume of coating solids used to calculate the emision rate. We believe coating
solids usage is an appropriate indicator of overall production level.
We used information obtained from industry responses to a 1998 questionnaire submitted
under the authority of Section 114 to calculate the source-wide organic HAP emission rate from
each survey respondent. The questionnaire was submitted to all known large appliance
manufacturers, and the responses represent the most complete (and most current) information
available to us. Of the 222 facilities that provided responses to the questionnaire, 95 were found
to be potential major sources, with 21 of these identified as synthetic minor sources. Table 5-1
presents a summary of data extracted from the responses submitted by the 95 potential major
sources and used in developing the MACT floors. We calculated total organic HAP emissions
by assuming that 100 percent of the organic HAP in all coatings (including adhesives), thinners,
and cleaning materials (including surface preparation materials) is emitted. This is a reasonable
assumption for coatings and thinners, because coated substrates are generally cured in an oven,
which will accelerate the release of HAP containing volatile materials. We also expect that a
large portion of cleaning solvents will evaporate during the application operation and from waste
solvent. Major sources were identified as: (1) those facilities that listed "major source" or
"synthetic minor source" as their Title V status on their questionnaire response, (2) those
facilities that reported their HAP emissions under "maximum design capacity" as greater than 9.1
Mg/yr (10 tpy), and (3) other facilities that were judged to have the capacity to increase their
HAP emissions to greater than 9.1 Mg/yr, based on their reported emissions. Facilities that were
included as a result of item (3) were those that did not report a "maximum design capacity," but
did report actual emissions of greater than 3 Mg (3.3 tons) during the reporting year. These
facilities were assumed to be operating one shift per day and to have the capacity to operate three
shifts per day, resulting in emissions of greater than 9.1 Mg per year.
The questionnaire response information from the 95 potential major source facilities was
used to determine the total source-wide HAP emissions and the total volume of coating solids
used by each facility from all types of coatings. Data provided in the responses to the
questionnaires were reviewed for completeness and, where needed, were converted to consistent
Metric units. In some cases where facilities did not provide complete information on the quantity
5-2
-------
or formulation of materials in the requested units, a default value for material density was used to
enable conversion between units of mass and volume. The default values were calculated by
averaging the values reported by all other respondents for similar types of materials. Table 5-2
presents the default density values that were used when necessary for unit conversions. The HAP
and solids contents of all materials used at each facility were summed by material type (water-
based, solvent-based, powders, thinners, surface prep, cleaners, and adhesives) to yield the
source-wide data presented in Table 5-1. We included decorative, protective, and functional
coatings as well as thinners and surface preparation materials in this total.
Using the source-wide organic HAP emissions and the total volume of coating solids
used for each survey respondent, we calculated the normalized organic HAP emission rate in
units of kilograms organic HAP per liter of coating solids used. This value is presented on Table
5-1 in column P, titled "HAP emission rate." Using the column headings A through R in Table
5-1 for reference, the equation for this calculation is as follows:
(C+E+G+I+J+K+L) - (D+F+H+M) - HAP emission rate
The facilities were then ranked from the lowest emission rate to the highest (sorted in
ascending order based on the values in column P). We did not include in the MACT floor
calculations facilities which: (1) did not report any cleaning material usage or did not provide
sufficient coating material formulation data; (2) reported more than 90% of their coating solids as
being from powder coatings; and (3) used an unusually large percentage of low HAP and non
HAP adhesives. The facilities that were excluded from the MACT floor calculations are
indicated by the footnotes in Table 5-1. Only those facilities that were evaluated as MACT floor
facilities and excluded from the top 12 percent were assigned a footnote in Table 5-1. We
excluded facilities that did not report any cleaning material usage or did not provide adequate
coating material formulation data because we did not have confidence that the final calculated
HAP emission rate value would represent all their emissions. Facilities that reported the
predominant use of powder coating technology (greater than 90 percent of all coating solids
usage) were excluded from the MACT floor calculations. While powder coating technology is a
proven low-HAP coating technology, its applicability is not considered to be universal for all
products manufactured within the source category. For those facilities whose products can be
coated with this technology, powder coatings are a very effective and efficient means of reducing
HAP emissions. However, because not all large appliance parts and products can be
satisfactorily coated with powder coating technology, we concluded that it would not be
5-3
-------
appropriate to define the MACT floors based primarily on their use. We excluded facilities with
very low organic HAP to coating solids ratios due to use of unusually large quantities of low-
HAP and non-HAP adhesives. The low- and non-HAP adhesive usage for these facilities ranged
from 40 to 84 percent of all coating solids. While many facilities in this source category use
adhesives, their use is not as widespread compared to the decorative and protective coatings
usually associated with the appearance of large appliance products. On the average, adhesives
account for about 4 percent of the total coating solids used by the facilities in the database.
Because of the specific function served by adhesives, the low-HAP adhesives technology
employed in these coatings may not be transferable to decorative coatings and protective
coatings which account for the remaining 96 percent of the coating solids usage in the surce
category. Thus, we concluded that the facilities using atypically large quantities of these
adhesives relative to decorative and protective coatings should not be included in the
determination of the floors for new and existing sources.
5.3 EXISTING SOURCES
For the existing source MACT floor, the top 12 percent of the facilities were determined
based on the number of facilities in the MACT floor database (95 database facilities x 12 percent
= 11.4). Because the calculated value was greater than 11, we used data from 12 facilities to
determine the MACT floor. The floor was calculated as the arithmetic average of the emission
rates of the top 12 best-performing representative facilities. These 12 facilities are identified in
Table 5-1 by the shaded rows.
This process resulted in a MACT floor equal to 0.134 kg HAP/L of coating solids. For
the proposed standards this value was rounded to two significant figures, i.e., 0.13 kg HAP/L of
coating solids (1.1 Ib/gal). The MACT floor facilities are typical of the remaining facilities in the
database in terms of the substrates coated, the coating and coating application technologies used,
or the applicability of control measures across the various operations. The 12 facilities included
in the MACT floor calculation include facilities that manufacture a range of products that are
typical of the entire industry, and include washers and dryers, laundry equipment,
refrigerators/freezers, microwave ovens, dishwashers, water heaters, air conditioners, gas heaters,
supermarket refrigerated display cases, chillers, fans, compressors, and air handling units.
