Un/tod State*
Environ
Agency
Offlc* of Air Quality
Planning and Standard*
R*»*arGh Triangle Park NC 27711
EPA 4S3/R-94-032
April 1994
Air
Alternative Control
Techniques Document:
Surface Coating Operations at
Shipbuilding and Ship Repair Facilities
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NOTICE
There are no planned changes to this document. However,
corrections or- updates sometimes become necessary. Submission of
a copy of the form below will insure you receive any supplement or
change to this report that is published in the next twelve months.
Comments may be sent to the same address.
TO: Emission Standards Division
MD-13
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Attention: Dr. Serageldin
Please forward any supplement or change to EPA Report Number
EPA/450/R-94-032, "Alternative Control Techniques Document:
Surface Coatings Operations at Shipbuilding and Ship Repair
Facilities" to the address below.
U.S. Env::-o— ' ' - --ruction Agency
Region 5, Li:,. ,_ .. <2j)
77 West Jackson Loui^vard l?th n
Chicago, IL 60604-3590 ' F1°°r
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EPA 453/R-94-032
Alternative Control Techniques Document:
Surface Coating Operations at Shipbuilding
and Ship Repair Facilities
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
April 1994
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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.
Copies of this report are available through the Library Services
Offices (MD-35), U. S. Environmental Protection Agency, Research
Triangle Park, N.C. 27711, Technology Transfer Network (TTN) under
the Clean Air Act Amendments Main Menu, Title 1, Policy and
Guidance or from National Technical Information Services, 5285 Port
Royal Road, Springfield, Virginia 22161 [800] 553-NTIS.
11
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TABLE OF CONTENTS
1.0
2.0
3.0
SUMMARY
INDUSTRY DESCRIPTION
2.1 GENERAL
2.2 PROCESS AND EQUIPMENT
2.2.1 Marine paints
2.2.2 Thinning Solvents
2.2.3 Cleaning Solvents
2.2.4 Abrasive Blasting
2.3 BASELINE EMISSIONS
2.3.1 VOC Emissions
2.3.2 PM - 10 Emissions
2.4 EXISTING REGULATIONS
2.4.1 Requirements of the Clean Air ACT
Amendments of 1990
2.4.2 Summary of Existing Regulations ....
2.5 REFERENCES
EMISSION CONTROL TECHNIQUES
3.1 INTRODUCTION
3.2 PAINTING OPERATIONS
3.2.1 Lower VOC Coatings
3.2.2 Paint Heating Systems
3.2.3 VOC Add-On Controls
3.2.4 Potential Emission Reductions
3.3 SOLVENT CLEANING
3.3.1 Cleaning Practice Modifications ....
3.3.2 Substitute Solvents in Cleaning
Materials
3.3.3 Potential Emission Reductions
3.4 ABRASIVE BLASTING OPERATIONS
3.4.1 PM-10 Control Techniques
3.4.2 Potential PM-10 Emission Reductions . .
Page
1.1
2*.l
2.1
2.6
2.9
2.27
2.27
2.30
2.35
2.35
2.42
2.44
2.44
2.48
2.57
3.1
3.1
3.1
3.2
3.2
3.3
3.4
3.5
3.6
3.6
3.6
3.7
3.7
3.17
111
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TABLE OF CONTENTS (cont.)
3.5 QUALITY CONTROL .. . . 3.18
3.5.1 Minimizing Air Exposures 3.18
3.5.2 Limiting Rework 3.18
3.5.3 Suspending Painting and Blasting
Activities 3.18
3.6 REFERENCES 3.19
4.0 MODEL SHIPYARDS AND EMISSION ESTIMATES 4.1
4.1 MODEL SHIPYARDS 4.2
4.1.1 Description of Model Yards 4.2
4.1.2 Model Yard Sizes ., 4.2
4.1.3 Model yard parameters 4.5
4.1.4 Relative usages 4.6
4.1.5 Average VOC Contents 4.6
4.2 VOC AND PM-10 EMISSION ESTIMATES 4.6
4.2.1 VOC Emission Estimates 4.8
4.2.2 PM-10 Emissions From Abrasive Blast
Media 4.8
4.3 REFERENCES 4.10
5.0 COST AND ENVIRONMENTAL AND ENERGY IMPACTS 5.1
5.1 COST OF LOWER-VOC COATINGS FOR SHIPYARD
COATING OPERATIONS 5.1
5.1.1 Lower VOC Control Options 5.2
5.1.2 Assumptions and Scenarios Evaluated . . 5.4
5.1.3 Results of the Analysis 5.8
5.1.4 Record Keeping and Reporting
Requirements 5.19
5.2 SPRAY BOOTH CONTROLS 5.28
5.2.1 Spray Booth Analysis—Development of
Inputs 5.28
5.2.2 Total VOC Emitted from Spray Booths . . 5.33
5.2.3 Spray Booth Add-on Control Analysis
Results 5.33
IV
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TABLE OF CONTENTS (cont.)
5.3 TANK PAINTING—USE OF ADD-ON CONTROL 5.35
5.3.1 Feasibility of Add-On Controls for
Tank Painting Operations 5.35
5.3.2 Assumptions and inputs to the
Analysis 5.37
5.3.3 Results of Tank Painting Add-On
Control Analysis 5.38
5.4 COST OF CONTROL OPTIONS FOR PM-10 EMISSIONS
FROM ABRASIVE BLASTING OPERATIONS 5.40
5.5 CLEANING CONTROL COSTS 5.40
5.6 ENVIRONMENTAL ENERGY, AND OTHER COSTS 5.41
x>
5.6.1 Environmental Impacts 5.41
5.6.2 Energy Impacts 5.43
5.6.3 Other Environmental Impacts 5.46
5.7 REFERENCES 5.46
6.0 FACTORS TO CONSIDER IN DEVELOPING BEST AVAILABLE
CONTROL MEASURES (BACM) 6.1
6.1 BACKGROUND 6.2
6.2 DEFINITIONS 6.2
6.3 APPLICABILITY 6.2
6.4 FORMAT OF THE STANDARD 6.3
6.4.1 Concentration Limit 6.3
6.4.2 Equipment Standard. . . 6.3
6.4.3 Percent Reduction 6.3
6.5 EMISSIONS REDUCTION AND COST 6.4
6.6 ADDITIONAL FACTORS TO BE CONSIDERED 6.4
6.7 TEST PROCEDURES 6.6
6.8 REPORTING AND RECORD KEEPING 6.6
6.9 REFERENCES 6.7
App. A Short List of Definitions A.I
App. B Emission estimation B.I
App. C Cost Analysis C.I
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LIST OF TABLES
Table 1-1.
Table 2-1.
TABLE 2-2.
TABLE 2-3.
TABLE 2-4.
TABLE 2-5.
TABLE 2-6.
TABLE 2-7.
TABLE 2-8.
TABLE 2-9.
TABLE 2-10
TABLE 2-11
TABLE 2-12
TABLE 2-13
TABLE 2-14
TABLE 3-1.
TABLE 4-1.
TABLE 4-2.
TABLE 4-3.
VOC CONTENT LIMITS FOR SHIPBUILDING
COATING .
U.S. SHIPYARD LOCATIONS
AREAS OF APPLICATION FOR MARINE PAINTS
(RESIN TYPES)
MARINE COATING (RESIN) TYPES
TYPICAL SOLVENTS USED IN MARINE
PAINTS
ADVANTAGES AND DISADVANTAGES OF SPRAY
PAINT APPLICATION METHOD .
SOLVENT USAGE BREAKDOWN
MEDIA COMMONLY USED IN ABRASIVE
BLASTING
COMPOSITIONS OF BLAST MEDIA
AVERAGE VOC CONTENT OF "AS SUPPLIED
PAINT" .
SUMMARY OF TEST DATA FOR UNCONTROLLED
ABRASIVE BLASTING OPERATIONS . . . .
1990 CLEAN AIR ACT AMENDMENT ATTAINTMENT
DATES FOR PRIMARY STANDARD
SUMMARY OF EXISTING REGULATIONS
STATE VOC LIMIT COMPARISON . .
ABRASIVE CERTIFIED BY GARB . .
SUMMARY OF ABRASIVE BLASTING CONTROL
OPTIONS
SHIPYARDS SURVEY RESPONSES USED FOR
MODEL YARD DEVELOPMENT
MODEL SHIPYARDS
RELATIVE USAGES
Page
1-6
2-4
2-10
2-11
2-18
2-28
2-30
2-33
2-33
2-41
2-43
2-46
2-49
2-51
2-54
3-8
4-3
4-4
4-7
VI
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LIST OF TABLES (cont.)
TABLE '
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
4-4.
4-5.
5-1.
5-2.
5-3a.
5-3b.
5-4.
5-5a.
5-5b.
5-6.
5-7a.
5-7b.
5-8.
5-9.
5-10
5-lla
5-llb
5-llc
AVERAGE VOC CONTENTS
VOC EMISSION ESTIMATES FOR MODEL
SHIPYARDS
OPTIONS BASED ON USING LOWER-VOC
COATINGS
COATING PARAMETERS
EMISSION REDUCTIONS FOR LOWER-VOC
SCENARIO 1 (METRIC UNITS)
EMISSION REDUCTIONS FOR LOWER-VOC
SCENARIO 1 (ENGLISH UNITS)
COSTS FOR LOWER-VOC SCENARIO 1
EMISSION REDUCTIONS FOR LOWER-VOC
SCENARIO 2 (METRIC UNITS)
EMISSION REDUCTIONS FOR LOWER-VOC
SCENARIO 1 (ENGLISH UNITS)
COSTS FOR LOWER-VOC SCENARIO 2
EMISSION REDUCTIONS FOR LOWER-VOC
SCENARIO 3 (METRIC UNITS)
EMISSION REDUCTIONS FOR LOWER-VOC
SCENARIO 1 (ENGLISH UNITS)
COSTS FOR LOWER-VOC SCENARIO 3
RECORDKEEPING AND REPORTING COSTS . . .
HOUR AND LABOR RATES FOR RECORDKEEPING
AND REPORTING
COST EFFECTIVENESS FOR LOWER-VOC
SCENARIO l(a)
COST EFFECTIVENESS FOR LOWER-VOC
SCENARIO 2 (a)
COST EFFECTIVENESS FOR LOWER-VOC
SCENARIO 3 (a)
. . 4-7
. . 4-9
. . 5-2
. . 5-6
. . 5-9
. . 5-10
. . 5-11
. . 5-12
. . 5-13
. . 5-14
. . 5-15
. . 5-16
. . 5-17
. . 5-22
. . 5-23
. . 5-24
. . 5-25
. . 5-26
Vll
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LIST OF TABLES (cont.)
TABLE 5-12 GENERAL DESIGN SPECIFICATIONS FOR
ADD-ON CONTROLS 5-30-
TABLE 5-13 SPRAY BOOTH ADD-ON CONTROL COSTS 5-34
TABLE 5-14a COST EFFECTIVENESS OF TANK ADD-ON
CONTROL (METRIC UNITS) 5-39
TABLE 5-14b COST EFFECTIVENESS OF TANK ADD-ON
CONTROL (ENGLISH UNITS) 5-39
TABLE 5-15a NATURAL GAS USE FROM THERMAL RECUPERATIVE
INCINERATION FOR SPRAY BOOTH PAINTING
OPERATIONS (METRIC UNITS) 5-41
x»
TABLE 5-15b NATURAL GAS USE FROM THERMAL RECUPERATIVE
INCINERATION FOR SPRAY BOOTH PAINTING
OPERATIONS (ENGLISH UNITS) 5-41
TABLE 5-16a ELECTRICITY REQUIREMENTS AND SECONDARY
EMISSIONS FROM USE OF IN-LINE
PAINT HEATERS (METRIC UNITS) 5-43
TABLE 5-16b ELECTRICITY REQUIREMENTS AND SECONDARY
EMISSIONS FROM USE OF IN-LINE
PAINT HEATERS (ENGLISH UNITS) 5-43
TABLE 5-17a ELECTRICITY REQUIREMENTS AND SECONDARY
EMISSIONS FROM THERMAL INCINERATION FOR
SPRAY BOOTH PAINTING OPERATIONS
(METRIC UNITS) 5-44
TABLE 5-17b ELECTRICITY REQUIREMENTS AND SECONDARY
EMISSIONS FROM THERMAL INCINERATION FOR
SPRAY BOOTH PAINTING OPERATIONS
(ENGLISH UNITS) 5-44
TABLE C-l IN-LINE HEATERS ANNUALIZED COSTS C-6
TABLE C-2 ESTIMATED RECORDKEEPING AND REPORTING
LABOR AND COST FOR MAXIMUM STANDARDS .... C-10
TABLE C-3 ESTIMATED RECORDKEEPING AND REPORTING
LABOR AND COST FOR MAXIMUM LIMITS —
CALCULATED VALUES C-12
TABLE C-4
ESTIMATED RECORDKEEPING AND REPORTING
LABOR AND COST FOR AVERAGE LIMITS . .
viii
C-14
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LIST OF TABLES (cont.)
TABLE
TABLE
TABLE
TABLE
TABLE
C-5
C-6
C-7
C-8
C-9
SUMMARY OF DATA AND EQUIPMENT COSTS ....
SPREADSHEET FOR REGENERATIVE THERMAL
INCINERATORS
CAPITAL COST FACTORS FOR THERMAL AND
CATALYTIC INCINERATORS
GENERAL ANNUAL COST ASSUMPTIONS
FOR ADD-ON CONTROLS
POLLUTANT EMISSION FACTORS
C-15
C-19
C-22
C-23
C-37
IX
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LIST OF FIGURES
Figure 2-1.
Figure 2-2.
Figure 2-3.
Figure 2-4.
Figure 2-5.
Figure 2-6.
Figure 2-7.
Figure 2-8.
Figure 2-9.
Figure 2-10.
Figure 2-11,
Figure 2-12,
Figure 2-13,
Figure 3-1.
Figure 3-2.
Figure 3-3.
437 Active U.S. Shipbuilding Facilities
(by State)
General Areas of Ship Structures with
Special Coating Needs
Shipyard Paint Usage (by Overall Category)
(Based on project data base)
Shipyard Solvent Usage ....
Suction Blast Nozzle Assembly
Suction-type Blasting Machine
Pressure Type Blasting Mactiine
Wet Blasting Machined ....
Adapter Nozzle Converting a Dry Blasting
Unit to a Wet Blasting Unit
Hydraulic Blasting Nozzle
Paint Category Usage . . ,
Timeline for Criteria Pollutant Emission
Inventory State Submittals
Explanatory Flow Diagram of California's
Blasting Regulation Provided by NASSCO . .
Schematic of Vacuum Blaster Head ,
Nozzle for Air Abrasive Wet Blast
Portable Enclosure ,
Page
2-3
2-8
2-23
2-29
2-34
2-35
2-36
2-37
2-38
2-39
2-40
2-47
2-52
3-11
3-13
3-16
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1.0 SUMMARY
1.1 INTRODUCTION
This report provides alternative control techniques (ACT)
for State and local agencies to consider for incorporating in
>"
rules to limit emission of volatile organic compounds (VOC's) and
particulate matter including PM1Q (that which measures 10 microns
or less) that otherwise would result from surface coating
operations at shipbuilding and ship repair facilities. This
document contains information on emissions, controls, control
options, and costs that State and local air pollution authorities
can use in 'developing rules. The document presents options only,
and makes no recommendations.
As a parallel project, the U. S. Environmental Protection
Agency (EPA) is developing a national standard to regulate
hazardous air pollutant (HAP) emissions from this source
category. Those rules are still well over a year away.
1.2 ALTERNATIVE CONTROL TECHNIQUES
Most of the VOC's contained in marine coatings are emitted
to the atmosphere as the paint is applied and cures. Most of
the painting work is performed outdoors. The massive scale of a
ship makes it difficult to capture the emissions from outdoor
painting, unlike for example, painting the inside of a tank where
the tank provides a natural enclosure, hence abatement equipment
has not previously been used.
1-1
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The emission points defined for this source category are
indoor and outdoor painting operations. A number of alternative
control techniques for surface coating operations in the
shipbuilding and ship repair industry were compared. Several
control options were evaluated. These include availability of
coatings with inherently lower emissions of VOC's (and associated
HAP's) and use of add-on control devices. Coatings that comply
with the California 1992 and 1994 (Rule 1106, Marine Coating
Operations) limits for the paint categories identified in Table
1-1 are the primary basis for the alternative control techniques
presented here. Many of the resulting compliant coatings have
survived the Navy's lengthy performance-testing program and
appear on the Navy "Qualified Products List", hence are
acceptable for use on Navy ships. Coatings with even lower
emissions are available for certain coating categories listed in
Table 1-1, they reportedly have not been fully tested and
approved by the NAVY. Such materials were not considered in this
report although the Navy has some of them undergoing standardized
multi-year exposure testing VOC limit.
Four lower VOC options of this alternative control
technology were investigated for "major-use" coating categories
in the project "data base.1" Three of the options (Nos.1,2 & 4)
set maximum or not-to-be-exceeded limits. The fourth option
(No. 3) places no limit on individual coatings but rather allows
calculation of a weighted average.
The three paint categories that make up about 90% of the
paint volume (as reported in the data base) for this industry
are: "general use" (epoxies, 60 % and alkyds, 10 %),
antifoulants (10 %), and inorganic zincs (10 %). The nationwide
emission reduction achievable for each of the four coating
categories was calculated based on imposing limitations in all
1 The "data base" is the paint information collected as a
result of an information request mailed to this industry.
1-2
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nonattainment areas, equal to the corresponding California
limits. It was assumed that relative paint usage among the
categories would not change.
Cost and environmental impacts of potential rules .were
developed using "model" shipyards to represent the range of
facilities found in this industry. Eight models were developed
to represent the various types of shipyards that could be covered
by the ACT.
The relative size of the yard and whether it does new ship
construction or repair were the bases for categorization
resulting in: (1) large/construction; (2) large/repair;
(3) medium/ construction; (4) medium/repair;
(5) small/construction; (6) small/repair; (7) extra
small/construction; and (8) extra small/repair. Size is
characterized by annual volume of paint and solvent usage which
affects annual VOC emission levels (Mg/yr).
Cleaning solvents constitute an important source of VOC
emissions They are used to remove contaminants such as dirt,
soil, oil, and grease to prepare the substrate for painting.
Equipment, vessels, floors, walls, and other work areas are also
cleaned using solvents. To aid States develop rules to control
emissions from the use of VOC-containing cleaning solvents in the
marine industry, earlier this year EPA published a report titled
"Alternative Control Techniques Document for Industrial Cleaning
Solvents" (EPA-453/R-94-015).
This study of shipyards revealed great confusion regarding
the use of "thinning", "reducing" or "dilution" solvents. Added
to the paint just prior to spraying, thinning solvents reduce the
viscosity of the paint as supplied by its manufacturer.
Enormous amounts of thinning solvents are used, yet many
paint manufacturers indicated that such use is largely
unnecessary; the paints are delivered in a ready to spray
condition for most climatological conditions.
Viscosity can also be controlled via use of "paint heaters",
commercial portable electrical heaters mounted in the paint
1-3
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delivery lines. These are widely used throughout paint
manufacturing industries.
The viscosity of a paint increases with decreasing
temperature. Northern-located shipyards, such as the Bath Yard
in Maine, argue that paint heaters are unsuitable for their
unique yard orientation and that addition of dilution solvent is
critical to their ability to paint during extreme weather
conditions.
The use of abrasive blasting media to remove rust and
deteriorated coatings before painting a marine surface results in
huge emissions of particulate including PM.J_Q. This document
provides an overview of several blasting systems and blasting
mediums commonly used. It also provides, information on
technologies under development that would significantly reduce
these emissions: a vacuum blast cleaning system marketed in
Europe and a self-supporting portable enclosure being developed
in the U.S. Existing regulations for VOCs and PM10 and
demonstrated control technologies that are transferable to ship
yards are discussed in this document.
The alternatives presented herein provide no distinction
between record keeping and reporting in shipbuilding and
construction yards. Although yards may already be required to
maintain records to satisfy permit conditions and requirements of
the Superfund Amendments and Reauthorization ACT of 1986 (SARA
313), the VOC limits will require additional records be
maintained.
As with rules for other industries, the alternative which
provides greatest flexibility to the shipyard has a price - more
detailed records and computations.
1.3 ENVIRONMENTAL IMPACT
Those normally result from a rule that mandates that add-on
control equipment be installed to control emissions that the
process generates. The bulk of the alternatives herein are based
on a pollution prevention approach; use of coatings with
inherently lower air pollution potential.
1-4
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1.4 Inorganic Zinc Coatings
Categories of coatings in Table 1-1 differ from the
California rule in two respects. These changes were made late in
the study based on an increased understanding of two different
coating operations. Two distinctly different inorganic coatings
have traditionally contained zinc. Zinc rich coatings offer
excellent corrosion resistance because the metal acts as a
sacrificial anode in the electrochemical corrosion phenomena.
One type has long been used in a thick (3 to 5 or more mils)
application as a prime coat which is overcoated with top coats to
protect the zinc. A second type, so called "weld-through" or
"preconstruction primer" is applied as a temporary coating to
protect steel plate while in inventory (-usually outdoors) at the
shipyard. These coatings are used in a thin film (nominal 1 mil)
to minimize both cost and available zinc in the weld zone that
contaminates the weld during the welding process. If a thicker
film were used, it is reported that the incremental zinc would
reduce the integrity of the resulting weld.
Lower VOC coatings of similar chemistry are generally more
viscous. As a result, thin films are difficult to apply with
conventional high build inorganic zinc coatings. Failure to
include a category that allows higher VOC weld-through primers
would require that the high build coating be blasted or ground
off of the steel plate before welding operations could take
place. The time, labor cost and pollution that would result
argue for providing a category for the unique properties of weld-
through primers, limited to only those coatings applied prior to
and in preparation for subsequent welding operations.
Because the weld-through products yield greater volatile
organics per volume of paint solids, it appears that abatement of
those emissions may be reasonable under some circumstances. Use
of automated systems to apply such high VOC products apparently
results in sufficient VOC to render the cost of control
reasonable. One shipyard indicated that it is installing
abatement on its automated, preconstruction primer line. This
information was gathered too late in the study to permit a
1-5
-------
detailed evaluation of the either the process or its cost, so a
State must evaluate each situation on a case-by-case basis. The
control costs presented in this report do not apply to an
automated system; they were developed for situations that would
be far more costly to control.
TABLE l-l.
VOC LIMITS FOR SHIPBUILDING COATING CATEGORIES
Coating category
General use
Specialty
Air flask
Antenna
Antifoulant
Heat resistant
High gloss
High temperature
Inorganic zinc high
build primer
Weld- through (shop)
primer
Military exterior
Mist
Navigational aids
Nonskid
Nuclear
Organic zinc
Pre- treatment wash
primer
Repair and maintenance
of thermoplastic
coating of commercial
vessels
Rubber camouflage
VOC limits3-
Grams per
liter (g/L)
340
—
340
530
400
420
420
500
340
650
340
610
550
340
420
360
780
550
340
Pounds per
gallon (Ib/gal)13
2.83
2.83
4.42
3.33
3.50
3.50
4.17
2.83
5.42
2.83
5.08
4.58
2.83
3.50
3.00
6.50
4.58
2.83
1-6
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Coating category
Sealant coat for
thermal spray aluminum
Special marking
Specialty interior
Tack coat
Undersea weapons
systems
VOC limitsa
Grains per
liter (g/L)
610
490
340
610
340
Pounds per
gallon (lb/gal)b
5.08
4.08
2.83
5.08
2.83
a VOC content limits are expressed in units of mass of VOC (g,
Ib) per volume of coating (L, gal) less >ra.ter and less "exempt"
solvents as applied. Volatile compounds classified by EPA as
having negligible photochemical reactivity are listed in
40 CFR 51.100(s).
bTo convert from g/L to Ib/gal, multiply by:
[(3.785 L/gal)(lb/453.6 g)] or (lb-L/120 g-gal).
1-7
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2.0 INDUSTRY DESCRIPTION
2.1 GENERAL
For purposes of this study, the shipbuilding and ship repair
industry consists of establishments that build and repair ships
with metal hulls. This industry also includes the repainting,
conversion, and alteration of ships. Subcontractors engaged in
ship painting, blasting, or any other operations within the
boundaries of a shipyard are considered to be part of the
shipyard, and resulting emissions are considered shipyard
emissions. The definition for Standard Industrial Classification
(SIC) Code 3731, Shipbuilding and Repairing, generally coincides
with the above definition but differs in that SIC Code 3731
includes the manufacture of both offshore oil and gas well
drilling and production platforms. Limits on emissions from
coatings used on such platforms' are being negotiated as part of
the Federal VOC rule on architectural and industrial maintenance
coatings which is still under development. In order to better
define which shipyard facilities will be subject to rulemaking,
the following definition of a ship has been adopted:
any metal marine or fresh-water metal hulled vessel
used for military or commercial operations, including
self-propelled vessels and those towed by other craft
(barges). This definition includes, but is not limited
to, all military vessels, commercial cargo and
passenger (cruise) ships, ferries, barges, tankers,
container ships, patrol and pilot boats, and dredges.
Pleasure craft such as recreational boats and yachts are not
included in the definition and are not typically built or
serviced in large-scale shipyards. As would be expected, there
2-1
-------
is some overlap with the pleasure craft industry. Some of the
smaller shipyards work on both ships and pleasure craft.
Approximately 437 facilities (shipyards) of varying
capabilities are involved in the construction and repair of ships
in the United States.2 This number includes eight Naval
shipyards and one Coast Guard facility. The shipyards are
located along the east, west, and Gulf coasts as well as at some
inland locations along the Mississippi River (and its
tributaries) and the Great Lakes. Many of the small bargeyards
are concentrated in Louisiana and Texas. The majority of these
do not qualify as major sources with regard to volatile organic
compound (VOC) and/or particulate matter 10 microns or less in
diameter (PM-10) emissions (as discussed- in Chapter 4).
Figure 2-1 shows the geographical location of active U.S.
shipyards, and Table 2-1 lists individual States, with the number
of shipyards located in each.
As reported in the U.S. Industrial Outlook '92--Ship-
building and Repair dated January 1992:3
The U.S. Active Shipbuilding Base (ASB) is defined
as privately-owned shipyards that are open, engaged in,
or actively seeking construction contracts for naval
and commercial ships over 1,000 tons. These full-
service yards are the primary sector of the first-tier
shipyards, which are facilities capable of
constructing, drydocking, or topside-repairing vessels
400 feet in length or more. As of October 1, 1992,
there were 16 ASB shipyards. The ASB shipyards
continue to employ about three-quarters of the
shipbuilding and ship repair industry's total work
force of more than 120,000. These figures do not
include nine Government -owned shipyards, which do not
engage in new construction, but rather in the overhaul
and repair of Navy and Coast Guard ships.
Another important sector of the shipbuilding and
2-2
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TABLE 2-1. U.S. SHIPYARD LOCATIONS2
State
Louisiana
Texas
Virginia
California
Florida
Washington
New York
Mississippi
Alabama
Pennsylvania
Oregon
Wisconsin
Massachusetts
Maine
New Jersey
Ohio
Indiana
Illinois
North Carolina
South Carolina
Michigan
Rhode Island
Tennessee
Missouri
Hawaii
Georgia
Maryland
Puerto Rico
Alaska
Arkansas
Connecticut
Minnesota
Oklahoma
New Hampshire
TOTAL
No, of shipyards
74
53
34
33
33
25
21
17
15
12
10
9
8
7
7
7
6
6
6
6
6
6
6
5
5
4
4
3
2
2
2
1
1
1
437
2-4
-------
ship repair industry is one composed of small-size and
medium-size facilities, or "second-tier shipyards."
These shipyards are primarily engaged in supporting
inland waterway and coastal carriers. Thei-r market is
the construction and repair of smaller type vessels,
such as tug boats, supply boats, ferries, fishing
vessels, barges, and small military and Government-
owned vessels.3
Shipyard employment varies from 10 employees to 26,000
employees, and subcontractors are used frequently for specific
operations like abrasive blasting and painting. Bargeyards
typically are relatively smaller operations with a focus on
repair activities, while most commercial and military shipyards
have more employees and can handle a wide variety of ships and
repairs.
All types of vessels are built or repaired in shipyards in
the United States. Many of the ships are foreign-owned/operated.
Government owned (Navy, Army, and Coast Guard) vessels account
for a significant portion of all shipyard work. Steel is the
most common material used in the shipbuilding and ship repair
industry, but wood, aluminum, and plastic/fiberglass are also
used.
The large shipyard organizations that have floating drydocks
and/or graving docks generally have extensive waterfront acreage
and are capable of all types of ship repair and maintenance.
Major shipyards usually combine repair, overhaul, and conversion
with shipbuilding capabilities, and employment usually numbers in
the thousands. It is difficult to draw a sharp line between
yards that build and ships and those that repair; many facilities
engage in both to various degrees. The mix of work varies widely
throughout the industry as well as from year to year at a single
shipyard.3'^
Repair yards perform a wide variety of services and can be
categorized into two groups based on the ability to drydock a
ship. Those facilities which have no drydock capabilities are
2-5
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known as topside repair yards and can perform the various repairs
that do not require taking a ship out of the water. Services
rendered by these yards may vary from a simple repair job to a
major topside overhaul. In general, topside yards do not do a
lot of painting so they have low VOC emissions and gnerally do
not qualify as major sources. On the other hand, typical repair
yards with the ability to drydock ships do more painting than do
construction yards of comparable size since repainting is an
integral part of most repair jobs and the underwater hull is a
significant part of the painted area of a ship.
2.2 PROCESSES AND EQUIPMENT
The vast majority of emissions from shipyards are VOC's, and
most of those come from organic solvents^contained in marine
paints and solvents used for thinning and cleaning. For that
reason, the focus of this CTG is on painting operations within
shipyards. The VOC emissions associated with the use of solvents
for cleaning were addressed by publication of an alternative
control techniques (ACT) document for industrial cleaning
solvents (EPA-453/R-94-015).
This section discusses related details of marine paints,
resins, solvents, coating systems, and application equipment. In
addition to VOC's, PM-10 is also emitted, primarily as a result
of abrasive blasting surface preparation activities. The final
portion of this section discusses the various processes used to
prepare surfaces for painting.
Information on the processes and equipment used in this
industry was based, in part, on information gathered from
responses to information requests sent to shipyards pursuant to
Section 114 of the Clean Air Act, EPA's information-gathering
authority.5 Information was also obtained from coating
manufacturer's Section 114 responses.6
Due to the size and limited accessibility of ships, most
shipyard painting operations are performed outdoors. When
painting and/or repairs are needed below the waterline of a ship,
it must be removed from the water using a floating drydock,
2-6
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graving dock, or marine railway. In new construction operations,
assembly is usually modular, and painting is done in several
stages at various locations throughout the shipyard.
The typical ship construction process begins with steel
plate material. The steel plate is abrasively cleaned (blasted),
and then coated with a preconstruction primer for corrosion
protection during the several months it may lay in storage before
it is used. The steel plate is formed into shapes or rolled.
This is typically done indoors at the bigger shipyards, where
some facilities have automated these steps. (Smaller shipyards
usually have no indoor facilities, and all metal- forming work is
done at or near the waterfront.) The preformed shapes or rolls
are assembled into subassemblies which are constructed into
"blocks". Blocks are blasted to bare metal to remove the
preconstruction primer and a paint "system" is applied. A paint
"system" is a succession of compatible coatings applied on top of
one another. At some point in the construction, even those
components fabricated indoors are moved outdoors to work areas
adjacent to the drydock. The next construction step is on-block
outfitting of piping, ventilation, and other materials. For
large ships such as aircraft carriers or cruise ships final
assembly (and then painting) can only be done at the drydock .
At some facilities, smaller ships are completed indoors and then
moved to the water using a marine railway and/or cranes.
There are five general areas of ship structures that have
special coating requirements:
1. Antennas and superstructures (including freeboard);
2. Exterior deck areas;
3. Interior habitability areas;
4. Tanks (fuel, water, ballast, and cargo); and
5. Underwater hull.4
Each of these areas is diagrammed in Figure 2-2 to aid with some
of the terminology used later in this chapter.7
2-7
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Antennas and Superstructures ,
Including Freeboard
TT7 /./ / J
Exterior
Deck Areas
Interior
Habitability Areas
Fuel, Water, Ballast, and Cargo Tanks
Underwater Hull
Figure 2-2.
General areas of ship structures with special
coating needs.
2-8
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2.2.1 Marine Paints
The basic components in marine paint (coatings) are the
vehicle (resin binder), solvent (except in 100 percent solids
coatings), pigment (except for clear coatings), and additives.
Resins and solvents are discussed further later in this section.
Paint is used for protective, functional or decorative
(aesthetic) applications or both.8
Marine coatings are vital for protecting the ship from
corrosive and biotic attacks from the ship's environment. Many
marine paints serve specific functions such as corrosion
protection, heat/fire resistance, and antifouling (used to
prevent the settlement and growth of marine organisms on the
ship's underwater hull). A ship's fuel^consumption will increase
significantly because of marine fouling, adding to the
operational costs. Different paints are used for these purposes,
and each may use one or more solvents (or solvent blends) in
different concentrations. Specific paint selections are based on
the intended use of the ship, ship activity, travel routes,
desired time between paintings (service life), the aesthetic
desires of the ship owner or commanding officer, and fuel costs.
Ship owners and paint suppliers specify the paints and coating
thicknesses to be applied at shipyards.
2.2.1.1 Marine Coating (Resin) Types. The general
properties of the different chemical types of coatings and their
uses in marine applications are discussed in this section. An
overall summary of these coating types and applications is
provided in Tables 2-2 and 2-3.4 These marine coatings are
usually applied as a "system." A typical coating system
comprises (1) a primer coat that provides initial corrosion
(oxidation) protection and promotes adhesion of the subsequent
coating, (2) one or more intermediate coats that physically
protect(s) the primer and may provide additional or special
properties, and (3) a topcoat that provides long-term protection
for both the substrate and the underlying coatings. The primer
is usually a zinc-rich material that will provide galvanic
corrosion protection if the overlying paint system is damaged but
2-9
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would quickly be consumed by sacrificial corrosion without a
protective topcoat. A good coating system can enhance the
beneficial properties of individual coatings. Each coating is
typically a different color to help the applicators ensure that
each layer provides complete coverage.
