' • t J Jr\ f
          EPA-450/2-77-008
          May 1977
          (OAQPS NO. 1.2-073)
CAN COATING
AP 42
Section 4.2.2.f
Reference Number
                          OAQPS GUIDELINES
                 CONTROL  OF  VOLATILE
                    ORGANIC EMISSIONS
                         FROM- EXISTING
                 STATIONARY SOURCES  -
          VOLUME II:  SURFACE COATING
                OF CANS, COILS, PAPER,
                FABRICS, AUTOMOBILES,
             ? AND LIGHT-DUTY TRUCKS
           U.S. ENVIRONMENTAL PROTECTION AGENCY
               Office of Air and Waste Management
             Office of Air Quality Planning and Standards
            Research Triangle Park, North Carolina 27711

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                            EPA-450/2-77-O08
                          (OAQPSNO. 1.2-073)
       CONTROL  OF VOLATILE
ORGANIC EMISSIONS FROM EXISTING
 STATIONARY  SOURCES . VOLUME II:
 SURFACE COATING OF CANS,  COILS,
  PAPER, FABRICS, AUTOMOBILES,
      AND LIGHT-DUTY TRUCKS
           Emission Standards and Engineering Division
             Chemical and Petroleum Branch
          I .S. ENVIRONMENTAL PROTECTION AGENCY
            Office of Air and Waste Management
           Office of Air Quality Planning anil Standards
           Research Triangle Park. North Carolina 2771 I

                  Mav IV77

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This report is issued by the  Environmental  Protection Agency to report
technical  data of interest to a limited number of readers.   Copies are
available  free  of charge to Federal  employees, current contractors and
grantees,   and nonprofit organizations * in limited  quantities  *• from  the
Library Services  Office  (MD-35) ,  Research Triangle Park, North Carolina
27711.
                         Publication No ,  EPA-450/2-77-008
                                    11

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                                      PREFACE
      This  is  the second  in  a  series  of  reports  designed  to  assist  State
and   local  jurisdictions   in   the   development   of  air  pollution   control
regulations   for  surface   coating  industries.   These  reports   are   directed
entirely  at  the  control  of  volatile  organic  compounds  (VOC)  which  con-
tribute   to  the  formation  of   photochemical   oxidants.  Volume   I   provides
very  general   information  on  the  cost   and  effectiveness  of control
technology  and  guidelines  for  sampling  and   analyzing  VOC  emissions.
      Volume  II provides   specific  information  on   air  pollution  control  of
five   surface  coating   industries; namely,  automobile  and  light  duty  truck,
can,  coil,   fabric   and  paper  coating  operations.   For   each   industry,
coating   systems   are  reviewed  and  various  VOC   control   alternatives  are
considered  together   with  their   costs   and  limitations.   This   volume   also
provides  guidance  on  the  preparation  of   air  pollution   control  reg"lation$
and   test  methodology  suitable  for their   enforcement  (Appendices   A and  C).
      It  must  be  cautioned that  the   limits  provided  below   are based  on
capabilities  and  characteristics   which  are   general  and  therefore  presumed
normal   to  these  industries;  the  limits may  not  be  applicable to every plant
within   an   industry.  For   example,   although  the  level   of  control  recommended
for   the  can   industry  is  based   on  coatings  that  are  generally   available,  those
coatings  may  not  be  suitable  for every product  manufactured   by   a  can  plant.
      In  each  case   the   recommended   limitation  is  stated  in   terms  of  solvent
content   of the  coating.    This  form  is  most  applicable   to  situations   where  low
solvent   coatings  are  employed.    If  an  operator  should   choose to comply by
                                         in

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installation  of  add-on  control  devices,   it  may be  appropriate  for  the  agency
to  set  minimal  requirements on  the  hooding or capture  system and  the
efficiency of the  control  device.
     The tables that follow  provide  emission limitations  Mrepresent
the  presumptive   norm  that  can  be  achieved  through  the  application  of
reasonably available control  technology  (RACT).  Reasonably  available
control  technology  is defined  as the  lowest emission limit  that  a par-
ticular  Source   is  capable   of  meeting  by  the  application of control   technology
that  is  reasonably  available  considering   technological and economic  feasibility.
It  may  require   technology  that  has  been  applied  to  similar, but  not necessarily
identical,  source  categories.    It  is  not  intended  that extensive  research  and
development  be   conducted  before  a  given   control   technology   can  be   applied
to  the  source.    This  does  not,  however,  preclude   requiring   a  short-term
evaluation  program  to  permit  the application of  a  given technology  to  a
particular  source.   This   latter  effort   is  an  appropriate   technology-forcing
aspect   of RACT.
CAN   INDUSTRY
             Affected    Facility
  Recommended    Limitation
kg  per  liter     Ibs per gal
 of  coating       of  coating
(minus water)    (minus  water)
          Sheet  basecoat  (exterior
            and  interior)  and over-
            varnish;   two-piece   can
            exterior   (basecoat   and
            overvarnish)
          Two  and  three-piece  can  interior
            body  spray,  two-piece   can
            exterior  end  (spray  or  roll
            coat)
          Three-piece   can  side-seam  spray
          End  sealing   compound
   0.34
2.8
   0.51
   0.44
4.2
5.5
3.7
                                        IV

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     The limitation for the sheet baseCOQt  (exterior and interior)  and

overvarnish; two-piece can exterior (basecoat and overvarnish) assumes

the average solids content of all coatings  is about 25 volume percent

and the solvent is an 80 percent water,  20  percent organic mixture.

The organic-borne equivalent  is 64 volume  percent solids. Such coatings

are now used by some companies on part of their Production.

     The  limitation  for two  and three-piece  can  interior  body  spray,

two-piece can exterior end  (spray or roll coat) oresumes all coatings

average 18 volume percent solids in an 70:30 water  to  organic solvent

ratio.   Such coatings  are  now used  on some beer and beverage  cans.

     The limitations for the  three-piece can side-seam spray assumes an

increase in the solids content of typical present-day coatings by  100

percent to 25 volume percent.   Water-borne coatings for some  unique

products have been developed  that are applied at solvent contents  as low

as 0.53 kilograms per liter of coating.

     The limitation on end sealing  compound emissions presumes an  increase

in the solids content of a typical  organic-borne coating from 30 to 50

percent.   Water-borne  coatings for  some unique products are applied at

solvent contents as low as 0.26 kilograms per liter of coating.




COIL COATING INDUSTRY



                 Affected  Facility               Recomnended Limitation

                                              kg per liter    Ibs  per  gal
                                                of  coating       of coating
                                               (minus  water)    (minus  water)
               Prime and topcoat or single        9.31              2.6
                 coat operation

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      This  limitation  is  based  on  incineration  of the  emissions  from  an
organic-borne  coating   which  contains  25  volume   percent   solids.   To  comply,
90  percent  of the  solvent  in the coating  would  have to  be  captured and
directed  to  the  control  device   (afterburner)  which  must   be  at  least  90
percent    efficient.   There  are  also  some  water-borne  coatings  that  will
comply  with  this  level  of control  without  the  need  for  add-on  control
equfoment.

FABRIC   COATING

                   Affected   Facility               Recommended  Limitation
                                                  kg  per  liter     Ibs per  gal
                                                    of  coating       of   coating
                                                   (minus  water)     (minus  water)
                  Fabric   coating  line               0.35               2.9
                  Vinyl   coating  line                0.45                3.8

      "Fabric  coating"   'includes  all  types  of  coatings  applied to   fabric,
a  large  portion  of which  is rubber  used  for  rainwear,   tents  and   industrial
purposes   such  as  gaskets   and   diaphrams.  "Vinyl  coatinq"  refers  to  any
printing   or  decorative  or protective  topcoat  applied  over  vinyl  coated
fabric  or  vinyl  sheets.    It  does  not  include   the  application of  vinyl
olastisol  to  the   fabric  (emissions  from  the  application  of  plastisol  are
near  zero).
      The  limitations  for  both   are  based  on  use  of  an   add-on control  device
which  recovers  or  destroys 81   percent  of the  VOC  introduced  in  the coating.
Typically,   this  will  require   that  90 percent  of  the  VOC  is  captured  and
delivered  to  the  control  device  which  also  must  have  an  efficiency of  90
percent.
                                         vi

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     The  limitation  for fabric coating could also be achieved by use  of

an organic-borne coating which is about 60 volume percent solids or a

water-borne 80:20 coating with a  solids content of about 24 volume percent.

Neither of these coatings  are known to be in routine use by the industry.



PAPER COATING


             Affected Facility               Recommended Limitation

                                           kg  per liter'    Ibs  per  gal
                                            of  coating       of   coating
                                            (minus  water)    (minus   water)

             Coating  line                      0.35              2.9


     These levels  are for  all coatings put on paper, pressure sensitive

tapes regardless of substrate  (including Daper,  fabric or  plastic  film)

and related web coating processes on plastic film such as  typewriter

ribbons,  photographic film,  and magnetic tape.   Also included  are decorative

coatings  on metal  foil such  as gift wrap and packaging. These  limits can

be achieved in all cases using incineration and  in many cases with coatings

that contain low fractions of organic solvents.



AUTOMOTIVE AND LIGHT DUTY  TRUCK ASSEMBLY PLANTS


                Affected Facility               Recommended Limitation

                                               kg per liter    Ibs  per  gal
                                                of coating      of coating
                                               (minus  water)   (minus   water)

            Prime  application, flashoff           0.  23            1.9
              area and oven

            Topcoat  application,  flashoff         0.34              2.8
              area  and oven

            Final  repair application,             0.58             4.8
              flashoff area and oven
                                        V 1 1

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     These limits apply to all objects surface  coated in the plant including




the  body,  fenders,  chassis,  small parts, wheels, sound  deadners,  etc. It




does  not  apply  to  adhesives.




     The  level rSCOIHnended for prime application is  based on use of an




electrophoretic system followed  by a 25 percent  solids  water-bone "surfacer"




to build  thickness  and  improve the adhesion of the  topcoat. Water-borne




surfacer  is in use at two U.S. plants.   The electrophoretic system is now in




use at about half of the plants  in the United States.  Although several of




these were converted to electrophoretic, such a transition may not be reasonable




for an existing assembly line which uses a  water-borne dip prime coating system




releasing about 0.38 kilograms  per liter of coating.  The moderate reduction




in emissions possible with  electrophoretic  coatings  would be obtained at




great   expense.




     The  level for topcoat represents a  water-borne  coating now in use by




two plants  in  the United  States. Because  of:  (1)  the  large  expenditures




required  to convert from organic-borne coatings to water-borne coating, it may




be reasonable to grant some  finite period for a source to develop low




solvent organic-borne coatings with equivalent  emission characteristics.




     The  level for  "final repair" is based on use of an organic-borne




enamel with 35 percent solids.   Water-borne coatings cannot be  employed




for the assembled automobile.   None of the automakers are using coatings of




35 percent s 'lids at present but  such use is now scheduled at  one  U.S.  plant.
                                        VI11

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                                TABLE  OF  CONTENTS



VOLUME  II    SURFACE   COATING OF  CANS,   COILS,  PAPER,   FABRICS,   AUTOMOBILES,
                AND   LIGHT-DUTY   TRUCKS

PREFACE  	          '

1,0  INTRODUCTION	     1-1

2.0 CAN COATING   	     2-1

      2.1  Summary   of  Control   Technology	      2-1

      2.2   General   Discussion   	       2-2

            2.2.1   Materials   Used	       2-4

            2.2.2   Processes   and   Affected  Facilities.	     2-6

      2.3   Special    Considerations   	       2-13

      2.4   Available   Control   Technology.  	      2-17

            2.4.1   Option   1   -   Incineration   	      2-17

            2.4.2   Option   2 -    Water-Borne/High-Solids!Powder     Coatings   - - -     2-25

            2.4.3   Control  Option   3  - Carbon  Adsorption   Coating  	     2-28

            2.4.4   Control  Option   4   -   Ultraviolet   Curing	     2-32

      2.5  Comparison   of  Control  Options  and  Conclusions  	     2-34


3.0   COIL   COATING	        3-1

      3.1  Summary   of  Control  Technology	      3-1

      3.2   -General   Discussion   	     3-1

            3.2.1   Materials  Used	       3-3

            3.2.2   Processes   and   Affected   Facilities	     3-4

      3.3    Special    Considerations	       3-8

      3.4   Available   Control   Technology	      3-11

            3.4.1   Option   1   -   Incineration   	      3-12

            3.4.2   Option  2  •  Water-Borne   and  High-Solids   Coating	     3-21

      3.v   Comparison  of  Control  Options  and  Conclusions  	     3-25

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4.0  FABRIC  COATING.  	       4 J
     4.1  Summary  of Control Technology	      4'1
     4.2   General   Discussion   	       4-1
           4.2.1  Materials Used	    4-2
           4.2.2  Processes  and   Affected   Facilities   	     4-2
     4.3  Special  Considerations.	    4-TJ
     4.4  Aval 1 able Con trolTechnol0^	    4-12
           4.4.1  Option  1 - Incineration   	      4-12
           4.4.2  Option   2 - Carbon Adsorption	     4.15
           4.4.3  Option  3 - tow Organic Solvent Coatings    	    4-18
     4.5  Comparison  of  Control  Options   and  Conclusions	    4-18
5.0  PAPER  COATING..   	        5-1
      5.1  Summary  of Control  Technology	      5-1
      5.2  General  Discussion.   	       5-1
            5.2.1   Materials   Used	       5-4
            5.2.2   Processes  and  Affected   Facility   	     5-8
      5.3   Special   Considerations.  	       5-14
      5.4   Available   Control   Technology.   	       5-14
            5.4.1  Option  1  -  Low  Solvent   Coatings.   	     5-14
            5.4.2  Option  2  •   Incineration.	      5-21
            5.4.3   Option  3  -  Carbon  Adsorption	     5-23
      5.5  Comparison  of  Control   Options   and   Conclusions	     5-27

 6.0 AUTOMOBILE  AND  LIGHT  DUTY  TRUCK ASSEMBLY	     6-1
      6.1   Summary   of Control  Technology	      6-1
      6.2  General  Discussion.	    .       6-2

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           6.2.1  Materials  Used  ...................      6-6
           €.2,2 Processes  and  Affected  Facilities ..........  6-7
     6.3 Special Considerations ...................     6-ltJ
     6.4 Available  Control  Technology ................     6~^
           6.4.1 Option  \  -  Electrodeposition of  Water-Borne Primer .     6-17
           6.4,2 Optlw 2  <•  tower Solvent Primer  and Topcoat .....    €-22
           6.4.3 Option 3  ~  Carbon  Adsorption  fur Primer and  Topcoat
                                Spray Booths  .............     6-24
           6,4,4 Option 4  -  'Incineration for  Spray Booths ......    6-29
           6,4.5 Option 5  -  Incineration for  Priscr  and
           6,4,6 Option 6  - Water-Borne  Topcoats  ...   .......  6-36
     6.5 Comparison  of  Control  Options  and  Conclusions  .......    6-41

APPENDIX  A - ANALYTICAL TECHNIQUES  .................    A-l
APPENDIX  B - RECOMMENDED  POLICY  ON  CONTROL  OF
                VOLATILE ORGANIC COMPOUNDS  ..............    B-l
APPENDIX C - REGULATORY   GUIDANCE.   ..................      C-l
APPENDIX  D - CONVERSION   METHODS  ...................      D-l
                                      XI

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                          1.0  INTRODUCTION






     The industries reviewed herein represent some of the largest and most




widespread sources of volatile organic solvents  in the nation.    Moreover,




their  products, often with very  specialized surface coatings, are  interwoven




into many facets of our economy  and are  subject  to a wide range of performance




demands.   Collectively,  they release about 850,000 tons of VOC annually to the




atmosphere with the  largest individual  sources each being responsible  for




over 1,000  tons per  year.   The five industries employ a variety  of coating




application and curing  techniques,  all  of which impact on the viability  of




alternative VOC control  technologies.   From the air pollution control  stand-




point, it is immaterial  whether  VOC are  removed  from the coating process or




are  controlled at the point of emission.   Nonetheless, since solvent recovery




and/or elimination strongly influence control costs and acceptance by  the




affected industries, much of this  document is directed at the review of




alternative control strategies,  costs, and energy impacts.




     To varying degrees,  four  different abatement methods have been  used




to reduce the contribution of  surface coating VOC to the photochemical




oxidant   burden.  These  are:




     (i) "Add-on"  technology  \* destroy or recover VOC from




     exhaust   gases,




     (2) Reformulation  of coatings  to minimize  organic




     solvent   content,




     ( ') Modification of the process to  f^-'uce  the quantity




     of VOC which escapes from a coating ]; I, and





                                 1-1

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      (4)   Substitution   of   less  photochemical ly   reactive   solvents
      in  surface   coating   formulations.
      The  first  three  are  "positive  reduction"  techniques  in  that  they
actually  reduce  the  mass  of  VOC  released  to  the  atmosphere.   The  fourth,
solvent  substitution,   doesn't   reduce  the  quantity   of  organic  emissions
and  has  been  only   marginally  effective   In   reducing  ambient   concentrations
of  photochemical  0x1 dints  (see  Appendix  8).  In  preparing  this  document,
principal  attentian  has  been  directed  at  add-on  control   technology  and
the   reformulation  Of  coatings.   These   two  positive   reduction  techniques
currently  offer  greeter  potential   for   reducing  organic   missions  than
process  modifications  far  the  five   surface   coating  operations  in  question.
       In  previous  years  the   primary method  used to   reduce  organic  emissions
 from  stationary  sources  has  been  through stack  gas  treatment,  primarily
 incineration.     Incinerators   or   afterburners  have   evolved  as   the  basic
 control  technique   to  which   the  efficiency  of   alternative  methods   is
 often   compared.   Within   the   coating   industry,   however,   incinerators
 have,  for  the  most  part,  been  limited  to  baking  and  curing  ovens.   In
 IDOSt   instances,   spray  coating operations,  which  are  much  larger  sources
 of  VOC  than  associated  ovens, have gone uncontrolled.   It  is  for  these
 coating  sources   that   low-solvent  coatings  offer  the  greatest  promise.

 1.1   LOW-SOLVENT  COATINGS
       Coatings  which  contain  relatively  low  fractions  of  organic.solvent,
 the   so-called  "low-solvent   coatings"    (water-borne,   high-solids,    and
 powder  coatings),    offer   the   advantage  of  saving   valuable   petroleum
 feedstocks  while  also  eliminating   the   need   for  abatement  equipment  and
 its  concomitant   requirement   for  fuel  and  power.
      The   desirability   of   low-solvent   coatings   was   recognized  and  acknowledged
 by  the  Los  Angeles County  Air  Pollution  Control  District  in   1971  when
                                       1-2

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 incentives were  added  to Rule 66--its regulation governing use of




solvents.   Under Rule  66,  operators are not required to incinerate




oven exhaust gases  if  the surface  coating meets specified limitations




 (less  than 20  percent  organic solvent in coating by volume or an organic




solvent-to-water ratio of 20:80 or  less  in water-borne coatings). Many




other  governmental  agencies  throughout the nation have adopted similar




 incentives.




     The  low-solvent coating provisions of Rule 66 were developed at a




time when few  water-borne, high-solids, or powder coatings were available.




 In the six years since these incentives were first offered to the industry,




there  has been only a  limited shift in that direction. Currently, they




represent only about 10 percent of industrial  surface coating sales. The




rest are  conventional  organic-borne formulations with an  organic  solvent




content of 60  to 90 percent  or more.   Lack of greater acceptance  of  low-




solvent coatings by the industry  is attributable to many factors,  some




of  which  are:   difficulties  in achieving Rule 66 specifications,  relatively




 low cost  of  solvents,  and the ability to comply with air pollution regulations




by  less burdensome  means such as solvent substitution.




     The  dramatic reduction  which can be achieved  in switching  to lov/-SOlvent




coatings  is often not  apparent  from coating specifications.    For  example,




with the  aid of  Figure 1,  it can be shown that an operator now using a 30




volume percent solids  (70 percent  organic solvent)  coating could reduce his




VOC emissions  57 percent by  rep  cement with a  coating  containing 50 percent




solids.   If  he could use a coating of 70 percent solids, his VOC reduction




would be 82 percent.   Even greater reductions can be realized by users of




highly  jilute  coatings  such  as  lacquers.   Al. ?Derat01" now using a 10 volume




percen* solids lacquer could effect a; 88   Tent VCC reduction by switching




to  ? 50 iercent solids  enamel.   By SWltchir,  to a 70 percent solids  coating,






                                   1-3

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Percent  Emission Reduction Per  Volume of  Solids


—     IM       C.J      **       tfl       Ol      ^1
O     O       O      O       O       O      O
                                                                                     (Item Coated)

                                                                                 00      <£>     O
                                                                                 o      o     o
lb.  S0lvent/
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his VOC  reduction would be  95 percent.   Conversion to water-borne coatings




will also significantly reduce VOC emissions.   Replacement of a  30 volume




percent solids  organic-borne coating with an 80:20 water-borne (80 percent



water, 20 percent organics,^  of similar  solids  content would yield a VOC



reduction of about 80  percent for a given industrial application.






1.2 STACK  GAS  TREATMENT




     Founding emission limitations on low-solvent technology  is  not without




its  drawbacks.    In some instances, switching to low-solvent coatings  may




not provide as  much VOC control  as would add-on control devices.   This   could




be true during  any transition period as we phase into lower solvent coatings.




For certain industries,  it will  be more effective and possibly less costly




to employ incineration,  adsorption, or other techniques to remove  or  destroy




VOC in  the  exhaust  gases.   Carbon adsorption should continue  to  find  use




where the solvent has  a relatively high market value and is amenable to




recovery  with   adsorption  techniques.   Incineration  is expected to  remain




a viable alternative where organic concentrations can be maintainei at




relatively high levels such  that auxiliary fuel requirements  are noi excessive




or where energy in the hot exhaust gases can be recovered and used tc offset




fuel requirements elsewhere  in the plant.




     A major disincentive to applying stack gas treatment to VOC sources  is




the low concentration  of organics often  encountered.  These low  concentrations




mean large volumes of  air or other diluents must be processed to control  the




solvent.   This   results' in  higher  costs  and energy  requirements  for  control




equipment and,  frequently,  lower control efficiencies.  Major reasons for




such low concentrations  are: (1) solvents  are  toxic to the worker, hence,




are intentionally diluted below  the thres'iold  limit value (TLV); (2) concen-




trations are maintained well below the lowc - explosive  limit  (LEL) to reduce
                                     1-5

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the  risk  of  fire  or  explosion;  (3)  large  dilution rdliub »'«=
accommodate  fluctuations  in  VOC  evaporation  rates,  and   (4)   the  operator   is
unaware  of  the   multiple benefits  of minimizing  the   intrusion of  diluent   air.
      The  greatest  dilution  and  lowest  VOC  levels  are  found  in  hand-held
spraying   operations   and  are  attributable   to   TLV  restrictions.    No  large
worker-occupied  spray  booths  such  as  those  used  in   auto  assembly  plants
have  been  controlled  with  VOC  stack  gas   treatment   technology.   Where  the
coating  is  applied   mechanically  as   with  a  knife,   roller,  or  electrostatic
spray gun,  it  is  usually  possible  to  maintain  much  greater  VOC  concentrations
in  exhaust  gases.   Similarly,  baking  and  curing  ovens  can  be  maintained   at
VOC   levels  much   greater  than  are  feasible  for  worker-occupied   spray  booths.
      Solvent  concentrations   in  ovens  and   automated   coating  applications   are
generally  maintained   below  25  percent  LEL  because  of  safety  hazards  associated
with   higher   concentrations.1   Unfortunately,  many  ovens   are  operated  at
organic  concentrations   well   below   this  level.  For  example,   at   5   percent  LEL,
the  exhaust  rate  is  five-fold greater  than at 25  percent  LEL  and  any  add-on
control  device  must  be  five  times  larger.   In  many   cases ,  such  low  concen-
trations   are  not  necessary.    Changes  in  system  design  and   operating  practices
can  minimize  air  intrusion  with  the  attendant benefit  of a  reduced  exhaust
volume  and  reduced   control   costs.
      In   a  few   industries,  operators  have   been  notably  successful  in
maintaining  VOC   levels  at  greater  than  25  percent  LEL  and   effecting
major  fuel   economies.   For  example,   several  coil   coaters  have  actually
reduced  fuel  consumption  in  the   coating  oven  by  use of  incineration
devices  and  heat exchangers   and  maintaining VOC  concentrations   at   30  to
40  percent  LEL.    In  many  more  applications,   incineration  would  be  a more
cost  effective  control   option  if  air   intrusion  were  minimized  and VOC
levels  held  to   25  percent  LEL  or  greater.  This  ancillary  aspect  of VOC
control  has   received  only  limited  attention   in  many industries.
 'Some  insurers  will  permit  operation  up  to  50  percent  of  the  LEL  if
 appropriate   monitoring  and   fail-safe  relief   systems   are   installed.
                                   1-6

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1.3  EMISSION LIMITATIONS



      Historically,   VOC  control  regulations   have   included  limitations  on   the



organic  solvent  of  coatings  or  have  stipulated  that  a  certain  percent  reduction



be  achieved  through  stack  gas  treatment.   While  either  approach   is  acceptable



if  limits  are   appropriate,  solvent  content  is  a  more  reasonable   basis   for



surface  coating  operations   which  are  expected   to   employ  low-solvent  coatings.



      For  these   five   industries,   it   is  recommended  that  emission  limitations



be  expressed  in terms   of organic  solvent  content  since  these  values  can  be



determined  with   relati Vely   simple  analytical   techniques  and  are  directly



relatable  to  VOC  emissions.   For  operators  who  use  stack  gas  treatment,



alternative    compliance procedures  should   be  included.



      Solvent   content   1 imitations  may  be  expressed  in  terms  of  mass  or



volume  and  may  be based  on  the  entire  coating  (including  solvent)  or  only  on



paint  solids.    In this   document,  limitations  are  expressed  as   the   allowable



mass  of VOC  per unit volume  of  coating  (kg  per  liter  or Ib  per  gallon)  as  it



is  applied  to  the product.   The  principal  advantage  of  this  format   ir  that



enforcement   is   relatively  simple.   Field  personnel  can  draw  samples  and  have



them  analyzed   quickly.    A  disadvantage   is   that   the  relationship   between  the



solvent  fraction  and  VOC  emissions  is  not  linear.    As  illustrated  in




Figure  D-Z of Appendix  D, use  of  a   coating  containing  3 Ibs  of VOC  per



gallon  of coating  emits 4.4  tim.S  as  much,  solvent  as use  of one  with



1  Ib Der gallon  and only 55  percent as much  as  one  of 4.1 Ibs  per gallon.



Thus,   VOC  emission  rates   could  be  easily  misunderstood by  the  general  public.
                                       1-7

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      The above  disadvantage is  eliminated if the solvent content is
 expressed  in  terms  of  mass  of  VOC  per  unit  volume  of  paint  solids
 (again  kg  per  liter or  Ib  per gallon).   Here   the  relationship  is   linear
 and  more  readily  understood  by   the  public,  e.g.,  a  coating  containing
 2  Ibs  per  gallon  of  solids  releases  twice  as  much VOC  as one of  1  Ib
 per  gallon.    The  disadvantage  of  this  format  is  that  it  relies  on  an
 analytical   method  which  has  had  only   limited  usage  in  the  industry  and
 is  virtually  untried  by  control  agencies.   When   more  experience   is
 developed  with the  procedure  for  measuring  the volume  of solids  in  a
 coating  sample  (approved by  the  American  Society  for  Testing  and  Materials),
 it  may  be reasonable  to  express  limitations   in terms of paint  solids.
 Until  these  uncertainties   are   resolved,  it  is  recommended  that  limitations
 be  based  on   the  volume  of  the  coating  (minus  water).  Appendix  A  presents
ASTM test  methods  for  determination of the  pounds  of  VOC per gallon
 of  coating  (minus  water).
      Other options  such  as  Ibs  or gallons  of  VOC per Ib  of  coating are
 generally  less  desirable  although  they  may  be  entirely   appropriate  for
 a given  industry.  Basing  limitations  on  the  mass  of  coating or  paint
 solids  is   not  recommended  because  the  specific  gravity  of  coatings
 tends  to  vary widely  with  the  degree  and  type  of  pigmenting  employed.
 Highly  pigmented  paints   have  much  greater   density   than  unpigmented  clear
 coats  or  varnishes.    Furthermore,   basing   limits  on  paint  mass  might
 encourage  users  to  employ  a greater  degree  of pigmentation solely  to
 meet air  pollution   limits.   Mass  rather  than  volume  of  VOC  is
 recommended   for  emission   limitations  because  measurement  techniques
 are   simple and  because  VOC  mass  is  more  closely  related to  photochemical
 oxidant    formation.
                                      1-8

-------
      For  any  given  industry,   it  may  be  desirable  to  express solvent  limits
in  terms other than those recommended in the Preface.    In  such  instances,
it  will  be  necessary  to adjust  numerical  limits  such  that  they provide
the  desired  degree  of  control.   Appendix  D   provides  equations  and  charts
through  which  recommended  limits  can  be  translated  into  other  solvent
limitation    formats.
      The  approach  outlined  above  was  designed  for   coating   processes  where
low-solvent  coatings  are  to  be  employed.  In  those   few Industries  where
stack  gas  treatment  is  a  more  likely  option,  it may be more appropriate
to  state  emission  limits  in  terms  of  control  efficiency  across the  incinerator,
adsorber,  etc*  This   concept   is   discussed  1rt  Appendix  C*  Where   limitations
are  expressed  only  in terms  of  the  coating   content,  it will  be  necessary
to  determine  mass  emissions   from  the  control  system  and  relate  them  to
the  quantity  of  coatings  applied   during  the  test period.  It is  often
difficult  to  determine  the  consumption  of   coatings   during  any  given
period  and  to  ascertain  the  fraction  of VOC  which  is  directed  to   the
control   device.    in  most  instances,  it  will  be  more reasonable  to  provide
an  alternative  efficiency  requirement   for   those  situations   where   add-on
control  technology  is  used  in  lieu  of  a complying   low-solvent  coating.
                                      1-9

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                           2.0  CAN COATING
2.1 Summary of Control  Technology
     Affected  Facility *

     Two-Piece Can Lines

     Exterior   Coating:
Control   Options
      Interior  Spray  Coating:
Catalytic  and
  catalytic  incineration

Water-Borne  & High-Solids
  coatings

Ultraviolet  Curing

Catalytic  and non-
  catalytic  incineration

Water-Borne  & High-Solids
  coatings

Powder  Coating

Carbon   Adsorption
Percent   Reduction



        90


      60-90


     up to  100

        90


      60-90


        100

        90
      Three-Piece Can Lines

      Sheet Coating Lines

         Interior   Coating:
         Exterior   Coating:
 Catalytic and non-catalytic
   incineration

 Water-Borne & High-Solids
   coatings

 Catalytic and non-catalytic
   incineration

 Water-Borne & High-Solids
   coatings

 Ultraviolet curing
         90
                                                                           60-90
         90
                                                                           60-90
                                                                          up to 100
                                       2-1

-------
Can  Fabricating   Lines
   Side  Seam  Spray  Coating:
    Interior  Spray  Coating:
                                        Water-Borne   &   High-Solids           60-90
                                           coatings
                                         Powder  (only  for   non-cemented       100
                                           seams)
                                         Catalytic    and   non-catalytic            90
                                           incineration
                                  Water-Borne   &   High-Solids           60-90
                                     coatings
                                  Powder   (only  for   non-cemented         100
                                     seams)
                                  Carbon    Adsorption                       90
End  Coating  Line
    Sealing   Compound:

    Sheet  Coating
                                         Water-Borne  &   High-Solids            70-95
                                           coatings
                                         Carbon   Adsorption                       90
                                         Catalytic   and   non-catalytic           90
                                            incineration
                                         Water-Borne  &  High-Solids            60-90
                                           coatings
*Any  sheet,  can  or  end coating  line  consists of the  coater(s) and  ovens(s).

 2.2   General   Discussion
       Cans  are made  in  one  of  two  different  ways.  A  "three-piece"  can  is
 made  from  a  rectangular  sheet   (body  blank)  and  two  circular  ends.   The
 metal  sheet   is  rolled   into  a  cylinder  and  soldered,  welded  or cemented
 at  the seam.   One  end  is  attached   during manufacturing,   the other   during
 packaging  of  the  product.   The  "two-piece" can is  drawn  and wall 1-ironed
 from  a shallow  cup  and  requires  only  one  end  which  is  attached after  the
 can  is filled  with  a  product.
                                    2-2

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      Cans  are  used  as  containers  for  over  2500  different  products  ranging
from  beer  and  other   beverages,   meats,  fruit,  vegetables  and   other  edible
products  to  tennis  balls,  motor  oil  and  paints.  Cans  are  fabricated  in
over  600  different  shapes,  styles  and  sizes.   There  are,   therefore,   major
differences  in  coating practices  depending   on  the  can  and  type   of  product
packaged  in  the  can.
      Independent  and   captive   can  manufacturers  make  up   the   industry.  The
independents  are  a  service   industry   that  coat  and  fabricate  cans  for   a
variety  of  customer's needs   and  specifications.  A few  olants  are owned by
independent  companies   but  manufacture   cans   for  a  single  customer.   Captive
can  manufacturers  coat and  fabricate   containers   only  for  products  of  that
corporatjoru
      Can  manufacturing plants  are  typically  located  either  near  steel  or
aluminum  mills  or  in  the  vicinity  of  their  customers.   In  the  independent
can  industry,  the  metal  sheets  for  three-piece  cans  are  usually  coated  near
steel  mills,  and  the  cans  are  usually  fabricated  near  the  customers.   The
captive  can  industry   typically coats   and  fabricates  cans  in  the  vicinity
of  the  plant that  uses  the  cans.   About  50  percent  of the  U.S.  can
coating  industry   is   located   in  California,  Illinois,   Ohio,   Texas,   Pennsylvania
and  New  Jersey.   On  a  regional   basis,  EPA  Region V has  about  27  percent
of  the  U.S.  can  industry,  Region  IX  about  16  percent  and  Region III  about  12
percent.
      Sizes  of  can  manufacturing  plants   vary.   Some   plants  coat  only
the  metal  sheets,  some  fabricate  only  the   three-piece  cans  from the
coated  sheets',  some  fabricate  and  coat  only  two-piece  cans.^jind  some
coat  and  fabricate  only  can  ends.   Othe   nlants   perform  combinations   of
these  processes.
                                      2-3

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2.2.1  Materials Used              - The  metal  sheets tyoically coated in



the three-uiece can manufacturing  industry are tinplate,  tin-free steel,



black plate and aluminum in gauges ranging from 0.006  to  0.015 inch and



sheet sizes ranging from 30 inches x  32  inches to 37 inches x 42 inches.



Aluminum is widely used in two-piece  can manufacturing but some steel is



also used.



     The interior base coat is roll coated on  the sheets  for three-piece



cans to provide a protective  lining between the can metal and product.



It  is  important that the interior  base coat does  not react with the



product to  alter  the  product's taste, odor, or appearance. All interior



COBtinqs for cans that will contain edible products must  meet Food and


                                 1  2
Drug   Administration   regulations.  '



     Some common resins used  in  the  interior base coat are butadienes,



rosin esters, phenolics, epoxies, and vinyls.   The coatings  in which



these resins are used range from 20 to 60  percent solids  by weight,


                                                                   1,2
and organosols that range from 30 to  66  percent solids by weight.



     The exterior base coat,  usually  white,IS  used frequently both on two



and three piece cans to provide  exterior protection to the metal and



background  for  the  lithograph or printing operations.  Some of the coating



resins used are polyesters, alkyds and acrylics.   These coatings are



approximately 55 to 72 percent solids by weight.



     Conventional inks used  for  printing or lithography contain approximately



90 to 99 percent solids by weight. '   These  inks  may be used  for both two



and three-piece cans,with or  without exterior  base  coat  as Specified by



the  customer.
                                  24

-------
      An  over-varnish  is   usually  applied  directly  over  the  inks  to  reduce
the  coefficient  of  friction  (to  allow for  proper  mobility  of  the  can  on
conveyor  tracks),  to   provide  gloss,  and  to  prbtect  the  finish  against
abrasion  and   corrosion.    Some  common  solvent-thinned   coating  resins
are    acrylics,epoxies,  alkyds,  and  polyesters  at  solids  contents  of  30  to  45
percent  by  weight.  '
      The orimer  or  size  coat  is  roll coated before  the  application  of the
exterior  base   coat  or  ink  to  provide  better  adhesion  of  the  coating,
eSDecially  if  a coating has  to  withstand  severe  deformation  during
stamoing  or   tooling  operations  or   withstand  high  temperature  processing
operations.     The  sizing  is  usually  an  epoxy,   eooxy   ester,   acrylic,  vinyl
or  po lyester  re s (i n.
      Over  30   different solvents  are   used   in  interior  and  exterior  base
coats,  overvarnish  and  size   coat.   These   include   mineral  spirits,  xylene,
toluene,  diacetone   alcohol,   methyl  iso-butyl  ketone,   methyl   et^yl  ketone,
isophorone, Solvesso  100  and  150   (TM),  ethylene  glycol  monoethyl  ether
(TM  under  Cellosolve) ethanol,  cyclohexanone,   ethylene   glycol   monobutyl
ether   (TM  under  Butyl   Cellosolve),ethylene   glycol  monoethyl   ether  acetate
(TM   under   Cellosolve  acetate),   n-butanol,    isooropanol,   butyl   carbinol,
oaraffins,  oropylene  oxide,   mesityl   oxide,  aliphatic   Petroleum    hydrocarbons,
di-isobutyl   ketone,   di-methyl   formamide,    and   nitrooropane.
      The coating used  for  the sideseam  on the interior  and  some-
times  on  the   exterior of three-oiece  cans  usually  contains  vinyl  and  eDOXY-
Dhenolic  resins  at  10  to  40  percent  solids  by weight.   Solvents   used  in
side-seam   coatings  are   xylene,    butyl  acetate,paraffins,   nitropropane,
Cellosolve  acetate  (TM),  methyl  iso-bu   /I  ketone,  mineral  spirits,   propy-
                            1  4
lenr  oxides  and  toluene.  '
                                     2-5

-------
       The  end  sealing  compound  is usually a dispersion of a synthetic rubber
  in  heptane or hexane,  and lines the  edges of can ends to form a gasket.
  It  contains 30-45 percent solids by  weight.'
2.2.2  Processes and Affected  Facilities
Two-Piece   Cans  - The  two-piece can manufacturing operation  is  a continuous,
high speed process  and  includes both fabricating and coating operations.
These cans are  typically used  by the beer and other beverage industries.
Figure 2-1 shows one  method of fabricating and coating two-piece aluminum
cans.
      Metal for two-piece  cans is received in coil form and is continuously
fed into  a press  (cupper)  that stamps and forms  a  shallow cup. The cups
go through an extrusion process that draws and wall-irons the cups into cans
in a lubricating solution  and  trims the uneven edge of the  cans.   The cans
are then  cleansed to  remove the lubricating solution, rinsed with hot water,
and dried.  Some manufacturers have been required to provide water treatment
facilities to treat the cleansing process water prior to disposal.
      The exterior  bodies  of these cans are  sometimes  reverse-roller
coated with a white base coat.   The base coat is transferred from a  feed
tray, through a series  of  rollers,  and onto  the  can, which  rotates on a
mandrel.   The coating is cured or baked at 350 to 400°F in  single or multi-
pass   continuous, high production ovens at a  rate of 500 to  2000 cans  per
minute.
      Several colors  of ink are applied to printing blankets on a rotary
printer that transfers   the designs and lettering to the can as it rotates
on a  mandrel.    A protective varnish is sometimes roll  coated directly over
the inks.   The  decorative  coating is cured or baked in single or multi-pass,
continuous, high production ovens at 325 to  400°F.
      After printing,  the  cans  are  necked,  flanged,  and tested.  Flanging
facilitates proper  tnd  assembly  once  the  can  is  filled.  Necking  allows
                                  o c

-------
use  of  a smaller  end.   Each can is tested for  leakage  by applying approximately




12  psig  of air pressure  and monitoring  the can  for  air  leakage.




      The cans are spray-coated on  the interior of the can body and spray




and/or  roll  coated on the exterior of the bottom end.   The   viscosity,




spray time,  atomization  pressure,  and temperature during application of




the  coating  require precise control to provide a continuous protective




film  between the  product and the can.2




      The coating  is usually cured  or  baked  in a continuous, single pass




oven  at temperatures of  225 to 400°F.   Coated  cans are stacked on pallets




for  shipment   to  users.




     Some two-piece steel cans are sprayed with an additional  interior




coating and  baked prior  to the application of the interior body spray.




Also  the cans are necked in and flanged after the final step.




Three-Piece  Cans  -  The three-piece  can manufacturing process can  be




divided into two  operations:   sheet coating and can fabricating.   The




sheet coating operation  may be subdivided further into base COeMng of




one  or  both  sides and the  printing or lithographing.  The base  coating




operation consists  of applying an interior coating for three-piece




cans  and can ends,  an  exterior background coating,  or a size coat  if the




customer  so  chooses.




