United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
May 1985
Air
Polymeric
Coating Of
Supporting
Substrates--
Background
Information For
Proposed Standards
Draft
EIS
Preliminary Draft
-------
NOTICE
THIS DOCUMENT HAS NOT BEEN FORMALLY RELEASED BY EPA AND SHOULD
NOT NOW BE CONSTRUED TO REPRESENT AGENCY POLICY, IT IS BEING
CIRCULATED FOR COMMENT ON ITS TECHNICAL ACCURACY AND POLICY
IMPLICATIONS,
POLYMERIC COATING OF
SUPPORTING SUBSTRATES--
BACKGROUND INFORMATION
FOR PROPOSED STANDARDS
EMISSION STANDARDS AND ENGINEERING DIVISION
U, S, ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR AND RADIATION
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
MAY 1985
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TABLE OF CONTENTS
List of Figures
List of Tables
CHAPTER 2
2.1
2.2
2.3
2.4
2.5
2.6
2.7
CHAPTER 3
3.1
3.2
3.3
3.4
3.5
CHAPTER 4
4,1
4.2
4.3
4.4
4.5
4.6
INTRODUCTION . . .
Background and Authority for Standards
Selection of Categories of Stationary Sources ....
Procedure for Development of Standards of
Performance
Consideration of Costs
Consideration of Environmental Impacts
Impact on Existing Sources
Revision of Standards of Performance
PROCESSES AND POLLUTANT EMISSIONS
Industry Description
Raw Materials
Processes and Their Emissions
Baseline Emission Level
References for Chapter 3
EMISSION CONTROL TECHNIQUES
Introduction
VOC Emission Capture Systems
VOC Emission Control Systems
VOC Emission Control Systems for Coating Mix
Preparation Equipment and Solvent (S to rage > •• . ••-• - ---• -
Tanks "'.
Low-Solvent Coatings
References for Chapter 4
Page
V
vi
2-1
2-1
2-4
2-6
2-8
2-9
2-10
2-11
3-1
3-2
3-7
3-7
3-19
3-22
4-1
4-1
4-2
4-9
4-31
4-34
4-35
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TABLE OF CONTENTS (continued)
Page
CHAPTER 5 MODIFICATION AND RECONSTRUCTION 5-1
5.1 Provisions for Modification and Reconstruction .... 5-1
5.2 Applicability to Polymeric Coating of Supporting
Substrates 5-3
5.3 References for Chapter 5 5-7
CHAPTER 6 MODEL PLANTS AND REGULATORY ALTERNATIVES 6-1
6.1 Model Plants 6-1
6.2 Regulatory Alternatives • . 6-12
6.3 References for Chapter 6 6-18
CHAPTER 7 ENVIRONMENTAL AND ENERGY IMPACTS 7-1
7.1 Air Pollution Impacts 7-1
7.2 Water Pollution Impacts 7-5
7.3 Solid Waste Impacts 7-7
7.4 Energy Impacts 7-8
7.5 Nationwide Fifth-Year Impacts 7-8
7.6 Other Environmental Impacts 7-9
7.7 Other Environmental Concerns 7-9
7.8 References for Chapter 7 7-38
CHAPTER 8 COSTS 8-1
8.1 Cost Analysis of Regulatory Alternatives 8-1
8.2 Other Cost Considerations 8-6
8.3 References for Chapter 8 8-31
CHAPTER 9 ECONOMIC ANALYSIS 9-1
9.1 Industry Profile . . . 9-1
9.2 Economic Impact Analysis 9-32
m
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TABLE OF CONTENTS (continued)
Page
9.3 Socioeconomic and Inflationary Impacts 9-43
9.4 References for Chapter 9 9-51
APPENDIX A EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT ... A-l
APPENDIX B INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS B-l
APPENDIX C EMISSION SOURCE TEST DATA C-l
C.I EPA-Sponsored Test at Polymeric Coating Plant .... C-l
C.2 EPA-Sponsored Tests for Related Industries C-6
C.3 Plant-Wide Solvent Recovery Efficiencies at
Polymeric Coating Plants C-10
APPENDIX D EMISSION MEASUREMENT AND MONITORING D-l
D.I Emission Measurement Test Program and Methods .... D-l
D.2 Performance Test Methods D-8
D.3 Monitoring Systems and Devices D-20
D.4 Test Method List and References D-26
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LIST OF FIGURES
Page
Figure 3-1 Solvent Borne Polymeric Coating Operations and
VOC Emission Locations 3-9
Figure 3-2 Three Typical Coating Application Equipment
Configurations 3-13
Figure 4-1 Flow Diagram of a Two-Unit, Fixed-Bed Adsorber .... 4-12
Figure 4-2 Fluidized-Bed Carbon Adsorber 4-17
Figure 4-3 Schematic of Condensation System Using Nitrogen . . . 4-22
Figure 4-4 Diagram of Conservation Vent 4-32
Figure C-l Solvent/Process Flow Diagram—Plant B C-13
Figure C-2 Solvent Block Flow Diagram—Plant B C-14
Figure C-3 Process Schematic and Sample Locations—Plant C . . . C-15
Figure C-4 Solvent Recovery Efficiency Data—Plant A C-16
Figure C-5 Solvent Recovery Efficiency Data—Plant B C-17
Figure C-6 Solvent Recovery Efficiency Data—Plant C C-18
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LIST OF TABLES
Table 3-1
Table 3-2
Table 3-3
Table 3-4
Table 3-5
Table 3-6
Table 4-1
Table 4-2
Table 4-3
Table 4-4
Table 4-5
Table 4-6
Table 4-7
Table 6-1
Table 6-2
Table 6-3a
Table 6-3b
Page
Major End Uses of Coated Substrates 3-3
Distribution of Plants that Apply Polymer Coatings
to Substrates by Number of Coating Lines 3-5
Number of Plants that Apply Coatings to Supporting
Substrates by State 3-6
Solvent and Solids Content of Polymeric
Coatings 3-8
Coating Applicator Parameters 3-15
State Regulations for VOC Emissions from Polymeric
Coating Sources 3-20
Range of Capture Velocities 4-5
Coefficients of Entry for Selected Hood
Openings 4-6
VOC Emission Control Devices Used by Polymeric
Coating Plants 4-10
Process Parameters for Polymer Coating Plants
Controlled by Fixed-Bed Carbon Adsorbers . 4-17
Process Parameters of Plant B Fluidized-Bed
Carbon Adsorber System 4-20
Range of Process Parameters for Polymeric Coating
Plants Using Inert Air Condensation Systems 4-24
Typical Process Parameters for Polymeric Coating
Plants Using Incinerators 4-28
Model Solvent Storage Tank Parameters 6-3
6-4
Model Coating Mix Preparation Equipment
Parameters
Model Coating Operation Parameters for Carbon
Adsorber or Incinerator Control Options
(Metric Units) 6-6
Model Coating Operation Parameters for Carbon
Adsorber or Incinerator Control Options
(English Units) 6-7
VI
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LIST OF TABLES (continued)
Page
Table 6-4a Model Coating Operation Parameters for
Condensation Control Option (Metric Units) 6-8
Table 6-4b Model Coating Operation Parameters for
Condensation Control Option (English Units) 6-9
Table 6-5 Model Coating Operation Parameters for
Substrate Type and Consumption 6-10
Table 6-6 Regulatory Alternatives for Solvent Storage
Tanks 6-13
Table 6-7 Regulatory Alternatives for Coating Mix
Preparation Equipment 6-15
Table 6-8 Regulatory Alternatives for Coating Operations .... 6-16
Table 7-1 Annual Air Pollution Impacts of the Regulatory
Alternatives and VOC Emission Reduction Beyond
Baseline for Model Solvent Storage Tanks 7-10
Table 7-2 Annual Air Pollution Impacts of the Regulatory
Alternatives and VOC Emission Reduction Beyond
Baseline for Model Coating Mix Preparation
Equipment 7-12
Table 7-3 Annual Air Pollution Impacts of the Regulatory
Alternatives and VOC Emission Reduction Beyond
Baseline for Model Coating Operations 7-13
Table 7-4 Annual Secondary Air Pollution Impacts for
Particulate Matter Emissions from Electrical
Energy Generation for the Control Equipment
Table 7-5 Annual Secondary Air Pollution Impacts for
Sulfur Oxide Emissions from Electrical
Energy Generation for the Control Equipment
Table 7-6 Annual Secondary Air Pollution Impacts for
Nitrogen Oxide Emissions from Electrical
Energy Generation for the Control Equipment
Table 7-7 Annual Secondary Air Pollution Impacts from
the Combustion of Natural Gas for the Control
Equipment
. 7-15
7-17
7-19
7-21
vn
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LIST OF TABLES (continued)
Page
Table 7-8 Annual Secondary Air Pollution Impacts for
Particulate Matter Emissions from Steam
Generation for the Control Equipment 7-22
Table 7-9 Annual Secondary Air Pollution Impacts for
Sulfur Oxide Emissions from Steam
Generation for the Control Equipment 7-23
Table 7-10 Annual Secondary Air Pollution Impacts for
Nitrogen Oxide Emissions from Steam
Generation for the Control Equipment 7-24
Table 7-11 Annual Secondary Air Pollution Impacts for
Carbon Monoxide Emissions from Steam Generation
for the Control Equipment 7-25
Table 7-12 Annual Wastewater Discharges and Wastewater
VOC Emissions from the Fixed-Bed Carbon Adsorber
Control of Model Mix Preparation Equipment 7-26
Table 7-13 Annual Wastewater Discharges from the
Fixed-Bed Carbon Adsorber Control of Model
Coating Operations 7-27
Table 7-14 Annual Wastewater VOC Emissions from the
Fixed-Bed Carbon Adsorber Control of Model
Coating Operations 7-28
Table 7-15 Annual Solid Waste Impacts of the Regulatory
Alternatives on the Model Coating Mix Preparation
Equipment and Coating Operations 7-29
Table 7-16
Table 7-17
Table 7-18
Table 7-19
Annual Electrical Energy Requirements for the
Control Equipment of Model Coating Mix
Preparation Equipment and Coating Operations .
Annual Natural Gas Requirements for the
Incinerator Control of Model Coating
Operations
. 7-30
7-32
Annual Steam Requirements for the Control
Equipment for Model Coating Mix Preparation
Equipment and Model Coating Operation . . .
7-33
Total Annual Energy Demand of Control
Equipment for the Model Coating Mix
Preparation Equipment and Coating Operations
. 7-34
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LIST OF TABLES (continued)
Table 7-20 Fifth-Year Impacts of Various Regulatory
Alternatives for Coating Lines 7-36
Table 7-21 Fifth-Year Impacts of Various Regulatory
Alternatives over Baseline for Coating Lines 7-37
Table 8-1 Basis for Estimating Annualized Costs--
Facilities 8-8
Table 8-2 Capital and Annualized Costs for Solvent
Storage Tanks 8-9
Table 8-3 Capital and Annualized Costs for Coating
Mix Preparation Equipment 8-10
Table 8-4 Capital and Annualized Costs for Coating
Operations 8-11
Table 8-5 Capital and Annualized Costs of Conservation
Vents for Solvent Storage Tanks 8-12
Table 8-6 Capital and Annual ized Costs of Pressure
Relief Valves for Solvent Storage Tanks 8-13
Table 8-7 Capital and Anualized Costs for Common
Carbon Adsorber for Control of Solvent
Storage Tanks 8-14
Table 8-8 Capital and Annualized Costs of Conservation
Vents for Coating Mix Preparation Equipment 8-15
Table 8-9 Capital and Annualized Costs for Common
Carbon Adsorber for Control of Coating Mix
Preparation Equipment 8-16
Table 8-10 Capital and Annualized Costs for Carbon
Adsorber Control of Model Operations--
Regulatory Alternative I 8-17
Table 8-11 Capital and Annualized Costs for Carbon
Adsorber Control of Model Operations--
Regulatory Alternative II 8-18
Table 8-12 Capital and Annualized Costs for Carbon
Adsorber Control of Model Operations--
Regulatory Alternative III 8-19
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LIST OF TABLES (continued)
Page
Table 8-13 Capital and Annualized Costs for
Condensation System Control of Model
Operations—Regulatory Alternative I 8-20
Table 8-14 Capital and Annualized Costs for
Condensation System Control of Model
Operations—Regulatory Alternative II 8-21
Table 8-15 Capital and Annualized Costs for
Condensation System Control of Model
Operations—Regulatory Alternative III 8-22
Table 8-16 Capital and Annualized Costs for Incinerator
Control of Model Operations—Regulatory
Alternative IV 8-23
Table 8-17 Capital and Annualized Costs, and Annualized
Costs Per Unit Area of Substrate Coated for
Each Regulatory Alternative 8-24
Table 8-18 Average and Incremental Cost Effectiveness
of Regulatory Alternatives for Storage Tanks 8-27
Table 8-19 Average and Incremental Cost Effectiveness
of Regulatory Alternatives for Coating Mix
Preparation Equipment 8-28
Table 8-20 Average and Incremental Cost Effectiveness
of Regulatory Alternatives for Model Lines
(Using Carbon Adsorber) 8-29
Table 8-21 Average and Incremental Cost Effectiveness
of Regulatory Alternatives for Model Lines
(Using Condensation System) 8-30
Table 9-1 Wholesale Value of Shipments by SIC Group,
1973-1982 9-3
Table 9-2 Polymeric Coating of Supporting Substrates:
Adjusted Value of Shipments, 1982 9-5
Table 9-3 Polymeric Coating of Supporting Substrates:
Wholesale Value of Shipments for Industry
Segments, 1973-1982 9-6
4
Table 9-4 Polymeric Coating of Supporting Substrates:
Percentages of Total Output by Industry
Segment, 1973-1982 9-7
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LIST OF TABLES (continued)
Page
Table 9-5 Average Prices for Selected Products 9-9
Table 9-6 Polymeric Coating of Supporting Substrates:
Industry Segment Employment, 1973-1982 9-12
Table 9-7 Plants Applying Polymeric Coatings to
Supporting Substrates: Location, SIC Code,
Type of Coater, and Business Size 9-13
Table 9-8 Polymeric Coating of Supporting Substrates:
Concentration Ratios for Industry Segments,
1977 9-22
Table 9-9 Correlation Between Polymeric Coating Industry
Output and Indexes of Motor Vehicle and Total
U.S. Industrial Production 9-24
Table 9-10 Value of Imports for Polymeric Coated Products,
1978-1982 9-27
Table 9-11 Value of Exports for Polymeric Coated Products,
1978-1982 9-28
Table 9-12 Projected Annual Growth Rates for Sales of
Selected Final Products Manufactured from
Polymeric Coated. Substrates . . . . 9-30
Table 9-13 Data Used to Derive Industry Forecast Equation .... 9-31
Table 9-14 Projected Value of Annual Output for the
Polymeric Coating Industry, 1984-1990 9-33
Table 9-15 Percent Cost Increases for Model Plants 9-38
Table 9-16 Annual Revenue Estimates for Model Lines
Producing Typical Products 9-40
Table 9-17 Percent Price Increases for Typical Products 9-41
Table 9-18 Total Value of New Solvent-Based Capacity
Required, 1986-1990 9-44
Table 9-19 Summary of Fifth-Year Annualized Costs Under
Most Costly Regulatory Alternatives 9-48
*
Table B-l Cross-Indexed Reference System to Highlight
Environmental Impact Portions of the Document .... B-2
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LIST OF TABLES (continued)
Page
Table C-l Process Parameters for FTuidized-Bed
Carbon Adsorption System—Plant B C-19
Table C-2 Process Parameters Monitored During
Plant B Source Tesing C-20
Table C-3 Valid Data—Carbon Adsorber Control
Efficiency for Single Fabric Coating
Line—Test Data for Plant B C-22
Table C-4 Valid Data—Mix Tank Emissions Estimated from
EPA Method 24 Data for Plant B C-23
Table C-5 Valid Data—Coating Viscosity Analysis:
Comparison of EPA Method 24 and Plant B
Cup Test C-24
Table C-6 Invalid Test Data—Capture, Control, and Total
VOC Reduction Efficiency for Single Fabric
Coating Line at Plant B C-25
Table C-7 Invalid Plant Data—Total VOC Reduction
Efficiency for Single Fabric Coating Line
at Plant B C-28
Table C-8 Invalid Test Data—Summary of Test Results
at Plant C C-29
Table C-9 Valid Data—Summary of Coating Line Operations
at PSTL Facility C-30
Table C-10 Valid Data—Press Operations During Tests at
Meredith/Burda C-31
Table C-ll Valid Data—Summary of Demonstrated VOC
Emission Control Efficiencies at
Meredith/Burda, Percent C-32
Table C-12 Valid Data—Summary of Capture Efficiency
Data—General Tire and Rubber Company C-33
Table C-13 Valid Data—Summary of Carbon Adsorption
Efficiency Data—General Tire and Rubber
Company C-34
Table C-14 Summary of Solvent Recovery Measurement
Procedures C-35
xn
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2. INTRODUCTION
2.1 BACKGROUND AND AUTHORITY FOR STANDARDS
Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail. Various levels of control based on different techno-
logies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for
a standard. The alternatives are investigated in terms of their impacts
on the economics and well-being of the industry, the impacts on the
national economy, and the impacts on the environment. This chapter sum-
marizes the types of information obtained by EPA through these studies
in the development of the proposed standards.
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended,
hereafter referred to as the Act. Section 111 directs the Administrator
to establish standards of performance for any category of new stationary
source of air pollution which ". . . causes, or contributes significantly
to, air pollution which may reasonably be anticipated to endanger public
health or welfare."
The Act requires that standards of performance for stationary
sources reflect "... the degree of emission limitation and the percentage
reduction achievable through application of the best technological
system of continuous emission reduction which (taking into consideration
the cost of achieving such emission reduction, any nonair quality health
and environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated." The standards apply only
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to stationary sources, the construction or modification of which commences
after the standards are proposed in the Federal Register.
The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
Examples of the effects of the 1977 amendments are:
1. The EPA is required to review the standards of performance
every 4 years and, if appropriate, revise them.
2. The EPA is authorized to promulgate a standard based on design,
equipment, work practice, or operational procedures when a standard
based on emission levels is not feasible.
3. The term "standards of performance" is redefined, and a new
term "technological system of continuous emission reduction" is defined.
The new definitions clarify that the control system must be continuous
and may include a low- or non-polluting process or operation.
4. The time between the proposal and promulgation of a standard
under Section 111 of the Act may be extended to 90 days.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction,
taking into consideration the cost of achieving such emission reduction,
any nonair quality health and environmental impacts, and energy require-
ments.
Congress had several reasons for including these requirements.
First, standards having a degree of uniformity are needed to avoid
situations where some States may attract industries by relaxing standards
relative to other States. Second, stringent standards enhance the
potential for long-term growth. Third, stringent standards may help
achieve long-term cost savings by avoiding the need for more expensive
retrofitting when pollution ceilings may be reduced in the future.
Fourth, certain types of standards for coal-burning sources can adversely
affect the coal market by driving up the price of low-sulfur coal or by
effectively excluding certain coals from the reserve base due to their
high untreated pollution potentials. Congress does not intend that new
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source performance standards contribute to these problems. Fifth, the
standard-setting process should create incentives for improving technology.
Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources. States are free under Section 116 of the Act to establish
even more stringent emission limits than those established under
Section 111 or than those necessary to attain or maintain the National
Ambient Air Quality Standards (NAAQS) under Section 110. Thus, new
sources may in some cases be subject to State limitations that are more
stringent than standards of performance under Section 111, and prospective
owners and operators of new sources should be aware of this possibility
in planning for such facilities.
A similar situation may arise when a major emitting facility is to
be constructed in a geographic area that falls under the prevention of
significant deterioration of air quality provisions of Part C of the
Act. These provisions require, among other things, that major emitting
facilities to be constructed in such areas are to be subject to best
available control technology. The term "best available control
technology" (BACT), as defined in the Act, means
... an emission limitation based on the maximum degree of
reduction of each pollutant subject to regulation under this
Act emitted from or which results from any major emitting
facility, which the permitting authority, on a case-by-case
basis, taking into account energy, environmental, and economic
impacts and other costs, determines is achievable for such
facility through application of production processes and avail-
able methods, systems, and techniques, including fuel cleaning
or treatment or innovative fuel combustion techniques for
control of each such pollutant. In no event shall application
of "best available control technology" result in emissions of
any pollutants which will exceed the emissions allowed by any
applicable standard established pursuant to Sections 111 or 112
of this Act. (Section 169(3))
Although standards of performance are normally structured in terms
of numerical emission limits where feasible, alternative approaches are
sometimes necessary. In some cases, physical measurement of emissions
from a new source may be impractical or exorbitantly expensive.
Section lll(h) provides that the Administrator may promulgate a design
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or equipment standard in those cases where it is not feasible to prescribe
or enforce a standard of performance. For example, emissions of hydro-
carbons from storage vessels for petroleum liquids are greatest during
tank filling. The nature of the emissions (i.e., high concentrations
for short periods during filling and low concentrations for longer
periods during storage) and the configuration of storage tanks make
direct emission measurement impractical. Therefore, a more practical
approach to standards of performance for storage vessels has been equip-
ment specification.
In addition, under Section lll(j) the Administrator may, with the
consent of the Governor of the State in which a source is to be located,
grant a waiver of compliance to permit the source to use an innovative
technological system or systems of continuous emission reduction. In
order to grant the waiver, the Administrator must find that: (1) the
proposed system has not been adequately demonstrated; (2) the proposed
system will operate effectively and there is a substantial likelihood
that the system will achieve greater emission reductions than the
otherwise applicable standards require or at least an equivalent
reduction at lower economic, energy, or nonair quality environmental
cost; (3) the proposed system will not cause or contribute to an
unreasonable risk to public health, welfare, or safety; and (4) the
waiver when combined with other similar waivers, will not exceed the
number necessary to achieve conditions (2) and (3) above. A waiver may
have conditions attached to ensure the source will not prevent attainment
of any NAAQS. Any such condition will be treated as a performance
standard. Finally, waivers have definite end dates and may be terminated
earlier if the conditions are not met or if the system fails to perform
as expected. In such a case, the source may be given up to 3 years to
meet the standards and a mandatory compliance schedule will be imposed.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Administrator to list categories
of stationary sources. The Administrator "... shall include a category
of sources in such list if in his judgment it causes, or contributes
significantly to, air pollution which may reasonably be anticipated to
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endanger public health or welfare." Proposal and promulgation of
standards of performance are to follow.
Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of an approach for assigning
priorities to various source categories. The approach specifies areas
of interest by considering the broad strategy of the Agency for imple-
menting the Clean Air Act. Often, these areas are pollutants that are
emitted by stationary sources rather than the stationary sources
themselves. Source categories that emit these pollutants were evaluated
and ranked considering such factors as: (1) the level of emission control
(if any) already required by State regulations, (2) estimated levels of
control that might be required from standards of performance for the
source category, (3) projections of growth and replacement of existing
facilities for the source category, and (4) the estimated incremental
amount of air pollution that could be prevented in a preselected future
year by standards of performance for the source category. Sources for
which new source performance standards were promulgated or under develop-
ment during 1977, or earlier, were selected using these criteria.
The Act amendments of August 1977 establish specific criteria to be
used in determining priorities for all source categories not yet listed
by EPA. These are: (1) the quantity of air pollutant emissions which
each such category will emit, or will be designed to emit; (2) the
extent to which each such pollutant may reasonably be anticipated to
endanger public health or welfare; and (3) the mobility and competitive
nature of each such category of sources and the consequent need for
nationally applicable new source standards of performance. The
Administrator is to promulgate standards for these categories according
to the schedule referred to earlier.
In some cases, it may not be immediately feasible to develop
standards for a source category with a high priority. This might happen
if a program of research is needed to develop control techniques or if
techniques for sampling and measuring emissions require refinement. In
the developing of standards, differences in the time required to complete
the necessary investigation for different source categories must also be
considered. For example, substantially more time may be necessary if
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numerous pollutants must be investigated from a single source category.
Further, even late in the development process, the schedule for completion
of a standard may change. For example, inability to obtain emission
data from well-controlled sources in time to pursue the development
process in a systematic fashion may force a change in scheduling.
Nevertheless, priority ranking is, and will continue to be, used to
establish the order in which projects are initiated and resources
assigned.
After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be
determined. A source category may have several facilities that cause
air pollution, and emissions from these facilities may vary according to
magnitude and control cost. Economic studies of the source category and
of applicable control technology may show that air pollution control is
better served by applying standards to the more severe pollution sources.
For this reason, and because there is no adequately demonstrated system
for controlling emissions from certain facilities, standards often do
not apply to all facilities at a source. For the same reasons, the
standards may not apply to all air pollutants emitted. Thus, although a
source category may be selected to be covered by standards of performance,
not all pollutants or facilities within that source category may be
covered by the standards.
*. •
2. 3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of performance must: (1) realistically reflect best
demonstrated control practice; (2) adequately consider the cost, the
nonair quality health and environmental impacts, and the energy require-
ments of such control; (3) be applicable to existing sources that are
modified or reconstructed as well as to new installations; and (4) meet
these conditions for all variations of operating conditions being
considered anywhere in the country.
The objective of a program for development of standards is to
identify the best technological system of continuous emission reduction
that has been adequately demonstrated. The standard-setting process
involves three principal phases of activity (1) information gathering,
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(2) analysis of the information, and (3) development of the standard of
performance.
During the information gathering phase, industries are questioned
through telephone surveys, letters of inquiry, and plant visits by EPA
representatives. Information is also gathered from other sources,
including a literature search. Based on the information acquired about
the industry, EPA selects certain plants at which emission tests are
conducted to provide reliable data that characterize the pollutant
emissions from well-controlled existing facilities.
In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies. Hypothetical
"model plants" are defined to provide a common basis for analysis. The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives." These regulatory
alternatives are essentially different levels of emission control.
The EPA conducts studies to determine the cost, economic, environ-
mental, and energy impacts of each regulatory alternative. From several
alternatives, EPA selects the single most plausible regulatory alternative
as the basis for standards of performance for the source category under
study.
In the third phase of a project, the selected regulatory alternative
is translated into performance standards, which, in turn, are written in
the form of a Federal regulation. The Federal regulation, when applied
to newly constructed plants, will limit emissions to the levels indicated
in the selected regulatory alternative.
As early as is practical in each standard-setting project, EPA
representatives discuss the possibilities of a standard and the form it
might take with members of the National Air Pollution Control Techniques
Advisory Committee. Industry representatives and other interested
parties also participate in these meetings.
The information acquired in the project is summarized in the back-
ground information document (BID). The BID, the proposed standard, and
*
a preamble explaining the standard are widely circulated to the industry
being considered for control, environmental groups, other government
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agencies, and offices within EPA. Through this extensive review process,
the points of view of expert reviewers are taken into consideration as
changes are made to the documentation.
A "proposal package" is assembled and sent through the offices of
EPA assistant administrators for concurrence before the proposed standard
is officially endorsed by the EPA Administrator. After being approved
by the EPA Administrator, the preamble and the proposed regulation are
published in the Federal Register.
The public is invited to participate in the standard-setting process
as part of the Federal Register announcement of the proposed regulation.
The EPA invites written comments on the proposal and also holds a public
hearing to discuss the proposed standard with interested parties. All
public comments are summarized and incorporated into a second volume of
the BID. All information reviewed and generated in studies in support
of the standard of performance is available to the public in a "docket"
on file in Washington, D.C. Comments from the public are evaluated, and
the standard of performance may be revised in response to the comments.
The significant comments and the EPA's position on the issues
raised are included in the preamble of a promulgation package, which
also contains the draft of the final regulation. The regulation is then
subjected to another round of review and refinement until it is approved
by the EPA Administrator. After the Administrator signs the regulation,
it is published as a "final rule" in'the Federal Register.
2.4 CONSIDERATION OF COSTS
Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111 of
the Act. The assessment is required to contain an analysis of: (1) the
costs of compliance with the regulation, including the extent to which
the cost of compliance varies depending on the effective date of the
regulation and the development of less expensive or more efficient
methods of compliance; (2) the potential inflationary and recessionary
effects of the regulation; (3) the effects the regulation might have on
small business with respect to competition; (4) the effects of the
regulation on consumer costs; and (5) the effects of the regulation on
2-8
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energy use. Section 317 requires that the economic impact assessment be
as extensive as practicable.
The economic impact of a proposed standard upon an industry is
usually addressed both in absolute terms and by comparison with the
control costs that would be incurred as a result of compliance with
typical, existing State control regulations. An incremental approach is
taken because both new and existing plants would be required to comply
with State regulations in the absence of a Federal standard of perfor-
mance. This approach requires a detailed analysis of the economic
impact of the cost differential that would exist between a proposed
standard of performance and the typical State standard.
Air pollutant emissions may cause water pollution problems, and
captured potential air pollutants may pose a solid waste disposal problem.
The total environmental impact of an emission source must, therefore, be
analyzed and the costs determined whenever possible.
A thorough study of the profitability and price-setting mechanisms
of the industry is essential to the analysis so that an accurate estimate
of potential adverse economic impacts can be made for proposed standards.
It is also essential to know the capital requirements for pollution
control systems already placed on plants so that the additional capital
requirements necessitated by these Federal standards can be placed in
proper perspective. Finally, it is necessary to assess the availability
of capital to provide the additional control equipment needed to meet
the standards of performance.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy Act (NEPA)
of 1969 requires Federal agencies to prepare detailed environmental
impact statements on proposals for legislation and other major Federal
actions significantly affecting the quality of the human environment.
The objective of NEPA is to build into the decision-making process of
Federal agencies a careful consideration of all environmental aspects of
proposed actions.
In a number of legal challenges to standards of performance for
various industries, the United States Court of Appeals for the District
2-9
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of Columbia Circuit has held that environmental impact statements need
not be prepared by the Agency for proposed actions under Section 111 of
the Clean Air Act. Essentially, the Court of Appeals has determined
that the best system of emission reduction requires the Administrator to
take into account counterproductive environmental effects of proposed
standards, as well as economic costs to the industry. On this basis,
therefore, the Courts established a narrow exemption from NEPA for EPA
determinations under Section 111.
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to Section 7(c)(l), "No action taken under the Clean Air Act
.«.
shall be deemed a major Federal action significantly affecting the
quality of the human environment within the meaning of the National
Environmental Policy Act of 1969." (15 U.S.C. 793(c)(l))
Nevertheless, the Agency has concluded that the preparation of
environmental impact statements could have beneficial effects on certain
regulatory actions. Consequently, although not legally required to do
so by Section 102(2)(C) of NEPA, EPA has adopted a policy requiring that
environmental impact statements be prepared for various regulatory
actions, including standards of performance developed under Section 111
of the Act. This voluntary preparation of environmental impact statements,
however, in no way legally subjects the Agency to NEPA requirements.
To implement this policy, a separate section is included in this
document which is devoted solely to an analysis of the potential environ-
mental impacts associated with the proposed standards. Both adverse and
beneficial impacts in such areas as air and water pollution, increased
solid waste disposal, and increased energy consumption are discussed.
2.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as ". . . any stationary
source, the construction or modification of which is commenced ..."
after the proposed standards are published. An existing source is
redefined as a new source if "modified" or "reconstructed" as defined in
t
amendments to the General Provisions (40 CFR Part 60, Subpart A), which
2-10
-------
were promulgated in the Federal Register on December 16, 1975
(40 FR 58416).
Promulgation of standards of performance requires States to establish
standards of performance for existing sources in the same industry under
Section lll(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality
criteria have not been issued under Section 108 or which has not been
listed as a hazardous pollutant under Section 112). If a State does not
act, EPA must establish such standards. General procedures for control
of existing sources under Section lll(d) were promulgated on November 17,
1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7 REVISION: OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
Section 111 of the Act provides that the Administrator ". . . shall, at
least every four years, review and, if appropriate, revise ..." the
standards. Revisions are made to ensure that the standards continue to
reflect the best systems that become available in the future. Such
revisions will not be retroactive but will apply to stationary sources
constructed or modified after the proposal of the revised standards.
2-11
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3. PROCESSES AND POLLUTANT EMISSIONS
Polymeric coating of supporting substrates is a subcategory of web
coating. Web coating is defined as coating of fabric, paper, plastic
film, metallic foil, metal coil, or other products that are flexible
enough to be unrolled from a large roll, coated by blade, roll coating,
or rotogravure as a continuous sheet and, after cure, rerolled. Several
web coating categories are already subject to, or are being investigated
for, regulation by new source performance standards. These are: publica-
tion rotogravure; rotogravure printing and top coating of flexible,
polyvinyl chloride (PVC), and urethane surfaces; coating of magnetic tape;
coating of pressure sensitive tapes and labels; and printing and application
of adhesives and coatings on paper, film, and foil in converting operations.
Polymeric coating of supporting substrates is intended to include
all other web coating operations excluding those that print an image on
the surface of the substrate. Any coating applied on the same printing
press that applies the image would also be excluded. While polymeric
coating encompasses a wide range of substrates, coatings, and products,
all of the operations are similar in that they coat a flexible web in a
continuous process with a common coating line configuration of unwind,
coating application, flashoff area, drying or curing oven, and rewind.
This chapter describes various processes used for polymeric coating
of supporting substrates and the resulting volatile organic compound
(VOC) emissions. The last section of this chapter discusses the selection
of the baseline emission level, which is used in later chapters to
determine incremental environmental and economic impacts of the regulatory
alternatives.
3-1
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3.1 INDUSTRY DESCRIPTION
A more detailed generalized flow of the coating process is:
(1) the receipt of raw materials such as substrates, solvents, polymer
resins, and additives; (2) the preparation of the coating; (3) the
application of the coating to the substrate; (4) the drying/curing of the
coating; and (5) any subsequent processes performed on the coated substrate,
such as slitting. The principle step in the manufacturing process is the
application of coatings to a substrate.
The coated substrate takes on a combination of properties from both
the coating and the substrate. Coatings generally impart elasticity to
the substrate and provide resistance to one or more of the following:
abrasion, water, chemicals, heat, fire, and oil. Examples of coatings
are natural and synthetic rubbers, urethanes, polyvinyl chloride (commonly
known as PVC or vinyl), acrylics, epoxies, silicone, phenolics, and
nitrocellulose. Substrates provide tensile strength, elongation control,
and tear strength. Substrates include woven, knit, and nonwoven textiles;
fiberglass; leather; yarn; cord; and paper. The most prevalent substrate
is woven fabric.1 Coated substrates are intermediate products that are
used in the fabrication of a variety of major end products, which are
listed in Table 3-1.
There are at least 128 domestic plants, owned by 108 companies, that
perform polymeric coating.2 The distribution of plants by number of
coating lines and by State is presented in Tables 3-2 and 3-3, respectively.
Over half of the 71 plants that supplied information (Table 3-2) have 1
to 4 coating lines, and only about 7 percent of the plants have 10 or
more lines. The largest number of coating lines found in a plant is
18.3 This source category is not restricted to any one region of the
country by raw material or market requirements, but most plants are
located in the more heavily populated and industrialized areas.
Polymeric coating plants may be classified into two broad categories,
commission and captive (or noncommission) coaters. The commission coater
has many customers and produces coated substrates according to each
customer's specifications. The captive coater produces coated substrate
as an intermediate product in a manufacturing process.4-6
3-2
-------
TABLE 3-1. MAJOR END USES OF COATED SUBSTRATES1,2
End use
Coating
Substrate'
Aircraft fabric
Architectural structures
Awnings
Book covers
Conveyor, light duty,
..and industrial V-be Its
Diaphragms and gaskets
Drapery linings
Fencing
Flexible hoses
Hot-air balloons
Inflatables
Lightweight liners
Mattress fabric
Military fabric
Offset printing blankets
Pond liners
Silicone, epoxies,
phenolics, vinyl
Silicone
Vinyl
Nitrocellulose,
urethanes
Synthetic rubber,
natural rubber
Synthetic rubber,
natural rubber
Acrylics
Synthetic rubber,
natural rubber
Synthetic rubber,
natural rubber
Urethanes
Synthetic rubber,
natural rubber
Synthetic rubber,
natural rubber
Synthetic rubber,
natural rubber
Silicone, epoxies,
phenolics, vinyl
Synthetic rubber,
natural rubber
Synthetic rubber
Fiberglass,
polyester, nylon
Fiberglass
Polyester, cotton,
canvas
Nylon, cotton,
polyester
Polyester, cord
Polyester, paper,
cotton, dacron
Polyester, polyester-
cotton blend
Nylon
Polyester, cotton
Dacron , nylon,
Glass or polyester
woven
Cord, yarn
Polyester drill
Fiberglass, Kevlar,
polyester, nylon
Polyester, cotton
and rayon blend
Nylon or polyester
scrim
(continued;
3-3
-------
TABLE 3-1. (continued)
End use
Coating
Substrate*
Protective clothing
Rainwear
Recreational clothing
and equipment
Sails
Shoe fabric
Soft-sided luggage
Tarpaulins
Tents
Truck and storage
tank covers
Upholstery
Synthetic rubber,
natural rubber,
urethanes
Urethanes, synthetic
rubber, vinyl,
acrylics
Urethanes
Adhesives, urethanes
Urethanes, vinyl
Urethanes, vinyl
Synthetic rubber,
urethane, vinyl
Urethanes
Synthetic rubber,
natural rubber, vinyl
Urethanes, Vinyl
Cotton, rayon,
nylon, polyester
Nylon, cotton
Nylon, polyester
Nylon, polyester
Cotton drill, high
density nonwoven
textiles
Rayon drill, nylon,
polyester
Nylon, polyester
Rayon, nylon,
polyester
Nylon, polyester
Cotton, rayon, nylon,
polyester
aSubstrates are listed by material, brand name, or physical form.
3-4
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TABLE 3-2. DISTRIBUTION OF PLANTS THAT APPLY POLYMERIC
COATINGS TO SUPPORTING SUBSTRATES BY NUMBER OF COATING LINES2
No. of
coating lines
1
2-4
5-10
>10
TOTAL
No. of
plants
19
30
17
_5
71
Percent-
age of
plants
27
42
24
_7
100
aCoating line is defined to include the coating
application/flashoff area and the drying oven.
3-5
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TABLE 3-3. NUMBER OF PLANTS THAT APPLY POLYMERIC
COATINGS TO SUPPORTING SUBSTRATES BY STATE2
State No. of plants
Alabama 1
Arkansas 2
California 7
Colorado 1
Connecticut 7
Florida 1
Georgia 6
Illinois 3
Indiana 2
Kansas I
Maryland 1
Massachusetts 18
Michigan 2
Minnesota 1
Mississippi 1
Missouri 2
New Hampshire 2
New Jersey 9
New York 10
North Carolina 6
Ohio 13
Pennsylvania 2
Rhode Island 7
South Carolina 8
Tennessee 5
Texas 3
Vermont 1
Virginia 3
Wisconsin 3
TOTAL 128
3-6
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3.2 RAW MATERIALS
The raw materials used to produce polymeric coatings include
plasticizers, solvents, polymer resins, pigments, curing agents, and
©
fillers such as carbon black or Teflon . Plasticizers are added to the
coating to increase its pliability. Frequently used plasticizers include
fatty acids, alcohols, and dialkyl phthalates.
Solvents are added to the coating to disperse the solids and to
adjust the viscosity of the coating. Factors affecting solvent selection
are dispersability, toxicity, availability, cost, desired rate of evapora-
tion, ease of use after solvent recovery, and effect on solvent recovery
equipment. Table 3-4 presents the solvent and solids content of the
various polymeric coatings.7 The major organic solvents used in the
coatings are toluene, dimethyl formamide (DMF), acetone, methyl ethyl
ketone (MEK), isopropyl alcohol, xylene, and ethyl acetate. Toluene is
one of the lowest cost organic solvents and therefore is the most commonly
used.
The trend over the past 15 years is to use less solvent because of
the increasing cost, environmental regulations, and awareness of the
hazards of emissions both to workers and to the environment.8 More than
30 percent of the plants identified in this source category currently use
low-solvent coatings such as waterborne or higher solids.2 Waterborne
coatings may be defined as containing more than 5 percent water (by
weight) in the liquid fraction.9 Higher solids coating is a term often
applied to any coating which contains considerably higher solids than
conventional coatings used in the past.10 Plastisol coatings and rubber
coatings used in calendering and extrusion processes are 95 to
100 percent solids.11-15
3.3 PROCESSES AND THEIR EMISSIONS
The process of applying a polymeric coating to a supporting substrate
consists of: mixing the coating ingredients (including the solvents),
conditioning the substrate, applying the coating to the substrate, and
evaporating the solvent in a drying oven. Sometimes, subsequent curing
or vulcanizing is necessary. The steps in this process are typical of
any polymeric coating plant applying liquid coatings. Figure 3-1 presents
3-7
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TABLE 3-4. SOLVENT AND SOLIDS CONTENT OF POLYMERIC COATINGS7
Typical percentage, by weight
Polymer type % solvent% solids
Rubber 50-70 30-50
Urethanes 50-60 40-50
Acrylics3 50 50
Vinylb 60-80 20-40
Vinyl Plastisol 15 85
Epoxies 30-40 60-70
Si licone 50-60 40-50
Nitrocellulose 70 30
aOrganic solvents are generally not used in the formulation of acrylic
coatings. Therefore, the solvent content for acrylic coatings represents
.nonorganic solvent use (i.e., water).
Solvent borne vinyl coating.
3-8
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co
i
UD
SOLVENT
STORAGE
CONDITIONED
SUBSTRATE
COATING
X
COATING
APPLICATION/
FLASHOFF
AREA
CLEAN UP
SOLVENT
•K
t
DRYING
OVEN
X
L
CURING
OVEN
(OPTIONAL)
I
COATED
SUBSTRATE
VOC emissions are denoted by an '*'
Figure 3-1. Solvent borne polymeric coating operation and VOC emission locations.
-------
a schematic of a solvent borne polymeric coating operation. The emissions
of concern are VOC's that result primarily from the vaporization of
solvents during coating and drying of the substrate and, in lesser
amounts, during solvent storage, coating preparation, and cleaning of
the equipment. Small amounts of VOC emissions also may occur as by-products
of reactions that take place when coatings are mixed or as the coatings
are cured.
3.3.1 Solvent Storage
Each polymeric coating plant may have up to five solvent storage
tanks. Generally, the capacity of the tanks ranges from 19 cubic meters
(m3) (5,000 gallons [gal]) to 38 m3 (10,000 gal). However, tanks as
small as 3.8 m3 (1,000 gal) and as large as 76 m3 (20,000 gal) in
capacity are used. The tanks are built with open vents or with conservation
vents. The majority of plants have solvent storage tanks that are
located below ground.6,16 However, industry contacts have indicated
that solvent storage tanks at new plants would be built above ground
because of concerns about potential ground water contamination.17
3.3.2 Preparation of Coating
For the purposes of this document, coating mix preparation equipment
includes all the mills, mixers, mixing and holding tanks, and pumps
required to produce a polymeric coating (either in dry or liquid form)
that is ready to be applied to the substrate. The number of steps
involved in preparing the coating depends on the form (chunks, blocks,
chips, pellets, or fine powder) in which the polymer is received and fed
to the process.
The polymers that are supplied in large chunks or blocks require
the most elaborate coating preparation procedure. This procedure for
preparing coating is typical of rubber coatings. The polymer, along
with pigments, fillers, and sometimes oils, is fed to a Banbury mixer
that blends the mixture by a set of rotors. The mixture is discharged
as a semi-molten slab, which is cooled and then is usually sent to a
two-roll mill in which curing agents and other additives are blended.
At some plants, the polymer is fed directly to the roll mill if the
chunks are small enough. The roll mill is a set of two rollers that
squeezes layers of polymer together. Mixing occurs as strips of polymer
3-10
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are peeled off and refed to the rolls. From the two-roll mill, the
polymer is either sent to a calendering or an extrusion process,
both of which use solventless coatings, or to a shredder that cuts the
polymer into small rectangular cubes or pellets. The cubes or pellets
are fed to a mixing vessel, sometimes called a churn or kettle, to be
dissolved or suspended in solvents or plasticizers.
Some manufacturers supply the polymer in chip or pellet form that
precludes the Banbury mixing and roll milling steps. Additives and
solvents are added directly to the polymer into a mixing vessel. The
homogeneity of a coating solution is critical; therefore, the coating is
filtered through a series of wire screens prior to application of the
coating.
Another procedure for preparing coatings is typical of PVC plastisols.
The polymer is a fine powder, which is suspended in plasticizers with
emulsifying agents. Occasionally a small amount (5 percent or less) of
organic solvent is added for viscosity control.11 A typical coating
preparation equipment configuration for plastisol coatings is a mixer,
vacuum pump, vacuum hood, and filter.18
Urethane coatings are generally purchased premixed and require
little or no mixing at the plant site. Acrylic and vinyl coatings are
also sometimes purchased premixed.19 Therefore, fewer, if any, pieces
of coating preparation equipment are required for these operations.
3.3.3 Substrate Preparation
Prior to the application of the coating, substrates are typically
cut into production size rolls and inspected for any defects. If there
are any major defects, the substrate is discarded. Minor defects are
cut out of the substrate.20 Substrates may also be washed and shrunk or
stretched.21 Sometimes the moisture content of the substrate is reduced
by passing it through a series of steam-heated rollers just prior to
coating.22
Fabric widths used in coating operations range from 48 to 72 inches.
Although use of the 72-inch width is increasing, the 60-inch width is
currently most commonly used. Wider fabrics maximize production rates
resulting in a less expensive intermediate product.4,5,23
3-11
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3.3.4 Coating Application
The three primary types of equipment used for applying liquid
coating (including plastisols) to the substrate are: knife-over-roll,
dip, and reverse-roll coaters. Figure 3-2 presents typical configura-
tions for these coaters. This equipment is applicable for organic
solvent borne and waterborne coatings.6
Knife-over-roll is the most common type of coating application
method.24 The coating is either pumped or manually poured onto the
substrate just in front of a perpendicular knife. The coating thickness
depends on the clearance between the edge of the knife and the substrate.
The equipment can apply a variety of coatings at a wide range of coating
thicknesses from 50 urn (2 mils) up to 2,500 (j"i (100 mils).25
Dip coating is another common coating application method used when
saturation of the substrate is desired.6 All cord- and yarn-coating
lines and some rubber- and epoxy-coating lines employ dip coaters.25
The substrate passes from a roller (or series of spools) through a
coating reservoir (called a dip tank or dip vat) and emerges through a
pair of rollers or wiper blades that removes excess coating. The amount
of coating remaining on the substrate is controlled by the pressure of
the rollers or wiper blades on the substrate.
The third coating application method is the reverse-roll coater.
This method is used when thin coating layers must be applied with a high
degree of precision.4,5,26 There are many configurations of reverse-roll
coaters. In a three-roll reverse-roll coater, the substrate is drawn
around the bottom of the three rolls while coating is applied to the top
roll. Coating thickness is controlled by the gap between rolls and the
line speed.27 The reverse-roll coating method is commonly used by
urethane coaters. According to one industry contact, rubber coatings
typically are not applied by this method because the coating tends to dry
on the rollers.28
While the three coating application methods vary in the physical
setup, the overall coating line configuration of unwind, coating application,
flashoff area, drying oven, and rewind is similar for all three. Their
main function of applying coatings to the substrate is the'same. Similar
VOC fugitive emission capture devices around the coating application/
3-12
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TO DRYING OVEN
CO
i-*
CO
COATING
COATED
SUBSTRATE
WIPER ,
BLADES
DIP COATER
COATED SUBSTRATE TO DRVER
,4— SUBSTRATE TO BE COATED
HARD RUBBER OR STEEL ROLLER
KNIFE-OVER-ROLL COATER
ROLL OF
UNCOATED
SUBSTRATE
COATED SUBSTRATE
TO DRYER
SUBSTRATE TO
BE COATED
KNIFE
COATING
REVERSE-ROLL COATER
Figure 3-2. Three typical coating application equipment configurations.
-------
flashoff area and similar control devices to control the VOC emissions
could be applied to coating lines using any of the coating application
methods.
The types of coating processes that apply 95 to 100 percent solid
coatings include calendering, extrusion, and lamination. Calendering is
a process in which the coating is formed into a self-supporting sheet by
squeezing it between successive pairs of heated rolls, each pair rotating
faster than the previous pair. The sheet is subsequently pressed against
the supporting substrate to form the coated product. Extrusion is the
process of forcing a heated thermoplastic resin through a slit or die to
form a sheet. In the coating process, the sheet, while still in a semi-
molten state, is pressed into the substrate. Lamination is a process of
using heat, adhesives, and pressure to bond a substrate and plastic film.
Table 3-5 presents the coating type, line speed, and dry coating
thickness of the coating applicators used to apply liquid coatings. Line
speeds of 5 to 32 meters (5 to 35 yards) per minute are typical for all
types of applicators; however, 46 meters (50 yards) per minute can be
achieved with some coating compounds.5,23 Although three different
coaters are used to apply a wide variety of liquid coatings, there is not
a wide variation in coating line speeds, amount of coating applied, or
dry coating thickness as can be seen by Table 3-5.
The line utilization rate is the amount of time the coating equip-
ment is in operation during a working day and is directly related to the
length of substrate rolls, the time required to change rolls, any downtime
due to process upsets, and product demand. The line utilization rate for
captive coating lines tends to range between 80 and 90 percent of a given
shift.4,5 Commission coaters generally have more product changes to
implement, and the time required to implement product changes may result
in lower utilization rates. Commission coaters may only use their
coating equipment 45 to 50 percent of a given shift.3-5
3.3.5 Drying
Liquid coatings must be solidified by evaporating the solvent, or in
the case of plastisols, causing the plasticizers to diffuse into the PVC
resin. This is accomplished by passing the coated substrate through a
drying oven. Drying ovens may be vertical or horizontal and range from 4
3-14
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TABLE 3-5. COATING APPLICATOR PARAMETERS2
Coater
Coating type
Line
speed,
meters/min
(yards/min)
Dry coating
thickness,
pin (mils)
Knife-over-roll
Dip
Reverse roll
Rubber (natural & synthetic)
Urethane
Vinyl
Silicone
Acrylic
Rubber (natural & synthetic)
Epoxy
Phenolic
Silicone
Vinyl
Urethane
6.1-23
(6.7-25)
1.5-40
(1.7-43)
13.7-64
(15-70)
75-500
(3-20)
25-2,000
(1-80)
25-1,250
(1-50)
-------
to 8 feet in width and 20 to 100 feet in height or length.6 They may be
steam heated or direct fired but usually involve some kind of forced air
convection system utilizing impingement nozzles. The air turbulence dries
the coating surface and prevents dead spots in the oven where the tempera-
ture or solvent vapor concentration might build up to a dangerous level.
Most ovens are single zoned; however, the temperature usually
increases between the oven entrance and exit. Multizoned ovens are used
where discretely different temperatures or residence times at particular
temperatures are necessary to complete the cure. Multizoned ovens are
also used when more than one coating application station exists in the
coating line.
A key design and operating parameter is the percentage of the lower
explosive limit (LEL) of the solvents that must be maintained inside the
oven for safe operation. Insurance companies require that solvent borne
coating lines maintain the solvent concentration in the oven at 25 percent
or less of the LEL if the solvent concentration in the drying oven is not
continuously monitored.29 Historically, most polymeric coaters have
operated their ovens at less than 25 percent of the LEL and at relatively
high airflow rates ranging from 3,000 to 15,000 scfm.4,30 The high
airflows allowed for future increases in production or higher solvent
load to the oven. Recently, advances in oven design and monitoring
instrumentation, spurred by rapidly rising fuel cost, have enabled
manufacturers to increase solvent concentrations up to 50 percent of the
LEL while allowing for varying solvent loads.29
Some rubber coated substrates require subsequent curing or vulcanizing.
One procedure is to drape the coated substrate on tiers in a festoon oven
that is heated up to 280°F for 1 to 12 hours. Another procedure is to
wind the coated substrate within a special nonadhering paper and cure as
a roll in a large autoclave.31
Some polymeric coaters that apply higher solids coatings are using
ultraviolet or electron beam curing.32 In ultraviolet curing, ultra-
violet light reacts with photosensitizers in the coating to initiate
crosslinking to form a solid. The electron beam curing process uses high
energy electrons to promote curing of electron beam-curable'coatings.
3-16
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For both curing methods, there is a substantial decrease in energy usage
compared with thermal curing.33
3.3.6 VOC Emissions
3.3.6.1 Sources of Emissions and Factors Affecting Emissions. The
VOC emissions from polymeric coating of supporting substrates are primarily
solvents and trace amounts of plasticizers and reaction by-products
(cure volatiles). Solvents are used in coatings and during cleanup of
the coater and ancillary equipment. The VOC emissions are released from
several points in the coating operation and these sources are identified
in Figure 3-1.
The VOC emissions from outdoor solvent storage tanks occur as
working losses during filling and breathing losses due to diurnal
temperature changes. The rate of these emissions depends on the tank
size, solvent vapor pressure, solvent throughput, magnitude of temperature
changes, and presence of conservation vents.
In the coating preparation area, VOC's are emitted from the individual
mixers and holding tanks during: (a) the filling of mixers, (b) transfer
of the coating, (c) intermittent activities such as changing the filters
in the holding tanks, and (d) mixing if the equipment is not equipped
with tightly fitting covers. The emissions may be intermittent or
continuous, depending on whether the method of coating preparation is
batch or continuous.
Emissions from the coating application area result from the
evaporative loss of solvent around the coating application area during
transfer and application of coating and from the exposed substrate as it
travels from the coater to the drying oven entrance (flashoff). The
length of the flashoff is within the same range for all polymeric coating
lines, despite the type of coating used and product produced. The
magnitude of these losses is a function of the amount of solvent in the
coating as well as line width and speed, coating thickness, volatility
of the solvent(s), temperature, distance between coater and oven, and
air turbulence in the coating area.
In the drying oven, the rate of evaporation of solvent is affected
by the temperature, airflow rate and direction, and the line speed. The
airflow rate is always adjusted to keep the VOC concentration below the
LEL. All but a very small fraction of the solvent from the coating
3-17
-------
evaporates in the oven, and there are virtually no solvent emissions
from subsequent production steps. Some plasticizers and reaction by-
products may be emitted if the coating is subsequently cured or vulcanized.
These emissions are usually negligible compared to the total emissions
from the operation.34
Information obtained in the development of new source performance
standards for the manufacturing of magnetic tapes was utilized to determine
the apportionment of emissions between the coating preparation equipment
and the coating line.35 Because both polymeric coating and magnetic
tape manufacturing are web coating processes using similar types of
solvents, it has been assumed that the ratio of emissions from the
coating preparation equipment and the coating line is the same for both
types of coating processes. In the magnetic tape manufacturing process,
it was estimated that of the total emissions, approximately 10 percent
are emitted from the coating mix preparation equipment and 90 percent
from the coating operation. This ratio of emissions from these two
areas has been assumed to be applicable for facilities performing polymeric
coating of substrates. This estimate was confirmed by a coating mix
preparation equipment vendor.36
Information on 18 facilities shows that the amount of solvent used
for cleaning of coating equipment in 1979 varied from 0 to 14 percent of
the total solvent used at the plants; the average was 3.5 percent.37
Much of this solvent stays in the liquid phase and can be reused or is
stored or disposed in accordance with solid waste and water quality
regulations.
3.3.6.2 Emission Estimates. Potential uncontrolled emissions from
polymeric coating operations were estimated from data on the total
amount of solvent used by polymeric coating plants. Information on
solvent usage was obtained from 32 plants using solvent borne coatings.
These data were reduced to determine the average solvent usage per
coating line per shift. This number was scaled to estimate the annual
solvent usage for an individual plant and on a nationwide basis for this
source category. The estimated average uncontrolled VOC emissions from
a polymeric coating line using solvent borne coating would 6e 155 Mg
(170 tons) per year. Potential uncontrolled VOC emissions from coating
3-18
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lines are estimated to range from 0 to 3,000 Mg (0 to 3,300 tons) per
plant. Potential nationwide uncontrolled VOC emissions were estimated to
range from 29,000 to 35,000 Mg (32,000 to 39,000 tons).37
3.4 BASELINE EMISSION LEVEL
The baseline emission level represents the level of control that is
required under existing State and local regulations. The baseline is
used to evaluate the impacts of the regulatory alternatives to be selected
for analysis.
3.4.1 Existing Emission Limits
Table 3-6 summarizes the State and local regulations for VOC emissions
applicable to plants with facilities that apply polymeric coatings to
supporting substrates. Of the 30 States that have plants with polymeric
coating facilities, 22 States (with 112 facilities) limit VOC emissions
to 0.35 kilogram per liter (kg/2) (2.9 Ib/gal) of coating applied,
excluding water. This emission limit is recommended by the control
techniques guideline (CTG) document.38 Three of the 30 States having
polymeric coating plants have no VOC emission limits that apply to this
source category. The remaining five States require intermediate levels
of VOC control.