Coating application techniques used at the 12 facilities include all those typically found within
the source category, and include conventional air and airless atomized spraying, electrostatic
5-4
-------
spraying, and dip coating. The amount of coatings applied by the 12 MACT floor facilities is
representative of facilities throughout the source category. The 12 facilities reported coating
solids usage ranging from about 6,000 liters to about 1,079,000 liters. For the entire MACT
database of 95 facilities, coating usage ranges from below 1,000 liters to over 4,000,000 liters of
coating solids. Only three facilities in the database reported the use of over 1,000,000 liters of
coating solids, and one of those facilities is in the MACT floor. The average coating usage for
the 12 MACT floor facilities is about 211,000 liters of coating solids and for all facilities in the
MACT database the average usage is about 147,000 liters of coating solids. Six of the 12
facilities use a combination of liquid coatings and powder coatings. The other six do not use any
powder coatings, and are using only low-HAP liquid coating materials to achieve the low HAP
emission rates indicated in Table 5-1. Four of the 12 MACT floor facilities reported the use of
adhesives, compared to 19 of the 95 MACT database facilities that reported adhesive use. The
amount of adhesives used by the 12 MACT floor facilities and the HAP content of those
adhesives is typical of the other facilities in the source category.
To evaluate the potential availability of low-HAP liquid coatings, an examination of the
reported HAP contents of water based and solvent based coatings was performed. When the
HAP emission rate for each facility in the spreadsheet was calculated using the HAP and solids
data from only liquid coatings plus thinners, 15 facilities were found to have HAP emission rates
below 0.13 kg HAP/L coating solids. The coating solids content of the liquid coatings applied at
these 15 facilities equals 29 percent of the total coating solids from liquid coatings applied at all
facilities in the spreadsheet. Therefore, 29 percent of the liquid coatings currently in use, in
terms of coating solids, would comply with the proposed existing-source emission limit.
A similar evaluation was performed to examine the availability of low-HAP adhesives
and cleaning materials. Of the 19 facilities that provided data on adhesives, 6 reported using
adhesives containing no HAP, and 4 additional facilities reported using adhesives with HAP
levels that are less than 0.13 kg HAP/L coating solids. In addition, nine of the facilities in the
spreadsheet reported the use of cleaning materials with zero HAP content.
Figure 5-1 shows the range of HAP emission rates calculated for facilities within each of
the six activity (SIC) categories, with the arithmetic average HAP emission rate indicated by the
diamond-shaped symbol. (Table 1-1 shows the six SIC categories, a description of the major
products manufactured under each category, and the corresponding NAICS information.) As
shown in Figure 5-1, the average emission rate for each of the SIC categories is in the same
5-5
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general range. The average for SIC 3639 is somewhat misleading because a single facility
reported a HAP level of 7.36 kg per liter of coating solids, and the next highest reported level in
the SIC category is only 0.635 kg per liter of coating solids. The similarity of the average values
for all SIC categories indicates that the HAP content of materials used throughout the source
category does not vary significantly from one product line to another. Also, because low-HAP
coatings are already being used within each SIC category, it appears that the use of low-HAP
coatings is a viable option for products manufactured under all six of the SIC categories.
Figure 5-1. HAP emission rate (normalized emissions) versus SIC code.
0
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5-6
-------
In addition to the availability of low-HAP liquid coatings, the widespread usage of
powder coatings within the appliance industry provides evidence of the availability of applicable
low-HAP coating technology. Powder coating technology is reported to be the fasted growing
industrial finishing method in North America, representing about 15 percent of the total
industrial finishing market.[l] The appliance industry is the largest single market sector for
thennosetting powders.fl] Current uses within the source category include refrigerators, washer
tops and lids, dryer drums, range housings, dishwashers, microwave oven cavities, and freezer
cabinets.[l]
With the availability of powder coatings and because the percentages of liquid coatings,
adhesives, and cleaners that currently comply with the HAP emission limit are relatively high,
and because the use of these materials is reported across the SIC categories, we believe that low-
HAP coating technology is available to all facilities within the source category, hi addition, for a
majority of the facilities within the source category, the "one number" format of the standard
would allow the higher HAP emissions from certain operations where low-HAP materials may
not be readily available to be offset by increased usage of available low-HAP materials in other
operations within the facility.
5.4 NEW SOURCES
To determine the new source MACT limit, we identified the best performing sources
from the list of database facilities ranked by their emission rate. As discussed above, two of the
best performing of the potential major sources reported a HAP content well below the existing
source MACT floor. However, these facilities were judged to be unique in their level of
adhesives usage relative to their decorative coating usage and were not considered for the new
source MACT.
The next best performing facility reported a HAP content level of 0.022 kg HAP per liter
of coating solids. This facility operates under SIC 3585 and manufactures supermarket display
cases and equipment. This facility uses both solvent-based coatings and powder coatings, and is
considered to be representative of the entire source category. The proposed new source MACT
limit was, therefore, established using the data from this facility. The facility-wide HAP content
value of 0.022 kg HAP per liter of coating solids was determined to be the new source MACT
floor. The fact that the facility upon which the new source MACT level is based uses a
5-7
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combination of solvent-based and powder coatings indicates that new facilities would not be
limited to the use of only powder coatings to comply with the proposed standards. The
availability of low-HAP liquid coatings, in conjunction with the widespread increase in the use of
powder coatings in the large appliance source category (as discussed in the previous section of
this chapter), indicates that the new source MACT level is achievable for new facilities.
5.5 BEYOND THE FLOOR
An analysis of the impacts of establishing standards more stringent than the MACT floors
was conducted. For the analysis of standards more stringent than the existing source MAC!
floor, we considered the impacts of standards based on the average performance of the fop 6
percent of the best performing facilities compared to the MACT floor level based on the top 12
percent. This level of stringency was evaluated because it represented roughly the midpoint
between the existing and new source MACT floors, and because it was expected to result in
significant HAP emission reductions. From Table 5-1, the top 6 percent of the best perfomiing
facilities would be the first 6 shaded rows. The average HAP emission rate for these 6 facilities
is 0.08 kg/L coating solids. Applying this level of control to Model Plant Number 1 would result
in an incremental HAP emission reduction of 250 kg. [MP #1 uses 5,000 liters oi coating solids:
at the proposed emission limit of 0.13 kg/L coating solids, HAP emissions are 5,000 * 0.13 - 650
kg; at an emission limit of 0.08 kg/L coating solids, HAP emissions are 5,000 * 0.08 - 400 kg]
For Model Plants 2 through 4, the incremental emission reductions are 1,250 kg, 5,000 kg, and
31,250 kg, respectively.