      The sheets  are roll coated on one side only by transfer of the




coating from the  coating tray,  through a series of rollers, and onto




the  sheet as shown in Figure _.2.  Sheets are then  picked up by the preheated




wickets and  transported  through a continuous, multi-zone, oven.   xhe  coating




is cured at  temperatures of up to 425°F.      Speeds are  70  to  150 sheets




per ninutei  depending on the age of equipment and the type of coating.




The sheets are air cooled in the last  2(.  -' of  the oven.  Oven  exhaust




rates  usually  vary  between  2,000  and K   jQ scfm.
                                  2-7

-------
                                                                                     CANS
        COIL
ro
 i
00
CUPPER
                          OVEN
 WALL
IRONER
                                                T
               INTERIOR BODY SPRAY
             AND  EXTERIOR END SPRAY
               AND/OR ROLL COATER
WASHER
                                                                      LEAK
                                                                    TESTER
                                                                                                            OVEN
        SECOATTRAV

EXTERIOR BASE COATER
                 i
              CANS
                                                                        HANfl


                                                      PRINTER AND OVER VARNISH
                                                              COATER
                                                                         1	
                                                                                                                    COLOR 4

                                                                                                                   .  .COLOR 3
                                                                                                               INTERr
                                                                                                                      COLOR 2

                                                                                                                   COLOR 1
                                                                                                                       VARNISH  TRAY
                                        NECKER AND
                                         FLANGER
                                                                                                                OVEN
                            Figure 2-1. Diagram  of  two-piece  aluminum  can  fabricating  and  coating operation.

-------
  COATING
   TRAY
              APPLICATION
                ROLLER
                                             WICKETS
                        ^\
                           r\+T*- PRESSURE
                        I  /   \J    ROLLER
SHEET (PLATE)
   FEEDER
BASE COATER
WICKET OVEN
SHEET (PLATE)
  STACKER
                                           Figure 2-2.  Sheet  base coating  operation.

-------
      The sheet printing or lithograph operation (graphic arts)  usually




consists of applying one  or two colors  of ink either on the exterior base




coat, the size coat,  or directly on the  metal.  A varnish is applied directly



over the wet  inks.   Inks are applied by a series of rollers transferring the




design first to a blanket cylinder,  then onto the  metal sheet as shown  in




Figure  2-3.    The transfer of inks  is  influenced by environmental factors




such  as   temperature,  draft  and humidity because the inks can become




emulsified in the presence of water.   Varnish is applied to the  metal sheets




by  a direct roll  coater.   Inks and overvarnish are cured in a wicket oven




similar to but usually  smaller than the base coat oven; exhaust rates are




1,500 to 8,000 SCfttl.    If the required  design has more than two  colors, the




first set of inks is dried in an oven.   Another set of inks is then applied




followed by an overvarnish and then baking in an oven.




      During the past several years,  ultraviolet light curable inks have




been developed which permit the application of up to 4 colors in a single




pass.   In addition, some printing  inks  have been developed that do not




require  an  overvarnish.




      The can fabricating process  is the  forming of cans from the coated




sheets.   Some of  these  cans have flat  surfaces and some are beaded




for  extra  strength.    Figure 2-4 describes a beer and  other beverage three-piece




can  fabricating   line.    Sheets are slit into can body  size blanks and fed  into




a "body maker" in which the body blank is formed into  a cylinder.   The seam




is  welded, cemented, or soldered,  and sprayed on the exterior and interior




of  the seam with usually  an air-dry lacquer to protect the exposed metal.




On  some cans other than beer  or other beverage containers, the coating  is usually




sprayed only on the interior.   The cylinders are flanged to provide proper




can end assembly and may  be necked-in depending  on the customer's specifications.
                                  2-10

-------
BLANKET
CYLINDER
SHEET (PLATE)
   FEEDER
                            INK
                       APPLICATORS
LITHOGRAPH
  COATER
OVER-VARNISI
   COATER
                                                                                    WICKET  OVEN
SHEET (PLATE)
  STACKER
                                                   Figure  2-3.  Sheet  printing operation.

-------
                             CAN END, AND THREE-PIECE BEER AND BEVER/GE CAN FABRICA™G OPERATION
ro
                                                   SHEET (PLATE) STACK
                                                              ENDSEAMER
                                                                                               BODY
                                                                                               BLANKS
                                             SCROLL
                                          STRIP  SHEARER
                                                                                                            FORMED
                                                                                                         SOLDERED
                                                                                                        OR CEMENTED
                                                                                    BODY MAKER
                                                                                         SIDE  SEAM
                                                                                           SPRAY
                                                                                       OVEN
                                                         INSIOIr     NECKEA AND FL.ANGER
                                                          BODY
                                                         SPRAY
         PALLETIZED LOAD
LEAK  TESTER
                                    Figure 2-4. Can end,  and three-piece beer and beverage can fabricating operation.

-------
      The  interior  of the cylinder is sprayed with a coating to ensure


a protective  lining between the beer or other beverage and the can.   Cans

used for other products  are typically not spray coated.




      The  spray coating  is usually cured or baked in single pass vertical


or  horizontal ovens at  temperatures of up to  425°F.  The oven  exhaust

rate is approximately 2,000 SCfm.

      Open cylinders  pass through an  "end double seamer" that attaches one


end  onto  the  cylinder.   The cans are tested for  leakage,  then stacked and


palletized   for  shipment.

      Can  ends are  stamped from coated sheets of metal in a reciprocating


press and  the perimeter  coated with a synthetic rubber compound that  functions


as  a gasket when  the  end is assembled on the can.   Solvent-based  compounds are

usually  air dried  and water-based  compounds  oven  dried at approximately  110°F.


The oven exhaust  rate is about 300 SCfm.


      Table 2-1 summarizes some typical oven exhaust  rates,  organic solvent


concentrations, type  of  fuel used for the curing or baking operations, and

control methods used  in  the can industry.


      Typical organic emission rates for can coating  lines are  listed in


Table 2-2.   For sheet coating lines,88 to _9|jiercent-0f ^thfi  solvent:_ i S^ estimated


to  be evaporated  in the  Oyen._  For interior coating,  side seam  and coating

and end sealing compound  line ,  most of the solvent evaoorates  in  the

                  1 4
coating   operation.  '

2.3  Special  Considerations


      Independent manufacturers have less  "ontrol over the coatings used

thar captive  manufacturers because the  ""dependents must satisfy  a broad


range of  customers' product needs and Specifications. An independent may


Ure as many as  300  different coating  for jlations.



                                   2-13

-------
TAME 21 OPERATIOH OF TYPICAL CM COATING  FACILITIES
                                          EXHAUST GAS
                                            SOLVENT
_ PLANT
ShWt Coating



Two-Piece Cans
Sheet Coating
Sheet Coating,
ro
£ Three- Piece Cans,
Two-Piece Cans



Sheet Coating,
Three- Piece
Cans and Ends

'hree-Piece Can
Fabrication (only
beer and beverage
PROCESS
Shget Base Coating
(fiJteriOr * interior)
Sheet Printing
Side Seam
Interior Body Spray
Exterior Base Coat
Lithograph, and
Overvarnish
Interior Body and
Exterfor End Spray
Exterior and Interior
Base Coat
Sheet Lithograph
Sheet Exterior and
Interior Base Coat
Sheet Printing
Side Seam
Interior Body Spray
Two-Piece: Exterior
Base Coat
Lithograph
Interior Body Spray
and End Spray/Rollcoat
Sheet Coating
Side Seam
Ends
Side Seam
'nterior Body Spray
OVEN
TEMPERATURE (*F)
400
380
Air dried
300-350
385
385
365
400
380
350-400
315
Air-dried
300
400
325
225
350-4Z5
Air -dried
Air -dried
Air-dried ,
300-350
OVEN EXHAUST
HATE IN SCW
8,000-10,000
4,000-5,000

2,000-3,000
6,800
4,000
2,000
6,000-6,00^
3,500-4,008
4,900
3.508
2,200
2.200
2,000
2,200
8,000-9,000

7,000
CONCENTRATION
tia
12
10-12

lo-12
8-15
8-15
8-15
5-10
5-10
5-15
3-12
10-15
5-15
5-15
10-15
10-15
-
10-15
FUEL
Itotural Gas
Natural Sas

Natural fits
natural
Gas
And
Propane
Backup
Natural
fiat And
Propatw
Backup
Natural
Gas
And
Propane
Backup



Satural
Gas
AM
Propane
Backup

Natural
Gas
CONTROL ftETHOO(S)
Each oven has a thermal incinerator
All OVtni ducted into one
incinerator.
None.
Some water-borne.
Single 20,000 ScflR thermal
incinerator, primary and
S«COndary heat recovery.
Use some water-borne; plan on
gO in) to water-borne, high-
solids and UV coatings. Use
WV for SOT* Inks.
CrUlytic incineration, plan
on goinQ to water-borne and
high-solids.
Plan on going to water-borne.
tV1gh-Sol1ds, and no-var Inks.
None.
Water-borne on some lines
Plan on going to water-borne
and high-solids.
Plan on going to water-borne
varnish or no-var inks.
Wse water-borne on some lines.
Carbon adSOrtar (feting replaced
by a catalytic inc1n»rator).
None.
Use some water-borne coatings.
None.
"Ion,-.

-------
                              Table  2-2  ORGANIC  SOLVENT  EMISSIONS  FROM  CAN  COATING  PROCESSES

Sheet
Sheet
Beer
Process
>".cJ coating line
lithographic coating line
and beverage can- side
Typical volatile organic
emissions from coating
line, lb/hr
112
. 65
12
Estimated fraction
of emissions from
Coater area
9-12
8 11
100
Estimated fraction
of emissions from
oven
88-91
89-92
air-dried
Typical organic
emissions,
tons/yr"
160
50
18
  seam spray coating process

Beer and beverage can-interior
  body spray coating process
54
75-85
15-25
80
Two-piece can coating line
End sealing compound line
86
8
uncertain
100
uncertain
air-dried
260
14
    •r.-ip-ii . solvent  emissions will vary  from line to  line  as a result of line speed, size  of can or sheet being
               *  'PS of  coating used.
         upon normal  operating conditions.
                                                                                                                             \
                                                                                                                             V

-------
      Interior  coatings must comply with (J. S. Food and  Drug Administration




(FDA)  Regulation No.  121.2514 if the cans are to contain edible products.




The FDA determines  compliance with the regulation through a  lengthy test




program.   First, the coating must be tested to verify that all of the




components in that  coating are specified in the FDA list of approved components.




Other tests must be performed to verify that extractables from that coating




are less than 50 ppm.   If a coating contains new components  not previously




tested by the FDA,  an extended period may be required for suitable testing.




      Frequently, the customer also performs long-range storage tests  (as




long as 18 months)  with the  interior coating in contact with the product to




determine if there  is any change in the product.    Interior coatings must prevent




the product from reacting with the can,and the coatings must not react with




the product to  alter its taste, odor,  or color.  Exterior coatings must  meet




requirements for flow,  gloss,  color,  hiding, adhesion, fabrication, blocking,




pasteurization, and retorting temperature resistance.  Both  exterior and interior




coatings are applied in very thin films, usually  round 0.0003 inches.   In  the



can  industry, film  thickness is expressed in mg/sq. inch; most range  from  1 to




15.




      Plants subject to interruptions in natural gas suooly  tynically  use




liquefied petroleum gas (LPG) as backup fuel  for can ovens.  Sulfur dioxide




and other products  of combustion of fuel oil may contaminate   the   coating




and affect  product  taste.   However, if  less efficient  indirect fired  ovens




are  employed, fuel  oil  is  acceptable.




      Most can  (coating ovens are designed to operate  at  25  percent of  the




lower explosive limit  (LEL). Some  can manufacturers,  especially independents,




operate their ovens at only 5 to  15  percent of the LEL. This is  less efficient




from both an energy and air pollution control standpoint because larger




volumes of air  must be handled and processed.   Some of the  reasons cited for







                                   2-16

-------
operating at  lower LEL  levels are:   the variety of temperatures and speeds




required for  different  coatings,  diverse sheet sizes, air volume distribution




requirements,    uneven evaporation rates,  and the tendency of LEL sensing  devices




to foul.  Coaters that  use uniform coatings and coat uniform sizes of cans or




sheets  are more  likely  to operate their ovens closer to 25 percent of the LEL




than COaters which use  a  large variety of coatings.



      Equipment  used for  can coating and fabricating varies with age and type




of cans coated and manufactured,  therefore, the ease of application of pollution




control  technology  will   vary.   Some existing equipment can apply  low   solvent




coatings without major  costs and alterations;  other  equipment  must be  replaced




or  extensively   modified.   Also,  add-on control equipment is more costly  to




retrofit to some lines  than others depending on the  extent of  line equipment




alterations and  structural  changes.




      The following  sections discuss the use of incineration and carbon




adsorption, and  conversion to water-borne, high-solids, powder, and ultraviolet




curable coatings to  reduce  organic emissions.




2.4  Available Control  Technology




2.4.1 Option  1  - Incineration




Achievable Reductions - Reductions of organic emissions of 90 to 98 percent




from can coating ovens       are achievable using non-catalytic incinerators.




At least 90 percent  control  is attainable by catalytic  incineration systems.




Technical   Analysis:   Catalytl   Incineration -  Catalytic incineration  frequently




can oxidize organic  emissions efficiently at catalyst inlet gas stream




temperatures of  500  to  600°F and outlet  gas temperatures of 750 to 1 ,000°F.
                                 2-17

-------
       Catalysts used in catalytic  incineration are usually made of
platinum  and  therefore,are   relatively  expensive  and  may  be  poisoned.
Its  activity  or  effectiveness  is  adversely  affected  by  normal  aging,
high  temperature,  and   participate   matter,   sulfur   oxides,   and  other
contaminants.     Natural  gas  or  propane  are  the  preferred  fuels  for  catalytic
incineration  because  their   combustion   products   will   not  adversely  affect
the   catalysts.   Normal catalyst  life  on  a  can  coating  line  can  be  2  to 4
years  if  the  catalyst  is  not subjected  to  overheating, due  to  higher  inlet
temperatures  and/or   higher  concentrations,and  is   not  poisoned.
       Catalyst   efficiency   may  be  monitored  by  a  hydrocarbon  analyzer   or  in
terms  of  temperature  rise   and/or  pressure  drop  across  the  bed.  Routine
inspection  and  periodic  cleaning  are  needed  to  insure  optimum  oxidation
of  volatile  organics.
       For  details  on  catalytic   incineration,  refer to   Volume  I,   Section
3.2.2  of  this   series.
       Table  2-3  presents   a  comparison  of  burner   fuel  requirements  for
catalytic  incineration  with  and  without  heat  recovery  for  two  flow  rates:
5,000  and  15,000 scfm.   As  shown   in  Table  2-3,  fuel  requirements  decrease
with the use of heat recovery.   When  using both   primary  and  secondary  heat
recovery,  a  net  line  fuel savings  is possible  with  use of  incineration
if  all   the  energy   available  for  recovery  can   be  utilized.   As  the  temperature
of  the  inlet  process  gas  stream   increases  and/or  the  concentration  of  organics
in  the  gas stream  increases  above  15   percent LEL,  the   potential  net  fuel
savings using  both  primary  and  secondary heat  recovery would even be greater.
As the  gas stream concentration approaches 25 percent  LEL,  the fuel  value  of
the   oven  exhaust  stream   increases.   If  all  other  factors  remain   constant,
                                     2  18

-------
       TABLE   2-3   BURNER  REQUIREMENTS  FOR   CATALYTIC  INCINERATION
                        WITH VARYING DEGREES OF  HEAT RECOVERY
                                                              a,5
          Method
                                         Process  gas flow rate into
                                         i nc i nerator,  SC fm
5,000
15,000
Catalytic incineration,  no heat
  recovery

  Burner requirements,  10  BtU/hr

    Net

    Gross

Catalytic incineration with
  primary heat recovery

  Primary heat exchanger efficiency,
    percent

  Burner requirements,  10  Btll/hr

    Net

    Gross

Catalytic incineration with primary
  and secondary  heat recovery
 1.69

 1.80
36.8
 0.26

 0.27
 5.07

 5.39
36.8
 0.77

 0.82
Secondary air flow, scfm
Secondary heat exchanger efficiency,
percent
Heat recovered, 10 BtU/hr
Net fuel savings, 10 BtU/hr
15,000
53.8
1.33
1.07
45,000
53.8
3.99
3.22
 300°F process inlet gas  stream,  15 percent LEL  concentration.

 Energy that may be used  for energy using facilities  other than an
 incinerator.
                                2-19

-------
the  temperature  of  the  catalyst  bed  will  increase  and  its  design
temperature  may  be  exceeded.   Therefore,  the  operator  may  not  always
be  able  to  utilize  all  of  the  energy  potentially recoverable  with  a
primary   system.
Technical   Analysis:    Non-Catalytic  Incineration  -  Many   organic  emissions
will  oxidize  at  temperatures  of  1,100°F  to  1,250°F.  Cellosolves  (TM),   toluene,
xylene,  and  some  other  organics,  however, require 1,400°F  to 1»500°F.   Effective
Oxidation  is  also  dependent on  residence  time  and  mixing  in the  incinerator.
Partially  oxidized  compounds  can  be  formed  1f   non-catalytic  incinerators  are
not  maintained  at  proper  oxidation  temperatures  and  residence  times.   Non-
Catalytlc  incineration  will  also  increase  NO,  levels  somewhat  over  those
experienced  with  Catalytic  units.
       For  details  on  non-catalytic  incinerators,  refer  to  Volume  I,   Section
3,2.2.
       Table  2-4  presents  a  comparison  of  incinerator  fuel   requirements  for
two  flow  rates (!5,000  and   15,000  scfm)  and  two  cases:  with  and  without
heat   recovery.   Fuel   requirements   decrease   with  primary  heat  recovery,more   so
with  both  primary  and  secondary   heat  recovery.  A net  fuel  savings   may  accrue
by  using  both  primary and  secondary  heat  recovery  if  all  of the  recovered
energy  can  be  utilized.   Moreover,   as  the   temperature   or  organic  concentration
of  the   inlet  process  gas  stream  increases,   there  will  be  an even  greater  net
fuel  savings  if  the  available  heat  can  be  utilized.   However,   the  can
coaters  may  often apply  a  variety  of  coatings  on a line  at  various  organic
solvent   contents   resulting  in  varied  emission  concentrations  and   variable
fuel   requirements.
      As  shown  in Table   2-1,   some   can   coaters  are  presently using  incineration,
typically  with  45   percent   efficient   primary  heat  recovery,   to  control  emissions
from   sheet  coating   facilities  and  two-piece  can  coating  facilities.  Some
                                        2-20

-------
      TABLE   2-4   BURNER   REQUIREMENTS   FOR  NON-CATALYTIC   INCINERATORS
                         WITH  VARYING  DEGREES  OF  HEAT  RECOVERY3'5
            Method
                                           Process  gas  flow  rate  into
                                           incinerator,   scfm	
 5,000
15,000
Thermal  incineration,  no   heat
  recovery
  Burner   requirements,  10    BtU/hr
     Net
     Gross
Thermal   incineration  with
  primary   heat  recovery
  Primary   heat  exchanger
     efficiency,    percent
  Burner   requirements,   10   Btu/hr
     Net
     Gross
Thermal   incineration  with   primary
  and   secondary   heat  recovery
  Secondary  air  flow,  scfm
  Secondary   heat   exchanger
     efficiency,    percent
  Btu   recovered,  10   Btu/hr
  Net  fuel  savings,  106  Btu/hrb
 4.05
 4.30
38.5
 1.56
 4.73
15,000
 55.2

   1.90
   0.34
 12.16
 12.93
 38.5
  1.66
  5.03
 45,000
  55.2

   5.69
   0.66
  300°F  process   inlet  gas  stream;  15  percent  LEL  concentration.
  Energy  that  may  be  used  for  eneryy  using  facilities  other  than
  an   incinerator.
                                   2-21

-------
secondary  heat  recovery   is   used   for  preheating  the  wickets  on  sheet  coating
 lines,  and  for  the  washers  and  dryers  on  two-piece  can  coating  lines.
Costs  of  Control  Option. -  The  value  of  recovered  energy  does not  completely
compensate   for   added  operating  costs,   Table 2«5 provides  a  comparison  of
estimated  annual  operating  costs  for  various  degrees  of  heat  recovery.         '
These  costs  were  derived   for  "ideal" facilities  using  5,000  and   15,800  scfm
flow  rates  at  15  percent   of the  LEI  concentration.    It  was assumed  that the
cost  of   installation   is  about  40   percent   of  the  equipment  costs.  However,
the varying  degrees  of  difficulty   of retrofitting  an incinerator  to  an  existing
facility  could  increase installation  costs   by a  factor  of  2  to  4.  The  age
and type  of can  coating  equipment,   the  price  of  fuel  and electricity, labor,
wat«*"»  engineering  costs and the  percent operating time where there is  solvent
Input  will  cause  operating  costs  to  vary   for  each   facility.
       Catalytic  incineration  as  shown  in Table  2-5, 1s  less  costly  than  thermal
 incineration in  all  cases  for 5,000 scfm  flow  rates  and  for  two  cases  with  15,000
scfm flow rates.   However,   catalytic  incineration   is  almost  equal   in  cost  to
thermal   incineration for  the  15,000  scfffl   primary  and  secondary  heat  recovery
cases.   As  more   energy  is  recovered,   operating  costs  of   either   type   incinerator
decrease.
       For   detailed  costs   of thermal  and   catalytic   incineration,  see  Valuma  I,
section  4  of  this  series.
Effects   and   Limitations  *   Adverse  environmental  effects   from  incinerators
are mostly  dependent  on  fuels  and  compounds  present  in  the  gas  stream,    If
sulfur  or  nitrogen compounds  are  present,   their  oxides  can  be  generated.
If halogens  are  present,   their  a-cids  will  be  formed,  Sulfur  oxides  will  be
generated  by  sulfur in the  fuel  oil  or in  the  oven  gases. Some  nitrogen  oxides
are always  generated  by  air fixation.
                                       2-22

-------
                                       TABLE  2-5  ESTIMATED  ANNUAL  OPERATING  COSTS  FOR
                                                   THERMAL  AND  CATALYTIC  INCINERATION9'b'5
    FLOW  RATE  INTO INCINERATOR:
        Type   of  Incineration
                                                        5,000   SCFM

                                         Annual   operating     Cost  per ton  of
                                         cost  range,          organics   removed
                                         dollars               range,   dollars
                                    15,000   SCFM
                       Annual   operating    Cost
                       cost  range,          "•"*"
                       dollars
                                                                                                                     	 per  ton of
                                                                                                                     organics    removed
                      range,   dollars

168,560-225,560          169-752

 99,560-156,560          100-522
t\3
CO
Thermal,   no  heat  recovery

Thermal,   primary  heat   recovery
 only

Thermal,   primary  and   secondary
 heat   recovery

Catalytic,   no  heat  recovery

Catalytic,   primary   heat
 recovery   only

i  ,\  »,.  .  (i- i>wv and secondary
 heat  recovery
                                         72,810-91,800

                                         52,550-70,550


                                         39,870-57,850


                                             55,040

                                         45,000-49,950


                                         37,310-45,310
218-918

158-706


120-579


165-550

135-500


112-453
 52,680-109,680


     120,390

 85,450-102,450


 55,060-82,090
 53-366


121-401

 86-342


 55-274
    a300°F   process   inlet  gas   temperature;  5-15  percent  LEl_  concentration range;  $2.00/10   Btu  fuel  cost;   tube  and
    b
 shell   heat   exchangers.
these  calculations  are  based  on  continuous  5000  hours  per  year  operating  time.   However,   due   to   the  variety
 of coatings  applied,  and  often  frequent  coating  changes   in  non-captive   facilities,  the  actual  operating  time
when  organic solvents  are  being emitted  may  not be  5000  hours  per  year.

-------
      The   can   industry  has  generally  avoided  using   fuel-oil-fired   ovens
because  of  potential   sulfur  contamination  that  may  affect  the  product
taste.   Using   fuel   oil  in  the  incinerator  would  necessitate   indirect
heat-exchangers  to  ensure  that  sulfur  compounds  do  not  reach  the  ovens.
      It  is  important  to  note  that the  energy  contribution  of  the   oven  exhaust
will   vary   considerably.   Solvent  will  actually  enter   an  incinerator  from
many  sheet  and  can  coating  facilities  rarely  more  than  75  percent   of the
operating   time  of  that  facility  due  to  coating  changes,  preparation  period,
etc.   During  this  time,  the  oven  and  incinerators  must  be  maintained at
operating   temperatures,  thus   using  additional   fuel.    In   addition,   the
solvent  concentration   will   vary  due  to   coating  composition-,   film   thickness,
line  speed,  sheet  size,  etc.   To  compensate  for  these  variations,   it is
common  tc   install   a  bypass  around  the  primary  heat  exchanger.  Then  during
periods  when  the  exhaust  gas  contains  less  organics,  the  bypass  can  be
throttled   to  maximize  the  inlet  temperature  to  the   incinerator.
       Incineration is applicable for  sheet  coating  facnitieSj_iwo-piece  can
facilities   and  three-piece  interior  body  spray  coati-ng  facilities,because
of  their   relatively   high  oven  temperature   and  organic   concentration
(around  10  percent  of  the  LEL).   Caoturing   and  incinerating  the  volatile
organics  from  side  seam  spray  coaters  and  end  sealing  compound  anolicators
is more  costly  and   energy   intensive  because:  the  exhaust  is  usually  at
ambient  temperatures,   gas   volumes  would   be  large  and  would   contain  relatively
low  concentrations  of  organics ,  and  since  these  coatings  are  air-dried,   there
may be  no  nearby  energy  using  facilities  that  can  benefit  from  the
recovered    energy.
                                      2-24

-------
 2.4.2   Option   2  »     Water-Borne/High-Solids/Powder    Coatings
 Achievable  Reduction,  -  The  potential  reduction  of  organic   emissions   from
 converting  to   water-borne   coatings  and  high-solids  coatings  is  60  to   90
 percent.    This  depends  on  the  solvent  content  of  the  original  coating.
 The  reduction   from  conversion  to  powder  coating  approaches  100  percent.
 Technical   Analysis:   Water-Borne   Coatings   •  Water-borne   coatings  contain
 a  polymer  or   resin  base,  water,  some  organic  "cosolvent"  and  solubilizing
 agent.   The  presence  of  some  organic  solvent   in  water-borne  coatings  is
 necessary   to   improve  stability,   flow-out,   appearance,   as  well   as  to
 depress  foaming,  and   control   the  evaporation  rate.
      Problems   associated  with  conversion   to   water-borne  coatings  often
 vary  due   to   application  characteristics   and  the  type  of  equipment  available.
 The  replacement  of certain  existing  equipment  is  usually  necessary  to
 protect   against  corrosion.
      Water-borne  coatings  may  be  applied  by   conventional  techniques   and
 other   newer  methods.   One. newer-^t4w>dy—currently, jus ed..forsome tK'Q-piece
 beer  cans  is  to  apply a_water.rJbtonie  base  coat on  the, entire  can.  during-the
 final-stages  of  the  cleansing   section,  then  bake the  coating  in an  oven.
 Another  method,  in  the  experimental  stages,  is  to  coat  the  interior   of
 two-piece   cans  by  filling  them   with  a  water-borne  coating,  apolyinq
 a  charge   and   electrodepositing  the   coating particles   onto   the   can.   This
method of  apoli cat ion,  however,   is  relatively  slow  and  might  require
 several  such  units   on each  line.   This  could  be  a disadvantage  to  an  older
 plant  which  does  not  have  enough  room  to  install  these  applications.
      The  temperatures  Of  the oven  zones  have  to  be  adjusted to  avoid
 "Ditt^nq"  the  water-borne  coating   film.     1 though  some  water-borne   coatings
may  require  higher   curing  temperatures,  this   increase  in  energy  consumption
                                      2-25

-------
may  be  balanced  by  a  significant  reduction  in  oven  exhaust  flow  because
Of  the reduced  input  of  volatile organics.
      Water-borne  coatings  are  often  difficult  to clean  up  after  thev  have
dried  because  they  do  not  remain  soluble  in  their  carrier.  Also,  water-
borne  coatings  should  be  protected   in  transport  and  storage  during  winter
and  summer  months.   For  details  on  water-borne  coatings,  see  Volume  I,
section  3.3.1  of  this  series.
Technical    Analysis:   High-SoUds Coatings •  "High-solids"    coatings  have
been  defined  by  various  agencies  as  those  with  volatile  solvent  contents  of
only  20  or  30  percent by volume.   To  convert  a  process to   a high-solids
coating   may  present  application  difficulties   because  of  the  high  viscosity
of  the  material.    To  lower  viscosity,  it  may  be  necessary  to raise  the
application  temperature  by  installing  a  heating  unit  as  well as  changing
the   application   equipment.    For   details  on  high-solids  coatings,  see
Volume  I,  Section  3.3.2  of this  series.

Technical  Analysis:  Powder   Coatings   -  Powder  coatings  approach   100  oercent
solids.    Converting  to   powder  coatings  necessitates  a  major  change  of
application    equipment.    Powder  coating  application  technology  is  being  pursued
in  the  can  industry for  two-piece  can  interiors,  and  has  been  used  for  the
sjde   seam  coating  of   nonHcemented   three-piece  cans.   Powder  coatings   may
also  be   applicable  as  an  overvarnish  on  two-piece  cans.   However,    present
powder  coating  application   technology  has   not  been  perfected  to   produce
the  thin  continuous  film on the  can  at  high  speeds,  as with solvent  or
water-borne.   For  details  on  powder  coatings,  see  Section  3.3.3  of Volume
I  of  this series.
                                       2-26

-------
Cost  of  Control  Options -  The  cost  of  converting  to   water-borne,  high-
solids,  or  powder coatinqs  will vary from  Dlant  to  plant depending  on
the  type  of cans,  and  the   age   and  design  of application  equipment.
Some  application  equipment  may  require   only   small   adjustments   or   the
replacement  of  a  spray  nozzle;   others   will   require  much  more  extensive
modification.
      Water-borne,   high-solids  and   powder coatings  are  often  more   expensive
than  the  pure  organic  solvent-borne  coatings.    With  increased   consumption,
further  development  and  the   increasing   costs   of  organic  solvents,   the  overall
cost  of   low  solvent  coatings  may  become  less  than  conventional  organic
solvent-borne    coatings.
      Secondary  costs  for  conversion  to  low   solvent  coatings   include:
refinements  needed   to  meet  customer's   specifications   and  Federal   Food
and   Drug   Administration   standards.  One  independent  can  company   reportedly
has  spent more  than $4iiOOO,000  in  the   last  3  years  in the development
and   testing  of  water-borne,  high-solids,  powder   and   "exempt"   solvent
coatings.  4'8'9
Effects   and  Limitations -   Some  water-borne,    high-solids   and   powder  coatings
have  been  developed   for  the  can   industry  that  are  comparable  in  performance
to   solvent-borne   coatings;  they  also   comply   with  FDA  standards.  Since
these  coatings  are  new to  th«=»  industry,   many  customers  require   extensive
testing  because   their  differer    friction  characteristics   may   affect  the
mobility  of  the  cans  during  packaging  or they may  change  the  taste  of
the  oroduct.   Many  customers  conduct  independent   tests   to  determine  effects
of  a  coating on their  product.
                                      2-27

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     The  can  industry  applies  very  thin  films   of  coating.  Many  of  these
coatings,such  as  the side   seam  spray  and  interior  body spray coatings,
are  low  solids  (10-18  volume  percent)   coatings  at  6.8  to  6.6 pounds  of
organic  solvent   for   each gallon  of  coating  (minus  water).   Water-borne
coatings  available  for  some   of  those  applications  contain  3.5 to   4.0  pounds
per  gallon  (minus  water).    '    This  represents   about  an  80  percent   reduction
in   organic  emissions  over   conventional  organic   coatings.   Available   water-
borne  and  high-solids  sheet  and   can  exterior   base  coats  and  overvarnishes
can  contain  about  2.2  pounds  per  gallon  (minus   water).   The  sheet  interior
water-borne  or  high-solids base  coats  may  contain  2.2  to  2.8 pounds  per   gallon
(minus  water).
      Water-borne,high-solids  or  powder  coatings  are  not  available  to
replace  all   the  present   organic  solvent-borne  formulations  used  in   the
can   industry.    Therefore,   this  option   is   not   universal.   However,
availability  of  these  systems  is   predicted   to  increase  substantially
over  the  next   several  years.
2.4.3   Control   Option  3  -   Carbon  Adsorption
Achievable   Reductions  «•  Carbon  adsorption  units  can  be  used  to  control
organic  emissions  with  an  efficiency  of  85  to   90  percent.'
Technical   Analysis  •  A   single  carbon   adsorption  unit   may  be  installed  on
one  can   coating  facility or  on  several  coating  lines  together  depending
on  the  location  of  the   coating  lines  and  the  type  of  coating being performed.
      Carbon   adsorption  is  most   adaptable  to"low   temperature"  processes
using  a  limited  number of solvents   such  as  the  can  end sealing  compound  or
the  interior  body  spray  coater  for beer and  beverage  cans,   because
collecting  mixtures  of solvents   can be  difficult.
                                      2128

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      Coatings  in  the  can  industry  may  contain  as many as  ten  solvents.
Because  of  the  difficulty   in  separating-them,   the  recovered  solvent  is
probably  best  used  as  boiler  fuel  for  generating  steam  for  the  regeneration
of  the carbon  bed.    If the  solvent  is  recovered  for  reuse,  additional
distillation  would  probably  be  necessary   to   render   it  acceptable  for  reuse
in  can  coating.
      Process  gas   streams  must  be  cooled  below  100°F  for  carbon  adsorption
to  be  effective.   Also  particulate  collection  may   be   required  since
particulate  matter  will  coat  the  carbon  bed  and  reduce  its  adsorption
efficiency.    Carbon   adsorption   systems  are  not   practical   if  non-filterable
matter  is  present   in  the  gas  stream.   For  example,  silicone   coatings
will  coat  the  carbon  bed  and  prevent  adsorption.   Corrosion  of   equipment
can  occur  if  the  solvents  contain  acid-forming  compounds.   If  the  carbon
adsorption  units  are  located  out  of  doors,  improper  operation  may  be
encountered  on  cold winter  days  unless  care  is  taken  in   the  design.
      An  experimental   carbon  adsorption   system   that  uses  the reco\'Qtd  solvent
as  fuel  to  produce steam  for  the  regeneration  of the  carbon  bed  is  known to
have  been  retrofitted  to  one  can  coating  facility,   a  sheet  coating  line.
This  unit  has not been successful  due  to   plugging  of  the  carbon  bed  by
condensables   and   polymerization  of  some  solvents.
Other  cited  Dr obi ems  are:   h'gh   operating  costs,  water-soluble   solvents
causing-water  pollution,   con  'ling  of   the  carbon  support  screen,  short  useful  life
of  the  carbon,  and  large   fuel  and  water  usage  for  steam  regeneration.    This
system  is  reportedly  being  replaced  with a   catalytic  incinerator.   Many  of
the? a  problems  causing  the  carbon  adsorber  to   function   improperly  were
                                      2-29

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related  to  the   relatively   higher   operating  temperatures   of  the  oven
and  the  mixtures  of  solvents  used.   Carbon  adsorption   is   technically
feasible   for   "lower" temperature   operations  such   as  the  end  sealing
compound,  side  seam  spray or the   interior  body spray  of both  two  and
three-piece   cans.   However,    capture  of  the  volatile   emissions   from  the
sealing  compound  and  the  side  seam  application  areas may   be   difficult
and   costly.   This   technique,  although  technically   feasible,  has   not  been
commercially     demonstrated.    For  details  on  carbon  adsorption,   see  Volume
 I,   Section  3.2.1  of  this series.
Cost  of  Control  Option  » The costs   of carbon  adsorption  systems  to  control
organic  emissions  are  summarized   in  Table  2-6.  These   costs  were  derived
for  an  "ideal"  facility,  where  the   installation  cost  is  about  40 oercent
of   the  cost  of  equipment.    Installation  costs   will   vary  depending  on
the  pi  ant  involved  and  will  be  higher when retrofitting  a  carbon adsorber
on   an  existing   facility.
      The  cost  figures  are  for  carbon  steel  equipment,  although  some  solvents
such  as  ketones  will  require  more  costly  alloys   to  avoid  corrosion,   costs
will  increase also  if distillation   equipment or  filtration of  the process
gas  stream  is  necessary.   For  additional  cost  data,  see  Volume  I,   section
4  of  this series.
                                      2-30

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                                       TABLE  2-6.   CUST OF CARBON  AUSuRPTIOfi. IN CAN COATING
                                                                  INDUSTRY a*
ro

Costs
Installed cost, $
5,000 scfm
15,000 scfm
No credit
for recovered
solvent
162,000
302,000
Recovered
solvent
credited at
fuel value
162,000
302,000
Recovered
solvent
at market
chemical value
162,000
302,000
Annual operating
cost, $
   5*000  scfm
   15,003   scfn

rr"t of collected
sol "'N» hs  > '• " >n

   15,'000  scfm
 60,000
142,000
                                                  145
42,000
90,000
                                     215
                                     105
15,000
 1,000
                                100
                                 -5C
     300  F inlet  process gas temperature;  15  percent  of  LEL  concentration.

     Installation  cost assumed to  be 40 percent of equipment cost.

   'Cost  indicates a net qaitl.

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 Effects   and   Limitations  - The  oven  gas  stream  may  contain not  only  the  organic
 vaoors  from   the  coating  but  also  other  products  such  as   from  thermal
 degradation   and  volatilization  of  resin.   Some  of  these  may  condense  to
 sticky   tar-like   particulates.    In  such  a  case,  the  gas stream  must  be  filtered
 or  scrubbed  upstream  of  the  adsorber  and  the  solid  waste-must  be  disposed
 in  an   environmentally   acceptable  manner.   If the filter  does  not  remove
 these  particulates,  the  carbon  bed  will  foul.   When  solvents  that  are
 miscible  in  water  are  used,  the  condensate  from  the  steam  used  to  regenerate
 the  carbon bed may  have  to be  heated  to  remove  the  solvents  to avoid a
 water   pollution  problem.   Any  boiler  operating  on  recovered  solvent  must  be
 supplementally   fired   because  of   the   typically   low  organic   concentrations
 of  the  process gas  and  the  potential  water  loss  of any miscible  organics
 during  steam  regeneration  of  the  carbon  bed.
 2.4.4  Control  Potion  4  -  Ultraviolet  Curing
 Achievable  Reductions   -   The  curing chamber   is  lighted  by special  lamps
 such  as  mercury  vapor  lights.   Some ultraviolet  curing   lamps  in  the  can
 industry  are   water  cooled  and   some  air  cooled.  The  air cooled systems
 exhaust  at about   3000   scfm.   These   ultraviolet   curable  coatings   are  specially
 formulated  to  cure  in  the  presence of  ultraviolet  light.   These  coatings
although  totally  organic,  may  be  considered  the  equivalent  of  near  zero
 percent  solids  since  little  vaporization  takes   place  during  the  near
 instantaneous     curing.  Theoretically,  UD to  100  Percent  reduction  of  organic
 emissions  is   achievable  when  using  ultraviolet   curing  technology,  however,
                                       2-32

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 there may  be some volatilization of low molecular weight  compounds during



 the   curing  process.  The amount emitted  will  depend  on the coating



 formulation; In addition, ozone generated by the  lamps, is  also emitted.



 (The ozone concentration will  likely never exceed  1  ppm in the exhaust


                                                       12
 air for the ultraviolet systems in the can industry.}     Rapid  curing,



 which can take place in less than one  second,  make the process attractive


                                        13
 for high soeed can coating ooerations.



