United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NIC 2771 1
EPA-450/2-79-004
September 1979
Air
Guidance to State and
Local Agencies in
Preparing Regulations
to Control Volatile Organic
Compounds from Ten
Stationary Source
Categories
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EPA-450/2-79-004
Guidance to State and Local Agencies in
Preparing Regulations to Control Volatile
Organic Compounds from Ten Stationary
Source Categories
by
Stephen V. Capone and Malcolm Petroccia
GCA Corporation
GCA/Technology Division
Burlington Road
Bedford, MA 01730
Contract No 68-02-2607
Work Assignment No. 29
EPA Project Officer: Tom Williams
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 1979
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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,
general public, grantees, and nonprofit organizations - as supplies
last - from the Library Services Office (MD-35), U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina 27711; or for
a nominal fee, from the National Technical Information Service,
5285 Port Royal Road, Springfield, Virginia 22161.
This report was furnished to the Environmental Protection Agency by GCA
Corporation, Technology Division, Burlington Road, Bedford, Massachusetts
01730 in fulfillment of Contract No. 68-02-2607, Work Assignment 29.
This document has been reviewed by the Office of Air Quality Planning
and Standards, U.S. Environmental Protection Agency, and approved for
publication. Approval does not signify that the contents necessarily
reflect the views and policies of the Environmental Protection Agency,
nor does mention of trade names or commercial products constitute
endorsement or recommendation for use.
Publication No. EPA-450/2-79-004
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ABSTRACT
This document provides assistance to state and local air pollution
control agencies in preparing Reasonably Available Control Technology (RACT)
regulations for 10 industrial categories covered by the Control Techniques
Guidelines (CTG) documents published between January 1978 and January 1979.
The CTG source categories covered by this report are as follows: Leaks
from Petroleum Refinery Equipment; Surface Coating of Miscellaneous Metal
Parts and Products; Manufacture of Vegetable Oil; Surface Coating of Flat Wood
Paneling; Manufacture of Synthesized Pharmaceutical Products; Manufacture of
Pneumatic Rubber Tires; Graphic Arts - Rotogravure and Flexography; Petroleum
Liquid Storage in External Floating Roof Tanks; Perchloroethylene Dry Cleaning
Systems; and Leaks from Gasoline Tank Trucks and Vapor Collection Systems.
The intent of this report is to provide a rational and factual basis for state
and local agencies to develop industry-specific RACT regulations in their own
codes.
The arrangement of this guidance is such that a specific sample regula-
tion is written for each CTG industrial category. After each section within
each sample regulation there is a discussion of information pertinent to that
section of the sample regulation. Appendix A contains general provisions
which are not based on the CTG documents but are provided strictly as additional
information for the regulatory agency's consideration. Appendix B contains
written comments received on the draft final report, reprinted in their
entirety. A substantial amount of information, which should be considered
by the state and local agencies, is contained in the comments received.
111
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CONTENTS
Abstract iii
Acknowledgment viii
INTRODUCTION 1
PART I General Definitions 5
PART II Specific Provisions 9
§XX.9000 Petroleum Refinery Equipment Leaks 11
§XX.9100 Surface Coating of Miscellaneous Metal
Parts and Products 25
§XX.9200 Manufacture of Vegetable Oil 43
§XX.9300 Surface Coating of Flat Wood Paneling 47
§XX.9400 Manufacture of Synthesized Pharmaceutical
Products 59
§XX.9500 Manufacture of Pneumatic Rubber Tires 71
§XX.9600 Graphic Arts Systems 89
§XX.9700 Petroleum Liquid Storage in External Floating
Roof Tanks 103
§XX.9800 Perchloroethylene Dry Cleaning Systems 115
§XX.9900 Leaks from Gasoline Tank Trucks and Vapor
Collection Systems 125
Appendices
A. §XX.8000 General Provisions A-l
B. Comments on Draft Final Report B-l
§XX.9000 Petroleum Refinery Equipment Leaks B-3
American Petroleum Institute* B-5
Gulf Oil Company* B-21
Shell Oil Company* B-23
Union Oil Company of California* B-28
§XX.9100 Surface Coating of Miscellaneous Metal
Parts and Products B-33
Deere & Company B-35
E.I. Dupont DeNemours & Company B-38
Freightliner Corporation B-43
General Motor Corporation B-45
Ransburg Electrostatic Equipment (6/25/79) B-47
U.S. EP^, Chemicals and Petroleum Branch (8/8/79) . . B-49
Ransburg Electrostatic Equipment (8/28/79) B-52
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CONTENTS (continued)
§XX.9200 Manufacture of Vegetable Oil B-57
Crown Iron Works Company B-59
National Cottonseed Products Association, Inc. . . . B-65
National Soybean Processors Association B-67
§XX.9300 Surface Coating of Flat Wood Paneling B-71
Vanply Ire B-73
§XX.9400 Manufacture of Synthesized Pharmaceutical
Products B-75
Pharmaceutical Manufacturers Association B-77
§XX.9500 Manufacture of Pneumatic Rubber Tires B-87
Armstrong Rubber B-89
BF Goodrich Company B-91
Firestone Tire and Rubber Company B-98
General Tire & Rubber Company B-103
Goodyear Tire & Rubber Company B-107
Rubber Manufacturers Association B-112
Uniroyal International B-131
§XX.9600 Graphic Arts Systems B-133
Crown Zellerbach B-135
Dayton Press, Inc B-137
Diversified Printing Corporation B-142
Envelope Manufacturers Association B-144
Flexible Packaging Association B-148
Flexogrstphic Technical Association Incorporated. . . B-154
Gravure Research Institute, Inc B-157
Gravure Technical Association, Inc B-164
National Association of Printing Ink
Manufacturers, Inc B-165
Regenerative Environmental Equipment Co., Inc. . . . B-166
Rexham B-168
Reynolds Aluminum B—174
RJR Arc tier B-179
St. Regis Paper Company B-182
§XX.9700 Petroleum Liquid Storage in External Floating
Roof Tanks B-185
American Petroleum Institute* B-187
Atlantic Richfield Company* B-188
Chevron U.S.A., Inc. (7/18/79) B-190
Getty Oil Company B-191
Marathon Oil Company B-193
Shell Oil Company* B-23
§XX.9800 Perchloroethylene Dry Cleaning Systems B-197
Dan Landon Enterprises, Inc B-199
JMS Enterprises, Inc B-200
Patton, Boggs & Blow B-201
TEAM Enterprises, Inc B-207
VI
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CONTENTS (continued)
§XX.9900 Leaks from Gasoline Tank Trucks and Vapor
Collection Systems B-209
American Petroleum Institute* B-187
Chevron U.S.A., Inc. (7/16/79) B-211
National Tank Truck Carriers, Inc B-213
Truck Trailer Manufacture Association B-215
Union Oil Company of California* B-28
Miscellaneous B-233
Century Systems Corporation B-235
^Comments are applicable to more than one of the following sections:
1) §XX.9000 Leaks from Petroleum Refinery Equipment
2) §XX.9700 Petroleum Liquid Storage in External Floating Roof Tanks
3) §XX.9900 Leaks from Gasoline Tank Trucks and Vapor Collection
Systems
VII
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ACKNOWLEDGMENT
The authors wish to gratefully acknowledge Mr. Tom Williams of EPA's
Control Programs Development Division for his extensive review, comments, and
technical advice during each stage In the development of this document.
We also wish to thank EPA's Regional Task Representatives and Mr. John
Calcagni of EPA's Control Programs Development Division, who were specially
convened to review the draft of the sample regulations. Their comments and
advice are greatly pppreciatetd.
Vlll
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INTRODUCTION
The Clean Air Act Amendments of 1977 require each state in which there is
a nonattainment area to adopt and submit a revised State Implementation Plan
(SIP), which meets the requirements of Section 110 and Subpart D of the Act.
The oxidant plan portion of the SIP submittals must contain regulations which
reflect the application of reasonably available control technology (RACT) to
stationary sources for which control techniques guidelines (CTG) documents have
been published.* -
Eleven CTG's covering 15 source categories were published prior to
January 1978. EPA published a guidance document, "Regulatory Guidance for
Control of Volatile Organic Compound Emissions from 15 Categories of Stationary
Sources," EPA-905/2-78-001, to assist the state and local agencies in developing
regulations for the SIP submittal due in January 1979. Between January 1978
and January 1979 an additional 10 CTG documents (Group II) were published.
Legally enforceable regulations must be submitted to EPA by July 1980 for these
source categories.
The CTG documents recommend control technology and in some cases limits on
the emission of volatile organic compounds (VOC) and contain information on
the economic and technological feasibility of available techniques for the
reduction of VOC emissions. EPA's intent in publishing the CTG documents is
to provide the state and local regulatory agencies with information on the pre-
sumptive norm or reasonably available control technology for source categories.
EPA defines RACT, however, as the lowest emission limitation that a particular
source is capable of meeting by the application of control technology that
is reasonably available considering technological and economic feasibility. The
state or local regulatory agencies preparing SIP submittals should be aware that
the CTG documents (and this document) address categories of sources and do not
fully account for variations within source categories.
This document provides assistance to state and local agencies in preparing
RACT regulations for 10 industrial categories covered by the Group II CTG
documents. The 10 CTG volatile organic compound source categories covered by
this report are as follows:
• Leaks from Petroleum Refinery Equipment (EPA-450/2-78-036)
• Surface Coating of Miscellaneous Metal Parts and Products
(EPA-450/2-78-015)
*RACT regulations would not have to be adopted for these stationary sources,
if a state can demonstrate attainment of the photochemical oxidant standard
by photochemical dispersion modeling.
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• Manufacture of Vegetable Oil (EPA-450/2-78-035)
• Surface Coating of Flat Wood Paneling (EPA-450/2-78-032)
• Manufacture of Synthesized Pharmaceutical Products
(EPA-450/2-78-029)
• Manufacture of Pneumatic Rubber Tires (EPA-450/2-78-030)
• Graphic Arts - Rotogravure and Flexography (EPA-450/2-78-033)
• Petroleum Liquid Storage in External Floating Roof Tanks
(EPA-450/2-78-047)
• Perchloroethylene Dry Cleaning Systems (EPA-450/2-78-050)
• Leaks from Gasoline Tank Trucks and Vapor Collection Systems
(EPA-450/2-78-051)
EPA asked its consultant to review the CTG documents listed above from
the point of view of a state agency and to write sample regulations. A
draft report was produced in June 1979 which included sample regulations and
discussions of each section of each regulation. The discussion sections
included the "thought processes" that went into the regulatory language, issues
and problems that were encountered, and in some instances requests f°r further
information on particular points.
The draft report was widely distributed to industry and air pollution
control agencies for comment. About 50 letters of comment were received from
affected companies and business associations. Meetings with state agencies
and key industry groups provided further input into this document. All of
this information was reviewed, and appropriate (in some cases substantial)
modifications were made to the draft report. This document in final form
reflects this extensive input effort.
EPA intended to meet several objectives in producing this final report.
These objectives are as follows:
• Identify areas where difficulties existed in converting CTG
information into regulatory language.
• Provide an opportunity for industry comment on CTG information
after it has been converted to a regulatory format.
• Identify specific areas of industry concern.
• Provide assistance to state and local agencies preparing RACT
regulations for the source categories covered by the Group II
CTG's.
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This report is organized as follows: Part I contains the General
Definitions; Part II - Specific Provisions, contains all of the specific
sample regulations; Appendix A contains general provisions; and Appendix B
contains the written comments received on the draft final report, reprinted
in their entirety. The general provisions in Appendix A are not contained in
the CTG documents, but are provided strictly as additional information for
regulatory agencies' consideration. Provisions similar to these already exist
in most state codes and are included here because these types of requirements
are essential to a fully enforceable set of regulations. In some cases the
comments in Appendix B may not appear to be pertinent, due to the changes
which have been made in finalizing this report. However, a substantial amount
of information, which should be considered by the state and local agencies, is
contained in the comments.
The arrangement of the Specific Provisions, Part II, of this report is such
that a specific sample regulation is written for each CTG industrial category.
After each section within a sample regulation there is a discussion of infor-
mation pertinent to that section of the sample regulation. Some of the sections
(e.g., Compliance Schedules) are very similar in each of the 10 sample regula-
tions because this report attempts to make each sample regulation self-
contained. This has the obvious advantages of making each sample regulation
more readable and allowing changes in the regulatory language of one section
without affecting any of the other sample regulations.
It should be emphasized that both the CTG documents and this document
are, of necessity, general in nature. There are a number of valid reasons
why state or local agencies might deviate from the general guidance provided
in this report when developing regulations. The potential variability within
source categories, which has already been mentioned, is an example of this.
In addition, areas with severe oxidant problems may need more stringent
emission limitations than those recommended in the CTG documents. According
to EPA a state may develop case-by-case RACT requirements independent of EPA's
recommendations for any source or group of sources, provided the State submits
documentation which justifies its determinations.
This document is offered as guidance to assist state and local agencies
in preparing RACT regulations for volatile organic compounds. The sample
regulations are illustrative in nature and are not to be construed as rule-
making by EPA. The intent of this report is to provide a rational and factual
basis for state and local agencies to develop industry-specific RACT regula-
tions in their own codes.
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GENERAL DEFINITIONS
Approved: Approved by the designated air pollution control
official.
Breakdown: A sudden failure of a source of emission control or
emission monitoring equiptr.ent to function as a result of wear,
failure to repair, breakage, unavoidable damage, or other causes.
Capture Efficiency: The weight, per unit time of VOC entering a capture
system and delivered to a control device divided by the weight
per unit time of VOC emitted by a source of VOC, expressed as a
percentage.
Capture System: The equipment (including hoods, ducts, fans, etc.) used
to contain, capture, or transport a pollutant to a control device.
Carbon Adsorption System: A device containing adsorbent material
(e.g., activitated carbon, aluminum, silica gel); an inlet and
outlet for exhaust gases; and a system to regenerate the saturated
adsorbent. The carbon adsorption system must provide for the
proper disposal or reuse of all VOC adsorbed.
Carbon Bed Breakthrough: A concentration of VOC in the carbon
adsorption device exhaust that exceeds 10 percent by weight
of the inlet VOC concentration.
Coating Applicator: An apparatus used to apply a surface coating.
Coating Line: One or more apparatus or operations which include a
coating applicator, flash-off area, and oven wherein a surface
coating is applied, dried, and/or cured.
Condenser: A device which removes condensable vapors by a reduction
in the temperature of the captured gases. A surface condenser effects
condensation by indirect contact between the coolant and process gas
stream. A barometric condenser effects condensation by direct contact
between the coolant and process gas stream.
Construction: Commencement of onsite fabrication, erection, or installa-
tion of an emission source, air pollution control equipment, or a
facility.
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Control Device: Equipment (incinerator, adsorber, floating roof tanks, or
the like) used to destroy or remove air pollutant(s) prior to discharge
to the ambient air or to prevent air pollutants from reaching the
ambient air.
Day: A 24-hour period beginning at midnight.
Director: The Executive Director and Chief Executive Officer of
the Agency.
Emission: The release or discharge, whether directly or indirectly,
of any air pollutant into the ambient air from any source.
Facility: Any building, structure, installation, activity, or
combination thereof which contains a stationary source of
air contaminants.
Incinerator: A combustion apparatus designed for high temperature
operation in which solid, semisolid, liquid, or gaseous combustible
wastes are ignited and burned efficiently and from which the solid
and gaseous residues contain little or no combustible material.
Lower Explosive Limit: (also denoted as LEL) The lower limit of flam-
mability of a gas or vapor at ordinary ambient temperatures expressed
in percent of the gas or vapor in air by volume.
Organic Material: A chemical compound of carbon excluding carbon
monoxide, carbon dioxide, carbonic acid, metallic carbides or
carbonates, and ammonium carbonate.
Oven: A chamber within which heat is used to bake, cure, polymerize,
and/or dry a surface coating.
Overall Emission Reduction Efficiency: The weight per unit time of VOC
removed by a control device divided by the weight per unit time
of VOC emitted by a source, expressed as a percentage.
Owner or Operator: Any person who owns, leases, controls, operates
or supervises a facility, an emission source, or air pollution
control equipment.
Person: Any individual, partnership, copartnership, firm, company,
corporation, association, joint stock company, trust, estate,
political subdivision, or any other legal entity, or their legal
representative, agency or assigns.
Reasonably Available Control Technology: (also denoted as RACT) means
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 identical, source categories.
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Reid Vapor Pressure: The absolute vapor pressure of volatile crude
oil and volatile nonvisccus petroleum liquids except liquified
petroleum gases as determined by American Society for Testing
and Materials, Part 17, 1973, D-323-72 (Reapproved 1977).
Shutdown: The cessation of operation of a source or of emission
control or emission monitoring equipment.
Solvent: Organic materials which are liquid at standard conditions
and which are used as dissolvers, viscosity reducers, or cleaning
agents.
Source: Any article, container, machine, process equipment, or other
contrivance from which air pollutants emanate or are emitted,
either directly or indirectly.
Standard Conditions: A temperature of 20°C (68°F) and pressure of
760 millimeters of mercury (29.92 in. of mercury).
Startup: The setting in operation of a source or of emission control
or emission monitoring equipment.
Technological Infeasibility: Technologically incapable of being
accomplished or carried out as a matter of practicality; technically
impracticable rather than technically impossible.
True Vapor Pressure: The equilibrium partial pressure exerted by a
petroleum liquid as determined in accordance with methods described
in American Petroleum Institute Bulletin 2517, "Evaporation Loss
from Floating Roof Tanks," 1962.
Volatile Organic Compound: (also denoted as VOC), any organic compound
which participates in atmospheric photochemical reaction or is
measured by the applicable reference methods specified under any
subpart of 40 CFR 60.
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5XX.9010 Definitions.
(a) For the purpose of this Regulation, the general
definitions apply.
(b) For the purpose of this Regulation, the following
definitions also apply:
(1) "Petroleum refinery" means any facility engaged
in producing gasoline, aromatics, kerosene,
distillate fuel oils, residual fuel oils,
lubricants, asphalt, or other products through
distillation of petroleum or through redistillation,
cracking, rearrangement or reforming of unfinished
petroleum derivatives.
(2) "Component" means any piece of equipment which has the
potential to leak volatile organic compounds when
tested in the manner described in SXX.9050. These
sources include, but are not limited to, pumping seals,
compressor seals, seal oil degassing vents, pipeline
valves, flanges and other connections, pressure relief
devices, process drains, and open ended pipes.
Excluded from these sources are valves which
are not externally regulated.
(S) "Liquid service" means equipment which processes,
transfers or contains a volatile organic compound
or mixture of volatile organic compounds in the
liquid phase.
(4) "Gas service" means equipment which processes,
transfers or contains a volatile organic compound
or mixture of volatile organic compounds in the
gaseous phase.
(5) "Valves not externally regulated" means valves that
have no exteirnal controls, such as in-line check valves.
(6) "Refinery unit" means a set of components which are a
part of a basic process operation, such as, distillation,
hydrotreating, cracking or reforming of hydrocarbons.
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SXX.9020 Applicability:
This Regulation applies to all petroleum refineries located
in the following counties:
DISCUSSION
This regulation is intended to cover all petroleum refineries, including
topping plants, regardless of size. The regulation is not intended to affect
facilities which recycle waste oil.
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§XX.90SO Provisions for Specific Processes.
(a) The owner or operator' of a petroleum refinery complex subject
to this regulation shall:
(1) Develop a monitoring program consistent with the provisions
in §XX.9040(a).
(2) Conduct a monitoring program consistent with the provisions
in %XX.9060(a).
(3) Record all leaking components which have a VOC concen-
tration exceeding 10,000 ppm when tested according to
the provisions in %XX. 9050, and place an identifying
tag on each component consistent with the provisions
in %XX.9060(a)(3).
(4) Repair and retest the leaking components, as defined
in part (3), as soon as possible but no later than
IS days after the leak is found.
(5) Identify all leaking components, as defined in part (3),
which cannot be repaired until the unit is shutdown
for turnaround.,
(b) The Director at his discretion may require early unit
turnaround based on the number and severity of tagged leaks
awaiting turnaround.
(c) Except for safety pressure relief valves, no owner or operator
of a petroleum refinery shall install or operate a valve at
the end of a pipe or line containing volatile organic com-
pounds unless the pipe or line is sealed with a second valve,
a blind flange, a plug, or a cap. The sealing device may be
removed only when c. sample is being taken or during mainte-
nance operations.
(d) Pipeline valves and pressure relief valves in gaseous volatile
organic compound service shall be marked in some manner that
will be readily obvious to both refinery personnel performing
monitoring and the Director.
DISCUSSION
The 15-day repair pericd should allow sufficient time for a leaking
component to be included in the normal maintenance schedule for most facilities.
The 15-day period was included in the CTG document which the petroleum industry
was given an opportunity to review. No objections were raised to the repair
period at that time.
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Part (d) of this section of the regulation is included to identify
those valves which must be monitored quarterly under the provisions of
§XX.9060(a)(1)(ii). If the Director determines that too many leaking
components are being designated for repair at a unit turnaround, he may
order an early turnaround.
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SXX.9040 Compliance Schedules,
The owner or operator of a petroleum refinery, in order to comply
with SXX.9030, shall adhere to the increments of progress contained
in the following schedule:
(a) Submit to the Director a monitoring program by January 15,
1981. This program shall contain, at a minimum, a list
of the refinery units and the quarter in which they will be
monitored, a copy of the log book format, and the make and
model of the monitoring equipment to be used. In no case
shall a monitoring contract relieve the owner or operator
of a petroleum refinery of the responsibility for compliance
with this regulation.
(b) Submit the first quarterly monitoring report to the Director
by July 15, 1981.
DISCUSSION
The first milestone in a compliance schedule should be a submittal by the
refinery owner or operator which contains a monitoring program. Processing
areas of the refinery can be broken out and monitored separately. A list
of the units which will be monitored and reported on the given dates must
also be presented. The four quarterly reports should be filed on January 15,
April 15, July 15, and Octob€;r 15. For those components which must be moni-
tored yearly, a schedule should be established outlining which fraction will
be monitored within a particular quarter. The resulting monitoring report
should be submitted on the four dates previously mentioned.
Pump seals, pipeline valves in liquid service, and process drains must be
monitored yearly. For exampLe, assume that the refinery has four basic processing
operations: distillation, hydrotreating, cracking, and reforming. The operator
could choose to monitor all the pump seals, pipeline valves in liquid service
and process drains in the distillation area in the first quarter and report the
results by April 15. He may then monitor similar equipment in the hydrotreating
area in the second quarter and report the results by July 15. The following
year, the operator would again monitor the distillation area in the first
quarter. This schedule would insure that monitoring is being accomplished at
a uniform rate throughout the calendar year.
The important issue is that a schedule be formulated by the refinery
personnel and submitted to the regulatory agency for review. After implemen-
tation of the regulations, fr months should be allowed to formulate a monitoring
schedule and purchase monitoring equipment. The first monitoring report should
be due 6 months later.
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§XX. 9050 Testing and Monitoring Procedures.
(a) Testing and calibration procedures to determine
compliance with this regulation must be consistent
with Appendix B of the OAQPS Guideline Series
document, "Control of Volatile Organic Compound
Leaks from Petroleum Refinery Equipment,"
EPA-450/2-78-036.
DISCUSSION
Two monitoring procedures are presented in Appendix B of the CTG
document. The first is the Individual Source Survey. This is the most
severe method and requires the inspection of every seal and valve in the
entire petroleum refinery complex. The second is the Unit Area Survey and
requires a "walkthrough" with a VOC monitor. If the ambient VOC level is
above an "action level" (which is not defined here), an Individual Source
Survey is performed in the specific area only. The action level can be
determined by comparison of area survey VOC levels and Individual Source
Survey VOC levels.
It is important that the burden of proof of the effectiveness of alterna-
tive test procedures be put on the refinery personnel. One suggestion is to
require that the refinery personnel present data for testing done by the
Individual Source Survey method and for testing done by the proposed alternative
method for similar operating installations. The regulatory agency could then
compare the number of leaking components discovered as a fraction of the number
of potential leaking sources for both methods and also against the data collected
by EPA in the CTG document. This gives the regulatory agency a method to
assess the stringency of the emission limit.
It is EPA policy that the SIP revision must include a legally enforceable
limitation, with associated test methods specifically designated. Any language
which leaves the test method completely to the discretion of the Director is
unacceptable. Minor changes to designated test methods would be approved,
however.
In order to better understand the complexities and problems of the test
methods, a regulatory agency representative familiar with testing equipment
should be present during some of the first surveys.
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§XX.9060 Monitoring, Recordkeeping, Reporting
(a) Monitoring
(1) The owner or operator of a petroleum refinery subject
to this regulation shall conduct a monitoring program
consistent with the following provisions:
(i) Monitor yearly by the methods referenced in
5XX.9050., all
(A) pump seals;
(B) pipeline valves in liquid service; and
(C) process drains,
(ii) Monitor quarterly by the methods referenced in
SXX.9050, all
(A) compressor seals;
(B) pipeline valves in gaseous service; and
(C) pressure relief valves in gaseous service.
(Hi) Monitor weekly by visual methods all pump seals;
(iv) Monitor immediately any pump seal from which
liquids are observed dripping;
(v) Monitor any relief valve within 24 hours after
it has vented to the atmosphere; and
(vi) Monitor immediately after repair any component
that was found leaking,
(2) Pressure relief devices which are connected to an
operating flare header, vapor recovery device,
inaccessible valves, storage tank valves, and
valves that are not externally regulated are exempt
from the monitoring requirements in paragraph (1) of
this section,
(3) The owner or operator of a petroleum refinery, upon
the detection of a leaking component, as defined in
§XX.9030(a)(3), shall affix a weatherproof and readily
visible tag, bearing an identification number and the
date the leak is located, to the leaking component.
This tag shall remain in place until the leaking
component is repaired.
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(b) Recordkeeping
(1) The owner or operator of a petroleum refinery shall
maintain a leaking components monitoring log as
specified in §XX. 9030(a)(3) which shall contain, at
a minimum, the following data:
(i) The name of the process unit where the
component is located.
(ii) The type of component (e.g., valve, seal).
(iii) The tag number of the component.
(iv) The date on which a leaking component is
discovered.
(v) The date on which a leaking component is
repaired.
(vi) The date and instrument reading of the recheck
procedure after a leaking component is repaired.
(vii) A record of the calibration of the monitoring
instrument.
(viii) Those leaks that cannot be repaired until
turnaround.
(ix) The total number of components checked and the
total number of components found leaking.
(2) Copies of the monitoring log shall be retained by the
owner or operator for a minimum of 2 years after the
date on which the record was made or the report
prepared.
(3) Copies of the monitoring log shall immediately be made
available to the Director, upon verbal or written
request, at any reasonable time.
(c) Reporting
(1) The owner or operator of a petroleum refinery, upon
the completion of each yearly and/or quarterly monitoring
procedure, shall:
(i) Submit a report to the Director by the 15th day,
of January, April, July, and October that lists
all leaking components that were located during
the previous 2 calendar months but not repaired
within 15 days, all leaking components awaiting
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unit turnaround, the total number of
components 'Inspected and the total number
of components found leaking.
(ii) Submit a signed statement with the report
attesting to the fact that, with the excep-
tion of those leaking components listed in
subparagraph (c)(l)(i) all monitoring and
repairs were performed as stipulated in the
monitoring program.
(d) The Director^ upon written notice, may modify the
monitoring3 recordkeeping and reporting requirements.
DISCUSSION
Before the owner or operator of a refinery can meet the requirements of
this regulation, he must purchase one or more portable VOC monitors. Also,
since in most petroleum refireries the only valves that are tagged are the
control valves, the owner or operator must identify every gaseous service
pipeline valve, as requred by §XX.9030(d).
With the preliminaries accomplished, the VOC monitoring team must prepare
a schedule such that pump seals, pipeline valves in liquid service, and process
drains are monitored yearly; compressor seals, pressure valves in gas service
and pressure relief valves in gas service are monitored quarterly; and pump
seals are visually monitored weekly. No individual monitoring is required
for pipeline flanges and pressure relief valves in liquid service. Whenever
liquids are observed dripping from a pump seal, the seal should be checked
immediately with a portable VOC monitor. Also, upon the venting of any relief
valve to atmosphere, that component should be checked with a monitor.
In order for the regulatory agency to insure monitoring is properly
accomplished, a log must be maintained. Time must be spent maintaining this
document, possibly as a computer application. The CTG recommends that the
survey log be retained for 2 years after the inspection is completed. The
state or local agencv should choose a period of time sufficient to document
the equivalency of proposed alternative test methods and to complete any
enforcement action.
When a leak is located, a weatherproof and readily visible tag bearing
an identification number and the date the leak is located must be affixed to
the leaking component. The owner or operator of the refinery then has 15
days to repair the leak.
After each quarterly and annual monitoring has been performed, the
refinery operator should submit a report to the Director listing only the leaks
that were located, but not repaired within the required time limit and those
leaks awaiting turnaround. Also, the refinerv operator should submit a signed
statement attesting to the fact that all monitoring and repairs were performed
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as stipulated. This is a reasonable approach from the regulatory agency's
point since it reduces the work load in order to concentrate on those sources
that were not in compliance. Since the regulation also states that the
leaking component monitoring log will be made available to the Director upon
verbal or written request at any reasonable time, the agency can perform spot
checks on the survey log to determine whether the monitoring program is being
properly conducted. A point that should not be overlooked is that the leaking
source, once repaired, should be monitored and the results recorded.
Due to the obvious fact that there are shortcomings in the establishment
of a monitoring schedule, the CTG recommends that the regulations be written
to allow for modifications in the monitoring schedule where it is proven to
be either inadequate or excessive. Therefore, a paragraph is included that
will provide the Director with the legal right to modify the monitoring,
recordkeeping, and reporting requirements. Also, a paragraph is included in
the Petition for Alternative Controls Section (§XX.9070) to allow the owner
or operator of the refinery to request modifications. On the other hand,
if the air pollution control officer finds an excessive number of leaks during
any inspection, he may require more frequent monitoring.
The point to be made here is that the establishment of an effective
monitoring schedule will probably require some give and take from both the
regulatory agency and the refinery. A considerable amount of judgment will
be required.
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§IZ.9070 Petition for Alternative^Controls.
(a) Iff at any time after two complete liquid service
•inspections and five complete gaseous service
inspections, the ownzr or operator of a petroleum
refinery can demonstrate that modifications to
§11.9050 are in order, he may petition to the
Director that revisions be made.
(b) The petition of paragraph (a) of this section
must contain:
(1) the name and address of the company and the
name and telephone number of the responsible
company representative over whose signature
the petition is submitted;
(2) a detailed description of the problems
encowitered by implementing §XX.9060; and,
(S) a detailed description of the proposed
alternative monitoring procedure.
(c) If at any time the owner or operator of a petroleum
refinery can demonstrate that compliance with SXX.9030
would require more than leaking component repair or
equipment changeour-, he may petition the Director to
allow the use of alternative operational and/or equip-
ment controls for the reduction of volatile organic
emissions.
(d) The petition of paragraph (c) of this section must be
made for each component within a given facility, and
must contain:
(1) the name and address of the company and the name
and telephone number of the responsible company
representative over whose signature the petition
is submitted;
(2) a description of all operations conducted at the
location to which the petition applies and the
purpose that the volatile organic compound
emitting component serves within the operations;
(S) a detailed description of the proposed
alternative operational and/or equipment
controls; and,
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(4) a schedule for the installation and/or
institution of the alternative operational
and'/or equipment controls.
(e) The Director may approve a Petition for Alternative
Control if the petition is submitted in accordance
with paragraph (d) of this section.
DISCUSSION
The wording in paragraphs (a) and (b) of this section is similar to what
appears in the CTG document. The phrase "two complete liquid service inspec-
tions and five complete gaseous service inspections" is a clarification of the
phrase, "after over 1 year of monitoring" which appears on page 6-4 of the
CTG document.
As stated in the CTG, there are sources that may need to be isolated from
the process in order to be repaired. This procedure may be difficult for some
equipment; especially compressors that do not have spares and valves that
cannot be isolated. For these and possibly other sources, it may be necessary
to have a partial or complete unit shutdown to repair the leak. Since a
unit shutdown may create more emissions than the repair eliminates, these
sources need not be repaired until the necessary shutdown occurs, such as
a scheduled unit turnaround. These components must be identified in the
leaking component monitoring log and in the quarterly report submitted to
the Director.
In certain instances, more than simple or unit shutdown repairs will
be necessary to bring a leaking component into compliance. This can be true
for some pump or compressor seals or for drain systems. It may be necessary
to modify or replace the whole pump or compressor seal system or to modify
the underground drain pipes. Sources such as this, where the leak cannot
be repaired by maintenance or equipment changeout, should be addressed indi-
vidually by the air pollution control agency, taking into account both the
potential emission reduction and the cost and technical feasibility of bring-
ing such a source into compliance with the concentration limit.
This alternative situation can be handled by paragraph (c) under
Petition for Alternative Controls. If the owner or operator can demonstrate
that compliance with the Provisions for Specific Processes would be techno-
logically infeasible, he may petition for alternative control. Since the
operator may reach his conclusion after a series of repair failures or after
the addition of new process equipment, there should not be a time limit for
petitioning. In other words, the operator should be allowed to petition for
alternative control whenever he feels it is appropriate. Since VOC leaks can
be estimated, the petitioner may be required to present figures which show
the magnitude of the emission reduction. It will be the responsibility of
the regulatory agency to determine whether the alternative control is effective.
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Both industry and the State and local regulatory agencies should be aware
that a Petition for Alternative Controls may be a revision of the SIP and, as
such, would require EPA approval.
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SXX.9110 Definitions.
(a) For the purpose of this Regulation, the general definitions
apply.
(b) For the purpose of this Regulation, the following definitions
also apply:
(1) "Single coat" means one film of coating applied
to a metal surface;
(2) "Prime coat" means the first of two or more
films of eoating applied to a metal surface;
(3) "Topaoat" means the final film or series of
films of coating applied in a two-coat (or more)
operation;
(4) "Low solvent coating" means coatings which contain
less organic solvent than the conventional coatings
used by the industry. Low solvent coatings
include water-borne., higher sol-Ids, electrodeposition
and powder coatings;
(5) "Heat sensitive material" means materials which
cannot consistently be exposed to temperatures
greater than 95°C (20Z°F);
(6) "Transfer efficiency" means the portion of coating solids
which adheres to the metal surface during the application
process, expressed as a percentage of the total volume
of coating solids delivered by the applicator;
(7) "Air dried coating" means coatings which are dried
by the use of c.ir or forced warm air at temperatures
up to 90°C (194°F);
(8) "Clear coat" means a coating which lacks color and
opacity or is transparent and uses the undercoat as
a reflectant base or undertone color-
(9) "Extreme performance coatings" means coatings
designed for harsh exposure or extreme environmental
conditions;
(10) "Coating application system" means all operations
and equipment which applies, conveys, and dries
a surface coating, including, but not limited to,
spray booths, flow coaters, flashoff areas, air
dryers and ovens; and
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(11) "Extreme environmental conditions" means, exposure
to any of; the weather all of the time, temperatures
consistently above 95 C, detergents, abrasive and
scouring agents, solvents, corrosive atmospheres, or
similar environmental conditions.
DISCUSSION
A certain amount of judgment must be exercised in categorizing specific
coatings as a "clear coat" or an "extreme performance coating." Clear coats
are intended to be those coatings which allow the underlying coating or
material to be seen. However, these coatings may have a certain amount of
opaqueness. Extreme performance coatings are intended to be those coatings
that are designed to meet any one of the "extreme environmental conditions"
given in definition (b)(11).
The air dried coating definition is included to differentiate these
coatings from oven dried coatings. The 90 C temperature is the upper limit
that is generally used to increase the drying rate of air curable coatings.
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%XX.9120 Applicability.
(a) This Regulation is applicable to surface coating of
miscellaneous metal parts and products in the following
counties:
Miscellaneous parts and products include:
(I) Large farm machinery (harvesting, fertilizing
and planting machines, tractors, combines, etc.);
(2) Small farm machinery (lawn and garden tractors,
lawn mowers, rototillers, etc.);
(3) Small appliances (fans, mixers, blenders, crock
pots, dehumidifiers, vacuum cleaners, etc.);
(4) Commercial machinery (office equipment, computers
and auxiliary equipment, typewriters, calculators,
vending machir.es, etc.);
(5) Industrial machinery (pumps, compressors, conveyor
components, fans, blowers, transformers, etc.);
(6) Fabricated metal products (metal covered doors,
frames, etc.); and
(7) Any other industrial category which coats metal
parts or products under the Standard Industrial
Classification Code of Major Group 33 (primary
metal industries)3 Major Group 34 (fabricated
metal products), Major Group 35 (nonelectric
machinery), Major Group 36 (electrical machinery),
Major Group 37 (transportation equipment), Major
Group 38 (miscellaneous instruments), and Major
Group 39 (miscellaneous manufacturing industries).
(b) This Regulation is not applicable to the surface coating
of the following metal parts and products:
(1) automobiles and light-duty trucks;
(2) metal cans;
(3) flat metal sheets and strips in the
form of rolls or coils;
(4) magnet wire for wse in electrical machinery;
(5) metal furniture;
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(6) large appliances;
(7) exterior of airplanes;
(8) automobile re finishing;
(9) customised top coating of automobiles and trucks, if
production is less than 35 vehicles per day; and,
(10) exterior of marine vessels,
(c) This Regulation applies to the application area(s),
flashoff area(s), air and forced air drier (s), and
oven(s) used in the surface coating of the metal parts
and products in part (a). This regulation also applies
to prime coat, top coat, and single coat operations.
DISCUSSION
This section defines the category of "miscellaneous metal parts
and products." This section is based on the "List of Industrial Cate-
gories Covered" table in the CTG. Major Groups 40 and 41 of the SIC
Code are not included in this regulation because further investigation
has indicated that little or no surface coating is done by these industries.
Paragraph (b) of this section of the regulation is included to clarify the
extent of the regulation. Parts (b)(l) through (b)(6) are addressed in previous
RACT regulatory guidance (EPA-905/2-78-001) and are, therefore, excluded from
this regulation. Exterior coatings on airplanes and marine vessels are high
performance coatings which are applied under conditions that are not easily
controlled. However, parts for the exterior of airplanes and marine vessels
that are coated as a separate manufacturing or coating operation are intended
to be covered by this regulation. Automobile refinishing and the customized
top coatings of less than 35 automobiles and trucks per day are not included
because of: (1) the numerous small sources involves, (2) the fact that the
operations are different than those generally addressed by this regulation,
and (3) the difficulty of controlling the emissions from the small sources.
This regulation Is intended to control the bulk of the metal coating
operations. However, it is not intended to include categories of special
military, scientific or experimental coatings.
Question: Should there be a size exemption different from the general
exemption for sources emitting less than 15 Ib/day of VOC?
Answer: California has rules which are slightly different that those
suggested in this regulation. However, based on California
specific information, it has been found that exempting sources
emitting less than 20 Ib/day omits 45 percent of the sources
subject to the California regulation and the regulation is
still applicable to more than 95 percent of the potential
emissions.
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§XX.9ISO Provisions for- Specific Processes.
(a) No owner or operator of a facility engaged in the
surface coating of miscellaneous metal parts and
products may operate a coating application system
subject to this regulation that emits VOC in
excess of:
(1) 0.52 kg/I (4.3 Ib/gal) of coating3 excluding
water3 delivered to a coating applicator that
applies clear coatings;
(2) 0.42 kg/I (3.5 Ib/gal) of coating, excluding water,
delivered to a coating applicator in a coating
application system that is air dried or forced warm
air dried at temperatures up to 90 C (194 F);
(Z) 0.42 kg/I (3.5 Ib/gal) of coating, excluding
water, delivered to a coating applicator that
applies extreme performance coatings; and,
(4) 0.36 kg/I (3,0 Ib/gal) of coating, excluding
water, delivered to a coating applicator for
all other coatings and coating application
systems.
(b) If more than one emission limitation in paragraph (a)
applies to a specific coating, then the least stringent
emission limitation shall be applied.
(c) All VOC emissions from solvent washings shall be considered
in the emission limitations in paragraph (a), unless the
solvent is directed into containers that prevent evapora-
tion into the atmosphere.
(d) The emission limits set forth in paragraph (a) shall
be achieved by:
(1) the application of low solvent coating
technology;
(2) an incineration system which oxidizes at
least 90.0 percent of the nonmethane volatile
organic compounds (VOC measured as total combustible
carbon) to carbon dioxide and water; or,
(3) an equivalent means of VOC removal. The equivalent
means must be certified by the owner or operator
and approved by the Director.
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(e) A capture system must be used in conjunction with the
emission control systems in part (d)(2). The design
and operation of a capture system must be consistent
with good engineering practice, and shall be required
to provide for an overall VOC emission reduction
efficiency of at least 80 percent.
DISCUSSION
The emission limitations in this section of the regulation are based on
the information given in Chapter 4 of the "Surface Coating of Miscellaneous
Metal Parts and Products," EPA-450/1-78-015. The CTG document gave two
additional categories, which are:
1. Frequent color change and/or large number of colors
applied, or first coat on untreated ferrous substrate -
0.36 kg/1 emission limit; and,
2. Powder Coatings - 0.05 kg/1 emission limit.
The "frequent color change...." category has been included with
part (a)(4), because it has the same emission limitation. The powder coatings
category was also included in the "all other coatings" part (a)(4) as an
incentive to use powder coatings. A facility which converts a coating line
to powder coatings may use the difference between the actual emissions from
the powder coatings and the emission limitation as an internal offset.
In paragraph (d) the stipulation is made that, if an incinerator is
used, 90 percent of the VOC entering the device must be oxidized to H20 and
C02. This requirement assures that the incinerator is not simply oxidizing
large molecular weight organic compounds to smaller molecular weight organics
which would still participate in oxidant formation. The equivalent means of
VOC removal may be an alternative control device, such as an adsorber or
condenser. However, a combination of lower solvent usage and a lower efficiency
control device is also acceptable.
Emissions from purging of spray guns were not considered when developing
the emission limitations in this section. However, since they are controllable,
they should be included in a determination of compliance. Their inclusion
in a compliance determination raises three issues, however: (1) what method
can be used to factor these emissions into a compliance determination; (2) are
these emissions of a quantity large enough to require a separate emission
limitation; (3) are these emissions of a quantity small enough to be of no
concern? EPA recommends that these be ignored if solvent washings and purging
of spray guns are directed into essentially closed containers. If the emis-
sions are uncontrolled, they should be attributed to the coating.
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Question: Is the coating of hardware for wood and metal
cabinets covered in this CTG category?
Answer: Yes. Even though the language in the Metal
Furniture coating CTG, EPA-450/2-77-032 (page iii) ,
suggests that che coating of hardware for wood and
metal cabinets could be included in that CTG
category, that is not EPA's intent. The coating
of hardware is covered by the emission limits in
the Miscellaneous Metal Parts and Products CTG.
Question: Is the coating of metal pails and drums covered
by the can coating CTG or by the miscellaneous
metal coating CTG?
Answer: This industry is covered by the miscellaneous metal
coating CTG. The can coating emission limits were
based on high speed, high volume can manufacturing
and coating process. Metal pails and drums are
generally made of heavier gauge material and have
larger capacity than cans. This results in pails
and drums usually being manufactured and coated at
a slower rate and lower volume than cans.
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§XX,9140 Compliance Schedules.
(a) The owner or operator of a source of volatile organic
compounds subject to this regulation shall meet the
applicable Increments of progress In the
following schedules:
(1) Sources utilizing low solvent content coatings
to comply with the emission limitations In
SXX.9130 shall:
(i) Submit final plans for the application
of low solvent technology before
October 15, 1980;
(II) Complete evaluation of product quality
and commercial acceptance before
April 1J 1981;
(ill) Issue purchase orders or contracts for
low solvent content coatings before
June 1, 1981;
(iv) Initiate process modifications before
July 1, 1981; and,
(v) Complete process modifications and
begin use of low solvent content
coatings before July 1, 1982.
(2) Sources utilizing process equipment changes
or add-on control devices, Including incineration
with heat recovery, to comply with the emission
limitations shall:
(I) Submit final plans for the emission
control system, or process equipment,
or both, before October 15, 1980;
(il) Award contracts or purchase orders
for the emission control systems, or
process equipment, or both, before
December 15, 1980;
(ill) Initiate onsite construction or
installation of the emission control
system, or process equipment, or both,
before June 1, 1981;
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(iv) Complete onsite construction or
installation of the emission control
system o;" process equipment, or both,
before June 1, 1982; and,
(v) Achieve final compliance, determined in
accordance with §XX.91SO, before
July 1, 1982.
(3) Sources utilizing incineration without heat recovery
or process modifications not requiring purchase orders,
to comply with the emission limitations in §XX.9130, shall:
(i) Submit final plans for the emission control
system or process modification, or both,
before September 15, 1980;
(ii) Award contracts or purchase orders for the
the emission control system or process
modification, or both, before November 1, 1980;
(Hi) Initiate onsite construction or installation
of the emission control system or process
modification, or both, before January 15, 1981;
(iv) Complete onsite construction or installation
of the emission control system or process
modification, or both, before May 15, 1981;
and,
(v) Achieve, final compliance, determined in accordance
with SXX.9150, before July 1, 1981.
(b) l!he owner or operator of a source of volatile organic compounds
subject to this regulation may submit to the Director, and the
Director may approve, a proposed alternative compliance
schedule provided:
(1) the proposed alternative compliance schedule is
submitted before September 15, 1980:
(2) the owner or operator provides information showing
the need for an alternative schedule;
(3) the alternative compliance schedule contains
increments of progress;
(4) sufficient documentation and certification from
appropriate suppliers, contractors, manufacturers,
or fabricators is submitted by the owner or operator
of the volatile organic compound source to justify
the dates proposed for the increments of progress; and,
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(5) Final compliance is achieved as expeditiously
as possible and before the photochemical
oxidant attainment date,
(c) "One owner1 or operator of a volatile organic compound
source subject to a compliance schedule of this
section shall certify to the Director within 5
days after the deadline for each increment of
progress3 whether the required increment of
progress has been met.
DISCUSSION
According to the EPA memorandum of November 3, 1978, on "Categorical
Compliance Schedules for VOC Sources," a 2-year compliance schedule is recom-
mended for carbon absorption, incineration with heat recovery and low-solvent
technology. A 1-year compliance schedule is recommended for incineration
without heat recovery. Assuming July 1, 1980 as the effective day of the
regulation, the following progress increments would be required:
Compliance date
Incineration Carbon adsorption,
Progress increment without heat incineration with
recovery heat recovery
1. Control Plan Submitted September 15, 1980 October 15, 1980
2. Contract Award November 1, 1980 December 15, 1980
3. Initiation of Construction January 15, 1981 June 1, 1981
4. Construction Completed May 15, 1981 June 1, 1982
5. Final Compliance July 1, 1981 July 1, 1982
Part (a)(l) of this section of the regulation is not completely consistent
with the categorical compliance schedules. The wording has been changed
slightly to be more relevant to the application of low-solvent technology.
In addition, the date in part (a)(l)(ii) has been changed to April 1, 1981
to allow sufficient time for product quality and commercial acceptance testing.
Part (a)(l) of this section is primarily for owners and operators of sources
which are intending to use existing low-solvent technology. Owners or operators
of VOC sources intending to develop new low-solvent coatings are most likely
to submit a schedule consistent with part (b) of this section.
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Allowance for Alternative; Compliance Schedules is included as paragraph
(b) of this section. The owner or operator of the emission source should be
able to submit a proposed alternative schedule to the Director for review
as long as it is presented before September 15, 1980, and it is properly
documented. The Director mus-; be able to approve a separate schedule for any
source if he finds that compliance with paragraph (a) is not feasible.
EPA states, however, that "if such an alternative compliance schedule
would impact on attainment or maintenance of any ambient standards, then
approval of the alternative compliance schedule as an SIP revision would be
required....Too many alternative schedules extending until December 31, 1982,
might also prevent a state from showing reasonable further progress toward
attainment..."
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§XX.9150 Testing and Monitoring.
(a) Upon request of the Director, the owner or operator
of a volatile organic compound source required to
comply with this regulation shall, at- his own
expense, demonstrate compliance by the methods of
part (c) of this section, or an alternative method
approved by the Director. All tests shall be made
by, or under the direction of, a person qualified
by training and/or experience in the field of air
pollution testing.
(b) A person proposing to conduct a volatile organic
compound emissions test shall notify the Director
of the intent to test not less than 30 days before
the proposed initiation of the tests so the Director
may at his option observe the test. The notification
shall contain the information required by, and be in
a format approved by, the Director.
(c) (1) Test procedures to determine compliance with
§XX.9130 must be approved by the Director and
be consistent with:
(i) EPA Guideline Series document, 'Measurement
of Volatile Organic Compounds,"
EPA-450/2-78-041; and,
(ii) Appendix A of "Control of Volatile Organic
Emissions from Existing Stationary Sources -
Volume II: Surface Coating of Cans, Coils,
Paper, Fabrics, Automobiles, and Light-Duty
Trucks," EPA-450/2-77-008.
(2) The Director may accept, instead of the coating analysis
required in part (c)(l)(ii) of this paragraph, a certification
by the manufacturer of the composition of the coatings, if
supported by actual batch formulation records.
(d) If add-on control equipment is used, continuous monitors
of the following parameters shall be installed, periodically
calibrated, and operated at all times that the associated
control equipment is operating:
(1) exhaust gas temperature of all incinerators;
(2) temperature rise across a catalytic incinera-
tor bed;
(3) breakthrough of VOC on a carbon adsorption
unit; and,
(4) any other continuous monitoring or recording
device required by the Director.
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DISCUSSION
Low solvent coating technology: In order to determine the quantity of
VOC contained in a liter of coating for comparison to the limitations in
§XX.9130, the procedures described in Appendix A of the CTG document on
surface coating, EPA-450/2-77-008, (referenced in §XX.9150 (c)(l)(ii)) should
be used. Certification by a manufacturer, vendor or user of a coating, of the
results of the test procedure should be sufficient for a determination of
compliance in most cases.
Conversion of organic caroon to VOC: The results of the methods in the
"Measurement of Volatile Organic Compounds" document, EPA-450/2-78-041, are
expressed as a mass concentration of organic carbon. In order to convert these
results to a percent reduction by weight or to a mass rate of emission reduction
several situations must be considered.
In situations where only a single organic compound is being controlled,
the organic carbon weight is directly convertable to VOC weight by using the
molecular weight of the compound. In this case the percent reduction in mass
concentration of carbon across a control device is identical to the percent
reduction of VOC by weight.
In many situations a mixture of organic compounds enter a control device.
If two assumptions can be made:: (1) that the relative concentrations of the
compounds do not change across the control device (i.e., a specific compound is
not selectively absorbed or adsorbed); and (2) the relative concentrations of
compounds can be estimated from the conditions existing at the source of the
VOC emissions; then a weighted average of the mass of carbon as a percent of
the total weight can be calculated and this factor can be used to calculate
the weight of VOC represented by the mass concentration of organic carbon.
In situations where a mixture of organic compounds enter a control
device and a mixture with different relative concentrations leaves the control
device, the mass concentration of carbon cannot be converted without additional
test methods. These methods mist provide the relative concentrations of the
inlet and outlet mixtures of VOC. Once the relative concentrations are known
a factor can be calculated as in the above situation.
Additional test methods must also be used when measuring the emissions
from incinerators, because the organic carbon concentration test method
excludes CO and C02- Measurements of these compounds are necessary to
determine the percent conversion to C02 and H20.
Measurement of volumetric flow rate can be accomplished with EPA Reference
Methods 1 and 2, found in 40 CFR 60, Appendix A. The mass concentration
multiplied by the volumetric flow rate will equal the mass flow rate of VOC.
Once the mass flow rate is known at the inlet and at the outlet of a VOC
emission control device, the percent reduction can be calculated. Two potential
problems remain: (1) Methods 1 and 2 cannot be performed on small vents; and
(2) the guideline series document, EPA-450/2-78-041, does not rigorously define
the sampling procedure.
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Add-on control equipment: The quantity of VOC in the coating should be
determined first by using the procedures described in Appendix A of the CTG
document on surface coating, EPA-450/2-77-008, (referenced in §XX.9150 (c)(l)(ii))
The uncontrolled VOC mass emission rate can be calculated from the composition of
the coating and the rate of coating usage. Some procedure must be devised
which includes the number of runs required and the time limit for each run
for determining an average rate of coating usage. This is a weak point in
the test procedure, since an "average rate of coating usage" is not defined.
In most cases this rate of usage can be adequately determined by a source's
record of coating consumption.
The mass rate of VOC emission reduction by the emission control device
can be calculated by a combination of measuring the VOC mass concentration
(consistent with the procedures in EPA-450/2-78-041) in the entrance and
exit air streams along with the air flow measurements. The VOC emission
reduction rate (kg/hr) should be subtracted from the uncontrolled VOC
emission rate (kg/hr) and will result in the actual VOC emission rate (kg/hr).
The actual emission rate should then be divided by the average volumetric
rate of coating usage (1/hr) and will result in the quantity of VOC actually
emitted per liter of coating (kg/1) for comparison to the limits of §XX.9130.
Monitoring instruments are recommended where add-on control equipment
is used in order to insure that the VOC emission reduction efficiency remains
at the level required for compliance with §XX.9130. All incinerators should
be equipped with temperature indicators. Recorders should be required for
larger installations. The temperature rise across a catalyst bed should be
monitored continuously for catalytic incinerators and carbon adsorption bed
breakthrough should be monitored on carbon adsorption units.
State and local agencies developing a regulation for this source category
should give additional consideration to monitoring, recordkeeping and report-
ing requirements. Sample regulatory language for this type of provision can
be found in §XX.8070 Monitoring, Recordkeeping and Reporting in Appendix A.
39
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$XX.S160 Petition for Alternative Controls.
(a) The owner or operator of a source of volatile organic compounds
subject to this regulation may petition the Director to allow
the use of alternative operational and/or equipment controls
for the reduction of volatile organic compound emissions. The
petition must be submitted in writing to the Director before
September 1, 1980, and must contain:
(1) the name and aadress of the company and the name and
telephone number of a responsible company representative
over whose signature the petition is submitted;
(2) a description of all operations conducted at the
location to which the petition applies and the
purpose the volatile organic compound emitting
equipment serves within the operations;
(S) reference to the specific emission limitations
in ^XX.9130 for which alternative operational
and/or equipment controls are proposed;
(4) a detailed description of the proposed alternative
operational and/or equipment controls, the magnitude
of volatile organic compound emission reduction which
will be achieved, and the quantity and composition
of volatile organic compounds which will be emitted if
the alternative operational and/or equipment controls
are instituted;
(5) a schedule for the installation and/or institution of
the alternative operational and/or equipment controls in
conformance with the appropriate compliance schedule
section;
(6) certification that emissions of all other air contaminants
from the subject facility are in compliance with or under a
schedule for compliance with all applicable local, state
and f deral laws and regulations; and,
(7) all additional information, requested by the Director,
necessary to determine whether the VOC emission reduction
achieved by the alternative controls is equivalent to the
emission reduction achieved by the applicable regulations.
(b) The Director may approve a Petition for Alternative Control if:
(1) the petition is submitted in accordance with, paragraph
(a) of this section;
40
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(2) all other air contaminant emissions from the subject
facility are in compliance with, op under a schedule
for compliance as expeditiously as practicable with,
aii applicable local, state, and federal regulations;
(3) the petition demonstrates that the aggregate VOC
emissions from the affected operations will in no
case be greater through application of the alternative
control plan than would be permitted through, conformance
with the applicable VOC emission reduction regulations;
(4) the petition contains a compliance schedule for achieving
and maintaining a reduction of volatile organic compound
emissions as expeditiously as practicable, but no
later than t*he compliance date that would be required
under the applicable VOC emission reduction regulation;
and,
(5) a nuisance condition will not result from operation of
the source as proposed in th.e Petition.
(c) No alternative control plan is effective until it is submitted
to and approved by the Administrator of the United States
Environmental Protection Agency as a revision of the State
Implementation flan pursuant to Section 110 (a) (2) (A) of the
Clean Air Act.
DISCUSSION
This section allows the owner or operator of a source of VOC subject to
this regulation to use higher coating transfer efficiencies, powder coatings,
or internal offsets to reduce the VOC emissions by at least as much as if
the emission limitations in §XX.9130 were applied.
Question: How should an appropriate baseline transfer efficiency
be determined for a specific source?
Answer: If the actual transfer efficiency of the existing
coating operation at a specific source is typical
of the industry or state-of-the-art, then that
actual transfer efficiency would be baseline. If
the actual transfer efficiency of the existing
coating operation is less than what is typical for
that operation in the industry, then the baseline
transfer efficiency should be equal to the typical
transfer efficiency for that operation in the
industry. Additional information on transfer
41
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efficiency appears in three letters between
Ransberg Corp. and EPA, which are reprinted
in the Graphic Arts section of Appendix B.
Internal offsets should be allowed if the owner or operator is able
to reduce aggregate emissions to the level required by the emission limitations
in §XX.9130. This is to encourage the use of powder coatings and similar
extremely low VOC emitting coatings or operations. Certain powder coatings
require a primer which is applied as a high solvent dip solution. This addi-
tional source of VOC should be considered when determining allowable offsets.
Enforceability is not expected to be jeopardized in this situation because
the quantities of solvent consumed can be estimated from coating consumption
rates and compared to source specific limits. It should be noted that any
permits for alternative controls should specify that the conversion of a source
to the use of powder coatings or low VOC coatings must be permanent. A more
detailed discussion of internal offsets can be found in Appendix A - General
Provisions, §XX.8060.
42
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DISCUSSION
In June 1978, EPA published a Control Technique Guideline for the manu-
facture of vegetable oils, ("Control of Volatile Organic Emissions from Manu-
facture of Vegetable Oils," EPA-450/2-78-035). This guideline provides pro-
cessing flow and technology information as well as guidance on the planning
and analysis required for the control of VOC emissions at vegetable oil ex-
traction facilities. At the time this document was published, EPA acknowledged
that there were uncertainties about, the testing methods. EPA also had a field
testing program that was developing useful data in the area of testing and
monitoring. Initial results from several scheduled field tests indicated that
the measured data are significantly more variable than had been anticipated.
Consequently, in a letter date.d June 22, 1979 (see next page), EPA asked the
States to defer any regulatory action for vegetable oil plants until after the
field testing program is completed and all the data analyzed. It is anticipated
that the testing program will be completed in mid-1980. Accordingly, a sample
regulation for the control of VOC from vegetable oil processing plants is not
included in this document. Additional information will be provided after the
completion of the field testing program.
44
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DATE
SUBJECT
FROM
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
22 1979
Initial Results of Emission Testing of Volatile Organic Compounds from
Vegetable OiIs
Walter C. Barber, Director
Office of Air Quality Plannfng^afnd Standards (MD-10)
T0 Director, Air and Hazardous Materials Division, Regions I-X
As you are aware, in June 1978 EPA published a Control Techniques
Guideline (CTG) for the manufacture of vegetable oils ("Control of
Volatile Organic Emissions from Manufacture of Vegetable Oils,"
EPA-450/2-78-035, June 1978). That document stated that the regulatory
guidelines were based on engineering calculations and that further
verification of these emission levels would be made upon review of data
developed in conjunction with New Source Performance Standard development,
Initial results from the first of several scheduled field tests
indicate that the measured results are significantly more variable than
originally anticipated. Accordingly, I have concluded that it would be
prudent to defer regulatory action for vegetable oil plants until after
the test program is completed this fall and all the data have been
analyzed.
States should not be required to adopt rules for this CTG category
during 1979. Further information will be provided on this matter after
the completion of the field test program.
cc: Don Goodwin
Jack Farmer
Fred Porter
George Walsh
EPA Form 1320-6 (Rev. 3-76)
45
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5XX.9310 Definitions.
(a) For the purpose of this Regulation, the general definitions
apply*
(b ) For the purpose of this Regulation, the following definitions
also apply:
(1) "Class II hardboard paneling finish" means finishes
which meet the specifications of Voluntary Product
Standard PS-59-73 as approved by the American
National Standards Institute.
(2) "Hardboard" is a panel manufactured primarily from
inter-felted ligno-cellulosic fibers which are
consolidated under heat and pressure in a hot
press.
(Z) "Hardwood plywood" is plywood whose surface layer
is a veneer of hardwood.
(4) "Natural finish hardwood plywood panels" means
panels whose original grain pattern is enhanced
by essentially transparent finishes frequently
supplemented by fillers and toners.
(5) "Thin particleboard" is a manufactured board % inch
or less in thickness made of individual wood
particles which have been coated with a binder and
formed into flat sheets by pressure.
(6) "Printed interior panels" means panels whose grain
or natural surface is obscured by fillers and
basecoats upon which a simulated grain or decorative
pattern is printed.
(7) "Fileboard" means panelling that has a colored
waterproof surface coating.
(8) "Coating application system" means all operations
and equipment which apply, convey, and dry a surface
coating, including, but not limited to, spray booths,
flow coaters, conveyers, flashoff areas, air dryers
and ovens.
48
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SXX.9320 Applicability.
(a) This Regulation applies to all flat wood manufacturing
and surface finishing facilities, located in the
counties of , that manufacture
the following products:
(2) Printed interior panels made of hardwood
plywood and thin particle board;
(2) Natural finish hardwood plywood panels; or,
(3) Hardboard paneling with Class II finishes.
(b) This Regulation does not apply to the manufacture of
exterior siding, tileboard, or particleboard used
as a furniture component.
DISCUSSION
The emissions from inks used to print simulated grain or decorative
patterns on printed interior panels are covered in this CTG category, and
should not be considered a Graphic Arts activity.
49
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§XX.9330 Provisions for Specific Processes.
(a) No owner or operator of a flat wood manufacturing
facility subject to this regulation shall emit volatile
organic compounds from a coating application system
in excess of:
(1) 2.9 kg per 100 square meters of coated finished
product (6.0 lb/1,000 sq ft) from printed interior
panels, regardless of the number of coats applied;
(2) 5.8 kg per 100 square meters of coated finished
product (12.0 lb/1,000 sq ft) from natural finish
hardwood plywood panels, regardless of the
number of coats applied; and,
(3) 4.8 kg per 100 square meters of coated finished
product (10.0 lb/1,000 sq ft) from Class II finishes
on hardboard panels, regardless of the number of
coats applied.
(b) The emission limits in paragraph (a) of this section
shall be achieved by:
(1) The application of low solvent content coating
technology; or,
(2) An incineration system which oxidizes at
least 90.0 percent of the nonmethane volatile
organic compounds entering the incinerator
(VOC measured as total combustible carbon) to
carbon dioxide and, water; or,
(3) An equivalent means of VOC removal. The equivalent
means must be certified by the owner or operator
and approved by the Director.
(c) A capture system rrust be used in conjunction with the
emission control systems in parts (b)(2) and (b)(3).