At the beyond the floor level considered here, the availability of complying coating
materials and cleaning materials that could be used without extensive process or equipment
modifications is expected to become a problem for many existing facilities. Because complying
materials that can be used with existing coating equipment may not be available, some facilities
may be faced with the possibility of being required to convert a liquid coating line to powder
coatings or to install add-on control devices to comply with the standards. While a detailed cost
analysis for this type of conversion or installation was not performed for our evaluation of the
beyond the floor option, it is expected that the cost effectiveness of requiring such steps would
not be acceptable. As an example of the range of cost effectiveness values that could be
expected, we projected the annual costs for converting Model Plants 2 and 3 to the use of powder
coatings. The costs for such a conversion were estimated from information gathered during the
5-8
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development of the NESHAP for the metal furniture source category. [2] The annual costs to
convert Model Plants 2 and 3 from liquid coating lines to powder coating lines were projected
from the costs developed to convert similar sized metal furniture model plants. For Model Plant
2, which uses 25,000 liters of coating solids per year, the annual cost for the conversion to
powder coatings was estimated to be $150,000. For Model Plant 3, which uses 100,000 liters of
coating solids, the annual cost was estimated to be $200,000. In order to project the highest
possible emission reduction values, and, thus, the "best-case" cost effectiveness values, it was
assumed that the two model plants converted all of their coatings to powder coatings and that
they also use zero-HAP cleaning and surface preperation materials. Therefore, for our example,
the emission rate for the models under our beyond the floor option would be zero. For Model
Plant 2, which could emit 3,250 kg of HAP under the floor level of control (25,000 liters of
coatings solids * 0.13 kg per liter of coating solids = 3,250 kg), the projected cost effectiveness is
$46,154 per Mg of HAP emissions reduced ($150,000 - 3,250 kg * 1,000 kg per Mg). For Model
Plant 3, which could emit 13,000 kg of HAP under the floor level of control (100,000 liters of
coating solids * 0.13 kg per liter of coating solids = 13,000 kg), the projected cost effectiveness
is $15,385 per Mg of HAP emissions reduced ($200,000 + 13,000 kg * 1,000 kg per Mg).
The analysis presented above indicates that the cost effectiveness values are better for the
larger facilities. While this may be true in some cases, it should be noted that in actual practice
many facilities, regardless of their size, are expected to be unable to use zero-HAP technology for
all their coating, cleaning, and surface preperation needs. Thus, the example presented above
overstates the potential emission reductions that would be expected if a level of control beyond
the MACT floor level were required. The cost effectiveness values projected here were not
considered to be reasonable, and a beyond the floor option was not selected.
A beyond the floor option for the new source standards was rejected because no options
were identified that were believed to be applicable to all segments of the source category. While
the floor level of control is believed to be achievable through the use of a combination of
available low-HAP liquid coatings and powder coatings, more stringent control levels would rely
on the use of increasing percentages of powder coatings. As discussed in previous sections,
powder coatings are not believed to be a technology that can be utilized for all coating needs in
all segments of the source category. For example, powder coatings may not be suitable for
products with narrow gaps between surfaces or deep recesses where powder may not penetrate or
5-9
-------
cover adequately. Thus, establishing beyond the floor standards that could be achieved only by
the near exclusive use of powder coatings could not be justified.
5-10
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TABLE 5-2. DEFAULT DENSITIES USED FOR UNIT CONVERSIONS
TYPE OF MATERIAL
Conventional Solvent Based Coatings
High Solids Solvent Based Coatings
Water Based Coatings
Powder Coatings
Cleaning Materials
Thinning Materials
DEFAULT DENSITY (GRAMS
PER LITER)
1,063
1,315
1,265
1,584
991
876
NOTES:
Information presented in this table was obtained from responses to the 1998 industry
questionnaire. Responses are located in Docket A-97-41, Category II-D.
Multiply grams per liter by 0.00835 to obtain pounds per gallon
5-14
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5.6 REFERENCES
1. G. Bocchi, The Powder Coating Institute. Products Finishing. "Powder Coating in the
Year 2000." July, 2000. 4 pp.
2. Memorandum from D. Hendricks, E/CR, Inc. to M. Serageldin, EPA:CCPG. "New
Source MACT Cost Impacts for Metal Furniture Surface Coating Source Category," July
10, 2000 (Revised November 16, 2000). Appendix A. Docket No. A-97-40, Item No. H-
A-5.
5-15
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6.0 ENVIRONMENTAL, HEALTH, AND ENERGY IMPACTS
This chapter presents the estimated HAP emission reductions and discusses the non-air
quality health and environmental impacts and energy requirements associated with implementing
the MACT level of control at existing and new facilities within the large appliances source
category. The projected HAP emission reductions were developed using a model plant approach
and were then scaled up to the expected number of affected facilities nationwide. The model
plants are defined in Chapter 4.0.
6.1 APPROACH TO ESTIMATING IMPACTS
The HAP emission reductions associated with implementing the MACT standard for the
large appliance industry were analyzed for each of the four model plants that were identified in
Chapter 4.0 and the memorandum entitled "Development of Model Plants for the Large
Appliances NESHAP Project (Docket No. A-97-41, Item No. H-B-6). The estimated HAP
emission reductions for each model plant were then multiplied by the number of existing
facilities represented by each model to project the impacts to a nationwide value. An example of
this calculation is included at the end of this Chapter.
Non-air quality health and environmental impacts and energy requirements resulting
from the implementation of the proposed standards were also considered. Sufficient information
was not available to allow these impacts to be quantified, but the potential impacts of proposed
standards are discussed below.
6.2 ESTIMATED HAP EMISSION REDUCTIONS
The estimated reduction in HAP emissions resulting from implementing the proposed
standards at existing facilities is presented in Table 6-1. Emission reductions for each of the
model plants were based on the existing source MACT floor of 0.134 kg HAP emitted per liter of
coating solids. Since the proposed standard is rounded to two significant figures, i.e., 0.13 kg
HAP emitted per liter of coating solids (1.1 Ibs per gal), the values presented in Table 6-1 slightly
underestimate the predicted nationwide emission reduction. According to Table 6-1, total
nationwide HAP emission reductions from implementing the MACT level of control at existing
facilities are estimated to be around 1,079,871 kg (2,381,113 Ibs) per year. This represents a 45
percent reduction in HAP emissions industrywide. In Table 6-1, each model plant was assumed
6-1
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to comply with the standard by converting to non-HAP surface preparation materials, cleaning
materials, and adhesives as well as reduced-HAP coatings and thinners.