2.2.1.1.1 Alkyds.* Alkyd resins are polyester compounds
that are formed by reactions between polyhydric alcohols (e.g.,
ethylene glycol or glycerol) and a polybasic acid (e.g., phthalic
anhydride) in the presence of a drying oil (e.g., linseed or
soybean oil). The specific oil used determines the curing
properties of the resin and its ultimate chemical and physical
properties. Alkyds are frequently modified chemically to improve
their physical properties or their chemical resistance. Modified
alkyds are formed by reacting other chemical compounds (such as
vinyl, silicone, and urethane compounds) with the alkyd. Alkyd
coatings require chemical catalysts (driers) to cure. Typical
catalysts are mixtures of zirconium, cobalt, and manganese salts.
Depending on the catalysts and the ambient temperature and
humidity, it takes several days to several weeks before the
coating is fully cured.
Alkyd coatings are frequently used as anticorrosive primers
and topcoats in interior areas and as cosmetic topcoats over
high-performance primers in exterior areas. Alkyd coatings are
primarily used for habitability spaces, storerooms, and equipment
finishes. Fire-retardant alkyd paints are some of the most
common interior coatings used on Naval ships. Modified alkyds,
particularly silicone alkyds, have excellent weathering
properties and are good decorative and marking coatings.
However, alkyds are not recommended for saltwater immersion
service or for use in areas that are subject to accidental
immersion. The alkali generated by the corrosion reactions
rapidly attacks the coating and leads to early coating failure.
Also, alkyds should not be applied over zinc-rich primers because
they are attacked by the alkaline zinc corrosion products.
2.2.1.1.2 Chlorinated rubber.^ Chlorinated rubbers are
formed by reacting natural rubber with chlorine. Chlorinated
2-12
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rubbers by themselves are not suitable for use as coatings and
must be blended with other compounds to produce good coatings.
Coatings made from chlorinated rubbers that have been blended
with highly chlorinated additives provide tough, chemically
resistant coatings. These coatings cure by solvent evaporation.
These coatings are normally partially dry within 1 hour (hr) and
fully dry within 7 days. For this reason, chlorinated rubber
coatings are especially useful where fast drying, particularly at
low temperatures (0° to 10°C [32° to 50°F]), is required.
Chlorinated rubber coatings are tough, resistant to water,
and chemically resistant. However, they are softened by heat and
are not suitable for sustained use at temperatures above
66°C (150°F). Chlorinated rubber coatings are suitable for most
exterior ship areas that are not continually exposed to higher
temperatures.
2.2.1.1.3 Coal tar and coal tar eooxy.^ Coal tar coatings
are made from processed coal tar pitch dissolved in suitable
petroleum solvents. They form a film by evaporation of the
solvent, and the film can be redissolved in solvents. Coal tar
films provide very good corrosion protection. However, the dry
film is damaged by direct exposure to sunlight, which causes
rapid, severe cracking. Coal tars are normally blended with
other resins to improve their light stability and to increase
their chemical resistance. Common blending resins include vinyl
and epoxy materials. Coal tar coatings are widely used in highly
corrosive environments such as ship bottoms, where impermeability
is important. They are also applied as anticorrosive coatings in
ballast tanks and lockers used to store anchor chains.
Coal tar epoxy paints are packaged with the epoxy portion in
one container and the curing agent (either amine or polyamide
type) in a second container. The coatings must be thoroughly
mixed prior to use and must be used before the mixture
solidifies. The liquid coating forms a film by solvent
evaporation and continued chemical reaction between the epoxy
resin and the curing agent. The "pot life" is different for each
unique formulation. Commonly used coatings have pot lives that
2-13
-------
range from 2 to 8 hr at 25°C (77°F). Coal tar epoxy films have
high chemical resistance, easily form thick films, and have a
high dielectric strength. The high dielectric strength makes
them particularly suitable for use near anodes in cathodic
protection systems, where the high current densities can damage
other types of coatings. Coal tar epoxy coatings are known to
exude low-molecular-weight fractions (ooze solvent), which cause
recoating problems. The U.S. Navy limits the use of coal tar and
coal tar epoxy coatings to protect workers from the possibility
of low levels of carcinogens in the refined coal tar.
Coal tar epoxies are also commonly used on fresh-water
barges. Other suitable paints are available, but the coal tars
are the least expensive.
2.2.1.1.4 Epoxy.9 Epoxy coatings for marine applications
are typically formed by the chemical reaction of a
bisphenol-A-type epoxy resin with a "curing agent" (e.g., amines,
amine adducts, or polyamide resins). The coatings are packaged
with the epoxy portion in one container and the curing agent in a
second container. As with coal tar epoxy systems, the coatings
must be used within their pot life. Commonly used epoxy coatings
have pot lives that range from 2 to 8 hr at 25°C (77°F). Epoxy
coatings typically dry to touch within 3 hr and are fully cured
after 7 days at 25°C (77°F). The time to cure depends on the
catalyst, ambient and surface temperature during the curing
period. The curing reaction slows down markedly at temperatures
below 10°C (50°F).
Epoxy coating films are strongly resistant to most chemicals
and make excellent anticorrosion coatings. They are one of the
principal materials used to control corrosion in the marine
environment and are used in many primers and topcoats. However,
epoxy coatings chalk when exposed to intense sunlight. For this
reason, epoxy coatings are often used with cosmetic topcoats
(e.g., silicone alkyds) that are more resistant to sunlight.
2.2.1.1.5 Inorganic zinc.9 Inorganic zinc coatings consist
of powdered zinc metal held together by a binder of inorganic
silicates. The binder is formed by the polymerization of sodium
2-14
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silicate, potassium silicate, lithium silicate, or hydrolyzed
organic silicates. The liquid coating forms a film by the
evaporation of the solvent medium (water and/or VOC's), followed
by the chemical reactions between the silicate materials, zinc
dust, and curing agents. Oxygen molecules are adsorbed in the '
film matrix in the case of water borne zinc coatings.
A variety of curing mechanisms are used to form the final
inorganic zinc coating film. The coatings are frequently
packaged as multicomponent paints. All parts must be mixed
thoroughly before being applied. After mixing, inorganic zinc
coatings have a pot life of 4 to 12 hr. The solvent material
must evaporate from these coatings before they can form a film.
For solvent borne, self cure, inorganic -zincs, some water is
needed to allow the binder to cure. Low humidity can retard cure
rate.
Because the coatings consist primarily of zinc, they offer
extraordinary galvanic corrosion protection. At the same time
for a variety of reasons, they can be corroded by the same
environments that damage zinc. Inorganic zinc coatings are often
used on weather (exterior) decks and as primers for the ship
superstructure (above waterline).
2.2.1.1.6 Organic zinc.9 Organic zinc coatings use zinc as
a pigment in a variety of organic binders. The primary feature
of organic zinc coatings is that the coating film is
electrochemically active and reacts to provide cathodic
protection to the steel substrate. These coatings are not as
mechanically durable or as resistant to high temperatures as the
inorganic zinc coatings. However, they are frequently more
compatible with organic topcoats. Generally, these coatings are
more tolerant of application variables than are inorganic zinc
coatings. The drying and curing properties of this type of
coating are determined by the properties of the binder. These
coatings are not recommended for immersion service in salt water
for the same reason given for inorganic zinc coatings, namely,
that they can be corroded by the same environments that damage
zinc.
2-15
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2.2.1.1.7 Polyurethane.9 Polyurethane marine coatings are
made from resins that contain complex monomers that incorporate
isocyanate chemistry, which is highly reactive with hydroxyl
groups (e.g., water and alcohols)", which are commonly used as
curing agents. Coating films are formed in two overlapping steps
by solvent evaporation followed by a chemical reaction between
the polyurethane resin and the curing agents. The most commonly
used polyurethane marine coatings are packaged as two- or three-
component systems. One component contains the polyurethane
resin, and the second component contains an organic polyol. Some
systems require the use of a third component containing catalysts
(e.g., metallic soaps or amine compounds) to accelerate curing.
Polyurethane coatings form tough, chemically-resistant
coatings and make particularly good high-gloss cosmetic finishes.
They have good abrasion and impact resistance and are
particularly useful in high-wear areas. They have good weather
resistance but lose gloss when exposed to intense sunlight.
Weathered polyurethane coatings are often difficult to recoat,
and subsequent topcoats will not adhere unless special care is
taken to prepare the surface before repainting aged or damaged
areas. Polyurethane coatings are most commonly used as topcoats,
e.g., in a coating system consisting of one coat inorganic zinc,
one coat high-build epoxy, and one coat aliphatic polyurethane.
These coatings are used in the areas above the waterline such as
the topside, weather deck, and superstructure areas.
2.2.1.1.8 Spray-metallized coatings.9 Spray-metallized
coatings are formed by melting a metal and spraying it onto the
surface to be protected. The metal solidifies in place and forms
a tightly adhering barrier to protect against corrosion. Zinc
and aluminum are the most commonly used metals for
spray-metallizing. Aluminum is generally favored for marine
service because of its longer service life and low weight. It is
generally necessary to topcoat the sprayed metal coating to
improve appearance and protect the metallized coating to gain the
maximum possible service life. Vinyl or epoxy coatings are
typically used as topcoats for aluminum metal spray coatings.
2-16
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2.2.1.1.9 Vinyl coatings.9 Vinyl resins are formed by the
polymerization of vinyl compounds. The most common resins are
based on polyvinyl chloride (PVC) copolymers. These resins form
films by solvent evaporation. Freshly applied coatings are dry
to the touch within 1 hr and are fully dried within 7 days.
Vinyl coatings are particularly useful where fast drying,
particularly at low temperatures (0° to 10°C [32° to 50°F]), is
required.
Coatings based on vinyl polymers perform well in immersion
situations and are frequently used to protect submerged
structures such as the underwater hull of a ship. These coatings
have excellent resistance to many chemicals and are good
weather-resistant materials. Vinyl coatings are softened by heat
and are not suitable for sustained use above 66 °C (150°F). Vinyl
paint systems require the use of a thin coat of wash primer
(containing acids to etch the surface) as the first coat to
ensure good adhesion to steel.9
2.2.1.2 Paint Solvents.1^ The solvent component of marine
paints is a transient ingredient, but its quality and suitability
are apparent for the life of the coating. Choice of solvents
affects coating film integrity, appearance, and application.
Thus, solvents play an important role in film formation and
durability even though they are not a permanent component. The
solvent in most paints is a mixture of two or more chemical
compounds that impart different properties to the solvent blend.
Two basic performance properties must be considered in
selecting the proper solvent for marine coatings: solvent power
and evaporation rate. Solvency refers to a solvent's ability to
dissolve the resin and reduce its viscosity so the paint can be
applied. The solubility of the resin and the solvency of the
solvent determine initial coating viscosity. Evaporation is
subsequently necessary as part of the drying process and in
controlling the paint viscosity at various stages of drying (film
viscosity increases as the solvent evaporates). The solvent must
evaporate relatively quickly during initial drying to prevent
excessive flow (sagging of the wet paint film), but in later
2-17
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stages it must evaporate slowly enough to give sufficient
leveling and adhesion. Different solvent components are
typically used to achieve such evaporative performance.
Table 2-4 lists the most common organic solvents used at
shipyards based on the collected Section 114 information in the
data base.5 The predominant solvents used in marine paints and in
their associated cleaning are obtained from petroleum (crude
oil). Many of the commonly known solvents are actually petroleum
distillation fractions and are composed of a number of compounds.
Distillation fractions are typically distinguished as aliphatic
or aromatic.
TABLE 2-4. TYPICAL SOLVENTS USED IN MARINE PAINTS5
Xylene
Toluene
Ethyl benzene
Methyl ethyl ketone
Methyl isobutyl ketone
Ethylene glycol ethers
Mineral spirits3-
High- flash naphthab
Hexane
Isopropyl alcohol
Butyl alcohol
Ethyl alcohol
Methyl amyl ketone
Acetone
Propylene glycol ethers
aLigroine (light naphtha), VM&P naphtha, Stoddard solvent,
and certain paint thinners are also commonly referred to as
mineral spirits.
^Specifications for this material exist under ASTM D3734-91.
Aliphatic petroleum solvents are distillation products from
crude oil and are characterized by relatively low solvent power,
relatively low specific gravities, and bland odors. Typical
aliphatic petroleum solvents include hexane, mineral spirits,
varnish makers' and painters' (VM&P) naphtha, Stoddard solvent,
and kerosene.
Aromatic petroleum solvents may be produced from aliphatic
2-18
-------
compounds. There are only four commonly used aromatic solvents
in the coatings industry: xylene, toluene, medium-flash naphtha,
and high-flash naphtha. Aromatics are stronger solvents than are
aliphatics; they dissolve a wider variety of resins.
2.2.1.3 Coating Systems'. In general, the coating systems
described in this section are based on those used by the U.S.
Navy and may not be representative of those used by commercial
vessels with different (and perceived less stringent), service
requirements. Coating system selection requires consideration of
many different factors, including:
1. Service requirements of the coated surfaces;
2. Materials and application costs;
3. Temperature and humidity during-application and
drying/curing;
4. Surface preparation requirements;
5. Desired service life;
6. Accessibility of the area for maintenance;11 and
7. Life-cycle costs.
Coating system requirements can be broken down into several
generalized categories based upon the ship's structural
components. These structural components include the freeboard
areas and other exterior surfaces above the waterline (boot top)
area; exterior deck areas; interior habitability spaces; fuel,
water, ballast, and cargo tanks; and the underwater hull areas.
These basic areas of a typical ship are illustrated in
Figure 2-2. This figure and the following discussion were taken
from a letter from S. D. Rodgers of the Naval Sea Systems Command
to A. Bennett of EPA involving protective coatings for U.S. Naval
*j
ships. The remainder of this section provides information on
coating systems that have been identified to provide optimum
service performance for various ship components.
2.2.1.3.1 Freeboard areas and exterior surfaces above the
boot top area. The ship's exterior superstructure is subject to
acidic fumes, extreme temperatures ranging from those of the
tropics to those of the Arctic, intense sunlight, thermal shock
when cold rain or sea spray contacts hot surfaces, and attack of
2-19
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wind-driven saltwater and spray. A two- or three-part system is
recommended for these surfaces above the waterline. The
anticorrosion protection is provided by zinc-rich coatings and/or
epoxy-polyamide coatings. Cosmetic color and durability are
provided by a silicone-alkyd, acrylic-modified, two-component
epoxy, polyurethane, or acrylic topcoat. Typical paint systems
use either a two-coat epoxy with a two-coat silicone alkyd or a
one-coat, zinc-rich primer with a three-coat epoxy and a two-coat
silicone alkyd.
2.2.1.3.2 Exterior deck areas. Decks, in addition to being
in contact with seawater, are subject to the wear caused by foot
and/or vehicular traffic, mechanical abrasion, fuel and chemical
spills, and in the case of landing decks", the landings and take-
offs of aircraft. Antislip deck coatings are used to provide a
rough surface to help avoid uncontrolled motion of the crew and
machinery on wet, slippery decks. Antislip coatings need to be
selected for both their mechanical roughness and their resistance
to lubricants and cleaning compounds used on the decks. The most
durable antislip coatings are based on epoxy coatings that
contain coarse aluminum oxide grit. A typical antislip coating
system may consist of one coat of epoxy primer and one coat of
epoxy nonskid coating.
2.2.1.3.3 Interior habitability spaces. Interior
habitability areas suffer from high humidity, abrasion, cooking
fumes, soiling, fires, and heat. Nonflaming and intumescent
.coatings are the two major types of fire safety coatings used.
Nonflaming coatings prevent the spread of fire, and intumescent
coatings are used to reduce heat damage to surfaces that are
exposed to fire. Common nonflaming coatings are based on
chlorinated alkyd resins and on water emulsions of chlorinated
polymers. Intumescent coatings contain materials that expand
(foam) when heated and create a thick insulation film (char) that
retards damage to the substrate. Typical applications involve
the use of alkyd primers under chlorinated alkyd or waterborne
nonflaming coatings (e.g., one coat alkyd, two coats chlorinated
alkyd).
2-20
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2.2.1.3.4 Tanks. Often cargo spaces and tanks are in a
more varied, and in some cases, more chemically reactive
environment than the hull. The cargo/tank coatings must resist
seawater, potable (drinking) water, hydrocarbon fuels and
lubricants, sanitary wastes, and chemical storage and spills.
Coating requirements for potable water tanks are vastly different
from those for fuel or ballast tanks. Fuel tank coatings must
prevent contamination of the fuel by corrosion products or by
materials in the coatings. They must also prevent corrosion
damage to the tank and be resistant to aliphatic and aromatic
petroleum products. A three-coat epoxy system is satisfactory
for this use. Zinc coatings are not used in fuel tanks because
zinc dissolved into the fuel, particularly gasoline, can cause
serious damage to engines.
Coatings for potable water tanks must prevent contamination
of the potable water by corrosion products and must not
contribute objectionable smell or taste to the water. The
coatings must not react with halogen compounds (e.g., bromine or
chlorine) used to disinfect the water. Care must be taken to
avoid the use of phenolic compounds in any coating used for
potable water tanks. (Phenolic compounds are sometimes added to
epoxy coatings to accelerate curing.) Halogenated phenolic
compounds in concentrations as low as 1 part per trillion can
make drinking water unfit for use.
Ballast tanks are exposed to both total immersion and
partial immersion in seawater, but marine fouling is typically
not a problem. The upper parts of the tank are constantly
exposed to high humidity, condensation, and salt, while the lower
portions are constantly immersed. However, the continually
immersed areas can be protected by a combination of cathodic
protection and barrier coatings. Other portions of the tanks can
be protected with barrier coatings. A typical coating system may
consist of two or three coats of epoxy.
2.2.1.3.5 Underwater hull areas. The underwater hull is in
constant contact with seawater and must resist the ravages, of
impact abrasion, galvanic corrosion, and cavitation. Exterior
2-21
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underwater areas also need protection from the attachment of
marine organisms, known as fouling. This portion of ships and
structures are inaccessible for routine maintenance, and the
coatings chosen must give reliable performance for extended
periods of time. Corrosion control for underwater areas usually
includes cathodic protection using sacrificial anodes (zinc or
aluminum) or impressed current cathodic protection systems.
Cathodic protection systems generate strongly alkaline
environments near the anodes and in areas where damage exposes
metal to the water. Both corrosion control and antifouling
coatings must be resistant to the environment created by cathodic
protection.
2.2.1.4 Marine Specialty Coating Categories. A number of
marine specialty coating categories were adopted by the
California Air Resources Board (CARB) in 1990. All other marine
coatings were classified as "general use" coatings and are
subject to a single regulation. A description of the specialty
coating categories is given in this section because the paint
categories used for this project were based on them. Figure 2-3
shows that all specialty coatings (including antifoulants and
inorganic zinc) account for 31 percent of total marine coatings
used at U.S. shipyards in the project data base5. Specialty
categories are based primarily on their functions (e.g., an
antifoulant's function is to prevent the hull from fouling). To
satisfy these functions, a variety of resins/chemistries may be
used. Therefore, the paints in a specialty category may not
easily be substituted for one another. The whole paint system
may have to be changed to ensure compatibility.
Specific paint categories referred to as specialty were
defined by CARB after a number of discussions with industry
representatives indicated that a general VOC limit on all marine
coating categories was not technologically feasible in meeting
the performance requirements for marine vessels.11 Higher VOC
limits for these specialty coating categories were adopted by
2-22
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GARB to take into account the performance requirements of each
category. A description of each of the adopted specialty paint
categories is given below.
2.2.1.4.1 Air flask coatings. Air flask coatings are
special combustion coatings applied to interior surfaces of high
pressure breathing air flasks to provide corrosion resistance and
which are certified safe for use with breathing air supplies.
2.2.1.4.2 Antenna coatings. Antenna coatings are applied
to equipment which is used to receive or transmit electromagnetic
signals.
2.2.1.4.3 Antifoulant coatings. Antifoulant coatings are
applied to the underwater portion of a vessel to prevent or
reduce the attachment of biological organisms. They are required
to be registered with EPA as pesticides.
2.2.1.4.4 Heat resistant coatings. Heat resistant coatings
are used on machinery and other substrates that during normal use
must withstand high temperatures of at least 204°C (400°F).
These coatings are typically silicone alkyd enamels.
2.2.1.4.5 High gloss coatings. High-gloss coatings achieve
at least 85 percent reflectance on a 60 degree meter when tested
by ASTM Method D-523. These coatings are typically used for
marking safety equipment on marine vessels.
2.2.1.4.6 High temperature coatings. High temperature
coatings are coatings which during normal use must withstand
temperatures of at least 426°C (800°F).
2.2.1.4.7 Inorganic zinc coatings. Inorganic zinc coatings
contain elemental zinc incorporated into an inorganic silicate
binder, used for the express purpose of providing corrosion
protection.
Although water-based, zinc-rich primers have recently been
made available from nearly every major manufacturer, field
testing in a variety of services has not been completed. Failure
of a primer is considered to be more catastrophic than the
failure of a topcoat because it results in exposure of bare
metal.
2-24
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2.2.1.4.8 Nuclear (low-activation interior) coatings.
Nuclear coatings are protective coatings used to seal porous
surfaces such as steel (or concrete) that otherwise would be
subject to intrusion by radioactive materials.
2.2.1.4.9 Military exterior coatings. Military exterior
coatings are exterior topcoats applied to military vessels
(including U.S. Coast Guard) which are subject to specified
chemical, biological, and radiological washdown requirements.
2.2.1.4.10 Mist coatings. Mist coatings are thin film
epoxy coatings up to 2 mil (0.002 in.) thick (dry) applied to an
inorganic or organic zinc primer to promote adhesion of
subsequent coatings.
2.2.1.4.11 Navigational aids coatings. Navigational aids
coatings are applied to Coast Guard buoys or other Coast Guard
waterway markers when they are recoated at their usage site and
immediately returned to the water.
2.2.1.4.12 Nonskid coatings. Nonskid coatings are
specially formulated for application to the horizontal surfaces
aboard a marine vessel, which provide slip resistance for
personnel, vehicles, and aircraft.
2.2.1.4.13 Organic zinc coatings. Organic zinc coatings
are derived from zinc dust incorporated into an organic binder
which is used for the express purpose of corrosion protection.
2.2.1.4.14 Pretreatment wash primer coatings. Pretreatment
wash primer coatings contain a minimum of 0.5 percent acid by
weight and are applied directly to bare metal surfaces to provide
necessary surface etching.
2.2.1.4.15 Repair and maintenance thermoplastic coatings.
Repair and maintenance thermoplastic coatings have vinyl,
chlorinated rubber, or bituminous (coal tar)-based resins and are
used for the partial recoating of in-use non-U.S. military
vessels, applied over the same type of existing coatings. Coal
tar epoxies are not included in this category even though they
are bituminous-based; they were determined to better fit the
epoxy (general use) category.
2-25
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2.2.1.4.16 Rubber camouflage coatings. Rubber camouflage
coatings are specially formulated epoxy coatings, used as a
camouflage topcoat for exterior submarine hulls and sonar domes
lined with elastomeric material, which provide resistance to
chipping and cracking of the rubber substrate.
2.2.1.4.17 Sealant coat for wire sprayed aluminum. A
sealant coat for wire sprayed aluminum coating is a coating of up
to one mil (0.001 inch) in thickness of an epoxy material which
is reduced for application with an equal part of an appropriate
solvent used on wire-sprayed aluminum surfaces.
2.2.1.4.18 Special marking coatings. Special marking
coatings are used on surfaces such as flight decks, ships'
numbers, and other safety or identification applications.
2.2.1.4.19 Specialty interior coatings. Specialty interior
coatings are extreme-performance coatings with fire-retarding
properties that are required in engine rooms and other interior
surfaces aboard ships. They are generally single-component alkyd
enamels.
2.2.1.4.20 Tack coats. Tack coats are epoxy coats up to
two mils thick applied to allow adhesion to a subsequent coating
where the existing epoxy coating has dried beyond the time limit
specified by the manufacturer for the application of the next
coat.
2.2.1.4.21 Undersea weapons systems coatings. Under-sea
weapons systems coatings are applied to any component of a
weapons system intended for exposure to a marine environment and
intended to be launched or fired undersea.
2.2.1.5 Application Equipment. This section discusses the
paint application methods generally used to apply coatings to
marine vessels. These methods include:
1. Conventional air-atomized spraying;
2. Airless spraying;
3. Air-assisted airless spraying;
4. High-volume, low-pressure (HVLP) spraying;
5. In-line heaters (hot spraying) in conjunction with other
spray equipment;
2-26
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6. Brushing; and
7. Rolling.
Of these methods, the most popular techniques used at shipyards
include brushing, rolling, conventional air-atomized spraying,
and airless spraying. Brushing and rolling are primarily used
for touchup and recessed surfaces where spraying is not
practical. Spraying is primarily used for all other surfaces
because of its high application speed.
Spray paint application systems include three basic
components: a container that holds the paint, a pressurized
propelling system, and a paint gun. A brief summary of the
various spray application systems is provided in Table 2-5.12
2.2.2 Thinning Solvents
Solvents are frequently added to coatings by the applicator
just prior to spraying to adjust viscosity. The volume of VOC
emissions from "paint thinning" is second only to that from paint
solvents. Thinning is done at most shipyards (regardless of
size) even though the paint manufacturers typically state it is
usually unnecessary.5'6 Weather conditions also play a part in
thinning in northern locations during the winter months when the
cold temperatures increase paint viscosity.
2.2.3 Cleaning Solvents
Solvents used to clean spray guns and other equipment and to
prepare surfaces prior to painting are referred to as cleaning
solvents. As mentioned previously, emissions from cleaning
solvents were addressed in an ACT published by EPA on Industrial
Cleaning Solvents. Cleaning solvents must be compatible with
solvents in the various marine paints to be effective. A wide
range of practices and/or systems is used for spray equipment
cleaning. Methods range from spraying solvent through a gun into
the air (or a bucket) to using a totally enclosed system where
the spray gun is mounted. Several shipyards recycle used
solvents in-house, and many others (especially the major yards)
are required to dispose of the used solvent as a hazardous
material.5
Figure 2-4 and Table 2-6 give the breakdown of solvent usage
2-27
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TABLE 2-5.
ADVANTAGES AND DISADVANTAGES OF SPRAY PAINT
APPLICATION METHODS12
Advantages
Disadvantages
Conventional air-atomized spray
Low equipment and maintenance costs
Excellent material atoimzation
Excellent operator control
Quick color change capabilities
Coating can by applied by syphon or under pressure
Uses high volume of air
Does not adapt to high-volume material output
Low transfer efficiencies
Can cause contamination and worker visibility
problems
Airless spray
Most widely used
Low air usage (uses hydraulic pressures)
High-volume material output
Limited overspray fog
Large spray patterns and high application speeds
Application of heavy viscous coatings
Excellent for large surfaces
Good transfer efficiency on large surfaces
Uses high volume of air
Expensive fluid tips
High equipment maintenance
Difficult to mix some high viscosity materials
Minimum operator control during application
System not very flexible
Not suitable for high-quality surface appearance
Pressurized system can cause injuries to operator if
not used with adequate caution
Air-assisted airless spray
Low coating usage
Fair to good operator control on air pressure
Few runs and sags in painted surface
Good atomization
High equipment maintenance
Expensive fluid tips
Poor operator control on fluid pressure
Not suitable for high-quality surface appearance
High-volume, low-pressure (HVLP) spray
Low blowback and spray fog
Good transfer efficiency
Portable (totally self-contained equipment)
Easy to clean
Overall time and cost savings
Can be used for intricate parts
Good operator controls on the gun
High initial cost
Slower application speed (controversial)
Does not finely atomize some high-solids coating
materials (controversial)
High cost for turbine maintenance
Requires more operator training than conventional
Still relatively new on the market
Some very high solids products not sprayable by HVLP
In-line heaters
Reduces the need for solvent additions for viscosity
reduction
Application viscosity is not altered by ambient temperature
and weather conditions
High film build with fewer coats; smoother surfaces
Potential for improved transfer efficiency
Several designs available
Can be used in conjunction with most types of spray
equipment
Additional maintenance and equipment costs
Fast solvent flash-off can develop pinhole and
solvent entrapment if coating is applied too heavily
Requires additional fluid hose to spray gun for
recirculating
Not recommended for premised two-component
coatings
Not intended for water-based coatings
Brushing
Primarily used for touch-up jobs and in small work
areas
Labor-intensive
Rolling
Manual application used on larger areas where
overspray presents cleaning difficulties
May not be appropriate for some primers (does not
penetrate surface)
2-28
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2-29
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and the average density of each solvent type. Solvents used for
surface preparation have been included here because of the very
low usages reported and actual shipyard practices (all solvents
are usually stored/collected together). In general, all major
solvent uses at shipyards (solvents used for thinning, equipment
cleaning, and surface preparation cleaning) are the same in terms
of the VOC's used.
TABLE 2-6. SOLVENT USAGE BREAKDOWN5
Use description
Thinner
Cleaning to prepare
surfaces
Cleaning of Equipment
and other items
Total combined
Total usage,
L (gal)
514,739 (135,980)
73,433 (19,399)
683,030 (180,438)
1,271,202 (335,817)
Average density,
g/L (Ib/gal)
838.8 (6.99)
842.4 (7.02)
846.0 (7.05)
842.4 (7.02)
2.2.4 Abrasive Blasting
This section provides information on abrasive blasting media
used for preparing surfaces for painting and abrasive blasting
methods.
2.2.4.1 General. The abrasive blasting process is used to
prepare the surface (remove rust and deteriorated coatings) to
ensure adhesion and performance of a new anticorrosive or
antifouling system. Below the waterline on the hull, blasting
removes marine growth, algae, and barnacles that reduce ship
speed, increase fuel consumption, and increase noise as the ship
travels.
The quality of surface preparation is the greatest single
factor that will affect performance of the new coating system.
Blast cleaning is the most effective and the preferred method of
preparing metallic surfaces. Wire brushes, sanders, and other
2-30
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alternative means of surface preparation are less effective than
blasting and can lead to early coating failure because they do
not provide the optimum surface profile and/or cleanliness to
which the new coating must adhere.8
2.2.4.2 Types of Abrasives. Abrasive blast materials are
generally classified as sand, metallic shot or grit, or other.
The cost and properties associated with the abrasive material
dictate choice of use.
Sand is the least expensive blast material but presents some
safety concerns. It is commonly used when blasting outdoors
where reclaiming is not feasible. Sand has a rather high
breakdown rate (frets easily), which can generate substantial
dust and causes health and safety concerns involving silicosis.
For this reason, its use in most shipyards is limited. Synthetic
abrasives, such as silicon carbide and aluminum oxide, are
becoming popular substitutes for sand. Although the cost of
these synthetic abrasives is three to four times that of sand,
they are more durable and create less dust. Synthetic materials
are predominantly used in blasting enclosures and in some
unconfined blasting operations where abrasive materials can be
readily reclaimed.
Metallic abrasives are made from cast iron and steel. Cast
iron shot is hard and brittle and is made by spraying molten cast
iron into a water bath. Cast iron grit is produced by crushing
the oversized and irregular particles formed in manufacturing
cast iron shot. Steel shot is produced by blowing molten steel.
Steel shot is not as hard as cast iron shot but is much more
durable. Due to the higher costs associated with metallic
abrasives, they are predominantly used in specially designed
enclosures with reclaiming equipment.
Glass beads, crushed glass, cut plastics, and nutshells are
included in the "other" category. As with synthetic and metallic
abrasive materials, they are generally used in operations where
the material is readily reclaimed.
The type of abrasive used in a particular application is
usually specific to the blasting method. Dry abrasive blasting
2-31
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is usually done with sand, aluminum oxide, silicon carbide,
metallic grit, or shot. Wet blasting is usually done with sand,
glass beads, or any materials that will remain suspended in
water. Table 2-7 lists common abrasive materials and their
applications.13'14 The choice of abrasive also is influenced by
considerations of the abrasive cost at the blasting site, the
labor plus material cost for cleaning a unit area of hull, the
costs of cleaning and disposal of a particular abrasive, and the
desired surface profile. Table 2-8 provides the compositions of
some commonly used blast media.15
2.2.4.3 Abrasive Blasting Systems. Typically, blasting
media is analogous to spraying paint. Blasting systems require a
reservoir for the blast media, a propelling device, and a nozzle.
The exact equipment used depends on the application.
The three propelling methods used are centrifugal wheels,
air pressure, and water pressure. Centrifugal wheel systems
depend on centrifugal and inertial forces to mechanically throw
or propel the abrasive media at the substrate.1** Compressed air
systems blast the abrasive at the substrate. Finally, the water
blast method uses either compressed air or high-pressure water.17
The most popular systems are those that use either air pressure
or water pressure to propel the abrasive material. Therefore,
only these methods are described.
The "compressed air suction," the "compressed air pressure,"
and the "wet abrasive blasting" systems use air to create the
driving force for propelling the abrasive material out of the
gun. Hydraulic blasting systems use water to create this driving
force.
Compressed air suction systems include two rubber hoses that
are connected to the blasting gun. One delivers air from the
compressed-air supply, and the other delivers media from the
abrasive supply tank or "pot." The gun (Figure 2-5) consists of
an air nozzle that discharges into a larger nozzle. The high-
velocity air jet (expanding into the larger nozzle) creates a
partial vacuum in the chamber. This vacuum draws the abrasive
into the outer nozzle and expels it through the discharge
2-32
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TABLE 2-7. MEDIA COMMONLY USED IN ABRASIVE BLASTING13'14
Type of medium
Glass beads
Aluminum oxide
Garnet
Crushed glass
Steel shot
Steel grit
Cut plastic
Crushed nutshells
Sizes normally available
8 to 10 sizes from 30 to 440 mesh;
also many special gradations
10 to 12 sizes from 24 to 325 mesh
6 to 8 sizes (wide-band screening)
from 16 to 325 mesh
5 sizes (wide-band screening) from
30 to 400 mesh
12 or more sizes (close gradation)
from 8 to 200 mesh
12 or more sizes (close gradation)
from 10 to 325 mesh
3 sizes (fine, medium, coarse);
definite-size particles
6 sizes (wide-band screening)
Applications
Decorative blending; light deburring; peening; general
cleaning; texturing; noncontaminating applications
Fast cutting; matte finishes; descaling and cleaning of
coarse and sharp textures
Noncritical cleaning and cutting; texturing;
noncontaminating for brazing steel and stainless steel
Fast cutting; low cost; short life; abrasive;
noncontaminating applications
General-purpose rough cleaning (foundry operation,
etc.); peening
Rough cleaning; coarse textures; foundry welding
applications; some texturing
Deflashing of thermoset plastics; cleaning; light
deburring
Deflashing of plastics; cleaning; very light deburring;
fragile parts
TABLE 2-8. COMPOSITIONS OF BLAST MEDIA
15
Trade or common name
Natural sand
Green Diamond
Polygrit
Boiler slag
Dolcite Porphyry
Black Diamond
Composition
Essentially pure silicon dioxide
Copper slag containing residues of free silica, lead, nickel, and chromium
Cuprous slag
Silica containing iron oxide, alumina, and traces of magnesium, calcium,
copper, lead, tin, antimony, and arsenic oxides
Igneous crushed rock
Iron slag containing silica, iron, aluminum, calcium, magnesium and
titanium oxides, sulfates, phosphorus, manganese and carin
2-33
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Gasket
Air nozzle
Nozzle
Suction nozzle
body
Figure 2-5. Suction blast nozzle assembly.
