National Air Pollution
Control Techniques
Advisory Committee
Minutes of Meeting
December 12 and 13, 1979
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Emission Standards and Engineering Division
Research Triangle Park, North Carolina 277.11
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National Air Pollution
Control Techniques
Advisory Committee
Minutes of Meeting
December 12 and 13, 1979
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Emission Standards and Engineering Division
Research Triangle Park, North Carolina 27711
January 11, 1980
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U. S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
Chairman and Executive Secretary
Mr. Don R. Goodwin
Director, Emission Standard and Engineering Division
Office of Air Quality Planning and Standards (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Members
Mr. Carl G. Beard II
Director, West Virginia
Air Pollution Control Commission
1558 Washington Street, East
Charleston, West Virginia 25311
Dr. Eugene M. Bentley III
President, ECO-Labs, Inc.
1836 Euclid Avenue-Room 608
Cleveland, Ohio 44115
*Mr. Robert J. Castelli
Director of Environmental Quality
Ideal Basic Industries
Cement Division
Post Office Box 8789
Denver, Colorado 80201
Mrs. Janet Chalupnik
Director of Environmental Health Programs
Washington Lung Association
216 Broadway East
Seattle, Washington 98102
Mr. A. 0. Courtney
Director of Air Quality
Commonwealth Edison
72 West Adams Street
Chicago, Illinois 60690
Dr. Robert W. Dunlap
Vice President, Director
Environmental Engineering Group
Environmental Research and Technology, Inc.
696 Virginia Road
Concord, Massachusetts 01742
Mrs. Joan Hays
2161 Sharon Road
Winter Park, Florida 32789
(Member of Board of Directors of National Clean
Air Coalition— Washington, D. C. , and Group
Against Smog and Pollution—Pittsburgh, Pa.)
Mr. Neil A. Kaye
Manager, Environmental Regulations
Environmental Services Division
American Cyanamid Company
Berdan Avenue
Wayne, New Jersey 07470
•Mr. Eric E. Lemke
Chief Deputy Executive Officer
South Coast Air Quality Management District
9150 East Flair Drive
El Monte, California 91731
*0r. James M. Lents
Director, Air Pollution Control Division
Colorado Department of Health
4210 East llth Avenue
Denver, Colorado 80220
Mr. Sidney R. Orem
Technical Director
Industrial Gas Cleaning Institute, Inc.
700 North Fairfax Street-Suite 304
Alexandria, Virginia 22314
Mr. Venkataraman Ramadass
Chief, Engineering Services Division
Department of Environmental Services
Bureau of Air and Water Quality
District of Columbia
5010 Overlook Avenue, S. W.—2nd floor
Washington, D. C. 20032
*Mr. William M. Reiter
Director, Pollution Control
Corporate Environmental Affairs
Allied Chemical
Post Office Box 1057R
Morristown, New Jersey 07960
Dr. William R. Samples
Technical Coordinator, Environmental Control
Wheeling-Pittsburgh Steel Corporation
DuVall Center
Wheeling, West Virginia 26003
Mr. Claibourne D. Smith
Manager, Environmental Activities
E. I. DuPont de Nemours and Company
1007 Market Street
Wilmington, Delaware 19898
Mr. Morton Sterling
Director, Air Pollution Control Division
Wayne County Department of Health
1311 East Jefferson Street
Detroit, Michigan 48207
Indicates New Member
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CONTENTS
I. OPENING REMARKS Don Goodwin 1-1
II. NEW SOURCE PERFORMANCE STANDARDS FOR PARTICULATE EMISSIONS FROM
ASPHALT ROOFING MANUFACTURING PLANTS 11-1
A. EPA Presentation Eric Noble II-l
Emission Standards and Engineering Division - EPA
B. Asphalt Roofing Industry Presentations 11-17
1. Johns-Manville Sales Corporation J. N. Siegfried 11-17
2. CVM Corporation John L. Wilki 11-29
3. Anderson 2000, Inc Jack D. Brady 11-34
4. Monsanto Enviro-Chem Systems, Inc Eugene Kennedy 11-41
5. Asphalt Roofing Manufacturers Assoc. . . . Richard Snyder 11-44
6. Asphalt Roofing Manufacturers Assoc. ... J. W. Ricketts 11-48
7. Owens-Corning Fiberglas Corporation Samuel Thomas 11-55
C. Discussion 11-64
D. Correspondence 11-68
1. Letter from CVM Corporation to Midwest Research Institute . 11-68
2. Letter from Chevron U.S.A., Inc. to EPA 11-77
3. Letter from United Air Specialists, Inc. to EPA 11-81
III. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR
BENZENE EMISSIONS FROM ETHYLBENZENE/STYRENE PRODUCTION III-l
A. EPA Presentations Buddy Newman, Marilyn Tressel III-l
EEA, Incorporated
B. Ethylbenzene/Styrene Production Industry Presentations .... 111-20
1. Monsanto Company Harry M. Walker II1-20
2. Oxirane Corporation Sylvester Fretwell 111-33
3. Dow Chemical U.S.A Paul Sienknecht 111-43
4. Cosden Oil and Chemical Co Theodore M. Nairn, Jr. 111-54
C. Discussion 111-56
D. Correspondence 111-59
1. Letter from Chemical Manufacturers Association to EPA . . . 111-59
IV. NEW SOURCE PERFORMANCE STANDARDS FOR VOLATILE ORGANIC COMPOUND
EMISSIONS FROM PRESSURE-SENSITIVE TAPE AND LABEL SURFACE
COATING OPERATIONS IV-1
A. EPA Presentations IV-1
1. Industry Description and Regulatory
Alternatives Thomas Nelson IV-1
Radian Corporation
2. Control Efficiency data James Berryv IV-15
Emission Standards and Engineering Division - EPA
B. Pressure-Sensitive Tape and Label Industry Presentations . . . IV-19
1. Vara International Thomas Vara IV-19
2. Regenerator Company William J. Darm IV-19
3. Anchor Continental, Incorporated Alonzo R. Moore IV-20
111
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4. NCASI Russell Blosser IV-23
5. 3M Company David Benforado IV-24
6. American Institute of Metalizers, Coaters,
and Laminators Richard Vieth IV-25
C. Discussion IV-27
D. Correspondence IV-31
1. Letter from Union Carbide Corporation to EPA IV-31
2. Letter from Allied Chemical to EPA IV-33
V. NEW SOURCE PERFORMANCE STANDARDS FOR VOLATILE ORGANIC CHEMICAL
EMISSIONS FROM PUBLICATION ROTOGRAVURE PRINTING INDUSTRY V-l
A. EPA Presentation Richard Burt V-l
Radian Corporation
B. Printing Industry Presentations V-l3
1. Gravure Research Institute, Inc Harvey George V-13
2. REECO Rodney Pennington V-l 9
C. Discussion V-25
D. Correspondence V-30
1. Letter from Dayton Press, Inc. to EPA V-30
APPENDIX Record of Attendance A-l
IV
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I. OPENING REMARKS
Don R. Goodwin, Chairman
National Air Pollution Control Techniques
Advisory Committee
A meeting of the National Air Pollution Control Techniques Advisory
Committee was held on December 12 and 13, 1979, at the Sheraton Crabtree
Inn in Raleigh, North Carolina. Chairman Don Goodwin called the meeting
to order at 8:45 a.m. NAPCTAC members in attendance for both days of the
meeting were:
Mr. Carl Beard II Dr. James M. Lents
Mr. Robert J. Castelli Mr. Sidney R. Orem
Mrs. Janet Chalupnik Mr. William M. Reiter
Mr. A. 0. Courtney Dr. William R. Samples
Mr. Neil A. Kaye Mr. Claiborne D. Smith
Mr. Eric Lemke Mr. Morton Sterling
Dr. Robert W. Dunlap was unable to attend the first day of the meeting,
but did attend on the second day. Dr. Eugene M. Bentley III, Mrs. Joan Hayes,
and Mr. Venkatamaran Ramadass were absent on both days of the meeting.
EPA staff members present during all or part of the meeting were:
Lawrence Anderson Thomas Link
James Bain David Mascone
Douglas Bell Ed McCarley
James Berry William MacDowell
Richard Colyer Nancy McLaughlin
Dennis Grumpier Eric Noble
Stanley Cuffe John O'Connor
Fred Dimmick David Patrick
Kenneth Durkee John Robson
Naomi Durkee Robert Rosensteel
Neil Efird David Salman
Jack Farmer Rene Smith
Greg Gasperecz Shirley Tabler
Don Goodwin Jeffrey Telander
Susan Grove Denise Thai
Richard Jenkins William Tlppitt
William Johnson Edwin Vincent
Robert Kolbinsky George Walsh
Susan Wyatt
1-1
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A copy of the registration sheets for the meeting, which include the
names and addresses of attendees representing the private sector, is included
in Appendix A.
Media involvement for the meeting was limited to the Federal Register
notice of November 14, 1979, announcing the proposed time and place of the
meeting.
Mr. Goodwin explained that the order of the meeting would be the EPA
presentation for each project first, followed by presentation by representa-
tives of the industries potentially affected by the proposed regulations
being developed, and discussion after each presentation. He encouraged an
open forum with audience participation.
Next, Mr. Goodwin introduced the EPA employees at the head table, Messrs.
David Patrick, Stanley Cuffe, and Kenneth Durkee, and then he introduced the
speaker to deliver the EPA presentation on asphalt roofing manufacturing,
Mr. Eric Noble, of EPA.
1-2
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II. NEW SOURCE PERFORMANCE STANDARDS FOR PARTICULATE EMISSIONS
FROM ASPHALT ROOFING MANUFACTURING PLANTS
A. EPA PRESENTATION
Mr. Eric Noble
Emission Standards and Engineering Division, OAQPS
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
The 1977 amendments to the Clean Air Act added a provision that EPA
develop a list of catagories of major stationary sources which contribute
significantly to air pollution. The asphalt roofing manufacturing industry
is among those sources recommended for new source performance standards MSPS.
The asphalt roofing manufacturing industry began in the late 1800s
and has grown until it now supplies over 80 percent of the roofing needs in
this country. Slide 1 gives growth information on the asphalt roofing
manufacturing industry. There are about 110 plants, ranging in production
rate from 30,000 to 400,000 tons per year. The ARM industry is forty-
fifth on EPA's priority list of 59 industries. It has grown at a
2 percent rate over the last 10 years and this growth rate is expected
to continue through 1985. This translates into the building of three
new roofing plants by 1985.
The asphalt roofing manufacturing industry produces shingles, roll
roofing, saturated felt, and specialty roofing products. Shingles
account for 75 percent of its total production, and roll roofing and
saturated felt each account for about 10 percent. Specialty roofing
products make up the remaining 5 percent. (Slide 2)
The asphalt roofing manufacturing industry encompasses two distinct
operations: the processing of asphalt for use in the manufacture of
roofing products and the actual roofing manufacturing processes. The
asphalt can be processed at refineries and asphalt processing plants, as
well as at asphalt roofing plants. The manufacture of asphalt roofing,
however, takes place only at roofing plants. During the industry survey,
visits were made to 21 roofing plants, 3 asphalt processing plants, and
5 refineries. (Slide 3)
Asphalt is processed to produce the saturant and coating asphalts
used in the manufacture of roofing products. Asphalt is processed by
blowing air through hot asphalt flux in devices known as blowing stills.
This causes an exothermic reaction that raises the softening point of
the asphalt and modifies other characteristics. Emission sources are
the still and the asphalt storage tanks. (Slide 4)
II-l
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ASPHALT ROOFING
SLIDE ]
MANUFACTURING INDUSTRY
NUMBER OF PLANTS
GROWTH IN CAPACITY OVER
LAST 10 YEARS
PROJECTED GROWTH IN
CAPACITY THRU 1985 ...
NEW PLANT PROJECTION
110
2 PERCENT PER YEAR
2 PERCENT PER YEAR
3 PLANTS BY 1985
PRIORITY LISTING
45 OUT OF 59
PRODUCT
CATEGORY
SLIDE 2
PERCENT OF
PRODUCTION
SHINGLE
ROLL ROOFING
SATURATED FELT
SPECIALTY PRODUCTS
75
10
10
II-2
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SLIDE 3
PLANTS INSPECTED
ASPHALT ROOFING
21
ASPHALT PROCESSING
REFINERIES
SLIDE 4
ASPHALT PROCESSING
ASPHALT
FLUX
ASPHALT
BLOWING
STILL
SATURANT
COATING
II-3
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Slide 5 is a diagram of an asphalt roofing line. Felt is saturated
with saturant asphalt, coated with a filled coating asphalt, and surfaced
on the top side with colored granules and on the bottom side with talc.
It is then cooled, cut, and oackaged. Fmission sources of interest are
the saturator and coater; the asohalt storage tanks; and the delivery,
transfer, and storage of talc and filler.
Slide 6 lists the emission sources being considered for standards
and the types of control equipment investigated for each. Other kinds
of control equipment may now be available.
The principal pollutant is a condensed HC particulate. An exception
is minerals handling activities, which emit an inorganic particulate.
Because of the nature of the particulate, it was necessary to develop a
new test method to measure it. This method is recommended EPA Reference
Method 26. Note that three different types of equipment can be used to
control particulate emissions from the saturator and coater. Also, when
the roofing line is operating, the asphalt storage tank fumes will be
directed to the saturator/coater control device. When the line is not
operating, fumes will be vented to a mist eliminator.
Slide 7 shows the facilities and control devices tested by EPA. The
EPA test program includes tests at six olants (A through F). For the
saturator, the selection included four plants (A through 0) and three
different tvoes of control enuinment (electrostatic orecipitator, afterburner,
and high velocity air filter). For the blowing still, in spite of an
extensive survey, only one site was located that was both well-controlled
and amenable to testing. Opacity testing was conducted on the mist
eliminator controlling asphalt storage tanks.
The araph in Slide 8 oresents the FPA oarticulate test data for a
saturator controlled by two afterburners operating in parallel. The
afterburners were identical but were operated at different temperatures.
The small circles reoresent the results of the individual tests, and
the horizontal lines indicate the average emissions for each test series.
The lowest vertical bar is for the afterburner operated at 1200°F; the
middle bar for the unit operating at 1000°F; and the top bar is the
combined emissions from both afterburners. The lower horizontal line on
the right is EPA's estimate of what the combined emissions would have
been if both afterburners had been operated at 1200°F. It assumes that
raising the combustion temoerature of the second afterburner from 1000°F
to 1200°F would have increased its efficiency (and reduced its emissions)
to the level of the first afterburner. This is a reasonable assumption
because the afterburners are identical.
There is well-documented evidence that afterburner efficiency is
strongly influenced by combustion temperature and that a temperature
differential of as little as 100°F can account for the difference in
efficiency observed here. This estimated average combined emissions
rate has been incorporated into Slide 9, which summarizes EPA particulate
test data on saturators and coaters. Other control devices tested were
the electrostatic precioitator (ESP) and the hiah velocity air filter
(HVAF). The tests were run during the manufacture of nominal 235-lb
shingle using recommended FPA Reference Test Method 26. Average emissions
were all below 0.08 Ib particulate per ton of product.
II-4
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SLIDE 5
SATURANT
ASPHALT
FELT
SHINGLES U*
ROLLS
COATING
ASPHALT
MINERAL
STORAGE
TRANSFER
CUTTING
AND
PACKAGING
MINERALS
SURFACING
AREA
COOLER
AFFECTED FACILITIES
SLIDE 6
CONTROL SYSTEM
• BLOWING STILLS
• AFTERBURNER (A/B)
• SATURATOR, COATER, AND
STORAGE TANKS (PLANT UP)
• ELECTROSTATIC
PRECIPITATOR (ESP)
• HIGH VELOCITY AIR FILTER (HVAF)
• AFTERBURNER
• MINERALS HANDLING AND
STORAGE
• FABRIC FILTER
• STORAGE TANKS (PLANT DOWN) • MIST ELIMINATOR
II-5
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SLIDE 7
EMISSION TESTS
PLANT FACILITY
CONTROL DEVICE
A SATURATOR
B SATURATOR, STORAGE TANK
C SATURATOR, STORAGE TANK
D SATURATOR
E BLOWING STILL
F STORAGE TANKS
ELECTROSTAT1C PRECIPITATOR
AFTERBURNER
HIGH VELOCITY AIR FILTER
HIGH VELOCITY AIR FILTER
AFTERBURNER
MIST ELIMINATOR
.12.,.