The design and operation of a capture system must be
consistent with good engineering practice and shall be
required to provide for an overall emission reduction
sufficient to meet the emission limitations in
paragraph (a) of this section.
(d) For Petition for Alternative Controls Section: see
Discussion.
50
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DISCUSSION
In the CTG the emission limitations are expressed as "kg of VOC per 100
square meters of coated surface." It is EPA's intent that the term "coated
surface" be interpreted as "coated finished product." The emission limitations
in this section of the regulation are expressed in a manner which allow increased
transfer efficiency or reduced film thickness to be used as an equivalent control
method. In addition, sources should be allowed to employ combinations of process
modifications and control equipment to meet the emission limitations. This
approach is similar to the "bubble" concept in that it allows sources to propose
a control strategy which is most cost-effective for their particular operations.
It is very important that, if several films of coating are applied, the aggregate
emissions must meet the emission limitations of this section regardless of the
control scheme used.
Except for incineration, capture and control efficiencies are not addressed.
It should be assumed that all of the solvent that exists in the coatings evap-
orates into the atmosphere. The overall reduction in VOC emissions achieved
by the capture and control devices must be sufficient to meet the emission
limitations. If an incinerator is used, 90 percent of the nonmethane VOC by
weight entering the device must be oxidized to t^O and C02 to insure that the
incinerator is not simply oxidizing large molecular weight organic compounds
to smaller molecular weight organics which would still participate in oxidant
formation.
It should be noted that Class II finishes referred to in part (a)(3) of
this section are classified according to the system in Voluntary Product Stan-
dard PS-59-73 of the American National Standards Institute. This classifica-
tion system is different from the one used for coating analysis in the
guideline document referenced in §XX.9350(c)(1)(ii).
Even though this regulation allows a source some flexibility in choosing
a cost-effective control strategy, more economically advantageous control
strategies may be devised by the affected sources, if the Petition for
Alternative Controls §XX.8060 in Appendix A, is incorporated into this regu-
lation. Additional information on alternative controls and the "bubble concept"
also appear in the discussion section following §XX.8060.
51
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§XX.9Z40 Compliance Schedules.
(a) The owner or operator of a source of volatile
organic compounds subject to this regulation shall
meet the applicable increments of progress in the
following schedules:
(1) Sources utilizing low solvent content coatings
to comply with the emission limitations in
5XX.9330 shall:
(i) Submit final plans for the application
of low solvent technology before
October 15, 1980;
(ii) Complete evaluation of product quality
and commercial acceptance before
April 1, 1981;
(Hi) Issue purchase orders or contracts
for low solvent content coatings
before June I, 1981;
(iv) Initiate process modifications before
July 1,, 1981; and,
(v) Complete process modifications and
begin use of low solvent content
coatings before July 1, 1982.
(2) Sources utilizing process equipment changes or
add-on control devices, including incineration
with ~heat recovery, to comply with the emission
limitations in SXX.9330 shall:
(i) Submit final plans for the emission
control system, or process equipment,
or both., before October 15, 1980;
(ii) Award contracts or purchase orders
for the emission control systems,
or process equipment, or both, before
December 15, 1980;
(Hi) Initiate onsite construction or
installation of the emission control
system, or process equipment, or both,
before June 1, 1981;
52
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(iv) Complete onsite construction or
•installation of the emission control
system or process equipment, or both,
before June 1, 1982; and,
(v) Achieve final compliance, determined in
accordance with SXX.9Z50, before
July 1, 1982.
(3) Bourses utilizing incineration without heat
recovery or process modifications not requiring
purchase orders, to comply with the emission
limitations in SXX.9330, shall:
(i) Submit final plans for the emission
control system or process modification,
or both, before September 15, 1980;
(ii) Award contracts or purchase orders for
the emission control system or process
modification, or both, before November 1, 1980;
(Hi) Initiate onsite construction or installation
of the emission control system or process
modification, or both, before January 15, 1981;
(iv) Complete onsite construction or installation
of the emission control system or process
modification, or both, before May 15, 1981;
and,
(v) Achieve final compliance, determined in
accordance with 5XX.9350, before July 1, 1981.
(b) The owner or operator of a source of volatile organic
compounds subject to this regulation may submit to the
Director, and the Director may approve, a proposed
alternative compliance schedule provided:
(1) the proposed alternative compliance schedule is
submitted before September 15, 1980;
(2) the owner or operator provides information showing
the need for an alternative schedule;
(3) the alternative compliance schedule contains
increments of progress;
(4) sufficient documentation and certification from
appropriate suppliers, contractors, manufacturers,
or fabricators is submitted by the owner or operator
of the volatile organic compound source to justify the
dates proposed for the increments of progress; and,
53
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(5) Final compliance is achieved as expeditiously as
possible and before the photochemical oxidant
attainment date.
(a) fhe owner or operator of a volatile organic compound
source sub-sect to a compliance schedule of this
section shall certify to the Director within 5 days
after the deadline for each increment of progress3
whether the required increment of progress has been
met.
DISCUSSION
According to the EPA memorandum of November 3, 1978, on "Categorical
Compliance Schedules for VOC Sources," a 2-year compliance schedule is
recommended for carbon adsorption and low-solvent technology. A 1-year
compliance schedule is recommended for incineration without heat recovery.
Assuming July 1, 1980, as the effective day of the regulation, the following
progress increments would be required:
Compliance data
Progress increment
Incineration
without heat recovery
Carbon adsorption
low solvent technology
1. Control Plan Submitted
2. Control Award
3. Initiation of Construction
4. Construction Completed
5. Final Compliance
September 15, 1980
November 1, 1980
January 15, 1981
May 15, 1981
July 1, 1981
October 15, 1980
December 15, 1980
June 1, 1981
June 1, 1982
July 1, 1982
Part (a)(l) of this section of the regulation is not completely consis-
tent with the categorical compliance schedules. The wording has been changed
slightly to be more relevant: to the application of low solvent technology.
In addition, the date in part (a)(l)(ii) has been changed to April 1, 1981,
to allow sufficient time for product quality and commerical acceptance
testing. Part (a)(l) of this section is primarily for owners and operators
of sources which are intending to use existing low solvent technology. Owners
or operators of VOC sources intending to develop new low solvent coatings
are most likely to submit a schedule consistent with part (b) of this section.
Allowance for Alternative Compliance Schedules is included as paragraph
(b) of this section. The owner or operator of the emission source should be
able to submit a proposed alternative schedule to the Director for review
as long as it is presented before September 15, 1980, and it is properly docu-
mented. The Director must be able to approve a separate schedule for any
source if he finds that corapliance with paragraph (a) is not feasible.
54
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EPA states, however, that "if such an alternative compliance schedule
would impact on attainment or maintenance of any ambient standards, then
approval of the alternative compliance schedule as an SIP revision would be
required....Too many alternative schedules extending until December 31, 1982,
might also prevent a state from showing reasonable further progress toward
attainment..."
55
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9350 Testing and Monitoring.
(a) Upon request of the Director, the owner or operator of a
volatile organic compound source required to comply with this
regulation shall, at his own expense, demonstrate compliance
by the methods of part (a) of this section, or an alternative
method approved by the Director . All tests shall be made by,
or under the direction of, a person qualified by training
and/or experience in the field of air pollution testing.
(b) A person proposing to conduct a volatile organic compound
emissions test shall notify the Director of the intent to
test not less than 30 days before the proposed initiation
of the tests so the Director may at his option observe the
test. The notification shall contain the information required
by, and be in a format approved by, the Director.
(a) (1) Test procedures to determine compliance with
SXX.9330 must be approved by the Director and
be consistent
(i) EPA Guideline Series document, "Measurement
of Volitile Organic Compounds, "
EPA-450/2-7 8-041; and,
(ii) Appendix A of "Control of Volatile Organic
Emissions from Existing Stationary Sources -
Volume II: Surface Coating of Cans, Coils,
Paper, Fabrics, Automobile, and Light-Duty
Trucks, " EF'A-450/2-77-008.
(2) The Director may accept, instead of the coating analysis
required by part (c)(l)(ii) of this paragraph, a certification
by the coating manufacturer of the composition of the coating,
if supported 'by actual batch formulation records.
(d) If add-on control equipment is used, continuous monitors
of the following parameters shall be installed, periodically
calibratea, and operated at all times that the associated
control equipment is operating;
(1) exhaust gas temperature of all incinerators;
(2) temperature rise across a catalytic incinerator
bed;
(3) breakthrough of VOC on a carbon adsorption unit; and,
(4) any other continuous monitoring or recording device
required by the Director.
56
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DISCUSSION
Low solvent coating technology: In order to determine the quantity of
VOC contained in a liter of coating for comparison to the limitations in
§XX.9330, the procedures described in Appendix A of the CTG document on
surface coating, EPA-450/2-77-008, (referenced in §XX.9350 (c)(l)(ii)) should be
used. Certification by a manufacturer, vendor or user of a coating, of the results
of the test procedure should be sufficient for a determination of compliance in
most cases.
Conversion of Organic Carbon to VOC: The results of the methods in the
"Measurement of Volatile Organic Compounds" document, EPA-450/2-78-041, are
expressed as a mass concentration of organic carbon. In order to convert these
results to a mass rate of VOC several situations must be considered.
In situations where only a single organic compound is being controlled,
the organic carbon weight is directly convertable to VOC weight by using the
molecular weight of the compound. In this case the percent reduction in mass
concentration of carbon across a control device is identical to the percent
reduction of VOC by weight.
In many situations a mixture of organic compounds enter a control device.
If two assumptions can be made: (1) that the relative concentrations of the
compounds do not change across the control device (i.e., a specific compound is
not selectively absorbed or adsorbed); and (2) the relative concentrations of
compounds can be estimated from the conditions existing at the source of the
VOC emissions, then a weighted average of the mass of carbon as a percent of
the total weight can be calculated and this factor can be used to calculate the
weight of VOC represented by the mass concentration of organic carbon.
In situations where a mixture of organic compounds enter a control device
and a mixture with different relative concentrations leaves the control device,
the mass concentration of carbon cannot be converted without additional test
methods. These methods must provide the relative concentrations of the inlet
and outlet mixtures of VOC. Once the relative concentrations are known a
factor can be calculated as in the above situation.
Additional test methods must also be used when measuring the emissions
from incinerators, because the organic carbon concentration test method excludes
CO and COa. Measurements of these compounds are necessary to determine the
percent conversion to C02 and H20.
Add-on control equipment: The quantity of VOC in the coating should be
determined first by using the procedures described in Appendix A of the CTG
document on surface coating, EPA-450/2-77-008, (referenced in §XX.9350(c)(1)(ii)).
The uncontrolled VOC mass emission rate can be calculated from the composition
of the coating and the rate of coating usage. Some procedure must be devised
which includes the number of runs required and the time limit for each run
for determining an average rate of coating usage. This is a weak point in
the test procedure, since an "average rate of coating usage" is not defined.
57
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The mass rate of VOC emission reduction by the emission control device
can be calculated by a combination of measuring the VOC mass concentration
(consistent with the procedures in EPA-450/2-78-041) in the entrance
and exit air streams along with the air flow measurements. The VOC emission
reduction rate (kg/hr) should be subtracted from the uncontrolled VOC emission
rate (kg/hr) and will result in the actual VOC emission rate (kg/hr). This
figure should be divided by the production rate (square meters/hr) to obtain
actual emissions in units of kg/square meter for comparison to the emission
limitations in §XX.9330.
The "overall emission reduction efficiency" can then be calculated by:
mass rate of VOC emission reduction
uncontrolled mass emission rate
x 100 percent
Monitoring instruments are recommended where add-on control equipment
is used in order to insure that the VOC emission reduction efficiency remains
at the level required for compliance with §XX.9330. All incinerators should be
equipped with temperature indicators. Recorders should be required for larger
installations. The temperature rise across a catalyst bed should be monitored
continuously for catalytic incinerators and carbon adsorption bed breakthrough
should be monitored on carbon adsorption units.
State and local agencies developing a regulation for this source category
should give additional consideration to monitoring, recordkeeping and report-
ing requirements. Sample regulatory language for this type of provision can
be found in §XX.8070 Monitoring, Recordkeeping and Reporting in Appendix A.
58
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SXX.9410 Definitions.
(a) Fov the purpose of this Regulation, the general definitions
apply. *
(b) For the purpose of this Regulation, the following definitions
also apply:
(1) "Condenser" means a device whieh cools a gas
stream to a temperature which removes specific
organic compounds by condensation;
(2) "Control system" means any number of control
devices, including condensers, which are designed
and operated to reduce the quantity of VOC
emitted to the atmosphere;
(3) "Reactor" means a vat or vessel, which may
be jacketed to permit temperature control,
designed to contain chemical reactions;
(4) "Separation operation" means a process that
separates a mixture of compounds and solvents
into two or more components. Specific mechanisms
include extraction, centrifugation, filtration,
and crystallization;
(5) "Synthesized Pharmaceutical Manufacturing"
means manufacture of pharmaceutical products
by chemical synthesis;
(6) "Production equipment exhaust system" means a
device for collecting and directing out of
the work area VOC fugitive emissions from
reactor openings, centrifuge openings, and
other vessel openings for the purpose of
protecting workers from excessive VOC
exposure.
60
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SXX.9420 Applicability.
(a) This Regulation applies to all synthesized pharmaceutical
manufacturing facilities located in the following counties:
(b) This Regulation applies to all sources of volatile organic
compounds, including reactors, distillation units, dryers,
storage of volatile organic compounds, transfer of volatile
organic compounds, extraction equipment, filters, cry stallizers
and centrifuges that have the potential to emit 6.8 kg/day
(15 Ib/day) or more.
DISCUSSION
The CTG document for synthesized pharmaceutical manufacturing suggests
an exemption for VOC emissions from reactors, distillation operations,
crystallizers, centrifuges, and vacuum dryers that are less than 6.8 kg/day
(15 Ib/day). Since many of these individual vents are likely to be small in
any given plant, it may often be reasonable to regulate on a plant by plant
basis. This approach involves determining which synthesized pharmaceutical
manufacturing facilities emit large amounts of VOC and within such plants which
operations are significant sources. Control requirements would then be imposed
after considering local air quality, the mass rate of emissions, control cost
estimates, and plant safety effects. Source specific size limitations should
be used instead of facility wide (100 TPY) size limits because of the variable
nature of the VOC emissions and the fact that many facilities emit less than
100 TPY.
There are several types of pharmaceutical production activities which
are not included in the synthesized pharmaceutical manufacturing definition.
Fermentation, extraction of organic chemicals from vegetable materials or
animal tissues, and formulation and packaging of the product are not covered
by this regulation. Facilities which perform these functions probably make up
the majority of the pharmaceutical facilities in the United States. However,
those facilities that are included in the definition of synthesized pharma-
ceutical facilities emit the majority of VOC. Regardless of the number of
different pharmaceutical production activities that may be conducted at any
one facility, only those activities which manufacture pharmaceutical products
by chemical synthesis are intended to be subject to this regulation.
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§XX.9420 Provisions for Specific Processes.
(a) The owner or operator of a synthesized pharmaceutical
manufacturing facility subject to this regulation shall
control the volatile organic compound emissions from all
reactors, distillation operations, crystallizers, centrifuges
and vacuum dryers that have the potential to emit 6.80 kg/day
(15 Ib/day) or more of VOC. Surface condensers or equivalent
controls shall be used, provided that:
(1) If surface condensers are used, the condenser
outlet gas temperature must not exceed:
(i) -25°C when condensing VOC of vapor
pressure greater than 40.0 kPa
(5.8 psi),*
(ii) -15°C when condensing VOC of vapor
pressure greater than 20.0 kPa
(2.9 psi),*
(iii) 0°C when condensing VOC of vapor
pressure greater than 10.0 kPa
(1.5 psi),*
(iv) 10°C when condensing VOC of vapor
pressure greater than 7.0 kPa
(1.0 psi),* or,
(v) 25°C when condensing VOC of vapor
pressure greater than 3.50 kPa
(0.5 psi),*
(2) If equivalent controls are used, the VOC emissions must
be reduced by at least as much as they would be by
using a surface condenser which meets the requirements
of part (a)(l) of this section.
(b) The owner or operator of a synthesized pharmaceutical manufacturing
facility subject to this regulation shall reduce the VOC emissions
from all air dryers and production equipment exhaust systems;
(1) by at least 90 percent if emissions are 150 kg/'day
(330 Ib/day) or more of VOC; or,
(2) to 15.0 kg/day (33 Ib/day) or less if emissions are
less than 150 kg/day (330 Ib/day) of VOC.
Vapor pressures as measured at 20°C.
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(o) The owner or operator of a synthesized pharmaceutical
manufacturing facility subject to this regulation shall:
(1) provide a vapor balance system or equivalent control
that is at least 90.0 percent effective in reducing
emissions from truck or railcar deliveries to storage
tanks with capacities greater than 7,500 liters
(2,000 gallons) that store VOC with vapor pressures
greater than 28.0 kPa (4.1 psi) at 20°C; and,
(2) install pressure/vacuum conservation vents set at
±0.2 kPa on all storage tanks that store VOC with
vapor pressures greater than 10.0 kPa (1.5 psi)
at 20°C} unless a more effective control system
is used.
(d) The owner or operator of a synthesized pharmaceutical
facility subject to this regulation shall enclose all
centrifuges, rotary vacuum filters, and other filters
having an exposed liquid surface, where the liquid
contains VOC and exerts a total VOC vapor pressure of
3.50 kPa (0. 5 psi) or more at 20°C.
(e) The owner or operator of a synthesized pharmaceutical
facility siibject to this regulation shall install covers
on all in-process tanks containing a volatile organic
compound at any time. These covers must remain closed,
unless production, sampling, maintenance, or inspection
procedures require operator access.
(f) The owner or operator of a synthesized pharmaceutical
manufacturing facility subject to this regulation shall
repair all leaks from which a liquid, containing VOC,
can be observed running or dripping. The repair shall
be completed the first time the equipment is off-line
for a period of time long enough to complete the repair.
(g) For Petition for Alternative Controls Section: see
Discussion.
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DISCUSSION
The surface condenser temperature versus VOC vapor pressure method was
chosen by the authors of the OAQPS Guideline Series document, "Control of
Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical
Products," EPA-450/2-78-029, because condensers are widely used in the
pharmaceutical industry to recover evaporated solvent from process operations
and as air pollution control devices. The method is fairly simple to
implement on gas streams containing a single condensable VOC component with
a known vapor pressure. However, the calculation methods for gases containing
more than one condensable component are complex, particularly if the gases and
liquids significantly depart from ideal behavior. A simplified calculation
method is provided on page 4-6 of the guideline series document described
above.
Part (a)(2) of this section allows for alternative controls that
reduce VOC emissions at least as much as a surface condenser operating at
the appropriate gas outlet temperature. The guideline series document
gives a method for calculating the percent VOC condensed by a surface
condenser on pages 4-2 throug;h 4-6. An alternative control device can then
be designed to provide an equal or greater reduction efficiency.
Appendix B of the guideline series document provides a means of calculating
VOC emission rates assuming ideal gas behavior. Emission rates and total
emissions are needed to determine applicability of the regulation to specific
sources and to maintain an emission inventory. _, .
An issue to consider is; what emission limit applies when several
different sources,, each with a different VOC component, are manifolded to a
single control device. However, available information indicates that this
situation is not very likely to occur.
Capture systems are not considered to be a problem in the pharmaceutical
industry since most emission points have either completely sealed ductwork
or sealable closures available. Notable exceptions are older centrifuges
and filters. These are addressed in paragraph (d) of this section of the
regulation. Venting to a control device may be necessary if the vapors in
the enclosed centriiuges and filters exceed the LEL.
The 150 kg/day figure which appears in paragraph (b) of this section of
the regulation is based on an engineering judgment by the authors of the CTG
That is the limit below which it is economically infeasible to control VOC
emissions at a 90 percent emission reduction efficiency.
The controls required by paragraph (c) of this section of the regulation
are similar to those required for the storage of petroleum distillates and
should be interpreted in that context. Although floating roof tanks are widely
used in refineries and petrochemical plants, their applicability to pharma-
ceutical plant storage tanks is less certain. Floating root tanks should
not be required at this time.
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Even though this regulation allows a source some flexibility in choosing
a cost-effective control strategy, more economically advantageous control
strategies may be devised by the affected sources, if the Petition for Alterna-
tive Controls §XX.8060 in Appendix A is incorporated into this regulation.
Additional information on alternative controls and the "bubble concept" also
appear in the discussion section following §XX.8060.
65
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.9440 Compliance Schedules.
(a) The owner or operator of a synthesized pharmaceutical manufacturing
facility subject to this regulation must meet the applicable incre-
ments of progress contained in the following schedule.
(1) Submit final plans for the emission control systems
or process equipment, or both, before December 1, 1980;
(2) Award contracts or purchase orders for the emission
control systems or process equipment, or both,
before March 1, 1981;
(3) Initiate onsite construction or installation of
the emission control or process equipment, or both,
before June 1, 1981;
(4) Complete onsite construction or installation of
the emission control or process equipment, or
both, before June 1, 1982; and,
(5) Achieve final compliance, determined by accordance
with SXX.9450, before December 1, 1982.
(b) The owner or operator of a synthesized pharmaceutical
manufacturing facility subject to this regulation
may submit to the Director, and the Director may
approve, a proposed alternative compliance schedule
provided:
(1) the proposed alternative compliance schedule
is submitted before September 15, 1980;
(2) the owner or operator provides information
showing the need for an alternative schedule;
(3) the alternative compliance schedule contains
increments of progress;
(4) sufficient documentation and certification from
appropriate suppliers, contractors, manufacturers,
or fabricators is submitted by the owner or operator
of the synthesized pharmaceutical manufacturing
facility to justify the dates proposed for the
increments of progress; and
(5) final compliance is achieved as expeditiously
as possible and before the photochemical oxidant
attainment dar.e.
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(a) The owner or operator of a synthesized pharmaceutical
manufacturing facility subject to a compliance schedule
of this section shall certify to the Director within
5 days after the deadline for each increment of progress
whether the required increment of progress has been met.
DISCUSSION
The compliance schedules in this section follow the categorical
compliance schedules recommended in the memorandum from the Director of
Air Quality Planning and Standards, "Categorial Compliance Schedule for VOC
Sources," dated November 3, 1978. A 2-year schedule is recommended for add-
on control equipment and process changes requiring the purchase of equipment.
The compliance schedules presented here assume that July 1, 1980 is the effec-
tive date of the regulation.
A provision is included to allow the owner or operator of an affected
facility to submit an alternative compliance schedule. This should provide
additional flexibility to deal with specific circumstances. For example,
pharmaceutical firms may need to seek the approval of the Food and Drug
Administration for process changes. Compliance schedules should be flexible
enough to allow additional time for FDA approval. The final compliance
date for this part could conceivably be extended to the photochemical oxidant
attainment date. However, EPA states that "if such an alternative would impact
on the attainment or maintenance of any ambient standards, then approval of
the alternative compliance schedule as an SIP revision would be required."
Also, too many schedules extending to the attainment date might prevent a
state from showing reasonable further progress toward attainment.
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§XX. 9450 Testing and Monitoring.
(a) Upon the request of the Director, the owner or operator
of any volatile organic compound source required to
comply with this regulation shall, at his own expense,
demonstrate compliance by the methods of XX.9450 (c) or
an alternative method approved by the Director. All
tests shall be made by, or under the direction of, a
person qualified by training and/or experience in the
field of air pollution testing.
(b) A person proposing to conduct a volatile organic
compound emissions test shall notify the Director
of the intent to test not less than 30 days before
the proposed initiation of the tests so the Director
may at his option observe the test. The notification
shall contain the information required by, and in a
format approved by, the Director.
(c) Test procedures to determine compliance with this
regulation must be approved by the Director and
consistent with EPA Guideline Series document,
"Measurement of Volatile Organic Compounds, "
EPA-450/2-78-041.
(d) If add-on control equipment is used, continuous
monitors of the following parameters shall be
installed, periodically calibrated, and operated
at all times that the associated control equipment
is operating:
(1) exhaust gas temperature of all incinerators;
(2) temperature ri-se across a catalytic incinera-
tor bed;
(3) breakthrough of VOC on a carbon adsorption
unit; and,
(4) any other continuous monitoring or recording
device required by the Director.
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DISCUSSION
The results of the methods in the "Measurement of Volatile Organic
Compounds" document, EPA-450/2-78-041, are expressed as a mass concentration
of organic carbon. In order to convert these results to a percent reduction
by weight or to a mass rate of emission reduction several situations must be
considered.
In situations where only a single organic compound is being controlled,
the organic carbon weight is directly convertable to VOC weight by using the
molecular weight of the compound. In this case the percent reduction in mass
concentration of carbon across a control device is identical to the percent
reduction of VOC by weight.
In situations where a mixture of organic compounds enter a control device
and two assumptions can be made: (1) that the relative concentrations of the
compounds do not change across the control device (i.e., a specific compound is
not selectively absorbed or adsorbed) and (2) the relative concentrations of
compounds can be estimated from the conditions existing at the source of the VOC
emissions. Then a weighted average of the mass of carbon as a percent of
the total weight can be calculated and this factor can be used to calculate
the weight of VOC represented by the mass concentration of organic carbon.
In situations where a mixture of organic compounds enter a control
device and a mixture with different relative concentrations leaves the control
device, the mass concentration of carbon cannot be converted without additional
test methods. These methods must provide the relative concentrations of the
inlet and outlet mixtures of VOC. Once the relative concentrations are known
a factor can be calculated as in the above situation.
Additional test methods must also be used when measuring the emissions
from incinerators, because the organic carbon concentration test method
excludes CO and C02- Measurements of these compounds are necessary to
determine the percent conversion to C02 and H20.
Measurement of volumetric flow rate can be accomplished with EPA
Reference Methods 1 and 2, found in 40 CFR 60, Appendix A. The mass concentra-
tion multiplied by the volumetric flow rate will equal the mass flow rate of
VOC. Once the mass flow rate is known at the inlet and at the outlet of a
VOC emission control device, the percent reduction can be calculated. Two
potential problems remain: (1) Methods 1 and 2 cannot be performed on small
vents; and (2) the guideline series document, EPA-450/2-78-041, does not
rigorously define the sampling procedure.
State and local agencies developing a regulation for this source category
should give additional consideration to monitoring, recordkeeping and reporting
requirements. Sample regulatory language for the type of provision can be
found in §XX.8070 Monitoring, Recordkeeping and Reporting in Appendix A.
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SXX.9510 Definitions.
(a) For the purpose of this Regulation, the general definitions
apply.
(b) For the purpose of this Regulation, the following defintions
also apply:
(1) "Pneumatic Rubber Tire Manufacture" means the
production of pneumatic rubber, passenger type
tire on a mass production basis.
(2) "Passenger type tire" means agricultural, airplane,
industrial, mobile home, light and medium duty truck,
and passenger vehicle tires with a bead diameter up
to 20.0 inches and cross section dimension up to
12.8 ^nches.
(3) "Undertread cementing" means the application of
a solvent based cement to the underside of a
tire tread.
(4) "Bead dipping'1' means the dipping of an assembled
tire bead into a solvent based cement.
(5) "Tread End Cementing" means the application of a
solvent based cement to the tire tread ends.
(6) "Green tires" means assembled tires before molding
and curing have occurred.
(7) "Green Tire Spraying" means the spraying of green
tires, both inside and outside, with release compounds
which help remove air from the tire during molding
and prevent the tire from sticking to the mold
after curing.
(8) "Water Based Sprays" means release compounds, sprayed
on the inside and outside of green tires, in which
solids, water, and emulsifiers have 'been substituted
for organic solvents.
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DISCUSSION
Water-based sprays are presently available for green tire spraying. The
only volatile organic compounds which may be in a water-based spray are bacteri-
cides, corrosion inhibitors and solvent added to increase solubility of high
molecular weight compounds. These compounds normally amount to less than 5
percent by volume of the spray as applied.
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§11.5520 Applicability.
(a) This Regulation applies to VOC emissions from the
following operations in all pneumatic rubber tire
manufacturing facilities located in the
counties of :_
(1) Undertread cementing
(2) Tread end cementing
(2) Bead dipping
(4) Green tire spraying
(b) The provisions of this Regulation do not apply to the
production of specialty tires for antique or other
•vehicles when produced on an irregular basis or with
short production runs. This exemption applies only to
tires produced on equipment separate from normal produc-
tion lines for passenger type tires.
DISCUSSION
The CTG document discusses controls for pneumatic tire manufacturing that
are applicable to four specific operations in the overall process. A brief
rationale for recommending control for undertread cementing, tread end cement-
ing, bead dipping and green tire spraying operations and not for the other
operations is given below.
The undertread cementing operation is a portion of the rubber stock
processing operation in which the tread is tackified by the application of
a solvent-based cement. This process emits approximately 94 grams of VOC
per average tire. This represents about 36 percent of the total VOC
emissions from an average facility. The available controls are carbon absorp-
tion, which is already in place in at least one facility, and incineration,
which has been used in other rubber industries on gas streams with similar
types and concentrations of VOC.
Tread end cementing is an operation in which cement is either automatically
sprayed or manually applied to tread ends. The estimated VOC emissions are 15
gm per tire or about 6 percent of the total VOC emissions from an average
facility. The available controls are carbon adsorption or incineration, both
of which are in place in other industries on gas streams with similar types
and concentrations of VOC emissions.
Bead dipping is an operation in which the bead (the part of the tire
which adheres to the wheel rim), which is assembled in several layers, is
dipped into a solvent-based cement. This tackifies the rubber and ensures
proper adhesion when the bead is anchored into the sidewall. The estimated
VOC emissions are 8.2 gm per tire, or about 3 percent of the total VOC emissions
from an average facility. T'ne available controls are carbon adsorption or
74
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incineration, both of which are in place in industries with similar types and
concentrations of VOC emissions. It should be noted that the bead dipping
operation is not used at all pneumatic rubber tire manufacturing plants,
Green tire spraying is an operation which occurs after the tires have
been built and before they have been molded and cured. The operation consists
of spraying the inside and outside of the tire with release compounds which help
remove air from the tire during molding and prevent the tires from sticking
to the mold after curing. The average VOC emissions from this operation are
about 100 gm per tire or about 38 percent of the total VOC emissions from a
facility. The preferred control technique is conversion to water-based sprays.
Alternative control methods include carbon adsorption and incineration.
The following list of operations were not recommended for control by the
CTG primarily because of the lower emission factors for these operations. An
exception to this is the tire building operation which emits a significant
quantity of VOC. However, the tire building machines occupy about 25 percent
of a facility's floor space. Consequently, there are very large areas over
which the VOC's are emitted at very dilute concentrations. Controlling these
emissions is significantly less cost effective than the operations recommended
for control by the CTG.
List of Operations Not
Affected by the Control
Technique Guideline Recommendations
Operation
Tire building
Compounding
Milling
Tread and sidewall
gm VOC emitted/
average tire
33
1.0
0.6
0.6
preparation
Calendering 0.6
Molding and curing 2.0
Finishing 5.7
One source of VOC emissions which does not appear on this list is a latex
dipping operation. This operation is believed to be part of only two tire
manufacturing facilities in the United States and will be covered as an
affected facility under the textile manufacturing CTG.
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The applicability of the guideline will not be limited by the size of the
plant. Since the average plant produces 16,000 tires per day and emits an
estimated 1,000 metric ton/yr (1,100 ton/yr), it is assumed that all plants
which manufacture passenger type pneumatic rubber tires will be subject to
the regulation.
A facility manufacturing a part of a pneumatic passenger type rubber
tire employing one or more of the operations listed in subparagraph (a) is
covered by the regulation. An example of this type of facility is one manu-
facturing tire treads for the tire recapping industry. The actual recapping
operation would not be covered.
Paragraph (b) of this section provides an exemption for the production
of specialty tires on an irregular basis or with short production runs.
However, if these tires are made on equipment that is also used for the produc-
tion of passenger type tires, the VOC emissions from those operations are
still covered by this regulation.
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SXX.9530 Provisions for Specific Processes.
(a) The owner or operator of an undertread cement-ing,
tread end cementing, or bead dipping operation
subject to this regulation shall:
(1) Install and operate a capture system,
designed to achieve maximum reasonable
capture, up to 85 percent by weight
of VOC emitted, from all undertread
cementing, tread end cementing and
bead dipping operations. Maximum
reasonable capture shall be consistent
with the following documents:
(i) Industrial Ventilation, A Manual
of Recommended Practices, 14th
Edition, American Federation of
Industrial Hygienists.
(ii) Recommended Industrial Ventilation
Guidelines, U.S. Department of Health,
Education and Welfare, National
Institute of Occupational Safety and
Health.
(2) Install and operate a control device that meets
the requirements of one of the following:
(i) A carbon adsorption system designed
and operated in a manner such that
there is at least a 95. 0 percent removal
of VOC by weight from the gases ducted
to the control device; or,
(ii) An incineration system that oxidizes at
least 90.0 percent of the nonmethane volatile
organic compounds (VOC measured as total
combustible carbon) which enter the
incinerator to carbon dioxide and water.
(iii) An alternative volatile organic compound
emission reduction system certified by the
owner or operator to have at least a 90.0
percent reduction efficiency, measured across
the control system, and has been approved
by the Director.
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(b) 'The owner or operator of a green tire spraying operation
subject to this regulation must implement one of the
following means of reducing volatile organic compound
emissions:
(1) Substitute water-based sprays for the normal
solvent-based mold release compound; or,
(2) (i) Install a capture system designed and
operated in a manner that will capture
and transfer at least 90,0 percent of the
VOC emitted by the green tire spraying
operation to a control device; and,
(ii) In addition to part (i), install and
operate a control device that meets
the requirements of one of the
following:
(A) A carbon adsorption system
designed and operated in a
manner such that there is at
least 95.0 percent removal of
VCC by weight from the gases
ducted to the control device; or,
(B) AY, incineration system that oxidizes
at least 90.0 percent of the nonmethane
volatile organic compounds (VOC measured
as total combustible carbon) to carbon
dioxide and water; or
(C) An alternative volatile organic compound
emission reduction system certified by the
owner or operator to have at least a 90.0
percent reduction efficiency, measured
across the control system, that has been
approved by the Director.
(c) An owner or operator of an undertread cementing, tread end
cementing, bead dipping or green tire spraying operation
subject to this regulation may, instead of implementing
measures required by subparagraph (a) and (b) above,
submit to the Director a petition for alternative con-
trols. The petition must be submitted in writing before
September 15, 1980 and must contain:
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(1) the name and address of the company and the name and
telephone number of a responsible company representative
over whose signature the petition is submitted;
(2) a description of all operations conducted at the
location to which the petition applies and the
purpose the volatile organic compound emitting
equipment serves within the operations;
(S) reference to the specific emission limits, operational
and/or equipment controls for which alternative
emission limits, operational and/or equipment controls
are proposed;
(4) a detailed description of the proposed alternative
emission limits, operational and/or equipment
controls, the magnitude of volatile organic compound
emission reduction which will be achieved, and the
quantity and composition of volatile organic com-
pounds which will be emitted if the alternative
emission limits, operational and/or equipment controls
are instituted;
(5) a schedule for the installation and/or institution
of the alternative operational and/or equipment
controls in conformance with the appropriate com-
pliance schedule section;
(6) a demonstration that the alternative control
program constitutes reasonably available control
technology for the petitioned facility. The factors
to be presented in this demonstration include but are
not limited to:
(i) the capital expenditure necessary to achieve
the petitioned level of control;
(ii) the impact of these costs on the firm;
(Hi) the energy requirements of the petitioned
level of control;
(iv) the impact on the environment in terms of
any increase in air, water and solid waste
effluent discharge of the petitioned level
of control;
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(v) any adverse worker or product safety
implications of the petitioned level of
control;
(vi) an analysis for each of the factors in (i)
through (v) above for the control levels
specifisd in paragraphs (a) and (b) of this
section.
(d) The Director may approve a Petition for Alternative
Control if:
(1) the petition is submitted in accordance with
paragraph (c) of this section;
(2) the petition demonstrates that the alternative
controls represent reasonable available control
technology;
(S) the petition contains a compliance schedule for
achieving and maintaining a reduction of volatile
organic compound emissions as expeditiously as
practicable, but no later than the photochemical
oxidant attainment date.
(e) No alternative control plan is effective until it is
submitted to and approved by the Administrator of the
United States Environmental Protection Agency as a
revision of the State Implementation Plan pursuant
to Section 110(a)(3)(A) of the Clean Air Act,
DISCUSSION
This sample regulation is based on the CTG's "presumptive norm" for
reasonably available control technology for specific processes covered by the
CTG. The CTG's recommended controls, of necessity, were based on an evaluation
of the industry as j. whole. Therefore, the sample regulation not only sets
forth the controls recommended in the CTG, but also specifically provides for
case by case determination of RACT. The alternative control option lists those
factors which should be considered in determining RACT for a particular source.
These factors include capital expenditures, cost impacts, energy requirements,
environmental impacts, and worker or product safety impacts. The use of an
alternative control option also recognizes that the cooperation of sources is
required in making case by case evaluation. The State may wish to make these
evaluations and adopt source specific rather than a generic regulation.
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There are several problems with determining a minimum capture efficiency
for undertread cementing, tread end cementing and bead dipping equipment and
operations. The design and layout of the equipment varies considerably from
plant to plant, operator accessibility must be provided to certain areas of
the equipment, and it may not be practical to completely hood long conveyors.
Therefore, instead of setting a minimum capture efficiency, the sample regula-
tion requires the determination of the maximum reasonable capture using 85
percent capture efficiency as a goal. The owner or operator of a source of
VOC is urged to make every reasonable effort to meet the 85 percent capture
efficiency. The referenced documents generally give ranges within which
specific design parameters fall. If a capture system is not designed to achieve
85 percent capture, then the owner or operator should choose the value within
the range which will result in a maximum capture efficiency, considering the
physical limitations of the specific situation. As noted in the CTG, percent
capture efficiency should be determined on an individual plant basis,
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SXX.9540 Compliance Schedules.
(a} The owner or operator of a pneumatic rubber tire
manufacturing plant with operations subject to this
regulation shall meet the applicable increments of
progress contained in the following schedules:
(1) For process equipment changes, low solvent
technology and add-on control devices,
incineration with heat recovery:
(i) Submit final plans for the emission
control system or process equipment,
or both, before October 15, 1980;
(ii) Award contracts or purchase orders for
the emission control system or process
equipment, or both, before December 15, 1980;
(iii) Initiate onsite construction or installation
of the emission control device or process
equipment, or both, before May 1, 1981;
(iv) Complete onsite construction or installation
of the emission control device or process
equipment, or both, before May 1, 1982;
and,
(v) Achieve final compliance, determined in
accordance with § XX.9550, before
July I, 1982.
(2) For incineration without heat recovery and substitution
of water-based spray in the green tire spraying operation:
(i) Submit final plans for incineration equipment
or water-based spray substitution, or both,
before September 15, 1980;
(ii) Award all contracts or purchase orders for
incineration equipment or water-based spray
substitution, or both, before November 15, 1980;
(iii) Initiate onsite construction or installation
of incineration equipment or water-based spray
modifications before January 15, 1980;
(iv) Complete onsite construction or installation
of incineration equipment or water-based spray
modifications before May 15, 1981; and,
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(v) Achieve final compliance, determined in
accordance with §XX.9550 , before
July 1, 2981.
(b) The owner or operator of a pneumatic rubber tire
manufacturing plant with operations subject to this
regulation may submit to the Director, and the
Director may approve, a proposed alternative
compliance schedule provided:
(1) The proposed alternative compliance schedule
is submitted before September 15, 1980;
(2) The owner or operator provides information
showing the need for an alternative schedule;
(3) The alternative compliance schedule contains
increments of progress;
(4) Sufficient documentation and certification from
appropriate suppliers, contractors, manufacturers,
or fabricators is submitted by the owner or operator
of the volatile organic compound source to justify
the dates proposed for the increments of progress;
and,
(5) Final compliance is achieved as expeditiously as
possible and before the photochemical oxidant
attainment date.
(a) The owner or operator of a pneumatic rubber tire
manufacturing plant with operations subject to a
compliance schedule of this section shall certify
to the Director within 5 days after the deadline
for each increment of progress, whether the required
increment of progress has been met.
DISCUSSION
The compliance schedules in this section follow the categorical compliance
schedules recommended in the memorandum from the Director of Air Quality Planning
and Standards, "Categorical Compliance Schedule for VOC Sources," dated
November 3, 1978. A 2-year schedule is recommended for add-on control equipment
and process changes requiring the purchase of equipment, except for incineration
systems without heat recovery. A 1-year schedule is recommended for installation
of incineration systems without heat recovery, or process modifications not
requiring the purchase of equipment. The compliance schedules presented here
assume that July 1, 1980 is the effective date of the regulation.
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A provision is included to allow the owner or operator of an affected
facility to submit an alternative compliance schedule. The final compliance
date for this part could conceivably be extended to the photochemical oxidant
attainment date. However, EPA states that "if such an alternative would impact
on the attainment or maintenance of any ambient standards, then approval of
the alternative schedule as an SIP revision would be required." Also, too
many schedules extending to the attainment date might prevent a state from
showing reasonable further progress toward attainment.
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SLOT.9550 Testing and Monitoring.
(a) Upon request of the Director, the owner or operator of
a volatile organic compound source required to comply
with this regulation shall, at his own expense, demonstrate
compliance by the methods of part (c) of this section,
or an alternative method approved by the Director. All
tests shall be made by, or under the direction of, a
person qualified by training and/or experience in the
field of air pollution testing.
(b) A person proposing to conduct a volatile organic compound
emissions test shall notify the Director of the intent to
test not less than 30 days before the proposed initiation
of the iests so the Director may at his option observe
the test. The notification shall contain the information
required by, and be in a format approved by, the Director.
(c) (1) Test procedures to determine compliance with this
regulation must be approved by the Director and
be consistent with:
(i) EPA Guideline Series document, "Measurement
of Volatile Organic Compounds," EPA-450/2-78-
041; and,
(ii) Appendix A of "Control of Volatile Organic
Emissions from Existing Stationary Sources -
Volume II: Surface Coating of Cans, Coils,
Paper, Fabrics, Automobiles, and Light-Duty
Trucks, " EPA-450/2-77-008.
(2) The Director may accept, instead of green tire spray
analysis, a certification by the manufacturer of
the composition of the green tire spray, if supported
by actual batch formulation records.
(d) If add-on control equipment is used, continuous monitors
of the following parameters shall be installed, periodically
calibrated, and operated at all times that the associated
control equipment is operating:
(1) exhaust gas temperatures of incinerators;
(2) temperature rise across a catalytic
incinerator bed;
(3) breakthrough of VOC on a carbon adsorption
unit; and,
(4) any other continuous monitoring or recording
device required by the Director.
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DISfcUSSION
Conversion of Organic Carbon to VOC: The results of the methods in
the Measurement of Volatile Organic Compounds document, EPA-450/2-78-041, are
expressed as a mass concentration of organic carbon. In order to convert these
results to a percent reduction by weight or to a mass rate of emission reduc-
tion several situations must be considered.
In situations where only a single organic compound is being controlled,
the organic carbon weight is directly convertible to VOC weight by using the
molecular weight of the compound. In this case the percent reduction in mass
concentration of carbon across a control device is identical to the percent
reduction of VOC by weight.
In many situations a mixture of organic compounds enter a control device.
If two assumptions can be made: (1) that the relative concentrations of the
compounds do not change across the control device (i.e., a specific compound
is not selectively absorbed or absorbed); and, (2) the relative concentrations
of compounds can be estimated from the conditions existing at the source of
the VOC emissions, then a weighted average of the mass of carbon as a percent
of the total weight can be calculated. This factor can be used to calculate
the weight of VOC represented by the mass concentration of organic carbon.
In situations where a mixture of organic compounds enter a control device
and a mixture with different relative concentrations leaves the control device,
the mass concentration of carbon cannot be converted without additional test
methods. These methods must provide the relative concentrations of the inlet
and the outlet mixtures of VOC. Once the relative concentrations are known a
factor can be calculated as in the above situation.
Additional test methods must also be used when measuring the emissions
from incinerators, because the organic carbon concentration test method excludes
CO and C02> Measurements of these compounds are needed to determine the per-
cent conversion to C02 and F^O.
Add-on control equipment: For undertread cementing, tread and cementing,
and bead dipping, the uncontrolled VOC mass emission rate can be calculated
from the composition of the cement and the rate of cement usage. Some proce-
dure must be devised which includes the number of runs required and the time
limit for each run for determining an average rate of cement usage. This is a
weak point in the test procedure, since an "average rate of cement usage" is
not defined.
The mass rate of VOC emission reduction by the emission control device
can be calculated by a combination of measuring the VOC mass concentration
(consistent with the procedures in EPA-450/2-78-041) in the entrance and exit
air streams along with the air flow measurements. Measurement of volumetric
flow rate can be accomplished with EPA Reference Methods 1 and 2, found in
40 CFR 60, Appendix A. The mass concentration multiplied by the volumetric
flow rate will equal the mass flow rate of VOC. Once the mass flow rate is
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known at the inlet and at the outlet df a VOC emission control device, the
percent reduction can be calculated. Two potential problems remain, Methods
1 and 2 cannot be performed on small vents and the guideline series document,
EPA-450/2-78-041, does not rigorously define the sampling procedure.
Determination of the VOC content of green tire sprays may be accomplished
with procedures similar to those referenced in part (c) (1).
The CTG recommends some monitoring instruments that should be required
where incineration is employed in order to aid the regulatory agency when
performing spot checks. All incinerators should be equipped with temperature
indicators in the combustion chamber. Recorders should be required for larger
installations. The temperature rise across the catalyst bed should be monitored
continuously for catalytic incinerators and carbon adsorption bed breakthrough
should be monitored on carbon adsorption units.
State and local agencies developing a regulation for this source category
should give additional consideration to monitoring, recordkeeping and reporting
requirements. Sample regulatory language for this type of provision can be
found in §XX.8070 Monitoring, Recordkeeping and Reporting in Appendix A.
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SXX.9610 Definitions.
(a) For the purpose of this Regulation, the general definitions
apply.
(b) For the purpose of r,his Regulation, the following definitions
also apply:
(1) "Packaging rotogravure printing" means rotogravure
printing upon paper, paper board, metal foil, plastic
film, and other substrates, which are, in subsequent
operations, formed into packaging products and labels
for articles to be sold.
(2) "Publication rotogravure printing" means rotogravure
printing upon paper which is subsequently formed
into books, magazines, catalogues, brochures,
directories, newspaper supplements, and other types of
printed materials.
(3) "Flexographic Printing" means the application of
words, designs and pictures to a substrate by
means of a TO II printing technique in which the
pattern to be applied is raised above the printing
roll and the image carrier is made of rubber or other
elastomeric materials.
(4) "Rotogravure printing" means the application of
words, designs, and pictures to a substrate by means
of a roll printing technique which involves an
intaglio or r&cessed image areas in the form of cells.
(5) "Roll printing" means the application of words,
designs and pictures to a substrate usually by means
of a series of hard rubber or steel rolls each with
only partial coverage.
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XX. 9620 Applicability.
(a) This Regulation applies to all packaging rotogravure,
publication rotogravure, and flexographic printing
facilities located in the following counties:
(b) This Regulation applies to all facilities whose potential
emissions of volatile organic compounds are equal to or more
than 90 megagrams (10& grams) per year (100 ton/yr). Potential
emissions are to be calculated based on historical records of
actual consumption of solvent and ink.
DISCUSSION
This regulation is applicable to both flexographic and rotogravure processes
as applied to both publication and packaging printing. It does not apply to
offset lithography or letterpress printing since these processes do not nor-
mally use volatile organic compounds.
Those machines which have both coating units (application of a uniform
layer of material across the entire width of a web) and printing units (forma-
tion of words, designs and pictures) should be considered as performing a
printing operation. This approach is consistent with the "Clarification of
Paper Coating Definition for VOC Sources" memorandum by the Director of the
Control Programs Development Division, OAQPS, dated November 1978.
The 100 TPY size limitation is based on the|following information from
an EPA study on the Flexible Packaging Industry." The study states that the
bulk of the emissions from the flexographic printing industry are produced
by large facilities, each emitting more than 1000 TPY of volatile organic
compounds. This study does not include the publication rotogravure industry,
but these numbers are considered representative of the industries addressed in
this regulation since most publication rotogravure facilities also emit in
excess of 1,000 TPY.
Facilities with Percent of total
total VOC emissions less than industry VOC emissions
50 TPY <1.0
125 TPY <2.7
250 TPY <7.6
*
Draft Overview Assessment of Organic Emissions of the Flexible Packaging
Industry, EPA Contract No. 68-03-2580.
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Operating schedules for printing machines vary considerably, making usual
potential emissions calculations difficult. Calculations based on actual
consumption of solvent and ink should include both the solvent used for dilu-
tion of ink and for equipment cleanup.
In some cases waste solvent and dirty cleaning solvent will be collected
and disposed of in a manner which prevents its evaporation to the atmosphere.
Unless specifically documented, it should be assumed that all other solvent
used evaporates into the atmosphere.
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SXX.9630 Provisions for Specific Processes.
(a) No owner or operator of a packaging rotogravure, publication
rotogravure or flexographic printing facility subject to this
regulation and employing solvent containing ink may operate,
cause, allow or permit the operation of the facility unless:
(2) The volatile fraction of ink, as it is applied to the
substrate, contains 25.0 percent by volume or less of
organic solvent and 75.0 percent by volume or more of
water;
(2) The ink as it is applied to the substrate, less water,
contains 60.0 percent by volume or more nonvolatile
material; or,
(Z) The owner or operator installs and operates;
(i) A carbon adsorption system which reduces
the volatile organic emissions from the
capture system by at least 90.0 percent
by weight;
(ii) An incineration system which oxidizes at
least 90.0 percent of the nonmethane volatile
organic compounds (VOC measured as total
combustible carbon) to carbon dioxide and
water; or,
(Hi) An alternative volatile organic compound emission
reduction system demonstrated to have at least a
90.0 percent reduction efficiency, measured
across the control system, and has been approved
by the Director.
(b) A capture system must be used in conjunction with the emission
control systems in part (a)(3). The design and operation of
a capture system must be consistent with good engineering
practice, and shall be required to provide for an overall
reduction in volatile organic compound emissions of at
least:
(1) 75.0 percent where a publication rotogravure process
is employed;
(2) 65.0 percent where a packaging rotogravure process is
employed; or,
(3) 60. 0 percent where a flexographic printing process is
employed.
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(o) FOP Petition for Alternative Controls Section: see
Discussion.
DISCUSSION
There are three general methods of limiting VOC emissions from rotogravure
and flexographic printing processes.
The first method is water-borne ink which requires that the volatile
portion of the ink contain 25 percent by volume or less VOC. An example of
an ink meeting this requirement is one that contains 20 percent solids, 20
percent organic solvent and 60 percent water, after it has been diluted for use
in the printing machines. The organic solvent and water constitute the volatile
portion of the ink. The water and solvent exist in a 3 to 1 ratio or 75
percent water and 25 percent VOC.
The second method is high solids technology which is primarily experimental
at this time, but which could provide emission reductions comparable to the
existing technology. This method of reducing VOC emissions is included at the
request of the printing industry.
The third method is add-on control which is generally available technology
for this industry. The reductions in VOC across the control equipment are the
same as for other industries. However, capture efficiencies pose somewhat of
a problem. The printing and drying equipment often cannot be tightly hooded
and efforts to achieve high capture efficiencies may result in large volumes
of captured gases with dilute concentrations of VOC. This of course results
in extremely large and costly control equipment. The overall reduction effi-
ciencies in §XX.9630(b) are meant to be target reduction efficiencies. A
careful review of the final plans submitted to the state or local agency must
be conducted to insure that the capture system provides an optimal capture
efficiency. The following list is based on the Summary of Applicability of
Control Methods, pages 3-9 through 3-10 of the Graphic Art CTG document,
EPA-450/2-78-033.
Process Capture efficiency (percent)
Publication Rotogravure 75 - 85
Packaging Rotogravure 70 - 80
Flexography 65 - 70
94
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Many of the present solvent mixtures were developed to comply with
Rule 66 of Los Angeles County and similar legislation. Because of EPA's 1977
policy statement on reactivity, it may be possible to revert to solvent
mixtures used prior to Rule 66 type regulations. Many printers will be able
to revert to a mixture of immiscible hydrocarbons and a single ester or MEK,
which could be reused after dewatering. It will be practical for many
packaging type printers to solve a large percentage of their emission control
requirements by the use of carbon adsorption and relatively simple dewatering
techniques. The owner or operator of a graphic arts VOC emission source
should be given the opportunity to change the type of ink which is used before
designing the carbon adsorption system or incinerator for the capture or
destruction of the solvent emission.
Paragraph (c) of this section of the regulation is included to allow
the bubble concept or internal offsets to be applied. A detailed discussion
appears after XX.8060 in General Provisions, Appendix A.
Question: Does this regulation apply to VOC emissions
from the application of coatings, varnishes
and/or adhesives?
Answer: The printing regulation does not apply, unless
the application of coatings, varnishes and/or
adhesives is done on the same machine or in
the same operation as the printing. In this
case these emissions cannot practically be
separated from the printing emissions and all
emissions would be included in the overall
emission reduction required by §XX.9630(b).
Except for this case, VOC emissions from the
application of coatings, varnishes, and/or
adhesives are not intended to be covered by
this regulation. However, these emissions may
by subject to previous coating regulations, such
as the paper coating regulation.
Even though this regulation allows a source some flexibility in choosing
a cost-effective control strategy, more economically advantageous control
strategies may be devised by the affected sources, if the Petition for Alter-
native Controls §XX.8060 in Appendix A is incorporated into this regulation.
Additional information on alternative controls and the "bubble concept" also
appear in the discussion section following §XX.8060.
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SXX.9640 Compliance Schedules.
(a) 'She owner or operator of a packaging rotogravure, publication
rotogravure or fleaographlc printing facility subject to
this regulation must meet the increments of progress in
the following schedules.
(1) For process equipment changes, and add-on control
devices, including Incineration with heat recovery:
(I) Submit final plans for the emission control
system or process equipment, or both, before
October IS, 1980;
(II) Award contracts or purchase orders for the
emission control system or process equipment,
or both, before December 15, 1980;
(III) Initiate onslte construction or Installation
of the emission control or process equipment,
or both, before June 1, 1981;
(iv) Complete onslte construction or Installation
of the emission control or process equipment,
or both, before June 1, 1982; and,
(v) Achieve final compliance, determined In
accordance with SXX.9650, before
July 1., 1982.
(2) For Incineration equipment without ~heat recovery or
process modifications not requiring purchase orders:
(1) Submit final plans for the emission control
systen, or process modifications, or both,
before September 15, 1980;
(ii) Award contracts for process modifications
or for incineration equipment, or both,
before November 1, 1980;
(ill) Initiate onslte construction or Installation
of process modifications or emission control
equipment, or both, before January 15, 1981;
(iv) Complete onslte construction or Installation
of process modifications or Incineration
equipment, or both, before May 15, 1981; and
(v) Achieve final compliance, determined In accordance
with 5XX.9650, before July 1, 1981.
(2) For low solvent technology: (see discussion)
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(b) The owner or operator of a packaging rotogravure, publication
rotogravure or flexographic printing facility subject to this
regulation may submit to the Director, and the Director may
approve, a proposed alternative compliance schedule provided:
(1) The proposed alternative compliance schedule is
submitted before September 15, 2980;
(2) The owner or operator provides information
showing the need for an alternative schedule;
(3) The alternative compliance schedule contains
increments of progress;
(4) Sufficient documentation and certification from
appropriate suppliers, contractors, manufacturers,
or fabricators is submitted by the owner or operator
of the subject facility to justify the dates
proposed for the increments of progress • and
(5) Final compliance is achieved as expeditiously as
possible but no later than the photochemical oxidant
attainment date.
(c) The owner or operator of a volatile organic compound
source subject to a compliance schedule of this section
shall certify to the Director within 5 days after the
deadline for each increment of progress, whether the
required increment of progress has been met.
DISCUSSION
According to the EPA memorandum of November 3, 1978, on "Categorical
Compliance Schedules for VOC Sources," a 2-year compliance schedule is recom-
mended for carbon adsorption, incineration with heat recovery, and low-solvent
technology. A 1-year compliance schedule is recommended for incineration
withort heat recovery. Assuming July 1, 1980 as the effective day of the
regulation, the following progress increments would be required:
Compliance date
_ T Carbon adsorption,
Progress increment Incineration , .. . ,
low-solvent technology
1. Control Plan Submitted September 15, 1980 October 15, 1980
2. Contract Award November 1, 1980 December 15, 1980
3. Initiation of Construction January 15, 1981 June 1, 1981
4. Construction Completed May 15, 1981 June 1, 1982
5. Final Compliance July 1, 1981 July 1, 1982
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For certain applications, low solvent technology (LSI) can be applied
in an expeditious manner according to the Flexible Packaging Association,
Gravure Technical Institute and other industry representatives who commented
on the draft of this document. They also indicated that LST can result in
greater emission reduction than incineration or carbon adsorption. However,
sufficient time is needed to allow for the development of water borne or high
solids inks. Accordingly, the Flexible Packaging Association is preparing a
series of alternative compliance programs to allow for the development of low
solvent inks for certain applications. We anticipate that this program will
be presented to EPA and affected states in the coming months. Since EPA has
not had an opportunity to review and comment on these proposals and since one
is expected in the next few weeks, it is not appropriate to include a schedule
at this time. Additional information will be provided at a later date.
A paragraph for Alternative Compliance Schedules is included. The owner
or operator of the emission source should be allowed to submit a proposed
alternative schedule to the Director for review as long as it is presented
before September 15, 1980 and it is properly documented. The Director must be
able to approve a separate schedule for any source if he finds that compliance
with paragraphs (a)(l) or (2) is not feasible.
EPA states, however, that "if such an alternative compliance schedule
would impact on attainment or maintenance of any ambient standards, then
approval of the alternative compliance schedule as a SIP revision would be
required...Too many alternative schedules extending until December 31, 1982,
might also prevent, a state from showing reasonable further progress toward
attainment..."
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§JZ.9850 Testing and Monitoring.
(a) Upon request of the Director, the owner or operator
of a volatile organic compound source shall, at his
own expense, demonstrate compliance by the methods of
part (a) of this section_ or an alternative method
approved by the Director. All tests shall be made
by, or under the direction of, a person qualified by
training and/or experience in the field of air
pollution testing.
(b) A person proposing to conduct a volatile organic compound
emissions test to demonstrate compliance with this regulation
shall notify the Director of the intent to test not less
than 30 days before the proposed initiation of the tests
so the Director may at his option observe the test. The
notification shall contain the information required by,
and be in a format approved by, the Director.
(c) (1) Test procedures to determine compliance with
%XX.9630 must be approved by the Director and
consistent with:
(i) EPA Guideline Series document, "Measurement
of Volatile Organic Compounds," EPA-450/2-78-042;
and
(ii) Appendix A of "Control Volatile Organic Emissions
from Existing Stationary Sources - Volume II:
Surface Coating of Cans, Coils, Paper, Fabrics,
Automobiles, and Light-Duty Trucks, " EPA-450/2-77-008.
(2) The Director may accept, instead of ink solvent analysis,
a certification by the ink manufacturer of the composition
of the ink solvent, if supported by actual batch formulation
records.
(d) If add-on control equipment is used, continuous monitors
of the following parameters shall be installed, periodically
calibrated, and operated at all times that the associated
control equipment is operating:
(1) exhaust gas temperature of all incinerators-
(2) temperature rise across a catalytic incinera-
tor bed;
(3) breakthrough of VOC on a carbon adsorption unit;
and,
(4) any other continuous monitoring or recording device
required by the Director.
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DISCUSSION
Water-borne Technology: Where the owner or operator of a graphic arts
process chooses water-borne technology to reduce emissions, a verification
of the composition of the ink must be made by the regulatory agency. In
order to qualify, the volatile fraction of the ink must contain, 25 percent
by volume or less of organic solvent and 75 percent by volume or more of
water.
High Solids Technology: Where the owner or operator of a facility
subject to this regulation chooses high solids technology, a verification
of the composition of the ink must be made by the regulatory agency. In
order to qualify the ink must, contain 60 percent or more nonvolatile
compounds by volume.
Conversion of ^rganic Carbon to VOC: The results of the methods in the
Measurement of Volatile Organic Compounds document EPA-450/2-78-041, are
expressed as a mass concentration of organic carbon. In order to convert these
results to a percent reduction by weight or to a mass rate of emission reduction
several situations must be considered.
In situations where only a single organic compound is being controlled,
the organic carbon weight is directly convertable to VOC weight by using the
molecular weight of the compound. In this case the percent reduction in mass
concentration of carbon across a control device is identical to the percent
reduction of VOC by weight.
In situations where a mixture of organic compounds enter a control
device and two assumptions can be made; (1) that the relative concentrations
of the compounds do not change across the control device (i.e., a specific
compound is not selectively absorbed or adsorbed); and (2) the relative concen-
trations of compounds can be estimated from the conditions existing at the
source of the VOC emissions. Then a weighted average of the mass of carbon as
a percent of the total weight can be calculated and can be used to calculate the
weight of VOC represented by the mass concentration of organic carbon.
In situations /here a mixture of organic compounds enter a control
device and a mixture with different relative concentrations leaves the
control device, the mass concentration of carbon cannot be converted without
additional test methods, "hese methods must provide the relative concentra-
tions of the inlet and outlet mixtures of VOC. Once the relative concentra-
tions are known a factor can be calculated as in the above situation.
Additional test methods must also be used when measuring the emissions
from incinerators, because the organic carbon concentration test method
excludes CO and C02- Measurements of these compounds are needed to determine
the percent conversion to C02 and
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Add-on control equipment: The regulation recommended by the authors
of the CTG is based on "overall emission reduction efficiency" factors. In
order to calculate these factors, the uncontrolled VOC mass emission rate
and the mass rate of removal must be calculated.
The uncontrolled VOC mass emission rate can be calculated from the
composition of the ink and the rate of ink usage. Some procedure must be
devised which includes the number of runs required and the time limit for
each run for determining an average rate of ink usage. This is the weak
point in the test procedure, since an "average rate of ink usage" is not
defined.
The mass rate of VOC emission reduction by the emission control device
can be calculated by a combination of measuring the VOC mass concentration
(consistent with the procedures in the Guideline Series document) in the
entrance and exit lir streams along with the air flow measurements.
The "overall emission reduction efficiency" can then be calculated by:
mass rate of VOC emission reduction
uncontrolled mass emission rate
x 100 percent
The CTG recommends some monitoring instruments that should be required
where incineration is employed in order to aid the regulatory agency when
performing spot checks. All incinerators should be equipped with temperature
indicators in the combustion chamber. Recorders should be required for larger
installations. The temperature rise across the catalyst bed should be monitored
continuously for catalytic incinerators and carbon adsorption bed breakthrough
should be monitored on carbon adsorption units.