17
2-34
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opening. Figure 2-6 shows a typical suction-type blasting
machine.
Figure 2-7 illustrates the compressed air pressure system.
Pressure in the tank forces" abrasive through the blast hose
rather than siphoning it, as in the suction-type system. The
compressed air line is connected to both the top and bottom of
the pressure tank. This allows the abrasive to flow by gravity
into the discharge hose without loss of pressure (see
Figure 2-7).
Finally, wet abrasive blasting systems (Figure 2-8) propel a
mixture of abrasive and water with compressed air. (An alternate
method uses a pressure tank and a modified abrasive blasting
nozzle, Figure 2-9.)
Figure 2-10 illustrates the nozzle used for yet another
blast scheme. Hydraulic blasting incorporates a nozzle similar
to that of air suction systems. High-pressure water is used
instead of compressed air as the propelling force.
Pressure blast systems generally give a faster, more uniform
finish and use less air than do suction blast systems. Pressure
blast systems can operate at as low as 1 pound per square inch
(psig) to blast delicate parts and up to 125 psig to handle the
most demanding cleaning and finishing operations.14
Suction blast systems are generally selected for light to
medium production requirements, limited space, and moderate •
budgets. Since the suction blast systems use open-top
reservoirs, it is unnecessary to stop blasting to change the
abrasive or refill the supply tank.1-^'14
2.3 BASELINE EMISSIONS
2.3.1 VOC Emissions
Figure 2-11 shows the annual usage breakdown of all marine
paint categories. Table 2-9 gives the average of the reported
solvent VOC contents for specialty and general use categories,
respectively (weighted by volume).5 Using these average values
which assume that all "as supplied" paint solvents and thinners
are emitted, VOC emissions on a per-gallon basis are then
calculated for each paint and thinning solvent category. These
2-35
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Abrasive :;•;:;•::;
Abrasive drawn into
gun by suction
Air —
Figure 2-6. Suction-type blasting machine.17
Abrasive control
Choke relief valve
3 > Equal air pressure
above and below
abrasive
Figure 2-7. Pressure-type blasting machine.13
2-36
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Water
Air supply valve
•Air
Choke relief valve
Equal air pressure
above and below
abrasive
Figure 2-8. Wet blasting machine.
13
2-37
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Water
Figure 2-9.
Adapter nozzle converting a dry blasting unit
to a wet blasting unit.13
2-38
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Water
/
II \
Abrasives
/
Figure 2-10. Hydraulic blasting nozzle.13
2-39
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TABLE 2-9. AVERAGE VOC CONTENT OF "AS SUPPLIED" PAINTS5
Paint category
General use - Alkyd
General use - epoxy
Antifoulant
Repair and maintenance
thermoplastics
Fire retardant
Heat resistant/high temperature
(HR/HT)
High gloss
Inorganic zinc
Nuclear (low activation interior-
LAI)
Organic zinc
Pretreatment wash primer
Special marking
Total reported usage,
L(g8l)a
604,765 (159,658)
3,515,080 (927,981)
674,466 (178,059)
122,886 (32,422)
297,432 (78,522)
22,360 (5,903)
65,174(17,206)
570,064 (150,497)
35,026 (9,247)
28,114(7,422)
8,235 (2,174)
38,473 (10,157)
Average VOC content
g/L (less water
and 'exempt"
solvents)
474
350
388
493
360
466
492
545
401
548
712
446
Ib/gal (less water
and "exempt*
solvents}
3.95
2.92
3.23
4.11
3.00
3.88
4.10
4.54
3.34
4.57
5.93
3.72
"Total from the 37 shipyard responses in data base.'
2-41
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values are the sums of the solvent contents of all reported paint
and thinning solvents used. The figures do not include the
t
contribution of reaction byproducts to the total VOC emitted.
Paint/solvent usage breakdowns for each model yard are provided
in Chapter 4, as are baseline emissions estimates for each of the
uncontrolled model plant categories.
2.3.2 PM-10 Emissions
Table 2-10 summarizes the test data available on PM-10 and
respirable particulate matter (RP) emissions from the abrasive
blasting of ship hulls and other structures. The data sets were
evaluated using the criteria and rating system developed by EPA's
Office of Air Quality Planning and Standards (OAQPS) for
developing AP-42 emission factors. In Chose cases where emission
factors were presented in the reference document, the reliability
of these emission factors was indicated by an overall rating
ranging from A (excellent) to E (unacceptable). These ratings
took into account the type and amount of data from which the
factors were derived. Based on the criteria and rating system
developed by OAQPS, emission factors reported in Table 2-10 for
particulate matter emissions from abrasive blasting operations
were below average in quality.1^ Although measurable levels of
RP were documented from blasting ship hulls, there was
insufficient information to support the relationship between the
amount of PM-10 found, the type of abrasive, and the type of
docking facility tested. Emissions data gathered for abrasive
blasting of ship hulls and other structures (Table 2-10) are
incomplete and give little insight. Therefore, it is concluded
that the currently available data gathered for nonsimilar
applications cannot be used to estimate emissions from blasting
operations at shipyards.
If the analogy of spraying paint and blasting media against
substrates has any validity, it is clear that developing emission
factors for blasting will be challenging. Studies of paint spray
transfer efficiency (the portion of paint leaving the spray gun
that adheres to the substrate being painted) conducted by the
U. S. EPA several years ago revealed that the variable to which
2-42
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transfer efficiency is most sensitive is the velocity of
ventilation air in the spray booth.
One could readily conclude that the emissions of fine
particulate associated with blasting are a function of the
particle distribution of the blast media, the friability of both
the media and the coating and corrosion products being removed,
wind speed and direction, relative humidity, and downwind
distance of the sampling point. If true, the accuracy or
validity of emission factors will continue to be gross estimates
until a study is performed that incorporate all of the essential
variables.
It is believed that any PM-10 released by the blasting
process is likely to be found among the more visible portion of
the downwind plume and would likely remain airborne longer than
the larger (heavier) particulate. Using such reasoning, one
could conclude that any visible downwind plume contains some
PM-10, and the further from the blast site, the greater its
portion of the total particulate, as it is naturally winnowed
from the larger particles.
2.4 EXISTING REGULATIONS
Regulations that affect the emissions of VOC's and PM-10
from shipyards are discussed in this section. First, the
constraints imposed upon shipyards by the Clean Air Act
Amendments of 1990 are discussed. This discussion is followed by
a summary of existing regulations for VOC and PM-10 emissions
that are used in various States to control emissions from
shipyards.
2.4.1 Retirements of the Clean Air Act Amendments of 1990
Section 130 of the 1990 Amendments requires EPA within
6 months after enactment, and at least every 3 years thereafter,
to review and, if necessary, revise methods for estimating
emissions. These emission estimation methods are used primarily
by States to develop emission inventories for criteria pollutants
in nonattainment areas (NAA's) (areas not meeting the National
Ambient Air Quality Standards [NAAQS]). The criteria pollutant
emission inventories are used to develop control strategies that
2-44
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are reflected in State implementation plans (SIP'a), to track
reasonable further progress for bringing NAA's into attainment
with the NAAQS, and to perform air quality studies and
monitoring. Shipyards are one of the sources that need to be
considered in the SIP process.
2.4.1.1 Area Classifications. Nonattainment areas are
designated by EPA, which assigns one of five classes for ozone
and one of two classes for PM-10. Table 2-11 shows the criteria
by which EPA designates the nonattainment classes and the
respective dates by which the 1990 Amendments require that
attainment of the NAAQS for ozone and PM-10 must be met. For the
purpose of class designation, the ozone design value for an area
is defined as the facility's fourth highest monitored ozone
concentration for the years 1987 through 1989.
2.4.1.2 Ozone and PM-10 Emission Inventories. The 1990
Amendments require States with ozone NAA's in any of the five
area classes shown in Table 2-11 to have submitted a baseline
emission inventory for those areas by November 15, 1992. This
baseline emission inventory must be based on the 1990 peak ozone
season, typically between June and August. Shipyards were to be
one of the sources inventoried. All future progress toward
attainment of the primary standard will be measured against the
baseline emission inventories. The 1990 Amendments require
States to submit periodic (revised) ozone emission inventories
every 3 years, beginning November 15, 1995, until areas are in
attainment with the primary standard. Figure 2-12 shows a
timeline for State submittals of ozone emission inventories to
EPA. The 1990 Amendments do not specifically require baseline
emission inventories for PM-10 but do specify a schedule for
PM-10 SIP submittals, which will probably require PM-10 emission
inventories. The EPA plans for States with NAA's to submit PM-10
emission inventories according to the schedule shown in
Figure 2-12.
It is anticipated that shipyard contributions to the
reasonable further progress deadlines for ozone can be estimated
and tracked using paint and solvent usage records. Emissions of
2-45
-------
TABLE 2-11.
1990 CLEAN AIR ACT AMENDMENT ATTAINMENT DATES
FOR PRIMARY STANDARD
1 Ozone
Area
class
Marginal
Moderate
Serious
Severe
Severe
Extreme
Design value,
ppm
0.121 up to (but
not including)
0.138
0.138 up to (but
not including)
0.160
0.160 up to (but
not including)
0.180
0.1 80 up to (but
not including)
0.280
0.180 up to (but
not including)
0.190
0. 190 up to (but
not including)
0.280*
0.280 and above
Attainment
November 15, 1993
November 15, 19%
November 15, 1999
November 15, 2005
November 15, 2005
November 15, 2007
November 15, 2010
PM-10
Area class
Moderate
Serious
X*
Attainment
December 31, 1994 for
Section 107(d)(4) areas,
otherwise 6 years after
designation
December 31, 2001 for
Section 107(d)(4) areas,
otherwise 10 years after
designation
a!988 ozone design value only.
2-46
-------
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PM-10, however, are unknown. Emission factors for PM-10 from
shipyard operations have not yet been and will not be easily
developed. For this reason, it will be difficult to estimate any
potential contribution or reasonable further progress of the
shipyard for PM-10.
2.4.2 Summary of Existing Regulations
An understanding of existing regulations is crucial in
assessing regulatory and cost impacts, as well in determining
appropriate control measures for the industry. States and
localities with existing regulations are Virginia, Connecticut,
Louisiana, Maine, Washington, Wisconsin, California, and
California's Bay Area, South Coast, and San Diego County Air
Pollution Control Districts.11 Table 2-^12 summarizes these
regulations. The regulations pertain to the marine coating of
ships and the resulting VOC emissions and to the outdoor abrasive
blasting of ships and the associated PM-10 emissions. These
regulations were reviewed to determine whether the rules are
shipyard-specific. California and Louisiana are the only States
with regulations that specifically address the shipbuilding and
ship repair industry. For those States/localities and/or unit
operations for which shipyard-specific regulations do not exist,
there are general provisions for regulating emissions from
shipyards. The regulations are described in greater detail
below.
2.4.2.1 Marine Coating and VOC Requirements. The
California Air Resources Board's and California's Bay Area, South
Coast, and San Diego County Air Pollution Control Districts'
regulations specifically limit emissions from the shipbuilding
and ship repair industry. They specify maximum VOC contents for
paints typically used in specific applications (e.g., as
antifoulants). Louisiana enforces VOC limits for its shipyards
by estimating facility emissions from paint material safety data
sheets (MSDS's) and comparing those emissions with the maximum
allowable VOC contents defined by the regulation. Louisiana has
adopted VOC limits for various specialty marine coating
categories that are similar to those adopted by California. (Use
2-48
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TABLE 2-12. SUMMARY OF EXISTING REGULATIONS11
Area
California Air Resources Board
(CARB)
SCAQMD
BAAQMD
San Diego APCD
Connecticut
Maine
Washington
Wisconsin
Louisiana
Virginia
Marine coatings and VQC's
Require use of low-VOC coatings.
Require control of solvent emissions
from equipment cleaning and thinning
paint.
See Table 2-14.
Adopted CARB rules.
Adopted CARB rules.
Adopted CARB rules.
California's Rule 66.
Generic RACT* for sources
> 100 tons.
Require low-VOC paints for indoor
coating.
Require new sources to use BACT".
Existing permitted sources renew
operating licenses every 5 years.
Regulate spray coatings under general
provisions.
California's Rule 66.
Title 33 regulates criteria pollutants.
Chapter 21 regulates VOC emissions
reported on MSDS's.
VOC limits similar to California's.
N/A
Abrasive blasting and PM-10
Stringent regulation.
See Figure 2-13.
Adopted CARB rules.
Adopted CARB rules.
Adopted CARB rules.
N/A
N/A
Tarp blasting operations.
Regulate on a "complaint basis. "
No blasting if wind speed is
>20 mph.
Fugitive rule for participate matter.
Specific to blasting process.
Require tarping of blasting area.
20 percent opacity visibility
standard.
Require "adequate containment of
sandblasting or similar operations. "
N/A = Not available or not applicable.
^Reasonably available control technology.
"Best available control technology.
2-49
-------
of the MSDS for compliance indicates that the enforcement
mechanism incorporates a margin of safety for the shipyards. The
EPA reference method considers cure volatiles which the MSDS does
not.) A comparison of California and Louisiana VOC limits is
given in Table 2-13.
Connecticut and Wisconsin do not regulate VOC emissions
directly from shipyards. They do, however, require coating
manufacturers to substitute slower reactive solvents using the
old "California Rule 66" to delay formation of ozone. Rule 66,
promulgated in California in 1962, required an 85 percent
reduction in highly photochemically reactive compounds by
substitution of more slowly reacting solvents that it identified
as "exempt." In 1976, EPA published a VOC policy statement in
the Federal Register that noted that essentially all organics are
photochemically reactive and urged States to change their
substitution rules as EPA provided more specific guidance. A few
States have not withdrawn Rule 66 even though it does not
constrain ozone formation.
Maine and Washington have general State provisions that
allow VOC emissions to be regulated. Under Maine's regulations,
new sources are required to use best available control technology
(BACT) feo control emissions, and existing permitted sources are
required to renew their operating licenses every 5 years.
Washington's Puget Sound Air Pollution Control Agency's rule
restricts or prevents painting operations when wind speeds exceed
20 miles per hour (mph).
2.4.2.2 Abrasive Blasting and PM-10 Requirements. The most
stringent abrasive blasting regulation adopted in the United
States to date (adopted November 1990) is in the State of
California. A summary of the regulation guidelines is provided
in Figure 2-13.18'19 The regulation states that abrasive
blasting can be conducted either inside or outside of a permanent
building. Stack emissions from indoor abrasive blasting must
meet a Ringlemann 1 (20 percent opacity) visibility emission
standard, regardless of the abrasive or the abrasive blasting
method used. All outdoor abrasive blasting is required to meet a
2-50
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TABLE 2-13. STATE VOC LIMIT COMPARISON11
(Expressed in units of g/L and Ib/gal of coating as applied,
minus water and exempt solvent)
Coating category
General limits
Antenna
Antifoulant
Heat-resistant
High-gloss
High-temperature
Inorganic zinc
Low-activation
ulterior (Nuclear)
Military exterior
Navigational aids
Pretreatment wash primer
Repair and maintenance
thermoplastics
Wire spray sealant
Specialty interior
Special marking
Tack coat
Undersea weapons systems
Extreme high-gloss
Metallic heat-resistant
Anchor chain asphalt
(TT-V-51)
Wood spar varnish
(TT-V-119)
Dull black finish
(DOD-P-15146)
Tank coatings
(DOD-P-23236)
Potable water tank coating
(DOD-P-23236)
Flight deck markings
(DOD-C-24667)
Vinyl acrylic top coats
AntifoulantS on aluminum
hulls
Elastomeric adhesives (with
15 wt % rubber)
California VOC limits
g/L
Sept. '92
340
530
400
420
420
500
650
420
340
550
780
550
610
340
490
610
340
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Sept. '94
340
340
400
420
420
500
340
420
340
340
420
340
610
340
420
610
340
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Ib/gal
Sept '92
2.8
4.4
3.3
3.5
3.5
4.2
5.4
3:5
2.8
4.6
6.5
4.6
5.1
2.8
4.1
5.1
2.8
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Sept, *94
2.8
2.8
3.3
3.5
3.5
4.2
2.8
3.5
2.8
2.8
3.5
2.8
5.1
2.8
3.5
5.1
2.8
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Louisiana, VOC limits
srt-
Ib/gal
Ju!y*91
420
490
440
420
420
650
650
490
420
420
780
650
648
420
490
610
490
530
620
492
444
420
444
504
648
550
730
3.5
4.1
3.7
3.5
3.5
5.4
5.4
4.1
3.5
3.5
6.5
5.4
5.4
3.5
4.1
5.1
4.1
4.4
5.2
4.1
3.7
3.5
3.7
4.2
5.4
4.5
6.1
2-51
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OUTSIDE
CONDUCTED INSIDE
OR OUTSIDE OF A
PERMANENT BUILDING
INSIDE
MUST MEET ONE
OF THE PERFORMANCE
STANDARDS
MUST MEET
RINGLEMAN NO. 1
1. STEEL OR IRON
GRIT/SHOT
1
2. GREATER THAN
8 FEET
DIMENSION
\
3. PERMANENT
LOCATION
I
MUST USE EXCLUSIVELY
ONE OF BELOW
1
i
1. WET
•LASTING
i
r
2. HYORO-
BLASTINQ
i
3. VACUUM
BLASTING
i
t
4. CERTIFIED
ABRASIVE
Figure 2-13.
F;roianatory flow diagram of California's blasting
regulation provided by NASSCO.18'19
2-52
-------
Ringlemann 2 (40 percent opacity) visibility emission standard.
To conduct abrasive blasting outside, one of these criteria must
be met: (1) steel or iron shot/grit must be used exclusively,
(2) the item being blasted must exceed 8 ft in any dimension, or
(3) the item being blasted must be at or close to its permanent
location. If Options 2 and 3 are met, then wet abrasive
blasting, hydroblasting, vacuum blasting, or dry blasting with a
certified abrasive must be used. The grades and brands of
abrasives certified by GARB are listed in Table 2-14. According
to the regulation, abrasives are certified biannually based on
particle size and distribution. Abrasives are certified to
restrict the types of abrasives used in dry unconfined blasting
for the purpose of reducing the amount of fine particles
introduced to the blasting process. The particle size and
distribution constraints ("cut-point for fineness") criterion
allows abrasives to be reused only if they can be shown to still
meet the physical requirements.18
Virginia, Washington, and Wisconsin also have requirements
for open blasting operations. These regulate total particulates,
not PM-10. Virginia has adopted a general 20 percent opacity
visibility emission standard. Virginia has also adopted a
standard that requires facilities to take reasonable precautions
to prevent particulate matter from becoming airborne.
Washington's Puget Sound rules state that if fugitive dust from
blasting (or any process) becomes a public nuisance, the agency
can intervene with some measure to reduce the fugitive emissions.
The agency also restricts blasting operations when wind speeds
exceed 20 mph. Wisconsin has adopted a general fugitive rule for
PM emissions from blasting.^
2-53
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TABLE 2-14. ABRASIVES CERTIFIED BY GARB
Company
Alpheus Cleaning Technologies Corp.
Rancho Cucamonga, CA
Apache Abrasive, Inc.
Houston, TX
Applied Industrial Materials Corp., (AIMCOR)
Deerfield, IL
R.A. Barnes, Inc.
Portland, OR
Barton Mines Corp.
North Creek, NY
Blackhawk Slag Products
Midvale, CT
California Silica Products Company
San Juan Capistrano, CA
Cominco-American Resources, Glenbrook Nickel Company
Riddle, OR
Corona Industrial Sand Company
Corona, CA
Crystal Peak Garnet Corp.
Vancouver, BC, Canada
Desert Garnet
Cadix, CA
Don Kelland Materials, Inc.
Yuma, AZ
Dwyer Consolidated Mines, Inc.
Thousand Palms, CA
£. I. Du Pont de Nemours & Company, Inc.
Wilmington, DE
Emerald Creek Garnet Milling Company
Femwood, ED
Gordon Sand Company
Compton, CA
Foster-Dudana Corp.
Columbia, SC
Norfolk Plant
Chesapeake, VA
Columbia Plant
West Columbia, SC
Savannah Pier.!
Hardeeville, SC
Fusco Abrasive Systems, Inc.
Compton, CA
Brand name or grade
CC*2 Cleanblast
Apache-Blast 12-50 and Utility
Green Lightning 20 x 46 <
Safe-T-Blast Types I and U
Barton 1640
Blackhawk; Fine, Medium, Utility
Nos. 12, 16, 20, 30
Ruby Garnet; 16, 36
Cisco Nos. 12, 16, 20, 30
16-40
Gemshot Nos. 36, 30-60
Geronimo Nos. 36, 30-60
Arizona Utility
Garnet Storm Nos. 16, 20, 40, 60
Starblast, cpff = No. 200 sieve
Starblast XL, cpff = No. 200 sieve
Zirclean, cpff = 270 sieve
Nos. 36, 30/40, SOX
Black Diamond-CX8, CX12
U.S. Technology Corp., Poly Plus
2-54
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TABLE 2-14. (continued)
Company
Garnet Millers Australia (manufacturer)
Geraldton, Australia
Barton Mines Corp.
Golden, CO
Gordan Sand Company (distributor)
Compton, GA
Gemstar Stone Products Company
Hunt Valley, MD
P. W. Gillibrand Company
Simi Valley, CA
Glenbrook Nickel Company
Riddle, OR
Gordan Sand Company
Compton, CA
Grangrit, Inc.
Harvey, LA
Harsco Corp., Reed Mineral Division
Highland, IN
Reed Minerals/Harsco
Memphis, IN
Concord [Bowl], NH
Gary, NH
Drakesboro, KY
Hydro-Air Products, Inc.
Vernon, CA
Industrial Minerals Products Inc. , reserve abrasives
Cebu City, Phillipinea
Kayway Industries, Inc.
Winnipeg, Mantoba, Canada
3M Company
Corona, CA
Minerals Research and Recovery of Arizona, Inc.
Tuscon, AZ
Pacific Abrasives & Supply & Inc.
Grand Forks, BC, Canada
Parker Brothers & Company, Inc.
Houston, TX
Parker Mining Corp.
San Francisco, CA
Brand name or grade
ROM 30 X 60
Camel Black, Utility Grade
Gillibrand; Silver Nos. 12, 16,
20, 30
Gillibrand; M-16, M-20, M-30
Green Diamond; 10-40, 16-36,
16-50, 20-50
Golden Flint; G-16, G-20, G30
Lapis Luster; G-12
Silver Flint; S-12, S-16, S-20, S-30
Grangrit-Medium
Black Beauty-2250
Black Beauty- 1243, 2043
Black Beauty-2550
Black Beauty- 1040, Black Beauty- 1240
Du Pont Coarse Staurolite
Utility
Kayway Grit; 16-30, 20-40
3M; C-110, C-lll
Sharpshot; F-80(25), F-80(36), M-#>
Kleen Blast; 16-30, 35, 16, 8-12, 30-60
8-20, 12-50
Little Sister Garnet Grade; 28, 40
2-55
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TABLE 2-14. (continued)
Company
RDM Multi-Enterprises, Inc.
Anaconda, MT
Ron Hanna Mining Company
Prescott, AZ
RMC Lonestar
Pleasanton, CA
Spreckles Limestone and Aggregate Products
Cool, GA
Silica Resources, Inc.
Marysville, CA
Stan-Blast Abrasive Company, Inc.
Harvey, LA
Tidewater Materials of Virginia, Inc.
Houston, TX
Unimim Corp.
Emmett, ID
Union Pacific Resources
Magna, UT
Valley Sand and Gravel
Trona, CA
Virginia Materials Corp.
Norfolk, VA
Waupaca Materials, a division of Falks Bros. Construction
Company, Inc.
Waupaca, WI
Brand name or grade
Ferro Blast; 8-20, 16-30, 36 fine,
30-60 X-fine
Best Grith; 8-20, 16-30, 36 'fine,
30-60 X-fine
Ferro Blast-73 Nos. 8/20, 16/30, 36
Superior; coarse, medium
Lapis-Luster Nos. 3, 1/20, 1C, 2/12,
2/16, 0/30
.Clementina Nos. 3, 1/20, 1C, 2/12,
2/16, 0/30
Calcarb; medium, coarse
SRI Premium Nos. 8, 12, 16, 20, 30
Stan-Blast-Galveston, TX
San-Blast-Harvey, LA
Sure-Shot Utility (New Orleans plant)
Sure-Shot Utility (Portsmouth plant)
Granusil Nos. 16, 20, 30
Copper Blast Medium
Dynacut; 100, coarse, medium MSR
(fine)
Desert Diamond coarse, medium
VMC Black Blast
Blackjack MSM
acpff = cut point for fineness.
2-56
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2.5 REFERENCES
1. Memorandum from Reeves, D. W., Midwest Research Institute,
to Driver, L. M., EPA/CPB. March 24, 1992. Source Category
Definition.
2. U. S. Maritime Directory Listings. U. S. Shipyards. Marine
Log. £7:49-59. June 1992.
3. U. S. Department of Commerce, U. S. Industrial Outlook '92--
Shipbuilding and Repair. January 1992. 7 pp.
4. Meredith, J. W., M. Moskowitz, J. G. Keesky, and D. Harrison
(CENTEC Corporation). VOC Emission Control Technologies for
Ship Painting Facilities - Industry Characterization.
Prepared for U. S. Environmental Protection Agency.
Cincinnati, Ohio. Publication No. EPA-600/2-8-131. July
1981.
5. Memorandum from deOlloqui, V., MRI/'to Project File.
Facilities in the Shipbuilding and Ship Repair Data Base.
November 11, 1992.
6. Memorandum from deOlloqui, V., MRI, to Project File. List
of Coating Manufacturers Surveyed. November 16, 1992.
7. Letter and attachments from Rodgers, S. D., Naval Sea
Systems Command, to Bennett, A., EPA. November 24, 1986.
16 pp. Response to requested materials from November 7,
1986 meeting.
8. Brandau, A. H. (Consolidated Research, Inc.). Introduction
to Coating Technology. Blue Bell, Pennsylvania, Federation
of Societies for Coatings Technology. October, 1990.
46 pp.
9. Bleile, H. R. and S. Rodgers. Marine Coatings, Federation
of Societies for Coatings Technology. March 1989. 28 pp.
10. Ellis, W. H. Solvents, Philadelphia, Federation of
Societies for Coatings Technology. October 1986. 19 pp.
11. Belik, D. (Chair, Industrial Coatings Committee). Report to
the Technical Review Group on the Development of the
suggested control measure for the surface coating of marine
vessels. Prepared for California Air Pollution Control
Officers Association/Air Resources Board (CAPCOA/ARB)
Technical Review Group. December 26, 1989. 35 pp.
2-57
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-12. Environmental Paints and Coatings Training Program
Materials. Prepared for Stationary Source Compliance
Division, U. S. Environmental Protection Agency.
Washington, B.C. Contract No. 68-02-4465. Prepared by Ron
Joseph and Associates, Inc. and Alliance Technologies
Corporation. May 1989.
13. Midwest Research Institute. Assessment of Outdoor Abrasive
Blasting. Prepared for U. S. Environmental Protection
Agency. Research Triangle Park, NC. September 11, 1989.
14. South Coast Air Quality Management District. Section 2:
Unconfined Abrasive Blasting. Draft Document. El Monte,
CA. September 8, 1988.
15. Department of the Navy. Abrasive Blasting of Naval
Shipyards. Draft Environmental Impact Statement.
Washington, D.C. October 1, 1973.
16. Mallory, A. W. Guidelines for Centrifugal Blast Cleaning.
Journal of Protective Coatings and Linings, i(l). June
1984.
17. Baldwin, B. Methods of Dust-Free Abrasive Blast Cleaning.
Plant Engineering. 12(4). February 16, 1978.
18. State of California Air Resources Board. Technical Support
Document for the Report to the California State Legislature.
Prospects for Attaining the State Ambient Air Quality
Standards for PM-10, VRP, Sulfates, Lead and Hydrogen
Sulfide. Draft Document. January 1991.
19. State of California Air Resources Board. Public Hearing to
Consider the Adoption of Amendments to the Abrasive Blasting
Regulations. Staff Report. September 21, 1990.
2-58
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3.0 EMISSION CONTROL TECHNIQUES
3.1 INTRODUCTION
Emissions from shipyard operations are primarily volatile
organic compound (VOC) emissions that result from shipyard
painting operations. Particulate matter^ less than 10 microns in
diameter (PM-10) also is emitted from abrasive blasting conducted
to prepare ship surfaces for painting. This chapter discusses
control techniques that are demonstrated and those for which
technology transfer appears to be applicable to control shipyard
emissions. Section 3.2 discusses the control techniques that
apply to painting, Section 3.3 discusses those that apply to
cleaning, and controls that can be applied to abrasive blasting
operations are discussed in Section 3.4. In addition, Section
3.5 discusses other available measures for both VOC and PM-10
emissions control.
3.2 PAINTING OPERATIONS
Emissions of VOC's from painting operations result from
three components: (1) organic solvent in the paint "as supplied"
by the paint manufacturer, (2) organic solvent in the thinner,
which is added to the paint prior to application and becomes part
of the paint "as applied", and (3) any additional volatile
organic released during the cure. The organic solvents from both
components are emitted as the applied paint dries/cures. This
organic solvent portion of a paint is composed of a mixture of
different solvents that perform either of two equally important
functions: (1) reduce viscosity so the paint can be atomized as
3-1
-------
it leaves the spray gun or (2) provide essential surface
characteristics of the paint once it is applied. Solvents used
for atomization typically have low boiling points and flash to a
vapor upon leaving the spray gun. These solvents evaporate
relatively quickly during initial drying to prevent excessive
flow. Solvents responsible for imparting the desired surface
characteristics must have higher boiling points and subsequently
evaporate more slowly than atomizing solvents to allow sufficient
leveling and adhesion.1 Of the solvents used in marine paints,
most are VOC's.2
3.2.1 Lower-VOC Coatings
Historically, the selection of marine paints was centered
around two characteristics, performance,-and cost. Now, with the
implementation of the 1990 Clean Air Act Amendments, the emphasis
will shift to lowering both the VOC and hazardous air pollution
(HAP) content of paints. Since most HAPs that are found in paint
are volatile organics, the previous trend to lower VOC coatings
has undoubtedly also reduced HAPs in the aggregate! Lower VOC
coatings have been of two general types, waterborne and higher-
solids coatings. Both have a lower VOC-to-solids ratio than
traditional coatings.3 Waterbornes have not made significant
inroads into this industry. The regulatory alternatives
presented are all essentially based on higher solids
formulations.
3.2.2 Paint Heating Systems
Paint heaters can be used in place of or in conjunction with
paint solvents (i.e., thinners, reducers, etc.) to reduce paint
viscosity by heating the paint prior to application using an in-
line heating element just upstream of the spray gun. Paint
heaters are used by at least two shipyards and many have also
been used in a variety of industrial and automotive paint
applications.2 These heaters appear adaptable to any paint spray
system but are most often used to reduce the viscosity of higher-
solids coatings. The increase in paint temperature that a single
heater can provide depends on the paint flow rate; the lower the
flowrate, the greater the temperature increase. One manufacturer
3-2
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indicates that an in-line heater can increase paint temperatures
by 38°C (100°F) at 0.76 liters per minute (L/min) (0.2 gallon per
minute [gal/min]), 22°C (72°F) at 1.51 L/min (0.4 gal/min), and
6°C (43°F) at 3.0 L/min (0.8 gal/min).4 The relationship between
temperature and viscosity varies somewhat between coatings and
depends on the physical properties of the paint.
Paint heaters reportedly are not a panacea for visosity
problems. Representatives of shipyards in colder climates have
complained that applying heated paint to cold surfaces in winter
months results in poor paint surface characteristics
(i.e., cracking) because of the rapid cooling of the hot paint
after it is applied to the cold surface.2
3.2.3 VOC Add-On Controls
Add-on pollution control devices are used by many
industries to control VOC emissions from paints. The efficiency
of the control system depends on the capture efficiency of the
enclosure used to contain the paint emissions aa well as the
removal/destruction efficiency of the add-on control device to
which the emissions are routed.
Most of the painting that occurs within this industry
involves outdoor painting of very large vessels. Emissions from
outdoor painting are expensive to control due to the difficulty
of effectively enclosing the large substrates. With existing
technology, add-on controls are technically feasible for only one
outdoor painting process, the painting of tanks, because the tank
itself is a natural enclosure. See Chapter 5 and Appendix C for
cost information.
One recent innovation, a patented portable enclosure system
to contain grit during hull blasting, has potential for
containing VOC as well. Pilot demonstrations have been
conducted, but the device is not yet commercially available.
A small percentage of indoor painting is performed relative
to outdoor painting: This includes painting of internal ship
compartments and spray booth painting of smaller ship parts
within buildings prior to assembly. Because emissions from'
indoor painting operations are more esily contained, it is
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technically feasible to capture and route emissions directly to a
control device.
For control of indoor painting (including tanks) emissions,
the add-on devices evaluated are thermal and catalytic
incinerators and carbon adsorption systems. Incinerators are
control devices that destroy VOC contaminants using combustion,
converting them primarily to carbon dioxide (€02) and water.
Carbon adsorbers are recovery devices that collect VOC's on an
activated carbon bed. The VOC's are recovered when the carbon
bed is regenerated using steam or hot air. The steam or hot air
also reactivates the carbon bed. The recovered VOC's are then
disposed of or destroyed. Summaries of these add-on control
devices, their associated costs, and their performance
characteristics are in References 6, 7, and 8, respectively.
3.2.4 Potential Emission Reductions
Chapter 2 identifies the coating categories used for
specialty purposes in the marine industry. All other paints that
are not used for these specialty purposes are considered a
"general-use" paint. General-use paints are identified by resin
type, e.g. epoxies and alkyds. Of the 23 categories (22
specialty and 1 general-use), 3 account for approximately 90
percent of the total emissions: antifoulants, inorganic zincs,
and general-use (primarily the: epoxies and alkyds). Emission
reductions options were evaluated for these three coating
categories.