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SLIDE 8
HH
PLANT B
A/B (2)
SATURATOR
II-6
-------
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SLIDE 9
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SLIDE 10
— 5.0
—
— 4.0
—
— 3.0
— 2.0 f
— 1.0
•~: '
-
-1
I
SATURANT COATING
BLOW BLOW
S?,M^oL ESP<2) A'B<2) HVAF HVAF
SATURATORS
CONTROL DEVICE
A/B
A/B
ASPHALT BLOWING STILL
-------
The graph in Slide 10 presents EPA oarticulate test data on a
blowing still afterburner durina the blowing of saturant and coating
asphalts. Participate emissions are higher for the coating blow because
coating has a higher softening point and blowing times are longer. The
average particulate emissions were less than 4.0 Ib per 1,000 gallons of
asphalt flux for both the saturant and coating blows.
Summarized in Slide 11 are visible emissions data on the control
devices for saturator, still, and storage tanks. Measurements were made
using EPA Reference Test Method 9, and observation times ranged from
12 to 29 hours. Six-minute averages of visible emissions for the four
saturator control devices ranged from 0 to 18 percent, but all were
under 20 oercent opacity. Emissions from the still afterburner were
consistently 0 percent opacity, while the mist eliminator on the storage
tanks exceeded 0 percent opacity for only one 6-minute average.
Similarly, Slide 12 summarizes visible emissions data for the
minerals handling and storage facilities. The data were transferred
from EPA tests on sources in the nonmetallic minerals industry. These
tests were also run using FPA Method 9 and the same minerals were being
processed as are used here. Readings were consistently at 0 percent
opacity.
Fugitive emissions data were gathered on saturator and coater hoods
and enclosures at four plants, using recommended EPA Reference Method 22.
Method 22 differs from Method 9 in that the observer records the time
duration that fumes are visible rather than opacity. Only the enclosures
at Plants A and B captured fumes effectively (see Slide 13), and only
Plant B has a modern, well-sealed enclosure that encompasses both the
saturator and coater and is representative of current capture technology.
There were no fugitive emissions from the enclosure when the doors were
closed.
Slide 14 presents, superimposed on the saturator test data, the
typical State Implementation Plan (SIP) level of 0.76 Ib of particulate
per ton and the recommended oarticulate emissions limit of 0.08 Ib of
particulate per ton. All EPA test averages fall below this limit. This
emission limit would aoply during the manufacture of shingle and granular-
surfaced roll roofing. Compliance would be determined during the manufacture
of nominal 235-lb shingle.
On Slide 15 the typical SIP level of 14.3 Ib per 1,000 gallons of
asphalt and the recommended oarticulate emission limit of 4.6 Ib per
1,000 gallons are superimposed on the blowing still test data. The test
averages fall below this recommended level. Compliance to this standard
would be determined during a coating blow and would apply for all asphalt
blowinn.
Recommended visible emissions limits are shown in Slide 16. Also
included for reference are the measured opacities. In each case the
recommendation is equal to, or less than stringent than, the measured
values. All limitations are on stack opacities except those for the
saturator enclosure, which are on fugitive emissions.
II-8
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VISIBLE EMISSIONS SLIDE n
EPA REFERENCE METHOD 9
TIME
CONTROL OPACITY OBSERVED
PLANT FACILITY DEVICE RANGE (MRS.)
A
B
C
D
E
F
SATURATOR
SATURATOR
SATURATOR
SATURATOR
STILL
STORAGE
TANKS
ESP
A/B
HVAF
HVAF
A/B
MIST ELIM.
0-18
0
0-5
10-15
0
0-0.4
22.3
13.4
12.0
13.1
29.0
24.0
VISIBLE EMISSIONS
EPA REFERENCE METHOD 9
SLIDE 12
PLANT FACILITY
CONTROL OPACITY
DEVICE PERCENT
G CONVEYOR BAGHOUSE
TRANSFER POINT
H
SCREENS
BAGHOUSE
SCREENS
BAGHOUSE
K SCREENS BAGHOUSE
II-9
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SLIDE 13
FUGITIVE EMISSIONS
EPA REFERENCE METHOD 22
PLANT SOURCE
CAPTURE PERCENT TIME
SYSTEM EMISSION VISIBLE
SATURATOR
ENCLOSURE
B SATURATOR
AND COATER
ENCLOSURE
_SIP SLIDE 14
..10
C/5
03
O)
a
uj t:
f- 03
O
I-
cc
...06
...04
.02
I-OH
PLANT A B
CONTROL DEVICES ESP (2) A/B (2)
C D
HVAF HVAF
RECOMMENDED EMISSIONS LIMIT
SATURATORS
n-io
-------
1-14.3
v>-s
— 5.0
SIP
SLIDE 15
W P
Z
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55
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5
M
2
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01
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GC
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w
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M
Q
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_4.o _-- ---
— 3.0
— 2.0
SATURANT COATING
BLOW BLOW
RECOMMENDED EMISSION LIMIT
BLOWING STILLS
SLIDE 16
RECOMMENDED VISIBLE
EMISSIONS LIMITS
MEASURED RECOMMENDED
OPACITY LIMITS
(PERCENT) (PERCENT)
0
0-18
0-0.4
BLOWING STILL
SATURATOR COATER
ASPHALT STORAGE TANKS
MINERAL HANDLING & STORAGE Q
SATURATOR & COATER HOOD NO VISIBLE
ii-n
o
20
10
NO VISIBLE
-------
We have now presented the test data and recommended for each source
emissions limitations that we believe are warranted by the data. We
will now present the regulatory alternatives, which provide a number of
options regarding the processes to be covered by standards. Slide 17
shows that five regulatory alternatives were chosen for consideration;
with the Xs indicating the processes selected for new source performance
standards for each alternative.
Alternative 1 is the baseline, or State Implementation Plan, case.
Alternative 2 is an intermediate case and reflects the setting of standards
for only the saturator and the asphalt storage tanks. Alternatives 3 and 4
are other intermediate cases and Alternative 5 is the maximum control
option. It represents the aoplication of standards to all the emission
sources being considered for standards. To recap, only one level of
particulate control (or recommended emission limit) is recommended for
each emission source. The regulatory alternatives reflect choices
regarding which sources to control, not the control level.
Slide 18 presents the reduction in particulate emissions in 1985
for the regulatory alternatives. Alternative 1 is the State Implementation
Plan level to which the other alternatives are compared. The incremental
reduction for Alternative 2 is 250 tons per year, and the reduction for
Alternative 5 is 590 tons per year.
Slide 19 presents other impacts that Alternative 5 would have
in 1985. Regulatory Alternative 5 has the highest adverse impact of the
alternatives, but would increase oil consumption in 1985 by only 16 barrels
oer day, from a baseline level of 523 barrels to a level of 539 barrels.
It is based on the use of an ESP or HVAF as the saturator control device.
The increase will be greater if an afterburner is used. Because of the
nature of the particulate, the temperature of the gas stream entering
the ESP or HVAF must be reduced to maximize collection. Water sprays
can be used for this purpose. Most of this water is either evaporated
or recycled, but there can be some increase in the amount of water
effluent to be treated by the plant. This increase is expected to be
negligible. The only solid waste produced is the used filter material
from the HVAF. Only a negligible amount of additional filter will be
used for any alternative.
The cost impacts shown in Slide 20 are the incremental 1985 capital
and annualized cost impacts of each regulatory alternative over the
baseline, which is Alternative 1, when an ESP or HVAF is used as the
saturator control device. It also shows the wholesale price increase
attributable to each alternative. As you can see, the maximum impact is
an increase in the wholesale price of shingles of less than one-quarter
of 1 percent. This correlates to a price increase of less than $3 for a
typical three-bedroom, ranch-style house. (Slide 21)
EPA's recommendations are summarized in Slide 22. We recommend the
selection of Regulatory Alternative 5, which includes emissions limitations
on the saturator, still, storaae tanks, and minerals handling and storage
facilities. For all emission sources except minerals handling and
storage, we also recommend that limitations be placed on control device
11-12
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REGULATORY ALTERNATIVES
SLIDE 17
REGULATORY
ALTERNATIVES
1
2
3
4
5
SATURATOR
COATER
X
X
X
X
ASPHALT
STORAGE
^IP L
Oil 1—
X
X
X
X
BLOWING
STILLS
EVEL
X
X
MINERAL
HANDLING
AND
STORAGE
X
X
AIR IMPACTS
SLIDE 18
REGULATORY
ALTERNATIVE
1
2
3
4
5
EMISSIONS REDUCTION
IN 1985 (TONS/YEAR)
250
580
260
590
11-13
-------
SLIDE 19
OTHER IMPACTS
ALTERNATIVE 5 IN 1985
ENERGY INCREASE- 523 TO 539 BBL/DAY OIL, (3%)
• WATER INCREASE— NEGLIGIBLE
• SOLID WASTE INCREASE— NEGLIGIBLE
SLIDE 20
COST IMPACTS
REGULATORY
ALTERNATIVE
1
2
3
4
5
1985 COST IMPACT
x $1,000
CAPITAL
215
215
305
305
ANNUAL
81
160
109
188
PERCENT
PRICE INCREASE
0.08
0.15
0.11
0.18
11-14
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SLIDE 21
COST INCREASE, AVERAGE
THREE-BEDROOM HOUSE
$3.00
SLIDE 22
RECOMMENDATIONS
• REGULATORY ALTERNATIVE 5
• EMISSION LIMITS
• MONITORING
• ESP & HVAF INLET TEMPERATURE
• A/B OPERATING TEMPERATURE
11-15
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inlet or operating temperatures and continuously monitored and recorded.
Allowable temperatures would be determined during performance tests.
The continuous monitoring of ESP and HVAF inlet temperatures is
necessary because these units are particulate control devices and the
amount of pollutant which is a particulate is strongly dependent on its
temperature. Temperature monitoring is also less expensive and more
reliable than continuous stack monitoring. The continuous monitoring of
afterburner combustion temperature is also warranted because afterburner
efficiency is a function of temperature.
Slide 23 summarizes the recommendations for emission limits. The
recommended limits for the saturator would be 0.08 Ib of particulate per
ton of shingle or granule-surfaced roll roofing produced and a 20 percent
opacity. The recommended limit for the storage tanks would be 5 percent
opacity, when it is not being vented through the saturator control
device. For the still the recommended limits are 4 Ib of particulate
per 1,000 gallons of asphalt flux charged to the process and a 0 percent
opacity. For minerals handling and storage: a 10 percent opacity. For
the saturator enclosure: a "no visible" fugitive emissions standard.
As a result of industry comments, a separate standard is being
considered for lines that do not have the capability for producing
shinqle or granular-surfaced roll roofing. This standard is 0.4 Ib of
particulate per ton of saturated felt or smooth-surfaced roll roofing
produced. The puroose of this standard is to compensate for the lower
final weights of these products as compared to the granule-surfaced
products. Granule-surfaced products, because of the amount of surfacing
applied, have a lower asphalt to product weight than saturated felt.
Compliance would be determined during the manufacture of 30-lb saturated
felt.
EMISSION LIMITS SLIDE 23
VISIBLE
PERCENT
PARTICULATE OPACITY
• SATURATOR & COATER 0.08 LB/TON OF 20
SHINGLE & SURFACED
ROLL ROOFING
0. 4 LB/TON OF
SATURATED FELT &
SMOOTH ROLL ROOFING
• ASPHALT STORAGE TANKS ~" 5
• BLOWING STILL 4.0 LB/1000 GAL 0
OF CHARGE
• MINERAL HANDLING & STORAGE — 10
• SATURATOR & COATER HOODS — NO VISIBLE
11-16
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B. ASPHALT ROOFING INDUSTRY PRESENTATIONS
1. Johns-Manville Sales Corporation
Mr. J. N. Siegfried
Johns-Manville Sales Corporation
Ken-Caryl Ranch
Denver, Colorado, 80217
My name is Jim Siegfried. I am employed by the Johns-Manville
Sales Corporation in Denver and came to North Carolina today
specifically to talk about some of the elementary arithmetic
associated with the proposed standard that would be made applicable
to new asphalt roofing plant operations.
In that connection, I call your attention to Figure 9-2 which
appears on page 9-11 of the background information document
(a copy of which is included with these remarks for quick re-
ference) . The proposed standard would limit particulate emis-
sions from combined saturating and coating equipment sources
to 0.03 pounds per ton of production (0.04 kilograms per megagram).
Because a modified sampling procedure was developed and thence
utilized by EPA during the course of field studies, it is estimated
that substantially all of the relevant data currently available
for consideration has been incorporated into this single chart.
The bulk of stack testing information accumulated up to this time
by industry and state control authorities is no longer valid by
virtue of the chance in test method. The evidence to support
or refute any numerical limit thus hardly would be rated as over-
whelming; especially when taking into account the variables of
process operations and raw material supplies normally encountered
within the roofing industry.
11-17
-------
As a consequence, I sense that both government officials and
industry representatives find themselves caught in the same
uncomfortable predicament; neither can truely judge the quality
or practicality of the present proposal with any feeling of total
confidence. There is also a distinct danger that the practicality
question could remain in doubt until after a standard is adopted
and applicants subsequently strive to demonstrate compliance. By
that time, of course, the Emissions Standards and Engineering
Division of EPA will no longer be principally involved in the out-
come. Instead, the matter would be basically treated as an en-
forcement issue.
Let's then examine in some detail the minimal relevant data that
are presently available. Note the controlled emissions from Plant
"D"; where individual test results show good correlation. It is
projected that total emissions would be somewhat higher than
plotted if coater fumes also had been channeled through the high
velocity filtration control device. That would place actual
emission rates at, or perhaps somewhat in excess of, the proposed
Federal limit of 0.08 Ibs per ton.
You will see that we are right back to the chronic problem that
has characterized the New Source Standards program from the outset.
We have one more example of a "skin-tight" standard which places
highly controlled production facilities into a marginal or question-
able category,and thereby simply fosters the totally unproductive
and very costly game of "compliance roulette" at field level,
11-18
-------
after efficiently controlled new facilities are placed into initial
service. From the standpoint of real air quality improvement, this
kind of regulatory strategy contributes nothing and makes no sense
at all. The*" Agency motives for persisting in this approach remain
A
unclear .
Let me now discuss an even more serious compliance complication
which would be imposed by the draft standard. In the case of
Plant "D", for example, if one multiplies the indicated 0.072 Ib
per ton emission factor by the 47.7 hourly production tonnage, you
will see that particulate emissions equate to about 3.4 Ibs per
hour from the saturator after HVAF control. The 0.08 Ib per ton
limitation was barely met because the production tonnage rate was so
high. The reported tonnage reflects the weight of felt materials,
organic saturant, coating asphalt, and mineral granules introduced
into the process to produce shingles.
However, roofing machines and manufacturing lines do not exclusively
fabricate shingles. Some machines never produce shingles. For
instance, whenever, base underlayment products are manufactured,
only the felt and saturant become involved in the process; the
heavier coating and granule components are missing. Under these
circumstances, production tonnages in the range of 3 to 6 tons per
hour would be representative; while saturant emissions would be
expected to remain essentially unchanged.
Again referring to the charted Plant "D" data, if production rates
during manufacture of saturated roll goods are only one-tenth of
the 47.7 Ibs per hour shown, the simplest calculations will disclose
that the resultant emission factor will then be ten times higher
11-19
-------
than the plotted 0.072 average value, and the source would exceed
proposed EPA emission limits by almost a whole order of magnitude.
On a company-wide basis, we roughly estimate that something approaching
one-third of the total roofing plant machine hours presently are
devoted to the manufacture of these lighter weight saturated pro-
ducts which would have no chance of qualifying for compliance under
the kind of standard being recommended by ESED.
In view of the apparent gross oversight in the draft regulations
which-1 have tried to set forth, it seems essential from an industry
standpoint that ESED begin anew in its efforts to develop a sound
and practical type of standard for new roofing plant facilities.
Since an entirely different approach to the standard-writing may
be required in order to remedy the situation which has been described,
we therefore advocate that any future new proposal by EPA initially
be brought before this same advisory body for technical review
and discussion to insure that no critical aspect has been over-
looked. We hope the Committee would request that such opportunity
be afforded.