State and local agencies developing a regulation for this source category
should give additional consideration to monitoring, recordkeeping and report-
ing requirements. Sample regulatory language for this type of provision can
be found in §XX.8070 Monitoring, Recordkeeping and Reporting in Appendix A.
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SXX.9710 Definitions.
(a) For the purpose of this Regulation, the general definitions
apply.
(b) For the purpose of this Regulation, the following definitions
also apply:
(1) "Condensate" means hydrocarbon liquid separated from
natural gas which condenses due to changes in the
temperature and/or pressure and remains liquid at
standard conditions.
(2) "Crude oil" means a naturally occurring mixture which
consists of hydrocarbons and sulfur, nitrogen and/or
oxygen derivatives of hydrocarbons which is a liquid
at standard conditions.
(3) "Lease custody transfer" means the transfer of
produced crude oil and/or condensate, after processing
and/or treating in the producing operations, from
storage tanks or automatic transfer facilities to
pipelines or any other forms of transportation.
(4) "External floating roof" means a storage vessel
cover in an open top tank consisting of a double
deck or pontoon single deck which rests upon and
is supported by the petroleum liquid being
contained and is equipped with a closure seal
or seals to close the space between the roof edge
and tank wall.
(5) "Liquid-mounted seal" means a primary seal mounted in con-
tinuous contact with the liquid between the tank wall and
the floating roof around the circumference of the tank.
(6) "Petroleum liquids" mean crude oil, condensate,
and c ly finished or intermediate products manufactured
or extracted in a petroleum refinery.
(7) "Vapor-mounted seal" means a primary seal mounted so
there is an annular vapor space underneath the seal.
The annular vapor space is bounded by the bottom
of the primary seal, the tank wall, the liquid
surface, and the floating roof.
(8) "Waxy, heavy pour crude oil" means a crude oil with
a pour point of 50 F or higher as determined by the
American Society for Testing and Materials Standard
D97-66, "Test for Pour Point cf Petroleum Oils."
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5XX.9720 Applicability.
(a) This Regulation applies to all petroleum liquid storage
vessels equipped with external floating roofs, having
capacities greater than 150,, 000 liters (40,000 gal),
that are located in the following counties:
(b) This Regulation does not apply to petroleum liquid storage
vessels which:
(1) are used to store waxy, heavy pour crude oil;
(2) have capacities less than 1,600,000 liters (420,000
gal) and are used to store produced crude oil and
condensate prior to lease custody transfer;
(3) contain a petroleum liquid with a true vapor
pressure of less than 10.5 kPa (1.5 psia);
(4) contain a petroleum liquid with a true vapor
pressure less than 27.6 kPa (4.0 psia); and,
(i) are of welded construction; and,
(ii) presently possess a metallic-type shoe
seal, a liquid-mounted foam seal, a
liquid-mounted liquid filled type seal,
or other closure device of demonstrated
equivalance approved by the Director; or,
(5) are of welded construction, equipped with a metallic-
type shoe primary seal and has a secondary seal from
the top of the shoe seal to the tank wall (shoe-
mounted secondary seal).
DISCUSSION
It should be noted that storage vessels containing petroleum liquids
with a true vapor pressure of less than 10.5 kPa (1.5 psi) are not included
in this applicability statement. However, in paragraph iXX.9730 (c) the
owner or operator must maintain records for petroleum liquids with a true
vapor pressure of greater than 7.0 kPa (1.0 psi). This is done to insure that
records are kept of marginal exemptions on a continuing basis.
Some disucssion of the exemptions in part (b) of this section of the
regulation is necessary. The CTG suggests that an exemption be given to "waxy,
heavy pour crudes." This is due to the fact that "these crudes cause a deposit
on the tank wall which is scraped onto the roof when the tank is worked,
damaging the secondary seal."
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If the vessel is of riveted construction and not used for lease custody
transfer, the only exemption is for size (less than 150,000 liters) and true
vapor pressure (less than 10.5 kPa). If the vessel is of welded construction
(and, also not used for lease custody transfer), the size exemption ia still
150,000 liter but the vapor pressure exemption becomes a function of the
existing primary seal type. If the seal is a metallic-type shoe, liquid-
mounted foam, liquid-mounted liquid filled, or equivalent, the minimum vapor
pressure for exemption rises to 27.6 kPa (4.0 psia). An expected result of
this variable vapor pressure requirement will be attempts by owners of tanks
with primary seals that cannot be conclusively included in the three categories
exempted at 4.0 psia to demonstrate equivalence to the Director. If they
cannot demonstrate equivalence they are then subjected to a stricter regulation.
The state agencies must understand the criteria of equivalency. The key
criteria is that the seal must be either shoe-type or liquid mounted (i.e.,
the seal is in contact with the surface of the contained liquid). If the seal
is of any of the vapor-mounted types, it should be subject to the 1.5 psia
vapor pressure exemption.
An exemption is provided for petroleum liquid storage vessels which
are of welded construction, which have a metallic-type shoe primary seal, and
which have a secondary seal from the top of the shoe seal to the tank wall
(shoe-mounted secondary seal).
Tanks less than 420,000 gallons used to store crude oil prior to lease
custody transfer (oil field production storage) are exempted also. These
tanks are generally of a fixed roof type and bolted construction to enable
them to be moved as needed. As fixed roof tanks are not covered by this
regulation, the exemption is only for those oil field production storage tanks
that have external floating roofs. The emissions from these tanks have not
been quantified at: present, therefore the emission reductions from requiring
a secondary seal is uncertain. This exemption applies to tanks storing the
petroleum liquid from the time it is removed from the ground until custody
is transferred from the production operation to the transportation operation.
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§XX.9730 Provisions for Specific Processes.
(a) No owner1 of a petroleum liquid storage vessel subject
to this regulation shall store a petroleum liquid in
that vessel unless:
(1) "Phe vessel has been fitted with:
(i) a continuous secondary seal extending
from the floating roof to the tank wall
(rim-mounted secondary seal)$ or
(ii) a closure or other device which controls
VOC emissions with an effectiveness equal
to or greater than a seal required under
part (a)(l)(i) of this section and
approved by the Director.
(2) All seal closure devices meet the following
requirements:
(i) there are no visible holes3 tears, or
other openings in the seal(s) or seal
fabric;
(ii) the seal(s) are intact and uniformly in
place around the circumference of the
floating roof between the floating roof
and the tank wall; and,
(Hi) for vapor mounted primary seals, the accumulated
area of gaps exceeding 0.32 cm (1/8 in.) in width
between the secondary seal and the tank wall
shall not exceed 21.2 cm2- per meter of tank
diameter (1.0 in.2 per ft of tank diameter), as
determined by the method in §XX.9750(c).
(S) All openings in the external floating roof, except for
automatic bleeder vents, rim space vents, and leg
sleeves, are:
(i) equipped with covers, seals, or lids in the
closed position except when the openings are
in actual use; and,
(ii) equipped with projections into the tank which
remain below the liquid surface at all times.
(4) Automatic bleeder vents are closed at all times except
when the roof is floated off or landed on the roof leg
supports;
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(5) Rim vents are set to open when the roof is being
floated off the leg supports or at the manufacturer's
reQommended setting-.; and,
(6) Emergency roof drains are provided with slotted membrane
fabric covers or equivalent covers which cover at least
90 percent of the area of the opening.
(b) The owner or operator of a petroleum liquid storage vessel
with an external floating roof subject to this regulation
shall:
(1) perform routine inspections semi-annually in order to
insure compliance with part (a) of this section and
the inspections shall include a visual inspection of
the secondary seal gap;
(2) measure the secondary seal gap annually in accordaance
with §XX.9750 when the floating roof is equipped with
a vapor-mounted primary seal; and,
(3) maintain records of the types of volatile petroleum
liquids stored, the maximum true vapor pressure of the
liquid as stored, and the results of the inspections
performed in aubparagraphs (b)(l) and (2).
(c) The owner or operator of a petroleum liquid storage vessel
with an external floating roof exempted from this regulation
by SXX.9720(b)(3), but containing a petroleum liquid with a
true vapor pressure greater than 7.0 kPa (1.0 psi), shall
maintain records of the average monthly storage temperature,
the type of liquid, and the maximum true vapor pressure
for all petroleum liquids with a true vapor pressure greater
than 7.0 kPa.
(d) Copies of all records under paragraphs (b) and (c) of this
section shall be retained by the owner or operator for a
minimum of 2 years after the date on which the record was
made.
(e) Copies of all records under this section shall immediately
be made available to the Director, upon verbal or written
request, at any reasonable time.
(f) The Director may, upon written notice, require more frequent
inspections or modify the monitoring and recordkeeping require-
ments, when necessary to accomplish the purposes of this
regulation.
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DISCUSSION
Some discussion of "the area of gaps" is needed. The CTG sample regula-
tion intended part (a)(2)(iii) to apply only to tanks equipped with vapor-
mounted primary seals. The secondary seal gap measurement, as specified in
part (b)(2) should be made annually. This measurement is only required where
the primary seal has been determined to be a vapor-mounted type. For all
other primary seal types, semi-annual visual inspection of the secondary seal
is all that is required. However, if the state agency official feels that
improper inspections are being conducted, he should then require a measurement
of the secondary seal on any tank. It is important that this section allow
the Director, at his discretion, to change the monitoring schedule such that
he can demand gap measurements for nonvapor-mounted seals or more frequent
gap measurements for vapor-mounted seals.
In order to determine equivalent effectiveness of part (a)(l)(ii), the
state agency should require the owner or operator to submit test data, along
with details of the test procedure. The agency will then be able to compare
the submitted figures with those published in the CTG.
With respect to recordkeeping, the owner or operator should be required
to maintain as a minimum:
1. records detailing all activities relating to any
Compliance Schedule;
2. records of all monitoring (routine inspections
and measurements);
3. records of the average monthly storage temperature, the
type of liquid, and the maximum true vapor pressure of the
liquid as stored for all volatile petroleum liquids;
(i) having a true vapor pressure greater than
7.0 kPa (1.0 psi); and,
(ii) stored in an external floating tank nojt equipped
with a secondary seal or approved alternative.
This suggested regulation is not completely consistent with that for fixed
roof tanks. In EPA-905/2-78-001, it was recommended that monthly temperature
and vapor pressure data be kept for all liquids and tanks. Here, only those
tanks holding a liquid with a true vapor pressure greater than 7.0 kPa and
not equipped with a secondary seal or approved alternative are obligated to
keep such records. The intention of this regulation is to keep track of those
tanks which contain liquids with vapor pressures marginally below the minimum
applicability. Since it is very difficult to estimate emissions from leaking
storage tanks, it would not be useful for the owners or operators to collect
physical property data for tanks complying with the regulation unless an
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exemption is being sought. In order to determine applicability, the state
agency can determine the true vapor pressure "by using the average monthly
storage temperature and typical Reid vapor pressure of the contained liquid
or from typical available data on the contained liquid." The true vapor
pressure of a crude oil with a Reid vapor pressure less than 13.8 kPa (2.0 psi)
or whose physical properties preclude determination by the above method need
not be reported.
It is again emphasized that the inspection and measurement of gaps does
not apply to primary seals. Semi-annual visual inspection of the secondary
seals is all that is required except in the case of vapor mounted primary
seals, where an annual measurement of the secondary seal gaps is also required.
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§XX. 9740 Compliance Schedules.
(a) The owner or operator of a petroleum liquid storage vessel
subject to this regulation shall meet the applicable
increments of progress contained in the foil-owing schedule
for installation of a secondary seal, closure, or other
VOC emission reduction device:
(U submit final plans for the emission control
system before September 15, 2980;
(2) aviard contraxts for the emission control
system before November 1, 1980;
(3) initiate onsite construction or installation of
the emission control equipment before January 15_, 1981;
(4) complete onsite construction or installation of the
emission control equipment before May 15, 1981; and,
(5) achieve final compliance with SXX.9730 before
July 1, 1981.
(b) The owner or operator of a source of volatile organic
compounds subject to this regulation, may submit to
the Director, and the Director may approve, a proposed
alternative compliance schedule provided:
(I) the proposed alternative compliance schedule is
submitted before September 15, 1980;
(2) the owner or operator provides information showing
the need for an alternative schedule;
(3) the alternative schedule contains increments of
progress;
(4) sufficient documentation and certification from
appropriate suppliers, contractors, manufacturers,
or fabricators is submitted by the owner or operator
of the subject facility to justify the dates proposed
for the increments of progress; and,
(S) final compliance is achieved as expeditiously as
possible, but no later than the photochemical
oxidant attainment date.
(c) The owner or operator of a source of VOC emissions subject
to a compliance schedule of this section shall certify to
the Director within 5 days after the deadline for each
increment of progress, whether the required increment of
progress has been met.
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DISCUSSION
The regulation for floating roof storage tanks is written around an
equipment specification. According to the EPA memorandum of November 3, 1978
on "Categorical Compliance Schedules for VOC Sources;" "Sources subject to
equipment, operating, and/or maintenance standards have 1 year to comply."
Therefore, the 52-week schedule is used in this regulation. Assuming July 1,
1980 as the effective day of the regulation presented here, the following
progress increments are required:
1. Control Plant Submittal - September 15, 1980
2. Contract Award - November 1, 1980
3. Initiation of Construction - January 15, 1981
4. Construction Completed - May 15, 1981
5. Final Compliance - July 1, 1981
A paragraph for Alternative Compliance Schedules is necessary. The
Director must be able to approve a separate schedule for any source if he
finds that the 52-week compliance schedule is not feasible. Also, the owner
or operator of a source of VOC emissions should be able to submit a proposed
alternative schedule to the Director for review, as long as it is presented
before September 15, 1980 and is properly documented.
EPA policy states that ''If such an alternative compliance schedule would
impact on attainment or maintenance of any ambient standard, then approval of
the alternative schedule as an SIP revision would be required...Too many
alternative schedules extending until December 31, 1982, might also prevent
a state from showing reasonable further progress toward attainment..."
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§XX.9750 Testing and Monitoring.
(a) The owner or operator of any volatile organic compound
source required to comply with %XX.9730 shall, at his
own expense, demonstrate compliance by the methods of
this section or an alternative method approved by the
Director.
(b) A person proposing to conduct a volatile organic
compound emissions test shall notify the Director
of the intent to test not less than 30 days before
the proposed initiation of the tests so the Director
may at his option observe the test. Ihe notification
shall contain the information required by, and be in
a format approved by, the Director.
(a) Compliance with §XX.9730(a)(2)(iii) shall be determined by:
(1) physically measuring the length and width of all gaps
around the entire circumference of the secondary seal
in each place where a 0.32 cm (1/8 in.) uniform diameter
probe passes freely (without forcing or binding against
the seal) between the seal and tank wall; and,
(2) summing the area of the individual gaps.
DISCUSSION
The area of gaps exceeding 0.32 cm (1/8 in.) in width between the
secondary seal and the tank wall should not exceed 21.2 cm2 per meter of
tank diameter (1.0 in.2 per foot of tank diameter). If the tank is equipped
with a metallic-type shoe or liquid-mounted seal, compliance can be determined
by visual inspection. However, if the primary seal is of the vapor-mounted
type, then compliance must be determined by physically measuring the length
and width of the gaps around the entire circumference of the secondary seal.
Only gaps greater than or equal to 0.32 cm (1/8 in.) shall be used in com-
puting the gap area. The area of the gaps should be accumulated to determine
compliance.
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§11.9820 Definitions.
(a) For the purpose of this Regulation, the general
definitions apply.
(b) For the purpose of this Regulation, the following
definition also applies;
(1) "Dry cleaning facility" means a facility
engaged in the cleaning of fabrics in an
essentially nonaqueous solvent by means of
one or more washes in solvent, extraction
of excess solvent by spinning, and drying
by tumbling in an airstream. The facility
includes but is not limited to any washer,
dryer, filter and purification systems,
waste disposal systems, holding tanks, pumps,
and attendant piping and valves.
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SXX. 9820 Applicability.
This Regulation applies to all perchloroethylene dry
cleaning facilities located in the following counties.
DISCUSSION
The CTG recommends specific exemptions from the installation of a
carbon adsorber or other control devices where one cannot be accommodated
because of inadequate space or unavailability of sufficient steam capacity
to desorb adsorbers. Since this exemption applies only to the installation
of a control device and not to the operation and maintenance provisions, it
has been included in the specific process section (XX.9830) rather than this
section.
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§XX.9830 Provisions for Specific Processes.
a
(a) The owner or operator of a perchloroethylene dry
cleaning facility subject to this regulation shall:
(1) vent the entire dryer exhaust through a properly
functioning carbon adsorption system or equally
effective control device;
(2) emit no more then 100 ppmv, of volatile
organic compounds from the dryer control
device before dilution;
(3) immediately repair all components found
to be leaking liquid volatile organic
compounds;
(4) cook or treat all diatomaceous earth filters so
that the residue contains 25 kg or less of volatile
organic compounds per 100 kg of wet waste material;
(5) reduce the volatile organic compounds from all
solvent stills to 60 kg or less per 100 kg of wet
waste material;
(6) drain all filtration cartridges, in the filter
housing, for at least 24 hours before discarding
the cartridges; and
(7) when possible, dry all drained cartridges without
emitting volatile organic compounds to the atmosphere.
(b) The provisions of subparagraphs (a)(l) and (a)(2) are not applicable
to: perchloroethylene dry cleaning facilities which are coin-
operated; facilities where an adsorber cannot be accommodated because
of inadequate space; or facilities with insufficient steam capacity
to desorb adsorbers. The Director may exclude other facilities from
the scope of subparagraphs (a)(l) and (a)(2) if it is demonstrated
that other hardships justify such an exclusion.
DISCUSSION
For vapor emissions from dryers, the CTG document for perchloroethylene
dry cleaning systems, EPA-450/2-78-050, recommends that all exhaust gases be
vented through a carbon adsorber or other control device and that the
perchloroethylene concentration leaving the adsorber or other control devices
not exceed 100 ppmv before dilution.
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It should be noted that many existing regulations for VOC emissions
through adsorption control devices specify the outlet concentration at no more
than 25 ppmv. The authors of the CTG document feel that "carbon adsorbers
tested by the EPA have achieved much better control than 100 ppmv outlet
concentration. This figure was chosen because it is high enough to indicate
'breakthrough' of the carbon bed. Breakthrough is a good indicator to
enforcement officials of improper maintenance or operation of the adsorber."
A regulation prohibiting liquid leaks is readily enforceable. Such
leaks can easily be detected by sight. Periodic inspections by the regulatory
agency officer can be an effective means of preventing this source of VOC
emissions. Section XX.9850 (b) list inspection points for liquid leaks.
RACT is straightforward for filter and distillation wastes. The test
method is well documented and fulfills the requirements of EPA. The CTG
states that: "For determining the amount of solvent in filter materials
(muck and distillation waste) the test method described by the American National
Standards Institute in the paper 'Standard Method of Test for Dilution of
Gasoline-Engine Crankcase Oils' should be used. To be derived are the
kilograms of VOC per kilogram of discarded muck. This method can be used for
the enforcement of the performance requirements of RACT."
Paragraph (b) of this section allows the Director to consider specific
instances where it is technologically infeasible to locate or operate a con-
trol device. It is expected that some older facilities in crowded urban areas
will not be able to install control equipment because of physical space con-
straints. In addition, some facilities which have the space may not have the
steam generating ability or access to sufficient quantities of steam for carbon
adsorption bed regeneration. In these situations, the owner or operator is
responsible for providing the Director with sufficient documentation to con-
firm that no reasonable alternatives are available. The Director may then
decide to allow the source to continue operations provided it continues to
comply with subparagraphs (a)(3) through (a)(7).
The exemptions provided in paragraph (b) are explictly recommended in
the CTG. In addition, coin-operated plants have been delineated to prevent
confusion as to the coverage for these sources. Coin-operated systems have
special problems. There is generally no steam demand at coin-ops and thus
no steam boiler. In most cases, the steam necessary to desorb a carbon bed
does not exist at these plants and necessary space for an adsorber is not
available.
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§XX.9840 Compliance Schedules.
(a) The owner or operator of a perchloroethylene dry cleaning
facility subject to SXX.9830 (a)(l) or (a)(2) of this
regulation mast meet the applicable increments of progress
in the following schedule:
(1) Award contracts, issue purchase orders, or otherwise
order the emission control system and process
equipment, before January 1, 1981;
(2) Complete installation of the emission control and
process equipment, before December 1, 1981; and,
(3) Achieve final compliance, determined in accordance
with 5XX.9850, before January 1, 1982;
(4) In the event that equipment cannot be delivered prior
to November 1, 1981 and the owner or operator placed
the order prior to January 1, 1981, the final compliance
date shall be 60 days following delivery of the
equipment.
(b) The owner or operator of a perchloroethylene dry
cleaning facility subject to this regulation must
comply with the operational and maintenance provisions
of SXX.9830 (a)(3) through (a)(7) by January 1, 1981.
(a) The owner or operator of a perchloroethylene dry cleaning
facility subject to this regulation may submit to the
Director, and the Director may approve, a proposed alter-
native compliance schedule provided:
(1) The proposed alternative compliance schedule is
submitted before September 15, 1980;
(2) The owner or operator provides information
showing the need for an alternative schedule;
(3) The alternative compliance schedule contains
increments of progress;
(4) Sufficient documentation and certification from
appropriate suppliers, contractors, manufacturers,
or fabricators is submitted by the owner or operator
of the subject facility to justify the dates
proposed for the increments of progress; and
(5) Final compliance is achieved as ezzpeditiously as possible
and before the photochemical oxidant attainment date.
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DISCUSSION
Assuming July 1, 1980 as the effective date of the regulation, compliance
with the operation and maintenance provision of the regulation shall be
attained by January 1, 1981. The awarding of a contract or issuance of a
purchase order for an emission control system is also required by January 1,
1981. Normally installation of the emission control system is required by
December 1, 1981 with final compliance occurring by January 1, 1982. However,
if delivery of the control equipment cannot be made prior to November I, 1981,
final compliance does not have to be demonstrated until 60 days after the
delivery date. The last provision is included because the large number of
carbon adsorption units expected to be ordered may exceed the manufacturers'
capacity to deliver these units.
A paragraph tor Alternative Compliance Schedules is included. The owner
or operator of the emission source should be allowed to submit a proposed
alternative schedule to the Director for review as long as it is presented
before September 15, 1980 and it is properly documented. The Director must be
able to approve a separate schedule for any source if he finds that compliance
with paragraphs (a) or (b) is not feasible.
EPA states, however, that "if such an alternative compliance schedule
would impact on attainment or maintenance of any ambient standards, then
approval of the alternative compliance schedule as an SIP revision would be
required....Too many alternative schedules extending until December 31, 1982,
might also prevent a state from showing reasonable further progress toward
attainment..."
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SXX.9850 Testing and Monitoring.
(a) Compliance with SXX.9830 (a)(l), (a)(6) and (a)(7) shall be
determined by means of a visual inspection.
(b) Compliance with SXX.9830 (a)(2) shall be determined by means
of a visual inspection of the following components:
(1) Hose connections, unions, couplings and valves;
(2) Machine door gaskets and seatings;
(3) Filter head gasket and seating;
(4) Pumps;
(5) Base tanks and storage containers;
(6) Water separators;
(7) Filter sludge recovery;
(8) Distillation unit;
(9) Diverter valves;
(10) Saturated lint from lint basket; and
(11) Cartridge filters,
(c) Compliance with SXX.9830 (a)(2) shall be determined by:
(1) a test consistent with EPA Guideline Series document,
"Measurement of Volatile Organic Compounds,"
EPA-450/2-78-041; or
(2) the proper installation, operation, and maintenance of
equipment which has been demonstrated to be adequate to
meet the emission limits in SXX.9830 (a)(2).
(d) Compliance with SXX.9830 (a)(4) and (a) (5) shall be determined
by means of the procedure in the American National Standards
Institute paper, "Standard Method of Test for Dilution of
Gasoline Engine Crankcase Oils."
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DISCUSSION
The test method for liquid leaks is a straightforward visual observation
for liquid perchloroethylene which is dripping or leaking from the dry cleaning
equipment.
The test method for determining the amount of solvent in filter materials
(muck and distillation waste) is described by the American National Standards
Institute in the paper "Standard Method of Test for Dilution of Gasoline-Engine
Crankcase Oils." The results are to be expressed in kilograms of VOC per
kilogram of discarded filter muck. This method can be used for the enforcement
of §XX.9830(a)(4) and (a)(5).
Testing for VOC emissions from a dryer control device may be accomplished
by any of the following potential methods:
1. Measuring organic carbon by the procedures described in
the EPA Guideline Series document, "Measurement of Volatile
Organic Compounds," EPA-450/2-78-041; and converting to
ppmv of VOC;
2. A draft reference method for determining ppm of halogenated
organic compounds (which includes perchloroethylene) presently
exists and should be proposed during early 1980;
3. The carbon adsorbers tested by EPA have achieved much
better control than 100 ppm outlet concentration.
It should be possible for vendors to demonstrate
that their equipment, if properly installed and
operated, will be adequate to meet the emission
limits. If the carbon adsorber has been properly
maintained and breakthrough has not occurred, the
carbon adsorber would be in compliance based on
previous equipment performance.
The first two methods are very accurate, but are probably too costly for
most routine compliance determinations. These methods could be used to docu-
ment a violation by a large facility. For routine compliance determinations
the third method is probably most useful.
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SXX.9910 Definitions.
(a) For the purpose of this Regulation, the general
definitions apply.
(b) For the purpose of this Regulation, the following
definitions also apply:
(1) "Bottom filling" means the filling of a tank
truck or stationary storage tank through an
opening that is flush with the tank bottom.
(2) "Gasoline" means a petroleum distillate having
a Reid vapor pressure of 27.6 kPa (4 psi) or
greater that is used as fuel for internal
combustion engines.
(3) "Gasoline Tank Truck" means tank trucks or
trailers equipped with a storage tank and
used for the transport of gasoline from sources
of supply to stationary storage tanks of
gasoline dispensing facilities, bulk gasoline
plants or bulk gasoline terminals.
(4) "Gasoline Dispensing Facility" means any site
where gasoline is dispensed to motor vehicle
gasoline tanks' from stationary storage tanks.
(5) "Bulk gasoline terminal" means a gasoline storage
facility which receives gasoline from refineries
primarily by pipeline., ship, or barge, and delivers
gasoline to bulk gasoline plants or to commerical or
retail accounts primarily by tank truck- and has a
daily throughput of more than 76,000 liters (20,000
gal) of gasoline.
(6) "Bulk gasoline plant" means a gasoline storage and
distribution facility with an average throughput of
76,000 liters (20,000 gal) or less which receives
gasoline from bulk terminals by gasoline tank truck,
stores it in tanks* and subsequently dispenses the
gasoline via account trucks to local farms, businesses,
and gasoline dispensing facilities.
(7) 'Vapor Collection System" means a vapor transport
system which uses direct displacement by the gasoline
being transferred to force vapors from the vessel
being loaded into either a vessel being unloaded
or a vapor control system or vapor holding tank.
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SXX.9920 Applicability.
This Regulation is applicable to all vapor collection and
control systems at bulk plants, bulk terminals and gasoline
dispensing facilities, and to all gasoline tank trucks
equipped for gasoline vapor collection located in
the following counties:
DISCUSSION
The CTG document for Leaks from Gasoline Tank Trucks and Vapor Collection
Systems is a fairly straight forward guidance document primarily concerned with
defining and detecting VOC leaks during loading and unloading operations by
gasoline tank trucks at bulk plants, bulk terminals and gasoline dispensing
facilities. The guidance is applicable to all bulk plants, bulk terminals,
gasoline dispensing facilities and tank trucks which are required to have a
vapor collection system. Also, all gasoline dispensing facilities with
Stage I controls and, most importantly, all tank trucks loading or unloading
at any of these facilities are effected by this guidance.
There are no exemptions based on the size of the facility, number of
trucks or total quantity of VOC emissions in the CTG document.
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SXX.9930 Provisions for Specific Processes.
(a) No person shall allow a gasoline tank truck subject
to this regulation to be filled or emptied unless the
gasoline tank truck:
(1) is tested annually according to the test
procedure referenced in §XX.9950(c);
(2) sustains a pressure change of no more than
750 pascals (3 in. of H20) in 5 min when
pressurized to a gauge pressure of 4,500
pascals (28 in. of H20) or evacuated to a
gauge pressure of 1,500 pascals (6 in. of
H20) during the testing required in
subparagraph (a)(l) of this section;
(3) is repaired by the owner or operator
and retested within 15 days of testing
if it does not meet the criteria
of subparagraph (a)(2) of this section;
(4) displays a sticker near the Department of
Transportation Certification plate required
by 49 CFR 178.340-lOb, which:
(i) shows the date that the gasoline
tank truck last passed the test
required in subparagraphs (a)(l)
and (a)(2) of this section;
(ii) shows the identification number
of the gasoline tank truck tank;
and,
(Hi) expires not more than 1 year from
the date of the leak tight test.
(b) 1*he owner or operator of a vapor collection system
subject to this regulation shall:
(1) design and operate the vapor collection system and the
gasoline loading equipment in a manner that prevents:
(i) gauge pressure from exceeding 4,500
pascals (18 in. of H20) and vacuum
from exceeding 1,500 pascals (6 in.
of H20) in the gasoline tank truck;
(ii) a reading equal to or greater than 100
percent of the lower explosive limit (LEL,
measured as propane) at 2.5 centimeters from
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all points on the perimeter of a potential
leak source when measured by the method
referenced in §XX.9950(d) during loading
or unloading operations at gasoline
dispensing facilities, bulk plants and
bulk terminals;
(iii) avoidable visible liquid leaks during loading
or unloading operations at gasoline dispensing
facilities, bulk plants and bulk terminals; and,
(2) within 15 days, repair and retest a vapor collection or
control system that exceeds the limits in subparagraph
(b)(l) of this section,
(c) The Director may, at any time, monitor a gasoline tank truck,
vapor collection system, or vapor control system, by the method
referenced in §XX.9950(d), to confirm continuing compliance with
paragraphs (a) or (b) of this section.
(d) fhe Director may, upon written notice modify the testing
frequency of paragraph (a).
DISCUSSION
The approach taken in the CTG document to control leaks from gasoline
tank trucks, vapor collection systems, and vapor control systems is a program
of monitoring and maintenance. No emission limits are given in this regulation,
since none are specified in the CTG document.
The owner or operator of a gasoline tank truck will be required to have
each tank and their vapor collection systems pass a leak tightness test
annually. The CTG document does not address who is responsible for admin-
istering and performing the test. The sample regulation provides for repair
and retesting of a component if it is not leak tight.
There are several possible methods of operating a gasoline tank truck
certification program; a program may be operated entirely by a state or
local agency, the state or local agency may license specific testing facilities,
or the testing may be done by the owners and operators of the gasoline tank
truck. In the last example, the state or local agency could issue certification
stickers based on information received under the certification requirement of
§XX.9960; or the owner or operator of a gasoline tank truck may perform and
administer the testing, including supplying the stickers, with only monitoring
by the state and local agency as provided for in §XX.9930(c).
The vapor collection system must be designed and operated to prevent
gauge pressure in the tank truck from exceeding 4,500 pascals (18 in. of
H20) and prevent vacuum from exceeding 1,500 pascals (6 in. of H20). This
is to assure the accuracy of the certification test results.
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In addition to the annual leak tightness tests the CTG document recommends
periodic monitoring for leaks by the owner or operator and spot checks by
regulatory agencies, "as needed." The "as needed" should be defined, at least
initially, as some percentage of the certified fleet. The monitoring is done
during loading and unloading operations using the Combustible Gas Detection
Procedure given in Appendix B of the "Control of Organic Compound Leaks from
Gasoline Tank Trucks and Vapor Collection Systems," CTG document, EPA-450/2-78-051,
If the combustible gas detection procedure measures a VOC leak at equal to or
greater than 100 percent of the LEL, the leak is to be repaired within 15 days
and the equipment must pass either the Combustible Gas Detection Procedure or
the Pressure-Vacuum test.
Presently, there is limited Information available on the amount of
monitoring necessary to ensure that leaks are kept to the limits described
above. Therefore, regulations should allow for modifications in the moni-
toring schedule when experience proves it to be either inadequate or exces-
sive. If, after over 1 year of monitoring, i.e., at least two complete annual
checks, the operator of an affected facility feels that modifications of
the requirements are in order, he may request in writing to the air pollution
control officer that a revision be made. The submittal should include data
that have been developed to justify any modifications in the monitoring
schedule. On the other hand, if the air pollution control officer finds an
excessive number of leaks during an inspection, or if the operator finds an
excessive number of leaks during scheduled monitoring, consideration should
be given to increasing the frequency of inspections.
The intent of the wording in paragraph (a) is to make owners or operators
of bulk terminals, bulk plants, and gasoling dispensing facilities, as well as
the owner and operator of the gasoline tank trucks, responsible for allowing
VOC emissions from loading and unloading of gasoline. Responsibility should
be limited to checking for a valid sticker in most cases.
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SXX.9940 Compliance Schedules.
(a) The owner or operator of a gasoline tank truck subject
to this regulation must meet the following increments
of progress:
(1) Submit plans to the Director for operating and
maintenance procedures to implement SXX.9930 and
SXX.9950 before September 15, 1980;
(2) Issue purchase orders or contracts for all needed
test equipment before November 1, 1980;
(3) Commence certification of gasoline tank trucks
before July 1, 1981; and,
(4) Complete initial certification of all gasoline
tank trucks before January 1, 1982.
(b) The owner or operator of a gasoline tank truck subject
to this regulation, may submit to the Director, and the
Director may approve, a proposed alternative compliance
schedule provided:
(1) The proposed alternative compliance schedule is
submitted before September 15, 1980:
(2) The owner or operator provides information
showing the need for an alternative schedule;
(3) The alternative compliance schedule contains
increments of progress;
(4) Sufficient documentation and certification from
appropriate suppliers, contractors, manufacturers,
or fabricators is submitted by the owner or operator
to justify the dates proposed for the increments
of progress; and
(5) Final compliance is achieved as expeditiously as
possible and before the photochemical oxidant
attainment date.
(c) The owner or operator of a gasoline tank truck subject
to a compliance schedule of this section shall certify
to the Director within 5 days after the deadline for each
increment of progress, whether the required increment
of progress has been met.
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DISCUSSION
The RACT for this source category is the establishment of equipment
maintenance standards. Therefore, the l-ye,ir compliance schedule set forth
in an EPA memorandum, dated November 3, 1978, "Categorical Compliance
Schedules for VOC Sources" is applicable. Assuming July 1, 1980, as the
effective date of this regulation, the following progress increments would
be required.
1. Plan necessary operating and maintenance procedures
by September 15, 1980;
2. Issue Purchase Orders for all necessary test equipment
by November 1, 1980;
3. Commence certification of gasoline tank trucks before
July 1, 1981; and
4. Complete initial certification of all gasoline tank
trucks by January 1, 1982.
The last two dates should be adjusted to insure that most of the annual
certification testing occurs just prior to the photochemical oxidant season.
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§XX. 9950 Testing and Monitoring.
(a) The owner or operator of a volatile organic compound
source shall, at his own expense, demonstrate compliance
with XX. 9930 by the methods of part (c) of this section,
or an alternative method -approved by the Director. All
tests shall be made by, or under the direction of, a
person qualified by training and/or experience in the
field of air pollution testing or tank truck maintenance
and testing.
(b) The owner or operator of a gasoline tank truck subject
to this regulation must notify the Director in writing
of the date and location of a certification test at
least 10 days before the anticipated test date.
(c) Test procedures to determine compliance with §XX.9930
must be approved by the Director and consistent with
the test procedures described in Appendix A of the
OAQPS Guideline Series document, "Control of Organic
Compound Leaks from Gasoline Tank Trucks and Vapor
Collection Systems," EPA-450/2-78-051, or an equivalent
procedure approved by the Director.
(d) Monitoring to confirm the continuing existence
of leak tight conditions shall be consistent with
the procedures described in Appendix B of the OAQPS
Guideline Series document, "Control of Organic
Compound Leaks from Gasoline Tank Trucks and Vapor
Collection Systems," EPA-450/2-78-051.
DISCUSSION
The recommended compliance test methods referenced in §XX.9950(c) can be
used to determine the leak tightness of a gasoline tank truck. Pressure and
vacuum are applied to the tanks of a gasoline delivery truck and the change
in pressure/vacuum is recorded after a specific period of time. The recom-
mended test procedure in effect defines a "leak tight condition." The
recommended compliance procedure is actually an equipment performance criteria
rather than a true emission measurement test. However, emissions from a truck
tank can be estimated from the required degree of leak tightness. Acceptable
modifications of the pressure/vacuum test are described on page 6 of the
referenced document. These alteratives include using a liquid to create the
required pressure and vacuum or conducting the test with gasoline vapors in
the tank under specific conditions. The compliance schedule section of this
regulation provides a 6-month period for owners and operators to complete
the initial leak tight testing of their fleets.
Thereafter, all fleets should complete their testing before the beginning
of the seasonal photochemical oxidant period in their region.
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. 9960 Recordkeeping and Reporting.
(a) The owner or operator of a source of volatile organic compounds
subject to this regulation shall maintain records of all
certification testing and repairs. Trie records must- identify
the gasoline tank truck, vapor collection system, or vapor control
system; the date of the test or repair; and, if applicable, the type
of repair and the date of retest. The records must be maintained in
a legible, readily available condition for at least 2 years after
the date the testing or repair was completed.
(b) The records of certification tests required by paragraph (a)
of this section, shall, as a minimum, contain:
(1) the gasoline tank truck tank identification number;
(2) the initial test pressure and the time of the
reading;
(3) the final test pressure and the time of the
reading;
(4) the initial test vacuum and the time of the
reading;
(5) the final test vacuum and the time of the
reading;
(6) at the top of each report page shall be the company
name, and the date and location of the tests on
that page; and,
(7) name and the title of person conducting the test.
(a) The owner or operator of a gasoline tank truck subject to
this regulation must certify to the Director annually that
the gasoline tank truck has been tested by an applicable
method referenced in %XX.9950. The certification must
include:
(1) the name and address of the company and the name
and telephone number of responsible company repre-
sentative over whose signature the certification
is submitted; and,
(2) a copy of the information recorded to comply
with paragraph (b) of this section.
(d) Copies of all records and reports under this section
shall, immediately be made available to the Director,
upon verbal or written request, at any reasonable
time.
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DISCUSSION
The amount of reporting required by a state or local agency is dependent
on several factors. First, the type of certification program which is imple-
mented can be designed with either a maximum involvement in the testing and
administration by the agency and minimum of reporting necessary on the part
of persons affected by this regulation or a minimum involvement by the agency
in the testing and administration and much heavier emphasis on reporting and
recordkeeping by the companies involved. Second, the emphasis on reporting
and recordkeeping will vary with the amount of monitoring done by the regulatory
agency.
It is important to note that in order to make this type of regulation
effective, a consistent program of testing, monitoring, recordkeeping, and
reporting must be implemented, Although the emphasis on the various components
of the program may be changed, elimination of any one of the components will
result in an ineffective program.
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SXX.8010 Applicability.
(a) These Regulations avz effective after June 30, 1980.
(b) These Regulations are not applicable to:
(1) Sources whose emissions of volatile organic compounds are
less then 6.8 kilograms (15 pounds) per day and less than
1.4 kilograms (3 pounds) per hour, provided the emission
rates are determined and certified before September 15, 1980
in a manner approved by the Director.
(2) Sources used exclusively for chemical or physical analysis
or determination of product quality and commercial acceptance
(such as research facilities, pilot plant operations, and
laboratories) unless;
(i) the operation of the source is an integral part of
the production process; or,
(ii) the emissions from the source exceed 36S kilograms
(800 pounds) in any calendar month; or,
(Hi) the exemption is denied in writing by the Director.
(c) Part (b) of this section does not apply to the following
regulations:
§ZZ.9000 Control of Volatile Organic Compound Leaks from Petroleum
Refinery Ecruipment
SXX.9600 Graphic Arts (Rotogravure and Flexography)
%XX.9700 Petroleum Liquid Storage in External Floating Roof Tanks
§XX.9800 Perchloroethylene Dry Cleaning Systems
§XX.9900 Leaks from Gasoline Tank Trucks and Vapor Collection Systems
DISCUSSION
Some discussion is required in order to determine the applicable size of
operation or amount of pollutant emission. In the memorandum of February 24,
1978, on "Criteria for Approval of 1979 SIP Revisions," two separate regulatory
philosophies are presented. One, for major urban areas (population greater than
200,000), states that the regulation must reflect RACT for virtually all
sized sources covered by the CTG. The other, for rural nonattainment areas,
requires RACT only for large sources (more than 100 ton/yr potential emissions).
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Thus, applicability exemptions should be presented for both urban and
rural areas where necessary. In urban areas, the size exemption should be
similar to the one presented in EPA-905/2-78-001, "Regulatory Guidance for
Control of Volatile Organic Compound Emissions from 15 Categories of Stationary
Sources":
In urban areas (population > 200,000), these regulations will not
apply to sources whose emissions of volatile organic compounds are
not more than 6.8 kilograms (15 pounds) in any 1 day, not more than
1.4 kilograms (3 pounds) in any 1 hour, provided the emission rates
are determined and certified before March 1, 1980, in a manner
approved by the Director.
The size limitation contained in the above paragraph is applicable to
the following industrial categories:
§XX.9100 Surface Coating of Miscellaneous Metal Parts and Products
§XX.9300 Surface Coating of Flat Wood Paneling
§XX.9400 Manufacture of Synthesized Pharmaceutical Products
§XX.9500 Manufacture of Pneumatic Rubber Tires
The general size limitation does not apply to the other CTG categories
because either the intent of the regulation is to control VOC leaks (e.g.,
Petroleum Refinery Equipment, External Floating Roof Tanks, Gasoline Tank
Trucks and Vapor Collection Systems) or the applicability section of the
specific regulation has a different size limitation (e.g., Perchloroethylene
Dry Cleaning Systems and Graphic Arts). State and local agencies should
carefully review new general regulatory language to insure that it is
consistent with previous regulations. Please note that David G. Hawkins'
memo dated September 11, 1978, "Continuity of SIP Regulations," is pertinent
to this topic.
This section also provides an exemption for research facilities, pilot
plant operations, and laboratories if they meet the criteria of part (b)(2).
It is not EPA's intent to regulate VOC sources within a facility if the sources
are being used to develop process changes that may reduce VOC emissions from
actual production equipment.
Part (b)(2)(ii) suggests an emission limit of 363 kilograms (800 Ibs)
in any calendar month. This quantity was used by the EPA when it promulgated
hydrocarbon regulations for a state in Region I. It also appeared in
EPA-905/2-78-001, "Regulatory Guidance for Control of Volatile Organic Compound
Emissions from 15 Categories of Stationary Sources." The important point here
is that some quantity should be included in a state's VOC regulation to insure
authority to require control on continuous large emissions from these types
of sources. Since these sources may emit large quantities of VOC
intermittently, it is recommended that the emission averaging period be no
shorter than 1 month.
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§XX.8030 Inspection^ Maintenance and Operating Procedures.
(a) The owner or operator of a facility subject to these
regulations must make available to the Director an Inspection
and Maintenance Manual for all control equipment before the final
compliance date required under the appropriate compliance schedule
section of the specific regulation. The manual shall include
all normal maintenance required and the period or intervals at
which the maintenance or inspection is to be completed. Normal
maintenance shall include the calibration of monitoring equipment.
(b) The owner or operator of a facility subject to these
regulations must keep a written record of all maintenance
or repair work performed on the control equipment for
2 years after the date on which the maintenance or repair
work is completed. This record shall be made available
to the Director upcn request.
(c) The owner or operator of a facility subject to these
regulations must sitomit an Operators Manual to the
Director before the final compliance date in the
appropriate compliance schedule section. This manual
shall be suitable for training a person to properly
operate the control equipment.
(d) Only trained operators shall startup and shutdown
the control equipment.
DISCUSSION
This regulation is included to insure that proper control equipment
maintenance and operation procedures are followed. In addition, a comparison
of maintenance requirements in the manual with actual maintenance records can
help state and local agencies determine liability in the event of a malfunction
or breakdown.
Depending on the importance that a state or local agency places on
control equipment inspection, maintenance and operating procedures, the
agency may want to substitute, for the phrase in part (a), "must make
available to the Director," the phrase, "must submit to and have approved
by the Director." This wording would give the agency much more control in
defining normal maintenance. Conversely, a state or local agency may substitute
for the phrase in part (c), "must submit an Operators Manual to the Director,"
another phrase, such as, "must make available to the Director."
The "appropriate compliance schedule section of the specific regulation"
is the compliance schedule which applies to the specific control device
discussed in the Inspection and Maintenance Manual. If more than one control
device is included in the manual the schedule with the earliest final compliance
date is the appropriate one.
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Part (d) of this section of the regulation is included because startup
and shutdown of control equipment by personnel unfamiliar with the operation
of the control equipment has been a cause of malfunctions and breakdowns in
the past. Trained operators in this case means personnel familiar with the
operation of the control equipment.
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§XX.8040 Breakdown, Malfunction and Operation Changes.
(a) Breakdown, malfunction. The owner or operator of an
emission source shall notify the Director immediately
(1) of a breakdown or malfunction of more than 1 hr
duration of any control equipment; and, (2) of a break-
down or malfunction of any process equipment, if the
breakdown or malfunction causes an increase in the
emission of air contaminants. At the time of notifi-
cation or as soon thereafter as possible, the owner
or operator shall also notify the Director of the
cause of the breakdown or malfunction and the
estimated duration. The owner or operator shall
notify the Director when the breakdown or malfunction
is over.
(b) Operation changes. In a shutdown, startup, breakdown
or malfunction, the owner or operator shall immediately
take all practical steps to modify operations to maintain
the emission of air contaminants within emission limitations.
The Director may require feasible and practical modifications
in the operation to reduce emissions of air contaminants to
within emission limitations. No affected facility which has
an unreasonable breakdown or malfunction frequency of control
equipment shall be permitted to operate. Nothing in this
regulation shall permit the operation of an affected source
which may cause an immediate public health hazard.
(c) Records. The owner or operator of an affected source shall
maintain records of the occurrence and duration of any
breakdown, or malfwiction in operation of the source or any
air emission control equipment. The owner or operator shall
maintain records of every period of time in which a continuous
monitoring system or monitoring device is inoperative. These
records shall be retained for at least 2 years following the
date of the shutdown, startup, breakdown, or malfunction.
These records shall be made available to the Director upon
request.
(d) Monitoring Equipment. The owner or operator of a continuous
monitoring system or monitoring device shall notify the
Director of a shutdown, breakdown or malfunction of more than
1 hour duration of the device or system.
(e) Emissions during startup, shutdown, breakdown, or malfunction
that exceed emission limitations in the State Implementation
Plan constitute violations of that plan.
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DISCUSSION
This section requires the immediate notification to the Director in the
event of a breakdown or malfunction of any air pollution control device or
of any process equipment if it causes an increase in the emission of air
contaminants. This section allows the Director to initiate an investigation
into the possibility of a violation of applicable regulations and to respond
to any citizen complaints.
According to EPA guidance all emissions that exceed emission limitations
during startup, shutdown, breakdown, or malfunction of process or control
equipment should be considered a violation of the SIP. EPA policy states
that, "any malfunction provisions must provide for the commencement of a
proceeding to notify the source of its violation and to determine whether
enforcement action should be undertaken for any period of excess emissions,
whether due to malfunction or otherwise." However, the guidance does imply
that "enforcement discretion" should be used in cases where there is a sudden
and unavoidable malfunction that is entirely beyond the control of the owner
or operator.
The manual entitled "Workshop on Requirements for Nonattainment Area
Plans" offers some guidelines on this subject. A copy of the applicable
sections is provided at the end of this discussion.
The first key point made in the workshop manual is that the malfunction
provision cannot be the type that provides an automatic exemption where a
malfunction is alleged by a source. The burden of proof must be placed on
the source.
Another point is that there are three possible options for a malfunction
provision depending on the projected attainment date for the ambient air
quality standards.
The first option applies when the SIP calls for attainment of the ambient
air quality standards for VOC by 1982. Any malfunction provision must then
provide for the commencement of a proceeding to notify the source of its
violation. A question arises as to how might the regulatory agency be aware
of a malfunction violation. One way, of course, is to observe the violation
during normal inspections. However, for VOC emissions, such sightings
are not always possible due to the invisibility of many of the compounds.
The other course of action is for the source to report its malfunction
and follow the notifying procedure in the hope of being subsequently
exonerated. This situation of "guilty until proven innocent" may discourage
many violators from reporting malfunctions. The regulatory agency needs
to work with industry toward understanding and solving the problems that
result in malfunctions and breakdowns. The source, when reporting the
malfunction occurance, must also submit appropriate information concerning
the malfunction or breakdown. EPA has presented, in a memorandum entitled
"Comments on Regulatory Guidance for Control of VOC Emissions from 15 Categories
of Stationary Sources Final Report," some suggestions on the reporting requirements
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Breakdown, malfunction. The owner or operator of an emission source
shall notify the Director immediately of a breakdown or malfunction
of more than 1 hour duration of any control equipment and, if the
breakdown or malfunction causes an increase in the emission of air
contaminants, of a breakdown or malfunction of any process equipment.
At the time of notification or as soon thereafter as possible, the
owner or operator shall also notify the Director of the cause of the
breakdown or malfunction and the estimated duration. The owner or
operator shall notify the: Director when the breakdown or malfunction
is over.
Then, based on the information submitted by the source, the State must
determine whether additional enforcement action is necessary by considering
the five factors outlined in the "workshop" guideline.
The second and third options for a malfunction provision are applicable
to the SIP's which will not be able to demonstrate attainment of ambient air
quality standards for VOC's by December 31, 1982.
The second option is simply not to provide any malfunction provision
at all.
The third option is very similar to existing malfunction provisions
in most state regulations. The source is given the opportunity to demonstrate
that the excess emissions resulted from an unavoidable breakdown. The reporting
requirements and the evaluation procedures are the same as outlined in the
first option above. The key point is that until the information reported by
the source is evaluated by the state, issuance of a notice of violation is
not required. If the source does not sustain its burden of proof, enforcement
proceedings must then be initiated. If the source is able to demonstrate
that the malfunction was genuinely unavoidable, it will not constitute a
violation of the emission limitation.
The "workshop" guidelines do not allow for a shutdown-startup provision.
"Any activity or event which can be foreseen and avoided, or planned, falls
outside of the definition of sudden and unavoidable breakdown of equipment."
Therefore, any emission in excess of an emission limitation due to phasing
in and out of process equipment or due to routine maintenance procedures
will be in violation of the regulations."
The regulations should provide some flexibility for two unavoidable
situations which are not malfunctions. First, in certain circumstances, it
is necessary to bypass the control equipment to avoid endangering life or
sustaining severe property damage. Second, occasionally excess emissions
result from process fluctuations that are unavoidable. In both these cases,
the agency's and source's responsibilities are the same as presented under
MALFUNCTION, BREAKDOWN.
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Many of the foregoing statements and the wording of §XX.8040 are based on
interpretations of EPA policy statements which appear in the "Workshop on Require-
ments for Nonattainment Area Plans." The Malfunction and Exemption Provision
section of the Workshop, which appears below, is included in this discussion
as a basis for interpretation of the sample regulation.
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NONATTAINMENT PLAN REVISIONS
MALFUNCTION AND EXEMPTION PROVISIONS
Several of the existing State Implementation Plans (SIP) provide for an
automatic emission limitation exemption during periods of excess emissions due
to start-up, shutdown, or malfunction. Generally, EPA agrees that the imposi-
tion of a penalty for sudden and unavoidable malfunctions caused by circum-
stances entirely beyond the control of the owner and/or operator is not appro-
priate under certain conditions. However, since the SIPs must provide for
attainment and maintenance of the national ambient air quality standards, SIP
provisions on malfunctions must be narrowly drawn. (SIPs may, or course, omit
any provision on malfunctions.)
I. AUTOMATIC EXEMPTION APPROACH
If a nonattainment plan revision contains a malfunction provision, it
cannot be the type that provides for automatic exemption where a malfunction
is alleged by a source. Automatic exemptions might aggravate air quality so
as to result in not providing for attainment of the ambient air quality stand-
ards as required by Section 172 of the Clean Air Act, as amended. Additional
grounds for disapproving a SIP that includes the automatic exemption approach
are discussed in more detail at 42 FR 58171 (November 8, 1977) and 42 FR 21372
(April 27, 1977). As a result, EPA will disapprove any nonattainment plan
revision that provides for an automatic exemption in those instances where a
source claims excess emissior.s were caused by start-up, shutdown, or mal-
function.
II. ENFORCEMENT DISCRETION APPROACH—SIP EMISSION LIMITATION ADEQUATE TO
ATTAIN AMBIENT STANDARDS
EPA could approve nonattainment plan submittals which incorporate the
"enforcement discretion approach." Such plans would include a requirement
that places the burden on the source of demonstrating to the appropriate State
agency's satisfaction that the excess emissions, though constituting a violation,
were due to an unavoidable malfunction. For nonattainment plan revisions that
provide for attainment of the ambient air quality standards for a pollutant by
1982, any malfunction provisions must provide for the commencement of a pro-
ceeding to notify the source of its violation and to determine whether enforce-
ment action should be undertaken for any period of excess emissions, whether
due to malfunctions or otherwise. (The term "excess emission" means air emis-
sion rate which exceeds any applicable emission limitation.)
Commencement of such a proceeding could be by issuance of a notice of
violation (or some equivalent State mechanism) with the source being provided
the opportunity to establish that the violation was due to an unavoidable
malfunction. Thr>. malfunction provision should provide that the burden is
entirely upon the source to establish that the excess emissions resulted from
a true malfunction. (A malfunction is defined as a sudden and unavoidable
breakdown of process or air pollution control equipment.)
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Based on information submitted by the source, the State must determine
whether additional enforcement action is necessary. The following factors must,
at a minimum, be considered:
1. The air pollution control equipment, process equipment, or processes
were at all times maintained and operated, to the maximum extent practicable,
in a manner consistent with good practice for minimizing emissions;
2. Repairs were made in an expeditious fashion when the operator knew
or should have known that applicable emission limitations were being exceeded.
Off-shift and overtime labor must have been utilized to insure that such repairs
were made as expeditiously as possible;
3. The amount and duration of the excess emissions (including any bypass)
were minimized to the maximum extent practicable during periods of such emissions;
4. All possible steps were taken to minimize the impact of the excess
emissions on ambient air quality; and
5. The excess emissions are not part of a recurring pattern indicative
of inadequate design, operation, or maintenance.
The malfunction provision must provide that only if the State determines that
each of these criteria are satisfied, no additional course of action could
reasonably have been expected of the owner or operator. In such situations,
the malfunction provision could provide that the State would not follow the
initial notice of violation with any further enforcement action.
III. SOURCE DEMONSTRATION APPROACH--RACT LIMITATION NOT ADEQUATE TO ATTAIN
AMBIENT STANDARDS
Section 172 requires that those nonattainment submittals for photochemical
oxidants and carbon monoxide that will not be able to demonstrate attainment
by December 31, 1982, must provide for implementation of all reasonably avail-
able control measures (RACT). In a recent Federal court decision (Marathon
Oil Co. V. EPA, F.2d (9th Cir., November 21, 1977) [a decision on mal-
function provisions in certain water pollution requirements ] ), the court dis-
tinguishes requirements that are technology based (e.g. nonattainment plans
based on RACT rather than attainment of ambient standards) from requirements
that are health based (e.g., SIP emission limitations for attainment of the
ambient standards). The enforcement discretion approach could be approved in
RACT SIPs if modified as set forth below. A State may choose, however, as
part of the RACT submittal not to provide a malfunction provision (i.e.,
Section 116). An acceptable malfunction provision for periods of excess emis-
sions could require a source exceeding applicable emission limitations to re-
port the five categories of information set forth in II above. The source
could be given the opportunity to demonstrate that the excess emissions re-
sulted from unavoidable production problems. Until such information is evalua-
ted by the State, issuance of a notice of violation (or some equivalent State
mechanism) would not be required. An approvable malfunction provision should
specify that if the source does not sustain its burden of proof to the State's
satisfaction, the excess emissions are a SIP violation and appropriate
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enforcement proceedings will be initiated by the State. If the source is
able to demonstrate that the ma.lfunction was genuinely unavoidable, it will
not constitute a violation of the emission limitation.
It should be understood that if over a period of time, application of
either the enforcement discretion approach or the source demonstration approach
does not significantly curtail malfunctions to the extent that they are the
cause of ambient violations, the malfunction portion of the SIP will either
have to be further revised by the State or EPA will have to disapprove the SIP.
IV. PHASING IN AND OUT OF EQUIPMENT, ROUTINE MAINTENANCE, BYPASS PROVISIONS,
AND PRODUCTION PROCESS EXCESS EMISSIONS
Any activity or event which can be foreseen and avoided, or planned falls
outside of the definition of sudden and unavoidable breakdown of equipment.
For example, a sudden breakdown which could have been avoided by better
maintenance procedures is not a malfunction. In such cases, the control
agency must enforce violations; of the emission limitation. Two such common
events are phasing in and out of equipment, and routine maintenance.
Phasing in and out of process equipment is part of the normal operation
of a source and should be accounted for in the design and implementation of the
operating procedure for the process and control equipment. Accordingly, it is
reasonable to expect that careful planning will eliminate violations of
emission limitations during E.uch periods. If excess emissions should occur
during routine phasing in and out of such equipment, the excess emissions will
not be considered as having resulted from a malfunction, unless the source can
demonstrate that such emissions were actually caused by a sudden and unfore-
seeable breakdown in the equipment.
Routine maintenance is a predictable event, which can be scheduled at the
discretion of the operator, and which can therefore be made to coincide with
maintenance on production equipment, or other source shutdowns. Most sources
have the ability to build and maintain inventory upon which the source can
draw during periods of shutdown for routine maintenance. Consequently, no
excess emissions may be allowed for periods of routine maintenance.
It is recognized that in certain circumstances, it is necessary to bypass
control equipment to avoid endangering life or sustaining severe property
damage. Such bypassing will not be considered a violation of a RACT SIP under
the source demonstration approach if the source sustains its burden of proof in
the excess emissions report, but will be considered a violation of the attain-
ment SIP under the enforcement discretion approach.
In addition to malfunctions, it is recognized that excess emissions may
occasionally occur during normal production processes, even when the control
equipment is well designed, operated and maintained. If the source can de-
monstrate, in its required excess emissions report, that it was operating the
plant according to the above malfunction criteria, and that it was scheduling
operations to preclude fluctuations, but that the emission limitation was
nevertheless violated for production reasons beyond the control of the source,
the excess emissions will not be considered a violation of the RACT SIP under
the source demonstration approach, but will be considered a violation of the
attainment SIP under the enforcement discretion approach.
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§IX.8050 Circumvention.
(a) No owner or* operator of a source of volatile organic compounds
subject to these Regulations may build, erect, install, or use
any article, machine, equipment, process, or method, the use of
which conceals an emission which would otherwise constitute a
violation of an applicable Regulation.
(b) Paragraph (a) of this section includes, but is not limited to, the
use of gaseous diluents to achieve compliance and the piecemeal
carrying out of an operation to avoid coverage by a Regulation
that applies only to operations larger than a specified size.
DISCUSSION
This section of the Regulations is designed to prevent circumvention of
the intent of the Regulations. This section, as written, only addresses the
concealment of a violation. There are other types of circumvention which
may be addressed in this section. An example of this is reducing the rate
of capture of VOC by a capture system.
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5XX.8060 Petition for Alternative Controls.
(a) The owner or operator of any source of volatile organic compounds
subject to these regulations may petition the Director to allow
the use of alternative emission limits, operational and/or
equipment controls fcr the reduction of volatile organic compound
emissions. The petition must be submitted in writing to the
Director before September 15, 1980, and must contain:
(1) the name and address of the company and the name and
telephone number of a responsible company representative
over whose signature the petition is submitted;
(2) a description of all operations conducted at the location
to which the petition applies and the purpose the volatile
organic compound emitting equipment serves within the
operations;
(Z) reference to the specific emission limits, operational
and/or equipment controls for which alternative emission
limits, operational and/or equipment controls are proposed;
(4) a detailed description of the proposed alternative emission
limits, operational and/or equipment controls, the magnitude
of volatile organic compound emission reduction which will
be achieved, and the quantity and composition of volatile
organic compounds which will be emitted if the alternative
emission limits, operational and/or equipment controls
are instituted;
(5) a schedule for the installation and/or institution of
the alternative operational and/or equipment controls
in conformance with the appropriate compliance schedule
section;
(6) certification that emissions of all other air contaminants
from the subject facility are in compliance with or under
a schedule for compliance with all applicable local, state
and federal laws and regulations; and,
(7) all additional information, requested by the Director,
necessary to determine whether the VOC emission reduction
achieved by the alternative controls is equivalent to the
emission reaction achieved by the applicable regulations.
(b) The Director may approve a Petition for Alternative Control if:
(1) TJie petition is submitted in accordance with paragraph
(a) of this section;
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(2) all other air contaminant emissions from the subject
facility are in compliance with, or under a schedule
for compliance as expeditiously as practicable with,
all applicable local, state, and federal regulations;
(3) the petition demonstrates that the aggregate VOC
emissions from the affected operations will in no
case be greater through application of the alternative
control plan than would be permitted through conformance
with the applicable VOC emission reduction regulations;
(4) the petition contains a compliance schedule for achieving
and maintaining a reduction of volatile organic compound
emissions as expeditiously as practicable, but no
later than the compliance date that would be required
under the applicable VOC emission reduction regulation;
and,
(5) a nuisance condition will not result from operation of
the source as proposed in the Petition.
(c) No alternative control plan is effective until it is submitted
to and approved by the Administrator of the United States
Environmental Protection Agency as a revision of the State
Implementation Plan pursuant to Section 110(a)(3)(A) of the
Clean Air Act.
DISCUSSION
This section of the general regulation allows the owner or operator of
a source of VOC to meet emission limitations through the use of alternative
emission limits, operational and/or equipment controls. This section addresses
occasions when a specific facility desires to meet an alternate emission
limitation which may be more cost-effective. This section can be used to
reduce the economic impact on a specific facility without changing the
aggregate emissions from the facility. Consequently this is the section that
would allow the "bubble concept" to be applied. The "bubble concept" implies
relatively more control, than would be required by the applicable regulation,
on sources with a low marginal cost of control and less on sources with a
high cost, thus achieving the same emission reduction for less cost. It is
important to note that the aggregate of the facility's emissions must be no
more than the aggregate of the emissions allowable by the applicable regulations,
Care should be taken in applying this concept so that the enforceability of the
regulations is not jeopardized.