It is projected that, even in the absence of the proposed NESHAP, most new sources will
use coating technologies that are considered to be "state-of-the-art" coatings (e.g., powder
coatings and low HAP liquid coatings). Powder coating technology has advanced rapidly in
recent years, and is gaining widespread acceptance in the large appliances industry. Powder
coatings are not only very cost effective, their use eliminates the problems associated with
worker exposure to organic solvents. Many of the facilities in the database indicated that they
were in the process of converting part or all of their coating operations to use powder coatings.
Table 6-2 contains a list of these facilities. For these reasons the baseline emission levels for
new sources are expected to be at, or below, the requirements in the proposed standards.
Therefore, no emission reductions beyond the baseline levels from new sources have been
attributed to the proposed standards.
6.3 NON-AIR QUALITY HEALTH AND ENVIRONMENTAL IMPACTS
The compliance options expected to be used by the large appliance industry for this
standard are not expected to create significant adverse environmental impacts. Coating material
reformulation is expected to be used by most facilities to reduce their emissions of hazardous air
pollutants (HAP) from their coating operations. The use of reformulated coating materials is
expected to result in the generation of equal, or smaller, amounts of solid waste, waste solvents,
and wastewater. In addition, the reformulated coating materials have the benefit of reduced
percentages of HAP in the wastes that are generated. The expected increase in the use of powder
coatings will result in a decrease in the generation of waste because most powder coating booths
utilize dry filters to collect overspray. The dry powder that is collected as overspray can often be
recycled, thus reducing the overall amount of waste material. Because of the many variables
involved, and the lack of specific information on the control approach that will be selected by the
affected sources, these impacts could not be quantified.
6.4 ENERGY REQUIREMENTS
6-2
-------
The impact of the standard on the amount of energy consumed by surface coating
operations within the affected industry could not be determined with the information available.
Energy consumed is extremely variable and depends on the type and formulation of coating
materials used, the film thickness needed for each product, the size and shape of the products
being coated, curing oven capacity and desired line speed, and the method of heating the curing
oven. Increases in energy consumption by the existing capture systems and add-on control
devices is also variable and depends on whether increased utilization of these devices will be a
part of the control strategy used by the facilities that have these devices. Because there is such a
range of factors, and because some compliance options may result in a decrease in energy
consumption (for example, high solids coatings may require less energy to cure than
conventional coatings), it was assumed that on a nationwide basis there would be no quantifiable
change in energy consumption as a result of the standard.
TABLE 6-1. SUMMARY OF ESTIMATED ENVIRONMENTAL IMPACTS
Model Plant 1
Model Plant 2
Model Plant 3
Model Plant 4
Baseline
Emission
Levels (kg)
3,887
15,234
29,436
125,235
Compliant
Emission
Levels (kg)
670
3,350
13,400
83,750
Emission
Reduction
(kg)
3,217
11,884
16,036
41,485
Number of
facilities
Nationwide
26
19
17
12
Nationwide
Nationwide
Emission
Reduction (kg)
83,642
225,796
272,612
497,820
1,079,871
6-3
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EXAMPLE OF HAP EMISSION REDUCTION CALCULATION
This example demonstrates the calculations performed to determine the HAP emission
reductions from Model Plant number 3.
• As shown in Table 4-5, Model Plant number 3 is representative of facilities that use from
50,001 and 200,000 liters of coating solids; the model plant uses 100,000 liters of
coating solids.
• At the baseline conditions Model Plant number 3 emits 29,436 kilograms of HAP (the
total from the column labeled "HAP" in Table 4-5.
The baseline emission rate for Model Plant number 3 is: 29,436 kg HAP -> 100,000 liters
of coating solids = 0.29436 kg HAP/liter of coating solids.
• Model Plant number 3 will need in this example to reduce its emission rate to a maximum
of 0.134 kg HAP/ liter of coating solids.
• At an emission rate of 0.134 kg HAP/liter of coating solids, and assuming the same
amount of coating solids will be used as under the baseline condition, Model Plant
number 3 will emit: 0.134 kg of HAP/liter of coating solids * 100,000 liters of coating
solids = 13,400 kilograms of HAP.
• The proposed standards result in a reduction of: 29,436 kg -13,400 kg = 16,036 kg of
HAP.
• Because this model plant is estimated to represent 17 existing facilities, the nationwide
HAP reduction for this segment of the source category is estimated to be: 16, 036 kg of
HAP * 17 facilities = 272,612 kilograms of HAP.
• This procedure was applied to each of the four model plants and the results are shown in
Table 6-1.
7.0 COST IMP ACTS
6-5
-------
This chapter presents the approach developed to estimate the cost impacts of
implementing the MACT level of control at existing and new large appliances surface coating
operations. The cost impacts were developed using a model plant approach and were then
projected to a nationwide number of facilities. The first section of this chapter describes the
approach that was used to estimate the compliance alternatives and the costing assumptions. The
second section presents the results of the cost analysis on a model plant and nationwide basis.
7.1 APPROACH TO ESTIMATING COSTS
The basic approach used to estimate the cost impacts of the standards was to predict the
method of compliance to be used by each model plant and the costs associated with that method.
The four model plants were developed to represent the range of facility sizes and coating,
thinning, and cleaning materials used throughout the industry. Tables 7-1 through 7-4 present the
model plant parameters as well as cost impact information.
Because an affected source-wide average HAP limit approach was selected for the
standard, there is a wide variety of actions that a facility could take to lower its HAP emissions
from coating-related operations to a compliant level. Reductions in the HAP contents of
adhesives, surface preparation materials, thinning solvents, and cleaning materials as well as the
coatings themselves, all contribute toward compliance. Converting from HAP-containing liquid
coatings to powder coatings can essentially eliminate HAP emissions from the coating operation.
Add-on control devices could be installed to reduce HAP emissions from selected exhaust gas
streams, such as a curing oven exhaust. (Thermal incinerators can achieve HAP reductions in
excess of ninety percent.) Various combinations of the actions outlined above can also be
implemented to achieve the necessary HAP emission reductions.
An analysis of the model plant parameters and information provided in the industry
responses to the 1997 and 1998 questionnaires (114 authority) led to the following selection of
compliance alternatives for performing the cost analysis.
It was estimated that no facility within the industry would install add-on control devices
as a result of the proposed standards. The capital costs and annual operating costs of add-on
7-1
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control devices usually make them less desirable than other compliance options for reducing
volatile organic emissions from coating operations. The responses to the industry questionnaires
included information on seven such devices located at only five out of the total of 222 facilities.