Twenty States do not have existing polymeric coating plants. Of
these States, three have applicable VOC emission limits of 0.35 kg/£
(2.9 Ib/gal) of coating applied, excluding water. Two of these three
have exemptions for sources using or emitting less than a specified
amount of coating or VOC's. Thirteen of the 20 States that do not have
existing polymeric coating plants have no VOC emission limits that apply
to this source category. The remaining four States require intermediate
levels of VOC control.
3.4.2 Determination of Baseline Emission Levels
The baseline emission level for the coating operation is considered
to be an allowable VOC emission limit of 0.35 kg/£ (2.9 Ib/gal) of
coating for a typical formulation. This is the average of the State
regulations when each emission limit was weighted by the number of
existing polymeric coating plants in that State.39
3-19
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TABLE 3-6. STATE REGULATIONS FOR VOC EMISSIONS FROM
POLYMERIC COATING SOURCES 39
No. of
plants
State per State
Alabama
Alaska
Arizona
Arkansas
California0"
Colorado
Connecticut
Oeleware
District of Columbia
Florida
Georgia
Hawai i
Idaho
11 linois
Indiana
Iowaf
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
1
—
—
2
7
1
7
--
--
1
7
—
—
3
2
1
1
—
—
1
19
2
1
1
2
—
—
--
3
7
—
10
6
~
13
—
Air pollution regulation reference
Regulation (Environment Reporter)
1
b
b
2,3,4
1
1
1
d
1
1
b
b
e
1
b
5
1
b
1
1
1
b
b
1
b
b
b
1
1
b
1
1
b
1
g
Ch. 6.1.1.6 and Ch. 6.1.1.7. March 23, 1982.
November 1, 1982.
February 2, 1982.
Sec. 5.5. September 26, 1980.
November 11, 1982. Reg. 7 IX.
Sec. 19-508-20(0) and Sec. 19-508-20(0.) January 2, 1975.
Regulation XXIV, Section 9. October 8, 1982.
Sec. 8-2:707(F). February 26, 1981.
17-2.650(1). December 30, 1982.
391-3-1-0. 02(w) and 391-3-l-0.02(x). August 27, 1982.
May 13, 1976.
October 1, 1979.
Rule 205(f).
Article 8, Rule 2, November 8, 1982.
November 17, 1982.
May 1, 1982.
401 KAR 59:210, 401 KAR 61:120, 401 KAR 59:214 and
401 KAR 61:124. January 14, 1983.
Sec. 22.9.2. January 27, 1983.
December 22, 1982.
Sec. 10.18.21.07. December 27, 1982.
Sec. 7.18(14), Sec. 7.18(15), Sec. 7.18(16), and
Sec. 7.18(17). December 31, 1982.
Part 6, Table 63 and R 336.1620. December 31, 1982.
November 8, 1982.
December 8, 1982.
Ch. 2 and Ch. 5. November 11, 1982.
June 1, 1981.
August 6, 1982.
July 1981.
Part 1204.05 and Part 1204.06. July 20, 1982.
7:27-16.5. March 1, 1982.
November 24, 1980.
Parts 228.3, 228.7, and 228.8. May 10, 1981.
Regulation 0.0920, 0.0921, and 0.0935. December 1, 1982
July 1, 1982.
3745-21-09(F), (G), (H). December 3, 1982.
Regulation 3.7.3(A)(1). April 9, 1982.
(continued)
3-20
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TABLE 3-6. (continued)
State
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
No. of
plants
per State
—
2
7
8
--
5
3
—
1
3
—
—
3
—
Regulation3
2,3,4
2,3,4
1
1
b
1
1
1
1
1
2,3,4
b
1
b
Air pollution regulation reference
(Environment Reporter)
340-22-170. January 22, 1982.
Sec. 129.52. January 7, 1983.
APC Regulation 19. April 5, 1982.
Standard No. 5, Sec. II(C), and (G). December 16, 1982.
March 18, 1982.
Ch. 1200-3-18-0.06, 0.14 and 0.20. February 1, 1982.
Regulation V. February 16, 1982.
Part IV. July 29, 1982.
Subch. 1, 5-253. November 3, 1981.
Rule Ex-5, 4.55. March 1, 1983.
Ch. 173-490 and WAC 173-490-207. December 31, 1981.
April 8, 1982.
NR 154.13(E), (F), and (K). December 1, 1982.
August 26, 1981.
Following regulations are applicable for fabric coating facilities:
Regulation 1: 0.35 kg/2 (2.9 Ib/gal) of coating, minus water, delivered to coating applicator.
Regulation 2: 0.52 kg/2 (4.3 Ib/gal) of coating, minus water, delivered to a coating applicator
that applies a clear coating.
Regulation 3: 0.42 kg/2 (3.5 Ib/gal) of coating, minus water, delivered to a coating applicator
that utilizes air or forced air dryers and that applies extreme performance coatings.
Regulation 4: 0.36 kg/2 (3.0 Ib/gal) of coating, minus water, delivered to a coating
applicator for all other coatings.
.Regulation 5: No more than 15 percent by weight of VOC's net input into an affected facility.
National ambient air quality standards only.
^Pending.
No discharge to atmosphere of more than 15 Ib of photochemically reactive solvents in one day or
3 Ib in 1 hour unless uncontrolled organic emissions are reduced by 85 percent. No discharge to
atmosphere of more than 40 Ib of nonphotochemically reactive solvents in 1 day or 8 Ib in 1 hour
unless uncontrolled organic emissions are reduced by 85 percent.
No discharge to atmosphere of >8 Ib per hour of organic material from any emission source, except'
if controlled: (1) By flame, thermal, or catalytic incineration to reduce emissions to S10 ppm
equivalent methane or convert 85 percent of hydrocarbons to CO, and H20. (2) By vapor recovery to
control 85 percent of total uncontrolled organic material. (3) By any other air pollution control
.equipment capable of 85 percent reduction of uncontrolled organic material.
Emissions from painting and surface coating operations—0.01 grain of particulate per standard
cubic foot of exhaust gas.
^(a) No discharge to atmosphere from any coating line or operation using: Alkyd Primer, 4.8 Ib/gal;
vinyls, 6.0 Ib/gal; NL lacquers, 6.4 Ib/gal; Acrylics, 6.0 Ib/gal; Epoxies 4.8 Ib/gal; maintenance
finishes, 4.8 Ib/gal; custom product finishes; 6.5 Ib/gal. (b) An owner or operator may develop a
plant-wide emission plan instead of for each coating line, (c) No discharge of more than 3,000 Ib of
organics in one day or more than 450 Ib in 1 hour, (d) 90 percent reduction by incineration.
(e) 85 percent reduction by adsorption or any process of equivalent reliability and effectiveness.
3-21
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To comply with the State regulations, polymeric coating plants may
either install an abatement device, use low-VOC-content coatings, or
both. Typically, when a control device is used, only emissions from the
drying oven are controlled; emissions from the coating preparation
equipment and solvent storage tanks are not ducted to the control device.
Therefore, the baseline emission levels for solvent storage tanks and
coating preparation equipment are considered to be the uncontrolled
emission levels. For coating operations, the baseline emission level is
considered to be the level attained by controlling drying oven emissions.
3.5 REFERENCES FOR CHAPTER 3
1. Kirk-Othmer Encyclopedia of Chemical Technology. Volume 6. John
Wiley and Sons. Third Edition. 1978. pp. 377-386.
2. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. July 9, 1984. Information summarizing
the name and locations of each plant, type of coating used, number
of coating lines, major end products, and whether or not the plant
is a commission coater.
3. Reference 2, p. 9.
4. Letter from Hindle, M., The Kenyon Piece Oyeworks, Inc., to
Grumpier, D., EPA:CPB. March 23, 1984. Information provided about
1983 monthly solvent recovery efficiency data and factors affecting
commission coaters.
5. Telecon. Maurer, E., MRI, with Swain, R., Lembo Corporation.
March 7, 1984. Information on coating equipment design and operation.
6. Telecon. Maurer, E., MRI, with Leach, A., Indev Machinery Division.
March 7, 1984. Information on coating equipment design and operation.
7. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 26, 1984. Summary of information
on polymeric coatings used in the coating of supporting substrates.
8. Telecon. Thorneloe, S., MRI, with Walsh, W., Ph.D, Associate Dean
for Research and Graduate Studies, North Carolina State University.
March 12, 1984. Information regarding trends in solvent usage in
polymeric coating operations.
9. U. S. Environmental Protection Agency. Glossary for Air Pollution
Control of Industrial Coating Operations. Second Edition. EPA-450/
3-83-013R. December 1983. p. 23.
10. Reference 9, p. 9.
3-22
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11. Reference 9, p. 22.
12. Telecon. Maurer, E., MRI, with Hartenstein, R., President, Custom
Coated Products, Division of Hartco. November 29, 1983. Information
regarding the conversion by this plant to 100 percent solid PVC
coatings.
13. Telecon. Maurer, E., MRI, with Venkataraman, Vice President,
Seaman Corp., Shelterite Division. January 3, 1984. Information
on a solventless "hot melt" (calendering) process.
14. Telecon. Maurer, E., MRI, with Schoen, W., Armstrong Cork Company.
December 19, 1983. Information on a solventless rubber coating
operation.
15. Telecon. Maurer, E., MRI, with Gilbert, R., and D. Phillips, Reef
Industries, Inc. January 19, 1984. Information on an extrusion
operation.
16. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 19, 1984. Summary of nonconfidential
information regarding solvent storage tanks at polymeric coating
plants.
17. Telecon. Friedman, E., MRI, with Coffey, F., Southern Tank and
Pump Company. August 23, 1984. Information on solvent storage
tanks.
18. Telecon. Friedman, E., MRI, with Mueller, J., Southeast Regional
Manager, Day Mixing Company. June 5, 1984. Information regarding
plastisol coatings.
19. Telecon. Maxwell, C., MRI, with Raffi, C., Vice President, Raffi
and Swanson, Inc. July 15, 1983. Information regarding retail
customized coatings.
20. Memorandum from Newton, D., MRI, to Grumpier, D., EPA:CPB. July 22,
1983. p. 3. Report on site visit to Aldan Rubber Company, Philadelphia,
Pennsylvania.
21. Memorandum from Maxwell, C., MRI, to Grumpier, D., EPA:CPB. June 24,
1983. p. 2. Report on site visit to Reeves Brothers, Inc., Buena
Vista, Virginia.
22. Memorandum from Thorneloe, S., MRI, to Grumpier, D., EPArCPB.
March 2, 1984. p. 6. Report of site visit to Utex Industries,
Inc., Weimer, Texas.
23. Holden, V., Manufacturing Methods Give Coated and Laminated Fabrics
Their Character. Industrial Fabric Products Review. September 1983.
pp. 60-62.
3-23
-------
24. Grant, R., Coating: Science, Engineering, or Art? Journal of
Coated Fabrics. 11:80. October 1981.
25. Grant, R., Coating and Laminating Industrial Fabrics. Journal of
Coated Fabrics. 12:196-212. April 1983.
26. Grant, R., Coating and Laminating Applied to New Product Development.
Journal of Coated Fabrics. 10:232-253. January 1981.
27. U. S. Environmental Protection Agency. Control of Volatile Organic
Emissions from Existing Stationary Sources—Volume II: Surface
Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty
Trucks. EPA-450/2-77-008. May 1977.
28. Telecon. Maurer, E., MRI,with Salos, E., Archer Rubber Company.
March 15, 1984. Information on rubber-coating operations.
29. Reference 23, p. 79.
30. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. May 9, 1984. Process parameters for
plants using control devices while applying polymeric coatings to
supporting substrates.
31. Reference 20, p. 6.
32. Kardashian, R. Electron Processing for the 1980's. Journal of
Coated Fabrics. 11:131-136. January 1983.
33. Reference 26, pp. 90-93.
34. U. S. Environmental Protection Agency. Flexible Vinyl Coating and
Printing Operations—Background Information for Proposed Standards.
EPA-450/3-81-016a. January 1983. pp. 3-12 - 3-13.
35. Memorandum from Meyer, J., MRI, to Magnetic Tape Project File.
August 1, 1983. Distribution of emissions between mix preparation
and the coating line.
36. Telecon. Friedman, E., MRI, with Mueller, J., Day Mixing Company.
June 5, 1984. Information on coating preparation equipment.
37. Memo from Maurer, E., MRI, to Elastomeric Coating of Fabric Project
File. April 12, 1984. Estimated solvent consumption at facilities
performing elastomeric coating of fabrics.
38. U. S. Environmental Protection Agency. Control of Volatile Organic
Emissions from Existing Stationary Sources—Volume I: Control
methods for surface-coating operations. EPA-450/2-76-028.
November 1976.
3-24
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39. Memorandum from Maurer, E., MRI, to Polymeric Coating of Supporting
Substrates Project File. April 19, 1984. Baseline emissions
level.
3-25
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4. EMISSION CONTROL TECHNIQUES
4.1 INTRODUCTION
The VOC emissions from polymeric coating of supporting substrates
result primarily from evaporative losses of solvent from solvent storage
tanks, coating mix preparation equipment, the application/flashoff area,
and the drying oven. A small amount of solvent may be retained in the
final product. As stated in Chapter 3, some of the VOC's emitted may be
reaction by-products rather than evaporative losses. However, the
control techniques for these emissions are no different from the control
of evaporative emissions. Emission control approaches consist of a VOC
capture system and an emission control device or the use of low-solvent
coatings. The first approach requires two separate steps: capture of
the emissions and removal of the emissions from the solvent laden air
stream.
This chapter describes the technology available for capture and
control of emissions from all of the sources mentioned above and the
expected levels of control achievable. The use of low-solvent coatings
is also discussed.
4.2 VOC EMISSION CAPTURE SYSTEMS
A capture system combines one or more capture devices to collect
VOC emissions and deliver them to a control device. Capture efficiency
is defined as the fraction of all organic vapors generated by a process
that are directed to a control device. The capture of emissions is
broken into two major categories. These are: (1) capture from solvent
storage tanks, coating mix preparation equipment, and drying oven; and
(2) capture from the coating application/flashoff area. Emissions from
the first category can be easily captured using ductwork for storage
4-1
-------
tanks, a combination of covers and ductwork for coating mix preparation
equipment, and installing leak-proof ovens with ductwork. Emissions
from the application/flashoff area may be captured by local ventilation
techniques such as hoods, floor sweeps, air intake ducts, and by partial
and total enclosures.
4.2.1 Emission Capture Systems for Solvent Storage Tanks, Coating Mix
Preparation Equipment, and Drying Ovens
It is relatively simple to capture VOC emissions from sources such
as solvent storage tanks, covered coating mix preparation equipment, and
drying ovens. All VOC emissions from solvent storage tanks can be
captured using standard valves and ductwork and vented to a control
device. While no polymeric coating plant has been identified that is
employing this capture technology, it is common in other industries that
store organic solvents, such as the magnetic tape manufacturing industry.
The VOC emissions from coating mix preparation equipment may be
captured in a similar manner. By tightly covering and venting the
coating mix preparation equipment (i.e., mixers and holding tanks) to a
control device, effective capture of emissions can be achieved with a
minimum airflow rate. The solvent laden air discharged from the coating
preparation equipment can be used as part of the oven make-up air, or it
can be vented directly to the control device.
At least eight polymeric coating plants are known to use covered
coating preparation equipment. Three plants are known to duct coating
mix preparation equipment emissions to a control device.1,2 At one
plant, all coating mix preparation equipment is covered. Whenever the
covers are opened, dampers in the ductwork are opened, and the emissions
are vented to the carbon adsorber. The draft created by the control
device blower is sufficient to cause a slight negative pressure in the
coating mix preparation equipment ductwork so that emissions are drawn
to the control device.2
Emissions from drying ovens may also be captured using relatively
simple capture systems. Well-designed and -operated ovens are maintained
at slightly negative pressure to prevent leakage and reduce loss of oven
»
gases containing VOC emissions through substrate inlet and outlet openings.
Large pressure differentials are avoided to prevent unnecessary dilution
4-2
-------
dilution of oven exhaust. The solvent laden air in the oven exhaust is
drawn into the oven ductwork and may be recirculated in the oven before
it is directed to a control device. This recirculation allows faster air
velocities and therefore better drying conditions and more efficient use
of energy needed to heat the air.
4.2.2 Emission Capture Systems for the Application/Flashoff Area
The coating application/flashoff area requires more complex systems
to capture VOC emissions. The types of capture systems employed at
polymeric coating plants and at plants in other web coating industries
include local ventilation, partial enclosures, and total enclosures.
4.2.2.1 Local Ventilation Systems. Local ventilation systems are
the most widely used capture systems at polymeric coating plants. Their
efficiencies vary widely because of the sensitivity of such systems to
their design.
An efficient local ventilation capture system should maximize the
collection of VOC emissions, minimize the collection of dilution air, and
maintain an adequate ventilation rate in the work place. The factors
important in designing an efficient capture system include:
1. Degree of turbulence;
2. Capture velocity; and
3. Selectivity of collection.
Although these factors are interdependent, each one will be discussed
separately.
Turbulence in the air around a VOC emission source will make
effective collection much more difficult. Turbulence dilutes the solvent
laden air stream and contributes to the transport of VOC away from the
capture device. Sources of turbulence that should be recognized and
minimized include:
1. Thermal air currents;
2. Machinery motion;
3. Material motion;
4. Operator movements;
5. Room air currents; and
6. Spot cooling and heating of equipment.
4-3
-------
The velocity necessary to collect contaminated air and draw it into
a capture device is called the capture velocity. At capture velocity,
the inflow of air to the capture device is sufficient to overcome the
effects of turbulence and thereby minimize the escape of contaminated
air. Empirical testing of operating systems has been used to develop the
guidelines for capture velocity presented in Table 4-1.3
Selectivity describes the ability of the capture system to collect
pollutants at their highest concentration by minimizing the inflow of
clean air. A highly selective system will achieve a high capture
efficiency using low airflow rates. Low airflow rates result in systems
that are relatively economical to operate, and the increased VOC concen-
tration in the air stream ducted to the control device reduces the cost
of emission control.
One method of improving selectivity is the use of flanges in hood
design to reduce turbulence, thereby minimizing airflow from areas of low
concentration. This technique can reduce dilution air by as much as
25 percent.4 Flanges lower the pressure drop at the hood by altering the
coefficient of entry (C ). The coefficient of entry is a measure of the
degree of turbulence caused by the shape of the opening. A perfect hood
with no turbulence losses would have a coefficient of entry equal to one.
Table 4-2 gives coefficients of entry for selected hood openings.5
Another method of improving selectivity is to minimize the distance
between the emission source and the capture device. Using local ventila-
tion systems requires higher capture velocities than using total or
partial enclosures, resulting in larger quantities of air being ducted to
the control device. Most local ventilation systems cannot be installed
close enough to the emission source to achieve a high capture efficiency
at a low airflow rate. Some systems locate air intake ducts as close to
the emission source as 0.15 meter (m) (0.5 foot [ft]), while other
systems suspend overhead hoods 0.3 to 1.5 m (1 to 5 ft) above the
emission source and place floor sweeps underneath the source. Some
plants rely on air intake created by the drying oven to provide the local
ventilation for the coating application/flashoff area (and sometimes the
entire coating room).1 Turbulence, cross-drafts, and natural diffusion
and convection are quite common for the reasons discussed above. A larger
4-4
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TABLE 4-1. RANGE OF CAPTURE VELOCITIES3
Capture velocity
Condition of dispersion of contaminant m/s (fpm)
Released with little velocity into quiet air 0.25-0.51 (50-100)
Released at low velocity into moderately still 0.51-1.02 (100-200)
air
Active generation into zone of rapid air motion 1.02-2.54 (200-500)
Released at high initial velocity into zone of 2.54-10.2 (500-2,000)
very rapid air motion
4-5
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TABLE 4-2. COEFFICIENTS OF ENTRY FOR SELECTED HOOD OPENINGS3
Hood type
Description
7 IX
Plain opening 0.72
Flanged opening 0.82
Bell mount inlet 0.98
4-6
-------
and more costly control device is, therefore, needed to process the
larger airflows necessary to improve capture.
Current practice in this industry is to vent all or part of the
emissions directly to the atmosphere rather than to a control device
primarily because State and local regulations do not require the capture
and control of VOC emissions from these sources. In cases where the
plant does not have a control device, local ventilation systems are used
to maintain a safe working environment. However, it would be technically
feasible to duct emissions to a control device rather than to the
atmosphere.
4.2.2.2 Partial Enclosures. Partial enclosures exhibit a wide
range of capture efficiencies depending on their design and the required
capture velocities. Partial enclosure systems observed in similar
industries consist of flexible vinyl strips hung around the coating
application/flashoff area to form a curtain. The curtain helps to
eliminate cross-drafts and VOC emissions are captured inside the
enclosure using local ventilation. Partial enclosures achieve equal or
better capture efficiencies at lower airflow rates than local ventila-
tion systems. The emissions may be .vented through the drying oven and
then to the control device or directly to the control device.6
One polymeric coating plant installed a partial enclosure composed
of a 10-foot-high panel of silicone-coated fiberglass strips that
surrounds the dip tank. The top of the enclosure is bounded by the base
of a vertical drying tower (vertical oven) so the flashoff area is within
the enclosure. Canopy hoods are positioned above the dip tank, and
solvent laden air drawn into the hoods is exhausted to the atmosphere.
However, the remaining VOC emissions contained by the enclosure are drawn
into the drying tower and from there to the control device.7
4.2.2.3 Total Enclosures. The most effective emission capture
system is a total enclosure surrounding the emission source. A ventila-
tion system can be designed so that the room containing the coating
preparation equipment or application/flashoff area functions as a total
enclosure. By closing all doors and windows, the room may be evacuated
either by the draft from the oven(s) or by exhaust ducts. The room
ventilation exhaust can be directed to the control device, or to the oven
4-7
-------
which is served by a control device. One polymeric coating plant is
known to use room ventilation to capture emissions from the application/
flashoff area.1 At this plant, the coating operation is contained in a
room that is kept at negative pressure. There is an indraft of about
0.25 to 0.51 m/s (50 to 100 fpm) at the room openings. The capture of
emissions from the coating application/flashoff area is augmented by the
use of floor sweeps, which are located along the coating operation, with
inlet velocities of 1.52 m/s (300 fpm). Ventilation ducts are located
directly under the flashoff area to capture emissions. The captured
emissions are vented to the oven to serve as make-up air and then to a
control device.8
A total enclosure may also be designed as a small room surrounding
the emission source or as a "glove box" whose shape roughly conforms to
the shape of the equipment. Total capture may not be obtained at all
times, however, because of turbulence or back drafts caused by the
opening of enclosure doors during operation.
The VOC emissions that are contained by the enclosure are ducted to
the oven to serve as make-up air or directly to the control device.
When the captured emissions are used as oven make-up air, the total
airflow to the control device is reduced in comparison to systems that
duct air from the application/flashoff area to the control device through
independent ductwork. In some cases, the draft from the oven opening at
the substrate entrance is sufficient to draw the captured emissions into
the oven without the use of additional ducts.9 Using ventilation air as
oven make-up air increases the VOC concentration in the solvent laden
air that is ducted to the control device, and the potential size of the
control device required to treat the solvent laden air may be smaller.
One polymeric coating plant uses a total enclosure designed as a small
room that captures emissions from the coating application/flashoff
area.9
The most common substrate, fabric, is relatively nonhomogeneous (as
compared to paper or film), and polymeric coating plant personnel claim
that the coating process may require the constant attention of an operator.
Insecure seams and fabric imperfections may result in tension tears.
The lack of uniform substrate thickness may require continuous tension
4-8
-------
adjustments. For these reasons, it may be necessary for workers to have
immediate access to the enclosed area in the event of a web break or
other problem. The efficient operation of a small room or "glove box"
total enclosure depends upon the enclosure doors being closed. Estimates
of the number of times during a shift that a worker would need access to
the coating application/flashoff area ranged from 8 to 150. A representa-
tive of one plant stated that an operator would have to be stationed at
the application/flashoff area.10
A room ventilation type of total enclosure could be used to allow
frequent or continuous worker access, and fresh air could be supplied to
operators stationed within the enclosure. Although such a system was
not observed in use at a polymeric coating plant, it would reduce the
airflow rate to the control device in comparison to room ventilation and
would provide for worker safety. Fresh air supply systems are currently
used at plants in at least two spray coating industries and could be
adapted to polymeric coating plants.
The ventilation systems described above can be designed to capture
emissions from the wide range of coating processes found in this source
category.
4.3 VOC EMISSION CONTROL SYSTEMS
The emission control devices used by polymeric coating plants are
listed in Table 4-3.ll The technologies used to control VOC emissions
are carbon adsorption, condensation, and incineration. The theory,
design characteristics, and principles of operation of these control
devices are discussed in the following sections, with emphasis on factors
affecting their application in polymeric coating plants. Emissions from
the coating line are commonly controlled using these devices. Three
plants control emissions from the coating mix preparation equipment by
ducting them to a carbon adsorber used to control coating operation
emissions.2 It would also be possible to duct emissions from a solvent
storage tank to one of these control devices, although no tanks at
polymeric coating plants are known to be controlled by this method at
the present time.
4-9
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TABLE 4-3. VOC EMISSION CONTROL DEVICES USED BY
POLYMERIC COATING PLANTS11
Control device
No. of
control devices
Percentage
Carbon adsorber
Fixed-bed
Fluidized-bed
Condensation system
Inert atmosphere
Air atmosphere
Incinerator
Catalytic
Thermal
Type not specified
Total
9
J.
10
2
1
—
9
16
1
26
39
25
67
100
4-10
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4.3.1 Carbon Adsorption
Carbon adsorption has been used for the last 50 years by many
industries to recover a wide variety of solvents from solvent laden air
streams.12 Carbon adsorbers reduce VOC emissions by adsorption of
organic compounds onto the surface of activated carbon. The high
surface-to-volume ratio of activated carbon and its preferential affinity
for organics make it an effective adsorbent of VOC.13 The organic
compounds are subsequently desorbed from the activated carbon and
recovered. The two types of carbon adsorbers are fixed-bed and
fluidized-bed.
4.3.1.1 Fixed-Bed Carbon Adsorbers. For most of the 50 years that
carbon has been used as a commercial adsorbant, it has been available
only in a fixed-bed process. The typical depth of the carbon bed is 20
to 25 centimeters (cm) (8 to 10 inches [in.]), and the bed is supported
within a vertical or horizontal cylindrical metal vessel. The solvent
laden air is fed into the bed, and the organics are adsorbed as the air
passes through the bed. Most fixed-bed adsorbers have multiple beds in
separate cylinders to allow simultaneous adsorption and desorption and,
thus, continuous operation. Figure 4-1 is a schematic of a two-unit
fixed-bed adsorber.14 When the VOC concentration in the air discharge
from a bed starts to increase, or at a preset time interval, the inlet
solvent laden air is routed to a different carbon bed, and the nearly
saturated bed is regenerated. Regeneration is usually accomplished using
low pressure steam. The steam heats the bed to desorb the solvents and
acts as a nonflammable carrier gas. Typical steam requirements range
from 4 to 9 kilograms (kg) of steam per kg of recovered solvent (4 to
9 pounds [Ib] of steam per Ib of recovered solvent).12,15 After regen-
eration, the carbon bed is dried and cooled to improve the ability of the
carbon to adsorb organic compounds. The mixture of steam and organic
vapors exhausts from the adsorber and is condensed in a heat exchanger;
the condensate is routed to a decanter (see Figure 4-1) or to a holding
tank if the condensate is water-miscible. In the decanter, the solvent
floats on the sol vent-insoluble water layer. Both water and organics are
drawn off to separate storage or further treatment. Distillation is
necessary in the case of a water-miscible condensate.
4-11
-------
-P.
i—•
ro
SOLVENT-LADEN AIR
UNIT 1 ON
ADSORBING CYCLE
\i
CARBON
STEAM
_f \
—txj-
CONDENSER
-tXr—
UNIT 2 ON
REGENERATING CYCLE
OPEN
CLOSED
DECANTER
TOP-PHASE LIQUID
BOTTOM-PHASE LIQUID
SOLVENT-FREE AIR
Figure 4-1. Flow diagram of a two-unit, fixed-bed adsorber.1
-------
The interdependent parameters considered in the design of a fixed-bed
carbon adsorption system are:
1. Type of solvent(s);
2. Drying oven exhaust outlet temperature;
3. Control device solvent laden air inlet temperature;
4. Solvent laden air inlet concentration;
5. Solvent laden air inlet flow rate;
6. Type and amount of carbon;
7. Superficial bed velocity;
8. Bed pressure drop;
9. Cycle time;
10. Degree of regeneration of the carbon bed; and
11. Pressure and temperature of steam.
The first five parameters are characteristics of the production process.
The next three are design parameters for the adsorber. The remaining
parameters are operating variables that may affect the performance of the
adsorber. Table 4-4 presents process parameters representative of
polymeric coating plants controlled by carbon adsorbers.11
Major problems encountered in the operation of fixed-bed carbon
adsorbers in polymeric coating plants are: fouling of beds, corrosion,
and excessive heat buildup or bed fires. Carbon beds can be fouled by
dust or other particulate matter, high boiling compounds, high molecular
weight compounds, and compounds that polymerize or oxidize on the carbon
particles.12 Fouled carbon cannot be regenerated at normal steam
temperature and pressure. Fouling reduces adsorption efficiency and
requires early replacement of the carbon. Filtration equipment may
prevent fouling if there is dust or other particulate matter in the
drying oven exhaust.
Corrosion can be a problem in fixed-bed carbon adsorbers used to
recover solvents that are converted to acidic compounds in the wet steam.
The carbon acts as a catalyst in some of these reactions. This problem
can be overcome by the use of corrosion resistant materials, such as
stainless steel, or by switching to a less corrosive solvent.
4-13
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TABLE 4-4. PROCESS PARAMETERS FOR POLYMERIC COATING
PLANTS CONTROLLED BY FIXED-BED CARBON ADSORBERS11
Parameters Typical range
Solvent laden air
Flow rate 1.4 to 3.3 m3/s (3,000 to 7,000 scfm)
Inlet concentration <20% LEL
Inlet temperature 35° ± 6°C (95° ± 10°F)
Oven temperature 93° ± 28°C (200° ± 50°F)
|%3/s = cubic meters per second at standard conditions.
scfm = standard cubic feet per minute where standard conditions are
20°C (68°F) and 101.3 kPa (29.92 in. Hg).
4-14
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Heat buildup is perhaps the most common problem of carbon bed
operation. Adsorption is an exothermic phenomenon; typical heat genera-
tion is 465 to 700 kilojoules (kJ) per kg (200 to 300 British thermal
units [Btu] per Ib) of solvent adsorbed. At high solvent concentrations
more heat of sorption may be generated than can be dissipated by the
carrier gas. The carbon bed overheats in this situation resulting in
poor adsorption and possibly bed fires.16 The addition or replacement of
carbon to the bed also increases the tendency for the bed to overheat due
to the increase in adsorptive sites per unit of new carbon.17
Ketones are frequently associated with carbon bed fires. In
addition to a high heat of sorption, ketones react in the presence of low
concentrations of water to form acids and acid anhydrides. This exo-
thermic reaction is catalyzed by the carbon. These properties of ketones
can lead to excessive heat buildup or bed fires.
Excessive heat buildup can be avoided by adequately cooling the bed
between regeneration and adsorption cycles and by maintaining the inlet
gas temperature at or below 38°C (100°F) and the organic concentration at
or below 25 percent of the LEL. A recommended practice for operations
using ketones is to keep the relative humidity at 40 percent or higher,
which creates competition between water and the organic vapor for adsorp-
tive sites.16- The energy required to evaporate the water helps to
dissipate the heat of sorption from the organic. Some carbon beds may
contain cooling coils to continually remove heat from the carrier gas.
Many polymeric coating plants use a single solvent in coatings, and
the recovered solvent requires only decantation. A further treatment
step, distillation, is required when multiple solvents or water-miscible
solvents are used. Typical distillation systems consist of a decanter
and one or more distillation columns. Caustic drying systems are used
for the removal of small, amounts of residual water from the solvent. The
complexity and the recovery efficiency of the separation equipment will
vary with the amount of water in the recovered solvent and the desired
purity of the recovered solvent. One plant that is using multiple
solvents sends the recovered solvent to a solvent broker for separation
and purification.18 A plant that uses large amounts of s'olvent might
find it economical to separate and purify the solvents in-house.
4-15
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Volatile organic compound removal efficiencies of 95 to 97 percent
are achievable with modern designs of fixed-bed adsorbers.19,20 There
are nine fixed-bed carbon adsorbers in operation at polymeric coating
plants. Most of these units were built during the last 5 to 7 years.11
One of these units has been tested by the EPA and is described below to
illustrate the emission control efficiency achieved and the applicability
of carbon adsorption to polymeric coating plants.
Plant A installed a carbon adsorber in 1977 to control toluene
emissions from three coating lines. The solvent recovery system at
Plant A consists of three carbon beds and a decanter for solvent separa-
tion. The design flow rate for the carbon adsorption unfit is 4.7 cubic
meters per second (m3/s) (9,900 actual cubic feet per minute [acfm]) with
an inlet concentration of about 2,000 parts per million by volume (ppmv).
The average operating cycle of the carbon adsorber is 3.6 hours. Outlet
solvent concentrations ranged from 6 to 390 ppmv, depending on the degree
of staturation of the carbon bed. When the performance test was conducted,
average VOC removal efficiency was found to be in excess of 97 percent
for 5-year-old carbon.19
4.3.1.2 Fluidized-Bed Carbon Adsorbers. In fluidized-bed systems,
adsorption and desorption are both carried out continuously in the same
vessel. Figure 4-2 presents a flow diagram of a fluidized-bed carbon
adsorber.21 The system consists of a multistage, countercurrent,
fluidized-bed adsorption section; a pressure-sealing section; and a
desorption section. Nitrogen gas is used as a carrier to remove the
solvent vapors from the desorption section. The pressure-sealing section
prevents air from entering the mixture of solvent and nitrogen vapors.
The regenerated carbon is carried by air from the bottom to the top of
the column via an external duct.
The solvent laden air is introduced into the bottom of the
adsorption section of £he column and passes upward countercurrent to the
flow of carbon particles. Adsorption occurs on each tray as the carbon
is fluidized by the solvent laden air. The carbon flows down the column
by a system of overflow weirs. Below the last tray, the carbon falls to
«
the desorption section where indirect heating desorbs the organic
compounds from the carbon; hot nitrogen gas passes through the bed
4-16
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CLEAN AIR
ADSORPTION
SECTION
PRESSURE-SEALING
SECTION
OESORPTION
SECTION
(SHELL-AND-
TUBE HEAT
EXCHANGER)
MIXTURE OF SOLVENT
AND NITROGEN VAPORS
NITROGEN
RECYCLE
BLOWER
AIR LIFT AIR LIFT NOZZLE
BLOWER FOR CARBON RECYCLE
-> CARBON FLOW
Figure 4-2. Fluidized-bed carbon adsorber.21
4-17
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countercurrent to the flow of carbon flow and removes organic compounds.
The desorption temperature is normally around 121°C (250°F) but can be
raised to 260°C (500°F) to remove buildup of high-boiling materials. The
desorption section is maintained continuously at the temperature required
to volatilize the adsorbed compounds.22 The solvent and nitrogen mixture
is directed to a condenser where the solvent can be recovered for reuse.
The nitrogen is sent through the "secondary adsorber" (top layer of
carbon in the desorption section), which removes residual solvent from the
nitrogen, and is then recycled.
The microspherical particles of carbon used in a fluidized-bed are
formed by spray-drying molten petroleum pitch. The carbon particles are
easily fluidized and have strong attrition resistance.27 The adsorptive
properties of the carbon particles are similar to those of other activated
carbons.21
The interdependent parameters considered in design of a fluidized-bed
carbon adsorber are:
1. Type of solvent(s);
2. Drying oven exhaust outlet temperature;
3. Control device solvent laden air inlet temperature;
4. Solvent laden air inlet concentration;
5. Solvent laden airflow rate;
6. Superficial bed velocity;
7. Bed pressure drop;
8. Rate of carbon flow; and
9. Degree of regeneration of the carbon (bed).
The first five parameters are characteristics of the production process.
The next two parameters are characteristics of the design of the adsorber.
The eighth parameter, rate of carbon flow, is set by the operator to
achieve desired control efficiency. The remaining parameter is an
operating variable that may affect the performance of the adsorber.
Just as with the gas entering the fixed-bed, the dryer exhaust gas
(solvent laden air) must be cooled before it reaches the fluidized-bed
adsorber in order to optimize the carbon's absorptivity. The pressure
drop per stage normally ranges from 1 to 2 kilopascals (kPa) (4 to 8 in.
water column [in. w.c.]), with six to eight stages required, depending on
4-18
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the application. The pressure drop across the entire bed is 6 to 16 kPa
(24 to 64 in. w.c.). The gas velocity through the adsorption section
may be as high as 1 m/s (200 fpm), which is two to four times that used
in fixed-bed adsorbers.22
The primary problem that may occur with the operation of fluidized-bed
adsorbers is fouling of the carbon. The same factors that affect fouling
of carbon in fixed-bed adsorbers also affect the carbon used in fluidized-
bed adsorbers. Corrosion is generally not a problem in fluidized-bed
adsorbers because stripping is by nitrogen rather than by steam and the
water content of the recovered solvent is low, typically 5 percent or
less by weight. The only water present in the recovered solvent is that
which was absorbed from the solvent laden air. Thus, generally, the
carbon adsorber need not be constructed of expensive corrosion-resistant
materials. Bed fires are also not-a problem in fluidized-bed adsorbers
because the relatively high superficial velocities eliminate the possibility
of hot spot formation.
One polymeric coating plant is currently using a fluidized-bed
carbon adsorber. This unit is described below to illustrate the application
to polymeric coating plants.9
Plant B installed a fluidized-bed carbon adsorber in August 1983 to
replace a fixed-bed carbon adsorber that was subject to- frequent carbon
bed fires. The plant uses MEK exclusively. Table 4-5 lists process
parameters for the fluidized-bed carbon adsorber at Plant B.9 This unit
was tested by EPA and was found to achieve 99 percent solvent recovery
efficiency.23
The fluidized-bed carbon adsorber is sized for an inlet airflow of
5.66 m3/s (12,000 acfm). Influent VOC levels to the control device
range from 1,000 to 2,600 ppmv, and effluent levels range from 5 to
60 ppmv (averaging 15 to 20 ppmv).
The fluidized-bed carbon adsorber has been said to control emissions
of water soluble solvents because steam is not the regenerating fluid.
However, according to an EPA study, the recovered solvent may still
contain enough water (5 to 10 percent) to require further treatment.24,25
This has been the case at Plant B where humidity has proven to be a
4-19
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TABLE 4-5. PROCESS PARAMETERS OF PLANT B FLUIDIZED-BED
CARBON ADSORBER SYSTEM9
Solvent laden air
Inlet temperature, °C (°F) 57 to 66
(135 to 150)
Relative humidity, %, range 30 to 100
average 65 to 75
Inlet concentration, ppmv, design 2,600
actual 1,000 to 2,600
Outlet concentration, ppmv, range 5 to 60
average 15 to 20
Total carbon charge, kg (Ib) 4,040
(8,900)
Number of trays 8
Carbon flow rate, kg/h (Ib/h) 750 to 1,280
(1,650 to 2,815)
Pressure drop per tray 1/2 in. w.c.
Regeneration temperature, °C (°F) 222 to 223
(431 to 434)
N2 flow rate, m3/s (acfm) 0.10 to 0.12
(220 to 260)
4-20
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problem. The carbon captures a substantial amount of water, which
contains about 27 percent MEK after condensation. This water/MEK
solution is distilled to recover the solvent.
4.3.2 Condensation
Condensation is a method of recovering VOC emissions by cooling the
solvent laden air to the dew point of the solvent (or solvent mixture)
and collecting the solvent droplets. The temperature reduction necessary
to condense the solvent vapor depends on the vapor pressure and concen-
trations of the solvents in the gas stream.26 Two types of commercially
available condensation systems have been used to recover VOC emissions
from drying ovens at polymeric coating plants. These systems differ in
the design and operation of the drying oven (i.e., use of inert gas or
air in the oven) and in the method of cooling the solvent laden air
(i.e., liquified inert gas or refrigeration).
4.3.2.1 Condensation System Using Inert Gas (Nitrogen) Atmosphere.
Figure 4-3 presents a flow diagram of a condensation system using a
nitrogen-blanketed drying oven and a nitrogen-cooled heat exchanger.27
The inerting curtains shown in Figure 4-3 are streams of sol vent-free
nitrogen gas that prevent both airflow into the oven and VOC flow from
the oven. Fume collection hoods may also be located near the ovens and
curtains to capture any gases escaping from these areas.
Nitrogen is used in the drying oven to permit operation with high
solvent vapor concentrations without the danger of explosion. The
nitrogen recycled through the oven is monitored and operated to maintain
solvent vapor concentrations of 10 to 30 percent, by volume.27 The use
of high solvent vapor concentrations and minimum gas flow rates allows
economical solvent recovery.
Solvents are recovered by sending a bleed stream of approximately
1 percent of the recycle flow through a shell-and-tube condenser.28 The
liquid nitrogen is on the tube side, and the solvent laden nitrogen
passes over the outside of the tube surfaces. Vapors condense and drain
into a collection tank.29 The nitrogen that vaporizes in the heat
exchanger is recycled to the oven and inerting curtains. To avoid
t
solvent condensation in the oven and to maintain the product cure rate
4-21
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DRY NITROGEN GAS
i
ro
ro
WEB
VOC EMISSIONS
HEAT EXCHANGER
WITH LIQUID N2
COOLANT
LIQUID
N2
SUPPLY
x y
RECYCLED GASES
DRYING OVEN WITH INERT ATMOSPHERE
UEB
~ "VOC'EMISSIONS
INERTING CURTAIN
INERTING CURTAIN
Figure 4-3. Schematic of condensation system using nitrogen.27
-------
and the recycle and virgin nitrogen feed rates, the temperature in the
oven must be maintained so that the solvent vapor concentration is above
the dew point.
The nitrogen-blanketed system is water-free; hence, the cost of a
distillation system may be avoided, especially if the coating uses a
single solvent.30
The interdependent parameters considered in the operation and
design of an inert condensation system are:
I. Type of solvent(s);
2. Temperature of the solvent laden nitrogen bleed stream;
3. Solvent laden nitrogen flow rate; and
4. Concentration of VOC in nitrogen.
The first two parameters are characteristics of the production process.
The remaining parameters are design characteristics of the condensation
system. Table 4-6 presents typical process parameters for polymeric
coating plants controlled by these systems.11
The major problem associated with the use of this system is the
need .to purge the unit of the inert atmosphere every time there is a
production change or problem requiring workers to enter the oven.
According to one plant, the normal production operation involves inter-
ruptions due to fabric and product changes, process corrections, and
routine mechanical problems such as damaged rolls and contamination of
coating. All of these events contribute to a reduced VOC recovery
efficiency because of necessary system purges.31
An additional operating problem anticipated with this condensation
system design is the possibility of air leaking into the oven which would
create explosive conditions. However, these ovens have well-designed
safety systems. Because of the inert atmosphere and low water content,
corrosion is not a problem. Therefore, special materials of construction
are not required when using a nitrogen condensation system even when
recovering ketones.
A possible limitation to use of this system is the difficulty in
operating a total enclosure around the coating application/flashoff area.
A purge of the inert atmosphere would be required every time workers need
4-23
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TABLE 4-6. RANGE OF PROCESS PARAMETERS FOR POLYMERIC COATING
PLANTS USING INERT AIR CONDENSATION SYSTEMS11
Parameter
Range
Gas flow rate
Oven temperature
Inlet temperature
Inlet concentration
0.21 to 8.50 mVs
(450 to 18,000 scfm)
per coating line
66° to 121°C
(150° to 250°F)
66° to 107°C
(150° to 225 °F)
10 to 30% by volume
4-24
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access to the enclosure. Every time the system is purged, VOC recovery
efficiency decreases, and nitrogen requirements increase.
The only practical way to determine the overall efficiency of this
system is by measuring the solvent used at the coater and the solvent
recovered. There are no exhaust stacks so the nitrogen and any uncondensed
organic vapor are recirculated. Fugitive emissions might occur at the
ends of the oven if there is an inadvertant pressure increase in the oven
that overcomes the action of the inert gas curtains.32
Presently, two polymeric coating plants use this type of condensation
system to recover solvents. Plant C installed a condensation system in
1982 to recover VOC emissions from the oven for a single solvent. The
solvent laden air is fed through a closed-loop system at a rate of 0.2
m3/s (450 acfm) and a temperature of 107°C (225°F). The company estimates
that 99 percent of the solvent that enters the condenser is recovered and
returned to solvent storage.33
The other plant is using a unit developed by equipment suppliers
and plant personnel that is atypical of condensation systems using a
nitrogen atmosphere and is not representative of control technology
applicable to the polymeric coating industry. This plant is able to
augment the cooling function of the nitrogen with well water, which
significantly reduces operating costs. Most plants do not have this
advantage. Plant personnel estimate that the unit operates at 75 to
95 percent efficiency. Purging losses cause the variation in efficiency.34
4.3.2.2 Condensation System Using An Air Atmosphere. One company
markets a condensation system in which solvent laden air is drawn from a
tightly sealed drying oven through a counterflow heat exchanger.35
There, the solvent laden air is cooled to reduce the moisture content and
heat load on the refrigerated condenser. The solvent and water formed by
the refrigerated condenser are stored for further processing. The cooled
sol vent-free air is then blown through the heat exchanger for preheating
before being returned to the oven. Drying ovens used with this system
must have a minimum of air leakage and be equipped with solvent vapor
concentration monitoring devices. Typically, these ovens are designed to
operate at 40 to 50 percent of the LEL or at solvent concentrations of
less than 0.5 percent, by volume, for typical solvents.36
4-25
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Recycling the solvent laden air through the ovens means the relative
humidity in the oven exhaust is quite low, and the condensate contains
small amounts of water. Solvent purification can be accomplished by
caustic drying or by distillation, depending on the solvent purity
specifications and whether a mixture of solvents is used.11
The interrelated factors important in the design and operation of a
condensation system using a counterflow heat exchanger are:
1. Type of solvent(s);
2. Solvent laden airflow rate;
3. Temperature of the solvent laden air at the heat exchanger
inlet;
4. Solvent laden air concentration in the oven exhaust;
5. Temperature of the refrigerated air entering the heat exchanger
and the efficiency of the heat exchanger; and
6. Operating temperature of the refrigeration coil.
The first four parameters are characteristics of the production process.
The remaining parameters are operating variables that may affect the
performance of the condenser.
Solvent laden air streams that have high water vapor concentrations
tend to cause the refrigeration coils of the condensation system to
freeze. To prevent this from occurring, the refrigeration coils must be
monitored periodically to ensure satisfactory operation. Corrosion
problems are not expected for this system if the water content of the
recovered solvent is less than 5 percent. Consequently, even recovery of
ketones or solvent mixtures containing ketones does not require the use
of stainless steel or other special construction materials if the device
is properly operated.
One polymeric coating plant has recently installed an air atmosphere
condensation system. However, this system has not been in operation long
enough to determine actual performance under normal operating conditions.7
The company manufacturing the system claims that the solvent recovery
efficiency should exceed 90 percent.35
4.3.3 Incineration
Thermal incineration is the oxidation of organic compounds by the
exposure of the VOC's to high temperatures in the presence of oxygen.
4-26
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Carbon dioxide and water are the oxidation products. Incinerators are
used to control VOC emissions from several polymeric coating plants (see
Table 4-3). These control devices have been selected in similar
industries when solvent recovery is not economically feasible or
practical, such as at small plants or at plants using a variety of
solvent mixtures.37 Incinerators used to control VOC emissions from
polymeric coating plants may be of thermal or catalytic design and may
use primary or secondary heat recovery to reduce energy consumption.
Table 4-7 presents typical process parameters for polymeric coating
plants using incinerators.11
4.3.3.1 Thermal Incinerators. Thermal incinerators are usually
refractory-lined oxidation chambers with a burner located at one end. In
these units, part of the solvent laden air is passed through the burner
along with an auxiliary fuel. The gases exiting the burner are blended
with the by-passed solvent laden air and are used to oxidize the solvents
in the solvent laden air. With most solvents, complete oxidation is
obtained in less than 0.75 seconds at temperatures of 870°C (1600°F).38,39
The interrelated factors important in incinerator design and
operation include:
1. Type and concentration of VOC;
2. Solvent laden airflow rate;
3. Solvent laden air temperature at incinerator inlet;
4. Burner type;
5. Efficiency of flame contact (mixing);
6. Residence time;
7. Auxiliary fuel firing rate;
8. Amount of excess air;
9. Firebox temperature; and
10. Preheat temperature.
The first three parameters are characteristics of the production process.
The next three parameters are characteristics of the design of the
incinerator. The auxiliary fuel firing rate is determined by the type
and concentration of VOC, the solvent laden airflow rate, firebox
temperature, and the preheat temperature. The last four parameters are
4-27
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TABLE 4-7. TYPICAL PROCESS PARAMETERS FOR POLYMERIC COATING
PLANTS USING INCINERATORS11
Parameter Typical values
Gas flow rate 2.36 to 4.72 m3/s (5,000 to 10,000 scfm)
Oven temperature 121° ± 28°C (250° ± 50°F)
Inlet temperature 93° ± 28°C (200° ± 50°F)
Inlet concentration 18% LEL
4-28
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operating variables that may affect the performance of the incinerator.
Well-designed and well-operated incinerators in similar industries have
achieved VOC destruction efficiencies of 98 percent or better.38,39
Thermal incinerators are in current use at 14 polymeric coating plants.
Presently, there are 16 polymeric coating plants using thermal
incinerators. Plant D uses a thermal incinerator to control VOC emissions
from the oven of a single fabric coating line using primarily acetone in
the coating. The SLA from the oven has a flow rate of 1.9 mVmin
(4,000 scfm) and a temperature of 135°C (275°F).
The plant uses two heat exchanger along with the incinerator to
recover some of the heat generated in the incinerator. In the first
heat exchanger, the exhaust from the incinerator is used to raise the
temperature of the oven exhaust from 135°C (275°F) to 317°C (603°F)
before it enters the incinerator. In the second heat exchanger, the
exhaust from the first heat exchanger is used to heat fresh air which is
used as oven makeup air. The exhaust from the second heat exchanger is
then vented to the atmosphere through a stack. The plant claims the
efficiency of the incinerator to be about 97 percent.40
4.3.3.2 Catalytic Incinerators. Catalytic incinerators use a
catalyst to promote the combustion of VOC's. The solvent laden air is
preheated by a burner or heat exchanger and then brought into contact
with the catalyst bed where oxidation occurs. Common catalysts used are
platinum or other noble metals on alumina pellets or ceramic honeycomb
support. Catalytic incinerators can achieve destruction efficiencies
similar to those of thermal incinerators while operating at lower tempera-
tures, i.e., 315° to 430°C (600° to 800°F). Thus, catalytic incinerators
can operate with significantly lower energy costs than can thermal
incinerators that do not practice significant heat recovery.41 Con-
struction material may also be less expensive because of the lower
operating temperatures.
Factors important in the design and operation of catalytic
incinerators include the factors affecting thermal incinerators as well
as the operating temperature range of the catalyst. The operating
temperature range for the catalyst sets the upper VOC concentration that
can be incinerated. For most catalysts on alumina, catalyst activity is
severely reduced by exposure to temperatures greater than 700°C (1300°F).42
4-29
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Consequently, the heating value of the inlet stream must be limited.
Typically, inlet VOC concentrations must be less than 25 percent of the
LEL.
A catalytic incinerator used at a polymeric coating plant is described
below to illustrate the applicability of this control system.
At Plant E, the VOC emissions from each of two ovens are controlled
by one of two catalytic incinerators.43 A similar company-designed
incinerator controls emissions from a smaller oven. The gas stream is
preheated before it crosses the catalyst, and the catalytic reaction
raises the temperature of the gas to 310°C (610°F). After moving through
a heat exchanger, the gas stream is divided. A portion of the gas
stream, retaining 50 percent of the heat, is vented to the atmosphere.
The remaining heat laden air is either returned to the incinerator or is
cooled to oven temperatures by mixing with fresh air and returned to the
oven.
In 1976, one of the larger units was tested with a flame ionization
detector total carbon analyzer. It revealed that a 95.7 percent reduction
in hydrocarbons was being achieved in the incinerator. The company
estimates that it is currently capturing and controlling 90 percent of
the VOC emissions from the oven. The catalyst is thermally cleaned
every 2 months and replaced every 3 years.43
4.3.3.3 Heat Recovery. Heat recovery offers a means of reducing
the energy consumption of the incinerator or another process in the
plant. Primary heat recovery refers to the transfer of heat from the
hot incinerator effluent to a relatively cool inlet VOC stream. Secondary
heat recovery refers to exchange of heat from the incinerator to any
other process.
Overall heat recoveries of 70 to 80 percent can be achieved by
plants installing new lines in similar industries using primary and
secondary heat recovery.44 Actual overall energy savings obtained will
vary with the VOC concentration in the oven exhaust, the incinerator
operating temperature, and the ability of the plant to incorporate
secondary heat recovery.
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4.4 VOC EMISSION CONTROL SYSTEMS FOR COATING MIX PREPARATION EQUIPMENT
AND SOLVENT STORAGE TANKS
4.4.1 Conservation Vents and Pressure Relief Valves
Conservation vents have been used to minimize tank losses from
plants (including polymeric coating plants) in a variety of industries.
The conservation vents are permanently attached to the outside of sealed,
vapor-tight vessels; these vents open when either positive or negative
pressure within a vessel exceeds predetermined values. The pressure or
vacuum settings are achieved by weights inside the vent. Conservation
vents reduce VOC emissions that would occur because of cyclic changes in
the temperature of the liquid inside a vessel. These losses are called
breathing losses.
Figure 4-4 presents a diagram of a conservation vent.45 The vessel
pressure is applied to the underside of the pressure pallet and the top
side of the vacuum pallet. As long as the vessel pressure remains
within the valve pressure and vacuum settings, the pallet remains in
contact with the seat rings, and no venting or breathing takes place.
The pressure pallet lifts from its seat ring when the vessel pressure
reaches the valve pressure setting and allows the excess pressure to
vent to the atmosphere. As the vessel pressure drops below the valve
setting, the pressure pallet returns to the closed position. For a
negative pressure (vacuum), the vacuum pallet lifts from its seat ring
when the vessel vacuum reaches the valve vacuum setting, allowing air to
flow into the vessel to relieve the excess vacuum condition. The vacuum
pallet returns to its normal position as the vessel vacuum drops below
the valve vacuum setting.46 Conservation vents will not prevent the
tank from venting when it is filled (working losses) because the internal
pressure will exceed the set pressure on the valve.
The amount of VOC emission reduction achieved by conservation vents
depends on the solvent vapor pressure, the diurnal temperature change,
the tank size, and the vent pressure and vacuum settings. Breathing and
working losses from solvent storage tanks can be estimated using emission
equations.47 Assuming yearly average diurnal temperature changes of
*
11°C (20°F), the true vapor pressure of toluene (the most common solvent
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STEM GUIDE
GO
:ro
GUIDE POLE,
PRESSURE
PALLET ASSEMBLY,
PRESSURE
GUIDE POLE, PRESSURE
PALLET WEIGHT
VACUUM COVER
SEAT RING
FLANGE
PALLET ASSEMBLY, VACUUM
SEAT RING
GUIDE POLE, VACUUM
SCREEN
Figure 4-4. Diagram of conservation vent.45
-------
in the industry) (5.3 kPa [0.77 psia]), and a turnover rate of 5 volumes
per year, these equations yield estimates for breathing losses of 55 to
70 percent of the total annual emissions from solvent storage tanks.
According to one equipment vendor, as much as 50 percent of the total
VOC emissions from the tank can be reduced with the use of properly
installed and maintained conservation venting equipment to control
breathing losses.48 Conservation vents set at 0.215 kPa (0.5 ounce)
vacuum and 17.2 kPa (2.5 psig) pressure control all of the breathing
losses and a small amount of the working losses for toluene for an
average overall efficiency of 70 percent.49
A pressure relief valve operates in a manner similar to that of a
conservation vent. These valves operate at higher pressures achieved by
internal springs, not weights, and usually do not have any vacuum settings.
The pressure relief valves control all of the breathing losses and much
of the working losses. Based on the vapor pressure of toluene and a
pressure setting of 103 kPa (15 psig), a control efficiency of 90 percent
was calculated for pressure relief valves.49
4.4.2 Internal Floating Roof Solvent Storage Tanks
Emissions from solvent storage tanks have been reduced in other
industries by the use of internal floating roof tanks. An internal
floating roof tank has a permanently affixed external roof and an internal
roof that rises and falls with the liquid level.50 Tanks of this design
reduce the area of exposed liquid surface in the tank which, in turn,
decreases evaporative losses.51 However, this control technique is
inappropriate for the small (<75 m3 [20,000 gal]) solvent storage tanks
in use at polymeric coating plants. Therefore, internal floating roof
tanks are not considered a control option for tanks at polymeric coating
plants.