 Technical Analyses




      Ultraviolet curing technology is becoming more  attractive to the can



 industry partially due to natural gas shortages.   Ultraviolet curing



 technology was first applied on sheet coating lines  to  dry the first  two



 colors (set) of ink quickly such that  another-two  colors of ink could be



 applied in the same pass,  thereby eliminating the  need  for  oven drying the



 first  set.   Research efforts report  some progress  in ultraviolet  curing of



 the exterior base coat, the inks and the  overvarnish in a  single pass,



 followed  sometimes by oven baking the coatings to  achieve the  dtsired



 coating  film  properties.   This would not only eliminate individua" oven



 baking of the base coat and inks,  but would also eliminate almost  a^l



 organic emissions from the oven since all  the coatings  would be ul T3-



 violet sensitive and set before entering the oven.  >L,\3t\'l




      Ultraviolet light curing technology  is also being  considered and in



 some cases used on a limited basis in other areas  of the can industry such



 as the curing-of the exterior  ">f two-piece beer and beverage  cans.  Progress



 in the acceptance  of ultraviole  coatings for can  interiors  will likely be



slow because each must  await  Federal  Food anc Drug  Administration aooroval



 before  they  can be  used.
                                   2-33

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      For  further  technical  details   on  ultraviolet  curing,   see  Volume  I
section  3.3.8  of  this  series.
Cost  of  Control  Options  « The  cost  of ultraviolet   curable   coatings   is
about  twice  as  much  as  conventional  coatings  because  their  use  is  not  wide-
spread,  and  the   chemistry  of  ultraviolet  coatings  is  more  complex.
On  the  other  hand,  ultraviolet  curing   reduces  energy  usage  by  60  percent.
The  cost  of  curing  equipment for  ultraviolet   coatings  is   about  one-fifth
that   of  conventional  ovens.   The  line  speed  for  ultraviolet  curing  is
                                                                          15
comparable  to   if not greater than  that  for  conventional  coating.
Effects   and   Limitations -  Ultraviolet   curing  technology   is  presently
limited   to   thin  semi-transparent  coating  films  although  they   are  being
tested  for   additional   uses   in  the  can  coating   industry.  There  are,   however,
coating  apn 11 cations  (such as  some  can  interiors)  that  will  require  a
matter  of  years  before  acceptable   ultraviolet  curable  coatings   are   available.
2.5   Comparison  of   Control  Options  and  Conclusions
      Incineration  is  a   proven  retrofit  control  system  that  can  reduce
organic  solvent  emissions  from  can   coating  facilities.   Although   inci-
neration  can  require  significant  amounts   of  fuel,   installation   of   primary
and  secondary   heat  recovery  systems   when  feasible,   will  significantly  reduce,
if   not  eliminate   the   incremental   energy  requirements.
      Mater-borne,  high-solids,   powder   and  ultraviolet  curable  coatings   can
reduce  organic  solvent   emissions   to   the  same  degree  as   incineration   and
may  use  less   energy  than  solvent-borne  coatings.    Conversion   to   water-borne,
high-solids,  powder  and   ultraviolet   curable  coatings   has   been   successful
on   some   can  coating  formulations;  however,  many  coatings  are  still   in  the
development  stages   or  are  undergoing  tests   for Food  and  Drug
                                      2-34

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Administration  and   the  packaging  customer  approval.   The   ability  to  convert   to
water-borne,     high-solids,  oowder  and  ultraviolet  curable  coatings  as  a
control  option  will  vary  from  plant to  plant  depending  on  the product.
      Carbon  adsorption  can  be  feasi  fa] e  for  reducing  organic  emissions  on
the  interior body  and  end  spray  area  and oven,  the  end  sealing compound
application  area  and  the  side  seam  spray  area.   Measures  may  be  needed
in  soiac  cases  to  clean  the  process  gas  stream   first.   Because  different
solvent  mixtures   are   used,    the  recovered  organics  may  have  little  market
value.   However,  they  can  be  used  as boiler  fuel  or  be  incinerated.

      Costs  of  controlling   organic  emissions   from  the  can  coating  industry
using  low  solvent  coatings  is  difficult   to determine   because   of the  many
variable   factors   in  the  manufacturing  process.    Incineration  is  the   most
economical  retrofit   control   option  when  combined   with  heat  recovery.
Control  costs  for  carbon  adsorption are  greater  than  incineratic/i  but  approach
that  of  incineration  if  recovered solvent   can  be  used  as  fuel.
      It  may  be  costly  to  collect  and  retrofit  add-on  control  devices  to
reduce  organic  emissions  from   side   seam  spray  coaters,   beer  and  beverage
can  interior  spray  coaters  and  ovens,   and  the  can  end  sealing  compound
coaters  because  75-100  percent  of  the  organic  solvent vapors  are  now
emitted  as   fugitive  emission:   within   the  plant.  Conversion   to  water-borne,
high-solids  or  powder  coatings  is  the  best  control  option  for  those  systems.
Moreover,   conversion   to  water-borne,   high-solids,  powder  or  ultraviolet
curable  coatings  for  the  two-piece   can   coat  nq  lines  and   the sheet  coating
lines   would  be   the  economical   options  i*  ^ceptable.  Otherwise,  incineration
i*with  heat  recovery)  or  carbon  adsoroti'   vwith   solvent  recovery   for  fuel)
is  re<- jrnmended.
                                      2-35

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     If incineration or carbon adsorotion is used to reduce emissions,




the coater can either be covered with a hood which is ducted to the oven




exhaust stream or the coater may be enclosed up to the oven entrance so




that the coater emissions are drawn directly into the oven.



     The control of orqanic emissions from can COatinq facilities will



most likely require a combination of several  control  technologies because




of the complexity of coatings used and their annlication, and the economic




and energy considerations in any Particular plant.
                                 2-36

-------
 References

 1.    Gallagher,   V.   N.,   Environmental  Protection   Agency,   Research   Triangle
       Park,   N.C.    Reoorts  of trips  to  various   can  coating  facilities  in
       1975  and  1976.

 2.    Read,   R.T.,  Recent    Developments  in  Protective  Finishes  for  Metal
       Containers,   Part  I:   Internal"  Organic   Coatings.   Oil   Colour  and
       Chemists  Assoc.   58:   51-56,   1975.

 3.    Holt,   J.C.,  Recent   Developments  in  Protective  Finishes   for  Metal
       Containers,    Part   II:   External  Organic   Finishes.   Oil   Colour  and
       Chemists  Assoc.   58:  57-61,  1975.

 4.    Personal  communication  between   Environmental   Protection  Agency   and
       a  representative  of  American  Can  Company,   December   1975.

 5.    Combustion   Engineering  Inc.,  Wellsville,   N.Y.  Report   on  Fuel   Require-
       ments,   Capital  Cost  and  Operating  Expense   for  Catalytic  and   Thermal
       Afterburners,   prepared   for  the   U.S.   Environmental  Protettion   Agency
       under  Contract  No.   68-02-1473,   (Task  No.   13)  EPA-450/3-76-031.

 6.    Ansfield,   J., Powders   Competition.   Canadian   Paint   and  Finishing.
       December  1974.

 7.    Henning,   C.C.,  and   M.J.  Krupp.,  Compell  ing  Reasons  for  the  Use  of
       Water   Reducible  Industrial   Coetings.  Metal   Finishing.   October   1974
       po 57-61.

 a.    Water-Borne   Coatings  Developed  for  Beer,  Soft  Drink  Can   Interiors.
       Industrial  Finishing,  December   1974.  p  76.

 9.    Landauer,    L.,  and  C.E.  Scruggs,  New  Can  Coatings  to  Meet  Air  Quality
       Standards    - Status  Report.   American   Can   Company,    Barrington,    Illinois

10.    LeBras,  L.R.,  PPG  Industries,   Pittsburgh,  Pa.,   Letter  to  Vera   Gallagher
       in  comment to  draft  of this  document.    Dated  August  13,   1976.

11.    Carlson,  D.T.,  Coors   Container   Corporation,   Golden,   Colorado.   Letter
       to  Vera  Gallagher  in  comment  to   draft   of  this   document.   Dated
       September   13,   1976.

12.    Sal lee,  Elgin D.,  Ultraviolet   and  Other  Metal  -  Decoration  Processes,
       American  Can  Company,  September   24,  1975.

13.    Shahidi,   I.K.,  J.C.   Trebellas,   and  J.A.  Vona.   Improving UV   Cured   Can
       Coatings.    Celanese  Chemical  Company;  Modern   Paint   and  Coatings;  Summit,
       New  Jersey,  July  1375.  pp   21-26

14.    Capron,   J.W.  and  R.C.  Heininger.   Continental  Can  Corporation,   Thor
       V  Solventless   Metal   Decorating for  Three-Piece   Cans,   Background.
       Preoared  for  the   U.S.   Environmental   Protection  Agency,  1976.
       Series 600/2-76-011

15.    Radiation  Curing  Goes  Begging  for  Coaters.    Iron  Age.   August  18,    1975
       pp  43-52
                                       2-37

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                                 3.0 COIL COATING

 3.1  Summary  of   Control   Technology

            Affected                                                 Percent
            facility                     Control  Option            Reduction
       Coil  coating  line           Therial   incineration          90-98
                                     Catalytic    incineration           9 0
                                     Water-borne  &  high-           70-95
                                       solids    coatings
 Coil  coating  line  consists of  tbe  coater(s),  the oven(s)  and  the  quench  area(s),

3.2  fienera^ tHstnrsstQn
       Coil  coating  is  the  coating  of  any  flat  metal  sheet  or strip  that
 comes  in  rolls  or  coils.1    The metal  is  typically  roll  coated  on  one  or
 both  sides  on  a  continuous  production  line  basis.  The  metal  may  also
 be  printed  or  embossed.    The  coated  metal  is slit  and  fabricated  by
 drawing,     stamping,  roll -forming,   or  other  shaping  operations   into
 finished  products   to  be used   for  cans,   appliances,  roof  decks,  shelvinq,
 industrial  and  residential   siding,   cameras,  culvert  stock,   cars,   gutters,
 and  many other  items'.
       "Toll"  and  "captive"  coaters  represent  the  two  basic  divisions  of  the
 industry.   The  toll   coater  is  a service  coater  who  accepts  orders  to
 coat  metal   according   to  his   customers'   needs  and  specifications.  The
 captive  coater  both  coats   the  letal  and  fabrisates  the  product  from  the
 coated  metal  within  the same   plant  or   corporation.   Some  coil  coaters  are
 both  captive  and  toll  coaters.
       Coil  coating  plants  are  tyoically   lo  ited  near  industrial  areas  to
 reduce  raw  material  shipping  time  and  cr  .   About  half  of the  U.S.  coil
 coatv  ]  plants  are   located  in  Peimsylvan  ,   Illinois  and Ohio.  On an EPA

                                        3-1

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regional   basis,  Region  V comprises  about 46  percent of the coil  coalers
and  Region  III  about   28  percent.   Plants  vary  in size  based on  the
number  and the  size  of  the  coil  coating  lines.
      Coil  coating  lines  vary  in  the  maximum width  of  metal  they  are capable
of  coating.    The  lines  can  coat  metal  widths  ranging  from  0,50 to ?2  inches
and  thickness  ranges   of  approximately  0,005  to  0.090 Inches,   11  ne  speeds
can  range  yp to  400 feet  per minute  with plant to go  as high  as 800  feet
per  minute.    Some  common  coil   coating  line  sizes  are  18,  26,  48,   54, 60
and  66  inches.
      Coil  coating  line   emissions  come  from  the  Coating area,  the preheat
and  baking zones  of the oven,   and  the  Cjueneh  area,  These  emissions  are
mainly  volatile organics  and  other  compounds,   such  as   aldehydes,  that
result   from   thermal   degradation  of   volatile   organics,   Emissions  from   the
combustion of  natural  gas,  which  is  typically  used  to  heat the  ovens,   are
carbon   monoxide,   unburned  fuel,  nitrogen  oxides,   and  aldehydes.   If fuel
oil  is  used   to  heat  the  ovens,  sulfur  oxides  and  greater  quantities of
                                                           2
nitrogen  oxides,and partiClllates  may also  be  emitted.
      The  major  emissions  from  a  typical  coil   coating  operation  are
summarized  in Table  3-1.
TABLE  3-1  EMISSIONS MEASURED  F-ROM  AN  UNCONTROLLED  NATURAL  GAS FIRED  COIL
                 COATING  OPERATION   USING  SOLVENT-BORNE  COATINGS
	Pollutant	Amount   emitted	
   Hydrocarbons                        1.0  Ib/lb of  coating  apolied
   Carbon   monoxide                     1,10  lb/103 ft3 gas  fired
   Nitrogen   oxides                     0.20 lb/103 ft3  gas  fired
      (as N)2)
   Aldehydes                            0.020  Ib/lb  coating   volatiles
      (as   formaldehyde)                 applied when water quench  is  used
   Aldehydes                            0.027  Ib/lb  coating   volatiles
      (as   formaldehyde)                 applied when air  quench  is  used
                                      3-2

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3.2.1 Materials  Used-  - The metals coated in the  coil  coating industry
include various  aluminum alloys;  steel; plated steel;  steel alloys; and
some  zinc, brass  and  copper.
      Some plants may use as many as 900 different coatings,  each containing
four  to ten  different  solvents,  and some use as much as 40,000 gallons of
coatings  oer  month.   ADDfOXimate weight percentages of volatiles in
coatings most often applied in the coil coating industry are shown in
Table 3-2.

               TABLE  3-2 COATINGS USED IN  COIL COATING4'5
                                                      Volatile
         Coatings                                (weight  percent)

      Acrylics                                        40-45
      Adhesives                                       70-80
      Alkyds                                           50-70
      Epoxies                                         45-70
      Fluorocarbons                                    55-60
      Organosols                                     10-15
      Phenol ics                                       45-50
      Plastisols                                        0-50
      Polyesters                                       45-50
      Silicones                                       35-50
      Vinyls                                         60-75
       Dacromet  (TM)
     The  solvents most often used in the  coil  coating industry include
xyl ene» tol uene ,  methyl ethyl ketone,  Cellosolve Acetate  (TM) , butanol ,
diacetone alcohol,  Cellosolve (TM) , Butyl fellosolve (TM) ,  SolveSSO 100
and  150  (TM),  isophorone, butyl  carbine"1   mineral spirits, ethanol ,
nitrOD,X>Dane, tetrahydrofuran, Panasolv  ?TM) ,  methyl  isobutyl  ketone,

Hisol 100 (TM),  Tenneco  T-125 TM)t isopi -panol »bd  di isoamyl ke ^ne.
                                   3-3

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3.2.2 Processes  and Affected Facilities  -  Configurations of coil coating




lines differ from one another.   On some lines,  the metal is uncoiled at




one end of the  line and recoiled at the  opposite  end.  On other lines, called



"wrap  around" lines, the  metal  is uncoiled  and  recoiled at about the same




point  on the  line.   Some  coil  coating lines have a single COater and one




curing or baking oven;  others  called "tandem" lines,  have several successive




COaterS each followed by  an oven  so that  several different coatings  may be




applied  in   a  single  pass.   Figure 3-1  is  a  schematic  of a "tandem" coil




coating  line.




     The metal on the coil  coating line is  moved through the line by power-




driven rollers. It  is uncoiled as the process begins  and goes through a




splicer, which joins one  coil of metal  to the end  of  another coil for




continuous, nonstop production.   The metal  is then accumulated so that




during a splicing operation,  the accumulator rollers  can descend to pro-



vide a continuous  flow  of metal  throughout the  line. The metal is cleaned




at temperatures of  120°F  to 160°F» brushed, and  rinsed  to remove dirt,




mill scale, grease,  and rust  before coating  begins, The metal is then




treated for corrosion protection and for  proper coating adhesion with




various pretreatments,depending on the  type of  metal  being coated and the




type of coatings applied.




     The first or "prime"  coat  may be applied on one  or both sides of the




metal by a set of three or more power-driven  rollers.    The  "pick-up"!  roll,




partially immersed  in the coating,  transfers the coating to the applicator




roll.   The  metal is coated  as  it passes between the applicator roll  and




the large back-up roll.   The  metal is typically reverse roll coated.
                                3-4

-------
                       ACCUMULATOR
                                                                                                                        ACCUMULATOR
OJ
i
                                                                                   PRIME
                                                                                  COATER
                   PRIME
                   OVEN
           PRIME
          QUENCH
                                         METAL  CLEANING  PRETREATMENT
                                                                          /T
       UNCOILING
        METAL
TOPCOAT
COATER
TOPCOAT
 OVEN
TOPCOAT
 QUENCH
                                                  SHEAR
LJ     U
   RECOILING
     METAL
                                                         Figure 3-1. Diagram of coil coating line.

-------
Figure  3-2  is a schematic of a typical rollcoater. A third  roll, Called




a "doctor"  rol1,may  be used to control film thickness when  applying a nigh




viscosity coating,by making contact with the  "pick-up" roll.




     The applied  coating is usually  dried or baked in  continuous, mul ti -




zone,   high  production  cateaary, flotation, or double-pass oven.  The




temperatures of the preheat, drying or baking zones may  range from 100°F to




1000°F  depending  on the  type and  film thickness  of coating used,  and the




type of metal  being  coated.  The  flow rates of the ovens' exhaust may vary




from approximately 4000  SCfm to 26,000 scfm. Many of these ovens  are




designed for operation at 25 percent  of the room-temperature lower




explosive level when coating at rated solvent input. As  the  metal exits



the oven, it  is cooled in a quench chamber by either a spray of water or a




blast of air  followed  by water cooling.




     A  second  coat or  "topcoat" may be applied and cured in  a manner similar




to the  prime  coat.  The topcoat oven,  however,  is usually longer than the




prime  coat oven and contains more  zones.




     Another method of applying a prime coat  on  aluminum coils or a Single




coat on steel  coils is to electrodeposit a water-borne coating to either one




or both sides  of the coil.  The coil  enters a V-shaped electrocoating bath




that contains  a roll on the bottom.   As  the metal goes around the roll,




electrodes on  each side  can be activated and permit the  coagulation of the




paint particles on either one  or  both surfaces  of the  coil.  The coated coi ]




is then rinsed and wiped by squeeges  to remove the water and  excess paint




particles.    For steel  coils, the  electrodeposited coating must be baked in




an oven.  For  aluminum coils, however,  the prime coat is stable enough to
                                    3-6

-------
                                                                                  INTO OVEN
                         APPLICATOR ROLL
PICKUP  ROLL
           FLOW OF  METAL INTO COATER
                                 Figure 3-2. Typical reverse roll coater.
                                                3-7

-------
 immediately go over rolls to the topcoat coater without destroying  the


                                                6

 finish,  and then be baked as a two-COdt system.



      After   cooling,  the coated metal passes through another accumulator,  is



 sheared at the spliced section, usually waxed, and finally recoiled.  The



 accumulator rolls rise during the shearing process, collecting the  coated



 metal  to ensure continuous production.   Table 3-3 summarizes the ooeration  of



 typical  coil   coating  facilities.




      Organic vapors are emitted in three areas of a coil coating line:



 the area where  the  coating is  applied,  the oven, and  the  quench area.  The



 oven  emits approximately 90 percent of the organic vapors and a majority



 of the other pollutants.   Of the remaining 10 percent of hydrocarbons emitted,



 approximately 8 percent are emitted from the coater area and approximately



 two percent are emitted from the quench area.  »   Organic vapor emissions



 from  a tested uncontrolled coil coating facility,  reported as methane, are:


                                                                117
 coater arek 480 ppm;  oven,  4950 ppm; and quench area 100 ppm.    Considerable



 amounts  of aldehydes are also  emitted from the thermal degradation and



 oxidation of volatiles in the  ovens.   Carbon monoxide emissions mainly  result


                                           3
 from  improper adjustments of oven burners.



 3.3  Special  Considerations -  The coil coating  industry has exhibited about



 15 percent annual growth rate over the past decade compared with the 4 to 5


                                                                          8 9
 percent  annual  growth  rate for most other industrial coating industries.  '



The reasons  for this rapid growth include  the  high speed at which the metal  ma;



be coated, the  low  labor costs,  the small  amount of waste that occurs during




 the coating process,  the uniformity of film thickness  (al though the range of




thickness that  can be  applied  may be limited), the savings on plant space,




the Wide variety  of  coatings and  designs available,  and the short changeover



times needed when changing coatings.'
                                      3-3

-------



Line Size Ovens
(in width;
18 inch Prime
Topcoat
26 inch Prime
Topcoat
31 inch Single

31 inch Single

w 48 inch Prime
I'D Topcoat
54 inch Prime
Topcoat
54 inch Prime
Topcoat
60 inch Prime
Topcoat
60 inch Prime
Topcoat
Flow Rate
scfm

4,900
3,400
7,400
12,000
5,000

5,600

25,900
11,700
6,500
12,500
24; 000
24,000
26,000

35,000

Operating solvent
Ternperature°F concentration
(in % LEL)
10-20
600 10-20
?00
700 25 and less
Zoned at Near 25
400-600
Zoned at 25 and less
300-600
900-1100 25 and less
725
Zoned at fjear 25
3CO-600
750 10-15
775 15-25
600 Near 25

Zoned at 25 and less
300-800
Type of
fuel used

Natural
gas
Natural
gas
Natural
gas
Electric

Natural
gas
Electric
and gas
Natural
gas
Natural
gas
Natural
gas

Control Method

NONE

Thermal
incineration
Going water-borne

Plan on going to
water-borne
Catalytic
incinerator
Plan on going to
water-borne
Thermal
incineration
Thermal
incineration
Thermal
incineration
Mme        24,000
Topcoat     24,ooc
Less  than  25
Propane
Thermal
incineration   on
each  oven

-------
     The  captive  coil  coater,  because he fabricates his own product, tends


to  have more control  over the coatings used than the toll coater, v.'ho


must meet the needs and specifications of customers.  New uses for coil


coated metal  are  being found continuously as are new coatings.


     Because of the  different post-forming operations that coated coils


must  undergo, coatings must survive many "acceptance tests",  including adhesion,


impact   resistance, film  thickness, color, sheen, gloss, hardness and  resistance

                            4
to  salt spray and abrasion.    Approximately 65 percent of the coil coated


production is used by the building industry: therefore, the coatings often


must be resistant to  weathering,  must provide durable finishes,  and must


satisf" a product warrant.1'.     Extensive testing (as long as  5 years) may be

                                                6
required before a coating can be commercialized,


     Natural gas  is the  primary fuel used in coil coating,  and propane is


the primary  backup fuel  during curtailments of  natural  gas  or V.'here natural


gas is  not  available.  The coil coating industry consumes less than 1 percent


of the U.S. total gas  usage.   Production has been curtailed  in some plants


because of the  shortages  of natural gas and the lack of availability of


propane  as  backup  fuel!'  In some areas of the country, the gas companies


are not accepting new  orders of natural  gas.   This,  couoled  \.ith increasing


demands for propane are causing some coil  coaters to  use other forms of fuel


such as oil and electricity  to heat the ovens,  or oil to fire the incinerators.


Others  are T0okincj into more efficient methods  of baking.


     The coil coaters  typically try to operate  the  ovens around  25   ercent


of the lower explosive limit (LEL)  as permitted by  the  insurance companies.


Some are permitted to  operate at higher LEL'S under special  conditions and
                                  3-10

-------
  reliable  LEL  monitoring  equipment.   However, present LEL monitoring


  equioment reoortedly requires a high  degree  of maintenance because


  condensate fouls the sensing device.


       It  is  not  always possible to operate at  a high LEL.  Coil coaters


  are not always able to vary the exhaust  flow rates  dynamically from each


  oven to maintain high  LEL's at a  given line SDeed when applying a  tWO-


  coat system.


       On some  coil  coating lines,  the coater is isolated in a room.
 [-^
! Since the oven is maintained at negative pressure,  the  organic vapors


  from the coater room  are Dulled into the oven.  Others  have hoods over the


  coater to exhaust the organic vapors  into the  atmosphere.    f


       Coil coaters are  also faced  with controlling the water pollution from


  their metal cleaning ooerations.   Many have been required to  install water


  treatment systems and have faced the  associated sludge  disposal oroblems.


  Thus, coil coaters are  faced with water pollution control and S\,lid waste

                                                            4
  disoosal costs as well  as those  of air pollution control.


  3.4 Available Control  Technology » The  followinq discusses incineration,


  water-borne and high-solids coatings,  all  of which reduce organic  vapor


  emissions.    Other technically feasible control options  may be used on coil


  coating lines that coat metal for a specific purpose, but  they are not


  yet applicable to the industry as a whole.


       Electrostatically  sprayec DOWder coating  is limited because a complete


  selection of acceptable resins is not yet available  for use  in the  coil


  industry, and the present aoolication technology cannot adequately control


  film thickness and edge overlap.


       The use of electron beam ClirirK  is     .ited because coating formulations


  have P't yet been developed to  satisfy  f  requirements of the coil coating


  industry.    The deficiencies may be relat.   to the chemistry presently used


                                    3 11

-------
                                12
 for these coating formulations. ""Ultraviolet curing  is  limited because it



 is presently restricted to thin semi-transparent coatings.   Moreover,  an



 acceptable variety of such coatings has not yet been developed  for use by



 the coil coating industry.



      The use of carbon adsorption is limited because the high oven discharge



 temperatures necessitate  a large  decree of cooling upstream of the adsorber.



 Further pretreatment would be  required because cracking and nolytnenzation



 of organics form condensable products that can foul or poison the adsorbent.



 (Pretreatment by water scrubbing may produce a potential water pollution



 problem).   Moreover, even after pretreatment by scrubbing  or filtering,  some



 products may still  foul  the carbon bed, resulting in an  inefficient collection



 of organic vapors.   In addition,  there would be little market value  for  solvents



 recovered by this industry because of the mixtures of solvents  used  and  the



 expense required to separate them.



      Carbon adsorption  may be applicable to certain coil COatGPS who operate



 low  temperature  ovens  and use uniform  coating  formulations.  However,  because



 the  industry is  finding new uses for coated coil as  well  as new coatings that



may  poison the carbon,  adsorption is not widely applicable,  especially for



 independent coil coating operations.    If carbon adsorption is considered,  it



 is advisable to  analyze the gaseous and condensable  organics in the gas stream



 vented  from the  ovens to assure such control is practical.    For  further  details



 on carbon adsorption, see  Volume I,  section 3.2.1  of this series.
 3.4.1 Option  1  - Incineration . A reduction of over 90 percent  in organic



 emissions from a coil coating line  is achievable  using either noncatalvtlC



 or catalytic incineration.
                                      3-12

-------
Technical Analysis  -  Catalytic incineration oxidizes organic emissions




efficient!;  at catalyst inlet  gas  stream terrueratures over 500 to 600°F and




Catalyst outlet gas stream temperatures  of 750 to  1000°F.




     The platinum catalysts usually  used in catalytic incineration can be




deactivated  by:  aging or high temperatures,  coating with particulate




matter, or poisoning with contaminants.   Natural gas or propane is the




preferred fuel for preheating  the  gases  (if necessary)  because of its




cleanliness.




     The life of a catalyst on a coi?  coating line is about 1 to 2 years,




depending on the inlet gas stream  temperature, on  the inlet concentration




of  organics, and on other pollutants in  the gas  stream.   At higher inlet




temperatures and organic concentrations, the temperature rise from combustion




of the organic vapors increases;  thus, the exit temperature in the catalyst




may become too high for normal catalyst  life.




     The catalyst can be  poisoned by  certain materials  or coated  5} particulate




such as that from si 1 iconized  coatings.   These will reduce its efficiency if




they are not removed effectively ahead of the catalyst bed.



     Catalyst  efficienctmay  be monitored  by  a hydrocarbon analyzer  or in




terms of temperature  rise  and pressure  drop  across  the  bed.  Such routine




inspection and periodic cleaning can insure optimum reduction efficiency of




volatile organics and possibly a longer  catalyst life.




     For further technical details on  catalytic  incineration,  refer to




Volume I,  section 3.3.2 of this series.




     Table 3-4 presents a comparison of  calculated catalytic  incinerator burner




requirements for three systems:   simple catalytic incineration, catalytic



incineration with "primary"  heat recovery, | ~eheat of gases into the




          >r) and catalytic  incineration wft1 Tl'mary and "secondar*'" h=>at
                                    3-13

-------
                                     TABLE  '3-4 FUEL  REQUIREMENTS  FOR  CATALYTIC  INCINERATORS  WITH
                                                         AND  WITHOUT HEAT  RECOVERS

I LEL
15
25

Gas
twnperature to
catalyst, °F
600
500
Catalytic
Incineration
mo t-teat recovery
Fuel
Requirements
WBtu/hr
Net Gross
1.69
0
1.80
0
Catalytic Incineration with
primary heat recovery
Heat exchanger
efficiency, %
20
-
Fuel
Requirements ,
10 Btti/hr
net eross
0
0
0
0
Catalytic
and
bat exchanger
efficiency, %
5 5
55
Incineration with primary
secondary heat recovery
Heat recovered
by secondary
heat exchanger,
10 Btu/hr
5.58
6.76
Net fuel
rate,
10° Bfu/h
-5.88
-6.76
Process  gas  flow  rate of  15,000 scfm;  process  gas  inlet  temperature  of 500*F

-------
recovery  (recovery of heat  from  the incinerator exhaust for prOGSS heat).




     As can be seen  from Table 3-4, when the concentration of the qas stream




approaches 25 percent of the  LEL,  and the inlet gas stream temperdture




to the combustion chamber is  maintained at about 500°F, a coil coating




line equipped with a catalytic incinerator may use little, if any,




additional energy for the operation of the burner, even without primary




heat   recovery.   A primary heat exchanger without a bypass may not save much




energy because the efficiency of the heat exchanger is limited by the upper




temperature limitations  of  the catalyst.   Klien catalytic  incineration with




only 55 percent efficient secondary heat  recovery is  used, there is a net




fuel   savings , assuming  the recovered heat can be used for process heat.



     Coil coating facilities  are currently using catalytic incinerators to




reduce organic emissions from their surface coating operations.




Technical   Analysis:   Noncatalytic  (Thermal)  Incineration  - Noncatalytic




incinerators will oxidize most organics at temperatures of 1100 tc 1250°F.




Some  organics, however, such as Cellosolves,  (TM), toluene and xyl£fl3



require 1400 to  1500°F  incineration temperatures for oxidation.   Proper




oxidation is also dependent on residence time     (usually 0.4 to  0.6 seconds)




and sufficient mixing.   If noncatalytic  incinerators  are  not maintained




at proper oxidation  temperatures or residence times,  partially  oxidized com-




pounds  can be  formed.   Such compounds,in some cases, may be harmful.




Noncatalytic incineration may also  increase  NO   levels from a source.  For




further technical details on noncatalytic incineration, refer to  Volume I,




section 3.2.2 of this series.




     As can be seen  from Table 3-5, a significant amount of energy is consumed




"'hen n -ncatalytic incineration is  used t^,   educe  organic   emissions.   As  the




organic concentration of the gas  stream  "  ,reaS6S from 15 percent to 25




Percent of the LEL,  the burner requirements are reduced by almost





                                   3-15

-------
                                                                                                                                         \
                                 TABLE   3-5   FUEL  REQUIREMENTS  FOR  NONCATALYTIC  INCINFRATORS  WITH
                                                            AND  WITHOUT  HEAT  RECOVER?
% LEI
15
25
JMoncata-iytic
Incinerator
10 heat, recovery
Burner
Requirements,
10 Btu/hr
Net Qress
9.95
5.59
10.58
5.95
Noncatalytic Incinerator with
primary heat recovery
Heat exchanger
efficiency, %
35
25
Fuel
Requirements ,
KTTJtu/hr
Net
3.14
1.5
Gross
3.36
1.65
Noncatalytic Incinerator with primary
and secondary heat recovery
Heat exchanger
efficiencv, %
55
55
Heat recovered
by secondary
heat exchanger,
10DBtu/hr
6.12
6.73
Net fuel
gate,
10 TTtu/hr
-2.76
-5.23
   Process  gas flow  rate  of  15,000  scfm;  process gas  inlet  temperature  of  500°F;  Incinerator temperature  of 1 »400°F.
CO
I

-------
50 percent  because of the fuel value  of organics. The incinerator would




have to heat only  60  percent as much gas with no change in fuel value.




     Primary heat  recovery (preheating the incoming gas into the incinerator)




will decrease the  burner fuel requirements in the  noncatalytic incinerator



as shown in Table  3-5.   At a gas stream concentration of 15 percent of




LEL, the energy usage will decrease  by about  30 percent with a 35 percent




efficient primary  heat exchanger.   At 25 percent of LEL concentration,




the energy usage will be the minimum required for noncatalytic incineration




using only a 25 percent  efficient heat exchanger.  Installation of both




35 percent efficient  primary and  55 percent efficient secondary heat




recovery system will  result  in a  net fuel savings if all the recovered heat




is used as  process  heat.   Greater heat exchanger efficiencies  will result




in  even  greater  fuel  savinqs.




     Many coil coating  facilities have successfully used either retrofit




or integrated noncatalytic incinerators and both orimary and  SE ondary




heat   recovery  systems.




Cost of Control Option  - Table 3-6 provides a comparison of estimated




annual operating costs and operating costs per ton of emissions removed




by incineration alone and with various degrees of  heat  recovery,  providing




sufficient recovered  energy  can be used.   Operating costs are  based on




an assumed  inlet  process temoerature of  500°F.  For further details on




the cost of controlling  orgari"*" vapor emissions with noncatalytic and




catalytic incineration,  see section 4 of Volume I  of this series.




     The ooeratinq costs for a coi?  coatincj facility using  incineration




wiV  decrease as the  organic concentratior increases,  and as more




is r-covered from  the incinerators to [   JSed for  other energy-usinq




 roc  ses,  as can  be  seen from Table 3-p    The difference  in  00
                             3-17

-------
                              TABLE   3-6  COMPARISON  OF  ESTIWTED ANNUAL ABATING   COST
                                            FOR COIL COATING INCINERATION'3 a
Type of Annual Operating Cost
Incineration at 15% LEL,
dollars
Noncatalytiq
no heat recovery
Noncatalytic,.
primary heat
recovery only
Noncatalytic*
primary and
secondary heat
recovery
Catalytic,
no heat recovery
Catalytic, primary
heat recovery only
Catalytic, orimary and
secondary heat recovery
Catalytic, secondary
heat recovery only
122,580

74,100

34,800


78,850

75,030
39,690
42,710
Ooerating Cost
per ton of
organ! cs removed
at 15% LEL,
.dollars/ton
153

93

44


98

94
50
53
Annual operating
cost per year at
25% LEL
dollars
85,540

61,100

16,910


64,450

not applicable
n
II
19,670
Operating cost
per ton of
organics removec
at 25% LEL,
dollars/ton
71

51

14


54

not applicable
11
16
Process gas  flow rate  of 15,000  scfm at  500°F, 4,000 hr/yr operating  time,   $2.00/10° BTU  fuel  cost,  tube  and  shell heat
exchangers.

-------
costs   for   catalytic   incinerators  with  and  without  primary  heat   recovery
is  minimal  orovided  that  organ!cs  constitute  at  least  15  percent  of
the  LEL  and  oven  exhaust temperatures  are  at  least  500°F.
      For   aoncatalytic   incineration,  the  smallest   annualized  operating
cost  is  realized  when  both  orimary  and  secondary  heat  recovery   are  used.
Catalytic   incineration  without  heat  recovery  was  found  to  have   lower
annualized   operating   cost   than   noncatalytic   incineration  without  heat
recovery.
      If  the  energy  can  be   recovered and used,   incineration  with  heat
recovery  can  reduce  net  energy  consumption  compared  to  a  line  without
an   incinerator.     The  value  of  this  recovered  energy  does  not,  however,
completely compensate  for   other  operating  costs,   and  incineration  will
invariably   increase  overall   operating   costs.   In  addition,  there  is  40
percent  more  gas  to   be   treated  for  a  given  solvent  amount,   with  resultant
increased  capital  cost,  at  15  percent of the  LEL than  at  the same  plant
at  25  percent of  the  LEL.
      These  costs  did  not  include  enclosing  the  coater  area  or   installing
hoods  to  duct  the  coater  exhaust  into  the  oven  exhaust.  Also,   these  costs
were  based  on  an  "ideal"  facility  where the   cost   of  installation was  about
40  percent  of  the cost   of   equipment.   The  degree  of   difficulty   of  retrofitting
an  incinerator   to an  existing  facility  will   likely   increase  the  installation
and   engineering  costs, therefore,  increasing  the cost oer  ton  of  organics
removed ,.
Effects   and  Limitations   -Adverse  environmental   effects   from  incinerators
are mostly dependent,  on  the  compounds nr  ..  _:it  in  the inlet  gas  stream.    If
sul,  T  comoounds  are  present  in the  in!    ^as stream  or  in  the   fuel,  their
;xid?   will  be  generated; ff  halogens c ^   present,  their acids  may  be
termed.  Also,   nitrogen   oxides  are  gen?  red  from the  nitrogen  present  in
the  gas  stream.

-------
      Some  of the  particulates  found  in  the  gas  stream,  for example,  from
si1iconized  coatings  may   corrode   or  foul  the  heat  exchanger  tubes.  If
the  incinerator  is  not  preheated   before  the  operation  begins,  condensate
and  other  particulate  matter  formed  in  the  tubes  during  shutdown may   ignite
and  warp  the  heat  exchanger.    In   addition,  catalytic   incineration   may  have
limitations  because  of  catalyst  poisoning  from  some  coatings  used  in
the  coil   coating   industry.
      It  was assumed  in  the cost  and  fuel  usage calculation that  the
exhaust  from both  the  prime and  toncoat  ovens  Is  ducted  to  one  incinerator.
Actual  solvent  input  into  an  incinerator will  rarely  exceed  85 oercent  of
the  operating  time  of  a   coil  coating  line due  to  coating  and  color  changes,
running  out  a  coil  of rejected  metal,  etc.  During  this time,  the  ovens
                                                                      12
and   incinerator  must   be  maintained  at   ooerating  temperatures.     In
addition,   it  is  difficult  to  maintain  an  optimum  percentage  of  the LEL
exhaust  from  each  oven.   The  concentrations  can  vary  wjjftcompositions  of
the  primer and  topcoat,  film  thickness  and  line   speed.  At  higher  LEL's
high  heat  exchanger  efficiencies  can  cause  the   incinerator  to  exceed  its
design   temperature  limits.   To  minimize fuel  usage,  the  primary  heat
exchanger   should   be   designed   to   handle  such  varying   concentrations,   i.e.,
to  maximize  the   heat   exchanger  efficiency  as   the   solvent  input   decreases
and  lower  the  efficiency  as  the  solvent   input   increases.   One method  of
achieving   this  is  to   design a  bypass  around  the  beat  exchanger.  To
ontimize  investment  and   minimize   fuel   usage   and   operating  costs,  each
coil  coating   ooeration  should  be  studied  individually   to  determine
the  most   effective  heat   exchanger  efficiency.  However,  the   coil
                                     3-20

-------
COater will still have to base the choice of an  incinerator with  optimum



heat exchanger efficiencv on the most critical situation.



     The use of tube and shell heat exchangers was assumed in the cost



calculations.    There  are, however,  other types of heat exchangers used j '



the coil CQaterS.   These heat exchangers will  var'  in net efficiencies



and in cost; and include the rotating ceramic  wheel , packed ceramic beds,  air



to liquid heat exchangers and  some others.  In addition,  there  are other



methods of operating ovens and incinerators to achieve optimum heat recover-:



and fuel savings such as;  inert atmosphere baking systems with rich fume



incinerators, and the recycling of solvent  rich  exhaust  through zoned inci-



nerators .



3.4.2  Option  2  -  Water-Borne  and  High-Solid  Coatings



Achievable Reduction - Water-borne coatings are  defined  as coatings that



contain a polymer or resin base, water  and often some organic solvent or



"CDSOlvent" that is miscible with water.   The presence of a certain per-



centage of organic  solvents  in  water-borne coatings is necessary tc



improve stability,  appearance,  reduce the "orange-peel"  effect, depress


                              14
foaming and improve edge-pull.     Water-borne coatings typically used in



coil coating are water-isoluble  coatings.



     High-solids coatings contain a solid composition up to 70



or 80  percent  by  volume.  The remaining portion is organic solvent



necessary for proper application and optimum curing characteristics.



     Table 3-7 lists the potential  percentage  reduction,  in pounds of



organic solvent per unit volume of  coating,which could be realized by



           to water-borne and high-solids  coatings.
                                   3-21

-------
               TABLE  3-7  POTENTIAL  REDUCTIONS  FROM  USE  OF  WATER  BORNE
                                 AND  HIGH  SOLIDS  COIL  COATINGS
                                Pounds  of  organic  solvent         Potential    reduction
Coatinq   formulation            per  gallon  of  coating            by   using  water-borne
 (by  volume)                        (minus   water)                     coatings,  percent


 Water-borne
   32%  solids
 54.4%  water
 13.6%  organic  solvents                2.2


 Orq anlc   solvent-borne
   20%  solids
   80%  solvent                          5.9                                   90


   50%  solids
   50%  solvent                          3.7                                   58


   70%  solids
   30%  solvent                          2.2                                   0
                                            3-22

-------
Technical Analysis - Water-borne  and  high-solids coatings are easily applicable

with roller coating  Systems because the;  have application characteristics


similar  to  organic  solvent  borne  coatings.   Converting to these COStinciS,

however, could present some difficulties.


      High-solids coatings are  difficult  to apply due to high viscosity and may

 necessitate heating of the rolls to  reduce the  viscosity.   This may cause a build-

 up of resin in the rolls unless  a three-roll  roller coating system is used.

 Progress is being made in commercializing medium high to high-solids coatings

 for the  coil  coating  industry.



      Water-borne coatings have different  flow and wetting properties from

 solvent-borne    coatings.   Evaporation of  water from an applied coating

 cannot  be controlled as well as from a solvent  mixture.   Sometimes  coil

 coating line speeds must be reduced to avoid  popping  of the  film.

      Care must be taken to thoroughly clean the metal prior  to  coating

 because any grease will result in lack of adhesion and edge-covering,

 and formation of craters.   Also, care must be taken  in using certain pre-

 treatments,  such as chromic acid, that may cause water-borne coatings to gel.