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The Flat Wood Paneling industry will have numerous process change and
add-on control options available within the limits of the specific regulation.
However, the economics of meeting the specific emission limitations is going
to vary depending on the type, quantity and quality of the various products.
Therefore, it would be economically advantageous to the industry to allow
the bubble concept to be applied.
The Manufacture of the Synthesized Pharmaceutical Products Regulation
§XX.9400 is likely to address numerous small sources and few large sources
of VOC within any specific facility. This is a situation where it may be
advantageous to allow more stringent controls on the larger sources and less
stringent controls on the smaller sources than would be allowed by the
specific regulation.
In the Graphics Arts industry, a plant may operate many printing machines
each emitting varying amounts of VOC. The variation in emissions from each
machine may make it difficult to quantify emissions. Before the bubble concept
can be applied to the Graphic Arts industry, the person petitioning for
alternative controls must be able to quantify the uncontrolled emissions,
the emissions that would result iE the required emission reductions are met
and the emissions that would result if the proposed alternative controls
were implemented. If these quantities can be determined the bubble concept
may be applied to this industry.
Any state which desires to include a "Petition for Alternative Controls"
type of regulation should be thoroughly familiar with EPA's Proposed Policy
Statement on this subject which appeared in Volume 44, No. 13 of the Federal
Register on January 18, 1979 (44 FR 3740). As set forth in that Proposed
Policy Statement, both air quality and enforcement considerations are
pertinent to the development of an Alternative Controls section of an SIP.
The air quality considerations are:
1. Air quality standards must be attained and maintained;
2. Emissions under the alternative must be quantifiable and
trades among them must, be at least even, both from
mass emissions and air quality impact standpoints;
3. The trades must involve comparable pollutants (i.e.,
a VOC which has been determined to be hazardous can
not be traded with other VOC).
It is important to noi;e that any Alternative Controls regulation should
place the burden of proving quantifiable and even trades on the facility
proposing the trade.
A-16
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The enforcement considerations are:
1. All proposed alternative emission control provisions must be
submitted to EPA as alternatives or additions to the existing
SIP, not as a replacement for it. This is to ensure that
an enforceable SIP provision remains in effect, even if the
alternative emission control provision is not approved or is
unenforceable for any other reason.
2. Each emission point must have a specific emission
limit and a test method that insures enforceability.
3. Noncomplying sources should not be allowed to submit
alternative emission reduction proposals.
4. Final compliance must be achieved as expeditiously
as possible and no later than the date that would be
required under the applicable VOC emission reduction
regulation.
5. There should be no delay of existing enforcement
actions.
Finally, as of this writing, the statement at 44 FR 3740 is a Proposed
Policy Statement and, as such, there may be changes. States are reminded
that any alternative controls provisions they may propose should be compatible
with final EPA policy on this subject.
It is important to note that enforcement consideration number (2)
specifically excludes facility wide emission limitations or control alterna-
tives which allow variable emission limits for a specific source. It is
clear that, in order to be enforceable, an alternative control petition
must provide measurable, permanently established emission limits for each
source of VOC emissions that is affected by the petition.
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%XX.8070 Monitoring, Recordkeeping, Reporting.
(a) Monitors shall be •Ins-balled on all process and control equipment as
required by the Director. The monitors shall include visual and
audible alarms actuated when the monitored parameters exceed design
specifications. The monitors shall be calibrated at intervals
stated in the maintenance manual required under the Inspection,
Maintenance and Operating 'Procedures SXX.8030.
(b) (1) A daily written record shall be kept of all monitored
parameters, as required by the Director.
(2) Records shall be kept of all testing performed in
conformance with the appropriate Testing and
Monitoring Section.
(2>) A written record shall be kept of every time a monitor
alarm system is actuated. The record shall include
the date, time, duration and cause of the alarm actuation.
(4) All records required by this section must be main-
tained in a legible, readily available condition for
at least two (2) years after the date on which the
record was made.
(a) (1) The owner or operator of a volatile organic com-
pound emission source subject to these regulations
shall submit to the Director, as a minimum, annual
reports detailing the nature, specific sources, and
total annual quantities of all volatile organic
compound emissions. However, the Director may require
more frequent reports where necessary to accomplish
the purposes of these Regulations.
(2) Copies of all records and reports under this section
shall immediately be made available to the Director,
upon verbal or written request, at any reasonable
time.
DISCUSSION
Control equipment monitors are essential to determine continuing compliance
with regulatory requirements. Specific monitoring requirements are often
included in construction and operating permits; however, it is left to the
Director's discretion to choose the specific parameters to be monitored, when
permit requirements are lacking.
A-18
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The following monitoring devices should be considered by the Director
for major sources:
(1) A device to determine breakthrough in carbon absorption equipment
which is connected to both a direct readout meter and a device
that initiates regeneration;
(2) A device to monitor exit gas temperature on incineration
equipment;
(3) A device to measure condenser outlet gas temperature; and
(4) Devices to measure scrubbing liquid flow rate and the pressure
drop of the gas stream across a scrubber.
Records are required for monitored parameters, emissions tests and
alarm system actuations. The period should be sufficiently long to allow for
averaging of emissions, if needed, and completion of any enforcement cases.
A-19
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American Petroleum Institute
2101 L Street, Northwest
Washington, D.C. 20037
202-457^000 7084
July 19, 1979
Mr. Tom Williams
Control Programs Development
Division, MD-15
Environmental Protection Agency
Research Triangle Park
North Carolina 27711
Dear Mr. Williams:
This is in response to your June 25, 1979 request for comment
on the sample regulations for Group II Control Technique Guide-
lines on Volatile Organic Coumpounds.
Enclosed are our technical comments on the draft which like CTG's,
we understand to be guidance documents to the states as they
formulate SIP implementation.
If there are questions on the comments please contact me.
Sincerely,
Edward P. Crockett
EPC/fh
Enclosure
B-5
An equal opportunity employer
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Comments of the
AMERICAN PETROLEUM INSTITUTE
on
Sample RACT Regulations for the
Control of Volatile Organic Compounds
A. GENERAL COMMENTS
1. A serious concern is the manner in which tne sample
regulations expand upon and alter the provisions of the Control
Technique Guidelines (CTGs) published by EPA. The CTGs were
generally based upon the best available data at the time of their
promulgation. Industry input and review of drafts was sought.
In the case of the refinery equipment leak CTG, the petroleum
industry cooperated in the conduct of an extensive research
effort in support of its development and participated in a number
of meetings as well as a three day workshop. Yet these model
rules then subvert those carefully worked technical provisions by
editorially imposing more stringent requirements without justifi-
cation, without explanation of their scientific or emperical
basis and without assessment of their cost effectiveness. An
example of such arbitrary treatment is the imposition of inspec-
tion schedules and record keeping requirements in excess of those
contained in the CTGs. Other specific cases are noted tnroughout
our detailed comments.
2. The designation of a technology as RACT must consider
economic feasibility. Similarly, the implementation of RACT
should consider economics in terms of demonstrating tnat tne
environmental benefits .to be derived are commensurate witn tne
costs and inflationary impact to be incurred. In tnis regard,
you are referred to the cost information submitted with API
B-6
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letters of May 12, 1978, and November 22, 1978, in response to
the proposed CTGs on refinery equipment and external floating
roof tanks.
3. An excessive amount of record Keeping and reporting is
stipulated in the sample regulation. Certainly, some degree of
record keeping is an essential part of demonstrating compliance.
In fact, the published CTGs contain realistic reporting require-
ments. Why are they ignored? The collection and reporting of
unduly voluminous data does not serve directly to reduce emis-
sions. On the contrary, it unnecessarily consumes the valuable
time of engineers who might better devote their time to running a
tight, e-fficient pl-ant. Numerous suggestions are offered in tne
detailed comments to reduce the paperwork without compromising
the needs of compliance.
4. Explicit compliance dates appear throughout the draft.
These specific dates are out of place in a guidance document
intended to be "illustrative in nature." In adhering to the
basic SIP compliance date of December 1982, the states must be
allowed to prepare their own schedules, taking into account local
conditions.
B. SPECIFIC COMMENTS
PART I -- GENERAL DEFINITIONS
Source
Consistent with the court decision in Alabama Power et al.
v. Costle, Nos. 78-1006 and Consolidated Cases (D.C. Circuit,
B-7
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June 18, 1979}, this definition should conform to tnat in the
Clean Air Act.
Vapor Control System
Delete the phrase "at least 90 percent by weight." It is
inappropriate to include a specific control efficiency in a
general definition.
Volatile Organic Compound and Organic Material
These definitions should be consistent with EPA's "Recom-
mended Policy on Control of Volatile Organic Compounds (42 FR
35314 — 316, 7/8/79), namely: "Volatile organic compound:
(also denoted as VOC) means any compounds of caroon except carbon
monoxide, carbon dioxide, carbonic acid, metallic carbides or
carbonates, ammonium carbonate, methane, ethane, 1,1,1-trichloro-
ethane and trichloro-trifluoroethane."
Vapor pressure has no place in a general definition. Vapor
pressure is applied in specific instances, e.g., floating roof
tank guidelines, where low volatility stocks are exempted because
control is not cost effective.
Malfunction
This term should be defined. It is used in various sections
of the document.
Bo
— o
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PART II —
SECTION 9000 PETROLEUM REFINERY EQUIPMENT LEAKS
Section 9010(h)(2) -- Delete the phrase "flanges and other
connections." The EPA-Radian refinery study found that flanges
are a negligible source of leakage and are excluded from the CTG.
"And other connections" is too vague a term to be included in
a regulation.
Section 9020 — The inclusion of pilot plants and facilities
used for chemical or physical analyses goes beyond the CTG. Tne
magnitude of these emissions should be estimated and the cost
effectiveness determined before EPA suggests bringing fugitive
emissions from research laboratory facilities under regulation.
Low volatility liquids should be excluded as in the case of
floating roof tanks.
The exemption threshold should be 0.1 psia, not 0.011
psia.
Discussion -- paragraph 2 -- The EPA-Radian refinery study
indicates that "heavy liquid service equipment" in petroleum
refineries have a low propensity to leak. Therefore, a comment
should be included to provide for change in future refinery
guidelines to that effect.
Section 9030(a)(1) -- The operator is required to include a
leaking component on a written list of scheduled repairs within
24 hours after the leak is found. As GCA noted, this goes beyond
the CTG. It is an unnecessary requirement and will not serve to
B-9
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stimulate the operator's intention nor ability to repair the
component in a timely manner. Recording of the component inspec-
tion date alone on the work order and the requirement to repair
the leak within 15 days is sufficient to expedite work orders.
Section 9030(a)(2) — Restate to conform to CTG wording,
"... make every reasonable effort to repair the leak within
fifteen (15) days."
Section 903Q(b) — Sample lines and bleeds between double
block valves should be exempt or, as an alternative, exempt
fittings on all lines one inch or smaller until a cost effective-
ness analysis is performed to demonstrate the need for control.
Section 903Q'(c) -- As presently worded in the aosolute,
a refiner might have to cease an operation in order to remarK
a component the moment its identity became ooscure. Reword
to preclude such unreasonable enforcement by such pnraseology
as, "Pipeline valves, and pressure relief valves in gaseous
VOC service will be marked in some manner which is oovious to
both. "
Discussion — '"repair" is misspelled in last sentence of the
second paragraph.
Section 9040(a) -- Notification of purchase or ownership of
VOC monitors is an unnecessary requirement. The operator snould
merely indicate on the report what instrument was used. The
refiner may contract the work and not ever own an analyzer.
3-10
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Section 9040(b) — The requirement to submit a monitoring
schedule goes beyond the CTG. Its benefit is questioned in view
of the unreasonable burden it imposes. This might result in a
listing of 10 to 20 thousand components in a refinery. At most,
all that should be required is scheduling by unit.
Discussion — Specific quarterly submission dates should not
be stipulated. This type detail should be left to the refinery
and local authority to work out to their mutual advantage. Some
regulatory offices will be overwhelmed with paper if all submis-
sions are due on the same date.
Section 9050 Discussion -- Spot checks of recently monitored
components by regulatory personnel is proposed as a means of
preventing "circumvention" of monitoring procedures. A leaking
component so identified by an agency spot check is not proof
of "circumvention." As both the EPA-Radian work and the API-
Rockwell study clearly reveal/ components may leak on an inter-
mittent or variable basis.
Section 9060(a) — As written, this section could be inter-
preted to require that records be maintained on every component
in a refinery whether it leaks or not. This could amount to
40,000 records in a 100,000 barrel per day refinery. At most,
records should be required only on those components found to
exceed the action level.
Section 9060(b)(5) — The language of the CTG snould be
incorporated for relief valve monitoring and repair. The CTG
B-ll
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recognizes that relief valves are inaccessible to inspection with
a portable instrument. The horn on a relief valve, which vents
the material, usually extends well above an access platform,
making it extremely unsafe to reach with an instrument probe. A
visual inspection is sufficient to determine whether a relief
valve has seated properly.
Explicit exemption should be made for inaccessible valves.
Some valves on top of columns and vessels would require construc-
tion of special scaffolding to monitor.
Section 9060(d) — The details of leaker marking should be
left to the operator. For example, all information concerning
leaks might be conveniently stored in a computer in whicn case
only an identification number is needed on the tag.
Section 9Q60(e) — The submission of a quarterly report of
leakers not repaired is excessive. It is recommended that the
records be maintained in the refinery and made available to
inspectors on request.
Section 3060(f)(3) — Requiring listing of the stream
composition on the log components is unnecessary. One needs only
the component identification number to locate it.
Section 9060(g ) — Requiring records to be kept for four
years is arbitrary, excessive and serves no useful purpose. The
object of record keeping is to demonstrate the current status of
regular monitoring. Maintaining records for one year satisfies
this objective adequately. An absolute maximum period would be
the 2 year CTG provision.
B-12
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Discussion -- Paragraph 2 -- The 1 minute monitoring esti-
mate is low. An actual experience in a large refinery showed 1
to 1-1/2 minutes per on-plot valve and 2 to 10 minuts for each
off-plot valve.
Section 9070(c) -- Essential components which would require
process unit shut-down to repair should be automatically exempt
from the 15 daqy repair and variance request requirements. They
would be repaired during the next scneduled shut-down. The paper
work associated with variance requests for every case is overour-
densome for both operator and regulator.
Section 9070(e)( 1 ) -- The term company officer should be
replaced with "responsible company representative." The term as
written could be construed to mean corporate officer. In a large
company such officers are far removed from tne details of day to
day refinery operations.
SECTION 9700 PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING
ROOF TANKS
Section 9710(b)(7) -- The definition of vapor mounted seal
is confusing. Use the identical definition of the CTG.
Section 9710(b)(8) -- Waxy, heavy pour crude oil snould be
defined as, a "crude with a pour point of 30°F or higher or with
a Reid Vapor Pressure (RVP) less than 2 psia." This is based on
the fact that the analytical procedure for determining RVP (and
ultimately true vapor pressure using API 2517, "Evaporative Loss
From Floating-Roof Tanks") requires a sample transfer at 32-40°F.
B-13
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If a crude does not pour at those temperatures, a valid RVP
measurement cannot be obtained. If a crude RVP is less than 2
psia, a valid true vapor pressure could not be readily obtained
from API 2517. In each of those cases, it would be impossible to
accurately judge whether a crude should be controlled under the
true vapor pressure requirements for these regulations.
Section 9730(a)(2)(iii) — Delete the 1/2 inch gap require-
ment. No such provision appears in the CTG and no discussion or
basis for this arbitrary limit is offered.
Section 9730(b)(1) — The montnly inspection requirement is
unnecessary, unreasonable and inconsistent with the CTG wnich
indicate-s annual inspections. Tne basis stated in the Discussion
section "... to be consistent with regulatory guidance for fixed
roof tanks" is both erroneous and irrelevant. The CTG for fixed
roof tanks specifies 6 months or snorter. Furthermore, fixed
roof tank requiremetns in this regard bear no relationship to
external floating roof tanks.
Section 9730(c) — It is recommended that the record keeping
threshold be changed to 1.5 psia. This would have the effect of
excluding a fair number of tanks from the record keeping process
but would make very little difference in the emissions recorded.
For example, the difference in emissions from a 100 foot tank
storing 1.0 psia stock and one storing a 1.5 psia stock is
approximately 1 ton per year (assuming neither is equipped with a
secondary seal). _ ...
—
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Section 9730(d) -- Submission of annual reports is unneces-
sary. Records should be maintained by the operator and available
upon request to inspectors. Furthermore, information on content
amounts and physical properties is excessive. Gap criteria
information is the critical requirement and is the only item
which should be mandatorily recorded. Physical properties
apparently refers only to vapor pressure and snould be so stated
if retained as an entry.
Section 9730(e) — Requirement for maintaining records on
file should not exceed the 2 years specified in the CTG.
Discussion — paragraph 1 discusses "demand gap measurement
for non "vapor mounted seals and more frequent gap measurements
for vapor-rnounted seals." Based on current test programs, these
considerations are not consistent with potential emissions levels
that might be found as a function of different seal types and gap
configurations. The CTG should be followed explicitly until the
new API Bulletin on evaporative loss from floating roof tanks is
published in late 1979. Discussion of tank and seal effect on
emission levels in the bulletin will permit proper technical
assessment.
Delete item 3 (page 1-8) regarding throughput. Floating
roof tank throughput has an insignificant effect on emissions.
SECTION 9900 LEAKS FROM GASOLINE TANK TRUCKS AND VAPOR COLLECTIOiN
SYSTEMS
Section 9910 — A definition of "submerged filling" is
needed. B-15
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Section 9930(a) -- Simplify this confusing paragraph by
rewording to the effect that, "no owner, operator or driver of a
gasoline truck subject to the regulation shall allow the loading
or unloading or other use or operation of such vessel unless it
has a valid certification of vapor integrity and displays a
sticker issued by the regulatory authority." The test criteria,
frequency for testing and procedures for issuance of stickers
should be described separately.
The intent of the present wording to hold owners of loading
facilities responsible for policing transport vehicles is under-
stood, but tnis is a:n inequitable assignment because a large
number of loading facilities are "key-lock" types which are
unmanned. The promulgation of this requirement would reduce
productivity by requiring the "owner or operator" of tne loading
facility to provide personnel to double check tne operation of
the truck owner or operator who should properly be the respon-
sible party.
Section 9930(a)(2) -- The three inch delay pressure in five
minutes is arbitrary and unnecessary. Recent analytical work has
shown that losses from tanks which have pressure changes of less
than six inches of water during the pressure test have infinites-
simally small leaks during transit.* It is recommended that
"Setting a 95 percent Vapor Recovery Standard" R.A. Nichols
Engineering, !i19 Iris Avenue, Corona del Mar, California
92625.
B-16
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a six inch water pressure delay be incorporated. It will have no
measurable effect on emissions. The vacuum requirement should be
retained.
Section 9930(b) -- This section is unnecessarily verbose and
should be restated as, "The vapor collection system shall operate
within the specified pressure limits and shall not nave vapor
leaks greater than the specified readings above background or
liquid leaks."
Section 9930(b)(1 ) (i) — This section should be deleted.
Pressure in the truck per se should not be considered in this
regulation as atmospheric emissions are the true concern and
compliance can be amply determined with other methods.
Section 9930(b)(1)(ii) — The use of an explosimeter should
not be used as the only criteria for determining leakage.
Preliminary results of tests done by Western Oil and Gas Associ-
ation (WOGA) indicate that the explosimeter is strictly a leak/no
leak device. Implicit in the tank truck pressure delay test is
the premise that a certain amount of leakage from tanks is
allowable. The use of the explosimeter effectively precludes any
leakage during product transfer at the loading racK.
It is recommended that a tiered test system be employed to
determine if there is leakage during loading. The modified test
procedure would work as follows:
(1) During truck loading, check tne collection system
with the explosimeter -- if there are no leaks as defined in
B-17
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(b)(1)(ii) the truck passes. If the truck fails tne explosimeter
test, a leakrate test of the system should be performed.
(2) The leaKrate test is accomplisned by blocking the vapor
return line returning to the vapor processor. The tank is
pressurized with bottled nitrogen to a nominal loading pressure
(approximately 6 to 8 inches of water) and the leakrate measured
with a rotometer. The allowable leakrate would be based on the
size of leak allowed by the tank pressure test in (i) wnicn is
approximately one percent.
The leakrate tesr has several advantages. It allows a small
amount of leakage during loading which is less than that allowed
by the pressure test. It takes into account tne size of the tank
being filled. Smaller tanks are allowed less leakage than larger
ones. Small leaks which are difficult to fix but nave no signi-
ficant air pollution impact can be evaluated and allowed to
remain if they are within the guidelines. WOGA will soon issue a
report on this method.
Section 9930(b);2) — It is assumed that the reference to
"subparagraph (c)(1)(ii)" snould be "(b)(1)(ii)."
Section 9940 -- Delete specific dates. See paragraph 4,
General Comments. Schedules should be specified in terms of
months following promulgation of the regulation.
Section 9950(a) — The owner or operator of a "source" can
only be responsible for his side of the vapor recovery system.
He may refuse to load vehicles which are out of compliance, but
B-18
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he cannot be responsible for the integrity of the inspection
procedure.
Change the last sentence to read, "All tests shall be made
in tank truck maintenance shops."
Section 9950(b) — The requirement to notify "the Director
in writing" at least 30 days before a certification test (presum-
ably of a tank truck) is scheduled, with the provision that the
Director may reschedule the test is unjustifiably arbitrary. One
or two days notice should suffice.
Section 9960(a) — Maintaining records for 4 years serves
no useful purpose. Two years should be the absolute maximum
requirement. —
Section 9960(c)(1) — Change "company officer" to "company
representative." The responsible supervisor should be the one to
sign the certificate, not a far removed corporate executive.
Discussion -- The suggestion that a summary of recent
testing and monitoring information be kept with the truck would
only increase the paperwork to administer the program to an
unreasonable extent.
PART III --
SECTION 800 GENERAL PROVISIONS
This section appears to be unnecessary. In places it is
too brief or generalized. Some of its provisions may overlap
specific equipment and procedure regulations. Breakdown and
B-19
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malfunction provisions usually found in existing SIPs are ade-
quate. Most require only notification and from tnat point on the
local authorities have several options to include tne imposition
of penalties.
Section 8020(a) -•- Tne 1.5 gallon/day limitation seems to be
not only arbitrary and extreme out is impossible to apply without
further explanation or rationale. What is the basis of this
number? Does "person" have a special meaning in this case? By
the definition at page H-2, "person" means "firm, company,
corporation." The 1.5. gallon/day on a cumulative basis is
unreasonable for an entire large refinery, to say nothing of a
large corporation with numerous refineries.
The term "disposal" should be defined.
B-20
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R n ; r1 -
U J ^i_j^
ENVIRONMENTAL AFFAIRS
D P Martin
v A ', A G E R
T J Beachar
^IRL'^TOR
W T. Wells
RE"TOR
R C. Lieber
ADVISOR
P O Box 2OO1
Houston TX Y7OO1
July 20, 1979
Mr. Tom Williams
Control Programs Development Division, MD-15
Environmental Protection Agency
Research Triangle Park, NC 27711
Dear Mr. Williams:
Re: REVIEW OF A GUIDANCE DOCUMENT FOR THE GROUP II CONTROL
TECHNIQUE GUIDELINES FOR VOLATILE ORGANIC COMPOUNDS
Vie have reviewed the document sections pertaining to
volatile organic compound leaks from petroleum refinery
equipment as requested in your June 1979 letter to all
interested parties. It is our understanding that EPA will
submit the guidance document to the states for their use in
revising State Implementation Plans (SIP) to meet the require-
ments of the Clean "Air Act Amendments of 1977. Our comments
are as follows:
First of all, it is our opinion that the detail and
time consuming requirements of the document guidelines with
respect to refinery equipment leaks is counterproductive
to ''improving government regulations" in accordance with
Executive Order 12044. The President's purpose was to stream-
line regulations and eliminate unnecessary red tape and paper
shuffling.
We believe it is unwise to divert technically trained
personnel from the task of energy product production to
engage in a mandated effort of monitoring for leaks with all
the necessary preparation, calibration, recordkeeping, filing,
retrieval, report writing, etc. This type of activity is
routinely provided for in normal everyday operations without
the associated burdensome reporting to government agencies
and approvals, certifications, and review by a third party
not involved with the production of energy products for the
consuming public.
B-21
2 HOUSTON CENTER
909 FANNIN bTREET
F GULF QI [_ CORPORATION
-------
Mr. Tom Williams
July 20, 1979
Page 2
A monitoring schedule with all its associated require-
ments will require a substantial number of man-hours. The
results obtained by the use of the proposed procedures and
approved equipment are questionable at best. Maintenance of
leaking hydrocarbon equipment is normally performed without
the oversight of an outside agency because of safety considera-
tions and conservation of valuable hydrocarbon material. It
is just good business to conserve energy by operating refinery
processes and equipment in an efficient manner.
In connection with "Petitions for Alternative Controls,"
there is not any reasonable justification to require the approval
of a control agency whose personnel are most likely to be less
knowledgeable in petroleum refinery operations than persons
experienced in the manufacture of petroleum products who cur-
rently make such decisions on a routine basis. It is admitted
in the discussion that the potential amount of paperwork is
great. All this unnecessary involvement by the EPA will add to
the cost and further retard the efficient production and supply
of petroleum products.
Various time periods will be required to repair leaks,
depending on the urgency with respect to safety, fire hazard
or loss of material, availability of parts, etc. Fifteen days
could be short in some cases. The allowable repair period
should be extended to 60 days to allow greater flexibility in
repair scheduling and sufficient time to obtain necessary parts.
Most routine type leaks would not require that much time for
repairs. However, a minor leak could occur in some cases and
be subject to the regulations, which would require facility
shutdowns that would impact adversely on energy product supply
and substantially increase emissions of volatile organic
compounds.
It is noted that the time frame between the effective
date of the regulations and the due date for the first monitor-
ing report is eight months. This is probably unrealistic when
considering the quantity of monitoring equipment required by
the industry, preparation of schedules, providing for inacces-
sible components, etc. A minimum time period of twelve months
would be more appropriate.
Very truly yours,
D. P. Martin
WTW:lb B~22
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Shell Oil Company
One Shell Plaza
P O Box 4320
Houston Texas 77210
July 18, 1979
Mr. Tom Williams
Control Programs Development Division
MD-15
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
Dear Mr. Williams:
This is in response to your request for review of the draft guidance
document prepared to assist the States in preparation of RACT
regulations for the Group II CTG's.
Before offering comment on the specifics of the sections sent us for
review, we must strongly voice our objection to the preparation and
distribution of this document under the guise of a "guideline" which is
"not to be construed as rulemaking by EPA." We have, in the past,
expressed our concern to the EPA that the CTG's themselves and the
instructions to the states have in effect set regulations which must be
followed if a state is to have an approvable SIP. All of this has
occurred without proper rulemaking procedures and, as such, violates the
Administrative Procedures Act. This particular "guidance" document
carries this illegal type of rulemaking even further by essentially
dictating the exact wording a state must adopt in its rules in order to
have an approvable SIP.
We do not believe that this document is proper EPA action. If the
agency indeed adheres to the position that the states are free to adopt
any set of regulations which accomplish the same purpose as the CTG's
would, there should be no reason to issue this document.
We, therefore, recommend that this proposed "guidance" document be
withdrawn - or in the alternate that it be subject to the proper
rulemaking procedures as required by the APA.
In regard to the specific sections of the proposed document, we offer
the following:
GENERAL DEFINITIONS
"Breakdown": We do not believe that it is necessary to include
possible causes in order to define "breakdown." The definition
should read:
B-23
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A failure of an emission control device or emission monitoring
equipment to function as designed.
We note that there is no proposed definition for "malfunction" even
though that term is used in several "regulations." We do not
believe that such a definition is necessary; however, if the EPA
intends to make a distinction between "breakdown" and "malfunction"
then a separate definition should be included.
"Control Device": The proposed definition does not include equipment
that prevents the creation of an air pollutant. A floating roof
on a stc.age tank is an example of this type of equipment. The
agency has, in the past, always considered floating roofs to be
control devices.
"Facility" and "Source": The definitions proposed here are not
consistent with those used in other EPA areas - such as PSD.
They are also not consistent with the recent court decision
on the PSD challenge.
"Volatile Organic Compound": This definition is overly restrictive
and serves no purpose other than to unduly complicate regulatory
efforts. Furthermore, it is not consistent with the definitions
used in most SIP's nor that used by EPA in its SIP regulations.
This definition should be left to the discretion of each state.
PETROLEUM REFINERY EQUIPMENT LEAKS (xx.90QQ)
xx.9010
The definition proposed for "petroleum refinery" is not
consistent with that used in the NSPS. This will cause
confusion in state plans.
It is not known what is meant by the last sentence in
this definition.
A definition should be provided for "pipeline valve".
We suggest that it be defined to exclude sample valves,
bleed valves and bypass valves.
xx.9020
We do not believe that pilot plants or facilities used
for analysis should be covered by this regulation. These
facilities were not included in the CTG document nor were
they studied by Radian in the supporting studies. There
has been no estimate of the leaks from this equipment nor
the cost effectiveness of these control.
B-24
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xx.9030
(a) (1)
(a) (2)
A specific written list of scheduled repairs is not necessary.
The rule should be flexible enough to allow sources to inte-
grate their leak maintenance program with their already estab-
lished other maintenance programs. Job tickets are one
example of a method of "listing" leaks.
No recognition is made for the leak which cannot be repaired
within the 15 day period. The CTG recognized that in some
cases this would occur or that their repair would cause even
greater emissions than those which would occur if the leak
were allowed to continue until the next scheduled shutdown.
This situation must be provided for in any regulation.
xx.9040, xx.9050, xx.
9060
xx.9040
xx.9050
xx.9060
xx.9070
The regulations offered in these sections provide for only one
method of leak detection and monitoring. There are other
acceptable methods available, many of which have been approved
by the EPA under NESHAPS. We object to offering only one
option to the states when others may be more effective for a
particular situation. No provision is made to allow approval
of an alternate plan.
Each state should be permitted to set its own compliance plan
and schedule.
Each state should be permitted to determine its own method of
testing compliance.
Again, each state must be allowed to determine its own method
of recordkeeping and reporting.
This entire action should be deleted. Each state should set
its own alternative procedures and methods for providing
variances.
B-25
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PETROLEUM LIQUID STORAGE! IN EXTERNAL FLOATING ROOF TANKS (xx.9700)
xx.9710
As discussed, it is necessary to exempt "waxy, heavy pour
crude oil" from this regulation because of the tank wall and
wax deposition problem. In our experience, we believe that
crude oils with a cloud point more than 15°F above ambient and
a pour point at ambient or above will cause a significant wax
buildup which will lead to failure of the tank seal or roof.
xx.9720
xx.9730
The temperature at which the true vapor pressure should be
determined is not defined. Usually this is specified to be
actual storage conditions.
Subpart (b) (1) requires monthly inspections to insure com-
pliance with subpart (a). This would include some type of
inspection which includes measurement of seal gaps. As
indicated in Subpart (b) (2), this measurement is intended to
be made only annually. Therefore, subpart (b) (1) should
read:
"perform routine inspections once per month in order to
insure compliance with part (a) of this section [except
part (a) (2) (iii)]
Subpart (b) (3) is an unnecessary requirement.
A person who has met the remaining requirements has
fulfilled the intent of the regulation. A record of
throughput or types of liquids has no bearing on com-
pliance.
Subpart (c) is also an unnecessary regulation. The
reasons that a storage vessel may not be subject to the
regulation could be any of those listed in xx.9720. The
vessel could be too small; contain crude oil prior to
custocy transfer; contain waxy, heavy pour crude oil; or
be exempt because of the type of construction. If this
is the case, the records of vapor pressure, temperature,
type and throughput serve no useful purpose.
In Subpart (d), the submittal of records should be left
to the discretion of the State agency.
B-26
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xx.9740
This section of the regulation suddenly switches to the term
"volatile organic compounds" instead of "petroleum liquid".
It would appear that confusion will result unless consistency
is maintained.
Furthermore, the entire compliance section should be deleted.
Each State should determine its own schedule based on input
from the industry involved at any public hearings.
GENERAL PROVISIONS
This entire set of regulations should be deleted. We are not aware of
any CTG which has been issued which covers the issues addressed here.
As discussed above, we feel that the issuance of detailed regulations,
based on CTG's without formal rulemaking procedures is improper. In
this case, there have not even been CTG's prepared on which these
regulations could be based.
Many of the provisions in these regulations are no more than harassment
techniques and serve no purpose in reducing air pollution. The record-
keeping, training manual and operator qualification sections are
totally unjustified. Such requirements will lead to highly increased
operational costs with no realization of benefit.
The agency has cited at least two references as the basis for its draft
regulations covering Breakdown, Malfunction and Operation Changes
(xx.8040) which are clearly improper. The so-called "Workshop
guidelines and a proposed policy statement published in the "Federal
Register" are hardly valid justification for the requirement that states
adopt the proposed or model regulations.
Very truly your,s,
Haxby, Manager
Environmental Regulatory Analysis
JAM:hg
B-27
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Union Oil Company of California
Union Oil Center, Box 7600, Los Angeles, California 9005
Telephone (213) 486-7538
ES79-402
uni*n
E-D-Blum July 19, 1979
Coordinator Environmental Programs
Mr. Tom Williams, Project Officer
Control Programs Development
Division, MD-15
U.S. Environmental Protection
Agency
Research Triangle Park,
North Carolina 27711
Dear Mr. Williams:
We appreciate the opportunity to comment on the draft suggested
RACT regulations for control of volatile organic compounds
that will eventually appear as EPA guidance to the states.
We received a request for review and comments on Sections A,
B, and L direct from you. Union Oil also received a copy of
Section K via the American Petroleum Institute.
This letter contains our comments on all four sections. For
ease of reference, the comments appear in the order of the
draft document.
Definition of Volatile Organic Compound (p. A-4)
We strongly urge that both methane and ethane be added to the
list of compounds that are excluded from the definition of
volatile organic compounds (VOC) for the following reasons:
-- Methane and ethane are generally recognized as having very
low or negligible photochemical reactivity. In fact, EPA's
"Recommended Policy on Control of Volatile Organic Compounds"
that appears as Appendix B in EPA document EPA-450/2-77-008
(OAQPS No. 1.2-073) dated May, 1977, specifically states that
methane and ethane should be exempt from regulation under
state implementation plans (SIPs) .
B-28
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Mr. Tom Williams
July 19, 1979
Page 2
-- Many states are already adopting regulations for control
of VOCs as a part of their SIP review process. Many of these
regulations exclude methane and ethane from the definition
of volatile organic compounds. Failure to exclude these
compounds in the suggested regulations can only lead to
confusion and unnecessary regulatory revisions. Past
experience tells us that the states have a tendency to accept
EPA "guidance" as a mandate rather than the suggested guidance
intended by EPA.
-- If EPA intends that methane and ethane are to be included
as VOCs, it follows that all pipelines that carry natural
gas should be subjected to fugitive emission regulations.
This would impose what would appear to be an intolerable
burden on the natural gas supply and distribution industry
considering the literally millions of valves that would
have to be monitored.
Section XX.9050(a)(2) (p. B-4]
This section requires repair and retesting of leaking components
within 15 days. It does not specifically address the problem
of the leaking component that cannot be successfully repaired
while the equipment is operating. This problem is covered in
Section XX.9070(c) which allows the owner or operator to
petition for a variance until the next shutdown. We suggest
that Section XX.9070(c) be referenced in Section XX.9030(a)(2).
Section XX.9060(b)(2) (p. B-9)
This section requires that all pipeline valves in gaseous service
be monitored quarterly. Consistent with the earlier comment
that methane and ethane be excluded from the definition of VOC,
we urge that valves in lines that handle only methane and
ethane be excluded from this requirement.
We also feel that pipeline valves in inaccessible locations
that are normally either open or closed (i.e. block valves)
should be excluded from the quarterly monitoring requirement
provided that the valve is not found to leak during the initial
inspection.
Section XX.9060(e)(1) (p. B-10)
Tt is unreasonable to expect anyone to submit a report of moni-
toring activities on the first day of the new quarter. We
suggest that reports be required no earlier than the ISth of
B-29
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Mr. Tom Williams
July 19, 1979
Page 3
January, etc.
In any event, requiring a report in September is not consistent
with reports in January, April, and July. We suspect this is
an oversight and that October is what was intended.
Section XX.9910 - Definitions (p. K-2)
§XX,9910(b)(7) "Vapor Collection System"
This definition is inconsistent with the definition of vapor
collection systems on page A-4 of Part I. Also, the term
"direct displacement by the gasoline being transferred to
force vapors ..." may be confusing to someone not practiced
in the art and furthermore may not even be appropriate in
some collection systems. We suggest that both definitions
be rewritten as follows:
"Vapor Collection System": A vapor transport system which
directs vapors from the vessel being loaded into either
the vessel being unloaded or a vapor control system.
§XX.9910(b1(8) "Vapor Control System" (p. K-5)
This definition is consistent with the definition on page A-4
of Part ]. We believe that it is not appropriate to include
the control effic Lency of a vapor control system in these
definitions. Control efficiencies are more appropriate
in the body of the regulations. This would allow specifica-
tion of different control efficiencies for different types
of installations, for example. We suggest that the definitions
be rewritten as follows:
"Vapor Control System": A system that controls the release
to the atmosphere of volatile organic compounds in the
vapors displaced from a vessel during transfer of gasoline.
Section XX.. 9930(b) (1) (ii) (pp. K-5-6)
This section requires that leak testing be done by the method
referenced in the CTG EPA-450/2-78-051. We believe that
equivalent leak test methods should be permitted and suggest
that the following be added at the end of the section: "or an
equivalent procedure approved by the Director."
B-30
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Mr. Tom Williams
July 19, 1979
Page
Section XX. 9950(10
Section XX.9950fa) requires that the owner or operator demon-
strate compliance at his expense. Section (b) as written would
allow the Director to postpone or reschedule a compliance to
suit his convenience. It is clearly the responsibility of
the owner/operator to schedule compliance tests. The Director
can request that tests be rescheduled; he should not reschedule
them on TTTs" own.
Section XX.9950(c) (p. K-10)
The last sentence is more appropriately a part of the test
procedure and should be deleted from this section.
Section XX. 9950 - Discussion (p. K-ll)
The first paragraph again refers to the Director scheduling
compliance tests. We believe that test dates must be by mutual
agreement of the involved parties as equipment must be taken
out of service to perform the test. We again emphasize that
it is not appropriate for the Director to schedule tests.
If you have any questions, I will be happy to try and answer
them.
EDBrnjr
cc: Mr. Dick Southard: API
B-31
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DEERE & COMPANY
JOHN DEERE ROAD MOMNF UMNO'S 612C"> USA
Safety & Environment
9 July 1979
Mr. Tom Williams
Control Programs and Development Division, MD-15
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Dear Mr. Williams:
Deere & Company Comments
Guidance Document for Group II
Control Technique Guidelines
for Volatile Organic Compounds (VOC)
We appreciate the opportunity to review the guidance document being
prepared to assist state and local agencies in preparing Reasonable
Available Control Technology (RACT) regulations. Our comments are
as follows:
1. Page C-7, § XX.9130(c)(3);
"Equivalent means of VOC removal" could include combustion
processes other than incineration. It should be possible to
approve an alternative combustion process such as sending the
VOC exhaust through an existing furnace or other burner at
efficiencies less than 90%. This would not eliminate
alternatives that would reduce VOC emissions by capturing
some of the energy available in the compounds. Such schemes
might meet the 3,5 Ib. /gal. criteria while destroying less than
90% of the VOC. These options should not be limited by the 90%
efficiency requirement applied to incinerators.
2. Page C-9, § XX. 9140:
The development of alternate compliance schedules by major
sources will not be an infrequent occurrence. The guideline
should point out that there will be many legitimate requests
for alternative compliance schedules. There are several
reasons for this. First, most large sources will use a
combination of low solvent coatings, process equipment changes,
and add-on control devices so that neither schedule presented
B-35
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DEERE & COMPANY
Mr. Tom Williams
9 July 1979
Page Two
in the guideline would be applicable. Second, inmost cases,
changing to a flow solvent content coating requires more than
just changing paints. For example, most existing systems
require additional washing facilities and forced-air ovens
before the conversion to waterborne coatings can be made.
Planning and engineering these changes in addition to switching
to low solvent coatings will take additional time. Third, in
many cases, it maybe more economical to replace existing
systems with new processes that require significant modifica-
tions to other manufacturing areas along with the surface
coating area. Fourth, OSHA and energy conservation consider-
ations will expand the scope of most changes made in coating
systems. This too will extend the time required for planning
and engineering.
In summary, the compliance schedules in the guideline are too
short for most of our major systems. The states must be
aware of the additional planning required for major coating
system changes and must be willing to provide the additional
planning and engineering time. For major sources the two-year
compliance schedule does not allow sufficient time to achieve
compliance.
3. Page C-17, § XX.9l60(c):
If the alternative control plan has emissions no greater than
those permitted by complying with the VOC emission limitations,
approval by the Administrator of U. S. EPA is unnecessary
since that level of emissions has already been considered in the
SIP.
4. Page L-5, § XK.8030(a);
Operation and maintenance manuals for large coating lines can be
extremely large documents. We do not believe any state agency
has either the resources or manpower to properly review
operation and maintenance manuals as proposed. We believe
that the submittal should be made at the discretion of the director
on a case-by-case basis to avoid unnecessary paperwork.
B-36
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DEERE & COMPANY
Mr. Tom Williams
9 July 1979
Page Three
Please call me (309/752-5152) if you have questions or need additional
information.
Yours truly,
Michael E. McGuire
Environmental Control
/dk
c: R. D. Grotelueschen
C. R. Neff
B-37
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E. I. DU PONT DE NEMOURS & COMPANY
INCORPORATED
WILMINGTON, DELAWARE 19898
June 21, 1979
Mr. Tom Williams, Project Officer
Control Programs Development Division MD-15
Environmental Protection Agency
Research Triangle Park, NC 27711
Dear Mr. Williams:
REVIEW OF GUIDANCE DOCUMENT (SAMPLE REGULATION)
FOR SURFACE COATING OF MISCELLANEOUS METAL PARTS
AND PRODUCTS (DRAFT FOR COMMENT)
As requested, we have attached our comments regarding the
subject draft guidance document.
Our comments are as objective as possible, taking into
account the objectives of EPA, available and projected coating
technology and the resources of the users of these coatings.
We consider this sample regulation extremely important to
industry with considerable impact on coatings users. If we can be
of any service to your staff in finalizing the document, we would be
pleased to have our people visit your offices to discuss problem
areas.
Very truly yours,
John E. Lowe
Environmental Coordinator
Finishes Division
JEL/bjr
Attach. B-38
-------
DU PONT COMPANY COMMENTS REGARDING GUIDANCE
DOCUMENT (SAMPLE REGULATION) FOR SURFACE COATING
OF MISCELLANEOUS METAL PARTS AND PRODUCTS
We suggest that the regulation allow considerable lee-
way in considering metallic coatings as "clear coats". In many
instances such metallics are transparent and use the undercoat
as a reflectant base or undertone color. Technology does not
exist to appreciably increase the solids and lower VOC emissions.
C-4 (a)7 Regarding SIC Major Group 37 - Heavy Truck Listing
C-5 (b)9
The number of vehicles that constitute a significant
source should read 35 vehicles per day average.
The heavy truck manufacturers represent a unique surface
coating problem vs. the proposed regulation.
Heavy truck coatings can be characterized as follows:
1. Require coatings quality to withstand exterior ex-
posure - user expectation equal to passenger automotive.
2. Custom color requirements, i.e.; all units coated
require almost unlimited color selection which means that the
coating system must utilize the automotive refinish product lines
that are available, or which may be custom mixed on site, in
approximately 12,000 colors.
3. Units are coated with tires and bearings mounted which
limits the coatings to low bake products.
There is no coating technology in existance that will
satisfy the above requirements and comply with the proposed regula-
tion. No complying technology is expected until the 1987-1988
time frame. Active research is underway
C-4 A-7 Regarding Automotive Refinishinq
C-5 B-8
C-5 Dis. The sample regulation recommends that "this regulation
is not applicable to surface coating of the following metal parts
and products" - (B-8) "Automobile Refinishing".
Then under the Discussion section on C-5, the reasons
for exempting automobile refinishing are documented.
B-39
-------
Pq. Ref _.
The discussion section then advises that the states may
want to extend the regulation to include automobile refinishing.
We strongly request that the portion of the discussion
section that would eillow regulation of the automotive refinishes
be eliminated.
There is absolutely no technology in existance that can
lower VOC emissions from this sub-industry regardless of the size
of the shop. They require: (1) literally thousands of colors
that only exist in present product lines; (2) the durability,
aesthetic appearance-, and color match must be exacting.
We recomnend that the discussion reference to both
automobile refinishing and heavy trucks be eliminated.
C-7 (a) 1. There is now no air dry (3.5 Ibs./gal.) technology
that will meet the needs of the Casket Industry. Suggest Item
(a) 1 which allows 4.3 Ibs./gal. be reworded to say "O..that
applies coatings which are clear or which require more than 1.5
mils DFT for hiding".
2. The term "forced air dryers" implies use of ambient
air. The rule should be written to say simply "forced dried" or
"forced warm air dried".
C-7 (d) In one of the C-7 (c) (3) cases where "higher" solids
paint is used in combination with oven incineration, the capture
efficiency can be less than 80 percent and still yield a better
than 80 percent emission reduction for the whole system.
C-7 (d) In those cases where incineration is to be used to re-
duce emissions as well as other process changes, it should be
explicitly stated that the incineration unit may capture any
part of the emission stream.
C-8 Dis. Suggest that control be simply that solvent washings
and purgings be directed into essentially closed containers.
C-13 C-2 We agree and support the "certification by the manu-
facturer of the composition of the coating" so long as the
certification is limited to total VOC solvent content. Composit:
of the coating or specific solvent composition would represent
divulging proprietary and confidential formula data.
B-40
-------
Pq. Reg...
C-13 (d)4 We suggest rewording to assure this requirement would not
be used to require exotic devices of high cost and/or low value.
C-14 Dis. We are opposed to the conversion of organic carbon as
a measurement of VOC - for the following reasons:
1. The method has not been validated - very little data.
2. The method is cumbersome, i.e.; a full one day
test - one sample.
3. Expensive equipment required.
4. Some portions of the method involve questionable
ASTM tests.
5. Would require a complete change of nomenclature and
testing by the coatings industry without just cause.
C-15 Dis. Average rate of coating useage can most practically be
determined by a review of the user (source) records of consumption„
L-12 (b) We consider the 15 #/day exemption for small industry
extremely stringent vs. the relatively small emission pollution
involved.
We recommend:
Urban Areas - 200 #/day
Rural Areas - 100 tons/year
L-4 (a) A disposal limit of 1.5 gal./day is too inflexible for
all coating operations. The limitation should be related to the
size of the source and the type of coating involved. Example;
Electrodeposition tanks where, under specific operating situations,
as much as 10% of the solvent can go to waste on the Ultra
Filtration Unit.
L-7 (e) Emissions beyond the control of the source should not
constitute a violation, i.e.; start-up, shutdown, breakdown or
malfunction of properly designed equipment.
B-41
-------
Pg. Ref._
L-16 Dis. Reference; !)„ G. Hawkins1 7/3/78 response to
L-17 Att. R. L. Duprey 5/18/78 correspondence.
There is a distinct implication that R&CT limits may be
made more stringent. This position by the agency can only pro-
duce a "let's wait and see" strategy by sources who must commit
capital investment into control equipment or process changes
involving higher cost. There must be assurances to sources that
investment on their p>art to attain compliance will not become
outdated due to limit, requirement changes affecting existing
sources.
General Comment
While this document encompasses the Miscellaneous
category of sources, we feel strongly that the guideline should
be as specific as possible toward consistent application of the
regulation for like sub-industries both within a state and from
state to state.
B-42
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FREIGHTLINER CORPORATION
4747 N CHANNEL AVE
PO BOX 3849
PORTLAND, OREGON 97208
503 283 8000
June 21, 1979
Tom Williams
Control Programs Development Division, MD-15
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
SUBJECT : Review of a Guidance Document for Group II CTG's for VOC's
Dear Mr. Williams:
We submit herewith Freightliner Corporation's comments and attachments
concerning the sample regulation on the development of a guidance docu-
ment for volatile organic compounds in the surface coating of miscellaneous
metal parts and products, Group II.
We would be pleased to supply any additional information which may be help-
ful to assist in data gathering or explain Freightliner Corporation's
operations.
Very truly yours,
FREIGHTLINER CORPORATION
Gary C. Strealy I
Finish System Engineer
GCSrjs
Encls .
B-43
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
PROPOSED GUIDANCE DOCUMENT FOR GROUP II, CTG'S FOR VQC'S
Freightliner Corporation June 21, 1979
Portland, Oregon
Freightliner Corporation is a manufacturer of custom built Class 8 diesel
trucks. Our truck manufa.cturLng plants located in Portland, Oregon; Chino,
California; Indianapolis, Indiana; and Mt. Holly, North Carolina perform
customized truck painting as a part of the manufacturing process.
We generally sell our trucks to the owner/operator who operates his own
business as an independent contractor. He is extremely proud of his
vehicle, places very high aesthetic value on its appearance, and expects the
paint finish to withstand exterior exposure in all types of weather and road
condition usage
When placing their orders, owners regularly specify very intricate paint
designs with five and up to eight colors, or they can choose from current
designs. Freightliner takes pride in offering very intricate paint design
schemes on our fully customized trucks. Attached is our latest paint design
brochure showing some of the newest paint schemes available. Currently we
have available approximately 151 different paint designs.
The coating materials used by Freightliner are acrylic enamel, both air dry
and bake, and air dry polyurethane enamel. These coating materials provide
good color match characteristics, and achieve specific extreme performance
characteristics, such as hardness; mar resistance; high gloss and color
retention levels; film flexibility; crack, chemical and gasoline resistance.
Freightliner1s ability to provide coatings which meet customer requirements
is crucial to compete in the heavy duty truck market.
We custom mix our paints on-site in each truck plant using color formulas
provided by our paint supplier. This allows us flexibility in scheduling
and provides an almost unlimited color selection necessary for our require-
ments of a fully customized operation.
Any proposed standards which would restrict our capability to mix paints at
truck plant sites would impede Freightliner's ability to meet customer
demand for a broad range of colors and designs. Our paint supplier indicates
that it cannot provide an on-site coatings system with low VOC emissions
which could meet the proposed standards.
The EPA guidelines recognize this dilemma and exempt custom coatings
operations with a production of fewer than twenty units per day. However,
most custom painting operations in the heavy duty truck manufacturing
industry have a capacity to produce thirty to thirty-five trucks per day.
Thus we believe that a more realistic level for exclusion from the proposed
guidelines would be somewhat above present custom production levels of
approximately thirty-five trucks per day.
B-44
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Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
Warren, Michigan 48090
July 5, 1979
Mr. T. Williams, Project Officer
Control Programs Development Division
MD-15
U. S. EPA
Research Triangle Park, N. C. 27711
Dear Mr. Williams:
General Motors submits these comments relative to the sample
regulations for implementing the CTG for surface coating of
miscellaneous metal parts and products.
A survey is being made within the Corporation to identify the
number and kinds of coating used in operations that would fall under
this type of regulation. We expect to submit additional comments
within the month, based upon results of this survey.
One area that needs clarification is the status of assembled products
or sub-assemblies that contain non-metallic substances incapable of
withstanding the curing temperatures associated •with coatings that
meet the suggested VOC content limits. For instance, products that
contain plastic, paper, fabric, wood, or sealing and fastening agents
may not be resistant to temperatures needed to cure high solids or
waterborne coatings.
The portion of the regulations that defines and discusses applicability
should clearly state how such products are to be treated. If they were
not meant to be covered, XX-9120(b) should so state. If they were,
a warning that the emission limits may not be applicable and that
alternative limits based upon coating materials that can safely be used
should be added.
The clarification is particularly important to motor vehicle manufac-
turers and their suppliers, as non-metallic materials play increas-
ingly larger roles in programs to reduce weight and improve fuel
economy.
B-45
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Mr. T. Williams -2- July 5, 1979
I trust that these comments will assist the EPA in its goal to
develop regulations with maximum cost-effectiveness and minimal
burden to affected industry. Please give them careful consideration.
Should you have any questions, please call Mr. Doug Frank of my
staff at 313/575-8609.
Sincerely yours,
W. RT /Johnson, Director
PlantvEnvironment
WRJ:mb
B-46
-------
June 25, 1973
A DIVISION OF RANSBURG CORPORATION
Mr. James Berry, Director
Chemical Applications Section
Mail Drop 13
U.S. EPA
Research Triangle Park, NC 27711
Dear MV. Berry:
Recently, in correspondence with state air pollution agencies, as well as
affected customers, a concern has arisen pertaining to the Control Techniques
Guidelines for control of VOC emissions from surface coating. The guidelines,
as you know, set forth emission limitations in a format of mass of VOC per
volume of coating as delivered to the applicator.
Some categories of coating, (can, coil, paper, fabric, vinyl, and magnet wire)
employ applicators such as roll, gravure, knife or die. For these categories
and their corresponding applications techniques, this format is appropriate.
The amount of VOC emitted from the operation is in direct proportion to the
amount of VOC present in a volume of coating for a given production rate.
However, the other categories, auto and light duty truck, metal furniture and
large appliances, typically employ atomizing or spray application techniques.
For these categories the limitation specified in terms of mass of VOC per
volume of coating does not relate well to actual emissions of the operation.
This is because not all of the coating delivered to the applicator ends up on
the part. Coating ends up in water wash, walls, floor and exhaust. This
amount will vary, depending on the equipment used, but whatever is not on the
part still emits VOC to the atmosphere. Practically speaking, industry is
only concerned with coating a part to a certain thickness (build). If a
person's equipment is only capable of putting 40% of the paint from the
applicator on the part, (a transfer efficiency of 40%) he will spray until
that 40% gives him the desired build. If this person coats large appliances,
for instance, and uses a coating with 2.8 Ibs. per gallon, he will be in
compliance. If he were to replace his equipment with automatic electrostatic
equipment, he would find that better than 90% of the coating could be applied
to the part. Although he is still in compliance, he has reduced his actual
VOC emissions by over 50%.
In the CTG for Large Appliances, Volume V, the section on Monitoring
Techniques and Enforcement Aspects states that if a facility "... converts
from a manual conventional spray application (at a transfer efficiency of
40-70%), to an automated electrostatic spray system (at a transfer efficiency
of 70-90/£)... a reduction in VOC will be realized." Further, it says, "this
reduction in VOC can be considered in any evaluation of the overall reduction
achieved by the operator." Unfortunately, we do not know what transfer
efficiency the author had in mind when formulating the 2.8 Ibs. per gallon
coating, so it is impossible to quantify. In Volume VI, the CTG on
Miscellaneous Metal Finishing, in the same section, similar language is found
B-47
Mailing Address Post Office Box 88220 Indianapolis, Ind 46208 Shipping Address 3939 West 56th Street Indianapolis. Ind 46254
Phone (317)298-5000 Telex 027-464 Cable Ranscoat
-------
U.S. EPA
Research Triangle Park, NC
Page 2.
except it now reads, "... should be considered in any evaluation...". We
agree and have attempted to consider it but, again, we do not know what
transfer efficiency is assumed with the limitations. Finally, in a
justification of changing the limitations for auto and light duty truck NSPS
to a Ibs. VOC/gallon applied solids format, we find the following: "When
add-on controls or high solids coatings are used to comply, transfer
efficiency must be taken into account to determine equivalency to water base
coatings." In this document, the format stated as pounds VOC/gallon applied
solids was developed with a specific transfer efficiency in mind, and
calculations of equivalency are easily carried out. Obviously it is of
greatest importance to determine what transfer efficiency is assumed with
limitations in terms of mass VOC per volume coating to determine equivalency.
Many states have adopted VOC limitations for auto and light duty truck surface
coating specifying a minimum transfer efficiency assuming (based on the CTG)
that a waterborne coating would be used and applied with conventional
equipment at about a 40% transfer efficiency We feel this is reasonable but
we need your corroboration.
I contacted RTP recently to ascertain a transfer efficiency for the large
appliance limitation. In a telephone conversation on June 19 with Bill
Johnson of your staff, Bill suggested that since electrostatic methods are the
industry norm, a transfer efficiency of 65% would be appropriate. Again, we
feel this is an acceptable representation of the industry, but we need a
written confirmation of this figure.
The metal furniture limitation applies to a more diverse spectrum of industry
and is more difficult to assess. Dennis Grumpier told me that he would try to
develop a presumptive figure for this category. We would be happy to offer
any necessary assistance to determine a value at an early date.
Finally, in miscellaneous metal finishing where we were urged to consider
transfer efficiency improvements, we unfortunately have no facility for doing
so without such knowledge of the presumptive efficiency used to arrive at the
limitation.
I would greatly appreciate hearing from you at your earliest convenience, as I
am sure it will eliminate a majority of the confusion surrounding the CTG's.
Further, many states have hesitated incorporating their own transfer
efficiency estimations in the event that your determinations will be
different. In order to promote a uniform application of the CAA Amendments,
and avoid confusion and unnecessary problems, we hope you will be able to
provide us with guidance.
Sincerely yours,
*-
Robert M. Acker
Director, Environmental Affairs
RMA:mjb B~48
cc: D. Caffee
E. Drum
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Stdndards
Research Triangle Park, North Carolina 27/11
8 AUQ
Mr. Robert Acker
Ransburg Electrostatic Equipment
3939 West 56th Street
Indianapolis, Indiana 46254
Dear Bob:
Thank you for your letter of June 25, which discussed the need to
establish "baseline" tranfer efficiencies for surface coating industries
in order for a company to receive credit towards compliance with State
regulations by improving transfer efficiency, I recognize that your firm
has a vested interest in highlighting the environmental benefits of good
transfer efficiency achievable by automatic electrostatic atomization and
spray equipment. We are enthusiastic about electrostatic applications
because the environmental benefits are derived directly from the reduced
paint consumption by the coater.
In the letter you asked us to: (1) corroborate the 40 percent baseline
transfer efficiency for water-borne coatings applied to auto and light duty
trucks that some States have already adopted; (2) confirm the 65 percent
baseline transfer efficiency in the large appliance industry which was
discussed in a previous telephone conversation with Bill Johnson arid;
(3) establish "baseline" efficiencies for the industries which coat metal
furniture and miscellaneous parts and products. First, let rne point out
that we did not consider transfer efficiency initially in writing the CTG's
because of the absence of generally accepted measurement methods. We
presumed that each manufacturer, as a normal course, would use an efficient
application technique to minimize his material cost. As we learned more
about the "real world" the States were at first given the opportunity
and later urged to include transfer efficiency in their consideration.
Correspondingly, we have learned more about which industries lend themselves
to transfer efficiency considerations and to what extent.
Autos and Light Duty Trucks
The latest data we have indicate the application efficiency of non-
electrostatic water-borne coatings is only 30 percent. I have enclosed two
memos which provide more detail.
B-49
-------
Large Appliances
The 65 percent baseline transfer efficiency given by Bill Johnson is in
the right ballpark. His estimate was based on the fact that practically
all the manufacturers use equipment at least as efficient as electrostatic
spray guns. Recent information provided by the contractor responsible
for developing a NSPS for coating large appliances leads us to accept 60
percent as a better "average."
Metal Furniture, Miscellaneous Metal Parts and Products
The 60 percent baseline for large appliances could be determined because
the industry as you know, consists of a limited number of manufacturers
who coat a limited number of end products. These products tend to be "boxy"
with large, flat areas to be coated, a favorable condition for electrostatic
applications.
The metal furniture industry and even more so, the miscellaneous metal
parts and products industries are not so easily categorized. Thousands of
firms coat as many products which range from small parts that are flow
or dip coated (for which conversion to automatic spray might even increase
emissions) to large machinery that often is air-sprayed. Second there is
great uncertainty in even estimating the efficiency of a single application
method when it is used to coat substrate configurations as diverse as
found in the metal furniture and miscellaneous metal parts and product
industries. Based on these problems we could do a disservice to many were
we to attempt to establish a single presumptive norm for the transfer
efficiency for all companies involved in these two extremely diverse categories,
It seems that the'only prudent way to deal with these problems is to
leave some discretion to the investigator charged with developing a
limitation for a specific plant or process. Certainly we can give some
general guidance. For example, we would expect flow and dip coating to
average about 90 percent regardless of the shape of the substrate. Handheld
air spray could be expected to average between 40 and 50 percent handheld
electrostatic about 60 percent, automatic electrostatic about 75 and high
speed discs arid bells from 85 to 90 percent.
This timidity on our part need not stymie Ransburg's attempts to
exploit the higher average transfer efficiencies typical of electrostatic
coating. Rather, I would suggest that the ratio of transfer efficiencies
given above be used to develop the relative improvement in emission rats
over an existing system. The State (with our help if necessary) need only
identify the most common application system in use by a specific subset
of the miscellaneous metal parts and products or metal furniture industries
and compensate for an improved transfer efficiency with the appropriate
ratio.
B-50
-------
We welcome any further comments or suggestions you have concerning
these matters or any data which may improve estimates of reasonable
transfer efficiencies for' given equipment and process situations.
Sincerely yours,
/)
Dennis Grumpier
Chemical Application Section
Chemicals and Petroleum Branch
B-51
-------
D/1IMQRI Of""^ When You Say ELECTROSTATIC You Mean RANSBURG
ELECTROSTATIC
EQUIBI/IEKT
A DIVISION OF RANSBURG CORPORATION AllQUSt 28, 1979
Mr. John Calcagni
Physical Scientist
Control Programs Operations Branch
Mail Drop 15
U.S. EPA
Research Triangle Park
North Carol,na 27711
*
Dear John:
Since meeting with you on the 22nd I have been trying to come up with the best
approach to recognize transfer efficiency improvements. After trying to
develop a case by case basis review procedure, I have the following comments
to make.
First of all, we recognize that the entire issue of emission limitation on
surface coating is a result of the solvent evaporating from the coating. It
has been -established that photochemical oxidants, and ozone in particular, are
formed in the troposphere by reactions which start with hydrocarbons. Reduc-
ing the amount of sclvent allowed to escape to the atmosphere reduces the
amount of ozone formed, and thus the public health is protected. It is obvi-
ous therefore that the EPA is ultimately concerned with how much solvent is
actually emitted from a particular coating operation.
Industry is engaged in producing necessary goods for society. They are inter-
ested in coating materials for their goods which provide corrosion resistance,
durability, hiding, and perhaps most difficult of all, aesthetic appeal. The
solvent in coating materials used by industry is only a means to transfer
solids, which provide the desired characteristics, to the part. The cost for
a given vo.ume of coating is for the most part the cost of the solids. The
solvent portion of the material is about ten or fifteen times less expensive
than the solids. It remains, however, a necessary ingredient to deposit a
uniform thickness of coating on a substrate.