Returning to Figure 9-2, mere casual scanning is sufficient to
observe that the tests conducted at Plant "A" and at Plant "C"
produced results that varied over a range of several hundred
percent. This wide degree of fluctuation hardly represents a
solid endorsement for the quality of data employed as the basis for
rule-making decisions.
11-20
-------
Perhaps the most curious information graphically presented relates
to Plant "B". This plant had two incineration devices installed in
parallel arrangement to treat the fumes from saturating and coating
process equipment. Based upon separate assessment of each unit,
average emission factors of 0.025 and 0.065 Ibs per ton are re-
ported; both comfortably within the proposed limit of 0.08 Ibs
per ton.
That much having been established, and assuming an approximate
even split in air flow to the two afterburners, I suspect that
most people would have predicted an overall emission factor for
the total system somewhere about midway between; in the vicinity
of the dashed line and symbol on the chart. Not so, according to
EPA. Agency calculations show total system emissions to be 0.093
Ibs per ton; more than 16 percent above the intended allowable
limit. If one takes the time to scrutinize the background test
data, I believe you will find that the first two calculations for
the separate units actually were erroneously derived and presented.
I don't know whether the kinds of things thus far commented upon
raise any eyebrows among the members of the Technical Advisory
Committee or not. Considering the sparse amount of data available
upon which to base a rational standard, however, I can tell you
that these oversights and analytical discrepancies do trouble
those of us that will need to operate in accord with the resultant
rules.
11-21
-------
Now, let me direct attention to a very basic issue that relates to
this proposed standard and to all other Federal New Source Performance
Standards as well. The matter is highlighted in the projections which
appear in Table 9-1 on page 9-8 of the background document (copy
included for quick reference). Note the inference that Federal
regulation of the asphalt roofing industry wJ11 reduce annual
particulate emissions by 674 tons within a period of five years.
I certainly am aware that the actual reduction will be some small
increment of that amount. Likewise, EPA and this Committee are
equally astute in their ability to distinguish between theoretical
and actual reductions. Unfortunately, the general public is not.
The projection presumes that without Federal intervention, all new
roofing plant facilities will just barely meet State limitations.
This presumption of course is absurd - and EPA knows that.
Control hardware at the four plant locations tested by EPA originally
was installed specifically to meet State requirements. In each
case and in each jurisdiction, the Federal emission reduction credit
thus would be zero. The Agency alternatively could have selected
a large number of other similarly controlled facilities for baseline
testing. In most instances, the potential Federal credits also
would have been zero. Within our own company alone, we operate
more than a score of highly controlled roofing production units
throughout the country that would generate essentially no Federal
pollutant reduction credits under a new standard.
In fact, one has to search the industry rather thoroughly to determine
just where Federal credits legitimately could be claimed. Despite
substantial propaganda to the contrary, a great many State and local
11-22
-------
agencies effectively are getting the pollution control job done;
without much of the fanfare, complexity, and confusion which so
often accompanies Federal programs.
Now, none of these remarks should be construed to represent opposition
to Federal rules wherever they are warranted. My argument is with
the misleading accounting system which is being employed. I guess
my "hang-up" in regard to the Agency's "rinky-dink arithmetic"
stems from an old fashioned and perhaps outmoded notion that the
public is entitled to know, as precisely as possible, what these
new standards realistically can do and cannot do in respect to
improving air quality; and that consumers and taxpayers deserve
to know in advance what they can expect to get for the amount
they are going to pay. EPA presently is not providing adequate
and accurate information in this connection.
Permit and consider this constructive recommendation which could
more accurately inform the public and simultaneously provide a
more genuine basic for making decisions than does the heavily
biased data traditionally computed by EPA in support of its new
source regulatory programs. If the inflated projections are
somehow important to the Agency, simply modify all such tabu-
lations to include two rows or columns of data. Let the first be
titled "Maximum Reductions From SIP" and, in the case of this
specific standard for example, enter the 674 tons per year presently
claimed. Label the second "Most Probable Anticipated Decrease"
and determine the credits applicable to the Federal rule by first
subtracting out all of the reductions below SIP levels that will
11-23
-------
logically or automatically accrue under state codes in any event;
then record the remainder. Considering the extensive background
j
studies conducted in connection with each new proposal, it appears
that the second estimate will be no more difficult to derive than
was the first.
It is further emphasized that the recommended comparative tabulation
could best serve the public interest if compiled retroactively; going
back to the very first New Source Standard dealing with utility steam
generating units, proceeding down through all previously adopted or
proposed regulations, and hereafter routinely presented with each
new draft regulation that is brought before the Advisory Committee
for review. In further explanation of this concept, a skeletal
tabular outline is incorporated into the written text (see below).
MAXIMUM
REDUCTIONS
FROM SIP
MOST PROBABLE
ANTICIPATED
DECREASE
I. ADOPTED
STANDARDS
1. Utility steam generators
2.
3.
etc.
II. FR PROPOSED
STANDARDS
28.
29 .
30.
etc.
III. DRAFT RULES IN
DEVELOPMENT
glass furnaces
non-metallic milling
asphalt roofing
etc.
674 tons/yr
TOTAL REDUCTIONS
H-24
-------
This hardly represents the first request to EPA for more reliable
guidance data. It is recognized that the Agency may not be particularly
anxious to publicize projections that could undercut the rationale
for some rules,but it seems strange that the Administrator has not
previously requested precisely this same kind of information which
could serve as a basic management tool. As a consequence, I do
not foresee that these comments alone can change anything, and the
whole concern is likely to be dismissed by the Agency almost as
soon as I step down from the podium. Neither is there much con-
fidence that the subject would be treated any differently; even
if every speaker for the remainder of today and throughout all
of tommorrow were to echo the same identical theme.
I sincerely do believe however, that this Technical Committee/-
with its prestige and in view of its designated advisory role;
represents the only instrument existing anywhere in the country
that might successfully influence EPA to adopt realistic emission
reduction accounting procedures. I also firmly believe that the
Committee could perform no more important public service than to
pursue the matter and persuade the Agency to restructure these
procedures. The outcome is up to you. Without the Committee's
leadership and direction, it seems obvious that it will be "business
as usual" here at Triangle Park; using the same old warped arithmetic.
KPA recently lias common cod development work on regulations that
pertain to many of the lower priority segments of industry; some
of which are bound to underscore the complications associated with
artificial projections much more sharply than has been the case with
11-25
-------
past standards. That is one more key reason why the subject merits
thorough analysis and resolution now.
My comments this morning really have dealt with two closely related
topics; the first pertaining to some of the major weaknesses and
oversights associated with the proposed asphalt roofing standard
and the second pertinent to the glaring deficiencies inherent in
the method used to calculate potential emission reductions that
disproportionately affect all new source standards. I appreciate
this opportunity to bring these important matters before your
Committee and hope they will evoke fuller discussion and closer
scrutiny among your membership. Thank You.
II-26
-------
c
o
(J
o
S-
Q.
CD
C
Ol
c_
l/>
c;
.
CD
ro
cu
E
Q.
1/1
en
o
0.05 (0.10)
^ 0.04
0.03
0.02
(0.08)
(0.06)
l-H
(0.04)
0.01 -- (0.02)
h
Maximum
Average
Minimum
0.093
SHO.065
- - - -O- -
0.045
0.025
0.072
0.054
^ 0
Plant
Emission source
Control devices
Avq. shingle .prod.
Mg/h
(Tons/h)
Avg. ren.oval
A B CD
S+C S+C S+C+T S
ESP Afterburners (2) HVAF HVAF
27.85
(30.70)
92.2
37.0
(40.8)
77
and
93
19.1
(21.0)
98.3
43.3
(47.7)
78
Figure 9-2. Particulate emissions from asphalt roofing
processes when various control devices are used (EPA tests)
11-27
-------
TABLE 9-1. IMPACTS OF REGULATORY ALTERNATIVES FOR
THE PROJECTED FIFTH YEAR GROWTH
00
Recjulatory alternative
Emissions increase
Mg/yr
(Tons/yr)
J\ Emission reduction below
basel ine
Mg/yr
(Tons/yr)
Costs of mission controls
Capita] $1000 1
Annual ized $1000
Impact on product cost
Costs increase $/sq.
Percent increase
Energy increase ,.
Electricity joules x 10
kWh x 105
Oil m3
Barrels
1
684
(754)
0
0
,201 - 1,968
193 - 335
0
0
0
0
2
457
(504)
227
(251)
1,791 - 2,004
199 - 413
0.01 - 0.06
0.07 - 0.40
7.56
2.10
0 - 1,929
0 - 12,100
3
84
(93)
600
(602)
1,791 - 2,004
212 - 426
0.01 - 0.06
0.07 - 0.40
7.56
2.10
573
3,770 - 15,870
4
445
(491)
239
(263)
1,881 - 2,274
208 - 422
0.01 - 0.06
0.07 - 0.40
12.66
3.54
0 - 1,929
0 - 12,100
5
73
(80)
1,881 - 2,274
221 - 435
0.02 - 0.06 '
0.01 - 0.40
12.66
3.54
573
3,770 - 15,870
The projected growth by the fifth year is equal to 3 medium-size model plants.
The impact of one model plant will be one-third of the above values.
-------
2. CVM Corporation
Mr. John L. Hilki
CVM Corporation
402 Vandever Avenue
Wilmington, Delaware 19802
CVM CORPORATION
402 VANDEVER AVENUE
WILMINGTON, DELAWARE 19802
(302) 654-7070
PRESENTATION BY CVM CORPORATION TO NATIONAL AIR POLLUTION CONTROL
TECHNIQUES ADVISORY COMMITTEE MEETING
DECEMBER 12, 1979
CVM Corporation manufactures fume eliminators that use fiberglass wool
packed in tubes to remove asphalt fume particulate in the exhaust gas from
asphalt saturators. We know of at least five installations that are in
operation handling asphalt saturator exhaust, and several more that are
presently being manufactured.
One CVM unit has been in operation since 1978 and the others have been
in service about six months. All are working well, producing an opacity of
5 - 10%, on a continuous basis. CVM also has another unit that has been in
operation over three years that handles fumes from a tar-impregnation service.
We volunteered to make a presentation at this December 12 meeting when we
read the 1978 EPA draft of the Proposed Regulation for the Asphalt Roofing
Manufacturing Industry. Their reports had no reference to this method of fume
control which is generically called "high efficiency filtration." Since it is
one of the best performing types of fume control systems for this service, we
felt an obligation to bring this information forward and to comment on the pro-
posed regulations based on proven and superior technology.
In brief, the CVM Fume Eliminator is a tank with multiple tubes having
fiberglass wool packed in an annular configuration, with each tube approximately
12" in diameter and 12 ft. long. These tubes convert submicron fume particulate
into droplets of oil which can readily be removed from the exhaust gas. These
elements are conservatively rated for 10 CFM per sq. ft. dirty side element area
to achieve extended element life.
11-29
-------
The exhaust from a modern saturator is usually about 160°F - 180°F, parti-
cularly in the summer time. This is too hot for effective fume control without
precooling because fume particulate would reappear upon release to the atmosphere
if the exhaust gas temperature was more than 150°F, even after removal of fume
particulate in an efficient fume control system. We have selected 100°F - 125°F
as the desirable temperature range to avoid reforming particulate from exhaust on
release to the atmosphere.
In a CVM unit, the hot exhaust gas is cooled by contact with recirculated
sump oil and a limited amount of water on a scrubbing tray. A temperature con-
troller that measures the stack gas outlet temperature controls the water flow.
The temperature controller is set to maintain a temperature at least 15°F above
the adiabitic saturation temperature, A set temperature of 1CO°F - 125°F forces
the system to evaporate the water to dryhess, thus avoiding a water pollution
problem. The oil recovered from the exhaust gas may be burned as fuel in a
properly designed burner/ returned to the process/ or disposed of as slop oil.
The CVM unit includes an indexing prefilter to extend element life beyond a
year in this service/ even with our conservative 10 FPM element face velocity.
Pref ilter media replacement is required on about a weekly basis at a media cost
of about $40 per week for a 20,000 CFM unit. The pref ilter removes the fouling
components that would otherwise foul the elements.
The performance of the CVM unit exceeds the requirements in the EPA November
1979 Proposed Regulations for ARM! as follows in Table I:
Table I
Comparison, CVM vs EPA Proposed Regulations
Handling ARM! Saturator Exhaust Gas
Proposed EPA Regulations CVM Performance
Opacity 20% or less 5 - 10% (max.)
On Stream Reliability No Specification Continuous
Visible Fugitive Emissions None Practically None
Emission Rate 0.04 KG particulate per mega- 1.2 Ib/hr.
gram asphalt produced
Calculated Allowable m '
Emission Rate Not Available1 '
Particulate and Oil
Removed from Exhaust - 50.0 Ib/hr.
Calculated Removal
Efficiency - 97.7%
'Client considered production information confidential. Would not reveal at
this time. Could not calculate EPA allowable.
11-30
-------
As a supplier of a proven and superior fume control system for this applica-
tion, we feel that the proposed standards should be updated to reflect performance
that is readily achieved on a consistent basis. We recommend the following changes
to the EPA November 1979 Proposed Regulations for ARMI as shown in Table II below:
Table II
Suggested Modif ications to EPA Proposed Regulations
Handling Saturator Exhaust Gas
Proposed EPA Regulation Suggested Alternative
Opacity 20% or less 10% or less
On Stream Performance/
Percent of Operating Time No Specification Proven 90 - 95%
Visible Fugitive Emissions None Practically None
Allowable Emission Rate 0.04 KG particulate per None
megagram asphalt produced
Required Particulate Removal 90 - 95% Removal of Parti-
Efficiency Requirement None culate in Exhaust Gas
Exhaust Gas Temp. Limit Arbitrary Less than 140°F
Recommended Equipment ESP & HEAF Anything that works
Analysis of Particulate
Matter Method 26 Needs further work
Referring to Table II, the key to monitoring performance is opacity. When
there is a question about performance, it should be resolved by a test to determine
particulate removal efficiency. In selecting a performance level in terms of opac-
ity, we must keep in mind that we are, in fact, dealing with the potential of an
exhaust gas to cause an odor problem when released to the atmosphere. Only proper
incineration can eliminate all odors present, but neither ARMI, nor the world can
afford this except in extreme circumstances. This is probably one of the reasons
why EPA is writing these regulations and we must recognize this progressive atti-
tude for what it is.
CVM feels that the opacity specification should be "10% or less" for future
saturator air pollution control installations because this performance is readily
achieved in proven and competitive equipment. Allowing 20% opacity for f-^tetge '^-^~
applications would allow the inferior performance characteristic of some HEAF and
ESP units to continue until replacement or upgrading is required. In addition,
II
-31
-------
EPA should write a specification insisting on near full-time operation of the air
pollution control system. It has become a joke with some ESP users that 40 - 50%
on-stream time is "enough to get by". This attitude gives air pollution control
and EPA a bad name. It should be made known that a part-time air pollution control
system is not acceptable.
The definition of allowable particulate as proposed by EPA is somewhat arbit-
rary because it does not recognize the effects of line speed, saturator exposure
area, and product type. It also requires information which might be considered
confidential. To specify required performance in terms that a supplier of air
pollution equipment can understand, we do recommend that the particulate removal
standard specify that "at least 90 - 95% of the particulate present in the exhaust
gas be removed" . This should be further defined as particulate at a temperature
which is the outlet temperature of a fume eliminator (in the before and after treat
ment measurement) . In no instance should the temperature of the exhaust gas exceed
140°F because of the effect of the higher temperature on opacity of the exhaust gas
after release to the atmosphere.
CVM feels that proposed analytical Method 26 should be modified to exclude the
104°F specification and the use of a precollector filter. Thr pra-iail 1 fi^T filtrr
-allows .?ui-^«dereng±n'e^red~~system-whic^ -judged •---
CVM f eels that the samples before and after
treatment should be taken and analyzed at the system exhaust temperature. The ex-
haust gas temperature should be less than 140°F for reasons previously stated.
Several studies have been made showing that isokinetic sampling is unnecessary when
sampling an exhaust gas containing particulate smaller than 10 micorns. Method 26
should reflect this reality and allow non-isokinetic sampling to be acceptable, at
least for the exhaust gas after treatment. This would save many a plant the cost
of mounting a special test outlet stack and a scaffold, exclusively for a perform-
ance test.