4.4.3 Disposable-Canister Unit Carbon Adsorption
This system can theoretically be used to control emissions from
individual solvent storage tanks and coating preparation equipment that
have low flow rates and solvent concentrations. This system is designed
for air streams having flows generally less than 0.05 m3/s (100 acfm)
and low organic loading. No one is known to use this system at a polymeric
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coating plant; however, it has been used to control solvent storage tank
and reactor vessel emissions at plants in other industries.52
In this carbon adsorption system, a prefabricated canister containing
activated carbon is connected to the emission source vent. The principle
of operation is the same as that of a fixed-bed carbon adsorber except
that there is no regeneration of spent carbon. Rather, the canister and
contents are removed for disposal, and a new canister is installed. The
actual useful life depends on size of the canister and the type and
amount of vapors to which the carbon is exposed.52
Bed overheating can be a problem if these systems are used to
recover ketones. The large surface area of the activated carbon allows
ketone molecules to react exothermically, possibly leading to bed fires.
.».
This problem can be circumvented by keeping the carbon damp.53
4.5 LOW-SOLVENT COATINGS
The use of low-solvent coatings is an effective technique to reduce
VOC emissions. Some combination of waterborne, higher solids, plastisol,
calendered or extruded coatings are used as the sole means of reducing
VOC emissions at over 30 percent of the plants that apply polymeric
coatings to supporting substrates. A combination of low-solvent coatings
and control of the drying oven is used by at least 10 percent of the
plants applying polymeric coatings to supporting substrates. The primary
factor that influences the. effectiveness of low-solvent coatings as an
emission control technique is that many polymeric-coated products cannot
be satisfactorily produced with low-solvent coatings at this time.
Therefore, it is anticipated that solvent borne coatings will continue
to be necessary in some coating applications.
Waterborne coatings allow the mixing of certain materials that
would be incompatible in solvent borne coatings. Although waterborne
coatings dry more slowly than solvent borne coatings, the longer drying
time required is partially offset by the fact that the solids content of
waterborne coatings is typically 55 to 60 percent by volume.54-56 A
disadvantage of existing waterborne coatings is that, for some products,
these coatings may not be able to achieve the desired final, product
characteristics.
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The advantages of higher solids coatings compared to solvent borne
coatings include reduced solvent usage, reduced energy costs for the
heat to dry the coating, and faster line speeds. Some manufacturers use
ultraviolet or electron beam curing with higher solids coatings which
reduces energy costs and allows for a more physically compact coating
operation. A disadvantage of higher solids coatings is short pot life;
they must be applied shortly after preparation.57
Coatings applied by calenders and extruders or in plastisol form
have virtually no VOC emissions. The only emissions are due to a small
percentage of plasticizers that evolve as process heat is applied to the
plastisol/plasticizer. An advantage of calenders and extruders is
faster line speeds, but these processes are limited to application of
fairly thick coatings. The use of plastisols is currently limited to
PVC and some urethanes.
4.6 REFERENCES FOR CHAPTER 4
1. Memorandum from Banker, L., MRI, to Polymeric Coating of Supporting
Substrates Project File. May 17, 1984. Summary of Confidential
and Nonconfidential Information on the Use of Covered Coating
Preparation Equipment and the Use of Room Ventilation for the
Capture of VOC Emissions.
2. Memorandum from Mclaughlin, N., EPA:EMB, to McCarley, J. E. Jr.,
EPA:EMB. May 10, 1984. Status report and recommended testing
options for Elastomeric Coating NSPS (83/13).
3. Industrial Ventilation. A Manual of Recommended Practice (14th
Edition). American Conference of Governmental Industrial Hygienists.
Committee on Industrial Ventilation. Lansing, Michigan.
pp. 4-4 - 4-5.
4. Reference 3, p. 4-1.
5. Reference 3, p. 4-12.
6. Memorandum and attachments from Glanville, J., MRI, to Magnetic
Tape Project File. April 5, 1984. Summary of emission capture
systems used at magnetic tape coating facilities (located in ESED
confidential files).
7. Memorandum from Thorneloe, S., MRI, to Grumpier, D., EPA:CPB.
July 6, 1984. Report of site visit to ODC Incorporate^, Norcross,
Georgia.
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8. Memorandum from Newton, D., MRI, to Grumpier, D., EPA:CPB. July 25,
1983. Report of site visit to Burlington Industrial Fabric,
Kernersville, North Carolina.
9. Memorandum from Thorneloe, S., MRI, to Grumpier, D., EPArCPB.
March 2, 1984. Report of site visit to Utex Industries, Inc.,
Weimar, Texas.
10. Memorandum from Thorneloe, S. , MRI, to Polymeric Coating of Supporting
Substrates Project File. October 19, 1984. Summary of Confidential
and Nonconfidential Information on the Need of a Worker to Access
the Coating Application/Flashoff Area and Drying Oven.
11. Memorandum from Thorneloe, S., MRI, to Elastomeric Coating of
Fabrics Project File. May 9, 1984. Typical process parameters of
polymeric coating plants using VOC control devices.
12. Meyer, W. Solvent Broke. Vulcan-Cincinnati, Inc. Cincinnati,
Ohio. (Presented at TAPPI Test/PAP Synth. Conf. Boston. October 7-9,
1974.) pp. 109-115.
13. Danielson, John A. Air Pollution Engineering Manual. Research
Triangle Park, North Carolina. U. S. Environmental Protection
Agency. May 1973. pp. 189-202.
14. Stunkard, C. B. Solvent Recovery from Low Concentration Emissions.
Calgon Carbon Corporation. Undated.
15. Radian Corporation. Full-Scale Adsorption Applications Study:
Draft Plant Test Report—Plant 3. Prepared for L). S. Environmental
Protection Agency. Cincinnati, Ohio. EPA Contract No. 68-03-3038.
August 19, 1982. p. 29.
16. U. S. Environmental Protection Agency. Control of Volatile Organic
Emissions from Existing Stationary Sources—Volume I: Control
Methods for Surface-Coating Operations. EPA-450/2-76-028. Research
Triangle Park, North Carolina. November 1976. pp. 33-34.
17. Memorandum from Newton, D., MRI, to Grumpier, D., EPA:CPB. July 22,
1983. Report of site visit to Aldan Rubber Company, Philadelphia,
Pennsylvania.
18. Memorandum from Friedman, E., MRI, to Polymeric Coating of Supporting
Substrates Confidential Project File. August 21, 1983. Recovery of
Multiple Solvents.
19. Memorandum from Thorneloe, S., MRI, to Grumpier, D., EPA:CPB.
March 28, 1984. Report of site visit to Dayco Corp., Three Rivers,
Michigan.
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20. Crane, G. B. Carbon Adsorption for VOC Control. U. S. Environ-
mental Protection Agency. Chemicals and Petroleum Branch, Research
Triangle Park, North Carolina, p. 1.
21. Golba, N., and J. Mason. Solvent Recovery Using Fluidized-Bed
Carbon Adsorption. Union Carbide Corporation, Tonawanda, New York.
(Presented at the Water-Borne and Higher Solids Coating Symposium.
New Orleans. February 17-19, 1982.) 18 p.
22. Basdekis, H. (IT Enviroscience). Emission Control Options for the
Synthetic Organic Chemicals Manufacturing Industry. Control Device
Evaluation, Carbon Adsorption. Prepared for U. S. Environmental
Protection Agency. Research Triangle Park, North Carolina. EPA
Contract No. 68-02-2577. February 1980. pp. 11-25 - 11-26.
23. Radian Corp. Polymeric Coating of Supporting Substrates: Emission
Test Report for Utex Industries, Inc. Revised draft. Prepared for
U. S. Environmental Protection Agency. Research Triangle Park,
North Carolina. EPA Contract No. 68-02-3850. November 21, 1984.
p. 5-24.
24. Telecon. Thorneloe, S., MRI, with Pfeiffer, R., Union Carbide.
August 22, 1983. Information on cost of fluidized-bed carbon
adsorbers.
25. Parmele, C., H. Basdekis, and M. Clark. Evaluation of the Union
Carbide PURASIV HR Vapor Recovery System. U. S. Environmental
Protection Agency. Cincinnatti, Ohio. EPA Contract
No. 600/52-83-014. July 1983. p. 2.
26. Reference 16, p. 56.
27. Rothchild, R. Curing Coatings With an Inert Gas Solvent System.
Journal of Coatings Technology. 53(675):53-56. April 1981.
28. Nikityn, J. Inert Atmosphere Solvent Recovery-Reprinted from the
Journal of Industrial Fabrics. Volume I, Number 4. Spring 1983.
29. Erikson, D. (IT Enviroscience). Emission Control Options for the
Synthetic Organic Chemicals Manufacturing Industry-Control Device
Evaluation, Condensation. Prepared for U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina. EPA Contract No.
68-02-2577. July 1980. p. II-l.
*
30. Telecon. Thorneloe, S., MRI, with Rieman, D., Airco Industrial
Gases. May 18, 1983. Information on Airco condensation system for
solvent recovery.
31. Letter from Hindle, M., The Kenyon Piece Dyeworks, Inc., to
Grumpier, D., EPA:CPB. March 23, 1984. Recovery efficiency data
for condensation system.
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32. Telecon. Beall, C., MRI, with Rieman, D., Airco Industrial Gases.
February 15, 1984. Information on Airco condensation system.
33. Letter and attachments from Koch, D., Kellwood Company, to Farmer, J.,
EPA. February 21, 1984. Response to Section 114 letter on the
elastomeric coating of fabrics.
34. Memorandum from Maxwell, C., MRI, to Grumpier, D., EPA:CPB. July 21,
1983. Report of site visit to the Kenyon Piece Dyeworks, Inc.,
Kenyon, Rhode Island.
(R)
35. United Air Specialists, Inc. Kon-den-Solver for Solvent Vapor
Recovery. Undated.
36. Telecon. Thorneloe, S., MRI, with Memering, L., United Air ~
Specialists. May 4, 1983. Information on the Kon-den-Solver
system for VOC recovery.
37. Telecon. Meyer, J., MRI, with Harper, S., Verbatim Corp. March 3,
1983. Information on VOC control system at Verbatim, Sunnyvale,
California, plant.
38. Memorandum from Mascone, D., EPA:CPB, to Farmer, J., EPA:CPB.
July 22, 1980. Thermal incinerator performance for NSPS, Addendum.
39. Memorandum from Mascone, D., EPA:CPB, to Farmer, J., EPA:CPB.
June 11, 1980. Thermal incinerator performance for NSPS.
40. Memorandum from Powers, S., MRI, to Grumpier, D., EPA:CPB. May 10,
1985. Report of site visit to the Narmco Materials facility in
Anaheim, California.
41. Reference 16, p. 51.
42. Reference 16, p. 54.
43. Memorandum from Maurer, E., MRI, to Grumpier, D., EPA:CPB. February 24,
1984. Report of site visit to the Gates Rubber Company, Denver,
Colorado.
44. U. S. Environmental Protection Agency. Pressure Sensitive Tape and
Label Surface Coating Industry-Background Information for Proposed
Standards. EPA-450/3-80-003a. Research Triangle Park, North
Carolina. September 1980. p. 4-18.
45. Varec Division, Emerson Electric Company. Gas Control Equipment
Catalog S-5. Undated.
46. Telecon. Glanville, J., MRI, with Harper, S., Verbatim Corp.
February 2, 1984. Information on storage tank ventilation.
4-38
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47. U. S. Environmental Protection Agency. VOC Emissions from Volatile
Organic Liquid Storage Tanks—Background Information for Proposed
Standards. EPA 450/3-81-003a. Research Triangle Park, North
Carolina. July 1984. pp. 3-26 - 3-27.
48. Varec Division, Emerson Electric Company. Pollution and Gas Control
Equipment. Bulletin CP-6003-B. Undated.
49. Memo from Doshi, Y., MRI, to Project File. May 24, 1985. Calculation
of conservation vent and pressure relief valve control efficiency.
50. Reference 47, p. 3-6.
51. Reference 47, p. 4-9.
52. Letter and attachments from Wetzel, J., Calgon Carbon Corp., to ~
Beall, C. , MRI. February 13, 1984. Information on Calgon's VentSorb
unit.
53. Telecon. Beall, C., MRI, with Byron, B., Tigg Corp. February 8,
1984. Information on disposable-canister carbon adsorption system.
54. Telecon. Friedman, E., MRI, with Silver, R., Aurora Bleachery,
Inc. June 6, 1984. Information on waterborne coatings.
55. Telecon. Friedman, E., MRI, with Coughlin, T., Nylco Corp. June 6,
1984. Information on waterborne coatings.
56. Telecon. Friedman, E., MRI, with Lam'a, R., Chase and Sons. June 6,
1984. Information on waterborne coatings.
57. Telecon. Maurer, E., MRI, with Swain, R., Lembo Corp. March 7,
1984. Information on coating equipment.
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5. MODIFICATION AND RECONSTRUCTION
Standards of performance apply to plants for which construction,
modification, or reconstruction commenced (as defined under 40 CFR 60.2)
after the date of proposal of the standards. Such plants are termed
"affected facilities." Standards of performance are not applicable to
"existing facilities" (i.e., facilities for which construction, modifi-
cation, or reconstruction commenced on or before the date of proposal of
the standards). An existing facility may become an affected facility and,
therefore, be subject to the standards of performance if the facility
undergoes modification or reconstruction. The enforcement division of
the appropriate EPA regional office will make the final determination as
to whether an existing facility is modified or reconstructed, and, as a
result, subject to the standards of performance as an affected facility.
Modification and reconstruction are defined under 40 CFR 60.14 and
60.15, respectively. These General Provisions are summarized in
Section 5.1. Section 5.2 discusses the applicability of these provisions
to facilities performing polymeric coating of supporting substrates.
5.1 PROVISIONS FOR MODIFICATION AND RECONSTRUCTION
5.1.1 Modification
With certain exceptions, any physical or operational change to an
existing facility that would increase the emission rate to the atmosphere
from that facility of any pollutant covered by the standard would be
considered a modification within the meaning of Section 111 of the Clean
Air Act. The key to determining if a change is considered a modification
is whether actual emissions to the atmosphere from the facility have
increased on a mass per time basis (kg/h [lb/h]) as a result of the
change. Changes in emission rate may be determined by the use of emission
5-1
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factors, by material balances, by continuous monitoring data, or by
manual emission tests in cases where the use of emission factors does not
clearly demonstrate that emissions do or do not increase. Under the
current regulations, an emission increase from one facility may not be
offset with a similar emission decrease at another facility to avoid
becoming subject to new source performance standards (NSPS). If an
existing facility is determined to be modified, it becomes an affected
facility, subject to the standards of performance for the pollutant or
pollutants that have increased due to modification. All emissions, not
just the incremental increase in emissions, of the pollutants that have
increased from the facility must be in compliance with the applicable
standards. A modification to one existing facility at a plant will not
cause other existing facilities at the same plant to become subject to
the standards.
Under the regulations, certain physical or operational changes are
not considered to be modifications even though emissions may increase as
a result of the change (see 40 CFR 60.14(e)). The exceptions as allowed
under 40 CFR 60.14(e) are as follows:
1. Routine maintenance, repair, and replacement (e.g., lubrication
of mechanical equipment; replacement of pumps, motors, and piping;
cleaning of equipment);
2. An increase in the production rate without a capital expenditure
(as defined in 40 CFR 60.2);
3. An increase in the hours of operation;
4. Use of an alternative fuel or raw material if, prior to proposal
of the standard, the existing facility was designed to accommodate that
alternate fuel or raw material;
5. The addition or use of any system or device whose primary function
is to reduce air pollutants, except when an emission control system is
replaced by a system determined by the EPA to be less environmentally
beneficial; and
6. Relocation or change in ownership of the existing facility.
An owner or operator of an existing facility who is planning a
physical or operational change that may increase the emissio'n rate of a
5-2
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pollutant to which a standard applies shall notify the appropriate EPA
regional office 60 days prior to the change, as specified in
40 CFR 60.7(a)(4).
5.1.2 Reconstruction
An existing facility may become subject to NSPS if it is recon-
structed. Reconstruction is defined as the replacement of the components
of an existing facility to the extent that (1) the fixed capital cost of
the new components exceeds 50 percent of the fixed capital cost required
to construct a comparable new facility and (2) it is technically and
economically feasible for the facility to meet the applicable standards.
Because the EPA considers reconstructed facilities to constitute new
construction rather than modification, reconstruction determinations are
made irrespective of changes in emission rates.
The purpose of the reconstruction provisions is to discourage the
perpetuation of an existing facility for the sole purpose of circumventing
a standard that is applicable to new facilities. Without such a provi-
sion, all but vestigial components (such as frames, housing, and support
structures) of the existing facility could be replaced without causing
the facility to be considered a "new" facility subject to NSPS. If the
facility is determined to be reconstructed, it must comply with all of
the provisions of the standards of performance applicable to that facility.
If an owner or operator of an existing facility is planning to
replace components and the fixed capital cost of the new components
exceeds 50 percent of the fixed capital cost of a comparable new facility,
the owner or operator must notify the appropriate EPA regional office
60 days before the construction of the replacement commences, as required
under 40 CFR 60.15(d).
5.2 APPLICABILITY TO POLYMERIC COATING OF SUPPORTING SUBSTRATES
5.2.1 Examples of Modification
5.2.1.1 Solvent Storage Tanks. Few, if any, changes in the physical
configuration of storage tanks that would increase emissions are
anticipated. Because replacement of frames, housings, and supporting
structures would not increase emissions from a storage tank, such replace-
t
ment would not constitute a modification. An increase in the capacity of
5-3
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a storage tank, while an unlikely occurrence, could cause emissions to
increase and, therefore, could constitute a modification.
5.2.1.2 Coating Mix Preparation Equipment. No changes in the
physical configuration of coating mix preparation equipment that would
increase emissions are expected. Industry practice is to replace individual
items of equipment if a major process change requires different processing
equipment. Except for replacement to accommodate process changes, mixers,
mills, and tanks are used indefinitely and repaired as needed.1-3
Operational changes that might increase VOC emissions would be a
change in the length of time required to prepare coating or a change in
raw materials. A change in processing time would not constitute a modi-
fication, however, because it would be an increase in hours of operation,
which is exempted under 40 CFR 60.14(e) from modification determinations.
Also under 40 CFR 60.14(e), existing facilities that change to an alternate
raw material are exempted from modification determinations if the facility
was designed to accommodate the raw material prior to proposal of ths
standard. The same coating mix preparation equipment is used to prepare
the known range of coatings used in this industry.1-3 Thus, modifica-
tions of coating mix preparation equipment are not expected.
5.2.1.3 Coating Operation. Potential modifications of polymeric
coating operation and processes include changes to increase production
and changes in the method of applying the polymeric coating to the
substrate. Changes in the application method may affect the VOC emission
rate of the coating operation. Production increases can also increase
the VOC emission rate from a coating line.
The productivity of a polymeric coating operation is determined by
the substrate width, the line speed, the hours of operation, and the
efficiency of scheduling. Most of the equipment modifications that might
be made to increase productivity involve totally new sources, or invest-
ments so large as to qualify as reconstruction. Specific examples of
production equipment changes are discussed below, with emphasis on the
few cases where the modification providions might apply. However, in
general, no changes are expected that would cause the operation to be
subject to the modification provisions.
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5.2.1.3.1 Changes in substrate width. Changes in the width of the
substrate would increase both production and emissions. The maximum
substrate width that any given coating operation can accommodate is an
integral part of the basic design of the system. Substrate width cannot
be increased significantly beyond this maximum without installing
essentially all new equipment. It is, therefore, unlikely that such a
modification would be made.
5.2.1.3.2 Changes in line speed. An increase in maximum operating
speed is the most likely change that could constitute a modification.
The maximum operating speed for a given facility depends on both the
basic design of the coating operation and on the specifications for each
product. The factors that might constitute an operating speed limitation
include:
1. A limitation on the available power and/or speed of the motors
that drive the substrate;
2. Drying limitations based either on the amount of heat available
or on residence time in the oven;
3. A limitation on air circulation in the drying oven that causes
the lower explosive limit (LEL) to be exceeded; and
4. A limitation on the maximum speed at which a smooth coating can
be achieved with a given coating head or at which the line can be operated
without shutdowns.
Any equipment changes made to obtain an increased production rate
(such as larger/faster drive motors, higher capacity boilers for the
ovens, higher capacity oven air circulating blowers, or LEL sensors with
alarm/shutdown capacity) would require capital expenditure and result in
increased emissions and could cause the facility to come under the
modification provisions. Depending on the cost of the changes, they
might, however, cause a considered facility to come under the
reconstruction provisions.
5.2.1.3.3 Raw material changes. Many changes in coating
specifications (such as percent VOC or coating thickness) could also
result in increased VOC emissions. Such changes would only be considered
modifications if the coating operation equipment had to be altered to
accommodate use of that coating. However, coating reformulation tends to
5-5
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be directed toward reducing VOC content. It is unlikely that any equipment
modifications resulting from reformulation would increase VOC emissions.
5.2.1.3.4 Changes in. the hours available for operation and/or
scheduling efficiency. A typical polymeric coating operation operates
approximately 80 hours per week.4 Significant increases in production
and emissions could result from extending the working hours, but an
increase in the hours of operation is specifically exempted from
modification considerations by 40 CFR 60.14(e).
Even during the hours of operation, a coating operation may be shut
down to change products. Each time a change is made in the type of
substrate to be coated on a given operation or the type of coating to be
applied, time must be allowed to clean the equipment and to reset the
controls to the new product specifications. Thus, careful scheduling can
increase production, which will result in increased VOC'emissions. The
careful scheduling of production would not be considered a modification
if that production rate increase can be accomplished without a capital
expenditure.
5.2.2 Examples of Reconstruction
Reconstruction, as defined under 40 CFR 60.15, might occur if the
components of a polymeric coating plant (i.e., storage tanks, coating mix
preparation equipment, coating operation, and other miscellaneous sources)
are replaced and if the fixed capital costs of the replacement components
exceed 50 percent of the fixed capital costs of a comparable new facility.
There appear to be no circumstances which would cause the relatively
small storage tanks (less than 40 m3 [10,000 gal]) used by polymeric
coaters to fall under the reconstruction provision.4 Because associated
support structures (frames, housing, etc.) are not part of a tank, replace-
ment of such structures would not constitute reconstruction.
Repair of coating mix preparation equipment may occasionally incur
sufficient expense to qualify as reconstruction if the repairs are
extensive. Replacement of single components in a coating operation
(i.e., a change in coating application method or drying oven) occurs
rarely, but replacement of the oven in particular may incur sufficient
expense to require EPA's determination as to whether it would be considered
a reconstruction of a coating operation.
5-6
-------
Some of the coating application equipment changes discussed in
Section 5.2.1.3 are likely to incur sufficient cost to qualify as recon-
structions. Any change of equipment to increase substrate width
significantly would probably require such extensive equipment replacement
that it would be considered a reconstruction. It is doubtful that any
such change would occur since the plant probably could install a new
coating operation for approximately the same expenditure. Similarly,
equipment changes to increase operating speed could be costly enough to
require a reconstruction determination. This would be most likely in
cases where oven capacity limits line speed. Reconstruction of polymeric
coating facilities is expected to occur only in isolated cases, if at
all.
5.3 REFERENCES FOR CHAPTER 5
1. Telecon. Friedman, E., MRI, with Melton, D., Moorehouse Industries,
Inc. June 13, 1983. Information on mix room equipment.
2. Telecon. Maurer, E., MRI, with Herman, K., Sherman Machinery, Inc.
March 8, 1984. Information on mix room equipment.
3. Telecon. Friedman, E., and Banker, L., MRI, with Mueller, J., Day
Mixing Company. June 5, 1984. Information on mix room equipment.
4. Memorandum from Thorneloe, S.,. MRI, to Polymeric Coating of Supporting
Substrates Project File. May 9, 1984. Typical process parameters
for elastomeric coating of fabric facilities using VOC control devices.
5-7
-------
6. MODEL PLANTS AND REGULATORY ALTERNATIVES
This chapter describes model plants that are representative of new
plants that apply polymeric coating to supporting substrates. A model
plant is defined to include a model coating operation and associated
model solvent storage tanks and model coating mix preparation equipment.
Also, presented in this chapter are the regulatory alternatives that
represent the various levels of VOC emission control that could be
achieved by the use of available control devices. The model plants and
regulatory alternatives.are used in subsequent chapters as the basis for
estimating the environmental, economic, and energy impacts associated
with the control of VOC emissions.
6.1 MODEL PLANTS
As discussed in Chapters 3 and 4, the polymeric coating process
encompasses a wide range of coatings, substrates, end products, produc-
tion processes, and VOC control options. The model plants presented
here are parametric descriptions of polymeric coating lines and represent
typical plants in the industry.1-5 The model plants are based on specific
information from polymeric coating plants, general information from
various industry contacts, and published literature.
The model plants reflect polymeric coating lines that are expected
to be built in the future, whether they are captive or commission coaters.
The model plants represent the fact that expansion is expected to occur
on the basis of a single coating operation with the possibility of
expansion of support areas (solvent storage tanks and coating mix
preparation equipment).
Annual solvent consumption rates were selected as the.basis for
determining the model plant size categories because these data are more
6-1
-------
readily available than data pertaining to the total amount of substrate
coated per year.6 Because of the variety of end products and their
inherent production process differences, solvent consumption is a more
meaningful common denominator than annual production rates based on line
speed and coating thickness.
Solvent consumption may vary on a single line because of several
factors. In general, production variables such as substrate width,
coating thickness, line speed, and utilization rate affect the rate of
coating consumption which necessarily affects solvent consumption. The
hours of line operation are another important variable.
6.1.1 Solvent Storage Tanks
The solvent storage tanks for the model plant are those tanks
required to store and supply solvents to the model coating mix preparation
equipment. While most polymeric coating plants presently use under-
ground solvent storage tanks, it is expected that new tanks will be
above ground, fixed roof tanks. Above ground tanks are easier to install
and maintain and, most importantly, reduce concerns regarding groundwater
contamination.7
The number and capacity of the model storage tanks are given in
Table 6-1. The number and capacity are based on the calculated annual
solvent consumption of the model plants and an inventory turnover rate
of five times per year.8
6.1.2 Coating Mix Preparation Equipment
The coating mix preparation equipment for the model plant will
contain the equipment (mixers and holding tanks) required to supply
coating to the model coating operation. The model coating mix preparation
equipment parameters are given in Table 6-2. The capacity and number of
pieces of coating mix preparation equipment required to process the
coatings are based on discussions with vendors and are representative of
equipment configurations likely to be installed in the future. Because
urethane coatings are purchased premixed, coating mix preparation equipment
is not required and model coating mix preparation equipment parameters
are not included for a urethane coating operation.4
Rubber compounding equipment such as roll mills or Banbury mixers
are not included in the model coating mix preparation equipment parameters
6-2
-------
TABLE 6-1. MODEL SOLVENT STORAGE TANK PARAMETERS
Parameter
Model tank configuration
Solvent usage, m3/yr (gal/yr)
No. of tanks
Capacity of each
No. of turnovers
Total emissions,
tank, m3 (gal)
per year
Mg/yr (ton/yr)a
A
113.6
(30,000)
2
11.4
(3,000)
5
0.06
(0.07)
B
189.3
(50,000)
2
18.9
(5,000)
5
0.11
(0.12)
C
378.5
(100,000)
2
37.9
(10,000)
5
0.27
(0.30)
Based on calculated emission rate of toluene using volatile organic
liquid storage tanks equations for above ground fixed roof tanks.7
6-3
-------
TABLE 6-2. MODEL COATING MIX PREPARATION EQUIPMENT PARAMETERS
I
.£>
Parameter3
Coating prepared, m3/d
(gal/d)
Solvent used, mVd (gal/d)
Equipment, No. of:
100-gallon mixers
200-gallon mixers
330-gallon mixers
55-gallon holding tanks
Equipment ventilation rate,
mVmin (scfm)
Uncontrolled emissions,
Mg/yr (tons/yr)
1. Rubber-coated
industrial fabric
A
0.68
(180)
0.45
(120)
1
1
0
4
6
(200)
9.5
(10.5)
B
1.01
(290)
0.72
(190)
0
2
0
6
4
(150)
15
(17)
C
2.20
(580)
1.44
(380)
0
4
0
11
9
(300)
31
(34)
3. Rubber-
coated cord
A
0.53
(140)
0.45
(120)
2
0
0
3
6
(200)
9.5
(10.5)
B
Q.83
(220)
0.72
(190)
1
1
0
4
. 4
(150)
15
(17)
4. Epoxy-coated
fiberglass
B
1.97
(520)
0.80
(210)
0
1
2
10
4
(150)
15
(17)
C
3.90
(1,030)
1.55
(410)
1
1
3
19
9
(300)
31
(34)
.Based on solvent consumption.
Based on solvent concentration of 4,000 ppm in the exhaust.
to those of coating line.
Based on 10 percent of total VOC emissions.
Hours of operation assumed to be equal
-------
for the operations using rubber coating. If a new rubber coating operation
is added to an existing plant, rubber compounding could be handled by the
existing equipment. In the case of a new plant consisting of a single
coating operation, it would be less costly to purchase compounded rubber
than to install rubber compounding equipment.9
6.1.3 Coating Operation
The coating operation of the model plant is defined as the coating
application/flashoff area and associated drying oven required to manufacture
polymeric coated substrates. In some instances, the coating operation
may include more than one coating application/flashoff area and associated
drying oven operated in a continuous series for the purpose of applying
multiple coats on the substrate. However, for the purposes of impact
analysis, a single application/flashoff area and drying oven is being
evaluated because it represents the most typical case.
Parameters for four model coating operations are summarized in
Tables 6-3, 6-4, and 6-5. The parameters were chosen to reflect a range
of market conditions, such as import competition and changes in consumer
demand, and differences in end-product values. The parameters also
address the variations in coating formulation, substrate types, process
equipment, and VOC capture and control devices used.
6.1.3.1 Coating Formulation. Rubber, urethane, and epoxy coatings
are widely used polymeric coatings, and model coating operation parameters
have been developed for processes using these typical coating formulations.
Acrylic coatings, which are typically waterborne, and both PVC coatings
and rubber coatings containing 100 percent solids emit little or no VOC.
Therefore, the coating processes associated with these coating formulations
are not included in the model coating operation parameters. Solvent
borne silicone and nitrocellulose coatings are not widely used and are
expected to be represented by the model coating operation parameters for
rubber-coated industrial fabric. Phenolic coatings are represented by
the model coating operation for epoxy-coated fiberglass.10
6.1.3.2 Substrate Types. Table 6-5 summarizes the substrate types
and annual substrate consumption for typical products produced on each
model coating operation.11
6-5
-------
CTt
cr>
TABLE 6-3a. MODEL COATING OPERATION PARAMETERS FOR CARBON ADSORBER OR INCINERATOR CONTROL OPTIONS
(Metric Units)
Rubber-coated
industrial fabric
Parameter
Production
Total volume of coating used, mVyr
Amount of solvent used, mVyr (Mg/yr)
Ind product(s)
Operating Parameters
Period of operation, h/yr
Utilization rate, %
Actual operation, h/yr
No. of operators
Process Parameters
Coating composition
Solids
% by volume
Solvent(s)
% by volume
Coating equipment
Coating applicator
Drying oven
Coating application
Oven temperature, °C
Oven ventilation rate, mVmin
Solvent concentration in exhaust,
% LEL
Control device
Carbon adsorber inlet temperature, °C
Incinerator heat exchanger inlet
temperature, °C
Inlet solvent concentration, ppmV
Uncontrolled VOC emissions .
from coating operation, Mg/yr
A
169
110
(95)
<- Diaphragms
2,000a
«•
1,000
«-
<-
«-
B C
274 548
178 282
(154) (308)
, printing blankets >
4,000b 4,000
50 ->
2,000 2,000
3 ->
Rubber ->
35
Toluene
65
Knife-over-roll, dip tank
Single-zone
93
116
25
«-
<-
3,250
85.5
93 93
102 188
23 25
35 -»
93
2,990 3,230
139 277
Urethane-coated
fabric
B C
306
168
(154)
* Luggage, tents
4,000 4
50
2,000 2
4
<- Urethane
45
DMF, Toluene
35,20
613
333
(308)
-»
,000
50
,000
4
-»
-»
Knife-over-roll
reverse- roll
Double-zone
177
104
25
35
177
3,250 3
154
177
209
25
35
177
,250
308
Rubber-coated
cord
A
129
110
(95)
* V-belts
2,000
50
1,000
2
«- Rubber
15
Toluene
85
B
209
178
(154)
Epoxy-coated
fiberglass
B C
488
199
(154)
975
390
(308)
-> «- Aircraft/military •»
4,000
50
2,000
2
->
40-cord dip tank
Triple-zone
232
116
25
35
232
3,250
85.5
232
102
23
35
232
2,990
139
products
4,000 4
50
2,000 2
4
«- Epoxy
60
Acetone
40
Dip tank
Single-zone
121
102
18
35
121
4,680 6
139
,000
50
,000
4
•»
121
148
25
35
121
,500
277
^Period of operation 8 h/d, 5 d/wk, 50 wk/yr.
Period of nnni"f »«« ic KiA c. A/utt an t.itf/\i
^Standard
Based on 90 percent of total VOC emissions except for the urethane coating operations which are based on 100 percent of total VOC emissions because urethane
coatings are purchased premixed and, therefore, have no coating mix preparation equipment emissions.
of operation 16 h/d, 5 d/wk, 50 wk/yr.
rd conditions are 20°C and 1 atmosphere pressure.
-------
TABLE 6-3b.
CT>
MODEL COATING OPERATION PARAMETERS FOR CARBON ADSORBER OR INCINERATOR CONTROL OPTIONS
(English Units)
Parameter
Production
intal volume of coating used, gal/yr
Amount of solvent used, gal/yr
(tons/yr)
End product(s)
Operating Parameters
I'eriod of operation, h/yr
Utilization rate, %
Actual operation, h/yr
No. of operators
Process Parameters
Coating composition
Solids
% by volume
Solvent(s)
% by volume
Coating equipment
Coating applicator
Drying oven
Coating application
Oven temperature, °F
Oven ventilation rate, scfm
Solvent concentration in exhaust,
% LEL
Control device
Carbon adsorber inlet temperature,
Incinerator heat exchanger inlet
temperature, °F
Inlet solvent concentration, ppmV
Uncontrolled VOC emissions .
from coating operation, tons/yr
^Period of operation 8 h/d, 5 d/wk,
^Period of operation 16 h/d, 5 d/wk,
C»anHa^H rnnHitinnc ar-o RA°F anri 1
Rubber-coated
industrial fabric
ABC
44,690 72,350 144,700
29,050 47,030 94,050
(105) (170) (340)
«- Diaphragms, printing blankets •»
2,000a -4,000b 4,000
50
1,000 2,000 2,000
3
*• Rubber -»
35
<- Toluene ->
«- 65 -»
«• Knife-over-roll, dip tank ->
«• Single- zone •>
200
4,100 3,600 6,640
25 23 25
°F <- 95
200
3,250 2,990 3,230
94.5 153 306
50 wk/yr.
50 wk/yr.
a frmncnhor'O nr>ac. cnr>a
Urethane-coated
fabric
B C
80,900 161,900
44,500 88,050
•(170) (340)
«- Luggage, tents •»
4,000 4,000
50 50
2,000 2,000
4 4
«- Urethane ->
<- 45
«• DHF, Toluene •»
35,20 -»
* Knife-over-roll ->
reverse- roll
<- Double-zone •»
350 350
3,690 7,380
25 25
95 95
350 350
3,250 3.250
170 340
Rubber-coated
cord
A
34,180
29,050
(105)
<- V-belts
2,000
50
1,000
2
«• Rubber
15
«• Toluene
85
«- 40-cord dip
B
55,330
47,030
(170)
.,
4,000
50
2,000
2
-»
->
•*
->
tank ->
«- Triple-zone ->
450
4,100
25
95
450
3,250
94.5
450
3,600
23
95
450
2,990
153
Epoxy-coated
fiberglass
B C
128,000 257,600
52,520 103,030
(170) (340)
«- Aircraft/military ->
products
4,000 4,000
50 50
2,000 2,000
4 4
* Epoxy ••
60
*• Acetone ->
«- 40
«- Dip tank ->
<- Single-zone ->
250 250
3,600 5,220
18 25
•
95 95
250 250
4,680 6,500
153 306
Based on 90 percent of total VOC emissions except for the urethane coating operations which are based on 100 percent of total VOC emissions because urethane
coatings are purchased premixed and, therefore, have no coating mix preparation equipment emissions.
-------
TABLE 6-4a.
at
i
oo
MODEL COATING OPERATION PARAMETERS FOR CONDENSATION CONTROL OPTION
(Metric Units)
Parameter
Production
Total volume of coating used, mVyr
Amount of solvent used, mVyr (Hg/yr)
End product(s)
Operating Parameters
Period of operation, h/yr
Utilization rate, %
Actual operation, h/yr
No. of operators
Process Parameters
Coating composition
Solids
% by volume
Solvent(s)
X by volume
Coating equipment
Coating applicator
Drying oven
Coating application
Oven temperature, °C
Oven ventilation rate, n^/min
Solvent concentration in exhaust,
% LEL
Control device
Inlet temperature, °C
Inlet solvent concentration, ppmV
Uncontrolled VOC emissions .
from coating operation, Mg/yr
Rubber-coated
industrial fabric
ABC
169 274 548
110 178 282
(95) (154) (308)
<- Diaphragms, printing blankets •»
2,000a 4,000b 4,000
50 *
1,000 2,000 2,000
* 3
«- Rubber *
35
«• Toluene -»
65
«• Knife-over-roll, dip tank •»
«- Single-zone •»
«- 93 -»
102 102 118
28 23 40
82 ->
3,640 2,990 5,200
85.5 139 277
Urethane-coated
fabric
B C
306
168
(154)
<- Luggage, tent
4,000 4
50
2,000 2
4
«• Urethane
* 45
DHF, Toluene
«• 35,20
613
333
(308)
-,
,000
50
,000
4
-»
-»
-»
->
* Knife-over-roll -»
reverse-roll
*• Double-zone
177
102
26
166
3,380 5
154
-
177
131
40
166
,200
308
Rubber-coated
cord
A B
129
110
(95)
«• V-belts
2,000 4
50
1,000 2
2
*• Rubber
15
«• Toluene
85
209
178
(154)
Epoxy-coated
fiberglass
B C
488
199
(154)
975
390
(308)
•» <- Aircraft/military •*
,000
50
,000
2
-»
->
-»
•»
«- 40-cord dip tank ->
«- Triple-zone
232
102
28
221
3,640 2
85.5
-»
232
102
23
221
,990
139
products
4,000 4
50
2,000 2
4
«- Epoxy
60
«- Acetone
*• 40
< Dip tank
«- Single-zone
121
102
18
110
4,680 9
139
,000
50
,000
4
•>
•»
•*
•*
-»
-"
121
102
36
110
,360
277
^Period of operation 8 h/d, 5 d/wk, 50 wk/yr.
"Period of operation 16 h/d, 5 d/wk, 50 wk/yr.
^Standard conditions are 20°C and 1 atmosphere pressure.
Based on 90 percent of total VOC emissions except for the urethane coating operations which are based on 100 percent of total VOC emissions because urethane
coatings are purchased premixed and, therefore, have no coating mix preparation equipment emissions.
-------
TABLE 6-4b.
cn
i
UD
MODEL COATING OPERATION PARAMETERS FOR CONDENSATION CONTROL OPTION
(English Units)
Parameter
Production
Total volume of coating used, gal/yr
Amount of solvent used, gal/yr
(tons/yr)
End product(s)
Operating Parameters
Period of operation, h/yr
Utilization rate, %
Actual operation, h/yr
No. of operators
Process Parameters
Coating composition
Solids
% by volume
Solvent(s)
% by volume
Coating equipment
Coating applicator
Drying oven
Coating application
Oven temperature, °F
Oven ventilation rate, scfm
Solvent concentration in exhaust.
% LEL
Control device
Inlet temperature, °F
Inlet solvent concentration, ppmV
Uncontrotled VOC emissions .
from coating operation, tons/yr
Rubber-coated
industrial fabric
ABC
44,690 72,350 144,700
29,050 47,030 94,050
(105) (170) (340)
«- Diaphragms, printing blankets -»
2,000a 4,000b 4,000
50
1,000 2,000 2,000
«- 3 -»
<- Rubber •»
35
«• Toluene •»
65
«- Knife-over-roll, dip tank . •>
* Single-zone -»
200 -»
3,600 3,600 4,160
28 23 40
«• 180
3,640 2,990 5,200
94.5 153 306
Ure thane-coated
fabric
B C
80.900 161,
44,500 88,
Rubber-coated
cord
900
050
i (170) (340)
«- Luggage, tents
4,000 4,
50
2,000 2,
4
*• Urethane
45
«- DMF, Toluene
35,20
«• Knife-over-roll
reverse- roll
«• Double- zone
350
3,600 4,
26
330
3,380 5,
170
.,
000
50
000
4
-»
->
-»
•»
-»
A
34,180
29,050
(105)
<- V-belts
2,000
50
1,000
2
<- Rubber
15
«- Toluene
85
«- 40-cord dip
B
55,330
47,030
(170)
-*
4,000
50
2,000
2
-»
•-»
-»
•»
tank -»
-» <- Triple-zone ->
350
620
40
330
200
340
450
3,600
28
430
3,640
94.5
450
3,600
23
430
2,990
153
Epoxy-coated
fiberglass
B
128,000 257
52,520 103
(170)
C
,600
,030
(340)
<- Aircraft/military-*
products
4,000 4
50
2,000 2
4
«- Epoxy
60
*• Acetone
<- 40
<- Dip tank
<- Single-zone
250
3,600 3
18
230
4,680 9
153
,000
50
,000
4
->
-»
->
->
-•
-»
250
,600
36
230
,360
306
?Period of operation 8 h/d, 5 d/wk, 50 wk/yr.
^Period of operation 16 h/d, 5 d/wk, 50 wk/yr.
^Standard conditions are 68°F and 1 atmosphere pressure.
Based on 90 percent of total VOC emissions except for the urethane coating operations which are based on 100 percent of total VOC emissions because urethane
coatings are purchased premixed and, therefore, have no coating mix preparation equipment emissions.
-------
TABLE 6-5. MODEL COATING OPERATION PARAMETERS FOR SUBSTRATE TYPE AND CONSUMPTION
Parameter A
Product 1 <-
Substrate
Type
Width, inches <-
Coated substrate, yd2/yr 580,970
Product 2 «•
Substrate
Type c
Width, inches
Coated substrate, yd2/yr 137,508
Rubber-coated
industrial fabric
8 C
Diaphragms -»
Nylon fabric -»
48 -»
940.550 1,881,100
Printing blankets -»
Cotton fabric -»
72
222,616 445,230
Urethane-coated
fabric
B C
«- Luggage ->
*• 8-ounce polyester ->
60 60
4,700.290 9,406,390
«• Tents -»
* Nylon fabric ->
60 60
13,091,481 26,199,144
Rubber-coated Epoxy-coated
cord fiberglass
ABB C
<- V-belts •» «- Aircraft/ •*
military products
«- Nylon cord -> <- Fiberglass »
* Cord -> 72 72
193 313 1,512,112 3,024,224
tons/yr tons/yr
N/Ab -> «• N/A
.Plant size based on solvent consumption.
ov Not applicable.
-------
6.1.3.3 Process Equipment. The primary types of equipment used
for applying the coating to the substrate are knife-over-roll, dip tank,
and reverse-roll coaters.3 All three types of coating application
methods are included in the model coating operation parameters, where
applicable, for subsequent evaluation of the economic impact of various
regulatory alternatives.
The drying ovens and drying temperatures are representative of
those used by polymeric coating plants to dry/cure each of the coating
types. The ventilation rates for the drying ovens were calculated based
on oven operation at a percentage of the lower explosive limit (LEL) of
the solvents.12 The LEL values are assumed to be representative of
those that will be used in the industry.
6.1.3.4 VOC Capture and Control Devices. The VOC capture devices
used on the coating application/flashoff area of the model coating
operations are total enclosures and partial enclosures. The calculation
of the ventilation rates required is based on specific suction velocity
and design of the vents located at either side of the substrate in the
application/flashoff area. The exhaust air from the total and partial
enclosures is directed into the oven and through the VOC control device.12
The VOC control devices used at polymeric coating plants are carbon
adsorbers, incinerators, and condensation systems.1 Model coating
operation parameters have been developed for fixed-bed carbon adsorbers
and thermal incinerators because these are the most commonly used control
devices. Separate model coating operation parameters are also provided
for a condensation system using an air atmosphere. Effective control of
fugitive VOC emissions from the application/flashoff area has not been
demonstrated when a condensation system using an inert atmosphere in the
oven is used. Therefore, model coating operations parameters were not
developed for this control device.
For model coating operations controlled by carbon adsorbers or
incinerators, the drying oven exhaust rate was calculated for each
solvent mixture and usage rate assuming operation of the oven at a
concentration of 25 percent of the LEL of the solvents. The ovens can
be designed to operate safely at this level, and ovens are operated at
this level in other similar surface coating operations. While perhaps
6-11
-------
more cost effective, a higher VOC concentration was not chosen due to
the increased potential for premature breakthrough and carbon bed fires.
Furthermore, carbon adsorption can achieve 95-percent or greater removal
efficiencies cost effectively when the VOC concentration in the exhaust
stream is 25 percent of the LEL.
For model coating operations controlled by air atmosphere
condensation systems, the drying oven exhaust rate was calculated for
each solvent mixture and usage rate assuming operation of the oven at
40 percent of the LEL. This solvent concentration was based on discus-
sions with an equipment vendor on condensation system design
considerations and is necessary to operate the unit cost effectively.14
In order to capture most of the emissions from the enclosure, a
minimum face velocity of 0.6 m/s (100 ft/min) must be maintained at all
openings according to standard industrial ventilation practices. This
results in a minimum oven ventilation rate of 102 mVmin (3,600 scfm),
which is the sum of the exhaust from the capture device and the
infiltration from the two openings in the oven for substrate entrance
and exit. Therefore, some model coating operation parameters include
solvent concentrations in the oven exhaust of less than 25 and 40 percent
for carbon adsorber or incinerator and condensation system control,
respectively.
6.2 REGULATORY ALTERNATIVES
Separate regulatory alternatives have been developed for solvent
storage tanks, coating mix preparation equipment, and coating operations.
The regulatory alternatives considered for solvent storage tanks, coating
mix preparation equipment, and coating operations represent the various
emission control levels that are achievable based on available emission
control equipment. The control levels assigned to the regulatory alter-
natives are calculated using estimated uncontrolled emission rates and
estimated efficiencies of various capture and control device options.
6.2.1 Solvent Storage Tanks
The regulatory alternatives for solvent storage tanks are presented
in Table 6-6. The four alternatives for the tanks are:
6-12
-------
TABLE 6-6. REGULATORY ALTERNATIVES FOR SOLVENT STORAGE TANKS
Reg. Alt. Control device
I None
II Conservation vents, set at 17.2 kPa
(2.5 psig)
III Pressure relief valves, set at 103.4 kPa
(15 psig)
IV Carbon adsorber or condensation system
Percent
VOC
control
0
70a
90a
95
Approximate control level based on ratio of calculated breathing losses
to calculated total emissions from tanks.
6-13
-------
1. Alternative I. Baseline. (No control). This case represents
uncontrolled solvent storage tanks. Most States do not require any
control of emissions from this source.
2. Alternative II. (70-percent control). This case represents
the approximate level of emission reduction achievable by control of
breathing losses by the use of conservation vents set at 17.2 kPa
(2.5 psig) installed on solvent storage tanks.
3. Alternative III. (90-percent control). This case represents
the approximate level of emission reduction achievable by control of
breathing losses by the use of pressure relief valves set at 103 kPa
(15 psig) installed on storage tanks.
4. Alternative IV. (95-percent control). This control level can
.«.
be achieved by venting all storage tank emissions to a control device
that is 95-percent efficient.
6.2.2. Coating Mix Preparation Equipment
The regulatory alternatives for coating mix preparation equipment
are presented in Table 6-7. The three alternatives are:
1. Alternative I. Baseline. (No control). This case represents
uncontrolled coating mix preparation equipment. The States do not
require any control of emissions from this source.
2. Alternative II. (40-percent control). This case represents
the approximate level of emission reduction achievable by control of
breathing Tosses by installation of fastened, gasketed covers with
conservation vents on each piece of coating mix preparation equipment.
3. Alternative III. (95-percent control). This case represents
the emission reduction achievable by covering the coating mix preparation
equipment and ducting the vapors to a control device that is 95-percent
efficient.
6.2.3. Coating Operation
The regulatory alternatives for the coating operation with the
associated emission capture and control device configurations are
presented in Table 6-8. The three alternatives are:
1. Alternative I. Baseline. (81-percent control). This case
corresponds to the Control Techniques Guideline (CTG) recommended emission
limit of 0.35 kg VOC/liter (2.9 Ib VOC/gallon) of coating, minus water
6-14
-------
TABLE 6-7. REGULATORY ALTERNATIVES FOR COATING MIX PREPARATION EQUIPMENT
Reg. Alt.
I
II
Control device.
None
Fastened, gasketed covers with
Percent
VOC
control
0
40a
conservation vents
III Carbon adsorber or condensation system 95
Approximate control level based on ratio of calculated breathing losses
to calculated total emissions from tanks.
6-15
-------
TABLE 6-8. REGULATORY ALTERNATIVES FOR COATING OPERATIONS
en
I
(71
Reg.
Alt.
I
II
III
IV
Recommended
Emission capture
Appl i cati on/fl ashof f
Suction into oven
Partial enclosure
Total enclosure
Total enclosure
abatement
a
Oven
Negative
pressure
Negative
pressure
Negative
pressure
Negative
pressure
technology
Emission control
Carbon adsorber
or condensation
system
Carbon adsorber
or condensation
system
Carbon adsorber
or condensation
system
Incinerator
Emission
capture
efficiency,
percent
90
95
98
98
Control
device
efficiency,
percent
90b
95C
95C
98C
Overall
VOC
control ,
percent
81
90
93
96
all the alternatives, the use of well-
Recommended efficiency of carbon adsorber
Based on actual emission measurements.
designed oven with no losses to room is assumed.
in the CTG.
-------
for existing polymeric coating plants and is based on application of
reasonably available control technology (RACT) to polymeric coating
operations. The 81-percent control level of Alternative I assumes that
plants are capturing and venting 90 percent of the emissions from the
coating operation to a control device that achieves 90-percent VOC
control.
2. Alternative II. (90-percent control). The 90-percent control
level of Alternative II can be achieved by capturing approximately
95 percent of all VOC emissions from the coating operation and by venting
these emissions through a control device that achieves 95-percent control
efficiency. The required 95-percent capture efficiency can be achieved
by use of a partial enclosure to collect a portion of the emissions from
the coating application/flashoff area in addition to capturing the
drying oven emissions.
3. Alternative III. (93-percent control). This case is based on
capture of at least 98 percent of the emissions from the coating operation
and control of these emissions by a 95-percent-efficient control device.
This results in an overall 95-percent control level. The required
98-percent capture efficiency can be achieved by use of a total enclosure
to collect emissions from the application/flashoff area in addition to
capturing drying oven emissions.
4. Alternative IV. (96-percent control). This case is based on
capture of at least 98 percent of emissions from the coating operation
and control by a 98-percent-efficient control device. Capture of coating
operation emissions can be achieved by use of a total enclosure around
the application/flashoff area and by capturing 100 percent of drying
oven emissions.
6.2.4. Low-Solvent Coatings
An optional technique for achieving emission reductions equivalent
to or greater than those associated with the regulatory alternatives is
the use of low-solvent coatings (waterborne or higher solids). Reformula-
tion to low-solvent-coatings is not a universally applicable solution
because adequate substitutes for traditional solvent borne coatings are
not yet available for many products. Because it is not a universally
6-17
-------
available alternative, the use of low-solvent coatings was not considered
as a regulatory alternative.
Due to the wide range of products produced by polymeric coaters,
there is a significant range of coating formulations in use. No single
formulation can represent all of the coatings in use. Because of the
lack of a single baseline coating for polymeric coating plants, the use
of low-solvent coatings could not be considered an option to achieving
the emission reductions required by Regulatory Alternatives II through
IV. For example, a polymeric coating plant that is currently using a
coating containing 4.70 Ib VOC/gal of coating applied would have to
switch to a coating containing 0.83 Ib VOC/gal coating (12-percent
solvent) to achieve an emission reduction equivalent to Regulatory
Alternative III (93-percent control). A plant that is currently using a
lower solvent coating (2.64 Ib VOC/gal coating) would have to switch to
a coating containing 0.30 Ib VOC/gal of coating (4-percent solvent) to
obtain the same emission reduction. In other words, the second plant,
which is already using a low-solvent coating, would have to switch to a
far lower solvent content coating than the first plant. Because of this
differential impact, the use of low-solvent coatings was not considered
as an option to the regulatory alternatives, but it would be permitted as
an alternative means of compliance as determined on a case-by-case basis
by the Administrator.
6.3 REFERENCES FOR CHAPTER (>
1. Memorandum from Thorneloe, S., MRI, to Elastomeric Coating of
Fabric Project File. May 9, 1984. Typical process parameters for
elastomeric coating of fabrics, facilities using VOC control devices.
2. Memorandum from Maurer, E., MRI, to Elastomeric Coating of Fabrics
Project File. April 12, 1984. Estimated solvent consumption at
facilities performing elastomeric coating of fabrics.
3. Memorandum from Maurer, E., MRI, to Elastomeric Coating of Fabric
Project File. April 23, 1984. Coating operation equipment design
and operating parameters.
4. Memorandum from Friedman, E., MRI, to Polymeric Coating of Supporting
Substrates Project File. July 27, 1984. Information.on mix room
equipment.
6-18
-------
5. Memorandum from Hester, C., MRI, to Grumpier, D., EPA. February 17,
1984. Preliminary Section 9.1—Industry characterization.
6. Memorandum from Maurer, E., MRI, to Elastomeric Coating of Fabric
Project File. April 12, 1984. Estimated solvent consumption at
facilities performing elastomeric coating of fabrics.
7. Telecon. Friedman, E., MRI, with Coffey, F., Southern Tank and
Pump Company. August 23, 1984. Information on solvent storage
tanks.
8. VOC Emissions from Volatile Organic Liquid Storage Tanks—Background
Information for Proposed Standards. Draft. U. S. Environmental
Protection Agency. Research Triangle Park, North Carolina. Report
No. EPA-450/3-81-003a. June 1983. pp. 3-25 to 3-26.
9. Telecon. Friedman, E., MRI, with Herman, K., Sherman Machinery.
August 29, 1984. Information on coating preparation equipment.
10. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Webs Project File. June 21, 1984. Summary of information on
coatings used in the process of elastomeric coating of fabric.
11. Memorandum from Friedman, E., MRI, to Polymeric Coating of Supporting
Substrates Project File. September 18, 1984. Product specific raw
material costs for model coating lines.
12. Memorandum from Banker, L., MRI, to Polymeric Coating of Supporting
Substrates Project File. November 20, 1984. Calculation of Drying
Oven Ventilation Rates for Model Coating Lines.
13. Flexible Vinyl Coating and Printing Operations—Background Information
for Proposed Standards. Draft. U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina. Report
No. EPA/450/3-81-016a. January 1983. p. 6-6.
14. Telecon. Thorneloe, S., MRI, with Memering, L,, United Air Specialists,
Inc. May 25, 1984. Information on the Kon-den-Solver condensation
system.
6-19
-------
7. ENVIRONMENTAL AND ENERGY IMPACTS
This chapter presents an analysis of the environmental and energy
impacts of the regulatory alternatives for model solvent storage tanks,
coating mix preparation equipment, and coating operations. The incremental
increase or decrease in air pollution, water pollution, solid waste
generation, and energy consumption for the regulatory alternatives
compared to baseline are discussed. These impacts are examined for
individual coating lines.
Separate regulatory alternatives have been developed for solvent
storage tanks, coating mix preparation equipment, and coating operations.
The regulatory alternatives used in the impact analyses for model solvent
storage tanks and coating mix preparation equipment are summarized in
Tables 6-6 and 6-7, respectively. The regulatory alternatives used in
the impact analyses for model polymeric coating operations are summarized
in Table 6-8.
7.1 AIR POLLUTION IMPACTS
Volatile organic compounds (VOC's) are emitted from several points
in the polymeric coating of supporting substrates. The largest single
source of VOC emissions is the drying oven used to evaporate the solvent
and cure the coating. Fugitive VOC emissions are emitted from around
the coating application/flashoff area. Volatile organic compound emissions
also occur during coating preparation activities, solvent storage, and
cleanup of the coater and ancillary equipment. Some solvent (0 to
20 percent of solvent applied, below 5 percent on an average) may be
retained in the product depending on the product type and specification.