Two of these devices are used to reduce VOC emissions from the ovens on spray application
operations, and five of the devices are used on dip coating operations. Dip coating operations
lend themselves to add-on control because they generally have configurations that facilitate the
use of capture systems. Even though these facilities may consider the devices' HAP emission
reductions when determining compliance with the proposed standards, no additional cost was
attributed to them in our analysis because they would be operated even in the absence of the
proposed standards.
Conversion of a liquid coating line to powder coating was also not expected to be a
desirable option for the two smallest model plants. While case studies indicate that powder
coatings are very cost effective for facilities that apply large volumes of coatings, the initial
investment required to convert to powder could discourage smaller coating operations from
selecting this option. The two larger model plants currently use both liquid and powder coatings
and, therefore, a possible option would be to reduce the use of liquid coatings and apply powder
to a larger percentage of their products using existing powder coating capacity. For example,
model plant number 4 could achieve compliance with the standard by switching about 60 percent
of the current coating solids usage from solvent based coatings (and associated thinners) to
powder coatings. For this analysis, it was assumed that the MACT level of control for the final
standard will be 0.13 kilograms of HAP emitted per liter of coating solids used.
For the reasons presented above, the option that would most likely be selected by most
facilities within the industry is the use of a combination of lower HAP liquid coatings and non-
HAP adhesives, surface preparation materials, and cleaning materials. It was also assumed that
the use ©flower HAP coatings would be accompanied by the use of lower HAP coating thinners.
Because the compliance option expected to be used by most facilities to comply with the
standard utilizes reformulated raw materials rather than a different coating technology or add-on
controls, no capital costs were estimated. Some facilities will, no doubt, encounter up-front costs
during a materials conversion. Some facilities may need to upgrade application equipment to be
7-2
-------
able to apply reformulated lower HAP coatings that may have a higher viscosity. These costs
will be site specific, however, and will most likely be offset by increased efficiencies of the new
equipment and by reductions in the cost of handling and disposal of HAP-containing wastes.
The impacts of variables such as shelf life of coatings, curing requirements, or spray booth
ventilation rates could also be positive or negative depending on the specific facility being
evaluated. No cost information was available for these variables. It should also be noted that
there will be some cost incurred for testing or qualifying new coating materials. These costs are
also very site specific depending on the products manufactured, the relative usage of each type of
material, and the availability of demonstrated reformulated materials.
For liquid coatings there exists a wide range of HAP contents, coating solids contents,
and prices. Because of the variability from one facility to another regarding coating needs, it was
not possible to estimate each of the variables that must be considered to determine the increase or
decrease in costs that would be encountered in converting to a lower HAP coating. Several
contacts were made with industry representatives in an attempt to obtain data on the relative costs
of lower HAP coatings versus higher HAP coatings (Docket Item No.n-E-12). Most of these
contacts did not result in useful cost data. Because the cost of coatings is usually compared in
terms of coating solids content ($/L coating solids) or actual coverage capability ($/sq m), we
found that cost data was not readily available in terms of HAP content. An assumption was
made, therefore, that it was reasonable to expect that the higher percentage of solvent in a low
solids coating would result in a corresponding higher percentage of HAP. Likewise, the lower
percentage of solvent in a high solids coating would result in a lower percentage of HAP. This
assumption correlating high solids to lower-HAP and low solids to higher-HAP allowed us to use
available data comparing the costs of low solids and high solids coatings. In an article appearing
in Products Finishing Magazine, the costs of high solids coatings were reported to be about 30
percent less than the costs of low solids coatings [1]. One industry representative supplied
information indicating that the costs of their new high solids coatings are about 10 percent higher
than the costs of low solids coatings [2]. Information from a third source indicated practically no
difference in the costs between low solids and high solids coatings [3]. Because of the many site
specific variables, and the lack of a trend in the cost information available, it was assumed that
7-3
-------
overall there would be no change in annual costs for coatings and, therefore, no cost was
estimated for this analysis. It is likely, however, that the annual costs of coatings will increase
for some facilities, will remain about the same for many facilities, and may decrease for some
when the reformulation to lower HAP coatings is accompanied by an increase in coating solids
content (and thus, greater coverage and less waste per a given volume).
For adhesives, as for other coatings, no change in costs was predicted for converting to
non-HAP materials. Individual facilities may experience cost increases or decreases depending
on the types and quantities of adhesives used. A telephone survey of several adhesives
manufacturers conducted during the development of the NESHAP for the Plastic Parts and
Products Surface Coating Source Category resulted in the collection of cost and HAP data for
seventeen different adhesives. The data showed no clear relationship between the costs of the
adhesives and the HAP content, and it was assumed that reformulating to non-HAP adhesives in
large appliances would result in no additional costs [4].
The surface preparation materials, thinning solvents, and cleaning materials used by the
large appliances surface coating industry in 1997 were evaluated to determine the constituent
compositions and the amount of product used. Xylene is a commonly used, inexpensive HAP
surface preparation/thinning/cleaning product and isopropyl alcohol is a commonly used, and
much more expensive, non-HAP solvent. The cost of non-HAP alternative solvents such as
isopropyl alcohol and acetone was estimated to be one hundred percent higher than the cost of
higher-HAP solvents. A summary of cost information for xylene and isopropyl alcohol is
presented in Docket Item n-B-12. The selection of acceptable non-HAP alternative solvents will
be a case-by-case decision to be made by each facility, and the comparison of xylene to isopropyl
alcohol is used here only for the purpose of establishing a cost differential. Many types of
solvent blends, which have much reduced levels of HAP, may also be acceptable substitutes and
may cost less than the non-HAP materials. The one hundred percent increase in cost for these
materials is believed to be a conservative (worst-case) assumption, however, and also does not
consider the savings that could result from current waste solvent disposal costs [5].
For new sources it is projected that most, if not all, will use coating technologies that are
considered to be "state-of-the-art" coatings (e.g., powder coatings and low HAP liquid coatings)
7-4
-------
even in the absence of the proposed standards. Powder coating technology has advanced rapidly
in recent years, and is gaining widespread acceptance in the large appliances industry. Powder
coatings are not only very cost effective, their use eliminates the problems associated with
worker exposure to organic solvents. Many of the facilities in the database indicated that they
were in the process of converting part or all of their coating operations to use powder coatings.