California limits for these three categories were developed
in the late 1980's to force research for lower VOC coatings.
Those limits, now being achieved by shipyards in that state, were
used as a benchmark. Emission reductions elsewhere across the
Nation were estimated by calculating the emission reductions
achievable if coatings currently in use were replaced with higher
solids products. It was assumed that those yards currently using
higher VOC coatings would switch to coatings with VOC levels
equal to the weighted average VOC content of all coatings in the
data base at or below a regulatory limit. In other words, it was
assumed that the distribution of all higher solids coatings used
3-4
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after a role is in effect would be similar to that of the
compliant coatings currently available.
Also, the emission reductions that could be achieved by
using paint heaters in lieu of or in conjunction with thinning
solvents were evaluated as was the reductions associated with
ducting spray booth emissions to add-on control devices.
Reductions in VOC emissions would be obtained from all of these
control options; however, by far the most significant reductions
would result from shipyards transitioning to reformulated
coatings. The reductions achieved from implementing these
options and the associated costs are outlined in more detail in
Chapter 5.
3.3 SOLVENT CLEANING
The Alternative Control Techniques (ACT) document for
Industrial Cleaning Solvents 9 suggests a two-step program for
reducing solvent emissions. The first element of this program
consists of tracking the use, fate, and costs of all cleaning
solvents. The second element consists of actions management may
take to reduce or control emissions based on the knowledge of
gained cleaning solvent use, fate, and costs. ^
Cleaning solvents are used at shipyards to prepare surfaces
prior to painting and to clean spray equipment including spray
guns, lines, pumps, and containers (pots) used to hold the paint.
All of the equipment, except the pots, are usually cleaned by
purging solvent through the spray system (i.e., the spray gun
with the paint line and pump still attached) into a container.
The solvent-filled container is then emptied into a 55-gallon
waste drum. Paint pots are also cleaned with solvent. Any dried
paint remaining in the pot after cleaning is removed with a
brush.2'10 The ACT discusses cleaning practices and work
practices for reducing evaporation during use thereby reducing
solvent purchase and disposal costs. It also encourages
investigation of alternative cleaning solutions including
substitution of solvents that are less volatile.
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3.3.1 gleaning Practice Modifications ^
Certain cleaning practices can be modified to minimize the
amount of solvent used as well as the evaporative losses. Using
special solvent dispensers for wiping a surface with rags and
disposing.of the rags in a covered container will help reduce
evaporation. Also, emptying the spray gun of paint prior to
cleaning (i.e., spraying the equipment dry) and cleaning
equipment promptly after use (not allowing the paint to dry in/on
equipment) reduce the amount of solvent required.
Cleaning practices that reduce evaporative emissions include
(1) lowering the gun pressure (decreasing air and paint pressure)
during cleaning to eliminate or minimize atomization of the
solvent, and (2) storing solvent in closed containers and
discharging cleaning solvent into a vented container through a
small opening that accommodate only the tip of the spray gun.
Waste solvent containers release solvent vapor each time one
is opened due both to displacement when new solvent is added and
the effect of air movement across the opening. When left
uncovered, solvent will evaporate constantly. Emissions also
occur when solvent is poured from one container into another.
A variety of devices have been developed that minimize
evaporative emissions. An example is self-closing funnels.
These screw into the bung hole on a container and minimize
emissions because the barrel is normally closed, sealed when
solvent is not being added. They also reduce spillage.
3.3.2 Substitute Solvents in Cleaning Materials
Several low-VOC cleaning products are available that may be
used in place of solvents. The chemical behavior of these
substitutes (i.e., vapor pressures, drying times, cleaning
effectiveness, etc.) may differ from that of the solvent which it
replaces. These behavioral differences may require changes in
cleaning practices.
3.3.3 Potential Emission Reductions
Significant emission reductions can often be achieved by
changes in cleaning practices and/or cleaning materials. This
was verified by two companies whose case studies are presented in
3-6
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Chapter 5 of the alternative control techniques document (ACT)
for Industrial Cleaning Solvents.9
3.4 ABRASIVE BLASTING OPERATIONS
Emissions of PM-10 from abrasive blasting operations are a
function of the blast media used, the paint and corrosion
products being removed, and the wind and weather conditions in
which the blasting occurs. Section 3.4.1 presents the mechanisms
available to control or reduce PM-10 emissions, and Section 3.4.2
discusses why emissions of PM-10 cannot be estimated for this
industry.
3.4.1 PM-10 Control Techniques
A number of technologies are used to contain debris
generated from abrasive blasting and to-reduce or control PM-10
emissions. Others are under development. The existing
technologies consist of drydock covers (use of tarpaulins in a
variety of ways to inhibit emissions), vacuum blasters, water
curtains, wet blasters, centrifugal blasters, improved abrasives,
and underwater cleaning. These control techniques are summarized
in Table 3-1. The technologies under development include the
SCHLICK blast cleaning systems being developed in Germany and a
portable enclosure system being developed by Metro-Machine
Shipyard in Virginia. 5>11
3.4.1.1 Current Technologies.
3.4.1.1.1 Blast enclosures. Blas.t enclosures are designed
to completely enclose one or more abrasive blast operators,
thereby confining the blast debris.12 The enclosure floor is
usually equipped with funnels to divert the captured debris into
adjacent trucks. In one design, a ventilation system removes the
airborne dust from the enclosure by using a wet scrubber to
remove the particles from the effluent airstream air.
Alternatively, baghouses or other dust collectors can be used to
control dust emissions.
Blast enclosures can be very effective in containing and
recovering abrasive blast debris. However, they are specifically
designed for a particular application (e.g. recovery of lead),
are relatively expensive, and tend to slow down the overall
3-7
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TABLE 3-1. SUMMARY OF ABRASIVE BLASTING CONTROL OPTIONS12"18
Control option
Blast
enclosures
Dry dock covers
Vacuum blasters
Schlict vaccum
blaster
Water curtains
Wet blasting
Improved
abrasives
Water cleaning
Advantages
- Effective control
Work can continue under
inclement weather conditions
Offer some suppression of
airborne particulates
- Movable from one ship area to
the next
Good for small or touch-up
jobs where neighboring
surfaces should not be
disturbed
- Often used to touch up weld
joints
Faster than manual
Robotic motion
Relatively inexpensive
(controversial)
Substantially lower dust
emissions
Lower dust emissions due to
fewer dust particles in media
and fewer dust particles
generated during blasting with
"hard" abrasives
Reduces abrasive blast media
usage rate if cleaning
performed while hull is wet
Di sadvantages
- Must be specifically
designed for a
particular application
Expensive (permanent
structures only)
- Flimsy and detach under
high wind conditions
Crane access is limited
for large ships
- Heavy and awkward to
use
Paint removal is very
slow
Operator cannot see
surface while blasting
- Costly
- Generate wastewater and
potential water
pollution problems
- Debris more difficult
to clean up
- Generates wastewater
problem
- Without abrasive, water
blasting is slow,
surface is not
adequately prepared,
and corrosion problems
occur
Can be costly unless
adequate means of
recycling available
Does not remove paint
3-8
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cleaning rate due to the time required to move the enclosure as
the work progresses.
Some leakage of abrasive and paint debris can also occur at
the joints between the blast enclosure and the structure being
cleaned. Although attempts have been made to seal the joints
with canvas, this is usually not very effective, particularly
when the blast is directed into these areas. A better method to
minimize leakage from enclosure joints is to fasten a flexible
seal made of rubber, plastic, or thin metal to the inside edges
of the enclosure walls. The end of the flexible seal rests on
the structure being cleaned, thus reducing the escape of airborne
dust.13
3.4.1.1.2 Drydock covers. Several, schemes that use some
form of drydock cover have been evaluated. "Cocooning" consists
of draping plastic/fabric tarps from the drydock walls to the
hulls and superstructures of ships. This form of drydock cover
provides some suppression of airborne particulates; however, the
tarps have a tendency to detach and tear under moderate to high
wind conditions. Also, cocooning a ship limits the accessibility
of drydock cranes to the covered ship. Another common measure
for suppressing dust emissions is erecting a fabric barrier to
close off the end of the drydock. Because they do not completely
enclose the ship, these barriers would appear to be less
effective than cocooning regardless of the cocoon's quality.16
Puget Sound Naval Shipyard completely roofs the drydock
during abrasive blasting of submarines with reportedly complete
containment of blast particulates. Because the vertical height
of the submarine is less than the top of the drydock, roofing is
simplified. However, for larger surface ships, the Navy believes
that a complete cover may be an impractical approach. An
alternative approach under consideration for development by the
Navy is encapsulation by air-supported, bubble-like structures.14
3.4.1.1.3 Vacuum blasters. Vacuum blasters are designed to
remove paint and other surface coatings by abrasive blasting and
simultaneously collecting and recovering the spent abrasive and
3-9
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paint debris with a capture and collection system surrounding the
blast nozzle (Figure 3-1).
In this type of system, the abrasive is automatically
reclaimed and reused as work progresses. Vacuum blasters are
made in a variety of sizes, but even the smaller units are
comparatively heavy and awkward to use.15 Boston Naval Shipyard
has been using a vacuum unit capable of picking up abrasive grit,
wet sand, or slurry.14 The vacuum unit is equipped with a
moisturizer to trap dust from dry debris after collection.
Newport News Shipbuilding uses vacuum blasting only for small
jobs (e.g., a vacuum blaster is used on seams to be welded.)
This yard estimates the system to be one-third as fast as
conventional blasting because the area being blasted is
obstructed from view by the blasting apparatus, the blast nozzle
is smaller, and the worker must move along the blast surface
slowly enough for the vacuum to capture the spent media before
the nozzle is moved along.1°
3.4.1.1.4 Water curtains. In this technique, a water
header with a series of nozzles is installed along the edges of
the structure being blasted. The water spray from the nozzles is
directed downward, creating a water curtain to collect debris
from abrasive blasting performed below the header, which is
subsequently washed down to the ground. This technique is
relatively inexpensive and does reduce the amount of airborne
dust. It requires proper water containment and treatment
facilities to avoid water contamination or other clean-up
problems.12 Multimedia transfer from air pollution to water
pollution can cause an increase in hazardous waste stream and
result in increasing operational cost.
One method used to avoid the spillage problem associated
with water curtains involves placing troughs under the spray
pattern to catch the water/abrasive mixture and divert it to an
appropriate container (e.g., tank truck) for disposal. For low
structures, the troughs can be placed on the ground. For high
structures, the troughs can be supported from the structure
itself.12
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Control Valve
To
Separator
Vacuum
Hose
Ejector
Nozzle
Blast
Nozzle
Vacuum
Recovery
Head
Figure 3-1. Schematic of vacuum blaster head.15
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3.4.1.1,5 Wet blasting. Wet blasting techniques include
wet abrasive blasting and high-pressure water blasting.17 The
type of wet blasting method used depends on the application.
Wet abrasive blasting was introduced in Chapter 2. Wet
abrasive blasting is accomplished by adding water to conventional
abrasive blasting nozzles. Most wet abrasive blasters mix the
water with the abrasive prior to its impact on the surface. This
interaction can cause the rate of surface cleaning to be slower
than with dry abrasive blasting.12 Other disadvantages include
the need for touch-up abrasive steps and the need to include rust
inhibitors and in some cases antifreeze solutions in the slurry.
Such additives are water pollutants.
A retrofit device designed to minimize premixing of the
water with the abrasive blast has been developed to fit over the
end of conventional abrasive blast nozzles. This device is
expected to be an improvement over traditional wet abrasive
blasting, and is shown in Figure 3-2.12 The two principal parts
of the device are a swirl chamber and an exit nozzle. The swirl
chamber is equipped with a tangential water inlet. The incoming
water swirls around the inside of the chamber and then out the
exit nozzle. Centrifugal force causes the water to form a hollow
cone pattern around the abrasive blast stream. The angle of the
water cone is controlled principally by the shape of the exit
nozzle and centrifugal forces. The modified water nozzle design
provides a water curtain around the abrasive/airstream. Thus,
the cleaning effectiveness of the abrasive/airstream should not
be substantially affected. The device is simple to install and
operate with conventional abrasive blasting equipment.12
Long Beach Naval Shipyard studies show that enveloping the
abrasive blast streams with a cone of water reduced the
particulate generation by about 80 percent. However, this method
can make removing the saturated abrasive from the drydock floor
more difficult.14
High-pressure water blast systems include an engine-driven,
high-pressure pump, a high-pressure hose, and a gun equipped with
a spray nozzle. High-pressure water blasting using a pressurized
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Pressurized
Water
Nozzle for air abrasive wet blast
Needle Valve
Nozzle Adapter
Nozzle
Nozzle Abrasive
Holder and Air
Water
Jets
Atomized
Water
Injector
Air
Abrasive
Water
Figure 3-2. Nozzle for air abrasive wet blast.17
3-1.3
-------
stream of water is a technique that was evaluated at Pearl Harbor
Naval Shipyard but was not fully accepted because of its
operational slowness, the fact that water promotes corrosion of
bare metal, the requirement that a rust inhibitor be included in
the jet stream (rust inhibitors may be pollutants), the high
initial cost of equipment, and the fact that the operation will
not blast to white metal. In Northern shipyards, antifreeze
additives would have to be added, and these additives may be
water pollutants. The advantage of high-pressure water blasting
is that it reduces air pollution.14
If abrasives are introduced to a high-pressure water blast
system, high-pressure water and abrasive blasting is provided.
As compared to dry blasting, all wet blasting techniques produce
substantially lower dust emissions.
3.4.1.1.6 Improved abrasives. There is an on-going study
at shipyards to find better abrasives. Abrasives can be improved
by ensuring that they are screened to remove dust emissions prior
to being purchased. Hunters Point Naval Shipyard has changed to
commercial Green Diamond1* to reduce the dust problem; however,
complete elimination of dust is improbable. Norfolk Shipbuilding
and Drydock Corporation (NORSHIPCO) has evaluated several blast
media for paint removal, including garnet and baking soda.1" The
friability, or disintegration tendency, of abrasive grit can be
selected to minimize particulate emissions and to make
reclamation economical; however, friability must be traded off
with costs and effectiveness and with the hardness of the grit
chosen to prevent metal surface damage.
3.4.1.1.7 Water cleaning. Underwater cleaning of a ship's
hull is normally accomplished by mechanically brushing the marine
growth from the hull surface, but this method is only partially
effective. This operation is not meant to remove paint, but it
does significantly reduce the amount of blasting required before
repainting, thereby reducing the level of emissions. Like
underwater cleaning, water cleaning a vessel immediately after
drydocking will remove some marine growth and help reduce
abrasive blasting requirements.
3-14
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3.4.1.2 Technologies Under Development.
3.4.1.2.1 SCHLICK blast cleaning systems. SCHLICK has
developed a line of blast cleaning systems that are presently
operated in European shipyards only. The "Mubid" is an automatic
cleaning unit used in drydocks that is capable of cleaning dirt
and debris from the ship's hull. It can also be used to remove
marine fouling and rust from the bottom of the ship using high-
pressure water blasting and abrasive blasting with wire shot as
the blast medium. This unit can operate with as little as 1.4
meters (55.5 inches) of clearance between the drydock floor and
the bottom of the hull. A new system, the "Model 3770 Dust Free
Ship Cleaning System," is a device that cleans dirt, marine
fouling, and rust from ship hulls using^the same blasting
techniques as the Mubid system. Particulate emissions and toxic
waste are supposed to be reduced when using this device because
it is equipped with a dust and debris capture unit. Other units
developed by SCHLICK include a manual blast cleaning and recovery
capsule, a portable recovery unit (Model VC-4000), a portable
large-volume blasting unit (Model G-7) for use in areas where the
3770 model cannot clean, and a ship deck turbine wheel (Roto-Jet
Model AB-9) for deck cleaning.11
3.4.1.2.2 Portable enclosure system. A self-supporting
portable enclosure under development by Metro Machine Corporation
is depicted in Figure 3-3. This system is designed specifically
to control particulate matter emissions from abrasive blasting of
ship hulls. However, as discussed in Section 3.2.3, it has
potential to control VOC emissions from painting operations. The
enclosure must be ventilated during use. Dead air space in
corners, which can lead to fugitive emissions and particulates in
the worker's visibility zone, are minimized with downdraft air
circulation.
In the Metro Machine design, portable enclosures will cover
small portions of the ship's hull at any given time; multiple
units can be used concurrently. Metro Machine Corporation
estimates that 80 to 85 percent of the typical hull can be
accessed with the self-supporting mobile enclosures. However,
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Figure 3-3. Portable enclosure.
3-16
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remote areas of the hull are usually difficult to enclose with
these enclosures. The enclosures are moved from one area of a
ship to another by crane.
The enclosures will be available in a variety of shapes and
sizes and must have a certain amount of flexibility in their
range of motions. Designs vary as to one-person or two-person
platforms, depending upon the work application. Sufficient air
is supplied within the enclosure to maintain worker visibility.
Because the surface being blasted will be temporarily
enclosed and therefore protected from the weather, increased work
time is expected in certain weather conditions such as light rain
(mist) or fog. The shape of the hull and the shipyard facilities
dictate the support mechanism used for the enclosures. Units can
be mounted to the drydock wing wall, supported from the drydock
floor, or attached to a man-lift (cherry picker) for mobility.5
3.4.2 Potential PM-10 Emission Reductions. Potential PM-10
emission reductions from using any of the control mechanisms
described above are difficult to quantify because no reliable
source for estimating PM-10 emissions from uncontrolled and
controlled sources is currently available. A comparison of
emission data gathered for abrasive blasting of ship hulls versus
other structures (see Table 2-11) revealed no apparent trends.
For this reason, data gathered on nonsimilar applications cannot
be used at this time to estimate emissions from shipyard abrasive
blasting operations.13
Emission factors for PM-10 cannot be developed without
appropriate source test data from shipyard abrasive blasting
operations. An ambient monitoring test was conducted at
NORSHIPCO on September 9, 1992. The results of this test
revealed that PM-10 emissions occur during ship blasting
1 Q
operations. However, emissions from further tests need to be
quantified in order to develop appropriate emission factors.
Even with source test data, developing emission factors within
this industry is challenging because of the variability in the
particle distribution of the blast media, the friability of both
3-17
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the coating and corrosion products being removed, and variable
wind and climatic conditions.
3.5 QUALITY CONTROL
In addition to the control measures for painting and
blasting operations outlined in the above sections, emissions of
PM-10 and VOC may also be reduced by minimizing air exposure,
limiting rework, and suspending painting and blasting activities
when wind and weather conditions are unfavorable.
3.5.1 Minimizing Air Exposure
From an industry perspective, the lowest-impact approach to
reducing VOC emissions is to change work practices to minimize
the opportunities for emissions. Section 3.3 discussed how
emissions from cleaning solvents can be"reduced by work practice
modifications. Emissions of VOC's from paints and solvents
(i.e., cleaning compounds, thinners, etc.) can also be controlled
by limiting the quantities intentionally exposed to air. Using
training and other programs to inform employees of good work
practices would be necessary to implement such measures.
3.5.2 Limiting Rework
Rework may be required because of improperly prepared
surfaces, inclement weather conditions that disrupt painting
schedules, or other scheduling errors that result in improper
paint application procedures. The cost of rework in any shipyard
is so high that it is continually being addressed through the
improvement of production techniques and processes. Continued
awareness of the level of rework occurring in a shipyard and the
relationships with paint usage, blast media usage, and their
associated emissions would help in reducing emissions from these
sources. Improved recordkeeping practices would help in tracking
rework and the associated emissions.
3.5.3 Suspending Painting and Blasting Activities
Paint overspray and PM-10 emissions can be controlled to a
limited extent by monitoring wind speed and by suspending
painting and blasting activities when wind speed exceeds some
preselected value. Resulting emission reductions are difficult
to quantify, and emission credits cannot be given to a facility
3-18
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for following such a practice. However, improvements in air
quality at nearby residential areas are often obvious when
blasting is halted.
3.6 REFERENCES
1. Ellis, W. H. Solvents. Philadelphia, Federation of
Societies for Coatings Technology. October 1986. 19 pp.
2. Memorandum from deOlloqui, V., Midwest Research Institute
(MRI), to Project File. November 11, 1992. List of
Shipyards Included in the Shipbuilding and Ship Repair Data
Base.
3. Telecon. Williamson, M., MRI, with Tatavuk, N.,
International Paint Company. June 11, 1993. Discussion
concerning higher-solids coatings.
4. Telecon. deOlloqui, V., MRI, with Olsen, G., Graco, Inc.
October 9, 1992. Discussion concerning paint heaters.
5. Telecon. Harris, V., MRI, with McConnell, F., Metro Machine
Corporation, Norfolk, Virginia. April 28, 1992. Discussion
of portable enclosures.
6. Seiwert, J. J. Regenerative Thermal Oxidation for VOC
Control. Smith Engineering Company. Duarte, CA. Presented
at Wood Finishing Seminar--Improving Quality and Meeting
Compliance Regulations. Sponsored Key Wood and Wood
Products and Michigan State University. Grand Rapids.
March 5, 1991. 27 pp.
7. Radian Corporation. Catalytic Incineration for Control of
VOC Emissions. Park Ridge, NJ, Noyes Publications. 1985.
8. Crane, G. Carbon Adsorption for VOC Control. U. S.
Environmental Protection Agency. Research Triangle Park,
NC. January, 1982.
9. Midwest Research Institute. Alternative Control Techniques
document for Industrial Cleanup Solvents. Draft. Prepared
for U. S. Environmental Protection Agency. Research
Triangle Park, NC. June 1993.
10. Telecon. Caldwell, M.J., MRI, with Ambrose, L., Norfolk
Shipbuilding and Drydock Corp. October 15, 1992. Painting
and Cleaning Operations at Shipyards.
11. Letter and attachments from Kidd, R., Grand Northern
Products, Ltd., to Berry, J., EPA/ESD. March 10, 1993.
SCHLICK Blast Cleaning Systems.
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12. Snyder, M. K., and D. Bendersky. Removal of Lead-Based
Bridge Paints. NCHRP Report 265. Transportation Research
Board. Washington, D.C. December 1983.
13. Midwest Research Institute. Assessment of Outdoor Abrasive
Blasting. Prepared for U. S. Environmental Protection
Agency. Research Triangle Park, NC. September 11, 1989.
14. Department of the Navy. Abrasive Blasting of Naval
Shipyards. Draft Environmental Impact Statement.
Washington, D.C. October 1, 1973.
15. Baldwin, B. Methods of Dust-Free Abrasive Blast Cleaning.
Plant Engineering. 3_2(4) . February 16, 1978.
16. Memorandum from Williamson, M., MRI, to Project File. List
of Shipyard Site Visits. March 18, 1993.
17. Appleman, B. R., and J. A. Bruno, Jr. Evaluation of Wet
Blasting Cleaning Units. Journal of Protective Coatings and
Linings. 2.(8) . August 1985.
18. Bruno, J. A. Evaluation of Wet Abrasive Blasting Equipment.
Proceedings--2nd Annual International Bridge Conference.
Steel Structures Painting Council. Pittsburgh, PA.
June 17-19, 1985.
19. Ambient Monitoring Test for Total Suspended and PM-10
Particulate Emissions During a Ship Sandblasting Operation.
Norfolk Shipbuilding and Drydock Corporation, Norfolk, VA.
Prepared by Industrial and Environmental Analysts, Inc.,
Morrisville, NC. September 9. 1992.
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4.0 MODEL SHIPYARDS AND EMISSION ESTIMATES
This chapter describes the models that have been developed
to characterize the shipbuilding and ship repair industry, their
corresponding emission estimates, and the methods used to
determine these estimates. Due to the nature of this industry
and its sporadic painting operations, an individual shipyard can
fall in and out of a given model yard description. The model
yards represent various practices within the shipbuilding and
ship repair industry. However, due to the diverse nature of the
industry, many shipbuilding and ship repair yards have developed
specialized marketing niches that are not easily represented by a
model yard approach. For these reasons, the model yards have
been developed to represent the shipbuilding and ship repair
industry as a whole; they do not necessarily represent every
existing shipyard. These model yards will be used to evaluate
the costs and environmental and energy impacts of control options
on the affected sources. The majority of the existing yards have
no controls for volatile organic compounds (VOC's) or particulate
matter less than 10 micrometers in diameter (PM-10) on their
outdoor operations; therefore, model yards represent uncontrolled
operations.
Section 4.1, Model Yards, elaborates on the types of model
yards, their corresponding sizes, and their overall coating,
solvent, and blast media usage rates. Emission estimates are
4-1
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discussed in Section 4.2, and the references used to develop this
information are listed in Section 4.3.
4.1 MODEL SHIPYARDS
Model yard development was based primarily on 1990 and
••.
1991 information gathered from responses to information requests
sent to shipbuilding and ship repair yards pursuant to
Section 114 of the Clean Air Act, EPA's information-gathering
authority.1 Information gathered from coating manufacturers'
Section 114 survey responses and site visit reports was used to
supplement the data gathered from the shipyard survey
responses.2'3 A total of 25 private shipyard responses and
8 Naval repair yard Section 114 responses were used as the major
source for developing model yards. These shipyards are listed in
Table 4-1. In addition, nine coating manufacturer responses were
received, and several shipyards (including one Naval repair yard)
were visited to observe yard operations.
4.1.1 Description of Model Yards
Several key variables were considered in developing model
yards. The type of vessel coated--military or commercial--is of
primary importance because of different performance constraints.
The type of ship operation--repair or construction--is important
because painting and blasting operations differ between these two
types of yards. The location of the painting and blasting
operations within a yard affect the control options. Finally,
the size of the model yard is another key factor that affects the
economics of the control options.
Table 4-2 describes the eight model yards developed to
characterize the industry. The models are divided into two main
categories based on the type of work typically conducted,
construction or repair. Within these two categories, the yards
are segregated further by size. A more detailed discussion of
model yard development is provided in Appendix B.
4.1.2 Model Yard Sizes
Four size classifications for construction and repair yards
were developed. The "extra-small" category consists of yards
that emit less than 22,680 kilograms per year (kg/yr) (25 tons
4-2
-------
TABLE 4-1. SHIPYARD SURVEY RESPONSES
USED FOR MODEL YARD DEVELOPMENT1
Name
Location (City, State)
PRIVATE YARDS
Bath Iron Works
Bath Iron Works
Bath Iron Works
Campbell Industries
Eastern Shipyards
Equitable Shipyard
General Dynamics Corporation
Gretna Machine & Iron Works
HBC Barge, Incorporated
Halter Marine-Lockport
Halter Marine-Moss Point
Ingalls
Jeffboat Industries
Marco Shipyard
Moss Point Marine
National Steel & Shipbuilding Corporation
Newport News Shipbuilding
Norfolk Shipbuilding & Drydock Corporation
Northwest Marine
Peterson Builders
Southwest Marine
Southwest Marine
Todd Pacific Shipyard
Trinity Beaumont
West State, Incorporated
Bath, Maine
East Brunswick, New Jersey
Portland, Maine
San Diego, California
Panama City, Florida
New Orleans, Louisiana
Groton, Connecticut
Harvey, Louisiana
Brownsville, Pennsylvania
Lockport, Louisiana
Moss Point, Mississippi
Pascagoula, Mississippi
Jeffersonville, Indiana
Seattle, Washington
Escatawpa, Mississippi
San Diego, California
Newport News, Virginia
Norfolk, Virginia
Portland, Oregon
Sturgeon Bay, Wisconsin
San Diego, California
San Francisco, California
Seattle, Washington
Beaumont, Texas
Portland, Oregon
PUBLIC NAVAL YARDS
Charleston Naval
Long Beach Naval
Mare Island Naval
Norfolk Naval
Pearl Harbor Naval
Philadelphia Naval
Portsmouth Naval
Puget Sound Naval
Charleston, South Carolina
Long Beach, California
Valejo, California
Norfolk, Virginia
Pearl Harbor, Hawaii
Philadelphia, Pennsylvania
Portsmouth, New Hampshire
Bremerton, Washington
4-3
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per year [tons/yr]) of VOC's. The "small" category consists of
yards that emit between 22,680 kg (25 tons) and less than
45,360 kg/yr (50 tons/yr) of VOC's. The "medium" category
consists of yards that emit between 45,360 kg (50 tons) and less
than 90,720 kg/yr (100 tons/yr) of VOC's, and the "large"
category consists of yards that emit 90,720 kg/yr (100 tons/yr)
or more of VOC's.
4.1.3 Model Yard Parameters
Table 4-2 summarizes the average total coating, solvent, and
abrasive media usages for each model yard. These usages are the
averages of the actual usage rates reported by the shipyards in
Table 4-2.1 The overall total coating and solvent usage for
"construction yards" is greater than that of the "repair yards"
for all but the extra small model yards. This is because there
are significant differences between painting a ship during
construction and repainting during repair operations. Ship
construction requires the constant application of paint systems
to various ship parts before, during, and after the ship is
assembled. Repairing a ship requires repainting or spot
repairing of ship areas, mainly the hulls. The frequency of
repainting depends on many factors, including the ship owner's
specifications.4
The model yards in Table 4-2 indicate that large
construction yards use approximately eight times as much abrasive
media as large repair yards. Ship construction requires the use
of large amounts of blast media for surface preparation and
blasting. The surface of ship parts must be prepared before
initial painting to remove mill scale (rust) or any other
materials that could interfere with the performance of the
coating system. After coating systems have been applied to
various ship parts, blasting usually takes place several times as
the parts are assembled.
Repairing a ship usually requires less blast media because
blasting occurs only on the portion of the ship to be repainted.4
Table 4-2 indicates, however, that medium and extra-small repair
yards use considerably more abrasive media than their
4-5
-------
construction yard counterparts. These apparent inconsistencies
may be the result of incomplete information submitted by the
shipyards, including blast media recovery rates, area blasted,
and blast media effectiveness.
4.1.4 Relative Usages
Relative coating usages were determined for both
construction and repair-type shipyards. In Table 4-3, a
comparison of relative coating usage shows that repair yards use
more antifoulants than do construction yards, and construction
yards use more inorganic zincs and alkyds than do repair yards.1
Repair yards use relatively more antifoulants because a greater
proportion of their painting is on exterior ship hulls, which
require antifoulant coatings. Construction yards use more
inorganic zinc and alkyd coatings as anticorrosive primers and
undercoats for painting interior surfaces and bare metal; repair
yards are typically involved in very little interior-surface
repainting. Epoxy coating usage is similar between the two types
of yards. There are many types of epoxy resins, which increases
their versatility for use as undercoats on all parts of a ship.
4.1.5 Average VOC Contents
Table 4-4 gives the weighted (normalized) average VOC
content, i.e., the average VOC content weighted by volume used,
for the five coating categories.1'2 These averages were
determined collectively for construction and repair yards because
the yards use the same coatings, although not in the same
relative quantities. The inorganic zinc coating category has the
highest average VOC content; the general-use epoxy coating has
the lowest.
4.2 VOC AND PM-10 EMISSIONS ESTIMATES
This section discusses the estimation of VOC and PM-10
emissions. Section 4.2.1 presents the VOC emission estimates for
the eight model yards. The VOC emission calculations are based
on relative usages and average VOC content data presented in
Section 4.1. Section 4.2.2 provides details of why PM-10
4-6
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TABLE 4-3. RELATIVE USAGES1
Category
Specialty coatings
Antifoulant
Inorganic zinc
Other specialty
General -use coatings
Alkyd based
Epoxy based
TOTAL
Yard type
Construction, %
4.0
15.0
9.8
16.6
54.6
100.0 ,.
Repair, %
22.3
0.7
11.8
2.4
62.8
100.0
TABLE 4-4. AVERAGE VOC CONTENTS
1,2
Category
Specialty coatings
Antifoulant
Inorganic zinc
Other specialty
General -use coatings
Alkyd based
Epoxy based
Thinning solvent
Average VOC content
g/L, less
water
387
544
425
473
350
839a
lb/gal, less
water
3.23
4.54
3.55
3.95
2.92
7.00a
aThe weighted average VOC content of reported solvents.
4-7
-------
emissions could not be estimated for any of the eight model
yards.
4.2.1 VQC Emission Estimates
Table 4-5 gives a breakdown of the VOC emissions by category
for each model shipyard. Within each model, the VOC emissions
for the various coating categories are the product of the average
total coating usages, the relative usages in Table 4-3, and the
weighted average VOC contents in Table 4-4. The VOC emissions
estimated for the thinning solvent category are the product of
the average total solvent usages, the percent solvent used for
thinning, and the weighted average VOC content of 839 g/L
(7.0 Ib/gal) of reported solvents.
Table 4-5 shows that the major contributor of VOC emissions
from both construction and repair operations is epoxy-based
coatings (approximately 40 and 50 percent, respectively).
Although epoxy-based coatings are comparatively low in VOC
content, as indicated in Section 4.1.4, they are by far used in
the greatest volume because of their versatility.
Overall, VOC emissions by coating/solvent category from both
construction and repair operations are similar with the exception
of VOC emissions from the use of antifoulant and inorganic zinc
coatings. The VOC emissions from antifoulant coatings account
for approximately 3 and 25 percent of VOC emissions from
construction and-repair operations, respectively, while the VOC
emissions from inorganic zinc coatings account for approximately
16 and 1 percent of the total VOC emissions from construction and
repair operations, respectively. On average, construction
operations (based on overall coating usage) emit considerably
more VOC's than do repair operations.
4.2.2 PM-10 Emissions From Abrasive Blast Media
Information on the amount of blast media used for surface
preparation of ships was provided by 20 shipyards.1'^'^
Table 4-5 does not, however, present estimated PM-10 emissions
from abrasive blast media usage for the eight model yards because
no correlation was found between blast media usage and PM-10
emissions. Further, it would be difficult to develop such a
4-8
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correlation because PM-10 emissions in this industry are
dependent upon a number of factors including wind and weather
conditions during blasting, the type of blast medium used, and
the material (e.g., paint and/or corrosion products) being
removed from the ship surface.
The shipyards reported recovery of blast media at rates
ranging from 50 to 99 percent.5 However, the low recovery rates
that were reported include media losses not related to air
emissions. Typically, the bulk of the media falls to the floor
of the drydock, where front-end loaders are used to remove the
material for disposal. During the use and recovery of the media,
an indeterminate quantity may be lost due to windblown
entrainment or losses to the waste water" system. An evaluation
of media losses to air, water, and land based on a mass balance
would be a significant undertaking given the imprecise use and
recovery practices, and so far, none have been conducted at
shipyards.