In an uncontrolled line, the entire amount of solvent used is vented to
»
the atmosphere. The VOC emissions can be controlled by use of add-on
7-1
-------
control equipment such as carbon adsorbers, incinerators, and condensers.
Carbon adsorber and condenser control systems recover solvent for reuse
in coating mix formulations.
7.1.1 Primary Air Pollution Impacts
The annual VOC emission levels associated with the application of
each regulatory alternative l:or model solvent storage tanks and coating
mix preparation equipment ar« presented in Tables 7-1 and 7-2, respectively.
The annual VOC emission levels associated with the application of each
regulatory alternative for model coating operations are presented in
Table 7-3. The annual emissions were calculated using the model solvent
storage tanks, coating mix preparation equipment, and coating operation
parameters given in Chapter 6. The range in annual uncontrolled emissions
are as follows:
1. Model solvent storage tanks--0.06 to 0.27 Mg (0.07 to 0.30 tons);
2. Model coating mix preparation equipment--9.5 to 30.8 Mg (10.5
to 34 tons); and
3. Model coating operation—85.7 to 308.4 Mg (94.5 to 340 tons).
The range in annual VOC emissions are as follows for Regulatory Alter-
natives II, III, and IV for model solvent storage tanks, II and III for
coating mix preparation equipment, and II, III, and IV for model coating
operations:
1. Model solvent storage tanks—0.002 to 0.08 Mg (0.002 to 0.09 tons);
2. Model coating mix preparation equipment—0.5 to 19 Mg (0.5 to
20 tons); and
3. Model coating operation—3.4 to 31 Mg (3.8 to 34 tons).
The annual VOC emission incremental reduction beyond baseline for model
solvent storage tanks, coating mix preparation equipment, and coating
operations are given in Tables 7-1, 7-2, and 7-3, respectively.
The primary impact of a VOC emission reduction in this industry is
a potential decline in ambient VOC levels and thus a reduction in subsequent
ozone and photochemical smog formation. For plants in rural areas or
areas of low ambient nitrogen oxide and ozone concentrations, the primary
environmental impact is the prevention of transport of VOC's in the
atmosphere to locations where ozone and photochemical smog are problems.
7-2
-------
7.1.2 Secondary Air Pollution Impacts
Secondary emissions of air pollutants result from generation of the
energy required to operate the control devices. Electrical energy is
needed primarily to operate the motors and fans used to capture and
convey gases to different sections of the control system. Generation of
the electric power required to operate carbon adsorbers, incinerators,
and condensers will result in particulate matter (PM), sulfur oxide
(SO ), nitrogen oxide (NO ), and carbon monoxide (CO) emissions. The
X X
combustion of natural gas in incinerators will result in PM, NO , and
carbon monoxide (CO) emissions. The combustion of fuel oil in the boiler
used to produce steam for the fixed-bed carbon adsorption system will
also result in PM, SO , NO , and CO emissions.
/\ *\
Secondary emissions were calculated assuming that electric power to
the control device was supplied by a coal-fired power plant. The thermal
efficiency of the electric generator was assumed to be 33 percent. Also
for this analysis it was assumed that for all types of power plants and
all ages of plants, the estimated emissions per Btu of heat input in
1990 are approximately equal to the current new source performance
standards (NSPS) for coal-fired power plants.1 Therefore, the secondary
emissions were calculated using the NSPS values.2 The applicable standards
limit PM emissions to 15 kg/TJ* (0.03 lb/10 Btu) of heat input, SO
J\
emissions to 520 kg/TJ (1.20 lb/106 Btu) of heat input, and NOV emissions
X
to 260 kg/TJ (0.60 lb/106 Btu) of heat input.3 There are no annual
secondary pollutant emissions associated with Regulatory Alternatives I,
II, and III for model solvent storage tanks and I and II for coating mix
preparation equipment. The annual secondary pollutant emission levels
associated with application of Regulatory Alternative IV for the model
solvent storage tanks is negligible. The annual secondary pollutant
emission levels associated with the application of Regulatory Alter-
native III for model coating mix preparation equipment and the annual
secondary pollutant levels associated with each of the regulatory
alternatives for the model coating operations are presented in Tables 7-4,
*TJ = Terajoules = 1012 joules.
7-3
-------
7-5, and 7-6. Annual secondary emissions of PM for model coating operations
range from 2.7 to 56 kg (5. Si to 124 Ib). The annual secondary SO
/\
emissions for model coating operations range from 107 to 2,260 kg (236
to 4,980 Ib). The annual secondary NO emissions for model coating
/\
operations range from 54 to 1,130 kg (118 to 2,490 Ib).
The combustion of natural gas as supplemental fuel in incinerator
control devices results in secondary air pollutants. Assuming the
incinerator generates pollutants at a rate comparable to that of an
industrial process boiler, the secondary emissions were calculated using
emission rates of 5 kg/TJ (0.011 lb/106 Btu) of heat input for particulates,
8 kg/TJ (0.019 lb/106 Btu) for CO, and 84 kg/TJ (0.194 lb/106 Btu) for
NO .4 The annual secondary emissions for Regulatory Alternative IV for
y\
each model coating operation are presented in Table 7-7.
The major secondary air pollution impacts for fixed-bed carbon
adsorption systems are the emissions from the boiler used to produce
steam. The steam is used to strip the carbon bed of adsorbed VOC at a
ratio of 4 kilograms of steam per kilogram (4 Ib steam/1b) of recovered
solvent. Assuming that the boiler uses fuel oil containing 1.5 percent
sulfur by weight and that the thermal efficiency of the boiler is 80 percent,
estimates can be made of the levels of secondary emissions. For particu-
lates, the emission rate is 50 kg/TJ (0.12 lb/106 Btu) of heat input;
for S0x, it is 690 kg/TJ (1.6 lb/106 Btu); for NOX, it is 170 kg/TJ
(0.4 lb/106 Btu); and for CO, it is 14.5 kg/TJ (0.034 lb/106 Btu).5 The
secondary emissions for those regulatory alternatives that require the
generation of steam are presented in Tables 7-8 through 7-11. Annual
emissions of PM for model coating operations range from 51 to 275 kg
(111 to 606 Ib). Annual emissions of SO for model coating operations
^
range from 661 to 3,598 kg (1,458 to 7,930 Ib). Annual emissions of NO
/\
for model coating operations range from 169 to 917 kg (371 to 2,020 Ib).
Annual emissions of CO for model coating operations range from 14 to
76 kg (31 to 168 Ib).
The magnitude of the secondary pollutants generated by the operation
of the control system is much smaller than the magnitude of solvent
M
emissions being recovered. F:or the worst case, the largest amount of
secondary emissions result from the application of Regulatory
7-4
-------
Alternative III for the control (by a carbon adsorber) of a urethane
coating line (line designation C). VOC emissions are reduced from 308
to 22 Mg (340 to 24 tons) annually, while 4.3 Mg (4.7 tons) of secondary
pollutants are emitted annually.
7.2 WATER POLLUTION IMPACTS
There are no wastewater effluents from an uncontrolled polymeric
coating line or from the use of incinerators and condensation systems
using a nitrogen atmosphere. There are some wastewater effluents from
the use of fixed- and fluidized-bed carbon adsorbers and condensation
systems using an air atmosphere. The amount of this wastewater discharge
depends on the amount of water vapor in the solvent laden air, solubility
of solvent in water, and whether or not the mixture is distilled. For
this analysis, this amount is assumed to be negligible for fluidized-bed
carbon adsorber and condensation systems using an air atmosphere.
Wastewater problems do arise from the use of fixed-bed carbon
adsorbers. In a fixed-bed carbon adsorption system, water is used to
produce steam, which is then used to strip adsorbed solvent from the
carbon beds. Upon completion of the stripping operation, the solvent-steam
vapors are condensed and fed to a decanter where the water insoluble
organic layer separates from the water and water soluble organic layer.
Water soluble organics can be separated by distillation, but trace
amounts of organics could remain in the aqueous discharge. The wastewater
discharged after the solvent has been decanted poses a potential adverse
environmental impact resulting from possible organic contamination of
the water. Even if the solvent is considered immiscible in water, trace
concentrations of solvent may become fixed in the water during the
operation of the condensation stage.
7.2.1 Coating Operation Wastewater Emissions
The annual wastewater discharges associated with each model coating
operation and regulatory alternative (for model coating mix preparation
equipment and coating operations) requiring fixed-bed carbon adsorber
control are presented in Tables 7-12 and 7-13. There are no annual
wastewater discharges associated with regulatory alternatives for model
solvent storage tanks. As shown, annual wastewater discharges range from
7-5
-------
36 to 117 m3 (9,600 to 31,000 gal) for model coating mix preparation
equipment and 278 to 1,170 m:J (73,500 to 310,000 gal) for model coating
operations.
The annual wastewater VOC emissions associated with each regulatory
alternative are based on the solvent concentration of the wastewater
discharge. The VOC concentration of the wastewater effluent is dependent
on the requirements of solvent purification for each model coating
operation line. Model coating operations 1 and 3 use a single solvent
(toluene) that has a 0.05 percent miscibility in water. Therefore, the
solvent does not require purification after decantation for reuse in the
coating formulation.6 The solvent concentration in the wastewater
discharge for model coating operations 1 and 3 is, therefore, based on
the solubility of toluene in water, which is 500 ppm.7 Recovered solvent
from model coating operation 2 requires a distillation system because
more than one solvent is used. A distillation system will provide a
solvent purity of 98 percent with 100 ppm in the water effluent. Recovered
solvent from model coating operation 4 also requires a distillation
system because acetone, which is completely miscible in water, is used.
A distillation system will provide a solvent purity of 99.9 percent with
10 ppm in the water effluent.15
The annual wastewater VOC emissions associated with each regulatory
alternative for model coating mix preparation equipment and coating
operations are presented in Tables 7-12 and 7-14, respectively. For
model coating operations 1 and 3, which do not require solvent purification
after decantation, the maximum organic load is 8.2 percent of the total
air emissions shown in Table 7-3. For model coating operation 2, based
on a solvent concentration of 100 ppm in the wastewater discharge, the
maximum organic load is 1.7 percent of the total air emissions shown in
Table 7-3. For model coating operation 4, based on a solvent concentration
of 10 ppm in the wastewater discharge, the maximum organic load is
0.2 percent of the total air emissions shown in Table 7-3.
The potential impacts of the organics are further lessened because
of the availability of an ample number of water pollution control tech-
nologies. These treatment technologies include recycling tfie condensate
into the steam-generating stream, which could allow a 95 percent or
7-6
-------
greater reduction of solvent discharge.9 The effects of recycling on
boiler life are undetermined. Other control options are aqueous-phase
carbon adsorption, activated sludge treatment, and oxidation of the
organics.9
7.3 SOLID WASTE IMPACTS
7.3.1 Line Impacts
The only solid waste impacts from the add-on control systems result
from the use of carbon adsorption units. The activated carbon in these
units gradually degrades during normal operation. The efficiency of the
carbon eventually drops to a level such that replacement is necessary,
thereby creating a solid waste load. The average carbon life was estimated
to be 5 years. The amount of waste generated annually for various size
lines for each of the regulatory alternatives is presented in Table 7-15.
Annual solid waste disposal impacts range from 144 to 1,250 kg (296 to
2,500 Ib) for model coating operations. Three alternatives are available
for handling the waste carbon material: (1) landfill ing the carbon,
(2) reactivating the carbon and reusing it in the adsorber, and (3) using
the carbon as fuel. Landfill ing is simple and efficient because the
technology for the operation is considered common practice. No environ-
mental problems would occur if the landfill site has been properly
constructed. If the site is not secured by a lining of some type (either
natural or artificial), possible soil leaching could occur. The leachate
may contain traces of organics which have been left on the carbon as
residues. Transmission of this leachate into ground and surface waters
would represent a potential environmental impact.
The second, and most common, alternative for handling the waste
carbon material does not create any significant amount of solid waste.
Most of the carbon is reactivated and reused in the carbon adsorber.
Disposal of waste carbon represents only 5 to 10 percent of the carbon
used. Disposal of this waste by landfill ing poses minimal environmental
problems provided the landfill site is properly constructed.
The third method involves selling the waste carbon as a fuel. The
physical and chemical structure of the carbon in combinatiqn with the
hydrocarbon residues make the waste a fuel product similar to other
7-7
-------
solid fuels such as coal. Potential users of this fuel include industrial
and small utility boilers. Eiecause activated carbon generally contains
very little sulfur, furnace >>02 emissions resulting from combustion
would be negligible. Particulates and NO emissions from the burning of
/\
activated carbon would be comparable to those of coal-fired operations.
However, the use of this disposal method would be limited because of the
small quantities of carbon generated by lines in this industry.
7.4 ENERGY IMPACTS
The air emission control equipment for polymeric coating utilizes
two forms of energy: electrical energy and fossil fuel energy. Electrical
energy is used in the carbon adsorber, incinerator, and condensation
control systems. The electrical energy is required to operate fans,
cooling tower pumps and fans, boiler support systems, and all control
system instrumentation. Fuel oil is used in steam generation for fixed-bed
carbon adsorption units and natural gas is used for supplemental fuel in
incineration units. Electrical energy and steam are also required for
the distillation systems used to separate and purify recovered solvents
from typical sized lines.
7.4.1 Electricity and Fossil Fuel Impacts.
The annual electricity consumption calculated for each model operation
and regulatory alternative is presented in Table 7-16. Table 7-17 shows
the annual natural gas demand for incinerators associated with Regulatory
Alternative IV. Incinerators may use primary or secondary heat recovery
to reduce energy consumption. A heat recovery factor of 35 percent was
used in the energy analysis. Table 7-18 shows the annual steam demand
for each model plant and regulatory alternative. The total annual
energy demand for each regulatory alternative is presented in Table 7-19.
Comparison of the total energy demand of each regulatory alternative
shows that energy consumption does not increase significantly with
increased VOC control, except for regulatory alternatives requiring
incinerators.
7.5 NATIONWIDE FIFTH-YEAR IMPACTS
Table 7-20 presents the fifth-year impacts at various regulatory
alternatives. These impacts are based on the projection of 18 new
7-8
-------
coating lines being built by 1990. Table 7-21 presents the fifth-year
impacts at various regulatory alternatives beyond baseline.
7.6 OTHER ENVIRONMENTAL IMPACTS
The impact of increased noise levels is not a significant problem
with the emission control systems used at polymeric coating plants. No
noticeable increases in noise levels occur as a result of increasingly
stricter regulatory alternatives. Fans and motors, present in the
majority of the systems, are responsible for the bulk of the noise in
the control operations.
7.7 OTHER ENVIRONMENTAL CONCERNS
7.7.1 Irreversible and Irretrievable Commitment of Resources
As discussed in Section 7.4, the regulatory alternatives will
result in an increase in the irreversible and irretrievable commitment
of energy resources. However, this increased energy demand for pollution
control by carbon adsorption systems, condensers, and incinerators is
insignificant compared to the total line energy demand.
7.7.2 Environmental Impact of Delayed Standard
Because the water pollution and energy impacts are small, there is
no significant benefit to be achieved from delaying the proposed standards.
Furthermore, there does not appear to be any emerging emission control
technology that achieves greater emission reduction or that achieves an
emission reduction equal to that of the regulatory alternatives at a
lower cost than those represented by the control devices considered
here. Consequently, there are no benefits or advantages to delaying the
proposed standards.
7-9
-------
TABLE 7-1. ANNUAL AIR POLLUTION IMPACTS OF THE REGULATORY ALTERNATIVES AND VOC
EMISSION REDUCTION BEYOND BASELINE FOR MODEL SOLVENT STORAGE TANKS
Rubber-coated
industrial fabric
Emissions
Reg. Alt. I, Unc.
Mg
tons
Reg. Alt. II, Unc. x 0.3
Mg
tons
Reg. Alt III, Unc. x 0.1
Mg
tons
Reg. Alt. IV, Unc. x 0.05
Mg
tons
Emission reduction vs.
Reg. Alt. ID
Reg. Alt. II
Mg
tons
A
0.06
0.07
0.02
0.02
0.01
0.01
0.00
0.00
0.04
0.05
B
0.11
0.12
0.03
0.04
0.01
0.01
0.01
0.01
t
0.08
0.08
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
Urethane-
coated
fabric
C B C
27 a a
30 a a
08 a a
09 a a
03 a a
03 a a
01 a a
02 a a
19 a a
21 a a
Rubber-
coated cord
0.
0.
0.
0.
0.
0.
0.
0.
.:-,
0.
0.
A
06
07
02
02
01
01
00
00
04
05
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
B
11
12
03
04
01
01
01
01
08
08
Epoxy-coated
fiberglass
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
B
11
12
03
04
01
01
01
01
08
08
C
0.27
0.30
0.08
0.09
0.03
0.03
0.01
0.02
0.19
0.21
(continued)
-------
TABLE 7-1. (continued)
Rubber-coated
industrial fabric
Reg. Alt. Ill
Mg
tons
Reg. Alt. IV
Mg
tons
0.
0.
0.
0.
A
06
06
06
07
6
0.10
0.11
0.10
0.11
C
0.24
0.27
0.26
0.29
Urethane-
coated
fabric
B
a
a
a
a
C
a
a
a
a
Rubber-
coated cord
0.
0.
0.
0.
A
06
06
06
07
B
0.10
0.11
0.10
0.11
Epoxy-coated
fiberglass
B
0.10
0.11
0.10
0.11
C
0.24
0.27
0.26
0.29
.Not applicable.
Reg. Alt. I is baseline.
-------
TABLE 7-2. ANNUAL AIR POLLUTION IMPACTS OF THE REGULATORY ALTERNATIVES AND VOC
EMISSION REDUCTION BEYOND BASELINE FOR MODEL COATING MIX PREPARATION EQUIPMENT
I-J
ro
Emissions
Reg. Alt. I, Unc.
Mg
tons
Reg. Alt. II, Unc. x 0.6
Mg
tons
Reg. Alt III, Unc. x 0.05
Mg
tons
Emission reduction vs.
Reg. Alt. ID
Reg. Alt. II
Mg
tons
*
Reg. Alt. Ill
Mg
tons
Urethane-
Rubber-coated coated
industrial fabric fabric
A B C B C
9.5 15.4 30.8 a a
10.5 17 34 a a
5.7 9.3 18.5 a a
6.3 10.2 20.4 a a
0.5 0.8 1.5 a a
0.5 0.9 1.7 a a
3.8 6.2 12.3 a a
4.2 6.8 13.6 a a
9.0 14.6 29.3 a a
10.0 16.2 32.3 a a
Rubber-
coated cord
A
9.5
10.5
5.7
6.3
0.5
0.5
3.8
4.2
9.0
10.0
B
15.4
17
9.3
10.2
0.8
0.9
6.2
6.8
14.6
16.2
Epoxy-coated
fiberglass
B
15.4
17
9.3
10.2
0.8
0.9
6.2
6.8
14.6
16.2
C
30.8
34
18.5
20.4
1.5
1.7
12.3
13.6
29.3
32.3
.Not applicable.
Reg. Alt. I is baseline.
-------
TABLE 7-3. ANNUAL AIR POLLUTION IMPACTS OF THE REGULATORY ALTERNATIVES AND VOC
EMISSION REDUCTION BEYOND BASELINE FOR MODEL COATING OPERATIONS
-J
I
Rubber-coated
industrial fabric
Emissions
Uncontrolled
Mg
tons
Reg. Alt. I, Unc. x 0.19
Mg
tons
Reg. Alt II, Unc. x 0.1
Mg
tons
Reg. Alt. Ill, Unc. x 0.07
Mg
tons
Reg. Alt. IV, Unc. x 0.04
Mg
tons
A
85.7
94.5
16.3
18.0
8.6
9.5
6.0
6.6
3.4
3.8
B
138.
153.
26.
29.
13.
15.
9.
10.
5.
6.
8
0
4
1
9
3
7
7
6
1
.C
277.5
306.0
52.7
58.1
27.8
30.6
19.4
21.4
11.1
. 12.2
Urethane-
coated
fabric
B
154.2
170.0
29.3
32.3
15.4
17.0
10.8
11.9
6.2
6.8
C
308.4
340.0
58.6
64.6
30.8
34.0
21.6
23.8
12.3
13.6
Rubber-
coated cord
A
85.7
94.5
16.3
18.0
8.6
9.5
6.0
6.6
3.4
3.8
B
138.
153.
26.
29.
13.
15.
^9.
10.
5.
6.
8
0
4
1
9
3
7
7
6
1
Epoxy- coated
fiberglass
B
138.8
153.0
a
138. 8a
153. Oa
13.9
15.3
9.7
10.7
5.6
6.1
C
277.5
306.0
a
277. 5a
306. Oa
27.8
30.6
19.4
21.4
11.1
12.2
(continued)
-------
TABLE 7-3. (continued)
—I
(-•
*»
Rubber-coated
industrial fabric
ABC
Urethane-
coated
fabric
B C
Rubber-
coated cord
A B
Epoxy-coated
fiberglass
B C
Emission reduction vs.
Reg. Alt. Ip
Reg. Alt. II
Mg
tons
Reg. Alt. Ill
Mg
tons
Reg. Alt. IV
Mg
tons
7.
8.
10.
11.
12.
14.
7
5
3
3
9
2
12.
13.
16.
18.
20.
23.
5
8
7
4
8
0
25.0
27.5
33.3
36.7
41.6
45.9
13.9
15.3
18.5
20.4
23.1
25.5
27.8
30.6
37.0
40.8
46.3
51.0
7.7
8.5
10.3
11.3
12.9
14.2
12.5
13.8
16.7
18.4
20.8
23.0
124.9
137.7
129.1
142.3
133.2
146.9
249.7
275.4
258.1
284.6
266.4
293.8
Emissions are same as uncontrolled.
Reg. Alt. I is baseline.
-------
-vl
J
TABLE 7-4. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR PARTICULATE MATTER
EMISSIONS FROM ELECTRICAL ENERGY GENERATION FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
ABC
Urethane-
coated
fabric
B C
Rubber-
coated cord
A B
Epoxy-coated
fiberglass
B C
Emissions
Reg. Alt. III-CA3
(Mix equipment)
kg
lb
Coating operation
Reg. Alt. I-CA
kg
lb
Reg. Alt. I-Cond.a
kg
lb
Reg. Alt. II-CA
kg
lb
Reg. Alt. II-Cond.
kg
lb
0.2
0.4
2.9
6.5
28
62
2.9
6.5
28
62
0.2
0.3
5.2
11.5
56
124
5.2
11.5
56
124
0.3
0.7
9.6
21.1
56
124
9.6
21.1
56
124
b
b
6.5
14.4
56
124
6.5
14.4
56
124
b
b
13.0
28.7
56
124
13.0
28.7
56
124
0.2
0.4
4.1
9.0
28
62
4.1
9.0
28
62
0.2
0.3
7.1
15.7
56
124
7.1
15.7
56
124
0.2
0.3
b
b
b
b
5.6
12.3
56
124
0.3
0.7
b
b
b
b
8.1
17.8
56
124
(continued)
-------
TABLE 7-4. (continued)
Rubber-coated
industrial fabric
Reg. Alt. III-CA
kg
Ib
Reg. Alt. III-Cond.
kg
t u
IU
Reg. Alt. IV-Inc.a
kg
Ib
A
2.9
6.5
28
dZ
2.7
5.9
B
5.2
11.5
56
124
4.7
10.4
C
9.6
21.1
56
124
8.7
19.1
Urethane-
coated
fabric
B
6.5
14.4
56
124
5.9
13.1
C
13.0
28.7
56
124
11.8
26.1
Rubber-
coated cord
A
4.1
9.0
28
62
3.7
8.2
B
7.1
15.7
56
124
6.5
14.3
Epoxy-coated
fiberglass
B
5.6
12.3
56
124
5.1
11.2
C
8.1
17.8
56
124
7.3
16.2
. CA = carbon adsorber; Cond.
Not applicable.
= condensation-air refrigeration system; Inc. = incinerator.
-------
TABLE 7-5. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR SULFUR OXIDE EMISSIONS FROM
ELECTRICAL ENERGY GENERATION FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
Emissions
Reg. Alt. III-CA3
(Mix equipment)
kg
Ib
Coating operation
Reg. Alt. I-CA
kg
Ib
Reg. Alt. I-Cond.a
kg
Ib
Reg. Alt. II-CA
kg
Ib
Reg. Alt. II-Cond.
kg
Ib
A
8.1
17.8
117
258
1,127
2,484
117
258
1,127
2,484
B
6.1
13.5
208
458
2,254
4,967
208
458
2,254
4,967
C
12.5
27.6
383
844
2,254
4,967
383
844
2,254
4,967
Urethane-
coated
fabric
B
b
b
261
575
2,254
4,967
261
575
2,254
4,967
C
b
b
521
1,149
2,254
4,967
521
1,149
2,254
4,967
Rubber-
coated cord
A
8.1
17.8
163
360
1,127
2,484
163
360
1,127
2,484
B
6.1
13.5
285
629
2,254
4,967
285
629
2,254
4,967
Epoxy-coated
fiberglass
B
6.1
13.5
b
b
b
b
223
491
2,254
4,967
C
12.5
27.6
b
b
b
b
323
713
2,254
4,967
(continued)
-------
TABLE 7-5. (continued)
Rubber-coated
industrial fabric
Reg. Alt. III-CA
kg
Ib
Reg. Alt. Ill-Cond.
kg
1U
1 U
Reg. Alt. IV-Inc.a
kg
Ib
A
117
258
1,127
S\ * f> *
•i.HOH
107
236
B
208
458
2,254
f,b»b/
188
415
C
383
844
2,254
4,yt>/
346
764
Urethane-
coated
fabric
B
261
575
2,254
4,yb/
238
524
C
521
1,149
2,254
4,967
474
1,044
Rubber-
coated cord
A
163
360
1,127
2,484
148
327
B
285
629
2,254
4,967
259
571
Epoxy-coated
fiberglass
B
223
491
2,254
4,967
203
447
C
323
713
2,254
4,967
294
647
.CA = carbon adsorber; Cond. = condensation-air refrigeration system; Inc. = incinerator.
Not applicable.
-------
TABLE 7-6. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR NITROGEN OXIDE EMISSIONS FROM
ELECTRICAL ENERGY GENERATION FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
Emissions
Reg. Alt. III-CA3
(Mix equipment)
kg
Ib
Coating operation
Reg. Alt. I-CA
kg
Ib
Reg. Alt. I-Cond.a
kg
Ib
Reg. Alt. II-CA
kg
Ib
*
Reg. Alt. Il-Cond.
kg
Ib
A
4.0
8.9
59
129
563
1,242
59
129
563
1,242
B
3.1
6.7
104
229
1,127
2,484
104
229
1,127
2,484
C
6.3
13.8
191
422
1,127
2,484
191
422
1,127
2,484
Urethane-
coated
fabric
B
b
b
130
287
1,127
2,484
130
287
1,127
2,484
C
b
b
261
575
1,127
2,484
261
575
1,127
2,484
Rubber-
coated cord
A
4.0
8.9
82
180
563
1,242
82
180
563
1,242
B
3.1
6.7
143
315
1,127
2,484
143
315
1,127
2,484
Epoxy-coated
fiberglass
B
3.1
6.7
b
b
b
b
111
245
1,127
2,484
C
6.3
13.8
b
b
b
b
162
356
1,127
2,484
(continued)
-------
TABLE 7-6. (continued)
ro
o
-•*.
Urethane-
Rubber-coated
Reg. Alt. III-CA
kg
Ib
Reg. Alt. III-Cond.
kg
Ib
Reg. Alt. IV-Inc.a
kg
Ib
industri
A
59
129
563 1,
1,242 2,
54
118
al
B
104
229
127
M S\ *
tot
94
207
fabric
C
191
422
1,127
£,fOf
173
382
coated
fabric
B
130
287
1,127 1,
2,484 2,
119
262
Rubber-
C
261
575
127
4H4
237
522
coated
A
82
180
563
1,242
74
164
cord
B
143
315
1,127
2,484
130
285
Epoxy-coated
fibergl
B
111
245
1,127 1
2,484 2
101
224
ass
C
162
356
,127
,484
147
324
.CA = carbon adsorber; Cond. = condensation-air refrigeration system; Inc. = incinerator.
Not applicable.
-------
TABLE 7-7. ANNUAL SECONDARY AIR POLLUTION IMPACTS FROM THE
COMBUSTION OF NATURAL GAS FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
Emissions
Reg. Alt. IV-Inc.a
Parti cul ate matter
kg
Ib
Carbon monoxide
kg
Ib
Nitrogen oxide
kg
Ib
A
20
44
34
75
350
772
B
35
77
60
132
615
1,356
C
65
143
110
243
1,135
2,502
Urethane-
coated
fabric
B
32
71
55
120
562
1,238
C
64
142
109
241
1,124
2,477
Rubber-
coated cord
A
16
36
28
61
286
631
B
29
63
49
108
503
1,108
Epoxy-coated
fiberglass
B
34
75
58
127
593
1,307
C
49
108
84
184
860
1,895
Inc.'= incinerator.
-------
TABLE 7-8. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR PARTICULATE
MATTER EMISSIONS FROM STEAM GENERATION FOR THE CONTROL EQUIPMENT
ro
ro
Rubber-coated
industrial fabric
Emissions
Reg. Alt. III-CA3
(mix equipment)
kg
lb
Coating operation
Reg. Alt. I-CA
kg
lb
Reg. Alt. II-CA
kg
lb
Reg. Alt. III-CA
kg
lb
A
7
15
51
111
56
124
58
128
B
11
24
82
181
91
201
94
207
C
21
47
164
361
182
401
188
415
Urethane-
coated
fabric
B C
b b
b b
127 255
280 562
137 275
302 606
123 245
270 541
Rubber-
coated cord
A
7
T r
Xil
51
111
56
124
58
128
B
11
24
82
181
91
201
94
207
Epoxy-coated
fiberglass
B
11
24
b
b
136
299
116
257
C
21
4/
b
b
271
598
233
513
j*CA = carbon adsorber.
Not applicable.
-------
ro
oo
TABLE 7-9. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR SULFUR OXIDE EMISSIONS
FROM STEAM GENERATION FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
Emissions
Reg. Alt. III-CA3
(mix equipment)
kg
Ib
Coating operation
Reg. Alt. I-CA
kg
Ib
Reg. Alt. II-CA
kg
Ib
Reg. AH. III-CA
kg
Ib
h
A
86
190
661
1,458
736
1,622
760
1,676
B
140
308
1,072
2,363
1,191
2,625
1,230
2,711
C
280
617
2,145
4,728
2,382
5,251
2,461
5,425
Urethane-
coated
fabric
B
b
b
1,663
3,665
1,794
3,955
1,605
3,539
C
b
b
3,334
7,347
3,598
7,930
3,211
7,077
Rubber-
coated cord
A
86
190
661
1,458
736
1,622
760
1,676
B
140
308
1,072
2,363
1,191
2,625
1,230
2,711
Epoxy-coated
fiberglass
B
140
308
b
b
1,775
3,913
1,523
3,356
C
280
617
b
b
3,551
7,826
3,046
6,713
?CA = carbon adsorber.
Not applicable.
-------
TABLE 7-10.
ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR NITROGEN OXIDE EMISSIONS
FROM STEAM GENERATION FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
Emissions
Reg. Alt. III-CA3
(mix equipment)
kg
Ib
Coating operation
Reg. Alt. I-CA
• kg
£ Ib
Reg. Alt. II-CA
kg
Ib
Reg. Alt. III-CA
kg
Ib
A
22
48
169
371
188
413
194
427
B
36
79
273
602
303
669
313
691
C
71
157
547
1,205
607
1,338
627
1,382
Urethane-
coated
fabric
B
b
b
424
934
457
1,008
409
902
C
b
b
849
1,872
917
2,020
818
1,803
Rubber-
coated cord
A
22
46
169
371
188
413
194
427
B
36
79
273
602
303
669
313
691
Epoxy-coated
fiberglass
B
36
79
b
b
452
997
388
855
C
71
157
b
b
905
1,994
776
1,710
?CA = carbon adsorber.
Not applicable.
-------
ro
en
TABLE 7-11. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR CARBON MONOXIDE EMISSIONS
FROM STEAM GENERATION FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
ABC
Urethane-
coated
fabric
B C
Rubber-
coated cord
A B
Epoxy-coated
fiberglass
B C
Emissions
Reg. Alt. III-CAa
(mix equipment)
kg
lb
Coating operation
Reg. Alt. I-CA
kg
lb
Reg. Alt. II-CA
kg
lb
Reg. Alt. III-CA
kg
lb
2
4
14
31
16
34
16
36
3
7
23
50
25
56
26
58
6
13
46
100
51
111
52
115
b
b
35
78
38
84
34
75
b
b
71
156
76
168
68
150
2
4
14
31
16
34
16
36
3
7
23
50
25
56
26
58
3
7
b
b
38
83
32
71
6
13
b
b
75
166
65
143
CA =" carbon adsorber.
Not applicable.
-------
TABLE 7-12.
ANNUAL WASTEWATER DISCHARGES AND WASTEWATER VOC EMISSIONS
FROM THE FIXED-BED CARBON ADSORBER CONTROL
OF MODEL COATING MIX PREPARATION EQUIPMENT8
Regulatory Alternative III
Model coating line
Wastewater
discharge
m3 10* gal
Wastewater VOC
emissions
kg Ib
1. Rubber-coated industrial fabric
Line designation:
A 36
B 59
C 117
2. Urethane-coated fabric
Line designation:
B a
C a
3. Rubber-coated cord
Line designation:
A 36
B 59
4. Epoxy-coated fiberglass
Line designation:
9.6
15.5
31.0
a
a
9.6
15.5
16
25
51
a
a
16
25
35
56
112
a
a
35
56
B
C
59
117
15.5
31.0
0.4
0.9
1.0
2.0
Not applicable.
7-26
-------
TABLE 7-13.
—I
ro
•-•4
ANNUAL WASTEWATER DISCHARGES FROM THE FIXED-BED CARBON ADSORBER
CONTROL OF MODEL COATING OPERATIONS8
Wastewater discharges
Regulatory
Alternative I
Model coating line
1.
2.
3.
4.
Rubber-coated industrial fabric
Line designation:
A
B
C
Urethane-coated fabric
Line designation:
B
C
Rubber-coated cord
Line designation:
A
B
Epoxy-coated fiberglass
Line designation:
B
C
*
m3
278
450
900
499
999
278
450
a
a
103 gal
73.5
119
238
132
264
73.5
119
a
a
Regulatory
Alternative II
m3
309
499
999
556
1,110
309
499
499
999
103 gal
81.6
132
264
147
294
81.6
132
132
264
Regulatory
Alternative III
m3
326
530
1,060
586
1,170
326
530
530
1,060
103 gal
86.2
140
279
155
310
86.2
140
140
279
Not applicable.
-------
TABLE 7-14.
I
ro
oo
ANNUAL WASTEWATER VOC EMISSIONS FROM THE FIXED-BED CARBON ADSORBER
CONTROL OF MODEL COATING OPERATIONS8
Wastewater VOC emissions
Regulatory
Alternative I
Model coating line
1.
2.
3.
4.
Rubber-coated industrial fabric
Line designation:
A
B
C
Urethane-coated fabric
Line designation:
B
C
Rubber-coated cord
Line designation:
A
B
Epoxy-coated fiberglass
Line designation:
B
C
«
kg
120
194
389
46
91
120
194
a
a
Ib
265
428
857
101
201
265
428
a
a
Regulatory
Alternative II
kg
133
216
431
51
102
234
216
4.0
7.7
Ib
294
475
950
112
224
294
475
8.7
17
Regulatory
Alternative III
kg
141
229
454
54
107
141
229
4.2
8.2
Ib
310
504
1,000
118
236
310
504
9.2
18
Not applicable.
-------
TABLE 7-15. ANNUAL SOLID WASTE IMPACTS OF THE REGULATORY ALTERNATIVES ON THE
MODEL COATING MIX PREPARATION EQUIPMENT AND COATING OPERATIONS
PO
VO
Regulatory alternatives
IIIa-CAb
Model coating line
1.
2.
3.
4.
Rubber-coated
industrial fabric
Line designation:
A
B
C
Urethane-coated fabric
Line designation:
B
C
Rubber-coated cord
Line designation:
A
B
Epoxy-coated fiberglass
Line designation:
B
' C
kg
22
19
37
c
c
22
19
55
111
Ib
48
41
82
c
c
48
41
122
244
I-CA
kg
195
158
320
144
296
195
158
c
c
Ib
430
348
704
318
652
430
348
c
c
II-CA
kg
208
168
336
155
309
208
168
536
1,080
Ib
459
370
741
341
681
459
370
1,180
2,370
III-CA
kg
219
175
353
162
451
219
175
568
1,135
Ib
482
385
778
356
993
482
385
1,250
2,500
.This regulatory alternative applies to model coating preparation equipment.
°CA = carbon adsorber.
Not applicable.
-------
TABLE 7-16. ANNUAL ELECTRICAL ENERGY REQUIREMENTS FOR THE CONTROL EQUIPMENT
OF MODEL COATING MIX PREPARATION EQUIPMENT AND COATING OPERATIONS
CO
o
Rubber-coated
industrial fabric
Energy requirement
Reg. Alt. III-CA3
(Mix equipment)
GJ
Million Btu
Coating operation
Reg. Alt. I-CA
GJ
Million Btu
Reg. Alt. I-Cond.a
GJ
Million Btu
Reg. Alt. II-CA
GJ
Million Btu
*
Reg. Alt. II-Cond.
GJ
Million Btu
A
5.1
4,9
75
71
721
683
75
71
721
683
B
3.9
3.7
133
126
1,441
1,366
133
126
1,441
1,366
C
8.0
1 C.
1 . \J
244
232
1,441
1,366
244
232
1,441
1,366
Urethane-
coated
fabric
B
b
u
u
167
158
1,441
1,366
167
158
1,441
1,366
C
b
b
333
316
1,441
1,366
333
316
1,441
1,366
Rubber-
coated cord
A
5.1
4.9
104
99
721
683
104
99
721
683
B
,
3.9
3.7
183
173
1,441
1,366
183
173
1,441
1,366
Epoxy-coated
fiberglass
B
3.9
3.7
b
b
b
b
142
135
1,441
1,366
C
8.0
7.6
b
b
b
b
207
196
1,441
1,366
(continued)
-------
TABLE 7-16. (continued)
Rubber-coated
industrial fabric
•"•4
1
to
Reg. Alt.
GJ
Million
Reg. Alt.
GJ
Million
Reg. Alt.
GJ
Million
III-CA
Btu
III-Cond.
Btu
IV-Inc.a
Btu
A
75
71
721
683
69
65
B
133
126
1,441
1,366
120
114
C
244
232
1,441
1,366
222
210
Urethane-
coated
fabric
B
167
158
1,441
1,366
152
144
C
333
316
1,441
1,366
303
287
Rubber-
coated cord
A
104
99
721
683
95
90
B
183
173
1,441
1,366
166
157
Epoxy-coated
fiberglass
B
142
135
1,441
1,366
129
123
C
207
196
1,441
1,366
188
178
. CA = carbon adsorber; Cond.
Not applicable.
= condensation-air refrigeration system; Inc. = incinerator.
-------
TABLE 7-17.
ANNUAL NATURAL GAS REQUIREMENTS FOR THE INCINERATOR
CONTROL OF MODEL COATING OPERATIONS
Model coating line
Regulatory Alternative IV
GJ
Btu
1. Rubber-coated industrial fabric
Line designation:
A
B
C
2. Urethane-coated fabric
Line designation:
B
C
3. Rubber-coated cord
Line designation:
A
B
4. Epoxy-coated fiberglass
Line designation:
B
C
4,200
7,380
13,620
6,740
13,484
3,440
6,030
7,120
10,320
3,980
7,000
12,910
6,390
12,780
3,260
5,720
6,750
9,780
7-32
-------
TABLE 7-18. ANNUAL STEAM REQUIREMENTS FOR THE CONTROL EQUIPMENT FOR
MODEL COATING MIX PREPARATION EQUIPMENT AND MODEL COATING OPERATIONS
GO
co
Rubber-coated
industrial fabric
Steam requirement
Reg. Alt. III-CA3
(Mix equipment)
GJ
Million Btu
Coating operation
Reg. Alt. I-CA
GJ
Million Btu
Reg. Alt. II-CA
GJ
Million Btu
Reg. Alt. III-CA
GJ
Million Btu
A
100
95
768
728
855
810
883
837
B
162
154
1,244
1,180
1,383
1,311
1,429
1,354
C
325
308
2,491
2,361
2,767
2,622
2,858
2,709
Urethane-
coated
fabric
B
b
b
1,931
1,830
2,084
1,975
1,864
1,767
C
b
b
3,871
3,669
4,178
3,960
3,729
3,534
Rubber-
coated cord
A
100
95
768
728
855
810
883
837
B
162
154
1,244
1,180
1,383
1,311
1,429
1,354
Epoxy-coated
fiberglass
B
162
154
b
b
2,062
1,954
1,768
1,676
C
325
308
b
b
4,123
3,908
3,536
3,352
?CA = carbon adsorber.
Not applicable.
-------
TABLE 7-19. TOTAL ANNUAL ENERGY DEMAND OF CONTROL EQUIPMENT FOR THE MODEL
COATING MIX PREPARATION EQUIPMENT AND COATING OPERATIONS
I
co
Rubber-coated
industrial fabric
Energy requirement
Reg. Alt. III-CA3
(Mix equipment)
GJ
Million Btu
Coating operation
Reg. Alt. I-CA
GJ
Million Btu
Reg. Alt. I-Cond.a
GJ
Million Btu
Reg. Alt. II-CA
GJ
Million Btu
*
Reg. Alt. Il-Cond.
GJ
Million Btu
A
105
10Q
843
799
721
683
930
882
721
683
B
166
158
1,377
1,305
1,441
1,366
1,516
1,437
1,441
1,366
C
333
*•>-! r
2,735
2,592
1,441
1,366
3,011
2,854
1,441
1,366
Urethane-
coated
fabric
B
b
b
2,097
1,988
1,441
1,366
2,250
2,133
1,441
1,366
C
b
b
4,204
3,985
1,441
1,366
4,511
4,276
1,441
1,366
Rubber-
coated cord
A
105
100
872
827
721
683
959
909
721
683
B
166
158
1,427
1,353
1,441
1,366
1,566
1,484
1,441
1,366
Epoxy-coated
fiberglass
B
166
158
b
b
b
b
2,204
2,089
1,441
1,366
C
333
316
b
b
b
b
4,330
4,104
1,441
1,366
(continued)
-------
TABLE 7-19. (continued)
co
en
Rubber-coated
industrial fabric
Reg. Alt.
GJ
Million
Reg. Alt.
GJ
Mi 11 i on
Reg. Alt.
GJ
Million
III-CA
Btu
III-Cond.
Btu
IV-Inc.a
Btu
A
959
909
721
683
4,269
4,047
B
1,562
1,480
1,441
1,366
7,502
7,110
3
2
1
1
13
13
C
,103
,941
,441
,366
,843
,121
Urethane-
coated
fabric
B
2,031
1,925
1,441
1,366
6,894
6,534
C
4,062
3,850
1,441
1,366
13,787
13,068
Rubber-
coated cord
A
988
936
721
683
3,531
3,347
B
1,612
1,528
1,441
1,366
6,196
5,872
Epoxy-coated
fiberglass
B
1,910
1,811
1,441
1,366
7,246
6,868
C
3,743
3,547
1,441
1,366
10,503
9,955
. CA = carbon adsorber; Cond. = condensation-air refrigeration system; Inc. = incinerator.
Not applicable.
-------
TABLE 7-20. FIFTH-YEAR IMPACTS OF VARIOUS REGULATORY ALTERNATIVES
FOR COATING LINES3
Emissions
VOC
Reg.
Alt.
I
II
III
IV
Mg
1,540
475
240
130
tons
1,700
525
265
145
Wastewater
m3 103
7,710 2
1-\ cm ~
13,210 3
--
gal
,040
,060
,485
--
Solid
kg
2,930
6,340
7,480
--
waste
Ib
6,460
13,940
16,470
--
Energy
TJ
27.
42.
42.
147.
1
5
7
5
lO9^
25.
40.
40.
139.
Btu
7
3
5
8
co
aCoating line includes the storage tanks, coating mix preparation equipment, and coating operation.
-------
TABLE 7-21. FIFTH-YEAR IMPACTS OF VARIOUS REGULATORY ALTERNATIVES
OVER BASELINE FOR COATING LINES
I
CO
Emissions
VOC
Reg.
Alt.
II
III
IV
Mg
(1,065)
(1,300)
(1,410)
tons
(1,175)
(1,435)
(1,555)
Wastewater
m3
3,850
5,500
--
103 gal
1,020
1,445
—
Solid
kg
3,410
4,550
--
waste
Ib
7,480
10,010
—
Energy
TJ
15.
15.
120.
4
6
4
109
14.
14.
114.
Btu
6
8
1
-------
7.8 REFERENCES FOR CHAPTER 7
•
1. The Final Set of Analysis of Alternative New Source Performance
Standards for New Coal-Fired Power Plants. June 1979. ICF Inc.,
Washington, D.C. p. C-III-3C.
2. Memorandum from Thornelce, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 22, 1984. Calculation of
Environmental and Energy Impacts.
3. Environmental Protection Agency General Regulations on Standards of
Performance for New Stationary Sources. Code of Federal Regulations.
Title 40, Chapter I, Subchapter C, Part 60, Subpart Da. July 1,
1979. Environmental Reporter. January 22, 1982. pp. 121:1518.11-121:1526.
4. Compilation of Air Pollution Emission Factors. 3rd Edition. U. S.
Environmental Protection Agency. Research Triangle Park, North
Carolina. Publication No. 999-AP-42. April 1981. pp. 1.4-1 - 1.4-3.
5. Reference 4. pp. 1.3-1 •• 1.3-5.
6. Telecon, Thorneloe, S., MRI, with Schweitzer, P., Chempro. August 29
and 30, 1984. Information on solvent purification requirements for
model coating lines.
7. Perry, R. and C. Chilton. Chemical Engineers' Handbook. Fifth
Edition. McGraw-Hill Book Company. 1973. p. 3-43.
8. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 22, 1984. Wastewater Calculations
and Summary.
9. IT Enviroscience. Assessment of the Impact of Untreated Steam
Condensate from Planned Vapor—Phase Carbon Adsorption Systems in
Selected Industries. Prepared for U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina. EPA Contract
No. 68-03-2568. Undated.
7-38
-------
8.0 COSTS
This chapter presents the process and control costs for each of the
model plants for new, modified, or reconstructed facilities. Emphasis
is placed on the incremental control cost impacts of implementing the
various regulatory alternatives presented in Chapter 6. Model plant
design and operating parameters are also presented in Chapter 6. The
costs presented in the following sections provide input for the economic
impact analysis described in Chapter 9.
Capital and annualized costs are presented for an uncontrolled
plant and for the pollution control devices for the various regulatory
alternatives. All costs are reported in first quarter 1984 dollars.
8.1 COST ANALYSIS OF REGULATORY ALTERNATIVES
Regulatory alternatives were developed to represent various
emission control levels that are achievable based on available emission
control equipment. Model plants and lines were developed to evaluate
the economic and environmental impacts to implement the regulatory
alternatives. A model polymeric coating plant includes a single coating
operation and associated solvent storage tanks and coating mix
preparation equipment. A model coating operation is defined as the
coating application/flashoff area and associated drying oven required to
manufacture polymeric coated substrates. Four model coating operations
were selected to characterize the manufacturing operations that are
expected to be constructed, modified, or reconstructed in the near
future. The solvent storage tanks for the model plants are those tanks
required to store and supply solvents to the model coating mix
preparation equipment. The coating mix preparation equipment for the
model plant includes the preparation equipment (mixers and holding
tanks) required to supply mixed coatings to the model coating operation.
8-1
-------
The following sections of this chapter present the capital and
annualized costs to construct, install, and operate model coating
operations, storage tanks, and mix preparation equipment. Also, the
installed capital cost, operating cost, annualized cost, and cost
effectiveness to implement the emission control systems on which the
regulatory alternatives are based are analyzed for each model plant. A
discussion about the costs of modified or reconstructed facilities is
also presented.
8.1.1 Capital and Annualized Costs of Model Plants
Table 8-1 presents the factors that are used to calculate the
annualized costs. Tables 8-2! through 8-4 present the estimated capital
and annualized costs for the uncontrolled model solvent storage tanks,
coating mix preparation equipment, and coating operations. The
installed capital costs presented in these tables are based on
conversations with equipment vendors and include the cost of solvent
storage tanks; mixers and holding tanks; and coating application
equipment, associated drying oven, substrate unwinders and rewinders,
and other ancillary equipment, respectively for the three model
facilities.1-4 Building and land costs were also included in the
capital cost estimates for the model coating mix preparation equipment
and coating operation.
The annualized costs for solvent storage tanks include maintenance
and inspection costs, taxes, insurance, administration, and the annual
capital charge. The annual capital charge is the cost associated with
recovering the initial capital investment over the depreciable life of
the equipment and is calculated by multiplying the total installed
capital cost by the capital recovery factor. The capital recovery
factor is based on the depreciable life of the equipment and a 10 percent
interest rate.
The annualized costs for the coating mix preparation equipment and
the coating operation are the sum of the annual operating and
maintenance costs, plus the annual capital charge. The operating costs
include operating labor, supervision, raw materials, utilities, and
overhead. The land cost is not included in the capital recovery charge,
instead it is multiplied by the interest rate to obtain the annual
interest charge on the money invested in the land.
8-2
-------
Tables 8-5 through 8-8 present the total installed capital and
annualized costs for the control devices associated with Regulatory
Alternatives II and III (Regulatory Alternative I is uncontrolled) for
model solvent storage tanks and coating mix preparation equipment. The
capital cost of the conservation vents for the solvent storage tanks and
coating mix preparation equipment (Regulatory Alternative II) are based
on vendor quotes.5 The capital costs of the pressure relief valves
(RA III) for the storage tanks are based on an engineering study
performed to determine the capital and annualized costs of these valves.
The capital cost of the carbon adsorber presented in Table 8-9 is the
incremental cost that would be incurred because of the addition of
solvents from coating mix preparation equipment control to the solvent
emissions to be controlled from the coating operation. The ductwork
costs are calculated based on information from the Richardson
Engineering Manual.6 "Saved" solvent credit (Tables 8-5, 8-6, and 8-8)
is based on the current market price of the solvents that are prevented
from being emitted to the atmosphere by use of conservation vents and
pressure relief valves.7 Similarly, the recovered solvent credit
(Tables 8-7 and 8-9 through 8-15) is based on the current market price
of the solvents that are recovered by the control device.
The capital and annualized costs for carbon adsorber control that
achieves the levels of Regulatory Alteratives I through III for model
coating operations are presented in Tables 8-10 through 8-12. The
capital costs of the control device are based on information from model
plant parameters and the Economic Analysis Branch (EAB) Control Cost
manual.8 The control device capital costs include costs for control
device itself, as well as auxiliary equipment and indirect installation
charges. Distillation system costs are included for model operations
using solvent blend and water-soluble solvent (acetone). The annualized
costs include the annual operating, maintenance, and capital recovery
charges, and are based on factors from the EAB Control Cost manual
(Table 8-1). Again, the recovered solvent credit is the value of the
solvents recovered by the control device.
The capital and annualized costs for condensation system control
that achieves the levels of Regulatory Alternatives I through III for
8-3
-------
model coating operations are presented in Tables 8-13 through 8-15. The
capital cost of the control device is based on information provided by
the equipment vendor for one particular case; then, a logarithmic
relationship known as the six tenths-factor rule is used to estimate the
equipment costs given various model coating operation parameters.9,10
The annualized costs are based on information from the equipment vendor
and EAB Control Cost manual (Table 8-1). One advantage of using a
condensation system is that a major portion of oven exhaust can be
recirculated back to the oven after being cleaned of the solvents. This
recirculated air is heated in a heat exchanger with the hot oven exhaust
directed to the condensation system. Since this recirculated air is at
a higher temperature than ambient air, reduction in heating requirements
of the oven make-up air results, thereby, reducing the energy costs.
The capital and annualized costs for incinerator control to achieve
the level of Regulatory Alternative IV are presented in Table 8-16. The
capital costs of the control device are based on information from model
plant parameters and EAB Control Cost manual.11 The capital costs
include costs for incinerator, heat exchanger, fan or blower, damper
controls, and instrumentation. Incinerator costs are based on design
factors including operating temperature of 815°C (1500°F), residence
time of 0.5 seconds, and 35 percent heat recovery.11
Table 8-17 presents the estimated total plant annualized costs and
annualized cost per unit area of substrate coated at various regulatory
alternatives. For comparison, the uncontrolled capital and annualized
costs are also presented in the table.
8.1.2 Cost Effectiveness
The cost-effectiveness value is the annual cost to control 1 Mg
(ton) of VOC pollutant. The average cost-effectiveness value is the
annualized cost per Mg (ton) of pollutant required to implement a
control system achieving greater VOC reduction than that which is most
commonly being used at present (baseline). The average cost
effectiveness of an alternative was determined by dividing the
incremental annualized control system cost by the incremental annual VOC
reduction. The incremental annual cost is the difference in the net
annualized cost of the alternative compared to baseline. The
8-4
-------
incremental VOC reduction is the difference in the VOC reduction of the
alternative compared to baseline.
The incremental cost effectiveness is a measure of the additional
annual cost required to achieve the next higher level of emission
reduction. The incremental cost effectiveness was calculated by
dividing the incremental increase in the annual control device cost by
the incremental emission reduction.
The average and incremental cost-effectiveness values for the
various regulatory alternatives for model solvent storage tanks and mix
preparation equipment are presented in Tables 8-18 and 8-19,
respectively. The average and incremental cost-effectiveness values for
various regulatory alternatives for model coating operations using
carbon adsorber control for Alternatives I through III and incinerator
control for Alternative IV are presented in Table 8-20, and using
condensation system control for Alternatives I through III and
incinerator control for Alternative IV are presented in Table 8-21.
As shown in Table 8-18, the incremental cost effectiveness ranges
from $800/Mg ($730/ton) for conservation vent controlling emissions from
a storage tank to 380,270/Mg (344,900/ton) for a common carbon adsorber
controlling emissions from storage tanks and model coating operations.
Table 8-19 shows that the incremental cost effectiveness ranges from
$-412/Mg ($-375/ton) for conservation vent controlling emissions from
coating mix preparation equipment to $l,127/Mg ($l,023/ton) for a common
adsorber controlling emissions from coating mix preparation equipment
and model coating operations.
The incremental cost effectiveness for the model coating operations
(Table 8-20) ranges from $-794/Mg ($-720/ton) for a carbon adsorber
controlling emissions from a coating operation to $27,862/Mg
($25,271/ton) for an incinerator controlling emissions from a coating
operation. The incremental cost effectiveness ranges from $-932/Mg
($-846/ton) for condensation system control to $37,886/Mg ($34,363/ton)
for an incinerator controlling emissions from a coating operation
(Table 8-21).
8-5
-------
8.1.3 Modified/Reconstructed Facilities
Under the provisions of 40 CFR 60.14 and 60.15, an "existing
facility" may become subject to standards of performance if it is deemed
modified or reconstructed. In such situations, control devices may have
to be installed for compliance with new source performance standards
(NSPS).
The cost for installing a control system on an existing facility
may be greater than the cost of installing the control system on a new
facility. Because retrofit costs are highly site-specific, they are
difficult to estimate. The availability of space and the configuration
of existing equipment in the plant are the major limiting site-specific
factors.
8.2 OTHER COST CONSIDERATIONS
In addition to costs associated with the Clean Air Act, the
polymeric coating plants may also incur costs as a result of other
Federal rules or regulations. These impacts are discussed in this
section.
8.2.1 Costs Associated with Increased Water Pollution and Solid Waste
Disposal
Wastewater disposal problems arise from the use of carbon
adsorption solvent recovery systems. Dissolved solvents in the
condensate from the carbon adsorber represent the primary potential
water pollutant. Because of the distillation involved in the solvent
recovery system (for model operations using solvent blend and
water-soluble acetone), the aqueous bottoms contain from 70 to 5,500 ppm
solvent, with a typical value of less than 500 ppm.12 This wastewater
is usually disposed of in a municipal sewer system following treatment
in a stripper column in the distillation system. The actual amount of
any surcharges would be determined by local regulations. In any event,
it is unlikely that such charges would be significant.
Solid waste consists of the spent carbon used in carbon adsorption
systems. The carbon from fixed-bed and fluidized-bed carbon adsorbers
is usually sold back to processors, reactivated, and then sold again to
the original purchaser or to other carbon adsorber operators; therefore,
there are no solid waste disposal costs associated with these systems.