The EPA Proposed Regulations aara..-l±i3fcsthoy should require the same performance
from all related sources in an asphalt roofing plant. There is no reason why tank
vents should be rated any differently from the saturator exhaust, particularly when
the opacity specification is changed to specify "10% opacity or less".
Historically, the exhaust gas from asphalt blowing stills has been subjected to
incineration. In many cases, this has consisted of partial incineration in an
existing boiler fire box. In the future, as oil prices continue to rise, the plant
operators will realize that much of the blowing fume now consumed to support incin-
eration is an alternate source of Btu's if the fume is removed and collected as oil.
Then there will be a development program to solve this air pollution problem in a
more economical way. To keep the door open for this future and beneficial develop-
ment, the performance requirement for the treated exhaust gas from asphalt blowing
should match the standards proposed by CVM for the exhaust from asphalt saturators.
The proposed new regulations for blowing stills should require that the opac-
ity of the blowing still exhaust be 10% opacity or less, and that the particulate
removal efficiency be 90 - 95% or less when measured at the exhaust gas temperature
by a revised Method 26 providing that the treated gas temperature does not exceed
14CPF.
11-32
-------
-5-
In summary, we mist recognize that the EPA has taken steps in the direction
of reality on air pollution control requirements for ARMI plants. Let us hope
that they have the wisdom to upgrade their November 79 Proposed Regulations to
something that people inside and outside the ARMI fences can live with.
11-33
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3. Anderson 2000, Inc.
Mr. Jack D. Brady
Anderson 2000, Inc.
20UO Sullivan Road
December 14, 1979 p.Q. BOX 20769
Atlanta, Georgia 30320
Mr. Don R. Goodwin, Director
Emission Standards and
Engineering Division (MD-13)
Environmental Protection Agency
Research Triangle Park, N.C. 27711
Re: NAPCTAC Meeting On December 12
Regarding New Source Performance Standards
For Particulate Emissions From
Asphalt Roofing Manufacturing Plants
Dear Mr. Goodwin:
This letter generally covers the comments which I made during the
meeting on December 12. I would appreciate having this information
entered into the transcript of the meeting for consideration in
adopting the new source performance standards.
Andersen 2000 Inc. is the largest supplier of emission control systems
for asphalt saturators in the asphalt roofing industry. The company
also supplies emission control equipment for asphalt blow stills and
for asphalt storage tanks. Similar systems have also been furnished to
asphalt loading terminals. My reason for appearing at the meeting is
to discuss some new test data which have been collected, using HEAF®
(HVAF) units which have been installed recently in the roofing
industry. I also intend to discuss briefly four subjects which we feel
are important to the adoption of appropriate new source performance
standards for these sources. These subjects are: 1)
2) Temperature controls and temperature recording on HVAF
systems. 3) Sampling using Method 7^26. 4) A comparison of current
asphalt emission sources, compared with the souces which were tested
for development of HVAF data by EPA.
On the subject of blow still control technology, our company has
installed one commercial system and one pilot plant system on blow
still emissions. In the full-scale commercial installation, the
from the HEAF system. Preliminary odor
testing indicates that the emissions from the HEAF unit have no greater
odor than the odor which was emitted from the fume incinerator which
was previously installed on this source. The average outlet gas
temperature from this HEAF system is 120° F. There has been no
particulate testing on this source yet, since it is a very new
installation. However, based on the visible emissions, we would expect
the system to easily comply with particulate loading requirements in
the area in which it is installed. Unfortunately, local codes require
P. 0. BOX 20769 ATLANTA, GEORGIA 30320 (404) 997-2000 TELEX 54-2858
__
-------
Mr. Don R. Goodwin -2- December 14, 1979
a modified EPA Method #5 for testing with inclusion of the impinger
catch. Thus, we will not have, in the near future, any Method #26
data.
We have also installed a pilot plant system on a larger blow still.
The pilot plant operates at 1,000 acfm and the average inlet
temperature to a cooler on this HEAP system is 203° F. The outlet
temperature from the cooler is averaging approximately 142° F. In this
^although the particulate emissions are clearly reduced
fantially, based on the quantity of oil being collected from the
filtration device, there are occasions where a visible emission is
seen with an opacity of up to 5%. In addition, because of the higher
saturated gas temperature of 142° F, compared with the commercial
system mentioned above, the outlet odor concentration is higher from
the HEAF system. The odor concentration has been measured on one
occasion, using the ASTM panel technique, at 265 odor units/scf.
We are also aware of a number of fume incinerator installations on blow
stills where the hot exhaust gas from the incinerator is ducted to
asphalt heaters. It is sometimes possible to observe the exhaust gas
going into the heater and there are a number of occasions where a
properly operating incinerator does produce visible emissions. These
incinerators appear to be operating under reasonable operating
conditions and with very high outlet gas temperatures. Thus ,-***»
It is extremely important
that the regulation not be written in such a fashion that it excludes
other control equipment. This is particularly important where the only
device observed to give the 0% opacity is a fume incinerator. Many
plants are installed in locations where interruptable gas supplies are
used to fuel the incinerator. When this is the case, the plant would
be shut down if the fuel supply were interrupted. By substituting
alternate control equipment, such as HVAF equipment and other devices,
it is possible to eliminate this dependence on interruptable gas and
still achieve adequate particulate collection efficiency. However, our
tests results would indicate that although it is probable the
particulate emission requirements can be complied with, the proposed 0%
opacity cannot be guaranteed on a routine basis. We thus suggest that
EPA consider increasing the visible emission requirement <^—AftS—*******
On the subject of temperature control and temperature recording for
HVAF equipment, our company has the largest number of control devices
of any manufacturer in the world installed on asphalt saturators.
11-25
-------
Mr. Don R. Goodwin -3- December 14, 1979
More than 80% of these units now include gas coolers preceding the HEAF
system. Most of these coolers are designed to cool the gas to the
lowest possible temperature, namely the saturated gas temperature. In
practice, these coolers routinely reduce the gas temperatures to within
10° F of saturated gas temperature. Many of these devices have no
means for temperature control, since they recirculate large quantities
of water through a recirculated liquid system and the gas and liquid
streams simply equilibrate at the saturated gas temperature or near the
saturated gas temperature. The important point is that in high ambient
temperature conditions, the air which is sucked into the saturator hood
is already very hot. In some areas, the air may be dry, but in some of
the southeastern areas, the sir is quits tacist. Therefore, the
saturated gas temperature varies dramatically with ambient air
conditions and with location in the United States. Furthermore, a
saturator hood operating in Chicago during the winter might produce
an exit gas stream which saturates at about 80° F while at the same
time of the year, a saturator hood in Louisiana might product an
effluent which saturates at a temperature of 110° F. Using the best
cooling system which can practically be considered for this type of
application, one would expect to achieve an outlet gas temperature
within about 10" F of the wet bulb temperature. If, as proposed by
EPA, performance testing were done on the system immediately after
installation, and the results of these tests were used to determine the
temperature at which the system had to operate, it is possible that
such a system could be tested in the winter and it is quite probable
that it would comply with the opacity and particulate requirements
under those conditions. On this basis, the cooled gas temperature
would be established at a much lower level than could practically be
achieved during summer months and furthermore, a much lower level than
would be necessary for compliance with regulations. If the same system
were then operated during summer months, and if the temperature
requirement had been established during winter months, the system could
not comply with the regulatory requirements, even though it would be
operating with an opacity and particulate emission level lower than
specified by the new source performance standard. In addition, we have
found dramatic differences between asphalts used in one plant and those
used in another plant. If two plants, using two different asphalts,
produce emissions at the same gas temperature, the particulate emission
level out of an identical piece of emission control equipment will vary
dramatically, depending upon the type of asphalt used in the plant.
Very few asphalt saturators utilize the same asphalt on a routine
basis. Often, the crude oils which are furnished to the refineries
change as a function of market conditions and availability. The
asphalt plants must accept whatever asphalt they can get from a given
refinery, since it is not economically feasible to transport asphalt
for any great distance before using it for roofing material.
11-36
-------
Mr. Don R. Goodwin -4- December 14, 1979
Thus, if the temperature requirement were established for one
asphalt during initial testing of such an emission control device, that
temperature might not be practical and might, in fact, not be even
acceptable for another type of asphalt in the same plant under
virtually the same operating conditions. We therefore question the
wisdom of requiring temperature recording devices, when the temperature
is not the sole indicator of control capability and where the
temperature basically cannot be controlled in the most modern coolers,
since they are intentionally designed to cool the gas to the absolute
minimum possible. As an alternate, we would simply suggest that the
regulation be written requiring a gas cooler which would reduce the gas
to within 10° F of the wet bulb temperature. This would compensate for
differences in ambient temperature, differences in asphalt, differences
in moisture content of the felt being saturated, and operating
condition differences which would increase or decrease the saturated
gas temperature. Our extensive experience with HVAF systems indicates
that if the gas were within 10° F of wet bulb, this would always enable
maximum opacity and particulate reduction.
Our concern about test Method #26 is that virtually all data collected
on emissions from control equipment in asphalt saturator applications
have been taken using either EPA Method #5 or a modification of EPA
Method #5 to enhance collection of organic matter. Our own test
procedure involves use of a standard EPA Method #5 sampling train, but
operated with a number of differences from EPA Method #5 recommended
techniques. As an example, we operate the probe heater on the sampling
train to maintain a temperature within 10" F of the exit temperature
from the filtration device used to control the emissions. We then pass
the gas through an absolute filter and route it into iced impingers.
The organics collected in the impinger are then solvent extracted and
recovered for weighing. Because the sampling probe is not heated to a
high temperature, the organic matter does not bake on the inside of the
probe and can easily be washed out of the probe and included with the
oily material collected in the iced impingers. We have also found that
acetone is not a particularly good solvent for the asphalts and have,
instead, used such solvents as isopropanol and other similar solvents
which better solublize the asphalt oils. We always run a blank on
these solvents to ensure that there is no additional weight gain
attributed by these solvents. We suspect, although we have no
confirmation of this estimate, that our method probably gives similar
results to your proposed Method #26. Unfortunately, unless some
correlation is done between this method or other methods which have
been used for asphalt sampling, it is virtually impossible for anyone
to evaluate either the capability of the emission control equipment to
comply with the proposed regulations or to evaluate if present sampling
data bears any relationship to results which can be anticipated in the
future, using Method #26. Without such data, we find it extremely
ii-o/
-------
Mr. Don R. Goodwin -5- December 14, 1979
difficult to comment on the reasonableness or lack thereof of the
particulate emission requirements suggested for new source performance
standards. To possibly clarify performance capabilities of HVAF
systems, we are attaching a table which shows outlet particulate
loadings using the method described above on recent HEAP installations
using closed-loop coolers. Unfortunately, we do not have data on the
quantity of product which was passing through the saturator during
these tests and we are thus unable to relate these particulate loadings
to mass emissions per unit of product produced.
Our final concern is with the differences between the sources which
were tested by EPA and current practice in the industry. We have made
numerous improvements in the HEAP system for asphalt saturator emission
controls. Simultaneously, the roofing industry has made major efforts
to reduce the total gas flow rate required to collect the emissions
from the saturator, in an attempt to reduce energy consumption in these
plants. Virtually all of this activity has taken place since the
samples were taken for the EPA study. The HVAF installations used by
EPA for producing data to allow development of new source performance
standards were all comparatively high gas flow rate installations,
compared with current technology. In many instances, the roofing
manufacturers have reduced this gas flow rate by a factor of 2 for the
same size saturator and the same quantity of product being produced.
It is important that you recognize what effect this has on emissions,
control requirements, and outlet particulate loadings. By reducing the
flow rate through the saturator hood, the partial pressure of asphalt
volatile components increases in the gas over the saturator tank.
This, in turn, creates a resistance to evaporation of additional
organics from the saturator. Thus, using lower gas flow rates for the
same sized system by simply tightening the hoods around the saturator
actually reduces total emissions per unit volume of product produced,
within any emission control equipment. However, reducing the gas flow
rate also increases the particulate loading per cubic foot of gas.
Thus, the concentration of particulate in the gas stream at the
emission control device is higher at the inlet. To achieve the same
outlet concentration, it is therefore necessary for the control
equipment to achieve a higher collection efficiency than would have
been the case with the higher gas flow rate. As a supplier of this
type of equipment, we have been forced to design higher efficiency
equipment to accommodate these changing conditions. However, although
the collection efficiency of the equipment has improved, the outlet
concentrations have not gone down due to the higher inlet
concentrations. Therefore, the evolutionary process has been primarily
one of reducing energy consumption, rather than reducing outlet
emissions. This should be taken into consideration in the rule-making
process. It would obviously be beneficial to have tests conducted on a
newer installation with the new gas cooling equipment and on a
11-38
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Mr. Don R. Goodwin
-6-
December 14, 1979
saturator which is equipped with a much tighter emission control hood
system. If this is not possible, an attempt should at least be made to
collect as much emission control data as possible on newer
installations. We hope that you will review the enclosed table and
consider its inclusion in your data base for the rule-making process.
Very truly yours,
ANDERSEN 2000 INC.
Jack D. Brady
President
JDB/dm
enc.
-------
RESULTS OF RECENT EMISSION TESTING
ON HEAP® SYSTEMS INSTALLED ON ASPHALT
ROOFING INDUSTRY OPERATIONS
COMPILED BY ANDERSEN 2000 INC - HEAP MANUFACTURER
Source
Saturator, Coater
and Storage Tanks
Saturator and
Coater
Saturator
•pBlowing Still
Blowing Still
HEAP System Flow
Decription
t
Rotary Drum HEAP With
Closed-Loop Recircula-
ted Water Cooler
Rotary Drum HEAP With
Closed-Loop Recircula-
ted Water Cooler
Rotary Drum HEAP With
Closed-Loop Recircu-
ted Water Cooler
Outlet Emissions
Dual Cartridge
Mini-Heaf
Rate
15,000
acfm(outlet)
@ 110° F
30,000
acfm *#**.T;I>T
@ 300° F
28,000
acfm ****
@ 250° F
Particulate*
0.0066
gr/acf
(0.85#/hr.)
Not
Tested
0.0043
gr/acf
(0.78#/hr.)
Opacity ** Odor***
<100
No Odor
Visibles Units/scf
<100
Odor
<5% . Units/scf
<80
Odor
<5% Units/scf
5,000
acfm (outlet) Not Yet
120" F Tested
No
Visibles
Pilot Plant Test
of Rotary Drum HEAP 1,000
with Closed-Loop acfm ****
Cooler @ 203° F
Outlet Gas
Temperature
110' F
114° F
Not Tested
0-5%
Equal to or
Less than From
Fume Incinerator
265
Odor
Units/scf
102' F
120° F
142'
*
**
Using EPA Method #5, Including "Back-Half" Catch
By Qualified Opacity Reader, Excluding Water Vapor
*** Using ASTM Panel Test Procedure
**** Cooler Inlet
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4. Monsanto Enviro-Chem Systems. Inc.
Mr. Eugene Kennedy
Monsanto Enviro-Chem Systems, Inc.
800 N. Lindberg Boulevard
St. Louis, MO 63166
I WOULD LIKE TO COMMENT ON TWO MINOR POINTS AND ONE MAJOR ITEM.
THE FIRST POINT CONCERNS TEMPERATURE CONTROL FOR PARTICULATE TYPE
COLLECTORS. WHILE THE BACKGROUND DOCUMENTS DO INDICATE THE IMPORTANCE OF
PROPER COOLING FOR PARTICULATE COLLECTOR TYPE CONTROL DEVICES, IT WOULD
APPEAR THAT THIS SHOULD BE BETTER HIGHLIGHTED. THE TEMPERATURE THAT IS,
IF YOU WILL, RECOMMENDED IS RATHER BURIED BACK IN AN APPENDIX ON ENFORCE-
-. rr*\ "
MENT ASPECTS. WHILE WITHIN OUR EXPERIENCE, THE TEMPERATURE SUGGESTED
(110°F) IS APPROPRIATE, IT WOULD SEEM ADVISABLE TO BRING THAT MORE TO
THE FOREFRONT OF THE DOCUMENTS.