      Tubes,  shafts,  bearings and other movable  parts  on a COater must  be

 replaced  or somehow protected from the water-borne coating to avoid  corrosion.

 In addition, all the pipes and pumps  must be  replaced with non-corrosive

 materials if the coating is pumped from  a separate storage or mixing area.

 However,  since there exists little fire  hazard  with water-borne coatings,

 it is possible to use"tote-bins"inside the plant.

      Cleaning dried water-borne  coatings  is difficult because they do


 not remain soluble in their carrier.   Water-borne coatings are difficult to

 dispose of,  and are difficult to transnort ard  store  during  the winter
               n
 surlier  months.
                                  3-23

-------
     Electrodeposited water-borne  coatings  have been successfully applied



on aluminum and some Steel coils.   The electrodeposited coated steel is



baked directly after  application of the coating. The  electrodeposited



coated aluminum can be coated immediately with  a topcoat then baked in an



oven.   This system not onl ' reduces volatile  organic emissions but also



the fuel usage and the costs of  a  prime coat  oven.



     For further details on water-borne and high-solids coatings,  see



Volume  I,  section  3.3.1 and 3.3.2 respectively,  of this series.



Cost of Control Option - The cost of converting to water-borne or high-



solids coatings will  vary  from  plant to plant.  Some secondary costs will



result from the necessity to test  the  coating and  its  performance  on the



line, during forming and during  the use of  the  end-product.    It may also be



necessary to alter or adjust the equipment  with which  the metal  is formed



into its  final  shape.



     Some water-borne coatings may require  higher curing temperatures than



organic solvent-borne coatings;  however,  many  do  not.   Increases in



energy maybe counteracted  by  a reduction in  aiir flow through the oven



necessary in organic solvent systems to maintaiin the organic vapor con-



centration below  25  percent of  the LEL.  It is  estimated that in con-



verting to water-borne coatings  ,  d COll COater may  reduce the dilution air


                                                                          14
by a factor of four,  therefore reducing energy  COnSUfflDtlOn by 50 percent.



     Water-borne coatings may be more  costly  than  organic solvent borne



coatings because  industrial consumption is  not widespread.   With   increased



consumption, further  improvements  in  water-borne coatings and increasing



cost Of organic solvents,  water-borne coatings may  become tess 'jxpensfve than
                                 3-24

-------
organic solvent-borne coatings.     High-solid coatings are generally equal




to or more exoensive than equivalent high-solvent coatings.




Effects and Limitations  • Water-borne primers,  backers,and some low to




medium gloss tODCOatS that equal the performance of organic solvent borne




coatings have been develooed for aluminum but have  not achieved full line




speed  in all  cases.'[  For other metals,  such as steel,  the uses are so




varied that water-borne  coatings have not been developed to provide




properties equivalent to all of the present organic solvent-borne coatings




and which can withstand  all post-forming operations.   Some, however, are




in the early stages  of development, but have not reached commercial status.




      Water-borne coatings  can contain on the average about 2.2 pounds of



volatile  organic per gallon of coating (minus water)  as applied.  Medium




high solids  coatings can contain on the average of 3.1 pounds per  gallon




of  coating  applied   (minus  water).





 3.5 Comparison  of Control  Options and Conclusions •




      Incineration and conversion  to water-borne or high-solids coatings




 appear to be the most reasonable  control options for  reducing




 organic emissions from  coil coating lines  because  of  the typically high




 curing temoeratures and the various mixtures of organic solvents found in




 the coatings used by this industrv.   Incineration, coupled with various




 types of heat recovery, has be°n  successfully anplied to existing  coil




 coating   lines.   Similarly, water-borne coatings have  been successfully applied,




within limits,  to several existing coil coating lines.   Over 90 percent




 reduction of organic emissions is achievable with  incineration and 70-95



Dercent reduction is achievable with WfttPr-bom8  coatings, depending on the




Processes and the solvent  level   of the  O1' inal solvent-borne coatings




used.
                                 3-25

-------
      There  are  limitations  on  the  options  from  which  to  choose.  Some
coatings  used   in  the  industry  can  poison  incinerator  catalysts.   There
is  a   lack  of water-borne  and  high-solids  coatings  equivalent  to   organic
solvent-borne  coatings  for  many  metal   uses,   especially  where   resistance
to  corrosion  or  wear  is   critical,  where  severe   forming  operations  are performed
or  where  a high  gloss   finish  is  required.  Incineration,  especially HOD*
catalytic,  will  increase   the   use  of natural  gas  or  other  fuels   if no  nearby
operations   can  use   the   recovered  energy.
      Ooerating  costs  of incineration  for  each ton of volatile  organic  com-
pounds  removed  are  reduced  by  one  half  when  the  concentration  of volatiles
is  increased from  15  oercent  of the  LEL  to  25  percent  of the   LEL.  Cost
per  ton  removed  for  noncatalytic  incineration  could  be  reduced  further  if
concentrations  were   increased  above  25  percent  of  the  LEL.   Such  high  con-
centrations,  however,   for  catalytic   incinerators   would   exceed   their  design
temperature   limits.    If  incinerator heat  is  recovered,   costs  per  ton  removed
can  be reduced by  a  factor of 2  to  5  depending  on  the  extent   of  recovery
and  tyne  of   incineration.   The  most  cost  effective  systems  shown  in this
document  are   noncatalytic   incinerators  with   both   Primary  and   secondary
heat   recovery   and   catalytic  incinerators  with  only  secondary  heat  recovery;
both  oxidizing  exhausts  at 25 percent  of  the  LEL.
      If  incineration  is   chosen as  a  control  option,  the coater   may  be
enclose!  in  a   room.    Since  the   ovens   are   maintained   at negative  pressure,
the  volatile organ!cs  will  be  pulled  into   the  oven through  the  oven  opening.
A  hood may  also  be  installed   over  the  coater  area  to  collect  the  volatile
organ!cs  and  exhaust   them   into   the  incinerator.
                                      3-26

-------
     There does not appear to be a single best control system for the entire




coil coating industry; therefore, each coil coating facility must be con-




sidered separately to determine the most applicable system.
                                  3-27

-------
 REFERENCES


 1.   National   Coil  Coaters  Association;   Fact   Sheet  1974.  National  Coil
      Coaters  Association,   Philadelphia,   Pa.

 2.   A  Study   of  Emissions   from  the  Coil  Coating   Process,  Volume  I.  Scott
      Research   Laboratories,   Inc.,   Plumsteadville,   Pa.,   December   1970,
      Prepared   for  the  National  Coil  Coaters  Association.

 3.  Cosden,  W.  B.,  The  Ecology  of  Coil  Coating,  Metal  Finishing,  November
      1974.   op   55-58

 4.   Gallagher,   Vera  N.,  U.S.   Environmental    Protection   Agency,   Research
      Triangle   Park,   N.C.    Reports   Hf  visits  to  coil  coating  facilities.

 5.  A  Study  of  Gaseous  Emissions  from  the   Coil  Coating  Processes:  Volume  II
      Survey  Results,  Scott   Research   Laboratories,   Inc.,   Plumsteadville,   Pa.
      March   1971,   Prepared  for  the  National  Coil  Coaters  Association.

 6.  LeBras, L.  R.,  PPG  Industries,  Pittsburgh,   Pa,,   Letter  to  Vera  N.  Gallagher
      in comment  to  draft  of  this  document,   letter  dated  August  13,  1976.

 7.  A  Study  of  Gaseous  Emissions  from  the   Coil  Caoting  Process  and  their
      Control,   Scott   Research  Laboratories,   Plumsteadville,    Pa.   October   1971,
      Prepared   for  the  National  Coil  Coaters   Association.

 8.   Hughes,  T.  W.,   D.  A.  Horn,  C.  W.  Sandy,  and  R.  W.   Serth,    Source
      Assessment:    Prioritization   of  Air   Pollution   from Industrial   Coating
      Operations,   Monsanto   Research   Corporation,   Dayton,  Ohio.    Prepared
      by  U.S.   Environmental   Protection   Agency,  Research  Triangle   Park,   N.C.
      under   contract   No.  68-02-1320  (Task   No.   14).   Publication  No.  650/2-75-019a.
      February   1975.

 9.  Why  Coil   Coating  Growth  Continues.    Products   Finishing,   November   1974.
      pp 60-61.

10.  Moorsman,   R.,   Coil  Coating   -  Past   and  Present.  Products   Finishing,
      November   1974.    pp  163-165

11.   Messing,   R.,   Outlook   for  Natural  Gas   Suoply.   (Presented   at  National
      Coil    Coaters   Association  Convention,   Chicago,  Illinois  -  October   3,
      1Q75.)

123.  Mil  on,  C.  L.,  Rnner  Eastern,  Columbia,  Md.,   Letter  to  Vera Gallagher
      in comment  to  draft  of  this  document.    Letter  dated  August  10,  1976.

13.   Combustion   Engineering,   Inc., Wellsville,  N.Y. Report  of  Fuel
      Requirements,    Caoital  Cost  and  Operating   Exnense   for   Catalytic  and
      Thermal    Afterburners.   Prepared   for  the  U.S.  Environmental  Protection
      Agency,   Research  Triangle  Park,   N.C.   under  contract  no.   68-02-1473
      (Task   No.  13).    Publication  No.   450/3-76-031.

14.   An is field,   J.,  Powders    Competition.   Canadian  Paint  and   Finishing,
      December   1974.    pp  41-44


                                      3-28

-------
15.   Heiming,  C.  C.  and  M. J.  Krunp,  Compelling  Reasons  for the  Use  of
     Water-Reducible   Industrial   Coatings.   Metal   Finishing,   October   1674,
     DO  57-61
                                    3-29

-------
                             4.0  FABRIC COATING





4.1  Summary of Control Technology



           Affected            Control system             Percentage

           facility             or strategy               reduction


         Coating  line          Incineration                    95


                               Carbon adsorption              90+


                               Low  solvent  coatings          80-100


 (A coating line consists of the application area and the drying oven.


The application technique may be a roll, knife or rotogravure coater.)


4.2 General  Discussion


      Fabric coating involves the coating of a textile substrate with  a


knife or roller spreader to impart properties that are not  initially


present,  such as strength, stability, water or acid repel 1 ancy  or


appearance.'


      The fabric coating industry is diverse, concentrated in the


northeastern and southeastern portions of the United States, With a wide


variation in products and plant sizes.  The  industry consists mal'.ly of


small to moderate size plants each of which specializes  in  a limited


product  line.


      Most of the industrial facilities located in the northeast are old;


some are over 40 years of age.   (These can be  difficult to  modify to


achieve an air pollution  standard.)  Plants  in this industry, which is


highly competitive,  are usually  located near either the textile raw


material producers or  industries  usinq the coated fabric.


      Coating solutions may be either aqueous  or organic base.  It is  the


 latter that produces  the organic emissions into the atmosphere.   It is


estimated that 36 x 10  kilograms per  v  r  (80 x 10   Ibs per year)  are


emitted in the United States  by  the  VIP1  coated fabric segment of the
          2
 industry.


                                 4-1

-------
      Rubber,  coating  of fabrics is  also  a large  scale  of solvent  emissions,
although  nationwide   emissions   from  this  source  are   not  currently  known.
      ADD!ications  for  coated  textiles   include  industrial   and  electrical
taoes,  tire  cord,  utility  meter  seals ,   imitation   leathers,   tarpaulines,
shoe  material,  and  upholstery  fabrics.
4.2.1   Materials   Used •  Substrates   (textile  materials   used   to   suonort
the  coating)  can  be either  natural  or   man-made.  Coating   of polyvinyl
chloride  (PVC)  substrates  is  covered  in  this  section.
      Coatings   include   latexes, acrylics,   polyvinyl  chloride,  DOlyurethanes,
and  natural  and   synthetic   rubbers.
4.2.2   Processes   and  Affected  Facilities -  The  coating line  is  the  largest
source  of  solvent  emissions  in a  fabric  coating  plant,   and   the  most
readily    controllable.   Some  coating  plants  report  that  over  70  percent
of  solvents  used   within  the  plant  are  emitted  from  the coating  line.
Other  plants,  especially  those  involved  in  vinyl  coating,   report   that only
40  to  60 percent  of solvents  purchased  by  the  plant  are  emitted  from the
               o
coating   line.    Remaining  solvents  are   lost  as  fugitive  emissions-  from
other stages  6f  processing  and  in cleanup.   These   fugitive   losses  are
generated  by:
      1.   Transfer  from  rail   cars  or  tank  trucks  to   storage  tanks,
          and subsequent   transfer   to  processing  tanks.
      2.  Breathing   losses  from  vents  on storage   tanks.
      3.   Agitation  of  mixing  tanks  which are  vented  to  the
          atmosphere.
     4.  Solvent evaporation  from   clean  up  of  the  coating  applicator
          when coating color  or tyoe  is  changed.
                                      4-2

-------
     5.   Handling,  storage and disposal of solvent soaked




         cleaning  rags.




     6.   Waste  ink  disposal.   Waste ink is usually distilled




         to  recover much of solvent.  After  distillation the sludge,




         which  still contains some solvent,   is usually dumoed in a




         landfill.




     7. Losses  from drums used to store coatings which  are being




         bumped onto coating applicator.  These are usually 55 gallon




         drums  which a re not hooded and may not  even be covered.




     8.   Cleaning of empty coating drums with solvent.




     9.   Cleaning coating lines with solvent.




    10. Evaporation of solvent from the coated fabric after it leaves




         the  coating line.   From  two to three percent of total plant




         solvent usage remains in the  product.  Half of  this may




         eventually evaporate into the air.




     Control  techniques for the above types  of  sources  include tightly




fitting  covers  for ooen  tanks,  collection hoods for  areas where  solvent




is  used  for  clean  up,  and  closed  containers  for  solvent  wiping  cloths.




     Figure  4-1 shows a general outline of a fabric coating operations.




The following discussions describe these ooerations and control  options




for the coating line.
                              4-3

-------
         RUBBER
PIGMENTS
CURING AGENTS
                                           SOLVENT
         MILLING
                                              1
                           MIXINB
        DRYING  AND
         CURING
                           COATING
                         APPLICATION
                                                                FAifilC
                        COATED PRODUCT
            Figure 4-i. typical fabric coating operation.

-------
                         COATING
                                          KNIFE
                                              COATED  FABRIC TO  DRYER
                                                                                 EXPANDED COATED  FABRIC

                                                                                                 COATING
                                                                                                        SUBSTRATE
                                                              SUBSTRATE
 i
OT
HARD RUBBER OR STEEL ROLLER
                                                     Figure  4-2.  Knife  coating  of  fabric. 1

-------
Milling  .Milling  is  primarily   restricted  to  coatings   containing  rubber.

Natural  and   synthetic  rubbers  are  usually  milled  with   pigments,   curing

agents,  and   fillers  to  produce  a  homogeneous  mass  that  can  be  dissolved

in  a  suitable  solvent.    Organic  solvents  are  not  usually  involved  in

the   milling   process;  thus,  there  are  seldom  any orqanic emissions  from  this

operation.

Mixing  -  Mixing  is  the  dissolution  of  solids  from  the   milling  process

in  a  solvent.   The  formulation  is  usually  mixed   at   ambient   temperatures.

Sometimes   only  small  fugitive   emissions  occur.  However,  some  vinyl

COdters  estimate  that  as  much  as  25  percent  of plant solvents are  lost

in   mixing  operations.

Spreading  or  coating  »  Fabric  is  usually  coated  by  either a  knife  or  a

roller coater.   Both  methods  are  basically   spreading techniques  used  for

high   speed  application   of  coatings  to  flat  surfaces.  In some  unique

situations,  dip   coating  may  be  used.

       In   knife  coating,  probably  the  least  expensive  method,   the  substrate

is  held  flat  by   a roller  and drawn  beneath  a  knife  that spreads  the

viscous  coating  evenly  over  the  full  width  of the fabric,    Knife   coating

may  not   be   appropriate  for  coating  materials  such as certain  unstable
            •i
knitgoods,1   or  where  a  high  degree  of accuracy  in  the  coating  thickness

is   required.    Figure  4-2  illustrates   knife   coating.

       In   'roller  coating,  the  coating  material  is  applied  to  the  moving

fabric,  in a direction  opposite  to  the  movement of  the   substrate,  by

hard   rubber   or  steel  rolls.   The  depth  of  the  coating   is  determined  by

the  gap  between  rolls  (A  and B as  shown  in  Figure  4-o). The  coating

that   is  transferred  from  A  to  B   is then  transferred  to  the  substrate
                                   4-6

-------
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                                          CO
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-------
from  roll  B.   Unlike   knife   coaters,   roller  coaters  apply  a  coating
of   constant  thickness  without  regard   to  fabric   irregularities.
      Rotogravure  printing  is  widely  used  in  vinyl  coating  of  fabrics
and  is  a  large  source  of  solvent  emissions.   Rotogravure   printing   uses
a  roll  coating  technique  in 'which  the  pattern  to  be  printed  is  etched
as  a  series  of  thousands  of  tiny  recessed  dots  on the  coating  roll.
Ink  from  a  reservoir  is  picked  up  in  these  recessed  dots  and  is  transferred
to  the  fabric  surface.   Shadow  prints  are   used   to   simulate  leather  grain
A  variety  of patterns  are  printed  on  such  Items  as  vinyl  wall  paper
A  transparent protective   topcoat   over  the  printed  pattern  is   also  applied
with   rotogravure   techniques.
      Solvent  emissions  from  the  coating  applicator  account  for  25  to
35   percent  of all  solvent   emitted  from   a  coating  line.  This   solvent
may  be  collected  by  totally  enclosing  the  coating  applicator  in  a small
room or  booth  and  sending  all  booth exhaust  to  a  control  device.
However,  a  total  enclosure  of  the  coater  may  be  difficult  to  retrofit
on   many  existing  lines.   Another  alternative  is  to  cover  the   coater
with  a  hood  which  can  collect  most  of the  solvent  emissions.
Drying  and  Curing  •  Solvent emissions   from  the  ovens  account  for  65  to  7b
percent  of  all   solvent  emitted  from   a  coating  line.  In most   ovens,   almost
all  solvent  emissions  are   captured   and  vented  with   exhaust  gases.  On
some coating  lines  tne  emissions  from  tne  coating  anpltcator  nood are
ducted  to  the oven  and   included  with  the  oven  exhaust.
                                   4-8

-------
     Estimated  and reported solvent concentration levels from drying operations


                                           456
range between 5 and 40 percent of the LEL.  ' '       Typically drying ovens



are designed to process fabric on a continuous  basis operating with a web



or  conveyor  feed  system.   Ovens  can be enclosed or semi enclosed and,



depending  on  size,  may exhaust from a few thousand to tens of thousands of


                              7
cubic feet per minute of air.    Obviously,  if an add-on control device is



to be installed,  it is in  the owners best interest to minimize the volume



of air which must be treated.



     The oven heat  increases  the evaporation rate of the solvent and, with



some coatings, will produce chemical changes within the coating solids to



give desired  properties  to the product.  In  many cases,  evaporation rates are



controlled to give the desired properties to the coated fabric.



     High air velocities distribute heat  uniformly over the fabric surface,



facilitate heat transfer to the  coating and  substrate (by minimizing the



laminar zone next to the coated  surfaces), and  remove the evaporated solvents



from the oven at a rate that  will prevent their buildup to explosive levels.



     Ovens are heated by natural gas, steam, or electricity.  Those heated



by gas may be either  direct or  indirect-fired.  In the direct-fired oven,



the products  of combustion are combined  with fresh  air and circulated over



the  material.   Indirect-fired, steam heated ovens are the most common



method for heating most existing facilities,  although they are less



fuel efficient than direct-fireo ovens.  They are also limited



in the maximum temperature achievable.   One advantage of indirect-



fired ovens  is that the  fuel  or  combustion products cannot



contaminate  the   product.   In electrically htated ovens makeup



air peases over resistance heaters  before   posure to  the  fabric.
                                 4-9

-------
                                          TABLE 4-1 FABRIC AND  PAPER COATING OPERATIONS
                                                     USING CARBON ADSORPTION
Company
Alden Rubber
Company
Tuck Industries
(two plants)
Nashua Corporation
(two plants)
DenniSOn Manu-
facturing Company
Anchor Continental
Company
Product
Rubber coated fabric
Specialty tapes
(fabric and paper)
Specialty tapes
(fabric and paper)
Paper
Paper
Sol vent
Toluene
Toluene
Toluene

Toluene
Exhaust
*cfra
14,000
43,000
20,000
48,000
55,000
Carbon
adsorption
recovery
percent
85
95
85
96
70
Operating
percent
of LEL
50
45
45
(one)
25
18
 I
—«J
o

-------
     Many drying  ovens  in older  plants  are  only  semienclosed.  As  a



consequence  they  draw  in  excessive  dilution  air.   Solvent   concentrations



range  between  5  and 12 percent of the LEL according to both  calculations



and reports by industry.   Newer installations are reported  to be


                                                                    4,5
operating with exhaust concentrations up to 40 percent of the LEL.


      Levels  of up to 50 percent of the LEL are possible if proper safety



 devices  are  used according to recent publications. When ODeratinq at



 at 50 percent of the LEL,  the total exhaust rate  is only one-fifth (20%)  of


 that at 10 percent of the  LEL.   This greatly reduces the cost  of a control



 system.   As  shown in Table 4-1, at least three plants in the United States


 are operated at 40 to 50 Dercent of LEL. 4»5,8,9,10



 4.3 Special  Considerations



      The fabric coating industry has a number of unique considerations that



 affect  the technical and economic feasibility  of organic emission control.



 Although a number of the larger facilities specialize in a specific product,



 many plants  produce a variety of products or   operate  on contract to coat



 products  to  a   customer's  specifications.    The latter  type,  often called



 "commission  coaters", must use a variety of coating formulations to comply



 with the customer's specifications.   The coating may be specified or even



 supplied by  the customer.   The variety of coating specifications causes



 variations in emissions  which present problems in designing  the control



 system.   Even  if the COdtfir knows the solvent compositions,  it is necessary



 to base  exhaust volume  and controls upon the most critical or  difficult



 situation.    The number of solvents used al S3 affects the owner's ability
                                  4 11

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to  recover  and  reuse  the solvent.   Thus the coating type is an important




factor  in the cost of controlling emissions from a fabric coating plant.




Not only  are  insurance costs sensitive to the maximum solvent concentration




achieved  but  also the availability and cost of fuel also affect the djMiign




and cost  of  control.




     These considerations all emphasize that one must define and specify control



technology for  many existing plants in the fabric coating industry on a




case-b/-case   basis.




4.4 Available Control Technology




     Although few companies have elected to use organic emission controls,




there are alternative systems available that are technically feasible.




These are carbon adsorption and  incineration.  Another approach to reducing




organic emissions is  to switch to lower organic solvent coatings such



as aqueous emulsion coatings.   These alternatives are discussed in




the  following  sections.




4.4.1 Option  1  -  Incineration                          - Both catalytic



and thermal incinerators  (afterburners) can destroy'95 percent




of the  organic  emissions  introduced to them.  Since the effectiveness of




the capture and containment system varies  from  plant  to plant,  the overall




reduction in  coating  plant  emissions may be less than 90 percent.




Technical Analyses  -  Incinerators  convert  organic vapors to carbon dioxide




and water.  They  have been  used  by fabric  COaters for a number of years  to




control V latile  OrganiCS.   A detailed description of incineration is given



in Volume I,  Section  3.2.2  of this series  of reports.




     Incinerators can consume large amounts  of energy.  Fortunately,  the




heat they generate  frequently can be used  within the olant. A number
                                4  12

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of heat  recovery schemes are possible including preheating of the




incinerator inlet stream (so called  primary heat recovery). Another is



to transfer the heat from the incinerator exhaust gases to  supply process




needs  (secondary   recovery).   Primary heat recovery alone can provide




approximately 50 percent of the energy necessary to incinerate gases from



a typical  fabric coating system.      If the  oven exhaust is operated at




greater  than 25 percent of the  LEL,  both  primary and secondary heat recovery




can  actually decrease overall plant fuel  requirements.  Fabric  COflterS usually




can  generate all  of their steam requirements with secondary heat recovery.




Since the  economics  of incineration improve  with higher solvent concentrations,




the  cost of modifying an existing system  to  maximize the concentration of




solvent  in the oven exhaust must be explored when considering retrofitting




a control  system.   Higher concentrations  of solvent also decrease the fuel




requirements  for  the  oven.   The prospect  of future energy shortages, and ever




increasing fuel costs 'will  render such modifications of an oven desirable



form a cost effectiveness standnoint.








Cost  Of  Control  Options . The cost of installing and operating an  incinerator




for an exhaust  stream of 15,000 scfm  at 25 Percent of the LEL and




300°F is given  in Table 4-2.   Note that a noncatalytic incinerator  (afterburner)



with primary and  secondary  heat recovery  has the lowest annualized operating




cost.  If  the stream is at a lower inlet  temperature, more auxiliary fuel




would be required and operating costs would  be  higher.   Chrpter 4  of Volume



I  details  the assumptions made in calculating  these costs.  In assessing




fuel reqrirementS one must  consider that  coating operations usually operate




intc -mitiently and  that qreater quantities r.   fuel are required to




Stan up   i  incinerator than to operate  at „•> ?ady state.
                                  4 13

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               TABLE  4-2 INCINERATION  COSTS FOR  A TYPICAL  FABRIC
                                COATING OPERATION3
   Device
Installed
 cost,  $
Incineration
 No  heat  recovery

  Catalytic

  Noncatalytic
155,000

125,000
 Annualized
jsost,_$/yr_
 100,000

 105,000
  Control   cost
$/ton   of  solvents
   recovered
       51

       54
Incineration
 Primary   heat
 recovery
Catalytic
Noncatalytic
(Afterburner)
180,000
150,000

75,000
66,000

39
34

Incineration  -
 Primary   and
 secondary   heat
 recovery

  Catalytic

  Noncatalytic
  (Afterburner)
220,000

183,000
  54,000'

  26sOOOfc
       28L
       13'
   aProcess  rate  of  15,000  scfm;  temperature of  300°F,  operation  at  25
      percent of  LEL.    See Volume I,  Chapter 4  for costs for other
      operating parameters.

    Assumes  heat  is recovered  and  used.
                                    4 14

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 Effects and Limitations - Energy consumption  is  a disadvantage of inci-




 neration but as discussed both in this Section and in Volume  I,  recovery




 of the heat generated can eliminate or minimize the disadvantage.




      Other adverse environmental effects are mostly dependent  on the




 compounds present in the inlet gas stream.   If nitrogen or sulfur-




 containing compounds are present in  fuel  or exhaust gas, their  oxides




 will  be  generated.  Nitrogen oxides  will  also be generated from oxidation




 of nitrogen present in the combustion air.   If  halogens are  present,  acids



 will  be  formed.   For a further discussion,  see Volume  I of this series.




 4.4.2 Option 2  •  Carbon Adsorption                           -  A   carbon




 adsorber can remove over 90 percent of the  organic vapors from the gases



 that  pass  through  it.   Oftencollection efficiency across the  carbon bed is




 greater  than  95   percent.   Just as with the  incinerator,  the inability to




 capture 100 percent of the emissions will result  in a lower overall plant




 reduction.    Experience has shown that in  plants  that use activatec carbon,  the




 greatest  losses   occur  in  handling  of  solvent.   As care  is  taken to




 minimize handling losses,  the overall solvent recovery  increases.  It ha!:  been




reported that 95 percent of the captured solvent  vapor  can be recovered.  '




 Table 4-1  identifies  some  sources that use  carbon adsorbers and presents




 their   effectiveness.   These companies all have one factor  in  common:  they




 are able to recycle recovered solvent.  The importance  of this fact can be




 seen  below under "Cost of Contrc  Option."




 Technical  Analyses -  Activated  carbon is used not only  by  fabric COdters but by




 a number of industries  in  a  variety of coating applications.   Carbon




 adsorbers  are particularly attractive for tK >^* sources  which  use  a single




 Solvenc  or which constantly  use the  same  Si ;ent blend.    This permits the




owr.cr tc  recycle the  solvent without first  rjrifyir»g the recovered material.
                                 4-15

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 For those  nlants  that  must  use many  solvents  or  a  variety  of mixtures,
 the  recovered  material   would  probably  have  to  be  distilled.  The
 recovered  solvent  could,  of  course,  always  be  used  as  fuel  but   its  fuel
 value  would  always  be much  lower  than  its  value as  a  solvent.
      Historically,  the  decision  to  recover  solvent  has  been  based  upon
 cost  effectiveness   (return  on  investment)   rather  than  air  pollution
 considerations.
 Cost  of Control  Option  -  Table  4.3  summarizes  installation  and  operating
 costs  for  a  15,000  scfm  carbon  adsorption  unit operating  at  170°F and
 25  percent  of  the  LEL.    Tnree  cases  are oresented:   (1)  the  solvent  has
 no  value,  (2)  credit at  fuel  value  and  (3) credit at  replaceaent  value.
 Notice   that   only  where  the  recovered  solvent   can  be  recycled  does  the
 investment  pay for  itself.
 Effects  and  Limitations  -   Recovered  solvent  may  be sufficiently  water-
miscible  to  Dose  a  water  pollution problem if  the  condensate  from  the
 steam  is  not  treated before   discharge.  This  is  not   likely  to  be  a
 problem  with  adsorbers  on  tke  discharge  stream  from lost  fabric  coating
 ovens.    In  cases  where  this  problem  exists,  it can  be  solved by  treating
 the   condensate   or   incinerating  the   condensate-solvent  stream.   One
 fabric  coating  operation  that  uses a  water soluble  organic  solvent  is
 Vinyl  coating  which  uses  methyl  ethyl   ketone.
                                  4-16

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                      TABLE 4-3  CARBON ADSORPTION COSTS  &OR A TYPICAL FABRIC
                                       COATING   OPERATION  '
                               Installed
                               cost,  $
                 Annualized
                  operating
                  cost $/yr
                    Control cost
                  $/ton  of  solvents
                     recovered
Case with no credit for
recovered   solvent
Case with recovered
solvent credited at
fuel   value
Case V.'ith solvent
credited at market
chemical   value
320,000
320,000
320,000
 127,000
  60,000
(100,000)°
                                                                         72
 34
(57)'
aProC6SS rate of 15,000 SCflTl, temperature of 170°F,  operation at 25 percent  LEL
 See Volume I,  Chapter 4 for cost for other operating parameters.

 See Volume I, Chapter  4  for details on cost estimates


 'Costs  in parenthesis indicate a net gain
                                            4-17

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4.4.3  Option   3  •  Low  Organic  Solvent   Coatings  •  Organic  emissions  can
be  reduced  80 to  1_00_ Dercent  through  use  of  coatings which  inherently
have  low  levels  of  organic  solvents.   Both  high-sol   ids  and  water-borne
coatings  are  used.    The  actual  reduction   achievable   depends  on  the  organic
solvent  contents  of  the  original   coating  and  the  new  one.
Teabnical  Analyses   - Using  a  coating  which has  a low organic  solvent
content  may  preclude  the  need  for  an  emission  control  device.    Often
the  coating  equipment  and  procedures  need  not  be  changed  when   a  plant
converts  to  coatings  low  in  organic  solvent.
      There  is only  a  limited  number  of  cases  for which   information  is
available  to  compare  the  resulting  coating to   its   organic solvent
counterpart.     Although  a  number  of  companies  have  converted  to  low
solvent   coatings,   either  in part  or  in  total,  one  may  not Presume them
to  be  a  universal   control  measure.    Each  coating  line  is  somewhat  unique
and   many   coated  fabricshave   different  soecifications.
Cost  of  Control  Option  -  The  cost  of  converting  to   a low organic  solvent
coating  and  the cost  effectiveness of such a  strategy  is  dependent  aoon  a
number of  factors.   Research  and  develooment  costs   for  the  coatings  may
be  high and al  though  the  unit  cost  will  be  lowered  as  use  increases,  some
users  are  so  specialized  that  consumption will  be  small   and  developmental
costs  oer  unit  volume  will   remain  high.
4.5   Comparison  of  Control   Options  and   Conclusions
      lach  control  ootion  discussed  in  Section  4.4  is  a  viable  alternative
and  probably  the  best  choice  for  some  sources.   Th-  most  desirable  strategy
for  all  parties  concerned   is  probably  the  conversion  to  low  solvent
                                 4-18

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coatings.    Unfortunately,   this  option  may  not  be  available   at  present   for
all   situations.
      Carbon  adsorotion  and   incineration   are  possible  for   those  sources
that  cannot  use  low  polluting  coatings.   Carbon  adsorotion   is   probably   the
most  economical  for  sources  that   use  a  single  solvent  or   solvent mixture,
but  the  larqe  caoital  investment  required   is   appreciably  greater  than  for
incineration.
      Incineration.;   Preferably  with   primary  and  secondary   heat  recovery,
is  most aoolicable  at those sources that  use  a variety of  solvents.   Fuel
costs  can  be  reduced by  increasing  the  organics  level  in-exhaust gases,
i.e.,  by  reducing  dilution  air.
                                 4-19

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 References


 1.   Smith,  J  C, Coating  of  Textiles.   The  Shirley  Link,  The  Shirley
      Institute, England,  pp.   23-27

 2.   Telephone  communication  between  W.  I.  Johnson,  U.S.  Environmental
      Protection  Agency  and  Paul  Johnson,  Executive  Secretary  of  Chemical
      Fabrics  and   Film  Association,   August  20,  1976,

 3.   letter  to  James McCarthy,  U.S. Environmental  Protection  A
-------
                                 5.0  PAPER   COATING
5.1  Summary of Control  lecnnolugy
                                                                              Percentage
      Affected   facility                    Control    technique              reduction
      Coating   line                          Incineration                         95
                                             Carbon   adsorption                  90+
                                             Low  solvent  coatings             80-99
 (A  coating  line  consists  of  the  application  area  and  the  drying ovens.   The
application technique  may  be  a  roll,  knife  or  rotoqravure coater.)
5.2   General   Discussion
      Paoer  is  coated  for  a  variety  of  decorative  and  functional  purposes,
using   water-borne,   organic   solvent-borne,   or  solventless   extrusion   type
materials.    Because  the  organic  solvent-borne  coating  process  is  a
source   of  hydrocarbon   emissions,  it  is   an  air  pollution  concern.   Among
oroducts  that  are  coated  using  organic  solvents  are:   adhesive  tapes;
adhesivelabels   ;     decorated,  coated,   and  glazed  paper;  book  covers;
office   copier   paper  (zinc   oxide  coated);   carbon   paper;  typewriter  ritbons;
and   photograph i c   fi1ms.
      In  organic  solvent  paper  coating,   resins are  dissolved  in  an  organic
solvent  or  solvent  mixture  and  this  solution  is  applied  to  a  web  (con-
tinuous  roll)  of  paper.    As  the  coated  web   is  dried,  the  solvent  evaporates
and  the  coating  cures.   An  organic   solvent  has  several  advantages:   it  will
dissolve  organic  resins  that  are  not  soluble  in  water,   its  components  can
be  changed  to  control  drying  rate,   and  organic  base  coatings  show  suoerior
water   resistance   and   better  mechanical  prone  ties  than  some  types  of water-
borne   coatings.    In  addition,  a  large  varie    of  surface  textures  can
be  ohtair  3d using  solvent  coatings.1
                                      5-1

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     Most organic solvent-borne coating  is done by  paper converting com-

panies that buy paper from the mills and apply coatings  to  produce  a

final   product.   The paper mills themselves sometimes applv coatings

but these are usually water-borne coatings consisting of a  pigment  such
                                               2
as clay and a binder such as starch or casein.    These water-borne

coatings are not normally sources of organic  emissions.

     Mo$t companies that coat paper using organic solvents  are listed

in the U.S. Department  of Commerce's Standard Industrial Classification

(SIC) grouping  2641,  Paper  Coating and  Glazing. This group includes

establishments primarily engaged in manufacturing of coated, glazed or
                                            3
varnished papers from purchased paper  Stock.    Also included are

establishments primarily manufacturing nressure-sensitive tane with backing

of any material  other than rubber.   Establishments  primarily engaged in

manufacturing carbon paper are classified  in  Industry Code 3955 and nhO-

tographic and  blue-printed paper in Industry Code 3861, Some tyDG

of paper coating with organic solvents,  however,  may not fall into  ail"

of these  groups.
                                      4
     The 1967 Census of Manufacturers   gives  the following  information

about companies in SIC  2641:

         Total employment in industry:       37,100
         Number of oroduction employees      27,000
         Total plants by geographic region:

           New England                           61
           Mid-Atlantic                        122
           North   Central                        117
           South                                 44
           We s t                                  53
         Total plants in top ten states  for paper coating:

           New York                              57
           California                            41
           Massachusetts                         40
           New Jersey                            40
           Illinois                               34
           Ohio                                  27


                                   5-2

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            Pennsylvania                        25
            Wisconsin                           17
            Michigan                            16
            Rhode   Island                         7


      Nationwide emissions of organic solvents from paper coating have been

 estimated  to be 0.56 million tons/year.   This estimate includes resin

 emissions  from solventless polyethylene extrusion coatings applied to

 milk  cartons and resin emissions from  water  emulsion coatings.  Also

 included are solvent emissions from rubber adhesives used to glue paper

 bags  and  boxes.   A more conservative estimate based on solvent emissions

 from  the type of coating operations found in  SIC  2641 is 0.35 million tons/yr.

This  is slightly  less than 2.0 percent  of the estimate of 19 million tons/yr

of hydrocarbon emissions  from all stationary  sources reported in Volume I

nf this series.   Manufacturing of pressure sensitive tapes and labels, the

 largest solvent source  in SIC 2641,  alone accourts for 0.29 million tons/yr.

      Solvent emissions  from an individual coating facility will  vary with

the size and number of  coating lines.   A plant ma ' have only one or as

many as 20 coating  lines.   Uncontrolled emissions from a single line may

vary from 50 to 1000 Ibs/hr depending on the  line size.   The amount of

solvent emitted also depends  on the number of hours the line operates each

day.

     Table 5-1  gives tyoical  emission data from various D3Der coating

 ano Heat ions.
                                 5-3

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  TABLE    5-1  EMISSION DATA FROM  TYPICAL  PAPER  COATING  PLANTS
Plant
A
B
c
D
E
Number
of coating
lines
2
5
a
2
10
Solvent
usage ,
Ib/day
10,000
15,000
9,000
1,200
24,000
Solvent
emissions
Ib/day
10,000
15,000
9,000
1,200
950
Control *
efficiency, %
0
0
0
0
96
Control
device
None
None
None
None
Carbon
adsorptton
                20
55,000
           41,000
                           90
    G


    H


    I
 5,000


21,000


10,500
             1,500


              840


              500
90


 96


 96
Car&on
 adsorption
 (not all  lines
  control  led)

Carbon
 adsorption

Carbon
 adsorption

Afterburner
*Neglecting emissions that are  not captured in the hooding system.


5.2.1  Materials  Used  -  The  formulations  usually  used  in  organic  solvent-borne

paper  coatings may be divided  into the following  classes:  film-forming

materials,  plasticizers,  pigments,  and solvents.  Dozens of  organic solvents

are used.,   The  major  ones are:   Toluene,  xylene. methyl  ethyl ketone, 1SO-

propyl alcohol, methanol,  acetone, and ethanol.

     Although  j single solvent  is  frequently -used, often a solvent mixture

is necessary to obtain the optimum drying rate.   Too rapid drying results in

bubbles  and an "orgnge peel" effect in the  coating;  whereas, longer drying

coatings require  longer ovens or slower production rates.   Variations  in the

solvent mixture also affect  the solvent qualities  of the mix.
                                        54

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     The main classes of film formers used in paoer coating  are cellulose

derivatives  and  vinyl  resins.   The most commonly  used cellulose derivative,

nitrocellulose has been used  for paper coating decorative paper, book

covers  and similar items since the 1920's.   It  is relatively easy to formulate

and handle,  and it dries quickly, allowing lower oven temperatures  than

vinyl   coatings.   The most common vinyl resin is the copolymer of vinyl

chloride  and  vinyl  acetate.   These vinyl copolymers are superior to

nitrocellulose in toughness,  flexibility and abrasion,  resistance.  They

also show  good resistance to acids,  alkyds, alcohols and greases.   Vinyl

coatings tend to retain solvent,  however, so that  comparatively high

temperatures   are  needed.   In general, nitrocellulose  is most applicable to

the decorative paner field,  whereas vinyl copolymers are used for functional
                                         "i
papers  such  as  some DackagintJ  materials.'

     Plasticizers are often added to a coating to  improve  its flexi-

bility.   Three common plasticizers  are dioctyl phthalate,  tricrer 1

phosphate,  and  castor  oil.   Each type of resin  has an optimum nlasticizer

concentration.    As plasticizer concentration increases,  the  coating becomes

more flexible until it begins to  be too soft and tacky.

     In the production of pressure sensitive tapes and  labels, adhesives

and silicone release agents are applied using an organic solvent carrier.

The adhesive layer is usually based on one of the  following  organic

solvent-borne    resins:   natural or synthetic rubber, acrylic  or silicone.