8-6
-------
8.2.2 Resource Conservation and Recovery Act
The liquid solvent wastes generated by the air pollution control
devices associated with the polymeric coating plants are classified as
hazardous or toxic under the provisions of the Resource Conservation and
Recovery Act (RCRA). However, there are no liquid solvent wastes
generated because all of the solvents that are recovered are reused.
8.2.3 Resource Requirements Imposed on State, Regional, and Local
Agencies
The owner or operator of a polymeric coating plant is responsible
for making application to the State for a permit to construct and
subsequently to operate a new installation. The review of these
applications, and any later enforcement action, would be handled by
local, State, or regional regulatory agencies. It is expected that
these plants will be distributed throughout the United States instead of
clustered in one State and that they will be added primarily in States
already having polymeric coating plants. Therefore, the promulgation of
standards for polymeric coating plants should not impose major resource
requirements on the regulatory agencies. Any costs incurred are .not
expected to limit the financial ability of these plants to comply with
the proposed NSPS.
8-7
-------
TABLE 8-1. BASIS FOR ESTIMATING ANNUALIZED COSTS--
NEW FACILITIES13-15
(First Quarter 1984 Dollars)
Cost element
Cost factor
Direct operating costs
1. Utilities
A. Electricity
B. Steam
C. Cooling water
D. Natural gas
2. Operating labor
A. Direct labor
B. Supervision
3. Maintenance
A. Labor (hourly rate of 10% premium over
operating labor)
B. Material parts
4. Replacement material
A. Activated carbon
Indirect operating costs
S. Overhead
6. Capital charges
A. Administrative
B. Property tax
C. Insurance
D. Capital recovery factor
$0.056/kWh
$7.96/103 Ib
$0.13/103 gal
$3.13/Mcf
$7.60/h
15% of 2A
$8.36/h
100% of 3A
$1.35/lb
80% of 2A+2B+3A
2% of capital cost
1% of capital cost
1% of capital cost
0.16275
aBased on 10 percent interest rate and an equipment life of 10 years.
8-8
-------
00
I
CO
TABLE 8-2. CAPITAL AND ANNUALIZED COSTS FOR SOLVENT STORAGE TANKS1,8,16
(First Quarter 1984 Dollars)
Rubber-coated Urethane-coated Rubber-coated Epoxy-coated
industrial fabric fabric cord fiberglass
Cost item A B C B
I.
1.
II.
1.
Ill
1.
2.
3.
IV.
Capital costs
Total installed costs:3 9,400 11,000 12,700 b
Direct operating costs
Inspection and maintenance: 560 660 760 b
Indirect operating costs
Taxes, insurance, administration: 380 440 510 b
(0.04X1)
Capital recovery charges: 1.100 1,290 1,490 b
(0.11746)(I)C
Total indirect costs: (1 + 2) 1,480 1,730 2,000 b
Total annualized costs (II + III) 2,040 2.390 2,760 b
C A B B C
b 9.400 11,000 11,000 12,700
b 560 660 660 760
b 380 440 440 510
b 1,100 1,290 1,290 1,490
b 1,480 1,730 1,730 2,000
b 2.040 2,390 2,390 2,760
.Based on vendor quote.
"Not applicable—coatings are bought premixed; no solvent storage tanks used.
Based on 10 percent interest rate and an equipment life of 20 years.
-------
TABLE 8-3. CAPITAL AND ANNUALIZED COSTS FOR COATING MIX PREPARATION EQUIPMENT2,17
(First Quarter 1984 Dollars)
Cost item
I. Capital costs
1. Coating preparation equipment:3
2. Purchased equipment cost: (1.18)(1)
3. Equipment installed cost: (1.102X2)
4. Building: (0.29)(2)
5. Land: (0.06)(2)
6. Total installed costs: (3+4+5)
II. Direct operating costs
1. Labor:
CO -Operator
' -Supervisory
O
2. Maintenance:
-Labor
-Parts
3. Utilities: ,
-Electricity3
4. Total direct costs: (1+2+3)
III. Indirect operating costs
1. Overhead:
2. Capital charges :c
3. Total indirect costs: (1+2)
IV. Total annualized costs (II + III)
A
19,200
22.660
24,970
6.570
1.360
32,900
7,600
1.140
8,360
8,360
670
26,130
13,680
5,100
18,780
44.910
Rubber-coated
industrial fabric
B
24.300
28,670
31,590
8,310
1.720
41,620
15,200
2,280
16.720
16,720
1,670
52,590
27,360
6,460
33.820
86,410
Urethane-coated
fabric
• C
48,550
57,290
63,130
16,610
3.440
83,180
15,200
2,280
16,720
16.720
3,340
54,260
27,360
12,900
40,260
94,520
?Based on industry and vendor data.
Not applicable—coatings are bought prefixed; no coating preparation tanks used.
Administration, taxes, and capital recovery costs, equal to 15.746 percent of total
by multiplying total direct land costs by a 10 percent interest rate to estimate the
B
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
C
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
installed equipment costs
annual interest charge on
Rubber-coated
cord
A
14,150
16,700
18,400
4,850
1,000
24,250
7,600
1.140
8,360
8,360
500
25,960
13,680
3.760
17,440
43,400
(excluding land
money invested
B
19,200
22,660
24.970
6.570
1,360
32,900
15.200
2,280
16,720
16,720
1,340
52,260
27,360
5,100
32,460
84,720
costs). Land
in the land.
Epoxy-coated
fiberglass
B
48,500
57,230
63,070
16,600
3,430
83,100
15,200
2,280
16,720
16,720
5,850
56,770
27,360
12,890
40,250
97,020
costs are
C
97,950
115,580
127,370
33.520
6,930
167,820
15,200
2,280
16,720
16,720
10.530
61,450
27,360
26,030
53.390
114,840
included
-------
TABLE 8-4. CAPITAL AND ANNUALIZED COSTS FOR COATING OPERATIONS3,4,18
(First Quarter 1984 Dollars)
00
I
Rubber-coated
industrial fabric
Cost item
I.
1.
2.
3.
4.
5.
6.
11.
1.
2.
3.
4.
5.
Ill
1.
2.
3.
IV.
Capital costs
Coating operation:
Purchased equipment cost: (1.18)(1)
Equipment installed cost: (1.102)(2)
Building: (0.29)(2)
Land: (0.06)(2)
Total installed costs: (3+4+5)
Direct operating costs
Labor:
-Operator
-Supervisory
Raw materials:3
-Substrate
-Coatings
Maintenance:
-Labor
-Parts
Utilities: ,
-Electricity3
-Natural gas
Total direct costs: (1+2+3+4)
Indirect operating costs
Overhead:
Capital charges:""
k
Total indirect costs: (1 + 2)
Total annualized costs (II + III)
A
389,000
459,000
506,000
133,100
27,500
666,600
45,600
6,840
295,640
268,140
16,720
16,720
210
2,100
651,970
55,330
103,380
158,710
810,680
389
459
506
133
27
666
91
13
478
434
33
33
3
1,088
110
103
214
1,302
B
,000
,000
,000
,100
,500
,600
,200
,680
,620
,100
,440
,440
420
,400
,300
,660
,380
,040
,340
C
389,000
459,000
506,000
133,100
27,500
666,600
91,200
13,680
957,250
868,200
33,440
33,440
420
6,800
2,004,430
110,660
103,380
214,040
2,218,470
Urethane-coated
fabric
B
501,000
591,000
651,000
171,400
35,500
857,900
121,600
18,240
4,764,400
566,300
33,440
33,440
1,920
6,640
5,545,980
138,620
133,050
271,670
5,817,650
C
501,000
591,000
651,000
171,400
35,500
857,900
121,600
18,240
9,534,600
1,133,300
33,440
33.440
1,920
13,280
10,889,820
138,620
133.050
271,670
11,161,490
Rubber-coated
cord
A
615,000
726,000
800,000
210,500
43,600
1,054,100
30,400
4,560
579,400
51,950
16,720
16,720
1,380
5,970
707,100
41,340
163,470
204,810
911,910
B
615,000
726,000
800,000
210,500
43,600
1,054,100
60,800
9,120
937,840
84 , 100
33,440
33,440
2,760
9,700
1,171,200
82,690
163,470
246,160
1,417,360
Epoxy-coated
fiberqlass
B
397,000
468,000
516,000
135,700
28,100
679,800
121,600
18,240
2,268,200
1,932,000
33,440
33,440
1,090
3,640
4,411,650
138,620
105,430
244,050
4,655,700
C
397,000
468,000
516,000
135,700
28,100
679,800
121,600
18,240
4,536,300
3,864,000
33,440
33,440
1,090
7,280
8,615,390
138,620
105,430
244,050
8,859,440
?Based on industry and vendor data.
80 percent of the sum of operating, supervisory, and maintenance labor.
Administration, taxes, and capital recovery costs, equal to 15.746 percent of total installed equipment costs (excluding land costs). Land costs are included
by multiplying total direct land costs by a 10 percent interest rate to estimate the annual interest charge on money invested in the land.
-------
TABLE 8-5.
00
M
ro
CAPITAL AND ANNUALIZED COSTS OF CONSERVATION VENTS FOR SOLVENT STORAGE TANKS5,7
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost item
I.
1.
2.
3.
II.
1.
2.
Ill
1.
IV.
V.
VI.
Capital costs
Control device:3
Purchased equipment cost:0
(1.18)(No. 1 above)
Total installed cost:
(1.50)(No. 2 above)
Direct operating costs
Labor and maintenance:
Utilities:
Indirect operating costs
Capital recovery charges:
(20.275 percent of total
installed cost)
Total annualized costs (II + III)
"Saved" solvent credit
Net annualized costs (IV - V)
A
700
830
1,240
0
0
250
250
17
233
B
700
830
1,240
0
0
250
250
29
221
C
700
830
1,240
0
0
250
250
72
178
Urethane-coated
fabric
B
b
b
b
b
b
b
b
b
b
C
b
b
b
b
b
b
b
b
b
Rubber-coated
cord
A
700
830
1,240
0
0
250
250
17
233
B
700
830
1,240
0
0
250
250
29
221
Epoxy-coated
fiberglass
B
700
830
1,240
0
0
250
250
39
211
C
700
830
1,240
0
0
250
250
97
153
.Costs are for two conservation vents for two storage tanks at a price of $350/vent.
Not applicable.
".Includes costs for instruments and controls, taxes, and freight.
Includes installation direct and indirect costs.
e!6.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 4 percent for taxes, insurance, and administration.
-------
00
I-1
to
TABLE 8-6. CAPITAL AND ANNUALIZED COSTS OF PRESSURE RELIEF VALVES FOR SOLVENT STORAGE TANKS
(First Quarter 1984 Dollars)
Cost item
I.
1.
2.
Capital costs
Control device:
Purchased equipment cost:
Rubber-coated
industrial fabric'
ABC
000
000
Urethane-coated
fabric
B C
a a
a a
Rubber-coated
cord
A B
0 0
0 0
Epoxy-coated
fiberglass
B C
0
0
0
0
(1.18)(No. 1 above)
3. Total installed cost:
(1.50)(No. 2 above)
II. Direct operating costs
1. Labor and maintenance:
2. Utilities:
III. Indirect operating costs
1. Capital recovery charges:
(20.275 percent, of total
installed cost)D
IV. Total annualized costs (11 + III)
V. "Saved" solvent credit
VI. Net annualized costs (IV - V)
0
22
-22
0
37
-37
0
92
-92
0
22
-22
0
37
-37
0
SO
-50
.Not applicable.
16.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 4 percent for taxes, insurance, and administration.
0
124
-124
-------
TABLE 8-7. CAPITAL AND ANNUALIZED COSTS FOR COMMON CARBON ADSORBER
FOR CONTROL OF SOLVENT STORAGE TANKS6,7
(First Quarter 1984 Dollars)
00
1
I-*
Cost
I.
1.
2.
3.
4.
5.
II.
1.
2.
3.
Rubber- coated
industrial fabric
item ABC
Capital costs
Control device:3
Purchased equipment cost:
(1.18)(No. 1 above)
Equipment installed cost:
(1.61)(No. 2 above)
Ductwork installed cost: 17,000 17,000 17,000
Total installed cost: (3 + 4) 17,000 17,000 17,000
Direct operating costs
Labor and maintenance: 000
Carbon replacement cost at 5-year life: 000
Utilities:
-Electricity 000
-Steam 000
-Cooling water 000
Ore thane-coated
fabric
B
b
b
b
b
b
b
b
b
b
b
C
b
b
b
b
b
b
b
b
b
b
Rubber-coated Epoxy-coated
cord fiberglass
A B B C
--
.-
—
17,000 17,000 17,000 17,000
17,000 17,000 17,000 17,000
0000
0000
0000
0000
0000
4. Total direct costs: (1+2*3) o 0 0
III. Indirect operating costs
1. Capital recovery charges: 3,450 3,450 3,450
(20.275 percent of total
installed cost)
IV. Total annualized costs (II * III) 3,450 3,450 3,450
V. RecoveVed solvent credit 23 39 97
VI. Net annualized costs (IV - V) 3,427 3,411 3,353
3,450
3,450
23
3,427
3,450
3,450
39
3,411
3,450
3,450
53
3,397
.No incremental cost in the carbon adsorber cost.
°Not applicable.
16.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 4 percent for taxes, insurance, and administration.
3,450
3,450
131
3,319
-------
00
I
U1
TABLE 8-8. CAPITAL AND ANNUALIZED COSTS OF CONSERVATION VENTS
FOR COATING MIX PREPARATION EQUIPMENT5-7
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost item
I.
1.
2.
3.
4.
5.
II.
1.
2.
Ill
1.
IV.
V.
VI.
Capital costs
Control device:
Purchased equipment cost:0
(1.18)(No. 1 above)
Equipment installed cost:
U.SO)(No. 2 above)
Ductwork installed cost:
Total installed cost (3 * 4):
Direct operating costs
Labor and maintenance:
Utilities:
Indirect operating costs
Capital recovery charges:
(20.275 percent of total
installed cost)
Total annuali zed costs (II + III)
"Saved" solvent credit
Net annual ized costs (IV - V)f
A
700
830
1.240
680
1,920
0
0
390
390
1,430
-1,040
B
700
830
1,240
680
1,920
0
0
390
390
2,310
-1,920
C
1,400
1,660
2,480
1.360
3,840
0
0
780
780
4,620
-3,840
Urethane-coated
fabric
B
b
b
b
b
b
b
b
b
b
b
b
C
b
b
b
b
b
b
b
b
b
b
b
Rubber-coated
cord
A
700
830
1,240
680
1,920
0
0
390
390
1,430
-1,040
B
700
830
1,240
680
1,920
0
0
390
390
2,310
-1,920
Epoxy-coated
fiberglass
B
1,050
1,240
1,860
1,020
2,880
0
0
S80
580
3,130
-2,550
C
2,450
2,890
4,340
2,380
6.720
0
0
1,360
1,360
6,260
-4,900
.Based on price of the conservation vents of $350/vent.
Not applicable.
jlnclud.es costs for instruments and controls, taxes, and freight.
Includes installation direct and indirect costs.
?16.275 percent capital recovery factor based on a 10-year life and 10 percent interest, plus 4 percent for taxes, insurance, and administration.
Negative value indicates a credit.
-------
CO
M
cn
TABLE 8-9. CAPITAL AND ANNUALIZED COSTS FOR COMMON CARBON ADSORBER FOR
CONTROL OF COATING MIX PREPARATION EQUIPMENT6-8,19
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost
I.
1.
2.
3.
4.
5.
II.
1.
2.
3.
4.
III.
1.
IV.
V.
VI.
item
Capita) costs
Control device:3
Purchased equipment cost:0
(1.18)(No. 1 above)
Equipment installed cost:
(1.61)(No. 2 above)
Ductwork installed cost:
Total installed cost: (3 + 4)
Direct operating costs
Operating and maintenance labor
plus materials: (6 percent of
total installed cost)
Carbon replacement cost at 5-year life:
Utilities:
-Electricity
-Steam
-Cooling water
Total direct costs: (1+2+3)
Indirect operatinq costs
Capital recovery charges:
(22 percent of total
installed cost)
Tolal annualized costs (II + III)
Recovered solvent credit
Net annualized costs (IV - V)f
A
4,300
5,100
8,200
18,250
26,450
1,585
: 65
80
635
75
2,440
5,820
8,260
3,390
4,870
B
3,400
4,000
6,500
18,250
24,750
1,485
55
60
1,030
120
2,750
5,445
8,195
5,490
2,705
C
3,700
4,400
7,000
22,680
29,680
1,780
110
125
2,060
240
4,315
6,530
10,845
10,980
-135
Urethane-coated
fabric
B
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
C
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
Rubber-coated
cord
A
4,300
5,100
8,200
18,250
26,450
1,585
65
80
635
75
2,440
5,820
8,260
3,390
4,870
B
3,400
4,000
6,500
18,250
24,750
1,485
55
60
1,030
120
2,750
5,445
8,195
5,490
2,705
Epoxy-coated
fiberglass
B
5,600
6,600
10,600
20,460
31,060
1,865
165
60
1,030
120
3,240
6,830
10,070
7,430
2.640
C
6,900
8,100
13,100
29,930
43,030
2,580
330
125
2,060
240
5.335
9,46b
14,800
14,860
-60
.Incremental cost due to coating preparation equipment control.
Not applicable.
(.Includes costs for instruments and controls, taxes, and freight.
"includes installation direct and indirect costs.
,16.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
Negative value indicates a credit.
-------
CO
TABLE 8-10. CAPITAL AND ANNUALIZED COSTS FOR CARBON ADSORBER CONTROL
OF MODEL OPERATIONS-REGULATORY ALTERNATIVE 16-8,19,20
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost item
1.
1.
2.
3.
4.
5.
6.
II.
1.
2.
3.
4.
Ill
1.
IV.
V.
VI.
Capital costs
Control device:3
Purchased equipment cost:
(1.18)(No. 1 above)
Equipment installed cost:
(1.61)(No. 2 above)
Ductwork installed cost:
Distillation system installed cost
Total installed cost: (3+4+5)
Direct operating costs
Operating and maintenance labor
plus materials: (6 percent of
total installed cost)
Carbon replacement cost at 5-year
Utilities:
-Electricity
-Steam
-Cooling water
Total direct costs: (1+2+3)
Indirect operating costs
Capital recovery charges:
(22 percent of total
installed cost)"
Total annuali zed costs (II + III)
Recovered solvent credit
Net annualized costs (IV - V)h
A
115,900
136,800
220,300
65,400,
.e ' __f
285,700
17,140
life: 1,050
1,170
4,870
600
24,830
62,850
87,680
26,010
61,670
B
106,800
126,000
202,800
58,100
260,900
15,660
850
2,060
7,890
950
27,410
57,410
84,820
42,130
42,690
C
138,900
163,900
263,900
87,900
351,800
21,110
1,700
3,800
15,790
1,900
44,300
77,390
121,690
84,290
37,400
Urethane-coated
fabric
B
107,900
127,300
205,000
65,400
79,000
349,400
20,970
870
2,590
12,240
1,340
38,010
76,870
114,880
122,150
-7,270
C
140,000
165,300
266,100
103,000
119.000
488,100
29,290
1,740
5,180
24,540
2,670
63,420
107,370
170,790
244,390
-73,600
Rubber-coated
cord
A
115,900
136,800
220,300
80,400
--
300,700
18,040
1,050
1,620
4,870
600
26,180
66,150
92,330
26,010
66,320
B
106,800
126,000
202,800
72,900
275,700
16,540
850
2,840
7,890
950
29,070
60,660
89,730
42,130
47,600
Epoxy-coated
fiberglass
B
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
C
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
Included costs for carbon adsorber, carbon, fans and blowers, controls, condenser, decanter, heat exchanger, etc. A 20 percent allowance was added to the major
.equipment purchase cost to compensate for unspecified items.
Not applicable—no control device needed for Alternative I level for these model lines.
^Includes costs for instruments and controls, taxes, and freight.
"includes installation direct and indirect costs.
,Based on vendor quote.
Distillation system not needed for these model lines; therefore, no costs.
JJ16.275 percent capita! recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
Negative value indicates a credit.
-------
00
I
M
CO
TABLE 8-11. CAPITAL AND ANNUALIZED COSTS FOR CARBON ADSORBER CONTROL
OF MODEL OPERATIONS-REGULATORY ALTERNATIVE 116-8,19,20
(First Quarter 1984 Dollars)
Rubber-coated
Industrial fabric
Cost
I.
1.
2.
3.
4.
5.
6.
7.
T I
1.
2.
3.
4.
III.
1.
IV.
V.
VI.
item
Capital costs
Control device:3 b
Purchased equipment cost:
(1.18)(No. 1 above)
Equipment installed cost:
(1.61)(No. 2 above) .
Partial enclosure installed cost:
Ductwork installed cost:
Distillation system installed cost:
Total installed cost: (3 + 4 + 5 + 6)
DlreCt upcfatli'iy Cublb
Operating and maintenance labor plus
materials: (6 percent of total
installed cost)
Carbon replacement cost at 5-year life:
Utilities:
-Electricity
-Steam
-Cooling water
Total direct costs: (1+2+3)
Indirect operating costs
Capital recovery charges:
(22 percent of total
installed cost)9
Total annualized costs (II + III)
Recovered solvent credit
Net annualized costs (IV - V)h
A
118,700
140.100
225,500
5,700
65,400,
1 f
296,600
17,800
1,110
1,170
5,420
650
26,150
65,250
91,400
28,930
62,470
B
109,100
128,700
207,200
5,700
58,100
271,000
16.260
900
2,060
8,770
1,050
29,040
59,620
88,660
46,820
41,840
C
141,
166,
268,
5,
87,
361,
21.
1,
3,
17,
2,
46,
79,
126,
93,
32,
200
600
200
700
900
--
600
710
800
800
540
100
950 •
600
550
640
910
Ure thane-coated
fabric
B
110,200
130,000
209,400
5,700
65,400
79,000
359,500
21,570
920
2,590
13.210
1,490
39.780
79,080
118,860
135,780
-16,920
C
142,300
168,000
270,400
5,700
103,000
119.000
498,100
29,890
1,830
5,180
26,490
2,870
66,260
109,600
175,860
271,480
-95,620
Rubber-coated
cord
A
118.700
140,100
225,500
5,700
80,400
311,600
18,700
1,110
1,620
5,420
650
27,500
68,550
96,050
28,930
67,120
B
109,100
128,700
207,200
5,700
72,900
285,800
17,150
900
2,840
8,770
1,050
30.710
62,870
93,580
46,820
46,760
Epoxy-coated
fiberglass
B
165,300
195,100
314,000
5,700
65,400
118,000
503,100
30,190
2,880
2,210
13,070
1,520
49,870
110,690
160,560
63,340
97,220
C
225,000
265,500
427,400
5,700
80,400
179,000
692,500
41,550
5,760
3,210
26,140
3,040
79,700
152,360
232,060
126,680
105,380
Includes costs for carbon adsorber, carbon, fans and blowers, controls, condenser, decanter, heat exchanger, etc. A 20 percent allowance was added to the major
.equipment purchase cost to compensate for unspecified items.
Includes costs for instruments and controls, taxes, and freight.
^Includes installation direct and indirect costs.
Installed cost of a capture device obtained from the NSPS development of magnetic tape coating, a similar surface coating operation.
,Based on vendor quote.
'Distillation system not needed for these model lines; therefore, no costs.
fjl6.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
Negative value indicates a en-slit.
-------
00
TABLE 8-12. CAPITAL AND ANNUALIZED COSTS FOR CARBON ADSORBER CONTROL
OF MODEL OPERATIONS—REGULATORY ALTERNATIVE III6-8,19,20
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost item
I. Capita) costs
1. Control device:3 .
2. Purchased equipment cost:
(1.18)(No. 1 above)
3. Equipment installed cost:
(1.61)(No. 2 above) d
4. Total enclosure installed cost:
5. Ductwork installed cost:
6. Distillation system installed cost:
7. Total installed cost: (3+4+5+6)
II. Direct operating costs
1. Operating and maintenance labor
plus materials: (6 percent of
total installed cost)
2. Carbon replacement cost at 5-year life:
3. Utilities:
-Electricity
-Steam
-Cooling water
4. Total direct costs: (1+2+3)
III. Indirect operating costs
1. Capital recovery charges:
(22 percent of total
installed cost)"
IV. Total annualized costs (II + III)
V. Recovered solvent credit
VI. Net annualized costs (IV - V)h
fc
A
120,500
142,200
229,000
15,000
65,400f
' f
309,400
18,560
1,140
1,170
5,600
700
27,170
68,060
95,230
29.880
65,350
alncludes costs for carbon adsorber, carbon, fans and
.equipment purchase cost to compensate for
B
110,
130,
210,
15,
58,
283,
17,
2,
9,
1.
30,
62,
92,
48,
44,
blowers,
800
700
500
000
100
—
600
020
930
060
060
100
170
390
560
380
180
controls
C
142,900
168,600
271,500
15,000
87,900
.
374,400
22,460
1,850
3,800
18,120
2,200
48,430
82,370
130,800
96,760
34,040
, condenser
Urethane-coated
fabric
B
111,400
131,400
211,500
15,000
65,400
79,000
370,900
22,260
950
2,590
11,820
1,340
38,960
81,610
120,570
140,280
-19,710
, decanter, heat
C
143,700
169,600
273,000
15.000
103,000
119,000
510,000
30,600
1,890
5,180
23,640
2,680
63,990
112,210
176,200
280,550
-104,350
exchanger.
Rubber-coated
A
120,500
142,200
229,000
15,000
80,400
--
324,400
19,460
1,140
1,620
5,600
700
28,520
71,360
99,880
29,880
70,000
etc. A 20
cord
B
110
130
210
15
72
298
17
2
9
1
31
65
97
48
49
,800
,700
,500
,000
,900
--
,400
,900
930
,840
,060
,100
,830
,640
,470
,380
,090
percent allowance
Epoxy-coated
fiberglass
B
167,600
197,800
318,400
15,000
65,400
118,000
516,800
31,010
2,970
2,210
11,210
1,340
48,740
113,700
162,440
65,450
96,990
was added to
C
229,600
270,900
436,200
15,000
80,400
179,000
710,600
42,630
5,940
3,210
22,420
2,680
76,880
156,320
233,200
130,900
102,300
the major
unspecified items.
Includes costs for instruments and controls, taxes, and freight.
.Includes installation direct and indirect
costs.
Installed cost of a capture device obtained from the
NSPS development
of magnetic
tape coating, a
similar surface coating operation.
Distillation system not needed for these model lines; therefore, no costs.
?16.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
Negative value indicates a credit.
-------
00
ro
o
TABLE 8-13. CAPITAL AND ANNUALIZEO COSTS FOR CONDENSATION SYSTEM
CONTROL OF MODEL OPERATIONS—REGULATORY ALTERNATIVE I6,7,9,10,20
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost
I.
1.
2.
3.
4.
5.
6.
II.
1.
2.
3.
4.
III.
1.
IV.
V.
VI.
item
Capital costs
Control device:3
Installation cost:3 (0.5)(1)
Equipment installed cost:a (1 + 2)
Ductwork installed cost:
Distillation system installed
cost:3
Total installed cost: (3+4+5)
Direct operating costs
Operating and maintenance labor
plus materials:
Utilities: ,
-Electricity3
Heat savings:3
Total direct costs: (1+2+3)
Indirect operating costs
Capital recovery charges:
(-22 percent of total installed
cost)"
Total annual i zed costs (II + III)
Recovered solvent credit
Net annual ized costs (IV - V)e
A
100,300
50,150
150.450
17,310
--c
167,760
2,230
11,200
-1,000
12,430
36,910
49,340
26,010
23,330
B
88,500
44,250
132,750
13,960
—
146,710
4,470
22.400
-2,000
24,870
32,280
57,150
42,130
15,020
C
134,200
67,100
201,300
24,650
--
225,950
4,470
22,400
-2,000
24,870
49,710
74,580
84,290
-9,710
Ure thane-coated
fabric
B
84,400
42,200
126,600
17,310
79,000
222,910
4,470
22,400
-2,000
24,870
49,040
73,910
122,180
-48,270
C
127,900
63,950
191,850
24,650
119,000
335.500
4,470
22,400
-2,000
24,870
73.810
98,680
244,360
-145,680
Rubber-coated
cord
A
100,300
50.150
150.450
21,120
--
171,570
2,230
11,200
-1,000
12,430
37,750
50,180
26,010
24,170
B
88,500
44,250
132,750
17,310
--
150,060
4,470
22,400
-2,000
24,870
33,010
57,880
42,130
15,750
Epoxy-coated
fiberglass
B
b
b
b
b
b
b
b
b
b
b
b
b
b
b
C
b
b
b
b
b
b
b
b
b
b
b
b
b
b
.Based on vendor quote.
Not applicable—no control device needed
.Distillation system not needed for these
16.275 percent capital recovery based on
eNegative value indicates a credit.
at Alternative I for these model lines.
model lines; therefore, no costs.
10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
-------
TABLE 8-14. CAPITAL AND ANNUALIZED COSTS FOR CONDENSATION SYSTEM
CONTROL OF MODEL OPERATIONS—REGULATORY ALTERNATIVE II6,7,9,10,20
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost item
00
ro
M
I.
1.
2.
3.
4.
5.
6.
7.
II.
1.
2.
3.
4.
Ill
Capital costs
Control device:3
Installation cost:3 (0.5)(1)
Equipment installed cost:3 (1 + 2)
Partial enclosure installed cost:
Ductwork installed cost:
Distillation system installed
cost:3
Total installed cost: (3+4+5+6)
Direct operating costs
Operating and maintenance labor
plus materials:
Utilities: ,
-Electricity3
Heat savings:3
Total direct costs: (1+2+3)
Indirect operating costs
A
100,300
50,150
150,450
5,700
17,310
c
173,460
2,230
11,200
-1,000
12,430
B
88,500
44,250
132,750
5,700
13,960
—
152,410
4,470
22,400
-2,000
24,870
C
134,200
67,100
201,300
5,700
24,650
—
231,650
4,470
22,400
-2,000
24,870
Urethane-coated
fabric
B
84,400
42,200
126,600
5,700
17,310
79,000
228,610
4,470
22,400
-2,000
24,870
C
127,900
63,950
191,850
5,700
24,650
119,000
341,200
4,470
22.400
-2,000
24,870
Rubber-coated
cord
A
100,300
50,150
150,450
5,700
21,120
—
177,270
2,230
11,200
-1,000
12,430
B
88,500
44,250
132,750
5,700
17,310
—
155,760
4,470
22,400
-2.000
24,870
Epoxy-coated
fiberglass
B
76,200
38,100
114,300
5,700
13,960
118,000
251,960
4,470
22,400
-2,000
24,870
C
115,500
57,750
173,250
5,700
21,120
179,000
379,070
4,470
22.400
-2,000
24,870
1. Capital recovery charges:
(22 percent of total installed
cost)8
38,160
33,530
50,960
50,290
75,060
39.000
34,270
55,430
83,390
IV. Total, annualized costs (II + III)
V. Recovered solvent credit
VI. Net annualized costs (IV - V)e
50.590 58,400 75,830 75,160 99,930 51,430 59,140 80,300 108,260
28,930 46,820 93,640 135,750 271,500 28,930 46,820 63,340 126,680
21,660 11,580 -17,810 -60,590 -171,570 22,500 12,320 16,960 -18,420
.Based on vendor quote.
Installed cost of a capture device obtained from the NSPS development of magnetic tape coating, a similar surface coating operation.
^Distillation system not needed for these model lines; therefore, no costs.
16.275 percent capital recovery factor based on 10-year life and 10 percent interest, pluse 5.725 percent for taxes, insurance, administration, and overhead.
Negative value indicates a credit.
-------
CO
ro
TABLE 8-15. CAPITAL AND ANNUALIZED COSTS FOR CONDENSATION SYSTEM
CONTROL OF MODEL OPERATIONS-REGULATORY ALTERNATIVE III6,7,9,10,20
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost
I.
1.
2.
3.
4.
5.
c
7.
11.
1.
2.
3.
4.
III.
1.
IV.
V.
VI.
item
Capital costs
Control device:3
Installation cost:3 (0.5)(1)
Equipment installed cost:3 (1 + 2)
Total enclosure installed cost:
Ductwork installed cost:
Dictillgticr. system inslalleu
cost:3
Total installed cost: (3+4+5+6)
Direct operating costs
Operating and maintenance labor
plus materials:
Utilities: ,
-Electricity3
Heat savings:3
Total direct costs: (1+2+3)
Indirect operating costs
Capital recovery charges: .
(22 percent of total installed
cost)8
Total >annual ized costs (II + HI)
Recovered solvent credit
Net annual ized costs (IV - V)e
A
100,300
50,150
150,450
15,000
17,310
r
182,760
2,230
11,200
-1,000
12,430
40,210
52,640
30,530
22,110
B
88,500
44,250
132,750
15,000
13,960
--
161,710
4,470
22,400
-2,000
24,870
35,580
60,450
49,440
11,010
C
134,200
67,100
201,300
15,000
24,650
--
240,950
4,470
22,400
-2,000
24,870
53,010
77,880
98,840
-20,960
Urethane- coated
fabric
B
84.400
42,200
126,600
15,000
17,310
79,000
237,910
4,470
22.400
-2,000
24,870
52,340
77,210
143,300
-66,090
C
127,900
63,950
191,850
15,000
24,650
119,000
350,500
4,470
22,400
-2,000
24,870
77,110
101.980
286,600
-184,620
Rubber-coated
cord
A
100,300
50,150
150.450
15,000
21,120
--
186,570
2,230
11,200
-2,000
12,430
41,050
53,480
30,530
22.950
B
88,500
44,250
132,750
15,000
17,310
—
165,060
4,470
22,400
-2,000
24,870
36,310
61,180
49,440
11,740
Epoxy-coated
fiberglass
B
76.200
38.100
114.300
15,000
13,960
118,000
261,260
4,470
22,400
-2,000
24,870
57,480
82,350
66,880
15,470
C
115,500
57,750
173,250
15,000
21,120
179,000
388,370
4,470
22,400
-2,000
24,870
85,440
110,310
133,720
-23,410
.Based on vendor quote.
Installed cost of a capture device obtained from the NSPS development of magnetic tape coating, a similar surface coating operation.
.Distillation system not needed for these model lines; therefore, no costs.
16.275 percent capital recovery based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
Negative value indicates a credit.
-------
00
ro
CO
TABLE 8-16. CAPITAL AND ANNUALIZED COSTS FOR INCINERATOR CONTROL
OF MODEL OPERATIONS—REGULATORY ALTERNATIVE IV6,11,19
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost
1.
1.
2.
3.
4.
5.
6.
'7.
II.
1.
item
Capital costs
Control device:
Purchased equipment cost:
(1.18)(No. 1 above) .
Equipment installed cost:
(1.61)(No. 2 above)
Total enclosure installed cost:
Ductwork installed cost:
Stack installed cost:
Total installed cost: (3+4+5+6)
Direct operating costs
Operating and maintenance labor
A
115,500
136,300
219,400
15,000
65,400
5,200
305,000
18,300
B
113,600
134,000
215,700
15.000
58,100
5,200
294,000
17,640
124
146
236
15
87
5
344
20
t
,400
,800
,300
.000
,900
,200
,400
,660
Ure thane-coated
fabric
B
114.100
134,600
216 , 700
15,000
65,400
5,200
302,300
18,140
C
128,000
151,000
243,100
15,000
103,000
5,200
366,300
21,980
Rubber-coated
cord
A
115,500
136,300
219,400
15,000
80,400
5,200
320,000
19,200
B
113,600
134,000
215,700
15,000
72,900
5.200
308,800
18,530
Epoxy-coated
fiberglass
B
113,600
134,000
215,700
15,000
65,400
5,200
301,300
18,080
C
119,700
141,200
227,300
15,000
80,400
5,200
327,900
19,670
plus materials: (6 percent of
total installed cost)
2. Utilities:
-Electricity 1,070 1,870 3,450 2,360 4,710 1,470 2,580 2,010 2,920
-Natural gas 13,800 24,250 44,750 22,150 44.300 11,290 19,810 23,380 33,890
3. Total direct costs: (1+2) 33,170 43,760 68,860 42,650 70,990 31,960 40,920 43,470 56,480
III. Indirect operating costs
1. Capital recovery charges: 67,100 64.680 75.770 66,510 80,590 70,400 67,940 66,290 72,140
(22 percent of total
installed cost)"
IV. Total annualized costs (II + III) 100,270 108,440 144,630 109,160 151,580 102,360 108,860 109,760 128,620
.Includes costs for instruments and controls, taxes, and freight.
Includes installation direct and indirect costs.
.Installed cost of a capture device obtained from the NSPS development of magnetic tape coating, a similar surface coating operation.
16.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
-------
00
ro
TABLE 8-17. CAPITAL AND ANNUALIZED COSTS, AND ANNUALIZED COSTS PER
UNIT AREA OF SUBSTRATE COATED FOR EACH REGULATORY ALTERNATIVE
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost item
Regulatory Alternative I
Installed capital cost, $
1. Storage tanks
2. Preparation equipment
3. Coating operation
4. Coating operation control system
5. Total
Annual i zed costs, $
i. Storage tanks
2. Preparation equipment
3. Coating operation
4. Coating operation control system
5. Total
Coated substrate, yd2/yr
Total annual ized operating costs
per unit area, $/yd2
Regulatory Alternative II
Installed capital cost, $
1. Storage tanks
2. Preparation equipment
3. Coating operation
4. Storage tank control
5. Preparation equipment control
6. Coating operation control
7. Total
Annualized costs, $
1. Storage tanks
2. Preparation equipment
3. Coating operation
4. Storage tank control
5. Preparation equipment control
6. Coating operation control
7. Total
A
9,400
32,900
666,600
215,300
924,200
2,040
44,910
810,680
41,500
899,130
137,508
6.54
9,400
32,900
666,600
1,240
1,920
225,400
937,460
2,040
44,910
810,680
243
-1,040
42,040
898,873
B
11,000
41,620
666,600
197,500
916,720
2,390
96,410
1,302,340
24,380
1,425,520
222,616
6.40
11,000
41,620
666,600
1,240
1.920
205,300
927,680
2.390
96,410
1,302,340
236
-1,920
22,890
1,422,346
C
12,700
83,180
666,600
269,700
1,032,180
2,760
94,520
2,218,470
13,660
2,329,410
445,230
5.23
12,700
83,180
666,600
1,240
3,840
279,600
1,047,160
2,760
94,520
2,218,470
219
-3,840
9,090
2,321,219
Urethane-coated
fabric
B
N/Aa
N/A
857,900
269.800
1,127,700
N/A
N/A
1,056,250
-29,630
1,026,620
4,700,290
0.22
N/A
N/A
857,900
N/A
N/A
279,900
1,137,800
N/A
N/A
1,056,250
N/A
N/A
-39.230
1.017,020
C
N/A
N/A
857.900
382,100
1,240,000
N/A
N/A
1,626,890
-103,700
1,523,190
9,406,390
0.16
N/A
N/A
857,900
N/A
N/A
392,200
1,250,100
N/A
N/A
1,626.890
N/A
N/A
-125,830
1,501,060
Rubber-coated
cord
A
9,400
24,250
1,054,100
223,400
1,311,150
2,040
43,400
978.440
44,210
1,068,090
193
(tons/yr)
5,534
($/ton)
9,400
24,250
1,054,100
1,240
1,920
235,600
1,326,510
2,040
43,400
978,440
243
-1,040
45,350
1,068,433
B
11,000
32,900
1,054,100
202,400
1,300,400
2,390
84,700
1,521.880
26,470
1.635,440
313
(tons/yr)
5,225
($/ton)
11,000
32,900
1,054,100
1,240
1,920
210,200
1,311,360
2,390
84,700
1,521,880
236
-1,920
24,970
1,632,256
Epoxy-coated
fiberglass
B
11,000
83,100
679,800
N/A
773,900
2,390
97,020
3,311,640
N/A
3,411,050
1,512,112
2.26
11,000
83,100
679,100
1,240
2,880
413,100
1,191,120
2,390
97,020
3,311,640
232
-2,550
70,950
3,479.682
C
12,700
167,820
679,800
N/A
860,320
2,760
114,840
6,171,420
N/A
6,289,020
3,024,224
2.08
12,700
167,820
679,800
1,240
6,720
562,900
1,431,180
2,760
114,840
6,171,420
208
-4,900
67,760
6,352.088
(continued!
-------
TABLE 8-17. (continued)
CO
Ul
Rubber-coated
industrial fabric
Cost item
Coated substrate, yd2/yr
Total annual i zed operating costs
per unit area, J/yd2
Regulatory Alternative HI
Installed capital cost, $
1. Storage tanks
2. Preparation equipment
3. Coating operation
4. Storage tank control
5. Preparation equipment control
6. Coating operation control
7. Total
Annualized costs, $
1. Storage tanks
Z. Preparation equipment
3. Coating operation
4. Storage tank control
5. Preparation equipment control
6. Coating operation control
7. Total
Coated substrate, yd2/yr
Total annual i zed operating costs
per unit area, $/yd2
Regulatory Alternative IVC
Installed capital cost, $
*
1. Storage tanks
2. Preparation equipment
3. Coating operation
4. Coating operation control
5. Total
A
137,508
6.54
9,400
32,900
666,600
17.000
26.450
237.000
989,350
2,040
44,910
810,680
3.434
4.870
44,070
910,004
137.508
6.62
9,400
32,900
666,600
268,000
976,900
B
222,616
6.39
11,000
41,620
666,600
17,000
24.750
218,900
979,870
2,390
96,410
1,302,340
3,418
2,705
24,630
1,431,893
222,616
6.43
11,000
41,620
666,600
260,200
979,420
C
445,230
5.21
12,700
83,180
666,600
17,000
29,680
295,600
1,104,760
2,760
94,520
2,218,470
3,376
-135
9,490
2,328,481
445,230
5.23
12,700
83,180
666,600
293,500
1,055,980
Urethane-coated
fabric
B
4,700,290
0.22
N/A
N/A
857,900
N/A
N/A
293,600
1,151,500
N/A
N/A
1,056,250
N/A
N/A
-42,330
li 013, 920
4,700,290
0.22
N/A
N/A
857,900
258,700
1,116,600
C
9,406,390
0.16
N/A
N/A
857,900
N/A
N/A
436,400
1.294,300
N/A
N/A
1,626,890
N/A
N/A
-126,900
1,499,990
9,406,390
0.16
N/A
N/A
857,900
290,700
1,148,600
Rubber-coated
cord
A
193
(tons/yr)
5.536
($/ton)
9,400
24,250
1.054,100
17,000
26,450
247,200
1,378,400
2,040
43,400
978,440
3,434
4,870
47,370
1,079,554
193
(tons/yr)
5,594
($/ton)
9,400
24,250
1,054,100
278,200
1,365,950
B
313
(tons/yr)
5,215
($/ton)
11,000
32,900
1,054,100
17,000
24,750
223,800
1,363,550
2,390
84,700
1,521,880
3.418
2,705
26.730
1,641,823
313
(tons/yr)
5,245
($/ton)
11,000
32,900
1,054,100
265,200
1,363,200
Epoxy-coated
fiberglass
B
1,512,112
2.30
11,000
83,100
679,800
17,000
31,060
424,500
1,246,460
2,390
97,020
3,311,640
3,407
2,640
71,230
3,488,327
1,512,112
2.31
11,000
83,100
679,800
251,500
1,025,400
C
3,024,224
2.10
12,700
167,820
679,800
17,000
43,030
581,000
1,501,350
2,760
114,840
6,171,420
3,350
-60
67,040
6,359,350
3,024,224
2.10
12,700
167,820
679,800
281,000
1,141,320
(continued)
-------
CO
I
TABLE 8-17. (continued)
Rubber-coated
Industrial fabric
Cost item
Annual i zed costs, $
1. Storage tanks
2. Preparation equipment
3. Coating operation
4. Coating operation control
5. Total
Coated substrate, ydVyr
Total annual i zed operating costs
per unit area, $/yd*
A
2,040
44,910
810,680
90,040
947,670
137.508
6.89
B
2,390
96,410
1,302,340
96,960
1.498,100
222,616
6.73
C
2,760
94,520
2.218,470
130,380
2,446,130
445,230
5.49
Ure thane-coated
fabric
B
N/A
N/A
1,056,250
92.870
1,149.120
4.700,290
0.24
C
N/A
N/A
1,626,890
122,320
1,749,210
9,406,390
0.19
Rubber-coated
cord
A
2.040
43,400
978,440
90,650
1,114,530
193
(tons/yr)
5.775
($/ton)
B
2,390
84,700
1,521,880
94,610
1,703,580
313
(tons/yr)
5,443
($/ton)
Epoxy-coated
fiberglass
B
2,390
97,020
3,311,640
88,760
3,499,810
1,512,112
2.32
C
?,760
114,840
6,171.420
115,370
6,404,390
3,024,224
2.12
.Not applicable.
°Data from Table 6-5.
There is no Regulatory Alternative IV for storage tanks and preparation equipnr
>nt, and therefore there is no control costs for them.
-------
CD
I
PO
TABLE 8-18. AVERAGE AND INCREMENTAL COST EFFECTIVENESS OF
REGULATORY ALTERNATIVES FOR STORAGE TANKS, $/Mg ($/ton)
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost effectiveness
A
B
C
Urethane-coated
fabric
B
C
Rubber-coated
cord
A
B
Epoxy-coated
fiberglass
B
C
Average
1.
2.
3.
Alternative II vs. Ia
Alternative III vs. Ic
Alternative IV vs. Id
5,140
(4,660)
-400
(-370)
53,980
(48,960)
3,050
(2,760)
-370
(-340)
34,190
(31,000)
940
(850).
-380
(-340)
12,750
(11,560)
b
b
b
b
b
b
b
b
b
b
b
b
5,140
(4,660)
-400
(-370)
53.980
(48,960)
3.050
(2.760)
-370
(-340)
34,190
(31.000)
2,910
(2,640)
-500
(-460)
34,050
(30,880)
800
(730)
-510
(-460)
12,620
(11,450)
Incremental
1.
2.
3.
Alternative II vs. Ia
Alternative III vs. IIe
Alternative IV vs. IIIf
5,140
(4,660)
-28,120
(-25,500)
380,270
(344,900)
3,050
(2,760)
-9.480
(-8,600)
377.070
(342,000)
940
(850)
-4,960
(-4,500)
189,900
(172,250)
b
b
b
b
b
b
b
b
b
b
b
b
5,140
(4.660)
-28,120
(-25,500)
380,270
(344,900)
3,050
(2,760)
-9.480
(-8,600)
377,070
(342,000)
2,910
(2,640)
-9,590
(-8,700)
375,970
(341,000)
800
(730)
-5,090
(-4,620)
189,800
(172,150)
.Cost effectiveness = Table 8-5 item VI T Table 7-1 VOC emission reduction beyond baseline for Regulatory Alternative II.
"Not applicable.
jCost effectiveness = Table 8-6 item VI r
Cost effectiveness = Table 8-7 item VI f
Cost effectiveness = (Table 8-6 item VI -
,Alternative III).
Cost effectiveness = (Table 8-7 item VI
Alternative IV).
Table 7-1 VOC emission reduction beyond baseline for Regulatory Alternative III.
Table 7-1 VOC emission reduction beyond baseline for Regulatory Alternative IV.
- Table 8-5 item VI) T (Table 7-1 VOC emission at Regulatory Alternative II - Table 7-1 VOC emission at Regulatory
- Table 8-6 item VI) T (Table 7-1 VOC emission at Regulatory Alternative III - Table 7-1 VOC emission at Regulatory
-------
CO
l\i
CD
TABLE 8-19. AVERAGE AND INCREMENTAL COST EFFECTIVENESS OF
REGULATORY ALTERNATIVES FOR COATING MIX PREPARATION EQUIPMENT, $/Mg ($/ton)
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost effectiveness
Average
1. Alternative II vs. Ia
2. Alternative III vs. Ic
Incremental
1. Alternative II vs. Ia
2. Alternative III vs. IId
A
-273
(-248)
537
(488)
-273
(-248)
1,127
(1,023)
B
-310
(-282)
185
(169)
-310
(-282)
545
(495)
C
-310
(-282)
-4
(-4)
-310
218
(198)
Ure thane-coated
fabric
B
b
b
b
b
b
h
b
b
C
b
b
b
b
b
b
b
Rubber-coated
cord
A
-273
(-248)
537
(488)
-273
1.127
(1,023)
B
-310
(-282)
185
(168)
-310
545
(495)
Epoxy- coated
fiberglass
B
-412
(-375)
180
(163)
-412
(-375)
611
(555)
C
-396
(-360)
-2
(-2)
-396
(-360)
285
(259)
.Cost effectiveness = Table 8-7 item VI * Table 7-2 VOC emission reduction beyond baseline for Regulatory Alternative II.
Not applicable.
.Cost effectiveness = Table 8-8 item VI -f Table 7-2 VOC emission reduction beyond baseline for Regulatory Alternative III.
°Cost effectiveness = (Table 8-8 item VI - Table 8-7 item VI) ^ (Table 7-2 VOC emission at Regulatory Alternative II -
Alternative III).
Table 7-2 VOC emission at Regulatory
-------
00
l\i
UD
TABLE 8-20. AVERAGE AND INCREMENTAL COST EFFECTIVENESS OF REGULATORY ALTERNATIVES
FOR MODEL LINES (Using Carbon Adsorber), $/Mg ($/ton)
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost effectiveness
A
B
C
Urethane-coated
fabric
B
C
Rubber-coated
cord
A
Epoxy- coated
fiberglass
B
B
C
Average
1.
2.
3.
Alternative
Alternative
Alternative
II vs. Ia
III vs. Ib
IV vs. Ic
103
(93)
357
(324)
2,997
(2,718)
-68
(-62)
89
(80)
3,152
(2,859)
-180
(-163)
-101
(-91)
2,576
(2,336)
-696
(-631)
-673
(-610)
5,034
(4,566)
-794
(-720)
-831
(-754)
4,868
(4,415)
103
(93)
356
(323)
2,798 2
(2,538) (2
-67
(-61)
89
(81)
,937
,663)
778
(706)
751
(682)
824
(747)
442
(383)
396
(359)
483
(438)
Incremental
1.
2.
3.
Alternative
Alternative
Alternative
II vs. Ia
III vs. IId
IV vs. Ill6
["Cost effectiveness = (Table 8-10
"fnst effort iuonpcc = ITahlB B-11
103
(93)
1,138
(1,032)
13,746
(12,468)
item VI - Table 8-9
itom VI - Tahlo fl-Q
-68
(-62)
558
(507)
15,404
(13,972)
item VI) T
item VM -
-180
(-163)
137
(124)
13,252
(12,020)
Table 7-4 VOC
Table 7-a wnr
-696
(-631)
-605
(-549)
27,862
(25,271)
emission reduction
-794
(-720)
-944
(-856)
27,664
(25,091)
beyond
103
(93)
1,134
(1,029)
12,742 14
(11,557) (12
baseline for Regulatory
-67
(-61)
558
(507)
,326
,993)
Alternative
778
(706)
-55
(-50)
3,061
(2,776)
II.
Ill
442
(383)
-368
(-334)
3,153
(2,860)
-15 item IV - Table 8-9 item VI) T Table 7-4 VOC emission reduction beyond baseline for Regulatory Alternative IV.
-11 item VI - Table 8-10 item VI) * (Table 7-3 VOC emissions at Regulatory Alternative II - VOC emissions at Regulatory
effectiveness = (Table 8-
"Cost effectiveness = (Table 8-
Alternative III).
Cost effectiveness = (Table 8-15 item IV - Table 8-11 item VI) •=• (Table 7-3 VOC emissions at Regulatory Alternative III - VOC emissions at Regulatory
Alternative IV).
-------
00
CO
o
TABLE 8-21. AVERAGE AND INCREMENTAL COST EFFECTIVENESS OF REGULATORY ALTERNATIVES
FOR MODEL LINES (Using Condensation System), $/Mg ($/ton)
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost effectiveness
A
B
C
Ure thane-coated
fabric
B
C
Rubber- coated
cord
A
B
Epoxy-coated
fiberglass
B
C
Average
1.
2.
3.
Alternative II vs. Ia
Alternative III vs. Ib
Alternative IV vs. Ic
-213
(-194)
-118
(-107)
5,974
(5,418)
-274
(-249)
-240
(-218)
4,478
(4,062)
-324
(-294)
-338
(-307)
3,707
(3,363)
-887
(-805)
-963
(-874)
6,807
(6,174)
-932
(-846)
-1,052
(-954)
6,426
(5,829)
-214
(-194)
-118
(-107)
6.071
(5.506)
-274
(-249)
-240
(-218)
4,463
(4.048)
135
(123)
120
(109)
824
(747)
-74
(-67)
-91
(-82)
483
(438)
Incremental
1.
2.
3.
Alternative II vs. Ia
Alternative III vs. IId
Alternative IV vs. Ill6
-213
(-194)
177
(161)
30,770
(27,914)
-274
(-249)
-137
(-124)
23,352
(21,180)
-324
(-294)
-377
(-342)
19,844
(17,999)
-887
(-805)
-1,189
(-1,078)
37,886
(34,363)
-932
(-846)
-1,411
(-1,279)
36,333
(32.961)
-214
(-194)
177
(161)
31.263
(28,361)
-274
(-249)
-139
(-126)
23,278
(21,113)
135
(123)
-357
(-324)
22,600
(20,498)
-74
(-67)
-598
(-542)
18,216
(16,525)
?Cost effectiveness = (Table 8-13
"Cost effectiveness = (Table 8-14
^Cost effectiveness = (Table 8-15
"Cost effectiveness = (Table 8-14
Alternative III).
eCost effectiveness = (Table 8-15
Alternative IV).
item VI - Table 8-12 item VI) T Table 7-4 VOC emission reduction beyond baseline for Regulatory Alternative II.
item VI - Table 8-12 item VI) -f Table 7-4 VOC emission reduction beyond baseline for Regulatory Alternative III.
item IV - Table 8-12 item VI) -r Table 7-4 VOC emission reduction beyond baseline for Regulatory Alternative IV.
item VI - Table 8-13 item VI) T (Table 7-3 VOC emissions at Regulatory Alternative II - VOC emission;: at Regulatory
item IV - Table 8-14 item VI) T (Table 7-3 VOC emissions at Regulatory Alternative III - VOC emissions at Regulatory
-------
8.3 REFERENCES FOR CHAPTER 8
1. Telecon. Friedman, E., MRI, with Coffey, F., Southern Tank and
Pump Company. August 23, 1984. Information on solvent storage
tanks.
2. Telecon. Friedman, E., MRI, with Herman, K., Sherman Machinery.
August 29, 1984. Information on mix preparation equipment.
3. Telecon. Friedman, E., MRI, with Swain, R., Lembo Corporation.
August 20 and 27, 1984. Information on coating line costs.
4. Telecon. Friedman, E., MRI, with Litzler, W., C. A. Litzler Company,
Inc. August 27, 1984. Information on coating line costs.
5. Telecon. Thorneloe, S., MRI, with Sandra, W. F. Crist. August 16,
1983. Information on conservation vents.
6. Richardson Engineering Services, Inc. Process Plant Construction
Estimating Standards. 1983-1984 Edition. Volumes 1 and 3.
7. Telecon. Friedman, E., MRI, with Ledbetter, B., Union Chemicals
Division. August 27, 1984. Information on solvent prices.
8. Neveril, R. B., GARD, Inc. Capital and Operating Costs of Selected
Air Pollution Control Systems. U. S. Environmental Protection
Agency. Research Triangle Park, N.C. EPA Publication
No. EPA-450/5-80-002. December 1978. p. 5-45.
9. Letter from Memering, L., United Air Specialists, Inc., to
Thorneloe, S., MRI. November 7, 1983. Information on
Kon-den-Solver solvent vapor recovery systems.
10. Peters, M. S., and K. D. Timmerhaus. Plant Design and Economics
for Chemical Engineers. New York, McGraw-Hill Book Company. 1980.
p. 166.
11. Reference 8, p. 5-37.
12. Memorandum from Glanville, J., MRI, to Magnetic Tape Project File.
June 22, 1984. Wastewater discharge calculations and summary.
13. Reference 8, p. 3-12.
14. U.S. Department of Labor. Bureau of Labor Statistics. Employment
and Earnings.
15. U.S. Department of Labor. Bureau of Labor Statistics. Producer
Prices and Price Indexes Data.
8-31
-------
16. U. S. Environmental Protection Agency. VOC Emissions from Volatile
Organic Liquid Storage Tanks--Background Information for Proposed
Standards. EPA-450/3-81-003a. Research Triangle Park, North
Carolina. July 1984. p. 8-19.