Also, four of the most recently constructed facilities in the database are using powder coatings
extensively. Therefore, the baseline condition for new facilities is expected be the use of powder
and low HAP liquid coatings and no compliance costs beyond the baseline levels from new
sources have been attributed to the proposed standards [6]. New facilities are, however, expected
to incur monitoring, recordkeeping, and reporting costs and these have been included in the
analysis.
7.2 ESTIMATED COST IMPACTS
Tables 7-1 through 7-4 present the model plants and the estimated cost that each would
incur as a result of complying with the standard. Each model plant would comply with the
standards by switching to non-HAP adhesives, surface preparation materials, and cleaning
materials and reducing the HAP content of the coating materials and thinners to meet the
emission limit of 0.13 kg HAP per liter of coating solids. The percentage HAP reduction varies
from about 35 percent for model plant 4, which already uses a great deal of powder coatings, to
about 83 percent for model plant 1, which uses mostly solvent based coatings. [For model plant
1, current emissions of 3,887 kg of HAP are reduced to a complying level of 650 kg of HAP:
((3,887- 650) -s- 3,887) * 100 = 83 percent.] As shown in Table 7-5, the total nationwide annual
cost of complying with the standard is estimated to be approximately $476,000, the sum of the
costs for each of the four industry segments.
In addition to the costs associated with complying with the proposed HAP emissions
limitation, affected facilities will incur costs associated with the monitoring, recordkeeping, and
reporting (MR&R) requirements of the proposed standards. The MR&R costs were developed
for the first five years after proposal, and are summarized in Table 7-6 [7]. Costs were developed
for existing affected facilities and for an estimated four new sources each year after the proposed
7-5
-------
standards become final. All existing sources were assumed to come into compliance at the end
of the three-year compliance period in the proposed standards. New sources are assumed to
comply when initial operation begins.
Table 7-7 presents a summary of the estimated nationwide costs for the proposed
standards, including the costs to comply with the HAP emissions limit and the monitoring,
recordkeeping, and reporting requirements. The fifth-year nationwide total cost is projected to be
approximately $2 million.
7-6
-------
7.3 REFERENCES
1. G. Bocchi, The Powder Coating Institute. Products Finishing. "Powder Coating
Advantages." June 1997. 5 pp.
2. Telecon from K. Maw, PES, Inc., to B. Vogt, Whirlpool. Discussion of costs of lower
HAP coatings and thinners. July 29, 1999. 1 p. Docket No. A-97-41, Item No. H-E-10.
3. Facsimile from C. Profilet, Thermal Engineering Corporation, to J. Paumier, PES, Inc.
Information on costs and emissions for coatings and two spreadsheets dated January 18
and 27, 1997. 4pp. Docket No. A-97-41, Item No. H-D-433.
4. Letter from K. Teal, EPArCCPG, to M. Serageldin, EPA:CCPG. Adhesive Cost
Information Prepared for the Plastic Parts and Products Surface Coating NESHAP.
December 5, 2000. Docket No. A-97-41, Item No. H.-B-13.
5. Alternative Control Techniques Document - Industrial Cleaning Solvents. EPA-453/R-
94-015. U.S. Environmental Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, North Carolina, February 1994, pp. 5-8 and 5-9.
6. Memorandum from C. Hester and K. Maw, PES, Inc., to M. Serageldin, EPA:CCPG.
"Projected Number of New Sources and Impacts of the Proposed Standards," October 2,
2000. Docket No. A-97-41, Item No. H-B-10.
7. OMB 83-1 and Supporting Statement for the Large Appliances Surface Coating
Operations NESHAP. EPA Tracking Number 1954.01. Docket No. A-97-41, Item No.
H-F-1.
7-7
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TABLE 7-5. SUMMARY OF COST IMPACTS FOR EXISTING SOURCES
Model Plant 1
Model Plant 2
Model Plant 3
Model Plant 4
Annual Cost ($)
731
2,332
6,023
25,899
TOTAL
Number of Facilities
26
19
17
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Nationwide Costs ($)
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44,308
102,391
310,788
476,493
7-12
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COSTS ($)
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153,861
674,852
1,909,538
1,971,938
991,957
7-14
-------
ECONOMIC IMPACT ANALYSIS: LARGE APPLIANCE COATING
THE FULL TEXT OF THE ECONOMIC IMPACT ANALYSIS IS LOCATED IN THE DOCKET FOR
THE PROPOSED STANDARDS (DOCKET NUMBER A-97-41, ITEM NUMBER II-A-4).
8-1
-------
APPENDIX A
A-l
-------
TABLE A-1. LARGE APPLIANCE POTENTIAL MAJOR AND
SYNTHETIC MINOR FACILITIES
Facility
City
State
Major Sources
Amana Appliances
Amtrol, Inc.
Beam Industries
Behr Climate Systems, Inc.
Beverage- Air
Bristol Compressors
Bristol Compressors - Sparta
Broan Mfg.
Buffalo Air Handling Company
Carrier Corporation
Copeland
Evapco, Inc. - Midwest
Fedders Corp.
Friedrich Air Conditioning Company
Frigidaire Commercial Products
Frigidaire Home Products
Frigidaire Home Products
Frigidaire Home Products, Laundry
Division
GE Appliances
Goodman Manufacturing Co. LP
Heatcraft Inc. OEM Plant
riussmann Atlanta Custom Systems
In-Sink-Erator
international Comfort Products
Corporation
International Comfort Products
Corporation
Cysor Warrren
^ennox Industries Inc.
Marvel Industries
Searcy
West Warwick
Webster City
Ft. Worth
Spartanburg
Bristol
Sparta
Hartford
Amherst
Collierville
Sidney
Greenup
Effingham
San Antonio
Conway
Edison
Springfield
Webster City
Louisville
Houston
Grenada
Norcross
Racine
Lewisburg
Lewisburg
Conyers
Marshalltown
Richmond
AR
RI
IA
TX
SC
VA
NC
WI
VA
TN
OH
IL
IL
TX
AR
NJ
TN
IA
KY
TX
MS
GA
WI
TN
TN
GA
IA
IN
A-2
-------
TABLE A-l. LARGE APPLIANCE POTENTIAL MAJOR AND
SYNTHETIC MINOR FACILITIES (Continued)
Facility
Matsushita Compressor Corporation of
America
Matsushita Home Appliance Corporation
of America
Matsushita Refrigeration Company of
America
Maytag Appliances - Newton Laundry
Products-Plant 2
Maytag- GRP
Maytag Herrin Laundry Products
McQuay International, Inc.