A discussion of existing data used to evaluate PM-10
emission factors is provided in Chapter 2. From this data it may
be concluded that until emissions from further tests are
quantified, appropriate emission factors cannot be developed.6
4.3 REFERENCES
1. Memorandum from deOlloqui, V., Midwest Research Institute
(MRI), to Project File. Facilities in the Shipbuilding and
Ship Repair Data Base. November 11, 1992.
2. Memorandum from deOlloqui, V., MRI, to Project File. List
of Coating Manufacturers Surveyed. November 16, 1992.
3. Memorandum from Williamson, M., MRI, to Project file. List
of Shipyard Site Visits. March 18, 1993.
4. VOC Emission Control Technologies for Ship Painting
Facilities - Industry Characterization. Centec Corporation.
Prepared for the U. S. Environmental Protection Agency,
Cincinnati, Ohio. EPA 600/2-18-131. July 1981.
5. Memorandum from Harris, V., MRI, to L. Driver, ESD/CPB/CAS.
Source Test Justification for Measuring PM-10 Emissions from
Abrasive Blasting Operations at Shipyards. September 24,
1992.
4-10
-------
Ambient Monitoring Test for Total Suspended and PM-10
Particulate Emissions During a Ship Sandblasting Operation.
Norfolk Shipbuilding and Drydock Corporation, Norfolk, VA.
Prepared by Industrial and Environmental Analysts, Inc.,
Morrisville, NC. September 9, 1992.
4-11
-------
5.0 COSTS AND ENVIRONMENTAL AND ENERGY IMPACTS OF
CONTROL OPTIONS
This chapter presents the costs and VOC emission reductions
associated with selected control strategies. The costs and
emission reductions associated with the use of lower-VOC coatings
are presented in Section 5.1. The VOC emission reductions and
costs of using add-on controls to control spray booth and tank
VOC emissions are presented in Sections 5.2 and 5.3,
respectively. A discussion of why the costs and emission
reductions of various strategies to reduce PM1Q emissions from
abrasive blasting operations could not be evaluated is in
Section 5.4. Control costs for cleaning are presented in
Section 5.5. The environmental and energy impacts of the various
control strategies evaluated are presented in Section 5.6.
5.1 COST OF USING LOWER-VOC COATINGS FOR SHIPYARD COATING
OPERATIONS
This section presents the methodology and results of the
cost impact analysis for the use of lower-VOC coatings.
Section 5.1.1 describes the three control scenarios evaluated,
and Section 5.1.2 discusses the assumptions and costing inputs.
The costs and associated emission reductions and the
recordkeeping and reporting requirements are presented in
Sections 5.1.3 and 5.1.4, respectively. The cost effectiveness
of the three scenarios based on the information presented in
Sections 5.1.1 through 5.1.4 is presented in Section 5.1.5.
5-1
-------
5.1.1 Lower-VOC Control Options
Four lower-VOC control options were evaluated for each of
the three major-use coating categories derived from the project
coatings data base. These options are described in Table 5-1.
The first two correspond to the 1992 and 1994 VOC limits
contained in South Coast Air Quality Management District (SCAQMD)
Rule 1106, Marine Coating Operations.1 The other two were
derived from the "project coatings data base" (data base), which
was developed from data supplied by shipyards and supplemented by
coating manufacturers' data. That information is somewhat dated
since most facilities provided data on coatings used in 1990; a
few from 1991.
N»
TABLE 5-1. OPTIONS BASED ON USING LOWER-VOC COATINGS
Options
1
2
3
4
Never to be
exceeded
Never to be
exceeded
Weighted
Average
Never to be
exceeded
Basis
1992 California limits
(by paint category)
1994 California limits
(by paint category)
Average of paints that
meet 1994 California
limits2 (by paint
category)
Lowest VOC paint (by
paint category)"
"exempt" soivetu
9Hrtf m
coating minus wat,
» aad flBMia
t* /Hv XtfM^/'Ofcll f»TM»**««r -nwftn* -wia-titr
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340 (2.83)
340 (2.83)
297 (2.48)
200 (1.67)
Antifoulaot
400 (3.33)
400 (3.33)
360 (3.00)
315 (2.62)
?«*&}
•" ^^Q^^ffl^ftr ^fifi
650 (5.40)
340 (2.83)
5 (0.04)
0
aAverage VOC content (weighted by volume) of paints in the project data base that meet the 1994
California standards.
lowest VOC paint in the project data base with a minimum annual usage of 3,790 liters (1,000 gallons).
Note: For Options 3 and 4, the limits are based on the project coatings data base, which was developed
primarily from 1990 data.
Two approaches to VOC limitations based on using lower-VOC
coatings were considered. The first involves selecting a maximum
or never-to-be-exceeded VOC limit for each coating category. The
5-2
-------
shipyard and coating manufacturer would know that by using or
producing a coating that meets the limit (s), as applied, there
would be no violation of the rule. Options 1, 2, and 4 in .
Table 5-1 involve such maximum or
never-to-be-exceeded values for each coating category.
The second type would allow the shipyard to use a coating of
any VOC content. However, planning, calculating, and
recordkeeping are required to make certain the weighted average
of the VOC content of all coatings in a category do not exceed
the limit. Use of coatings with VOC contents above the average
limit must be offset by use of ones with VOC contents lower than
the average limit within the designated averaging period (e.g.,
during a quarter). Averages allow more -flexibility, but at the
price of a significant administrative workload. Option 3
designates weighted average VOC limits for the three coating
categories.
The basis for the options presented in Table 5-1 can be
further described as follows:
Option 1--Maximum limits for each coating category identical
to the 1992 California limits;
Option 2--Maximum limits for each coating category identical
to the 1994 California limits;
Option 3--An average limit for each coating category based
on the weighted average VOC content of coatings within each
category that comply with the 1994 California limits; and
Option 4--A maximum VOC limit for each coating category that
would mandate use of coatings with no more VOC than the lowest
VOC content used in significant volume in the data base for each
category.
Options 1 and 2 differ only in the limit for inorganic zinc.
The 1992 and 1994 levels contained in SCAQMD Rule 1106 are the
same for antifoulants and general use coatings.
The average limits for each coating category in the third
option were calculated as the weighted average VOC content of all
the coatings in the data base that comply with the 1994
5-3
-------
California limits.
The fourth option designates not-to-be-exceeded VOC contents
for each of the three major-use coating categories based on the
lowest-VOC coating in the data base for each category. In
determining the lowest-VOC coating in each coating category, only
those coatings with an aggregate reported usage of more than
3,790 L (1,000 gal) were considered. The calculation of the
limits corresponding to the four options is described more fully
in Appendix C.
All of the options in Table 5-1 are for coatings "as
applied." The term "as applied" refers to the coating as it is
applied to the substrate, after thinning. The information
obtained in the surveys from shipyards and coating manufacturers
pertained to "as supplied" coatings, i.e., before thinning. In
evaluating the coatings in the data base against all of the "as
applied" limits shown in Table 5-1, all coatings at or below the
indicated levels were included. Thus, it was assumed that an
"as-supplied" coating with a VOC content equal to those in the
table could not be used if any solvent were added.
For options 1, 2, and 4, in evaluating the use of lower-VOC
coatings, it was assumed that those yards currently using
coatings with VOC contents greater than the limits shown in
Table 5-1 would switch to coatings with VOC contents equal to the
weighted average VOC content of the coatings in the coatings datat
base that meet the limits shown in Table 5-1. In other words, it
was assumed that the distribution of the lower-VOC coatings would
be similar to the usage distribution of the compliant coatings in
the project data base. As stated previously, Option 3, places no
constraint on coatings that can be used as long as the weighted
average VOC content over the designated averaging period is less
than the limit.
5.1.2 Assumptions and Scenarios Evaluated
Volatile organic compound emissions from the coating
operation result from VOC inherent in the coatings and the
solvent used to thin the coatings. Emissions of VOC's also
5-4
-------
result from cleaning. The reduction of VOC emissions from
cleaning is discussed in Section 5.4. For this analysis, the
reduction in VOC emissions that occurs with the use of lower-VOC
coatings is calculated based on the following assumptions:
(1) the VOC content of the coating is lower, and (2) less coating
is used due to the increased solids content of the lower-VOC
coating. For purposes of estimating costs, the total usage of
thinning solvent decreases with the decreased coating usage
because of the assumption 5% solvent is added to all coatings.
These factors are described more in the following paragraphs and
in Appendix C.
Emission reductions and costs were developed for baseline
and for the lower-VOC options presented-in Table 5-1. The
parameters for coatings used in the impact analysis for baseline
and lower-VOC options are based on information in the
data base. ' These coating parameters are summarized in
Table 5-2. Baseline emissions correspond to emissions associated
with the coatings used in the yards today as indicated by the
data base. The VOC emissions were based on the organic solvents
in the paint and thinner as indicated in Appendixes B and C.
For the impact analysis, it was assumed that the total build
of the lower-VOC coating (the dry film thickness) would equal
that of the conventional counterpart, and the total amount of
solids applied per. unit area of surface would remain constant.4
Because the lower-VOC solventborne coatings have higher solids
contents (on a percent volume basis), the total number of liters
(gallons) applied to coat a given area is less than that for the
conventional, lower-solids coatings (assuming constant transfer
efficiency and constant paint film thickness).
The solids contents of the majority of the coatings was
calculated using the equation described in Appendix C, which is
not valid for coatings that contain more than trace quantities of
water or "exempt" solvents. In a few cases where the equation
(or associated assumption) produced unrealistically high solids
contents, the maximum solids was established for each of the
5-5
-------
TABLE 5-2. COATING PARAMETERS3"0
Coating
Antifoulant
Baseline
Option 1 limit
Option 2 limit
Option 4 limit
Inorganic zinc
Baseline
Option 1 limit
Option 2 limit
Option 4 limit
General use
Baseline
Option 1 limit
Option 2 limit
Option 4 limit
Solvent
VOC limit, g/L-water
(Ib/gal-water)
None
400 (3.33)
400 (3.33)
315 (2.62)
None
650 (5.40)
340 (2.83)
0(0)
None
340 (2.83)
340 (2.83)
200 (1.67)
None
Weighted
average price,
$/L ($/gal)
9(34)
9(34)
9(34)
9(34)
6(22)
6(22)
8 (29)
8(29)
4(16)
5(20)
5(20)
5(20)
1(4)
Weighted average
VOC content,
g/L-water
(Ib/gal-water)
387 (3.23)
344 (2.87)
344 (2.87)
306 (2.55)
544 (4.54)
541 (4.51)
2 (0.02)
0(0)
368 (3.07)
275 (2.29)
275 (2.29)
178 (1.48)
840(7)
Average
weighted solids
content, % vol
54
59
59
63
51
51
65
65
57
65
65
70
N/Ad
aDevelopment of these coating parameters is based on the shipyard and coating supplier survey responses
and is described in more detail in Appendix C.
"Volatile organic compound content given in grams of VOC per liter of coating minus water (pounds of
VOC per gallon of coating minus water), as applied.
cNumbers in this table are independently rounded.
Not applicable.
5-6
-------
three main coating categories based on data provided by coating
suppliers.5'6 The maximum solids content for antifoulants and
inorganic zinc coatings was assumed to be 65 percent by volume
and that of general use coatings was assumed 70 percent.
Actual solids data (based on product data sheets or Material
Safety Data Sheets [MSDS's]) were available for the major-use
inorganic zinc and alkyd coatings (part of the general use
category). Solids data provided by the manufacturer were used
for these coatings rather than the solids content calculated by
the equation described in Appendix C.
In evaluating the use of lower-VOC solventborne coatings,
three different scenarios were considered. The first assumed
that lower-VOC coatings require the same- amount of thinning
solvent, gallon for gallon, as conventional coatings. Since
fewer gallons of lower-VOC coatings are required because of their
higher solids content, thinner use would also decrease.
In the second scenario, it was assumed that in-line paint
heaters would be used rather than solvent to decrease the coating
viscosity to the desired levels. This assumption was based on
information supplied by vendors and shipyards that use in-line
paint heaters.7"10
The third scenario used both in-line paint heaters and
thinning solvent. The quantity of thinning solvent required was
assumed to be the same as for the first scenario. These three
scenarios were evaluated as options for shipyards that may have
different requirements depending on the painting operation, the
coatings used, and climatological conditions. For example, some
yards may not be able to spray the higher-solids, lower-VOC
coatings without reducing their viscosity. Ideally, in-line
heaters will decrease the viscosity and thinning solvent will be
unnecessary (Scenario 2). In some instances, heating alone will
not be sufficient and some solvent may also be required
(Scenario 3). For example, if a yard uses relatively long
coating supply lines, during very cold weather it may not be
possible to heat the coating enough to ensure the proper
5-7
-------
viscosity or pressure at the gun tip.10 Clearly, however,
shortening the distance between the gun and the paint container
is a low cost option to solvent addition for viscosity control
under freezing conditions as would spacing several heaters along
the length of the supply line.
Based on information contained in the shipyard survey
responses, the net cost associated with switching to lower-VOC
coatings was assumed to be the sum of difference in cost of the
coatings, the cost of in-line heaters, the savings associated
with decreased thinner usage, the costs of additional
recordkeeping and reporting requirements, and the cost of
implementing new work practices. Some yards that had tested
lower-VOC, higher-solids coatings indicated that they had to
change spray guns because higher pressures were needed to atomize
the new coatings. One yard indicated that higher solids coatings
tended to clog the lines, requiring more purging and more
cleaning time. Some yards indicated that it takes longer for the
lower-VOC coatings to cure, which can slow down the coating
operation overall. However, in the aggregate, there was no
consensus on the need for different spray guns, additional
purging, or increased cure times.2 Therefore, these potential
costs were not quantified.
5.1.3 Results of the Analysis
The emission reduction and costs associated with scenario 1
are presented in Tables 5-3 and 5-4. Scenario 2 emission
reductions and costs are presented in Tables 5-5 and 5-6.
Scenario 3 results are presented in Tables 5-7 and 5-8. The
emission reductions and coating costs associated with option 3
are assumed to be the same as those of option 2, because both
options are based on the 1994 California limits.
In all three scenarios, fewer gallons of higher solids
coatings are required. The lower-VOC coatings, however, are more
expensive on a dollar-per-gallon basis. The savings associated
with the decreased volume requirements is more than offset by the
higher price of the lower-VOC inorganic zincs and general use
5-8
-------
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5-17
-------
coatings. However, there is a net savings in coating costs for
antifoulants. Because all three scenarios presume the same
lower-VOC coatings, the decrease in coating usage is the same for
all three scenarios. Therefore, the additional cost of the paint
is constant.
In the first scenario, thinner usage remains a constant
percentage of total coating use. The costs for this scenario
include the costs of the lower-VOC coatings and savings from
decreased thinner usage. (The decrease results from the decrease
in the volume of coating usage required.)
In the second scenario, in-line heaters are used with the
lower-VOC coatings, eliminating the need for thinner. The costs
for this scenario are lower-VOC coatings", savings from decreased
thinner usage, and in-line heaters. The annualized in-line
heater costs include capital recovery, maintenance and indirect
costs, and the cost of electricity. The annualized heater costs
are described more fully in Appendix C.
Scenario 3 involves the use of lower-VOC coatings, thinning
solvent, and in-line heaters. The costs of the coatings,
thinner, and heaters for scenario 3 were calculated as described
above for scenarios 1 and 2.
The total emission reduction that is achieved under each of
the scenarios is the sum of two components: (1) the emission
reduction directly related to the use of lower-VOC paints and
(2) the emission reduction that results from decreased thinner
usage. The emission reductions directly associated with the
lower-VOC coatings are the same for all three scenarios because
all presume the same coatings are used. Under all three
scenarios, additional emission reductions are achieved (relative
to baseline) because less thinner is used. The reduction in
thinner usage and the associated emission reduction are identical
under scenarios 1 and 3. A greater emission reduction is
achieved under scenario 2 because all thinner is eliminated.
5-18
-------
5.1.4 Recordkeepina and Reporting Requirements
To gather information on the recordkeeping and reporting
requirements currently in effect in this industry, current
regulations were reviewed and a limited number of shipyards were
contacted.11"16 The recordkeeping and reporting practices
currently used in this industry represent those needed to comply
with permit conditions, and in some instances, the requirements
of section 313 of the Superfund Amendments and Reauthorization
Act of 1986 (SARA 313). The recordkeeping requirements and
associated costs to comply with existing permits and SARA 313
requirements in areas without marine coating regulations are
considered to represent baseline.
Options 1, 2, and 4 represent-never-to-be-exceeded (or
maximum) limits on the VOC contents of the coatings. Complying
with maximum limits will require more involved recordkeeping
practices than those necessary at the baseline.
Option 3 establishes weighted average VOC contents for each
of the coating categories. Complying with this limit is even
more involved than complying with the maximum limits established
in options 1, 2, and 4. Extensive planning, recordkeeping, and
reporting are required.
This section discusses the recordkeeping and reporting
requirements and the associated costs developed for baseline,
maximum limits, and average limits. Section 5.1.4.1 discusses
the assumptions and various inputs used to develop the
recordkeeping and reporting requirements, and Section 5.1.4.2
provides and elaborates on the associated costs. Additional
detail on recordkeeping and reporting costs is presented in
Appendix C.
5.1.4.1 Assumptions and Inputs. Information gathered from
shipyards indicates that there is no distinct difference between
the recordkeeping and reporting practices at construction versus
repair yards.14"16 Therefore, model yard recordkeeping and
reporting requirements presented in this section are based on
model yard size only. Because the same paints are used under all
5-19
-------
three of the scenarios introduced in Section 5.1.2, it is assumed
that recordkeeping and reporting costs are identical for all
three scenarios.
Recordkeeping and reporting costs are a function of the
equipment and labor required. Equipment includes computer
hardware and software. Labor is required to train the workers in
the recordkeeping procedures, to record the necessary data in the
field, to aggregate and manipulate the data, and to prepare the
required reports.
Baseline. At baseline, most large and medium shipyards
already maintain records to comply with State or local permits as
well as SARA 313 requirements. It is assumed the operations at
these facilities are complex enough to Require a computerized
system for recordkeeping and reporting. In contrast, small and
extra small yards typically are both too small to be subject to
SARA 313 requirements or significant permit conditions. As a
result, small and extra small model yards are assigned no
equipment costs at baseline.
The reporting requirements for large and medium yards at
baseline are assumed to consist of an annual SARA 313 report and
an annual report of VOC emissions. To prepare these reports, it
is assumed that the facilities have adapted their central
inventory tracking system to record the quantity of each paint
and thinner used at the yard. This information is coupled with a
data base in which the toxics and VOC contents of each paint and
thinner are stored. The total technical labor devoted to
baseline recordkeeping and reporting for large and medium yards
is estimated to be 159 hours per year (hr/yr). Additional detail
on this estimate is presented in Appendix C. Because small and
extra small facilities are not typically subject to SARA 313 or
other reporting requirements, the baseline labor assigned to
these model yards is 0 hr/yr.
Maximum limits. To comply with maximum limits (Options 1,
2, and 4), it is assumed that no additional equipment beyond
baseline is required for any model facility. Large and medium
5-20
-------
yards do not need to purchase new equipment because the equipment
required at baseline is adequate for this purpose. Small and
extra small yards are assumed not to need equipment because their
operations are simple enough to be tracked manually.
Significant recordkeeping and reporting labor is required to
meet a maximum VOC limit. For this analysis, it is assumed that
records must be kept on a daily basis (consistent with EPA policy
on VOC emissions averaging periods and enforcement) and compiled
weekly. Quarterly reports are assumed, as are initial and
refresher training sessions for the employees involved in
recordkeeping. Estimates of the total technical labor for
recordkeeping and reporting range from 145 hr/yr for extra small
yards up to 1,274 hr/yr for large yards.,. (See Appendix C for
additional information.)
Average 1imits. Complying with an average VOC limit
(option 3) is more involved than complying with a maximum limit.
For this reason, it is assumed that even small and extra small
facilities will need computer equipment to meet an average limit.
The baseline equipment is expected to be adequate for large and
medium yards to comply with an average limit.
The labor associated with an average limit is estimated at
twice the level of effort necessary for a maximum limit. This
estimate reflects the extensive advance work that is necessary to
plan, schedule, and track production and paint/solvent usage to
meet an average limit. On this basis, technical labor for
option 3 is estimated to range from 290 hr/yr for the extra small
model yard to 2,548 hr/yr for the large model yard. (See
Appendix C for additional information.)
5.1.4.2 Costs of Recordkeeping and Reporting. Table 5-9
shows the model yard costs developed for the recordkeeping and
reporting requirements for baseline, maximum limits (options 1,
2, and 4), and average limits (option 3). The final
recordkeeping and reporting costs were developed based on hour
and labor rates from the Emission Standards Division (BSD)
Regulatory Procedures Manual.17 These rates are summarized in
5-21
-------
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calculations are presented in Appendix C.
5.1.5 Cost Effectiveness of Lower-VOC Control Options
The cost effectiveness (cost per mass of VOC controlled) of
the four lower-VOC control options under scenarios 1, 2, and 3
are presented in Tables 5-lla, 5-lib, and 5-lie, respectively.
Only incremental costs above baseline are presented in these
tables. The cost effectiveness values were calculated based on
the emission reductions and the costs of the control options
relative to baseline. The emission reductions for the four
control options are presented in Tables 5-3 (scenario 1), 5-5
(scenario 2), and 5-7 (scenario 3). The costs relative to
baseline for the four control options are the sum of the coating-
related costs (Tables 5-4, 5-6, and 5-8 ^for scenarios 1, 2, and
3, respectively) and the recordkeeping and reporting incremental
costs (Table 5-9). For each option, the total incremental cost
relative to baseline was divided by the emission reduction to
obtain the cost effectiveness.
TABLE 5-10
HOUR AND LABOR RATES FOR RECORDKEEPING
AND REPORTING
Type of Labor
Technical
Management
Clerical
Hour rate
(A)
0.05 (A)
0.10 (A)
Labor rate
$33/hr
$49/hr
$15/hr
Comparison of scenarios. The cost-effectiveness tables show
that total costs progressively increase from scenario 1 through
scenario 3 for all four control options. Accordingly, cost
effectiveness generally becomes progressively less favorable
(i.e., the $/Mg [$/ton] increases) from scenario 1 through
scenario 3 for all four control options. (The exception is that
cost effectiveness is more favorable for large construction yards
5-23
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5-26
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under scenario 2 than under scenario 1 for options 1, 2, and 3.)
This analysis indicates that in terms of cost effectiveness, the
increased cost of paint heaters generally outweighs the improved
emission reduction they achieve as one moves from scenario 1 to
scenario 2.
It is anticipated that actual practice at shipyards will
most closely resemble scenario 1. Many marine paints are used
"as supplied". When the viscosity is to be reduced, thinning is
the method of choice. However, to reduce the viscosity of
coatings supplied with a VOC content at or near the limit, paint
heaters will have to be used to avoid violating the limit, as in
scenario 2. In rare cases, both thinner and heaters might be
used, as in scenario 3.
Comparison of options. Tables 5-lla, 5-lib, and 5-lie show
that across all three scenarios, the total costs above baseline
increase progressively from option 1 through option 3, then
decrease for option 4. Option 2 is slightly more costly than
option 1 because the increase in -paint cost per gallon slightly
outweighs the savings from decreased paint and thinner use. The
cost increase from option 2 to option 3 is larger because daily
recordkeeping costs double, although paint costs remain constant.
Costs decrease to their lowest level for option 4 because paint
usage is reduced substantially while the cost model leaves the
per-gallon cost of the paint unchanged from options 2 and 3.
Under scenario 1, option 4 results in a net savings for repair
yards of all sizes. Under scenarios 2 and 3, all yards show net
costs for option 4.
The comparison of cost effectiveness for the options does
not mirror the cost comparison. When the options based on
maximum limits (options 1, 2, and 4) are compared, the cost model
indicates cost effectiveness improves with the stringency of the
limit. Thus, while the total cost for option 2 is greater than
that for option 1, the cost increase is more than counterbalanced
by the greater emission reduction achieved by option 2. Option 4
has lower costs and greater emission reduction than either
5-27
-------
option 1 or 2, resulting in the most favorable cost effectiveness
by far.
The cost-effectiveness ranking of the option based on an
average limit (option 3) differs between repair and construction
yards. For repair yards, option 3 is the least cost-effective of
all the options. For construction yards, option 3 falls between
options 1 and 2 in cost effectiveness.
5.2 SPRAY BOOTH CONTROLS
Spray booths are used at some shipyards to apply coatings to
parts before they are connected to the main part of the ship.
Spray booths are used at both construction and repair yards. The
use of add-on controls such as thermal incinerators for VOC
emissions resulting from spray booth coating operations was
evaluated. A conservative analysis was performed to develop
preliminary cost estimates to be used to determine whether
additional analysis was warranted. The assumptions and inputs
used in evaluating add-on controls for spray booths are discussed
in Section 5.2.1. The results of the analysis are presented in
Section 5.2.2.
5.2.1 Spray Booth Analysis
Two aspects will be discussed in this section.
5.2.1.1 Methodology and Assumptions. Shipyards that fit
the "extra small" classification criteria generally do not
perform any indoor painting. The majority of the larger
facilities do. At shipyards that paint indoors, some use spray
booths; others do not. Rather, the spray area may be an entire
building or an area of one. The spray booths used in shipyards
vary significantly in. size and number. The exhaust rate from
individual booths can vary from about 0.7 to 62.3 cubic meters
per second (m3/s) (1,500 to 132,000 cubic feet per minute
[ft3/min]). The exhaust from entire buildings that function as
spray areas can be more or less than that from booths, depending
on the building and the spray operation.
The methodology used to estimate the costs of recuperative
and regenerative thermal incinerators is that described in the
5-28
-------
Office of Air Quality Planning and Standards (OAQPS) Cost
Manual.^° The Permissible Exposure Limit (PEL) for xylene is
100 parts per million (unless the operator uses a supplied air
source). Xylene is the most prevalent paint solvent in the data
base. Because manual coating operations are conducted inside
booths, concentrations must remain at or below the PEL.
Therefore, a maximum VOC concentration of 100 ppm was assumed in
the analysis of spray booths. Due to the relatively low-
concentration airstream entering the control device from the
spray booths, a destruction efficiency of 95 percent was assumed
for the thermal incinerators.1° In costing add-on control
devices, it was assumed that all the spray booths are operated at
once, a worst-case assumption. Based ori the survey responses, it
was assumed that the booths operate 8 hours per day, 200 days per
year. Other inputs used in the add-on control costing are shown
in Table 5-12 and are described in more detail in Appendix C.
Generally, the spray booths now used in shipyards are not
fully enclosed, so the capture efficiency of the exhaust system
is expected to be less than 100 percent. To capture all of the
emissions, the booth and the associated flashoff and drying areas
would have to be enclosed. When an operator leaves the parts in
the booth to cure, most of the emissions are released inside the
booth. For this analysis, total capture was assumed, but the
cost of the enclosure was not included, because of the lack of
specific data. Therefore, the results presented provide a more
favorable value of cost effectiveness ($/ton of VOC controlled),
as the total cost of control is understated by the cost of the
enclosure.
5.2.1.2 Total Spray Booth Flowrate. In developing the
costs of using add-on controls to control VOC emissions from
spray booth coating operations, it was assumed that one large
unit would be used to control the exhaust from all the spray
booths. In some shipyards, one large unit would be undesirable
due to the distances between spray booths. Long lengths of
ductwork would be needed between the booths and the control
5-29
-------
TABLE 5-12. GENERAL DESIGN SPECIFICATIONS FOR
ADD-ON CONTROLS
Specification
Destruction efficiency, percent
Applicable range of flowrates, m^/s (scfm)
Exhaust temperature, °C (°F)
Relative humidity of exhaust, percent
Operating temperature, °C (°F)
Pressure drop, centimeters of water (inches of
water)
Equipment life, years
Heat recovery, percent
Incinerator warmup period, minutes
Shifts operated per day
Annual operating hours
Control device
Thermal incineration-
recuperative H.Ra
95b
<23.6
(< 50,000)
25(77)
70
760 (1,400)
,48 (19)
10
70
45
1
2,000
Thermal incineration-
regenerative H.R.a
95b
>23.6
(> 50,000)
25(77)
70
814 (1,500)
74 (29)
10
95
60C
1
2,000
aH.R. = heat recovery.
"Destruction efficiency of 98 percent can be achieved if VOC concentration at inlet to control device is
increased sufficiently (>300 ppm). A destruction efficiency of 98 percent can be achieved if air curtain
booth spray booths are used.
cUnit is maintained at idle for 15 hours per day at 15 percent of the total flow.
5-30
-------
device, and the large pressure drops associated with such long
lengths of ductwork would make such a system impractical. In
some instances, two smaller control units may be more practical,
but the capital and operating costs would be higher. Thus, the
assumption of one large unit will understate the costs and
overstate the cost effectiveness.
Initially, the total spray booth flowrate to be controlled
was calculated assuming all booths are used concurrently. Limits
on the total number of booths operated concurrently and/or spray
booth coating usage cutoffs (i.e., no control for booths that use
less than some designated amount of coating) could reduce the
maximum spray booth exhaust rate to be controlled. The analysis
discussed here assumes that all booths operate at once and that
all booths are exhausted to the control device.
Some spray booth information was provided from the surveys
that were sent to shipyards as part of the CTG and NESHAP
projects. This information was compiled and used to develop
spray booth parameters for the add-on control analysis. It was
determined that shipyards that fall into the "extra small"
classification, whether construction or repair yards, generally
do not have spray booths. Therefore, for purposes of the
analysis, it was assumed that extra small model plants have no
spray booths.
For each shipyard that provided complete information on all
spray booths, the total spray booth flowrate, total coating
usage, percentage of coatings used indoors, and the typical
operating hours for each booth were compiled.2 It was assumed
that all coatings applied indoors were applied in spray booths.
The estimated spray booth coating usage at each of the yards and
the actual total spray booth exhaust at each yard (assuming all
spray booths are used at once) were used in a linear regression
analysis to develop an equation relating total spray booth
coating usage and total spray booth exhaust.
Using the resulting regression equation, the flowrates for
each of the shipyards with booths were estimated, and the
5-31
-------
estimated flowrates were compared to the actual flowrates. The
agreement between the predicted flowrates and the actual
flowrates was best for the larger yards. However, in all the
model yard'size ranges, the total flowrates from some yards were
significantly below the predicted flowrates. Therefore, to
represent such actual cases in the cost analysis,, the minimum
expected flowrates for all the model yards were determined by
selecting the actual minimum flowrate for each model yard
category. Only yards that supplied complete spray booth
information were used in this selection process. Because the
capital and operating costs of add-on controls increase with
flowrate, the costs associated with these minimum flowrates
represent the minimum costs that would be expected for the model
yards. Likewise, the corresponding cost-effectiveness values are
the minimum expected (i.e., the most favorable). The development
of the regression equation and model yard spray booth flowrates
is discussed further in Appendix C.
The total spray booth exhaust flowrates calculated for the
model yards using the regression equation range from minimal up
to 19.8 m3/s (419,500 ft3/min) for the large construction model
yard. The minimum expected flowrates range up to 174 m3/s
(369,200 ft3/min). The use of thermal incineration with
recuperative heat recovery was evaluated for total spray booth
exhausts less than or equal to 23.6 m3/s (50,000 ft3/min).
Thermal incineration with regenerative heat recovery was
evaluated for total spray booth exhaust flowrates greater than
23.6 m3/s (50,000 ft3/min).
Catalytic incineration and combined carbon
adsorption/thermal incineration systems could also be considered
but were not costed. In some instances, catalytic incineration
and combined adsorption/thermal incineration may be less
expensive, but the potential difference in cost is not expected
to be significant.
5-32
-------
5.2.2 Total VOC Emitted from Spray Booths
The amount of VOC emitted from the spray booths at each
model yard was estimated based on the percentage of coatings and
thinner applied indoors and corresponding average VOC contents.
Detailed information concerning the type of coatings sprayed in
the spray booths was not provided on the shipyard survey
responses. Therefore, to calculate the VOC emissions from
applying coatings in spray booths, the weighted average VOC
content of all the coatings was used in conjunction with the VOC
content of the thinner. Based on information contained in the
shipyard survey responses, it was assumed that 10 percent of all
coatings and thinner is sprayed in spray booths in each of the
model yards except the large construction yard where 30 percent
was used.2
The actual emission reduction associated with using add-on
controls for spray booths could be lower or higher than that
estimated in this analysis. Because 100 percent capture
efficiency was assumed and the actual capture efficiency is
expected to be less, the actual emission reduction may be less
than estimated. On the other hand, actual emission reductions
may be higher if cleaning solvents are used in the booth. Such
miscellaneous cleaning could include gun, coating lines and
pumps, and coating containers. The operating costs associated
with the control device would increase very slightly if there is
an increase in operating time, but the increase is not expected
to be significant.
5.2.3 Spray Booth Add-on Control Analysis Results
The cost and associated emission reductions for using
thermal incinerators to control VOC emissions from spray booth
coating application operations were developed for each of the six
model yards that use spray booths (the two "extra small" models
do not have spray booths). Results of the model yard analysis,
presented in Table 5-13, indicate the cost effectiveness of using
add-on controls ranges from $44,700 to $338,000/Mg ($40,500 to
$306,900/ton) of VOC reduced. Using the minimum expected
5-33
-------
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flowrates, the cost effectiveness ranges from $32,600 to
$65,700/Mg ($29,600 to $59,600/ton). Because of the series of
assumptions these values tend to be maximums. The cost would
decrease if the booth airflows in the booths are reduced.
5.3 TANK PAINTING--USE OF ADD-ON CONTROLS19"26
Tanks are used to store fuel oil, jet fuel, ballast, and
potable water. There can be as many as 1,000 tanks on an
aircraft carrier; 500 may be on a single deck.19 During
construction, tank components may be painted before or after
assembly. When a preassembled tank is painted it serves as a
sort of natural enclosure. The same is true for voids on the
ship that must be painted for corrosion protection. For purposes
of this analysis, both tanks and voids are referred to as tanks.
The tank must be ventilated during painting to protect the
worker and the final finish (dried overspray can settle on the
finish). Because the tank acts as a natural enclosure, the VOC
emissions resulting from the painting operation could conceivably
be sent to an add-on control device. The feasibility and cost of
using an add-on control to control tank painting operations was
evaluated and is discussed in the following sections.