17. Reference 10, pp. 172, 174.
18. Memorandum from Friedman, E., MRI, to Polymeric Coating of
Supporting Substrates Project File. September 18, 1984. Product
specific raw material costs for model coating lines.
19. U. S. Environmental Protection Agency. Organic Chemical
Manufacturing Volume 5: Adsorption, Condensation, and Absorption
Devices. EPA-450/3-80-027. Research Triangle Park, North Carolina.
December 1980. pp. IV-2, IV-6.
20. Telecon. Thorneloe, S., MRI, with Schweitzer, P., Chempro.
August 29 and 30, 1984. Information on distillation system.
8-32
-------
9. ECONOMIC ANALYSIS
9.1 INDUSTRY PROFILE
9.1.1 Introduction and Summary
Nationwide, there are over 100 manufacturing firms whose activities
include polymeric coating of supporting substrates. The firms in
the polymeric coating industry are located throughout the country;
however, they tend to be concentrated in the Northeast. The majority
of coating operations involve the production of industrial or inter-
mediate products as opposed to final or consumer products. About half
of the firms are "commission" coaters who sell coated products to
manufacturers of final products, while the other half consists of
"captive" coaters who either manufacture final products themselves, or
are owned by firms that do so.
The firms may be grouped into eight four-digit SIC industry cate-
gories. Two of these categories account for about 50 percent of the
total value of polymeric coated substrates. These are SIC 2295 (Coated
Fabrics, Not Rubberized), and SIC 2296 (Tire Cord and Fabric).
There are many final or consumer products which incorporate poly-
meric coated substrates -- one firm, for example, has estimated that its
output is eventually used in the production of over 1,500 final products,
By far, however, the most important use of polymeric coated products is
in the manufacture of motor vehicles. Currently, more than half of the
output of polymeric coated products is consumed in this use.
In 1982, the total value of output produced by the polymeric
coating industry was about $5.8 billion. The industry is expected to
grow at an annual rate of 2.8 percent over the period from. 1982 to 1990.
9.1.1.1 Industry Segments. As noted above, the firms that may be
affected by the NSPS can be grouped into eight four-digit SIC cate-
gories. These categories are:
9-1
-------
o 2241 - Narrow Fabric Mills;
o 2295 - Coated Fabrics, Not Rubberized;
o 2296 - Tire Cord and Fabric;
o 2394 - Canvas and Related Products;
o 2641 - Paper Coating and Glazing;
o 3041 - Rubber and Plastics Hose and Belting;
o 3069 - Fabricated Rubber Products, Not Elsewhere Classified; and
o 3293 - Gaskets, Packing, and Sealing Devices.
Two of these groups SIC 2241 (Narrow Fabric Mills) and SIC 2641 (Paper
Coating and Glazing) are only remotely affected by the NSPS since the
overwhelming majority of products attributed to these groups do not
require polymeric coating. Accordingly, these two SIC groups are given
only limited attention in this section. The value of annual shipments
for each of the remaining six SIC groups is presented in Table 9-1.
All values are in current dollars (i.e., unadjusted for inflation).
SIC 2295 (Coated Fabrics, Not Rubberized) includes pyroxylin
(nitrocellulose) coated fabrics, vinyl coated fabrics, and others such
as polyurethane coated fabrics.1 Most firms included in this group
are considered part of the coating industry.
Included in SIC 2296 (Tire Cord and Fabric) are all firms that
manufacture tire cord and feibric regardless of whether these products
are consumed internally or sold to tire manufacturers.2 Most firms
in this industry group are considered part of the coating industry.
The group SIC 2394 (Canvas and Related Products) includes all
manufacturers of canvas and canvas products such as awnings, tents,
air-supported structures, tarpaulins, and other covers.3 Most firms
in this SIC group are considered part of the coating industry.
Census Bureau data for SIC 3041 (Rubber and Plastics Hose and
Belting) indicate that most of this group's output can be attributed to
the polymeric coating industry.k Most of the products of SIC 3041
are manufactured by coating textile substrates; a small portion is
manufactured using wire as the supporting substrate. About 85 percent
«
of the total value of the output of this SIC group is attributable to
coated products that could be affected by the NSPS.
9-2
-------
TABLE 9-1. WHOLESALE VALUE OF SHIPMENTS BY SIC GROUP, 1973-1982
($ Current X10 e)
SIC group
Year
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
2295a
975.9
1,056.4
986.1
1,182.5
1,059.0
949.1
998.3
951.7
1,044.7
1,217.7
2296b
717.5
805.0
748.9
835.7
1,013.2
1,090.1
1,129.2
1,009.2
1,060.1
981.5
2394C
321.8
293.2
284.3
301.7
486.8
578.6
542.3
517.2
658.1
741.3
3041^
1,052.0
1,249.9
1,235.4
1,411.9
1,765.7
2,007.8
2,177.7
1,941.5
2,147.2
1,958.0
3069e
3,265.3
3,490.2
3,409.1
3,888.1
4,565.0
4,930.3
5,433.6
5,385.4
6,280.6
6,193.6
3293f
723.0
834.7
842.2
1,019.3
1,267.1
1,481.0
1,675.4
1,610.4
1,781.2
1,650.0
Reference 1, p. 3.
Reference 2, p. 3.
Reference 3, p. 3.
^Reference 4, p. 3.
^Reference 5, p. 3.
*Reference 6, p. 3.
9-3
-------
Most of the products covered by SIC group 3069 (Fabricated Rubber
Products, Not Elsewhere Classified) are rubber goods sold for a wide
variety of products such as foam rubber, mats, surgical gloves, and
shoe parts. Analysis of Census Bureau data indicates that roughly
15 percent of the total value of output of SIC 3069 can be considered
part of the polymeric coating industry. Some of the products affected
are: industrial products such as fuel cells and single ply membrane
rubber roofing; rubber coated fabrics such as protective clothing,
footware fabrics, and inflatable fabrics; and other rubber goods such
as boats, pontoons, life rafts, and hot air balloons.5
Another group only partially affected by the NSPS is SIC 3293
(Gaskets, Packing, and Sealing Devices). This group includes production
of a variety of metallic and nonmetallic gaskets, and sealing devices
including those composed of asbestos, paper, felt, cork, and various
types of metals.5 Polymeric coated rings and seals account for about
15 percent of the total value of this group's output.
9.1.1.2 Industry Output. The data presented above can be used
to estimate the polymeric coating industry's total value of output
for 1982. Such an estimate can be obtained by adjusting the total
output values presented in Table 9-1 (for the six four-digit SIC groups)
by the estimated percentage of each SIC group affected by the NSPS.
The results obtained using this adjustment procedure are presented in
Table 9-2; they show that in 1982, the polymeric coating industry pro-
duced $5.8 billion worth of output. This represents about 0.2 percent of
the 1982 GNP figure of $3,057.5 billion.7
9.1.2 Production, Prices, and Employment
9.1.2.1 Historical Production. The most consistent source of
historical output data for this industry is the Census of Manufactures.
As noted previously, Table 9-1 presents the level of shipments for each
of the major SIC groups in which polymeric coating is known to be
performed. In Table 9-3, these data are adjusted by the percentages
discussed above to obtain shipment estimates for only those products
that could be affected by the NSPS. The estimates are expressed in
1982 dollars to facilitate observation of production trends in the
industry segments. Table 9-4 expresses the output of each segment as a
percentage of the annual totals.
9-4
-------
TABLE 9-2. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
ADJUSTED VALUE OF SHIPMENTS, 1982
($ 1982 X106)
SIC
group
2295
2296
2394
3041
3069
3293
TOTAL
1982 value
of shipments3
1,217.7
981.5
741.3
1,958.0
6,193.6
1,650.0
Percentage
X affectedb
100
100
100
85
15
15
Adjusted
value of
shipments
1,217.7
981.5
741.3
1,664.3
929.0
247.5
5,781.3
aTable 9-1 data.
^These percentages are rough approximations of the portion
of total four-digit SIC output that could be considered part
of the source category affected by this NSPS. The percent-
ages are estimates based upon inspection of Census of Man-
ufacturing product and product class data for the appro-
priate SIC groups. See Section 9.1.1.1.
9-5
-------
TABLE 9-3. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
WHOLESALE VALUE OF SHIPMENTS FOR INDUSTRY SEGMENTS, 1973-19823
($ 1982 X106)
SKjegment
Year 2295b 2296C 2394d 3041e 3069f 32939 total
1973 1,610.5 1,542.5 531.0 1,922.1 1,052.8 233.1 6,892.0
1974 1,551.6 1,428.0 430.6 1,884.6 928.7 222.1 6,445.6
1975 1,460.9 1,204.6 421.2 1,689.1 822.5 203.2 5,801.5
1976 1,630.1 1,268.;? 415.9 1,821.3 885.1 232.0 6,252.6
1977 1,404.9 1,460.6 645.8 2,163.5 987.1 274.0 6,935.9
1978 1,213.4 1,506.7 739.7 2,358.8 1,022.2 307.0 7,147.8
1979 1,209.0 1,404.}. 656.7 2,301.7 1,013.5 312.5 6,897.5
1980 1,059.6 1,121.!i 575.8 1,834.0 897.7 268.4 5,757.0
1981 1,068.8 1,090.7 673.3 1,895.7 978.5 277.5 5,984.5
1982 1.217.7 981.5 741.3 1.664.3 929.0 247.5 5,781.3
aTable 9-1 data converted to 1982 dollars through use of the Producer Price
Index for Rubber and Plastic Products (for SIC's 2296, 3041, 3069, and 3293)
or the Producer Price Index for Textile Products (for SIC's 2295 and 2394).
bCoated Fabrics, Not Rubberized, 100 percent included.
cTire Cord and Fabric, 100 percent included.
dCanvas and Related Products, 100 percent included.
eRubber and Plastics Hose and Belting, 85 percent included.
^Fabricated Rubber Products, Not Elsewhere Classified, 15 percent included.
^Gaskets, Packing, and Sealing Devices, 15 percent included.
9-6
-------
TABLE 9-4. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
PERCENTAGES OF TOTAL OUTPUT BY INDUSTRY SEGMENT, 1973-1982
Year
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
2295a
23.4
24.1
25.2
26.1
20.3
17.0
17.5
18.4
17.9
21.1
2296b
22.4
22.2
20.8
20.3
21.1
21.1
20.4
19.5
18.2
. 17.0
SIC
2394C
7.7
6.7
7.3
6.7
9.3
10.3
9.5
10.0
11.3
12.8 .
segment
3041d
27.9
29.2
29.1
29.1
31.2
33.0
33.4
31.9
31.7
28.8
3069e
15.3
14.4
14.2
14.2
14.2
14.3
14.7
15.6
16.4
16.1
3293f
3.4
3.4
3.5
3.7
4.0
4.3
4.5
4.7
4.6
4.3
• Industry
total9
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
aCoated Fabrics, Not Rubberized.
bTire Cord and Fabric.
cCanvas and Related Products.
dRubber and Plastics Hose and Belting.
fabricated Rubber Products, Not Elsewhere Classified.
fGaskets, Packing and Sealing Devices.
9Columns may not sum exactly to 100 because of rounding.
9-7
-------
Tables 9-3 and 9-4 shovi that the Rubber and Plastics Hose and
Belting (SIC 3041) segment of the industry accounts for the largest
portion of the total value of industry output. Significant shares are
also accounted for by Coated Fabrics, Not Rubberized (SIC 2295), Tire
Cord and Fabric (SIC 2296), Fabricated Rubber Products, Not Elsewhere
Classified (SIC 3069) and Canvas and Related Products (SIC 2394). A
small portion is due to Gaskets, Packing, and Sealing Devices (SIC 3293).
As Table 9-3 shows, total industry output during the early 1980's
was below the levels of the late 1970's. The reduced output of the
early 1980's is probably attributable to the recession experienced
during those years. This is especially true in light of the fact that
many of the products affected by this NSPS are sold as industrial
products.
Output in the Tire Cord and Fabric (SIC 2296) segment of the
industry has declined both in absolute value as well as in relation to
the whole industry. Table 9-3 shows that shipments for this industry
segment declined by more than one-third over the period 1973-1982.
During the same period, the percentage of total industry output accounted
for by Tire Cord and Fabric declined from 22.4 percent in 1973 to 17.0
percent in 1982 (see Table 9-4). Most of this decline can be attributed
to improved tire life.
Output for the industry segment Coated Fabrics, Not Rubberized
(SIC 2295) also declined over the period 1973-1982. This decrease,
however, was less severe than that of SIC 2296, and is largely attrib-
utable to decreased automobile sales.
9.1.2.2 Prices. Most of the products of the polymeric coating
industry are intermediate products, which are consumed internally by the
same firm, or sold to other firms. Consequently, the market for these
products is often poorly defined, and price information is not widely
available. However, the quantity and value data reported in the Census
of Manufactures can be used to approximate average per-unit prices.
Table 9-5 presents prices derived from the Census data noted above.
Included are average prices for products such as vinyl and^urethane
coated fabrics, tire cord and fabric, and various rubber and plastics
hoses and belts.
9-8
-------
TABLE 9-5. AVERAGE PRICES FOR SELECTED PRODUCTS
($ 1982)
SIC code
22951a
2295111
22952
2295213
2295215
2295217
2295222
2295224
2295226
2295232
2295234
2295236
22953
2295315
2295322
2295338
2295348
2296000b
3041 1C
3041103
3041105
3041113
3041116
30412
3041231
3041241
3041251
30414
3041451
30415
3041561
3041563
30416
3041642
3041644
Product
Pyroxylin coated fabrics
- Light cotton fabric
Vinyl coated fabrics
- 10 oz or less, woven fabric
- 10 oz or less, knitted fabric
- 10 oz or less, nonwoven fabric
- 10 to 16 oz, woven fabric
- 10 to 16 oz, knitted fabric
- 10 to 16 oz, nonwoven fabric
- More than 16 oz, woven fabric
- More than 16 oz, knitted fabric
- More than 16 oz, nonwoven fabric
Other coated fabrics
- Polyurethane coated fabrics
All other coated fabrics
- 10 oz or less, woven fabric
- 10 to 16 oz, all fabrics
- More than 16 oz, all fabrics
Tire cord and fabric
Rubber and plastics flat belts
- Lightweight conveyor
- Heavy duty conveyor
- Transmission, flat
- Other rubber and plastic belts
Rubber and plastics belts, not flat
- Industrial
- Agricultural
- Fractional horsepower
Rubber hose, nonhydraul ic, not garden
- Textile based
Rubber and plastics garden hose
- Plastic garden hose
- Rubber garden hose
All other rubber and plastic hose
- Single jacket woven textile
- Double jacket woven textile
Price, $
1.11/linear yd
1.63/linear yd
1.91/linear yd
1.67/linear yd
2.74/linear yd
2.70/linear yd
3. 28/1 i near yd
3.10/linear yd
4.04/linear yd
3.90/linear yd
3.12/linear yd
1.57/linear yd
2. 95/ linear yd
2. 77/1 i near yd
1.99/lb
2.05/lb
1.63/lb
4.29/lb
1.72/lb
6.39 ea
5.98 ea
1.89 ea
0.40/lb
0.17/lb
0.26/lb
0.96/lb
1.28/lb
(Continued)
9-9
-------
TABLE 9-5. (continued)
SIC code Product Price, $
3069Cd Industrial Rubber Products
3069C14 - Single ply membrane roofing 0.42/ft2
Reference 1, pp. 4-5.
^Reference 2, p. 4.
cReference 4, p. 4.
^Reference 5, pp. 4-5.
9-10
-------
9.1.2.3 Employment. Census Bureau data were used to estimate
employment in the various industry segments for the years 1973-1982.
The annual employment for each segment was obtained by applying the
appropriate industry affected percentage noted in Table 9-2 to the Census
estimate of employment at the four-digit SIC level. The calculated
employment estimates are presented in Table 9-6. Total industry employ-
ment during 1982 is estimated to have been 71,300 persons. While this
figure represents less than 0.08 percent of total nonagricultural employ-
ment for 1982, it should be noted that it includes all persons employed
by coating firms, including those who manufacture final products at
captive coaters.
9.1.3 Market Structure
9.1.3.1 Polymeric Coating Companies. Table 9-7 lists 108 companies
operating 128 plants that perform polymeric coating of supporting sub-
strates. Listed for each plant are the location, SIC code, whether the
coating operation is commission or captive, the major end products
produced, and whether the firm is a "small business" according to cri-
teria set forth by the U.S. Small Business Administration. An inspection
of the types of products manufactured by the plants provides some idea of
the diverse nature of this industry.
The plants are concentrated in the Northeastern part of the United
States. Massachusetts, New York, New Jersey, and Ohio account for over
one third of the plants currently in operation. Information regarding
the degree of integration and levels of industrial concentration exhibited
by the companies in this industry is provided in the following sections.
9.1.3.2 Integration. Among the firms belonging to this industry
there is evidence of horizontal and vertical integration as well as
diversification. A horizontally-integrated firm owns and operates
multiple coating facilities in various locations. A vertically-integrated
firm, on the other hand, is involved in related activities other than the
coating operation itself, such as manufacturing the substrate and coat-
ings, or further processing coated materials into final products such as
conveyor belts or tires. Diversification means that the. company manufac-
tures other products or provides services unrelated to its coating
activities.
9-11
-------
TABLE 9-6. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
INDUSTRY SEGMENT EMPLOYMENT, 1973-1982
(thousands)
SIC segment
Year
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
2295a
18.5
18.6
15.9
17.1
13.6
12.3
12.9
11.8
11.4
11.7
2296b
10.3
11.4
10.0
10.1
9.6
9.6
9.7
8.9
8.6
6.5
2394C
14
11
10
10
13
15
12
11
12
14
.0
.2
.4
.3
.9
.4
.0
.1
.5
.5
3041d
25
26
23
25
29
32
32
27
22
21
.6
.5
.1
.4
.2
.5
.9
.5
.9
.0
3069e
16
15
13
14
14
14
15
14
14
13
.4
.8
.5
.0
.8
.9
.9
.2
.4
.1
3293f
4
4
3
4
5
5
5
4
4
4
.2
.2
.8
.1
.0
.1
.4
.7
.5
.5
Industry
total
89.0
87.7
76.7
81.0
86.1
89.8
88.8
78.2
74.3
• 71.3
Reference
^Reference
°Reference
^Reference
Reference
^Reference
1, p. 3.
2, p. 3.
3, p. 3.
4, p. 3.
5, p. 3.
6, p. 3.
9-12
-------
TABLE 9-7. PLANTS APPLYING POLYMERIC COATINGS TO SUPPORTING SUBSTRATES:
LOCATION, SIC CODE, TYPE OF COATER, AND BUSINESS SIZE a
Plant/location
Albany International
Buffalo, N.Y.
Aldan Rubber Co.
Philadelphia, Pa.
Alpha Associates, Inc.
Woodbridge, N.J.
The Amerbelle Corp.
Rockville, Conn.
American Waterproofing
New Haven, Mo.
Archer Rubber Co.
Milford, Mass.
Armstrong Rubber Co.
New Haven, Conn.
Athol Manufacturing Corp.
Butner, N.C.
Aurora Bleaching, Inc.
Aurora, 111.
Bibb Company
Macon, Ga.
Bond Cote of Virginia, Inc.
Pulaski , Va.
Bridgestone
Lavergne, Tenn.
A.S. Browne Manufacturing Co.
Tilton, N.H.
Buffalo Weaving and Belting
Buffalo, N.Y.
Burlington Industries, Inc.
Kernersville, N.C.
CEBI Norton
Watertown, Mass.
Chase & Sons, Inc.
Randolph, Mass.
CHEMFAB
N. Bennington, Vt.
Chemprene
Beacon, N.Y.
SIC Code
3041
2295, 2394,
3069
2295
2295, 2394
2295
3069
2296
2295
2295
3041
2295
2296
3041
3041, 3069
2296, 3041,
3069
2295
3069
3041
3041, 3069
Com-
mission
coater
Yes/No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
c
c
Yes
No
No
No
No
c
Yes
No
No
Small
businessb
Major end products Yes/No
Conveyor belts No
Coated fabric used to Yes
fabricate products
(e.g., tents, tarpau-
lins, rainwear)
Coated fabric Yes
Coated fabric used to Yes
make products (e.g.,
sails and tents)
.*.
Coated fabric Yes
Coated fabric used to Yes
fabricate products
(e.g., diaphragms,
hospital sheeting)
Tire fabric No
Upholstery for auto- Yes
mobiles, school buses
Coated fabric Yes
Coated yarn for V-belts, No
coated fabric for con-
veyor belts
Coated fabric No
No
Industrial belts Yes
Belting, sheeting, Yes
matting
Coated fabric for tire No
cord, V-belts, snow
fences, diaphragms
Coated fabric No
Coated fabric for Yes
cable and wire industry
Coated fabric for Yes
belting
Coated fabric for dia- No
phragms, belting, tar-
paulins, machine covers
(Continued)
9-13
-------
TABLE 9-7. (continued)
Plant/location
:>IC Code
Com-
mission
coater
Yes/No
Major end products
Small
business0
Yes/No
Chrysler Plastic Products ;!295, 3069
Corp., Sandusky, Ohio
Cleveland Plastics 2295
Cleveland, Tenn.
Coast Craft Rubber Co. 3069
Torrance, Calif.
Collins 5 Aitonan Corp. 2295
Roxboro, N.C.
Columbus Coated Fabrics 2295
Columbus, Ohio
Compo Industries 21295
Lowell, Mass.
Cooley, Inc. 22195, 3069
Pawtucket, R.I.
Cooper Tire and Rubber Co. 2296
Findley, Ohio
Texarfcana, Ark.
Custom Coated Products 2295
Cincinnati, Ohio
Oayco Corp. 30.59
Three Rivers, Mich.
Waynesville, N.C.
Oelatex Processing Corp. 22
-------
TABLE 9-7. (continued)
Plant/location
Elizabeth Webbing Co., Inc.
Central Falls, R.I.
Emerson Textiles
Chelsea, Mass.
Engineered Yarns, [nc.
Coventry, R.I.
Essex Group, Inc.
Fort Wayne, Ind.
Ex-Cell-0 Fabric Finishers
[nc., Coshocton, Ohio
Exxon Chemical Americas
Summerville, S.C.
Fabrite Laminating Corp.
Woodridge, N.J.
Facemate Corp.
Chicopee Falls, Ohio
Ferro Corp.
SIC Code
2295
3069
2295
3069
2394
2295
2295
c
2295, 3069
Com-
mission Small
coater business13
Yes/No Major end products Yes/No
c Fabric coated for
mildew and water
repel lancy
c Footwear fabric
c' Coated fabric
c Coated electrical wire
Yes Canvas products
Yes Coated fabric, geotex-
tiles
Yes toated fabric
c c
Yes Coated fabric for auto-
Yes
Yes
Yes
No
Yes
No
Yes
Yes
c
Culver City, Calif.
Norwalk, Conn.
Firestone Industrial Products 3041, 3069 No
Noblesville, Ind.
Flextrim Products 2295 Yes
South El Monte, Calif.
Foss Manufacturing Co., Inc. 2295, 3293 Yes
Haverhill, Mass.
GSC Rubber Coating c c
Oalton, Ga.
Gates Rubber Co. 3041 No
Si loam Springs, Ark.
Denver, Colo.
Ellzabethtown, N.J.
H.A. Gelman, Co. 2295, 3069 c
Brooklyn, N.Y.
motive, military indus-
tries
Hoses, seatbelts, roof-
ing
Coated fabric
Carpet, gaskets, geo-
textiles, footwear fab-
ric, wallcoverings
Belts and hoses
Fabric for automotive,
apparel, bedding, fur-
niture and footwear
industries
No
Yes
Yes
No
Gem Urethane Corp.
Amsterdam, N.Y.
General Fabric Fusing
Cincinnati , Ohio
General Tire and Rubber Co
Toledo, Ohio
Columbus, Miss.
Jeanette, Pa.
Barnesville, Ga.
2295
2295
2295
2296
Yes Artificial leather for
footwear, luggage
c Coated fabric
Vinyl coated fabric
t
Tire cord
Yes
Yes
No
(Continued)
9-15
-------
TABLE 9-7. (continued)
Plant/location
Globe Albany
Buffalo, N.Y.
Com-
mission
coater
SIC Code Yes/No
3041 Yes
Major end products
Belting
Small
business15
Yes/No
No
8.F. Goodrich, Co.
Akron, Ohio
Elgin, S.C.
Greenville, S.C.
Oneida, Tenn.
W.ft. Grace and Co.
Adams, Mass.
Morristown, Tenn.
Graniteville Co.
Graniteville, S.C.
Guilford Mills, Inc.
Greensboro, N.C.
Haartz Auto Fabrics, Inc.
Action, Mass.
Haartz Mason, Inc.
Wat art own, Mass.
Hadbar
Monrovia, Calif.
Hexcel
Livennore, Calif.
Holliston Mills, Inc.
Kingsport, Tenn.
Lincoln, R.I.
Hub Fabric Leather
Everett, Mass.
Jewell Sheen Coating, Inc.
Long Island City, N.Y.
Joanna Western Mills Co.
Chicago, 111.
Johns Manville Corp.
Manville, N.J.
Kenyon Piece Oyeworks Co.
Kenyon, R.I.
Kleen-Tex Industries, Inc.
LaGrange, Calif.
2295, 3069 No
3041
3069
!!29S
•069
3069
229S
2*95
22!95
2295
2295
32'33
2295
22295, 2394 Yes
Yes
Yes.
Yes
Yes
Yes
No
Yes
Belting, hoses, mis- No
sile and marine pro-
ducts, and tank lining
V-belts
Rubber hose
Hoses, belting
Printing blankets No
Awnings, tents, outdoor No
furniture
Automotive fabric, No
tents, upholstery wall-
coverings
Automotive fabric Yes
Convertible top fabric Yes
Automotive fabric, fab- Yes
ric for military, min-
ing, aircraft missiles
Fabric for aircraft and No
missiles
Fabric for graphic arts No
and book covers
Coated flocked fabric Yes
Sporting goods, lap- Yes
Idary supplies, fabric
for instruction
Bookcovers, window No
shades
Packings, seals, gasket No
fabric
Coated fabrics for pro- No
ducts (e.g., rainwear,
tents, luggage, hot air
balloon cloth, heat seals)
Coated fabric for pro-
ducts (e.g., awnings,
upholstery, cushions
for pole vault and
high Jump, seat covers)
Yes
(Continued)
9-16
-------
TABLE 9-7. (continued)
Plant/location
Lewcott Chemicals and .
Plastics Co.
Mlllford, Mass.
Lloyd Manufacturing Co., Inc.
Warren, R.I.
Ludlow Composites
Fremont, Ohio
Marathon Rubber Products
Wausau, Mis.
McCord Gasket Co.
Wyandotte, M1ch,
Michel in Corp.
Greenville, S.C.
Mil liken and Co.
La Grange, Ga.
Murray Rubber^Co.
Houston, Tex.
National Cdating Corp.
Rochland, Mass.
Neese Coated Fabrics
St. Louis, Mo.
Nyl co Corp .
Nashua, N.H.
OOC, Inc.
Norcross, Ga.
Orchard Manufacturing Co.
Lincoln, R.I.
Otto Fabrics, Inc.
Wichita, Kans.
Pacific Combining Corp.
Los Angeles, Calif.
Packaging Systems Corp.
Orangeburg, N.Y.
Plymouth Rubber Co.
Boston, Mass.
Pol yd ad Laminates
Millburg, Mass.
Franklin, N.J.
Putman-Herzl Finishing
Co., Inc.
Putnam, Conn.
SIC Code
2295
2295, 3069
2295
3069
3293
2296
2295
3293
2295
2295, 3069
2295
2295
3069
2295
2295
2295
3069
2295
2295
Com-
mission
coater
Yes/No
Yes
Yes
Yes
Yes
"
No
No
c
No
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Small
business0
Major end products Yes/No
Military products
Backing for napping
machines, cloth for
textile industry
Coated fabric
Rainwear
Gaskets
Cord coating
Coated fabric
Seals and Gaskets
Textiles cloth for
laminates
Coated fabrics for tar-
paul ins, convertible
tops and shoe fabric
Waterproofed fabric
Architectural coverings
for tennis courts, green-
houses
Rubber-coated fiberglass
Awnings, belts, roofing
Coated fabric
Coated fabric
Rainwear, gas mask
fabric
Coated fabric used to
produce a laminate for
printed circuits
Coated fabric for pfo-
ducts (e.g., backpacks.
ski wear, snowmobiles)
Yes
Yes
No
Yes
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
(Continued)
9-17
-------
TABLE .9-7. (continued)
Plant/location
RCA Rubber Co.
Akron, Ohio
RM Industrial Products, .Inc.
North Charleston, S.C.
Rainfatr
Racine, Wis.
Reef Industries, Inc.
Houston, Tex.
Reeves Brothers, Inc.
Rutherfordton, N.C.
Soartanburg, S.C.
Buene Vista, Va.
Rose 4 Sons
Hialeah, Fla.
Scapa Dryers, Inc.
Waycross, Ga.
Seaman Corp.
Millersburg, Ohio
Stacy Fabrics Corp.
Wood Ridge, N.J.
Stanbee Co. , Inc.
Carlstadt, N.J.
Standard Coated Products
Havre de Grace, Md.
Star Tex Industries
Newburg Port, Mass.
Stedfast Rubber Co.
North Eastern, Mass.
J.P. Stevens and Co., Inc.
Walterboro, S.C.
Easthampton, Mass.
Stuart, Va.
Trostel Leather Products
Elkhorn, WIs.
Uni royal, Inc.
Middlebury, Conn.
Utex Industries
Weimar, Tex.
S/IC Code
3(169
2295, 3069
3069
30,59
22515, 3069
22515
3069
2295
2295
306!)
22951
229 E
2295
2295, 3069
3069
2295
3069
2295
3069
2295
3293
Com-
mission
coater
Yes/No
c
c
No
No
Yes
c
c
Yes
Yes
No
c
c
Yes
No
No
No
No
Small
business0
Major end oroducts Yes/No
Rubber-coated fiber Yes
Coated fabric No
Protective clothing, Yes
rainwear
Lightweight liners for Yes
outdoor storage covers
No
Coated fabric
Upholstery
Printing blankets,
inflatibles, diaphragms,
gaskets
Coated- fabric c
Coated fabric Yes
Coated fabric Yes
Coated fabric Yes
Shoe products (e.g., Yes
box heels, 1 iners)
Coated fabric and No
paper for aircraft
Coated fabric for c
• shoes, handbags, sport-
ing goods
footwear fabric Yes
No
Coated fabric for insect
Coated fabric
Backing to carpet for
automotive industry
Impregnating leather for No
industrial packings and
seals
Coated fabric for up- No
holstery, automobiles,
and furniture
Seals and gaskets No
(Continued)
9-18
-------
TABLE 9-7. (continued)
Plant/location
Victor Products
Chicago, 111.
Com-
mission
coater
SIC Code Yes/No Major end products
3293 No Gaskets
Small
business0
Yes /No
Yes
Viking Technical Rubber Co.
West Haven, Conn.
3069
Yes Coated fabric for pro-
ducts (e.g., tarpau-
lins, marine vests)
Yes
aCompiled from State and industry contacts, plant visits, trade associations, 1983
NEDS listing by SIC codes, and the 1983 Industrial Fabric Reviewer/Buyer's-Guide.
bAccording to employment-size criteria established by the U.S. Small Business
Administration. For the SIC groups affected by this standard, S8A defines .a small
business as one that employs fewer than 1,000 persons, for SIC's 2295 and 2296, and
fewer than 500 persons, for all other affected SIC groups.
clnformation not available.
9-19
-------
Concerning horizontal Integration, there are several firms with
coating operations in more than one location. Industrywide, however,
only about 10 percent of all plants currently operating are owned by
horizontally-integrated firms. Horizontally-integrated firms do not tend
to fall exclusively within c;ny of the SIC segments previously discussed.
With regard to vertical integration, the distinction between captive
(vertically integrated) and commission (nonintegrated) coating firms is
pertinent. Most coating firms are vertically integrated backward to some
degree, manufacturing some raw materials used in the coating process such
as the coating itself, or certain substrates. However, the distinction
between a captive and commission coater is made according to the level of
forward integration displayed by the firm. Commission coaters generally
do not produce a final product but instead sell coated substrates to
other firms that use them to produce a variety of products. Captive
coaters typically either produce some final product themselves, such as a
printing blanket or industrial belt, or are owned by another firm that
consumes the majority of the coated output, such as tire cords and
fabric. In general, the vertically integrated captive coaters are those
that belong to SIC 2296 (Tin; Cord and Fabric) or SIC 3041 (Rubber and
Plastics Hose and Belting) or to a lesser degree, SIC 2295 (Coated
Fabrics, Not Rubberized).
Diversification is typically observed in the larger firms in this
industry. Generally, these are firms whose principal products are tires
and rubber, but may also produce plastics, synthetic organic chemicals,
and agricultural chemicals.
9.1.3.3 Concentration. The extent to which industry output tends
to be concentrated at a specific number of manufacturers is a general
indicator of the presence of entry barriers and thus the degree of
competition existing in an industry. Lower levels of concentration are
usually indicative of relatively easy entry of new firms and thus higher
degrees of competition, while high concentration levels generally indi-
cate the existence of entry barriers and thus the absence of a highly
competitive environment. Levels of concentration are reported by the
Census Bureau in the form of concentration ratios, which indicate the
percentages of total industry output produced by the largest 4, 8, and 20
companies. 8
9-20
-------
Table 9-8 presents concentration ratios for the six four-digit SIC
industries analyzed in this study, and for the products of the polymeric
coating industry. The highest degree of competition is exhibited among
the producers of coated fabrics, particularly those who coat with ure-
thane, rubber, and vinyl (SIC 2295 and SIC 3069D). The producers of
canvas products and gaskets, packing and sealing devices also exhibit
high levels of competition, as indicated by low concentration ratios.
Production is highly concentrated in the industry segments performing
rubber coating. In particular, the segments involving the production of
tire cord and fabric (SIC 2296) and various flat belts and V-belts (SIC
30411 and SIC 30412) show high concentration ratios, as does the coating
of fabrics with pyroxylin (nitrocellulose). Accordingly, lower levels of
competitive pressure are experienced by firms manufacturing these prod-
ucts. The industry segments with higher degrees of concentration are
composed largely of captive coaters exhibiting greater forward integra-
tion. These segments generally include the manufacturers of rubber-coated
products such as tire cords and fabrics and various belts and hoses.
9.1.4 Demand and Supply Issues
9.1.4.1 Determinants of Demand. The majority of products produced
by the polymeric coating industry are used primarily as inputs in the
manufacture of final or consumer products. Therefore, the demand for the
output of the industry is a "derived demand" in that it results directly
from consumer demand for the various final products incorporating poly-
meric coated substrates.
The single most important factor shaping demand for the industry is
the consumer demand for new automobiles and trucks. In automobiles, the
coated fabric products of SIC 2295 are used in headliners, seat coverings,
dashboard panels, door inserts, hardtop coverings, carpet backings, and
convertible tops. The bulk of all tire cord and fabric produced by SIC
2296 is used to manufacture tires sold as replacement tires or as original
equipment with new automobiles, as are significant portions of the hoses
and belts produced by SIC 3041. Even the output of SIC 3069 (Fabricated
Rubber Products, Not Elsewhere Classified) and SIC 3293 ,(Gaskets, Packing,
and Sealing Devices) are consumed by the automobile industry in the form
of rubber motor mounts, exhaust system supports, tubing, washers, weather
strip, gaskets, and oil seals.
9-21
-------
TABLE 9-8. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
CONCENTRATION RATIOS FOR INDUSTRY SEGMENTS, 1977a
ro
ro
Percent of output accounted for by the:
SIC
Code
2295
22951
22952
22953
2296
2394
3041
30411
30412
30413
3069
3069D
3293
Industry/Segment/Product
Coated Fabrics, Not Rubberized
- Pyroxylin coated fabrics
- Vinyl coated fabrics
- Other coated fabrics
Tire Cord and Fabrics
Canvas and Related Products
Rubber, Plastic-Hose and Belts
- Flat belting
- Other belts and belting
- Rubber hose (hydraulic)
Fabricated Rubber Products, N.E.C.
- Rubber coated fabrics
Gaskets, Packing, and Sealing Devices
4 largest
companies
37
86
53
33
10
17
51
63
93
53
15
33
24
8 largest
companies
52
97
68
48
-
26
68
77
99
84
23
53
36
20 largest
companies
69
100
86
74
100
40
83
97
100
100
36
78
55
aReference 8, pp. 147, 156, 189, 198.
-------
The link between motor vehicle output and demand for the output of
the affected industry may be seen by examining output levels for both
industries. Table 9-9 lists the value of output estimated for the poly-
meric coating industry (see Table 9-3) along with indexes of output for
both the motor vehicle industry and total U.S. industrial production, for
the years 1973 through 1982. Correlation coefficients have been calcu-
lated to estimate the strength of the relationship between two pairs of
output data: (1) polymeric coating industry output and motor vehicle
output; and (2) polymeric coating industry output and total U.S. indus-
trial production. The correlation coefficients show that industry demand
is highly correlated with motor vehicle production, while there is very
little correlation with total industrial production. It may therefore be
concluded that the demand for polymeric coated substrates is probably a
result of the demand for new motor vehicles.
9.1.4.2 Demand Elasticity. Quantitative estimates of demand
elasticities are not available for the products whose manufacture may be
affected by the NSPS. Because most of the products affected are inter-
mediate or industrial products, estimates of demand elasticity are
usually generated from confidential producer-sponsored research. Further-
more, the number of products involved, variations in product quality, and
the high degree of captive consumption limit the availability of price
and production data that could be used to estimate quantitative demand
elasticities for this analysis.
On the basis of a qualitative assessment, however, it would appear
that the elasticities of demand for the majority of products covered by
the NSPS are probably low. There are three basic reasons for this
conclusion: (1) there are not many substitutes for the affected products;
(2) the affected products account for only a small portion of final
product price; and (3) many of the final products incorporating polymeric
coated substrates are necessities for which demand is relatively inelas-
tic. Consequently because demand elasticities are low, small changes in
the prices of the products affected by this NSPS will not prompt signifi-
cant changes in the quantities demanded.
9.1.4.3 Determinants of Supply. The output of an industry is
determined by the prices commanded by its products as well as by the
9-23
-------
TABLE 9-9. CORRELATION BETWEEN POLYMERIC COATING INDUSTRY OUTPUT AND
INDEXES OF MOTOR VEHICLE AND TOTAL U.S. INDUSTRIAL PRODUCTION
Year
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
Estimated
polymeric coating
industry output3
($ 1982 X10:6)
6,892.0
6,445.6
5,801.5
6,252.6
6,935.9
7,147.8
6,897.5
5,757.0
5,984.5
5,781.3
Correlation coefficient with polymeric
coating industry output
Motor vehicles
production
and partsb
(1967 = 100)
148.8
128.2
111.1
142.0
161.1
169.9
159.9
119.0
122.3
109.8
0.955
Total industrial
production0
(1967 = 100)
129.8
129.3
117.8
130.5
138.2
146.1
152.5
147.0
151.0
138.6
0.192
aTable 9-3.
bReference 7, p. 212.
Reference 7, p. 211.
9-24
-------
availabilities and prices of labor, capital, and raw materials. To some
extent, the importance of these factors in the decision to produce
depends upon whether the producer is a captive or commission coater. In
general, the captive coaters are those who coat with rubber and are part
of SIC 2296 (Tire Cord and Fabric) or SIC 3041 (Rubber and Plastics Hose
and Belting). SIC group 2295 (Coated Fabrics, Not Rubberized) is evenly
split between captive and commission coaters.
Commission coaters may be more sensitive to fluctuations in inter-
mediate product prices because they eventually sell the coated product
rather than process it further into consumer products. Commission
coaters generally operate on a job basis, negotiating price before the
decision to produce.
Captive coaters, on the other hand, do not sell the basic coated
product but process it further into some higher value product such as a
tire, belt, hose, or motor vehicle interior. Because a sale is not made
at the end of the coating process, no explicit product price is estab-
lished at that point.
Several conditions characterize the availability of factors of
production in this industry. First, firms tend to value the ability to
manufacture their own raw materials. This is true for both captive and
commission coaters, with firms in both groups manufacturing both the
substrates and the polymers used in the coating. Anong the benefits of
this backward integration are increased control over quality, reduced
risk of raw material shortages, and increased flexibility to experiment
with new coating formulations and substrate types.9
Another important supply factor is the flexibility of the capital
equipment used in various coatings processes. For example, coating
equipment used in coating fabrics may be used in the manufacture of other
products without extensive modification. Among the other products that
may be manufactured are coated papers, films, and pressure-sensitive
adhesive tapes.10 Flexibility such as this has the effect of reducing
barriers to entry, and thereby increasing the degree of competitiveness
in the industry.
9-25
-------
9.1.5 Foreign Trade
9.1.5.1 Imports. Presented in Table 9-10 are import data covering
the period 1978-1982 for the three largest SIC segments of the polymeric
coating industry: SIC 2295 (Coated Fabrics, Not Rubberized); SIC 2296
(Tire Cord and Fabric); and part of SIC 3041 (Rubber and Plastics Hose
and Belting). In all segments, imports are small ranging from less than
0.1 to 2.5 percent of the value of domestic production.
With regard to SIC 2295, 1982 imports are valued at $22.8 million,
or about 1.9 percent of domestic production of comparable products for
the same year (see Table 9-3). The decline in imports from the preceding
years is most likely a reflection of the recession rather than the onset
of a long-term decline. There is some evidence of variations in import
penetration for specific products; in particular, the ratio of imports to
domestic production for urethane-coated fabrics is probably higher than
that for other types of coated fabric.16
With regard to SIC 229(5 (Tire Cord and Fabric), 1982 imports are
valued at $1.5 million. While this level represents a significant increase
over the levels for the preceding 4 years it represents less than 0.2
percent of 1982 domestic production.
Imports of belting and belts for 1982 are valued at $25.2 million,
or less than 3 percent of domestic production. Because statistics for
imported rubber hoses are nc>t made available, it is assumed that such
quantities are not significant relative to domestic production. Conse-
quently, it appears that with the possible exception of urethane-coated
fabrics, import penetration is not likely to significantly affect the
ability of domestic producers to pass-through control related price
increases.
9.1.5.2 Exports. Table 9-11 presents the annual value of exports
for various polymeric-coated products, for the period 1978-1982. The
data cover SIC 2295 (Coated Fabrics), SIC 2296 (Tire Cord and Fabric),
SIC 2394 (Canvas Products), as well as parts of SIC 3041 (Rubber and
Plastics Hose and Belting) and SIC 3069 (Fabricated Rubber Products, Not
Elsewhere Classified). Comparison of this export data to.the import data
discussed above shows that the U.S. is a net exporter of the subject
products.
9-26
-------
TABLE 9-10. VALUE OF IMPORTS FOR POLYMERIC COATED PRODUCTS, 1978-1982
Value of imports, $
SIC Code
2295
2296
30412A
Product 19783
Coated fabricsf 28.2
Tire cord and fabrics9 0.2
Belting and belts9 26.0
1979b
27.3
0.3
30.0
1980C
27.0
0.2
25.2
1982 X106
1981d
27.2
0.5
21.7
19826
22.8
1.5
25.2
Reference 11.
bReference 12.
Reference 13.
^Reference 14.
Reference 15.
fAdjusted to 1982 dollars by the Producer Price Index for textile products.
9Adjusted to 1982 dollars by the Producer Price Index for rubber products.
9-27
-------
TABLE 9-11. VALUE OF EXPORTS FOR POLYMERIC COATED PRODUCTS, 1978-1982
Value of exports, $
SIC Code
2295
2296
2394
30412A25
30412A45
30412A95
3069DO
Product
Coated fabrics^
Tire cord and fabric9
Canvas products1"
Conveyor beltsQ
Motor vehicle belts9
Machinery belts9
Rubber coated fabrics9
19789
96.5
75.1
7.8
18.0
22.7
24.7
53.3
1979b
117.9
93.6
16.0
24.6
22.1
27.8
51.3
1980C
104.9
163.4
7.5
18.8
19.5
42.0
.».
75.3
1982 X10S
198ld
102.1
111.4
15.0
17.1
19.8
24.1
70.6
19826
77.7
80.3
9.7
15.7
19.8
20.9
63.1
Reference 17.
bReference 18.
cReference 19.
dReference 20.
Reference 21.
fAdjusted to 1982 dollars by the Producer Price Index for textile products.
^Adjusted to 1982 dollars by the Producer Price Index for rubber products.
9-28
-------
Exports of SIC 2295 exceeded 6 percent of total domestic production
for 1982, while exports of SIC 2296 were more than 7 percent of total
domestic production for the same year (see Table 9-3 for data on total
domestic production). A high ratio of exports to domestic production is
also observed for SIC 2394. Exports are an insignificant portion of the
total output of all other products identified.
9.1.6 Industry Growth
Table 9-12 presents projected annual growth rates for selected final
products manufactured from polymeric coated substrates. The rates range
from a low of 3.0 percent for the printing and recreational equipment
markets to a high of 12.1 percent for aircraft manufacturing. As
noted earlier, the demand for the products of the polymeric coating
industry is essentially derived from the consumer demand for the final
products that incorporate polymeric coated substrates as inputs. It is
difficult, however, to translate growth in final product demand into
estimates of demand increases for the products of the polymeric coating
industry. Complicating factors include: (1) style and technological
changes that could alter the amounts of coated materials consumed in each
product class; (2) the need to estimate the precise distribution of .
coated material consumption among all final product classes; and (3) the
large number of final products for which growth rates would be required.
Nonetheless, an estimate of the growth rate of sales for the entire
polymeric coating industry can still be made by recognizing that the
demand for the industry's output is derived mainly from the demand for
motor vehicles. As discussed in Section 9.1.4.1, annual output levels
for the motor vehicles and polymeric coating industries are highly
correlated. This correlation, together with projected domestic produc-
tion of motor vehicles may be used to estimate future industry growth.
Table 9-13 lists output levels for both the motor vehicle and
polymeric coating industries for 1973-1982. By applying linear regression
to these output levels, output in the polymeric coating industry may be
expressed as a function of motor vehicle production. The parameters of
the function are specified by the equation:
$ PCSS (millions) = 3,188.43 + 20.93 $ MV (billions),
9-29
-------
TABLE 9-12. PROJECTED ANNUAL GROWTH RATES
FOR SALES OF SELECTED FINAL PRODUCTS
MANUFACTURED FROM POLYMERIC COATED SUBSTRATES*
Product/Market
Automobiles
Aircraft
Conveyor belts
Flexible hoses
Printing
Protective clothing
Recreational equipment
V-Belts
Growth rate, percent
4.8
12.1
3.4
3.9
3.0
5.0
3.0
3.3
Period
1980-1990
1982-1987
1983-1988
1982-1987
1983-1985
1981-1990
1982-1987
1983-1988
Reference 22.
9-30
-------
TABLE 9-13. DATA USED TO DERIVE INDUSTRY FORECAST EQUATION
Year
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
Value of
motor vehicle
output3
($ current X 10 9)
—
74.61
68.67
70.21
96.10
118.01
132.21
132.70
114.85
137.42
__
Producer
price
index*3
118.0
119.2
129.2
144.6
153.8
163.7
176.0
190.5
208.8
237.6
251.3
Value of
motor vehicle
output
($ 1982 X 109)
—
157.29
133.57
122.02
157.02
181.16
188.77
175.05
138.23
145.71
130.82d
Value of
polymeric coating
industry
output0
($ 1982 x 106)
—
6,892.0
6,445.6
5,801.5
6,252.6
6,935.9
7,147.8
6,897.5
5,757.0
5,984.5
5,781.3
Reference 23.
^Producer Price Index for
cTable 9-3.
^1982 value derived using
motor vehicles and equipment; Reference 24.
motor vehicle production index from Table 9-9.
9-31
-------
where:
$ PCSS = value of polymeric coating industry output, and
$ MV = value of motor vehicle industry output.
The coefficient of determination, or R 2, is 0.77, indicating that about
77 percent of the variation in polymeric coating output can be explained
by variations in the production of motor vehicles.
Estimates of future output levels for the polymeric coating industry
can be made using the above equation and forecasts of motor vehicle
production. The estimates obtained are presented in Table 9-14 and show
that the estimated value of output for 1990 is $7.2 billion (in 1982
dollars). This level represents an annual growth rate for the entire
industry of 2.8 percent per year over the period from 1982 to 1990.
9.2 ECONOMIC IMPACT ANALYSIS
9.2.1 Introduction and Summary
The following sections present an evaluation of the economic impacts
associated with the costs estimated to result from compliance with this
NSPS. Economic impacts are discussed in terms of percentage cost and
price changes along with qualitative evaluations of the implications of
the estimated changes. The socioeconomic impacts of the proposed NSPS
including inflationary, employment, and small business impacts are
described in Section 9.3. As noted in that section, the fifth-year
annualized costs of compliance with the most costly regulatory alterna-
tives are $1.9 million. Such costs are well below the $100 million level
that Executive Order 12291 specifies as one indicator of a major regula-
tory action.
With regard to price and cost increases, all regulatory alternatives
other than Regulatory Alternative IV, which requires the incineration of
captured VOC's, entail relatively small price and cost increases. For
reasons outlined in the following sections, it is not expected that such
cost and price increases will significantly affect either the demand for
polymeric coated substrates, the production rates of firms that manufac-
ture such products, or employment levels at such firms.
9-32
-------
TABLE 9-14. PROJECTED VALUE OF ANNUAL OUTPUT
FOR THE POLYMERIC COATING INDUSTRY, 1984-1990
Projected value of motor vehicle output
Year
1984
1985
1986
1987
1988
1989
1990
($ 1972 X10-9)3
84.85
84.28
82.11
90.70
95.66
94.79
90.72
($ 1982 X109)b
180.70
179.49
174.87
193.16
203.72
201.87
193.20
Projected value of
polymeric coating
industry output0
($ 1982 X109)
6.97
6.94
6.85
7.23
7.45
7.41
7.23
Reference 25.
^Adjusted through price index of Table 9-13.
Estimated through equation $ PCSS (millions) = 3,188.43 + 20.93 $ MV (billions)
9-33
-------
9.2.2 Method
The method used to estimate potential economic impacts is based upon
an analysis of both cost and price changes that could be prompted by the
promulgation of this NSPS. The cost changes of concern are the incre-
mental net annualized costs incurred by the firms that would operate new
polymeric coating facilities. Price impacts refer to the extent to which
coating line product prices are expected to change if all NSPS-related
control costs, or in some cases cost savings, are passed to consumers.
Percentage cost changes are presented to provide an indicator of the
relative magnitude of NSPS costs for model plants of various types and
sizes under different levels of control. Price increases are estimated
in order to provide an evaluation of the extent to which typical coating
line product prices would be affected by the standard. Percentage cost
increases are estimated by dividing incremental net annualized control
costs by baseline annualized costs, while percentage price increases are
approximated by dividing incremental net annualized control costs by the
value of specific coating line products.
9.2.2.1 Cost Issues. The costs of concern in this analysis are the
incremental costs associated with operating coating facilities under
various NSPS control alternatives. Consequently, NSPS costs are measured
as increments above the baseline control level, or that level of control
required under State Implementation Plans. Baseline net annualized costs
are calculated by combining uncontrolled annualized costs with the costs
to control to the baseline level or Regulatory Alternative I. Thus, to
derive baseline net annualized costs for coating lines using carbon
adsorbers, the uncontrolled total annualized costs of Table 8-4 are added
to the Regulatory Alternative I net annualized costs presented in Table 8-9,
For purposes of this analysis it is assumed that all model facilities
will use carbon adsorber control systems rather than condensation systems,
because the use of the former is most typical of the coating industry.
Also the analysis is based upon the consideration of complete sets of
facilities, that is, coating operations together with compatible coating
preparation equipment and storage tanks. Finally, because ^ach of the
affected facilities can be controlled to one of several levels not all
potential combinations of facilities and control levels are examined in
9-34
-------
this analysis. For example, because coating operations could be con-
trolled to one of four regulatory alternatives, while both coating
preparation equipment and storage tanks could be controlled to one of
three alternatives, 36 combinations of facility and control level
would be possible. Therefore, in order to limit the number of situations
examined, only those combinations that require each facility to be
controlled above the baseline level (i.e. Regulatory Alternative I) are
considered. Limiting the analysis in this way reduces the combinations
of facility and control alternatives to the 12 noted in Section 9.2.3.
9.2.2.2 Price Impacts. In order to obtain an indication of the
extent to which coating line product prices could be affected by the NSPS
control costs, typical products of the model lines have been identified.
The products of concern are in all cases intermediate products in that
they require further processing before being used in their intended
applications. Consequently, the prices for the products described below
are approximations of the value of the coated product at the end of the
coating stage of manufacturing.
The selection of typical products of the model lines is based upon
four general criteria. First, the product selected should be manufactured
through the application of a polymeric coating that is consistent with
the model line parameters described in Chapter 6. Second, the market
value of the product should adequately represent the value of all possible
products that could be produced at the model line. Third, reliable
price/value data should be available for the selected products. Fourth,
the selected products should be expected to exhibit some growth in output
over the next 5 years. Based upon these criteria, five products have
been selected as being representative of the four model lines previously
noted.
The model coating line "rubber-coated industrial fabric" is assumed
to have two typical products, offset printing blankets and diaphragms.
Printing blankets are used to transfer inked images from inking rollers
to paper and in some cases metal. The resiliency of rubber printing
blankets allows the use of a wide variety of paper thickness and texture.
The printing blankets examined in the price increase estimates of Section
9.2.3.2 are specified as being based upon a 72-inch wide cotton substrate,
9-35
-------
and are estimated to have a value of $16.57 per square yard when the
coating process is completed. 26
Diaphragms are constructed of rubber-coated nylon, and are used in a
variety of industrial applications including valves and seals. Diaphragm
valves are used to control the flow of slurries and corrosive fluids and
for vacuum. Diaphragms are also used as seals in packless valves. The
diaphragm material examined in the price analysis is based upon 48-inch
wide nylon, and has an intermediate value of $7.52 per square yard.27
The products of urethane coating lines can vary in terms of coating
thickness, substrate weight, and width. The product thought to be
typical of the "urethane-coated fabric" model line is a 60-inch wide,
1.7-oz nylon coated fabric. A common use for such a product is in the
construction of tents, but can also be used in other recreational equip-
ment including footware and luggage. The product described above is
estimated to have an intermediate value of $1.02 per square yard.23
V-belts are estimated to be typical of the "rubber-coated cord"
model line. Such belts are used in a variety of power and motion trans-
mission applications and are generally consumed by the automobile and
industrial equipment industries. The rubber-coated polyester cord used
to construct V-belts of various dimensions is estimated to have a value
of about $2.60 per pound. 29
The product selected as being typical of the model coating line
"epoxy-coated fiberglass" is aircraft parts. Such parts are used in
various applications by the military and aircraft construction industry,
including interior moldings and panels, roof linings, and aircraft
exteriors. The advantages of epoxy-coated fiberglass in these applica-
tions include its low weight and durability. It is estimated that the
epoxy-coated product used to fabricate aircraft products has a value of
about $3.75 per square yard. 30
In order to evaluate the extent to which various regulatory alter-
natives could increase the prices of the coating line products noted
above, the net annualized costs of such alternatives are expressed as
percentages of the total revenue generated by production pf each product
at individual coating lines. These percentages are described in Section
9.2.3.2 along with some evaluation of the ability of individual firms to
9-36
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pass through control-related price increases. The probability that price
increases will be passed to the purchasers of the intermediate products
described above is based upon a qualitative evaluation of the degree of
competition among firms producing the affected products, the level of
price increases needed, and the elasticity of demand for the affected
products.
9.2.3 Analysis
9.2.3.1 Percent Cost Changes. As described in the previous section,
the effects of the cost to meet various regulatory alternatives are
described in terms of increased or decreased annualized costs as well as
increased or decreased product prices. With regard to costs, percentage
changes for each of the model lines are presented in Table 9-15. The
changes summarized in that table are generated by finding the incremental
net annualized control costs associated with meeting the appropriate
regulatory alternatives, and expressing those costs as a percent of the
baseline (i.e., Regulatory Alternative I) annualized costs for the same
facilities. The following example shows how the 0.50 percent cost
increase associated with the control of rubber-coated industrial fabric
model coating line B, and the compatible mix preparation equipment
and storage tank, to Regulatory Alternative III was estimated.
Net annualized incremental control costs to meet Regulatory Alterna-
tive III for the three facilities are determined by finding the difference
between the net annualized cost to control the coating operation to
Regulatory Alternative III (Table 8-11) and the cost to control the same
line to the baseline level (Table 8-9). In this example, the incremental
net annualized costs are $1,060. Because there are no costs to control
coating preparation equipment and storage tanks to the Regulatory Alterna-
tive I baseline, the appropriate increments for these facilities are
found in Tables 8-8 and 8-6, respectively. The appropriate increments in
this example are $2,705 for coating preparation equipment and $3,418 for
storage tanks. Thus the total net annualized incremental cost to control
all three facilities to Regulatory Alternative III is $7,183.