In spite of the general impression of adversity, the interests of EPA and
industry are really the same. Industry does not want to buy solvent and then
see it go up the stack, and neither does EPA. In this regard, powder coat-
ings, two component systems and others that have no solvent content are highly
desirable coatings from both perspectives. However, for a variety of reasons,
these may not be a,ble to satisfy the performance characteristics of a particu-
lar user. It is therefore only realistic to assume that a certain amount of
solvent is necessary to convey solids to a production piece.
B-52
Mailing Address Post Office Box 83220 Indianapolis, Ind 46208 Shipping Address- 3939 West 56th Street Indianapolis, Ind. 46254
Phone (317) 296-5000 Telex 027-464 Cable. Ranscoat
-------
M^. Join Calcagni
Research
"^ Park
Page 2
August ?3, 1579
Because solvent is necessary to coat Items, and because it needs to oe
limited, ~\\. H }xioi:iatic that J:rrss!on limitations should specify the minimum
a mint :>f s^l/ei" necesscr/ to achieve tne desired cilm characteristics. The
asnojrit of solvent jsed (and ul -.imat ?] y ?>rpj:ted; -;o achieve the Hesired
ch irac if ; s : i ci •ic,3e'ri 1s 01 POJ'- vari ab"! ss :
1) Soli 1s Conten
ent (or VOC Contsnt) of Coating
;^ Ti-ansfef Efficiency (contioj applied/coating sprayed)
3; "iln B-jil1 ('ii ickness)
•1; A-ea Coated
If three of tnese variables are held constant and one varied, the following
"el ati ^nshios ex ' ,t:
3olids
Content
increase
Con si: ait
Constant
Constant
Transfer
Efficiency
Constant
Increase
Constant
Constant
F i 1 iti
Build
Constant
Constant
Decrease
Const a- it
Area
Coated
Constant
Constant
Constant
Decrease
VOC
Emissions
Decrease
Decrease
Decrease
Decrease
Tne interrelationships of these variables can be exppressed by tiie following
equation:
Soli Is Content x Transfer Efficiency riln Build x Area Coated
Using these ''ela.t ;ons:i 'ps, t;-:e i^'i^l e'niss':o"! I imi tat^'on should reflect the
highest percentage soliJs coating material available, applied at the highest
transfer efficiency achievable A'ili tm- least '"il'n t)jild acceptable and the
least a;noijnt 3f area coat-1. Of tiie r^>ur variables, the one which hiitori-
caT!v his not be^'i limited and probably s'nuM not 'o? limited is the a°ea
'
coated.
effectively
,)roi1'ici;ion '-.'h'c'n :s -le
B-53
-------
Mr. John Calcagni Piie 3
Ress^ch T.-iang1.; Park Auj-is" ?S, [l7S
desirable nor necessary. Pot simply, how much someone coats is jp IT them,
out they must coat in the most iffactive (least VOC emiss;.ons) manner
available.
The present format of mass VOC emitted per volume of coating delivered to the
applicator only specifies one of the variables. This of course is not suffi-
cient to limit emissions. A format of minimum transfer efficiency is not
acceptable for the same reason, nor maximum cilm bjild.
The main difficulty with the mass VOC per gallon delivered format is that
actual reductions in VOC emissions gained by improving transfer efficiency or
reducing film build are ignored. Altnough I.e. has every bit as much an
effect on VOC emissions as solids content, a source wishing to employ t.e.
improvements must submit an involved petition and be granted an alternative
limitation on a case-by-case basis. Further, as you point out, the state must
submit this alternative limit as a SIP revision. This is obviously inequit-
able and -in fact arbitrary. It is analogous to specifying a minimum transfer
efficiency and forcing sources to petition for the use of higher solijs o«"
specifying a maximum -cilm build and ignoring both t.e. and soMds content.
The solution to the problem John is to change the format to an equivalent com-
bination of the independent variables. Either a mass of VOC emitted per
volume of applied solids (as per the auto and light duty truck NSPS draft), or
mass emitted per area coated at a specific cilm build, would be ideal. TnK
would be far easier to enforce, solves the problem of t.e. measurement, and
accounts for the recoa':ing of rejects. Instead of recommending that states
allow case by case t.e. improvements, I think it would serve everyone's
interest to recommend that the states change the format. For example, in
large Appliance coating, instead of 2.3 i'os per gallon as delivered to the
applicator, at a not well krowi t.e. of 60%^ change to 7.5 Ibs per gallon o*
applied solids, or else 4.7 IDS pe1" 1000 ft-'- coated at a 1 mil build. Both
of these limitations are identical to the one presented ^n the CTG, but more
importantly they are clear concise limits that eliminate the extensive time,
effort, and money associated with a case by case review. Additionally, they
make enforcement a great deal easier, as plant "ecords can be used and cleanup
solvent as well as reject coating is accounted for.
All tnat is necessary to determine compliance with these formats is the
following items:
1) Volirne of coating used
2) Percent solids (or VOC)
3; Volume of solvent jseci
4) Number of parts coated
5) Surface area of parts
6) Film Bjild
The solids content, as we discussed, could be certified by the coating sup-
plier. The purchase orders or daily production records could be used to John
B-54
-------
Mr. John Calcaq-r' Page 1
Research Triangle Park 4-jy-jit 28, 1979
determine volume of coating and solvent used, as well as number of parts
coaced. The surface area of parts would need to LIO Determined only once.
Film build can be measured directly on the parts or, since this is a very
closely controlled quantity, from the plant personnel. ! have enclosed a form
which we use on a routine basis in our lab for calculating "paint mileage",
which is simply how many square feet a gallon of a given coating will cover at
a 1 ni I thickness. Alternatively, this could be converted to gallons of
applied solids by appropriate conversion factors.
I think that this approach is attractive for several reasons. First, it would
be one method that would accurately account for t.e. and film build, effec-
tively limiting actual VOC emisssions for a given production level. This is
most important from an air quality planning point of view. Secondly, it
accounts for cleanup, recoat of rejects, and other sources of fugitive emis-
sions. Lastly, enforcement does not rely on one variable, paint solids, to
determine compliance. Compliance is determined just as easily, but in a man-
ner which reduces the possibility of circumvention. I would appreciate hear-
ing from you regarding this approach at an early date, as I think it has
special merit.
Sincerely yours,
Robert M. Acke>% Director
Environmental Affairs
cjc
cc: John Rasnic
Bob Marshall
DSSE
Jim Berry
Dennis Grumpier
Bill Johnson
OAQPS
Don Jonnston
RTI
B-55
-------
RANSBURG LABORATORY TESTS
Paint Mileage
FOR
EQUIPMENT
Test Number
Part Name or Number
Hanger Number
Rotate-Index-St-Thru
Work Height
Paint Number
Rotated- Indexed Dia.
CC/Gal.
Total Delivery*
Conv. Speed (fpm)
Hanger Centers (ft.)
Parts per Banger
Parts Cut Gal.
Parts Paint + Thinner
Parts Paint
Parts Uncut Gal.
Sq.Ft. per Part
Sq.Ft. Uncut Gal.
Average Film (mils)
Sq.Ft.nncut Gal 3 1 mil
4)
a
3
14
s
«J
r-4
3
U
r-t
|Q
U
Ent.
r
X
7
X
=
X
••
s
X
=
X
=;
3785
DATE
3785
<
3735
3785
•
3785
FORMULAS:
3785
cc/min.
F?M
Cen. in Ft.
X Parts /Hanger =» Part/Cut Gal.
Part/Cut Gal. X Paint + Thinner * Parts/Uncut Gal.
Paint
B-56
Form No. SL 6906-2
-------
* • .* •*•* -""*v --
P^-!.?J
CROWJY IRON WORKS COMPANY
1229 TYLER STREET N. E.
P. O. BOX 1364
MINNEAPOLIS, MINN. 55440
U. S. A.
PHONE (612) 781 -3101
July 13, 1979
U.S. Environmental Protection Agency
Office of Air Quality Planning & Standards
P.O. Box 12194
Research Triangle Park, North Carolina 27709
Attn: Tom Williams
Dear Mr. Williams:
Thank you for the draft copy of the proposed Guidance Document for
Group II Control Technique Guideline for Volatile Organic Compounds (VOC).
Our company's interest in them is as a manufacturer of solvent extraction
systems for Vegetable Oil Mills. The solvent commonly used is hexane.
We appreciate the opportunity to comment prior to distribution of a finalized
document. Crown Iron Works Company works very closely with the Vegetable
Oil Mill Industry and does feel an interest in regulations pertaining to
them.
In all honesty, we believe the proposed regulations are difficult to under-
stand, unnecessarily complex and a likely source of technical and legal
controversy. First of all, the classification of hexane as a VOC of medium
photochemical activity in the atmosphere can be disputed as it has not
been proven. Secondly, the proposed method of determining residual solvent
in meal is fairly repeatable, but is of unknown accuracy, disagreeing with
a similar previously accepted method by as much as 66 times! Thirdly, the
regulations are not geared to overall performance but rather to unnecessary
and impractical restrictions on emissions at every moment including short
breakdowns. Fourthly, economic impact to the community, state and the
U.S. are not considered. The cost of complying and maintaining records,
the complexity of regulations and issuance of permits, possible court
litigations, means companies will be very hesitant to make capital investment
in increased capacity equipment. Companies will find it easier and cheaper
to build plants overseas. This will deprive our nation of tax producing
revenue.
To expound a bit on the four (4) reasons for objecting, let me go over them
point by point. Hexane has not to my knowledge been proven to be a compound
photochemically active. It was originally classified as non-active and was
re-classified only on the assumption it is active.
The second point is that there are two methods for determining hexane content
in the meal. We do not have EPA-450/2-78-041. By EPA's admission, however,
this does not define sampling procedures. This is still to be determined
by future tests in the field. The other reference (WAN) describes an improved
analytical method.
B-59
-------
U.S. Environmental Protection Agency
7/13/79
Page 2
While this does allow better repeatability, it is of unknown accuracy. It
is highly subject to variation under field test conditions, and as noted, it
differs dramatically in results (up to 66 times) compared to a previously
accepted method. How can regulations be written when testing is not yet
accurate or defined?
Thirdly, the guidelines are geared to monitor and regulate short duration
problems and not more meaningful overall performance. Hexane is non-toxic,
of moderate environmental .urpact, and the effect of momentary fluctuations
in a small emission are totally meaningless. Furthermore, regulations should
be for overall performance over fairly long periods not for limited breakdowns.
The regulations proposed require the Oil Mill to notify the National Director
within one (1) hour of a shutdown causing any increase in emission. The burden
of proof then is on the processor to show it was an unavoidable breakdown.
Furthermore, Vegetable Oil Mills run 24 hours per day, 7 days per week, 330
days per year and the National Director will have a staff on duty the same
operating hours as Oil Mills ('holidays and nights), just sitting and waiting
for calls; rather absurd.
Fourthly, economic ijmpact to community, state and country can be great. Must
we continue to see a program of non-growth in this country. Because of high
costs of complying with U.S. regulations or worse, not being able to get
permits, plants will be built outside the country. For instance, the State
of California is producing more cottonseed than it has capacity to process.
State EPA regulations hovever,, prohibit expansion of processing capacity. A
California Oil Mill has been working for a year to receive a permit for a new
plant and has not received one yet. This refusal of permit is despite the
fact a new plant would use better available technology than is used in existing
facilities. Solvent loss would be much less in new plants than in old ones.
Also, excess cottonseed produced by American farmers must be sold at reduced
prices for processing overseas or must be sold for feed without removal of
oil. The old worn out facilities continue to operate at over capacity often
with higher emissions than would be true with a new plant. The community and
state lose on dollars to the farmer, unemployment and tax revenue.
I thank you for the opportunity to voice my opinion. Unless simplified
regulations are rewritten based on overall performance, I believe they can
only lead to court litigations, reduced capital investment and significant and
unnecessary increase in non-productive costs.
A letter is enclosed frcsn our Chief Engineer also regarding these regulations.
His comments are very interesting, I believe.
Respectfully yours,
cc: Senator Boschwitz
Senator Durenbergea:
Congressman Frenzel
ODB/jo
Glenn D. Brueske
Sales Mgr. - Process Div.
B-60
-------
CROWJNT IRON WORKS COME^NTY
1229 TYLER STREET N. E.
P. O. BOX 1364
MINNEAPOLIS, MINN. 55440
U. S. A.
PHONE (612) 781 -3101
July 13, 1979
The Honorable Dave Durenberger
Senator from Minnesota
Washington, D.C.
Dear Sir:
Recently the EPA sent us a draft of proposed regulations for emission
of hexane (a volatile organic compound or VOC) from the several hundred
domestic plants which process our soybeans, cottonseed, corn germ, etc.
Our company does not operate these oilseed extraction plants. We do,
however, design and manufacture the solvent extraction and solvent
recovery systems used in these plants. We thought long and hard before
writing in response to this draft in complete openness because we do
not wish to become needlessly entangled in a possible controversy
between our customers who do operate these plants and the EPA. In the
final analysis we could not, in good conscience, remain silent.
Our Mr. Brueske has written a letter to the EPA and a copy is enclosed.
I would like to add a few personal observations and encourage you to
read the other letter as well.
In my opinion, this draft of a proposed EPA regulation reflects an
approach to controlling emissions which is much more complex than
necessary and will result in serious technical and legal enforcement
problems. The result may be disruption of domestic production, the
dispiriting of domestic processors, very little net gain in air quality
and further erosion of business and public esteem for the EPA and
government in general. I feel that the vitality of our farming and
food economy is at stake — most of the larger grain companies and
countless farmer-owned cooperative processors would be weakened in
world competition or would increasingly move operations overseas.
Probably our company would benefit in the short term because we build
equipment which may be required, but in the longer view, rules which
needlessly harm our customers or undermine our productive system
may not help our business for long, and cannot help our nation.
The technique used in developing the regulations or the laws which
demand them may lead automatically to the problems I will note. I have
followed the process at a distance for a few years, and seen many
EPA consultants and managers with no previous knowledge of the industry
begin to develop an understanding and then become submerged under a
new layer of people; under the best circumstances a comprehensive
B-61
-------
Senatcr Darenberger
7/13/79
Page 2
understanding is not easily developed and even those most closely
involved at EPA have never run a plant or in many cases are not even
enabled to visit one until quite late in the game!
Consequently those involved must fall back upon their legal expertise or
experience as consultants oriented towards somewhat complex environmental
testing — and this seems to have biased the result away from practical
plant concerns and towards legal-technical complication.
Major concern #1: The proposal is written in specialized terms,
abbreviations, and is legally complex; I have extreme difficulty in
understanding what it really says. For example, the last paragraph
on page L-13 leaves me unsure if there is any way to be safe from
violation under the variety of "approaches" available. I am reminded
of the Business Week article in which a Kennecott smelter spent $280
million for EPA mandated controls, only to be told 'oops, you need
to spend twice that again'. With the confusing format of this proposal
and the possible overlap of other regulations, the processor is left in
continual discomfort.
Major concern #2: The proposal lacks a legitimate incentive to cooperate.
It seems that "enforcement--language" standards (EPA or other) tend
largely to make confused and frightened plant managers conversant with
their lawyers and discouraged at being alluded to as law-violators for
their failure to meet somewhat obscure or controversial goals. Economic
pressures and resulting stock-holder questions, however, speak a
language the manager knows and directly responds to without translation,
delay, intimidation or social degradation. The EPA should encourage
incentives within the managers language and area of capability, not
the lawyers. This attempt to adopt the language and understand the
interests of those governed would seem appropriate in all forms of government.
Major concern #3: The controls are on specific points of emission from
the system and require expensive equipment and testing, Further, the
methods are in question ass to accuracy and reliability of equipment. As
an example of an uncertain technique likely to generate disagreement
and turmoil, note the EPA reference (c)-(2), page D-ll, Wan, P.J.: in
Table II of the reference, the two methods cited (both showing good
"reproduceability" but unknown accuracy) for determining solvent content
in cottonseed meal disagree (under laboratory conditions) by as little as
1.37 times and as much as 66.33 times! The newer method is apparently
preferred over the previously accepted method - but can one imagine the
countless court confrontations over disputed data?
Also, note that an optional emission control device mentioned by EPA
is the carbon bed absorber. These are not advisable for use in hexane
plants; they were used years ago, and all removed due to inherent hazards
of explosion. The uses noted, would also involve much wasted energy.
Major concern #4: Even if practical and understood, I do not suspect that
the regulation would be as effective in the real goals of reducing
pollution as far simpler methods might be. The specific limits defined
for each point of emission, (a necessary area of controversy) have to
B-62
-------
Senator Durenberger
7/13/79
Page 3
be set at practical levels, taking into account the variables of
different plants, and when summed, it may well be that the total
allowable emission could be higher than is desirable; an equal possibility
is that a very low emission plant might fail in one specific test or
have a minor malfunction and be in "violation", probably shut down.
Note also that such specific regulations eliminate a flexible response
to the total emission problem. This complexity and possible disfunction
could be avoided.
Please note that the solvent in question, hexane, is not (to my knowledge)
toxic. It is of interest to the EPA only for the fairly long-term average
emission as a volatile organic compound which is assumed to increase
photochemical "smog", and it is of interest in the short term only
because it makes one"drunk" (or could smother a person if over-exposed)
and is highly flammable. The operators, managers, and insurance
regulations direct their efforts towards the short-term safety issues,
and the EPA is only legitimately concerned about the longer-term
averages. So why does the EPA concentrate on continual recording of
specific point emissions, immediate mandated telephone admission of
failures, 4 years of detailed records, etc.? In a serious problem a
manager would do better to remember calling the fire department! This
is not plutoneum, it is hexane.
May I very tentatively suggest (for other, better ideas could perhaps
be devised if industry were seriously consulted) that point emissions
or "tail end monitoring" be dropped in favor of the relative simplicity
of plant inventory reporting, "head end monitoring" of total monthly
solvent lost per ton of raw oilseed processed? I must assume that the
ultimate intent is to see that all plants run fairly low emissions
levels, which requires fairly efficient operation, and with efficient
operation the loss to atmosphere is a fairly constant and high pro-
portion of total losses. Probably it is also true that under inefficient
conditions a similar high proportion would be lost to atmosphere. It
would be necessary that specific, reasonable limits on gallons of
solvent lost per ton of meal produced be tabulated for each oilseed,
type of system, weather condition, or whatever — and the solvent
purchases of each plant be compared and graphed for trends. Then,
I highly recommend that the incentive be economic and reasonable, (to
avoid resentment and justified legal challenge) on a basis of how many
excess gallons were needed. It may even be practical to reduce or
eliminate penalties for high emission plants when they can show specified
improvement trends or active plans. The main point, however, is the
comparative simplicity of generating the data needed for a highly accurate
view of the situation. The technical-legal testing hassle and operational
interference are eliminated, the spot-inspection threat is less worrisome
(ever have the mother-in-law drop in on your wife just as she burned
the bacon?), and the economic trend can be predicted and improved more
happily and cooperatively.
May I risk mentioning a possible further simplification? The increasing
cost, allocations, and possible shortages of hexane already have the
more aware operators moving rapidly to reduce its loss. Somewhat uniquely,
the EPA and managers herein find a common economic incentive! Further,
these plants are nowhere near to the largest emitters of volatile organic
B-63
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Senator Durenberger
7/13/79
Page 4
compounds. Further still, the level of photochemical activity of
hexane has admittedly not been demonstrated. Would a somewhat informal,
statistical and educational program suffice? Few managers will continue
to spend $135,000 more annually (for a medium size plant) on solvent
than their average competitors once they (or plant owners...) find
they needlessly use 50% more solvent than the average. That sum may
seem small in government, but it is a large share of annual profit!
Certainly objections may exist to some aspects of the above ideas, but it
is doubtful they could compare to what I feel are unfortunate aspects of
the EPA draft proposal. I write in an attempt to find a means, someplace
in our complex society, for government and business to cooperate in
respect, in knowledge of and accomodation for strengths, weaknesses,
and problems of the other party. Excessive reliance on the legal
adversary approach to an improved American life style is a blind alley
as we all will find as we increasingly become the object of regimen-
tation from afar, and find shortages of production close to home.
Thank you.
Yours very truly
-
a-
George Anderson
cc: Senator Boschwitz Chief Engineer - Process Div.
EPA
GA/jo
B-64
-------
NATIONAL COTTONSEED PRODUCTS ASSOCIATION, INC.
Established 1897
SUITE MA,L ADDRESS
2400 POPLAR AVE M E M P H IS , T EN N . P. O. BOX 12023
38112
July 19, 1979
Mr. Tom Wi11iams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, NC 27111
Dear Mr. Williams:
The National Cottonseed Products Association, Inc. is the trade
association of the cottonseed processing industry. There are 76 out
of a total of 81 operating oil mills in the United States which are
members of this Association. Forty (kO) operating mills have solvent
extraction plants so the total volume of volatile organic compounds
emissions from this industry are a small percentage of the total.
To our knowledge, there has been no economic impact study con-
ducted by EPA directed toward a regulation on volatile organic
compounds nor has there been one conducted by this industry. However,
it is reasonable to assume that there will be increased production
costs as well as increased power requirements with no increase in pro-
duction efficiency. It can be reasonably estimated that monitoring
and record keeping costs might well exceed $25,000 per year and some
mill operators calculate costs up to $50,000 per year. This is a
significant item for the average cottonseed oil mill with a 200-225
ton capacity processing 40,000 tons of seed per year.
While there are some fundamental differences in the processing
of soybeans and cottonseed, there are areas in common. In respect to
carbon adsorption and incineration systems I would refer you to
comments made by the National Soybean Processors Association in which
we concur, as follows:
'The proposed RACT controls of carbon adsorption and
incineration on the post-DT vents will add significant
fire and explosion hazards to the extraction process.
NSPA members have worked for years with professional
and technical associations and with the National Fire
Protection Association to develop and institute plant
design features and operating practices which will
enhance plant safety. The extraction process for oil
seeds has special safety problems (not present in, for
example, a petroleum refinery) because of the requirement
B-65
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Mr. Tom Will!ams
July 19, 1979
Page 2
to introduce, and later remove, large volumes of
solids (prepared soybeans) into and from process
vessels containing a flammable and explosive solvent.
If required to be added to the present process, carbon
adsorption or incineration would greatly increase the
risk of fires or explosions in the plant and would
likely result in loss of life or property in some
cases. In the process of carbon adsorption, heat is
generated when the solvent vapor adsorbs on the
carbon. A plant upset in the main process could momen-
tarily send a high concentration of solvent vapors into
the adsorbers, resulting in a possible fire or explosion
inside the adsorber which could then propagate backwards
into the main process.
With regard to incineration, you should be aware that
incineration of post-DT vents is not allowed by the
National Fire Protection Association due to the special
hazards involved. Even ducting these vapors to a point
100 feet from the extraction building does not suffi-
ciently reduce the hazard. Additionally, as the report
points out, the incineration process is also economi-
cally unsound and energy inefficient."
The cottonseed processing industry has also worked closely with the
National Fire Protection Association and its representatives assisted in
the development of NFPA3&.
In addition, mineral oil scrubbers now in operation may not be as
efficient in controlling emissions as required by the proposed regulation.
This industry does not now know of equivalent means of VOC removal
that guarantees 95% reduction by weight.
There are many problems associated with this regulation that are not
addressed by the EPA Guidance Document. For example, energy is of criti-
cal importance in the cottonseed products industry. Virtually all
regulations to date promulgated by EPA, OSHA, ej^ aj_. , called for increased
energy usage without a corresponding increase in productivity. Infla-
tionary costs are also a part of these new regulations and they too should
be considered before additional burdens are heaped on industry and the
consumer.
These are but two, which to be sure are out of the realm of pure
technology, but should be taken into consideration.
Very, truly yours, -
\ r/ ' '
L-. o
Kenneth 0. Lewis
Executive Vi ce-P res i dent
KOL:mw B-66
-------
NSDA
§ NATIONAL
NATIONAL
SOYBEAN
PROCESSORS
ASSOCIATION
1800
M
STREET
N.W.
WASHINGTON
D.C.
20036
(202) 452-8040
TELEX:
89-7452
JOHN G REED, JR
Chairman
C LOCKWOOO MARINE
Vice Chairman
SHELDON J HAUCK
P'es.dent
A E IDLEMAN
Secretary
EDWARD J CORDES
Treasure'
50
HALF CENTURY OF
WORLD LEADERSHIP
August 10, 1979
Mr. Tom Williams
Project Officer
Control Programs Development Division
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, N.C. 27711
RE: REVIEW OF A GUIDANCE DOCUMENT FOR GROUP II
CONTROL TECHNIQUE GUIDELINES FOR VOLATILE
ORGANIC COMPOUNDS
Dear Mr. Williams:
We are in receipt of your undated memorandum on the
above subject which asks for comments on your "sample
regulations" prescribing RACT for vegetable oil plants.
We would initially like to note that your office did
not provide copies of your memorandum and its attach-
ment to NSPA nor any of its member companies in a
timely fashion. We learned of the existence of the
document indirectly, and were finally provided copies
only after a specific request. In discussions with
your office we were given permission to file our com-
ments on or before August 10, 1979.
According to your memorandum, the document attached
thereto is intended as "... a guidance document to
assist State and local agencies in preparing RACT
regulations..." We vigorously object to your including
vegetable oil plants in this document for the simple
and obvious reason that State and local agencies have
been asked not to prepare RACT regulations for the vege-
table oil industry at this time. As stated in Walter
Barber's memo of June 22, 1979 (copy attached):
"Initial results from the first of several
scheduled field tests indicate that the
measured results are significantly more
variable than originally anticipated.
Accordingly, I have concluded that it would
be prudent to defer regulatory action for
vegetable oil plants until after the test
program is completed this fall and all the
data have been analyzed.
States should not be required to adopt
rules for this CTG category during 1979.
Further information will be provided on this
matter after the completion of the field
test program."
B-67
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Mr . Tom Williams Page 2.
Don Goodwin was even more precise in his letter of
June 29, 1979 to the State of Ohio (copy attached) -.
"... we are requesting that regulatory
action for vegetable oil plants be de-
ferred until the data from this test
program have been analyzed,"
Messrs. Barber and Goodwin are saying, in effect, that
the data base underlying; the CTG has been called into
question. Additional data is presently in the process
of being collected, and it is certainly possible, if
not likely, that the CTG will have to be modified. In
view of this fact, and in view of the fact that States
will not be proceeding with regulatory action on vege-
table oil plants at this time, it would be needlessly
confusing, if not irresponsible, to include vegetable
oil plants in a guidance document intended for current
State regulatory action.
Although we strongly believe that the guidance document
should not include vegetable oil plants, we have agreed
to provide you with preliminary comments. You should
bear in mind, however, that the results of the current
test program will likely necessitate a fresh look at
this situation.
After publication of the CTG, NSPA sent comments thereon
to each potentially affected State (each of these comments
had previously been discussed with personnel from your
Chemical and Petroleum Branch). Since the "guidance
document" currently under consideration is based on the
CTG, we have attached for your present consideration a
copy of our letter to the affected States. The following
paragraphs contain additional comments.
Section XX.9230 (page D-6) requires "at least a 95%
removal of VOC by weight". We believe that 95% removal
far exceeds "reasonably available control technology",
and in fact is at the upper limit of the capabilities
of any removal system. We feel that a 9070 VOC removal
requirement would be more appropriate.
As presently written, the sample regulation does not
require post DT control equipment if the solvent content
of the meal leaving the DT does not exceed 1350 ppm. We
would like you to clarify that individual plants may
achieve the 1350 ppm threshold utilizing any appropriate
method, including but not limited to process modifications
On page D-7 the statement is made that "the air flows
to be controlled are usually small". We would like to
point out that the air flows involved, especially in
the dryer and cooler, are anything but small. We would
expect air flows of approximately 30,000 scfm for a
1,000 ton/day plant.
B-68
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Mr. Tom Williams Page 3
Section XXX.8040 (page L-7) attempts to deal with
"Breakdown, Malfunction and Operation Changes". We
would like to point out that soybean oil plants can
lose several thousand gallons of hexane upon normal
start-up and shut-down. These procedures can be
expected to occur several times per quarter. Accor-
dingly, we would request a specific exemption in the
regulations for emissions which result from start-up
and shutdown.
Section XX.8020 prohibits "the disposal" of more than
1.5 gal/day of VOC. Obviously, VOC can be said to be
"disposed of" during normal operation of a soybean
plant (i.e., hexane evaporation). Accordingly, the
section should be modified to make it clear that the
prohibited act includes only the intentional discarding
of VOC material.
Moreover, and a fundamental shortcoming, the guidance
document makes no distinction as to plant size, plant
age, seed quality (as it affects hexane loss), or type
of seed processed. In fact, some seeds are much more
difficult to desolventize than are soybeans.
The compliance schedules set forth in Section XX.9240
are unnecessarily short. The equipment which will be
required to comply with the regulations will require
extensive engineering and will involve long lead-time
purchases. Furthermore, in most cases the statutorily
mandated compliance date is December 31, 1987. Accordingly,
we believe it is an unwarranted intrusion into the State's
prerogative to have USEPA "suggest" that compliance must
be achieved many years sooner.
In conclusion, we would again like to emphasize our basic
contention, which is that the vegetable oil industry
should not be included in the guidance document which
you are now preparing for distribution to the States. In
view of the fact that your own agency has requested that
States not take action on vegetable oil regulations at
this time, inclusion of the vegetable oil industry in the
guidance document simply increases the paperwork burden
and is likely to lead to needless confusion. If it is in
fact your agency's intention to decrease the regulatory
burden, as we often hear Mr. Costie say, here would be
a good place to start.
ially,
Sneidon J. Hauck
President
B-69
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July 3, 1979
Mr. Tom Williams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, N. C. 27711
Dear Mr. Williams:
As a member of the printed interior panel prefinishing industry,
we have closely followed the progress of the development of
EPA recommendations which affect our industry. We are aware
of the many hours of research and the time spent meeting with
industry representatives and coating suppliers. We feel the
recommendation of limiting volatile organic chemical
emissions to 2.9 kp per 100 square meters of coated finished
product (6.0 Ibs./lOOO sq.ft.) is realistically achievable
by 1982 and will make a significant impact on air quality
when compared to the existing standard.
We also feel a limit of 6.0 Ibs./lOOO sq.ft. is, in fact,
based on the application of reasonable available control
technology (RACT). Problems have arisen in some areas, but
we feel in time the EPA regulations can be achieved. As you
stated in your cover letter, "The intent of the document is
to provide a rational and factual basis for State and local
agencies to develop industry-specific regulations in their
own codes". Vanply, Inc., as a company, believes the
recommendations set forth for our industry are "rational" and
"factual". We ask the State and local agencies to accept the
recommendations as illustrated. Any further restrictions or
lowering of limits through legislative action could not be
realistically acomplished.
Sincerely yours,
VANPLY, INC.
Don R. McDonald
Vice President of Operations
DRMc/jb
B-73
PREFINISHEO PRODUCTS DIVISION P.O. Box 8289 900 North HosKins Road Charlotte, N C 28208 Telephone (704) 392-1315
-------
:: ,i. 'J ' ! C A L M A i\! U ,~A
/
/-
July 12, 1979
Mr. Tom Williams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Re: Comments on Draft Regulations for the
Group II Control Technique Guidelines
for Volatile Organic Compounds
Dear Mr. Williams:
The Pharmaceutical Manufacturers Association is a voluntary non-
profit association composed of 140 companies engaged in the development,
manufacture and marketing of prescription and ethically promoted Pharma-
ceuticals, medical devices and diagnostic products.
While we appreciate the opportunity to comment on the draft, we are
concerned about the informal nature of the comment procedure, as there is
no assurance that PMA's comments or comments of other interested parties
will be considered in finalizing the sample regulations. Indeed, our com-
ments will apparently only be appended, along with other comments, to the
guidance document distributed to the states. In your cover letter accom-
panying the draft regulations you note that they are, "sample regulations
(that) are illustrative in nature and are not to be construed as rulemak-
ing by EPA." You further note that state agencies will propose their own
regulations and hold public hearings on their inclusion in state implemen-
tation plans. However, experience has shown that many states adopt EPA's
sample regulations unchanged in their implementation plans. Thus repre-
sentatives of industry and others are deprived of any meaningful opportunity
to participate in the rulemaking process.
In order to help assure that such a situation does not occur, we
recommend that the guidance document contain a preface which strongly em-
phasizes the illustrative nature of the regulations and which underscores
the need for public participation in the rulemaking procedure.
In addition, we would like to make the following comments on specific
sections of the draft regulations.
B-77
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Condenser, page A-2
The definition of condenser should be expanded to include surface
condenser and barometric condenser. A second sentence should be added as
follows: "A surface condenser effects condensation by indirect contact be-
tween the coolant and the process gas stream. A barometric condenser ef-
fects condensation by direct contact between the coolant and the process gas
stream."
Source, page A-4
"Source" is defined as "any article, container, machine, process
equipment, or other contrivance from which air pollutants emanate or are
emitted, either directly or indirectly." While this definition is con-
sistent with that usually incorporated in state implementation plans, it
is inconsistent with EPA's Prevention of Significant Deterioration regula-
tion (43 FR 26380) and the Emissions Offset'Interpretive Ruling (44 FR 3274).
Both of those define "source" as "any structure, building, facility, equip-
ment, installation or operation (or combination thereof) which is located on
one or more contiguous or adjacent properties and which is owned or operated
by the same person (or persons under common control)." In order to prevent
confusion, we recommend that another term be employed to describe the con-
cept of "source" as used in the draft regulation.
Volatile Organic Compound, page A-4
VOC is defined as having a "vapor pressure greater than 0.1 millimeters
of mercury at standard conditions." The vapor pressure used in the definition
is too low, and should be set at 2.5 psia at standard conditions. A vapor
pressure of 2.5 psia more accurately reflects a volatility commensurate with
the proposed general exemption of sources emitting less than 15 Ibs/day or
3 Ibs/hr. EPA's suggested standard of 0.1 millimeters of mercury has not
been justified, and in fact has been based only on subjective opinions as
to the appropriate standard for the coating industry.
If a state will not. accept a vapor pressure of 2.5 psia, then we
recommend that no vapor pressure limit be included in the definition of VOC,
as individual RACT regulations have their own vapor pressure limits anyway.
§ XX.9420 Applicability, page F-3
We note with approval that Subsection (a) has been changed over earlier
drafts to make the regulation applicable only to nonattainment areas in a
state.
B-78
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Subsection (b) states that the regulation applies to all sources of
VOC that have the potential to emit 6.8 kg/day (15 ib/day) or more. In order
to assure conformance with recommendations made in the Control Techniques
Guideline (CTG) document, we recommend that the following sentence be added
to this subsection: "Implementation should be carried out on a plant by plant
basis."
We recommend that the last sentence of the first paragraph of the
discussion section be replaced by the following language from the Control
Techniques Guideline (CTG) document: "Since many of these individual vents
are likely to be small in any given plant, it may often be reasonable to
regulate on a plant by plant basis. This approach involves determining which
synthesized pharmaceutical manufacturing facilities emit large amounts of
VOC and within such plants which operations are significant sources. Control
requirements would then be imposed after considering local air quality, the
mass rate of emissions, control cost estimates, and plant safety effects."
For clarity, the third and fourth sentences of the second paragraph
of the discussion section should be revised as follows: "Facilities which
perform those functions probably make up the majority of the pharmaceutical
facilities in the United States. However, those facilities that are included
in the definition of synthesized pharmaceutical manufacturing emit the majority
of VOC."
§ XX.9430 Provisions for Specific Processes, page F-4
Subsection (b) (1) should require an 85%, rather than 90%, reduction
in VOC emissions from all air dryers and production equipment exhaust systems
in order to be consistent with current state requirements.
Subsection (d) requires owners/operators to enclose all centrifuges,
rotary vacuum filters, and other filters which process liquids containing VOC
with vapor pressures of 3.50 kPa (0.5 psi) or more at 2QOC. We recommend
that the sentence be changed to read, "...and other filters having an exposed
liquid surface where the liquid contains VOC..." Many pieces of process equip-
ment are operated in a closed fashion to provide for an inert gas purge for
safety reasons. Further, this is the language of the CTG document.
Discussion, page F-6
The last sentence in the first paragraph requires that the temperature
of outlet gases from the surface condenser be monitored in order to determine
compliance with § XX.9430 (a) (1). This subject should more logically be
addressed in the section on monitoring. In any event, such a procedure is
not current practice and would be expensive to implement. Since different
monitoring methods are used at different facilities, we recommend that the
use of coolant outlet temperature, vapor outlet temperature, or condensate
outlet temperature be allowed for determining compliance.
B-79
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The discussion raises the issue of what emission limit should apply
when several different sources, each with a different VOC component, are
manifolded to a single control device. We recommend that under those cir-
cumstances the appropriate emission limit should be determined on a case by
case basis.
The sixth paragraph of the discussion section indicates that the 150
kg/day figure in § XX.9430 (b) was selected because it is the limit below
which it is economically infeasible to control VOC emissions at a 90% emis-
sion reduction efficiency. We recommend that a final sentence be added to
the paragraph as follows: "Current energy and economic factors may suggest
an emission reduction efficiency of less than 90%."
i XX.9440 Compliance Schedule, page F-7
Subsection (a) sets forth compliance schedules based on a January 1,
1980 effective date of the regulation. In general, one and two-year compliance
schedules are much too short, and do not reflect real industry experience in
achieving compliance. With regard to the specific dates set forth, we recom-
mend that commencement of the compliance schedules should begin no sooner
than 180 days after adoption of the State Implementation Plan (SIP). As
drafted, Subsection (a) (1) (i) would require an owner/operator to submit
final plans for emission control systems or process equipment, or both, by
April 15, 1980. To meet such a timetable, preliminary planning would have to
be under way as of this writing and would have to be based on an uncertain
knowledge of the regulations.
In addition, there is no need for separate compliance schedules for
process equipment changes and add-on control devices, and incineration
equipment without heat recovery. Rather, we recommend that owner/operators
submit, within 180 days of approval of the SIP, a compliance plan that in-
cludes target dates for (1) awarding contracts or issuing purchase orders;
(2) initiating ons'.te construction or 'installation of equipment; (3) completing
onsite construction or installation of equipment; and (4) achieving final com-
pliance.
Subsection (b) should be eliminated in light of our previous suggestions.
Discussion, page F-8
Approval of the Food and Drug Administration is required before process
modifications can be made by pharmaceutical manufacturers. This will, of course,
place constraints on the ability of manufacturers to meet compliance deadlines.
Therefore, we recommend that the following be added to the discussion section:
B-80
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"Manufacturers of synthesized pharmaceutical products
must normally seek approval of the Food and Drug Administration
for process changes. Compliance schedules must be flexible
enough to allow additional time for FDA approval."
I XX.9450 Testing and Monitoring, page F-10
Subsection (d) requires continuous monitoring of add-on control
equipment, regardless of size. In order to reduce the burden of this
requirement, we recommend that continuous monitoring be required only for
add-on control equipment with a potential to emit more than 100 tons per
year of regulated pollutants. In addition, only periodic monitoring should
be required for the parameters referred to in subsections (d) (3) and (4).
i XX.801.0 Applicability, page 1-2
Subsection (b) (1) provides that the regulations are not applicable
to sources whose emissions are less than 6.8 kilograms (15 pounds) per day,
and less than 1.4 kilograms (3 pounds) per hour, provided that the emission
rate is determined and certified by March 1, 1980. We recommend that a period
be inserted after "...6.8 kilograms (15 pounds) per day", for two reasons.
First, § XX .9420 indicates that the 1.4 kg/hr standard is not applicable
to the manufacturers of synthesized pharmaceutical products. Second, the
certification requirement is unnecessary and will only add to the paperwork
burden of both the states and industry.
Subsection (b) (2) provides that the regulations are not applicable
to sources used exclusively for chemical or physical analysis or determination
of product quality and commercial acceptance. In order to clarify the pro-
vision, we recommend that the phrase "...such as research facilities, pilot
plant operations, and laboratories" be added after the word "acceptance".
Discussion, page L-3
For the reasons set forth in our comments on § XX.8010 (b) (1), we
recommend that all references to the 1.4 kg/hr limitation and the certifica-
tion requirement be deleted from the discussion section.
I XX.8020 Disposal of Volatile Organic Compounds, page L-4
This section prohibits the disposal of VOC or materials containing
VOC in a manner that would permit their evaooration into the atmosphere. We
recommend that the entire section be deleted, as it would be virtually
impossible to comply with or to enforce. In addition, disposal of hydro-
carbons recovered by control equipment under this regulation is already
B-81
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covered by the Water Pollution Control Act, the Resource Conservation and
Recovery Act, the Safe Drinking Water Act, and other applicable state and
local regulations.
i XX.8030 Inspection, Maintenance and Operating Procedures, page L-5
Subsection (a) requires the owner/operator of a facility to make
available to the Director an Inspection and Maintenance Manual for all con-
trol equipment. Current FDA regulations require pharmaceutical manufacturers
to prepare written maintenance procedures for process equipment, which are
available for examination by FDA inspectors. We recommend that similar
policy be adopted with respect to control equipment so that firms may be
consistent in their approach to the development of procedures for all process
and control equipment, thereby eliminating needless duplication of effort.
Subsection (a) should be revised as follows:
"The owner and operator of a facility subject to these regulations
shall prepare written inspection, maintenance and operating procedures
for all equipment, and such procedures shall be readily available
for use by operating personnel and inspection by the Director."
§ XX.8040 Breakdown, Malfunction and Operation Changes, page L-7
Subsection (a) requires owners/operators to notify the Director of
breakdowns or malfunctions of control equipment of more than 1 hour duration
and breakdowns or malfunctions of process equipment which cause an increased
emission of air contaminants. First, we recommend that "malfunction" be
defined. Second, we recommend that emergency reports be required only if
the breakdown creates an immediate public health hazard. As an alternative
we suggest that owners/operators be required to keep records, which would be
available for inspection, of breakdowns or malfunctions of greater than 1
hour or which cause increased emissions, along with an estimate of any
emission exceedance over permit levels. This requirement should apply only
to sources with a potential to emit 100 tons per year or more. If this
suggestion is implemented, subsections (b), (c) and (d) should be deleted.
The heading of subsection (b) is "Operation Changes", but this matter
is not addressed. Indeed, the subsection continues to address breakdowns
and malfunctions. For clarity, the heading should be changed. Subsection (b)
also provides that affected facilities which have unreasonable breakdown or
malfunction frequency of control equipment shall not be permitted to operate.
We believe that inclusion of a penalty provision in the regulation is inappro-
priate, as penalties are normally addressed in the applicable state law. The
sentence should be deleted.
B-82
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Subsection (c) provides that records of malfunctions and breakdowns
be retained for at least 4 years. We recommend that a 2-year period for
retaining records be required. If necessary to allow for averaging of
emissions or completion of enforcement cases, the period could be increased
to 3 or 4 years.
Subsection (d) requires an owner/operator to notify the Director of
any shutdown, breakdown or malfunction of monitoring systems or devices. Again,
we believe that notification is unnecessary, and we recommend that owners/
operators be required to keep records, which would be available for inspection,
of any shutdown, breakdown or malfunction.
Subsection (e) states that emissions during startup, shutdown, break-
down, or malfunction that exceed emission limitations in the SIP constitute
violations of the plan. We recommend that such an occurrence may constitute
a violation only if due to negligence on the part of the owner/operator.
Discussion, page L-9
The next to the last paragraph of the discussion indicates that
emissions in excess of emission limitations due to shutdown and startup
will be considered in violation of the regulation. However, there are cir-
cumstances in which shutdown and startup will result in unavoidable process
fluctuations which will result in excess emissions. The regulations should
provide some flexibility for such unavoidable situations during shutdown and
startup.
i XX.8050 Circumvention, page L-14
Subsection (b) prohibits the use of gaseous diluents to achieve com-
pliance. This provision should be deleted, as none of the emission control
systems covered by the regulation or the CTG document addressed emission con-
centration.
i XX.8060 Petition for Alternative Controls, page L-15
Subsection (a) sets forth the procedure by which an owner/operator
can petition the Director for the use of alternative emission limits, operational
and/or equipment controls for the reduction of VOC emissions. We strongly
endorse inclusion of a provision which allows the use of alternative controls.
However, we recommend that the following changes be made in this subsection:
a. The deadline for submission of the petition to the
Director should be 180 days after approval of the
SIP.
B-83
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b. Rather than requiring the signature of a company officer
the signature of any responsible company official should be
allowed.
Discussion, page L-16
We recommend that the document allow for variable winter/summer operation
schedules as an alternative control system. Pharmaceutical manufacturers
may have the flexibility to manufacture substances requiring the use of volatile
organic compounds during winter months, scheduling water based operations, then,
for summer months. States could identify the winter months during which they
have experienced no ozone episodes as permissible manufacturing months. In
like manner, we recommend that such energy intensive control systems as
refrigerated condensers and incinerators be allowed to be shut down during
winter months.
I XX.8070 Monitoring, Recordkeeping, Reporting, page L-19
Subsection (a) requires monitors to be installed on all process and
control equipment, as required by the Director. We recommend that monitors
only be required for sources with potential to emit 100 tons or more per year.
Subsection (a) also provides that monitors shall include visual and
audible alarms actuated when the monitored parameters exceed design specifica-
tions. We recommend that the word "shall" be changed to "may", making the
requirement optional, and that the word "and" be changed to "or", so that
both visual and audible alarms are not required.
Subsection (b) (4) requires that records be retained for at least 4
years. We recommend that records be retained for a 2-year period which
could be extended to 3 or 4 years if necessary to allow for averaging of
emissions or comp^tion of enforcement cases.
Subsection (c) (1) requires owners/operators to submit to the Director
reports, at least annually, detailing the nature, source, and quantity of
VOC emissions. We regard the requirement of annual reports as unduly burden-
some, and recommend that the phrase "as a minimum" be changed to "at his re-
quest" .
Discussion, page L-20
The discussion section outlines types of monitoring devices that should
be considered by the Director. As previously discussed in our comment number 6,
B-84
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we recommend that item (3) be revised to read "a device to measure coolant
outlet temperature, vapor outlet temperature, or condensate outlet temperature."
Respectfully submitted,
BRUCE 6. BRENNAN
Vice President and
General Counsel
B-85
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EXECUTIVE OFFICES: 500 SARGENT DRIVE / NEW HAVEN, CONNECTICUT 06507 / 203-562-1161
July 13, 1979
Mr. Tom Williams
Control Development Division MD-15
Environmental Protection Agency
Research Triangle Park
ITorth Carolina 27711
Dear '-ir. Williams:
The following is in response to your request for comment on the draft
sample regulation for the control of V.O.C. emission from tire manu-
facturing :
Reference page G-2 - "tfater based sprays'' definition implies that no
hydrocarbons are present in this material. This is correct for inside
tire spray; but incorrect for (outside tire spray) presently success-
fully used material supplied by SWS Corporation which contains approxi-
mately 10;b hydrocarbons.
Reference page G-lj - The statement, "The following list of operations
are not included in the regulation primarily because of the lower
emission factors for these operations", should be expanded to include
the statement; that except for the Tire Building operation, the balance
of tabulated operations represent in total approximately 3$ of total
tire plant emissions. The cost benefit of control of these sources is
extremely adverse due to their dilute nature, also the pollutant trade-
off and energy requirement implications require careful consideration.
Reference page G-k - In discussing reasons for not controlling emissions
on Tire Building operations the statement is made that "controlling these
emissions is generally economically unfeasible. However, specific circum-
stances may warrant other-wise." It is requested that either this comment
be deleted or the specific circumstance that would warrant control be
defined.
Reference page G-6 - Section j>530 (a)(2)(i) and page G-7 - Our experience
indicates that 95% control equipment efficiency for carbon bed adsorption
is possibly not achievable. Suggest 90$ as a more reasonable number.
B-89
WEST HAVEN A. NATCHEZ A. DES MOINES A. HANFORD A. LITTLE ROCK A. NASHVILLE A. CLINTON A. LAUREL HILL
-------
Mr. Tom Williams July 13, 1979
Environmental Protection Agency page 2
Reference page G-8 - Last paragraph should be corrected to indicate that
presently successfully used green tire outside spray supplied by SWS
contains approximately 10/o hydrocarbon. Other materials currently being
subjected to trials, contain approximately 1% hydrocarbon.
Reference page G-9 - Compliance schedule time of one year is inadequate
for substitution of water based sprays, a process change involving safety
considerations, should be provided a two year compliance schedule.
Reference page G-ll - Last sentence. "Also, too many schedules extending
to the attainment date might prevent a state from showing reasonable further
progress toward attainment". I respectfully submit that in any determina-
tion of what is a reasonable effort (and time frame) for tire companies to
comply with new regulations, that a state's ability to demonstrate adequate
increments of progress should not be a factor.
Reference page L-3 - A four year record keeping requirement is considered
excessive.
Reference page L-7 - (1st paragraph) - Requirement for notification of any
incident of breakdown or malfunction of more than one hour duration of
control equipment - is considered too burdensome for all parties concerned.
Reference page L-7 - (2nd paragraph) - Statement "No affected facility
which has an unreasonable breakdown or malfunction frequency of control
equipment shall be permitted to operate". The term unreasonable requires
definition.
Reference page L-7 -L (3rd paragraph) - Four year record retention time is
excessive.
Reference page L-7 - (last paragraph) - "Emission during start-up, shut-
down, breakdown or malfunction that exceed emission limitations in S.I.P.
plan constitute violations of that plan". Allowances should be made for
extenuating circumstances; as long as good management practices are
followed some discretionary judgement should prevail before citing sources
for violations of emission limitations under stated conditions.
Reference L-19 - "Monitoring, Record Keeping, Reporting". - Considered
excessive.
Reference page L-20 (isro sentence) - While devices to initiate regeneration
upon sensing breakthrough are available, they are much more costly than
time devices which depend on one's ability to predict time-wise when
breakthrough Mill occur. This requirement should be deleted. If carried
to extremes this equipment control device requirement could represent a
major part of equipment investment.
Sincerely,
cc: Janet Weller
,>t rt
F.M. Luysterborghs"
-------
The BFGoodrich Company
500 South Mfj'm Street
Akron, Ohio 44318
Address Reply To: Dept. 3201
Bldg. 10-B
July 13, 1979
Control Programs Development Division
Office of Air Quality Planning and Standards
United States Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Attn: Tom Williams
Project Officer
Dear Mr. Williams:
Attached are our comments to the draft sample regulation regarding
the Control of VOC Emissions from Pneumatic Tire Manufacturing
Facilities.
Should you have any questions after reviewing our comments, please
feel free to call me at 216-379-2781.
Yours truly,
The BFGoodrich Company
R. R. Clark, P.E.
Environmental Engineer
Iw
cc/J. J. Boyd
D. L. Corbett
R. W. Strassburg
T. W. Peterson
M. E. Rossman
Attachments
B-91
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COMMENTS ON
DRAFT
SAMPLE REGULATIONS
CONTROL OF VOLATILE ORGANIC
EMISSIONS FROM TIRE MANUFACTURING
TO:
TOM WILLIAMS
PROJECT OFFICER
CONTROL PROGRAMS DEVELOPMENT DIVISION
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
U. S. EPA
RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
BY:
RONALD R. CLARK, P.E.
ENVIRONMENTAL ENGINEER
THE B F GOODRICH COMPANY
DEPT. 3201 BLDG. 10-B
500 SOUTH MAIN STREET
AKRON, OHIO 44318
TELEPHONE: 216-379-2781
B-92
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DRAFT
July 13, 1979
THE B F GOODRICH COMPANY APPRECIATESTHE OPPORTUNITY TO COMMENT ON THE DRAFT
SAMPLE REGULATIONS FOR CONTROL OF VOC'S FROM TIRE MANUFACTURING FACILITIES. OUR
COMMENTS ARE BRIEF AND ONLY COVER THE GENERAL DEFINITIONS SECTION AND THE MANU-
FACTURE OF PNEUMATIC RUBBER TIRES SECTION.
ATTACHED ARE B F GOODRICH COMPANY'S COMMENTS ON THE THREE DRAFTS OF THE CTG
DOCUMENT FOR TIRE MANUFACTURING. SOME OF THESE COMMENTS ARE STILL APPROPRIATE TO
THE FEASIBILITY OF IMPLEMENTING THE LIMITATIONS OUTLINED IN THE SAMPLE REGULATION.
THEREFORE, WE AGAIN REQUEST THE EPA REVIEW THESE COMMENTS. THE B F GOODRICH
COMPANY ALSO SUPPORTS THE COMMENTS SUBMITTED BY THE RUBBER MANUFACTURERS ASSOCI-
ATION, AND REQUESTS THESE COMMENTS BE THOROUGHLY REVIEWED ALONG WITH OURS.
THE FOLLOWING ARE SPECIFIC COMMENTS LISTED PAGE BY PAGE. WE HAVE TRIED TO
MAKE CONSTRUCTIVE COMMENTS SO THAT A USEFUL, ACCURATE DOCUMENT WILL BE PUBLISHED.
PAGE A-3: DEFINITION OF REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT)
THE RUBBER INDUSTRY HAS A WIDE VARIETY OF PLANTS AND PRODUCTION OPERATIONS.
BECAUSE OF THE UNIQUE NATURE OF EACH PLANT WHAT IS RACT AT ONE FACILITY MAY NOT
BE REASONABLE FOR USE AT ANOTHER FACILITY. THEREFORE, WE BELIEVE THE DEFINITION
OF REASONABLY AVAILABLE CONTROL TECHNOLOGY SHOULD BE AMENDED BY ADDING THE
FOLLOWING SENTENCE:
"RACT FOR A PARTICULAR SOURCE IS DETERMINED ON A CASE-BY-CASE BASIS,
CONSIDERING THE TECHNOLOGICAL AND ECONOMIC CIRCUMSTANCES OF THE IN-
DIVIDUAL SOURCE".
B-93
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PAGE A-3: DEFINITION OF ECONOMICAL INFEASIBILITY
A SAMPLE DEFINITION IS GIVEN FOR TECHNOLOGICAL INFEASIBILITY, THEREFORE,
A DEFINITION SHOULD BE GIVEN FOR ECONOMICAL INFEASIBILITY. WE RECOMMEND THE
FOLLOWING DEFINITION:
"ECONOMICAL INFEASIBILITY: ECONOMICALLY INCAPABLE OF BEING ACCOM-
PLISHED OR CARRIED OUT AS A MATTER OF PRACTICALITY AND SOUND BUSINESS
JUDGEMENT".
IT SHOULD BE NOTED BASED ON THE COST EFFECTIVENESS DATA IN THE CTG DOC-
UMENTS PUBLISHED TO DATE WE BELIEVE IT IS CLEARLY INFEASIBLE TO REQUIRE CONTROLS
WHEN COSTS EXCEED $250/TON OF VOC CONTROLLED. WHEN MINIMUM COSTS OF CONTROLS
EXCEED THIS LEVEL THE CTG CONTAINS A STATEMENT INDICATING DUE TO THE HIGH COSTS
OF CONTROLLING EMISSIONS IT MAY NOT BE REASONABLE TO REQUIRE EMISSION CONTROLS.
(SEE CTG FOR GRAPHIC ARTS - ROTOGRAVURE AND FLEXOGRAPHY, PAGE 1 - 6, OR CTG FOR
SURFACE COATING OF MISCELLANEOUS PARTS AND PRODUCTS, P. 4-2).
PAGE G-2 XX .9510 (b) 1
THE DEFINITION OF "PNEUMATIC RUBBER TIRE MANUFACTURE" IS NOT CONSISTENT
WITH THE PROCESSES COVERED BY THE CTG. THE CTG ONLY ADDRESSES PASSENGER-TYPE RUBBER
TIRES. ALL TIRES, INCLUDING LARGE OFF-THE-ROAD TIRES, ARE "MANUFACTURED ON ASSEMBLY
LINES USING AUTOMATED EQUIPMENT". (EMPHASES ADDED) HOWEVER, MANY SECTIONS OF THE
CTG DOCUMENT ARE NOT APPROPRIATE TO THE MANUFACTURING OF OFF-THE-ROAD TIRES. THIS
DEFINITION IS AN ISSUE BEING DISCUSSED AS A PART OF THE EPA AND THE TIRE INDUSTRY
LITIGATION INVOLVING THE SUBJECT. WE REQUEST THE DEFINITION BE ADOPTED WHICH IS
DEVELOPED AS A RESULT OF LITIGATION.
B-94
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PAGE G-2 (COMT'D):
THE DEFINITION OF "WATER-BASED SPRAYS" IS NOT ACCURATE. WE ARE NOT AWARE
OF ANY WATER-BASED RELEASE AGENTS COMMERCIALLY AVAILABLE WHICH CONTAIN NO ORGANIC
SOLVENTS. TO AVOID FUTURE CONFUSION WE RECOMMEND THE DEFINITION BE CHANGE TO READ
AS FOLLOWS:
"'WATER-BASED SPRAYS' MEANS RELEASE COMPOUNDS, SPRAYED ON THE INSIDE AND
OUTSIDE OF GREEN TIRES, IN WHICH SOLIDS, WATER, AND EMULSIFIERS HAVE
REPLACED ALL BUT TRACE AMOUNTS OF ORGANIC SOLVENTS".
PAGE G-3: DISCUSSION
THE THIRD AND FOURTH SENTENCES IN THE FIRST PARAGRAPH SHOULD BE REVISED TO
READ:
"THE RACT CONTROL TECHNIQUE IS CONVERSION TO WATER-BASED SPRAYS.
THE ALTERNATIVE CONTROL METHODS, CARBON ABSORPTION AND INCINERATION,
WOULD NOT NORMALLY BE CONSIDERED RACT. CARBON ABSORPTION IS NOT TECHNICALLY
FEASIBLE DUE TO SOLIDS PLUGGING THE FILTER BEDS. INCINERATION IS NOT
ECONOMICALLY FEASIBLE DUE TO THE LARGE EXHAUST AIR FLOWS, AND THE FUEL
REQUIREMENTS TO INCINERATE THESE AIR FLOWS".
PAGE G-4:
WE STRONGLY OBJECT TO THE CONCLUSIONS INFERRED IN THE SECOND PARAGRAPH,
PAGE G-4, THE REFERENCE TO CONTROLLING OTHER TIRE MANUFACTURING PROCESSES, AND THE
INCLUSION OF UNSUPPORTED EMISSION FACTORS FOR THESE PROCESSES. EXCEPT FOR TIRE
BUILDING, THERE IS NO DATA WHICH SUPPORTS THE EMISSION FACTORS GIVEN IN THE TABLE.
WITHOUT INFORMATION QUANTIFYING THE EMISSION IT IS IMPOSSIBLE TO KNOW IF CONTROLS
ARE EVEN NECESSARY. THEREFORE, IT SHOULD NOT BE IMPLIED THAT THE STATES MAY FIND
CASES IN WHICH CONTROLS ARE WARRANTED. THIS PARAGRAPH SHOULD BE REVISED TO READ:
B-95
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PAGE G-4 CONT'D:
"THE OTHER MANUFACTURING PROCESSES IN A TIRE PLANT (e.g) TIRE BUILDING,
COMPOUNDING, CURING) DO NOT WARRANT THE INSTALLATION OF RACT".
PAGE G-5:
THE FIRST PARAGRAPH SHOULD BE REVISED TO READ:
"THE APPLICABILITY OF THE GUIDELINE WILL NOT BE LIMITED BY THE SIZE
OF THE PLANT. SINCE THE AVERAGE PLANT PRODUCES 16,000 TIRES PER DAY
AND EMITS AN ESTIMATED 1,000 METRIC TON/YR (1,100 ton/yr), IT IS AS-
SUMED THAT ALL PLANTS WHICH MANUFACTURE PNEUMATIC RUBBER PASSENGER-TYPE
TIRES LOCATED IN NON-ATTAINMENT AREAS WILL BE SUBJECT TO THIS REGULATION".
PAGE G-6 XX .9530 (a)2 (iii):
IF 90 PER CENT REDUCTION EFFICIENCY IS SATISFACTORY FOR INCINERATION, THERE
IS NO JUSTIFICATION FOR SETTING THE MINIMUM REDUCTION EFFICIENCY FOR AN ALTERNATIVE
VOLATILE ORGANIC COMPOUND EMISSION REDUCTION SYSTEM AT 95.0 PER CENT. THEREFORE,
WE REQUEST THAT THE 95.0 PER CENT REQUIREMENT BE LOWERED TO THE 90.0 PER CENT LEVEL.
PAGE G-8: DISCUSSION
THE FIRST PARAGRAPH DISCUSSES THE MINIMUM CAPTURE EFFICIENCY REQUIREMENT, AND
REQUESTS COMMENTS ON METHODS OF ASSURING THAT MAXIMUM REASONABLE CAPTURE WILL BE
ATTAINED. WE BELIEVE THIS IS SOMETHING THAT WILL HAVE TO BE WORKED OUT ON A CASE-
BY-CASE BASES BETWEEN PLANTS AND THE STATES. VENTILATION IS MORE OF AN ART THAN A
SCIENCE AND BECAUSE OF THIS, ONE USUALLY DOES NOT KNOW WHAT THE CAPTURE EFFICIENCY
WILL BE UNTIL IT IS TESTED. THEREFORE, WE WOULD SUGGEST IT BE RECOMMENDED THE
STATES REVIEW WITH EACH PLANT ITS PROPOSED VENTILATION SYSTEM AND AGREE TO ITS GOOD
ENGINEERING DESIGN. IF AFTER INSTALLATION TESTING SHOWS THE CAPTURE EFFICIENCY IS
BELOW THAT ANTICIPATED, IT rtlLL HAVE BEEN ALREADY AGREED THAT THE BEST RACT SYSTEM
WAS INSTALLED. B_96
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PAGE G-9 XX 9540:
"TIRES" IS A PRODUCT THAT HAS TO ADHERE TO STRINGENT SAFETY REQUIREMENTS.
ANY PROCESS OR TECHNOLOGY CHANGES HAVE TO GO THROUGH A LENGTHY EVALUATION PROCESS
BEFORE IMPLEMENTATION CAN BE EVEN CONSIDERED. THE ESTABLISHMENT OF SPECIFIC DATES
FOR COMPLIANCE IN MANY CASES MAY NOT BE POSSIBLE. THIS SHOULD BE NOTED IN THE
SAMPLE REGULATIONS TO THE STATES.
BEING SPECIFIC, BFGOODRICH PROBABLY COULD NOT COMPLY WITH A REQUIREMENT TO
CONVERT TO WATER-BASED SPRAYS WITHIN ONE YEAR FOR SOME PRODUCTS.