THE SECOND POINT CONCERNS THE SAMPLING PROCEDURE. WHILE AN UPPER TEMPER-
ATURE LIMIT FOR THE FILTER IS IDENTIFIED, A LOWER LIMIT IS NOT. I
APPREICATE THE PRACTICAL DIFFICULTY OF MAINTAINING VERY TIGHT TEMPERATURE
CONTROL IN A SAMPLING TRAIN. HOWEVER, THE PROPOSED METHOD DOES PRESENT
SOME DIFFICULTY. I WOULD EXPECT THERE TO BE A TENDENCY FOR SAMPLING
COMPANIES TO RUN THEIR TESTS AT AMBIENT TEMPERATURE WHICH COULD BE
SIGNIFICANTLY BELOW STACK TEMPERATURE. THE RESULTING CONDENSATION WOULD
SIGNIFICANTLY INCREASE THE APPARENT LOADING WHEREAS SAMPLING AT CLOSE TO
THE SPECIFIED MAXIMUM (40°C) WOULD RESULT IN LOWER APPARENT EMISSIONS.
THOSE INVOLVED IN HAVING PERFORMANCE TESTS RUN SHOULD AT LEAST MAKE SURE
THE SAMPLING AGENCIES RUN THEIR TESTS AT AS CLOSE TO THE UPPER LIMIT AS
11-41
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KDK
12/7/79
PRACTICAL. A SECOND POSSIBLE PROBLEM COULD OCCUR WHEN THE SATURATOR
EMISSIONS ARE AT A RELATIVELY LOW TEMPERATURE. BY SAMPLING AT A TEMPERA-
TURE HIGHER THAN THE PROCESS GAS TEMPERATURE, THE MEASURED EMISSIONS
COULD BE LOWER THAN ACTUAL.
THE LAST AND MAJOR POINT I WOULD LIKE TO MAKE CONCERNS THE SUGGESTED OR
APPROVED EQUIPMENT FOR SATURATOR EMISSIONS. WE WOULD LIKE TO POINT OUT
THAT THERE HAS BEEN ANOTHER TYPE OF CONTROL EQUIPMENT SUCCESSFULLY USED
TO CONTROL THE EMISSIONS FROM ASPHALT SATURATORS. THAT IS, THE FIBER
BED MIST ELIMINATOR. OUR COMPANY HAS THREE UNITS IN OPERATION IN THE
U.S. AND AN ADDITIONAL UNIT IN CANADA. IN ADDITION, WE HAVE SEVERAL
OTHER UNITS SOLD BUT NOT YET IN SERVICE. FURTHER, OTHER VENDORS OF
FIBER BED MIST ELIMINATORS ALSO HAVE EQUIPMENT IN OPERATION.
WHILE REPRESENTATIVE METHOD 26 PERFORMANCE DATA HAS NOT BEEN OBTAINED TO
OUR KNOWLEDGE ON THIS TYPE OF EQUIPMENT, WE DO KNOW THAT OUR UNITS IN
THIS SERVICE ARE ALL ACHIEVING LESS THAN 10% OF OPACITY. BASED ON
THIS, WE BELIEVE VERY STRONGLY THAT THEY WOULD ALSO MEET THE PROPOSED
MASS EMISSION CRITERIA AND HAVE COLLECTION EFFICIENCIES AT LEAST COMPAR-
ABLE TO THE OTHER CURRENTLY IDENTIFIED PARTICULATE CONTROL EQUIPMENT
WHEN OPERATED AT THE SAME CONDITIONS.
WE RECOGNIZE THE FACT THAT FIBER BED MIST ELIMINATORS WERE NOT TESTED BY
THE EPA CONTRACTORS IN 1975 BECAUSE AT THAT TIME WE DID NOT HAVE EQUIPMENT
IN SERVICE. HOWEVER, WE NOW HAVE HAD EQUIPMENT IN SERVICE FOR TWO
YEARS.
11-42
-------
EDK
12/7/79
WE BELIEVE THAT NEITHER THE INTEREST OF THE ASPHALT ROOFING INDUSTRY NOR
THE OBJECTIVES OF THE EPA ARE SERVED BY IGNORING AN ALTERNATE CONTROL
TECHNOLOGY SIMPLY BECAUSE THE READILY AVAILABLE INFORMATION IS FOUR TO
FIVE YEARS OLD.
IN CLOSING, I WOULD LIKE TO THANK THIS COMMITTEE FOR MAKING TIME AVAILABLE
FOR PEOPLE LIKE OURSELVES TO PRESENT OUR VIEWS AND IF WE CAN BE OF ANY
FURTHER ASSISTANCE, WE WOULD BE MOST HAPPY TO COOPERATE IN ANY WAY
POSSIBLE.
Presented by: E. D. Kennedy
Monsanto Enviro-Chem Systems Inc.
/rm/5d
11-43
-------
. inhc: P.oofin" "anufacturers Association
".r. P.i chard Snyder
it "oofir.n ''anufacturers Association
Suite 702
1000 ;
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1) To prepare an expedited presentation for the meeting today;
2) To bring you a unified opinion from companies v;ho will be
involved with the proposed performance standard.
The following.companies, who met yesterday and who are present today
for comments or response to questions based upon your requests are:
o Tamko Asphalt Products
o CertainTeed Corporation
o GAP Corporation
o Bird & Son, Inc.
o The Plintkote Co.
o The Celotex Corp.
o Masonite Corp.
o Georgia-Pacific Corp.
Unfortunately, due to schedule conflicts, Johns-Ha.nville and the
Owens-Corning Fiberglas representatives could not be v;ith us at our
briefing on December 11. The company representatives present are
Chief Engineers, Vice Presidents of Manufacturing, and/or environ-
mental control experts.
As we only met yesterday, we will not have a written presenta-
tion today, but will make our comments available for the record as
quickly as possible.
Our presentation will be in tvro parts. The first v/ill be
general comments I v/ill make on behalf of the Association, and then
1 have asked ?4r. J. W. Ricketts, Vice President of .Manufacturing for
Tamko Asphalt Pro-ducts, Joplin, Missouri, and the Chairman of our
Manufacturing Committee, to present the technical aspect- of our
presentation. We have a number of questions and suggestions to brir.j
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to your attention.
In general, we would request that you consider keeping the
proposed standards within parameters, a range of performance, instead
of flat minimums, because there are so many differences in company
sizes, locations, methods of operation, and types of control equip-
ment and systems. What is successful in one plant may not be in
another. We believe a wider range of performance parameters will
give some latitude, and yet still move toward your basic objective
of reducing emissions. To us, a flat minimum, i.e., zero, may be
impossible to reach based upon the equipment available, but also
due to sources of raw material, state-of-the art, and the circum-
stances of the plant involved.
A second point is relative to definitions in the EPA Report.
•
We believe there is a need for clearer definitions, because there
is some confusion on the part of many in the industry as to that
which may be included, or excluded, within a particular definition.
A third point relates to test methods and procedures. To my
knowledge, no one in our industry has had the opportunity to work
with Method 26 or Method 22. We realize much of the reasoning
behind the proposed standards is based upon those two methods, and
yet., we have had no opportunity to try those methods ourselves to dete:
mine whether they will be feasible in each and every one of our
plants across the country. We request acceptance of the already
proven test methods and procedures—most of which have been develoced,
and are primarily directed by states, instead of moving into these
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new test efforts that may be cost."!;/ and unworkable,
A fourth point is that 1975 is the data base year from which
most of the report devised its conclusions. We think there has
been enough change in the industry since 1975 to require a review
of the older data with data that has developed since the base year.
Decisions regarding performance standards should be based on the
most current data.
The balance of the Association's report will be handled by
Mr. Ricketts. But, before he continues cur presentation, we would
like to offer a task force of our members to work with you and the
E?A in considering appropriate standards, determining the best
test methods and procedures, and provide other assistance in
furthering your goals.
We need more time to discuss these matters with you and we look
forward to that opportunity!
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G. Asphalt RoofInn Manufacturers Association
Mr. John V.'. Ricketts
Tamko Asphalt Products
601 N. Hi oh Street
Joplin, Missouri 64801
The following is a summary of the comments which were made in behalf
of the Asphalt Roofing Manufacturing Association, by John W. Ricketts,
Chairman of the Industry Manufacturing Committee.
The background document prepared by EPA indicates on page 9-8 that
only three (3) new asphalt roofing plants will be effected by these reg-
ulations between now and 1985. All of their assumptions on energy, cost,
water pollution and solid waste impact are based on this three plant num-
ber. However, on page 8-54 they state that ten plants will be built be-
tween now and 1985 in order to meet the projected needs. On page 9-1
they state that there are now 110 plants in tha country and that the in-
dustry will grow at 2% a year. Obviously the document is still in draft
form and they have not had a chance to clear up all of the various dis-
crepancies between the individual authors. After reviewing these numbers
we agree that the 2% growth rate is approximately right. Therefore, if
you take a 110 plants with 2% growth/year beginning in 1973 you get approx-
imately 13 additional plants by 1985, effected by this regulation.. However,
as the agency very correctly pointed out on page 8-54 only about 5 of these
plants will be new. - The other 8 will actually be made up of increased
production capacity at existing plants. Since the normal economic expansion
increment in our industry is approximately 20%, this means that it will be
necessary to enlarge forty existing plants by about 20% each in order to
have the equivelant of 8 new plants. Due to the application of the modi-
fication and reconstruction portion of the air pollution law all 40 of
thesa plants will also be covered by the new source regulation. In addi-
tion our industry has a history of fire problems, normally we have a'cout
one major fire per year that would require a major reconstruction. The
reconstruction would then cause those plants that_had fires to fall under
the proposed regulations. Finally, in an industry as old as ours there
are many plants which are obsolete and are currently in the process of
being shutdown. These plants will be replaced by additional plants than
are more strategically located in relationship to the current growth rr.ar'c = ~
demands. Taking all of these above factors into consideration it is our
opinion that approximately one half of all asphalt roofing plants in the
nation will have to meet these new standards by 1935. This includes all
those-plants which are newly constructed as well as those which are
modified or reconstructed for the various reasons outlined above.
my comments concerning enercy impact:, cost effect, etc. are
-------
?
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Therefore, it is very important that we arrive at a consistent emission
limit which recognizes the difference in the product mix and the raw
material base that is used on each different type of line. The .4 Ibs.
per ton that was mentioned in this mornings presentation is definitely
a step in the right direction. However, on the basis of a cursory
examination it appears to be somewhat out of proportion to the originally
proposed emission limit. A saturated felt line normally runs at a rate
about 3 to 6 tons per hour, and a shingle line runs at a rate of about
30 to 50 tons an hour, about a 10 to 1 ratio. Although, we are not
familiar with the expected results on a Method 26 test, generally speak-
ing the emission from a saturated felt line is approximately the same
as from a shingle production line. Therefore, we believe that this re-
vised standard for saturated felt lines needs to be reviewed and perhaps
field tested to make sure that we are in the right area.
Because of our lack of familiarity with Method 26 results and the
fact that they cannot be correlated with Method 5 it is hard for us to
take a position on the recommended particulate the emission standard.
However, we are certainly interested in discussing the applicability
of this standard to the various types of machines and raw material (crude
oil) supplies that are in use through out the country. Apparently all
four of the plants (A,B,C, and D) met the proposed standard under the
operating conditions that were prevalent at the time of testing. The
background information indicates that the Plant A was operating at 126°
inlet temperature. 'Plant D at a 156°, Plant C at a 109° and Plant B
with a after burner was operating at a 1,000 - 1,200°F. in the combustion
chamber. Since these plants did meet the standard, we have some confusion
as to the actual implementation of the proposed regulations. Paragraph
60.005 (H) says that the average value for the ^temperature specified
shall be the temperature which is measured and recorded during the test;
however, Appendix E (Enforcement Aspects) says that the test shall be
mads using inlet operating temperature below 110°F. on KVAF and ESP units
and between 1300 and 1500°F. for after burner units. It seems to us that
the real purpose of the regulation is to meet the emission standards
irrelevant of the operation temperature. After the standards have been
met, then it is imperative for the operator to continue to operate the
unit'at the testing temperatures. It is our feeling that these temperatures
will vary significantly around the country, depending on the nature of
the crude oil that is being used as a raw material source.
I!-50
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We are also very concerned about the proposed regulation which calls
for no visible fugitive emissions from the saturatoir. Table 9-3 shows
that none of .the plants (A,B,C, or D). actually passed with zero visible
fugitive emissions at all tiir.es, table 4-8 also shows that all the plants
failed, and three of the plants with totally enclosed hoods,, varied from
0 to 10% visible emissions. We believe that if a fugitive emission
requirement is necessary it should at a more normal operating level as
experienced in the plants that were tested (not at zero); and in addition
should have'some provision for upsets, start-ups, shutdown, maintenance,
etc. In addition the real key to judging fugitive emissions should be
on the basis of outside observations, not those on the inside of the
building. •
In the area of blow stills we appreciate the comments that were
made earlier concerning the survey of 13 locations. However, because
of the significant changes which are taking place in our industry due
to the energy crisis, we now believe that within the next five years
virtually all coating will have to be blown using the catalytic process.
This may change the operation of the blow stills and should be taken
into consideration. ~. In addition as the study very correctly indicated
(page 3-35) crudes from various sources have significantly different
emission rates. Since we are not only not familiar with Method 26
and also not familiar with the particular crude that was tested, we
fael that the very limited data base (only one sample) should not be
used to set an industry wide standard.
Due to continued shortage of fuel and the fact that many of our
plants are on interruptable natural gas supplies, many blow still after
burners are now run on "6 fuel oil. When running "6 fuel oil and
incinerating the blow still fumes we believe that it is virtually impos-
sible to obtain a 0 opacity. We therefore suggest that the regulations
provide for a specified limit on emissions, but allow the opacity to
be something higher than 0 in order to provide for different crude oil,
different burner fuels, start-ups, shut-downs and upset conditions.
Possibly these after burners could be operated with the regulations which
are now used on boilers, providing times for soot-blowing, etc.
Because of the current, energy problems in our country a lot of work
has been done in the last year or two to develop an alternate means of
controlling the asphalt blow stills, which is not energy intensive.
vre r.o:.-' have information indicating that it is possible to reach the
required particulate emission rates, however, this new equipment will
-------
not be able to meet the 0 opacity at all times. We believe the re
lations therefore, should be concentrated on the particulate c:ni.v:s
limits and the opacity limits should be uniformed through out the .
at the 2G£ level.
The proposed regulation concerning asphalt storage '-.anks inc/1/.~.tes
that the best technology is to vent the tanks through the saturate.;/
control device when it is running, or to a mist eliminator when iL i.s
not running. In maV plants through out the country this arranaern-e;:'-
would be impossible due to the remote location of the asphalt storage
tanks. We submit that it would be more effective to control the
emissions from the asphalt storage tanks 100°; of the tiiaa with a "ust
eliminator or something similar. In addition for uniforraity and
cor.sistancy we believe that the opacity limit on the storage tan];
should be at 20%, and that'there should be a provision for shutdown,
start-ups, upsets, etc. which is spelled out in the regulation.
The standard for mineral handling and storage v,-as mentioned -..ri:.?r
by members of the Advisory Committee. We tend to agree with thosr-
•comments since cnxs .source represents less than 2%" of tr>2 pocanci;-._ •er.iis-
sions. In addition the emissions are of such a nature that they 'c-;-rid to
fall to the ground immediately. We believe that this type of rec •''..:: tiori
is not cost effective and should be left for S.I.P. control. Kovr- ..T,
if the regulation is ultimately decided to be necessary then we ac Ln
submit that the opacity rating through out the plant should be at .
consistent level- for ease of monitoring by the plant personnel .v • ./ell
as the local enforcement personnel. We believe that this level .'-ould
be set at 20S similar to the saturator exhaust stacks.
For all these reasons we believe that of the proposed racu-~ :ory
alternatives - Alternative "3 is the most cost effective. ?os~v;.y it
would be worthwhile- to'consider an additional alternative, (.--. •. t.~r:. -. • i v-.-;-
5) which would compare the cost and improvement in emission re: ;•-:• '. • ^ s'l
on the control of the saturator and blow stills since these ar; -:."..•> t...o
most significant sources (95.4% as indicated en. page 9-1;}.