With regard to baseline (Regulatory Alternative I) net annualized
costs, such costs are determined for the three facilities by adding the
uncontrolled annualized costs for the three facilities (Tables 8-2, 8-3,
9-37
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TABLE 9-15. PERCENT COST INCREASES FOR MODEL PLANTS9
I
CO
00
Regulatory alternative
Coating
Operation
II
II
II
II
III
III
III
III
IV
IV
IV
IV
Coating
Preparation
II
II
III
III
II
II
III
III
II
II
III
III
Storage
Tank
II
III
II
III
II
III
II
III
II
III
II
III
Ru
indu
A
0.00
0.35
0.64
0.99
0.27
0.62
0.92
1.26
4.11
4.46
4.75
5.10
bber-coated
strial fabric
B
-0.18
0.05
0.15
0.37
-0.04
0.18
0.28
0.50
4.47
4.69
4.79
5.01
C
-0.34
-0.21
-0.19
-0.05
-0.35
-0.21
-0.19
-0.06
4.40
4.54
4.56
4.69
Rubber-
Urethane-coated coated
fabric cord
B
-0.17
-0.17
-0.17
-0.17
-0.22
-0.22
-0.22
-0.22
2.00
2.00
2.00
2.00
C
-0.20
-0.20
-0.20
-0.20
-0.29
-0.29
-0.29
-0.29
2.03
2.03
2.03
2.03
A
0.00
0.31
0.58
0.89
0.25
0.56
0.82
1.13
3.44
3.75
4.02
4.33
B
-0.16
0.04
0.14
0.34
-0.04
0.16
0.26
0.46
3.84
4.04
4.14
4.34
Epoxy-coated
fiberglass
B
2.00
2.06
2.10
2.17
2.07
2.13
2.18
2.24
2.26
2.33
2.37
2.44
C
1.12
1.16
1.18
1.21
1.11
1.15
1.17
1.20
1.38
1.42
1.43
1.47
aAssumes use of carbon adsorber for Regulatory Alternatives II and III, and incinerator for
Regulatory Alternative IV.
-------
and 8-4) to the Regulatory Alternative I costs for coating operations
(Table 8-9). As noted previously, the baseline costs for coating prep-
aration equipment and storage tanks are zero, consequently the total net
annualized baseline costs for all three facilities are obtained through
the addition of the uncontrolled net annualized costs for the coating
operation ($1,302,340), coating preparation equipment ($86,410), and
storage tank ($2,390), to the Regulatory Alternative I cost for the
coating operation ($42,690), or a total of $1,433,830. Finally, the
percentage increase in annualized cost attributable to Regulatory
Alternative III is 0.50 percent (i.e. ($7,183/$1,433,830) x 100).
The percentage cost changes summarized in Table 9-15 are generally
less than 1 percent with the exception of Regulatory Alternative IV for
coating operations, and epoxy-coated fiberglass facilities under all
regulatory alternatives. Regulatory Alternative IV increases are excep-
tionally high because this most stringent control option requires that
all VOC emissions be incinerated, rather than captured and reused, thus
eliminating product recovery credits. Epoxy-coated fiberglass facilities
show relatively high cost increases because such coating operations do
not require control equipment to meet Regulatory Alternative I emission
limits. Consequently, the incremental costs of meeting more stringent
emission levels are relatively high for these types of facilities.
9.2.3.2 Price Changes. As noted in Section 9.2.2.2, coating
operation product price impacts are estimated by selecting a number of
products that are typical of the output of the model plants described in
previous sections. These products are summarized in Table 9-16, along
with estimates of annual quantities capable of being produced at the
appropriate model plants, estimates of product value at the end of the
coating process and annual revenue estimates based upon the price and
quantity levels noted. Specific product price increases are estimated
*
through the expression of incremental net annualized costs as a percent
of the revenues noted under various combinations of regulatory alterna-
tives. These percentages are presented in Table 9-17.
The percent price increases estimated for the typical products of
*
the rubber-coated industrial products model plant are generally less than
one-half of 1 percent for all combinations of regulatory alternatives
9-39
-------
vo
TABLE 9-16. ANNUAL REVENUE ESTIMATES
FOR MODEL LINES PRODUCING TYPICAL PRODUCTS
(First Quarter 1984 Dollars)
Model coating line/product
Rubber-coated Industrial fabric
- Printing blankets^
(7 2- inch wide cotton)
- Diaphragms0
(48-inch wide nylon)
Urethane-coated fabric
- Tent material0
(60-inch wide,
1.7 oz nylon)
Rubber-coated cord15
- V-belts
(polyester cord)
Epoxy-coated fiberglass^
- Aircraft parts
(72-inch wide,
20 oz fiberglass
fabric)
Annual Intermediate
quantity product value
Line/ produced or price3
size (ya2/yr) ($/yd2)
1A
IB
1C
1A
IB
1C
2B
2C
3A
3B
4B
4C
137,508
222,616
445,230
580,970
940,550
1,881,100
13,091,480
26,199,140
193.1 tons/yr
312.6 tons/yr
1,512,112
3,024,224
16.57
16.57
16.57
7.52
7.52
7.52
1.02
1.02
2.60/lb
2.60/lb
3.75
3.75
Annual
revenue per
coating line
($/yr)
2,278,510
3,688,750
7,377,460
4,368,900
7,072,940
14,145,870
13,353,310
26,723,120
1,004,120
1,625,520
5,670,420
11,340,840
aThe product prices implied by the values reported here are based upon the re-
view of confidential data supplied by manufacturers. However, where such values/
prices can be compared to the product prices implied by the Census of Manu-
factures data summarized in Table 9-5 (i.e. rubber belts and cords, and urethane-
coated tent fabric) the product prices reported by both sources are reasonably
consistent.
Reference 26.
cReference 27.
-------
TABLE 9-17. PERCENT PRICE INCREASES FOR TYPICAL PRODUCTSa»b
UD
Regul atory
alternative
COC
II
II
II
II
III
III
III
III
IV
IV
IV
IV
CPd
II
II
III
III
II
II
III
III
II
II
III
III '
STe
II
III
II
III
II
III
II
III
II
III
II
III
Printing blankets
A
0.00
0.14
0.26
0.40
0.11
0.25
0.37
0.51
1.66
1.80
1.92
2.06
B
-0.07
0.02
0.06
0.14
-0.02
0.07
0.11
0.19
1.74
1.82
1.86
1.95
C
-0.11
-0.07
-0.06
-0.02
-0.11
-0.07
-0.06
-0.02
1.40
1.45
1.45
1.50
Diaphragms
A
0.00
0.07
0.14
0.21
0.06
0.13
0.19
0.27
0.87
0.94
1.00
1.07
B
-0.04
0.01
0.03
0.07
-0.01
0.04
0.06
0.10
0.91
0.95
0.97
1.02
C
-0.06
-0.03
-0.03
-0.01
-0.06
-0.04
-0.03
-0.01
0.73
0.75
0.76
0.78
Tents
B
-0.07
-0.07
-0.07
-0.07
-0.10
-0.10
-0.10
-0.10
0.87
0.87
0.87
0.87
C
-0.08
-0.08
-0.08
-0.08
-0.12
-0.12
-0.12
-0.12
0.84
0.84
0.84
0.84
V-belts Aircraft parts
A
0.00
0.32
0.59
0.91
0.25
0.57
0.84
1.16
3.51
3.83
4.10
4.42
B
-0.16
0.04
0.13
0.33
-0.04
0.16
0.25
0.44
3.67
3.86
3.95
4.15
B
1.67
1.73
1.77
1.82
1.73
1.79
1.83
1.88
1.89
1.95
1.99
2.04
C
0.89
0.92
0.93
0.96
0.88
0.91
0.92
0.95
1.09
1.12
1.14
1.16
aSee Table 9-16 for specifications of products.
^Assumed use of carbon adsorber for Regulatory Alternatives II and III, and incerator for Regulatory Alterna-
tive IV.
CCO = Coating operation.
dCP = Coating preparation.
eST = Storage tank.
-------
with the exception of those that require the incineration of captured
VOC's (i.e. Regulatory Alternative IV for coating lines). Price increases
of this level are not considered to be significant, especially in light
of the fact that there are no comparable substitutes for the printing
blanket and diaphragm products, and that the prices for these products
represent only a very small portion of the costs of the final products
(i.e., printing and industrial process equipment) of which they are a
part. Because these two conditions are indicative of inelastic demand,
it is concluded that the price increases estimated will be paid by
the consumers of the rubber-coated industrial products noted.
With regard to the tent material manufactured by the urethane-coated
fabric model line, the cost decreases provided by the capture and recovery
of solvents would allow price decreases for products produced from these
lines. Therefore, it is not expected that any adverse demand-related
consequences could result from the promulgation of control alternatives
other than Regulatory Alternative IV.
If Regulatory Alternative IV is proposed for urethane coating lines,
the incineration of VOC's could cause price increases of about 2-1/2
percent. The ability to pass through price increases of this level would
be questionable, because the threat of foreign imports is most significant
for urethane-coated fabrics.3*
Price increases for the V-belt products manufactured at new rubber-
coated cord lines are generally less than 1 percent for regulatory
alternatives that capture and recover solvents. In these cases it is
expected that price increases could be passed to the manufacturers and
owners of motor vehicles who are the largest consumers of V-belt products.
This conclusion is based upon the belief that demand elasticity for
V-belts is very low because the products are necessities, with no substi-
tutes, and such belts represent a very small portion of the total cost of
the vehicles in which they are used.
Price increases for aircraft parts manufactured at epoxy-coated
fiberglass lines are estimated to range from about 1 to 2 percent. Even
though these percentages are generally higher than those estimated for
the other affected products, the consuming industries that purchase these
products can be expected to ultimately pay the required price increases.
9-42
-------
The consuming industries in this case are the manufacturers of civilian
and military aircraft that are eventually purchased by the Department of
Defense, airlines and other private companies, and foreign governments.
Low demand elasticities are most likely because the affected products
have no substitutes that offer comparable combinations of weight and
strength, and because the cost of the affected products are very small
compared to the total cost of the aircraft in which they are used.
9.3 SOCIOECONOMIC AND INFLATIONARY IMPACTS
The analysis presented in Section 9.2 describes the effects that
this NSPS could have upon prices and production costs of polymeric coated
substrates. In this section the potential for more general economic
impacts is discussed. Included among the issues addressed here are those
required to be considered by Executive Order 12291 including inflation
and employment impacts. Also addressed is the potential for small
business impacts as required by the Regulatory Flexibility Act. These
issues are considered after a review of the method by which the industry
growth estimates of Section 9.1.6 are expressed in terms of new plant
construction.
9.3.1 New Plant Construction
In order to project the total annualized costs of this NSPS during
the fifth year after its proposal, an estimate of the number of new
coating facilities that will be constructed over that period is needed.
The basis for the projection of new facilities described below is the
total industry annual growth estimates presented in Table 9-14.
The first step requires the estimation of the total value of output
required of new solvent-based coating operations over the five-years
including 1986 and 1990. The data summarized in Table 9-18 show that an
estimate of $79 million (1982 dollars) in new output is obtained by
observing the total output levels presented in Table 9-14, finding
increments over full capacity output needed for each year, and modifying
the annual increments by a factor to account for the general decline in
solvent-based output. The full capacity levels noted in Table 9-18 are
based upon the assumption that industrywide full capacity is defined by
the highest annual output level observed during recent years. Table 9-3
9-43
-------
TABLE 9-18. TOTAL VALUE OF NEW SOLVENT-BASED CAPACITY REQUIRED 1986-1990
-e*
.£>
Total industry
sales capacity3
Year ($1982 x 10 9)
1986
1987
1988
1989
1990
6.85
7.23
7.45
7.41
7.23
Current full
capacity1*
($1982 x 10 9)
7.15
7.15
7.23
7.45
7.45
Needed new
capacity0
($1982 x 10 9)
0.00
0.08
0.22
0.00
0.00
Solvent New solvent-
use based capacity
i factord ($1982 x 10 9)
0.320
0.288
0.256
0.224
0.192
5-year total =
0.000
0.023
0.056
0.000
0.000
0.079
aTable 9-14.
"Yearly values equal highest capacity observed during previous years.
cPositive difference between the total industry sales capacity and current full
capacity.
Derivation explained in Section 9.3.1.
eNeeded new capacity times solvent use factor.
-------
shows that before 1987 the highest industry output level was $7.15
billion, produced during 1978. This amount is assumed to represent full
capacity until 1987 when the $7.23 billion estimated to be produced
during that year becomes the new full capacity level.
The annual increments to capacity are modified by the solvent use
factors noted to represent the reduced popularity of solvent-based
coating methods due to solvent costs and environmental and health and
safety concerns. The factors used have been obtained through the linear
extrapolation of data indicating that in 1976 about 64 percent of all
coated substrate products were produced through the use of solvents,
while in 1981 this percentage declined to 48 percent.32 Because it is
expected that this trend will continue into the late 1980's the total
value of output from new solvent-based capacity is estimated to be $79
million (1982 dollars). Finally, in order to allow comparison with the
value of output from the model plants, this total is expressed in terms
of first quarter 1984 dollars, through the use of the Producer Price
Index for Industrial Commodities. Because this index stood at 272.8 in
1982, and 285.5 for for the first quarter of 1984, the total value of
output from new solvent-based capacity is $83 million in first quarter
1984 dollars. 33, 3<*
The second step in the new plant projection method requires the
estimation of the total value attributed to production from model plants.
Because the industrywide total value amounts previously described include
some value-added due to processing of coated products beyond the coating
operation itself, some adjustment to the product values implied by the
baseline model plant cost data of Chapter 8 is required, in order to put
the plant output data on a comparable basis. For example, that portion
of the total industry output projection that accounts for the production
of V-belts, reports the value of the coating operation product (rubber-
coated polyester cord) after it has been further processed into the
V-belt product. Consequently, dividing the coating operation cost (or
rubber-coated polyester cord product value) into the value of future
demand for V-belt type products would tend to overstate the number of new
lines needed to satisfy future demand. In order to adjust for this
discrepancy, coating line product values, as estimated by the baseline
costs of Chapter 8, are increased to account for additional processing
9-45
-------
that coated products typically receive before their sale. Such increases
have been made through the consideration of data reported in the 1982.
Census of Manufacturers which indicates that for rubber fabric and rubber
cord coating operations, the value of shipments by these companies
typically exceed the cost of materials purchased by a 2 to 1 ratio. 3S 36
Furthermore, for all other fabric coating companies, including urethane
fabric and epoxy fiberglass coating operations, the same ratio is 1.6 to
1. 37 Thus in order to quantify the value of shipments associated with
the output of the model coating operations, the total raw material costs
of the model lines presented in Table 8-4, are increased according to the
appropriate ratios. The resulting values are then directly comparable to
the new capacity dollar values presented in Table 9-18.
The final step in the new plant projection method entails the
expression of the increased capacity requirements in terms of the number
of new coating facilities. This is accomplished through the division of
increased capacity requirements in terms of value of output ($83 million)
by the total value of annual production from all model plants ($55
million). Therefore, assuming that new production would be distributed
evenly among the model plants, approximately two of each of the nine
model coating operations, coating preparation and storage tank facilities
described in Chapter 6, would be needed to satisfy increases in demand
over the next 5 years. Finally, because most coating line and related
equipment is easily repaired and tends to have a long life expectancy,
new plant construction related to the replacement of aged facilities is
not considered by the method described above.
9.3.2 Executive Order 12291
As defined by Executive Order 12291,38 "major rules" are those
that are projected to have any of the following impacts:
o An annual effect on the economy of $100 million or more;
o A major increase in costs or prices for consumers, individual indus-
tries, federal, State, or local government agencies or geographic
regions; or
9-46
-------
o Significant adverse effects on competition, employment, investment,
productivity, innovation, or on the ability of United States-based
enterprises to compete with foreign-based enterprises in domestic or
export markets.
9.3.2.1 Fifth-Year Annualized Costs. The estimation of fifth-year
annualized costs, under the most costly regulatory alternatives, is
presented in Table 9-19. The table shows that the highest cost regulatory
alternatives would entail increased annualized costs of about $1.9
million, after all affected facilities are constructed. This amount is
derived by taking the incremental net annualized costs required to meet
the most costly alternatives and multiplying by the number of new facil-
ities expected. It should be noted that this worst-case estimate of
fifth-year annualized costs is well below the $100 million threshold
specified by the Executive Order. If coating lines are controlled to
Regulatory Alternative III, rather than IV as assumed above, fifth-year
costs are reduced to about $413 thousand.
9.3.2.2 Inflationary Impacts. It is expected that the promulgation
of this NSPS would have no effect upon the rate of inflation in the U.S.
economy. Even at the industry level, price increases prompted by the
fifth-year costs noted above would be imperceptable because the total
annual value of the industry's output is expected to exceed $7 billion
during future years.
9.3.2.3 Employment Impacts. The costs of compliance with this
NSPS are not expected to have a measurable effect upon the level of
employment in the polymeric coating industry. Employment impacts are
unlikely because it is not expected that new plant construction will be
adversely affected, nor will new plants operate at reduced rates which
could warrant lower levels of employment.
9.3.2.4 Balance of Trade Impacts. For most of the products affected
by this NSPS, the level of foreign trade is relatively low (see Section
9.1.5). This fact together with the very small cost/price increases
previously noted, indicates that significant effects upon^the U.S.
balance trade are unlikely. For the urethane-coated products, where
imports could increase even in the absence of this standard, domestic
9-47
-------
UD
I
00
TABLE 9-19. SUMMARY OF FIFTH-YEAR ANNUALIZED COSTS
UNDER MOST COSTLY REGULATORY ALTERNATIVES3
(First Quarter 1984 Dollars X103)
Product type/
line size
Rubber-coated
industrial fabric
A
B
C
Urethane-coated
fabric
B
C
Rubber-coated
cord
A
B
Epoxy-coated
fiberglass
B
C
Net
cost
annual ized
per facility
Coating Coating Storage
operation preparation tank
38.60
65.75
107.23
116.43
225.18
36.04
61.26
109.76
128.62
4.87 3.43
2.71 3.42
-0.13 3.38
-
4.87 3.43
2.71 3.42
2.64 3.41
0.06 3.35
Number
Coating
operation
2
2
2
2
2
2
2
2
2
of new facil
Coating
preparation
2
2
2
_
2
2
2
2
itiesb
Storage
tank
2
2
2
-
2
2
2
2
Total
Total net
annual ized cost
93.80
143.76
220.96
232.86
450.36
88.68
134.78
231.62
263.82
= 1,860.64
aCoating operations controlled to Regulatory Alternative IV, other facilities controlled to
Regulatory Alternative III.
bNumber of new facilities needed to satisfy demand over next five years as described in
Section 9.3.1.
-------
product prices should not be increased by this NSPS. Consequently, the
standard will not prompt an increase in such imports.
9.3.2.5 Impacts Upon Investment. Productivity, and Innovation. It
is expected that the relatively low costs of compliance with this NSPS
will not affect investment, productivity, or innovation in the solvent-
based portion of the polymeric coating industry. Although there has been
a noted trend away from the use of solvents in the industry, this trend
is not expected to be compounded by the costs described above. This is
apparently so because while the use of solvents by the industry declined
about 25 percent from 1976 to 1981 (see Section 9.3.1) the cost of those
solvents increased approximately 300 percent. Consequently, it appears
that the use of solvents may be relatively insensitive to small changes
in solvent prices, or the costs of using such solvents in coating pro-
cesses. This is especially true of the minor cost changes previously
noted. Instead, it may be more likely that if the general trend away
from solvent use continues it may be a result of a combination of factors
including: technical improvements in alternative coating methods,
concern for worker health and safety, and uncertainty regarding the
continuous availability of solvent supplies.
9.3.3 Small Business Impacts and the Regulatory Flexibility Act.
The Regulatory Flexibility Act stipulates that if a proposed rule is
likely to have a significant economic impact on a substantial number of
small entities, the proposing agency must, among other things, prepare an
Initial Regulatory Flexibility Analysis. In response to this requirement,
EPA has developed guidelines defining what is meant by a "significant
economic impact" and a "substantial number."39 A significant impact
is said to exist whenever any of the following criteria are satisfied:
(1) annual compliance costs increase total production costs for small
entities by more than 5 percent; (2) compliance costs as a percent of
sales for small entities are at least 10 percentage points higher than
compliance costs as a percent of sales for large entities; (3) capital
costs of compliance represent a significant portion of capital available
to small entities, considering internal cash flow plus external financing
capabilities; or (4) the requirements of the regulation are likely to
result in closures of small entities. A substantial number is defined as
9-49
-------
being achieved if more than 20 percent of the affected small entities are
subject to significant economic impact.
A given polymeric coating company will only be affected by this NSPS
if it either constructs new facilities, or modifies or reconstructs
existing facilities. As discussed in Section 9.3.1, it is anticipated
that over the period 1986-1990, a total of 18 polymeric coating plants
will become subject to the NSPS. The projected distribution by plant
size and type are noted in Table 9-19.
In this analysis, the question of what constitutes a small business
was resolved using business size criteria developed by the U.S. Small
Business Administration. According to these criteria, a firm in SIC
group 2295 is classified as small if it has fewer than 1,000 employees.
The cutoff for SIC groups 3041 and 3069 is 500 employees.1*0 Given
these employment sizes, it is conceivable that even the large plants
could be owned by small firms. In the extreme case, then, as many as 18
small businesses could be affected by the NSPS.
As the analysis in Section 9.2 indicates, however, the economic
impacts on the plants are likely to be insignificant in nearly all cases.
The only exception is in the case of Regulatory Alternative IV, where the
percentage increase in production cost due to compliance can exceed 5
percent in two cases". In all other situations, cost increases are well
below 5 percent.
9-50
-------
9.4 REFERENCES FOR CHAPTER 9
1. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Coated Fabrics, Not Rubberized. MC82-I-22F-5(P).
May 1984.
2. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Tire Cord and Fabric. MC82-I-22F-6(P). July 1984.
3. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Canvas and Related Products. MC82-I-23E-4(p). April
1984.
4. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Rubber and Plastics Hose and Belting. MC82-I-30A-4(P)
June 1984.
5. U.S. Bureau of the Census. 1982 Census of Manufactures « Prelim-
inary Report: Fabricated Rubber Products, N.E.C. MC82-I-30A-5(P).
February 1984.
6. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Gaskets, Packing and Sealing Devices. MC82-I-32E-3(P),
April 1984.
7. Economic Report of the President. Washington, D.C., U.S. Government
Printing Office. February 1983. p. 163.
8. U.S. Bureau of the Census. 1977 Census of Manufactures -- Concentra-
tion Ratios in Manufacturing. MC77-SR-9. May 1981.
9. Frost and Sullivan, Inc. Flexible Coated and Laminated Materials
and Products Market in the United States. New York. Spring 1982.
p. 18.
10. Reference 9, pp. 16-17.
11. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1978. 1979.
Table 1.
12. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1979. 1980.
Table 1.
13. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1980. 1981.
Table 1.
»
14. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1981. 1982.
Table 1.
9-51
-------
15. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1982. 1983.
Table 1.
16. Reference 9, p. 23.
17. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1978. 1979.
Table 1.
18. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1979. 1980.
Table 1.
19. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1980. 1981.
Table 1.
.».
20. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1981. 1982.
Table 1.
21. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1982. 1983.
Table 1.
22. Predicasts. Forecast Abstracts 1983. pp. 80, 140, 251, 357, 358,
539, 552, 579.
23. Wharton Econometric Forecasting Associates. Industry Planning
Service - Historical Review. May 1982. p. A-76.
24. Reference 7. p. 231.
25. Wharton Econometric Forecasting Associates. Industry Planning
Service - Ten-Year Outlook. Volume 3. Number 5. May 1984. p.
D-24.
26. Letter from Friedman, E.M., MRI, to Costello, T.V., JACA Corp.
October 2, 1984.
27. Letter from Banker, L.C., MRI, to Costello, T.V., JACA Corp.
February 13, 1985.
28. Reference 27.
29. Reference 26.
30. Reference 26.
31. Reference 9, p. 23.
32. Reference 9, p. 22.
9-52
-------
33. U.S. Bureau of Labor Statistics. Monthly Labor Review. December
1983. p. 90.
34. U.S. Bureau of Labor Statistics. Monthly Labor Review. October
1984. p. 80.
35. Reference 5, p. 3.
36. Reference 4, p. 3.
37. Reference 1, p. 3.
38. The President. Executive Order 12291 - Federal Regulation. Federal
Register. February 19, 1981. p. 13193.
39. Memo from Administrator, EPA, to Associate Administrators, Assistant
Administrators, Regional Administrators, and Office Directors.
February 9, 1982. EPA Implementation of the Regulatory Flexibility
Act.
40. U.S. Small Business Administration. Small Business Size Standards.
Federal Register. February 9, 1984. pp. 5023-5048.
9-53
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APPENDIX A—EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
-------
APPENDIX A
EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
The purpose of this study was to develop a basis for new source
performance standards (NSPS) for industries that perform polymeric
coating of supporting substrates. To accomplish the objectives of this
program, technical data were acquired on: (1) solvent storage tanks,
coating preparation equipment, and coating operations; (2) the release
and controllability of organic emissions into the atmosphere by these
sources; and (3) the types and costs of demonstrated emission control
technologies. The bulk of the information was gathered from the following
sources:
• Technical literature
• State, regional, and local air pollution control agencies
• Plant visits
• Industry representatives
• Engineering consultants and equipment vendors
• Emission source testing data
Significant events relating to the evolution of the BID are itemized in
Table A-l.
A-l
-------
APPENDIX A. EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
Date
06/16/83
06/21/83
06/22/83
06/29/83
09/15/83
10/24/83
10/25/83
10/26/83
11/2/83
Company, consultant,
or agency/location
Reeves Brothers, Inc.
Buena Vista, Va.
The Kenyon Piece Dyeworks, Inc.
Kenyon, R.I.
Aldan Rubber Company
Philadelphia, Pa.
Burlington Industrial Fabrics
Kernersville, N.C.
U. S. EPA
Research Triangle Park, N.C.
The Gates Rubber Company
Denver, Colo.
Murray Rubber Company
Houston, Tex.
Utex Industries, Inc.
Weimar, Tex.
Victor Products Division
Nature of action
Plant visit
Plant visit
Plant visit
Plant visit
Memo authorizing
Phase II— "Draft
Development of New
Source Performance
Standards for
Elastomeric Coating
of Fabrics"
Plant visit
Plant visit
Plant visit
Plant visit
11/03/83
01/27/84
Dana Corporation
Chicago, 111.
Dayco Corp.
Three Rivers, Mich.
The Bibb Company
Macon, Ga.
Chemprene, Inc.
Bacon, N.Y.
W. R. Grace and Company
Lexington, Mass.
Plant visit
Section 114
information request
(continued)
A-2
-------
APPENDIX A. (continued)
Date
Company, consultant,
or agency/location
Nature of action
02/03/84
04/03/84
07/10-19/84
08/17/84
09/09/84
09/12-13/84
09/20/84
09/28/84
10/26/84
Hexcel Corp.
Dublin, Calif.
Kellwood Company
New Haven, Mo.
Nylco Corp.
Nashau, N.H.
ODC, Inc.
Norcross, Ga.
Ferro Corp.
Cleveland, Ohio
The Amerbelle Corp.
Rockville, Conn.
ODC, Inc.
Norcross, Ga.
Plant B
U. S. EPA
Research Triangle Park, N.C.
The Bibb Company
Macon, Ga.
Plant C
Mailed to industry members,
selected equipment vendors,
and consultants
Mailed to industry members,
selected equipment vendors,
and consultants
Mailed to industry members,
selected equipment vendors,
and consultants
Section 114
information request
Plant visit
Emission test
Change of scope and
name of project to
"Polymeric Coating of
Supporting Substrates"
Revised Section 114
information request
Emission test
Advance Notice of
Proposed Rule
Request for comment on
draft BID Chapters 3,
4, 5, and 6
Request for comment on
draft BID Chapter 8
A-3
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APPENDIX B—INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
This appendix consists of a reference system which is cross-indexed
with the October 21, 1974, Federal Register (39 FR 37419) containing the
Agency guidelines concerning the preparation of environmental impact
statements. This index can be used to identify sections of the document
which contain data and information germane to any portion of the Federal
Register guidelines.
B-l
-------
TABLE B-l. CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the Background
Information Document
1.
BACKGROUND AND SUMMARY OF
REGULATORY ALTERNATIVES
Summary of regulatory alternatives
Statutory basis for proposing
standards
Relationship to other regulatory
agency actions
Industry affected by the
regulatory alternatives
Specific processes affected by
the regulatory alternatives
2. REGULATORY ALTERNATIVES
Control techniques
The regulatory alternatives from
which standards will be chosen
for proposal are summarized
in Chapter 1, Section 1.1.
The statutory basis for proposing
standards is summarized in
Chapter 2, Section 2.1.
The relationships between EPA
and other regulatory agency
actions are discussed in
Chapters 3, 7, and 8.
A discussion of the industry
affected by the regulatory
alternatives is presented in
Chapter 3, Section 3.1. Further
details covering the business
and economic nature of the
industry are presented in
Chapter 9, Section 9.1.
The specific processes and
facilities affected by the
regulatory alternatives are
summarized in Chapter 1,
Section 1.1. A detailed technical
discussion of the processes
affected by the regulatory
alternatives is presented in
Chapter 3, Sections 3.2 and 3.3.
The alternative control techniques
are discussed in Chapter 4.
(continued)
B-2
-------
TABLE B-l. (continued)
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the Background
Information Document
Regulatory alternatives
3.
ENVIRONMENTAL IMPACT OF THE
REGULATORY ALTERNATIVES
Primary impacts directly
attributable to the regulatory
alternatives
Secondary or induced impacts
4. OTHER CONSIDERATIONS
The various regulatory alterna-
tives are defined in Chapter 6,
Section 6.2. A summary of the
major alternatives considered is
included in Chapter 1, Section 1.1
The primary impacts on mass
emissions and ambient air quality
due to the alternative control
systems are discussed in
Chapter 7, Sections 7.1, 7.2, 7.3,
7.4, and 7.5. A matrix
summarizing the environmental
impacts is included in Chapter 1.
Secondary impacts for the various
regulatory alternatives are
discussed in Chapter 7,
Sections 7.1, 7.2, 7.3, 7.4, and
7.5.
A summary of the potential
adverse environmental impacts
associated with the regulatory
alternatives is included in
Chapter 1, Section 1.2, and
Chapter 7. Potential socio-
economic and inflationary impacts
are discussed in Chapter 9,
Sections 9.2 and 9.3.
B-3
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APPENDIX C--EMISSION SOURCE TEST DATA
-------
APPENDIX C
EMISSION SOURCE TEST DATA
The emission source test data presented here were obtained from
EPA-sponsored testing at a polymeric coating plant and related web coating
facilities and from industry records of solvent recovery efficiencies.
C.I EPA-SPONSORED TEST AT POLYMERIC COATING PLANT
C.I.I. Plant B
Tests were conducted at Plant B to determine (1) the total volatile
organic compound (VOC) reduction efficiency of a single polymeric coating
operation and (2) the control efficiency of a fixed-bed carbon adsorber
system.
Plant B manufactures gaskets, diaphragms, and seals used by the oil
industry. Rubber-coated cord and fabric are produced as the first step
in the manufacturing process. During the test series, a single solvent,
methyl ethyl ketone (MEK), was used for the preparation of rubber coatings
and equipment clean-up. The coating used was a formulation of 82 percent
MEK and 18 percent synthetic rubber, by weight. Figure C-l is a schematic
of solvent/process flow at Plant B.
A continuous web of fabric is fed from a roll into the dip vat located
2 to 3 feet prior to entering the vertical tower drying oven. The coated
fabric enters the drying oven through an opening above the dip vat and
travels between air plenums. Make-up air for the oven is furnished from
louvered openings in the oven air-recirculation loop, web entrance and exit
slots, and any leaks through the door seals in the oven. These doors are
frequently opened to observe and adjust the coated fabric.*
*A telephone survey of the industry showed that the opening of oven doors
during operation is highly unusual.
C-l
-------
The dip vat is surrounded by a total enclosure that has viewing
windows on three of the four sides. The enclosure is maintained under
negative pressure with respect to the coating room by virtue of the
draft created by the drying oven. Air enters the enclosure through the
web entrance slot and presumably through any leaks in the doors.
The drying oven is maintained under negative pressure relative to
the dip vat enclosure; hence, room air drawn into the enclosure is in
turn drawn into the drying oven. Solvent vapors from the fabric coater
drying oven, the cord coater drying oven, the enclosure, and the scrap
solids bake oven are ducted to a carbon adsorption system.
Figure C-2 shows the locations of continuous or discrete-stream VOC
concentration/content and flow rate measurements made during the test
program. Table C-2 lists process parameters monitored during source
testing.
C.I.1.1 Valid Test Data.
C.I.1.1.1 Carbon adsorber efficiency. Process parameters for the
fixed-bed carbon adsorption system are presented in Table C-l. This
system features continuous regeneration using high-temperature nitrogen.
The carbon adsorber produces a recovered solvent/water stream that is
continually delivered to a recovery tank. Based on plant process
instrumentation, the carbon adsorber typically operates at 98-percent
efficiency, which decreases with increasing carbon service life. Expected
useful carbon life is 6 to 9 months.
During the 4-day test period, the carbon adsorber inlet VOC
concentration was monitored by a method similar to EPA Method 25A. The
analysis was performed by a Byron Model 401 THC analyzer. Gas flow rate
to the carbon adsorber was measured according to EPA Method 2. The
exhaust air from the carbon adsorber was monitored for VOC concentration
by a method and procedure similar to that used for the carbon adsorber
inlet. It was not possible to perform a velocity traverse on the carbon
adsorber outlet due to the configuration of the exhaust stack. However,
the outlet flow was estimated by adding the lift airflow rate (based on
design data) to the measured inlet flow.
C-2
-------
Table C-3 presents results of the carbon adsorber tests. The
control efficiencies shown in this table were calculated only for the
periods of operation during which a coating batch was being applied.
The measured carbon adsorber control efficiency averaged about 99 percent.
Control efficiencies as low as 90 percent (outlet solvent concentrations
of nominally 200 parts per million by volume [ppmv]) were measured
during periods of time during which the carbon circulation rate was in-
sufficient to achieve a high level of performance. However, these
periods of relatively poor performance were generally brief (i.e., less
than 30 minutes) due to the frequent monitoring of the system's operating
status by the plant operator.
C.I.1.1.2 Solvent retention in web product. The amount of coated
fabric produced and the extent of solvent retention were measured to
determine the mass of solvent retained in the product. Coated fabric
production rates were monitored based upon plant instrumentation, i.e.,
a web linear velocity/distance meter. The solvent content of the coated
fabric was determined by extraction of product samples with carbon
disulfide, followed by GC analysis of the extract for MEK content. The
total amount of solvent retained on the product was 11.2 kg (24.7 Ib)
during the entire test. If it is assumed that the total amount of
solvent in the feed coating was at least 1,667 kg/ (3,675 Ib), the
amount of solvent retained in the coated product would average 0.67 percent
or less. As discussed later, the actual amount of feed coating applied
during the test are not valid data, but is almost certainly greater than
the 1,667 kg (3,675 Ib) reported.
C.I.1.1.3 Other Test Results. Other activities performed during
the test period included estimation of coating mix preparation emissions
shown in Table C-4. Estimated emission rates from the slurry mix tanks
increased significantly from the first two batches (with mixing for
25 percent of the time) to the last two batches (with mixing 100 percent
of the time).
A comparison of EPA Method 24 and plant measurements (the "cup"
test) of coating viscosity is presented in Table C-5. As shown, no
strong correlation existed between the test and plant data for coating
slurry viscosity.
C-3
-------
C.I.1.2 Invalid Data.
C.I.1.2.1 Capture efficiency during tests. The measured capture
efficiency is invalid because of the following problems in the test
methodology.
1. Two methods were used to estimate the amount of solvent applied
to the web. However, both the methods have some inherent problems such
that accurate and reliable measurement was not possible. The first
technique of using dipstick measurements in the dip tanks does not
permit accounting for the coating which is being applied to the web
simultaneously as the dip tank is being filled. Thus, this procedure
underestimates the amount of solvent applied. The second technique
compares the amount of liquid solvent introduced to the mix equipment at
the beginning of every batch (perhaps 1 to 2 days before the coating is
used-in the process) with unused coatings introduced to the bake oven
after every batch is completed and assumes that the difference is the
solvent applied to the web. This methodology assumes no losses take
place during mixing, transfer, and holding which we know to be unrealistic.
Thus, this method is also suspect.
2. The reported capture efficiency is dependent on a valid correlation
between gaseous and liquid material balance. The EPA's attempt to
perform such a balance under ideal conditions in laboratory experiments
showed results that varied by as much as ±10 percent. One would expect
much greater error than 10 percent under field measurement conditions.
3. The solvent inleakage at the floor level is not accounted for,
and, as a result, it is reasonable to expect that the recovery efficiency
would be biased high.
4. The recovered solvent was stored in a large (7,000 gallon) tank
where the inherent error in measurement was equal to the change in
liquid level that was being measured. Another complicating aspect of
measuring the recovered solvent is that the liquid in the solvent recovery
tank was assumed to be MEK with a small amount of dissolved water. A
potentially major flaw in this assumption is that the liquid in the tank
(as recovered from the adsorber) in reality contains two immiscible
liquid phases: a solvent layer containing 12 percent water'and a water
layer containing 27 percent MEK (assuming the phases are at equilibrium,
C-4
-------
i.e., saturation). The test procedure did not account for any phase
distribution. The magnitude of this error is not known, but it is known
that the water-solvent phase is large enough to justify intermittent
(about once a month) use of distillation column to recover solvent.
For convenience, Table C-6 presents test results for capture,
control, and total control efficiencies. However, the information in
this table should not be used.
C.I.1.2.2 Plant data. Liquid solvent flows of applied and recovered
captured solvent are routinely measured and recorded by plant personnel
and were used to estimate total VOC reduction (recovery) efficiency.
Table C-7 presents tota-1 VOC reduction efficiency for a single fabric
coating line using plant data. Total VOC reduction efficiency data for
the entire test period as determined by the two methods differed
considerably—-83 percent for the test data compared to 60 percent for
the plant data. Larger variations (26 to 176 percent) in batch-to-batch
efficiency values were evident in the plant data than from EPA test data
(49 to 100 percent). Measurement error was inherent in the plant data
efficiency values with the major source of error attributed to the
quantity of recovered solvent and the amount of solvent applied at the
coating applicator because the fugitive emissions from mixing, transfer
and storage of coatings were not accounted for.
C.I.2 Plant C
The EPA conducted tests at Plant C to measure VOC emissions from
two mix tanks. Figure C-3 shows the general process schematic for
Plant C and for the N-line coating room. The figure also identifies the
slurry and gas sampling location for the tests.
At this plant, all coatings are formulated at the plant site. This
is done in batch mix tanks located in an area designated as the mix
tower. In the mix tower, the typical coating mix operation consists of
charging a steam-jacketed mix tank with a solvent, a solid polymer
resin, a pigment, and various additives. The mix tank is then closed,
and the polymer slurry is mixed with a shear mixer for 2 to 3 hours.
Solvent that vaporizes from the mixture is vented from the mix tank to
the atmosphere through an exhaust stack. At the end of the'mix period,
C-5
-------
the slurry is discharged to a holding tank. Solvent is used to wash the
mix tank and this increases the quantity of solvent in the slurry.
In the holding tank, the polymer slurry is pumped to a dip tank
where it is applied to a cotton or polyester web. The level of slurry
in the dip tank remains at a constant level while the level in the hold
tank goes down as the coating is applied. In both the hold and dip
tanks, additional solvent may be added by the operators to maintain
proper coating viscosity. From the N-line dip tank, the polymer-coated
web travels through a heated, nitrogen-atmosphere dryer. From here, the
dried coated fabric is rolled to await processing into a final product.
Emissions from the mix tanks were calculated from stack gas analysis
results and from liquid material balance. The results of the liquid
material balance show a gain of solvent with time instead of the expected
loss of solvent with time due to evaporation, thus invalidating these
results. Because the measured VOC emissions vary drastically for the
two methods, the validity of all of the collected data is questionable.
Therefore, no data were approved for use in setting a standard for
polymeric coating. The collected test data are presented in Table C-8.
However, the information in this table should not be used.
C.2 ERA-SPONSORED TESTS FOR RELATED INDUSTRIES
The emission source test data presented here were obtained from
EPA-sponsored testing at three plants in related web-coating industries.
C.2.1 Pressure-Sensitive Tape and Label Plant
The EPA conducted tests at plants in the pressure-sensitive tape
and label (PSTL) industry. This is an industry with coating and control
processes very similar to those used in the polymeric coating of supporting
substrates. In both types of plants, a solvent-borne coating is applied
to a continuous supporting web. Fixed-bed carbon adsorbers are control
devices used in both types of plants and similarly designed total enclosures
around the coating application/flashoff area are used to capture fugitive
VOC emissions. The following paragraphs describe relevant test data
from the PSTL industry.
One PSTL facility was examined over a 4-week period (January 15,
1979, to February 9, 1979). The facility consists of four adhesive
C-6
-------
coating lines controlled by a single carbon adsorption system. There
are three lines that are each 28-inches wide, and one line that is
56-inches wide. The plant operation is characterized by many short runs
at slow line speeds. Table C-9 summarizes the operations of each line
and the total system. This facility is an example of a hard to control
facility because slow coating lines are the most difficult-to-control
(e.g., they have the greatest potential for fugitive VOC emissions).
The makeup air for the ovens is pulled directly from the work area.
The building that houses the four coaters is tight enough to allow a
slight negative pressure in the work area as compared to the outside of
the building. Also, there is a slight negative pressure in the coater
ovens with respect to the room air. With a fully enclosed, tight system,
the overall result is that all makeup air flows into the building,
through the oven, and out to the carbon adsorption system. Therefore,
essentially 100 percent of all solvent emissions are captured. The
facility also uses hoods over the coater areas to capture fugitive
solvent emissions near the coating applicator. Ductwork directs hood
gases into the drying oven.
During the 4-week test period, the controlled facility used 28.7 m3
(7,589 gallons) of solvents in its adhesive formulations and recovered
26.7 m3 (7,065 gallons) from the carbon adsorption system. This represents
an overall VOC control of 93.1 percent. The system performed 140 separate
runs and used the following solvents: toluene, acetone, hexane, ethyl
acetate, MEK, rubber solvent, heptane, recovered solvents, xylene, ethyl
alcohol, and isopropanol.
C.2.2 Publication Rotogravure Printing
Plants in the publication rotogravure industry are similar to
polymeric coating plants in that solvent-borne coatings are applied to a
continuous web of supporting material. The percent of VOC contained in
typical coatings used at plants in this industry are within the range of
coating formulations used at polymeric coating facilities. Fixed-bed
carbon adsorbers are control devices used in both types of plants.
The EPA conducted tests on the two newest presses (presses 505 and
506) at the Meredith/Burda, Incorporated, plant during the week of
December 11 to 16, 1978. This plant uses toluene as the printing solvent.
C-7
-------
A cabin-like structure encloses the top one-third of each printing
press; thus, a partial enclosure system captures fugitive VOC emissions
from the application/flashoff area. The captured solvent laden air is
directed along with the dryer exhaust to the carbon adsorption system.
Table C-10 summarizes the process operation data. During the
tests, VOC measurements were made at both the inlet and outlet of the
carbon adsorbers. In this industry, bulk inks (coatings) are purchased
from an outside manufacturer and then diluted with additional solvent
prior to application. Mixed (diluted) ink samples were obtained from
each of the eight feed tanks on each press for determination of the
toluene content. The solvent content of the bulk (undiluted) inks was
obtained from the ink manufacturer.
This plant was revisited during January 22 to 24, 1980, for
supplemental measurements. The supplemental -measurements showed that
some air containing 60 to 70 ppmv toluene vapors is drawn into the
newest pressroom from other pressrooms and plant areas. This infiltration
of toluene vapors could have inflated the overall solvent recovery
results by about 3 percent. This estimate is based on the assumption
that the infiltrated toluene vapors were generated from other printing
facilities. In addition, the temperature correction factor was estimated
to be 2 percent.
Table Oil summarizes the overall coating line efficiency and the
carbon adsorber efficiencies. The overall efficiencies were determined
from liquid meter readings and were adjusted by 5 percent to account for
VOC infiltration and temperature correction for solvent volume. The
short term test data (8.5 to 9 h) show carbon adsorber efficiency of 97
to 99 percent and an overall recovery efficiency of 90 to 97 percent.
The 51.5- and 78-hour material balance show an overall recovery efficiency
of 89 and 88 percent, respectively. The carbon adsorber efficiency
during the 78-hour material balance was 99 percent. The long-term
monthly data obtained from the plant indicate overall plant-wide recovery
efficiency of 84 to 91 percent.
C.2.3 Flexible Vinyl Coating and Printing Operations (FVCP)
Plants in the FVCP industry are similar to polymeric coating plants
in that solvent-borne coatings are applied to a continuous web of
C-8
-------
supporting material. The percent of VOC contained in typical coatings
used in this industry are within the range of coating formulations used
in polymeric coating facilities. Fixed-bed carbon adsorbers are control
devices used in both the industries.
The EPA conducted tests at the General Tire and Rubber Company
plant in Reeding, Massachusetts, during March 18-26, 1981. The plant
produces vinyl coated fabric. The print line tested is housed in a
separate room in the plant. The line contains six print stations and an
inline embosser.
The print line VOC emissions are captured by a hooding system that
directs the captured emissions into the individual print head ovens.
The capture emissions from the ovens are controlled by a carbon adsorption
system.
The print room's ventilation system consists of a wall exhaust fan,
a room air supply fan, a carbon adsorption inlet fan, an embosser exhaust
fan, and several open doorways. During the tests, all the doorways were
closed and the room air supply fan was off. The use of the wall exhaust
fan was limited and the print line was always down during operation of
this fan.
The VOC emission capture system is considered a partial enclosure
because some air from the enclosed room is used as the process air for
embosser and is eventually exhausted to the atmosphere.
The test program consisted of two phases: Phase 1, determination
of capture efficiency and Phase 2, determination of carbon adsorption
control device efficiency. The tests required only gaseous VOC measure-
ments. During Phase 1, emissions were measured continuously at three
sites: carbon adsorber inlet, wall fan exhaust, and embosser exhaust.
Periodic VOC measurements at the embosser air intake were also taken.
During Phase 2, VOC measurements were made at both the inlet and outlet
to the carbon adsorber. Ambient VOC concentration measurements around
the embosser inlet were continued to obtain further data on capture
efficiency.
A summary of the capture efficiency results obtained during the
tests is shown in Table C-12. The capture efficiency ranged from 90 to
94 percent and averaged 92 percent. A summary of the carbon adsorption
C-9
-------
control device efficiency data is presented in Table C-13. Carbon
adsorption control device efficiencies ranged from 98.5 to 99.6 percent
and averaged 99 percent. However, the carbon adsorption system was not
operating at design conditions during the tests. The system, which had
been on-stream for only a week prior to the test, operated only 8 hours
a day. At the end of each day, the beds were regenerated twice to
minimize the possibility of bed fires during the next day's startup.
Therefore, these carbon adsorption efficiencies may be somewhat higher
than would be expected under design conditions.
C.3 PLANT-WIDE SOLVENT RECOVERY EFFICIENCIES AT POLYMERIC COATING
PLANTS
The EPA implemented plant-wide solvent recovery recordkeeping
programs at three polymeric coating plants. The plant-wide solvent
recovery efficiency accounts for all the VOC emissions sources in the
plant, which includes coating lines, material handling, clean-up, and
all other VOC generating sources. The programs were designed to provide
daily to weekly determinations of solvent recovery efficiency for a
period of at least 6 months. In all three cases, the implemented record-
keeping programs were modifications of already-existing plant recordkeeping
programs; all measurements and recordkeeping were performed by plant
personnel.
In general, the recordkeeping procedures estimate the total amount
of solvent used in the plant and the total amount of solvent recovered.
The measurement procedures vary among the three plants and are based
upon meter readings, coating formulation data, and storage tank level
measurements. Measurement procedures used by the three plants are
summarized in Table C-14.
A fixed-bed steam-regenerated carbon adsorption system controls the
VOC emissions from rubber-coating operations at Plant A. Solvent recovery
efficiency for the period is shown in Figure C-4. As shown, the weighted
average efficiency for the period is 49.5 percent. The weekly efficiency
values have a mean of 49.2 percent and a standard deviation of 19.8 percent.
Two significant observations are apparent from the data presented in
Figure C-4. First, weekly recovery efficiency values are highly variable,
C-10
-------
with the individual values range from 3 to 79 percent. Second, an
increasing recovery efficiency trend appears to coincide with the instal-
lation of new carbon and a new inlet gas cooling coil in the solvent
recovery system. These modifications to the system are expected to
improve the control device efficiency.
A fluidized-bed, nitrogen-regenerated, carbon adsorber installed in
1983 controls the VOC emissions from the polymeric coating operations at
Plant B. Measured solvent recovery performance is shown in Figure C-5.
As shown, the weighted average solvent recovery efficiency for the
period is 61.4 percent. Weighted average efficiency refers to the total
performance of the system for the entire test period. This value is
calculated based upon the amounts of used solvent and recovered solvent
summed over the entire period. This value is most indicative of long-term
performance.
The mean efficiency for the Plant B data is 63.3 percent with a
standard deviation of 20.5 percent. The mean efficiency is calculated
as the arithmetic average of the weekly efficiency values. The mean
efficiency gives equal weight to each weekly value, regardless of the
magnitude of solvent usage and recovery amounts. The standard deviation
indicates the degree of variability of the weekly values.
The high degree of variability indicated by the time plot and the
standard deviation is due to both measurement and process variability.
Measurement variability results primarily from uncertainties in deter-
minations of solvent quantities in storage tanks. Process variability
is due to the differences in coating conditions for various batch runs
as well as to nonroutine upsets in process operation. The variability
would be expected to decrease over longer monitoring periods.
At Plant C, xylene is transported as a concentrated vapor to a
condensation system. Figure C-6 illustrates plant-wide solvent recovery
efficiency data for the coating line controlled by the condensation
unit. As shown, the weekly efficiency data are less variable than the
data for Plants A and B. For the period, the weighted average efficiency
is 41.0 percent. The mean of the weekly value is 42.5 percent with a
standard deviation of 9.2 percent.
C-ll
-------
The results presented for Plants A and B included modifications to
the data collected and reported by plant personnel. Modifications to
the reported Plant B data were limited to corrections of arithmetic
errors and errors associated with transcription of data. Plant A data
included arithmetic interpretation errors. The interpretation errors
centered on the accounting of distilled solvent. In the Plant A operation,
solvent is distilled (recovered) from unused coating slurry and returned
to the solvent recovery storage tank. In the reported data sheets, the
solvent recovery system is not credited with this input. The results
presented include the credit.
C-12
-------
o
t—•
CO
Figure C-l. Solvent/process flow diagram--Plant B.
-------
SPIGOT DISCHARGES
FOR EXTERNAL USE
(invs. ntHst
I
i—*
4=»
TANK VENT
LEGEND
V- STREAM VOC CONCENTRATION/CONTENT
Q- STREAM FLOW RATE
SOLVENT RETAINED
IN PRODUCT (nip)
Figure C-2. Solvent block flow diagram—Plant B.
-------
Xylenc
AdJit ion
1
Xylene
Addition
MIX
TANK
II 9
V
To el-Line
TOPCOAT
MIX/ HOLD
TANK
I
MIX
TANK
0 8
.To Other Topcoat
Operations
S) Slurry Sample
'Cj Gas Sample
Xylene Additions
Xylene Additions
HOLD
TANK
N-LINE
N-LINE
PAD COAT
Xylene
Addition y_
Xylene
Add i c1 on T
MIX TDUliU
N-i.INE COAT INC KOOM
Figure C-3. Process schematic and sample locations--Plant C.
-------
nWGT AVG = 49>
=49.2%
E
F
C
N
C
Y
a - 19.3%
SLA Cooler
Coll Replaced
Figure C-4. Solvent recovery efficiency data—Plant A.
C-16
-------
E
F
C
H
C
Y
100T
90-
80-
78-•
68- •
50-
40-
30-
20-
10"
8
1
nWGT AVG = 6L4%
nMEAN = 63<3%
a = 20.5%
( , I ,
5
15
WEEK
Figure C-5. Solvent recovery efficiency data—Plant B.
C-17
-------
E
F
C
H
C
Y
199
99
80
70
68-
50
40
30
20
10
0
1
nWGT AVG
nMEAN =
a = 9.2%
1 1 1 1 1-
2
4 5
8
WEEK
Figure C-6. Solvent recovery efficiency data—Plant C.
C-18
-------
TABLE C-l. PROCESS PARAMETERS FOR FLUIDIZED-BED
CARBON ADSORPTION SYSTEM-PLANT B
SLA inlet temperature to water cooler
°C
SLA inlet temperature to carbon adsorber
°C
SLA relative humidity, %
Maximum range
Typical range
SLA inlet concentration, ppm
Design
SLA outlet concentration, ppm
Range
Average
Total carbon charge
kg
db)
No. of trays
Carbon flow rate
kg/h
(Ib/h)
Pressure drop per tray
kPa
(in. w.c.)
Regeneration temperature
°C
N2 flow rate
mVs
(acfm)
57 to 66
(135 to 150)
32 to 35
(90 to 95)
30 to 100
65 to 75
2,600
5 to 60
15 to 20
4,037
(8,900)
8
748 to 1,277
(1,650 to 2,815)
0.13
(0.5)
222 to 223
(431 to 434)
0.0017 to 0.0020
(3.7 to 4.3)
C-19
-------
TABLE C-2. PROCESS PARAMETERS MONITORED DURING PLANT B SOURCE TESTING
Solvent storage
• Recovered and virgin solvent storage tank inventories were monitored
through depth gauging of tank levels. Readings were typically taken
before and after each coating job. The virgin solvent tanks were not
monitored for increase in inventory because there were no deliveries
of make-up shipments.
Solvent transport
• All solvent flows from/to the storage tanks and between mixing
vessels were monitored using plant instrumentation.
• Solvent amounts withdrawn from spigots were monitored.
Coating preparation
• Preparation of coatings were observed.
• Solvent flow to the master mixer and each barrel mixer and the
preparation of specialty coatings in small drum mixers was con-
tinuously monitored.
• An on-hand solvent inventory was taken before start-up, during the
lunch break, between coating jobs, and at the end of the day.
• The amount of coating in the barrel mixers and in the small drum
mixers that were in use was monitored hourly.
Coating transport
• The amount of coating transferred from a mixer to a dip vat was
continuously monitored. (No coating was transferred from a mixer to
the denim or cord coater during the test program).
Coating application and drying
• Operation of the fabric coating line was continuously monitored.
• Operating parameters monitored include:
-- Coating process startups, operating periods, upsets, and shutdown;
and
-- Coating conditions, e.g., fabric type, fabric width (coated and
uncoated), and web speed.
(continued)
C-20
-------
TABLE C-2. (continued)
Residual coating disposal
• The amount of residual coating remaining in the dip vat, barrel
mixer, and plastic feed stock was determined at the end of each
coating job.
• The status and operating conditions of the bake oven and the booster
blower were continuously monitored.
• The amount of scrap solids discharged from the bake oven was
monitored.
Solvent capture
• Openings and closings of the dip vat enclosure and drying tower door
were continuously monitored.
• Velocity measurements were taken of the airflow into the dip vat
enclosure and drying tower.
Ventilation
• The operating status of the by-pass blower and the mix ceiling fans
was monitored.
• All entrances, doorways, and windows to the coating/mixing room were
monitored to note if they were open or closed.
Solvent recovery
• Solvent recovery rates were periodically monitored by depth gauging
of tank levels.
• Operating parameters monitored include:
-- SLA flow rate, temperature, and moisture content;
— Carbon adsorber inlet and outlet VOC concentrations;
-- Carbon adsorber operating status (on or off);
— Relative carbon recirculation rate;
-- Regeneration temperature; and
-- Nitrogen flow rate.
C-21
-------
TABLE C-3. VALID DATA-CARBON ADSORBER CONTROL EFFICIENCY FOR SINGLE
FABRIC COATING LINE—TEST DATA FOR PLANT Ba
Date
07/16/84
Daily Total
07/17/84
Daily Total
07/18/84
Daily Total
07/19/84
Daily Total
Batch
No.
219
219
222C
221d
221
223
223
223
225e
225
224
Solvent
in inlet,
kg
155
48
87
290
43
541
584
165
259
287
711
83
53
261
307
(lb)
(342)
(105)
(639) .