MIDCO International Incorporated
Osmonics, Incorporated
Pitco Frialator, Inc.
Porcelain Metals Corporation
Rheem Manufacturing Company
Scotsman Ice Systems-Fairfax
Operations
Sharp Manufacturing Company
State Industries, Inc.
Taylor Company
Tennant Company
The Amana Company, L. P.
The Ducane Co.
The Trane Company
The Trane Company
The Trane Company
The Trane Company
The Trane Company
Thermal Engineering Corporation
Toastmaster Inc.
Toastmaster Inc.
Tyler Refrigeration Corp., Niles Case
Plant
City
Mooresville
Danville
Vonore
Newton
Galesburg
Herrin
Verona
Chicago
Minnetonka
Bow
Louisville
Montgomery
Fairfax
Memphis
Ashland City
Rockton
Minneapolis
Amana
Blackville
Clarksville
Fort Smith
La Crosse
Trenton
Charlotte
Columbia
Macon
Boonville
Niles
State
NC
KY
TN
IA
IL
IL
VA
IL
MN
NH
KY
AL
SC
AL
TN
IL
MN
IA
SC
TN
AR
WI
NJ
NC
SC
MO
MO
MI
A-3
-------
TABLE A-l. LARGE APPLIANCE POTENTIAL MAJOR AND
SYNTHETIC MINOR FACILITIES (Continued)
Facility
Tyler Refrigeration Corp., Waxahachie
Case Plant
U.S. Filter / IWT
Vilter Manufacturing Corporation
West Bend Company
Whirlpool Corporation
Whirlpool Corporation
Whirlpool Corporation - Findlay
Division
Whirlpool Corporation - Marion Division
Whirlpool Corporation-Clyde Division
Whirlpool Corporation-Fort Smith
Arkansas Division
York International - Frick
York International - Grantley
York International - Reco
York International - Tempmaster
City
Waxahachie
Rockford
Cudhay
West Bend
LaVergne
Evansville
Findlay
Marion
Clyde
Fort Smith
Waynesboro
York
San Antonio
Albany
State
TX
IL
WI
WI
TN
IN
OH
OH
OH
AR
PA
PA
TX
MO
Synthetic Minor Sources
A.O. Smith Water Products Company
Addison Products Company
ALTO U.S. Inc. American-Lincoln
Technology
Bard Manufacturing Company
Brown Stove Works, Inc.
Carrier Corporation
Carrier Corporation, McMinnville
Copeland Rushville
Dunham Bush Inc
Frigidaire Home Products-Dishwasher
Prod.
ieatcraft Inc.
lill Phoenix, Inc.
iussmann Corporation
McBee
Orlando
Bowling Green
Bryan
Cleveland
Syracuse
Morrison
Rushville
Harrisonburg
Kinston
Danvilee
Colonial Heights
Bridgeton
SC
FL
OH
OH
TN
NY
TN
IN
VA
NC
IL
VA
MO
A-4
-------
TABLE A-l. LARGE APPLIANCE POTENTIAL MAJOR AND
SYNTHETIC MINOR FACILITIES (Continued)
Facility
Dvll Cornelius, Inc.
Maytag Cleveland Cooking Products
PMI Food Equipment Group/Hobart
RAE Corporation
Sub Zero Freezer Co., Inc.
Sub Zero Freezer Co., Inc.
Tecumseh Products Division
The Trane Company
The Trane Company
The Trane Company
The Trane Company
York International - Pace
City
Anoka
Cleveland
Hillsboro
Pryor
Phoenix
Madison
Tecumseh
Lexington
Macon
Macon
Pueblo
Portland
State
MN
TN
OH
OK
AZ
WI
MI
KY
GA
GA
CO
OR
A-5
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-------
CONVERSION FACTORS FOR METRIC UNITS
Metric units may be converted to common English units by using the following conversion factors:
Metric Unit
1m
2.54 cm
0.0283 m3
liter
dscm
scmm
kg
Mg
Mg
metric ton
1m3
3.785 liters
1.054U
1.054X106kJ
3514J/S
16.02kg/m3
Metric Name
meter
centimeter
cubic meter
liter
dry standard cubic meter
standard cubic meters per minute
kilogram (103 grams)
megagram (106 grams)
megagram (106 grams)
metric ton (106 grams)
cubic meter
liters
kilojoule
kilojoule
Joules per second
kilograms per cubic meter
Equivalent English Unit
3.2808 ft (feet)
1 in. (inch)
1 ft3 (cubic foot)
0.0353 ft3
35.31 dry standard ft3
35.31 rWmin
2.2046 Ib (pound)
2,204.6 Ib
1.102 English tons
2,204.6 Ib
264.17 gallons
1 gallon
1 Btu (British Thermal Unit)
MMBtu
1 ton (or 12,000 Btu/hr)
1 lb/ft3 (pounds/cubic foot)
T (°F) = temperature in degrees Fahrenheit
Temperature in degrees Celsius (°C) can be converted to temperature in degrees Fahrenheit (°F) by the
following formula:
T(°F) =1.8T(°C) + 32
T (°C) = temperature in degrees Celsius or degrees Centigrade
Temperature in degrees Fahrenheit (°F) can be converted to temperature in degrees Celsius (°C) by the
following formula:
T(°C) =[T(°F)-32]/1.8
A-13
-------
3 TRAVEL AUTHORIZATION CODE
EPA
United States
Environmental Protection Agency
New
TRAVEL AUTHORIZATION (Note. If this is Permanent Change of Station travel, EPA Form 2610-1A must be attached)
T 4212566
2 SOCIAL SECURITY NUMBER
111-62-0815
6 DATE 03/01/2001
RAVEL AUTHORIZATION TYPE
5 TYPE OF TRAVEL BY NON-EPA TRAVELER
Domestic
Foreign
INVITATIONAL
INTERGOVERNMENTAL PERSONNEL ACT (IPA)
7 APPLICABLE REGULATIONS
HFTRs
8B T|TLE tnvironmental hngineer
MAME
MOHAMfcU A. SERAGELDIN
OFFICIAL STATION
RTP, NC
8D ORGANIZATION UAUKb/tbU/UGHU (MU-1J)
10 TRIP INFORMATION
IP1
IP 2
iFT
A FROM • DATES - TO
B DESTINATION
MO DA YR
03/T472D01
MO DA YR
03/15/2001
Nil
GRAND RAPIDS
C PURPOSE
CODE
FINERARY AND OTHER DETAILS
D PURPOSE OF TRIP
To provide an explanation of the provision
in the metal furniture regulation, and
present an overview of the the MACT
Standards.