THIS COMPLETES OUR SPECIFIC COMMENTS ON THE SAMPLE REGULATION. OUR UNDER-
LYING CONCERN IS THAT THE SAMPLE REGULATION STATE IT IS NOT MANDATORY, AND THAT
STATES HAVE FLEXIBILITY TO DETERMINE WHETHER, AND TO WHAT EXTENT, CONTROL OF HYDRO-
CARBON EMISSIONS IS NECESSARY AT EACH PARTICULAR TIRE PLANT. THE SAMPLE REGULATION
SHOULD BE A GENERAL GUIDELINE FOR THE STATES TO REFER TO DURING THE DEVELOPMENT OF
SOURCE SPECIFIC REGULATIONS.
B-97
7/13/79
Iw
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CERTIFIED—Return
Receipt Requested
July 6, 1979
Mr. Thomas Williams
Control Programs Development Division
MD-15
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Re: Sample Regulations to Implement CTG for
Manufacture of Pneumatic Rubber Tires
Dear Mr. Williams:
On behalf of The Firestone Tire & Rubber Company, I am
submitting comments on the above-referenced document which
you have circulated to all interested parties for comment.
The above-referenced sample regulations attempt to implement
the CTG for pneumatic rubber tires which was issued in
December, 1978.
Firestone first objects to the concept of sample regulations
which would be distributed to states in order that the
states may incorporate the CTG into their respective state
implementation plans. We do not believe that issuance of
CTG's by the U.S. Environmental Protection Agency is authorized
by the Clean Air Act, and we do not believe that sample or
model regulations are authorized. We, further, do not see
the need for the sample regulations since the CTG is quite
explicit and detailed as to the technical information which
the EPA wishes to communicate to the states. We believe
that the states are more than capable of developing their
own regulations from the CTG.
On numerous occasions, representatives of the U.S. EPA have
informed Firestone representatives that states are not
required to incorporate the CTG, verbatim, into their state
regulations? but rather, the state has flexibility and
discretion with regard to including the recommendations of
the CTG into their state implementation plans. We strenuously
object to the sample regulations since they make no mention
of state flexibility or discretion in applying the CTG to
the sources within a particular state. The states must be
given guidance that they are authorized to conduct case-by-
case determinations of RACT for sources within their state,
independent of the CTG recommendation.
B-98
THE FIRESTONE TIRE & RUBBER COV1PANN •
-------
Mr. Thomas Williams July 6, 1979
The sample regulations require control of undertread cementing,
tread end cementing, bead dipping and green tire spraying.
We do not believe that carbon adsorption or incineration
represents RACT for tread end cementing, particularly since
Firestone employs manual tread end cementing. The December,
1978, CTG did not even consider manual tread end cementing
or does not even acknowledge that EPA was aware of such a
process. Firestone's use of manual tread end cementing
utilizes less solvent than the 15 grams per tire indicated
in the sample regulations. A survey of Firestone plants has
revealed usage of 3.5 to 8.0 grams per tire with an average
application of 6.2 grams of solvent per tire. Firestone's
manual tread end cementing, therefore, approaches a "controlled"
tread end cementing station and we believe that Firestone is
already meeting RACT on tread end cementing due to the lower
VOC emissions. Firestone, further, submits that it is not
physically possible to install capture equipment which would
even approach 85% capture efficiency due to the particular
nature of manual tread end cementing and the need for worker
accessibility.
Firestone also submits that carbon adsorption and incineration
are not RACT for the bead dipping operation. The sample
regulations state that these emissions will be about 3% of
the total VOC emissions from an average facility. The CTG
estimates capture costs for carbon adsorption at $250,000,
which does not seem reasonable considering the amount of
emissions. Incineration for control of bead dipping operations
would be less costly but would require substantial quantities
of fuel energy and would produce emissions of air pollutants
roughly equivalent to the emissions being controlled.
Control of undertread cementing has been accomplished at one
plant in the U.S. and we view this technology as still in
the experimental stage and not RACT. Depending on plant
configurations, there may also be serious feasibility
questions and excessive costs in retrofitting control technology
of undertread cementing.
Our Company notes that the sample regulations make several
references to incineration without specifying whether the
reference is to direct flame or catalytic incineration.
The sample regulations include other operations emitting
VOC's for which no control is being recommended. Tire
building is one of these areas and the sample regulations
include some justification for not including tire building
emissions. We object, however, to the last sentence in
paragraph 2 on page G-4 of the regulations which indicates
B-99
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Mr. Thomas Williams July 6, 1979
that specific circumstances may warrant otherwise with
regard to control of tire building. We respectfully request
that this sentence be deleted since no explanation is given
for this sentence and EPA has discovered no circumstances
under which control of tire building emissions would represent
RACT. Our Company further questions the accuracy of the
emission rates contained in the table on page G-4 of the
model regulations.
Section XX.9530(a)(1) of the sample regulations indicates
that the capture system shall be designed to achieve capture
of up to 85% of VOC emitted. We are not certain of the
meaning of this provision, but we object to 85% capture
efficiency as a goal for any of these processes. The CTG
indicates capture efficiencies of 65-85% for undertread
cementing, 65-85% for tread end cementing and 75-85% for
bead dipping. (Table L-l, page 1-4.) Thus, the sample
regulations seize on the maximum possible capture efficiency
as indicated by the CTG. The lower end of the range, as
specified in the CTG, is a much more reasonable capture
efficiency although Firestone has serious reservations about
even this number. Firestone, particularly, believes that a
65% capture efficiency cannot be achieved from control of
manual tread end cementing and undertread cementing.
The model regulations also specify a 95% efficiency of
carbon adsorption across the control device and Firestone
objects to this number as being unreasonable and suggests
that such removal efficiency be specified as 90%.
The sample regulations indicate that water-based sprays are
presently avciilable for green tire spraying. It is Firestone's
experience that water-based sprays currently available may
contain more than 2% solvent and may contain up to 11%
solvent in some situations. We must also point out that
carbon adsorption is not a viable alternative for control of
green tire spraying since particulates would "carry over"
into the carbon adsorption bed and plug the bed, making it
inoperative.
Firestone, further, objects to Section XX.9540 of the sample
regulations dealing with compliance schedules. First, we
believe that there is no need for the regulations to include
detailed compliance schedules with increments of progress
since this is usually best determined on a case-by-case
basis. A final compliance date is all that is needed to be
included in the regulations and Firestone submits that this
B-100
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Mr. Thomas Williams July 6, 1979
compliance date should not be specified as earlier than
December 31, 1982. We believe that more than two years will
be needed for add-on control equipment and more than one
year will be needed for process modifications in our particular
safety-related industry.
We appreciate the opportunity to provide comments on the
sample regulations which have been proposed and we hope that
EPA will carefully consider the foregoing comments.
Very truly yours,
h f\! , , Ju A , I
' ' ' "
Robert M. Walter
Assistant Counsel
(216/379-6693)
RMWrslp
B-101
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CERTIFIED—Return
Receipt Requested
July 12, 1979
Mr. Thomas Williams
Control Programs Development Division
MD-15
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Re: Sample Regulations to Implement CTG for
Manufacture of Pneumatic Rubber Tires
Dear Hr. Williams:
On "behalf of The Firestone Tire & Rubber Company, I am
submitting additional comments on the above-referenced
document which you have circulated to all interested
parties for comment. The following comments supplement
our written comments submitted by letter dated July 6,
1979- Those comments address issues raised by the sample
regulations which attempt to implement the CTG for pneu-
matic rubber tires.
The sample regulations distributed go beyond the CTG for
pneumatic rubber tires and suggest regulations dealing
with testing and monitoring; disposal of volatile organic
compounds; inspection, maintenance and operating procedures;
breakdown, malfunction and operation changes; and monitoring,
recordkeeping and reporting. Our Company respectfully
submits that these provisions should not be included in
the sample regulations. We believe that establishment of
such requirements is best handled on an individual basis
by the states and that these matters are totally within
the discretion of each state. Firestone also believes that
many of these requirements must be determined by each state
in light of the particular industry involved, the particular
control techniques utilized and the characteristics of the
operation and plant which would be affected.
We hope that EPA will consider the foregoing comments as
well as the comments submitted by our July 6, 1979 » letter.
Very truly yours,
Robert K. Walter
Assistant Counsel
1216/379-6693;
T H f=_ FIRESTONE TIRE & RUBBER COMPANY « 12OO FIRES TO N E P A R K W AY « AKRON, OHIO 4431
BMW : sip B-102
-------
THE GENERAL TIRE & RUBBER COMPANY
TIRE , ONE GENERAL STREET AKRON OHIO 44329
"* July 12, 197y
Mr. Tom Williams
Control Programs Development Division MD-15
Research Triangle Park., NC 27711
Re: Comments to a Guidance Document for the Group II Control
Technique Guidelines for Volatile Organic Compounds
Gentlemen:
The following comments are in response to the document identified
above, transmitted to "all interested parties" in your letter of
June 15, 1979- Currently, litigation is in progress in the United
States District Court for the District of Delaware with the Rubber
Manufacturers Association, Inc., The General Tire & Rubber Company,
and eleven other rubber manufacturers as plaintiffs and the U.S.
Environmental Protection Agency as defendant, case identification
being "Civil Action No. 79-189." In that lawsuit, the plaintiffs
have challenged many aspects of the procedures and substitutive
provisions employed by the EPA in the development and implementation
of the control technique guidelines entitled "Control of Volatile
Organic Emissions from Manufacturer of Pneumatic Rubber Tires."
Since many of the substitutive provisions of the subject "Guidance
Document" are identical and, in some cases, even more stringent than
the CTG, which is the subject of the lawsuit, and since the proposed
promulgation of the subject document by EPA will equally violate the
procedural objections in the lawsuit made to the promulgation of the
CTG, our Company objects to the issuance of the subject "Guidance
Document."
A copy of the complaint in the referenced lawsuit is attached hereto
and made a part hereof by tnis reference and shall constitute specific
objections arid comments to the subject "Guidance Document" and to the
implementation by your agency of the "Guidance Document". To the
extent the subject document is more stringent in its requirements for
control of volatile organic compounds than the CTG, objection is made
beyond the terms of the attached complaint, to the provisions that
are more stringent.
A partial list of substitutive provisions follows to which specific
objection is made:
B-103
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THE GENERAL TIRE ft RUBBER COMPANY
1) Coverage of the tire industry. The tire industry's contri-
bution to air pollution resulting from the manufacture of
tires in the area sought to be controlled by the CTG and
"Guidance Document" is such a small portion of the total
pollutants of this nature that, in view of the cost and
energy requirements, it is unreasonable to require their
control.
2) The definition of pneumatic rubber tire manufacture should
be clarified to indicate that only tires manufactured on
automatic assembly lines and falling within the size ranges
of passenger and light trucks are to be controlled by the
guideline.
3) Page G-3. Applicability - This statement is too broad and
includes facilities that contribute insignificantly to
hydrocarbon emissions.
4) Page G-3. Tread end cementing and bead dipping inclusions
in the applicability provisions is unreasonable in view of
the minute contribution to hydrocarbon emissions and the
costs and energy requirements for their control.
5) Page G-4. There are no known circumstances which would cause
the inclusion of the list of operations that are considered
infeasible from an economic point of view to be brought under
this regulation. The suggestion that there may be specific
circumstances, otherwise warranting their inclusion, is
without basis in fact.
6) Page G-5. The last paragraph indicating, that since the
average production facility emits a specified amount of
hydrocarbons, all plants must be controlled, is an unreason-
able statement and without basis in fact. There are
numerous facilities that contribute insignificantly when
compared to larger production facilities and their control
is patently unreasonable.
7) Page G-5- In the last line on page G-5 a reference is made
to the "Guidance Document" as follows:
"Subject to this regulation."
We know of no said statute or regulation of the EPA which would
elevate this "Guidance Document" to the status of a regula-
tion. Since it is apparently deemed by EPA to be a regula-
tion, then we object to its implementation due to violation of
the rulemaking provisions of the applicable Federal Statutes
and administrative law requirements for proper development of
regulations.
B-104
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THE GENERAL TIRE Ot RUBBER COMPANY
This objection will not appear again, although there are
numerous other locations through the "Guidance Document"
where it is referred to as a regulation.
8) Page G-6. The capture and control values are unreasonable
in view of the cost and energy requirements. Furthermore,
the authorities relied upon in establishing these values
are not valid since they were not developed for the purpose
of controlling hydrocarbon emissions for purposes of diminish-
ment of air pollution.
9) Page G-7. We restate the objections to the values for capture
and control set forth immediately above. Furthermore,
additional time is required for evaluation of water base
spray to assure its compliance with quality control standards
of the industry.
10) Page G-8. We object to the inclusion of tire recapping
industry which has not been previously covered in CTG
documents.
11) Page G-9. The compliance schedule has not been determined
to be a reasonable schedule in view of product safety consid-
erations, energy cost and cost to the manufacturers. It was
developed without regard to, or without opportunity for,
comment by the industry.
12) Page G-12. Objection is made to continuous monitoring due
to cost and technology considerations. Test procedures relied
upon in this section are not valid since they have not been
established for hydrocarbon emission control in the tire
industry.
Part III. The following comments to this part are with respect to the
application of the general provisions on manufacture of pneumatic
rubber tires only. No comments are intended to be directed to the
application of Part III to the other chapters it is intended to cover,
such as coated fabric operations.
13) Page L-5- Record keeping and monitoring regulations for
system effectiveness, maintenance and repairs is unreasonable
and overly burdensome. Certification of compliance should
be sufficient.
14) Page L-7. Definition of unreasonable breakdown and malfunc-
tion as well as emissions during start up, shutdown, break-
down or malfunctions should be specified in paragraph B and S
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THE GENERAL TIRE & RUBBER COMPANY
where these terms appear. As written, it would be subject
to subjective interpretation. Operator error should be an
exception. We repeat our objection to recordkeeping in
paragraph c.
15) The entirety of the general provisions in Part III have
been prepared without opportunity for industry comment and
participation and many of the provisions, too numerous to
respond to in this letter, are without basis in fact and
would, in operation, prove to be impracticable, unreason-
able, unduly burdensome, and in some cases, impossible to
implement. To tne extent these general provisions would
apply to coated fabric operations, we reserve the right to
make comments to them as they would apply to the specific
"Guidance Document" to be issued with regard to coated
fabrics.
Conclusion. The "Guidance Document" and the CTG referred to in the
opening paragraphs are both primarily deficient because of the failure
to inform the States of their ability to adapt the information con-
tained therein to each particular tire facility affected by these
documents. Case-by-case determination of RACT is the cornerstone of
the legislative history and regulatory procedures under the Clean Air
Act and other environmental legislation. To the extent the "Guidance
Document" does not contain this disclosure, this Company objects to
its dissemination due to the disruptions in governmental communications
that will result if it is adopted by the states and determined to be
RACT in all cases. The states are required to apply reason in imple-
menting federally mandated clean air standards. This would include
evaluation of many factors not set forth in the "Guidance Document."
To the extent the "Guidance Document" fails to illustrate for the
states the factors to be considered and the flexibility available in
applying the standards, this Company objects to its dissemination.
The above comments in no way are intended to modify, amend or revoke
any of the allegations in the referenced lawsuit and do not constitute
admissions or concessions on the part of this Company as a party
plaintiff in connection with said suit.
spectfully submitted,
I Jam^s D. Troxell, Attorney
V
\^_y
B-106
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July 13, 1979
Mr Tom Williams
Control Programs Development Division, MD-15
Environmental Protection Agency
Research Triangle Park
North Carolina 27711
Re: Comments of The Goodyear Tire & Rubber Company
On the Draft Sample Regulation for the
Control of VOC Emissions from Tire Manufacturing
Dear Mr Williams:
Goodyear appreciates the opportunity to comment on the draft
sample regulation for the control of emissions of volatile
organic compounds (VOC) from tire manufacturing.
We endorse and incorporate by reference the comments of the
Rubber Manufacturers Association on the above-referenced
draft sample regulation and submit the following additional
comments for your consideration.
Definitions (Section XX.9510)
The scope of the sample regulation should be limited to the
manufacture of pneumatic rubber passenger-type tires. The
definition of "Pneumatic Rubber Tire Manufacture" should be
replaced with the following:
"Manufacture of pneumatic rubber, passenger-type tires"
means the production of pneumatic rubber passenger-type
tires on a mass production basis. Generally, "Passenger-
type" tires include bead diameters through 16.5" and
cross sections through 12.8". Actual dimensions of this
category may vary within the industry. Most agricultural,
mobile home and light truck tires in this size range are
included. However, where a plant produces specialty
tires for antique or other vehicles, or other tires on
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an irregular basis or with short production runs, or
tires produced in connection with research and design or
a pilot plant, such production does not fall within the
scope of this definition even where some mass production
equipment is used during the manufacturing process.
Discussion (pp. 6-3 - 6-5)
Various statements in this section and throughout the draft
regulation should be revised or deleted for the reason that
the Clean Air Act does not authorize the use of CTGs to deter-
mine or define RACT. Any statements that state or imply a
definition or determination of RACT by the use of CTGs should
be deleted or modified accordingly.
We also recommend the deletion of the last sentence in this
section.
Provisions for Specific Processes (Section XX.9530)
Goodyear recommends the deletion of the provisions for specific
processes contained in Section XX.9530 of the draft sample
regulations. In view of the fact that RACT must be determined
on a case-by-case basis under the Clean Air Act, we believe
it is inappropriate for either the sample regulation or the
Control Technique Guideline (CTG) for tire manufacturing to
prescribe particular control levels, control techniques and
capture efficiencies.
RACT cannot be established, defined or prescribed on an indus-
try-wide basis due to the fact that each facility has unique
physical, process and other characteristics. In addition, the
inclusion of generic provisions will infringe on the discretion
of the States to determine what constitutes RACT on an individual
case-by-case basis.
In view of the requirements of the Clean Air Act, we believe
that both the sample regulation and the CTG should be back-
ground documents that contain general information only. We
recommend that the sample regulation be revised to expressly
inform the States that it contains general guidelines and that
the States are free to make individual determinations regarding
the types and levels of control that constitute RACT, taking
into account technological and economic feasibility and the
unique circumstances of each tire manufacturing facility.
The application of RACT to a particular plant must consider
all the circumstances related to the control of VOC emissions
from that plant.
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We believe the sample regulation should set forth, and each
State should consider, the following factors in determining
the particular control levels, control techniques and capture
efficiencies that constitute RACT for a particular facility:
1) The need for controls;
2) The cost effectiveness of the control technique or
practice;
3) The capital expenditure necessary to achieve a cer-
tain capture efficiency;
4) The energy requirements of the control technique or
practice;
5) The impact of required costs on affected parties;
6) The physical design and layout of the plant and equip-
ment;
7) The other pollutants created by the use of the con-
trol technique or practice;
8) The impact of the control technique or practice on
the ability of the plant to comply with product
safety requirements;
9) The impact of the control technique or practice on
the safety of the work environment.
We suggest that RACT and any applicable regulation implement-
ing the requirements of RACT be established on a case-by-case
basis with due consideration given to the factors listed above,
The regulation must allow each State sufficient leeway in
determining whether implementation of a control technique is
practicable and reasonable when viewed from the limitations
imposed by plant space availability, compatibility with exist-
ing technological facilities, employee safety requirements and
plant design constraints.
We commend the Agency's recognition of how difficult it is to
draft a generic regulation for tire manufacturing. Such draft-
ing difficulties are highlighted by the absence in the draft
regulation of any consideration of reduced solvent usage as
an acceptable means of reducing hydrocarbon emissions which
B-109
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is essentially the result when manual tread-end cementing is
employed instead of the alternative automatic method.
Due to the unavoidable diversity prevalent in the tire manu-
facturing industry, a clear, illustrative definition of the
factors to be considered by the States in establishing RACT
should be set forth in the draft regulation. Anything more
will limit the discretionary initiative of States to base
their RACT determinations on such basic factors as discussed
above.
Discussion (p. G-8)
No specific capture efficiency goal should be set in view of
varying physical limitations. Because of limited technical
data and correlations, it will not be possible to accurately
specify a value.
Discussion (pp. G-10 - G-ll)
The first paragraph should be deleted. Categorical compliance
schedules are inappropriate in view of the varying character-
istics of different facilities and the time that is required
to assess the impact of process changes on product safety
requirements.
We believe the EPA should give special consideration and
attention to the impact of control techniques or practices on
product safety and the safety of the work environment. The
Agency should also bear in mind that the safety of pneumatic
rubber tires is of paramount concern to not only the owner or
operator of the tire manufacturing plant but to other regula-
tory agencies. Process changes can be made only after exhaust-
ive testing.
Testing and Monitoring (Section XX.9550)
The testing and monitoring provisions should be deleted. The
proposed provisions are inappropriate in view of the varying
circumstances at various tire manufacturing facilities.
GENERAL PROVISIONS
Discussion (pp. L-2 - L-3)
The second sentence of the first paragraph of page L-2 of the
draft sample regulation, "dsr", should be deleted in its
B-110
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entirety, or as an alternative, the regulation should expressly
indicate that notwithstanding the Criteria for Approval of
1979 SIP Revisions memorandum (February 24, 1978), the informa-
tion contained in the CTGs does not establish nor determine
RACT.
Disposal of VOCs (Section XX.8020)
The provision (Section XX.8020) relating to the disposal of
VOC, we submit, should be deleted, or in the alternative, the
concentration of VOC and the size of the facility disposing
of such VOC compounds or materials to which the regulatory
prohibitions or limitations are applicable should be clearly
set forth in the regulations.
Inspection, Maintenance and Operating Procedures (Section XX.8030)
The requirements of inspection, maintenance and operating pro-
cedures (Section XX.8030) are burdensome and will generate
unnecessary paperwork and recordkeeping. The States would be
in a better position to determine what inspections, maintenance
and operating are necessary relative to the industry and control
techniques involved. We suggest the section on inspection,
maintenance and operating procedures be deleted.
Breakdown, Malfunction and Operation
The procedures for reporting and recording breakdowns, mal-
functions and operation changes should be left to the discre-
tion of each State in accordance with the Agency's "Workshop
on Requirements for Non-attainment Area Plans" manual.
Monitoring, Recordkeeping, Reporting
Similarly, the provisions for monitoring, recordkeeping and
reporting should be deleted from the sample regulation and
left to discretion of each State (Section XX.8070).
Respectfully submitted,
•4.-1
TI/GIK F R Tully, Director
dsp Governmental Environment, Safety
And Health Assurance Programs
The Goodyear Tire & Rubber Company
1144 East Market Street
Akron, Ohio 44316
B-lll
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RUBBER MANUFACTURERS ASSOCIATION
1901 PENNSYLVANIA AVE . N W • WASHINGTON, D G 2DOOB • (20V 785 2602
July 13, 1979
Mr. Tom Williams
Control Programs Development
Division, MD-15
United States Er. /ironmental
Protection Agency
Research Triangle Park, North Carolina 27711
Re: Review of Draft Sample Regulation
Dear Mr. Williams:
The Rubber Manufacturers Association (RMA) wishes to
submit the enclosed comments on EPA's draft sample regulation for
the control of emissions of volatile organic compounds from
pneumatic rubber tire manufacturing.
The RMA and its member companies strongly urge the
Agency to consider these comments before finalizing its guidance
document.
Respectfully submitted,
O
f T/
1-L..-S I ' L
Frank T. Ryan
Director, Environmental
Health & Safety Affairs
FTR:jlv
Enclosure
B-112
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COMMENTS OF
THE RUBBER MANUFACTURERS ASSOCIATION
ON THE
ENVIRONMENTAL PROTECTION AGENCY'S
DRAFT SAMPLE REGULATION
FOR THE
CONTROL OF EMISSIONS OF VOLATILE ORGANIC COMPOUNDS
FROM THE MANUFACTURE OF PNEUMATIC RUBBER TIRES
July 13, 1979
B-113
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The Rubber Manufacturers Association ("RMA"), on behalf of
itself and its member companies, appreciates the opportunity to
comment on the draft sample regulation for the control of emissions
of volatile organic compounds ("VOC") from pneumatic rubber tire
manufacturing. The RMA "nas the following general and specific
comments on the draft sample regulation.
I. GENERAL COMMENT
The RMA strongly believes that the sample regulation
must emphasize the authority and flexibility that each State has
under the Clean Air Act to determine whether, and to what extent,
control of hydrocarbon emissions is necessary at individual tire
manufacturing facilities. The sample regulation should be a general
guideline to which a State can refer during the development and
drafting of its own regulations that reflect the particular circum-
stances of each tire manufacturing facility within that State.
The draft sample regulation fails to address either the
proper purpose and use of the sample regulation or the interrelation
of the sample regulation, the Control Technique Guideline for tire
manufacturing ("the tire-making CTG"), and the requirements of the
Clean Air Act. To provide such information, the sample regulation
for tire manufacturing should contain the following introductory
statement:
B-114
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Section 172 of the Clean Air Act requires
States to adopt reasonably available control measures,
including reasonably available control technology
("RACT") for stationary sources. The States have
until January 1980 to adopt RACT requirements for
those tire manufacturing facilities located in areas
that have not yet been able to attain compliance
with the national primary and secondary ambient air
quality standards.
The sample regulation for the control of
VOC emissions from tire manufacturing is part of
an EPA effort to aid States in determining whether,
and to what extent, RACT requires controls at individual
tire manufacturing facilities. RACT for nonattain-
ment areas has been defined as the lowest emission
limit that a particular source is capable of meeting
by that application of control technology that is
reasonably available considering technological and
economic feasibility. RACT for a particular tire
manufacturing facility is to be determined on a case-
by-case basis, taking into account a variety of factors,
including the technological and economic constraints
that affect that facility.
EPA has also issued a Control Technique
Guideline entitled "Control of Volatile Organic
Emissions from Manufacture of Pneumatic Rubber Tires",
EPA-450/2-78-030 (December 1978). Notwithstanding the
language contained in the Control Technique Guideline
for tire manufacturing ("tire-making CTG"), the docu-
ment does not establish RACT. The purpose of the docu-
ment is to provide State and local air pollution control
authorities with general information on the control
techniques that can be used to control VOC emissions
from various stages of tire manufacturing. This infor-
mation addresses the general problems of the entire
tire manufacturing industry and is intended to serve
as a useful background document as the States begin
to determine what control techniques constitute RACT
at particular tire manufacturing facilities. EPA
recommends that the tire-making CTG be viewed as an
initial reference point which does not take into
account the unique circumstances of each tire manu-
facturing facility.I/
_!/ EPA has indicated its willingness to consider the tire-
making CTG to be only an underlying basis for the
development of individual State regulations appropriate
for various tire manufacturing facilities. EPA
has elaborated upon the function of CTGs in a draft
statement entitled "Control Techniques Guidelines
for Sources of Volatile Organic Compounds", a copy
of which is attached as Appendix A to this comment.
B-115
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In EPA's words, the tire-making CTG and
the sample regulation set forth a "presumptive norm"
for RACT for tire manufacturing. This presumptive
norm is, however, merely a suggestion of which control
techniques might be appropriate RACT based on EPA's
study of some of the problems general to the tire
manufacturing industry. Neither the tire-making CTG
nor the sample regulation establish or define RACT
for the tire manufacturing industry. The application
of RACT to a particular plant must reflect all the
circumstances relevant to the control of VOC emissions
from that plant, including the extent to which that
area has reached attainment of the national ambient
air quality stcindards.
The legislative history of the Clean Air Act
makes it clear that RACT cannot be established on
an industry-wide basis but must be based on the
individual characteristics and requirements of each
tire manufacturing facility. In order to properly
determine what level or type of control constitutes
RACT at a tire manufacturing facility, a State must
identify and take into account the various factors
affecting that facility and then revise or reject
the techniques discussed in the tire-making CTG
accordingly. The sample regulation should aid the
States in either adapting the CTG to particular facil-
ities or developing other, more appropriate control
strategies.
So long as a State adopts RACT for tire manu-
facturing facilities in nonattainment areas, the failure
of the State to follow the "presumptive norm" set
forth in the tire-making CTG and the sample regulation
will not affect the acceptability of the State's regula-
tions . EPA's review of these regulations seeks to
determine whether or not the State's regulatory scheme
provides for the attainment and maintenance of the
national ambient air quality standards. EPA will not
infringe on the discretion of the States to determine
what constitutes RACT so long as the States provide
for the attainment and maintenance of the national
standards by July 1982.
Unless the sample regulation contains the foregoing state-
ment explaining its purpose: and function, the States may be unaware
of their ability and authority to revise the information in the tire-
making CTG and the sample regulation to suit each tire manufacturing
facility within a State. The States must be fully informed of their
abilty to make individual determinations on the types and levels
of control that constitute RACT.
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II. COMMENTS ON SPECIFIC SECTIONS OF THE DRAFT REGULATION
A. The Scope of the Sample Regulation
(§§ XX.9510, XX.9520) __
1. Text of the Regulation (pp. G-2 - G-3)
The draft sample regulation, like the tire-making CTG,
is applicable to "pneumatic rubber tire manufacture", which is
defined as:
the production of passenger car tires, light
and medium truck tires, and other tires manu-
factured on assembly lines using automated
equipment. (Draft Sample Regulation, p. G-2.)
This definition, together with the draft regulation on "Appli-
cability", establishes the broad scope of the draft sample regulation.
The draft regulation thus repeats the error made in the tire-making
CTG of failing to recognize and make allowance for differences
in the production of various types and sizes of tires.
The scope of the sample regulation should be restricted
to the manufacture of pneumatic rubber, passenger-type tires. Hence,
the definition of "pneumatic rubber tire manufacture" in the draft
sample regulation should be replaced by the following definition:
"Manufacture of pneumatic rubber, passenger-type tires"
means the production of pneumatic rubber, passenger-
type tires on a mass production basis. Generally,
"passenger-type" tires include bead diameters through
16.5 inches and cross-sections through 12.8 inches.
Actual dimensions of this category may vary within the
industry. Most agricultural, mobile home, and light
truck tires in this size range are included. However,
where a plant produces speciality tires for antique
or other vehicles, or other tires on an irregular
basis or with short production runs, such production
does not fall within the scope of this definition
even where some mass production equipment is used
during the manufacturing process.
The title of the sample regulation and all other references to
"pneumatic rubber tire manufacture" should be changed to "manufacture
of pneumatic rubber, passenger-type tires".
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2. Discussion (pp. G-3 - G-5)
The discussion sections of the draft sample regulation
often refer to the tire-making CTG in a manner that contradicts
its actual role as a background document containing information
to which the States can refer. Other portions of the draft
sample regulation similarly fail to reflect the flexibility
that the States have in determining whether, and to what extent,
control techniques constitute RACT. These statements in the
draft sample regulation must either be revised or deleted. The
"Discussion" on pp. G-3 - G-5 of the draft regulation should
be revised as follows:
(a) The first sentence of paragraph 1 of the Discussion
on p. G-3 states: "The CTG document defines RACT controls for
pneumatic tire manufacturing that are applicable to four specific
operations in the overall process." Since the Clean Air Act requires
that RACT be determined on a case-by-case basis, the tire-making
CTG can only suggest and not define those control techniques which
could be considered RACT for tire manufacturing. This sentence
should be revised to read: "The tire-making CTG discusses control
techniques for the manufacture of pneumatic rubber, passenger-type
tires which, depending on particular circumstances, may be appropriate
RACT controls for four specific operations in the overall process".
(b) The fourth sentence of paragraph 2 of the Discussion
on p. G-3 states: "The applicable RACT controls are carbon adsorption
which is already in pla.ce in at least one facility, and incineration,
which has been used in other rubber industries on gas streams with
similar types and concentrations of VOC." This sentence should be
B-118
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revised to read: "The control techniques discussed in the tire-
making CTG which could constitute RACT at certain tire manu-
facturing facilities are carbon adsorption and incineration".
(c) The third sentence of paragraph 3 of the Discussion on
p. G-3 makes a statement comparable to that made in the fourth
sentence of paragraph 2. This sentence should be revised as
follows:
The control techniques discussed in the tire-
making CTG which could constitute RACT at certain
tire manufacturing facilities are carbon adsorption
and incineration. The tire-making CTG fails, however,
to address certain negative aspects of incinera-
tion. Specifically, the tire-making CTG fails to
take into account the energy used in incineration
and the fact that the quantity of pollutants created
by incineration can exceed the quantity of pollutants
controlled at this operation.
(d) The fourth sentence of paragraph 4 of the Discussion on
p. G-3 also makes a comparable statement to that contained in the
fourth sentence of paragraph 2 and should be revised in the same
manner as the third sentence of paragraph 3.
(e) The fourth sentence of paragraph 1 of the discussion
on G-4 states: "The preferred RACT control technique is conversion
to water-based sprays. Alternative RACT control methods include
carbon adsorption and incineration." This sentence should be
revised to read: "The control techniques discussed in the tire-
making CTG which could constitute RACT at certain tire manu-
facturing facilities are conversion to water-based sprays, carbon
adsorption and incineration. Given sufficient time to evaluate
the impact of conversion on product safety, conversion to water-
based spray may be the preferred control technique."
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(f) Paragraph 1 of the Discussion on p. G-5 of the draft
sample regulation states that the sample regulation is applicable
to all plants that manufacture pneumatic rubber tires, "as defined
in the CTG document". The second sentence of this paragraph
should either be deleted or revised to read:
Since the average plant produces 16,000 tires per
day and emits an estimated 1,000 metric ton/year (1,100
ton/year), it is assumed that all plants which manu-
facture pneumatic rubber, passenger-type tires in
nonattainment areas, as defined in the sample regulation,
will be covered by the regulation. (changes underlined).
B. Provisions for Specific Processes (§ XX.9530)
1. Text of the Regulation (pp. G-6 - G-7)
The draft sample regulation contains provisions requiring
the owner or operator of an undertread cementing, tread end cementing,
or bead dipping operation to install and operate a capture system
that achieves maximum reasonable capture, up to 85 percent by
weight of VOC emitted. Such owners and operators are also required
to install: (1) a carbon adsorption system that achieves at
least a 95 percent removal of VOC emitted; or (2) an incineration
system that oxidises at least 90 percent of the nonmethane VOC;
or (3) an alternative VOC emission reduction system that has
at least a 95 percent reduction efficiency (§ XX.9530(a)).
The draft regulation also contains provisions that
require the owner or operator of a green tire spraying operation
to substitute water-based sprays for the normal solvent-based
compound or to comply with capture and control requirements com-
parable to those required for undertread cementing, tread end
cementing and bead dipping (§ XX.9530(b)).
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The foregoing provisions on specific tire manufacturing
processes must be deleted from the sample regulation. The inclusion
of generic provisions in the sample regulation is inconsistent
with the statutory mandate that RACT be determined on an individual,
case-by-case basis. Due to substantial differences between tire
manufacturing facilities (even within one company), it is not
possible to develop a specific regulation that could be appropriately
included in the sample regulation. For example, no one regulation
could accornodate the differences in the ages of manufacturing
facilities, the types of equipment, the methods of production
and the physical layout of the plants.
VJhile it is inappropriate for the sample regulation to
prescribe particular control techniques, control levels and capture
efficiencies, the sample regulation should set forth the factors
that each State should consider in determining what techniques,
levels and efficiencies constitute RACT for a particular facility.
The factors to be considered by the States include the following:
(a) the capital expenditure necessary to achieve
a certain capture efficiency;
(b) the impact of required costs on affected parties;
(c) the energy requirements of the control technique
or control practice;
(d) the other pollutants created due to use of the
control technique or control practice;
(e) the need for controls, including the relative
severity of nonattainment with ambient air
quality standards in the area;
(f) the impact of the control technique or control
practice on the ability of the plant to comply
with product safety requirements;
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(g) the impact of the control technique or control
practice on the safety of the work environment;
(h) the physica.1 design and layout of the plant and
the equipment; and
(i) the cost-effectiveness of the control technique
or control practice.
The provisions of the draft sample regulation would allow
the States no leeway to consider the factors necessary to a
determination that application of a control technique is safe,
cost-effective, physically feasible, technologically practicable,
and environmentally justified. RACT and the regulations prescribing
RACT must, of necessity, be determined on a case-by-case basis,
so that RACT is established in light of the constraints present
at each facility.
The difficulty of drafting a generic regulation for the
various stages of tire manufacturing is evidenced by the first
paragraph of the discussion on page G-8 of the draft sample
regulation:
There are several problems with requiring
a minimum capture efficiency for undertread cementing,
tread end cementing and bead dipping equipment and
conveyors. The design and layout of the equipment
varies considerably from plant to plant, operator
accessibility must be provided to certain areas of the
equipment, and it may not be practical to completely
hood long conveyors. Therefore, a goal of 85 percent
capture efficiency was set. This section requires
the owner or operator of a source of VOC to make
every reasonable effort to meet the 85 percent capture
efficiency. The referenced documents generally give
ranges which specific design parameters should fall
within. If a capture system is not designed to achieve
85 percent capture, then the owner or operator should
choose the value within the range which will result
in a maximum capture efficiency, considering the physical
limitations of the specific situation. EPA encourages
comments on methods of assuring that maximum reasonable
capture will be attained. (Emphasis added).
EPA here acknowledges the difficulty of establishing an across-
the-board capture efficiency for tire manufacturing operations.
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Any effort to specify control techniques, control levels, or capture
efficiencies raises the problem of adjusting these specifications to
the various operating constraints at each plant.
The difficulty of drafting an appropriate generic regula-
tion is also illustrated by the failure of EPA's draft sample regula-
tion to take into account reduced solvent usage as a means of
reducing hydrocarbon emissions. Thus, this regulation would apply
the same control levels to both manual and automatic tread end
cementing despite the reduced solvent usage that results from
manual as opposed to automatic tread end cementing. The fact that
the tire-making CTG does not even discuss manual tread end cementing
further emphasizes the need for States to develop their own regula-
tions suited to the tire plants within each State.
In light of the diversity present in the tire manufacturing
industry, the RMA maintains that the sample regulation should only
identify various factors to be considered by the States in determining
RACT. Any effort to draft generic regulations infringes on the
discretion of the States to make their own determinations based on
the information in the tire-making CTG and the factors in the
sample regulation. Furthermore, a generic regulation drafted by
EPA may be inconsistent or incompatible with the existing State regu-
lations that affect tire manufacturing facilities.
2. Discussion (p. G-8)
The first paragraph of the Discussion on p. G-8 (which
is set forth above) addresses the problems involved in requiring a
minimum capture efficiency. The RMA agrees that the establishment
of a minimum capture efficiency, like the establishment of minimum
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control levels, is unrealistic. As discussed previously, EPA1s
effort to write detailed generic standards for the tire manufacturing
industry is inappropriate. Accordingly, the first paragraph of the
Discussion on p. G-8 should be revised to read:
There are several problems with requiring
a minimum capture efficiency for undertread cementing,
tread end cementing and bead dipping equipment and
conveyors. The design and layout of the equipment
varies considerably from plant to plant, operator
accessibility riust be provided to certain areas of
the equipment, and it may not be practical to com-
pletely hood long conveyors. Therefore, no specific
percent capture efficiency has been or can be set.
The owner or operator of a VOC source is required,
however, to make every reasonable effort to achieve
a high capture efficiency. Because of limited technical
data and correlation, it is not possible to specify
the capture efficiency that will result from such
efforts.
C. Compliance Schedule (§ XX.9540)
1. Text of the Regulation (pp. G-9 - G-10)
The draft sample regulation contains provisions establishing
two different detailed compliance schedules for: (1) process
equipment changes, low solvent technology and add-on control devices,
including incineration with heat recovery; and (2) incineration without
heat recovery and substitution of water-based spray in the green
tire spraying operation. The first schedule requires compliance
before January 1, 1982, and the second requires compliance by
January 1, 1981. Both schedules specify four interim dates by
which designated interim steps must be completed.
The RMA objects to the inclusion of detailed, industry-
wide compliance schedules in the draft s?*~'.i->ie regulation. Since a
determination of which controls constitute RACT at a particular
facility must be made en a case-by-case basis, the establishment
of a reasonable time for adoption and/or installation of such
B-124
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controls must also be made on an individual basis. Compliance
schedules must reflect the specific difficulties each facility will
encounter in the adoption or installation of RACT. The diverse
physical layouts of tire manufacturing facilities preclude tire
plants from adopting or installing RACT at a uniform rate.
The compliance schedules in the draft regulation also over-
look another relatively unique aspect of the tire manufacturing
industry — the overriding need for product safety. The RMA particu-
larly objects to the requirement that conversion to water-based
sprays for green tire spraying be completed by January 1, 1981.
The industry needs at least a two-year period in which to evaluate
the impact of water-based substitution on product safety. Any
change in the production process must be cautiously undertaken
and critically examined.
In establishing individual compliance schedules for tire
manufacturing facilities, the States will be able to set realistic
schedules that reflect the problems confronting each tire plant.
Individual schedules should be adjusted for those plants that have
difficulty installing add-on control technology without adversely
affecting the safety of the work environment. States may wish to
make some allowance for companies with more than one tire plant in a
State that find it difficult to simultaneously advance the adoption/
installation of RACT at all plants.
The States have the flexibility and the authority to
consider these and other concerns in the establishment of compliance
schedules. EPA's effort to establish industry-wide compliance
schedules infringes on the authority of the States. These compliance
schedules should be deleted from the draft sample regulation.
B-125
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2. Discussion (pp. G-10 - G-ll)
The first pareigraph of the discussion on p. G-10 of the
draft sample regulation explains that the compliance schedules in
the draft regulation are based on an EPA memorandum entitled
"Categorical Compliance Schedule for VOC Sources". The memorandum
suggests a two-year schedule for add-on control equipment and process
changes requiring the purchase of equipment, except for incineration
systems without heat recovery. A one-year schedule is recommended for
installation of incineration systems, or process modifications not
requiring the purchase of equipment.
This first paragraph should be deleted from the sample
regulation. Suggested compliance schedules for all VOC sources
cannot possibly reflect the diverse factors that will determine
the reasonable compliance deadlines by which various tire manufacturinc
facilities can install or adopt RACT. The inappropriateness of such
across-the-board compliance schedules is best illustrated by the
failure to consider the; additional time necessary to evaluate the
product safety impact of process changes.
D. Testing and Monitoring (§ XX.9550)
1. Text of the Regulation (p. G-12)
The testing and monitoring provisions set forth in the draft
regulation specify both the procedures for compliance testing and
the control parameters to be monitored. The appropriateness of
these suggested test procedures and the parameters to be controlled
is dependent upon the particular control techniques used and the
characteristics of the operation and plant at which the control
technique is used. However, the draft regulation suggests that
B-126
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these procedures and control parameters are equally applicable
to all tire manufacturing facilities.
As discussed previously, manufacturing equipment,
production processes, and plant layouts vary greatly from one tire
mnaufacturing facility to another. The types and levels of controls
that constitute RACT will similarly vary from one facility to
another. The necessity for and desired frequency and feasiblility
of testing and monitoring will also differ from plant to plant.
These diverse circumstances at individual tire manufacturing
facilities render the application of uniform testing and monitoring
requirements inappropriate on an industry-wide basis. Hence, the
draft regulation is useless and can only be regarded as regulation
for the sake of regulation. These provisions on testing and
monitoring should be deleted from the draft sample regulation.
Ill. GENERAL PROVISIONS
A. Applicability (§ XX.8010)
1. Discussion (pp. L-2 - L-3)
The Discussion on pages L-2 and L-3 of the draft regulation
addresses exclusions from control of VOC emissions, and the first
paragraph of the Discussion refers to relevant regulatory philosophies
set out in the memorandum of February 24, 1978, on "Criteria for
Approval of 1979 SIP Revisions". The second sentence of that
paragraph summarizes one philosophy as stating "that the regulation
must reflect RACT as determined in the CTG for virtually all
sized sources."
While this sentence may properly summarize one philosophy
contained in that memorandum, the sentence misrepresents the manner
B-127
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in which RACT should be determined under the Clean Air Act. This
sentence should either be deleted from the sample regulation,
or the sample regulation should include a subsequent statement
that, notwithstanding the memorandum referred to, the information
set forth in CTGs does not establish or determine RACT.
B. Disposal of Volatile Organic Compounds
(§ XX.8020)
1. Tex'_ of the Regulation (p. L-4)
This provision should be eliminated from the draft sample
regulation. Prohibitions of or limitations on the disposal of volatile
organic compounds or materials containing volatile organic compounds
must take into account the size of the facility disposing such com-
pounds and materials and the concentration of the volatile organic
compound involved.
C. Inspection, Maintenance and Operating Procedures
(§ XX.8030)
1. Text of the Regulation (p. L-5)
The section on inspection, maintenance and operating
procedures should be eliminated from the sample regulation.
The regulation will merely create an administrative burden and
generate useless papers; and records. The need for formalized
inspection, maintenance and operating procedures must be determined
by each State in light of the particular industry, company practices
and control techniques involved. The accompanying discussion
should also be deleted.
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D. Breakdown, Malfunction and Operation Changes
(§ XX.8040)
1. Text of the Regulation (p. L-7)
The provisions in the draft sample regulation that address
breakdown, malfunction and operation changes should be eliminated.
The necessity for and content of procedures for reporting and
recording breakdowns, malfunctions and operation changes are
within the discretion of each State. EPA has already provided
the States with suggestions on how to deal with these situations
in a manual entitled "Workshop on Requirements for Nonattainment
Area Plans", and EPA should not imply that the States must adopt
specific language on breakdowns, malfunctions, and operation
changes. So long as a State provides for the attainment and
maintenance of the national ambient air quality standards, the
procedures used to deal with breakdowns or malfunctions in control
equipment are within the discretion of the State.
2. Discussion (pp. L-8 - L-13)
Rather than drafting specific regulatory langauge on
breakdown, malfunction and operation changes, EPA should confine
itselr to the presentation of alternative regulatory approaches.
Of the three options reviewed on pages L-8 - L-13 of the Discussion,
the source demonstration approach is preferable. This option would
allow a source an opportunity to demonstrate that excess emissions
resulted from an unavoidable breakdown.
E. Monitoring, Recordkeeping, Reporting (§ XX.8070)
1. Text of the Regulation (p. L-19)
The draft regulation on monitoring, recordkeeping, and
reporting requirements should be eliminated from the sample
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regulation, since the establishment of such requirements is best
handled on an individual basis by each State. The discussion
following this draft regulation generally recognizes that these
details are within the discretion of each State.
2. Discussion (pp. L-19 - L-20)
The discussion relating to control equipment monitors and
monitoring requirements recognizes that each State must establish
its own requirements on this subject. The establishment of record-
keeping requirements is also within the discretion of each State,
and the last paragraph of the discussion should be revised to
reflect that fact.
B-130
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UNIROYAL INTERNATIONAL
Division of UNIROYAL, Inc.
Oxford Management & Research Center
Middlebury, Connecticut 06749, U.S A.
203-573-2000
July 13, 1979
Mr. Tom Williams
Control Programs Development Division, MD-15
Environmental Protection Agency
Research Triangle Park, NC 27711
Dear Mr. Williams:
This letter is in response to your undated memo entitled,
"Review of a Guidance Document for the Group II Control
Technique Guidelines for Volatile Organic Compounds" and
attachments which include draft regulations for the control
of VOC emissions from Tire Manufacturing. This material was
received without a covering letter from GCA Corporation of
Bedford, Massachusetts on June 19, 1979.
A comment has been prepared and is being submitted by the Rubber
Manufacturers Association (RMA) which we endorse. We consider
the RMA comments as our comment and for the sake of brevity
will not repeat them. You should consider the RMA comment
in the context of a summary of several individual commentors.
However, we wish to add to this comment and emphasize certain
additional points.
The tire-making CTG purports to set forth "a presumptive norm"
for RACT for tire manufacturing. A dictionary definition of
these terms would seem to imply that the CTG, RACT values,
would apply to at least 50% of the plants being controlled.
In my opinion, this is not the case and several technical
issues involved were ignored in the development of the CTG.
The Clean Air Act indicates that RACT is developed upon a plant
basis. Therefore, any guidance to the States must clearly
indicate that the CTG presumptive norm RACT is for a hypothetical
"typical" plant of 16,000 tires/day representing a contrived
model not indicative of real world conditions.
Section XX.9520 Applicability and Discussion, Page G-3. A
fundamental flaw in the tire-making CTG and these prepared
regulations is the lack of comprehension of industry process
diversification. This is supposedly guidance to the States,
yet no indication is made of the fact that all plants may not
employ the process steps discussed. For instance, we do not
employ the "Bead Dipping" process operation.
B-131
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Mr. Tom Williams
Environmental Protection Agency
July 13, 1979
Page 2
Section XX.9530 Provisions for Specific Processes, Page G-6.
This should be deleted entirely as discussed in the RMA comment.
It also is not consistent within itself or the CTG. Section
(a) (1) "...a capture system,...up to 85 percent"; (b) (2)
(i)n ...capture and transfer at least 90 percent. "The CTG
in Table 1-1, Page 1-4 gives capture efficiencies of 65-85%
and 80-90%; and as a footnote to this table "Percent capture
efficiency for a retrofit will vary depending on the design and
layout of the individual affected facility; minimum acceptable
percent capture should be determined on an individual plant
basis." A sample regulation that describes specific capture
efficiencies is appropriate.
Section XX.9400 Compliance Schedule, Page G-9. The dates and
time tables are unrealistic and do not reflect reality. Suppliers
could not supply the equipment necessary to comply with these
dates. Insufficient time is made available for Managements
approval of the funds necessary to implement these regulations,
(using the most cost effective control measure listed in the
CTG, capital requirements for a 16,000 T/D plant is $937,000).
Section XX.8030 Inspection, Maintenance and Operating Procedures,
Page L-5. This section is regulatory overkill and should
be eliminated. The control equipment being contemplated is
not high technology hardware requiring this type of monitoring.
The administrative burden is unnecessary upon the control agency
and controlled facility. I question the right of the Agency
to establish work practices and job classifications by specifying
the functions of "trained operators".
Section XX.8040 Breakdown, Malfunction and Operation Changes,
Page L-7. This section is unrealistic in light of normal
operating procedures in a manufacturing facility. Recording
of malfunctions should be required only when duration exceeds
4 hours and reporting only when duration is in excess of 8
hours. Two-year record retention should be adequate to show
that the operator has been in compliance.
Sincerely yours,
Ofyww y rw*y
Robert C. Niles
Director
Environmental Control
RCN/rmb
Attachments
B-132
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CrownZellerbach
Environmental Services
July 2, 1979
Mr. Tom Williams
Control Programs Development Division
U.S. Environmental Protection Agency
Office of Air Quality Planning & Standards
Research Triangle Park, North Carolina 27711
Dear Mr. Williams:
We have recently received a copy of the draft guidance document on
VOC controls for the Graphic Arts Industry. The Flexible Packaging
Association has submitted comments on the document which include our
coitinents.
However, since we are the only company which has installed carbon
adsorption systems to control water soluble VOC from flexographic
presses, we want to emphasize our concerns on proposed requirements.
The guidance documents suggests that the overall capture efficiency
should be 60% and an emission control system efficiency of 95%. This
latter requirement could prevent installation of carbon adsorption
systems for water soluble solvents. Unless the steam regeneration
cycle can be minimized, excess water will be mixed with solvent to
prevent reasonable disposal.
The alcohol-water mixture can be used as fuel if the solvent concen-
tration can be maintained above 50 wt. %. Alternately, a simplified
solvent mixture may be separated by azeotropic distillation. Addi-
tional water would complicate such attempts at either recovery or use
of the solvent as boiler fuel.
B-135
W. Drake St. Camas WA 98607 Tel. (206) 834-4444
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Mr. Tom Williams July 2, 1979
Page 2
The alcohols and other water soluble solvents are more difficult
to remove with carbon adsorption. Replacement of these solvents
by water insoluble solvents (which are generally more reactive and
toxic) is not compatible with the flexographic equipment, the sub-
strate (film) or the j_nks used on polyolefin printing.
The primary purpose of the regulation is to reduce VOC emissions.
The overall emission reduction efficiency is sufficient to specify
control, additional rules on how to achieve this reduction should
be left to th^ operator. It may be more cost and energy effective
to improve fugitive anission control to achieve the goal.
Please call if you wish to discuss this problem or any other aspects
of the regulation.
Very truly yours,
JPMES E. WWUTHER/jd
Supervisor,
Air & Noise Programs
cc:
Dor. H. R. ftmberg - BSD
B-136
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2219 MCCALL STREET
DAYTON, OHIO 45401 - P.O. BOX 700
(513) 268-6551
A CHARTER COMPANY
July 13, 1979
Mr. Tom Williams
Control Programs Development Div.
Mail Drop-15
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Dear Mr. Williams:
We are pleased to submit herewith our comments on
Part I, Part III and Section XX.960O Graphic Arts Systems
of the draft document for the Group II Control Technique
Guidelines for Volatile Organic Compounds.
We appreciate the opportunity afforded us to comment
on this guideline document. Attached herewith is your copy
of the draft in which our editorial suggestions and comments
have been inserted within the context in red markings for
ease of distinction. In addition, our more serious comments
with respect to the applicability of the draft document in
the printing industry are covered in the further discussions
which follow.
SECTION XX.9610
We find the Definitions at Section XX.9610 (b) somewhat
misleading inasmuch as those numbered (l), (2) and (j) do not
distinguish the method and kind of printing — from other print-
ing methods — as apparently intended. The following definitions
are proposed:
(l) "Printing means the reproduction of graphic images —
including text, patterns, designs or pictures — on a
substrate by a serial process in which fluid ink
applied to one or more plate or image carriers is
transferred to a receiving substrate by impression
contact.
(2) "Rotogravure Printing" means the process of printing
from an intaglio or recessed image plate cylinder
using very fluid inks.
B-137
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(3) "Flexographic Printing" means the process of
printing from a flexible relief or raised image
plate, made of rubber or other elastomeric material,
using very fluid inks.
(4) Same as (l) as listed in the draft document.
(5) Same as (2) as listed in the draft document.
With the above changes, definitions numbered (3)»CO
and (5) in the draft document can and should be deleted.
SECTION XX.9620
In regard to the discussion following Section XX.9620
we take exception in particular to the last statem3nt, "It
should be assumed that all of the solvent comsumed evaporates
into the atmosphere." Quite the contrary, "It should not,
however, be assumed that all of the solvent evaporates into
the atmosphere". It is our contention that neither that
portion of the ink solvent that is retained in the printed
product nor the waste or dirty inks and cleaning solvents which
are removed from the operation and disposed of in accordance
with applicable regulations should be included in determining
the potential or overall emissions.
SECTION XX.963O
Some of the proposed regulatory Provisions for Specific
Processes under Section XX.9630 apparently were either mis-
printed or mistranscribed from Volume VIII, EPA-^50/2-78-033,
of the CTG Series. Specifically part (3) (i) and(3)(iii) should,
instead of 95-0 percent, reflect 90.0 percent control device
efficiency as stated in paragraphs one and two in EPA-U50/2-78-033
at 3.4.1 on page 3-9»
SECTION XX.9650
¥ith regard to Section XX.9650, "Testing and Monitoring"
we vigorously object to paragraphs (c) (l) and (c) (2) as written.
We very much appreciate the desirability of specifying test methods
for certifying compliance and welcome a source specific procedure
which would apply equally throughout the industry. At this time,
however, we strongly urge that part (c) be limited to the following:
"(c) (l) Test procedures to determine compliance with Section XX.9630
must be approved by the Director". This proposal is based on the
following reasons:
Inclusion of EPA U50/2-78-O41 as a requirement for determining
compliance with Section XX.9^30 is technically invalid. The
test methods in EPA U50/2/-78-041 are only of very limited
applicability and are based on the measurements of the mass carbon
concentration, whereas, in contrast Section XX.9630 specifies
emission reductions in terms of the mass of organic solvent.
B-138
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The discussion sections which follow Section XX.965O
far oversimplify the ease of converting organic carbon to
mass rate of emissions by virtue of invalid assumptions and
casual reference to additional —undisclosed — test methods.
Moreover, U.S. EPA itself, in its program pursuant to the
development of New Source Performance Standards for the
publication rotogravure industry, chose not to use the
"reference method" in their site testing program and in their
attemps to employ variations of the "alternate method", at
considerable expense, have experienced dubious results.
This discussion is not meant to condemn the contributions
to the state of the art disclosed in EPA-^50/2-75-0^1; these
deserve recognition, but necessarily must be kept within the
realm of their practical application. Such perspective is
contained in EPA-^50/2-78-04l which states:
The reference method "is recognized
as leading the technology" and "The
Emission Measurement Branch of OAQPS
is working to refine the operating
details of the procedure;...."
The alternate method does not and
is not intended to indicate specific
applications where the method can
(or cannot) be used or correction
factors to be applied to the results",
and
"In addition to the limitations
associated with the alternate methods
screening methods may also lack
precision".
It has been our understanding, from participation in
printing industry association meetins with OAQPS personnel
at Research Triangle Park, that source specific applications
of test methods would not be specified until such test pro-
cedures had been tried and verified by EMB.
Based on these arguments, it would seem very inapprop-
riate to issue guidelines for state implementation plans that
specify the test methods described in EPA-450/2-78-0^1 as
required procedures applicable either to flexographic or
rotogravure printing operations.
B-139
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The discussion section under Section XX.9&50 requests
comments regarding "average rate of ink usage". In printing
practice the average rate of ink usage is a variable parameter
that is the result of press operations over a given interval
of time. Any rate of ink usage valve is only valid for the
time period which it represents because of continual variations
and changes in the materials and product, such as ink coverage
variations in accordance with changes and trends in the copy
to be printed, changes in the substrate and products being
printed, raw material variations particularily from one man-
ufacturing source to another, etc. Consequently, average rate
of ink usage is a historica.1 valve which is prone to fluctuate
upward or downward even over extended periods of time.
SECTION XX.8030. SECTION XX.SOUO And SECTION XX.807O
Individually and collectively these three proposed
regulations are extremely presumptive, represent excessive
administrative burdens and are indeed unreasonable. While the
intent of these regulations is clear their incorporation in
the SIP would incur significant costs and place a voluminous
administrative load on operators and agencies alike that ought
to be reserved for application to those sources and facilities
which are found to be negligant and recalcitrant. Additionally,
these are the kind of regulations which in practice end up being
adheared to very tightly in one district and very loosely in
another simply because of the amount and level of administrative
resources available. Briefly, the more outstanding objections
to these three sections of the proposed regulations are as
follows:
- Treatment of very complex subject matter in a
simplistic fashion,
- Idealization of practical problems in a textbook manner,
- Presume well ordained problem analyses and resolutions
before their occurrence,
- Would create inordinate and unjustifiable administrative
burdens on both operators and state agencies and a
potential avalanche of tutorial interactions, and,
- Would be extravagant, cumbersome and unproductive except
in extraordinary circumstances.
It is recommended that these three sections of Part III
should either be extensively revised to reflect their intent
and purpose in a more general and more reasonable way or deleted
from the document entirely.
B-140
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Ve trust that these comments? will be meaningful to you
and again wish to express our pleasure in having the opportunity
to comment on this draft guideline document. Should you have
any questions concerning these comments, please feel free to
contact the undersigned. I will appreciate being included on
the mailing of any further drafts and in particular I would
appreciate copy of the final document when it is issued.
Sincerely,
Dayton Press Inc.
Robert D. Fremgen, Manager
Chemical & Environmental Engineer
RDF/tr
Attachment: Edited Copy Of Part I
General Definitions & Section XX.9600
Graphic Art Systems And Part III
General Provisions
B-141
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July 3, 1979
Mr. Thomas Williams
Project Officer
Control Programs Development Division
Office of Air Quality Plaiming and Standards
United States Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Dear Mr. Williams:
Re: Guidance Document for State VOC Regulations Graphic Arts Industry
I would like to accept your opportunity to comment on this document.
Comments are as follows:
XX. 8060 Petition for Alternative Controls
I would hope that this procedure would not become mired down in time consuming
paperwork that would discourage the attempted application of new technology
or have even more far-r«;achiiig effects that would discourage the development
of new technology. Such a procedure should be streamlined to every extent
possible for all industries, not only the graphic arts industry.
XX. 9620 Applicability
The last sentence on Page H-4 under the Discussion heading is objectionable.
Although it does not appear explicitly in the CTG Document, part of the reason
the industry argued for 70-75% overall efficiency for publication gravure
operations and 60-65% overall efficiency for packaging gravure operations
(as appeared in the early CTG drafts, later changed to 75% and 65% respectively)
is the industry belief that as much as or more than 5% of the VOC in tie press-
ready ink remains on the printed copy. No test has yet been devised that will
support this belief, but material balance figures should show a higher overall
efficiency for plants with control systems were some VOC's not remaining
with the printed copy. Therefore it should not be assumed that all of the
solvent consumed evaporates into the atmosphere.
XX. 9650 Provisions for Specific Processes
Section (3) subsection (i) reads "A carbon adsorption system which reduces
the volatile organic emissions from the capture system by at least 95.0 percent
by weight; "Section 1.2.1 entitled "Available Add-On Control Devices" of the
CTG document for the graphic arts industry very clearly specifies 90% or greater
control device efficiency.. .."can and should be achieved."
B-142
DIVERSIFIED PRINTING CORPORATION. LOWER VALLEY ROAD—ROUTE 372, P. O. BOX D, ATQLEN. PENNSYLVANIA 19310, AREA CODE 215-593-511
-------
Since the Guidance Document should be consistant with the CTG document,
the 90% figure should be used.
Section (3) subsection (iii) would require all alternative control methods
to achieve at least 95% VOC reduction efficiency. My objection here is
similar to that for the earlier discussion of alternative controls. If
the requirements for alternative controls are too stringent, development
of potential alternative controls might be hampered. Thus the reouirement
for VOC reduction utilizing alternative controls should be 85% rather than
95%.
Sections XX. 9620, XX. 9650, XX. 9640
"Printing Rotogravure should read Publication rotogravure." ( Pages H-3,
H-5, H-6, H-8, and H-9.)
The opportunity to comment is appreciated. I trust the comments will be
well received.
Sincerely,
•y
Warren J. Weaver
/vim
cc: H. George GRI
C. R. Salisbury
B. Neal
M. Farkas
W. Schaeffer GATF
H. deh. Alexander Pa. DER
B-143
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June 29, 1979
Mr. Tom Williams
Control Programs Development
Division, MD-15
Environmental Protection Agency
Research Triangle Park,
North Carolina 22711
Deal Mr. Williams:
These comments on the draft Guidance Document for
the Group II Control Technique Guidelines for Volatile
Organic Compounds are submitted on behalf of Envelope
Manufacturers Assocation, the national association of
manufacturers of commercial envelopes. We appreciate
the invitation to review the document and offer comments
for consideration, and we particularly applaud the in-
tention to publish all industry comments as received.
By wa.y of background, according to the Preliminary
Report of the 1977 Census of Manufactures, there were
«c 267 establishments in the United States primarily en-
" "' gaged in the manufacture of commercial envelopes, of
* *;<" which 176 employed 20 or more persons. Members of
Envelope Manufacturers Association operate 170 of these
267 establishments and produce more than 80 per cent of
the approximately 100 billion envelopes produced annually
A substantial number of these envelopes are sold "plain,"
to be printed by others. Such printing as is performed
by envelope manufacturers represents a secondary process,
which is the reason the industry is classified as
SIC 2642 - within the Paper classification, rather than
Printing. While flexography is the predominant printing
process used by envelope manufacturers, this application
represents only a tiny portion of all flexographic
printing.