5.3.1 Feasibility of Add-On Controls for Tank Painting
Operations
Add-on controls can be used to control VOC emissions
resulting from tank painting operations. The enclosed nature of
tanks makes efficient capture of the VOC emissions feasible with
minimal or no modifications to the tank. These captured
emissions can then be vented to an add-on control device for
destruction. Although the use of add-on controls for tank
painting operations is technically feasible, in some cases it may
not be practical. During construction and repair operations,
deck space is often limited because of the numerous activities
occurring. At such times, it would be difficult to find space
for an add-on control device on the deck. As discussed in
Section 5.3.2, the maximum exhaust limitations of portable
control devices would limit their usefulness for tank painting
5-35
-------
operations, regardless of space limitations. Therefore, if an
add-on control device or multiple control devices were used to
control VOC emissions from tank painting operations, they would
probably have to be stationary units located on the ground. The
size and configuration of each ship is different, and tanks are
located all around a ship, so the location of the tanks relative
to the control device would constantly vary. If tanks were
vented to a control device located on the ground, long lengths of
flexible ductwork would be needed. A significant pressure drop
is associated with longer lengths of ductwork. It may be
necessary to thread ductwork through a maze of passageways, and
this may constrain the movement of equipment. Having flexible
ductwork traveling from the tanks, through work areas, down to
the control device might prove to be unsafe and would have to be
evaluated.
The varying nature of the total volume of exhaust from all
tank painting operations at any one time would have to be
considered in designing and operating an add-on control system.
Because the total airflow from all tank painting operations
varies with the number and size of the tanks being painted, the
airflow to be controlled could vary from about 0.47 m^/s
(1,000 ft^/min) to several m^/s (several hundred thousand.
ft3/min). Due to the changing capacity requirements, it might be
advantageous to use multiple smaller-capacity add-on control
units, rather than a single large unit. A combination of one
large unit and several smaller ones may enable a shipyard to take
advantage of the economy of scale offered by a larger unit while
at the same time have the ability to control smaller airflows.
A disadvantage of having multi add-on control units, is that the
distribution of airflow among the units would change with time,
as the tanks being painted changed, and this balance would have
to be monitored. A certain warm-up period is required with add-
on control units, and intermittent operation usually shortens the
5-36
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lifetime of the unit.
As stated above, using technology presently available to
control VOC emissions from tank painting operations is feasible,
though several challenges are present. There may be a market for
some type of innovative package add-on control units that are
suspended overhead, or canister units that can be taken below
decks to the tank. The development of such technologies may make
it easier and less expensive to use add-on controls for tank
painting emissions control.
5.3.2 Assumptions and Inputs to the Analysis
A comprehensive discussion of the assumptions made and
inputs that were developed as part of the tank analysis is
provided in Appendix C.
Due to the variability in the number and size of tanks that
may be painted at any time in a shipyard, add-on control costs
were developed for a range of airflows rather than for individual
model shipyards. Costs of using thermal incinerators with
recuperative heat recovery to control airflows ranging from 0.9
to 37.7 m3/s (2,000 to 80,000 ft3/min) were estimated.
Controlled emissions were estimated using two methods. One
estimate was based on the maximum tank VOC emissions calculated
for the shipyards in the data base. For this estimate, the tank
VOC emissions for each yard in the data base were calculated
using the reported usage of tank coatings and corresponding VOC
contents (as supplied) for the facility. Emissions from thinning
the tank coatings 5 percent by volume were included. The maximum
annual tank VOC emissions at any shipyard in the data base were
estimated to be 18 Mg (20 tons) using this method.
Another estimate of maximum tank VOC emissions was made
based on the maximum total VOC emissions from any of the
shipyards in the data base. This second estimate of tank
emissions was based on examination of the contribution of tank
coating VOC emissions to total coating VOC emissions at yards in
the data base. Based on the coating usage and classification
data in the data base, the relative contribution of tank coatings
5-37
-------
to total coating VOC emissions (including thinner) was found to
vary from less than 1 to 35 percent, with a mean of 9.8 percent.
To obtain the second estimate of annual tank painting VOC
emissions, which represents a maximum estimate, it was assumed
that 9.8 percent of the total VOC emissions from coatings
(including thinner) at the largest facility in the data base are
from tank painting. The total tank coating-related VOC emissions
for the largest facility were, thus, estimated to be 47 Mg (52
tons) annually, more than twice the first estimate.
5.3.3 Results of Tank Painting Add-On Control Analysis
The total cost and emission reductions for each of the
scenarios evaluated are presented in Table 5-14. Although, the
size and cost of a control device varies-with the total air
flowrate, the amount of VOC controlled were estimated in the two
methods given above, independently of the flowrate. The cost
effectiveness for each of the scenarios, calculated as the total
cost divided by the total amount of VOC controlled, is also
presented in Table. 5-14.
Using the first emission reduction estimate (based on actual
tank coating usage and VOC contents), the cost effectiveness
varies from $5,000/Mg to $40,300/Mg ($4,500/ton to $36,300/ton).
Using the maximum emission reduction estimate (calculated
assuming 9.8 percent of the VOC emissions at the largest facility
[in terms of total VOC emissions] are from tank painting), the
cost effectiveness varies from $l,900/Mg to $15,500/Mg
($l,700/ton to $14,000/ton).
In reality, the amount of VOC controlled is dependent on the
concentration of VOC's in the air stream and on the flowrate of
the air stream flowing into the add-on control unit. However,
in this analysis the estimates of VOC controlled are intended to
represent average and maximum tank emissions expected at any
shipyard. The actual amount of VOC controlled at any one
facility would depend on the amount of tank painting done at the
facility and the coatings used.
5-38
-------
TABLE 5-14a.
COST EFFECTIVENESS OF TANK
(Metric Units)
ADD-ON CONTROL3
Flowrate,
m3/s
0.9
2.4
4.7
9.4
18.9
28.3
37.7
Annuali zed
cost, $
90,800
124,700
170,700
280,400
435,800
582,900
726,200
Controlled
emissions,
Mg/yr10
18 (47)
18 (47)
18 (47)
18 (47)
18 (47)
18 (47)
18 (47)
Cost
effectiveness ,
$/Mgc
5,000 (1,900)
6,900 (2,700)
9,500 (3,600)
15,600 (6,000)
24,200 (9,300)
32,400 (12,400)
40,300 (15,500)
TABLE 5-14b.
COST EFFECTIVENESS OF TANK
(English Units)
ADD-ON CONTROL3
Flowrate,
scfm
2,000
5,000
10,000
20,000
40,000
60,000
80,000
Annual ized
cost, $
90,800
124,700
170,700
280,400
435,800
582,900
726,200
Controlled
emissions,
tons/yr0
20 (52)
20 (52)
20 (52)
20 (52)
20 (52)
20 (52)
20 (52)
Cost
effectiveness ,
$/tonc
4,500 (1,700)
6,200 (2,400)
8,500 (3,300)
14,000 (5,400)
21,800 (8,400)
29,100 (11,200)
36,300 (14,000)
aAdd-on control assumes a recuperative thermal incinerator
with 70 percent heat recovery.
"Controlled emissions were calculated using two methods. The
first number corresponds to the maximum calculated tank
emissions using coating classification usage and composition
data. The second number corresponds to maximum emission
reduction estimate assuming 9.8 percent of maximum total VOC
emissions are tank-related.
GCost effectiveness numbers correspond to both sets of
controlled emission rates that were calculated using two
different methods.
5-39
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5.4 COST OF CONTROL OPTIONS FOR PM-10 EMISSIONS FROM ABRASIVE
BLASTING OPERATIONS
It was not possible to estimate how much it would cost to
control PM-10. As discussed in Chapter 4.2.2, although a variety
of actions are routinely taken by many plants to minimize
particulate emissions, their effectiveness has not been
quantified. Therefore, the cost effectiveness of PM-10 control
options cannot be estimated at the present time.
5.5 CLEANING CONTROL COSTS
The cost associated with the use of accounting and
management to track and control usage of cleaning solvents in a
plant is discussed in the Alternative Control Techniques (ACT)
for Industrial Cleaning Solvents27. The-program for emission
reductions from using solvents as a cleaning media described in
the Industrial Cleaning Solvents ACT should be applicable to the
shipbuilding and repair industry.
The cleaning needs at no two shipyards are exactly alike
because of the different painting schedules and different paint
used. Usually, the coating is stored in 18.9-L (5-gallon) or
larger containers located on the floor of the dock. A pump
transfers coating to the spray gun located on some type of
elevated platform. In most yards, the length of the transfer
line varies between about 15 and 46 m (50 and 150 ft). One yard
was found to be using transfer lines 92 m (300 ft) long. The
longer the transfer line the more solvent is needed to "flush"
the line of paint residues. To clean the equipment after
spraying, one end of the hose is placed in a small container and
solvent is pumped through the hose and spray gun, and released
back into the container. The spray gun head is often removed
for cleaning, and the parts placed in a cleaning bucket.
Cleaning solvent used only once can then be used to thin the
coating. After more than one use, the spent solvent no longer
can be used for thinning but rather must be disposed or purified.
. Some of the larger shipyards have on-site distillation units for
purification; many shipyards send the spent cleaning solvent
5-40
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offsite for disposal or reclamation.28
5.6 ENVIRONMENTAL, ENERGY, AND OTHER IMPACTS
The environmental, energy, and other impacts presented here
are the effects that using any of the VOC and PM-10 emission
control options outlined in the previous sections of this chapter
will have on air quality, water quality, hazardous wastes, energy
usage, and other areas.
5.6.1 Environmental Impacts.
5.6.1.1 Air Quality Impacts. Emissions of VOC's are
significantly reduced by implementing lower-VOC or add-on control
options. Based on the information and assumptions presented in
the earlier sections, switching from lower- to higher-solids
coatings decreases the VOC content of the coatings and the total
volume of coatings required. Therefore, emissions of VOC's are
significantly decreased. If solvent thinner usage can be reduced
or eliminated, the emissions of VOC's are further lowered.
The emission reductions achievable from incineration of
spray booth emissions at large construction yards are
significantly greater than those from other model yards simply
because large construction yards use spray booths more
frequently. The VOC emission reductions obtainable with
incinerators are presumed to be 95 percent.
Auxiliary fuel is required for startup of thermal
recuperative incinerator units as well as for maintaining a
stable temperature. The auxiliary fuel used is assumed to be
natural gas. The pollutant emissions resulting from natural gas
use in incinerator units are nitrous oxides (NO.J , sulfur
J\,
dioxides (S02), carbon monoxide (CO), residual particulate matter
(PM), and various hydrocarbons. The emission factors for these
pollutant emissions can vary depending upon the heat input
required to destroy the waste gases, however, those used here are
presented in Appendix C. 29 Table 5-15 summarizes the primary
emissions that would result from a recuperative incinerator at
each model plant. The majority of the emissions resulting from
natural gas combustion is NO...
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5-41
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5-42
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Electrical energy is required to operate in-line coating
heaters and the induced draft (ID) fans in the thermal
incinerators. Secondary emissions of air pollutants (PM, SC^,
and NOV) result from the generation of the electrical energy
J^
required to operate these devices. Secondary emissions were
calculated assuming that the electrical power required to operate
the devices is supplied by a bituminous coal-fired power plant
that has a generator thermal efficiency of 38 percent.30 The
average heating value of bituminous coal is approximately
29,000 KJ/kg (12,600 Btu's per pound [Btu/lb]).31 The emission
factors used to estimate secondary pollutant emissions are
presented in Appendix C.
Tables 5-16 and 5-17 summarize the ,secondary emissions
associated with the electrical energy required to operate the in-
line paint heaters and the incinerators. Secondary emissions
caused by large construction yards are significantly greater than
other model yards because of their larger waste gas flows vented
to the incinerators. An increase in the electrical power
required to operate the fans causes an increase in the secondary
pollutant emissions that result from burning the fuel to generate
the power.
5.6.1.2 Water Quality Impacts. No adverse water pollution
impacts are expected from the use of any of the VOC control
options.
5.6.1.3 Hazardous Waste. Liquid hazardous waste generated
during shipyard painting operations consists primarily of spent
solvent and coatings. The use of higher-solids coatings may
require increased solvent usage for gun cleaning. However,
because less of the lower-VOC coatings will be used (due to their
higher-solids content), the overall amount of waste generated is
expected to decrease for the same usage efficiency.
5.6.2 Energy Impacts
Fuel (natural gas) is needed for operation of the thermal
incinerators. The resulting energy usage is presented in
Table 5-15.
5-43
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TABLE 5-16a. ELECTRICITY REQUIREMENTS AND SECONDARY
EMISSIONS FROM USE OF IN-LINE PAINT HEATERS
(Metric Units)
Model yard
No.
1
3
5
7
2
4
6
8
Description
Construction, Large
Construction, Medium
Construction, Small
Construction, Extra small
Repair, Large
Repair, Medium
Repair, Small
Repair, Extra small
Electricity,
kW-hr/yr
1.33E+06
5.51E+05
3.43E+05
2.42E+05
1.19E+06
4.71E+05
3.43E+05
2.55E+05
Emissions, kg/yr*
PM
1.63E+02
6.77E+01
4.21E+01
2.97E+01
1.47E+02
5.80E+01
4.21E+01
6.91E+01
so2
3.25E+03
1.35E+03
8.39E+02
5.92E+02
2.92E+03
1.15E+03
8.39E+02
6.24E+02
NOX
3.25E+03
1.35E+03
8.39E+02
5.92E+02
2.92E+03
1.15E+03
8.39E+02
6.24E+02
TABLE 5-16b. ELECTRICITY REQUIREMENTS AND SECONDARY
EMISSIONS FROM USE OF IN-LINE PAINT HEATERS
(English Units)
Model yard
No.
1
3
5
7
2
4
6
8
Description
Construction, Large
Construction, Medium
Construction, Small
Construction, Extra small
Repair, Large
Repair, Medium
Repair, Small
Repair, Extra small
Electricity,
Btu/yr
4.54E+09
1.88E+09
1.17E+09
8.26E+08
4.08E+09
1.61E+09
1.17E+09
8.71E+08
Emissions, Ib/yr*
PM
3.62E+02
1.49E+02
9.29E+01
6.56E+01
3.24E+02
1.28E+02
9.29E+01
6.91E+01
so2
7.17E+03
2.97E+03
1.85E+03
1.31E+03
6.45E+03
2.54E+03
1.85E+03
1.38E+03
NOX
7.17E+03
2.97E+03
1.85E+03
1.31E+03
6.45E+03
2.54E+03
1.85E+03
1.38E+03
aSecondary emissions were calculated based on emission factors for bituminous coal combustion in
Reference 31.
5-44
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TABLE 5-17a. ELECTRICITY REQUIREMENTS AND SECONDARY
EMISSIONS FROM THERMAL INCINERATION FOR SPRAY BOOTH
PAINTING OPERATIONS
(Metric Units)
Model yard*
No.
1
3
5
2
4
6
Description
Construction, Large
Construction, Medium
Construction, Small
Repair, Large
Repair, Medium
Repair, Small
Electricity,
kW hr/yr
5.36E+06
1.51E+06
1.25E+06
2.32E+06
1.41E+06
1.25E+06
Emissions, kg/yrb
PM
6.59E+02
1.85E+02
1.53E+02
2.85E+02
1.74E+02
1.53E4-02
SO2
1.31E+04
3.68E+03
3.05E+03
5.68E+03
3.46E+03
3.05E+03
NOX
1.31E+04
3.68E+03
3.05E+03
5.68E+03
3.46E+03
3.05E+03
TABLE 5-17b. ELECTRICITY REQUIREMENTS AND SECONDARY
EMISSIONS FROM THERMAL INCINERATION FOR SPRAY BOOTH
PAINTING OPERATIONS
(English Units)
Model yarda
No.
1
3
5
2
4
6
Description
Construction, Large
Construction, Medium
Construction, Small
Repair, Large
Repair, Medium
Repair, Small
Electricity,
Btu/yr
1.83E+10
5.14E+09
4.26E+09
7.93E+09
4.83E+09
4.26E+09
Emissions, Ib/yr5
PM
1.45E+03
4.08E+02
3.38E+02
6.29E+02
3.83E+02
3.38E+02
SO2
2.89E+04
8.12E+03
6.73E+03
1.25E+04
7.63E+03
6.73E+03
NOX
2.89E+04
8.12E+03
6.73E+03
1.25E+04
7.63E+03
6.73E+03
Construction and repair extra small model yards were not evaluated because these yards were assumed to
have no spray booths.
bSecondary emissions were calculated based on emission factors for bituminous coal combustion in
Reference 31.
5-45
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The electrical requirements of in-line heaters and thermal
incinerators are presented in Tables 5-16 and 5-17, respectively.
The necessary calculations for this section are described in
Appendix C.
5.6.3 Other Environmental Impacts
Other environmental impacts include noise impacts from
implementing any of the control options for all model yards. In
general, thermal incinerators require additional equipment
(larger ID fans to overcome pressure drops) that will increase
noise levels. However, theincrease is believed insignificant.
5.7 REFERENCES FOR CHAPTER 5
1. South Coast Air Quality Management District Rule 1106.
November 4, 1988. Amended June 2, "1989.
2. Memorandum. deOlloqui, V., Midwest Research Institute
(MRI), to Project File. List of Control Techniques
Guideline and National Emission Standard for Hazardous Air
Pollutants survey responses and related trip reports.
November 11, 1992
3. Memorandum. deOlloqui, V., MRI, to Project File. List of
survey responses received from marine coating suppliers.
November 16, 1992.
4. Telecon. Caldwell, M. J., MRI, with Folse, J., Sigma
Coatings. July 2, 1992. Relationship between, coating
solids content and usage.
5. Telecon. Caldwell, M. J., MRI, with Kelly, J., Courtaulds
Coatings. November 20, 1992. Maximum solids contents of
marine coatings.
6. Telecon. Caldwell, M.J., MRI, with S. Gag, Ameron Coatings.
October 6 and 29, 1992. Solids contents of particular
Ameron coatings.
7. Telecon. Caldwell, M.J., MRI, with J. Czajak, Sinks
Manufacturing. October 14, 1992. In-line paint heaters.
8. Telecon. deOlloqui, V., MRI, with G. Olson, Graco, Inc.
October 9, 1992. In-line paint heaters.
9. Telecon. Reeves, D., MRI, with M. Chee, NASSCO. October 8,
1992. Operating practices at NASSCO concerning in-line
paint heaters.
5-46
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10. Telecon. deOlloqui, V., MRI, with S. Devini, Bath Iron
Works. November 5, 1992. The use of in-line paint heaters.
11. Bay Area Air Quality Management District. Regulation 8,
Rule 43. Adopted November 23, 1988.
12. San Diego Air Pollution Control District. Rule 67.18.
Effective July 3, 1990.
13. California Air Resources Board. Determination of Reasonably
Available Control Technology and Best Available Retrofit
Control Technology For Marine Coating Operations. Criteria
Pollutants Branch. Stationary Source Division. January 8,
1991.
14. Telecon. Williamson, M., MRI with D. Austin, Southwest
Marine. June 7, 1993. Recordkeeping and reporting
requirements.
x*
15. Telecon. Williamson, M., MRI with T. Beacham, Norfolk
Shipbuilding and Drydock Corporation. June 3, 1993.
Recordkeeping and reporting requirements.
16. Response to Recordkeeping and Reporting Questionnaire.
National Steel and Shipbuilding Company. June 23, 1993.
17. U. S. Environmental Protection Agency. BSD Regulatory
Procedures Manual. October 1990. Volume X Section 2.2.
18. U. S. Environmental Protection Agency, OAQPS Control Cost
Manual, Fourth Edition. Research Triangle Park, N.C.
January 1990. EPA 450/3-90-006.
19. Presentation made at the 1992 Marine and Offshore
Maintenance Coatings Conference held in Ponte Vedra Beach,
Florida, June 3-5, 1992. Presentation made by R. Wheeler,
Puget Sound Shipyard, Bremerton, Washington.
20. Telecon. Caldwell, M.J., MRI, with T. Stewart, Newport News
Shipyard. September 15, 1992. Requesting information
regarding tank painting operations.
21. 29 CFR 1915.35, Subpart C.
22. Telecon. Caldwell, M. J., MRI, with R. Taylor, Durr
Industries. September 15, 1992. The feasibility of using
add-on controls to control marine tank painting VOC
emissions.
23. Telecon. Caldwell, M. J., MRI, with J. Minor, M&W
Industries, Inc. June 20, 1991. Clarification of
information provided in add-on control survey response.
5-47
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24. Telecon. Caldwell, M. J., MRI, with Minor, J., M&W
Industries, Inc. June 20, 1991. Clarification of
information provided in a survey received as part of the
wood furniture control techniques guideline project.
25. Telecon. Caldwell, M. J., MRI, with Bhushan, D., Durr
Industries, Inc. June 25, 1991. Clarification of
information provided in survey received as part of the wood
furniture control techniques guideline project.
26. Telecon. Caldwell, M. J., MRI, with Mcllwee, R., Smith
Engineering Company. June 25, 1991. Clarification of
information provided in survey received as part of the wood
furniture control techniques guideline project.
27. Alternative Control Techniques Document--Industrial Cleaning
Solvents. Office of Air Quality Planning and Standards,
U. S. Environmental Protection Agency. Research Triangle
Park. North Carolina. EPA 453/R-9*4-015. February 1994.
28. Telecon. Caldwell, M. J., MRI, with Ambrose, L., Norfolk
Shipbuilding and Drydock Corp. October 15, 1992. Painting
and cleaning at shipyards.
29. Compilation of Air Pollutant Emission Factors. Fourth
edition. Volume I, Supplement D, Section 1.4. p. 1.4-2.
September 1991.
30. Steam: Its Generation and Use. New York, The Babcock and
Wilcox Company. 1978. p. 22-11.
31. Electric Utility Steam Generating Units--Background
Information for Proposed Standards. Prepared for U.S. EPA.
July 1978. EPA-450/2-78-007a. p. 4-36.
32. Memorandum. Reeves, D., MRI, to Project File. Industry
meeting minutes. September 15, 1993.
33. National Steel and Shipbuilding Company. NASSCO Position
Paper on the Reconsideration of Standards for the Inorganic
Zinc Specialty Coating Category in Marine Coating
Operations. Presented at industry meeting on September 1,
1993. 9 pp.
34. Letter and attachments from Kaznoff, A. I., Naval Sea
Systems Command, to Berry, J. C., EPA/ESD/CPB.
September 17, 1993. 39 pp. Information on VOC and HAP
content of marine coatings.
5-48
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6.0 Factors to Consider in Developing BEST AVAILABLE
CONTROL MEASURES (BACM)
This Chapter presents information on factors that regulatory-
agencies should consider to select the best available control
measures (BACM) for VOC emissions from painting activities in the
shipbuilding and ship repair industry. ^Alternative technologies
(and options for one) were discussed in Chapter 3.
Findings regarding particulate emissions from abrasive
blasting are presented in Chapters 2 through 4. Because test
data was not available to us at this time our suggestions deal
only with changes in "manufacturing practices" and "work
practices.".
To control emissions from cleaning solvents, States should
consider the alternatives described in the "Alternative Control
Techniques (ACT) for Industrial Cleaning Solvents," EPA number
EPA-453/R-94-015, dated February 1994.
The statutory authority and goals for establishment of BACM
is discussed in Section 6.1 for the benefit of the State
regulators. In developing BACM for this industry a State agency
may select from control techniques stated in this report or may
transfer technology from other industries. Authorities may also
develop BACM on a case-by-case basis, considering the economic
and technological circumstances of the individual source. The
final rules must, however, be enforceable; include provisions
which allow determination of compliance.
In Section 6.6, factors to be considered for each individual
source are discussed. Information is provided related to
emission testing, equipment under-development, monitoring and
6-1
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reporting/record keeping.
6.1 BACKGROUND
The Clean Air Act, as amended in 1990, requires that control
techniques to control VOCs and PM1Q from the shipbuilding and
ship repair industry be based on BACM. This mandate represents a
stricter standard than has been applied to regulate emissions of
VOCs and particulates in non attainment areas: previous
standards for protecting the ambient air quality have been based
on reasonably available control technology (RACT).
6.2 DEFINITIONS
The Shipbuilding and Ship repair rule should accurately
describe the sources that will be affected and use terms that are
clearly defined to describe the method of control. The terms and
definition described in this document may need to be clarified
when used in the context of a rule. A short list of helpful
definitions is given in Appendix A.
A large source of air emissions in Shipyards are organics
from marine coatings. Chapter 2 discusses types of marine
paints, resins and equipment and application processes used.
Different types of paints are discussed and defined under
Section 2.2.1.
Table 2-9 lists a number of paint categories. The
categories correspond to those in that appear in the California
coatings rules (effective in 1992) in addition to four categories
that were added based on Department of Navy (NAVSEA)
recommendations. The definitions for the 23 paint categories
are given in Chapter 2. However, a State may elect to expand on
the definitions as this report has done for nuclear coatings.
6.3 APPLICABILITY
As outlined in Chapter 2.0, the shipbuilding and ship repair
industry consists of establishments that build and repair ships
(Fiber glass reinforced ship manufacturing processes are
excluded). A definition for a ship is also provided in
Chapter 2.0 to define the shipyards that would be subject to a
rule. Emissions from painting of drilling and offshore
6-2
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production platforms (which are a part of SIC Code 3731) were not
included in the Agency's investigation. The coatings category
"navigational aids" was included in the rule because buoys and
other waterway markers are exposed to the same weathering
conditions (e.g., corrosion) as a ship. The implementing agency,
may, of course, elect to include in its rule other paint
categories that it deems appropriate.
6.4 FORMAT OF THE STANDARD
The BACM regulations for this source category may be based
on one or more of the following formats.
I. Use of VOC limits
2. An equipment standard; and
3. A percent reduction level.
6.4.1 Use of VOC Limits
The EPA has evaluated the VOC control achievable by limiting
the maximum allowable VOC content of individual coatings and
another based on the weighted average VOC. The advantages and
disadvantages of one option relative to another are discussed in
Chapter 5. Table 1-1 presents a maximum, as-applied VOC of
various paint categories.
6.4.2 Equipment Standard
Air and airless spray equipment are commonly used in this
industry. The possibility of specifying special spray equipment
such as high volume low-pressure or "HVLP" was investigated to
gain the benefit of less paint waste (and lower VOC emissions)
due to the softer delivery of paint to the substrate. Although
it seems clear that such equipment is desirable, some shipyards
allege that low pressure systems are unable to accommodate some
of the higher solids coatings used by the industry.
6.4.3 Percent Reduction
Standards in this form are commonly used when the control
system is anticipated to be an "add-on" device such as an
incinerator or carbon adsorber. There are, however, no
commercially available technologies for enclosing outside areas
of a ship (a critical prerequisite for add-on devices) although a
6-3
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number of US companies are working on different enclosure
designs. Several technologies under development are reviewed in
Chapter 3. Efficient enclosures are desirable for many reasons.
They would help in controlling PM1Q emissions; pollution due to
storm water runoff could be almost eliminated. They would make
it possible for a shipyard to addon control equipment such as
catalytic incinerators and carbon adsorption systems to reduce
VOC emissions.
Add-on controls may be applicable for storage tanks in ships
and when painting operations within buildings in a shipyard.
6.5 EMISSION REDUCTION AND COST
The emission reduction and cost impacts associated with
several options are summarized in Tables' 5.11. For compliance
scenario 1 (see Section 5.1.2), which is expected to most closely
approximate actual practice at shipyards, the costs for
recordkeeping and reporting as estimated affect significantly
total cost and cost effectiveness of an option.
6.6 ADDITIONAL FACTORS TO BE CONSIDERED.
The cost to control emissions from several units was
determined based on painting operations believed to be typical of
most shipyards. There may, however, be situations where other
emission limitations or recordkeeping provisions are more
appropriate. Some potential cases are discussed below.
As presented in Table 5-13, the estimated cost
effectiveness of add-on controls for spray booths at the models
used to represent a variety of shipyards is very expensive.
Where facilities operate paint spray booths continuously with
relatively high paint use rates of high VOC coatings, the cost
effectiveness of add-on controls may be much more favorable. For
example, at one shipyard, an automated system for applying
preconstruction primer to steel plate is being retrofitted with
an abatement system. A State may choose to analyze spray booth
usage patterns on a case-by-case basis to determine whether add-
on controls are cost-effective. Part of the evaluation should be
to determine the minimum flow of exhaust air from the booth
6-4
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during painting based on VOC emissions and Occupational Safety
and Health Administration (OSHA) requirements. Cost
effectiveness of control is inversely related to exhaust air flow
from the booth.
All ships have fuel and ballast tanks. Some have other
types of tankage. The number, size, location, and type of tanks
to be painted may vary widely from day to day. Because the
interior of a tank is essentially a total enclosure, control of
tank painting emissions may be cost-effective if sufficient tanks
(and similarly enclosed substrates) are painted so that there is
a near continuous source of VOC feed to the control device.
Because viscosity is inversely related to temperature, at
some point paints must be thinned (or heated) to reduce viscosity
so that the spray guns will atomize the coating.
It has been impossible to determine at what temperature such
thinning must be initiated because traditionally, solvent has
been added to shipyard paints even under circumstances where the
coating manufacturer often instructs that no solvent addition is
necessary or recommended.
Since the only acceptable and legitimate purpose for
allowing paint to be thinned is to assure the resulting viscosity
permits it to be applied by spray, a State might use that
relationship to establish the maximum allowable dilution rate.
The shipyard might be required to determine the temperature at
which their spray systems are no longer capable of atomizing the
coating and then limit the requisite solvent additions to that
necessary to achieve the requisite viscosity at existing ambient
temperatures.
Because data on emissions from abrasive blasting for
cleaning metal surfaces was not available and tests conducted by
the Agency did little to enlighten, it was not possible to
evaluate achievable reductions and cost effectiveness of options
to reduce that source of PM1Q emissions. Suggestions on work
practices that reduce overall emissions are likely to also
control PM10 emissions.
6-5
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6.7 TEST PROCEDURES
EPA Method 24 2 is the recommended procedure for measuring
VOC from paints and coatings. The Administrator may approve a
request for an "equivalent" method if it yields equivalent
results.
6.8 REPORTING AND RECORD KEEPING
The recordkeeping assumed for this analysis was based on
daily records of paint and thinner usage that would allow the
as-applied VOC content of the paints to be calculated for each
day. If a shipyard does not thin its paints before application,
a State may allow it to certify the VOC of paints "as supplied"
(with VOC contents certified by the paint supplier) and that no
thinning solvent was added.
A similar approach might be considered for yards that use
only paints that meet the VOC limit, even when thinned to the
maximum level recommended by the paint supplier. An appropriate
certification procedure is described in reference 3.
The VOC content of a coating should not be estimated from
solvent composition data provided in a material safety data sheet
(MSDS) nor should it be based on the VOC value given in product
data sheet (PDS). Often that information is presented in very
general terms (the MSDS presents species concentrations in terms
of ranges rather than specific terms) and the VOC values on
product data sheets are commonly (and erroneously) presented in
terms of the paint solvent in the formulation, omitting the
contribution of volatile organic by-products of the cure reaction
(see Chapter 2). For determining compliance, specific paint data
should be used. As detailed in the Agency's publication
"procedure for Certifying Quality of Volatile Organic Compound
Emitted by Paint Ink and Other Coatings" 3. That report provides
step-by-step instructions for manufacturers and users of coatings
to provide information on VOC emitted by a coating.
6-6
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6.9 REFERENCES FOR CHAPTER 6.0
1. Alternative Control Techniques Document--Industrial Cleaning
Solvents; US EPA, RTP, NC 27711; EPA-453/R-94-015, February
1994; NTIS: PB94-156791.
4
2. EPA Method 24 (40 CFR Part 60 Appendix A).
3. Procedures for Certifying Quantity of Volatile Organic
Compounds Emitted by Paint, Ink and Other Coatings,"
(Revised June 1986); US EPA, NC, 27711; EPA-450/3-84-019.
6-7
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APPENDIX A
SPECIAL DEFINITIONS
-------
SPECIAL DEFINITIONS
Cleaning Practice
A repeated or customary action that is specific to an
industry. An example is nightly maintenance of a spray
booth or maintaining solvent waste containers closed.1
Nuclear coatings
These are protective coatings used to seal porous surfaces
such as steel (or concrete) that otherwise would be subject
to intrusion by radioactive materials. These coatings must
be resistant to long-term cumulative radiation exposure,
relatively easy to decontaminate and resistant to various
chemicals used to which the coatings are likely to be
exposed.2 (General protective requirements are outlined by
the Department of Energy (U. S. Atomic Energy Commission)
Regulatory Guide 1.54.)
Several terms in the above definition are defined for
specifity.
Radioactive Materials (isotopes); Contamination of a
surface (or substrate) can occur via air-borne,
water-borne materials or smearable means (e.g., during a
spill or leak).
Resistant to Chemicals; This is evaluated using
ASTM 3912-80 (except for potassium permanganate) or an
equivalent test method .
Decontamination; Protective coatings should be
decentaminable per ASTM D4256-83 or an equivalent method
Radiation Tolerance: This is be evaluated using ASTM
D4082-83 or an equivalent method.
Product substitution
Replacement of any product or raw material intended for an
intermediate or final use with another. This substitution is
a source reduction activity if either the VQC emissions or
the quantity of waste generated is reduced.
Work Practice
This term is reserved for specific human activities within
industry that lead to a reduction in VOC emissions (or
waste). The activities include increased operator training
and management directives. It does not include the use of
specialized equipment, such as (cleaning) solvent
dispensers.1 Cost items under this heading involve training
personnel on proper procedures for diluting coatings,
keeping coating records, or handling solvent containing
materials.
A-l
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A.2 REFERENCES FOR APPENDIX A
1. Alternative Control Techniques Document--Industrial
Cleaning Solvents. US EPA, OAQPS (MD-13), RTP, 27711,
EPA-453/R-94-015 {February 1994) . NTIS PB9.4-156791.
2. M. Serageldin., EPA, to Project File. Definition of
Nuclear Coatings. Adapted from Carboline Company,
Nuclear Binder. December 1993.
A-2
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APPENDIX B.
EMISSION ESTIMATES
-------
APPENDIX B.
EMISSION ESTIMATES
Appendix B is a compilation of the background information
and methodology used to develop Chapter 4, Model Shipyards and
Emission Estimates. Section B.l presents information used to
develop the model yards, and Section B.2-presents the methods and
sample calculations for estimating emissions.