:OST ESTIMATES FOR AUTHORIZED ALLOWANCES
(PER DIEM AND SUBSISTENCE)
^""^JBJcC
TOTAL COST ESTIMATES BY
CATEGORY
<\1 PER DIEM
$34.00
PLUS AVERAGE COST OF LODGING NOT TO EXCEED >
$96.00
AMOUNT
A2 ACTUAL SUBSISTENCE NOT TO EXCEED
A3 ACTUAL SUBSISTENCE GSA HRGA-
AREA
(A) 2111
2121
$34.00
(OTHER ALLOWANCES)
B1 COMMON CARRIER-AIR
B2 COMMON CARRIER-TRAIN, BUS, SHIP
33 FIRST CLASS COMMON CARRIER
B4 EXCESS BAGGAGE —-
LBS |
(B) 2113
2123
542.81
C1 INTRACITY TRANSPORTATION (Taxi, limousine, bus, POV) AND OTHER INCIDENTAL COSTS
(C) 21M
2127
75.00
D1 PRIVATELY OWNED VEHICLE (POV) (Auto, plane, etc)
40
RATE (Cents/mile - Justification Req'd)
|$.34.5
(D) 2114
2124
13.80
E1 GSA CONTRACT RENTAL - BOAC #
INTERCITY - TEMPORARY DUTY
E2 COMMERCIAL CAR RENTAL
- INTERCITY - TEMPORARY DUTY
(E) 2115
2125
:1 GOVERNMENT-OWNED (GSA) RENTAL - BOAC #
INTERCITY TEMPORARY DUTY
G1 REGISTRATION FEES
.DVANCE OF FUNDS APPLICATION (Note Outstanding advances must be liquidated within
0 days of completion of trip When travel is canceled or indefinitely postponed, the amount of
•ny outstanding advances must be repaid immediately Unliquidated advances are subject to
utomatic payroll deductions)
Total A1 through G1 (above)
665.61
Total H1 through L1 (Form 2610-1 A)
Grand Total
TOTAL
$665.61
YPE
ORDINARY
CONTINUING
B METHOD
OF
PAYMENT
CASH
CHECK
- ATM
C MAIL CHECK TO
ADDRESS
- OFFICE - HOME DIRECT DEPOSIT OFFICE PHONE->| (919)541-2379
E SIGNATURE OF APPLICANT
ASH RECEIVED BY
G DATE CASH RECEIVED
13 TO BE COMPLETED BY SERVICING FINANCE OFFICE
SIGNATURE (And reason for disapproval, if so checked)
14. Authorization
RECOMMENDING OFFICER
AUTHORIZATION OFFICER
: ANU 111 Lb (lypea or electronically enrereoy
)ianne M. Byrne,Group Leader, CCPG
Authority is granted to travel and incur such expenses as may be necessary tor this authorization
in accordance with EPA policy and applicable regulations I certify that this trip is essential to the
Agency's mission
NAMt ANU 111 Lt (lyped or electronically entereo)
Sally L. Shaver, Director, ESD
SIGNATURE
15 Financial and Accounting Data
DCN
(Max 11)
Budget/FYs
(Max 4)
Appropriation Code
(Max 6)
Budget Org/Code
(Max 7)
PRC
(Max 9)
Object Class
(Max 4)
SFO
1
2
3
:v
01/02
01/02
01/02
B
B
B
53C1
: 53C1
: 53C1
10204A
10204A
10204A
2111
2113
2117
Amount (Dollars) (Cents)
Sites/Project
(Max 6)
Cost Org/Code
(Max 7)
(Max 2)
1
2
3
$34|00
$542|81
$75(00
Prepared by.
Bertha M Joseph
(919)541-1546
'A Form 2610-1 (Rev 9-98/3-99) Electronic and Paper versions acceptable
BVIOUS editions are obsolete
RTP Optional
-------
3^ EPA
United States
Environmental Protection Agency
Washington, DC 20460
Financial and Accounting Data Continuation Sheet
ntinuation of Form Number: Date o
EPA-2610-1
DCN Budget/FYs
(Max 1 1 ) (Max 4)
1
2
3
x:: 01/20 Xv
.".*•" *•*.'
: Primary Form'
03/01/2001
Appropriation Code
(Max 6)
B Xv
Sites/Project
Amount (Dollars (Cents) (Max 8)
1
2
3
$13)80
DCN Budget/FYs
(Max 11) (Max 4)
4
5
6
.;.;.;
•X*
Appropriation Code
(Max 6)
Sites/Project
Amount (Dollars) (Cents) (Max 8)
4
5
6
DCN Budget/FYs
(Max 11) (Max 4)
7
8
9
•X- •'.•'.•
•'.•'.• •'.•'.•
Appropriation Code
(Max 6)
Sites/Project
Amount (Dollars) (Cents) (Max 8)
7
8
9
DCN Budget/FYs
(Max 11) (Max 4)
10
11
12
Appropriation Code
(Max 6)
Social Security Number:
111-62-0815
DCN
Budget Org/Code PRC Object Class oer»
(Max 7) (Max 9) (Max 4) SFO
53C1
Xv 10204A Xv 2
.;.;. .;.;.
•X- •'.•'.•
114 •)-)
(Max 2)
Cost Org/Code
(Max 7)
Budget Org/Code PRC Object Class
(Max 7) (Max 9) (Max 4)
Cost Org/Code
(Max 7)
:X:
Budget Org/Code PRC Object Class
(Max 7) (Max 9) (Max 4)
'."•" *i*.*
Cost Org/Code
(Max 7)
:X:
::x
Budget Org/Code PRC Object Class
(Max 7) (Max 9) (Max 4)
Sites/Project Cost Org/Code
Amount (Dollars) (Cents) (Max 8) (Max 7)
10
11
12
DCN Budget/FYs
(Max 11) (Max 4)
13
14
1J>
X •!•
Appropriation Code
(Max 6)
•:•::
Budget Org/Code PRC Object Class
(Max 7) (Max 9) (Max 4)
; X ! X
Sites/Project Cost Org/Code
Amount (Dollars) (Cents) (Max 8) (Max 7)
13
14
16
I
nited States of America by (S gnature)
Typed Name and Title of Contracting Officer
:>A Form 2550-23 (Rev. 12-99)
(RTF Optional)
-------
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, II 60604-3590
------- |