Our reaction to the Guidance Document is the same
as it was to the Control Technique Guideline (CTG)
document for flexographic printing in the graphic arts
industry. We do not believe it should be applicable to
envelope manufacturers, oecause the control technique
employed is not appropriate for printing equipment used
by envelope manufacturers.
B-144
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We do not request a "per se" blanket exemption for enve-
lope manufacturers. We do suggest that the parameters or defi-
nitions determining applicability be re-examined and more
carefully stated. It is natural that in approaching this
project an examination was made of control techniques being
employed in "typical" flexographic printing operations.
It is dangerous, however, to apply these findings to all
flexographic printing operations without an examination of
whether significant differences within flexography affect
the technological or economic feasibility of employing these
control techniques.
Knowledgeable persons have advised us that envelope
manufacturers need not be concerned, because of the proposed
exclusion fron applicability of facilities whose potential
emissions of volatile organic compounds are less than
100 ton/year. The great majority of envelope manufacturing
establishments have a potential emission of much less than
50 ton/year. We remain concerned, however, for two reasons.
The maximum potential emission may be slightly in excess of
100 ton/year, and there are a small number of facilities -
no more than four or five - whose potential emission may
approach this level. It would be patently unfair to subject
such a small part of an industry to a demand for the instal-
lation of costly control equipment or to have the threat of
such a demand act as a barrier to growth. Also, we are mind-
ful that individual State and local agencies may adopt regu-
lations with coverage extended to facilities with potential
emissions below 100 ton/year.
For these reasons, we respectfully ask that you consider
the following distinguishing characteristics of flexographic
printing equipment used by envelope manufacturers. The
figures cited are based upon the responses from 57 member
establishments who were able to reply to a survey within
the brief period before these comments were requested.
Only 20% of flexographic printing is performed on separate
printing presses; 80% is performed in-line on components of
a folding machine used to convert paper into envelopes. Only
13% of flexographic printing is performed on folding machines
with web feed; 87% falls into the category of sheet-fed equip-
ment - either in-line or off-line. Because of this, and because
of the typically limited ink coverage required, the potential
emission per printing unit is commonly less than 1 ton/year.
There is also a structural distinction that should be
considered. Flexographic printing units used by envelope
manufacturers do not utilize drying units, which affects the
feasibility and expense of add-on collection and treatment
systems.
B-145
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Because of these fcictors, the "Cost-effectiveness of
pollutant controlled" determined for "model" plants in the CTG
is not at all representative of the situation for envelope
manufacturing plants. While add-on control may be "generally
available technology" for the types of flexographic printing
examined, or even for the great majority of flexographic
printing operations,, its suitability for the particular type
of operation used by envelope manufacturers is at the least
highly suspect.
The guidelines document mentions high solids technology,
described as primarily experimental at this time, and the use
of water-borne ink as alternative methods of limiting VOC
emissions from flexographic printing operations. Although
such water-borne inks are being used by some envelope manu-
facturers for limited applications, their universal use so
as to satisfy the requirements of the guidelines is not
feasible at the current time.
Provision is a.lso made for petitions for alternative
controls, but in the case of envelope manufacurers, there would
appear to be no generally available controls that would
achieve the required change in aggregate emissions from the
facility.
In light of the above, we submit that it is not proper to
apply the guidance document to all flexographic printing
operations, regardless of type, or to advise State and local
agencies, directly or indirectly, that such universal application
is proper,.
While recognizing that the aggregate VOC emission from a
facility is of primary concern, the cost-effectiveness of
pollutant controlled will depend upon the number of sources
producing the emission. The cost of a given aggregate reduction
of emissions will be substantially greater for a facility with
seven sources, each with a potential emission of 1 ton/year,
than for a facility with a single source with a potential
emission of 7 ton/year.
We strongly believe that it is encumbent upon the Control
Programs Development Division to address the issues we raise
in the final Guidance Document. It would be highly inefficient
to leave these issues to be addressed during each State's
public hearing period.
B-146
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We also offer comments on the following two additional
areas.
We presume that a facility whose potential emissions of
volatile organic compounds exceeds 100 ton/year may be brought
into compliance with the proposed regulation by taking steps,
such as a change to inks with a lower percentage organic solvent,
that will reduce the potential emissions below 100 ton/year.
Perhaps a petition for alternative controls, stating this
action, would be required. In any event, we believe the
guidance document should explicitly state the acceptability
of this approach.
Our final comment deals with the measurement of potential
emissions. The discussion on page H-4 covers calculations
based on actual "consumption" of solvent and ink, but consumption
is not explicitly defined. We believe the document should make
clear that waste solvent and ink that is collected in drums and
properly disposed of should not be included in the measurement
of potential emissions. The disposal of volatile organic
compounds is addressed in the document (page L-4), but not in
relation to the measurement of potential emissions.
Very truly yours,
WRO'Nrjob William R. O'Neill
Secretary
B-147
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12025 Shaker Boulevard
Cleveland. Ohio 44120
Area Code 216/229-6373
Flexible Packaging flssociation
THOMAS). DUNN, JR.
Technical Director
June 26, 1979
Mr. Tom Williams
US-EPA
Office of Air Quality Planning & Standards
Research Triangle Park, NC 27711
Dear Mr. Williams:
The Flexible Packaging Association is pleased to" submit these comments
on the Guidance Document for the Group II CTG's for VOC. Our industry,
through the efforts of individual member companies and FPA task forces,
has been very much involved in the development of these VOC emission
control guidelines. We plan to continue to cooperate with US-EPA
and the states in the efficient and economic implementation of the
Clean Air Act.
Our primary concern at present is the time available for the develop-
ment and commercialization of low solvent inks, coatings, and adhesives.
We are actively planning an Association effort to support and enhance
the "forcing" of future technological breakthroughs in these areas.
Our involvement, of course, will be directed by the guidelines of the
Federal Trade Commission and Justice Department so as to avoid any
possible activities in restraint of trade. Our intent is to do every-
thing legally possible to encourage and enhance the efforts of companies
within the industry to comply with the Clean Air Act. I will submit
to you in the near future a more detailed description of our program
in this regard.
We are pleased that the information developed by the WAPORA survey
of our industry, in'which the Flexible Packaging Association actively
participated, has prompted you to suggest a 100 ton per year small
source exemption. As you know, the costs of compliance will be quite
high for our industry. Given the limited financial resources and
profit potential of smaller flexible packaging converters, this
exemption is most helpful.
However, we note t'.iat much of our industry is customized-product
oriented. Both large and small converters tend to have relatively
short runs for many different packages and customers. In fact, the
same WAPORA survey found that about one-third of scheduled production
hours in the industry are devoted to machine set-up and clean-up
operations. This characteristic of the industry results in a healthy
competitive situation between both small and large converters. The
small source exemption would upset this balance. As an equitable
compromise, we suggest a 100 ton per year exemption per facility
regardless of size. This provides administrative efficiency for the
regulator, economic relief for the small converter, fairness to the
large converter, and no significant increase in emissions.
B-148
• SERVING THE FLEXIBLE PACKAGING INDUSTRY
-------
Mr. Tom Williams June 26, 1979
Additional detailed comments are attached. These reflect input from
many Association members, both converters and suppliers. We look
forward to continued cooperation with your office and extend our
willingness to assist your work in any way we can.
Sincerely,
Thomas J. Dunn
Technical Director
TJD/ac
Enc.
cc: R. A. Lillquist
Malcolm MacArthur
FPA Environmental Task Force
B-149
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DETAILED COMMENTS OF THE FLEXIBLE PACKAGING ASSOCIATION
on
CONTROL GUIDANCE DOCUMENT GROUP II CONTROL TECHNIQUES GUIDELINES
VOLATILE ORGANIC COMPOUNDS
Page A-U
Definition of Volatile Organic Compound
We assume this definition will be amended to reflect the recent US-EPA
policy on methyl chloroform and methylene chloride (UU FR 320^2). Even
if subsequent regulations under other provisions of the Clean Air Act
are likely, the deletion of these compounds from SIP provisions will
help reduce confusion and overlapping regulatory requirements.
Page H-2
Definition of Packaging Rotogravure Printing (xx.96lO (b)(l))
In order to avoid confusion, add "rotogravure" to line 1 "between "means"
and "printing", and change "and" in the second last line to "or".
Definition of Publication Rotogravure Printing (xx.96lO (b)(2))
As above, add "rotogravure" between "means" and "printing" in line 1,
and change "other types of printed materials" to "other nonpackaging
printed materials" in the las- two lines.
Definition of Flexogrsiphic Printing (xx,96lO (b)(3))
Correct spelling of "elastomeric" in last line.
Page H-3
Small Source Exemptions (xx.9620 (b))
See comments in cover letter,,
Page H-5
Provisions for Specific Processes (xx.9630)
The intent regarding applicability of these regulations to coatings and
adhesives (Discussion, page H-T) is nowhere embodied in the suggested
regulatory language. This can be accomplished by referring to "inks,
coatings, and adhesives" in this section where "ink" is now specified.
The wording of paragrapn (l), water-based, and paragraph (2), high-solids,
should be parallel. In addition, other low-solvent formulations may be
developed which, although not meeting; these definitions, do in fact
provide equal or greater emissions reductions. Provisions should be made
for such materials, either by specific sections as suggested by suppliers,
B-150
-------
Detailed Comments of FPA June 26, 1979
or an "equivalency" section allowing certification of such materials upon
submittal of necessary documentation by suppliers or converters.
Paragraph (3) would establish a double standard of emission control tech-
nology at the expense of carbon absorption system operators. While CA
systems can be operated at 95% efficiency or more, this is achieved by
more frequent stripping of the columns. In package printing, the varied
and sometimes water-miscible solvents used preclude solvent recovery,
given present and forseeable technology. If a 95% efficiency is required,
the one useful application of the water-solvent mix, as a combustible
boiler fuel, is precluded. More importantly, the resultant dilute water/
solvent mixture becomes a "hazardous waste" which presents a significant
disposal and environmental problem of its own. We suggest either equali-
zation of control efficiencies for all technologies at 9Q% or below or
elimination of this paragraph in deference to Subsection (b), regarding
overall efficiency.
The intent of Subsection (b) is clouded by the reference to its provisions
in the Discussion (page H-6) as "target reduction efficiencies." Either
these reductions "shall be required" (line 9) or some other wording is
appropriate. Clarification is in order. Also, we know of no standard
method for calculating "capture efficiency" and hence "overall emission
reduction efficiency." We do know of considerable controversy and un-
certainty in this area, and fear industry may be faced with a requirement
which either cannot be achieved or cannot be verified if achieved.
Page H-6
Discussion on Specific Processes
These comments do not reflect the developmental nature of much of the low
solvent technology envisioned by the regulatory language. This should
be recognized in the compliance schedules as suggested below.
In addition, the outlook for suitable low-solvent replacements for some
high-performance inks, coatings and adhesives is not favorable. Years
were required, for example, to obtain Food & Drug Administration approval ^
of the adhesive systems in the retortable pouch. Provisions should be
made upon submittal of suitable information from suppliers or converters
for exemption of various high-performance systems that cannot be replaced.
Also, these comments do not reflect the economic impact of these add-on
controls to companies in the industry. We are not convinced of the
"economic feasibility" of these controls in general. As a means of assessing
this, we suggest that the state regulatory agencies ascertain for each facility
whether or not the.installed cost of the add-on equipment-is more than the current
value of the process equipment emitting the VOC and/or whether or not the
added operation and depreciation costs increase product costs by more
than 5%- If either situation is found to be the case, the state would have to
make an affirmative certification as to the necessity of add-on control equip-
ment.
Pages H-8 & H-9
Compliance Schedules (xx.9^6o)
B-151
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Detailed Comments of the FPA June 26, 1979
The suggested compliance schedules are unrealistic for both add-on controls
and low-solvent technology. Paragraphs (l) and (2) specify 6 months and
2^5 months respectively for initiation of construction following contract
award or purchase order issuance. At present, member companies have been given
delivery periods ranging from 6 to 10 months after preliminary engineering
has been done. This period can only increase as the demand for these controls
increases. For those companies choosing the add-on control option, we suggest
an initial plan be submitted to the state with appropriate milestones within
six months of state adoption of the regulations. This plan would then
serve as the relevant compliance schedule. We also suggest final compliance
be reflective of the time required for companies choosing the low solvent
option to comply with those provisions.
Regarding the low solvent option, we note a 9/18/78 US-EPA interoffice
memo of John Rasnic, Chief of the Compliance Monitoring Branch, to John
Calcagni, Control Program Operations Branch: "For example, five years'would
not be an unreasonable length of time to research, develop and evaluate a
low-solvent coating for a particular application. Time would also be
required to install the system."
As discussed in the cover letter, FPA will be working to help implement such
new systems. At the present time, we feel progress will be apparent within
the time frame envisioned in these regulations, but it will be less than
100/5 applicable. We will be in contact with your off ice as we develop possible
scenarios for low solvent systems. We hope to develop the case for a phased
reduction based on realistic and dedicated efforts to develop and commercial-
ize these new systems.
Should you not modify these provisions based on the above suggestions, we
do recommend guidance as to the extent of "final plans" in subparagraphs
(a)(l)(i) and (a)(2)(i). We also see no utility in requiring demonstration
of compliance in the middle of winter for most of the country. If the
general deadlines cannot be changed, we suggest at least modification of
the January 1 dates to June 1.
Page H-ll
Testing and Monitoring Cxx.9650)
Paragraph xx.9650 (c)(2) apparently calls for proprietary information from
the suppliers of inks, coatings and adhesives. At a maximum, state agencies
need only the volume and weight percents of both the nonvolatile and water
fractions and the identity and relative amounts of .VOC solvents.
Continuous monitoring of "breakthrough" is not an appropriate provision. If
reference here is to the definition of breakthrough in the General Defini-
tions, the intent seems to be to detect an exhaust clearly in excess of allowed
limits. This is not a continuously monitorable parameter, but rather a
discrete occurrence. Continuous monitoring for relative VOC concentrations in
the outlet of the CA unit would seem to be more appropriate.
Page L-7
Breakdown, Malfunction, and Operation Changes (xx.8oUo)
These provisions seem unnecessarily involved and strict. We see no reason
why VOC emission controls breakdown, malfunction, or changes should be
treated differently than controls for other pollutants and are quite aware
B-152
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Detailed Comments of the FPA June 26, 1919
of provisions for these occurrences in existing state regulations. We
recommend omission of this section.
Page L-15
Petition for Alternative Controls (xx.8o60)
We strongly endorse the inclusion of this section. It offers the only
feasible means of economic compliance for much of this industry.
We recommend that the date for submission of a petition under these
provisions be changed to six months following the adoption of the regu-
lations by the state.
We also note that VOC emissions effects are not confined to a single plant
site. Under the alternative controls option, it would seem feasible to allow
consideration of commonly-owned facilities in the same general area (an AQCE
possibly) to be considered in one petition. Adding a definition of the
permissible area of common consideration and reference to "location(s)"
and facility(ies) would make this possible.
B-153
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95 WEST 19TH STREET, HUNTINGTON STATION, N.Y. 11746 • 516-271-4224
June 21, 1979
ALLAN ALDRIDGE
MARK ANDREWS, JR.
DON DON ELAN
WILLIAM H. ECKLER
ISADORE GOODMAN
RICHARD H. MORAN
R. RAND RICHMOND
JAMES ROANE
GEORGE F.SCHUNING
FRED SHAPIRO
WARREN F. TAYLOR
JAMES R. WESTON
BILL R. WOOD
Mr. Tom Williams
Control Programs Development
Division, MD-15
Environmental Protection Agency
Research Triangle Park, N.C. 27711
Dear Mr. Williams:
This is in response to your request for comment on the
Guidelines Document Group II Control Technique Guidelines
for Volatile Organic Compounds XX.9600 Graphics Arts
Systems.
The Flexographic Technical Association is comprised of over
700 Flexographic printers and suppliers of printing equipment
and materials. It's purpose is to benefit the flexographic
printing industry by education and legal interchange of
information. FTA supports the objectives of the Environmental
Protection Agency. We consider it our obligation to assist
by providing information relative to flexographic printing
technology. Our suggestions are intended to achieve emission
control and at the same time be as amenable as possible to
industry. The following comments relate to sections as
indicated:
Page H-5 XX.9630 (a) We recommend that the high solids
specifications be modified to allow equivalent emissions
such as would be achieved by dilution of the 60% non volatile
composition with water. The following phraseology might
be used:
(2) "The facility prints with an ink containing
no less than 60% by volume non volatile less
water."
HOWARD K.SHELDON
Green Bay
Tissue Mills, Inc
DARRELL L. DOCHSTADEU
Gar-Doc, Inc
JOSEPH COTTON
Great Plains Bag Corp
JAMES K. ELY
Inmont Corporation
WILLIAM SAYRAFE
F'ermatype, Inc.
B-154
AFFILIATED WITH EUROPEAN FLEXOGRAPHIC TECHNICAL ASSOCIATION
i.aCTOR:
GEORGE J. PARISI
-------
Page H-6 The discussion of high solids coatings might read:
"The second method is high solids technology which is primarily
experimental at this time, but which could provide emission
reduction comparable to existing technology. This method of
reducing VOC's is included at the request of the printing
industry. The specification 60% non volatile by volume of
the composition less water will achieve equivalent emission
control and permit dilution of high solids with water to
achieve low viscosity".
Page H-8 XX.9640 Compliance Schedules We understand that this section
is to assure steady stream impact on oxidant level prior to the
December, 1982 attainment dated cited in the 1977 amendments. We
suggest final compliance be achieved for all add on controls before
July 1, 1982 for the following reasons:
1. The effect of emissions on oxidant level in the early
part of theyear will have much less significance than
during the warmer months - July and August. July and
August monitoring should be adequate to determine
effectiveness of emission control.
2. Extension to July 1, 1982 will allow an additional six
months for evaluation and acceptance of available low
solvent technology on products for which it has not
heretofore been used. Six months experience is usually
minimum for commitment to a major material or process
change. The January 1, 1981 and 1982 dates do not provide
opportunity for this necessary product assurance.
Page H-9 XX.9640 Compliance Schedules The alternate compliance schedule
appears to consider the attainment date as December 31, 1982. We
believe it should embody the technology forcing concept covered in
Barber to Regional Directors, November 3, 1978 and Rasnick to Calcagni,
September 18, 1978. (Copies attached). These cited references strongly
advocate time extension for development of innovative superior low
solvent inks and coatings. Time extension will be necessary for
segments of the packaging industry wherein products such as polyethylene
bread bags, snack packaging and other laminated products and barrier
coating such as required for protection of detergent cartons cannot
be accomplished with current low solvent materials.
The industry is, at this time, cooperatively segmenting the industry
and developing time phased programs for each, consistent with that
which has been allowed for the automotive industry. We believe that
inclusion of this type of program in the model rule will promote
advocated technology forcing low solvent coatings and will simultaneously
prevent much confusion on the part of industry and the states them-
selves.
B-155
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We, therefore, recommend that you modify the model rule by adding
the second page of Barber's November 3, 1978 letter to the alternative
schedule and using the last paragraph on page 2 (continuing on page 3)
of Rasnick's letter as a discussion. These sections are highlighted
in the attached copy.
We appreciate the opportunity to comment and will further appreciate
the opportunity to discuss this subject as you consider appropriate.
Executive Director
j
B-156
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GRAVURE RESEARCH INSTITUTE. INC
22 MANHASSET AVENUE. MANORHAVEN
PORT WASHINGTON. N.Y. 11O5O
HARVEY F. GEORGE TELEPHONE
Executive Vice President AREA CODE 51 e
And Research Director as3-667o-6S7i
July 5, 1979
Mr. Tom Williams, Project Officer
Control Programs Development Division
MD- 15
Environmental Protection Agency
Research Triangle Park
North Caiolina 27711
Re: Comments on Guidance Document for the
Group II Control Techniques Guidelines
for Volatile Organic Compounds
Dear Mr. Williams:
This letter is in response to your request for comments on the
Guidance Document for the Group II Control Techniques Guidelines
for Volatile Organic Compounds.
We are members of the GRI/GTA Gravure Industry Emission Control
Subcommittee. Gravure Research Institute is the cooperative research
organization of the gravure industry and Gravure Technical Association is
our industry association concerned with industry standardization, trade
relations, education,etc. Between Gravure Research Institute and Gravure
Technical Association we represent all the publication gravure printers in
the United States and most of the gravure packaging and specialty printers.
Our Committee has extensive experience in gravure printing technology,
the manufacture and use of gravure inks and in environmental control as
related to gravure printing.
We appreciate the opportunity to make known to you our views on
this Guidance Document which will have a significant impact on the gravure
industry as it affects the development of RACT regulations by the various
State anu local agencies. We would like to offer our assistance in the de-
velopment of the sample regulations to help insure that they are both
technically and economically sounu. Our committee has spent many hours
in meetings and consultations with United States Environmental Protection
Agency in commenting on the CTG document — "Control of Volatile
Organic Emissions from Existing Stationary Source — Volume VIM:
Graphic Arts, Rotogravure and Flexography", EPA - 450/2 - 278 - 033,
OAQPS No. 1.2 - 109, issued in December 1978, and on the LAER guidance
document for the graphic arts and the NSPS for publication rotogravure now
being aeveloped. We feel that our comments have helped USEPA to better
understand the special technical problems of gravure printing particularly
as it is uifferentiated from surface coating technology. We are prepared to
meet with you to discuss our comments which follow, in further detail if it
B-157
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Mr. Tom Williams Page 2 July 5, 1979
would be helpful.
First of all we would like to emphasize that the printing industry in general
and the gravure industry in particular have certain characteristics affecting emission
control which are not shared by many other industries.
1. The need for continuous visual inspection of the product and adjustments to
maintain image quality requires the presence of pressmen at the press and a
high rate of air changes in the pressroom to meet health standards and OSHA
requirements. Most packaging products have to be solvent and odor free to
meet Department of Agriculture and Food and Drug Administration regula-
tions. As a consequence large amounts of air, much of it at low solvent con-
centration, are circulated requiring very large and expensive emission control
equipment with high energy consumption.
2. The process is not continuous. Because of engraving corrections, paper breaks,
etc., presses are operating typically only 60% to 80% of scheduled running
time. In addition there are frequent job changes, make-ready periods, and
seasonal slack periods. This greatly impairs the energy efficiency of regen-
erative incineration devices.
3. Ink coverage, i.e., solvent concentration in the air going to the control unit
varies widely from job to job. Because of the danger of a malfunction, e.g.,
paper clogging a duct, the exhausts of press units with light ink coverage are
not fully baffled down, leading to air with low vapor concentrations.
4. In many cases, the ability of printers to schedule time for emission control
equipment maintenance is severly limited because of the need to meet dead-
lines for periodicals containing topical coverage such as news or catalogs
containing price information. Such material cannot be produced ahead of
time and held in inventory.
5. In packaging, a great variety of binder - solvent systems are presently used.
In view of the present shortages and high costs of hydrocarbon solvents,
solvent recovery by carbon adsorption and subsequent separation would be
desirable. Some problems exist with corrosion - even with stainless steel
construction. Simplification of solvent systems or restructuring the job mix
for different plants will be necessary to make solvent separation and reuse
feasible. For incineration or recovery, most existing presses will have to be
equipped with new dryers to reduce the overall air flow. Special ducting to
prevent mixing of different solvents may be necessary for recovery.
6. The total plant and dryer air system should in many cases be adapted or
rebuilt to take maximum advantage of incinerator or solvent recovery.
7. Although promising, the technology for low solvent or water borne gravure
inks has not evolved to a point where compliance can be assured by this
approach by December 31, 1982. Additional time will be required for the
necessary research and testing to perfect this technology. Five years is
considered by EPA officials to be not an unreasonable length of time for
this research and development.
B-158
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Mr. Tom Williams Page 3 July 5, 1979
In view of the above points, please consider the following changes in the
proposed guideline document:
A. General Definitions — Pages A-2 to A-4
Carbon Bed Breakthrough: "that exceeus 10% by weight of —Add— "rated"
inlet VOC concentration.
During press downtime the air reaching the recovery may have very low solvent
concentrations, but some traces of solvent from the solvent inventory on the bed will
still be exhausted. Alternatively, break-through could be defined as say, 200 ppm
in the exhaust for more than 3 minutes or rapidly increasing exhaust concentration.
Overall Emission Reduction Efficiency: "The weight per unit time of VOC removed
by a control device divided by the weight
per unit time of VOC emitted by a source"
—Add— "measured over at least a month"
expressed as a percentage.
Experience obtained by solvent recovery users and in testing for the NSPS for
publication rotogravure indicates that the only practical way to measure overall
emission reduction efficiency is by a materials balance taken over as long a period
as possible — a month or longer.
The definitions of "Facility" and "Source" are confusing and appear to be in
conflict with latest EPA terminology.
A definition of "Oven" is given but no definition for "Dryer" which is the
device used in gravure printing. We suggest that the following definition of "Dryer"
be included.
Dryer: A device used to cause evaporation of solvents from inks or coatings and
convey these materials away from the substrate producing a dryed product.
A definition of "Construction" is given which includes the word "Commence-
ment" which is not defined. We suggest the following definition of "Commencement"
be included.
Commencement: An owner or operator has undertaken a program of construction or
modification or that an owner has entered into a contractual obligation to undertake or
complete, within a reasonable time, a program of construction or modification.
B. XX.9610 Definitions - Page H-2
(1) "Packaging rotogravure printing" means printing —Add— "from intaglio or
recessed image areas in the form of cells" upon paper, paper board, metal foil,
plastic film, and other substrates, which are, in subsequent operations, formed into
containers and labels for articles to be sold.
(2) "Publication rotogravure printing" means printing -Add- "from intaglio or
recessed image areas in the form of cells" upon paper which is subsequently formed
into books, magazines, catalogs, brochures, directories, newspaper supplements, and
other types of printed materials.
B-159
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Mr. Tom Williams Page 4 July 5, 1979
C. XX9620 Applicability - Page H-3
(a) This regulation applies to all packaging rotogravure - Change to —
"publication^' rotogravure and flexographic printing facilities located in a photochemical
oxident nonattainment area in the State of .
The term "printing rotogravure" used on pages H-3, H-6, H-8 and H-9 is not
commonly used in the graphic arts industry. The term "publication rotogravure"
is more common and its use will clarify the Document.
(b) It should be made clear that "potential emissions" are those emissions which
remain after the application of pollution control equipment, in accordance with
"Alabama Power vs Castle" decided by the District of Columbia Court of Appeals
just recently.
Page H-4 Last Sentence - "It should be assumed that all of the solvent consumed
evaporates into the atmosphere" — Add — "except for solvent retained in the substrate".
In publication rotogravure 5 - 7% of the solvent is retained in the substrate. In
packaging rotogravure the retained solvent depends on the ink system and substrate.
D. XX. 9630 Provisions For Specific Processes — Pages H-5, H-6
(3) The owner or operator installs and operates;
(i) A carbon adsorption system which reduces the volatile organic emission
from the capture system by at least, — Change to — "90.0" percent by weight
Recognizing the intermittent nature of gravure printing, the Volume VIII CTG
Document provides for a reduction efficiency of 90.0% of the VOC delivered to the
carbon adsorption system. We feel the sample regulation should use a reduction
efficiency of 90.0% not 95.0%.
(Hi) An alternative volatile organic compound emission reduction system
demonstrated to have at least — Change to — "90.0" percent reduction efficiency
measured across the control system, that has been approved by the Director.
To encourage development of alternative systems the required percent reduction
efficiency should not be higher than that required under (i) or (ii) for carbon adsorbtion
and incineration systems.
Discussion — Last Paragraph
We favor the alternative wording calling for ranges of capture efficiency. This
follows the CTG's basic assumptions and is in accord with the bubble concept phil-
osophy of allowing greater add-on efficiency to compensate for a capture system's
problems, so long as, the overall efficiencies are obtained.
E. XX.9640 Compliance Schedules - Pag s //-
-------
Mr. Tom Williams Page 5 July 5, 1979
and which should be carefully integrated into the general plant mechanical system.
Extra boiler capacity and plant structural re-enforcements may be needed. A
careful, customized plant engineering job is required for reasonable energy efficiency.
This is not normally the concern of control cevice manufacturers. The rush to install
solvent recovery systems for supposedly "non corrosive" publication solvents in the
early 1970's led to units which had and still have severe corrosion problems and even
internal structural collapses. We feel that the compliance schedule is too tight for a
number of publication rotogravure printers where space considerations require major
plant alteration and not practical at all for packaging printers.
Recognition has to be given in the compliance schedule to the time required for
approval of construction permits, the seasonal limitations imposed by weather con-
ditions affecting construction, particularly in winter in northern states, the time re-
quired for retrofitting of control equipment in such a way as to avoid excessive dis-
ruption of production schedules and other such considerations. Of great importance
is the need to recognize in the compliance schedule, the differences between packaging
rotogravure, publication rotogravure and flexographic printing, not only as to the
levels of emission control achievable but also as to the state of the art of the tech-
nology for emission control either by add on controls or water base or low solvent
technology.
The ink industry has testified many times that low solvent technology for all
phases of rotogravure and flexographic printing is not available. Certain portions are
currently available but not for general use. The consensus is that complete develop-
ment of low solvent technology will take five years.
To submit final plans by April 15, 1980 would effectively eliminate the options
of low solvent ink. The available options would be add on controls requiring large
capital outlays.
Similarly the selection of control equipment could not intelligently be made by
the date. Solvent recovery design depends largely on the particular solvent used.
Evaluation of this would violate current Rule 66 type legislation and require
considerable time.
The most reasonable schedule for packaging gravure appears to be a percentage
reduction in steps over a five year period. This would promote development of low
solvent materials and allow time for evaluation of options if low solvent systems are
not satisfactory.
While control equipment is currently available the choice of technique is the
problem. Developing these answers will take time. The short schedule will result in
large capital investments in equipment that may quickly become obsolete. It will
also stifle the development of new low solvent technology. It is recommended that
for packaging rotogravure an alternate compliance schedule providing for the
development of low solvent technology be included in XX.9640 (b) in a form as
suggested in the Barber letter of November 3, 1978 to the Regional Directors and
the Rasnic to Calcagni Memorandum of September 18, 1978, copies which ere
attached.
B-161
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Mr. Tom Williams Page 6 July 5, 1979
For publication rotogravure we recommend the following changes in the com-
pliance schedule of XX.9640 (a)(1).
(ii) Award contracts or issue purchase orders for the emission control system or
process equipment, or both - Change to - "within 60 days of approval of con-
struction permits and not later than October 15, 1980"
This is in recognition of the fact that these steps cannot be taken until con-
struction permits are obtained.
( in) Initiate on site construction or installation of the emission control or process
equipment or both - Change to — "before May 1, 1981"
This allows for winter construction delays in the northern states.
(iv) Complete onsite construction or installation of the emission control or process
equipment, or both — Change to —'before 18 months from (Hi) or before October 15,
1982."
(v) Achieve final compliance, determined in accordance with XX. 9650 before —
Change to - "December 31. 1982"
These changes follow from the changes in (ii) and (in) and provide additional
time for retrofitting of equipment without excessive disruption of production.
We recommend similar changes in the compliance schedule XX.9640 (a) (2) for
incineration equipment without heat recovery to allow sufficient time to obtain permits
and retrofit equipment to avoid excessive disruption of production.
XX.9650 Testing and Monitoring Page H-11, H-12, H-13
With carbon adsorption, specification of control device efficiency or its measure-
ment appears not necessary as long as the total plant recovery efficiency is measured
by a materials balance. If measured stack exhaust should be integrated over about 24
hours. The tolerance of air flow and concentration measurements to the recovery can
be ± 10% so that the use of this measurement for materials balance purposes is
questionable. Data from plant meters, i.e., solvent from tank to plant, recovered
solvent meter and ink meters can yield in most cases, a reliable materials balance when
taken over sufficient time periods, i.e., one month minimum to eliminate the effects
of varying solvent inventories in the carbon beds, storage tanks and press fountains.
Paragraph (b) A person proposing to conduct a volatile organic compound
emissions test — Add- 'jtQ^jWQjisjmte__cj)m£lM]^
of the intent to test not less than 30 days before the proposed initiation of the tests
so the Director may at his option observe the test. The notification shall contain the
information required bv, and be in a format approved by. the Director.
Emission test c'.ata siioulr. ,je only reportoc- when a test is beiiuj concucteu i-j
uetermiii3 compliance otherwise, internal testin. will probably not occur ai all.
B-162
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Mr. Tom Williams Page 7 July 5, 1979
Paragraph (c)(1)(z) states that test procedures to determine compliance must be
consistent with EPA Guideline Series document EPA-450/2-78-041. The usefulness and
practicality of this test procedure, based on the determination of organic carbon
mass concentration, for this purpose is questioned and it is suggested that this test
procedure be reviewed in the light of the experience obtained in the NSPS tests for
publication rotogravure being conducted by EPA.
Paragraph (C)(I)(H) refers to test procedures given in Appendix A of CTG
Volume II. The applicability of these tests for the highly volatile inks used in gravure
is questioned.
Discussion
Comments on a definition and procedure for determining the rate of ink usage
are requested. We suggest the use of a materials balance taken over a sufficiently
long period — at least a month — be used. The materials balance approach should
also be used in calculating overall emission reduction efficiency with allowance made
for solvent retention in the substrate and a sufficiently long period — at least a month.
Part III General Provisions
There has not been time for our committee to comment in detail on Part III —
General Provisions. Our overall reaction is that the proposed regulations are too
complex and involve too much record keeping of questionable value, e.g., the re-
quirement in XX.8070 (b)(1) that a daily written record be kept of all monitored
parameters would impose an unnecessary burden on printers and would be of little
value toward insuring compliance. Storage of such records for 4 years is likewise
of little value and an unnecessary expense. We agree that important events like
start-up, shut down, breakdowns or malfunction should be recorded and overall
performance records be maintained for a reasonable period of time. We recommend
that the General Provisions be drafted in simpler language avoiding unnecessary
record keeping and other expensive requirements which do not contribute to the
overall objective of emission control.
We appreciate the opportunity to comment on this Guidance Document and
will be glad to assist further in whatever way we can. If you have any questions on
any of the above please contact us.
Yours sincerely,
/,
Harvey F/George, Chairman)
GRI/GTA Gravure Industry' Emission Control
Subcommittee
HFG:ep
Encl.
B-163
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GRAVURE TECMMICAL ASSOCIATION, IMC.
60 EAST 42nd STREET
riEW YORK, M. V. 10017
212-661-8936
Vv appen re. Uaum
VICE PRESIDENT-EXECUTIVE DIRECTOR
June 7, 1979
Mr. Tom Williams
Project Officer
Control Programs Development Div.
United States Environmental Protection Agency
Office of Air Quality Planning £ Standards
Research Triangle Park, NC 27711
Dear Mr. Williams:
Today we received the draft of your "Review of a Guidance Document
for the Group II Control Technique Guidelines for Volatile Organic
Compounds". We appreciate being kept informed and holiday spirit
not withstanding we are trying to apply ourselves to an appropriate
reivew.
I am sure you know that GTA and GRI have joined together and formed
a committee to provide imput for our industry. Mr. Harvey George,
Vice President Executive Director of GRI, has been elected Chief
Executive Officer of this project. He will be sending you our
observations as representative of both GTA and GRI.
I'm sure you are aware of the contributions made by our committee,
and I'm equally sure you will find Mr. George and his organization
most helpful.
Thank you for keeping us infomed and if there is any way in which we
can be of help please let us know.
Cordially yours,
Warren Daum
WD/hh
cc: Harvey Geor
\l\\ '
B-164
-------
napim
NATIONAL ASSOCIATION OF PRINTING INK MANUFACTURERS INC
550 Mamaroneck Avenue. Harrison New York 10528 914-698-1004
JAMES E RENSON. Executive Director
June 19, 1979
Mr. Tom Williams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, NC 27711
Re: Guidance Document for Group II, Control Techniques
Guidelines for Volatile Organic Compounds
Dear Mr. Williams:
Thank you for your recent letter calling our attention to the
proposed Guidance Document for Group II, Control Techniques
Guidelines for Volatile Organic Compounds. We appreciate
your invitation to comment on this draft document.
The National Association of Printing Ink Manufacturers working
through the Environmental Conservation Board of the Graphic
Arts Industry has provided substantial inputs to EPA at the
time of the drafting of the Control Techniques Guideline
Document by the Office of Air Quality Planning and Standards
during informal meetings with Mr. Ed Vincent and others.
NAPIM has also provided inputs and other statements in written
form to the Office of Air Quality Planning and Standards on
this subject. We trust that the information previously pro-
vided by NAPIM is part of the record.
In view of information already provided, NAPIM has no further
comments to make on the guidance document at this time.
We appreciate your keeping us informed on developments in this
matter and hope that you will continue to alert us to any
further changes in the status of the proposed guidance document.
Sincerely,
Janfes E. Renson
Executive Director
jj
-------
REGENERATIVE ENVIRONMENTAL EQUIPMENT CO., INC.
BOX 600 • 520 SPEEDWELL AVENUE • MORRIS PLAINS NJ 07950 • PHONE (201 i 538-8585
June 19, 1979
Mr. Tom Williams
Project Officer
Control Programs Development Division MD 15
ENVIRONMENTAL PROTECTION AGENCY
Research Triangle Park, NC 27711
Subject: Review of a Guidance Document for the Group to Control
Technique Guidelines for VOC
Reference: EPA Draft Part I and III
Dear Mr. Williams:
In reviewing the draft reyulations for Graphic Arts Systems, we find that
although some oxidation equipment has been mentioned as a viable solution,
the real potential in cost effectiveness needs additional clarification.
Highly efficient thermal oxidation equipment with 85 and 90% primary heat
recovery have and are being installed on printing processes and are providing
substantial return on investments. The high thermal energy recovery of the
RE-THERM Unit will allow the system to operate at a "NIL" fuel usage, plus
provide clean preheated drying air to the presses. The utilization of the
clean exhaust from the RE-THERM Unit as make-up or drying air at the press
will provide 'additional secondary heat recovery. This additional energy
savings can be substantial and should be considered even though the dryers
operate at a low temperature.
The attached table reflects typical applications of the RE-THERM System in
rotogravure printing applications. You will note that there is an overall
plant energy reduction on each application when the clean exhaust from the
RE-THERM is utilized. In the case of rotogravure packaging where solvent
concentrations are higher, the energy savings can be substantially greater
than those reflected in the attached table. ' In any case, this technique has
been and is being utilized on several printing applications.
May I repeat the most significant point . . . The RE-THERM System will reduce
the plant energy requirement while providing pollution control.
We trust that the above point, that volatile organic compound control can be
achieved while still reducing the overall plant energy consumption will be
clarified in your final report to the industry.
Respectfully yours,
Rodney L. Pennington
Sales Manager B~166
Rl P- irl
J Energy and the Environment
-------
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Rexham
PACKAGING RESEARCH CENTER
CHURCH STREET EXT
FLEMINGTON, NEW JERSEY 08822
201/782-4100
July 16, 1979
Mr. Tom Williams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park,
North Carolina 27711
Dear Mr. Williams:
Attached are Rexham1s comments on the Draft Guidance Document
for Group II Contsrol Technique Guidelines for Volatile Organic
Compounds.
We realize that the questions that we shall raise in this
letter are not the specific -issues under discussion in the
Guidance Document and so are separated from our direct
comments. Our questions in this letter refer to whether
or not the air quality goal is attainable and whether or
not the strategy to attain the goal is reasonable.
We as a company recognise our obligations to reduce the
quantity of solvent emitted from our operations. We are
now involved in significant changes to reduce emissions
and we are committed to an on going program in this regard.
Further, we have installed control devices where they are
appropriate.
We are very much concerned, however, that the stringent
requirements incorporated in the Guidance Document will
be unsuccessful in attaining the primary standard for
ozone regardless, of the efforts applied. If such strin-
gent measures are pressed to the fullest extent of the
states powers the net effect will be to stress the economy
without obtaining a commensurate improvement in air quality.
The natural sources of hydrocarbons in the air far exceed
the anthropogenic sources and substantially control the
ozone level in many areas of the United States. In these
areas the air quality standard of 0.12 ppm is unrealistic
and unattainable. A complete shutdown of industry in such
areas would have little effect on major "smog" episodes.
We note that the high ozone levels in California in 1978
were predicted based on a correlation between winter rain
and summer ozone. We believe that the ozone level in the
Northeast is strongly influenced by the natural emissions
from the Southern Appalachian mountains.
B-168
P.O. BOX 111 • FLEMINGTON, NEW JERSEY 08822
-------
The scientific basis for control of VOC is weak and in the
case of water miscible solvents it is virtually non existant.
We are particularly sensitive to this issue since we operate
a number of flexographic printing presses where the emissions
consist substantially of mixed alcohols.
We believe that EPA should reconsider the ozone standard and
the attainment strategy so that the massive effort that will
be put in motion will have a clear chance of success.
Very truly yours,
T. M. Bassett
Environmental Affairs Coordinator
TMB/b js
Enclosure
B-169
-------
Rexham Corporation June 29, 1979
COMMENTS ON THE GUIDANCE DOCUMENT FOR THE GROUP
II CONTROL TECHNIQUE GUIDELINES FOR VOLATILE
ORGANIC COMPOUNDS
INTRODUCTION:
Rexham Corporation is a producer of flexible packaging
materials, and so operates rotogravure and flexographic
presses, laminators, coaters, and a number of machines
that involve combined operations. This activity is
conducted at a number of plants, some quite small.
Rexham1s significant markets include flexible packaging
for foods, drugs, medical devices, and soft goods.
COMMENTS:
1. Definition of RACT - "economic feasibility"
The definition of Reasonably Available Control Technology
(RACT) specifically includes the test of "economic feasi-
bility" . If guidance to the states is required on any
issue it is required here. It is recommended that FPA
provide a series of tests to amplify the meaning of "economic
feasibility". We suggest that the following test be in-
cluded:
a. Capital value of equipment: The cost of a
device, including installation shall not
exceed the cost of the prime machine (invoice
value). It is unreasonable to require a re-
trofit that would cost more than the prime
machine.
b. Age of equipment: The age of equipment should
be taken into account in establishing a require-
ment for a device. Further, old equipment should
be granted an emission discount for purposed of
the "Bubble Concept". For example, a press 15
years old or older should have a 50% discount
when calculating emissions.
B-170
-------
c. Utilization of equipment" The degree of control
for equipment used less than 5000 hours per year
should not be equivalent to that required for a
machine that is fully utilized. There are a
number of machines in the flexible packaging
industry that are used for a very few grades, and
are idle at other times.
d. Inflationary impact: The cost of pollution con-
trols shall not add more than five percent to the
cost of materials manufactured at any single loca-
tion in order to minimize the cumulative inflationary
impact through the chain of manufacture and dis-
tribution.
If despite failure of one or more tests a device is to be
required the Authority shall issue a letter, signed by the
Director, reviewing the situation and confirming the require-
ment for a device.
2. Question and Answer on page H-7
It is highly desirable for reasons of consistent enforcement
to have all operations at a single flexible packaging plant
regulated under the same guideline, i.e. the Graphic Arts
guideline. This approach would avoid the confusion that will
exist if a "Bubble concept" plan is to be prepared for a
location operating under two different guidelines.
3. Compliance Schedules
The compliance schedules are unrealistic and invite over
optimistic projections. The design construction of an incin-
erator and air handling system is a time consuming enginerring
effort, especially for retrofit installations. Because of the
variety and complexity of abatement options available we sug-
gest the following schedule:
a. Submit plan for compliance before March 13, 1980
including a tentative schedule.
b. Submit an annual report of activity with a re-
vised compliance schedule that reflexts the
progress of the past year and the advances in the
state of the art for compliance.
In many areas, such as low solvent technology
the state of the art will change, perhaps sub-
stantially, in a year, so a revised compliance
schedule is in order.
B-171
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4. Carbon Absorption System (page H-5)
The Guidance Document assumes that a carbon bed is always
95% efficient. Further, any carbon bed that is less than
95% efficient would be in violation. Under this regulation
nine of ten carbon beds now in operation would be in viola-
tion. Carbon bed absorption involves many problems of
fouling and loss of efficiency.
It is recommended that an efficiency of 85% or better be
required at start-up, and that thereafter the carbon bed
meet commercial standards of efficiency.
5. Discussion - Water Borne Technology (page H-12-)
The technology of water borne inks and coatings is now
emerging and the prospects for achieving compliance by
this route appear to be good assuming the technology
continues to advance at its present pace. The Guidance
Document does not. discuss the experimental nature of
this approach so it may be assumed by state authorities
that aqueouse inks and coatings are "off the shelf" items
for all uses. We suggest that EPA consult with the
appropriate trade; associations for a realistic presenta-
tion of the current state of water borne technology.
6. Specialty Items
It is recommended that special consideration be given the
many low volume specialty items that are used for highly
regulated end uses such as Health Care packaging or high
performance end uses such as packaging chemicals e.g.
pesticides. The solvent emission involved in manufacturing
such items is a minor part of the total emissions of the
industry. Replacement of components to avoid the use of
solvents will be difficult and time consuming, and we believe
that the priority should be placed elsewhere. We suggest
that an "exempt" class be established for specialty items
for a period of time; such as three years.
B-172
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&. 100 TPY Size Limitation
We believe that a blanket exemption from control for any
establishment emitting less than 100 tons per year is
grossly unfair and may constitute unequal application of
the law.
The Flexible Packaging Industry is comprised of a large
number of very small operations, and relatively few medium
sized and large operations. In effect the small entre-
preneur would be permitted to operate without restraint or
responsibility, while a medium size or large business would
bear the full costs of the stringent requirements. It
should be noted that the 100 TPY exemption would apply to
almost half of the business in this industry. Further, it
would encourage a small operator to avoid the requirements
by setting up new locations rather than adding equipment
at one location.
8. Business Growth
The Guidance Document encourages the contraction of a busi-
ness by providing credits for the shut down of equipment
and by imposing substantial penalties for the installation
of new equipment. We believe that this is unwise at a
time of economic stress, and was not intended by Congress
when the Clean Air Act was under consideration. We ugre
that, at a minimum, the Guidance Document permit transfer
of "old" equipment from one location to another under RACT
requirements. Futher we urge that the Guidance Document
clearly permit increased utilization of equipment at a
location by adjustment of the "Bubble Concept" base and
goal.
9. Energy Consumption
The Guidance Document should provide instructions to the
states on the question of the acceptable trade-off of sol-
vent emission reductions against increased energy consump-
tion. For each location both the solvent emissions baseline
and the energy consumption baseline is known. It would seem
inappropriate and unacceptable to reduce solvent emissions
from a location by 25 percent at a cost of a 100 percent
increase in energy consumption. We suggest that, in general
if the energy required to operate a device calculated as
gallons of No. 2 fuel oil (i.e. 140,000 BTU) exceeds the
volume of solvent destroyed or recovered calculated as gallons,
the device would be considered inefficient and not required
except in unusual circumstances. For example, if an inciner-
ator requires two gallons of fuel oil to destroy one gallon
of solvent the device would be considered inefficient, and
not be required.
bjs B-173
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REYNOLDS ALUMINUM
REYNOLDS METALS COMPANY • RICHMOND, VIRGINIA 23261
July 5, 1979
Mr. Tom Williams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Dear Mr. Williams:
Reynolds Metals Company, welcomes the opportunity to
provide comments on the draft guidance document GCA Corp-
oration is developing under contract to the Environmental
Protection Agency (EPA) to assist State and local agencies
in preparing RACT regulations for the Graphic Arts Industry.
The comments provided below reflect Reynolds' experiences
in the Graphic Arts Industry and Reynolds' understanding
of the technical and regulatory issues encompassed by the
Graphic Arts Control Techniques Guidance document.
Reynolds has several concerns with Section XX.9620
entitled, Applicability (refer to Page H-3). The Clean Air
Act Amendments of 1977 require the adoption of "reasonably
available control technology" (RACT) on existing sources
located in nonattainment areas. Section XX.9620 (b) indi-
cates that the EPA apparently desires to require the instal-
lation of RACT contcols on at least major sources in attain-
ment areas. Reynolds believes that the Agency lacks the
requisite statutory authority to require State or local
agencies to adopt R^CT regulations in attainment areas.
Accordingly, Reynolds believes that the guidance document
being prepared by GCA Corporation should not address the
establishment of emission standards in attainment areas.
Reynolds takes this position in view of the absence of statutory
authority and the fact that any reference to attainment area
emissions in the guidance document merely confuses the issue
of what is required of an approvable state implementation
plan.
B-174
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Mr. Tom Williams
Page 2
July 5, 1979
Throughout the applicability section and ensuing dis-
cussion, the document indicates that potential emissions
are to be calculated based on historical records of actual
consumption of solvent and ink. The term "consumption,"
as it is employed in the body of the document , apparently
implies total input of inks and solvents will be considered
in determining total volatile organic compound VOC) emis-
sions. In that waste inks, coatings, adhesives and solvents
are generated and disposed of through authorized means, as
far as a printing plant is concerned, Reynolds believes that
consumption should be defined as the summation of VOC input
less VOC disposal by other authorized means.
In view of the recent court decision in Alabama Power
Company, et al V. Costle No. 78-1006, Reynolds further believes
the definition of potential emissions employed in the guidance
document is in need of substantial modification. Reynolds
generally agrees with the Court's opinion in the referenced
case that potential emission calculations must credit emission
reductions secured through the proper use of the air pollu-
tion control devices.
Reynolds believes that the applicability section would
be greatly improved by the addition of an emission floor
threshold below which additional control would not be required.
Sources emitting less than 100 tons per year VOC represent
a very small portion of the flexible packaging industry.
Requiring the installation of control equipment on such minor
sources does not appear to be justified on a cost-effect-
iveness basis. Accordingly, Reynolds believes small sources
with potential emissions below 100 tpy should be exempt from
the RACT regulations.
Reynolds' most serious concerns with the draft GCA
guidance document are with Section XX.9630 entitled Provisions
for Specific Processes (refer to Page H-5) and Section XX.9640
entitled Compliance Schedules (refer to Page H-8). It appears
to Reynolds that these regulations were developed for paper
printing and that foil or plastic film substrates were not
properly considered. The discussion following Section XX.9630
appears to imply that water-borne inks are commonly employed
on foil and plastic substrates. Water-borne inks may be
reasonable for paper printing, but are certainly not an avail-
able technology for impervious substrates such as metal foils
and plastic films. Additionally, we doubt that satisfactory
water-borne materials are available for process or partial
dot printing regardless of the substrate involved.
B-175
-------
Mr. Tom Williams
Page 3
July 5, 1979
The discussion following Section XX.9630 also implies
that add-on control equipment is generally readily available
to the Graphic Arts industry. The Agency's attempted transfer
of technology from what they consider to be similar sources
fails to recognize the complexity and necessity of producing
food grade flexible packaging material. Packaged food pro-
duct quality can be easily impaired by residual solvents
and steps to increase the concentration of VOC in printing
press exhausts can create an unsatisfactory product quality
situation. Add-on control technology is not feasible unless
VOC concentrations in exhaust gas concentrations and con-
temporaneous decreases in oven air flow rates can be realized.
Any effort, however, to effect such modifications to current
operating practices must be carefully and meticuously re-
searched to assure that high quality food packaging material
is not adversely impacted. Research in these areas has just
begun. Reynolds believes that it is incumbent upon EPA to
recognize in the model rule guidance document the complexity
of controlling emissions from flexible packaging materials.
The production of high quality flexible packaging materials
is vital to the nations food and drug distribution channels.
Any proposed modification to the production process requires
a more careful and complete examination than has been given in
the draft guidance document.
The categorical compliance schedules provided in Section
XX.9640 apparently are based in large part on the assumption
that control technology is readily available to the flexible
packaging industry. As heretofore discussed, control tech-
nology is not readily available to large segments of the
flexible packaging industry. The categorical compliance
schedules indicate compliance must be achieved by either
January 1, 1982 for process equipment changes, low solvent
technology, and ^.dd-on control devices including incineration
with heat recovery or by January 1, 1981 for incineration
equipment without heat recovery. Reynolds believes that
for printing on impervious substrates and partial or process
dot printing these schedules are unreasonable and unattain-
able. High solids and water-borne coating systems have not
been adequately developed for impervious substrates. Pack-
aging materials produced by Reynolds, among other producers,
are necessary and integral to the country's food and drug
distribution system. Modifications to ink systems and pro-
duction methods will require many approvals in addition to
EPA permits. Customer shelf life and taste tests alone may
require up to one year. Obtaining approval of the Food and
Drug Administration to utilize new inks may require, in certain
cases, up to two years. The high priority the industry places
B-176
-------
Mr. Tom Williams
Page 4
July 5, 1979
on developing suitable inks is evidenced by the estimated
75 percent or greater ink industry R & D directed at low
solvent technologies. EPA in the model rule should recognize
that the industry deserves the time to develop low solvent
technologies. The categorical compliance schedules, in
effect if adopted, will stifle a significant portion of low
solvent technology development efforts.
Reynolds believes that reasonable progress towards
attainment of the ozone national ambient air quality stan-
dard, can be achieved without the wholesale adoption of
categorical compliance schedules which ignore the complexities
of producing food grade flexible packaging materials and
the like. We believe that reasonable further progress can
be achieved while simultaneously allowing for the development
of technolgies suitable to the flexible packaging industry.
A stepwise program to reduce VOC emissions at flexible pack-
aging plants would accomplish these two worthy objectives.
A reasonable five year program to control VOC emissions at
a flexible packaging printing plant would.be:
(1) Submit compliance plan
(2) Reduce VOC emissions by
16.25% (1/4 of 65%)
(3)
(4)
5)
Reduce VOC emissions by
32.5%
Reduce
48.75%
VOC emissions by
12 months after plan
approval
24 months after
plan approval
36 month after
plan approval
48 months after plan
approval
Reduce VOC
65%
emissions by
60 months
approval
after plan
A compliance plan such as this will allow the develop-
ment of suitable technologies in the most advantageous way
to the country. Progress towards attainment of the national
ambient air quality standard will be achieved with minimum
disruption to the flexible packaging industry.
B-177
-------
Mr. Tom
Page 5
July 5,
Williams
1979
Due to our serious concerns with the Graphic Arts model
rule, Reynolds hereby requests the opportunity to meet with
the Agency and/or its contractor to discuss its recommenda-
tions prior to the time the draft guidance document is finalized,
Should you feel such a meeting would be worthwhile, please
feel free to contact me at (804) 281-3871.
rs,
/ct
cc: K. N. Weiss
Director of FnviroTmental'
Control
Environmental Control Dept.
B-178
-------
July 26, 1979
Mr. Tom Williams, Project Officer
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
SUBJECT: Comments on Draft Sample Regulations for VOC Control
of Graphic Arts
Dear Sir:
The following comments and recommendations are submitted in response to the
draft EPA guidance document on regulation of VOC controls for graphic arts.
The sample regulation is quite comprehensive in nature and, when reviewed
with the discussions and appendices provided, represents far more than just
an additional emission regulation. Consequently, there are two areas to be
addressed:
1) improvements in the sample VOC regulation presented, and
2) identification and comment on policy questions and future
strategies that are implied in the discussions and appendices.
Sample Regulation for VOC Control of Graphic Arts
1) Section XX.9620 (b) Applicability, Which specifies use of historical
records on consumption of solvent and ink, is a reasonable approach
to determine potential emissions and, thereby, identifying sources
subject to regulation. Caution should be exercised, however, when
calculating actual consumption of solvent and ink. An overly simplistic
approach, such as use of purchase records alone, may result in an excess
of emissions charged to the facility. A certain amount of solvent leaves
the plant as waste to be disposed of, or returned to the supplier for
reprocessing. Therefore, the emissions from waste material should be
counted as emissions. This solvent should be subtracted from the pur-
chased solvents to arrive at actual emissions.
B-179
-------
RJR Archer, Inc.
Wmston-Salem N C 27102
July 26, 1979
2) Section XX.9630 (3) Provisions for Specific Processes, specifies in (i)
and (iii) that the capture efficiency of carbon adsorption or alterna-
tive controls must be at least 95%. This is more stringent than the
recommendation of the CTG document in Section 1.2.1 which states, "A
reduction efficiency of 90 percent of the VOC delivered to these devices
(carbon adsorption and incinerator) can and should be achieved." It is
recommended that the capture efficiency be uniformly set at 90% for all
control methods. In addition the language of (3) can be cleaned up by
using the term "capture efficiency", which has been defined previously,
instead of attempting to describe the desired result.
3) Section XX.9640 (b) Compliance Schedules, is imperative to allow sources
using strategies tha.t are based on low solvent technology or process
change to write more appropriate increments of progress than those pro-
vided in a (1) .
4) Section XX.9650 (c) (2), Testing and Monitoring, is a reasonable method
of determining compliance for low solvent technology and provides the
most cost, effective approach to assuring compliance. Direct testing
should be minimized.
5) Section XX.8010 (c) Applicability, should include the exemption of graphic
arts pilot plant operations. The discussion clearly implies that these
operations are not intended to be regulated. Application of Section
XX.9620 (b) does not alleviate the situation since the word "facilities"
is used rather than the word "source". It is recommended that (c) be
amended to read "Part (b) (1) of this section does not apply to the
following regulations."
6) Section XX.8030 Inspection, Maintenance, and Operating Procedures, requires
the Inspection and Maintenance Manual to be available before the final
compliance date. The discussion adds that if more than one device is
included in the manual the earliest final compliance date is the appro-
priate one for the entire manual. There is no benefit to air quality
from this interpretation, and it may be impossible to meet if different
vendors are involvad.
7) Section XX.8040 (a) Breakdown, Malfunction and Operation Changes, requires
the source "immediately" notify the Director. Immediately is imprecise
and needs to be qualified in terms of specific periods of time and with
respect to precedence to safety of employees or others in the vicinity.
8) Section XX.8040 reporting can be construed as redundant of the non-
compliance penalty regulations. This section could be eliminated, or at
a minimum, coordinated with the non-compliance penalty regulations to
avoid conflict or duplication.
B-180
-------
RJR Archer, Inc.
V,instTi-Salem N C 27102
July 26, 1979
POLICY AND STRATEGY IMPLICATIONS
1) Since the sample regulations are not subject to a formal public review
process and will be circulated to the states as guidance, development
of some interpretive policies is inappropriate in this document. Policy
relating to "bubble concept", non-compliance penalties, and other major
regulations is developed in the discussions with no mention of maintain-
ing consistency, avoiding overlaps and, in some cases, based on proposed
policy.
2) Mr. Hawkins' memorandum of July 3, 1978 states that, "For VOC sources,
only source categories covered by a CTG document could be included in a
RACT Bubble." This requirement is unnecessarily restrictive since it
does not allow maximum flexibility to use the most cost effective mix
of controls. As long as a source can demonstrate equal environmental
benefit and equal emissions reductions, there should be no qualification
of what sources can be used in "internal offsets".
3) In the memorandum mentioned, there is a reference to elimination of
"internal offsets". Elimination of the "internal offset" policy will
not only reduce incentive to develop new and more effective methods of
control, but also reduce the ability of a facility to minimize the
economic impact of controlling emissions. Allowing industry to choose
the most cost-effective approach to control will not conflict with
achieving the ambient air quality standards.
In summary, I would like to thank you for the opportunity to present the
viewpoint of RJR Archer, Inc. on the draft sample regulations for VOC
control of graphic arts. We feel that availability of sample regulations
is beneficial to the states for developing workable SIP revisions, if care-
ful attention is given to wording. For instance, use of specific percent
reduction values or other definite numeric limits may encourage states to
adopc regulations with unrealistic limits. This possibility could be re-
duced by substituting a noncommital value like "XX%". Additionally, policy
discussion on interpretation of the regulation should be limited to that
which has already been decided in the public forum, rather than internal
views. If you have any questions or would like to discuss any of the comments
further, please call Mr. John Kartanson at 919-748-4416, or Connie Jurgensen
at 748-4611.
Very truly yours,
/o
L. J. Upton, Jr.
Vice President
LJUJr/jg
cc: Thomas J. Dunn
B-181
-------
PAPER COMPANY Gulf Life Tower, Jacksonville, Florida 32207 (904) 396-5741
June 28, 1979
MX-, Tom Williams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Dear Mr. Williams:
The following comments, on the draft of the guidance document for
State and local agencies in preparing RACT regulations for volatile
organic compounds, are submitted by St. Regis Paper Company.
St. Regis Paper Company is a fully integrated forest-based products
company whose primary lines of business are the manufacture and sale
of pulp, paper and paperboard, newsprint, packaging and converted
products and construction products. The St. Regis packaging and
converted products include overwraps, pouches, and bags of plastic
and composite film for distribution of baked goods, snacks and other
food and household products? multiwall bags, consumer bags, and
plastic film for distribution of chemical, mineral and agricultural
commodities, human and ctnimal foods, and consumer products; folding
cartons•for distribution of consumer products; laminated, coated,
and reinforced materials for construction, packaging, graphic arts,
and industrial uses; and paperware school supplies, envelopes, and
grocery bags for consumer, retail and institutional markets. In pro-
ducing these products the flexographic and rotogravure printing proc-
esses are of major importance. St. Regis Paper Company is therefore
concerned that reasonable, feasible, and cost effective regulations
are adopted by the States for the graphic arts industry. It is for
this reason that the following comments on tha guidance document tire
Page H-2, XX. 9610 Definitions
Since flexographic printing has been defined in (3), a definition of
rotogravure printing should also be included. The following definiti
is suggested:
"Rotogravure Printing" means the application of words, designs
and pictures to a substrate by means of a roll printing tech-
nique in which the pattern to be applied is recessed relative
B-182
-------
Mr. Tom Williams Page 2
Control Programs Development Division 6/28/79
——•••ETT
to the non-image area. The image is in the form of cells
or cups mechanically or chemically etched in the surface
of copper-plated steel cylinder which is usually also
chrome plated to enhance wear resistance.
The definition of "Packaging rotogravure printing" in (b)
(1) is narrowly restricted by specifying that subtrates
are formed into "containers". Containers, in the industry,
usually means a particular kind of packaging product. It
is suggested that "containers" be omitted and be replaced
by a more general term, such as "packaging product".
Page H-3, XX. 9620
To be consistent with the language found elsewhere in the guidance
document and in the Volume VIII CTG document, "publication rotogravure"
should be used instead of "printing gravure". This change should be
made in the following places:
Page H-3, XX.9620
(a) last word in line 1
Discussion, third paragraph, fifth line
Page H-5, XX.9630
(a) next to last word in line 1
Page H-6
(c) last word in line 1
Page H-8
(a) last word in line 1
Page H-9
(b) last word in line 1
Page H-3, XX.9620 (b)
We are pleased that a small source exemption of l.OiO tons/
year has been recommended by EPA.