Under the regulation on monitoring (50.004) we baslOTilZy ;•.-="•- c"-.:-: •
comments. "D V.'e r.eed to have a more explicit definition of the ;-; v.^-- :;f
equipment that ara included under the generic terms ZS?, M"A?. ;- •'." -.r.d
Mist Eliminator- "2} The requirement for recording the t e r_::-.r .^'-•..:.:•:> of
the inlet ens or corr.bu3ti.on zone should be spell-.rd out .— "r; r~~•'_:''. • r.^l.'.'
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to indicate the type of recording, (continuous or operator notes)
and the provisions to be made in the event of equipment breakdown, etc.
3). The six hour period for temperature averaging to determine excessive
emission reports is unduly short, due to the operating characteristic::
of our plants and the nature of the equipment involved. Therefore, we
submit that a 24 hour averaging period would be more reliable.
In the regulation concerning test methods, obviously Method 1,2,3,
and 9 are standard methods with which we are all familiar, and are totally
acceptable to the industry. However, the new method 22 and new Method 26
create a great number of questions in our mind. Primarily due to the
fact that Method 22 is not a scientific method for determining opacity,
similar to Method 9 and in fact requires "no training" on the part of
the observer, either as to distinction between moisture and fuir.es, or
the distinction between lighting conditions. We feel that Methcd 22 is
certainly borderline for making valid regulatory judgements. We prefer
that Method 9 be continued even in the case of visible fugitive emissions.
As I stated earlier, Method 26 is totally new to us and I don't know
really where we're coming from as far as this method is concerned.
Obviously it appears to have some scientific merit over Method 5 and the
modified methods that are now being used to collect asphalt particulate.
I do have a few comments however,, concerning cost effectiveness; Method
26 (according to the literature) cost about $12,000/run; Method 5 about
$3,000/run. Method 26 as applied to asphalt roofing calls for a 120
minute sampling period with a minimum of 3 runs. Due to the nature of
our plants and the relatively unstable manufacturing rates caused by
quality control problems and material supply variations 120 minute period
at 80S capacity is virtually impossible to obtaJ ru on a regular basis.
Therefore, we believe that a shorter test period would be more accurate
since it would eliminate the need for starting and stopping the test
frequently. As far as the application of Method 25 to the blow stills,
we need to have a more definitive description of the duration of the
test, indicating whether the test should be run during charging and dis-
charging or only during the air blowing of the product. We have very
little data in which to judge the validity of Method 25, however, we
believe that it may not be cost justified based on the results obtained
and perhaps a standard should be set by using a modified Method 5 or 20,
which would be less expensive and equally effective.
-------
As I pointed out earlier, by 1985 approximately half of our plants
will fall under this new regulation due to the provisions of section
60.14, that deal with modification and reconstruction of existing
facilities. This greatly changes the cost and energy impact of the
regulations. It will cost approximately $22,000,000 to meet these
regulations, which translates into substantially more than $3/house.
In addition the energy impact of the regulations will be much more
significant both in the number of plants that have to be considered,
i.e. 55 vs. 3, and also in the methods that have to be used in a
retrofitted plant vs. new green field construction. Obviously in a
green field plant the facilities can be properly sized to meet the
requirements at a relativley low cost. However, in a retrofit this
generally will not be possible, but will require that totally new
equipment be added parallel or in series with existing equipment in
order to improve the performance up to the levels required. This
duplication has the tendency to double the energy impact of the regula-
tions on those facilities. Solid waste and water pollution are no
longer minimal due to the large number of plants involved.
In conclusion, we would like to comment on the regulations as
they apply to potential new control devices. The regulations should
be written in such a way that no devices are specified, only the
desired results. By doing this, we can then continue to develop new
and better methods.that are efficient in the removal of potential
emissions and also efficient in energy and cost areas.
We certainly appreciate the opportunity to be here today and
express our opinions and concerns, and we appreciate the Chairmans's
offer to discuss the background information and-proposed regulations
in greater depth at future meetings with our association.
IT.
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7. Owens-Corning Fiberqlas Corporation
Mr. Samuel H. Thomas
rning Fiberglas Corporation
Fiberqlas Tower
Toledo, Ohio 43659
A. INTRODUCTION
I am Samuel H. Thomas, Director of Environmental Services for Owens-
Corning Fiberglas Corporation, Toledo, Ohio. Owens-Corning Fiberglas
Corporation is presently involved in the processing and manufacturing
of asphalt and asphalt roofing products at fifty (50) facilities in
nineteen (19) states located throughout the United States. As such,
Owens-Corning Fiberglas is interested in the proposed regulation, and
it is hoped that the comments which follow will be reviewed and incor-
porated or clarified in the final draft of the proposed regulation.
In addition, it is hoped that any comments relating to the background
information document can be included or modified to insure that the
information to support the regulation is representative of emissions
and processes in the industry.
B. PROPOSED REGULATION
a. 60.003 (a) Standards for Particulate Matter -
In this sub-part EPA states that "no owner or operator of an
asphalt roofing plant subject to the provisions of this sub-part
shall cause to be discharged into the atmosphere, from any
saturator, particulate matter at emission rates exceeding 0.04
kilogram of particulate per megagram (0.08 Ibs/ton) of asphalt
roofing produced."
II--55
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This selection of the emission limitation was based upon per-
formance tests conducted on four (4) saturators controlled by
an electrostatic precipitator, high velocity air filters, or
an afterburner. During each of these tests, the product was
asphalt roofing shingles. Tests were not reported during the
production of rolled roofing, siding, or saturated felt. Dur-
ing the production of these products, the amount of product
produced is less than during the production of shingles. These
products do not always contain fillers, coatings, and granules.
Therefore, the amount of product produced may be substantially
less. Although emissions generated during the production of
these products are less, they may not meet the proposed emission
limitation. Owens-Coming Fiberglas believes this area should
be further investigated, or the emission limitation should be
specified solely for the production of roofing shingles. In
addition, control efficiencies for lower inlet emission rates
may be less than those reported. This is evident from the data
supplied in the background information document for the high
velocity air filter where an inlet loading approximately ten
(10) times larger results in a control efficiency of 98% as
compared to 77.9% for the lower loading.
b. 60.003 (b) Standards for Particulate Matter -
In this sub-part the proposed draft states that no owner or
operator of an asphalt roofing plant, oil refinery, or asphalt
processing plant subject to the provisions of this sub-part
shall cause to be discharged into the ambient air exhaust
gases with opacity greater than 0%. In the background infor-
11-56
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mation document, afterburners are specified as the control for
emissions from the blowing stills. Boiler fire boxes are used
for this purpose at many of the asphalt processing facilities'.
In light of the current energy situation, Owens-Corning Fiberglas
believes this alternative should be investigated and utilized
wherever possible. EPA specifies an opacity limitation of 20%
in sub-part b_ - Standards of Performance for Fossil-Fuel Fired
Steam Generators. Since the application of existing boilers
to control particulate emissions from asphalt blowing stills
should be encouraged, Owens-Corning Fiberglas believes an
opacity limitation of 20% should be established in sub-part b_
of the proposed regulation to account for the joint emissions
from the boiler fire box.
c. 60.003 (c) Standards for Particulate Matter -
In this sub-part EPA states that, "if however, the emissions
from the asphalt storage tanks are ducted to the operating
saturator control device, the asphalt storage tanks shall
comply with the emission limit established in paragraph (a)
of this section." This may discourage the use of one piece
of control equipment to control both the saturator and the
storage tanks. Owens-Corning Fiberglas believes it would be
more cost effective to use one piece of control equipment to
control both of these sources. It is suggested that if storage
tanks are ducted to the saturator control equipment during
operation that the allowable given in sub-part (a) should be
increased to reflect the increase in concentration from the
storage tanks.
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C. BACKGROUND INFORMATION FOR PROPOSED STANDARDS
a. Section 3.1 General -
Figure 3-1 in the background information document consists of
a processing chart for asphalt roofing products from raw mate-
rials to finished roofing. In this chart asbestos is indicated
as being a major raw material in the production of dry felt.
This is not necessarily representative of the input operations
throughout the industry. As such, EPA should change this and
indicate that asbestos is not a basic raw material for dry felt.
b. Section 3.3 Baseline Emissions -
In this section the baseline emission level is defined as the
level of control that is achieved by the industry in the absence
of a new source performance standard. These were established
for various size model plants according to "typical" state
implementation plans and summarized in Table 3-4. It was further
stated that the typical state considers that a plant is one
source, so the regulation applies to the plant. As we have
indicated in the introduction, we have operating roofing facil-
ities in nineteen (19) states. In most of these states the
particulate emissions are regulated by a process weight code.
The process weight rate of this code is commonly defined as
the total weight of all materials introduced Into a source
operation. For the roofing line, the saturation process which
includes the dip, spray, and wet looper is usually enclosed
and ventilated to control equipment. This is what is defined
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as the source operation. The material input, therefore, is the
felt, the saturant asphalt, and sometimes the coating asphalt.
This input rate is usually, for a shingle production line,
about one-third of the rate of the finished product. The
allowable particulate emissions are based upon this process
input rate, which for the commonly encountered process weight
formula, E » 4.1 x P , is approximately one-third the values
listed in Table 3-3 which 1s considered by EPA as a typical
state allowable emission. In addition, it was noted that the
uncontrolled emissions from three of the roofing plants tested
would meet the mass emission standards for most states. Yet
each of these three facilities had control equipment installed
and the actual emissions from these facilities was substantially
less than what is referred to as meeting a typical SIP. In our
opinion, based upon experience with operating facilities in
nineteen (19) states, the baseline particulate emissions should
be substantially less than those indicated in Table 3-4.
c. Section 4.3.2.1 High Velocity Air Filter (HVAF)
In this section, it is indicated that for effective capture of
hydrocarbon emissions the gases entering the HVAF unit must be
cooled to about 32° to 49° C. (90° to 120°). The reference
given for this information was a publication provided by Anderson
2000 Corporation. There appears to be some discrepancy in the
statement included in the background information document and a
revised copy of the reference publication. The statement on
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page 14 of the referenced publication actually states and I
quote, "Many organic compounds can be condensed at a temperature
below about 200°F. Some lighter oils can be condensed at a
temperature of approximately 120°F. It is very uncommon for
"HEAP" units to require a temperature less than 120°F at the
inlet to achieve adequate correction efficiency. As a result,
Anderson offers a complete line of evaporative cooling chambers
for use with their HEAP units, which are capable of reducing
the exhaust gas temperatures from any industrial product to at
least 120°F."
From experience with these units, it has been found that in
some parts of the country during the summertime, it is very
difficult to attain temperatures below 120°F at the inlet of
the control device due to high ambient temperatures and/or
input water temperature. As a matter of fact, in many parts
of the country during the summer, the ambient air temperature
exceeds those temperatures given as a range for operation in
the background information document. Since monitoring this
temperature will be required by the regulation, it is imperative
that EPA recognize this discrepancy in inlet temperature to
the unit with varying times of the year, as well as, varying
locations within the United States. Even EPA's emission tests
were not conducted during operation of control equipment at
110°F at the inlet, which is required for performance tests
as stated in Appendix E.
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Cooling to 110°F in many Instances would require more elaborate
cooling systems which EPA has not even addressed In the back-
ground Information document. In addition, EPA has not shown
justification for the need to control to 110°F at Inlet to
the control equipment.
d. 6.1.1 Baseline Model Plant Control Systems -
Although data supplied EPA Indicated that many of the facilities
are controlled, EPA insists on using emissions data based on
SIP's for the model plants. As previously mentioned in part b_,
this 1s not even representative of existing allowable emissions.
In addition, following this model criteria will exaggerate the
potential emission impact and the potential emissions reduction
to be realized from the proposed standard. This data is used in
the remainder of the report; thus, reflecting an inaccurate
analysis for justification of a new source performance standard.
e. Appendix A - Reference Test Methods -
A review of the subject draft of the Reference Test Methods
has been made and evaluated with respect to our previous ex-
periences and practical knowledge in this area. The following
items should be considered:
The method indicates that particulate matter is collected on a
filter maintained at a temperature no greater than 104°F. The
temperature is monitored at the exit of the filter holder in
the gas stream. This presents two difficulties. First, in many
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cases cooling will be required and probably even on lower tem-
perature stacks <480°F when restrictions are such that a short
probe is required and when ambient temperatures are high. It
is not uncommon to have temperatures over 100°F on roof tops
during summer months, or in warm climates. Water cooling of
probes on high temperature stacks requires great care by the
operator as these can be dangerous to work with unless pre-
cautions are strictly followed. Maintaining temperature by
water cooling 1s more difficult than by resistance heating as
is done in Method 5. It will be difficult to control the
temperature close to 104°F without either exceeding it or going
lower and supposedly biasing the results. EPA might be
cognizant of this problem because they have not specified a
temperature range as they have with Method 5.
Secondly, by requiring that the temperature be monitored at the
filter holder exit, Method 5 equipment will require modification
and thus a new component is put into the system. This adds
another location for developing possible leaks in an already
complex train. Method 5 only requires that the box containing
the filter requires temperature monitoring. All of our his-
torical data using heated filters is based on this measuring
method.
Although we have not attempted this method at the lower temper-
ature of 104°F, water condensate in the front half catch will
11-62
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most certainly Increase above what we have seen In the past.
Precautions to avoid blinding the filter are incorporated into
the method under the discussion about using a cyclone. This
will add to the normal analytical and sampling time substantially.
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C. DISCUSSION
Following the EPA presentation, which reviewed the development
program and the recommended standards for air pollutant emissions from
sources in the asphalt roofing manufacturing industry, Don Goodwin
opened the floor to questions and comment from the NAPCTAC members. EPA
staff and contractor personnel were on hand to respond to questions and
discuss issues of concern to the NAPCTAC members. Industry representatives
then made presentations, each of which was followed by a question and
answer session in which members of the audience participated. For
clarity, comments are grouped herein by subject matter rather than being
placed in chronological sequence.
Opening questions from NAPCTAC members centered on the problem of
odors from asphalt roofing manufacturing plants. A committee member
noted that this subject is not broached in the BID, even though it is of
concern to regulatory authorities. He recommended that the odor problem
be mentioned in the BID. It was pointed out that he was not recommending
that EPA regulate odor, but the BID should mention the problem and state
that minimizing aerosal emissions also minimizes odors.
Several committee members commented on an apparent change in EPA
standards-setting policy from a few years ago, when NSPS seemed to
reflect the state of the art. They noted that, based on cost and energy
considerations, there is more margin of safety in this recommended NSPS
than is necessary in a new plant. The emission standards could be lower
and still be met by a new plant. The committee also pointed out that
EPA's claim that equal results were obtained by each control method is
not supported by the data, which show controlled emissions ranging from
.03 to .07 per ton of product, a variation of over 100 percent. Thus, a
large margin of safety is being built in and EPA has a right to be more
demanding. EPA personnel answered that NSPS have always had a margin of
safety built in, because EPA test data do not reflect the best that can
be done, but rather what is being done at the best controlled plants EPA
can find. These are usually retrofitted plants, not new ones.
A discussion insued concerning opacity limits and problems pertaining
to enforcement. A committee member pointed out that the recommended
saturator opacity limit was too loose, since only one outlier is reported.
This is not the technology achievable at a new plant. A control equipment
manufacturer, John Wilki (CVM), also stated that a 20% opacity limitation
is far too liberal. He recommended a 10% limitation. Another, Gene Kennedy
(Monsanto Enviro-Chem), stated that all saturator control units installed
by his company operated at under 10% opacity. Other speakers, Jack Brady
(Anderson 2000) and Bill Ricketts (Tamko) stated that it may be impossible
to meet a "no visible" limit on stills. Don Goodwin responded that EPA
will look into the opacity limitations. Committee members agreed that,
II-64
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although opacity is a good tool for day-to-day monitoring of compliance,
the reduction of participate emissions is the main objective. Some
attendees questioned the wisdom of setting different standards for
different stacks. One committee member stated that it would be difficult
to differentiate between the different sources and that there could be
charges of discrimination and uneven enforcement from the public.
Committee members then questioned whether a 5% opacity limitation
was enforceable, given the 7 1/2% variation in emissions reported by
different inspectors. They also asked whether this variation was applicable
to the "zero opacity" measurements. An EPA representative explained
that the 7 1/2% variation does not apply when "no visible" emissions are
reported. Method 9 was discussed, and it was also explained that each
six minute average consists of 24 individual readings, taken each 15
second intervals. It was noted that individual readings can be much
higher than the allowable limit, provided the six minute average is not.