Because of their low cost,  natural and synthetic rubber compounds are the

main film  formers used for adhesives in pressure sensitive tapes and

labels, although acrylic and silicone adhesives offer DerfOftTiance  advantages

for certain apolications.
                                5-5

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01
I
a\
               HEATED AIR

              FROM BURNER
             REVERSE ROLL

                CDATER
        UNWIND
ZONE 1
EXHAUST
t
n
L
ZONE
2
EXHAUST
T
n





^< 	 "—" 	 1
t^ D u
"ir 	 ii — *•.
p n -
                                                 OVEN
                                                                                       HOT AIR NOZZLES
tension MtitLS
                                                                                                                  REWIND
                                            figure 5 t.  Typical paper coating  line.

-------
         PAPER WEB
Figure 5-2.  Knife  coating of paper.
          5-7

-------
      The  oaoer  on  which  adhesive  labels  are  attached  until  use  are  treated
with  a  release agent  so  that  the  adhesive  tag  may  be  easily  removed.
This  is usually  a  silicone  coating that  is dDDlied  with  a  solvent.
Release  agents  are  also annlied  to  the  backside  of  pressure  sensitive
taoes  with  organic  solvents  so that  the  tapes  will  unwind  easily.
5,2.2 Processes  and  Affected Facilities   'Figure  5-1 shows  a  typical  oaoer
coating   line,   Components   include   an  unwind   roll,   a  coating  applicator
 (knife,  reverse  roll,  or   gravure),   an oven,  various  tension  and  chill  rolls,
and  a  rewind  roll.   The  unwind,   rewind  and  tension   rolls  display  various
degrees  of  complexity  depending on the design  of  the  line.
      The  coating   applicator  and   the  oven  are  the  main  areas  of-organic
emission  in  the  paper  coating facility.
      Coatings  may  be  applied  to   paper  in  several   ways.   The  main  application
devices  are   knives,   reverse  rollers,  or  rotogravure   devices.
      A  knife   coater   (Figure  5-2)   consists of a  blade that  scrapes  off
excess  coating  on  the  paoer.  The position  of  the  knife  (relative  to  the
paper  surface)  can  be  adjusted to  control  the  thickness  of  the  coating.
The  knife  coater   is  simply  constructed and  easy  to  clean.
      The  reverse   roll  coater  (Figure  5-3),   applies   a constant   thickness
of  coating to  the  caper  web,  usually  by  means  of three  rolls  -- each
rotating  in  the  same   direction.   A  transfer  roll  picks  up  the  coating
solution  from  a  trough and  transfers   it  to   a  coating roll.   (Sometimes
there  IS  no  transfer  roll  and the  coating  is pumped   directly  onto  a
coating  roll.)  A   "doctor   roll"   removes   excess   material   from  the  coating
roll.   The  gao  between  the  doctor roll  and  the  coating  roll  determines
the  thickness  of  the  coating.  The  web  is  supported  by  a  rubber backing
roll  where  the  coating  roll  contacts  the paper.   The coating  roll  turns
in  a  direction opposite to  that  of  the  paper,   hence   the  name  "reverse
                                  5-8

-------
                                    DOCTOR  ROLL
  METERING  GAP
TRANSFER ROLL
COATED PAPER WEB
                                                     BACKING ROLL
                                 COATING   RESERVOIR
          Figure 53.  Four-roll  reverse roll coater for paper.
                             5-9

-------
roll". This reverse direction of the coating roll reduces striations in



the coating that can form if the coating roll is turned in the same



direction as the paper web.



     Knife coaters can apply solutions of much higher viscosity than roll




coaters, thus  less solvent  is  emitted per pound of  coating  applied.



Knife coaters handle coatings with  viscosity up to 10,068 centipose(co).



Reverse roll coaters operate best in a much «»ore dilute  range where



viscosity is 300 to 1500 cp.  Roll coaters,  however, can usual ly operate



at higher speeds, and show less tendency to break the  pa^er.   Both kinds




of coaters apply coatings of good  uniformity.



     Rotogravure, another type of application method used by paper coaters,



is usually  considered a printing  operation, Uith  it, the image area on



the coating or rotogravure roll is recessed relative to the OOflifliage area.



The coating is picked up in the recessed areas of the rol1 and transferred



directly to  the  substrate.   The gravure printer can print patterns or a



solid sheet of color on a paper web.  Rotogravure can also be  used to



apply materials such as silicone release coatings for  pressure sensitive



tapes  and  labels.   Because of the  similarities, this Study  is  appropriate



for gravure as well as knife and roll coating.




     Most solvent emissions from coating paper come from the dryer or oven.



Ovens range from 20 to 200 feet in length and may be divided into two to




five  temperature  zones.   The first zone, where the coated paper enters  the



oven,  is usually at a  low temperature {^  110°F).  Solvent emissions are




highest  in  this zone.   Other zones have progressively  higher temperatures  that



cure the coating after most of  the solvent  has evaporated.  The typical



curing temperature is 250°F, although in some ovens  temperatures of 400°F



are   reached.  This is generally the maximum because higher  temperatures
                                5-10

-------
can  damage  tne paper.   Exhausts streams from oven zones  may be discharged




independently to the atmosphere or into a common header,  and sent to



some type of air pollution control device.   The average  exhaust temperature




is  about  200°F.




      Oven heaters are either direct  or indirect fired. With direct-fired




heaters,  combustion products contact the coated web inside the  oven. The




burners  themselves may be inside  the oven  chamber.  More commonly, the




burners  are mounted external to the  oven.  In this case, heated air




 (along with products of combustion) is blown directly  from  the burner to




the  oven  chamber.




      Although natural gas is the fuel most often used  for direct-fired




ovens,  fuel oil is sometimes used.   Some of  the  heavier  grades  of  fuel




oil can create  problems because SCL and particulate  may contaminate the



paper  coating.   Distillate fuel oil usually can be used satisfactorily.








      Indirect-fired oven heaters are arranged so that  products of  com-




bustion do  not enter the oven chamber.   A  heat  exchanger of some t} pe




is used to  transfer heat from the burner to the oven ehamber.   Because



combustion  products do not enter the oven chamber in the  indirect-fired




heater,  there is no chance for contamination of the naper coating, and




dirtier fuels can be burned.   Fuel is  not  used  as efficiently in  the




 indirect-fired oven, so more '-jel will  be required  than  if direct-firing




is  used.




      Steam  produced in gas or oil-fired boilers is  sometimes used  to




heat ovens  in the paper  industry  because  a^er coating ovens operate




. r  Tairly low temperatures.   (Such  boile  ;ou!d also  burn solvent




(  Elected by a carbon  adsorption  system   Typically,  the steam is




piped to  the  oven,  and fresh air  drawn i :o the oven is heated by





                                 5 11

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passing  it  over  the  steam  coils.
      Most  paper  coaters  try  to  maintain  air  flow  through  their  ovens  so
the  solvent  concentration  will be   25  percent  of  the  LEL,  although many
ovens are  run  at   much  lower solvent  concentrations.   As  the  energy  shor-
tages    intensifies,   coaters  are  making  greater  efforts  to  minimize
dilution air  and  thus  raise  solvent concentrations.

      Although  25 percent  of  the  LEL  is  often  regarded  as  the  maximum
allowable   solvent  concentration  in  the  oven  discharge  because  of safety
considerations,    insurance  and  safety  requirements  will  sometimes permit
even  higher   solvent   concentrations.   The  Handbook  of  Industrial  Loss
Prevention  notes  that  flammable  vapor  concentrations  of  up  to  50  percent
of  the  LEL  may  be  tolerated if   approved  continuous  vapor  concentration
                                    o
 indicator   controllers   are   used.    The  controller  must  sound  an   alarm
when concentrations  reach  50  percent,   and  shut  the  oven  down  automatically
when concentrations  reach  60  percent  of  the  LEL.
      Precise  methods   are  available for   calculating   the   amount  of  dilution
air  needed  to  maintain the  exhaust  solvent  concentration  at   a  given  LEL
level.   However,  most  of the paper-converting  industry  uses  the  estimation
method   of  assuming  10,000 ft  of  fresh  air,  referred  to 70°F,  per  gallon
                                       7
of  solvent  evaporated  in  the  oven.    This  method  will   give  a  solvent
concentration   of approximate!:'  25  percent  of  LEL  for  most  solvents,  but
the  r^nge  may  vary  from  10  percent to 32  percent of the LEL  for some
solvents.
      The  exhaust  flow  rates  from   paper  coating  ovens  vary  from 5000 to
35,000   scfm  depending  on size.   Average  exhaust  rates  are   10,000 to
20,000   scfm.   Paper  coating   ovens  vary  in  cost depending on  web  width,

                                  5-12

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line speed, and complexity of coating  and  associated  equipment.   For




example,  some  lines have  two coating stations SQ  that the paper web




may be coated  on both sides.  Paper coating lines have an installed




cost of $100,000 to $1,000,000.   A typical line would cost about $300,000.




     In a  typical  paper coating plant  about 70 percent of all solvents




used are emitted from the coating line.   The emphasis in this chapter is




on control of  the coating line.   However,  about 30 percent of plant emissions




are from the other sources.   These include solvent transfer, storage, and




mixing operations.    In order to control solvent emissions from these




areas, provisions must  be made  to insure that solvent containing vessels




have tight fitting covers and are  kept  closed. Another often overlooked




source of  solvent  loss  is use of solvents  for cleaning various coatings




and sludges from the coating line.   This must be done before ever" color




change.   Areas of the coating line that are frequently cleaned with




solvent can be hooded so  that solvent  fumes are caotured   and  sent to




a  control  device.   Dirty  cleanup solvent can be collected, distilled and




reused.   Solvent soaked wiping  rags should be kept in closed containers.




     Almost all emissions of the solvent from the.coating line itself




can be collected and sent to a  control  device.   Many plants report that




96 percent of solvent  introduced to the coating  line is recovered. Most




of the coating line emissions are from the.oven and the  coating application




area.   The oven emissions can be  exhausted directly to a control device.




     Part  of the solvent  remains  with  the  finished product after it has




cured  in the  oven.   For example,  certain types of jressure-sensitive tapes




have 150 to 2,000 ppm by  weight of solvent in the adhesive mass on the




finished tape.  Some COaterS estimate  th t 2 or 3 percent of solvent




remai; S in the product.






                                  5-13

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5.3  Special  Considerations

     The manufacture of photographic  film  pPtttCntS SDecial  solvent control

problems.   Four or more layers of coatings may be  applied to a photo-

graphic film, using equipment and coating techniques similar to  those

used for other paper coatings.   Because the coatings on the photographic

film later undergo chemical reactions,  the composition and quality of

the coatings must be  tightly controlled. Because  of the nature  of these

coatings, certain control options ma.y not  be practical.  For example,  it

may be impossible to recover solvents in a carbon  adsorption unit and  then

reuse these solvents  in new photographic coatings  since the reclaimed

solvents may contain enough impurities  to  contaminate  the  film.

5.4  Avai1ab1e  Contro1 Techno1ogy

5.4.1  Option 1 » Low  Solvent  Coatings

Achievable Reductions  - These are shown in Table 5-2.


               TABLE   5-2  ACHIEVABLE SOLVENT REDUCTIONS  USING
                LOW SOLVENT COATINGS  IN PAPER COATING  INDUSTRY

   Type of low solvent coating                   Reduction achievable.%

   Water-borne coatings                                 80-99

   Plastisols                                            95-59

   Extrusion coatings                                     99+

   Hot  melts                                              99+

   Pressure sensitive  adhesives
      Hot melt                                            99
      Water-borne                                       80-99
      Prepolymer                                          99
   Silicone release agents

      Water-borne emulsions                             80-99
      100 percent nonvolatile coatings                    99+


 Based on comparison with  a  conventional coating containing 35  percent
 solids by volume and 65  percent organic solvent by volume.

                               5-14

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Technical Analysis  -  Low Solvent Paper Coatings - A variety of low




solvent coatings have been developed  for coating paper.   These  coatings




form organic resin  films that  can equal  the properties exhibited by




typical solvent-borne coatings for some  uses.




     Water-borne coatings have long been used  in coating paper to



improve printability  and  gloss.   The  most widely used types of water-borne




coatings consist of an  inorganic pigment and nonvolatile adhesive.    Such




older  water borne coatings are useful but cannot compete with organic




solvent coatings in properties such as weather ,  scuff and chemical




resistance.    Newer  water-borne coatings  have been developed in which a




synthetic insoluble polymer  is carried in water as a colloidal dispersion




or  an  emulsion.  This a two-phase system in which water is the continuous




phase  and the  polymer resin is the dispersed  phase.  When the water is




evaporated and the coating cured,  the polymer forms a film that has pro-




perties similar to those obtained from organic solvent based COftings.




     Plastisols and organisols are low  solvent  coatings.  Plastiscls are




a colloidal dispersion  of a  synthetic resin in a plasticizer.   When the




plasticizer is heated,  the resin particles are solvated by the ^lasti-




cizer so that they fuse  together to form a continuous  film.    Plastisols




usually contain little  or no solvent,  but sometimes the addition of a




filler or pigment will  change  the  viscosity so that organic solvents




must be added to obtain desiraole  flow characteristics.   Uhen the




volatile content of a plactisol  exceeds  5 percent of the total weight, it




is referred to as an organisol.




     Plastisol technology began in the 19   's  and was first applied to




     ", vinyl  upholstery  in  automobiles i'  n example of a plastisol




    iri"   Paper is  coated with plastisols to make products such as
                               5-15

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artificial   leather  goods,  book  covers,  carbon paper  and  components  of
automobile    interiors,   Plastisals  may  be  applied  by  a  variety  of  means,
but  the most  common  method  is  probably  reverse  roll  coating,  One
advantage of plaStUoU 1s that  thiy ean  &«  applied In  layers  UP  te 1/8
 inch thick. This  avoids the neee§i1t > of multiple panes  through  a  coating
machine,
      Although orpnle solvents  an net  evipprated  from plastlsels, some
of the  pHstieUir my volit1l1« In  th«  oven,  This  p1§st1e1ier  win
condense when  I!fll1tt0d  frQW  the exhaust Stick to  form  a visible emission.
Companies  that  ult  pU»t1|Ql*  Often  have  a  small  electrostatic  precipitator
to  remove  these droplets  from the  GVin  exhaust
      Hot melt  coatings  contain  no  solvent;  the  polymer resins  are applied
in  a molten  state  to  the  pager  surfaces.   All  the materials  deposited  on
the  paper remain  as part  of the  coating,   Because  the  hot  melt cools to
a  Golid  coating soon  after  it  is  applied,   a  drying oven is  not needed
to  evaporate  solvent  or  to  cure  the  coating,  Energy-that   would  have been
used  to  heat an  oven and to heat  makeup  air  to replace oven exhaust
is  therefore  saved.   Considerable  floor  space  is  also  saved  when  an  oven
is  not  used.    In   addition,  the  paper  line speed  can  be increased  because
the  hot melt  coating cools  faster  than  a   solvent  coating  can  dry.'
      One disadvantage  with  hot  melt  coatings  is  that  materials  that  char
or  burn  when  heated cannot  be  applied  by hot  melt.  Other  materials  will
slowly  degrade  when  they  are  held at  the  necessary  elevated  temperatures.
      Hot melts  may be  applied  by heated gravure  or roll coaters and  are
usually   applied  at  temperatures   from   150°F  to  4509F.   The  lower   melting
point  materials  are generally waxy type  materials   with  resins  added   to
                                 5-16

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increase  gloss  and  hardness.   The higher melting point materials form



films that have superior scuff resistance,  transparency and gloss.



These coatings  form excellent decorative finishes.  One Particular



advantage of hot melts is that a  smooth  finish can be applied  over  a



rough textured paper.  This  is possi ble because the hot melt does not



penetrate into the  pores of the paper.



     A type of hot  melt coating,  plastic extrusion coating is  a solvent-



less system in which a molten thermoplastic sheet is discharged from



a slotted dye onto  a substrate of paper,  paperboard,  or synthetic



material.   The moving substrate and  molten  plastic are combined in  a



nip  'between a rubber roll  and a  chill roll.  A screw type extruder



extrudes the coating at  a temperature sometimes  as  high as 600°F.  Low



and medium density  polyethylene are  used for extrusion coating more than


                      3
any other type resins.



     More than 260  extrusion  coating lines  now produce materials for



Paper, paperboard,  and flexible packaging applications.'  Hundreds   of



products are  coated with extrusion coatings.  Food packaging materials



are often coated by extrusion coatings because a good moisture  barrier



can be  formed.   A well known  extrusion coated product is the polyethylene-



coated milk carton, which  became  popular in the  1960's.  Before that



time, milk cartons were coated with wax.



     Pressure sensitive adhesives are an area in which 1 ov  solvent  tech-



nology is being applied.    Because this  is a large industry, the potential



for solvent emission reduction is great. In 1974, sales of pressure-



sensitive adhesives in the  United States y.ere over $1 billion, and the
                               5-17

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growth  rate  about  15  percent  per  year.   Products   using  pressure   sensitive
adhesives  include  tapes  and  labels,  vinyl  wall  coverings,   and  floor
tiles.   Nationwide   organic   solvent  emissions   from   pressure  sensitive
tape  and  label  manufacture  is 580  million  pounds  per year.
      The  three  types  of  low  solvent  coatings   applicable  for  use  as
presstire  sensitive  adhesives  are:   hot  melts,  water-borne  systems,   and
prepo 1  yme r tyi terns.
      Pressure-sensitive hot melts currently being, marketed consist mostly
of styrene  " butadiene  rubber   block  copolymers.   Some  acrylic   resins  are
used,  but  these  are  more  expensive.   The  capital  expense  of hot  melt
coating  equipment  is  a  problem   for  paper  coaters   that   have  already  invested
heavily  in  conventional  solvent  coating  equipment.  There   are   currently
four  manufacturers   of  hot   melt  coating  application  equipment  for  pressure
sensitive    adhesives.
      Water-borne  adhesives  have   the  advantage   that   they  can  be  applied
with   conventional   coating   equipment.    Water-borne   emulsions,   which   can
be   applied   less   expensively  than   can  solvent-borne  rubber-based   adhesives,
are,'already  in  use for  pressure  sensitive  labels,  A  problem  with  water
borne  adhesives  is  that  they  tend  to  cause the  paper  substrate to  curl
and  wrinkle.   Some  companies  have   overcome  this  wrinkle  problem,   but
many  smaller  companies  have  not.
      Pre-polymer  adhesive   coatings  are  applied  as   a  liquid  composed  of
monomers   containing  no   solvent.   The  monomers  are  polymerized   by  either
heat  orradiation.   These  pre-polymer  systems  show  promise,  but  they  are
presently  only  in  a  developmental   stage.
                                  5-18

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      Silicone release coatings,  usually solvent-borne, are sometimes


used  for  oressure-sensitive,  adhesive-coated products.  Two  low-solvent


alternatives  are  currently on the market.   The first  is a 1 00 percent


nonvolatile coating which is usually heat-cured,  but may be radiation cured.


This  is a pre-polymer coating which is applied as liquid monomers that


are cross-linked  by the curing process to  form  a solid film. The second


system is water emulsion coatings,


      Products are being developed that will allow solvent recovery  from


solvent-borne silicone coatings using carbon adsorption.   Currently,  there


are difficulties  with recovering solvent from silicone coatings because


some  silicone is  carried into the adsorber where it fouls the carbon and


lowers collection efficiency.


             TABLE  5-3  CAPITAL COST OF SILICONE COAXING SYSTEMS IN
                              PAPER COATING INDUSTRY1"



                                   '                      Net  sost $/lb  of

       Coatinq  systems                                 silicone sclids on paper




Solvent Cwith  sol vent recovery)                                 8.20


Solvent   (with  solvent  incineration)                             7.33


Solventless (heat cure)                                         7.11


Solvent (with no  recovery)                                      6.69
                            <

Water emulsion System                                          5.28




      The  emulsion system is the lowest in cost,  but the 100 percent


solventless (pre-polymer) process may prove to be the most practical  system


in  the  long run.   It may be difficult for ^aper COaters that are familiar


V/ith  organic  solvent-borne systems to swi^fl to a water-borne system  because


of V*»  nkl ing  of the paper  and other appi ation problems.
                               5-19

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Cost  of  Control  Option  - Costs  will  vary  for  low  solvent  systems  depending
on  the  type  of  low  solvent coating and  the  particular  end  use.    The  low
solvent  coatings  will  be economical  once  the  technology  has  been
established,  but  there   can   be  large  costs  involved  in  initially  developing
the   coatings,   purchasing  new  application  equipment  and  learning  to   use
the   new  systems.
      Cost  comparisons  between  various  low  solvent  coatings  are  not  as  easy
to  make  as  are  cost  comparisons  between various   types  of  add-on  control
systems.    However,   a  detailed  cost  comparison  has  been  made  between
                                                     10
various   types   of   silicone   application  systems.      This  comparison  is
shown in  Table 5-3.  The cost  of  learning   to apply water-borne  systems
to  paper  could be   very  large.
      Additional  costs  will  be   associated  with switching  to   100   percent
nonvolatile    (pre-polymer)   coatings.   Most   organic   solvent-borne   silicone
release  coatings  are currently  applied  by  gravure  or  reverse  roller
fione   °f  these  are  suitable  for   solventless   coatings.  Solvent
less  coatings  must   be   applied   with 3-roll  or 4-roll  offset  gravure  presses.
These cost  from  $25,000 to  $200,000  per  coating  line.  A  cost  of  $100,000
would  be  about  average.  Because   of   these   costs,  availability  of  capital
can   be  an  impediment  to the  adoption  of  solventless  silicone  coatings.
Effects   and   Limitations •  Most  of the  low  solvent  coatings  listed  here
are   currently  being used for  certain  types  of  products,   However,    organic
solverit-borne  coatings   have  been  developed  over  the  course  of  decades,
whereas  the  low  solvent  coatings  are   only  now being  ipplied  to  many
products.    Continued  research  will  expand   the  number  of  applications
for   these   low solvent   coatings;  however,  at  present,   low  solvent  coating
systems  are  not  available  for  all  paper  coating applications.
                                   5-20

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 5.4.2   Option    2- -Incineration
 Achievable   reductions--Thermal   (noncatalytic)   incinerators   may   be   used   to
 control   organic  vapors  from   paper  coating  operations.   Catalytic     incinerators,
 widely   used  for   printing   operations,  have  rarely  been  applied  to  control
 paper  coating  operations  using  roll  coating  or   blade  coating  but  certainly
 are   applicable.
      Incinerators,   if  properly  operated,  can  be   over  95   percent  efficient
 in  controlling  organic  vapors  which  are  directed   to  the  incinerator.   The
 overall  control  for  the  entire  plant  will  be  less  because  of  the   emissions
 which   escape  captured.
 Technical   analysis- -Incinerators  have   been  retrofitted   to  a   large   number
 of  oven exhausts  from  paper  coating  lines  to  use  primary  and  even  secondary
 heat  recovery.   A  recent  article  describes  how  five  paper  coating   lines
 for  producing  office  copier  paper  were   fitted  with  incinerators,  which
 were  equipped with  ceramic  wheel  heat  exchanger.''  xhe   recovered  heat
 was  used  to  heat the  ovens.   Total  fuel  consumption  for   the  lines  actually
 decreased   after   the   incinerators   were  installed.   For   a  discussion  OT  the
 capabilities   .and  limitations  of  heat  recovery,   see  Section  3.2.2  of
 Volume   I.
 Cost of  control  option--Section  4  of  Volume   I  provides  cost  data   for
 incineration   at   various  gas  flow  rates   and   temperatures.   Exhaust   rates  from
 typical  paper coating  ovens  range  from  8,000  to  20,000 scfm  at  exhaust
 temperatures   of   175°F   to 300°F.    Costs   for   catalytic   and  noncatalytic   incinera-
tors onerating on  a  15,000  gas stream  at  300°F  and  at  25  percent  of  the  LEL
are  given  in  Table   5-4.
                                     6-21

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              TABLE 5-4  INCINERATION COSTS  FOR A TYPICAL PAPER
                               COATING  'OPERATION"



Device
Incineration-
No Heat Recovery
catalytic
nancatalytic
(afterburner)
Incineration- -
Primary Heat Recovery
catalytic
noncatalytic
( afterburner)
Incineration- -
Primary and Secondary
Heat Recovery
catalytic
noncatalytic
(afterburner)


Installed
$cost,


155,000
125,000


180,000
150,000



220,000
183,000



Annual! zed
cost. $/yr


100,000
105,000


75,000
66,000


h
26,'OQOb

Control
•cost, $/ton
of solvent
tmrnpH


51
51


39
34


K
28h

aProcess  rate  of 15,000 scfm;  temperature  of  300°F, operation  at  25
 percent  of  LEL.

 Assuming  recovered  heat  can be  used.
                                    '5-22

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         Effects and  limitations--The major problem associated with  the




use of afterburners to control  organic vapor emissions from paper coating



lines is the limited availability of natural  gas.  If heat recovery  is




used and the system  is operated properly,  no additional fuel may be




necessary.




         Primary heat recovery refers to using the incinerator exhaust




to preheat  oven gases going to  the  incinerator.  Secondary heat recovery




means using  heat from the  incinerator for  plant operations such as heating




the oven or  for room  heatiing.   Thermal (noncatalytic) incinerators can  be




operated at  lowest annual  expense if both  primary and secondary heat




recovery  are used.    It  is  possible,  however, that the heat recovered from




the secondary heat recovery unit cannot be totally utilized at some P3P&F




coating  plants.   Paper coating line ovens operate at relatively low




temperatures,   usually around 250°F and rarely over 400°F so the heat




available to the secondary heat exchanger  from the incinerator may be more




than needed   by  the  oven.   If some other use for  the  excess heat C^FIOt  be




found, the full cost  savings of secondary  heat recovery will not be achieved.




         When silicone-release coatings are being applied,  silicone  compounds




may be  emitted.   These will foul the heat transfer surface of a shell and




tube heat exchanger and the heat transfer  efficiency will decrease,




5.4.3 Option 3  - Carbon  Adsorption




       Achievable reductions--Carbon adsorption units can  be  over




90 percent efficient  in controlling organic solvent vapors that are drawn




into the carbon  bed.
                                 5-23

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Technical Analysis  -  Carbon adsorption has been used since  the




1930's for collecting solvents emitted from paper  coating operations.




Most operational systems on paper coating  lines were installed because




they  were  profitable.    Pollution control has  usually been a minor concern.




Carbon adsorption systems at existing paper coating plants range in size




from 19,000 to  60,000 SCfllh Exhausts from several paper  coating lines are often




manifolded together to permit one carbon adsorption unit  to serve several




coating   lines.  Paper products that are  now made on carbon-adsorption-




control led lines include pressure sensitive tape,  office copier paper,




and  decorative  paper.




         Carbon adsorption  is Imost  adaptable  to single solvent




processes. Many COdtePS using carbon adsorption have reformulated




their coatings  so that only one solvent is required.  Toluene, probably




the most widely used  solvent for paper coating,  is readily captured in




carbon   adsorption   systems.




         The  greatest obstacle to the  economical  use of carbon adsorption




is that in some cases  reusing solvent may  be  difficult.    In  many coating




formulations, a mixture of  several  solvents is needed to attain the desired




solvency and  evaporation rates.   If this solvent mixture  is recovered,  it




sometimes cannot be reused  in formulating  new batches of coatings.  Also




if different  coating  lines within the plant use different solvents and are




all ducted to one carbon  adsorption system, then  there may be difficulty




reusing the collected solvent mixture.  In this case solvents  must




be separated by distillation.
                                 5 24

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       Separation  of  solvent  mixtures  by   distillation   is   well   established

  technology   and   several  plants  are   already  doing  this.  One  paper  coating

  plant  has  been  using  such  distillation  procedures   since  1934.  Distillation

  equipment   can  be  expensive, however,  and  it  is hard  to  build  flexibility

  into  a  distillation  system.   Flexibility  is  needed  because  many  paper

  ceaters,  especially  those  who  do  custom work   for  others,  are  constantly

  changing    solvent    formulations.

  Cost  of  Control  Option «  The  cost  of using  carbon  adsorption   to  control

  hydrocarbons  emissions  is   outlined  generally  in  Chapter  4,  Volume  I.

  The  costs  for  a plant operating  with  an   exhaust  of  15,000  scftn  of gas

  at  '170°F  and 25 percent  of LEL  are given  in  Table 5-5
       TABLE  5-5  CARBON ADSORPTION  COSTS  FOR  PAPER  COATING  INDUSTRYa'b
                            (15,000  scfm,  170°F,  25% of  LEL)
                                                                       Control
                                                                     cost,   $/ton
                                Installed       Annualized          of  solvent
                                  cost,$        cost,  $/yr           recovered


No  credit  for  recovered       320,000        127,000               125
  solvent
Recovered   solvent   credited    320,000          60,000                 40
  at  fuel  value

Solvent  credited  at  market    320,000      (100,000)°
  value
aProcess rate  of 15,000 scfm,  temperature of  170°F, operation at
 25  percent  of  LEL.


 See  Volume   I,  Chapter  4  for  details  on  cost  estimates.


'Costs  in parenthesis  indicate  a  net  qain.
                                  5-25

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      The  installed cost qiven above is for a  carbon steel  adsorber.  Certain



solvents such as ketones and ethyl acetate require that the  vessel  be  made



of SDecial alloys.    These  solvents  form acids when exposed to steam,  and



can corrode carbon  steel.  Stainless  steel alloys are normally used in



these  cases,  For materials of other  than carbon  steel, the  cost  of equipment



increases significantly.



      If a distillation  unit must be included,  the installed cost of the



carbon  adsorption  system will increase significantly.  The  installed  cost



of the  distillation unit will  deuend  on the number of distillation



columns, the complexity of the separation, and  the size of the columns.



These factors will  be determined by the quantity,  complexity and  physical



prooerties  of the solvents to  be separated.



      An example of distillation costs  encountered is the  separation of a



mixture of  50 percent methyl  ethyl  ketone (MEK),  25 percent toluene and



25 percent  methyl isobutyl ketone (MIBK) into  a pure dry MEK stream and



a dry toluene •* MIBK mixture.   The separation  system consists of a



decanter, neutralizing  tank and  two distillation columns together with



necessary heat exchangers, pumps,  structural  supports and instrumentation.



The system  handles  a solvent  feed rate  of 1.5 gallons per  minute which



corresponds to a coating oven  exhaust of 15,000 cfm at solvent concentration



of 25 percent of LEL.   The cost of this separation system is approximately


                                       12
$125,000 in carbon  steel construction.

-------
 Impacts   and   Limitations -  The  only  adverse  environmental  effect  of  carbon
 adsorotion   is   the  possibility  of  small  amounts  of  organic  solvent
 remaining   in  the  water  phase  after  the  carbon  bed  is  steam  stripped.
 Water  pollution  has  not  been  reported   as  a  problem  by  paper coaters
 currently   using   carbon  adsorption.
 5.5  Comparison  of  Control  Sptions  and  Conclusions
       The   two  proven  add-on  control  devices  for  controlling  organic
 solvent  emissions   from  paper  coating   lines  are   incinerators  and   carbon
 adsorbers.    Both  have   been  retrofitted  onto  a  number  of  paper  coating
 lines   and   are  being   operated  successfully.
       The  main  constraint  to  the  use  of  incinerators  is  the  possible
 shortage  of natural   gas.   However,   in  many  cases  the  combination  of
 afterburner and  oven  will  use  no   more  fuel  than  the  oven  alone if  proper
 heat  recovery  is  used.   Incinerators  can  be  operated  on  LPG  or  distiHated
 fuel  oil   if  natural  gas  is  not  available.
       The  major  drawback  to   the  use  of  carbon  adsorption  is  that  in  some
 cases  solvent  mixtures   may  not be  economically  recoverable  in  usable  form.
 If the  recovered  solvent  has  no  value,  it   is  more  economical  to  incinerate
 and  recover  heat   than  install  a   carbon  adsorber.  However,  if the recovered
 solvent  can  be  used  as  fuel,  carbon  adsorption  compares  favorably  in
 operating   cost   with  an  incinerator.   If  the  solvent  can  be  recovered  as
usable  solvent,  use   of  carbon  adsorption  represents  an   economic   advantage
to  the  paper  coater.
      It IS more  difficult  to  estimate  costs  for  low  solvent  coatings,
 because  the  cost  will  vary  depending  on  chc  type of  coating.   Low  organic
                                   5-27

-------
solvent  coatings  will  usually  cost  less  in  dollars  per  pound  of  coatings
solids  applied  than   will  conventional  organic  solvent   coatings  with
some  type  of  add-on  control  device.
                                   5-28

-------
 REFERENCES

 1.   Mosher,  R.  H.,  and D.  Davis.   Industrial   and  Specialty  Papers,
      Vol.  I  -   Technology.    New  York,   Chemical  Publishing  Co.,   1968.

 2.   Cairns,  C.  W.,  Evolution  of  Raw  Materials,  TAPPI   Journal.
      Vol.  57,  No.   5,  page  85,  May  1974.

 3.   1972  Standard   Industrial   Classification   Manual.   U.   S.   Government
      Printing  Office.   Washington,   B.C.,   p.   1.

 4.   1967  Census  of  Manufacturers,  U.   S.   Department   of  Commerce,
      Washington,    D.C

 5,   Hughes,  T.  W.,  et  al,  Source   Assessment:  Prioritization  of   Air
      Pollution   from   Industrial  Surface   Coating  Operations,  Monsanto
      Research  Corporation,   Dayton,   Ohio.  Prepared  for   U.  S.  Environ-
      mental   Protection  Agency,   Research  Triangle  Park,   N.  C.,   under
      Contract  No.   68-02-1320  (Tech.   14)   Publication  No.  650/2-75-019a.
      February  1975.

 6.   Industrial  Ovens   and  Driers,   Handbook  of  Industrial  Loss  Prevention,
      Hightstown,    N.J.,  McGraw-Hill   Book   Co,,   1967.

 7.   Standards   for  Ovens  and  Furnaces,   Design,   Location,   and   Equipment,
      National  Fire  Protection  Association,  NFPA  No.  86A,  Boston,  MA,  1973.

 8.   Modern  Plastics   Encyclopedia   -  1973-74;  Vol.  50,  No. IDA,  New  York,
      N.Y.,   McGraw-Hill,  Inc.,   1974.

 9.   State-of-the-Art  in  Hot  Melt   Coating   Equipment;  Paper,  Film   and
      Foil  Converter,   September   1975,  page  51.

10,   Comparison  of  Alternatives  by  Incremental  Basis   -   Cost  Per   Pound  of
      Silicone  Solids,   Dow-Corning,   Midland,   Mich.

11.   Heat  Recovery:   Pays  for Air   Incineration  and   Process  Drying,
      Pollution    Engineering,   Vol.  7,  No.  9,  pages 60-61,   September   1975.

12.   Personal  communication  between  W.   L.   Johnson,   U.S.   Environmental
      Protection  Agency  and  John  W.  Drew,   Chem-Pro  Equipment  Corp.,
      March  16,  1976.
                                        5-29

-------
             6.0 AUTOMOBILE AND  LIGHT DUTY TRUCK ASSEMBLY
6.1 Summary  of Control Technology
     Affected
     Facility9
                              Control Option
Percentage
Reduction
Prime application,
and flashoff area
Prime cure oven
Topcoat app1i cati on
and flashoff area*
Topcoat cure oven
                        Water-borne  (electrodeposition)9
                        >50 volume percent  solids primer

                          Incineration

                          Carbon adsorption

                        Water-borne  (electrodeposition)
                        >50 volume percent  solids primer

                          Incineration

                        Water-borne  topcoat9
                        >50 volume percent  solids topcoat

                          Incineration
                          Carbon adsorption

                        Water-borne  topcoat
                            volume percent  solids topcoat

                          Incineration
   _
 0C-65d
                                                               90+

                                                               85+
                                                              Oc-65
40
                                                               90+
                                                               c,f Q:)e ,f
                                                                90+
                                                                85+
     _
 Oc-86
                                                               90+
 (a)  These  options reduce emissions from application, flashoff and
     cure.   The percentage reduction given is the reduction from all
     of  these   sources.
 (b)  Applicable but not costed in this report since water-borne  primer
     is  likely the preferred method.
 (c)  Based  on  an original coating with 50 volume percent solids. (3.7 1
 (d)  Based  on  an original coating with 26 volume percent solids.
     Surfacer  (guidecoat) is  included.  (5.5 Ibs/gal)
     Based  on  an original coating with 12 volume percent solids. (6.5 1
     Based  on  a water-borne topcoat with 2.76 pounds of organic  solvent
     Per galIon Of coating minus  water (e.g.,  25 volume percent solids,
     15  volume percent  organic solvent and 60 volume percent water).
 \9/  These  control  options  are applicable to all assembly and subassembly
     lines  in  the plant including those for frames,  small parts,  wheels,
     and main  bod.V parts.
*The application area(s) is  (are)  the
applied by dip  or spray.  The  flashoff
the  annl icatinn ar*>a  and
                              OV°P.
                                            s) where the coating is
                                             is  the space between
                               6-1

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6.2 General  Discussion



     For purposes of this study,  "automobiles" includes all passenger




cars or passenger car derivatives capable  of seating 12 or fewer pas-



sengers.   "Light duty  trucks"  includes any motor vehicles rated at 8500




pounds gross vehicle weight or  less  which  are designed primarily for




purposes of transporation of property  or are derivatives of such vehicles.




This is intended to include pick-ups,  vans and window vans.




     The automobile and  light duty truck assembly industry receives




parts from a variety of  sources and  produces finished vehicles ready for




sale to  vehicle  dealers.   Various models may be built on one line, but




they usually are of the  same general  body style.  A plant may have more




than one  line.   This chapter is intended to apply to assembly plants




only and not to customizers, body shops or other repainters.




     Although faster production is  possible, automobile and light truck




assembly lines typically produce from  30 to 65 units per hour using two




(or rarely three) worker shifts per  day.   Plants are usually shut down




on holidays and for several weeks during the model  changeover period.




Most plants operate about 4000  hours per year, '  depending  on  demand.




     Locations  of U.S. automobile and  light duty truck assembly plants




include:   American Motors--Kenosha,  WI, and Toledo, OH; Checker  Motors--




Kalamazoo, MI;  Chrysler  Corporation--Belvidere, IL, Hamtramck, MI,




Detroit, MI (2), Newark,  DE, and St. Louis,  MO; Ford Motor Company--




Atlanta, GA, Chicago,  IL,  Dearborn,  MI, Kansas City, MO, Lorain, OH, Los




Angeles, CA, Louisville,  KY, Mahaw,  NJ, Metuchen,  NJ,  Norfolk,  VA,  St.




Louis, MO, San Jose, CA, Minneapolis - St. Paul, MN, Wayne, MI,  and




Wixom, MI; General Motors--Arlington,  TX,  Baltimore, MD, Detroit,
                               6-2

-------
MI, Doraville, GA,  Fairfax,  KS,  Flint,  MI, Framingham,  MA, Fremont, CA,



.Janesville,  WI,  Lakewood, GA, Lansing, MI, Leeds, MO, Linden, NJ,



Lordstown, OH, Norwood,  OH,  Pontiac,  MI,  St.  Louis,  MO,  South Gate, CA,



Tarrytown, NY, Van  Nuys,  CA, Willow Run,  MI and Wilmington,  DE;  and



International--Springfield,     OH.   A plant  is under construction by  Volks-



wagen  in  Pennsylvania.   Volvo, who had planned a new Plant in Virginia,



recently announced  their plant has been postponed "indefinitely".



     Although no "typical" automobile or  light truck assembly line



exists,   features common to all  are shown in Figure 6-1. As the process



begins,   an automobile body emerges from the body shop and undergoes



metal treatment  (usually a phosphate  wash cycle) to improve  paint


                                   2 3
adhesion and  corrosion resistance.  '    The first coat, a primer, is



applied  by dip  and/or spray methods, then the unit is baked. The



topcoat  is then  applied  in one to three steps, usually with a bake  step



after each.   The painted body then goes to the trim shop where assembly



is  completed.



     Coatings which are  damaged during the trim step are repainted  in a



repair  spray  booth.   Because the automobile now contains heat sensitive



materials such as plastics and rubbers, repair  is generally  limited to



solvent-borne coating, which can be dried in low-temperature ovens.



(Water-borne  coatings usually require high curing temperatures.)



Production volume in the repair area  is intermittent,  making add-on



emission  control  devices less cost-effective than for the primary



coating   area.  Emission  controls, therefore are generally not practical



for the  repair spray booth and  its oven.  Considerable  reductions  in



emissions can be accomplished by the  use of a higher solids repair  coating.