B.I MODEL YARD DEVELOPMENT
Model yard development was based primarily on coatings
information gathered from responses to 37 questionnaires EPA sent
to industry and the Department of Navy. The questionnaires
solicited information on emissions of both VOC and HAP's.1 Of
these 37, 3 were not used because the yards were not considered
full-service. Another yard was deleted due to the lack of
coatings information provided. Coating manufacturer surveys and
site visits supplemented the information received from the
shipyards. '^ A coatings data base was formed from the shipyard
information. The information gathered was analyzed to determine
the types of coatings used in the ship industry, coating usage
trends, and VOC content correlations.
Based on the survey information, three major coating
categories account for 90 percent of the coatings used by the
industry. These are antifoulants, inorganic zincs, and general-
use coatings. The other 10 percent is attributable to a variety
of other coatings used for special purposes. Information on the
three major-use coating categories was used to develop model
yards.
B-l
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Due to the diverse nature of the industry, three different
options were evaluated for developing models to represent the
variety of yards. These options were: (1) the type of vessel
coated--military or commercial, (2) the type of operation--ship
construction or ship repair, and (3) the size of the shipyard.
The results of analyzing each option are as follows.
Option 1; Military Versus Commercial. Military vessels are
highly sophisticated sea vessels and therefore are very expensive
to construct. Military vessels need to be in a constant state of
mission readiness between drydockings. Coatings systems on
military vessels are required to perform a variety of functions
including corrosion protection, camouflage, resistance to wear
from the landings and take-offs of aircraft on landing decks,
resistance to heat damage from surfaces that are exposed to fire,
and ability to withstand the severe chemical exposure used to
decontaminate chemical warfare agents. Commercial vessels are
considerably less sophisticated and less costly to construct.
Frequent drydockings are required for commercial vessels.
Therefore, the durability of coating systems between drydocking
should be of less concern for commercial ships.
The yards within the data base were classified as either
military or commercial yards, depending on the primary source of
their revenue (military or commercial jobs). The coatings
information gathered from the Section 114 responses indicates
that there are no distinct differences in coating usage trends or
VOC contents between predominantly commercial and predominantly
military yards. Because the majority of the information gathered
pertained to military yards, however, any differences between
military and commercial yards may have been masked.
Option 2; Construction Versus Repair Yards. Yards within
the data base were classified as either construction or repair
yards depending on their major source of revenue. The coatings
information in the data base indicates that there are no distinct
differences in the VOC contents of coatings used at construction
yards and repair yards. Both use the same coatings, just not in
B-2
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the same quantities. There are, however, significant differences
in relative coating usages for construction and repair yards.
Construction yards tend to use significantly more inorganic zincs
and general use coatings as a percentage of total coatings
-«
applied than repair yards, while repair yards tend to use
proportionally more antifoulants.
Option 3: Size Classification. The shipyards in the data
base were segregated based on total coating usage to determine if
any significant differences exist between small, medium, and
large yards. The data base reveals no major differences in the
types of coatings or relative coating usages attributable to
size. Consequently, the VOC contents of the three major-use
coatings are presumed essentially the same regardless of yard
size.
B.I.I Model Yard Selection
Because major differences were found in the relative usage
of the three major paints used at construction and repair yards,
the type of work was considered the most significant
characteristic for segregating yards into models that could be
used to characterize the "shipbuilding" and "ship repair"
industry.
B.I.1.1 Construction Versus Repair Classification. For the
purpose of placing data from the shipyards into different model
yard categories, yards were classified based on where 70 percent
of their total revenue was from, construction or repair work.
Two yards in the data base could not be assigned on this basis
and their data were not used.
B.I.1.2 Size Determination. Eight model yards (four
construction and four repair) were developed from the information
derived from the coatings data base. These eight model yards
represent four model yard sizes (extra small, small, medium, and
large) that correspond to the emission rate used to define a
"major source" in extreme, severe, serious, and moderate
nonattainment areas, respectively. Therefore, "extra small"
model yards are those that emit less than 22,680 kilograms per
B-3
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year (kg/yr) (25 tons/yr) of VOC's. "Small" model yards emit
between 22,680 kg (25 tons) and less than 45,360 kg/yr
(50 tons/yr) of VOC's. "Medium" model yards emit between 45,360
kg (50 tons) and less than 90,720 kg/yr (100 tons/yr). of VOC's,
and "large" model yards emit 90,720 kg/yr (100 tons/yr) or more.
B.I.2 Model Yard Parameters
Table 4-2 summarizes the average total coating, solvent, and
abrasive media usages for each model yard class. They are the
averages reported by the shipyards that were assigned to that
model. For example, three yards in the data base had emissions
consistent with those of the large repair model yard class. To
obtain the average coating usage for the large repair model yard
class, the total coating usages reported" by the three yards were
summed and divided by three. This calculation, with all usage
volumes on a less water less 'exempt' solvent basis, is as
follows:
Example: Average Total Coating Usage for the Large Repair Model
Yard Class
Yard No.
7
15
37
Total: 3 shipyards
Coating usage reported,
1.000 L/vr (iToOO aal/yr)
515.6 (136.2)
421.3 (111.3)
424.0 (112.0)
1,361 liters (359.5 gallons)
(359.5xlQ3gal/yr = 119.8 x 103 gal/yr)
3 yards
Similar methodologies were used to obtain all other model yard
parameters presented in Table 4-2.
B-4
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B.I.3 Relative Usages
The relative coating usages determined for both construction
and repair shipyards are presented in Table 4-3. The relative
usage for each model yard was determined by dividing the usage of
each coating category by the total of all coating used. Relative
usages for repair model yards were calculated in the same manner.
The following example uses all volumes on a less water less VOC
'exempt' compounds basis:
Example:
1. Total antifoulant usage for construction model yards =
1.31 x 105 L (34,535 gal)
2. Total coating usage for construction model yards =
3.27 x 105 L (862,611 gal)
calculation: 1-31 x 105 L = 4 percent
3.27 x 10s L
•
Thus, antifoulant comprises 4 percent of the total coating
usage at construction model yards.
B.I.4 Average VOC Content- Determination
The VOC emissions from coatings were calculated based on the
amount of organic solvent in the coatings. The compound 1, 1, 1
trichloroethane was the only VOC 'exempt' solvent in the paint
data submitted by the industry. The total amount of 1, 1, 1
trichloroethane containing paint was insignificant, less than 50
gallons.
Table 4-4 gives the weighted (normalized) average VOC
content, i.e., the average VOC content weighted by volume used,
for each of the three major-use coatings used by the industry and
the solvent category. These averages were calculated from all
reported coatings and solvents. They were not evaluated for
construction and repair yards separately because both were found
B-5
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to use the same types of coatings and solvents; just not in the
same relative quantities. The VOC contents of individual
coatings were provided by the shipyards; this information was
supplemented by data gathered from manufacturers of marine
coatings. The weighted averages were calculated as follows.
First, the usage and corresponding VOC contents of the coatings
within a category were multiplied to obtain the total VOC
represented by the coatings. The sum total VOC of the coatings
within that category was then divided by the sum total of the
usages associated with the coating category to obtain the
weighted average VOC content. The overall VOC content for the
solvent category was calculated in the same manner as that of the
coating categories. The following example uses all volumes on a
less water and less VOC 'exempt' compounds basis:
Exampl e:
1. Total antifoulant VOC from all antifoulants in data
base = 2.6 x 108 grams (g) (5.8 x 105 pounds [Ib])
2. Total volume associated with antifoulant VOC =
6.8 x 105 L (1.8 x 105 gal)
Average VOC content calculation for antifoulant:
B.2 EMISSION ESTIMATES
Table 4-5 gives a breakdown of the VOC emissions by category
for each model shipyard. The VOC emissions for each coating
category is the product of the average total coating use, the
relative use (Table 4-3), and the weighted average VOC content
(Table 4-4). For example, from Table 4-5, the VOC emissions in
metric units) associated with specialty antifoulant usage at
extra-small construction model yards were calculated to be:
(27,785 L/yr) x . 04 x (387 g/L) = 40Q k / (rounded)
1,000 g/kg
B-6
-------
where:
27,785 L/yr = average total annual coating usage for extra
small construction model yards;
0.04 = relative antifoulant usage at construction
yards;
387 g/L = weighted average VOC content calculated for
all antifoulants; and
1,000 g/kg = conversion factor for g to kg.
The total amount of solvent used for each of the model yards
including the breakdown of usage between- thinning and cleaning,
was based on information obtained from the Section 114 responses
(the data base). In developing these emission estimates, the VOC
content associated with all cleaning and thinning solvents is
assumed to be 839 g/L (7.0 Ib/gal). The VOC emissions estimated
for the thinning solvent category are the product of the average
total solvent usages, the percent solvent used for thinning, and
the weighted average VOC content for all solvents. For example,
the VOC emissions in metric units resulting from thinner usage
estimated for extra-small construction model yards are calculated
to be:
14,415 L/yrQX.^X 839 g/L = 6/OOQ kg/yr (rounded)
where:
14,415 L/yr = average total annual solvent usage for extra
small construction model yards;
0.50 = percent solvent used at extra small model yards
for thinning;
839 g/L = assumed VOC content for all solvents; and
1,000 g/kg = conversion factor for g to kg.
B-7
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Emissions from cleaning were assumed to be at least 35
percent by volume of all cleaning solvents used. Therefore, as
an example, cleaning solvent VOC emissions (metric units) in
Table 4-5 for extra small construction model yards were
calculated to be: .
0.35xl4,415L/yrx0.50x839g/L = 2 1(JO k / {rounded)
1,000 g/kg
where:
0.35 = assumed emission rate from cleaning solvent
usage;
14,415 L/yr = average total annual solvent usage for extra
small construction model yards;
0.50 = percent solvent used for cleaning at extra
small construction model yards;
839 g/L = assumed VOC content for all solvents;
1,000 g/kg = conversion factor for g to kg.
The VOC emissions associated with the other coating/solvent
categories for extra small construction model yards were
estimated. The overall VOC emissions from extra small
construction model yards are the total for all the categories
under that model yard class. Similar calculations provided
parameters for the other seven model shipyards.
No data were available to estimate PM-10 emissions
associated with abrasive blasting operations at model yards.
REFERENCES FOR APPENDIX B
1. Memorandum from deOlloqui, V., Midwest Research Institute
(MRI), to Project File. Facilities in the Shipbuilding and
Ship Repair Data Base. November 11, 1992.
2. Memorandum from deOlloqui, V., MRI, to Project File. List
of Coating Manufacturers Surveyed. November 16, 1992.
3. Memorandum from Williamson, M., MRI, to Project File. List
of Shipyard Site Visits. March 18, 1993.
B-8
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APPENDIX C.
COST ANALYSIS
-------
APPENDIX C.
COST ANALYSIS
Appendix C is a compilation of the background information
and methodology used to develop Chapter 5, Costs and
Environmental and Energy Impacts. The development of coating
parameters is discussed in Section C.I, "and calculations of
emission reductions and costs associated with the use of
lower-VOC coatings are described in Section C.2. The development
of inputs for the spray booth analysis is described in
Section C.3, and the tank analysis is described in Section C.4.
The estimation of energy and environmental impacts is discussed
in Section C.5.
C.I COATING PARAMETER DEVELOPMENT
The Section 114 responses received from the shipyards and
coating manufacturers were the primary sources of coating
information.1'2 Based on this information, three primary
major-use coating categories were identified: "general use",
inorganic zinc, and antifoulant coatings. The last two
categories each account for at about 10 percent of total coating
use in the industry, and all three account for close to
90 percent of the total coatings in the project's data base. A
variety of specialty coating categories account for the balance
of coatings used in the industry. For simplicity, and because of
resource limitations, the analysis was limited to the major-use
coating categories.
The general use coating category was examined initially by
breaking it down by resin type. Alkyd and epoxy resin coatings
C-l
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were broken out. However, the coating characteristics and
intended use of coatings within a single resin type, such as
epoxy, vary considerably. Due to these difficulties, these
coatings were later combined into a single category referred to
as general use coatings. The general use coating parameters were
calculated using alkyd and epoxy information contained in the
data base. The development of the coating parameters for alkyds
and epoxies individually is discussed in this appendix, as well
as that of the combined general use category.
C.I.I Solids (Nonvolatile matter) Content
As discussed in Section 5.1.2, the solids contents of the
coatings were generally estimated assuming that a coating is
comprised of solids and volatile organic-compounds (VOC) . That
is, the solids content of a coating was calculated by assuming
that everything in the coating that is not VOC is solids. An
example calculation used to aid in comparing paint costs is:
Solids (gallon [gal] ) + VOC (gal) = coating volume (gal)
Assuming 1 gal of coating:
Solids (gal) = (1 gal coating) - VOC (gal)
Divide by total gallons of coating
Solids (gal) = ± VOC (gal)
• 1 gal coating gal coating
Solids (% by volume) = [l - V9C (gal) 1 x 1QQ
1 \ gal coat ing J
Solids (% by volume) = [l - VOC content of coating (Ib VOC/gal coating) 1 Q0
* [ density of solvent (Ib VOC/gal VOC) j
Assuming the density of the VOC is 7.0 Ib/gal, and that the
VOC content of an example coating is 4.0 Ib VOC/gal.
C-2
-------
Solids (% volume) = fl - *-°U>vac x 1 gal VOC ] x 10Q
[ gal coating 7.0 Ib VOCJ
Solids (% volume) = [1 - .57] x 100 = 43 percent
The solids content of several high-usage alkyds and inorganic
zincs were not estimated in the manner described above;
manufacturer's data on solid content was used.
C.I.2 Other Coating Parameters
The weighted average VOC content and price of the three
primary coating categories were calculated for the baseline and
lower-VOC options (see Section 5.1.1). The VOC content of all
the coatings in the shipyard data base was provided by the
shipyards and/or the coating suppliers.1'2 The price of most but
not all of the coatings was also provided by the shipyards. The
weighted average VOC content at baseline for each of the primary
coating categories was calculated by multiplying the VOC content
of each coating by its corresponding usage (gallons adjusted for
any water or 'exempt' compounds), summing this product, and
dividing by the total coating usage. To calculate the weighted
average VOC content for the lower-VOC options, coatings with a
VOC content exceeding the VOC limits (Table 1.1) were each
assigned values corresponding to the appropriate paint category
limit. VOC content of coatings that were already at or below the
limits were not modified. The weighted average VOC contents for
the lower-VOC scenarios were then calculated in the same manner
as described for the baseline using actual usage values for each
coating. This resulted in one average value.
The weighted average price of the baseline and lower-VOC
coatings were calculated in a similar manner. However, because
prices were not provided for all coatings, those coatings without
prices were first eliminated from the data base (only for the
calculation of weighted average price). For the lower-VOC
options, the weighted average price of existing coatings with VOC
contents equal to or less than the limit was calculated, and this
C-3
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price was used for all lower-VOC coatings. Using these revised
prices, a weighted average lower-VOC price was calculated for
each of the primary coating categories.
C.I.3 Solvent Usage
•-
Solvent is used in'shipyards for two primary uses--cleaning
and thinning. For the lower-VOC cost analysis, only the portion
of total solvent that is used for thinning was necessary. The
amount of thinning solvent used at each of the model yards was
calculated based on information in the shipyard data base. Based
on total coating usage and the type of work performed
(construction versus repair), each of the shipyards in the data
base was put into a model yard category. The total solvent usage
and thinning solvent usage were calculated for each of the
plants, and average usages were developed for each of the model
plant categories.
C.2 LOWER-VOC EMISSION REDUCTIONS AND COSTS
Based on the coating parameters corresponding to the
baseline and lower-VOC levels as discussed in Section C.I, the
VOC emission reduction and costs associated with the use of
lower-VOC coatings were estimated for each of the model yards.
In addition, the cost of recordkeeping and reporting associated
with rules based on lower-VOC cpatings was estimated.
Section C.2.1 discusses emission reduction estimates,
Section C.2.2 discusses costs associated with lower-VOC coatings,
and Section C.2.3 discusses recordkeeping and reporting costs.
C.2.1 Emissions Reductions
As presented in Section 5.1.2, three lower-VOC scenarios
were considered. Scenario 1 assumes that thinner solvent usage,
as a percentage of total coating usage, is constant, and that in-
line heaters are not required. Scenario 2 uses in-line paint
heaters in lieu of thinning solvent. Scenario 3 uses paint
heaters in conjunction with constant thinning solvent usage.
The reduction in VOC emissions is attributable to two
factors: (1) reduced total coating usage (gallons) due to
increased solids contents and (2) corresponding decreased thinner
C-4
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usage. The only differences between Scenarios 1, 2, and 3
involve in-line paint heaters and thinning solvent. Therefore,
the VOC emissions from the coating for all three scenarios is the
same. Although the combination of thinner and heaters would
result in lower viscosity of the coating than either alone. The
VOC emissions resulting from the use of thinning solvent were
calculated based on the average VOC content of thinning solvent
and the amount of thinning solvent used at each model yard.
Scenarios 1 and 3 assume that the amount of thinning solvent
required is a function of the total coating usage. Therefore,
the thinning solvent usage for Scenarios 1 and 3 was calculated
based on lower-VOC coating usage, assuming the percent thinning
remains constant. For Scenario 2, it was assumed that all
thinning solvent usage associated with the three major-use
coating categories could be eliminated by using in-line paint
heaters. Therefore, the thinning solvent emissions from these
coating categories for Scenario 2 are zero.
C.2.2 Cost of Using Lower-VOC Coatings
The costs associated with using lower-VOC coatings include
the cost of the coatings and thinning solvent and the cost of any
auxiliary equipment that may be used, such as in-line paint
heaters. The lower-VOC coating and thinning solvent usages were
calculated as described above; the associated costs were
calculated by multiplying the usages by the average costs of the
coatings and thinning solvent.
The annualized cost of in-line paint heaters includes the
capital recovery cost, indirect costs, maintenance costs, and the
cost of electricity to operate the guns. These costs are
summarized in Table C-l. First, the number of in-line paint
heaters had to be calculated. The number of heaters was assumed
to be a function of the number of painters. Therefore, the
number of painters at each model yard was estimated. Based on
the shipyard survey responses, a relationship between total
coating usage and the number of workers involved in painting
operations was developed. The information concerning the number
C-5
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of painters contained in the Navy responses could not be used
with confidence due to the wording of the relevant questions and
the lack of information concerning the use of subcontractors. A
regression analysis was performed to develop a relationship
between coating usage and the number of workers involved in
painting at all non-Navy yards in the data base. The regression
equation (which calculates the number of workers) developed is as
follows:
34.396 + 1.4852* [ (total paint + thinner usage, gal)/1000]
Using the above formula, the total number of workers involved in
painting was estimated for each model yard. A second assumption
was made in estimating the number of painters actually painting
(that would be using a paint gun and heater). For approximately
every three workers actually spraying, there is a helper on the
ground mixing paint, hooking up lines to full containers, etc.
Therefore, it was estimated that 75 percent of the workers
involved in painting operations are actually painting (referred
to as painters). It was assumed that each painter would need one
in-line paint heater. To account for the need for some backup
heaters, it was assumed that a backup inventory of heaters equal
to 3 percent of the number of painters would be maintained at
each yard. Two in-line paint heater manufacturers (Sinks and
Graco) were contacted for the capital and operating costs
associated with the heaters. Based on'the information provided,
a capital cost of $1,100 per in-line heater was assumed, as well
as a 5 year life. /4 In calculating the capital recovery of the
cost of the heaters, an interest rate of 10 percent was assumed.
Based on the OAQPS Cost Manual, it was assumed that annual
maintenance and indirect costs would both be 4 percent of the
capital cost of the heaters.5 Based on the vendor information,
the electrical requirements of the heaters was estimated as
2.3 kilowatts.3'4 For costing purposes, it was assumed that the
in-line heaters would operate 8 hours per day, 365 days per year.
C-7
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Based on information gathered from the Monthly Energy Review, the
cost of electricity was assumed to be $0.047/kilowatt-hour.6
C.2.3 Recordkeepincr and Reporting Costs
Recordkeeping and reporting costs have been estimated for
baseline, maximum limits (options 1, 2,.and 4), and average
limits (option 3). (See Section 5.1.1 for a discussion of the
control options.) In this analysis, no differentiation is made
among the compliance scenarios introduced in Section 5.1.2
because there is no difference in the paints that are used under
these scenarios. In addition, because there is no indication
that recordkeeping and reporting would differ for construction
yards versus repair yards, recordkeeping and reporting costs were
estimated based only on the size of the ^shipyard.
The two major cost components for recordkeeping and
reporting in this industry are labor and equipment. Labor costs
are discussed below in Section C.2.3.1, followed by a discussion
of equipment costs in Section C.2.3.2.
C.2.3.1 Labor hours and costs. The estimated labor hours
and costs for baseline, maximum limits, and average limits are
discussed below.
Baseline. Baseline recordkeeping and reporting is defined
as that which is required of shipyards that are located in areas
without marine coating regulations. At baseline, it is assumed
that the large and medium model shipyards are required to prepare
annual emission reports to comply with permit conditions and with
section 313 of the Superfund Amendments and Reauthorization Act
of 1986 (SARA 313). The small and extra small model shipyards
are assumed to be below the cutoff for such reporting
requirements.
Based on information from two large shipyards, it is assumed
that large and medium yards typically track paint and solvent use
through inventory records that are kept as a matter of course for
business purposes.7"^ The inventory records are electronically
coupled with data on the VOC content (for permit reporting
C-8
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requirements) and toxics content (for SARA 313 reports) of the
individual paints and solvents.
Baseline technical labor for tracking paint and solvent use
at large and medium yards is estimated at 75 hours per year
(hr/yr) in excess of the labor necessary for normal business'
inventory procedures, based on 50 weeks (wk) per yr and
1.5 hr/wk. (The 1.5 hr/wk is a standardized factor for "records
of all measurements and information required" from the Emission
Standards Division (BSD) Regulatory Procedures Manual. } An
additional 40 hr/yr is estimated for entering data on the VOC
content of new paints into the paint data base. Preparation of
the annual VOC emission report is also estimated at 40 hr/yr.
Finally, refresher training on proper tracking procedures is
estimated to total 4 hr/yr for two employees. Based on these
labor requirements, the total baseline technical labor for
recordkeeping and reporting at the large and medium model plants
is estimated at 159 hr/yr. For the small and extra small model
plants, where it is assumed that no reporting is required, the
baseline technical labor for recordkeeping and reporting is
estimated to be 0 hr/yr.
As presented in Chapter 5, the cost of baseline
recordkeeping and reporting was calculated using factors from the
BSD Regulatory Procedures Manual (see Table 5-10). Unless
otherwise determined, management and clerical labor hours are
assumed to be 5 percent and 10 percent of technical hours,
respectively. Technical labor, including fringe benefits and
overhead, is charged at a rate of $33/hr, management labor is
$49/hr, and clerical labor is $15/hr.1:L Using these factors, the
baseline recordkeeping and reporting cost for large and medium
model yards is calculated as follows:
159 hr/yr x [$33/hr +(0.05 x $49/hr)+(0.1 x $15/hi)] = $5,875/yr
Maximum limits. Table C-2 presents a spreadsheet developed
to calculate the technical labor hours and costs for the
reporting and recordkeeping required under a maximum VOC limit on
C-9
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-------
marine coatings (options 1, 2, and 4). Table C-3 repeats the
spreadsheet with all calculated values inserted. The values used
in the spreadsheet were derived primarily from information
received from shipyards and the BSD Regulatory Procedures Manual.
Additional information on the spreadsheet can be found in
Reference 12.
This methodology assumes that the amount of each paint and
thinner that is used must be recorded on a daily basis in
sufficient detail that a compliance determination can be made for
each day. Each painting area at the shipyard is assumed to have
a paint and thinner storage area from which paint and thinner are
issued; the employees who oversee the storage areas record the
required information for each painting shift. (A painting shift
is defined as a work shift during which painting is performed at
a single painting area. Thus, for each work shift that a
shipyard operates, the number of painting shifts can be less than
or equal to the number of painting areas at the yard.) The daily
records are compiled periodically, and quarterly reports must be
prepared. Initial training is required for the recordkeepers in
the first year of implementation, and refresher training is
required in subsequent years. Because of this variation in
training costs, the total technical labor hr/yr were calculated
for the initial year and subsequent years, and the average for
the first three years was calculated, as well.
Based on the estimated total technical labor hr/yr, the
associated costs for each model plant were calculated as
presented above for the baseline cost calculations. Estimated
average costs for the first 3 years range from about $5,400/yr
for the extra small model plant to about $47,000/yr for the large
model plant.
Average limits. For an average VOC limit on marine coatings
(option 3), recordkeeping and reporting were estimated to require
twice as much labor as maximum limits. Because there are no
cases where average limits are applied to an entire shipyard,
C-ll
-------
TABLE C-3. ESTIMATED RECORDKEEPING AND REPORTING LABOR AND
COST FOR MAXIMUM LIMITS-CALCULATED VALUES
Cost
Component
Paint usage (gal/yr)
Operating schedule (wk/yr)
Operating schedule (day/wk)
Total facility shifts/day
Painting areas
Painting shifts/day (pt shift/day)
Field records (hr/wk/pt shift)
Compiling field data (hr/wk)
Total recordkeeping (hr/wk)
Reports per year
Hours per report
Initial 1-timetraining(hr/yr)
Refresher training (hr/yr)
Total R&R, 1 st year (hr)
Total R&R, later years (hr/yr)
Average R&R over 3 yr (hr/yr)
Cost for R&R, 1 st year ($)
Cost for R&R, later years ($/yr)
Avg cost for R&R over 3 years ($/yr)
Large
128,000
50
6
3
10
10
1.5
8
23
4
16
60
40
1,314
1,254
1,274
48,552
46,335
47,074
Medium
39,000
50
6
3
3
3
1.5
6
10.5
4
16
18
12
619
601
607
22,872
22,207
22,429
Small
19,000
50
5
1
2
2
1.5
2.5
5.5
4
16
12
8
359
347
351
13,265
12,822
12,969
Extra
Small
8,000
50
5
1
1
1
1.5
0
1.5
4
16
6
4
149
143
145
5,506
5,284
5,358
C-12
-------
this estimate was based on information from a shipyard that
operates a spraybooth under an average limit.13 This estimate is
believed to be reasonable considering the advance planning, daily
tracking, and frequent rescheduling of work that^ would be
required to meet this type of limit.
The estimated total technical labor hr/yr and associated
costs for recordkeeping and reporting at each model shipyard
under an average limit are presented in Table C-4. These
estimates are simply double the estimated levels for maximum
limits. Accordingly, estimated average costs for the first 3 yr
range from about $10,700/yr for the extra small model plant to
about $94,100 for the large model plant.
C.2.3.2 Equipment costs. The equipment needed for
recordkeeping and reporting consists of computer hardware and
software for compiling the records and manipulating the data to
generate reports. Information on equipment used for
recordkeeping and reporting in this industry came from two
shipyards, a large shipyard subject to baseline requirements and
a medium shipyard subject to a maximum VOC limit.7'14 The data
received from these two yards and the analysis performed to
determine annual costs are summarized in Table C-5. The average
annual equipment cost for the yards is about $1,400.
As discussed previously, it is assumed that large and medium
yards are subject to annual reporting requirements at baseline,
while small and extra small yards are not. Accordingly, the
large and medium model yards were assigned baseline equipment
costs of $l,400/yr, while small and extra small model yards incur
no such costs.
Under a maximum limit, all yards are subject to daily
recordkeeping and quarterly reporting. For this analysis it is
assumed that the baseline equipment costs also apply under
maximum limits. For large and medium yards, it is assumed that
the baseline equipment remains adequate. This assumption is
supported by the fact that one of the yards that supplied
information on equipment is already subject to maximum limits.14
C-13
-------
TABLE C-4. ESTIMATED RECORDKEEPING AND REPORTING LABOR AND
COST FOR AVERAGE LIMITS
Parameter
Total R&R, 1st year (hr)
Total R&R, later years (hr/yr)
Average R&R over 3 yr (hr/yr)
Cost for R&R, 1st year ($)
Cost for R&R, later years ($/yr)
Avg cost for R&R over 3 years ($/yr)
Large .
2,628
2,508
2,548
97,105
92,671
94,149
Medium
1,238
1,202
1,214
45,744
44,414
44,857
Small
718
694
702
26,530
25,643
25,939
Extra
Small
298
286
290
11,011
10,568
10,716
C-14
-------
TABLE C-5. SUMMARY OF DATA ON EQUIPMENT COSTS
Cost
Component
Capital Costs
Hardware
Software
Base price
Customizing (a)
TOTAL
Annual Costs
Annualized capital costs (b)
Annual software maintenance
TOTAL
NORSHIPCO
—
$4,000
$4,000
>»
$1 ,055
$600
$1 ,655
NASSCO
$2,600
$500
$1,320
$4,420
$1,166
$1,166
AVERAGE
ANNUAL
COST
$1,411
(a) NASSCO software customizing: 40 hr x $33/hr (technical labor rate,
including fringes and overhead)
(b) Total captital costs x 0.2638 (capital recovery factor based on
a 10-percent interest rate and 5-year useful life)
C-15
-------
For small and extra small yards, it is assumed that the
operations are simple enough that recordkeeping and reporting can
be carried out manually. These smaller shipyards typically
occupy a certain niche in the industry and generally do not use a
wide range of different coatings.
For average limits, it is assumed that all yards must have
computer equipment because of the complexity of planning,
tracking, and demonstrating compliance. The baseline equipment
is expected to be adequate for this purpose for all yards.
Accordingly, equal equipment costs of $l,400/yr were assigned to
all the model yards.
C.3 SPRAY BOOTH ANALYSIS
The use of add-on controls to reduce VOC emissions from
spray booth coating operations was evaluated. The results of the
analysis are presented in Chapter 5.2. The development of
estimated spray booth flowrates and the VOC emissions from spray
booths is discussed in Section C.3.1. The estimation of costs is
discussed in Section C.3.2.
C.3.1 Estimated Flowrates and Spray Booth Emissions
In order to evaluate the cost effectiveness of using add-on
controls on spray booths, the total VOC emissions resulting from
spray booth coating operations, as well as the total flowrate
that would be sent to the control device, had to be estimated.
The total exhaust flowrate from the spray booths was estimated by-
examination of spray booth information provided in the shipyard
surveys. One yard had a very low flowrate for the amount of
coatings applied in booths; this outlier was eliminated from the
analysis. A regression analysis was performed to obtain a
relationship between total spray booth coating usage and total
spray booth exhaust air flowrate. Three separate regression
analyses were performed: just repair yards, just construction
yards, and repair and construction yards combined. The equation
based on repair and construction yards combined was used to
predict the exhaust flowrates from the model yards because this
equation showed the best correlation between coating usage and
C-16
-------
flow rate. The regression equation (which calculates the total
spray booth exhaust flowrate) is as follows:
82,126.78 + 8.30*(spray booth coating usage, gal)
As discussed in Chapter 5, in addition to the predicted
flowrates calculated using the regression equation, minimum
expected flowrates for each of the model yards were calculated by
comparing predicted and actual flowrates. This comparison was
made for each of the yards that supplied complete spray booth
information. Each of the actual yards was placed into a model
yard category, and the ratios of the actual to the predicted
flowrates of all yards in each of the categories were examined.
For example, the ratios of predicted to actual flowrates for the
three yards that fell into the small construction model yard
category were 0.36, 2.58, and 0.18. The flowrate calculated
using the regression equation was then multiplied by the smallest
of the ratios in a model yard category (in this case, 0.18) to
estimate the minimum expected flowrate.
The VOC emissions resulting from spray booth operations at
each of the model yards were estimated based on the amount of
coatings (and thinner) sprayed in booths and the average VOC
content of the coatings. Because information concerning exactly
which coatings were applied in each spray booth was not
available, booth emissions were estimated using an average VOC
content of 3.29 Ib VOC/gal (minus water and exempt solvents) for
the coatings, and 7.0 Ib VOC/gal for the thinner.
To estimate the costs of using thermal incineration to
control spray booth VOC emissions, the methodology described in
the OAQPS Cost Manual was used.5 Costs were developed for the
two flowrates calculated for each model yard (that calculated
using the regression equation and the minimum expected flowrate).
C-17
-------
C.3.2 Thermal Incineration Systems Cost
Recuperative and regenerative thermal incinerators were
evaluated, as discussed in Chapter 5. The spreadsheets used to
estimate costs for recuperative and regenerative thermal
incinerators were very similar; the spreadsheet for regenerative
thermal incinerators is presented in Table C-6.
The spreadsheet and some assumptions were based on information
developed as part of the Wood Furniture project. Therefore,
references to information obtained as part of the Wood Furniture
project are made in the following text.
C.3.2.1 Thermal Incinerator Inputs. The information
necessary to calculate thermal incinerator costs for any given
situation is listed under "Parameters" iii the spreadsheet. This
data is also listed below:
1. Volumetric Flow Rate, standard cubic feet per minute
(scfm)
2. Waste Gas VOC Concentration, parts per million by
volume (ppmv)
3. Heating Value of VOC's, British thermal units/scf
(Btu/scf)
4. Energy Recovery (percent)
5. Incinerator Operating Temperature, degrees Fahrenheit
(°F)
6. Incinerator Operating Temperature during Idle (°F)
7. Waste Gas Temperature (°F)
8. Molecular Weight of VOC (Ib/lb-mole)
9. Finishing hours per shift
10. Number of shifts per day
11. Number of operating days per year
12. Number of hours idled per day
13. Warm-up period (hours)
14. Pressure drop across the control device and heat
recovery unit (inches of water)
The heating value and molecular weight of the VOC's were
calculated assuming the VOC's were xylene because xylene is the
C-18
-------
PARAMETERS:
1. VOLUMETRIC FLOW RATE, (SCFM): 369,200
2. WASTE GAS VOC CONCENTRATION (PPMV): • 100
3. HEATING VALUE OF VOCS (BTU/SCF): 4,980
4. ENERGY RECOVERY (%): 95
5. INCINERATOR OPERATING TEMPERATURE (F): 1,500
6. INCIN. OPERATING TEMP. DURING IDLE (F): 1,100
7. WASTE GAS TEMPERATURE (F): 77
8. MOL WEIGHT OF VOC: 106
9. MOL WEIGHT OF GAS: 29.0077
10. FINISHING HOURS/SHIFT: 8
11. SHIFTS/DAY: 1
12. DAYS/YR: 200
13. IDLING HOURS/DAY 15
14. FLOWRATE WHILE IDLING (SCFM): 55,380
13. WARM-UP PERIOD (HOURS) 1
14. PRESSURE DROP (INCHES OF WATER) 29
STEP 1: CALCULATE TOTAL WASTE GAS FLOW
O2 CONTENT OF WASTE G AS (% VOL): 21.0
DILUTION AIR REQUIRED FOR COMBUSTION (SCFM): 0
DILUTION AIR FOR SAFETY 0.0
TOTAL GAS FLOW RATE (SCFM): 369,200
STEP 2: HEAT CONTENT OF WASTE GAS (BTU/SCF):
STEP 3: CALCULATE GAS TEMP EXIT PREHEATER :
STEP 4: CALCULATE PREHEATER EXIT TEMP.