Asked whether the proposed regulation allows for upsets and shut down,
it was stated that these situations are covered in the general provisions.
In response to a question concerning whether EPA has a legal obligation
to correlate particulate emissions with opacity, an EPA spokesman answered
that it is not a requirement to do so.
The next topic of discussion was the regulatory alternatives. A
committee member pointed out that the capital cost of going from alternative
3 to alternative 5 is $9,000 per ton of pollutant collected. EPA
personnel explained that the difference between alternative 3 and 5 on
an annualized cost basis, is only $2,800 per ton. This translates into
a manufacturing cost increase of only 0.03 percent (from 0.15 percent
for alternative 3 to 0.18 percent for alternative 5). EPA also pointed
out that the controls being added with alternative 5 are on the handling
and storage of talc and ground limestone filler, both very fine materials.
Many plants already control these operations. To the suggestion that
EPA examine a new regulatory alternative (#6) which would impose controls
only on the saturator and blowing still, EPA responded that alternative
6 might provide a reasonable level of control for an existing plant, but
all facilities ought to be controlled at new plants. A committee member
concurred, stating that if a new plant is to be built, it should be
built right.
A committee member asked whether there is a mechanism for considering
and commenting on new test methods developed by EPA for specific industries.
EPA responded that the test method is proposed with the NSPS. Comments
are received on both simultaneously. There was considerable discussion
on this point, and it was suggested that information on new test methods
be disseminated before the NAPCTAC meeting. Don Goodwin promised to
consider this suggestion and said that, in the future, EPA would try to
get information out on new test methods earlier.
One committee member stated that the standards are reasonable and
all the plants in his agency area should be able to meet them. Another
expressed the fear that changes ocurring in the industry and in raw
11-65
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materials usage may make them difficult to meet. Several members expressed
surprise at the paucity of test data with Method 26, considering the
length of time it has been available. They faulted industry for not
conducting tests using Method 26, so they would know what affect the
NSPS would have. They also suggested that EPA consult with the industry
to see if more up-to-date test data are available. Don Goodwin responded
that EPA will do so and will inform the committee of the results of
these discussions. He noted that initial contacts with the Asphalt
Roofing Manufacturers Association in 1974, and subsequent contacts, were
not fruitful.
One committee member noted that the bubble concept has just been
approved. He asked how this affects the recommended standard for asphalt
roofing. It was explained that the bubble concept does not apply to
NSPS. Next, it was asked whether a plant operating under a bubble would
still be under the bubble if it modifies or reconstructs an affected
facility, or if it would come under the provisions of the NSPS. The EPA
response was that, if it met the requirements for a modified or reconstructed
affected facility, it would have to meet the NSPS. It was further
stated that the bubble would need to be reevaluated if sources within it
became subject to the NSPS and that some sources might also become
subject to LAER.
A committee member asked for clarification on the relationship
between LAER, BACT, and the NSPS. It was pointed out that the states
decide what LAER is. EPA can, upon request by a state or region, provide
advice on this subject for a particular industry. Mr. Goodwin noted
that a LAER guideline document for about 20 industries is due to be
released by EPA. He promised to send copies to all the NAPCTAC members
when it is published.
Some inconsistencies in the BID were pointed out by committee
members and industry representatives. EPA agreed to review the comments
and make corrections and clarifications as necessary.
Several industry speakers noted in their presentations that new
emission control techniques for the saturator and blowing still have
come into use since the EPA tests were performed. One commented that
some agencies tend to use the BID almost as a bible, so producers of
devices not mentioned in it find it difficult to sell their product.
Don Goodwin responded that EPA will consider preparing an addendum to
the BID to mention these other control techniques. A committee member
noted that improvements in technology are made constantly, so the BID
cannot be expected to always include the latest technology. He stated
that the industry will meet the standards with the best and most economical
equipment available. Another commented that the Clean Air Act requires
standards to be reviewed within four years of adoption. If the new
equipment is better, the NSPS will be revised to incorporate advances in
technology.
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Jim Siegfried, Johns-Manville, claimed in his presentation that
emission reductions cited by EPA are erroneous. He stated that new
plants built by Johns-Manville would be constructed like the Johns-
Manville plant tested by EPA, so the emissions reduction would be zero.
Asked by EPA whether Johns-Manville claims to be able to meet the recommended
NSPS without difficulty, he admitted that the plant tested by EPA is
questionable. A committee member stated that it is not of overwhelming
importance that the numbers accurately reflect emissions reductions
which will occur as a result of the NSPS. What is important is that
they are reasonable, based on the assumptions used. An EPA representative
explained that reductions were calculated from the SIP level. All
plants are assumed to be meeting the SIP. This is a reasonable assumption,
since some plants are better and some are worse. Another EPA spokesman
cited the intensive survey which was necessary to locate a well-designed
and operated afterburner controlling a blowing still. In response to a
suggestion that EPA also test the worst plants, it was pointed out that
emission tests are expensive, and therefore, we want to test only the
best.
One industry speaker, Bill Ricketts (Tamko), claimed that the
impact of the NSPS on the industry will be much greater than projected
by EPA. He agreed that a 2% growth rate is reasonable but stated that
the number of plants covered by the NSPS by 1985 will more likely be 55
than 3. He estimated that the industry, by 1985, would build 10 new
plants, close 5, modify 40, and reconstruct 5 damaged by fire. He noted
that the impact may be much greater for an old plant than a new plant.
A control device manufacturer questioned the EPA recommendation to
limit saturator control device inlet temperatures to the temperatures
reported during compliance tests. He stated that the saturator exhaust
temperature may be higher in summer than in winter because of higher
ambient temperatures. As designed, precooler operating characteristics
are not adjustable if the compliance tests are run in winter, so, it may
be impossible to reduce the control device inlet temperature in the
summer to the level reported during the tests. He noted that technology
allows control to within 10°F of the saturated (wet-bulb) temperature of
the saturator emissions, and recommended adoption of this limit. EPA
agreed to consider his comments.
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D. CORRESPONDENCE
1. Letter from CVM Corporation to EPA
CVM CORPORATION
402 VANDEVER AVENUE
WILMINGTON. DELAWARE 19802
(302) 654-7070
November 20, 1979
Midwest Research Institute
Suite 202
4505 Creedmoor Road
Raleigh, NC 27612
Attention: Mr. Pat Shea
Re: CVM Fume Eliminator Systems in
Asphalt Roofing Saturator Fume
Control Service
Gentlemen:
We are sending you the information you requested on CVM Fume Eliminator
Systems in asphalt roofing saturator fume control service.
A report on the performance of CVM Fume Control Systems is attached. We
have units in service at the following locations:
Certainteed Products Corporation, Avery, Ohio
Certainteed Products Corporation, Richmond, California
Celotex Corporation, Chester, West Virginia
To bring the issues into focus, we have prepared a cost comparison for
various fume elimination systems that have been used in this service (Table I).
All three systems are competitive in installed costs. On a no-bid basis, it is
unrealistic to assign an installed cost advantage of one over another. We have
elected to show all costing $200 - ?250,000 on a turnkey basis.
There is a basis for making an operating cost and performance comparison
because the operating costs speak for themselves.
There are two performance deficiencies in the HEAF and ESP systems. Both
are borderline in meeting 20% opacity levels particularly with heavy input load-
ings, and both have outages of sufficient duration to result in air pollution
complaints.
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Research Institute -2- November 20, 1979
On the basis of this conparison, we believe the CVM Fume Eliminator
System is a better way to handle this air pollution problem.
If you have any further questions, please do not hesitate to contact
us.
Very truly yours,
John L. WiUci
Enc: Table I
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TABLE I
COST COMPARISON
FUME CONTROL SYSTEM FDR SATURATOR ROOFING PLANTS
Process
Particulate Removal Efficiency
Opacity, Treated Exhaust
Odor Renoval
Proven On-Stream Efficiency
Installed Horsepower
Installed Costs
~ Element Replacement Cost/Year
-•J 1C.]
0 Power Cost/Year1 '
Maintenance Cost/Year
Total Operating & Maintenance
Costs
(Basis: 6
,000 hr/yr operation
CVM with Prefilter
$200
95-9%
5-10%
Acceptable
Over 98%
125
- $250,000
$10,600(2)
$27,900
at 30,000 CFM)
HEAP
95-98%
10-20%
Acceptable
90-95% (1)
300
$200 - $250,000
$ 7,000(3)
$67,000
ESP
95-98%
10-20%
Acceptable
' 60-90% (1)
100
$200 - $250,000
$10,000(4)
$22,300
$ 2,250
(6)
$ 4,500
(7)
$20,000
(8)
$40,750
$78,500
$57,300
* 'Estimated by CVM Engineers
/2i
v 'Based on two year element life, $4,000 prefilter
media cost.
* 'Replacement media, mist rejioval media.
IA\
^ 'Replacement parts, prefilter media.
(5)
(6)
(7)
(8)
Power Cost @ 5C/KWH.
150 MH/yr @ $15/hr.
300 MH/yr @ $15/nr.
Requires specialist at $15,500/yr. plus
300 MH misc. maintenance @ $15/hr.
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AIR POLLUTION CONTROL
OF
ASPHALT SATURATOR FUMES
by John L. Wilki, P.E., CUM Corporation
November 16, 1979
Asphalt roofing manufacturing operations generate particulate and gaseous
emissions, including polycyclic compounds, from the asphalt blowing and felt
saturating processes. In addition to lint and fugitive dust from talc, flint,
and solids handling, the particulate consists of hydrocarbon fume particulate
which is smaller than 1 micron in size. A further complication is that the
fume particulate tends to be sticky, thus presenting a serious challenge to
the performance and reliability of conventional air pollution control devices.
Fume-laden gas is exhausted from an asphalt roofing line from three zones:
(1) Asphalt saturator; (2) Drying Section; (3) Coating section. The exhaust
gases from all sources contain air-borne dust, and oil fume particulate as well
as some vaporized organic components. The asphalt saturation kettle is usually
at 400 - A50°F. The passage of felt into the asphalt and through the saturator
and related equipment generates air-borne oil fume and vaporized.organic compon-
ents. The temperature of the exhaust gas may vary from 120 - 180°F, depending
on hovi/ fast the line is operated and hovi/ u/ell the saturator and other fume
sources are hooded.
In general, asphalt roofing plants are located in areas where adequate air
pollution control can be achieved by first cooling the exhaust fumes to 100 -
125°F and then removing practically all of the physical particulate present at
that temperature. The air pollution control regulations generally specify the
following requirements: (1) The opacity of the treated exhaust gas shall not
exceed 20?o opacity; (2) The exhaust gas shall not cause odors or be a nuisance
at the property line; (3) The unit operation shall not create a noise problem.
Odor control is related to the particulate and vaporized organic content
of the treated exhaust gas. It has been our observation that removal of fume
particulate to achieve a 20?o opacity will not, in some cases, solve the related
odor problem. An exhaust gas treated to a lower opacity level will have less
of a residual odor problem. In the future, the EPA regulations may require that
a fume elimination device for this application achieve a treated exhaust gas
opacity of 5 - 10?o on a consistent basis, particularly since this higher stand-
ard of performance can be achieved in a competitively priced fume eliminator
proven in this application.
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-2-
This report is about three asphalt plants that are now using high efficiency
filtration fume control systems manufactured by CVM Corporation. The system for
this application (Figure I) consists of a fume eliminator having multiple fume
control elements and an oil scrubber - water quench tray, preceded by a prefilter.
The fume eliminator elements are made of fine fiberglass fibers packed in wire
cages in an annular configuration. The prefilter also uses renewable fiberglass
filter media. The purpose of the prefilter is to extend element life. . The scrub-
bing tray cools and conditions the exhaust gas prior to final treatment in the
fume eliminator elements.
Hot exhaust enters the prefilter where a fiberglass filter media removes
solids and "gunk". The exhaust then contacts a scrubbing tray on which sump oil
is recycled. A limited water flow controlled by a preset temperature control is
admitted to the recirculated oil phase on the tray to cool the hot exhaust as the
water evaporates to dryness. The required cooling is accomplished without creating
an emulsion or water phase in the sump oil. The sump oil may be burned as a fuel
oil component or, in some cases, recycled to the process. The exhaust, now cooled
to 100 - 125°F, passes through the fume control elements where the final removal
of fume particulate is achieved by conversion to oil droplets which drain to the
sump.
Because of the odor problem that relates to saturator exhaust gas, the hot
exhaust must be cooled to 100 - 125°F prior to air pollution control by .fume elim-
ination. This limitation applies to treatment in any fume eliminator that accom-
plishes air pollution control by removal of fume particulate. Three methods which
have been used for cooling hot saturator exhaust gas are the following: (1) Cold
air dilution; (2) Indirect heat exchange using a finned air-water heat exchanger;
(3) Water spray quench cooling. The fume eliminator system offers a fourth option,
namely, limited water spray quench cooling in the presence of an oil phase to cool
by evaporating water to dryness. The advantage of this option is that it is re-
liable, easy to operate, and it does not create a spray nozzle plugging problem
(because no fine atomizing water spray nozzles are required). Nor does it contrib-
ute to a water emulsion problem (because the limited amount of quench water used
is evaporated to dryness).
The concept of cooling by evaporation of water in direct contact with hot ex-
haust gas at 150 - 180°F without creating a water phase emulsion disposal problem
is unique. Because of the low gas temperature relative to the dew point of the
exhaust gas (est. 80 - 100°F, summer), it is practically impossible to create a
water spray fine enough and distribute it uniformly enough to cool the exhaust gas
to 100 - 125°F without creating a water phase (which is the result of unevaporated
water). Yet, this is consistently achieved in this fume eliminator system by using
a temperature controller preset to 10 - 20°F above the adiabatic saturation temper-
ature to admit a limited amount of water to an oil phase recirculated onto a scrub-
bing tray.
The prefilter was not included in earlier installations, and it may not be re-
quired in some applications. However, a prefilter is desirable when the fume elim-
inator is handling the exhaust from a large unit operating at relatively high speeds.
The purpose of the prefilter is only to remove inorganic dust, lint, and "gunk" from
11-72
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-3-
the exhaust gas to avoid premature fouling of the elements. It is a low mainten-
ance item which may only require indexing on a weekly basis (1 - 2 hours labor per
week) and replacement of media on a monthly basis (2-3 hours labor).
In the standard design for a CUM fume eliminator, the inlet face (dirty side)
velocity at the elements is 10 FPM, i.e., 10 CFM/sq. ft. dirty side element area.
This is very low. The filter face velocity relates to fouling time. As a general
rule, a fume filter operating at 10 FPM face velocity will last about three times
as long as a fume filter operating at 30 FPM face velocity in an identical service.
We would expect that a properly applied prefilter would extend fume control ele-
ment life in a plant operating 8,000 hours per year from one year to perhaps two
years or more.
An evaluation air pollution emission test was made at one plant to determine
the performance of the fume elimination system installed on an asphalt saturator
at a roof shingle plant. The test was made according to EPA Method No. 5, which
includes the use of a heated probe and a filter maintained in an EPA "Hot Box" at
about 250°F, and an impinger train immersed in an ice bath (to condense and col-
lect the moisture and condensibles). Only the stack outlet gas was tested. Six
points were sampled at each test port during the test runs which were conducted
on the outlet stack. The average oil accumulation in the sump at the time of the
test was 150 gal/day based on 24 hours operation.
The stack emission tests were made on October 24, 1978. The basic flow, tem-
perature, moisture, visual emission and odor performance results are shown in
Table I below:
TABLE I
PERFORMANCE DATA
Visual (2)
SCFM % Moisture Emissions
Run Temp. F (Dry) by Volume (1) Max. Avg. Odor (3)
Avg. 25,300 & 106°F 23,025 2.8% 10% 555 Noticeable
Notes:
(1) Moisture percent in Table I is corrected to stack conditions. It
was obtained by the condensate method and is the average for the
entire run.
(2) Visual emissions expressed as percent opacity. The allowable limit
is 20%.
(3) Odor is measured at test ports and is rated as extreme, irritant,
excessive, annoying, noticeable, trace or not detectable (N.D.).
Odor readings based on the observations of the test team members.
Note this is "test port" odor level - not "property line" odor.
11-73
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-4-
The ACFM and SCFM values in Table I and the flows used in the emission rate
calculation are based on simultaneous velocity readings made at the nozzle during
the sampling runs.