                                6-3

-------
 FROM BODY SHOP
                                         METAL
                                     PRETREATMENT
                                       DRY-OFF  OVEN
     PRIME
  APPLICATION
      AREA
PRIMECURE  OVEN.
               FIRST TOPCOAT
            APPLICATION  AREA
  FIRST TOPCOAT
    CURE OVEN
  SECOND  TOPCOAT
 APPLICATION  AREA
                                         (IF  ANY)
              SECOND  TOPCOAT
                 CURE  OVEN
                   (IF  ANY)
                                                  COATED PARTS FROM
                                                     OTHER LINES
:•  THIRD TOPCOAT
 APPLICATION  AREA
      (tf ANY)
   THIRD TOPCOAT
     CURE  OVEN
      
-------
     Cost estimates  and  pollutant emissions presented in this chapter




are based on coating main body parts  including  hoods and fenders. In




some plants  (particularly those building larger vehicles),  hoods  and




fenders are  coated separately and joined to the body after coating.  The




total cost of controlling emissions may be  more  if the coating is done




on several lines instead  of one line.'




     Some automobiles  and most trucks have  a separate frame that is




joined to the body after  coating.   Frames and small parts such as wheel




rims may arrive at the assembly plant already  coated or may be coated at




the  assembly  plant.  These sources of emissions are liable to the same




control measures as  those for the main body and this report applies.




     Parts that are  not  visible from  the exterior of the vehicle may be




dipped in a  viscous  coating that can be either  water-borne or solvent-




borne.   Headlight  frames and other visible small parts may arrive at the




assembly plant already coated,  be coated after assembly to main body




parts,  or be coated  on a separate line. As  with the other vehicle




components,  the coating process for these parts  is liable to the same




control measures used  for the main body.




     Uncontrolled organic emissions  from coating vehicles  with  organic




solvent-borne surface  coatings can range from  less than 600 pounds per




hour (lb/hr)  to more than 4000 lb/hr  for an assembly  line.  This wide




range is caused by variations in the  surface area coated for different




vehicles,  the number of  vehicles coated per hour, and, most importantly,




the solvent  content  of the coatings.   There may be more than one  assembly




 line at  a  plant.
                                 6-5

-------
      Other sources of organic  emissions  from a vehicle assembly plant



that  are not  included in this  study include the  application of adhesives



and   sound-proofing   materials.   These  account  for about  10 to  30  percent



of  total  organic  emissions  from  the  plant.



6.2.1    Materials   Used           - Two types of coatings are used in this



industry:   lacquers  and  enamels.   Lacquers   are   resin-pigment   combinations



dissolved   in   a   high  solvent-power  solvent.   Drying   occurs  by  evaporation



of  the solvent and  deposition  of the  resin  and  pigment,  rather  than  by   ,



cross-linking.      Enamels  are  highly pigmented  drying  oils  thinned  with  a



low-solvent-power     solvent.    The   coating   is  formed   by   polymerization.



      The  uses  of coatings  can  be divided  into primers  and  topcoats.



Acrylic  coatings   may   be  either  lacquers  or  enamels   and  are  widely  used



for  topcoats.    Topcoats currently   used  contain  from  about  14   to   35



percent  solids  by  volume.    Primers are usually enamels  and are  complex



polymers  prepared  from  epoxy  and  drying  oil  acids.   Primers  are   usually



either  solution  epoxies  (cross-linked   with a  urea  or melamine)  or

                                    2

electrodeposition   primer    resins.    A  typical  solids   content  of  a solvent-



borne  primer   enamel   would  be  26  volume  percent  for   General Martf  and


                                  19
30-35  volume  percent   for Ford.



      Since  most   manufacturers   apply  about   a 3.0 to   3.5   mils  thick



coating,  the  mass  of  solvent  emitted  per  unit surface  area  Is  propor-



tional  to  the ratio   of  solvent  to  solid  material  in the  coating.  The



relationship   between   pounds  of  solvent  (assuming a   solvent  density  of



6.6  Ibs/gal)   emitted   per  gallon  of solids   applied  and  the  percentage
                                     6-6

-------
of organic solvent present  is shown in Figure 6-2.   The relative




positions of the various  types of coatings emphasize the great dif-




ferences  in emissions between coatings of different  solids  content,




e.g., between  lacquers and  enamels.  Even though  the positions  Of




lacquers  and enamels on this figure do not represent absolute  numbers




(since  exact percent solids and solvent density can  vary),  the dif-



ference   is  striking.   The amount of organic solvent  contained  per unit




of solids (as  used)  factor is a convenient comparative  tool because it



is independent of vehicle size, line  speed,  and  coating  thickness.




6.2.2 Processes and  Affected Facilities  • Four types of facilities  are




affected: (1)  prime application area(s),  including flashoff area




(evaporation area prior to the oven);  (2) prime cure; (3)  topcoat




application area(s),  including flashoff area  but  excluding repair




application   area;  and  (4)  topcoat  cure, excluding   repair  oven.




     The  prime coat  serves the dual function  of protecting  the surface




from corrosion and providing  for good adhesion of the  topcoat. A




combination of manual and automatic spray methods, with or without the




use of  electrostatic techniques,  is usually  used  to apply organic




solvent-borne   primer.   Because workers are in the spray area;  health




regulations require  solvent concentrations be kept  low. At some plants,




vehicle hoods  and fenders may have their  own prime  spray booth and OVSH.




In  'rare  cases, primers may  be  applied  in  more than  one  step with  each




fo11owed  by  cur i ng.




     Primers may also be applied by dipping  techniques.  The Chrysler




Corporation,  for example, uses water-borne dip primers  for underbodies
                                 6-7

-------
                    POUNDS OF  ORGANIC SOLVENT EMITTED PER GALLON OF SOLIDS APPLIED
w to
w  c

|3

•o  °»
<  3
C8  r+
o. to
» o_

i. a
F* «A
   0)


   r+

   CD
   a>
   a.

  T3
   CD
   -^

  CO
   3
   o^

   E

   D)
  •a
   CD
   a.
        •o
        m
        x
OJ<2    «

b>5    g
— T3    o
^ O    5b

"g 3    5
c:Q-    ^
r^ en    <
   O


  I
   o'
        m
        x
        o

        C

        5   S
        z
        o
        m
        3D
                                     NONAQUEWWB

                             DISPERSION  ENAMEL (40% SOLIDS)
                                  NONAQUEOUS

                         DISPERSION ENAMEL (50% SOLIDS)
                       URETHANE (60  PERCENT SOLIDS)
                    32 PERCENT SOLIDS, WATER-BORNE SPRAY  (80/20)
                  1 40 PERCENT SOLIDS, WATER-BORNE SPRAY <80/20>


                  HIGH SOLIDS (80 PERCENT SOLIDS)

                  50 PERCENT SOLIDS, WATER-BORNE SPRAY (80/20)
                   ELECTRODEPOSITION  (PRIMING  ONLY)


                          I
                   POWDER COATING


                    1      I      I
                                      I      1      I     I
                                            6-8

-------
at some of  its  plants.   Because the dip-coated primer is not smooth, the



coating must be sanded or else  be used  only on areas where appearance is



not  important.



     Of most interest from a pollution  control standpoint is total body



priming by electrophoretic (electrodeposited)  water-borne dip.    In  this



system the object to be  coated  is immersed in  a water-borne coating and



an electric potential difference is induced between the vehicle and the



coating  bath.   By correctly setting the electrical potential and the



time in the bath, the coating thickness can be controlled as desired.



Corrosion protection is  excellent because coverage is more complete than



can ever be obtained by  spray priming alone.   Additional primer  may be



sprayed on rough or sanded areas.   This additional primer, called



"surfacer"  or   "guidecoat",  can be either water-borne or organic  SOlvent-



borne.



     The paint in the electrophoretic bath consists of 5 to 15 volume



percent solids, 80 to 90 volume percent water, and about 5 volume



percent   organic  co-solvent.   The coating solids displace solvent as they



are deposited and solvent is squeezed out.   As the vehicle component



emerges from the bath, its coating  is 90 volume percent solids, 9 volume



percent water and  1  volume percent  organic co-solvent.  Excess coating



is returned to the bath  by washing  with makeup and ultra-filtered water.



Because of the extremely low  solvent usage  (about  7  1b/hr), the  exhaust



from this oven does  not  require further emission control unless  it



presents an odor problem.  The electrophoretic dip process is  used  at



over 40 percent of U.S.  assembly plants and is very widely used in


r      1,5,6,7
turope.
                              6-9

-------
      An  option suitable  for  some  plants  is  to  spray  a water-borne
primer.
      Organic  solvent-borne   primers  are   usually  spray   applied.   When
using   organic   solvent-borne   spray,  85  to  90  percent of  the  solvent
evaporates  in  the booth  and  flashoff  area;  the  remaining  10  to  15
percent  evaporates  in  the  oven.
      Water-borne  coatings   contain  relatively   small   quantities  of   organic
solvents,   principally  to   improve  leveling  and  gloss.  They  are   less
volatile  organics  than  those   from   organic  solvent-borne  coatings  and
consequently  a  lower  proportion  evaporates  in  the  booth(s)  and  flashoff
area(s).    For   water-borne   topcoats,   the  calculations  here   assume  that   50
percent  evaporates  in  the   spray  booth(s)  and  flashoff  area(s)  and  50
percent  in  the  cure   area(s).    Note   that   maximum   humidity  limitations
 (for   proper  curing),  the  necessity  of  an  adequate  air  flow at  oven
entrance,   and  avoidance  of explosive   mixtures,  all  affect  required oven
exhaust   volume  for  water-borne   coatings,
      A  relatively  new  system  of  coatings  called   "autophoretic"   has been
used  for  frames  and   parts.   This  system  has  been  proven  for   these
applications  but  has  not  been  applied  to  primers  or  topcoats.  »^° H
is  unknown  at  this  time  if  the  system  can be  used  for  parts   of the
vehicle  that   are  normally  visible.
6.3    Special    Considerations
      With  respect  to  the  coating  process,  the  automobile  and  light truck
assembly  industry  has  characteristics   that   make  it  unique.   The  companies
involved  are  large  and  possess  a  great  deal  of expertise   in coatings
                                      6-10

-------
 (unlike some other companies that  coat  their products),  the entire




process is under their control,  and they are free to change coatings,




within the limits of their equipment, (unlike toll coaters  that  often




have no choice  in the coatings they use). These  tend to facilitate




control, especially the use of low-solvent coatings.   The  process can,




and  usually  does,  run at  a relatively high percentage of capacity and at




a constant rate-which tends  to make  control more cost-effective. The




 industry produces a product that is expensive to  inventory,  must be




responsive to customer whim, and is available with a large  number of




optians  and  colors. These make frequent color change a necessity and




hence the  use  of powder coating difficult.  The industry has strong




competition from foreign  imports ,  and produces a product that is exposed




to a wide range  of climates and is judged critically by  its appearance.




These considerations make the  use  of unproven coatings  more difficult.




     Special considerations drastically affect the cost of control.  To




Obtain acceptable appearance and coverage on a complex shape SUCn as a




car or truck, manufacturers have found  it necessary to  apply topcoats  by




a combination of manual and automatic spray. Multiple applications are




necessary to achieve the  necessary thickness, and sufficient time must




be allowed between applications for adequate drying. Sufficient space




also must be provided between vehicles  on a  moving assembly line to




allow the operator to complete his task. All  of  these  factors cause




spray booths to be as  much as  several hundred feet long.  Because the




booth is occupied, OSHA requires a minimum air velocity away from the




workers to protect them.  This requirement  is normally met  by main-




taining a minimum air  movement from .top to  bottom of the booth. This




air flow, in conjunction  with  the  long Spt 3y booths characteristic of




the industry, results  in  exhaust volumes of hundreds of thousands of






                                 6-11

-------
cubic  feet  per  ainute.    The  concentrations  of  organic  vapors   range  from
50  to  200  ppm  (equivalent  to  less  than  2 percent  of  the  lower  explosive
limit,   i.e.,  the  LEL)  at   temperatures   of  60°F  to  90°F.  This  combination
of  high  volume  and   low  concentration  makes  add-on  devices  very  expensive
for  spray  booths.
      Ovens  are  not  restricted  to  the  same  low  organic concentrations
since   they   are   not  occupied.  Their  allowable   concentrations  are  governed
by  three  factors:   explosivity  limits   (usually   to   less  than  25  percent
of  LEL),  the  necessity  to  maintain  adequate  air  inflow  at  openings  to
prevent  escape  of  oven gas ,  and  the  necessity  to  prevent   condensation  of
high  boiling   compounds  on   the   inner  surfaces  of  the  oven.   Although
improved  oven  entrance  design  can  help  in  the   future,  the   problem  of
adequate   inlet  flow   presently  limits  motor  vehicle  assembly  plant   ovens
to  a maximum  of about  10  percent  of  the  LEL.     The    condensation   problem
                                                   7
may  begin  to  occur   at   higher   concentrations.     With   many  older ovens,
modifications  may  be  necessary  to  raise   the  concentrations   even to  10
percent  of  the  LEL.
      Besides  minimizing  the  size  and  fuel  requirements  of   the  control
equipment,  operating   ovens   at  the  higher  concentrations   has  the   additional
advantage  of  minimizing  the  fuel  requirements  of the  oven   itself  by
decreasing  the  quantity  of makeup  air   to be   heated.   The  higher  temper-
ature   and  the  higher  concentration   (with  correspondingly   lower  exhaust
flow  rates)  makes  incineration much   less  costly  for  an  oven  than  for  a
spray   booth.
      Some  special   considerations  make   powder   coating  difficult.   These
are  the  necessity  to  change  colors  often and  the  desirability  of  "metallic"
coatings.    It  would  be  desirable both  from a   manufacturing and air
                                         6-12

-------
pollution standpoint  to  switch colors as seldom as  possible.  Manufac-




facturers would like  to  schedule many vehicles  of one color through the




line in sequence for  convenience and to  save the  paint that must be




purged from spray  nozzles each time a color is changed.  Unfortunately,




vehicles are built with  a large number of available  options, of which




color  is only one.   Air  conditioners, power brakes,  power steering,




etc.,  are each installed on  a  given percentage  of the production volume.




Each of these subassembly operations has a production capacity that may




be less than the line speed  and each has a  finite  storage  capacity.




Vehicles are largely  built to  dealer or  customer  orders which must be




filled  within  a  limited  time.  The scheduling of vehicles on the assembly




line is, therefore, constrained by many  factors and  color change is




often necessary between  each vehicle.   The capability must  exist to




change colors quickly in the booth,  or else separate application areas




must be available for each color.   Because an assembly plant usually




applies in excess of  15  colors,  the latter choice is economically




prohibitive.




     Spraying powders of different color in one booth also has problems.




In the conventional spray system,  each color is delivered through a




separate hose and the operator manually  switches  his spray nozzle among




the hoses. The former color  is first flushed out  of  the nozzle with the




new color and then coating with a  new color begins.    Inertial    deposition




is the primary coating mechanism  although electrostatic attraction may




assist.   Once the coating material strikes the surface it agglomerates




and is not then susceptible  to reentrainment.   High air velocities are
                                 6-13

-------
maintained  in the booth to  meet health requirements and  to prevent



overspray from one vehicle  to another.    In contrast to this,  powder  does



not   coalesce:   the  sole  force holding  the  powder  is electrostatic



attraction.     Furthermore,  the  small  particle  size   makes   it  impractical



to  use  the  high  sweep  velocities  required  for  worker   safety   (because of



entrainment).    Exhaust  velocities  must  be   kept  low.   These  low  exhaust



velocities  make  it  necessary   to   use  largely  automated  coating  systems



and   require   face  masks   where  workers   are   essential.   The  low  velocities



can   result  in  carryover.   Any  carryover  of coating  in a powder  system



shows  up  as  discrete  specks  on  a  differently  colored   product  since  there



is  no  opportunity for dilution of carryover  paint specks   as  in  liquid-



borne   coatings.



      Metallic   coatings,   much   in   demand  for  automobiles,   obtain  their



name  from  platelets  of  aluminum  added  to  give  a  reflective  appearance.



In   a powder  system,  the   platelets  cannot  move  after application  and  are



thus  set in  a  random  order.   The  appearance   is  less   aesthetically



pleasing  than  that  achieved  with  liquid-borne  coatings   where   the   platelets



orient  parallel  to  the  surface.



      To  date   these  problems  have  been  an  obstacle   to  the  adoption  of



powder  coatings  as  topcoats   in  this  industry.



6.4   Available   Control   Technology



      For  ease  of  comparing  control   technology,  a flowchart  of  a  typical



plant  is shown in  Figure  6-3.  As outlined at  the  beginning  of  this



section,  certain   technologies   are  limited   to  certain  affected   facilities



and  some  will  reduce   emissions  from  more  than  one  affected  facility
                                      6-14

-------
COATINGS,
SOLIDS, b. v.
SOLVENTS,
AND TYPE
12% SOLUTION
LACQUER
18% DISPERSION
LACQUER
32% ENAMEL
50% ENAMEL
WATER-BORNE
PRIME APPLICATION
SOLVENT
EXHAUST
RATE, Ib/hr


380
170
NEGLIGIBLE
FLOW
RATE,
x 103 $cfm


262
123
SMALL
PRIME OVEN
SOLVENT
EXHAUST
RATE, Ib/hr


64
30
40
FLOW
RATE,
x 103 scfm


4.5
1.6
1.6
TOPCOAT APPLICATION
SOLVENT
EXHAUST
RATE, Ib/hr
2490
1546
720
340
85
FLOW
RATE,
x 103 scfm
1815
1129
525
248
525
TOPCOAT OVEN
SOLVENT
EXHAUST
RATE, Ib/hr
438
212
127
60
85
FLOW
RATE,
x 103 scfm
25.0
15.5
6.0
3.4
3.4
I
en


1
PRIME
APPLICATION
(AREAS)
k

t .
PRIME
OVEN(S)
k

1
TOPCOAT
APPLICATION
AREA(S)


I
r i
TOPCOAT
OVEN(S)
           ASSUMPTIONS: SOLVENT CORRESPONDS TO SO-SO mote percent HEXANE-BENZENE; 85 percent OF EMISSIONS ARE IN APPLICATION  AREA(S)
           FOR SOLVENT-BORNE  COATINGS; 50 percent OF EMISSIONS ARE IN APPLICATION AREA(S)  FOR WATER-BORNE TOPCOAT; 30 gal/hr OF SOLIDS
           ARE APPLIED FOR PRIME COAT; 60 gal/hr OF SOLIDS ARE APPLIED FOR TOPCOAT;  APPLICATION AREA EXHAUST AT 100 ppm WAS 0.0228 lb/103
           scf; OVEN EXHAUST AT 10 percent OF LEL WAS 0.296 lb/103 scf; ORGANIC SOLVENT DENSITY WAS 6.665 Ib/gal. FOR WATER-BORNE,  percent OF
           LEL WAS LOWER.
              Figure6.3 Typical plant for assembling intermediate-sized automobiles and light-trucks at rate of 60 per hour. (For
              different vehicles, the values would correspond to different production rates.)

-------
(e.g.,  transition  to water-borne  coatings  will   result  in  reduced  emissions


from  both  the   application   and  curing  areas).  Some  technologies  can  be


combined   (e.g.,   incineration  will  further   decrease  emissions  even  after


a  plant  changes  to  coatings  with  higher  solids  content).


      Caution  must  be  used   in  applying  the  cost  estimates  below  to  specific


plants,  since  retrofitting  costs  can  vary   greatly  depending   on   the


specific    situation.   In  some  cases  the  assumptions  used  herein  are  for


an  almost  'ideal  cafe;  any deviation  will  increase  the  cost. One  should


carefully  analyze  each  situation to   determine  if  the  assumptions  are


valid  or  the  deviations   essential   (for  example  the  cost  of  control  for  a


given  amount  of  organic  material   is  roughly  inversely  proportional  to


concentration  but  exhaust  gases  in  most  ovens  are  far  more  dilute  than


necessary),     The  paint  usage  assumptions  can  also  vary  considerably

                  i o
between   plants.      In  all  cases,  the  assumptions  (and  where  possible the


effects  on  costs  of different  assumptions}   are   listed,  either  In  this


Section  or  in  Section 4  of Volume  I


      The  control  options   described   have  varying  levels  of  current  use   in


assembly   plants.   Water-borne  primers  are   currently   used  in  almost  half


of  the  plants.    Water-borne  topcoats   are  being used   at  two  plants  and


their  use  is planned  at  a  third.   Incineration  of oven  exhaust  has  been


used  at a  number  of  plants.    Topcoats   with  greater  than   50  volume


percent  solids  have  not   yet been  used  but  this  level  is  being  approached.


One  compa.iy  plans  to use  topcoats  with  greater  than 70  percent  solids

              or
before 1981.      Incineration  or  adsorption  of  spray  booth  exhaust,


although  technically  feasible,  has  not  been  used  at  any  plant.    Carbon
                                        6-16

-------
adsorption  of  spray  booth   exhaust  would  require  pilot  studies  because  of
known   potential   problems.   Thus  the  timetable  and  cost  of  compliance  are
more  uncertain  using  carbon  adsorption   than  for  other  methods.
      Finally,  it should  be  noted  that  inclusion  of  a  discussion  of  a
technology  in  this  report   indicates  it  is  technically  feasible,  that  is
that  no   invention   is   required  for  its  implementation.  No  judgement  is
made  as  to  its  reasonability  or  advisibility  for  a  given  situation,  from
a  standpoint  of  either  cost  or energy.
6.4.1   Option  1  -   Electrodeposition  of  Water-Borne  Primer  -   This  option
assumes    electrophoretic    (electrodeposited    or   electrocoated)    application
of  primer  to  the vehicle.   Spraying  of  water-borne   primers   is  possible,
but  it  does  not achieve the   same   coverage  or  lend  itself to  automation
as  well   as  the  electrophoretic  method  does.   Water-borne   spray   priming
is  used  at  some  plants  and  it is  a  viable  option  for  many plants.    It is
important  to  evaluate  the   ratio  of organic  solvent   to  solids  for  spray
primers  and  the  losses  due  to  overspraying  to  determine  the  effective-
ness  of  this  option.
Achievable    Reduction -   The  amount   of   organic   solvent  in  an  electrophoretic
coating   is  less  than   0.15  Ibs  per  gallon   (minus  water).  However,   solvent
emitted  from evaporation in  the  tank  and  from  the   "surfacer"  used   after  the
dip  increases  the  overall  total to   about  1.9  Ibs  per  gallon  (minus  water).
The  percentage   reduction  achieved   by   a  change  to   electrophoretic   coatings
depends  on   the  original  system.  For  example,  if  the  change  is  from  a  32
volume  percent  solids  primer   (about  5.3  Ibs  of  organic  solvent  per  gallon
of  coating)  to  electrophoresis (about  1.9    Ibs  of  organic  solvent  per  gallon
of  coating),  the  reduction   is 80  percent.
                                        6-17

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Technical   Analysis  - A   description  of   electrophoretic   priming  (electro-
deposition  or  electrocoating)  is  provided  in   Section  3.3.1   of  Volume  I.
As   discussed  earlier,   electrophoretic   priming  requires   better  precleaning
of  the  metal  than  does  an  organic solvent-borne  primer  and  it  requ i res a
final   rinsing   with  deionized  water  before priming.
      With  an  organic  solvent-borne  system,  the  assembly  line  can  be
stopped   overnight,  on   weekends,  or  during shift   changes  and  breakdowns.
This  is  not  possible  with  electrophoretic  primer   or  with  other  water-
borne  systems  because  of  the  potential   for  rusting  and  dirt  pick-up   (due
to  the  longer  time  it  stays  wet).   Thus,  vehicles  covered   with  water-
borne  coatings  cannot  be   left  for  long  periods  of  time  before  being
baked   and  the assembly   lines  must have   the   capability  of   carrying   coated
vehicles   through   the  oven  after   assembly  line  shutdowns.   Accommodations
must  also  be  made  for   storage  of  these  vehicles  or  parts until  the  line
starts  up  again.    This   necessity   for   surge  storage  areas   and  independent
conveyor  chains  for  each  of  the   spray   booths  results  in  additional
conveyor   controls   and   costs.
      The  major  limitation  of  electrophoretic  dip  coating  is  that  it  can
be   used   only   directly   over  metal   or  other  conductive  surfaces.  It  is
 limited  to  one-coat  applications  or  primer finishes,  and  there  is  a
practical   maximum   thickness  that   can  be   achieved.'  A  bath  can only
contain one  color  so  a  separate  bath  would  be  necessary  for  each   color.
None  of  these problems  adversely  affects  the  use  of   electrophoretic  dip
 for primer,  but   they  do  make  it  unusable for  motor  vehicle  topcoats.
                                                                         13
 Electrophoretic dip  coating  is  a   fully  demonstrated technology.
                                     6-18

-------
     A consideration for  any control  option is natural gas usage.  In




electrophoretic dip priming, gas is used in the ovens.  Although higher




temperature must be maintained for a  longer time period than when



curing conventional primers,  organic  solvent  emissions are far less.




Thus,, required air flow may be reduced (this is limited by the ventil-




1ation necessary to keep oven gases from escaping and  to remove  reaction




products from the oven).    Unlike  organic  solvent-borne  primer,  no dry-




off of the body after cleansing is required prior to the electrophoretic




coating, therefore it eliminates fygl usage for this purpose.




     Electrical requirements  increase by about 1400 kilowatts  by a




switch to electrophoretic coatings.   Electrical  requirments for applying




the coating  are  about  1000 amps at 400 volts (400  kilowatts). Ford




reports that their plants use 1500 amps at 200 volts  (300  kilowatts).




Cooling requirements for the bath are about 150 tons of refrigeration,




equivalent to about 1300 kilowatts.   Some  additional  power is av50




required for the agitation  and ultrafiltration steps.   Note that  ;0 to a




300 kilowatt credit in power usage can be  taken because most of  the




120,000 to 260,000 SCfm exhaust from  replaced spray booths is  no longer




required.  ($ome spray booths may  still be needed  for surfacer.)




Depending on climate, this  air would  have  to  be  heated in the winter,




usually by natural gas, steam or propane.   Finally, there is no  increase




in pumping requirements since the circulation in the bath  that is




necessary in electrophoretic  systems  for mixing  and water  circulation is




offset by elimination of the water which would be required in  the spray




booths for collecting particulate,
                                 6-19

-------
     In summary, since an assembly  line  applying  organic solvent-borne




primers uses about 12,000 KW of electricity, the  1400 kilowatt  increase




caused by  electrophoresis represents a 12 percent increase.



Cost of Control Option » The principal disadvantage of electrophoretic




dip priming is its high capital cost.  Maintenance costs are equal to or




less than those for conventional spray systems and  operating  labor is



'reduced.   More coating is applied per vehicle than when spray is used




because coverage is better but total paint  usage  is about equal to spray




coating because there is almost no waste.




     The  installed cost of an electrophoretic system for a typical




vehicle assembly plant would be about $8 million.   Costs can, of course,




vary considerably depending on what building alteration and relocation




of existing equipment is necessary.   Table 6-1  gives increased operating




costs  for electrophoretic primer,  based  on electricity at $0.03/KWhr,




interest  and depreciation at 12 percent  of capital costs, and operation




for 4000  hours per year.




Effects and Limitations   - Electrophoretic  dip  coatings contain amines




that are  driven off during the curing step. Some plants have found  it




necessary to incinerate  the oven  exhaust gas to eliminate the visible




emission  and nialodors associated  with these amines.  No  other  adverse



environmental effects appear to result from a  change to  electrophoretic




dip  coatings, and no apparent safety problems exist, assuming normal




industrial procedures are followed.   The energy  impact was discussed




earlier in  this  section.
                                 6-20

-------
            TABLE  6-1.   INCREASED ANNUAL OPERATING COST
  FOR ELECTROPHORETIC DIP PRIMERS COMPARED TO  SOLVENT-BORNE PRIMER
Utilities:

  Electricity                $.03/kWhr x4000 hrs/vr  x 1400KK  168,000


Direct   labor:                8hrs/shift x 500 shift./yr         -180,000a
  Savings of                3 workers/ shift $15/hr


Interest and                 12 percent x  ^1^000,000             120,000
  depreciation               to 8,000,000} '                  to  960,000
     Total increased operating cost    —  108,000 to  948,000 $/yr
   There is a net credit for labor cost for electrophoretic dip  coating.
  The calculation is for the  difference between one operator VeTSU^ four
  in a conventional SDrav booth applying organic solvent-borne  primer.


 Assuming 20 year life,  10 percent  interest.

 The range of values is for different ages of the  existing prime line.
The  lower value represents the increased total installed cost of an
electrophoretic dip line over an organic solvent-borne crime line for a
plant with  an old prime line ready for replacement. The higher  value
represents  the total  installed cost for a plant with a new sol vent -
borne pr i me  1 i ne .
                             6-21

-------
§.4.2 Option  2  -  Lower  Solvent Primer  and  Topcoat  -  This  option  is  the



use   of   lower   solvent  (higher  solids)  organic  solvent-borne  systems   (not



to  be   confused  with  "high-solids" coatings  discussed   in   Volume   I,



Section   3.3.2).  At  many of its  plants,  General  Motors  uses  lacquers  for



the   topcoat.    Lacquers  have  very  low solids  content  (^14 volume  percent).



Ford,  American  and  Chrysler  use topcoat   enamels  with  22   to  35  percent



solids  by  volume  {^33  to  45   weight  percent).  Volkswagen  expects  to  use


                                                                              25
topcoats  with  ^70  volume  percent  solids  (80  weight  percent)  by  1981.



Current  solvent-borne  prime  coats  vary  from  26  volume  percent4   to  37



volume   percent  (sealer  at  new Volkswagen  plant).  European  and  Japanese

                                                    H

manufacturers   use  enamels   almost   exclusively.



      This  option  examines  the  general  effect  that  raising  the  solids



content  of  coatings   has  on  emissions.   The  choice  of  50  volume  percent



solids  as  a base is  intended as  an   example  only  since any  increase  in



solids   content   can   dramatically reduce   emissions,   as  shown  Figure  6-2.



An  obvious  improvement  would  be a change  from  a  low  solids  lacquer



system  to  a  higher  solid  enamel  system.



      Any  regulation  calling  for  a  minimum  solids  content  should  be  based



on  an  average   over   at  least  an  hour since the  solids  of different



colors  and  coatings  can  vary within   a  plant.   Distinction   between   weight



percent  and  volume  percent  solids  is also  necessary.



Achievable    Reduction «  The  achievable  reduction  again  depends   on  both



the  old  dating and its  replacement.   For  example,  the  50  volume  percent


coating  achieves  an  86 percent   reduction   if  it  replaces  a lacquer with



12  volume  percent  solids,  but   only  a 53  percent  reduction  if it  replaces



an  enamel  with  32   volume   percent  solids.  Obviously,   even   further



reductions  can  be  achieved  if  an  add-on  control  device  is  also  installed.
                                        6-22

-------
Technical Analysis  - There  are no significant changes in operating




requirements necessary to switch to lower solvent coatings.   Nozzles




would have to be slightly modified as  would procedures for application




and curing, but  generally,  the same equipment would  be used.  Oven




exhaust volumes could be reduced considerably, as could the number of




spray   booths,  if lacquers were replaced with enamels.




     There are no unresolved technical problems  associated with this




option.   At present only General Motors uses lacquer for vehicles, but




even they apply  enamel to many of their light trucks and some of their




automobiles.    General Motors recently  converted  their Kansas City




assembly plant from applying lacquers  to enamels on a trial  basis.




Cost of Control  Option • Typical capital costs for this option are




difficult to assess because they depend completely on the specific plant




situation.   We estimate a change from  lacquer to enamel would require a




capital cost  (including  engineering)  of $1,000,000. (General  Motors




claims that  it would  be  higher.) Based  on  a rule of thumb 12 percent of




capital investment, annualized operating costs could be as high as




$120,000 per year although  this would  be affected by the lower manpower




required to apply enamels and the increased manpower which would be



                                   4 14
needed to repair damaged coatings.  '




Effects and Limitations - The chief impact of this option would be on




General Motors (GM) Corporation,  the only company still predominantly




using the lacquer system.




     The energy  required to cure enamels should  be less than for ITacquers




because of lower exhaust flow rates (since fewer coats are needed,, fewer
                                 6-23

-------
booths are  used and less solvent is evaporated).  This potential energy




savings is  partially offset by  the  higher temperature required for




curing   enamels.




6.4.3  Option 3  -  Carbon Adsorption for Primer and Topcoat Spray  Booths  -




As discussed in Section  6.2 of  this volume, 85 to  90  percent  of the




solvent emissions  from organic  solvent-borne  coatings occur in the spray




booth and flashoff area  and only about  10 to  15  percent in the ovens.




This option considers installation  of carbon  adsorbers to control  organic




emissions from the spray booths and flashoff  areas where it is assumed




85 percent  of the  emissions occur.




Achievable  Reduction * Reductions of greater  than 85 percent can be




achieved using carbon adsorption to control emissions from primer and



               K  ^  15,16,17
topcoat  spray  booths.




Technical Analysis - Spraying processes for topcoats and primers are




subject to  the same health-related constraints on concentration because




an operator is required  in the  booth.   Thus the organic concentrations




in the exhaust typically average about  100 ppm and can be lower.   Some




areas,  such as  the booth for two-tone  coating jobs,  have significantly




lower average concentrations.




     There  are  problems  in the  application of carbon adsorption for




automotive  and  light duty truck spray  booths. These  problems, which




arise from  the  presence  of particulate matter and water miscible  organics




in the  inlet stream and  from high humidity, are  solvable.  General




Motors has  acknowledged  that activated carbon can be effectively  used" on




spray booths and  ovens to reduce solvent emissions by 90-95 percent if


                                                                               16  '
the carbon  adsorption system is properly engineered  and regularly maintained.   '
                                 6-24

-------
For instance, although excessive particulate matter  can reduce carbon


life, spray booths generally already use  some  type of particulate


control.    In  smaller booths this may be a panel  filter, although in the


more typical larger booths, 95 percent efficient water scrubbers (water-


wash booths) are used to give  a low particulate  concentration level.'


The remaining 5 percent could  still have  a significant effect on an


adsorber but additional particulate removal can  be used if necessary.


Such particulate removal  has  not been  included  in cost estimates.  A


humidity problem,  if any,  can be solved  by reheat of the gases. About a


10 F reheat may be necessary to reduce  the relative  humidity  below  80


percent.    Solvents that  are deleterious  to carbon can be avoided.  Spray


booth temperatures are too low to  degrade coimon solvents or  vaporize or


break down any of the resins into  compounds that can cause problems.


     As with any add-on control device, the capital  cost is largely


dependent  on the flow rate.   Generally anything that decreases flew


rates of exhaust will decrease capital  and fixed operating cost.  Possib le


methods of reducing  flow  rates include reduction of velocities past the


workers (yet  remaining in compliance with health requirements) and


recirculation of cleaned exhaust air from manned spray areas  to unmanned


areas using automatic spray.   '    Improved automatic spray machines


under development will enable  the  use  of  a wider variety of coatings  and

                            4
also decreased ventilation.    Another  avenue  that might be profitably


explored is to protect workers with breathing  masks  supplied  with an


exterior source of clean air.   This would permit reduced exhaust flow


rates limited only by the necessity of providing adequate ventilation to


avoid cross-contamination  of vehicles  on  the  line and by health  regu-
                                    6-25

-------
lations.      An attractive possibility,  especially for users of lacquers,
is  to switch to higher solids material  to reduce flow rates before
applying   carbon  adsorption;  the  lower  the  flow rate,  the  lower the
cost.
      Questions  that  have  been  raised  in  comments  to drafts  of  this
report  as  to  the  validity  of  the  assumptions  on  which  we  predicate
carbon   adsorption   can   be   satisfactorily   answered.   Therefc,   of   course,
no  one "typical solvent fnixtare^for^nc||^^                        i  &  -.
                                            &            "'  -4V ""    '
The  important  factor  in  assuming  a solvent  for  cost   estimation  purposes
is  that  it  be representative  of  the actual  solvents used  (to   the  greatest
degree  possible)  in   the  characteristics   important  to   the   control   technology
being   evaluated.   The  mixture  of  hexane  and  benzene  meets  these  criteria
for   carbon   adsorption.   This  mixture  was  chosen  because  it  represents
the  two   largest  classes  of   solvents  (aliphatic  and   aromatic  hydrocarbons)
used,  because  the  molar  volumes  of  these  compounds   are  representative  of
most  solvent  blends  (see  Section  3.2.1   of Volume  I  of  this  series  for
the  importance  of  this),  and  because  cost  data  were   available.  The
question  of  the miscibility  of  the  solvents  will  be covered  in  the  next
section.
      Although  carbon  adsorption  is  technically  feasible,  (i.e.,  no  new
inventions  are  needed   for  its  implementation),   no   full-scale   instal-
lations  are  presently  in  operation  on   automobile  or  truck  assembly  plant
paint spi ay  booths.   As  noted  earlier,   pilot  studies   would  be  necessary
for  use  of  this  technology.
Cost  of  Control  Option -  These  costs  were  estimated   assuming  adsorber
modules,  each  capable   of handling  50,000  cubic  feet  per  minute..   Total
costs  for a system  would be  a  multiple  of  the  cost  for one.   Special
                                        6-26

-------
designs for high volume low concentration  flows  are possible to lessen




capital   costs, but were not  investigated for this study.




     Three cases are costed in Table 6-2.    (Note that although these




estimates include installation,  actual  costs could be higher for difficult




retrofit   situations.    Ford estimates that capital costs would be about




80  percent  higher.   )  The first is with solvent recovery and no credit




for  solvent.  The second  case,  which is for solvent recovery with credit




as fuel only, is probably the most reasonable assumption for assembly




plants.   The  third case  is credit for the solvent at its solvent value.




Assembly  plants   general ly use multi-component solvents and reuse would




be difficult.4




Impacts and Limitations - Due to the pressure drop associated with gas




flow through  a carbon  adsorber  and the  large volumes of air through




spray booths, the electrical  requirements  for handling air are large.




Steam consumption for  desorption is also large because of the laroe




amounts of  low concentration  gas.    (See Section 3.2.1 of Volume I of




this series for  details.) Some solvent used in  assembly plants are




sufficiently  water miscible  to  pose a water pollution problem if regene-



                                                    4 14
ration steam  is condensed and discharged untreated.  *    Many of these




compounds   (e.g.,  alcohols, esters and ketones) are primarily  in the




formulation to comply  with regulations based on photochemical  reactivity




such as contained in the  former Los Angeles APCD Rule 66 (now Southern




California  Air Pollution  Control  District Rule  442). With effective




add-on controls,  less  expensive water-immiscible solvents could be




employed.    Carbon adsorption of these "non-exempt" solvent blends
                                   6-27

-------
      TAB'LE 6 2.   COST ESTIMATES FOR AUTOMOBILE AND LIGHT TRUCK ASSEMBLY
           PLANTS  WITH CARBON ADSORPTION FOR TOPCOAT SPRAY BOOTHS AND
                                FLAS'IOFF  AREA?
                         CASE 1
                 CASE  2
                                                         CASE 3
        cost
No credit
for  solvent
                                      Fuel  value
                                      for  solvent
                                                       Solvent  at    b
                                                       solvent  prices
Capital   cost
 per 1000 ft3 /min     '10,820

Total   capital           c
 cost, $ x 106      2.7  -

Annualized
 operating cost
 per 1000 SCfm,  $       4,162
otal annualized       r      ,
operat 1 ng  cost,    1.0  -7.3
t if in6
   Total annualized
    operat
    $ x  10

   Steam  use,,
    Ib/hr x 1(
  7c-55d
Cost per  ton of
 organic  removed,$     1,153
                                           10,820
                                         2.7C - 19.6d
                                            4,003
                       - 7.26
                                        7c-55d
                                            1,110
                                      10,820
                                   2.7C  -
                                      3,643
                                                        n.90C  -  6.61d
                                                         7c-55d
                                       1,005
'Based on 100 ppm of hexane-benzene - 90 percent removal  and 5840 hrs per year
 ooeration.    Correction  factors for different operating hours assumptions and
 a list of other assumptions can be found in Chapter 4 of Volume  I.   Note  tint
 costs for condensate stripping [if necessary) are not  included.


 It is very unlikely that recovered organiCS could be reused as solvents.

'Based on 50 percent solids topcoat (248,000  SCfm).

 Based on 12 norcent solids toncoat (1,815,000  scfm).
                                      6-28

-------
                                                     14
 (e.g., toluene and xylene)  would be less difficult    although some

 treatment of the condensate might still be necessary.   In  cases  where

 such a problem is unavoidable,  the uncondensed steam  (or  hot air if hot

 air regenerated ) and solvent can be incinerated  together   '   '   '

 or the condensate can be  stripped and the miscible solvent disposed of
   '   V - .              ,            '• ! ''
 properly.    The size, fuel usage and the cost of this  incinerator is many

 times less than if incineration were used alone.    There will, of course,

 be extra'  costs associated with  these  solutions:"  These  costs are,
'••''•'•  -r.T'r-M  IT.'"  '••••!,!!  -if!'  virrdi.:''  ";   vi/  , v.     ;.,'..'.. . 'Li1   .,  ; .tin    ifiili  ... l'  i ", -..>*' 0 J'-> '
      An important factor  which  must be considered before selecting
                                                        . b9V 1 nv'l"!!  V i n'j | lt>
 carbon adsorption as a means of control is space.   The exhaust from

 assembly plant topcoat spray booths and flashoff areas may need as many

 as 6 to 37 dual-bed carbon  adsorption units in parallel operation.    The

 floor area required by the  adsorbers would be comparable  to that'occupied

 by the spray  booths.