WHILE IDLING
STEP 5: CALC AUXILIARY FUEL REQ'D (SCFM):
DURING FINISHING
STEP 6: CALCULATE TOTAL GAS FLOW (SCFM):
DURING FINISHING
STEP 7. CALCULATE WARM-UP AUX FUEL REQ. (SCFM):
STEP 8. CALC. WARM-UP TOTAL GAS FLOW (SCFM):
STEP 9. CALC. AUX. GAS FLOW DURING IDLE (SCFM):
STEP 10. CALC. TOTAL GAS FLOW DURING IDLE (SCFM):
STEP 11. CALC. ANNUAL NATURAL GAS FLOW (SCFY):
0.50
1,429
1,049
1,540
370,740
1,749
370,949
188
55,568
202,582,081 ASSUMING 8 HR/DAY FINISHING,
15 HR/DAY IDLE, 1 HOUR WARMUP
Table C-6. Spreadsheet for Regenerative Thermal Incinerators
C-19
-------
CAPITAL COST CALCULATIONS
DIRECT COSTS
EQUIPMENT COST (REGENERATIVE INCIN) ($): 5,153,869
AUXILIARY EQUIPMENT (DUCTWORK,STACK) ($): 257,693
AUXILIARY COLLECTION FAN: 121,104
INSTRUMENTATION ($): 553,267
SALES TAX (S): 165.980
FREIGHT ($): 276,633
TOTAL PURCHASED EQUIP (TPE^ COST ($): 6,528,546
DIRECT INSTALLATION COSTS (S): 1,958,564
INDIRECT COSTS (S): 2,023,849
TOTAL CAP INVESTMENT (TCI) (S):
ANNUALIZED COST CALCULATIONS
OPERATING LABOR
OPERATOR: (.5 HR/SHIFT. S12.48/HR)
SUPERVISOR: (15 % OF OPERATOR)
MAINTENANCE: (.5 HR/SHIFT. S13.73/HR)
MATERIAL: (100% OFMAINT. LABOR)
UTILITIES:
NATURAL GAS DURING FINISHING: 487,838
NATURAL GAS DURING IDLING: 111,424
NATURAL GAS DURING WARM-UP: 69,259
ELECTRICITY: 221,685
BTU - NATURAL GAS 1.81 E +11
BTU - ELECTRICITY 1.61E-HO
BTU-TOTAL: 1.97E + 11
TOTAL DIRECT ANNUAL COST. 902,749
INDIRECT ANNUAL COSTS
OVERHEAD : (60% OF LABOR + MATERIALS) 7,526
ADMINISTRATIVE: (2%*TCI) 210,219
PROP TAX: (1%'TCI) 105,110
INSURANCE: (1%*TCI) 105,110
CAP ITAL RECOVERY 1,710,659
TOTAL 3.041,373
1ST QUARTER 1992 $
(ASSUMED 5% OF EQUIP. COST)
(ASSUMED 30% OFTPE)
(ASSUMED 31% OFTPE)
10.510,959 (IFFLOW<20,OOOCFM, TCI = 1.25'TPE)
3,744
562
4,119
4.119
($3.3/1 OOOSCF)
($3.3/1 OOOSCF)
($3.3/1000SCF)
($.047/KWH)
(ASSUMING 10YRS, 10 %)
Table C-6. (Continued)
C-20
-------
main VOC in many marine coatings. The molecular weight of xylene
is 0.23 Ib/lb-mole. The heating value (heat of combustion) of
xylene is 4,980 Btu/scf.15
The pressure drop across the combined control device/heat
recovery unit for the thermal recuperative incinerator was
calculated based on information in the OAQPS cost manual.5 The
pressure drop for the regenerative thermal incinerator was
calculated based on the electricity requirements provided by the
vendors contacted for the wood furniture CTG project (assuming
all electricity is used by the fan) . 16-27
There are also two fields in the "Parameters" section that
calculate parameters based on other input information. They are:
Molecular weight (MW) of gas. This value is calculated from
the VOC concentration (cone) and the molecular weight of the VOC
in the following way:
MWgas _ [ voc conc
-------
TABLE C-7. CAPITAL COST FACTORS FOI
AND CATALYTIC INCINERATORS.-
THERMAL
Cost item
Direct costs
Purchased equipment costs
Incinerator (EC) + auxiliary equipment3
Ductwork
Instrumentation*3
Sales taxes
Freight
Purchased equipment cost, PEC
Direct installation costs
Foundations and supports
Handling and erection
Electrical
Piping
Insulation for ductwork
Painting
Direct installation cost
TOTAL DIRECT COST, DC
Indirect costs (installation)
Engineering
Construction and field expenses
Contractor fees
Start-up
Performance test
Contingencies
Total indirect cost, 1C
TOTAL CAPITAL INVESTMENT = TCI = DC + 1C
Factor
As estimated, A
0.05 A
0.10 A
0.03 A
0.05 A
B = 1.23 A
0.08 B
0.14 B
0.04 B
0.02 B
0.01 B
0.01 B
0.30 B
1.30 B
0.10 B
0.05 B
0.10 B
0.02 B
0.01 B
0.03 B
0.31 B
1.61 B
aDuctwork internal to the unit and any other equipment
normally not included with unit furnished by incinerator
vendor.
"Instrumentation and controls often furnished with the
incinerator, and thus often included in the EC.
C-22
-------
TABLE C-8.
GENERAL ANNUAL COST ASSUMPTIONS FOR
ADD-ON CONTROLS
Annual operating hours:
Operating labor rate, $/hr
Operator labor required, hr/8-hr shift
Supervisor cost, percent of operating labor
Maintenance labor rate, $/hr
Maintenance labor required, hr/8 hr shift
Annual maintenance materials
Utilities
Natural gas, $/ 1,000 scf
Electricity, $/l,000 kWh
Overhead, percent of operation and
maintenance
Administrative charges
Property taxes
Insurance
Capital recovery
2,000
12.48a
0.5, or as specified by vendor
15b
13.73a b
0.5, or as specified by vendor
100 percent of maintenance labor, or as specified by vendor
3.3C
47.0°
60b
2 percent TCIb d
1 percent TCIb d
1 percent TCI° "
CRF (TCI)b d e
Reference 29.
Reference 5.
cReference 6.
dTCI = Total capital investment.
eCRF = Capital recovery factor assuming 10 percent interest.
C-23
-------
(1 - VOC conc/1 x 106) * 0.21 * 100
This equation assumes that the waste gas is composed of air
and VOC's.
b. Dilution air required for combustion (scfm) :
The OAQPS Cost Manual states that there must be at least
20 percent $2 ^n tne waste gas for combustion to occur
(p. 3-24) .5 For all of our situations, there will always be at
least 20 percent 02, because our waste gas streams are so dilute.
However, in a situation where the waste gas VOC content might be
on the order of 100,000 ppmv (10 percent by vol), for example,
the actual 02 content of the waste gas would be 18.9 percent by
volume. For a 1,000 scfm stream, the required additional
combustion air is calculated to be 985 s>2fm. This corresponds to
an 02 content of the waste gas (percent by volume) of:
(0.21)085 scfm) ( lbmQl ) + (.189X1,000 scfm) (1 lbm°h
392 ft3392 ft3
(1>000 + 985)
0.528 Ibmol 02 + 0.4821
_ =20 percent
5.06
Dilution air required for safety. According to the OAQPS
Cost Manual, p. 3-26, safety codes require that the maximum VOC
concentration in the waste gas stream not exceed 25 percent of
the lower explosive limit (LEL) of the organic compound when a
preheater is used. We conservatively assumed that the maximum
allowable VOC concentration in the booth would be 10 percent of
the LEL because the booths are manned. The LEL for xylene is
11,000 ppm.
A maximum allowable concentration of 10 percent of the LEL
corresponds to 11,000 * 0.10 = 1,100 ppmv.
In certain situations, additional air may need to be added
to the waste gas to dilute the waste gas VOC concentration to
1,100 ppmv. The cell formula is:
@ IF (Cone * Flow)/(Flow + Combustion air) < 1,100, 0,
C-24
-------
(Flow * Cone - 1,100 * Flow - 1,100 * F24)/l,100)
Dilution air for safety was not needed for any of the
scenarios evaluated.
Calculate total gas flow. This field calculates the total
amount of gas flowing into the incinerator. The total gas is
composed of:
Input flow (waste gas) + dilution air for combustion +
dilution air for safety
Step 2: Calculate Heat Content of the Waste Gas
The formula for this field is:
voc
_ * * 10 ,— * [Initial Flowrate] * VOC heat content (Btu/scf) = Btu/scf
Total Gas Flow
This information is used in calculating the amount of
auxiliary fuel required.
Step 3: Calculate Gas Temperature Exit Preheater
As stated in the OAQPS Cost Manual, the preheater
temperature is related to the fractional energy recovery and the
incinerator operating temperature and waste gas inlet temperature
by the following equation:
Energy Recovery
T - T •
•"•wo -"-wi
Tfi - Twi
where: TWQ = Gas preheater exit temperature
TW^ = Waste gas inlet temperature
Tfj_ = Incinerator operating temperature
This equation is manipulated to
Energy Recovery . . _
100 ufi " iwi; + xwi ~ wo
C-25
-------
in the spreadsheet. The same equation is used to calculate the
preheater exit temperature during idle; the incinerator operating
temperature is decreased, however, during idle.
Step 4a: Calculate Auxiliary Fuel Required
Auxiliary fuel use was estimated using the equation
presented on page 3-32 of the OAQPS Cost Manual^. It is:
o r PWO ^ [Cpmair (1'1 Tfi ' Two ' °-1 Tref} ' (" Ahcwo) .
af af = (-Ah) - 1.1 C. (Tf. - Tref)
where :
paf = density of auxiliary fuel (methane) ,
0.0408 lb/ft3 @ 77°F, 1 atm
Qa£ = natural gas flowrate, scfm
pwo = pwi = density of the waste gas (essentially air) ,
at 77°F, 1 atm (0.0739 Ib/scf)
cpmair = mean heat capacity of air
Assume 0.255 Btu/lb°F (the mean heat capacity of air
between 77 °F and 1375°F)
Tref = Taf = temp, ambient
(Temp, auxiliary fuel) = 77 °F
- Ahrwn » heat content of the waste stream, BTU/lb
- Ahcaf = heat content of natural gas, 886 BTU/scf
caf
51,0
(21,081 BTU/lb)
Step 4b. Calculate Auxiliary Fuel Required During Warm-up
The vendors provided estimates of warm-up periods but did
not provide estimates of fuel use during warmup. Therefore, the
OAQPS cost manual methodology was used to estimate the amount of
auxiliary fuel needed to warm up the incinerator, in the absence
of VOC's (since no process exhaust is directed into the unit
during warm-up). Based on vendor information, a recuperative
thermal incinerator warm-up period of 45 minutes, using
60 percent of the total airflow, was assumed. Also based on
vendor information, the regenerative thermal incinerator warm-up
period was assumed to be 1 hour with full airflow.17'23'28 The
C-26
-------
equation used to calculate the amount of auxiliary fuel required
during warm-up is similar to the one used in Step 4a, except that
the heat content of the waste stream, ~Ahcwo, is assumed zero.
Step 4c. Calculate Auxiliary Fuel Required during Idle
This field applies only to the regenerative thermal
incinerator, and calculates the amount of auxiliary fuel required
while the incinerator is in idle mode. Because the packing
material used in regenerative thermal incinerators takes a long
time to heat, vendors suggested idling the unit while not in use,
rather than shutting it down completely. The unit controls
finishing emissions for 8 hours per day and is warmed up for
1 hour per day; it was assumed to operate in idle mode for the
remaining IS hours per day. Based on vendor information, the
incinerator operating temperature drops gradually to 1100°F
during idle; only 15 percent of the total airflow is used. The
amount of auxiliary fuel require during warm-up is calculated
using Step 4a. However, in this case the temperature during the
idle period is 1100°F, the heat content of the waste stream -
Ahcwo, is assumed 0 and a lower air flow is used. 17/23,28
Step 5: Total Gas Flow=Total Waste Gas Flow + Auxiliary Fuel
The total gas flow during finishing, warm-up, and idle are
calculated using the total waste gas flow plus the corresponding
auxiliary fuel requirements.
The calculated annual auxiliary fuel flow, in standard cubic
feet per year (SCFY), is the amount of natural gas that is
required in the incinerator in a year, considering the weighted
average of the gas flow during finishing, warm-up, and idle.
C.3.2.3 Capital Cost Calculations.
Equipment Costs. Equipment costs were based on pp. 3-44 and
3-45 of the OAQPS Cost Manual).5 Equipment costs for
recuperative incinerators are a function of the total gas flow
through the incinerator. For 70 percent heat recovery, the
equation is:
,0.2500
EC = 21,342 Qj.Qt
C-27
-------
The equipment costs for regenerative thermal incinerators is
an approximately linear function of total flow rate. For
95 percent heat recovery, the equation is:
EC = 2.204 x 105 + 11.55Qtot
For both recuperative and regenerative thermal incinerators,
the equipment cost obtained using the above formulas was
multiplied by Chemical Engineering Equipment cost indices of
(393.7/342.5) to correct equipment costs to first quarter
1991 dollars.30
Auxiliary equipment (ductwork, stack). Based on the OAQPS
Cost Manual, the cost of auxiliary equipment was estimated as
5 percent of the equipment cost.5
Auxiliary collection fan. The auxiliary collection fan was
sized on a minimum gas flowrate of 500 scfm. The equation used
to estimate the fan cost is:
Fan cost ($) = 79.1239*[Total gas flow from Step 1 (d) ]°'5612* (361.8/342 .5)
The above equation is based on the 1988 Richardson Cost
Manual.31
Other capital costs. Instrumentation: 10 percent of
purchased and auxiliary equipment (based on OAQPS Cost Manual).5
Sales tax: 3 percent of purchased and auxiliary equipment
(based on OAQPS Cost Manual).5
Freight: 5 percent of purchased and auxiliary equipment
(based on OAQPS Cost Manual).5
Total purchased equipment cost (TPE) equals sum of the
equipment, ductwork, auxiliary fan costs, instrumentation, tax
and freight.
C.3.2.4 Direct Installation Costs. Direct installation
costs were estimated as 30 percent of the total purchased
equipment (TPE) cost (based on the OAQPS Cost Manual).5
C-28
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Indirect installation cost. Indirect installation costs
were estimated as 31 percent of the TPE cost (based on the OAQPS
Cost Manual).5
When the maximum total gas flow was less than 20,000 scfm,
then the total installation costs (direct and 'indirect) were
calculated as 25 percent of the purchased equipment costs. In
the other cases the direct and indirect installation costs were
determined as described above (based on the OAQPS Cost Manual),5
Total capital investment. Total capital investment (TCI) is
the sum of the total purchased equipment cost, direct
installation costs, and indirect installation costs.
C.3.2.5 Annualized Costs. In calculating annual operating,
maintenance, and supervisory labor costs-, the following equations
were used.
Operator: $12.48/hr x 0.5 hr/shift x shifts/day x
day/year
(Assume 1 shift/day, 365 days/year)
Supervisor: 15 percent of operator
Maintenance: $13.73/hr x 0.5 hr/shift x shifts/day x
day/year
Material: 100 percent of maintenance
The labor rates were based on the U. S. Industrial Outlook 1992
and the OAQPS Cost Manual.5'29
Utilities
Natural gas: Yearly natural gas usage (SCFY) x $3.3
1,000 scf
The yearly natural gas usage is the sum of auxiliary fuel
requirements during finishing, warm-up, and idling (as
applicable). To estimate electricity requirements, the formula
presented on page 3-55 of the OAQPS Cost Manual was used:
Power 1.17 x 10"4 Q. .AP
(fan) = tot
E
C-29
-------
where:
Qtot = maximum gas flow
AP» = pressure drop, inches of 1^0, across the control
device and heat recovery unit. Assumed to be 19
inches H20 for recuperative thermal incinerators
and 29 inches H20 for regenerative thermal
incinerators.
E = fan efficiency (assumed to be 60 percent)
P = power, in kW
Total electricity used during finishing, idle, warmup and
cooldown was calculated using the corresponding flows and
durations, and summed. The cooldown period was assumed equal to
the warmup period with the corresponding flow and no auxiliary-
fuel. To calculate the cost of the electricity, a factor of
$.047/kWh was applied to the total usage.6
Total Direct Annual Costs;
Sum of labor, materials, natural gas, electricity
Indirect:
Overhead: 60 percent of labor and materials
Administrative: 2 percent of TCI
Property Tax: 1 percent TCI
Insurance: 1 percent TCI
Capital Recovery: The cost of capital was annualized by
multiplying the total capital investment by a capital recovery
factor. For this analyses, an interest rate of 10 percent and a
10-year life were assumed, resulting in a capital recovery factor
of 0.1627.
C.4 TANK ADD-ON CONTROL ANALYSIS
The feasibility and cost of using an add-on control device
for tank painting operations was evaluated and is discussed in
Sections 5.3.1 and 5.3.2. The results of the analysis are
presented in Section 5.3.3. The development of assumptions and
inputs to the tank analysis is discussed in Section C.4.I., and
C-30
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the sensitivity of the analysis to key assumptions is discussed
in Section C.4.2.
C.4.1 Assumptions and Inputs to the Analysis
Enclosed tanks are presently vented during both blasting and
painting. During blasting, the tank is vented to protect the
worker and to remove the airborne particulate matter. During
tank painting, the tank is ventilated to protect the worker, to
maintain visibility, and to maintain an acceptable finish.
Because workers are inside the tank, adequate ventilation is
needed to assure their safety. Shipyards indicate that tanks are
ventilated during painting operations to ensure VOC
concentrations do not exceed 10 percent of the lower explosive
limit (LED,32'33 Tanks are vented for^a period of time after
painting to ensure concentrations in all pockets of the tank
remain below 10 percent of the LEL. Ventilation also removes
dried overspray, which reduces visibility for the workers inside
the tank and which can damage the finish.
The required exhaust airflow varies with the size and design
of the tank, the coating used, and the number of painters. There
is a very wide range of sizes of tanks that may be painted at any
shipyard. Even on a single ship, there may be voids that are
3 ft high, 3 ft long, and 3 ft wide, and wing tanks that are
40 ft high, 20 ft long, and 6 ft wide, or larger.
In some construction yards, all tank painting may be done
offsite. Not all repair operations involve tank painting.
Because tank painting is scheduled into the overall construction
or repair operation, tank painting operations may be
intermittent. The number of tanks painted during a repair
operation depends on many factors. Generally, only the most
critical tanks in the worst condition get attention. The cost of
tank painting as well as the effect on the total schedule must be
considered. On a large ship, 20 to 50 tanks may be repainted
during an overhaul. All the tanks may be painted simultaneously,
they may be painted in sequence, or several may be painted at one
C-31
-------
time, and the remainder may not be painted until several days or
even weeks later.
The variability in the number and size of tanks that may be
painted at any one time in a shipyard makes evaluating add-on
controls difficult. For this analysis, it was assumed that a
single, stationary add-on control device would be used to control
tank painting emissions. The maximum airflow that can be sent to
a portable add-on control device is about 2,000 cubic feet
per minute (ft3/min). In many cases, the exhaust from a single
tank may exceed 2,000 ft3/min during tank painting operations.
Due to the space constraints on a ship during construction and
repair operations and the exhaust limitation associated with
portable control devices, it is unlikely that an existing
individual portable add-on control device would be used for each
tank. It may be possible, however, by using innovative
technologies, to use individual control devices for each tank.
Because the size and number of tanks being vented to the
control device may vary with time, add-on controls for a range of
airflows were evaluated. Costs were developed for add-on
controls designed to handle airflows from 2,000 to
80,000 ft3/min. The actual capacity required varies from hour to
hour at any single shipyard.
Thermal incineration with recuperative heat recovery is
considered a technically feasible add-on control alternative for
controlling VOC emissions from tank painting operations. The
intermittent nature of tank painting operations discourages the
use of a regenerative thermal incinerator. For larger airflows
(>50,000 ft3/min), a regenerative thermal incinerator is
preferable to a recuperative thermal incinerator because of the
greater heat recovery. However, because the ceramic packing in a
regenerative thermal incinerator must be brought up to and
maintained at a minimum temperature, it is not suited for
intermittent operations such as tank painting at a shipyard,
according to vendors.28'34
C-32
-------
In theory, catalytic incinerators and carbon adsorption
systems could be used to control VOC emissions from tank painting
operations. Contamination of the catalyst by the blasting
residue and any poisons contained in the coatings would be a
concern. The intermittent operation could significantly decrease
the catalyst life. Because a wide variety of solvents are
contained in the various tank coatings, reuse of the recovered
solvent from a carbon adsorption system is probably not practical
in this application, although the recovered solvent might have
some value as a fuel or as a cleanup solvent. The precise mix of
VOC's that would be present cannot be determined because it would
vary from shipyard to shipyard, depending on what coatings are
used, which varies with the type of ship and tank being painted.
Some tank coatings contain alcohols, which are not effectively
adsorbed onto carbon. Due to the uncertainty of the solvent mix,
the control efficiency of a carbon adsorption system for this
application cannot readily be determined. For purposes of this
analysis, costs were developed only for recuperative thermal
incineration systems. These costs are not expected to be
significantly different from those associated with catalytic
incineration or carbon adsorption systems, if such systems are
feasible for this application.
Assumptions regarding design specifications and operating
conditions had to be made in developing cost estimates. Because
xylene is the primary VOC in marine coatings, the heating value
and LEL corresponding to xylene were used in all calculations.
Based on information obtained from shipyards and Occupational
Safety and Health Administration (OSHA) requirements, the maximum
allowable concentration of VOC's in tank exhaust was assumed to
be 10 percent of the LEL.32'33
The actual number of hours an add-on control system would be
operated would depend on the amount of time spent painting tanks,
which would, in turn, depend on the number of tanks painted and
the rate of painting. Shipyards were not able to provide the
number of hours spent painting tanks on an annual basis. For
C-33
-------
purposes of this analysis, it was assumed that the control device
would be used an average of 6 hours per shift, two shifts per
day. These operating hours include the time during which
painting occurs and the time after painting during which the
tanks are vented for safety. In addition, a daily 45-minute
warmup period was assumed, based on vendor information.17»23,28
In developing control system costs for tank painting, many
potential complications were ignored. As mentioned previously,
designing a control system to control VOC emissions from tank
painting operations would be complex. The cost of engineering
was calculated using the factors in the OAQPS Cost Manual; actual
engineering costs for this complex application would probably be
higher. Standard assumptions regarding"the cost of ductwork were
also made, based on the OAQPS Cost Manual. Due to the extensive
lengths of flexible ductwork required, the actual cost of
ductwork may be significantly higher than that estimated. The
OAQPS costing methodology applies to packaged recuperative
thermal incinerator units. Because of the potentially large
flowrates present at a shipyard, the units would have to be
field-erected instead of packaged, resulting in increased
1 Pi ? R
costs. ° 3 Due to the site-specific nature of such costs, they
have not been included. As a result, costs for control of tank
painting emissions have likely been underestimated for most
facilities.
For purposes of the tank painting add-on control analysis,
it was assumed that 100 percent of the tank painting VOC
emissions are sent to the control device. The recuperative
thermal incinerator was assumed to have a destruction efficiency
of 98 percent.16'25
C.4.2 Sensitivity of the Tank Add-On Analysis to Key
Assumptions. For airflows less than 20,000 ft3/min, the primary
annualized cost is the capital recovery of the control equipment.
For airflows exceeding 20,000 ft3/min, the primary annualized
cost is the cost of fuel to run the incinerator. Fuel costs
represent from 17 to 70 percent of the total annualized costs,
C-34
-------
depending on the combination of operating hours and VOC
concentration assumed.
For costing purposes, an airstream concentration equal to
10 percent of the LEL was assumed. Ten percent of the LEL is the
maximum allowable concentration; actual concentrations are
expected to be less. To explore the impact of lower VOC
concentrations, the increase in fuel usage associated with a VOC
concentration of 5 percent of the LEL (instead of the 10 percent
used in the original analysis) was calculated for airflows of
2,000 ft3/min and 80,000 ft3/min. The fuel cost for the
2,000 ft3/min unit would increase by almost 50 percent if the
actual VOC concentration was only 5 percent of the LEL.
Similarly, the fuel cost for the 80,000 -ft3/min unit would also
increase by almost 50 percent over that associated with a VOC
concentration of 10 percent of the LEL. Because the analysis
assumed a VOC concentration of 10 percent, the annualized fuel
cost may have been underestimated.
Fuel costs are also a function of the total number of
operating hours. As mentioned previously, for purposes of this
analysis it was assumed that the incinerator would operate
12 hours per day, 365 days per year. If tank painting operations
actually occur more than an average of 12 hours per day, then
annual fuel usage costs have been underestimated. On the other
hand, if tank painting occurs less than an average of 12 hours
per day, then fuel usage costs have been overestimated. Total
fuel usage is basically linear with operating hours, so if
operating hours increase by 30 percent, the fuel use would also
increase by 30 percent.
C.5 ENERGY IMPACTS
Energy impacts are described in Chapter 5. This section
provides further information regarding the estimation of energy
impacts.
The air emissions associated with the combustion of natural
gas required for incinerator operation (primary emissions) and
electrical power required for incinerators and heaters (secondary
C-35
-------
emissions) were calculated using the emission factors shown in
Table C-9. The primary emissions were estimated in Tables 5-15a
and 5-15b. As an example, from Table 5-15b, the primary
particulate matter (PM) emissions associated with small model
construction yards were calculated to be:
4.78 * 10
10
yr
5 Ib
106ft3
1,035
Btu
ft3
=2.31 Ib/yr
where:
4.78 x 1010 Btu/yr
5 lb/106 ft3
1,035 Btu/ft3
Natural gas usage at small model
construction yards;
PM emission factor given in
Table C-9; and
Heating value of natural gas.
The secondary air emissions that result from the generation
of the electricity supplied by a coal-fired power plant were
estimated in Tables 5-16 and 5-17. As an example from
Table 5-16, the secondary PM emissions associated with small
model construction yards were calculated to be:
1.17 * 10
1 ton
yr
, 000 lbm
* 0.76
Ib
ton
,38 *
12,600 Btu
'm
=92.9 Ib/yr
where:
1.17 * 109 Btu/yr
1 ton/2,000 Ib.
0.38
m
12,600 Btu/lbm
0.76 Ib/ton
bituminous coal requirement for small
model construction yards;
conversion factor;
thermal efficiency of power plant's
generator;
average heating value of bituminous
coal; and
PM emission factor given in Table C-9
C-36
-------
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C-37
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C.6 REFERENCES FOR APPENDIX C
1. Memorandum. deOlloqui, V., Midwest Research Institute, to
Project File. List of CTG and NESHAP survey responses and
related Trip Reports. November 11, 1992.
2. Memorandum. deOlloqui, V., Midwest Research Institute, to
Project File. List of survey responses received from marine
coating suppliers. November 16, 1992.
3. Telecon. Caldwell, M. J., Midwest Research Institute, with
J. Czajak, Sinks Manufacturing. October 14, 1992. In-line
paint heaters.
4. Telecon. deOlloqui, V., Midwest Research Institute, with
G. Olson, Graco, Inc. October 9, 1992. In-line paint
heaters.
5. U. S. Environmental Protection Ageilcy, OAQPS Control Cost
Manual, Fourth Edition. Research Triangle Park, N.C.
January 1990. EPA 450/3-90-006.
6. U.S. Department of Energy, Energy Information
Administration. Monthly Energy Review. April 1991.
DOE EIA 0035 (91/04).
7. Telecon. Williamson, M., MRI, with Beacham, T., Norfolk
Shipbuilding and Drydock Corporation. June 3, 1993.
Recordkeeping and reporting requirements.
8. Telecon. Edgerton, S., MRI, with Ayres, R. P., Newport News
Shipbuilding. November 9, 1993. Recordkeeping and
reporting requirements.
9. Letter from Ayres, R. P., Newport News Shipbuilding, to
Reeves, D., MRI. November 8, 1993. Information on
recordkeeping and reporting requirements.
10. U. S. Environmental Protection Agency. BSD Regulatory
Procedures Manual. October 1990. Volume X, Section 2.2,
p. 17.
11. U. S. Environmental Protection Agency. BSD Regulatory
Procedures Manual. October 1990. Volume X, Section 2.2,
p. 19.
12. Memorandum from Edgerton, S., MRI, to the project file.
December 10, 1993. Recordkeeping and reporting costs for
the CTG.
C-38
-------
13. Telecon. Williamson, M., MRI, with Austin, D., Southwest
Marine, Inc. June 7, 1993. Recordkeeping and reporting
requirements.
14. Response to. Recordkeeping and Reporting Questionnaire.
National Steel and Shipbuilding Company. June 23, 1993.
15. Perry's Chemical Engineers' Handbook. McGraw-Hill
Publishing Company. 1984. Sixth Edition.
16. Survey response and attachments from Durr Industries, Inc.,
to Wyatt, S., EPA/ESD. June 12, 1991. Response to add-on
control survey.
17. Telecon. Caldwell, M. J., Midwest Research Institute, with
Bhushan, D., Durr Industries, Inc. June 25, 1991.
Clarification of information provided in add-on survey
response.
x*
18. Telecon. Caldwell, M. J., Midwest Research Institute, with
Taylor, R., Durr Industries, Inc. June 27, 1991.
Clarification of information provided in add-on survey
response.
19. Telecon. Caldwell, M. J., Midwest Research Institute, with
Taylor, R., Durr Industries, Inc. August 8, 1991.
Regenerative incinerator idling and recirculating spray
booths.
20. Survey response and attachments from ABB Flakt Alpha, to
Wyatt, S., EPA/ESD. May 21, 1991. Voluntary response to
add-on control survey obtained from Nucon, International.
21. Telecon. Caldwell, M.J., Midwest Research Institute, with
Blocki, S., ABB Flakt Alpha. June 5, 1991. Clarification
of information provided in add-on survey response.
22. Survey response and attachments from Smith Engineering
Company, to Wyatt, S., EPA/ESD. May 16 and June 21, 1991.
Response and follow-on information pertaining to add-on
control survey.
23. Telecon. Caldwell, M. J., Midwest Research Institute, with
Mcllwee, R., Smith Engineering Company. June 25, 1991.
Clarification of information provided in add-on survey
response.
24. Telecon. Caldwell, M. J., Midwest Research Institute, with
Mcllwee, R., Smith Engineering Company. August 13, 1991.
Destruction efficiency of thermal incineration systems.
C-39
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25. Letter. Nowack, W., Industrial Technology Midwest, to
Wyatt, S., EPA/ESD. June 21, 1991. Response to add-on
control survey.
26. Teiecon. Caldwell, M. J., Midwest Research Institute, with
Nowack, W., Industrial Technology Midwest. August 7, 1991.
Recirculating spray booths.
27. Telecon. Christie, S., Midwest Research Institute, with
Nowack, W., Industrial Technology Midwest. February 26,
1991. Description and costs of recirculating spray booths.
28. Telecon. Caldwell, M. J., Midwest Research Institute, with
Minor, J., M&W Industries, Inc. June 20, 1991.
Clarification of information provided in add-on survey
response.
29. U. S. Department of Commerce. U. S. Industrial Outlook
1992-Business Forecasts for 350 Industries. January 1992.
30. Chemical Engineering. 9£:178. July 1992.
31. Richardson Engineering Services, Inc., Process Plant
Construction Estimating Standards. San Marcos, California.
1984.
32. Telecon. Caldwell, M. J., Midwest Research Institute, with
T. Stewart, Newport News Shipyard. September 15, 1992.
Requesting information regarding tank painting operations.
33. 29 CRF 1915.35, Subpart C.
34. Telecon. Caldwell, M. J., Midwest Research Institute, with
R. Taylor, Durr Industries. September 15, 1992. The
feasibility of using add-on controls to control marine tank
painting VOC emissions.Ill
C-40
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing}
1. REPORT NO.
EPA - 4S3/R-94-Q32
2.
3. RECIPIENTS ACCESSION NO.
4. TITLE AND SUBTITLE
Alternative Control Techniques Document
Surface Coating Operations at Shipbuilding
and Ship Repair Facilities
7. AUTHOR(S)
5. REPORT DATE
1994
April
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO AOORESS
Midwest Research Institute
401 Harrison Oaks Boulevard
Suite 350
Cary, North Carolina 27513
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-1115
12. SPONSORING AGENCY NAME ANO AOORESS
Director of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
13. TYPE OF REPORT ANO PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES . x-
EPA Work Assignment Manager: Mohamed Serageldin
(919) 541-2379
16. ABSTRACT
Volatile organic compounds (VOCs) and particulate matter
including PM1Q (that which measures 10 microns or less) are
released into the atmosphere during shipbuilding and ship repair
operations. This report presents alternatives from whicl) Spates
may select requirements for State rules. VOC reductions will
result from limits that States may place on the volatile content
of coatings. VOC containment equipment for ship hulls has not
yet been demonstrated. Consequently, use of abatement equipment
to recover or destroy the VOC from such painting is not yet
practical. Abatement equipment may be used, however, to limit
emissions from automated application of weld-through primers
where the inherently high VOC content, rapid application rate may
make the cost effectiveness of control acceptable.
The report also provides background information and general
economic estimates for several control techniques. Finally, it
identifies some new control techniques that are under development
or in use abroad.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFI6RS/OPEN ENDED TERMS C. COSATI Fieki,Group
Air Pollution
Shipbuilding and Ship Repair
Hazardous Air Pollutants
Volatile Organic Compounds
Marine Coatings
Surface Coating
Ship Painting ( Coating)
Alternative
Control Techniques
(ACT)
Ships
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Tins Report I
Unclassified
21. NO. OF PAG£S
Release Unlimited
20. SECURITY CLASS (This pagei
Unclassified
22. PRICE
EPA Form 2220-1 (R«v. 4-77) previous EDITION is OBSOLETE
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