(95)
(1,193)
(1,288)
(364)
(571)
(633)
(1,568)
(183)
(117)
(575)
T875T
Solvent
in exhaust,
kg
0.5
0.3
0.6
L4
0.3
10.6
10.9
1.5
5.3
0.3
n
0.9
0.3
0.4
1.6
(lb)
(1.1)
(0.7)
(1.3)
TTIT
(0.7)
(23.4)
(24.1)
(3.3)
(11.7)
(0.7)
(15.7)
(2.0)
(0.7)
(0.9)
TOT
Control
efficiency,
percent
99.7
99.5
99.4
9976
99.3
98.0
98.1
99.1
98.0
99.8
99~0
99.0
99.5
99.8
9976
TOTAL
1,982 (4,370) 21.1
(46.5)
98.9
The test report also lists data generated during shutdowns before and
after coating jobs and during employee breaks as well as the data
generated during batch operations. The efficiencies were calculated
based on data that were generated during batch operations only. Batch
only data are presented here.
s°1vent
Control efficiency =
"Enclosure doors were opened for approximately 84 minutes (70 percent of
.the time. )
^Upset. Drying oven doors opened for 35 minutes.
2Upset. Drying oven doors opened for 15 minutes.
C-22
-------
o
ro
CO
TABLE C-4. VALID DATA-MIX TANK EMISSIONS ESTIMATED FROM EPA METHOD 24 DATA FOR PLANT B
Batch No.
221
223
224
225
Mix
tank No.
3
4
1
3
Initial solvent
fraction (f,)
0.7824
0.8419
0.7914
0.7922
Final solvent
fraction (f )
0.7809
0.8416
0.7820
0.7800
Time (t)
between
initial
and final
readings, h
18.3
17.7
18.7
20.6
Time
mixing, h
4.2
3.7
18.7
20.6
Time
uncovered, h
14.1
14.0
0.0
0.0
Total
solvent los
(Psv>,
percent
0.858
0.262
5.40
6.97
s Rate of
solvent loss.
percent/h
0.047
0.015
0.288
0.338
Rate of
kg/h-m2
0.20
0.092
0.94
0.91
solvent loss
(Ib/h-ft2)
(0.041)
(0.019)
(0.193)
(0.186)
^As none ot the mix tanks were fitted with a leak-tight cover, the effectiveness of covering may be marginal.
Determined based upon estimated initial volume of the mix tank, estimated surface area of the slurry in the tank, initial density and volatile content, t, and
-------
TABLE C-5. VALID DATA-COATING VISCOSITY ANALYSIS;
COMPARISON OF EPA METHOD 24 AND PLANT B CUP TEST3
Batch No.
219
222
221
223
225
224
Average <
g/m£
0.917
0.869
0. 890
0.846
0.904
0.885
EPA Method 24
slurry density,
(lb/gal)
(7.652)
(7.252)
(7.427)
(7.060)
(7.544)
(7.385)
Average slurry
VOC, percent
70.2
73.9
71.3
71.2
69.5
72.3
Plant B
cup test
time, s
50
25-30
55
50
50
55
uSolvent and solids content of batch formulations varied.
Coating slurry viscosity judged as function of time elapsed for cup to
drain.
C-24
-------
TABLE C-6. INVALID TEST DATA-CAPTURE, CONTROL, AND TOTAL VOC REDUCTION EFFICIENCY
FOR SINGLE FABRIC COATING LINE AT PLANT Ba
o
ro
en
Date
07/16/84
Daily Total
07/17/84
Daily Total
07/18/84
Daily Total
07/19/84
Daily Total
TOTAL
Batch
No.
219
219f
222T
221g
221
223
223
223
225h
225
224
Solvent
applied
(mAp),
kg AP (Ib)
209
64
66
339
65
496
561
178
281
265
724
128
85
295
508
2,132
(461)
(141)
(146)
T7487
(143)
(1.093)
(1,236)
(392)
(620)
(584)
(1,596)
(282)
(187)
(650)
(1,119)
(4,700)
Solvent
in SLA
kg m$LA '(Ib)
• 155
48
87
290
43
541
584
165
259
287
711
83
53
261
397
1,982
(342)
(105)
(192)
(95)
(1.193)
(1,288)
(364)
(571)
(633)
(1,568)
(183)
(117)
(575)
T875T
(4,370)
Solvent in
bake oven
exhaust
(mRn) ,
kg B0 (Ib)
8
3
20
31
9
38
47
11
18
15
44
6
5
14
25
147
(18)
(7)
(44)
T69T
(20)
(84)
(lory
(24)
(40)
(33)
T97T
(13)
(11)
(31)
T557
(325)
Solvent
in- leakage
(mi),
kg ' (Ib)
1.8
0.6
3.0
574
1.0
11.5
12.5
3.7
6.5
7.3
17.4
0.4
0.3
1.0
r?
(37.0)
(4.0)
(1.3)
(6.6)
(12.0)
(2.2)
(25.4)
(27.6)
(8.2)
(14.3)
(16.1)
(38.6)
(0.9)
(0.7)
(2.2)
rsTsT
(82.0)
(continued)
-------
TABLE C-6. (continued)
o
I
ro
en
Captured
solvent K
Date
07/16/84
Daily Total
07/17/84
Daily Total
07/18/84
Daily Total
07/19/84
Daily Total
TOTAL
(
kg
145
44
64
253
32
491
523
150
235
265
650
76
48
246
370
1,796
mfAPT' »
LAN (lb)
(320)
(97)
(141)
(558)
(71)
(1,082)
(1,153)
(331)
(518)
(584)
(1,433)
(168)
(106)
(542)
(816)
(3,960)
Capture
effi-
ciency c
percent
69
68
99
74.9
50
99
93
84
84
100
90
60
56
83
73
84
Solvent in
adsorber
exhaust
kg<"EXH
0.5
0.3
0.6
1.4
0.3
10.6
10.9
1.5
5.3
0.3
7.1
0.9
0.3
0.4
176
21.1
Nib)
(i.D
(0.7)
(0.7)
(23.4)
(24.1)
(3.3)
(11.7)
(0.7)
(15.7)
(2.0)
(0.7)
(0.9)
(3.6)
(46.5)
Control
effi-
ciency .
(nCTRL),
percent
99.7
99.5
99.4
99.6
99.3
98.0
98.1
99.1
98.0
99.8
99.0
99.0
99.5
99.8
99.6
98.9
Total
effi-
ciency
(nT),
percent
69.2
67.8
98.0
74.6
49.3
97.0
91.6
83.5
81.9
99.8
88.9
59
56
83
72
83.4
(continued)
-------
TABLE C-6. (continued)
aThe test report also lists data generated during shutdowns before and after coating jobs and during
employee breaks as well as the data generated during batch operations. Capture, control, and total
efficiencies were calculated based on data that were generated during batch operations only.
Batch-only data are presented here.
"""CART = mSLA ' mBO ' ml '
nCAPT = mCAPT x 100.
mAP
d
nCTRL m$LA " mEXH x 100.
mSLA
e _
°T ~ nCAPT x nCTRL
loo
Enclosure doors were opened for approximately 84 minutes (70 percent of the time.)
?Upset. Drying oven doors opened for 35 minutes.
Upset. Drying oven doors opened for 15 minutes.
-------
o
I
TABLE C-7. INVALID PLANT DATA—TOTAL VOC REDUCTION EFFICIENCY FOR SINGLE
FABRIC COATING LINE AT PLANT B
Date
07/16/84
Daily Total
07/17/84
Daily Total
07/18/84
Daily Total
07/19/84
Daily Total
TOTAL
Batch No.
(a.m. , p.m. )
219 (a.m.)
222 (p.m.)
221 (a.m.)
221 (p.m.)
223 (a.m.)
223 (p.m.)
225 (a.m.)
224 (p.m.)
The superscript ' is used
b
lnAP' = mFD'
raBOF' '
Solvent
with b
kg
265
122
357
55
612 (1
557 TT
475 (1
336
811 H
235
363
597 H
2,462 (5
to indicate
mixed Solvent
atch not used
)." ("BOF^
(lb) kg
(584) 32
(269) 60
(SBt) 53
(121) 0
.350) 35
7471) 35
,047) 0
(741) 33
77157 233
(518) 31
(800) 36
73157 57
,430) 228
plant-available
(lb)
(71)
(132)
(5557
(0)
(77)
mi
(0)
(73)
f7l7
(68)
(1477
(502)
data.
Solvent
applied .
(»Ap,).b
kg
233
62
254
55
577
532
475
303
775
204
327
531
2,234
(lb)
(514)
(137)
7548)
(121)
(1.272)
(1,393)
(1,047)
(668)
(1.7155
(450)
(1,171)
(4.927)
Total solvent
recovered
kg
256
119
375
101
225
356
134
292
425
116
244
350
1,487
(lb)
(564)
(262)
(5277
(223)
(496)
(7157
(295)
(643)
(256)
(538)
(7547
(3,278)
Solvent
recovered from
bake oven
(""Boy).
kg
19
10
3B
13
64
75
12
8
25
15
15
30
156
(lb)
(42)
(22)
(6f)
(29)
(141)
(1757
(26)
(18)
1447
(33)
1667
(344)
Recovered
captured
solventc
kg
237
109
345
88
162
250
122
285
4(55
101
229
330
1,331
(lb)
(522)
(240)
(7527
(194)
(357)
rstit
(269)
(628)
(897)
(223)
(758)
(2,938)
Total
efficiency
percent
102
176
117
159
28
"40
26
94
"35
50
70
62
60
V1
V
'"RC1 x 100%
-------
TABLE C-8. INVALID TEST DATA-SUMMARY OF TEST RESULTS AT PLANT C
Volatile
weight
o
I
ro
UD
Date
9/12/84
9/13/84
9/13/84
Time
2110
1007
1345
Batch
656-1
902
220-3
Location
Mix
Mix
Mix
tank No. 8
tank No. 8
tank No. 9
fraction
0.
0.
0.
740428
498149
456089
Emission
rate from
stack analyses
ft3/min
0.2957
0.0059
0.0031
(Ib/h)
4.63
0.093
0.0420
Total
emissions
Emissions from
from stack material
analyses balance,
ft3
32.8
0.9
0.2
(lb) (lb)
8.6 (159)b
0.2 (97)
0.042 (26)
Calculated from measured stack gas concentrations and average flowrate. Average flowrate was
calculated from stack diameter and average velocity.
Value in parenthesis means net gain.
-------
TABLE C-9. VALID DATA—SUMMARY OF COATING LINE OPERATIONS AT PSTL FACILITY
CO
o
Line width, m
(in.)
No. of runs
Average line speed, m/s
(ft/min)
Average weight percent solvent
Total solvent used3
kg
(lb)
£
(gal)
1
1.42
(56)
25
0.21
(41)
57.5
12,750
(28,110)
15,630
(4,129)
Line
2
0.71
(28)
68
0.24
(46.5)
62.2
4,915
(10,837)
5,761
(1,522)
No.
3
0.71
(28)
23
0.24
(46.5)
66.0
3,747
(8,262)
4,323
(1,142)
4
0.71
(28)
24
0.22
(42.5)
62.4
2,309
(5,091)
3,017
(797)
Total
140
0.23b
(44.8)D
60. 3b
23,723
(52,300)
28,731
(7,589)
^Measured during 4-week test period.
Average of four runs.
-------
TABLE C-10. VALID DATA—PRESS OPERATIONS DURING TESTS AT
MEREDITH/BURDA3
Advertising Product-Press: No. 505
Press width, inches 79
Web width, inches , 50
Shutdown, daily fraction (hour) 0.27 (6.5)
Printing time, % 86
Press speed, ft/min 900-1,100
Magazine Product-Press: No. 506
Press width, inches 79
Web width, inches . 78 3/8
Shutdown, daily fraction (hour)0 0.58 (13.8)
Printing time, % 64
Press speed, ft/min 1,500-1,900
Both Presses: .
Shutdown, daily fraction (hour) 0.42 (10.1)
Printing time, %. 75
Both up, %c (ppma) d 60 (1,670)
One up/one down, %. (ppm ) 33 (770)
Both down, %c (ppma) 7 (300)
Total solvent usage, gal/h 143
Type of solvent used Toluene
uAverage of three test runs.
Equivalent shutdowns per 24 hour period.
^Actual press operating time relative to test time.
Adsorber inlet solvent vapor concentrations.
Includes solvent in inks, varnishes, and extenders.
C-31
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TABLE C-ll. VALID DATA-SUMMARY OF DEMONSTRATED VOC EMISSION CONTROL
EFFICIENCIES AT MEREDITH/BURDA, PERCENT
Meredith/Burda (Phase III)
Data sources Overall Adsorber
Short-term (8.5-9 hours) 90-97 97-99
51.5-hour material balance 89
78-hour material balance 88 99
Long-term monthly plant data 84-91
(10 months)
Efficiencies are 5 percent lower than measured apparent efficiencies:
2 percent for a temperature correction factor and 3 percent for
infiltration of solvent vapors.
C-32
-------
TABLE C-12. VALID DATA—SUMMARY OF CAPTURE EFFICIENCY DATA-
GENERAL TIRE AND RUBBER COMPANY
o
GO
GO
Date
3/18/81
3/19/81
3/20/81
3/23/81
3/25/81
3/26/81
aCapture
bWall fan
M A 4- A «* n
Production
order No.
T- 14582
T-15523
T-15521
T-15516
T-15519
T-15511
T-15508
T-15507
efficiency, % =
not operating
Run
Start
1401
1420
1256
0909
1351
0942
1126
1439
Embosser air
properly.
time
End
1607
1610
1402
1025
1413
1047
1222
1540
CA inlet
intake emissi
Run
length,
minutes
126
110
74
76
32
65
56
61
emissions
on, kg +
VOC
Embosser
air
intake
4.8
3.2
2.9
2.3
0.6
2.5
1.7
1.6
. k9
emissions, kg
Wall fan
Ob
6.9
Ob
OH
Ob
Ob
°h
ob
CA inlet emissions, kg
CA
inlet
66.4
21.6
27.0
22.3
6.0
35.5
21.6
21.5
(100%)
Capture
efficiency,
%a
93
NMC
90
91
91
94
93
93
-------
TABLE C-13. VALID DATA—SUMMARY OF CARBON ADSORPTION EFFICIENCY DATA--
GENERAL TIRE AND RUBBER COMPANY
0
CO
Date
3/25/81
3/26/81
Production
order No.
T-15511
T-15508
T-15507
Run
Start
0942
1126
1439
time
End
1047
1222
1540
Run
length,
minutes
65
56
61
VOC emi
CA inlet
35.5
21.5
21.5
ssions, kg
CA outlet
0.13
0.32
0.22
Carbon
adsorption
efficiency
99.6
98.5
99.0
-------
TABLE C-14. SUMMARY OF SOLVENT RECOVERY MEASUREMENT PROCEDURES'
Plant
Solvent recovered
Solvent used
A
B
Differences in recovered
solvent inventory
Differences in recovered
solvent inventory
Differences in recovered
solvent inventory
Differences in virgin (feed)
solvent inventory
Gravimetric and volumetric
readings of metered solvent
charged to the coating process
Volumetric readings of metered
solvent charged to the coating
process
ln general, solvent recovery efficiency, percent =
solvent used
x 100
C-35
-------
APPENDIX D - EMISSION MEASUREMENT AND MONITORING
-------
APPENDIX D - EMISSION MEASUREMENT AND MONITORING
This appendix describes the measurement method experience that was
gained during the emission testing portion of this study, recommended per-
formance test procedures, and potential continuous monitoring procedures.
The purposes of these descriptions are to define the methodologies used to
collect the data, to recommend potential procedures to demonstrate compliance
with a new source performance standard, and to discuss alternatives for
monitoring either emissions or process parameters to indicate continued
compliance with that standard.
D.I EMISSION MEASUREMENT TEST PROGRAM AND METHODS
Emission source testing in the polymeric coating industry was
conducted by the Emission Standards and Engineering Division (ESED) of the
Environmental Protection Agency (EPA) as part of the background support
study for the new source performance standard for this industry. These
tests included a complete balance test at one facility, a mix area test at
another facility, and long-term overall solvent recovery testing at three
facilities. The long-term data gathering was performed at facilities that
use carbon adsorption and condensation units for VOC control.
D.I.I Coating Analysis Testing
Coating samples were received from three polymeric coating manufacturers
and analyzed using EPA Reference Method 24. All samples were solvent-based
»
coatings; no low-solvent or waterborne coatings were available. Preliminary
analysis indicates that Method 24 is applicable to these coatings, although
specialized techniques and equipment may be needed.
D-l
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The results of the Method 24 testing met the previous requirements
of the ASTM standards on which Method 24 is based. The analysis results
generally compared well with the manufacturers' formulation data.
Therefore, Method 24 should be applicable to the polymeric coating industry.
D.I.2 Emission Source Testing Programs
One polymeric coating plant was tested for volatile organic compound
(VOC) emissions. In general, the purpose of the testing program was to
characterize the VOC emissions to the atmosphere and the control efficiency
of the vapor capture and processing systems, as well as the overall
solvent usage, end distribution, and material balance throughout the
entire coating process. This field testing was much more comprehensive
than the performance test procedures specified in the applicable regulations
for the industry in order to evaluate various testing approaches and
methods and to gather useful auxiliary information to better understand
the process operation.
D.I.3 Stack Emission Testing Conducted
D.I.3.1 Testing Locations. Gas streams that were tested for VOC
concentrations and flow rate included: inlets and outlets of vapor processing
devices; uncontrolled exhaust streams venting directly to the atmosphere;
intermediate process streams such as hood exhausts and bake oven exhausts
venting to other process units. From the concentration and flow rate
results, the VOC mass emissions or mass flow rate in each stream could be
calculated. The gas streams to the carbon adsorption recovery unit and
from the emergency blower exhaust were in vents that were suitable for
conventional EPA stack emission measurement techniques, and these
measurement approaches are described in this section.
If there were emissions that were not collected and vented through
stacks suitable for conventional testing, then ambient VOC survey techniques
had to be adopted. (An example would be open doorways, roof exhausts, and
bake oven exhausts.) Where possible, flow rates were estimated from vendor
data. These nonconventional measurement techniques are described in a
*
later section, D.I.6.
D-2
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0.1.3.2 Flow Measurements. During ESED/EPA's field testing programs,
Reference Methods 1 and 2 were used to determine the volumetric flow rate
of the gas streams being sampled. Moisture contents were measured by inline
psychrometers rather than EPA Method 4. Because all the stacks or ducts
that were tested had diameters of at least 12 inches, Methods 1 and 2
were applicable, and alternative flow rate measurement techniques were
not required. The volumetric flow rates were determined on a wet basis,
corresponding to the VOC concentration method used for that site measured
VOC concentrations under actual conditions (wet basis).
Reference Method 1 was used to select the sampling site along the duct
or stack, and to determine the number of sampling points on the cross-sectional
area inside the duct. Method 2 was used to measure gas velocity. This
method is based on the use of an S-type pitot tube to traverse the duct
cross-section to calculate an average gas velocity. To determine the gas
stream molecular weight and density, as required for Method 2, the fixed
gases composition and moisture content are needed. The fixed gas composition
(02, C02, CO, N2) was determined assuming the dry molecular weight of the
vent gases was assumed to be the same as ambient air in lieu of Method 3.
This was a valid assumption in that the measured streams were essentially
ambient air, i.e., there were no combustion sources involved and the
hydrocarbon concentrations in the stream were relatiavely low. Gas stream
moisture content was measured with a wet bulb/dry bulb technique. The
wet bulb/dry bulb technique may be less precise than Method 4; however,
it was acceptable.because the effect of the moisture value on the final
results was relatively insignificant (no corrections to dry conditions
were needed). The moisture content is used to adjust the molecular weight
in a calculation step in Method 2, and to adjust the flow rates to a dry
basis if needed. Using the duct area, the gas volumetric flow rate was
then calculated.
D.I.3.3 Concentration Measurements. The VOC concentration in each
stack was determined using a semi-continuous (one-minute interval) flame
«
ionization detector. For the polymeric coating industry the EPA recognizes
that this technique will give results equivalent to those of the continuous
0-3
-------
analyzer method specified in EPA Method 25A. It should be noted that, at
the time of the testing, Methods 25 and 25A had not been finalized, so
preliminary versions were followed. However, the later changes to these
methods are not expected to be significant and would not have affected
the test results.
The direct extraction FIA method was used at all measurement sites
which were analyzed for gaseous VOC emissions. The direct FIA had the
advantage that, with semi-continuous measurements, minor process variations
could be noted. Also, once it was set up, it was relatively inexpensive
to operate for a long peri.od, and thus, changes in emissions due to
process variations could be easily noted.
The other methods can be used at any sampling location, including
sites in explosive atmospheres or remote locations. When the time-integrated
sampling methods are used (such as EPA Method 25, bag sampling or syringe
sampling), the sample is collected for a 45- to 60-minute time period.
Because of its complex analysis procedure, the Method 25 samples are analyzed
later in the laboratory. The integrated bag samples, however, are analyzed
as soon as possible (within 24 hours) on-site by either a FIA or GC method.
The FIA's were usually calibrated with propane, although sometimes they
were also calibrated with the solvent being used in the coating process,
(GENERAL FIA). At the polymeric coating facility the FIA was calibrated
with the solvent being used in the process. This was convenient because
the process- used a single solvent.
The results from the different FIA sampling approaches should be equivalent,
provided they are compared for the same time periods. In previous tests of
other coating industries, the Method 25 results differed somewhat from the
results of the FIA. The differences were probably due to the fact that
Method 25 procedure measures all carbon atoms equally, while the FIA detector
has a varying response ratio for different organic compounds. The different
in results would be most pronounced when a multi-compound solvent mixture
is used.
0-4
-------
In situations where more than one solvent is used, a gas chromatographic
(GO technique may be best. The results from the GC sampling approaches
would necessarily be different from the continuous FIA because of the
different sampling time periods. The results from a GC analysis are reported
as concentrations for each individual compound, and thus cannot be compared
directly to the FIA results. The FIA is calibrated with one compound and
the total hydrocarbon concentration is reported as one number on the basis
of that compuond. Also, the FIA detector has a varying response ratio to
different organic compounds, so again the difference in results between the
GC and FIA would be most pronounced when a multi-component solvent mixture
i s used.
D.I.3.4 Tank Measurements
The measurement of solvents and coatings in tanks and or flow rates
through meters was critical to the material balance test at one plant in the
polymeric industry. Also, the long-term, liquid-solvent material balance
testing (discussed in Section D.I.5) requires measurement using tanks and
meters. There is no ASTM or EPA reference method for tank or meter measure-
ments. In all cases in the material balance and long-term tests, tank
volumes were verified by manufacturer's data, and meter readings were
verified by calibration data (where available) supplied by the plant. At
the one material balance test, additional calibration was performed by the
testing contractor.
D.I.4 Mix Room Emission Estimates
The mix room emissions from one .plant were measured using data gathered
by EPA Method 24. This procedure called for grabbing a sample at the start
of the mix operation and later grabbing a sample at the finish of the mix
operation. The solvent content of both samples was measured and compared.
Assuming the solids content remained the same, the VOC loss can be directly
calculated from this data.
D.I.5 Liquid Solvent Material Balance Testing Conducted
The EPA conducted long-term, liquid solvent material balance tets at
three plants in the polymeric coating industries. The EPA worked with the
D-5
-------
facilities and reviewed their procedures for data gathering. The recovery
devices include a fixed-bed, steam-regenerated carbon adsorber, a fluidized-
bed, hot nitrogen-regenerated carbon adsorber, and a condensation unit.
The solvent used by the plant was compared to the solvent recovered (usually
on a weekly or monthly basis), in order to obtain an overall control
efficiency, combining capture and recovery efficiencies. In general, the
solvent used by the plant was based on solvent purchases and any in-house
sources and the solvent recovered was determined by reading the level in
the solvent recovery tank at the recovery device.
D.I.6 Ambient Surveys and Fugitive Emission Characterization
Ambient measurements were conducted during some test series. Open
doorways were monitored periodically to estimate the mass flux of VOC into
and out of the coating area. The flow rate through openings was measured
with a hand-held velometer or a hot-wire anemometer (6 to 9 points were
sampled per doorway). Hydrocarbon concentration was measured with a
portable total hydrocarbon analyzer with a photoionization-type
detector (PID).
Ambient VOC concentration levels- in the coating area were measured
periodically during the testing period. The surveys were conducted
throughout the room at various heights and distances from the center.
Surveys were also made of the VOC concentrations and flow rates into
hood intakes above the coater, in order to estimate and characterize
the fugitive VOC's which were drawn into the hooding exhaust stack.
VOC concentration and flow measurements were made at representative
spots around intake hoods as close to the intake as the physical equip-
ment setup permitted.
0.1.7 Solvent Sample Analysis
Some plants mix their coatings on-site from raw materials. Samples
of the solvent (or mixture of solvents) can be obtained and analyzed for
speciation by direct injection into a gas chromatograph. The results
from these analyses indicate whether the solvent (or solvent mixture)
being used matches the plant's formulation data.
D-6
-------
Samples of recovered solvent from carbon adsorbers were also obtained
and analyzed in order to compare the composition of the recovered solvent
to that of the new solvent. This comparison identified species which
are more likely to be recovered by a particular recovery system.
D.I.8 Wastewater Sample Analysis
If the solvents being used were miscible in water, then the
recovered solvent/condensate from a steam-regenerated carbon adsorber
is separated in a distillation step. Wastewater would then result
from the distillation column. For immiscible solvents, the condensate
can be decanted and result directly in a wastewater. The wastewater
samples were analyzed for compound speciation and total organic carbon
using standard laboratory water analysis procedures.
The results from this determination were used to characterize the
operation of the carbon adsorber or condensation unit and applied to the
solvent material balance calculations.
D.I.9 Product Sample Analysis
Product samples were collected and analyzed for residual solvent
content for the material balance test. The results from this determination
were applied to the solvent material balance calculations. The test
procedure was an adaptation of a NOISH ambient carbon tube measurement
technique. The product samples were put in a container with a known
aliquot of carbon disulfide (C$2). The extract was analyzed for compound
speciation by a gas chromatograph, in the same manner as ambient sample
carbon tubes. This product sampling and analysis was a preliminary test
procedure, as there is no EPA reference method for product sampling. The
results were a range expected for polymeric coatings, but there is no way
to independently verify the results.
D-7
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D.2 PERFORMANCE TEST METHODS
Many different approaches, test methods, and test procedures can be used
to characterize volatile organic compound (VOC) emissions from industrial
surface coating facilities. The particular combination of measurement methods
and procedures to be used depends upon the format of the standard and test
.procedures specified in the applicable regulation.
General testing approaches are:
1. Analysis of coatings.
2. Direct measurement of emissions to the atmosphere from stacks.
3. Determination of vapor processing device efficiency.
4. Determination of vapor capture system efficiency.
5. Determination of overall control efficiency based on liquid solvent
material balance.
6. Survey of fugitive emissions.
D.2.1 Performance Testing of Coatings
D.2.1.1 Analysis of Coatings. Recommended Method. EPA Reference
Method 24 is the recommended method for the analysis of coatings. This
method combines several American Society of Testing and Materials (ASTM)
standard methods to determine the volatile matter content, water content,
density, volume solids, and weight solids of inks and related surface
coatings. These parameter values are combined to calculate the VOC content
of a coating in the units specified in the applicable regulation.
Reference Method 24A is similar in principle to Method 24, but some
of the analytical steps are slightly different and the results would differ.
It was developed specifically for publication rotogravure printing inks and
contains specific analytical steps which were already widely used in that
industry. Thus, Reference Method 24A is not recommended for analysis of
coatings for polymeric coatings.
Volatile Matter Content (Wv). The total volatile content of a
coating is determined by using ASTM D 2369-81, "Standard Test Method for
Volatile Content of Coatings." This procedure is applied to both aqueous
and nonaqueous coatings. The result from this procedure is the volatile
content of a coating as a weight fraction.
D-8
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Water Content(Ww). There are two acceptable procedures for
determining the water content of a coating: (1) ASTM D 3792-80, "Standard
Test Method for Water Content of Water-Reducible Paints by Direct Injection
into a Gas Chromatograph," and (2) ASTM D 4017-81, "Standard Test Method
for Water in Paints and Paint Materials by the Karl Fischer Titration Method."
This procedure is applied only to aqueous coatings. The result is the
water content as a weight fraction.
Organic Content (W0). The volatile organic content of a coating
(as a weight fraction) is not determined directly. Instead, it is determined
indirectly by substraction from the total volatile content and the water
content values.
U = U - U
0 V W
Solids Content (Ws). The solids content of a coating (as a weight
fraction) is also determined indirectly using the previously determined
values:
Ws = 1 - Wv = 1 - W0 - Ww
Volume Solids (Vs). There is no reliable, accurate analytical
procedure that is generally applicable to determine the volume solids of
a coating. Instead, the solids content (as a volume fraction) is calculated
using the manufacturer's formulation data.
Coating Density (Dc). The density of coating is determined
using the procedure in ASTM D 1475-60 (Reapproved 1980), "Standard Test
Method for Density of Paint, Varnish, Lacquer, and Related Products."
Cost. The estimated cost of analysis per coating sample is:
$50 for the total volatile matter content procedure; $100 for the water
content determination; and $25 for the density determination. Because
the testing equipment is standard laboratory apparatus, no additional
purchasing costs are expected.
Adjustments. If non-photochemically reactive solvents are used
in the coatings, then standard gas chromatographic techniques may be used
to identify and quantify these solvents. The results of Reference Method 24
»
may be adjusted to subtract these solvents from the measured VOC content.
D-9
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D.2.1.2 Sampling and Handling of Coatings. For Method 24 analysis of
a coating, a sample should be obtained and placed in a 1-liter container.
The head-space in the container should be as small as possible so that
organics in the coating do not evaporate and escape detection. The
coating sample should be taken at a place that is representative of the
coating being applied. Alternatively, the coating may be sampled in the
mixing or storage area while separate records are kept of dilution solvent
being added at the coating heads. Some polymeric coatings have a component
that causes the coating to "set" within a short time period. Samples of
these coatings need to be taken before the "setting agent" has been added.
The coating sample should be protected from direct sunlight, extreme
heat or cold, and agitation. There is no limitation given in Method 24
for the length of time between sampling and analysis.
D.2.1.3 Weighted Average VOC Content of Coatings. If a plant uses all
low-solvent coatings (as specified in the applicable regulation), then
each coating simply needs to be analyzed following Method 24. However, if
a plant uses a combination of low-and high-solvent coatings, the weighted
average VOC content of all the coatings used over a specified time period
needs to be determined. Depending on the format of the standard, the average
is weighted by the volume or mass of coating solids.
In addition to the Method 24 or manufacturer's formulation information,
the amount (as a weight) of each coating used must be determined. The EPA
has no independent test procedure to determine the amount of coating used,
and instead it is recommended that plant inventory and usage records be
relied upon. Most plants already keep detailed records of amounts of
coatings used. Thus, no additional effort or cost is expected to be required
to attain coating usage. If a plant keeps its inventory records on a volume
f,
basis, then the density of the coating needs to be determined to convert
the inventory to a mass basis.
D.2.2 Stack Emission Testing
D.2.2.1 Testing Locations. Stack emission testing techniques would be
^•^•^__«_«MlX
-------
streams from mixing equipment and/or storage tanks; uncontrolled exhaust
streams venting directly to the atmosphere; intermediate process streams
such as hood exhausts and drying oven exhausts venting to other process
units. The particular streams to be measured depends upon the applicable
regulation.
D.2.2.2 Use of Test Results. The results from the VOC concentration
measurement and flow rate measurement can be combined and used in many
ways. If a regulation is on a concentration basis, then only VOC concen-
tration measurement is needed and the result can be used directly. If the
regulation is on a mass emission basis (i.e., mass emitted per unit of
production; or mass emitted per unit of time), then the concentration and
flow rate results are combined to calculate the mass flow rate. If the
regulation is on an efficiency basis, then mass flow rate is determined for
each of the streams being compared and the efficiency is calculated straight-
forwardly.
The performance test procedure in the applicable regulation will
define the test length and the conditions under which testing is acceptable,
as well as the way the reference test method measurements are combined to
attain the final result.
D.2.2.3 Overall Control Efficiency. Performance test methods and
procedures are used to determine the overall control efficiency of the
add-on pollution control system. The add-on control system is composed of
two parts: a vapor capture system, and a vapor processing device (carbon
adsorber, condenser, or incinerator). The control efficiency of each
component is determined separately and the overall control efficiency is
the product of the capture system and processing device efficiencies.
(Note: This measured overall control efficiency will not reflect control
or emission reduction due to process and operational changes)
D.2.2.4 Processing Device Efficiency. The three types of processing
devices that are expected to be used in the polymeric coating industry
are carbon adsorbers, condensers, and incinerators. The test procedure to
determine efficiency is the same for each control technology.
D-ll
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To determine the efficiency of the emission processing device, the VOC
mass flow rate in the inlet and outlet gas streams must be determined. To
determine the mass of VOC in a gas stream, both the concentration and flow
rate must be measured. The recommended methods and the reason for their
selection are discussed later in sections D.2.2.7 and D.2.2.8.
D.2.2.5 Capture System Efficiency. The efficiency of the vapor
capture system can be defined in one of two ways: (1) as the ratio of the
mass of gaseous VOC emissions directed to the vapor processing device to
the total mass of gaseous VOC, or (2) as the ratio of the mass of gaseous
VOC emissions directed to the vapor processing device to the total mass of
solvent applied in the coating process. The definitions are essentially
equivalent; selection of the measurement approach using one of the two
definitions is based upon considerations discussed below.
In order to determine capture efficiency by the first definition (gas-
phase), all fugitive VOC emissions from the coating area must be captured
and vented through stacks suitable for testing. Furthermore, the coating
line being tested should be isolated from any fugitive VOC emissions originating
from other sources. All doors and other openings through which fugitive
VOC emissions might escape Would be closed.
One way to isolate the coating line from other VOC sources is to
construct a temporary enclosure around the coating line to be tested. This
approach is not recommended because a temporary enclosure would necesarily
alter the ventiliation around the coating line, making the performance test
not representative of normal operating conditions. Instead, if an enclosure
is needed, a permanent enclosure is recommended. The cost of a one-time
permanent enclosure would be comparable to that of constructing and taking
down a temporary enclosure each time a performance test is conducted. How-
«*
ever, if a temporary enclosure is used, the enclosure must be designed to
operate with ventilation proportional to the overall building ventilation.
In addition, the flow and VOC concentration of the ventilation air would
need to be measured using methods described in Sections D.2.2.7 and D.2.2.8
t
or alternative methods with similar precision and accuracy. Hence, the
temporary enclosure must also be designed for making these measurements.
D-12
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Instead of requiring a performance test, a regulation may require a
specific equipment configuration in order to ensure a high capture efficiency.
For example, the applicable regulation may specify a total enclosure around
the coater or sealed lids and a closed venting system for coating mix equip-
ment. To ensure that these equipment specifications are met, visible inspec-
tions or Method 21 leak detection surveys can be conducted. However,
ESED/EPA has r.c i;;pci"!c.:co using Method 21 for detecting such leaks in the
surface coating industries, and thus cannot recommend a leak concentration
level to be used in evaluating the performance of various pieces of capture
equipment.
In order to determine capture efficiency by the second (gas/liquid-
phase) definition, a generally simple approach is required. The gas-phase
VOC content of the capture streams must be measured, as discussed in sections
D.2.2.7 and D.2.2.8. This is generally a straightforward procedure, since
the VOC stream is typically of relatively constant flow rate and confined
within a duct of known configuration. Simultaneously, the liquid-phase
solvent application rate must be determined. This measurement typically
involves measurement of the coating application rate and the VOC content
and density of the coating. The coating application rate can be measured
using plant instrumentation or by use of volumetric or gravimetric
techinques. The coating characteristics are determined by EPA Reference
Method 24, as described in section D.2.1.
D.2.2.6 Stack Emission Testing - Time and Cost. The length of a
performance test is specified in the applicable regulation and is selected
to be representative for the industry and process being tested. The length
of a performance test should be selected to be long enough so to account
for variability in emissions due to up and down operation times, routine
process problems, and different products. Also, the performance test time
period should correspond to the cycles of the emission control device.
Coating line operations are intermittent; there are often long time
periods between runs for cleanup, setup, and color matching, so the total
length of a performance test could vary from plant to plant. In general,
D-13
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a performance test would consist of three to six runs, each lasting from
1/2 to 3 hours. It is estimated that for most operations, the field
testing could probably be completed in 2 to 3 days (i.e., two or three
8-hour work shifts) with an extra day for setup, instrument preparation,
and cleanup.
The cost of the testing varies with the length of the test and the
number of vents to be tested: inlet, outlet, intermediate process, and
fugitive vents. The cost to measure VOC concentration and flow rate is .
estimated at $6,000 to $10,000 per vent, excluding travel expenses.
D.2.2.7 Details on Gas Volumetric Flow Measurement Method. Recommended
methods. Reference Methods 1, 1A, 2, 2A, 2C, 2D, 3 and 4 are recommended
as appropriate for determination of the volumetric flow rate of gas streams.
Large stacks with steady flow. Methods 1 and 2 are used in stacks
with steady flow and with diameters greater than 12 inches. Reference
Method 1 is used to select the sampling site, and Reference Method 2 measures
the volumetric flow rate using a S-type pi tot tube velocity traverse technique.
Methods 3 and 4 provide fixed gases analysis and moisture content, which
are used to determine the gas stream molecular weight and density in Method
2. The results are in units of standard cubic meters per hour.
Small ducts. If the duct is small (less than 12 inches diameter)
then alternative flow measurement techniques will be needed using Method
2A, Method 2D, or Methods 2C and 1A. Method 2A uses an in-line turbine
meter to continuously and directly measure the volumetric flow. Method 2D
uses rotameters, orifice plates, anemometers, or other volume rate or
pressure drop measuring devices to continuously measure the flowrate.
Methods 1A and 2C (in combination) modify Methods 1 and 2 and use a small
standard pi tot tube tranverse technique to measure the flow in small ducts,
and apply when the flow is constant and continuous.
Unsteady flow. If the flow in a large duct (greater than 12 inches
diameter) is not steady or continuous, then Method 2 may be modified to
continuously monitor the changing flow rate in the stack. A continuous
1-point pi tot tube measurement is made at a representative location in the
D-14
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stack. For small ducts with unsteady flow, continuous measurement with
Method 2A or 2D is recommended.
Adjustment for moisture. The results do not need to be adjusted
to dry conditions (using Method 4 for moisture) if the VOC concentrations
are measured in the gas stream under actual conditions; that is, if the
VOC concentrations are reported as parts of VOC per million parts of
actual (wet) volume (ppmv). If the concentrations are measured on a dry
basis (gas chromatographic techniques or Method 25) then the volumetric
flow rate must correspondingly be adjusted to a dry basis.
D.2.2.8 Details on VQC Concentration Measurement Method.
Method 25A. The recommended VOC measurement method is Reference
Method 25A, "Determination of Total Gaseous Organic Concentration Using A
Flame lonization Analyzer"(FIA). This method was selected because it measures
the expected solvent emissions accurately, is practical for long-term,
intermittent testing, and provides a continuous record of VOC concentration.
A continuous record is valuable because of coating line and control device
fluctuations. Measurements that are not'continuous may not give a representa-
tive indication of emissions. The coating lines in this industry may
operate intermittently, and the vent concentrations may vary significantly.
Continuous measurements and records are easier to use for intermittent
processes, and the short-term variations in concentration can be noted.
The continuous records are averaged or integrated as necessary to obtain an
average result for the measurement period.
Method 2.5A applies to the measurement of total gaseous organic concen-
tration of vapors consisting of alkanes, and/or arenes (aromatic hydrocarbons),
and other organic solvent compounds. The instrument is calibrated in terms
of propane or another appropriate organic compound. A sample is extracted
from the source through a heated sample line and glass fiber filter and
routed to a flame ionization analyzer (FIA). (Provisions are included for
eliminating the heated sampling line and glass fiber filter under some
sampling conditions.) Results are reported as concentration equivalents of
»
the calibration gas organic constitutent or organic carbon.
D-15
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Instrument calibration is based on a single reference compound. For the
polymeric coating industry the recommended calibration compound is propane
or butane. (However, if only one compound is used as the sole solvent at a
plant, then that solvent could be used as the calibration compound.) As a
result, the sample concentration measurements are on the basis of that
reference compound and are not necessarily true hydrocarbon concentrations.
The response of an FIA is proportional to carbon content for similiar compounds.
Thus, on a carbon number basis, measured concentrations based on the reference
compound are close to the true hydrocarbon concentrations. Also, any minor
biases in the FIA concentration results are less significant if the results
will be used in an efficiency calculation -- both inlet and outlet measure-
ments are made and compared -- and biases in each measurement will tend to
cancel out. For calculation of emissions on a mass basis, results would be
nearly equivalent using either the concentration and molecular weight based
on a reference gas or the true concentration and true average molecular
weight of the hydrocarbons.
The advantage of using a single component calibration is that costly
and time consuming chromatographic techniques are not required to isolate
and quantify the individual compounds present. Also, propane and butane
calibration gases are readily available in the concentration ranges needed
for this industry.
The analysis technique using an FIA measures total hydrocarbons including
methane and ethane, which are considered non-photochemically reactive, and
thus not VOC's. Due to the coating solvent composition, little methane or
ethane is expected in the gas streams so chromatographic analysis is not
needed nor recommended to adjust the hydrocarbon results to a nonmethane,
nonethane basis.
Other Methods. Three other VOC concentration measuranent methods
were considered (and rejected) for this application: Method 18, Method 25B,
and Method 25.
Method 18. Gas chromatograph (GO analysis on integrated bag samples
following Method 18 was considered because results would be on the basis of
true hydrocarbon concentrations for each compound in the solvent mixture.
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However, the BAG/GC sample technique is not a continuous measurement and
would be cumbersome and impractical because of the length of the testing.
Also, it would be costly and time consuming to calibrate for each compound,
and there is little advantage or extra accuracy gained from the GC approach.
Method 25B. Method 258, "Determination of Total Gaseous Organic
Concentration Using a Nondispersive Infrared Analyzer," is identical to Method
25A except that a different instrument is used. Method 258 applies to the
measurement of total gaseous organic concentration of vapor consisting pri-
marily of alkanes. The sample is extracted as described in Method 25A and
is analyzed with a nondispersive infrared analyzer (NDIR). Method 258 was
not selected because NDIR analyzers do not respond as well as FIA's to all
of the solvents used in this industry. Also, NDIR's are not sensitive in
low concentration ranges (<50 ppmv), and the outlet concentrations from
incinerators and carbon adsorbers are expected to often be below 50 ppmv.
Method 25. Method 25, "Determination of Total Gaseous Nonmethane
Organics Content" was also considered. A 30- to 60-minute integrated
sample is collected in a sample train, and the train is returned to the
laboratory for analysis. The collected organics are converted in several
analytical steps to methane and the number of carbon atoms (less methane in
"the original sample) is measured. Results are reported as organic carbon
equivalent concentration. The Method 25 procedure is not recommended for
this industry because it is awkward to use for long test periods and it
takes integrated samples instead of continuously sampling and recording the
concentration. Concentration variations would be masked with Method 25
time-integrated sample. Also, Method 25 is not sensitive in low concentration
ranges (<50 ppmv). However, Method 25 has the advantage that it counts each
carbon atom in each compound and does not have a varying response ratio for
different compounds.
D.2.3 Liquid Solvent Material Balance
If a plant's vapor processing device recovers solvent (such as carbon
adsorption or condenser systems) then a liquid solvent material balance
*
approach can be used to determine the efficiency of the vapor control
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system. This is done by comparing the solvent used versus the solvent
recovered. These values may be obtained from a plant's inventory records.
The EPA has no test procedure to independently verify the plant's accounting
records. However, it is recommended that the plant set-up and submit to
the enforcement agency its proposed inventory accounting and record keeping
system prior to any performance testing.
For this performance testing approach, the averaging time (performance
test time period) usually needs to be 1 week to 1 month. This longer
averaging period allows for a representative variety of coatings and tape
products, as well as reducing the impact of short-term variations due to
process upsets, solvent spills, and variable amounts of solvent in use in
the process.
The volume of solvent recovered may be determined by measuring the level
of solvent in the recovered solvent storage tank. The storage tank should
have an accurate, easily readable level indicator. To improve the precision
of the volume measurement, it is recommended that the recovered solvent
tank have a relatively small diameter, so that small changes in volume
result in greater changes in tank level. Alternatively, the solvent recovered
may be measured directly by using a liquid volume meter in the solvent
return line. Adjustments to the amount of solvent recovered may be needed
to match the format of the applicable regulation. For example, if the
regulation applies to only certain unit operations in a plant, then the
contributions of other VOC sources must be subtracted from the total
amount of solvent recovered. When measuring the recovered solvent, special
techniques may be required if the solvent is not well mixed and homogeneous.
This may require the measurement of volume of two immiscible liquid phases.
These samples of each phase would need to be taken to determine the.sol vent
content. The concentration of solvent in each phase and the volumes would
then be used to calculate the total solvent recovered.
The volume of solvent used may be determined from plant inventory and
purchasing records or by measuring the level in the solvent storage tank.
«
Alternatively, a liquid volume meter can be used to measure the amount of
D-18
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solvent drawn off from the solvent storage tank. Adjustments to the amount
of solvent used may be needed to match the format of the applicable
regulation. For example, the regulation may apply to only certain unit
operations in a plant, or to only solvent applied at the coater not to
solvent used for cleanup.
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0.3 MONITORING SYSTEMS AND DEVICES
The purpose of monitoring is to ensure that the emission control system
is being properly operated and maintained after the performance test. One
can either directly monitor the regulated pollutant, or instead, monitor an
operational parameter of the emission control system. The aim is to select
a relatively inexpensive and simple method that will indicate that the
facility is in continual compliance with the standard.
The three types of vapor processing devices that are expected to be
used in the polymeric coating industry are carbon adsorbers, condensers,
and incinerators. Possible monitoring approaches and philosophy for each
part of the VOC control system are discussed below.
D.3.1 Monitoring of Vapor Processing Devices
0.3.1.1 Monitoring in Units of Efficiency. There are presently no
demonstrated continuous monitoring systems commercially available which
monitor vapor processor operation in the units of efficiency. This monitoring
would require measuring not only inlet and exhaust VOC concentrations, but
also inlet and exhaust volumetric flow rates. An overall cost for a complete
monitoring system is difficult to estimate due to the number of component
combinations possible. The purchase and installation cost of an entire
monitoring system (including VOC concentration monitors, flow measurement
devices, recording devices, and automatic data reduction) is estimated to be
$25,000. Operating costs are estimated at $25,000 per year. Thus, monitoring
in the units of efficiency is not recommended due to the potentially high cost
and lack of a demonstrated monitoring system.
D.3.1.2 Monitoring in Units of Mass Emitted. Monitoring in units of
mass of VOC emitted would require concentration and flow measurements only
at the exhaust location, as discussed above. This type of monitoring
system has not been commercially demonstrated. The cost is estimated at
$12,500 for purchase and installation plus $12,500 annually for operation,
maintenance, calibration, and data reduction.
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D.3.1.3 Monitoring of Exhaust VOC Concentration. Monitoring equipment
is commercially available, however, to monitor the operational or process
variables associated with vapor control system operation. The variable
which would yield the best indication of system operation is VOC concentration
at the processor outlet. Extremely accurate measurements would not be
required because the purpose of the monitoring is not to determine the
exact outlet emissions but rather to indicate operational and maintenance
practices regarding the vapor processor. Thus, the accuracy of a FIA (Method
25A) type instrument is not needed, and less accurate, less costly instru-
ments which use different detection principles are acceptable. Monitors
for this type of continuous VOC measurements, including a continuous recorder,
typically cost about $6,000 to purchase and install, and $6,000 annually to
calibrate, operate, maintain, and reduce the data. To achieve representative
VOC concentration measurements at the processor outlet, the concentration
monitoring device should be installed in the exhaust vent at least two
equivalent stack diameters from the exit point, and protected from any
interferences due to wind, weather, or other processes.
In addition to monitoring the exhaust only, the inlet to the vapor
control system can be monitored. This data will provide insight to the
performance of the recovery system and indicate whether increases in exhaust
VOC concentrations are due to process variables or improper operation of the
control device. The increase in cost would be primarily associated with
the capital cost of an additional continuous VOC monitor (i.e., less than
$6,000). The annual operation cost should not be much greater than the
costs for a single analyzer.
The EPA does not currently have any experience with continuous monitoring
of VOC exhaust concentration of vapor processing units in the polymeric
industry. Therefore, performance specifications for the sensing instruments
cannot be recommended at this time. Examples of such specifications that
were developed for sulfur dioxide and nitrogen oxides continuous instrument
systems can be found in Appendix B of 40 CFR 60.
D-21
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0.3.1.4 Monitoring of Process Parameters. For some vapor processing
systems, there may be another process parameter besides the exhaust VOC
concentration which is an accurate indicator of system operation. Because
control system design is constantly changing and being upgraded in this
industry, all acceptable process parameters for all systems cannot be
specified. Substituting the monitoring of vapor processing system process
parameters for the monitoring of exhaust VOC concentration is valid and
acceptable if it can be demonstrated that the value of the process parameter
is an indicator of proper operation of the vapor processing system. However,
a disadvantage of parameter monitoring alone is that the correlation of the
parameters with the numerical emission limit is not exact. Monitoring of any
such parameters would have to be approved by enforcement officials on a case-
by-case basis. Parameter monitoring equipment would typically cost about
$2,000 plus $3,000 annually to operate, maintain, periodically calibrate,
and reduce the data into the desired format. Temperature monitoring equipment
is somewhat less expensive. The cost of purchasing and installing an
accurate temperature measurement device and recorder is estimated at $1,500.
Operating costs, including maintenance, calibration, and data reduction,
would be about $1,500 annually.
D.3.1.5 Monitoring of Carbon Adsorbers. For carbon adsorption vapor
processing devices, the preferred monitoring approach is the use of a
continuous VOC exhaust concentration monitor. However, as discussed above,
no such general monitor has been demonstrated for the many different organic
compounds encountered in this industry. Alternatively, the carbon bed
temperature (after regeneration and completion of any cooling cycles), and
the amount of steam used to regenerate the bed have been identified as
indicators of product recovery efficiency. Temperature monitors and steam
flow meters which indicate the quantity of steam used over a period of time
are available.
0.3.1.6- Monitoring of Condensors. For condensor devices, the temperature
of the exhaust stream has been identified as an indicator of product recovery
s
efficiency, and condensor temperature monitors are available.
D-22
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D.3.1.7 Monitoring of Incinerators. For incineration devices, the
exhaust concentration is quite low and is difficult to measure accurately
with the inexpensive VOC monitors. Instead, the firebox temperature has
been identified and demonstrated to be a process parameter which reflects
level of emissions from the device. Thus, temperature monitoring is the
recommended monitoring approach for incineration control devices. Since a
temperature monitor is usually included as a standard feature for incinerators,
it is expected that this monitoring requirement will not incur additional
costs to the pi ant.
D.3.1.8 Use of Monitoring Data. The use of monitoring data is the
same regardless of whether the VOC outlet concentration or an operational
parameter is selected to be monitored. The monitoring system should be
installed and operating properly before the first performance test. Continual
surveillance is achieved by comparing the monitored value of the concentration
or parameter to the value which occurred during the last successful performance
test, or alternatively, to a preselected value which is indicative of good
operation. It is important to note that a high monitoring value does not
positively confirm that the facility is out of compliance; instead, it
indicates that the emission control system or the coating process is operating
in a different manner than during the last successful performance test.
The averaging time for monitoring purposes should be related to the
time period for the performance test.
D.3.2 Monitoring of Vapor Capture Systems
0.3.2.1 Monitoring in Units of Efficiency. Monitoring the vapor
capture system in the units of efficiency would be a difficult and costly
procedure. This monitoring approach would require measuring the VOC con-
centration and volumetric flow rate in the inlet to the vapor processing
device and in each fugitive VOC vent and then combining the results to
calculate an efficiency for each time period. Such a monitoring system has
not been commercially demonstrated. The purchase and installation of an
entire monitoring system is estimated at $12,500 per stack, with an additional
t
$12,500 per stack per year for operation, maintenance, calibration, and data
reduction. Thus, monitoring in the units of efficiency is not recommended.
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D.3.2.2 Monitoring of Flow Rates. As an alternative, to monitoring
efficiency, an operational parameter could be monitored instead. The key
to a good capture system is maintaining proper flow rates in each vent.
Monitoring equipment is commercially available which could monitor these
flow rate parameters. Flow rate monitoring equipment for each vent would
typically cost about $3,000 plus $3,000 annually to operate, maintain,
periodically calibrate, and reduce the data into the desired format. The
monitored flow rate values are then compared to the monitored value during
the last successful performance test.
Proper flow rates and air distribution in a vapor capture system could
also be ensured by an inspection and maintenance program, which generally
would not create any additional cost burden for a plant. In that case, the
additional value of information provided by flow rate monitors would probably
be minimal. Routine visual inspections of the fan's operation would indicate
whether or not capture efficiencies remain at the performance test level,
and no formal monitoring of the air distribution system would be required.
If a total enclosure is specified in the applicable regulation to
ensure proper capture, then the proper operation of the total enclosure
can be monitored. Examples of monitoring devices include VOC concen-
tration detectors inside the enclosure, pressure sensors inside the
enclosure, flow rate meters in ducts, and fan amperage meters.
D.3.3 Monitoring of Overall Control System Efficiency on a Liquid Basis
If a plant uses a vapor recovery control device, the efficiency of the
overall plant control (combined vapor capture and vapor recovery systems) can
be monitored using a liquid material balance. (These amounts may need to be
adjusted to match the format of the applicable regulation.) The amount of
solvent used is compared to the amount of solvent recovered. These values
are obtained from a plant's inventory records. For this monitoring approach,
the averaging time or monitoring period usually needs to be 1 week to 1 month
This longer averaging period is necessary to coordinate with a plant's
inventory accounting system and to eliminate short-term variations due to
«
process upsets, solvent spills, and variable amounts of solvent in use in
the process.
0-24
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Because most plants already keep good solvent usage and inventory records,
no additional cost to the plant would be incurred for this monitoring approach.
D.3.4 Monitoring of Coatings
If a plant elects to use low-solvent content coatings in lieu of control
devices, then the VOC content of the coatings should be monitored. There is
no simplified way to do this. Instead, the recommended monitoring procedure
is the same as the performance test: the plant must keep records of the VOC
content and amount of each coating used and calculate the weighted average
VOC content over the time period specified in the regulation. As an alterna-
tive, the plant could set up a sampling program so that random samples of
coatings would be analyzed using Reference Method 24.
0-25
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0.4 TEST METHOD LIST AND REFERENCES
The EPA testing methods that are mentioned in this Appendix are listed
below with their complete title and reference.
D.4.1 Reference Methods in Appendix A - 40 CFR 60
Method 1 - Sample and Velocity Traverses for Stationary Sources.
Method 2 - Determination of Stack Gas Velocity and Volumetric
Flow Rate (Type S Pitot Tube).
Method 2A - Direct Measurement of Gas Volume Through Pipes and
Small Ducts.
Method 3 - Gas Analysis for Carbon Dioxide, Excess Air, and Dry
Molecular Weight.
Method 4 - Determination of Moisture in Stack Gases.
Method 18 - Measurement of Gaseous Organic Compound Emissions by
Gas Chromatography.
Method 21 - Determination of Volatile Organic Compound Leaks.
Method 24 - Determination of Volatile Matter Content, Water Content,
Density, Volume Solids, and Weight Solids of Surface Coatings.
Method 24A- Determination of Volatile Matter Content and Density of
Printing Inks and Related Coatings.
Method 25 - Determination of Total Gaseous Nonmethane Organic Emissions
as Carbon.
Method 25A- Determination of Total Gaseous Organic Concentration Using
a Flame lonization Analyzer.
Method 25B- Determination of Total Gaseous Organic Concentration Using
a Nondispersive Infrared Analyzer.
0.4.2 Proposed Methods for Appendix A - 40 CFR 60
Method 1A - Sample and Velocity Traverses for Stationary Sources With
Small Stacks or Ducts (Proposed on 10/21/83, 48 FR 48955).
Method 2C - Determination of Stack Gas Velocity and Volumetric Flow
Rate From Small Stacks and Ducts (Standard Pitot Tube)
(Proposed on 10/21/83, 48 FR 48956).
Method 2D - Measurement of Gas Volume Flow Rates in Small Pipes and
Ducts (Proposed on 10/21/83, 48 FR 48957).'
D-26
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D.4.3 Other Methods
"General Measurement of Total Gaseous Organic Compound Emissions
Using a Flame lonization Analyzer," in "Measurement of Volatile
Organic Compounds Supplement 1," OAQPS Guideline Series, EPA Report
No. 450/3-82-019, July 1982.
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