 6.4.4 Option  4 -  Incineration  for  Spray  Booths

 Achievable Reductions  - Reductions in volatile emissions  of 95 percent

 are achievable with incineration.
      :., I "j   ! •        i  •   l - I .  .
 'Technical    Analysis  • The  basic  requirement  for  noncatalytic  incineration

 is to maintain sufficient temperature to combust the  gases.   For  the

 cost estimates presented  here,   an exit temperature of 1400 F has been

 assumed.   Depending on the  solvents used, however,  the  operator may be

 able to lower this somewhat and still achieve sufficient  oxidation of

 the organics.
                                  6 -29

-------
ec bfucsv  ;3nsi\A  bus ensure? ,.?.9;
                                    the
         Important operating  requirements for catalytic  incineration are
    ^tHw 29?5j n i   -v'f&229D9rt sd '  i U £ trio rr; s^Scfisbnoo srij ?ro 7 nsmj nS'fj
  necessity to preheat and, periodically  clean or replace the catalyst.
  , ,•'  •"'' "U£ Jon  ID;  mn9Jd  be ansbnoofuj erlj t 91 jab rovsnu 2  i fne i'dc^q e fiou?
   Moni ^pring or periodic testing of the  exhaust eases is necessary  to
          '                ustS'ianrDfif sd n&z tnevFoa bn& I  bsj sisrisrisi i rb
    assure that combustion is complete.
   TO Dsaoqa'rb- .tnsvfoa sfdroarm srtt  brie  bsqq'ma sd  nso  sjfiansbnoo  9 fit 10
         Although there are no  major technical problems associated with
 Y, -rr. "  ^ ;T' _t~"
    (e.g.,  for  odors).
                        ni'j  --" ,   v u  anc  ir».iU'-H -  sr* • '<"$ w :••*'   •- .'.-    ~  /
    Cost of Control Option  -  Incineration was  only considered for topcoat
                                           (  ^e't&n'rjfii  -J  rw 9 Fdsve !;'„•?  tr*;.
    related streams since the advantages of electrophoretic dip coatings are
                                                       '
    such that this would likely be the preferred  control method of reducing
                                                ••  '          ;i ro. .: i r;rn oj : r
    emissions from application of the prime coat.
                                          ji/wi i-j.tr.-.  i-r*q  ssJsrnrJ.?^  JSOD
         The following three options were considered  in estimating the cost
    of  control .
        ./!:*:>i>.'s.  . .   ,  •!;•  v-/9,:, £  ; : 32
         1.  Option  one is use of incineration without heat recovery.
                                                                  '
         2.   Option two is use of incineration with primary heat recovery,
    that is  preheating of exhaust  gases prior  to  incineration. The
    efficiency of heat recovery is 35 percent.
                                      &s- a
                                       6-30

-------
     3"  Option three  is the use  of a noncatalytic incinerator with 85
percent efficient primary  heat recovery. This option was  costed based
on captial costs and fuel and  electricity rates  given  in Reference 22.
Labor cost were assumed to be  the same as Option 2 and fuel costs were   23
reduced.   This option  is being used on a coil  coating  line in Wisconsin.
Heat recovery efficiencies of  up  to 90 percent are available.

Cost estimates for  these  three options are summarized  in  Table 6-3.

Secondary heat recovery was not costed as there  is no  apparent use for

this  energy.

Effects and Limitations -  Small  quantities  of oxides of nitrogen will

normally be formed  during incineration  (from  atmospheric  Np). If there

are nitrogen or sulfur-containing compounds present in the waste gas,

higher levels of their oxides may  be  formed.  Halogenated  compounds will

form  acids  upon   combustion.  The nitrogen oxides are formed  primarily at

high temperatures such as found  in a burner  flame and  are thus minimized

with high degrees of heat recovery.  Thus,  the heat recovery mandated by

cost and energy considerations should minimize nitrogen oxide emissions.

     The chief adverse effect  of incinerating spray booth exhaust  ''s

hl'Qh energy consumption.   This can be reduced through the use of: coatings

with lower solvent  content, catalysts, and primary and secondary hec.t

recovery.   Before requiring  incineration for spray booths one should

contact local fire  protection  agencies for  their approval.

6.4.5  Option  5  -  Incineration for Primer and Topcoat Ovens

Achievable Reductions  - Reductions in volatile organic emissions of 95

percent are achievable using catalytic or noncatalytic  incineration on

oven  exhausts.
                                   6-31

-------
                                  TABLE  63.   COST ESTIMATES FOR INCINERATION OF EXHAUST  FROM L
                                  AUTOMOBILE  AND  LIGHT  DUTY  TRUCK  ASSEMBLY  TOPCOAT  SPRAY  BOOTHS'L '
Costs
Capital cost per
1000 scfm, $
Total capital cost,
$ x 106
Annual ized operating
cost per 1000 scfm,$
Total operating cost,
$ x 10°
Fuel, Btu/hr x 10
Electrical
requ i rements , k W
No heat recovery
Option 1
Catalytic
6,814
i.6a-11.9b
8,674
2.1a-15.3b
182a-1332b
447a-3262b
Cost per ton of 2,!lr;
Organ 1CS removed, $
Noncatalytic
4,985
1.3a-9.4b
16,447
4.1a-29.8b
494a-3612b
349a-2553b
4,12n
38 percent efficient
Primary heat recovery
Option 2
Catalytic
8,050
2.0a-14.5b
7,306
1.8a-12.8b
118a'b-862b'c
7233-5280b
1,820
Yoncatalytic
6,435
1.5a-11.0b
11,578
2.9a-21.3b
314a'c-2300b'C
719a-5250b
2,910
85 oercent efficient
Primary
. heat recovery
Option 3
Noncatalytic
8,575
2.1a-15.5"
1,598
0.4a-2.6b
53a-384b
645a-4715b
a n
I
CO
ro
        Based on  50 volume percent solids,  248,000 Scfm from tODCOat booth(s).

        Based on  12 volume nercent solids  (lacquer),  1,815,000 Scfm from topcoat booth(s).

        Net energy  usaqe  considering recovered energy.

        Based on 95 nercent  removal  efficiency.

-------
Technical Analysis - There are no  serious  technical problems with the




use of incineration for oven exhaust  and incineration has been used on




automobile and  light truck assembly plant ovens.




Cost of Control Option  - The control  devices for the topcoat and the




primer ovens  -would most likely be separate.  Primer ovens have exhaust




rates ranging from 1600 SCflTl to 4500  and are assumed to operate at 10




percent  of the  LEL.  Topcoat  ovens have exhaust rates ranging from 3400




SCfm to 25,000 scftn, and are also  assumed  to  operate at 10 percent of




the LEL.




     Table 6-4 shows estimated costs  for primer and topcoat ovens




operating at  10 percent of the LEL.  Table 6-5 shows the cost for  15




percent  of the  LEL.  Note that the exhaust volumes are 33 percent lower




for 15 percent  of the LEL for the same solvent volume. The 15 percent




of the LEL case  is included to show the benefits of minimizing dilution.




It is important to note that  most existing ovens are operated at " fSS




than 10 percent of the LEL.   No  cost was assigned to the modificati  n$




necessary to  reduce air flow to achieve this concentration, however.




The modifications would vary considerably and it is difficult to estimate




a  "typical"  cost.  Since reduction of exhaust flow has a dramatic effect



on consumption  of increasingly scarce and expensive  natural  gas,this




modification  would  seem  to  be  mandated,  even without,  pollution  control




cons i derat i ons.




Effects and Limitations . As illustrated by Tables 6-4 and 6-5,  the fuel




consumed by incinerators for ovens need not be excessive if the ovens




operate above 10  percent  of the LEL.  If ovens were operated at
                                   6-33

-------
                         TABLE  6-4.   COST  ESTIMATES FOR  INCINERATION Oh tXHAUbl ur fiunt miu
                                       OVENS  FOR  AN  AUTOMOBILE  LIGHT  TRUCK ASSEMBLY Pt
                                            (AT  10 PERCENT OF  THE LOWER  EXPLOSIVE  i
i Flow rate3
and option
Lower
Option 1
Catalytic
Noncatalytic
Option 2
Catalytic
Noncatalytic
Option 3
" Catalytic
^ Noncatalytic
Higher
Option 1
Catalytic
Noncatalytic
Option 2
Catalytic
Noncatalytic
Option 3
Catalytic
Noncatalytic
i 1
Capital cost
for prime
oven , *
52,800:
31,400
79,40 b
69,20
-------
                            r\nu
                                      PLANT  (AT 15 PERCENT LOWER  EXPLOSIVE LIMIT)'
F low vtcH
and opt ! o r
Lower
Option 1 (No heat recovery)
Catalytic
Noncatalytic
Option 2 (Primary heat
recovery)
Catalytic
Noncatalytic
Option 3 (Primary and
secondary Heat recovery)
Catalytic
Noncatalytic
Higher
0"! >on ' 'r-1' heat recovery)
(itai,/ I*.
Noncatalytit
Option 2 (Primary heat
recovery)
Catalytic
Noncatalytic
Option 3 (Primary and
secondary heat recovery)
Catalytic
T Nuncatalytic
Capital cost
for pri me
oven, $b

42,100
41,000
49,000
48,800
56,700
57,400

122,000
112,000
146,000
126,000
170,000
158,000
Total
capital
cost, $ e

106,000
106,600
123,500
122,800
142,700
144,500

281,000
239,000
340,000
281,000
400,000
343,000
Annual total
operating
cost, $/yr e

48,600
58,800
42,500
48,500
42,500
44,000

197,400
254,000
147,000
163,000
105,000
102,000
Net energy
used,
xlO6 Btu/hre

1.2
2.8
.2
1.13
••"1
- .13d

9.0
21.5
1.5
8.5
-5.0d
-1.0d
Electrical
requirements,
kWe

10.6
8'. 2
13.3
12.2
16.0
16.2

80
62
100
92
120
122
Cost per ton
of organics
removed, F/ton^

195
236
171
195
171
177

108
139
81
89
58
56
l ower flow rate:  1,100 scfm for prime  oven:  ?,20n *r\lit for  topcoat oven.   Higher  flow  rate:  8,333 scfm for prime
  oven ,  16,666 SCfm for topcoat oven.
Calculated  from  data for  5^00 SCfm  using  six-tenths  rule.
Based  on 95  percent removal.
Recovered energy is greater than energy input.
                                                                    Prime  and Topcoat

-------
15  percent  of  the  LEL,  incinerators  can  actually  save  energy  by  recovery
of  the  fuel  value  from  the  solvents  that  would  have  been  exhausted.
This  energy  can  displace  natural  gas  or  other  fuels  that  otherwise  would
be  needed  for  the  oven,  for  metal  cleaning,  for  building  heat,  or  for
other  uses  in the  plant.   Note  that  distillate oil  as  well  as natural
gas  can  be  used  as   fuel   for  noncatalytic  incinerators.   Incinerators
with  higher  heat  recovery  efficiency  can  be  used  to  minimize  fuel  usage
even  of streams  with  lower  LEL  values.
6.4.6   Option  6  *   Water-Borne  Topcoats
Achievable    Reductions  -  Reductions  in   organic  solvent  emissions  of  up  to
92  percent   from  topcoat  spray  booths  and  ovens  are  achievable using
water-borne    topcoats.    The  exact  reduction  depends  on  both  the   original
coating   and   the   replacement.   If,  for  example  the  original  coating  were
 12  volume percent  solids  lacquer (6.5   Ibs  of  organic  solvent  per
gallon   of coating)  and  the  water-borne  had  2.8  Ibs   of organic solvent
per gallon   of coating  (as   do  GM  coatings   in  California),  reduction would
be  92  percent.    If  the  original  coating  were  33  volume  percent   solids,
reduction  would  be  70  percent.
Technical    Analysis -  Water-borne  topcoats  are  currently  being  used  at
two  General  Motors  automobile  assembly   plants   in   California  on a full-
scale   basis.   Although there  can  be  no  argument  as  to  the  technical
feasibility   of   water-borne   topcoats,  a number  of major   process   modifications
are  necessary  to  retrofit   this  technology  to   an   existing   plant.   '
These   are:
                                        6*36

-------
       1.   Lengthening of flash  tunnel  and ovens •  Water-borne coatings




  require a  longer  flash tunnel  prior to  curing. Temperatures must also




  be raised more slowly  in order to evaporate the water slowly enough to



  avoid  pitting the  coating.   This necessitates longer ovens, which in




  turn may force equipment relocations.



       2.   Cleanliness - Water-borne  coatings  do not "touch dry" (dry to




  the point where the surface  can  be  handled)  as quickly as solvent-borne




  coatings.   Thus they are more susceptible to  dirt pick-up. This necessi-




  tates filtration  of incoming spray booth air.  Overhead conveyors may




  also be unacceptable because of  potential  for dropping dirt on newly




  painted  parts.




       3.   Humidity and  temperature- Because the major solvent being




  evaporated is water, proper  temperature  and  humidity conditioning of the




  make-up spray booth air is vital.   If the humidity  is too  high or the




  temperature  too   low, the solvent will not dry quickly enough an' the




  coating will sag  on vertical surfaces.   If the humidity  is too  If./  or




  the temperature too high,  the  water will evaporate too rapidly and the




  coating will have "orange peel"  or  pits.   Each coating must be  for-




  mulated for a narrow humidity  range,  but formulations for  different




  humidities (within limits)  are possible. Water can be removed  from




  incoming air by chemical or  mechanical means.   The  chemical means




involves the use  of a  hydrosccpic solution.   The mechanical means




  involves the use  of refrigeration cycle.  The  most  economical choice




  depends on both the climate  and  the availability  of energy at the plant.




  The chemical method is more  complex,  but requires less energy.
                                   6-37

-------
The chemical method uses steam as  its energy  source while the mechanical



method uses electricity.   Thus,  steam availability favors the chemical




choice.   Both methods have been  used. '




     4.   Shutdown  * Because of the potential  for rusting and dirt pick-




up, vehicles coated with water-borne coatings cannot be left wet over-



night or even during shift change.   The assembly line must have facilities




for carrying painted vehicles through the following oven after a line




shuts  down.  Accommodations must also be made for storage of these




vehicles until the line starts up  again.   These requirements  necessitate




surge storage areas and independent conveyor chains for each of the




spray booths with  resultant controls and costs.




     5.  Cleanup - Unlike  overspray from organic solvent-borne coating,




water-borne coating overspray does not dry in  the  air before  being drawn




through the particulate collector.  This causes increased cleanup




problems  and  costs.




     6.  Sludge handling  - Water-borne coatings do not harden in the




water-wash particulate  collectors  ,  sludge  handling  is  more  difficult.




     7.   Corrosion -  The  pipe  commonly used  to convey  organic  solvent-




borne coatings from central mixing areas to the spray booth are not




suitable for water-borne coatings  and must be replaced with a corrosion




resistart   material.   The  lifetime  of carbon steel  spray  booths may also




be lessened when water-borne  coatings are used.




     8.  Maintenance  -  Maintenance costs will  increase because of the




new air conditioning  and humidity  control systems required.
                                   6-38

-------
     9.  Repair of coatings - Repair of coatings  damaged during assembly


is more difficult  than for lacquers but no more difficult than  for  other


enamels.


Cost of Control  Option -  The cost of converting to water-borne  topcoats


for an existing plant  will  vary.   A major variable will  be  the  age of


the  existing  coating   equipment.   If near retirement,  it may be  better to


build  entirely  new spray booths and ovens.  This was done at one of two


automobile plants  which converted  to water-borne coatings.   In  this


case:,  costs  should be  adjusted  to  give credit for the  value  of  the


improved    facilities.


     If the  coating equipment is still relatively modern, however,


retrofitting will  entail  lengthening of ovens  and modification  of spray


booths  and  conveyors.   This was the approach taken at  the other auto-


mobile plant using water-borne  topcoats and is the basis for the  cost


calculations presented here.   Capital costs  for a switch to water-borne

                                                                     5
topcoats for the model plant are estimated to be about $20  million.


For a  plant where  the  entire coating line is replaced,  capital  COSIS are


about   twice  this.


     Incremental  operating costs include increased electrical require-


ments and  increased maintenance labor.   Coating material costs  are


approximately the  same.   Higher oven temperature  causes  an  increase in


natural  gas  usage.  Annualizea operating costs for  the model are  given


in Table 6-6.


Effects and Limitations - The effluent water from water-borne coating


processes  will  require the same treatment methods as that from SOlvent-


borne  systems.    The treated effluent is acceptable to  sewer authorities
                                 6-39

-------
                 TABLE   6-6.   INCREASED  ANNUAL  OPERATING  COST  ESTIMATt  FOR
                    WATER-BORNE  TOPCOATS   OVER  ORGANIC   SOLVENT-BORNE
                                        TOPCOATS
T - f
Utilities:
Electricity
Direct labor:
Maintenance \
Building overhead \
(
Taxes and insurance j
Interest, and i
depreciation I
Total increased
operating cost
$.03/KWhr x AOOOhrs x 50QOKW
y*
20 additional hrs/shift x
500 shifts/vr $15/hr
21 percent x capital costs =
0.21 x $20,000,000



$6on,noo
$150,000
$4,200,000


$4,950,000/yr
Assuming  a  20  year  life  and 10  percent  interest  charge
                                          6-40

-------
at the two California plants now using  the  coatings.   Water-borne




coatings do not precipitate and dewater as  well  in the overspray col-




lection water as  do  some  other paints and this lack of dewatering




creates an increased solid waste disposal problem.




     The additional  electrical energy consumption to apply water-borne




coatings  is  about 5000  KW.   Since  a typical plant uses about 12,000 KW,




a change to water-borne topcoats increases  electrical  usage by 42 percent.




6.5     Comparison of Control  Options and Conclusions




Prime Line • For prime  application and cure, several control measures




are  applicable.    Electrophoretic priming and water-borne surfacer is the




most effective control  system.  The corrosion advantages of this system




is such that at  least one company  is replacing their priming systems




with electrophoretic systems as they are ready for replacement.   Water-




borne spray primer may  also be used.   Although emission reductions




through increased solids  content are more limited than for tOpCOfl.S




(enamels are very widely  used), this option is worth consideration since




there is still  a substantial  range  of  solids contents used. Incineration




of ovens is effective and not  energy intensive but it's benefit is   limited




since only 5-15 percent of the solvent  evaporates there.   Add-on devices




for prime spray booths  are technologically  feasible but probably would




not be installed  because  of the advantages  of a transition to an electrophoretic




coating.




Topcoat Line * Over  two-thirds of  uncontrolled emissions from the




coating line come from  the topcoat application and cure areas.   Considerable




reduction in emissions  can be  achieved  at many plants by increasing the
                                   6-41

-------
solids   content.   This is especially true  for plants using  lacquers.




Incineration of an oven exhaust  is effective for those  emissions  and




energy consumption is minor if the resultant heat is recovered, but  it




has limited impact since only 5-15 percent of the solvent  evaporates




there.   Carbon adsorption of spray booth  exhaust is technically feasible




but pilot studies are  needed to overcome the difficulties.  Incineration




of spray booth exhaust is technically feasible but it uses substantial




quantities of energy,  even with good heat  recovery.  Water-borne top-




COdtS are proven and reduce emissions considerably, but they are  substan-




tial users of electrical energy  and require substantial capital investment.




Unlike water-borne electrophoretic dip priming, there are  no product




quality advantages to the use of water-borne topcoats.




     Generally, different control options require different  lead  times




to implement and  utilize the technology. The consideration  of timing




(the time by which reductions are sought) should be included in determining




the degree of control required.
                                €-42

-------
References
1.   Sussman,  Victor,   H.,  Ford  Motor  Company,   Dearborn  Michigan.
    Letter to James  McCarthy in comment to draft of this report.
    Letter dated  August  6,  1976.

2.   LeBras,L.R.,  PPG  Industries,  Pittsburgh,  Pa.,  Letter to
    Vera  Gallagher in comment  to  draft of this  report.  Letter
    dated August  13,  1976.

3.   Schrantz, Joe,  Hitchcock Publishing Company, Wheaton, Illinois.
    Letter to James McCarthy in comment to draft of this report.
    Letter  dated  July 22, 1976.

4.   Johnson,  W.   R.,  General Motors Corporation,  Warren, Michigan.
    Letter to James McCarthy in comment to  draft of this report.
    Letter dated  August  13,   1976.

5.   McCarthy,  James, A., U.S.  Environmental Protection  Agency,  Research
    Triangle Park, N.C.,   Report  of trip to General Motors  assembly
    plants  in  South Gate and Van Nuys, California. Report  dated
    November  17,  1975.

6.   McCarthy,  James  A.,  U.S. Environmental  Protection Agency,  Research
    Triangle Park, N.C.,  Report of trip  to  assembly plant in Framingham,
    Mass.   Report dated November  17, 1975.

7.   Conversation with John Stockholm,  St. Gobi an Company in Paris,
    France,  September  20,  1976.

8.   Stockbower,   E.A.,  Amchem Products, Inc.,  Ambler,  Pa. Letter  to
    James McCarthy in comment  to draft of this  report. Letter dated
    August 2,  1976.

9.   Schrantz,  Joe, How  Autodeposited Coating  Benefits Chrysler.
    Industrial    Finishing, November 1975,   page  14.

10.  Anonymous,   "Electroless     Electrocoat"   Now  in  Production at Chrysler.
    Products Finishing, October 1975,  page  72.

11.  Conversation with Fred Port?r, Ford Motor Company,  Dearborn,  Michigan,
    September  23,  1976.

12. Johnson, W.   R. ,  General Motors Corporation,  Warren, Michigan.
    Letter to  James McCarthy in  COHItient to draft of this report.  Letter
    dated November  12,   1976.

13. Kachman, N.  C.,  General Motors Corporation,  Warren, Michigan.
    Letter  to Gerald  M. Hansler,  Region  II U.S. Environmental  Protection
    kg  OCy.   Letter dated February 11, 19  1.
                                   6-43

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14.  Bullitt,  Orville  H., E.  I.  DuPont  de  Nemours  &  Company,  Wilmington,
     Delaware.    Letter  to William  Johnson  in comment  to draft  of  this
     report.    Letter  dated  August  12,  1976.

15.  Sussman,  Victor,   H.,  Ford  Motor  Company,  Dearborn,   Michigan,
     Letter   to  James McCarthy  dated  August  6,   1976.

16.  Radian   Corporation,  Austin,  Texas,  Evaluation   of  a  Carbon   Adsorption
     Incineration  Control   System  for   Auto   Assembly  Plants.  EPA   Contract
     No.   68-02-1319,  Task No.  46,  January  1976.

17.  Johnson,   W.  R.,  General   Motors   Corporation,   Warren,   Michigan,
     Letter   dated  to  Radian  Corporation  commenting  on  Reference  16.
     Letter   dated  March   12,   1976.

18.  Roberts,  R.  W.  and  IB.  Roberts,  E.   I  DuPont  de  Nemours  and  Company,
     Wilmington,    Delaware.    An   Engineering  Approach   to  Emission   Reduction
     in  Automotive  Spray  Painting.    Presented  to  67th  Annual  Meeting  of
     the  Air  Pollution  Control   Association,  Denver,  Colorado,  June   1974.
     Paper No.   74-279.

19.  Sussman,  Victor  H.,  Ford  Motor   Company,  Dearborn,   Michigan   ,
     Letter   to  James  McCarthy  in  COlHnent   to  draft  of  this  report.   Letter
     dated November   15,   1976.

20,  MSA  Research  Corporation,  Package   Sorption Device  Systems  Study.
     EPA  Contract   Report No.   EPA-R2-73-202.   April   1973.

21.   Grandjacques,  Bernard,   Calgon  Corporation,  Pittsburgh,   Pa.,   Air
     Pollution   Control  and  Energy  Savings   with Carbon  Adsorption  Systems,
     Report   No.   APC  12-A.  July  18,   1975.

22,  Mueller,  James  H.,  Reeco,   Morris  Plains,   New  Jersey.  Letter  to
     James McCarthy  dated October  1,   1976.

23.  Inryco,  Inc.,  Mel rose   Park,  Illinois.   Inryco's  Solution  to   Paint
     Fume   Pollution.   Inryco  Today  1976/2.

24.  Combustion   Engineering   Air  Preheater,   Wellsville,  New   York,   Report
     of  Fuel  Requirements, Capital   Cost  and  Operating  Expense  for   Catalytic
     and  Thermal   Afterburners,   EPA   Contract   Report   No.   EPA-450/3-76-031,
     September  1976.

25.  Volkswagen  submittal   to   Commonwealth  of  Pennsylvania,  Summer  1976-
                                     644

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APPENDIX  A

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                              APPENDIX A





                          ANALYTICAL TECHNIQUES








     All analytical techniques  used in the determination of compliance




in the surface coating  industry have oreviously been published by the



American Society of Testing Materials (ASTM) or the U.S. Government




SlIDply  Agency.  This  Aooendix details the applicability and procedures




for  using  these  methods.   When used on certain coating products, however,




the methods may yield erroneous results.   Therefore,  any  emission  control




regulations which WOllld rely on these methods should also provide authority




for the source to request and the control agency to approve alternative




techniques.     During development of such alternatives, the source should be




encouraged to coordinate  with ASTM Committee D-l which is responsible for




the three ASTM test methods of interest,  numbers D 1644-59,  D 1475-60 and




D  2369-73.   The procedure that follows yields results in the units of mass




per  volume of coating.   If units of mass per volume of solids  are C4~sired»



the source should refer to ASTM test  method D X97-73.
                                 A-l

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                 DETERMINATION OF VOLATILE  CONTENT OF PAINT,  VARNISH,




                             LACQUER,  OR RELATED PRODUCTS






1.   Principle   and   Applicability




    1.1  Principle.   The weight  of  nonaqueous  volatile matter per unit volume




of  a  paint,  varnish,  lacquer, or related surface coating is calculated after




using standard methods to determine the density,  nonvolatile  matter content,




and (if necessary) water content of the surface coating.



    1.2  Applicability.  This method  is applicable to paint,  varnish,  lacquer,




and related products, which  are  air-dried or force-dried;  it  is not applicable




to any coating system which  requires  a  special curing process such as  exposure




to temperatures  in  excess  of 110% to promote  thermal cross-linking or exposure




to ultraviolet light to promote  cross-linking.




    There may be other specific  cases where the ASTM  methods  are not applicable.




In general, these cases will occur  when the evaporation temperature is so high




as to produce thermal degradation of  the nonvolatile  matter in the surface




coating or when the temperature  is  too  low  to  produce complete evaporation of




the  volatile  matter.  The former will generally be indicated  by a discoloration




of the solid residue, while  the  latter  will  be indicated by incomplete drying




of the residue (visible liquid or tackiness).




    Whenever it is determined that  the  ASTM methods are not applicable,




alternative methods subject  to the  approval  of the State or local agency, must




be used.




2. Classif'zation  of Surface Coatings




    For the purposes of this method,  the applicable surface coatings are divided




into  three  classes.   They arc:




    2.1 Class  I:   General  Solvent-Type Paints.  This class includes white
                                     A 2

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linseed oil outside paint,  white soya and phthalic alkyd enamel, white  linseed


o-phthalic alkyd enamel,  red lead primer, zinc chromate primer, flat white


inside   enamel, white  epoxy   enamel,  white vinyl toluene modified alkyd,  white


amino modified baking enamel,  and other solvent-type paints  not included in


Class  II.


    2.2 Class II:  Varnishes  and  Lacquers.   This class  includes  clear and


pigmented  lacquers   and   varnishes.


    2.3 Class III:  Water  Thinned   Paints.  This class  includes emulsion or


Idtex paints and colored  enamels.


3.   Applicable Standard Methods


    3.1 ASTM  D  1644-59 Method  A:   Standard Methods of Test  for Nonvolatile


Content of Varnishes.  Do not use Method  B.


    3.2 ASTM  D 1475-60:   Standard Method of Test for Density of  Paint, Varnish,


Lacquer,  and  Related  Products.


    3.3 ASTM  D 2369-73:   Standard Method of Test for Volatile Content of Paints.


    3.4 Federal  Standard 141 a,  Method 4082.1:  Water  in Paint and  Varnishes


(Karl   Fischer  Titration  Method).


4.   Procedure


    4.1 Classification of  Samples.   Assign  the coating  'to  one of  the  three


classes discussed  in Section 2 above.  Assign  any coating not clearly belonging


to Class II or III to Class  I.

                                                                        2
    4.2 Analyses and Calculations.   Determine the  density D  (in 9/cm  ) of


the paint, varnish, lacquer, or related product according to the  procedure


outlined in ASTM  D 1475-60.  Then, depending on the class  of the  coating, use one


of the following specified  procedures to determine the volatile content:
                                     A3

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    4.2.1 Class  I.   Use the procedure in ASTM D 2369-73; record the  following


information:


         W-j = Weight of dish and sample,  g.


         W,, s Weight of dish and sample after heating,  g.


          S = Sample  weight,  g.


Calculate the volatile matter  content Cv (in g/1 of paint) as follows:
                             r
                             lv =         1



To convert g/1 to  Ib/gal,  multiply Cy by 8.3455 x 10  .


    4.2.2  Class  II.   Use the procedure in ASTM D 1644-59 Method A;  record the


following    information:


          A  =  Weight of dish,  g.


          B  =  Weight  of sample used,  g.


          C = Weight of dish and contents after heating, g.


Calculate the volatile  matter content Cv (in g/1)  as follows:



                                   (A  + B -C)(Dm)(103)
                             "V ~           B


To convert  g/1 to  Ib/gal,  multiply C  by 8.3455 x  10   .


    4.2.3 Class   III.   Use the procedure in ASTM D 2369-73;  record the same


information as specified  in Section 4.2.1.   Determine the water content P (in


percentwater) of the paint according to  the procedure outlined  in Federal


Standard 14"1!, Method 4082.1.   Calculate the nonaqueous  volatile matter content
C  (in g/1) as follows:
                               (Hj - W2 . 0.01  PS)(Dfn)(103)

                          Cv =              S
To convert g/1 to  Ib/gal,  multiply Cv by 8.3455 x 10~3.
                                    A 4

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5.   Bibliography



    1.   Standard  Methods of Test for  Nonvolatile Content of Varnishes. In:



1974  Book of  ASTM Standards, Part  27.  Philadelphia,  Pennsylvania.  ASTM



Designation   D   1644-59.   1974.  p.  285-286.



    2.  Standard Method  of Test  for  Density of  Paint,  Varnish,   Lacquer,  and



Related  Products.   In:    1974  Book  of  ASTM  Standards,  Part  27.   Philadelphia,



Pennsylvania.    ASTM   Designation  D   14X-60.   1974.   p.  231-233.



    3.  Standard  Method   of  Test  for   Volatile  Content  of  Paints.  In:  1974



Book  of  ASTM  Standards,  Part  27.   Philadelphia,   Pennsylvania.   ASTM  Designation



D  2369-73.  1974. p. 441-442.



    4.  Federal  Test  Method   Standard  No.  141 a,  Paint,  Varnish,  Lacquer, and



Related  Materials;   Methods   of  Inspection,   Sampling,   and  Testing.   General   Semises



Administration,  Business  Service  Center.  Washington,   D,   C.   1965.
                                       A 5

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           APPENDIX  B
RECOMMENDED  POLICY  ON  CONTROL  OF



   VOLATILE ORGANIC COMPOUNDS

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                    ENVIRONMENTAL  PROTECTION  AGENCY




                              Air  Quality




                   RECOMMENDED POLICY ON  CONTROL OF




                      VOLATI LE ORGAN1 C COMPOUNDS








PURPOSE




     The purpose of this notice is to recommend  a policy for States to




follow on the control of volatile  organic compounds (VOC),  which are a




constituent in the  formation  of photochemical oxidants  (smog).  This




notice does not place any requirements on States; State  Implementation




Plan (SIP) provisions which offer  reasonable  alternatives to this policy




will  be  approvable.   However, this policy will be followed by EPA whenever




it is required to draft State Implementation  Plans  for the control of




photochemical    oxidants.






BACKGROUND
     Photochemical oxidants result  from sunlight acting on volatile




organic compounds (VOC) and oxides  of nitrogen.   Some VOC, by their




nature, start to form oxidant after only a short period of irradiation




in  the  atmosphere.   Other VOC may undergo irradiation for a longer




period before they yield meas'Table oxidant.




     In its guidance to States  for  the preparation,  adoption, and




submittal of State Implementation Plans published in 1971, the




Environmental Protection Agency emphasized reduction of total organic




Compound emissions, rather  than substitution. (See  40  CFR Part 51;




Appendix B.) However,  in Appendix  B,  £F stated that substitution of





                                 B-l

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one  compound  for  another  might be  useful  where  it  would  result  in  a
clearly  evident  decrease  in  reactivity  and  thus tend  to  reduce  photo-
chemical   oxidant    formation.   Subsequently,    many   State   implementation
Plans  were   promulgated   with  solvent  substitution  provisions  similar  to
Rule  66  of  the  Los  Angeles  County  Air  Pollution  Control  District.  These
regulations  allowed  exemptions  for  many  organic  solvents  which  have now
been  shown  to  generate  significant  photochemfcal   oxidant.
      On  January  29,   1976,  EPA  published  its  "Policy  Statement  on  Use  of
the  Concept   of  Photochemical  Reactivity   of  Organic  Compounds  1n   State
Implementation   Plans   for  Oxidant  Control."  The   notice  of  availability
of  this  document  appeared In  the  FEDERAL  REGISTER  on  February  5,   1976
(41  FR  5350).
      The  1976  policy  statement  emphasized  that  the reactivity  concept
was  useful  as  an  interim  measure  only,   and  would  not  be  considered  a
reduction  in  organic  emissions  for   purposes   of estimating   attainment  of
the  ambient   air   quality  standard   for  oxidants. The   document   also
included   the   following   statement:
      Although  the  substitution  portions  of  Rule 66  and similar
      rules  represent  a  workable  and  acceptable   program  at  the
      present  time,  better  substitution  regulations  can  be
      developed,   base3oiicurrentknowledgeof   reactivity  and
      industrial    capability.   EPA   in collaboration  with  State
      and  industry  representatives  will  formulate  in  1976  an
      improved  rule  for  national  use.
SUMMARY
      Analysis  of   available   data  and  information show  chat  very  few
Volatile  organic  compounds  are  of  such  low  photochemical  reactivity  that
they  can  be  Ignored  in  oxidant  control  programs,   for  this  reason,
                                       B-2

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EPA's recommended policy reiterates  the need for positive reduction




techniques (such as the reduction of volatile organic compounds in




surface coatings, process  changes,  and  the  use  of control  equipment)




rather than the substitution of compounds of low (slow)  reactivity in




the place of more highly (fast) reactive compounds.  There  are three




reasons  for  this.   First,  many of the VOC that previously have been




designated as having  low reactivity  are now known to be  moderately or




highly reactive  in urban atmospheres.  Second, even compounds that are




presently known to  have low  reactivity  can form  appreciable amounts of




oxidant under multlday stagnation  conditions such as occur during summer




in many  areas.  Third, some  compounds of low or negligible reactivity




may have other deleterious effects.




     Of the small number of  VOC which have only  negligible photochemical




reactivity, several (benzene,  acetonitrile, chloroform,  carbon tt ra-




chloride, ethylene  dichloride,  ethylene dibromide, and methylene c^oride)




have been identified  or implicated  as being carcinogenic, mutagenic, or




teratogenic.    An  additional  compound, benzaldehyde, while producing no




appreciable ozone,  nevertheless, forms  a strong eye irritant under




irradiation.  In  view of these circumstances, it would be inappropriate




for EPA to encourage  or support increased utilization of these compounds.




Therefore, they are not  recommended for  exclusion  from  control.  Only




the four compounds  listed  in Table 1  are recommended for exclusion from




SIP regulations and,  therefore, it is not necessary that they be inventoried




or  controlled.   In determining reductions required to meet oxidant




     , these VOC should not  be  included ir ;he base line nor should
                                    B-3

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reductions in their emission be credited toward achievement of the




\AAQS  .




      It  is  recognized that  the two halogenated  compounds listed in Table




1  (methyl chloroform  and Freon 113) may cause deterioration of the




earth's  ultraviolet radiation   shield  since  they  are  nearly  unreactive  in




the lower atmosphere  and all contain appreciable fractions of chlorine.




The  Agency  has  reached conclusions on  the  effects of only the fully



halogenated  chlorofluoroalkanes.   The Agency on  May  13,  1977  (42 FR




24542), proposed  rules  Under the Toxic Substances Control  Act {TSCA) to




prohibit the nonessential use of  fully halogenated  cblorofllioroalkanes




as aerosol propellants.   The restrictions were applied  to all members of




this  class,  including Freon  113,  since they are potential substitutes




for Freon 11, Freon 12,  Freon 114, and Freon 115, which are currently




used  as aerosol propellants.   The Agency is planning to investigate




control systems and substitutes for nonpropellant uses under TSCA, as




announced  on May  13.   Methyl chloroform is not a fully  halogenated




chlorofluoroalkane.   Rather, it is among the chlorine-containing compounds




for which the Agency  has not completed its analysis; EPA has not yet




concluded whether it  is  or is not a threat to the stratospheric  ozone.




Therefore,  it has been placed on this list as an acceptable exempt




compound.   As new information becomes available  on these  compounds,  EPA




will  reconsider the recommendation.




      The volatile organic compounds listed  in Table 2,  while  more




photochemical ly reactive than those in Table 1,  nevertheless  do  not




contribute large  quantities  of oxidant under many atmospheric conditions.







                                    B 4

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                                Table 1








        Volatile Organic Compounds of Negligible Photochemical




        Reactivity That Should Be Exempt From Regulation Under




                      State Imp]ementation Plans








                              Methane




                              Ethane




                             *l,1,1-Trichloroethane  (Methyl Chloroform)




                             *Trichlorotrifluoroethane  (Freon 113;
*These compounds have been implicated as having deleterious  effects  on




stratospheric ozone and, therefore, may be subject to  future controls.
                                   B 5

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               Table  2

Volatile  Organic  Compounds  of  Low
     Photochemical    Reactivity

             Propane
            Acetone
            Methyl   Ethyl   Ketone
            Methanol
             Isopropanol
             Methyl   Benzoate
             Tertiary  Alkyl  Alcohols
             Methyl   Acetate
             Phenyl   Acetate
             Ethyl Amines
             Acetylene
             N,   N-dimethyl   formamide
                   B-6

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Only during multlday stagnations do Table 2 VOC yield-significant




oxidants.   Therefore,  if resources are limited or if the sources are




located in areas where prolonged atmospheric stagnations are uncommon,




priority should be given to controlling more reactive VOC first and



Table 2 organics later.   Table 2 VOC are to be included in base line




emission inventories and reductions in them will be credited toward




achievement  of the  NAAQS.   Reasonably available control technology




should be applied to significant sources of Table 2 VOC where necessary




to  attain  the NAAQS  for  oxidants.   New sources of these compounds  will




also be subject to new source review requirements.




     Perchloroethylene,  the principal solvent employed in the dry




cleaning industry, is  also of low reactivity, comparable to VOC listed




in Table 2.    It  was  not included in Table 2  because of reported adverse




health   effects.  Uses, environmental distribution, and effects Q"




perchloroethylene currently are being studied intensively by occupational




health  authorities  and  EPA.   Findings from these investigations may have




major impact  on industrial users.   In designing control regulations for




perchloroethylene sources, particularly dry  cleaners,  consideration




should be given to these findings as well as industry requirements and




the  costs  of  applying   controls.   Available control technology  is  highly




cost effective for large perchloroethylene dry cleaning operations.




However, for  coin-operated and small dry cleaners,  the same equipment




would represent a  heavy  economic'burden.




     As part  of  its  continuing  program, EPA  will review new  information




relative  to  the photochemical reactivity, *"OX"icity, or effects on



stratospheric ozone  of  volatile organic COnipOUflds. Where appropriate,
                                   B 7

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additions  or deletions  will be  made  to the  lists  of VOC  in  Tables  1  and
2.

DISCUSSION
      Most  air  pollution  control   regulations   applicable  to  stationary
sources  of VOC  in  the United  States  are  patterned after  Rule  66 of the
Los   Angeles   County  Air  Pollution  Control  District   (presently   Regulation
442  of  the  Southern  California  Air  Pollution  Control  District).  Rule  66
and  similar  regulations Incorporate two basic strategies to reduce
ambient   oxidant   levels,   i.e.,  positive  VOC  reduction  and  selective
solvent   substitution   based   on  photochemical    reactivity.  Positive
reduction  schemes  such  as  Incineration,  adsorption,  and  the use of low-
solvent  coatings  are  acknowledged  means  of   reducing  ambient oxidant
levels;  they  should  be  retained   in  future   VOC   control   programs.   In
contrast,  the  utility  of  solvent  substitution  strategies  has  been
questioned  as  more  information  on  photochemical   reactivity  has  emerged.
      EPA  acknowledged  the  shortcomings  of  solvent  substitution  based   on
Rule  66  reactivity criteria  in  a  1976  policy statement  (41  FR  5350).
Findings  were  cited  which  indicated  that   almost   all  VOC eventually react
in  the  atmosphere  to  form  some  oxidant.    Concurrently,  EPA   Initiated   an
investigation  to   consider   implications-of   revising  the   solvent  substitution
aspect:  of Rule  66.   Three   separate   forums  were  conducted  with  repre-
sentatives  of  State  and  local  air  pollution  control  agencies,  university
professors,   and   industrial   representatives  with   knowledge   and  expertise
in  the   fields  of atmospheric   chemistry   and   industrial  solvent  applications,
In addition,   numerous  discussions   were   held  with  acknowledged   experts   in
                                      B-8

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the field.   Topics of particular concern were:




      . Whether Rule 66 substitution criteria could be revised




       consistent with available reactivity data and yet be




       compatible with industrial  processes and with product




       requirements.