Page H-5, XX.9630
(a) (3) In specifying a percent efficiency for carbon
adsorption, incineration, and alternative systems, it
would appear to be more practical and equitable to specify
a common efficiency level. A common level would not favor
one system over another, and would not penalize one system
over another. For example, the percent efficiency for a
carbon adsorption system determines the regeneration cycle
frequency and breakthrough point, which determines regener-
ation time and cost. A higher percent efficiency for carbon
adsorption, or for an alterntive system, may penalize these
B-183
-------
Mr. Tom Williams Page 3
Control Programs Development Division 6/28/79
, ,-,
selections over the selection of an incineration system.
It is therefore suggested that a common percent efficiency
of 9Q% be recommended for the three options in (i)<_, (ii)
and (iii)»
Page H-8, XX.9640 Compliance Schedules
The compliance schedules proposed in (1),(2) and (3) are,
in our opinion, unrealistic. It is known that regulations
development by the States is behind schedule, adoption
of regulations for the graphic arts industry is not ex-
pected in many states until early 1980*. To require final
plans by March and April 15, 1980, is for practical pur-
poses, unrealisitc. It has been our experience that
approval of final plans by most agencies, requires more-
time than the three months suggested in the guidance document
between submittal of final plans and awarding of contracts
or issuing purchase orders.
It is our opinion,, that equipment delivery times for VOC
control equipment will become extended beyond the proposed
compliance schedule time as increased orders extend beyond
the equipment manufacturer's ability to produce.
Sufficient evidence has been submitted to EPA and to State
agencies to indicate that the alternative of low solvent
technology may not be possible to develop, test and im-
plement in the time proposed in the guidance document.
In summary, it is clearly evident that insufficient time is
being allowed to properly analyze a multi-source VOC emission,
properly engineer the most optimum system (particularly con-
sidering energy requirements, solvent availabilty, existing
equipment modifications, and product acceptability). We be-
lieve it will become mandatory to develop a more realistic
compliance time schedule.
Page L-2, XX.8010 Applicability
(a) Because it appears that adoption by States of regulations
for graphic arts will extend beyond December 31, 1979, it is
suggested that the effective date be left to each State.
St. Regis Paper Company appreciates the opportunity to comment on the
proposed guidance document. We would be happy to participate in dis-
cussions of the document.
Very truly yours,
/
E. T. Tonn, PE
Environmental Engineer
ETT/abl
B-184
-------
tlanticRichfieldCompany
July 19, 1979
Mr. Tom Williams
Control Programs Development Division, MD-15
U. S. Environmental Protection Agency
Research Triangle Park
North Carolina 27711
Dear Mr. Williams:
The Atlantic Richfield Company has reviewed the draft Guidance Document to
assist state and local agencies in preparing RACT regulations for volatile
organic compounds, which you sent to us. Our specific comments are attached.
The concept of "sample" regulations is useful. The difficulty with them is
that, as in the case of Control Technique Guidelines (CTG's), state and local
agencies have interpreted the language of the "samples" as the bare minimum
acceptable by EPA. In addition, EPA personnel at the regional offices have
also made this interpretation, often without consulting with the various
authors of the CTG's to determine the true intent of CTG language. The result
has been additional turns of the screw by each agency when developing regula-
tions which "ratchet down" on existing facilities.
It would be a significant improvement if EPA would provide sample format
only and leave the development of appropriate numbers and other specifics to
the various agencies. This would allow for maximum flexibility to meet local
or state needs and would preclude overly restrictive regulation simply to
satisfy the language of a "sample" regulation.
Sincerely,
M. C. Roman for F. W. Chapman
Attachment
cc: Mr. H. M. Dole, Atlantic Richfield Company
B-187
-------
ATLANTIC RICHFIELD COMPANY
Comments on draft EPA Guidance Document
to State' and Local Agencies
July 19, 1979
Page A-2 through A-4
All definitions should be consistent with previous definitions of the same
item in the Clean Air Act and its amendments.
Page 1-7, para (b)(l) - "monthly" inspections
The specific inspection interval should reflect experience with tank seal
wear and local air quality requirements.
Page L-4, para (a) - "disposal...evaporation into the atmosphere."
It is impossible to eliminate hydrocarbon evaporation if hydrocarbon occurs
in sewage treatment plant, influent. This language is inconsistent with the
stated intent.
Page L-5, para (a) - "...Maintenance Manual..."; and
para (c) - "...Operators Manual..."
The requirement to prepare, submit for approval, and utilize the subject
manuals represents a clear move on the part of EPA to get into the business
of directing private sector operations on a daily basis. We are opposed to
this.
Page L-7, para (a), "...immediately..."
It is impossible to have a malfunction and simultaneous notification of a
regulatory agency or anyone else. A reasonable notification period should
be allowed. One hour after discovery of the malfunction should be satis-
factory notification.
Page L-7, para (b), "...require feasible and practical modifications..."
This language might be interpreted to require redundant or over-capacity
equipment for potential problems or regular maintenance requirements which
result in short term excess emissions occurences. Normal unit startup and
shutdown emissions are not likely to cause violations of ambient air qual-
ity standards or interfere with reasonable further progress toward attain-
ment. There must be some allowance for necessary maintenance without re-
quiring expensive equipnent which is likely to be idle for months, perhaps
years, between uses. B-188
-------
A good example of this is a fluid catalytic cracking unit (FCC) in a
petroleum refinery. During startup and shutdown an FCC is in a non-
steady-state operation for a short time (one or two days) until the
proper catalyst bed levels, air rates, etc. are established. During
this nonsteady-state operation, emission control devices do not oper-
ate as efficiently as normal and more pollutants than normal are
emitted. To require refineries to replace or add to existing FCC emis-
sion control devices with new equipment that is designed to control
emissions at the same efficiency during brief startup and shutdown oper-
ations as during steady-state operation would be extreraely expensive,
if possible. The air quality benefit would be very minimal since FCC
units are normally operated for more than a year between maintenance
shutdowns.
We strongly recoi.attend that:
(1) the rules be limited to application to recalcitrant organizations
and facilities that have not invested capital in facilities re-
quired by environmental regulations, and
(2) that the Director may not require redundant or excess capacity equip-
ment for potential problems or regular maintenance requirements.
Page L-15 - L-16, "Petition for Alternative Controls"
This concept is worthy of further development ana amplification and should
be allowed for by all (local, state, federal) regulatory agencies. It will
result in the most cost-effective controls and encourage innovative ap-
proaches to minimizing emissions. Vie compliment EPA on the concept. As
noted in our general comments, however, "sample" regulations tend to become
the yardstick for measuring up counter proposals. Specifics should be
eliminated from all "sample" rules to permit maximum flexibility in regula-
tion development.
B-189
-------
Chevron
|^^ Chevron U.S.A. Inc.
^^^ 575 Market Street, San Francisco, CA 94105
<" •& ; Mail Address. P.O. Box 7643, San Francisco, CA 94120
G.H.Weber July 18, 1979
Manager, Engineering
Marketing Operations
Mr. Tom Williams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, NC 27711
Dear Mr. Williams:
I am writing concerning your request for comments on the Document to Assist
State and Local Agencies in Preparing Regulations for Volatile Organic Com-
pounds (RACT categories) by GCA Corporation. I shall limit my comments to
Section XX.9700, Petroleum Liquid Storage in External Floating Roof Tanks.
XX.9720 (a) The application of the regulation should be increased to 160,000
liters (*4-2,200 gallons) to exclude 1000 barrel tanks which are a common
size at many locations.
XX.9730 (a)(2)(iii) This paragraph should be clarified as explained in the
discussion on Page 1-12. I suggest the following wording:
(a)(2)(iii) For vapor mounted seals, the area of gaps exceeding 0.32 cm.
(1/8 in.) in width between the secondary seal and the tank wall shall not
exceed 21.2 cm2 per meter of tank diameter (l.O in per foot of tank
diameter) as determined by the method in 8 XX.9750(c) and the width of
any gap shall not exceed 1.27 cm (1/2 in.).
Comment - It is suggested that the frequency of inspection be made yearly
and that record be kept for two years only unless directed by
the administrator., The regulation as put forth is unduly burden-
some and materially increases bookkeeping requirements.
XX.9750(b) The requirement of 30 days' notice before testing seems excessive.
Notice of no more than seven days should be sufficient.
If there are any questions on these comments, please call Don Gilson at
89^-6897.
Very truly yours,
B-190
-------
Getty Oil Company P. 0 Box 5237, Bakersfield, California 93388 • Telephone (805) 399-2961
Western Exploration and Production Division, R A Griffith, Pipeline Manager
July 19, 1979
File: GOV 1-15-5
Environmental Protection Agency
Control Programs Development Division
MD-15
Research Triangle Park, North Carolina 27711
Attention: Mr. Tom Williams
Re: Guidance Document for the Group II Control Technique
Guidelines for Volatile Organic Compounds
Gentlemen:
Thank you for giving us the opportunity to comment on the subject pro-
posed guidelines. While we concur in principal with the proposed guidelines and
techniques, we believe the following changes in language would be equally as ef-
fective in controlling air pollution and less cumbersome to administer.
Page 1-4, Paragraph XX.9720 (b) (2)
Delete expression "prior to lease custody transfer"
Reason: Whether custody transfer of oil takes place has no relationship
to emissions.
Page 1-7, Paragraph XX.9730 (d) - Change^to read:
"The owner or operator of a petroleum liquid storage vessel subject to
this regulation, shall retain records required by this part and shall
submit such records to the County Air Pollution Control Officer upon
his request."
Reason: Since air pollution control regulations are being administered
and enforced by local air pollution control districts who in
turn respond to state level authority, we recommend that EPA
look to state level authority for compliance information.
Page 1-10, Section XX.9740
The compliance schedules should be adjusted so that final compliance will
be achieved by January 1, 1982.
B-191
-------
Environmental Protection Agency
Control Programs Development Division
Attn: Mr. Tom Williams
Page 2
July 19, 1979
Reason: While EPA recognizes and addresses the problem on Page 1-11 that
a one-year period for compliance will be too short for many
owners, the filing and getting approval on alternate plans may
take as long as actual compliance. We recommend a two-year al-
lowance for compliance to allow adequate engineering, permitting
and construction time.
Page 1-12, Paragraph XX.9750 (a)
The last centence of the paragraph should be deleted.
Reason:: It is not necessary for persons who are measuring roof seal gaps,
or reading thermometers or running laboratory tests on hydrocarbc
liquids or their supervisor be "qualified by training and/or ex-
perience in the field of air pollution testing" to be able to cot
plete the reports necessary for compliance with Section XX.9730.
Compliance with Section XX.9730 can be determined by comparing
physical criteria with printed regulations by persons of normal
intelligence who are not necessarily trained in air pollution
testing.
We hope these coriments will be useful to you in preparing the final subjei
guidelines. If you wish to discuss any of these items, you may contact Mr. C. M.
Whitlock of this office.
Very truly yours,
GETTY OIL COMPANY
CMW:clk
cc: Mr. R. L. White, Attn: Don Gallaher
B-192
-------
William M. Nolan
Manager
Environmental Control Division
M' \ Marathon Findlay, Ohio 45840
\ A-f J?tl10n Telephone 419/422-2121
)Oil Company
August 10, 1979
Mr. Tom Williams
Control Programs Development Division, MD-15
ENVIRONMENTAL PROTECTION AGENCY
Research Triangle Park, North Carolina 27711
Dear Mr. Williams:
The attached comments are offered on the proposed Guidance
Document for the Group II Control Technique Guidelines for Volatile
Organic Compounds.
Very truly yours,
WMN rs
Attach.
B-193
-------
COMMENTS OF MARATHON OIL COMPANY ON DRAFT GUIDANCE DOCUMENT FOR THE
GROUP II CONTROL TECHNIQUE GUIDELINES FOR VOLATILE ORGANIC COMPOUNDS
Section XX.9730 (b)(1)
It is suggested that routine inspections once per month are too frequent
and that an equally effective alternative would be twice a year, say just
prior to and after the winter season.
Section XX.9730 (d)
Annual filing of the detailed inspection reports and operational records
would be highly impractical. The operational records would be especially
voluminous and since these records will be available to the director, as he
deems necessary, it does not seem prudent for all operators to make annual
filings of thi-s material.
Section XX.9730 (e)
It is recommended that the retention time for records be no longer than three
years. The current operating record retention requirement of the DOT for
Marathon Pipe Line Company is three years.
Section XX.9740 (a)
The suggested compliance schedule is not realistic. Individual state require-
ments will not be completely known until January, 1980. In order to submit
final plans, all engineering will have to be finalized, material and con-
tractors quotations obtained, and a complete schedule of construction completed
by March 15, 1980. The task required would involve review of each individual
tank to insure proper installation and fit of the secondary seal. The efforts
B-194
-------
of the various Marathon operating divisions, the seal manufacturers, and con-
tractors to evaluate the work will take much longer than the proposed eleven
weeks. The time required will be in excess of six months. The situation for
the manufacturers and contractors would be further complicated by the volume
of quotation requests they will be receiving from all operators of VOC storage
tank facilities. Associated delays in normal quotation response, delivery
schedules, and installation schedules make estimating the complete construction
schedule difficult at this time.
Section XX.9740 (b)
The provision for submitting an alternate compliance schedule by March 15, 1980
is restrictive for the same reasons described in the discussion of
Section XX.9740 (a). A minimum of six months should be allowed for preparation
and the transmission of an alternate compliance schedule.
Section XX.8040 (a)
Provision for immediate notification of the Director of a breakdown or mal-
function of more than one hour duration of any control equipment is unduly
restrictive in the case of a products distribution terminal vapor recovery
facility. It is suggested that the breakdown or malfunction of terminal
vapor recovery capability exceeding 24 hours duration is more appropriate for
notification purposes. Minor malfunctions that are repairable in the same day
do not justify notification.
B-195
-------
Section XX.8070
Monitoring devices to be considered should be practical and readily available
for the process being monitored. The monitoring device performance specifi-
cation of Appendix B of 40 CFR 60, Standards of Performance For New Stationary
Sources, is suggested as a desirable means of monitoring instrument specifica-
tion.
WMNolan
8/10/79
B-196
-------
CERTIFIES
THE MOST IN DRY CLEANING
DAN LANDON ENTERPRISES
Dan Landon, President
2415E. Ashlan
Fresno, California 93726
Telephone (209) 224-2996
July 25, 1979
DON DOERKSEN
Vice President
2025 Alta Vista
Bakersfield, California
(805) 325-5562
Mr. Thomas Williams-Program Analyst
Control Program Development Division
Research Triangle Park, North Carolina 27711
OTHER LOCATIONS
2513 So H Street
in Benton Park
2221 Brundage Lane
in Brundage Square
5630 Stockdale Highway
in Stockdale Village
2232 Miles Street
Corner of Ash Street
3801 Auburn Street
Corner of Oswald
1601 McDonald Way
Just off Ming
2507 N Chester Ave
at China Grade Loop
Ref:
Dear Sir:
Section 9800 Perchlorethylene Dry
Cleaning Systems.
Dry-cleaning plants in the United States using
perchlorethylene cleaning solvent number 18,000 plus
in the country. Of these many plants over 50% employ
five people or less and their sales average is above
$70,000.00. Most of these stores are owner-operated,
with the owner making a job for himself. They possess
limited capital, operate equipment of well over ten
years of age, they lease limited space, much of it
in high rent shopping centers, and are quite competitive.
We recommend exemption from the regulations of
locations where solvent consumption is under 100
gallons per month on a twelve month running average,
this, in addition to the exemptions already provided
for Coin-op Cleaners and provisional exemptions
because of space limitation and steam generating
capacity.
Very truly yours,
Dan Landon Enterprises, Inc.
Granny'* Wash
2234 Miles Street
3805 Auburn Street
1601 McDonald Way
2505 N Chester Ave..
„ r /
-*-c
. Dan Landon ^
DL/lr
cc: Mr.. William Roddy
Mr. William Fisher, Director Research Department
B-199
-------
One HOUR
II
certifies
THE MOST IN DRY CLEANING
779 E. OLIVE
FRESNO, CA 93728
486-0531
1320 VV. SHIELDS
FRESNO, CA 93705
224-7897
1320 W. SHIELDS
FRESNO. CA 93705
224-7897
4005 E. ASHLAN
FRESNO, CA 93726
224-7575
J.M.S. ENTERPRISES INCORPORATED
STEPHEN E.BERGLUND
July 20, 1979
Mr. Thomas Williams-Program Analyst
Control Program Development Division
Research Triangle Pcirk, North Carolina
27711
Ref: Section 9800 Perchlorethylene Dry Cleaning
Systems.
Dear Sir:
Dry-cleaning plants in the United States using
perchlorethylene cleaning solvent number 18,000 plus in
the country. Of these many plants over 50% employ five
people or less and their sales average is above $70,000.00.
Most of these stores are owner-operated, with the owner
making a job for himself. They possess limited capital,
operate equipment of well over ten years of age, they lease
limited space, much of it in high rent shopping centers, and
are quite competitive.
We recommend exemption from the regulations of locations
where solvent consumption is under 100 gallons per month on
a twelve month running average, this, in addition to the
exemptions already provided for Coin-op Cleaners and
provisional exemptions because of space limitation and steam
generating.capacity.
Very truly yours,
J.M.S. Enterprises, Inc.
SEB/pts-5
Stephen E. Berglund
cc: Mr. William Roddy
Mr. William Fisher, Director Research Department
Mr. Dan Landon, District Director
B-200
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JAMES R. PATTON, JR
GEORGE BLOW
CHARLES OWEN VERRILL.JR
JOSEPH L. BRAND
THOMAS HALE BOGGS,JR.
TIMOTHY J. MAY
HARRY A. IN MAN
EDWARD T. MITCHELL
ELLIOT H. COLE
J. GORDON ARBUCKLE
WILLIAM C FOSTER
DAVID C. TODD
LAWRENCE G. MEYER
RICHARD A. EARLE
ERNEST S. CHRISTIAN, JR
ROBERT H KOEHLER
E. BRUCE BUTLER
DAVID B. ROBINSON
JOHN H. VOGEL
ALLAN ABBOT TUTTLE
BART S. FISHER
JAMES GRANT O'HARA
JOHN L.OBERDORFER
LINDA ELIZABETH BUCK
LANNY J DAVIS
PATTON, BOGGS & BLOW
255O M STREET, N. W.
WASHINGTON, D. C. 2OO37
(2O2) 457-6OOO
ATTORNEY'S DIRECT DIAL
202-457-6074
July 19, 1979
OF COUNSEL
WILLIAM J. COLLEY
FRANK BOAS
LONDON BRUSSELS
DONALD A. LOFTY
DOMENICO DE SOLE
SHAOUL ASLAN
JOHN V. E. HARDY, JR
TIMOTHY A. VANDERVER, J R
CHARLES B. TEMKIN
NANCY W. NEWKIRK
JOHN F. WOODS
MIDDLETON A MARTIN
RICHARD S CHARIN
GARRET G RASMUSSFN
JAMES B. CHRISTIAN, JR
JANET M MEIBURGER
TIMOTHY A.CHORBA
JEANNE C. TRAHAN
DAVID E. DUNN
RICHARD J. CONWAY
STEVEN M. SCHNEEBAUM
LEE M. GOODWIN
GREGORY K PILKINGTON
MATTHEW J. ABRAMS
DON A. ALLEN
DUANE A. SILER
GARY L. STANLEY
CABLE. BARPAT
ITT TELEX 44O324
WU TELEX 89-452
TELECOPIER 457-6315
Mr. Tom Williams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, NC 27711
Dear Mr. Williams:
This letter sets forth the comments of the drycleaning
industry on a draft "Guidance Document for the Group II Control
Technique Guidelines for Volatile Organic Compounds" (hereinafter
referred to as the "Guidance Document"). Those parts of this
draft document which were forwarded to us include sample regulations
applying specifically to percloroethylene ("perc") drycleaning
establishments and more general regulations which are also appli-
cable to perc drycleaners.
These comments are submitted on behalf of the International
Fabricare Institute (IFI), the Institute of Industrial Launderers
(IIL), and the National Automatic Laundry and Cleaning Council
(NAijCC) . These three trade associations represent a broad spectrum
of the drycleaning industry. IFI represents commercial drycleaners
which are typically very small businesses. IIL represents businesses
which perform laundry services for other businesses; these launderers
normally have only small drycleaning units. NALCC represents coin-
operated laundries and cleaners.
Although this draft Guidance Document is acceptable in most
respects, it is subject to several weaknesses which should be cor-
rected before a final Guidance Document is issued. The most serious
objection to these sample regulations arises from a failure to take
account of the very small size of most drycleaning establishments.
Two problems result from this: the sample regulations would esta-
blish requirements which cannot reasonably be imposed on small
businesses such as the average drycleaner; and the sample regulations
fail to set forth a regulatory scheme which is sufficiently under-
standable for purposes of compliance and enforcement. Other problems
B-201
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PATTON, BOGGS & BLOW July 19, 1979
Mr. Tom Williams
Control Programs Development Division
Page Two
concern some of the testing requirements, the compliance schedules
proposed for perc drycleaners, and the general disposal requirements.
All these problems areas are discussed below.
Drycleaners are the prototype small business. When the
average American thinks of drycleaners, he undoubtedly thinks of
the neighborhood drycleaning establishment which is run by its
owner with the assistance of one or two employees. Statistics that
we have previously provided EPA shows that this perception is largely
correct. For example, the average gross annual receipts of all com-
mercial drycleaning plants is only $71,000 and the average net profit
(before taxes) is $4600 per year. Further, drycleaners are usually
not able to obtain the most skilled and highly competent employees
due to the low wages which they have to pay. Finally, it should be
obvious that such small, low-profit businesses will be quite limited
in the financial burden that they can undertake in order to comply
with any regulations that are eventually promulgated. Thus, dry-
cleaning establishments are far different from many of the plants
that would be regulated pursuant to the Guidance Document and we
believe that these differences should be taken into account in
developing this document.
We are of the opinion that most, if not all, drycleaning
establishments want to comply with all applicable laws, including
those designed to protect the environment. If this is to be done,
however, the regulatory burden on drycleaners must be reasonable--
one which can be met with a reasonable good faith effort and without
unreasonable expenditures of money and time. Further, the regula-
tory requirements must be readily understandable. In such a small
business-type setting, the average owner of a drycleaning establish-
ment will not be able to determine what is necessary to comply if
he must constantly cross reference several documents pertaining to
applicable regulatory requirements. By the same token, enforcement
will prove difficult in such circumstances.
We believe that EPA's Control Techniques Guidance document
on perc drycleaners (EPA 450/2-78-050; OAQPS No. 1,2-177) met this
test of regulatory reasonableness. After a great deal of effort in
developing it by all concerned, the final CTG set forth a regulatory
system which was reasonable, practical and workable. The sample
regulation in the CTG will encourage a significant reduction in VOC
emissions while being of such a nature that trade associations like
IFI, IIL, and NALCC can assist in assuring compliance with it. Indee
in view of the foregoing, we are somewhat puzzled as to the rationale
for revising the CTG sample regulation as is done in the Guidance
Document.
B-202
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PATTON, BOGGS & BLOW July 19, 1979
Mr. Tom Williams
Control Programs Development Division
Page Three
The Guidance Document does not adequately meet the test
of regulatory reasonableness. In one instance, however, it does
show a careful consideration of reasonableness and we would like to
commend the draftsmen on this. Section XX.9820(b) excludes coin-op
drycleaners from the regulation on account of their small percentage
of emissions and their inability to install control equipment. This
exclusion properly takes account of regulatory reasonableness and
recognizes the limits of what is possible.
Unfortunately, the Guidance Document does not do this in
every instance and several examples of this lack of regulatory rea-
sonableness are set forth below. We request that the provisions
described below be modified in order to make the burdens imposed
on those who are to be regulated more reasonable.
--Section XX.9830(c) permits the grant of a variance from
the dryer exhaust control requirements if the owner is able to
demonstrate technological infeasibility. It is unreasonable to
expect the owner of a drycleaning establishment which might be
eligible for such a variance to prepare a meaningful variance peti-
tion since the drycleaners who would be eligible are in the worst
financial and operating position and are least able to prepare or
afford to have prepared such a petition. Instead of the variance
procedure in paragraph (c), there should be a regulatory exclusion,
with discretion in the state Director to exclude other establishments
in appropriate circumstances. The CTG sets forth such an exemption
in Part 1.3, Regulatory Approach. We recommend that the relevant
language of the CTG be substituted for present section XX.9830(c):
"Subparagraphs (a)(1) and (a)(2) are not applicable
to plants where dryer exhaust controls cannot be
accommodated because of inadequate space or to plants
where insufficient steam capacity is available to
desorb absorbers. The Director may exclude other
plants from the scope of subparagraphs (a)(1) and
(a)(2) if it is demonstrated that other hardships
justify such an exclusion."
—Section XX.8030 of the general regulations requires the
owner or operator of a facility to make available an Inspection
and Maintenance Manual for all control equipment, to keep a written
record of all maintenance or repair work performed on the control
equipment, and to submit an Operations Manual to the Director.
Virtually no drycleaning establishment in the United States has
such manuals or keeps such records at present, and it is not
B-203
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PATTON, BOGGS & BLOW July 19, 1979
Mr. Tom Williams
Control Programs Development Division
Page Four
reasonable to expect such small businesses to develop meaningful
manuals or maintain meaningful maintenance records of the type
contemplated. Although such requirements may be reasonable for
the comparatively large plant which is the typical subject of air
pollution control regulations, such requirements simply cannot be
complied with by the average drycleaning establishment, which is
principally concerned with keeping its head above water financially.
Accordingly, we recommend that Section XX.8030 be modified so that
these provisions will not be applicable to drycleaning establishments
—Section XX.8040 establishes certain requirements with
respect to breakdowns and malfunctions, operation changes, and the
keeping of records. Application of this section to the average
drycleaner is not justifiable for the reasons discussed in connec-
tion with Section XX.8030, above, and this section should be modifiec
to exclude drycleaners from the scope of its applicability.
—Section XX.8070 would impose certain monitoring, record-
keeping, and reporting obligations on—drycleaning establishments.
For the same reasons discussed with respect to Section XX.8030,
above, this is an unreasonable requirement to place on drycleaning
establishments. Therefore, it should be modified to exclude dry-
cleaners from the scope of its applicability.
In addition, some parts of the draft sample regulations
are not sufficiently understandable to insure ready compliance and
enforcement. For example, Section XX.9850(c) sets forth certain
test procedures by reference to the CTG and to an American National
Standards Institute paper. Instead, the regulations should speci-
fically set forth the applicable test procedures in detail. For
example, the sample regulations should specify where an operator or
enforcement officer is to inspect for liquid leakage, as is done
in Section 4(a) of part 1.3 of the CTG. This subsection should be
incorporated into the sample regulations. Similarly, the methods
of testing for perc concentrations in carbon adsorber exhausts and
in the vicinity of gaseous leaks should be specifically set forth
when such test procedures are made applicable. Finally, the ANSI
paper described in subparagraph (c)(3) should be attached to the
regulations instead of being incorporated by reference. We believe
that these changes, while having no substantive impact on the sample
regulations, would make it easier for an owner or operator to comply
with them arid would also make enforcement easier. Since ease of
compliance and enforcement are of critical importance, we strongly
recommend that Section XX.9850(c) be modified in the manner
discussed above.
B-204
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PATTON, BOGGS & BLOW
July 19, 1979
Mr. Tom Williams
Control Programs Development Division
Page Five
A second problem involves the testing requirements set
forth in the sample regulations. The CTG stated that there was
no testing device available for monitoring perc concentrations in
carbon adsorber exhausts or near gaseous leaks, and we are un-
aware of the development of any such devices since the publica-
tion of the CTG. As a result, we recommend that the provisions
of Section XX.9850(c) which are relevant to such testing be
left blank with a footnote indicating that the test procedures
will be supplied when appropriate testing devices are developed
by EPA. To do otherwise would be misleading since that would
imply an ability to test which simply does not exist. In order
to avoid such a result, the sample regulation should be revised
to eliminate the present applicability of testing requirements
where no testing devices exist.
Section XX.9850(d) is subject to the same problem and
should be revised so that its continuous monitoring require-
ments are inapplicable until required monitoring devices are
available. Further, continuous monitoring requirements should
not be imposed on drycleaners at all unless an inexpensive
continuous monitoring device is developed. If such an inexpen-
sive device is not available, continuous monitoring would not
be reasonable for drycleaners.
A third problem concerns the compliance schedules set
forth in Section XX.9840. As the CTG and the Comments to the
sample regulations recognize, it may not be possible to achieve
the time deadlines set forth in subparagraphs (a)(1)(iv) and
(v) because of an inability to obtain the necessary control
equipment. Despite this, the sample regulations, as now worded,
would require compliance even though compliance might be im-
possible. In order to avoid placing those who want to comply
in such a position, we believe that this inability to obtain
necessary control equipment should be specifically recognized
in the body of the sample regulations. This could be accom-
plished by adding a new subparagraph (a)(1)(vi) which would
state that compliance with subparagraphs (a)(1)(iv) and (v)
would not be required if the owner or operator has made a good
faith effort to obtain the necessary equipment but has been
unable to do so throught no fault of his own.
A fourth problem concerns the requirements for disposal
of volatile organic compounds set forth in Section XX.8020 of
the regulations. Subsection (a) of this section would prohibit
the disposal of volatile organic compounds in a manner that
would permit their evaporation into the atmosphere. We are not
aware of any authority in the Clean Air Act pertaining to disposal
B-205
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PATTON. BOGGS <£ BLOW
July 19, 1979
Mr. Tom Williams
Control Programs Development Division
Page Six
practices. There are obviously such requirements in the Resource
Conservation and Recovery Act, but there are also substantial
questions as to the propriety of an EPA "recommendation" that
such requirements be included in State Implementation Plans man-
dated by the Clean Air Act. Further, the cost of implementing
this requirement may be considerable and it does not appear that
questions involving such costs have been adequately studied. As
a consequence, we urge the deletion of Section XX.8020 or an
exemption from its provisions for drycleaners.
We hope the foregoing comments are useful to EPA in
its consideration of these draft sample regulations and urge
that the final sample regulations be modified in accordance with
the foregoing. We request a meeting with you at your earliest
convenience in order to discuss the issues raised by EPA's pro-
posal to issue these sample regulations and by our comments
thereon.
Sincerely,
TAV/mw
T. A. Vanderver, Jr
cc:
Mr
Mr
Bill Fisher, IF I
Bud Sluizer, IIL
Mr. Ward Gill, NALCC
B-206
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On« HOUR
"i
"mmininne:
THt V O b 1 IN UHv CIFANING
ENTERPRISES INCORPORATED
AM
FRED P.JONES
President
TEDDY BEAR
COIN-OP LAUNDRIES
July if;, 1979
Mr. Thomas Wil1iams-Program Analyst
Control Program Development Division
Research Triangle Park , N, C. 27711
°eft Section 9900 Perchlorethylene Dry Cleaning Systems.
Dear Sir:
Rptail dry-cleaning plants using perchlorethylenc cleaning
solvent number 18,000 plus in the country. Of these over 50%
employ 5 people or less and have gross incomes averaging around
$70,000.00. The Bulk of these stores are owner-operated, in
effect the owner making a job for himself. They possess limited
capital, operate equipment of well over 10 years of age, lease
limited space, much of it in high rent shopping centers, and
ore. highly competitive. Steam generating capacity of these stores
is that required to operate drying and pressing equipment only.
We recommend exemption from the requlations of locations
where solvent consumption is under 100 gallons per month on a
12 month running average. This in addition to exemptionsalready
provided for Coin-op Cleaners and provisional exemptions because
of 'space limitation and steam generating capacity.
Very truly vcurs,
TEAM Enterprises, Inc.
F, P. /ones. President
cc Mr. Wm. Seddy
Fresno County Air Polution Control District
12i»6 L Street fresno, Calif. 93701
Mr. Vra Fisher director research Pppt.
International Fa brie-re Institute
12251 Tottv -r':cad Silver Springs Md. 2090*4
Mr. Dan ' sndot.-L'istrict Director
Cilifjtnia fai>i icare Institute
2'-il5 :.. 'U.hi^n,; ! resno, Ca'it. 93726
B-207
— 750 N.VALENTINE AVE. • FRESNO, CALIF. 93706 • TELEPHONE (209) 264-7488
-------
July 16, 1979
If the inspector is unable to witness the test, the test is allowed to continue. This
procedure has proven to be totally acceptable to both the State inspectors and the truck
owners.
We appreciate the chance to make these comments and hope that you win contact us if there
are any questions.
Very truly yours,
C. B.
B-212
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Chevron
Chevron U.S.A. Inc.
575 Market Street, San Fiancisco, CA 94105
Mail Address P 0 Bex 7643, San Francisco, CA 94120
C. B. Zachary July l6, 1979
Manaijer, Transportation
Marketing Deoartment
Mr. Tom Williams
Control Programs Development Division
MD-15
Environmental Protection Agency
Research Triangle Park, NC 27711
Dear Mr. Williams:
Thank you for the opportunity to comment on the proposed EPA guidance document XX.9900
"Leaks from Gasoline Tank Trucks and Vapor Collection Systems."
Basically, we are in agreement with the proposed document. It appears to be a reason-
able approach to the problem of obtaining uniform vapor recovery regulations. There are,
however, a few areas that we would like to make specific comments on.
The test outlined in Section XX.9930(b)(l)(ii) is not a quantitative test. While the
proposed test may be the only one suitable for checking leaks at piping fittings, the
majority of the leaks are in the dome area. The Western Oil and Gas Association, in
conjunction with the South Coast Air Quality Management District (SCAQMD) in the Los
Angeles area, is developing a quantitative test done with pressure at the truck loading
rack. The San Diego County Bag Test (refer to Sections 3.1.U and 3.2.8 of EPA document
^50/3-79-018, April 1979) is a quantitative test for bottom loaded trucks. We feel that
both these quantitative tests are superior, where applicable, to the use of a combustible
gas detector.
Section XX.9930(b)(l)(iii) should contain a provision to define "excessive liquid drainage"
at the termination (disconnect) of a loading operation. Rule U62, Section (a)(6) of the
South Coast AQMD contains a very realistic approach to this problem of drops of liquid
trapped between two halves of a dry break fitting or drops of liquid from a top loading
stem. Rule ^62 permits a specified small quantity of liquid to be lost in the two sit-
uations outlined above.
Our final comment pertains to Section XX,9950(b). We feel that the requirement for a 30
day written notice prior to testing a truck is completely impractical. Also, the provision
for the test to be cancelled at the discretion of the Director will completely disrupt
maintenance and dispatching schedules. This written requirement will generate a tremendous
amount of unnecessary paperwork. Tank truck tests are normally scheduled not more than
one week in advance. This schedule is based on truck condition, parts availability and
available maintenance personnel. Once a truck is scheduled for a test, causing a delay
will be quite expensive for the truck owner.
The California Air resources Board certification program (which is administered by the
California State Fire Marshal's office) simply requires verbal notification "prior to
testing." In actual practice, the notification is given 2U to kQ hours prior to the test.
B-211
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NATIONAL TANK TRUCK CARRIERS. INC
1616 P STREI- 7 N Vv WASHINGTON, D C 2OO36
AREA CODE 202797-5425
27 July 1979
Mr. Tom Williams
Project Officer
Control Programs Development Div.
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
Dear Mr. Williams:
The following are comments of NTTC, the national trade Association
for the for-hire tank truck industry, on state guidelines for rules
for vapor recovery and leak testing.
We doubt that these rules will have any great affect on air quality
because the hydrocarbon emissions from tank truck "leaks" are very
small when compared with other sources of air pollution. In other
words, carriers (and the public through higher prices for their
products) will be forced to pay for insignificant and temporary
reductions of leakages.
These costs will be high for the following reasons:
1) out of service time for a cargo tank is expensive.
While these tests are being made (and the tank is
being sealed and subsequently retested) a shortage
of transportation capacity for gasoline will be
created. The downstream dislocation, inconvenience
and inefficiencies will create a loss of produc-
tivity far greater than has been contemplated;
2) Present highway vehicles are not built to maintain
leak tightness while in operation. Once the vehicle
is tested and made leak tight, the first pot hole may
open the leak again. Then the tank will not be leak
tight until the next test. It is wasteful to make the
vehicle leak tight for a test when we know in actual
operation that the "tightness" will probably be very
temporary;
3) The costs involved in training enforcement personnel
and the administrative costs will be high when re-
peated in each state.
B-213
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Mr. Tom Williams 27 July 1979
Inspection of the tank truck is now required by the U.S. Depart-
ment of Transportation every two years or whenever the vessel has
had welding done on it. The inspection is "visual" if no hot work
has been done. The "visual" must be supplemented by a hydrostatic
test if the vehicle has been in an accident or if welding has been
performed. The inspection and test procedures are completely des-
cribed by the DOT in 49 CFR 177.824, as well as instructions for
marking the tank indicating compliance with the requirements.
The frequency for testing as described by the EPA in these guide-
lines should coincide with the present DOT requirements and the
test date markings should be modified to correspond with DOT's
rules. NTTC believes that if these regulations are adopted for
use by the states, the time period for testing should correspond
with the Department of Transportation's rules (49 CFR 177.854)
for cargo tanks.
The requirements to notify the Director of Schedules, etc. is
ridiculous. The frequency which the EPA is requesting for testing
is an example of an "over kill" reaction. These regulations are
being suggested before the vehicle hardware exists which can effec-
tively and realistically comply.
Therefore, we think the rules are wasteful, non-productive, infla-
tionary, and offer air improvement that is insignificant. For EPA
to create these guidelines and then encourage (force with threats
of withholding funds) the states to implement them is an example
of regulation at its worst.
Very truly
Albert B./Rosenbaum, III
Assistant Managing Director
B-214
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TRUCK TRAILER MANUFACTURER ASSOCIATION
2430 PENNSYLVANIA AVENUE, N.W. • WASHINGTON, D.C. 20037
CHARLES J. CALVIN
President
Telephone (202) 785-5833
September 6, 1979
Mr. Tom Williams
Project Officer
Control Programs Development Division
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
Dear Mr. Williams:
We would like the appendix to your Guidance Document for the Group n
Control Technique Guidelines for Volatile Organic Compounds to contain the
following comments.
The Truck Trailer Manufacturers Association which includes manufacturers
of gasoline tank trucks and trailers as well as suppliers of manholes, vents, and
vapor recovery equipment feels that the leak tightness criteria offered in the EPA
Guidance Document should not be adopted by the states for the following reasons:
(1) It has not been demonstrated that air quality has been improved in areas
where similar regulations are in effect.
(2) Many useful tank vehicles now providing good service will be obsoleted at
great economic waste because the original design prohibits retrofit.
(3) Sealing up of the normal in-breathing and out-breathing vents on gasoline
cargo tanks creates a condition that may be undesirable. The industry does
not have sufficient experience with equipment operated at these higher pressures.
(4) We estimate that the total cost to retrofit the industry's tank trailer fleet
over the next five years to be in excess of $140 million without taking interest
or finance cost into consideration.
B-215
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Mr. Williams - 2 - September 6, 1979
Attached you will find the data used to develop the population and economic
information used to make our decision.
The TTMA cannot assess what effect gasoline emissions may have on the
nations health. We do not feel EPA has shown that vapor recovery will significantly
affect the total emissions, If, however, future research shows that vapor recovery
in the gasoline marketing system is necessary it should be phased in on newly
manufactured equipment only, without retrofitting existing equipment.
The TTMA Tank Conference feels that the API .recommendation that the leak
tightness requirement be less restrictive has merit and would be more practical
than the 3 inches of water pressure change in 5 minutes recommended by EPA.
It is also felt that the tank integrity pass/fail criteria should be based on the leak
rate test and not on an explosivemeter test.
Sincerely yours,
Donald W. Vierimaa
Director of Engineering
DWV/em
Encl.
B-216
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TTMA VAPOR RECOVERY STUDY
MAY 1979
TANKS NOT SUITABLE FOR RETROFIT:
The current tank trailer fleet consists of many tank trailers built prior to
1967 when the DOT MC specifications received a major revision. This MC
specification revision specifies that the maximum calculated stress value must not
exceed 20 per cent of the minimum ultimate strength of the material. This calculation
considers stresses resulting from dynamic loading, internal pressure, superimposed
loads, reactions of supports, and effect of temperature gradients.
Pre 1967 tank trailers were designed for the state-of-the-art and the requirements
of the industry at the time they were built. The majority of these tank trailers were not
built for bottom loading and vapor recovery. The vents were designed to open whenever
the pressure or vacuum differed from atmospheric pressure.
Bottom loading required for vapor recovery usually involves high loading rates
which require that the tank heads, shell, and fittings be capable of withstanding hydraulic
surge greater than that encountered by top loading.
It would be a mistake to retrofit tank trailers for bottom loading and vapor
recovery if they have not been designed for this modification. Further tanks in use for
many years may have a lowered fatigue endurance and are therefore a poor risk to
retrofit for vapor recovery and resulting operation above and below atmospheric pressure.
We therefore recommend that tanks not in compliance with MC 306 or MC 307
cargo tank specifications not be retrofitted for vapor recovery.
TANK CATEGORIES:
The work required of retrofitting tank trailers depends upon their configuration.
The TTMA estimate of the cost of retrofitting tank trailers for vapor recovery is based
on the following four categories of tank trailer configurations.
CATEGORY CONFIGURATION
A. MC 306 tanks already equipped for vapor recovery and bottom loading
but without leak tightness integrity.
B. MC 306 tanks set up for conversion to vapor recovery but with bottom
loading capability.
C. MC 306 tanks with no provision for vapor recovery but equipped for
bottom loading.
D. MC 306 tanks with no provision for bottom loading or vapor recovery.
B-217
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TTMA Vapor Recovery May 1979
Study -
For the purpose of these estimates, it is assumed that the average tank has
four compartments.
An estimate of the vapor recovery retrofit cost per trailer and for the total
estimated population follows:
CATEGORY RETROFIT COST/TANK
A. $ 616
B. $ 1,712
C. $ 2,456
D. $ 6,590
The work required to convert all types of trailers is itemized in Appendix II.
Items are then selected for each specification category. The cost for each modification
is shown in the right hand column. Total cost of conversion for any category can be
determined by adding the appropriate items of cost. See Appendix III.
Costs were calculated based on retail prices for material components and a
labor rate of $22. 50. Eight per cent Federal Excise Tax on parts and four per cent
state sales tax. The detail of the cost build-up for each item is shown in Appendix IV.
POPULATION:
TTMA estimates that there are about 80,000 liquid tank trailers in service
(Appendix I). It is further estimated that 54% of the liquid tank trailers were produced
for flammable commodity service as MC 306, MC 305, or MC 303 cargo tanks.
It is conservatively estimated that 80% of the MC 306, 305, and 303 tank trailers
are in regular or occasional gasoline service and would need to be retrofitted. The
population of these gasoline tank trailers is 80,000 x . 54 x . 80 = 34,560.
It is estimated that of the 34,560 gasoline tank trailers in service, 30% or
10,368 tank trailers are pre-MC 306 tanks and should not be retrofitted.
B-218
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TTMA Vapor Recovery
Study - May 1979
It follows that there are about 24, 192 tank trailers that can be retrofitted for
vapor recovery. TTMA has developed four categories of tank trailers which may be
retrofitted for vapor recovery. An estimate of the population of each category is
shown below:
A. MC 306 tanks equipped for vapor 20% of 24,192 = 4, 838
recovery and bottom loading but
without leak tightness integrity.
B. MC 306 tanks equipped for conversion 25% of 24,192 = 6,048
to vapor recovery and equipped for
bottom loading.
C. MC 306 tanks with no provision for 25% of 24,192 = 6, 048
vapor recovery but equipped with
bottom loading.
D. MC 306 tanks with no provision for 30% of 24,192 = 7,258
vapor recovery or bottom loading.
It is estimated that 2,450 MC 306 tank trailers per year would normally be
produced from 1980 through 1984. Retirement of the 10,368 gasoline tank trailers
which do not qualify for retrofit for vapor recovery would increase the MC 306 tank
trailer demand by an estimated 1,000 tank trailers per year. Of the 2,450 MC 306
tank trailers normally produced, 80% or 1,960 of these tank trailers would be in
gasoline service. The expected MC 306 gasoline service tank trailer production
expected per year over the five year period from 1980 through 1984 would be
1,960 + 1,000 = 2,960. The production over the five year period would be 14, 800
MC 306 gasoline service tank trailers.
Of the total of 14, 800 MC 306 tank trailers for gasoline service produced from
1980 through 1984, 70% (10,360) would normally be equipped with bottom loading, and
30% (4,440) would normally be equipped without bottom loading. Some of these tank
trailers are presently equipped for vapor recovery due to existing state regulations
requiring the control of hydrocarbons. The remaining tank trailers not normally
equipped for vapor recovery, would have to be equipped with vapor recovery and
30% would in addition require bottom loading.
B-219
-------
TTMA Vapor Recovery
Study - May 1979
COST TO RETROFIT:
A
B
C
D
$ 616
$ 1,712
$ 2,456
$ 6,590
4,838
6,048
6,048
7,258
An estimate of the vapor recovery retrofit cost per trailer and for the
total estimated population follows:
RETROFIT COST/
CATEGORY RETROFIT COST /TANK X POPULATION = CATEGORY
$ 12,980,208
$ 10,354,176
$ 14,853,888
$ 47.830,220
Total 24,192 $ 86,018,492
ADDITIONAL COSTS:
New Tanks Normally Not Set Up for Vapor Recovery;
The cost of adding vapor recovery to new gasoline tank trailers which would
not be equipped for vapor recovery if not for the EPA regulations requiring the control
of hydrocarbon and benzene emissions is estimated at 10,360 tank trailers over the
five year period, at $2,000 each, the cost of adding vapor recovery at the time of
manufacture = $20,720,000.
New Tank Normally Not Bottom Loaded;
The cost of adding both vapor recovery and bottom loading to new gasoline tank
trailers which would not be equipped with either if not for the EPA regulation is 4,440
tank trailers x $4,500 at the time of manufacture = $19,980,000.
Early Retirement:
Of the 10,368 gasoline tank trailers which should not be retrofitted for vapor
recovery, it is estimated that about half of these tank trailers would be retired by 1984.
The cost of the early retirement of the remaining 5000 tank trailers is estimated at
15% of their original cost of $20, 000. The cost of the early retirement of these tank
trailers is then 5,000 x .15 x $20,000 = $15,000,000.
B-220
-------
TTMA Vapor Recovery
Study -
May 1979
TOTAL COST:
Retrofit
New Tank Extra for Vapor
Recovery
$ 86,018,492
20,720,000
New Tank Bottom Loaded to
Collect Vapors
19,980,000
Early Retirement
Total.
15,000,000
$ 141,718,492
B-221
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APPENDIX I
LIQUID TANK TRAILER POPULATION:
It is a guess estimate that there are about 80,000 liquid tank trailers presently
in service. It is estimated that MC 306 tanks make up approximately 54% of all
liquid tanks manufactured. (1)
While a van trailer has a life expectancy of about 10 to 12 years, steel tank
trailers are utilized for a longer time. A survey by Modern Bulk Transporter
magazine (2) has shown that about 16% of the tank trailers in service are more
than 20 years old. Based on a couple of surveys performed by Modern Bulk
Transporter magazine of its readership (2), (3), whose accuracy may be questioned.
and assuming a steel tank trailer may be sold by the original owner to a second
owner for use in some service for another five years, it will be arbitrarily determined
that the average steel tank trailer life is 17 years.
Arthur D. Little made a survey of aluminum MC 306 cargo tank trailer owners
in 1976 and found that the first owner uses the tank for five to seven years followed
by a second owner's usage of an additional five to seven years. They estimated
that the aluminum MC 306 tank trailer lifetime is 12. 3 years including all owners.
The number of MC 306 or its predecessor tank trailers produced between 1965
and 1976 (12 years) is 36,911. The number of non-MC 306 type tank trailers produced
between 1960 and 1976 (17 years) is 44,548. The total liquid tank trailers consisting
of 12 years of MC 306 tanks and 17 years of non-MC 306 tanks is 81,459. If the
average life of all liquid tank trailers is 12 years, then the number of liquid tank
trailers produced between 1965 amd 1976 is 69^879.
v
According to the 1972 Department of Commerce survey (1) there were 909,000
combination vehicles in service in 1972. Of these combination vehicles, 8. 5%,
77,265 were liquid tank vehicles. This same survey in another form shows that
26.7% of the 287,000 liquid tank vehicles, namely 76,629 liquid tank vehicles have a
liquid capacity of 4, 000 gallons or greater.
According to the Department of Transportation (6) in 1975 there were
2,699,444 semi and full trailers registered by the states. Due to many of these
trailers being registered in more than one state, TTMA estimates that there are
really about 1,700,000 semi and full trailers. The Department of Commerce Census
data (1) indicates that the number of tank trailers to all trailers produced during the
years 1965 to 1976 (12 years) is .043. The number of tank trailers in service may
be estimated by taking a 4. 3% of 1,700,000 trailers to obtain 73,100 liquid tank trailers.
B-222
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APPENDIX I (continued) Page 2
The National Tank Truck Carriers (a conference of the American Trucking
Associations) estimates that there are about 30,000 for-hire tank trailers and
about 40,000 private carrier tank trailers. This estimate does not include intrastate,
milk cooperative, and exempt carrier tank trailers. The National Tank Truck
Carriers estimates the total of tank trailers to be approximately 80,000 to 100,000
Arthur D. Little (4) estimated on the basis of gasoline demand from refinery to
storage to service station, hours of terminal operations, and one spare tank trailer
for every 20 tank trailers required to meet gasoline demand that the 1978 gasoline
tank trailer fleet consists of 24,760 trailers. They (5) also estimate that about 90%
of the aluminum MC 306 cargo tank trailers are used to carry gasoline. Department
of Commerce (6) data for the years 1965 to 1971 indicates that over 70% of the MC 306
type cargo tank trailers were made of aluminum.
B-223
-------
Appendix I (continued)
We shall calculate from the Arthur D. Little data the total number of
liquid tank trailers:
Let A = number of aluminum MC 306 tank trailers.
B = number of steel MC 306 tank trailers.
T = total number of liquid tank trailers.
According to Arthur D. Little,
24,760 = .9A + xB
It is believed that some steel MC 306 tank trailers may see gasoline service but
this number is small. We shall assume that x = 0.
Then, 24,760 = .9A and A = 27,511
According to Department of Commerce data,
A = .7 (A+B) = 27.511/.7 = 39,301
We have earlier estimated that
A +B = . 54T, that is, 54% of the liquid tank trailers are MC 306 tank trailers.
Then
T = 39.301/.54 = 72,780
Using the Arthur D. Little data on the number of gasoline tank trailers we
estimate that the total population of liquid tank trailers is 72,780.
The COMMERCIAL CAR, JOURNAL (7) in their June 1978 issue estimates that
the population of liquid tank trailers is 131,920 based on annual production figures
from the Bureau of the Census less scrappage.
The following is a compilation of the liquid tank trailer population based on the
various methods of estimation discussed.
B-224
-------
Appendix I (continued)
LIQUID TANK TRAILER PRODUCTION
Number of Liquid
Tank Trailers Source of Data
81,459 Dept. of Commerce trailer production data, 12 year MC 306 life,
17 year non-MC 306 life.
69, 879 Dept. of Commerce trailer production data, 12 year life for
all liquid tank trailers.
77,265 Dept. of Commerce 1972 Survey
73,100 Dept. of Transportation state registration trailer population
modified by TTMA and Dept. of Commerce ratio of tank to all
trailers.
80,000 to National Tank Truck Carriers estimate based on member survey.
100,000
72,780 Arthur D. Little estimate based on gasoline demand rr ' Dept.
of Commerce ratio of aluminum to all MC 306 type cat.'go tanks
and ratio of MC 306 to all liquid cargo tank trailers.
131,920 Commercial Car Journal estimate
85,200 Average
The Environmental Protection Agency has contracted with Pacific Environmental Services, Inc., to
perform a survey of all types of tank trucks and determine the population, age, and size of each type It is
also understood that the Department of Transportation is considering the required reporting of the number of
tank vehicles in service carrying hazardous materials in order that they may determine the impact of their
regulations,
REFERENCES
1 "1972 Census of Transportation, Truck Inventory and Use Survey", Department of Commerce,
October 1973, Tables 2, 8, and 9.
2 "1976 1977 Tank Trucking Industry Market Report" by Modern Bulk Transporter Magazine
Editorial Staff.
3 "1974-1975 Tank Truck Market Report" by Modem Bulk Transporter magazine editorial staff.
4 "The Economic Impact of Vapor Control on the Bulk Storage Industry", draft report by
Richard J. McCarthy, Arthur D. Little, July 1978.
5 Telephone communication with Richard J, McCarthy, Arthur D. Little, August 1978,
6 "Trailer and Semitrailer Registration -1975" and "Publicly owned Vehicles - 1975", Department
of Transportation, Federal Highway Administration, HHP 43, Table MV-11 and MV-7, July 1976,
7 Commercial Car Journal, June 1978 issue, Page 138.
B-225
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5/79
APPENDIX II
WORK MODIFICATION SUMMARY
CATEGORY OF WORK
1. Transport tank to shop
2. Steam to gas free and test for
safe access.
3. Modify manhole covers for higher
pressure and check over existing
vapor recovery system
4. Install vapor recovery system on
tank set up for conversion. With
nipples in the flashing rail and
flanges in the tank.
5. Cut nipples into flashing rail and
test for leaks
6. Weld up skip welded rail
7. Add bottom loading system - consists
of dropping manifold, spacing out lines,
installing openable bottom loading
adapters, bra'ue interlock float, switches
and mechanical vents
8. Hydrostatic pressure test
9. Vapor recovery pressure vacuum test
10. Return tank to terminal
TANK TYPE
A B C D
X X X X
X X X X
X X X X
XXX
X X
X X
X
X X
X X X X
X X X X
COST DOLLARS
$ 52.50
62.50
402.27
1,095.59
232.13
347.40
4,135.16
164.06
46.80
52.50
B-226
-------
Appendix III
COST SUMMARY BY VEHICLE CATEGORY
OPERATIONS
CATEGORY A:
1
2
3
9
10
Total
CATEGORY B: Same as "A" Pius
4
COST
$ 52.50
62.50
402.27
46.80
52.50
$ 616.57
1,095.59
616.57
Total $1,712.16
CATEGORY C: Same as "B" plus
5 232.13
6 347.40
8 164.06
Cost of "B" 1,712.16
Total $2,455.75
CATEGORY D: Same as "C" Plus
Bottom loading #7 4,135.16
Cost of "C" 2.455.75
TOTAL $ 6,590.91
5/79
B-227
-------
5/79
APPENDIX IV
COST BREAKDOWN BY CATEGORY OF WORK
COST
CATEGORY 1:
Transport tank to shop 70 MI at 75$ per mile $ 52.50
CATEGORY 2:
Vapor free tank and test for safe working 62.50
conditions avg. $50.00 to $75.00
CATEGORY 3:
Replace vents in Betts covers, fill plates
in Knapp covers
. Knapp Cost $16.50 Retail $33.00
Betts Cost $27.00 Retail $54.00
Average Cost: $ 43.50
Replace manhole covers and fill in
gaskets 9.00
Adjust mechanical vents and check and
replace as needed hoses, clamps and
gaskets - Vent gasket 1.60
Replace hoods on 10% of units $74.00
each - avg. $7.40/comp. 7.40
Subtotal per comp. parts 61.50
Misc. parts, hose clamps, hoses, etc. 2.00
Total parts and components 63.50
8% FET 5.08
Labor/comp. $1.25 hr. x $22.50 28.12
Subtotal 96.70
Total cost 4 x $96.70 386.80
4% Avg. state tax 15.47
Total Cost Category 3 402.27
B-228
-------
Appendix IV (continued)
Page 2
CATEGORY 4:
Add hoods,connect and add down line
Credit $7.40 for hoods replaced in
category 3
Hood - each
Hoses - each
Total Material/Compartment
Total
20' aluminum tube $3.50/ft.
Bkt. and misc. parts
4" male adapter and dust cap
4 al. elbows and 1 tee
Vacuum vent in flashing rail
Total parts
FET
16 hrs. labor® $22.50
Subtotal
4% state tax
Total Category 4
CATEGORY 5
Cut nipples into flashing rail and
dye check for leaks
Materials - nipples - elbow
FET
8 hrs. labor® $22.50
Subtotal
4% state tax
Total Category 5
CATEGORY 6
Weld up skip welded flashing rail
and test - all labor - welding
difficult because of dirty conditions
16 hrs. labor® $22.50
4% state tax
(7.40)
74.00
4.00
70.60
x 4
282.40
70.00
20.00
47.68
150.00
72.00
642.0.8
51.37
360.00
1,053.45
42.14
40.00
3.20
180.00
223.20
8.93
$ 1,095.59
232.13
360.00
14.40
TOTAL CATEGORY 6
B-229
374.40
-------
Appendix IV (continued) Page 3
CATEGORY 7:
Add bottom loading to tank with 4"
piping and manifold
Worst conversion will be to drop
manifold and go to individual lines
with openable bottom loading adapters
MATERIAL:
4 - B/L openable adapters ea. $278 x 4 $ 1,112.00
4 - 5" mechanical vents, pads and gaskets
$185.50x4 742.00
4 - float switches and pads $110. x 4 440.00
1 - wiring kit junction box, plug, etc. 100.00
Brake interlock valves and tubing 130.00
Pipe bracing and bracket, deflector plates 120.00
Total parts 2,644.00
8% FET 211.52
LABOR:
Drop manifold and spread lines 16 hrs.
Mount valves and brace 8 hrs.
Install deflector plates 8 hrs.
Install vents, hookrup and adjust 16 hrs.
Install float switches and wire 20 hrs.
Install brace interlock 1,597.50
Subtotal 4,453.02
4% state tax 178.12
Total worst condition $4,631.14
If tank blanked for vents, floats
and has individual lines material
saved is $154.00
$2,644.00 - $154.00 2,490.00
FET 199.20
Labor is only 36 hrs. compared to
71 hrs. — 36 hrs. @ $22.50 810.00
Subtotal 3,499.20
4% state tax 139.97
Total 3,639.17
Average cost - assume equal number of each
type $4631.14 + $3639.17
divide by 2 B-230 4,135.16
-------
APPENDIX IV. (continued) Page 4
CATEGORY 8:
Hydrostatic test in accordance with
3 PSI retest procedure $ 157.75
4% state tax 6.31
Total Category 8 $ 164.06
CATEGORY 9:
Perform pressure vacuum test on
V. R. System 45.00
state tax 1.80
Total Catehory 9 46.80
CATEGORY 10:
. Transport tank back to dispatching
terminal - same as number one 52.50
B-231
-------
CENTURY SYSTEMS CORPORATION
P. O BOX 133 / ARKANSAS CITY, KANSAS 67005
TELEPHONE 316/447-3311
TWX 910-740-6740
July 19, 1979
Mr. Tom Williams
Control Programs Development Division, MD-15
Environmental Protection Agency
Research Triangle, North Carolina 27711
SUBJECT: Review of Guidance Document for the Group II Control Technique Guide-
lines for Volatile Organic Compounds
Dear Mr. Williams:
This letter is in response to your request for comments on the referenced subject.
We appreciate the opportunity to express our views from an instrument manufact-
urers standpoint.
Our general comment is that it appears that there is no clearly defined monitoring
methodology for many of the CTG documents. It also appears that there has been
limited applicable field evaluation of the methods described in the commonly re-
ferenced document "Measurement of Volatile Organic Compounds", EPA-450/2-78-041.
Many of the draft guidance documents refer to the continual monitoring and add-on
control equipment including "breakthrough of VOC on a carbon adsorption unit".
We would like to inform you that Century Systems Corporation is involved in the
development of instrumentation designed specifically for the task of monitoring
breakthrough and efficiency of carbon adsorption units. Unfortunately, we were
late in compiling the required documents necessary to comment on a case by case
basis. We hope by this letter, to be placed on the applicable mailing lists
such that we receive draft and other documents necessary to submit timely comments.
Century attempts, where possible, to develop instruments for specific applications.
There are many new applications resulting from recent EPA activities in the field
of control of organic emissions. We must understand the requirements of these new
applications if we are to develop suitable instrumentation. Normally an instrument
developed for an application is more suitable than trying to find applications
for existing equipment.
We appreciate the congenial open door policy that EPA personnel have extended to
us and will try to arrange for closer liaison in the future.
Sincerely,
Robert W, Blihar
Regional Sales Manager
RWB:bs
B-235
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1 REPORT NO.
EPA-450/2-79-004
2.
4. TITLE ANDSUBTITLE
Guidance to State and Local Agencies in Preparing
Regulations to Control Volatile Organic Compounds
from Ten Stationary Source Categories
5. REPORT DATE
September 1979
6. PERFORMING ORGANIZATION CODE
3. RECIPIENT'S ACCESSION-NO.
7. AUTHOR(S)
Stephen V. Capone
Malcolm W. Petroccia
8. PERFORMING ORGANIZATION REPORT NO.
GCA-TR-79-38-G
9. PERFORMING ORGANIZATION NAME AND ADDRESS
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts 01730
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-2607
Work Order 29
12. SPONSORING AGENCY NAME AND ADDRESS
Control Programs Development Division
U.S. Environemntal Protection Agency
S. TYPE OF REPORT AND PERIOD COVERED
Final Report
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT Thig Document provides assistance to state and local air pollution control
agencies in preparing Reasonably Available Control Technology (RACT) regulations for
10 industrial categories covered by the Control Techniques Guidelines (CTG) documents
published between January 1978 arid January 1979. The CTG source categories covered by
this report are as follows: Leaks from Petroleum Refinery Equipment; Surface Coating
of Miscellaneous Metal Parts and Products; Manufacture of Vegetable Oil; Surface
Coating of Flat Wood Paneling; Manufacture of Synthesized Pharmaceutical Products;
Manufacture of Pneumatic Rubber Tires; Graphic Arts - Rotogravure and Flexography;
Petroleum Liquid Storage in External Floating Roof Tanks; Perchloroethylene Dry
Cleaning Systems; and Leaks from Gasoline Tank Trucks and Vapor Collection Systems.
The intent of this report is to provide a rational and factual basis for state and
local agencies to develop industry-specific RACT regulations in their own codes.
A specific sample regulation is written for each CTG industrial category. After
each section within each sample regulation there is a discussion of information perti-
nent to that section. Appendix A contains general provisions which are not based on
the CTG documents but art provided strictly as additional information for regulatory
agencies' consideration. Appendix B contains written comments received on the draft
final report, reprinted in their entirety.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group
Air Pollution Control
Organic Compounds
Guidelines
Regulations
Reasonably Available
Control Technology
Volatile Organic
Compounds
Control Techniques
Guidelines
Emission Limitations
13 DISTRIBUTION STATEMENT
Distribution Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
401
20 SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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