      . Whether some compounds  are  of sufficiently low reactivity




       that they are not  oxidant precursors and can be exempted




       from control under State Implementation Plans.




      • Whether the imposition  of reactivity restrictions in




       addition to positive  emission reductions will delay




       the development or implementation of promising




       technologies, particularly  the use of water-borne




       and high-solids surface coatings.




      Investigation  showed   that:




      1.  Solvent substitution  based on Rule 66 has been directionally




correct in the aggregate  and probably effects some reductions in peak




oxidant   levels.   However,  because  of the relatively high reactivity of




most  of the substituted solvents,  the reduction is small compared to




that  which can be accomplished with positive reduction techniques.




Revision of Rule 66 consistent with current knowledge of reactivity




would eliminate the solvent  substitution  option for most sources in




which substitution is now  employed.   Many of the organic solvents which




have  been categorized as  having low photochemical reactivity are,  in




fact, moderately or highly reactive;  they yield significant oxidant when




subjected to  irradiation  in  smog  chambers Designed to simulate the urban




atmosphere.
                                   B-9

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     2.   A few VOC yield only negligible ozone when irradiated in smog




chambers under both urban and rural  conditions.  Experiments conducted




to date indicate that  only  methane and ethane, a group of halogenated




paraffins, and three other  organics--benzene,    benzaldehyde, and  aCEtO-




nitrile--can be so classified.   These compounds react very slowly yielding




little ozone during the first few days following their release to the




atmosphere.    Available data suggest  that none of the listed compounds




contribute significant oxidant  even  during extended irradiation  under




Hiultiday  stagnation  conditions.




     The broad group "halogenated paraffins"   includes   important   industrial




solvents, most of which are chlorinated methanes and ethanes and Chloro-




fluoroethanes.    They find use as metal cleaning and dry cleaning solvents




and  as  paint  removers.  Halogenated  paraffins  also serve as building




blocks in the manufacture of other halogenated organics;  these processes




do not necessarily release  significant VOC to the atmosphere.




     3. Besides  focusing  on VOC  of  negligible reactivity,  smog chamber




studies show that a few additional VOC generate oxidant at a relatively




slow rate.   Under favorable atmospheric conditions, these VOC  releases




may not form oxidant until  they have been transported substantial




distances and become greatly diluted.   However, under multiday stagnation




conditions such as occur during summer in many areas of the middle and




eastern United States, there is the  potential  for these organiCS to




undergo appreciable conversion  to oxidant.   The more important VOC in




this category are acetone,  methyl ethyl ketone, perchloroethylene,




methanol, isopropanol, and propane.  All  except propane are industrial
                                  B-10

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solvents..  The  latter,  a gas under normal conditions,-is associated




principally with crude  oil  and liquefied petroleum gas operations.




     4.   The vast  number of volatile organic compounds--particularly




nonhalogenated  VOC--yield appreciable ozone when irradiated in the



presence  of  oxides  of  nitrogen.   While there are measurable variations




in their rates  of  ozone formation,  all are significantly more reactive




than VOC  listed in Table 2. Quickly  reactive  VOC include almost  all




aliphatic and aromatic  solvents,  alcohols, ketones, glycols, and  ethers.




     5.   Low photochemical  reactivity is not synonymous with low  bio-




logical   activity.   Some of the negligible or slowly reactive compounds




have adverse  effects on human  health.  Benzene,  acetonitrile, carbon




tetrachloride,  chloroform,  perchloroethylene,  ethylene  dichloride,




ethylene dibromide,  and methylene chloride have been implicated as




being carcinogens,  teratogens, or  mutagens.  In addition,  bfifizal^hyde,




which produces  no  appreciable ozone,  nevertheless  forms  a  strong  eve




irritant   under   irradiation.   While their use might reduce  ambient oxidant




levels,  it would be unwise  to encourage their uncontrolled release.




Additional halogenated  Organics are being investigated  for possible




toxicity.




     Most of the related health information available at this time




concerns acute  toxicity.  Thre;- !0ld limit values (TLV's) have been




developed  for  many  VOC.   They are appropriate for the healthy, adult




work force exposed  eight hours  a  day,  five days a week.    Experts  suggest




that more stringent levels  should be  estsb.ished for the generalpopuld-




tion. Hazards represented by chronic  and r 'bchronic exposure are  much




i^Oi'B diTicult  to  quantify  than  acute  toxicity.  Adverse health effects




of the VOC cited above  are  generally recognized although not completely




                                  B 11

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quantified.    Chlorinated solvents currently are  under-intensive study.

     6.   Some VOC are of such  low photochemical  reactivity that they

persist in the atmosphere for  several years, eventually  migrating to the

stratosphere where they are suspected of reacting and destroying ozone.

Since stratospheric ozone is the principal absorber of ultraviolet (UV)

light, the depletion could lead to an increase in UV penetration with a

resultant worldwide  increase  in skin cancer.  The only in-depth analysis

of this potential problem has  focused on the chlorofluoromethanes (CFM),

Freon 11 and Freon 12, because of their known  stability and widespread

use  in  aerosol  containers.  A report of the National Academy of Sciences

concerning environmental effects of CFM1S concluded that:

     "...  Selective regulation of CFM uses and releases is
     almost certain to be necessary at  some time and to  some
     extent of completeness."

In response to the report of the National Academy of Sciences and other

studies, EPA on May 13, 1977 (42 FR 24542) proposed rules to prohibit

nonessential usage of fully halogenated chlorofluoroalkanes as  aerosol

propellants.    The restrictions were applied to all members of this class

including Freon 113 since they are potential substitutes for Freon 11,

Freon 12, Freon 114, and Freon 115 which are currently used as  aerosol

propellants.

     Other stable halogenated  solvents  which are released in volumes

comparable to the chlorofluoroalkanes also are suspected of depleting

the earth's UV shield.  Of major concern  is  the  widespread substitution

of methyl chloroform  (1,1,1 trichloroethane) for the  photochemically
                                 B-12

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reactive degreasing solvent  trichloroethylene.   Such substitution under




Rule 66 generation regulations has already influenced industrial degreasing




operations to the extent  that  methyl  chloroform production has surpassed




that of trichloroethylene in the United States. Any  regulation in the




area will have a marked effect on the production and  atmospheric emissions




of  both  solvents.   Endorsing methyl chloroform substitution would increase




emissions, particularly in industrial States  that have not,  heretofore,




implemented  Rule  66.   On the other hand, disallowing methyl chloroform




as  a substitute  or banning it altogether would significantly increase




emissions of trichloroethylene even if degreasers were controlled to the




limits of available technology.   Presently, technology is only able to




reduce emissions by approximately 50  percent.    In  metropolitan  areas




which have already implemented Rule 66,  a return to trichloroethylene




would have an adverse effect on ambient  oxidant levels.    In addit on to




being highly reactive,  trichloroethylene has been implicated as a



carcinogen.




     Alternatives to the  above-cited  choices would be (1) development




and application  Of highly efficient degreaser control systems and (2)




replacement  with an intermediate  solvent which is neither reactive nor




detrimental  to the upper  atmosphere.   Major revisions would be needed to




degreaser designs to improve vapor capture  above the  current  best level.




Anticipated  design changes  could add materially to degreaser  costs.  No




alternative  solvent is clearly acceptable from the standpoints of




photochemical oxidant  and stratospheric ozone  depletion.  Neither




methylc.ne chloride nor trichlorotrifluoroe  ane  are reactive,  but,  like
                                  B-13

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methyl chloroform,  are suspected of causing damage to'the stratospheric




ozone   layer.   In addition,  methylene chloride is a suspect mutagen.




Perchloroethylene,  the principal dry cleaning solvent, does not present




a hazard to the  stratosphere but has been  implicated  as being a carcinogen




and also reacts  slowly in the atmosphere to  form oxidant.




      7.  Organic solvents of low or negligible photochemical reactivity




have  only  limited use  in many industries.   Most are chlorinated orcjaniCS




that  find  principal applications as cleaners  for metals and fabrics. A




few nonhalogenated  VOC such as  acetone, methyl ethyl  ketone,  and isopropanol




are of low reactivity  but these can't possibly satisfy all the myriad




needs of the paint,  plastics, pharmaceutical,  or many other industries.




While users of reactive VOC usually can employ effective control equipment




to recover or  destroy  VOC emissions,  they seldom have the option of




applying reactivity considerations  in choosing solvents.  Applying




reactivity restrictions to  the  surface coating industry would be especially




disadvantageous  since  it would  greatly inhibit the development of low-




solvent   coatings; essentially all of the  organic solvents used to constitute




high-solids coatings and water-borne coatings are, in fact,  highly




reactive.




      8. It  is  recognized  that smog  chamber  studies conducted to date




are incomplete because many organic compounds  have not been examined and




it has teen  impossible to  duplicate all atmospheric situations.  por




example, there has  been only limited examination of oxidant  formation




under relatively high  ratios  of VOC to NO,  (30:1 and greater), comparable




to rural conditions.   Any policy on photochemicai reactivity necessarily
                                  B-14

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has to  be open  to  revision  as  new  infonnation  is devel'oped  which may  show

specific organic compounds  to be more  or less photochemically reactive

than  indicated  by  current  data.
Dated::
                                            Acting Assistant Administrator
                                             for Air  and Waste Management
                                   B-15

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APPENDIX C

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                               APPENDIX C




                           REGULATORY   GUIDANCE






1.   INTRODUCTION




     This section serves to  facilitate the preparation of regulations




for the control of volatile  organic  compound (VOC) emissions from the




surface coating operations discussed in this document.  This guidance is




not intended to prescribe  specific regulatory  language.   Responsibility




for developing regulations and the associated  emission limitations




clearly rests with the respective States.




2.   GENERAL   DISCUSSION



     The recommended regulatory  approach is predicated on the concept of




positive emission reduction  rather than the substitution of compounds




Of-lower reactivity as the means of  reducing ambient levels of photochem-




ical oxidant.   This is in  keeping with EPA's recent policy statement on




reactivity.




    The facility to be controlled  in each of the  five coating operations




discussed in this document is the coating line.  In general, the recommended




control approach is to reduce emissions from the coating line by means of




low  solvent  coating  technology.   This approach is recommended since, in




addition to reducing emissions at the applicator,  it also serves to reduce




fugitive and flash area  emissions while at the same time eliminating the
                                    C-l

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need for add-on control equipment.   It should be recognized, however, that

for certain source categories or  coating  lines  it may be preferable to use

add-on controls, particularly when heat or  VOC  recovery techniques can be

employed.   Therefore, the  regulations  should not preclude the employment

of add-on devices such as  incinerators and  adsorbers with appropriate

capture   systems.

     Before developing regulations,  States  should carefully evaluate the

sources to be regulated within  their jurisdiction to determine whether

the emission limitations cited  in this document truly reflect reasonably

available control technology (RACT)  for  them.   In some  instances,  it may

be found that the guidance is not appropriate for a particular coating

material or coating operation.

     The employment of low solvent coatings may be  technology forcing for

certain products or applications.   Under such circumstances, an extended

time period may be required to  evaluate the low solvent coatings both in

the laboratory  and  the  field,  prior to placing them into production. In

comparison, the application of  add-on  control devices is well demonstrated

and the only constraint is the  time  necessary to purchase,  install, and

start  up  such  equipment.   In view of these factors, compliance schedules

should be flexible, taking into consideration the specific problems

associated with a given plant.   Consideration may also have to be  given
 Reasonably available  control  technology (RACT) is defined as the  lowest
emission limit that a  particular source  is  capable of meeting by the
application of control technology  that is reasonably available considering
technological and economic  feasibility.   It may require technology that
has been applied to similar, but not necessarily  identic"*"!, SOUfC"?
categories.     It  is  not intended that extensive research and development
be conducted before a  given control  technology can be-applied to the
source.   'This does  not, however,  preclude requiring a short-term evalu-
ation program to permit the application  of  a given technology to a particu-
lar type of  source.   This latter effort  is  a legitimate technology-foreing
aspect  of  RACT.
                                    c-2

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to the cumulative  impact  of other jurisdictions promulgating stmilar

regulations, which may  limit the  availability of control

equipment,   etc.

     Even though the regulatory requirements are based on control

technology that has been  determined  to be reasonably available for the

source category as a whole,  some  individual plants may not be able to

comply  with  them.   In  order to forestall future problems of compliance,

the States should  review  their various authorities at the time regulations

are  developed.   If it  is  found that existing authorities do not provide

sufficient  flexibility  to accommodate such problems, consideration should

be given to  developing  regulatory provisions which will provide adequate

relief.

     To assist in  developing regulations, the Office of Air Quality

Planning and Standards  (OAQPS)  has identified several areas that should

be taken  into  consideration. These  are discussed below.

COITITIOn Terminology

     When developing regulations  it  is important that a degree of

commonality  exists in the definition of key terms.  This will provide  a

greater degree of  understanding on the part of source owners and operators

and remove some of the  confusion  that presently exists for owners that

have   multi-State   operations.   With this in mind, the following definitions

were developed for commercial  an'  industrial   surface  coating  operations:

     a.   Coating applicator means an apparatus used to apply a surface
coating..

     b.   Oven means a chamber  within which heat is used to bake,  cure,
polymerize,  and/or dry  a  surface  coating.

     (•   Coating line means one or more apparatus or operations com-
prised of a coating  applicator, flash-off  a> ,, and  oven wherein a
surface coating  is applied, dried,  and/or  ci. i.
                                    c-3

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      d.   Owner  or  operator  means  any  person  who  owns,  leases,  operates,
controls,  or  supervises  a  surface  coating  operation  or  a 	
plant  of which  a  sufface  coating  operation  is a  part.
      e.  Standard  conditions  mean  a  temperature  of  20°C  (68°F)   and  pressure
of  760 mm  of Hg  (29.92  inches  of
      f.  Volatile  organic  compound   is   any  compound  of  carbon  (excluding
carbon  monixide,   carbon  dioxide,   carbonic  acid,  metallic   carbides  or
carbonates,  and  aHmonium  carbonate)  that  has  a  vapor  pressure  greater
than  0.1  tnm  of Hg  at  standard conditions.
      g.   Day  means  a  24  hour period  beginning  at  midnight.
      h.  Capture   system  means  the  equipment   (including  hoods,   ducts,
fans,  etc.)  used  to  contain,   capture,  or  transport  a  pollutant  to a
control   device.
      1,    Control   device  means  equipment   (incinerator,   adsorber,   or   the
like)  used  to  destroy  or remove  a  pollutant  from  a  discharge  gas  stream.
      j.  Approved  means  approved  by  the   designated  air  pollution  control
official.
Expression   of   Requirements
      When   developing   regulations,  the  language  used  to  express   the
requirement  must  be  carefully  weighed.   As  noted  on  page  1-5,   the
decision  to  express   emission   limitations   for  coating  operations  in
terms  of  weight of VOC per  volume  of  coating,   less water,  was  chosen
after   much   deliberation.   A  change  in the   manner   of expression  without
an  adjustment  in  the  limit  could  materially  affect  the  stringency  of
the   requirements.    Therefore,   if   it is  found  desirable  to  express  the
limitation  in  different  terms,  such  as  pound  of  VOC  per  pound of coating
solids,  reference  should  be  made  to  Appendix  D  so  the recommended emission
limit  can  be  properly  adjusted.
      Similar  care  must  be  exercised  when  specifying  requirements  for
incinerators  and  other  add-on control  devices.   At  present,  there  are
                                       c-4

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no standardized test methods that can be universally applied to  determine

mass rates of emission or concentrations of VOC.   In  view of this,

requirements for  incinerators and most  other  add-on devices should  be

expressed in terms of efficiency of removing  organics expressed  as

combustible   carbon.

     In view of the  above,  OAQPS developed the following language for

expressing an emission limitation based on the guidance  contained in

this  document:

     "No owner or operator subject to the  provisions of  this regulation

shall discharge or cause the discharge  into the atmosphere from  a

coating line any  volatile organic compound in excess  of 	pounds

per gallon of coating, excluding water, delivered to the coating applicator.

     "The emission limit prescribed above  shall be  achieved by:

     a.   Low solvent coating technology,

     b.   Incineration, provided that 90 percent of non-methane volatile
organic compounds (VOC measured as  total carbon) which enter the incinerator
are oxidized to carbon dioxide and  water;  or

     c.  Processing  the discharge in a  manner determined by control
official to be not less effective than  that of b obove."

     When providing  for the use of  add-on  devices as  a means of

complying with the requirements of  the  regulation,  the States  should also

require that such control devices be equipped with  an approved capture

system in order to assure effective  control.   When examining the need for

such a provision, OAQPS staff explored  whether it was feasible to prescribe

performance or  design  specifications for  capture systems.  After examining

the situation,  it was concluded that effective capture systems must be

custom designed to accommodate plant-to-plant variables  which affect

performance.    An  alternative approach of testing to determine whether VOC
                                 c-5

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is escaping capture was  also dismissed for the want of suitable testing




techniques.     In  view  of  these  findings,  it is recommended that case-by-case




design review be performed  to assure installation of effective capture




systems.




     When reviewing capture system designs ,  air  pollution  officials  must




take into consideration  requirements imposed by the Occupational Safety



and Health Administration and the National Fire Prevention Association,




as well as State and local health and safety officials. The publication




"Industrial Ventilation,  A  Manual of Recommended Practice" prepared by the




American Conference of Governmental Industrial Hygienists is one source  of



guidance on the  proper design of capture and ventilation systems.




Need for flexibility




     As was discussed earlier, the employment of low solvent coatings




may be technology forcing for certain products or applications.    Under




such circumstances-additional time should be afforded sources faced with




real technological problems,  provided they move as expediently as prac-




ticable   toward   compliance.   During this period  it may be appropriate  for




the State to require interim controls such as solvent substitution.




OAQPS does not necessarily  recommend the installation of add-on control




devices, particularly incinerators,  i f the interim period  is to  be of




relatively  short  duration.   In  many   instances,  to do so would be a




disincentive for the source to continue its efforts to develop low




solvent   coatings.




     An alternate approach  that has been the subject of discussion is to




allow the source to develop a plant-wide emission reduction plan.   Under




such an  approach, the source owner would have to demonstrate that any
                                    £-6

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emissions in excess  of those allowed for a given coating  line would be



compensated  for.  Compensation would be achieved by either reducing VOC




emissions from  other coating lines below the  allowable level  or by




controlling non-regulated sources within the  surface coating  facility.




The plant-wide  emission reduction plan  provides  flexibility by affording




the source owner the-Opportunity to  select the most cost-effective



means of providing the desired VOC reduction.   In addition, it promotes




innovation by encouraging the control of sources that have not been




previously regulated and by  providing the source owner an  incentive to




control certain coating lines to a greater degree than that required




by  the emission  limitation.   While this approach has been favorably viewed




by industry, enforcement officials have expressed reservations as to its




enforceability.     If the problems of enforceability  can be  overcome, the




plant-wide emission  reduction approach  would appear to be a very  useful




tool.



Seasonal Operation of  Natural Gas-Fired Afterburners




     As an energy conservation measure,  it is also  recommended that




provision be made for  the seasonal operation  of  natural gas-fired




afterburners.     The basic rationale for  seasonal  operation  of natural




gas-fired afterburners and  the criteria  for designating time  periods




within which the devices may be shut down was set forth in the July 28,




1976, policy statement "Seasonal Operation of Natural Gas-Fired




Afterburners"  issued by the Assistant Administrator of Air and Waste




Management (see attachment).   The  following  language is offered  if a



State determines that  the  best method  of implementing this policy is by




incorporation into its regulation:
                                  C 7

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      "The  operation  of  natural  gas-fired  incinerator  and  associated

capture  systems  installed  for  the   purpose  of  complying  with  this  regulation

will  not  be  required  in  (specify  AQCR)  during  the  month 4or  months)  of

	 provided  that  the  operation  of  such  devices  is  not  required

for  purposes  of occupational  health  of safety  or  for  the  control  of

toxic  substances,  malodors,  or  other   regulated  pollutants."

Disposal of Waste VOC

      Consideration  should  also  be   given  to   restricting  the  manner  by

which waste  volatile  organic compounds are  disposed.  To  accomplish

this  objective,   OAQPS  suggests  the  following  regulatory  language:

      "No  owner  or  operator shalfl dispose  of  or permit the  disposal of

BlOre  than 	gallons  per  day  of volatile  organic compounds  by

any  means  which will  permit  the  evaporation   of such  compounds  to  the
                IT,
atmosphere."

Small   Source   Exemption

      States  should  also  consider  for  inclusion  in their   regulation  a

provision  to  exempt  certain   coating  lines  from  control due  to  their

small  quantity  of  emissions.    When  determining which   coating  lines  to

exempt,  States   should  assess  the  sources  within  their jurisdiction  to

determine  a  lower  cut  off  level  which  will  result  in  the  most  effective

control   strategy.

      Finally,   when  developing  regulations   the  States  should   be  cognizant


of EPA  policy  statements  and  other  guidance   on  overall  strategy  for  oxidant

control   such  as  photochemical  reactivity,   seasonal  control,  and  the

pnortttzation of geographical areas jfor which reductions in  volatile
                                            ff,  ».* , .
organic   emissions  are   required.
                                      C-8

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                                 ATTACHMENT



  \    UNITED  STATES  ENVIRONMENTAL  PROTECTION  AGENCY
  *
  *                         WASHINGTON, D.C. 20460


                               JUL  2 8
                                                                   OFFICE OF
                                                           AIR AND WASTE MANAGEMENT
SUBJECT:    Seasonal   Operation  of  Natural
            Gas-Fired    Afterburners

MEMO   TO:   Regional    Administrators
      It  has  been estimated  that  the  use  of afterburners  for  control  of
air  pollutants  required  0.4  percent  of  the  total  22  trillion  cubic  feet
of  natural  gas consumed  in  1975  in  the  U.S..  While  not  a  high  percentage,
this  is  a  substantial  amount  of  natural  gas—equivalent,  for  example,  to
the  annual  amount  required  to   heat  62,000  homes   in  Washington,  D.C.

      Many  of  these  afterburners  are  required   solely   to  reduce  emissions
of   hydrocarbons   to  control   ambient   oxidant  levels.   However,  results
from  both   statistical  analyses  of  ambient   data  and smog  chamber  tests
show  that  oxidants  do  not  readily   form  at  temperatures  below  about  59°F.
Thus,  in  many parts  of  the  U.S.,  the   operation  of  afterburners   required
for   oxidant  control  may not be needed  during  the   winter months.   This
fact and t-fto expectation tnat natural gas  wil i  be in aiiui '\, ^UPH"^ dm luy
the  coming  winter  support  an   EPA  policy  of allowing  states  to  permit
natural  gas-fired  afterburners   to  be  shut  down  during  the  coming  winter
season  p.roVi
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 concentrations  during the  winter season.  This  observed seasonal phe-
 nomenon  is  consistent  with  the  theory  of oxidiant formation:; high  ambient
 temperatures and  strong sunlight assist is the  prodoction  of oxidants
 from a complex  photochemical reaction involving hydrocarbons and
 nitrogen oxi dfes.

       A recent analysis of oxidant air quality data and meteorological
 data* identifies  areas of the  country which,  during specified months,
 experience low  oxidant concentrations:.  This  analysis; shows a high
 correlation between maximum daily temperatures  and maximum nearly
 axidtnt concent rations, with concentrations above tine Rational standard
 becoming highly improbable when fflixiHun daily temperatures are consist-
 ently below SS*F.  The analysis suggests that the maximum  daily tem-
 perature can, be used as. a reasonably reliable indicator of the potential
 for oxidant formation and supports a policy which would permit seasonal
 use of natural  gas-fired afterburners in wany dress.

       Figure 1 is a  nap of the U.S. on which sttxty results art sumaHzed.
 It  shows general  areas (or zones) in  which seasonal shutoff  of natural
gas-fired afterburners cowld  be considered.  However,  it is important
 to  note that  local  conditions  may  obviate  seasonal  control  even  though
 shutdown otherwise  may  appear  to  be acceptable.  If,  for  example,  winter-
 time oxidant concentrations in a  particular area are  in  violation  of
   th  o  amiiiiaaii  ». r~r. .!_..'  i~\r + *•" -•  /- - , - -t»*v»->+>* •*>*•*  -»•••> f,,££j ,,S ^l \t K-Snh 4'
   n  e  cunuierti itaiiufU  ur  »,nc  vuii\»«.uwi uwi«.._  — .* - ._..._T.-.V   __  Tr
 afterburner   shutdown   could   create   violations,   you   should   neither   encourage
 nor  allow  seasonal  afterburner  operation  even though the  area  is  in  a
 theoretically   acceptable  zone.

      A  policy  to  seasonally  control  afterburners  can  only  be  implemented
 through  the  SIP  process  -- by  establishing  new  oxidant  SIPS  or by revising
 existing   SIPs.   Of course,  the enforceability  of the  policy  must  be care-
 fuliy  considered   in   reviewing  each  specfic  regulation.  The  approval   of
 SIP  changes  to  permit  seasonal   afterburner  operation  need  not   require
 detailed,   time-consuming  analyses  of air  quality  impacts  if  the  seasonal
 shutdown  time  period   is  consistent   with  the   zones  delineated  in  Figure.  1 ,
 and  if  existing  air  quality data  shows  no past  violations  in  the   month
 during  which   the  afterburners  will  be   shutdown.  The  attached  staff  study,
 supported   by   air  quality  data where  available,  normally  should be adequate
 technical  support  for  a decision  to  approve  the  seasonal  operation  of
 afterburne"S  in  a given  location.   If  an  occasional  high  oxidant   concentra-
 tion  has  been  noted  during the  winter months but  the  gas  savings   to  be
 achieved  by  afterburner  shutoff  appears  to  warrant  favorable   consideration
 *See  attached  OAQPS  "Staff  Study:   Oxidant  Air  Quality   and  Meteorology,"
 dated  February  6,   1976.
                                     C--10

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of  a  variance  request,  a  short  trial  period  to  test  the  impact  on  oxidant
concentrations   may   be   suggested.    If  it  is  found  that  ambient  violations
persist  or  are   exacerbated,   the   trial   program  must  be  terminated.

      It  is recommended  that  you notify those  state  agencies  in your
Region  which  may  be  eligible  to  implement  this  program  that  EPA  sup-
ports  a  policy  which  would  permit  sources  to  shut  off  afterburners
during  cold   weather  months  this  year when  oxidant   concentrations  are
below  the   ambient  standard.   In  discussing  this  policy   with  state  agency
personnel  ,  it  is   important  to  emphasize  that  the   policy pertains  only  to
oxidant  control  strategy  and  that  EPA  is  not  encouraging  a  wide-spread  in-
crease   in  hydrocarbon   emissions.   Moreover  you  must  make  it  clear  that,
consistent  with §116  of  the Clean  Air ^Act,   the  state  is not  required  in
any  way  to relax its strategy.
                                 Roger Jrcrelw
                            Assistant    Administrator
                        for  Air   and   Waste  Management
Enclosure

c c:   Stan  LearO
      William  Prick
                                       0-11

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                                          NOVEMBER  JHROU 5H  MARCH
                                             ER   THROUGH  1FE8RUARY
•«-««i. Figure 1.  Areas for1  Which theProbablHty of Maximjm Daily Tenperature > S9°Mft < 5X During Monthly Ranges
                 Indicated  (Based  on 5  Years of  Temperature  Data).

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STAFF  STUDY:   OXIDANT AIR  QUALITY AND METEOROLOGY
 * *    «<
                 February  6,   1976
                    Prepared By
          Honitoring  and Reports  Branch
      Monitoring   and   Data  Analysis  Division
 Office  of  Air  Quality  Planning   and   Standards
                        c-13

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                    Oxidant Air Quali ty  arid  Meteorology




        An analysis  was performed of the seasonal:  variation of days



   with violations of the  oxidant standard at sites across the nation



   with sufficient  data  for  all fowr quarters of  1974.  Depicted in



   Figures 2 tfon&wgh  4 are  the percent »f diayswitfe hourly coicentra-,



   titins exceeding the HAAQS of 16& m§/m3 for three periods:  (1} Dec-



   «lai;  (2J  Ptov-Oec-Jan-Fefc-Mar; and, ,{3} Apr  through Oct.  The       '



   analysis  shows conclusively  that for the two sets of monthly ranges



   dwring the  cold season, oxidant  NAAQ5 violations decrease substantial-



   ly from the warmer mon-ths.   This is  consistent  with the seasonal



   cycTe of  temperatures and solar  radiation that  has  a  pronounced ef-


•  . ^«_^JL „__.._,»••     "
   . U<,.L, i/n o^.vflic ^jr ll l-ilCi I 5 .



      .  Air quality  data  for  some states were  not available  in  EPA's



   data   bank.  Also,.'in some  states  only a  few monitoring "sites  had



   sufficient  data for all quarters or  those  stations  with  sufficient



amounts of  data  may  not  have  been located where  maximum  concentra-



   tions   occur.   Therefore,   because  of   some   deficiencies  inherent   in



   the air   quality  data  base,  an  additional  parameter  was  used  as  an



   indicator  of   significant  ozone  formation   potential,   xhis para-



meter,  tnav'imurii  daily  temperature,  was   used  as a   surrogate  for  oxidant/



   ozone data  in areas without such data and as a  supplement in  areas
 1                                                       •


   with  insufficient  data.  High maximum daily temperatures  have been

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  associated with hi gh ozone concentrations in  field and  smog chamber
  Studies.1* 2* 3  Our best estimate  is that  nearly all  oxidaht/ozone
  concentrations above the HAAQS occur with maximum daily temperatures
  above about  58-59°F.   This was corroborated by an independent analy-
  sis   of  1973   ozone/oxidant  data.1*
       In   the   current  analysis,  the frequency  of  maximum daily  tempera-
  turai exceeding  59  "f at  Selected National  Weather  Service Sites  was
                . .   •                                                          •
  tabulated for each month over  a 5-year climatic period.  Assuming  that
  maximum   da''ly   temperatures   above  59  F  indicate   high   ozone  formation
  potential,  the ranges  of  months  that  have   less  than  a  5  percent  proba-
  bility  of this  condition  were  noted.   Since sll days with temperatures.
  higher   than  59  F will  no-i;  have  all  other'conditions  (solar   radiation,
  air  mass  characteristics,  wind   speed,   etc.)  conducive   to  formation  of
 high  ozone  concentration,  the  5 percent   value  represents  a  reasonably
•  Tow  risk.  Accordingly,  the geographical  areas.meeting  this  criterion
  •for  the   two  sets  of cold  month ranges  December through  February  and
  November  through   March  are  shown in   Figure  1.
       Considering the analyses  of. the.two factors,  air  quality and
  maximum   daily  temperature.,   the  areas  of  the  nation  with  low   seasonal
  incidence   of,  and   low  potential  for  NAAQS   violations  are  well   defined.
  ,  The  only  possible  exceptions   are  the  Milwaukee,  Wisconsin area  and
 parts  of  Massachusetts  where  oxidant  violation  frequencies  that  may
                                                                          H
  be   considered  appreciable  occur  despite  the   temperature   data  indicat-
  ing  the   contrary  during  colder  months.  Possible  factors  that  may
                                     C-15

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have causod these anomalies  include  instrumental
transport, stratospheric intrusions,  or S'o«* other
local condition.
,  long  range

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                                      NO'MBER  THROJGH
                          /	      DECEMR •  THROUGH  \FEBRUARY
•:>  Figure 1.  Areas  for Which the ProbabiVy of Maxinum Daily Temperature > 59°F is  < 5% During Monthly Ranges
             Indicated (Based on 5 Years < Tempera tire Data).

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                                                 Oxidant D^ta in  Parenthesis
Figure 2.. Percent of Days with Maximum Hourly (Lone Concentrations > 160 vg/m3  January, February,  and
          December 1974.                                                -,

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                                                           \    i	*   <>=
                                                            /        < ^J-T-.j''
                                                     Cxidant Da'ta  in Parenthesis
:3  Figure  3.  Percent of Days with Maximum Hourly Ozone Concentrations > 160 yg/m3 Jarjuary,  February, March, and
             November-December 1974.                                               '•     '

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                                                    idant Data  in Parenthesis
Figure 4.  'Percent of Days with Max mum Hourly C20ne Concentrations > 160 yg/m* April .through October 1974.'

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                                REFERENCES

      1.   Bach,  W.  D.,   "Investigation  of   Ozone   and   Ozone   Precursor
Concentrations at Non^rban  Locations in  the Eastern  United States,"
Phase  II, Research Triangle Institute, prepared for  Environmental
Protection  Agency, Research  Triangle Pat-k,  N.  C.,  EPA  Report  No.
450/3/74-034a>  February  1975.

      2.   .  Lovelace,  D. E.,   Kapsilis,  T.,   Bourke, R.  C.,  and Cook,
P.  P.,  "Indianapolis  1974 Siirr.-ner  Ozone  Study," Indianapolis Center
for   Advanced  Research,   Indianapolis,   Ind.,   1975.

     . 3.  Jefferies, H.  E.,  University  of Not-th  Carolina,  Chapel
Hill,  Personal  Cornmunication to Dinitriades,  B., Environmental  Pro-
tection   Agency,  Research  Triangle  Park,   N.   C.,  November  1974.

      4.   Neligan,    R.  E., Memorandum to  Walsh,  R. T.,  "High Ozone-
0x1 dan t    Concentrations   and   Associated   Maximum   Daily   Temperatures
During Cold Season,"  Environmental  Protection   Agency,   Research
Triangle   Park,   H.  C.,   November  3,  1974

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APPENDIX 0

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                                APPENDIX D


                             CONVERSION METHODS



     Presented below are techniques  which will permit ready conversion

between alternative terms which may  be used for emission control

regulations:


. * English  Units - Metric  Units
     b)  Multiply   «{$gSS.    by 8.23  to get


     c)   Gallons    _    Liters
         Gallon      "    Liter


• o  Water-borne  coatings,  equivalent organic solvent-borne  coatings,  volume

percent solids,  and pounds of solvent per gallon of coating  (minus V^ter).

     a) From volume percent solids in coating,  draw vertical  line to

appropriate  line in Figure D-l (depending on ratio of water  to organic-

solvent  in   coating).   From the point  of  intersection, draw a horizontal

line.   Where this  line intersects the ordinate, read the pounds  of solvent

per gallon of coating (minus  water).   Where this  line  intersects the

"Or§anic- Bome"  line,  a vertical line yields the solids content  of the

equivalent organic-borne coating.

     b) To convert organic-borne coating to equivalent water-borne, draw

a vertical line  in Figure D-l from the volume percent solids to  the

"Organic -Borne"   line.   From this intersectior . ^raW a horizontal line.
                                    D-l

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Where  this  intersects  the  appropriate   water-borne   line,  draw  a  vertical   line

to  yield  the  solids  content  of  the  equivalent  water-borne  coating.   The

continuation  of  the  horizontal  line  yields  the  pounds  of solvent  per

gallon  of coating  (minus  water}   of the  organic-borne  coating  and  its

equivalent   water-borne   coating.



**  Weight percent  solids  - Volume  percent solids


      Multiply Weight Percent  Solids  by   figffi ff jffiffi  to  get  ^erofnt



The  density of  the  solvent  may  be  assumed  to  be  7.36 pounds  per gallon

 (0.89  kg per  liter)  unless  better  information  1s  available,  the  density

of  the  solids  may be  calculated  from  the composition  and  density  of  the

coating:


Density  of _  (100 x  density of coating)  • (%  solvent x 7.36)  • (%  water x 8.34)
  Solids     "                            Percent  Solids


Densities  of  coating  solids  may range   from  7  to  35  pounds  per  gallon

(0.84  to  4.2  kg  per  liter).



• o  Pounds of  Solvent per  Gallon  of Solid *  Pounds  of Solvent per  Pound of Solid


      a)    Divide   Pounds  of  Solvent  by  Density  of Solid  to  get   Pounds  of  Solvent
                    'Gallon  of  SolidIn  Pounds  Per                Pounds of  Solid
                                              Gallon


      b)   Multiply  Pounds  of  Solvent  by  Density  of  Solid  to  get  Pounds   of  Solvent
                     Pounds   of  Solid       In  Pounds  Per              Pounds   of  Solid
                                              Gallon



. o  Pounds of  So1vent           Pounds   of  Solvent
   Gallon of  Coating      "    (SalTon  of" Solid
       (minus   water)
                                           D-2

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                                      FIGURE  D-l
s-
QJ
4->
re


in
i/i
QJ
C. i—
•i— IO
-M c:
re *~s.
o =tfe
o
 o
 
 o
 to
      6     -^
5



4



3



2
       1
                                       Weight of Organic
                                       Solvent Per Gallon  for

                                       3 Coatings As A Function
                                       of  Solids Content
                10     20    30     40    50     60    70     80    90
                                                                     100
                              Volume % solids  in coating
                                     D-3

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   90
                                            riyure u-c
    80
    70
 O
 VI
 o
 
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                                     Fiqure D-3
    8 L
a   6
•a   5
fi   3
    2 L_
    1  I—
                    Pounds of solvent per gallon
                    of coating solids
                                 vs,
                     Pounds  of solvent  oer  gallon
                     of coating (minus  water)
                           Pounds of solvent oer gallon of coating
                                      (minus water)
                                         D-5

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                                   TECHNICAL REPORT  DATA
                            [Please read /nstructions on the reverse before Completing/
 REPORT  NO.
     EPA-450/Z-77-008
                                                            3. RECIPIENT'S ACCESSION-NO.
 TITLE AND SUBTITLE
  Control of Volatile Organic Emissions  from Existing
  Stationary Sources-Volume II:  Surface  Coating of Cans,
  Coils,   Paper,  Fabric,  Automobiles &  Light Duty Trucks
                                                            5. REPORT DATE
                       MAV 1971
          S. PERFORMING
                       May m//
                      ORGANIZATION
                                 CODE
 AUTHOR(S)
                                                            3.  PERFORMING  ORGANIZATION  REPORT  NO,
                                                               OAQPS  NO.  1.2-073
 PERFORMING ORGANIZATION NAME AND ADDRESS
 J.S.  Environmental  Protection Agency
 3ffice  of Air and Waste Management
 3ffiC6  of Air Quality Planning and  Standards
 Research Trianq1e Parkr North  Carolina  27711
                                                            10. PROGRAM  ELEMENT  NO.
          11.  CONTRACT/GRANT  NO.
 2. SPONSORING AGENCY  NAME  AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD  COVERED
                                                            14. SPONSORING  AGENCY CODE
 5. SUPPLEMENTARY NOTES
 6. ABSTRACT
        This report  provides the  necessary guidance  for development of regulations  to
   limit emissions of volatile  organic sources  (VOC)  of hydrocarbons,  especially
   from the coating  operations  of five industries:  can, coil,  paper,  fabric and
   automobile and light duty trucks.   This guidance includes an emission limit which
   represents Reasonably Available Control Technology  (RACT)  for each  df the five,
   analytical techniques for determining the solvent  content of coatings, EPA's
   policy on the control of VOC,  and  a monograph on how these components can be used
   to develop a State regulation.
                                KEY WORDS AND  DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                         c .  COS AT I Field/Group
  Air Pollution
  Cm,  Coil, Paper,  Fabric,  Automobile and
    Light  Duty Truck Industries
  Solvent  Substitution
  Emission Limits
  Regulatory  Guidance         /
Air Pollution Control
Stationary  Sources
Organic Vapors
 8. DISTRIBUTION STATEMENT
    Unlimited
                                               19. SECURITY CLASS (This Ht-pnrl)
                                                 Unclassified
                            N O .  Ol T'
                            232
                                               20. SECURITY CLASS (TMs P
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ENVIRONMENTAL  PROTECTION AGENCY
      Technical Publications Branch
        Office of Administration
Research Triangle Park, North Carolina  27711
         OFFICIAL  BUSINESS

   AN EQUAL OPPORTUNITY EMPLOYER
 «•? ' t
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          ENVIRONMENTAL  PROTECTION  AGENCY
                      EPA • 335
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                                 Return this sheet if you do NQT wjsh foi
                                 or if change of address is needed I   '
                                 ZIP code.)
     |tn is materialL-J
     '-1----->, including
                                                                              ,'fefV  • > V*,, ^' *. "*
                                                                              •*n  • •'• j.,  .  »•  >•
                               PUBLICATION  NO, EJR

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