The data obtained from the initial traverse and the traverse on the stack
are sho\i/n below:
TABLE 1A
TRAVERSE DATA
% Moisture
Location ACFH @ Temp. F SCFM (Wet) by Volume*
Avg. 25,162 HI 107°F 23,740 1.45?o
*Moisture in Table 1A is at Stack conditions and is determined by
Wet/Dry bulb thermometer measurements.
The particulate emission rates for each run and the average are provided
in Table II below:
TABLE II
EMISSION RATES
Run
1
2
Avg.
Notes; SCF(d) = standard cubic foot, dry basis
* Dry Catch consists of solid particulate and liquid particles
(condensibles) with particle sizing generally greater than .3
microns (based on particulate). The Dry Catch is obtained from
the filter collection, nozzle, probe, cyclone, filter holder and
washes upstream of the filter.
** Wet Catch consists of particulates generally smaller than 1.0 -
1.2 microns (which passed through the filter), dissolved solids
and organics and non-volatile residue from the impinger collect-
ion and washes downstream of the filter.
# Total consists of Dry Catch plus Wet Catch.
//# Based on Rules of the Ohio EPS, Section 3745-17-11, Table I.
11-74
Dry Catch*
Gr/SCF(d)
.0011
.0015
.0013
Lbs/Hr
.21
.31
.26
Actual
Allowable ////
Wet Catch**
Gr/SCF(d)
.0031
.0061
.0046
- Lbs/Hr
.59
1.30
.94
Total #
Gr.SCF(d)
.0042
.0076
.0059
Lbs/Hr
.80
1.61
1.20
Lbs/Hr
45.9
-------
-5-
The calculated particulate removal efficiency is presented in Table III,
Efficiences would probably be even higher at higher inlet loadings.
TABLE III
PARTICULATE REMOVAL EFFICIENCY
GPP Lbs/Hr GR/SCF
Exhaust Gas After Treatment - 1.20 0.0059
Oil Removed from Hot Exhaust 150 50.0
Hot Exhaust Before Treatment 51.2 0.252
?o Removal of Particulate 91.7%
An evaluation test at another plant was made in June 1979. It also used
EPA Method No. 5, using a heated probe and a filter maintained in an EPA "Hot
Box" at about 250°F. The observed opacity was consistently 5?o or less, and the
dry catch was determined to be 0.0015, 0.009, and 0.0005 grains per dry stand-
ared cubic feet. Since these corresponded to particulate content of 0.16, 0.11,
and 0.06 Ibs/hr. in 15,400 CFM exhaust gas, the tests were well within EPA require-
ments.
The three CUM fume eliminators handling asphalt roofing saturator exhaust
gas have continued to perform without significant interruptions for maintenance.
There is no need to fine tune the system so that it runs as well on Thursday,
Friday and Saturday as it did on Monday, Tuesday, and Wednesday. The ultimate
limit is filter fouling. With a prefilter, the elements M/ill last more than a
year. Filter replacement usually requires a 4-man crew for two shifts. No crane
is required. The need for element replacement is readily anticipated and the
change can be made over a weekend. None of the plants have found it necessary to
hire a special maintenance specialist or even assign special part-time personnel
to operate the unit. Perhaps the greatest tribute to its performance is the com-
ment by the Ohio EPA that they have had no odor or opacity complaints relating to
this source since the CVM fume eliminator was installed on this plant approxim-
mately two years ago.
11-75
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FIGURE I
CVM FUME ELIMINATOR*
FOR ASPHALT ROOFING LINE EXHAUST
CLEAN AIR
Blower
s-O*j
FUME ELIMINATOR
Fume Control Elements
Temperature
Control
(to regulate
quench water)
FUME LADEN
EXHAUST
Prefilter
Oil Scrubbing Tray
PREFILTER
Quench
Water
Excess
Sump Oil
Oil Recirculation Pump
* Patent Applied For
11-76
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2. Letter from Chevron U.S.A. Inc.
Chevron
Chevron U.SA Inc.
555 Market Street, San Francisco, CA 94105 • Phone (415) 894-3252
Mail Address: P.O. Box 3069, San Francisco, CA 94119
BruceBeyaert December 5, 1979
Manager, Environmental Programs
Environmental Affairs
Mr. Don R. Goodwin, Director
Emission Standards and Engineering Division
United States Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
Dear Mr. Goodwin:
My November 16 letter to Mr. S. T. Cuffe commented on EPA's draft
of chapters 3 through 7 and appendices A through E of the draft
Draft EIS concerning new source performance standards for the as-
phalt roofing industry. In this prior letter, Chevron commented that
"EPA has done a very thorough job in preparing these portions of
the Draft EIS.
With this letter, Chevron would like to comment on the additional
materials enclosed with your November 7 letter to Mr. J. H. Dotter.
These additional materials included the Proposed Regulation, as
well as chapters 8 and 9 of the Draft EIS. Our detailed comments
on these additional materials are attached.
Although EPA has done a good job in most respects, we do have major
problems with the concept of requiring opacity limitations of 0%
and 5% for emissions from blowing stills and storage tanks, respec-
tively. As described in the attached comments concerning proposed
regulation Sections 60 .003(b) , (c) , and (d) , we believe that such
stringent- opacity limits are unprecedented and unnecessary. We
also believe that such stringent limits would create very difficult
enforcement, legal, technical, and practical difficulties. We urge
you to relax the proposed limits to 201 opacity, coinciding with a
No. 1 Ringelman limit.
I hope that these comments will prove useful to EPA and to the
NAPCTAC Committee. I would appreciate it very much if you would
assure that each member of the NAPCTAC Committee has the opportunity
to review this letter, either prior to or during the Committee's
December 12 meeting.
Sincerely,
}
BB:ah
Attachment
cc: Mr. S. T. Cuffe 11-77
100 Years Helping to Create the Future
-------
COMMENTS BY CHEVRON U.S.A. INC. ON
DRAFT PROPOSED REGULATION AND CHAPTERS 8-9 OF
EPA "DRAFT" DRAFT EIS CONCERNING PROPOSED
NEW SOURCE PERFORMANCE STANDARDS FOR
THE ASPHALT ROOFING MANUFACTURING INDUSTRY
Proposed Regulation
Section 60.003Cb) - Mass Limits:
The mass emissions limitation on an asphalt blowing still of 0.48
kg/rn^ (4 Ib./lOOO gal.) of asphalt charged to the still appears
reasonable based on collected EPA data summarized in Chapter 9 of
the EIR. However, we do not have adequate data to confirm whether
existing Chevron facilities can meet the proposed mass emissions
limitation.
Section 60.003Cb), Cc) and (d) - Opacity Limits:
We strongly object to the unnecessary, unjustified, and unprecedented
opacity limitations of 0% and 5% for blowing stills and storage
tank emissions, respectively. No NSPS to date has contained such
stringent opacity limitations. No documentation is provided to
justify such a significantly more restrictive opacity limit for
these small sources compared to the many larger sources for which
NSPS have been developed.
In addition, EPA Method 9 allows a certified observer to have a 15%
opacity error on any single reading and up to 7.5% average error.
Thus, enforcement of a 0% or 5% opacity limit would be technically
impossible and would place a significant, unjustified burden on
regulatory inspectors to monitor one emission source much more severely
than any other in a refinery, as well as on equipment operators.
Finally, the test data upon which the 0% and 5% opacity limits were
based are only one test run taken over 29 and 24 hours, respectively.
Such a limited data base does not allow for typical operational
variability encountered over a longer time period (e.g., 1 year).
Recommendation:
To avoid the major technical, legal, and practical problems outlined
above, we strongly urge that the opacity limit for emissions from
both asphalt blowing stills and storage tanks (60.003(b) and (c)) be
revised to not exceed 20% opacity, i.e., No. 1 Ringelman. More
stringent opacity limits can be justified only if EPA can document
that emissions from asphalt blowing stills and storage tanks are
significantly more harmful than emissions from other sources which
have NSPS.
11-78
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-2-
Section 60.004(b-d) - Monitoring:
Recording and storage of temperature measurements in the combustion
zone of an afterburner (incinerator) for two years is a reasonable
and useful method of indicating proper incinerator operation. Also,
the selection of temperature controls of 1400°F and a 6 hour time
period for determining excess emissions appear reasonable based on
available data.
Section 60.005(a) - Test Methods:
Methods 1, 2, 3, 9, and 26 appear reasonable for use in asphalt
operations.
Chapter 9: Rationale for the Proposed Standards
In general, the rationale for the proposed standards appears well thought
out and reasonable -- except for the proposed opacity limits as
discussed above.
Section 9.5 - Basis of Standard:
Other methods may be available for control of particulates from stor-
age tanks. For example, one of our refineries employs a condenser
system on asphalt tank emissions. This system injects fresh water
into the vented gases at three different locations. The oil/water
mixture is sent to the water effluent treatment system and the ex-
haust gases depart at near ambient temperature with no visible emis-
sions. Thus, it is appropriate to determine if other emission con-
trol devices exist in addition to a mist eliminator. We concur,
though, that an opacity limit, rather than a technology-based require-
ment is appropriate. As discussed earlier, we strongly encourage
adoption of a 201 opacity' limit rather than the proposed SI limit.
Section 9.7 - Selection of Emission Limits:
The second last line of this section on p. 9-13 contains a typogra-
phical error ("4.0 Ib./gal"), should read ("4.0 Ib./lOOO gal.").
Section 9.8 ~ Selection of Opacity Standard:
See discussion of Section 60.003, above.
Chapter 8: Economic Impact
Our analysis indicates that EPA has underestimated the cost of
emission controls by a factor of about 2. One of the major reasons
is that EPA has improperly handled capital cost. The capital charge
calculations assume that a company would employ debt funding at a
101 interest rate. This results in an annual capital recovery fac-
tor of 11.71 for 20-year equipment life. This is unrealistic for
the industry involved. Firstly, we believe that the calculations
11-79
-------
-3-
should be made on the basis of equity financing, as discussed on
page 8-31. Moreover, we believe quite strongly that a 15% actuarial
rate of return should be used. A 10% rate is simply too low for
a commercial facility. Use of equity funding with a 15% actuarial
rate of return (20-year equipment life, 50% income tax, etc.) yields
a 27% annual capital recovery factor,which is 2.3 times the factor
used by EPA. This is a very significant point, because capital
charges (table 8-44) represent about one-half of the total annual
cost.
11-80
-------
3. Letter from United Air Specialists, Inc.
i
Air Pollution Control and Energy Recovery Systems
December 20, 1979
Mr. Don R. Goodwin, Director
Emission Standards and Engineering Division (MD-13)
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
SUBJECT: Asphalt Roofing Manufacturing Proposed Standards
Dear Mr. Goodwin:
I was very interested in observing the workings of government to arrive
at standards for roofing plant emissions last week and would like to con-
pliment you on what I considered a fair balance of interests for all
parties concerned.
If it is not too late, I would like to incorporate the following Garments
in the meeting record. If this is not possible, then I would like for you
to consider them as pertinent information:
•*•
1. For asphalt saturators, it may be possible to evaluate the various basic
crude oil types by area of origin and maximum temperature for the air stream
entering the air cleaner. It is possible to use a relatively simple lab-
oratory test to establish the necessary temperature for condensation for any
product. A procedure like this would eliminate cooling (other than radiant
duct cooling) as a requirement in many applications.
e
2. There is very little deviation in efficiency with particle size variation
in the Penney type, two stage ESP. Therefore, adding multiple passes will
result in. removing particles from each pass at essentially the same efficiency
per pass and give insurance against loss of efficiency from lack of maintenance.
In areas where O opacity is a requirement, we have gone to as many as four
passes to give the customer a safety margin. Because of the extremely low
pressure drop and power requirements of only about 500 watts per pass, the
operating cost for each additional pass is negligible.
.3. Efficiency, reliability, and ease, of maintenance have all improved since
testing was performed on the SMOG-HOG in 1975. We continue to devote major
effort toward the ease of maintenance.
4440 CREEK RQAD.QNQNNATI.OHiO 45242 D PHONE (5131891-0400 D TELEX: 214-668 (UAS ON) a CABLE: UAS CINT!
11-81
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Page #2
December 20, 1979
Don R. Goodwin
4. The emissions from asphalt saturators have hydrocarbon aerosols that
are largely in the respirable fraction range. I am enclosing a size
distribution analysis from some EPA studyI believe. (I am submitting
this chart because I understood a comient in the meeting that asphalt par-
ticles were normally in the 10 to 25 micrometer range.
Again, my thanks to you and your staff for preparing a good meeting. Please
contact me .or Mr. Bruce McKenna, UAS Technical Director, at this office if
you have any questions on these comments.
Yours truly,
UNITED AIR SPECIALISTS, INC.
William A. Chene\
Vice President
WACrmek
Enclosure: Particle size distribution chart
11-82
-------
UJ
Ivl
20.0
10.0
. 9.0
ao
,7.0
•' » . .
; 3.0
5 20
i
j
4
4
i 10
> 0.9
\ 0.7
0.6
0-5
0.4
0.3
0.2
' O.I
«l
1
— -
—
—
— i
—
1
**
—
—
K
4p
^»
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•~r?^?
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I
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"rnr
-
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i
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J.LUll
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- •
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.. ._
"-'* *-^A
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i
i
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- •-«*-
-~i
/ j
s '
i
. ^_
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• yf~
i
•-•
•'•'-
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20 30 10 50
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GO 70 80 00 - 90 9
. .. HCRCEfIT BY WEIGHT SKAUER THA.'i ItJOICATtD SIZE
7 '••."• "- -'
Figure 4rr2 Particle size distribution
in uncontrolled saturator exhaust.
11-83
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III. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS
FOR BENZENE EMISSIONS FROM ETHYLBENZENE/STYRENE PRODUCTION
A. EPA PRESENTATION
Mr. Buddy Newman
Ms. Marilyn Tressel
Energy and Environmental Analysis, Incorporated
1111 North 19th Street
Arlington, Virginia 22209
The purpose of this briefing is to present the background information
and to review the draft regulation for benzene emissions from the ethylben-
zene/styrene industry.
SLIDE 1
This regulation is a National Emission Standard for Hazardous Air
Pollutants. Benzene was listed as a hazardous pollutant on June 8, 1977
and is subject to regulation under Section 112 of the Clean Air Act as
amended. The ethylbenzene/styrene industry is a source of benzene emissions
and should be regulated.
The proposed EPA Carcinogen Policy does not allow for any emissions in
excess of the standard; however, since in the EB/S Industry some excess
emissions are unavoidable, this analysis considers continuous and excess
emissions as separate topics.
SLIDE 2
The ethyl benzene and styrene industries are considered jointly for
regulation because of the physical integration of the processes. Also,
99 percent of the ethyl benzene produced is used to make styrene, and
styrene is made only from ethyl benzene.
The ethyl benzene industry consists of 14 companies producing ethyl ben-
zene by benzene alkylation or by mixed xylene extraction. The mixed xylene
extraction is a refinery process and will be covered under a separate
regulation. The styrene industry consists of 11 companies producing styrene
by ethyl benzene dehydrogenation or by ethyl benzene hydroperoxidation. Only
one plant used this process to produce styrene. The typical method of
III-l
-------
FIGURE 1
REGULATION OF A
HAZARDOUS POLLUTANT
• SECTION 112 PROVIDES FOR REGULATION OF HAZARDOUS
POLLUTANTS.
• BENZENE WAS LISTED AS A HAZARDOUS POLLUTANT
ON JUNE 8, 1977,
t ETHYLBENZENE/STYRENE (EB/S) INDUSTRY Is A SOURCE
OF BENZENE EMISSIONS AND SHOULD BE REGULATED,
FIGURE 2
ETHYLBENZENE/STYRENE INDUSTRY
NUMBER COMPANIES
PROCESS h® PERCENT OF PRODUCTION
INDUSTRY
• BENZENE ALKYLATION 95%
• MIXED XYLENE EXTRACTION ^
NUMBER COMPANIES . .11
PROCESS Ato
STYRBE INDUS™
• ETHYLBENZENE DEHYDROGENATION 50%
• ETHYLBENZENE HYDROPEROXIDATION 10%
INTEGRATED ETHYLBBffiE/ 10
STYPBE FACILITIES p^c^ OF STYRENE RRCDUCTION
III-2
-------
production is benzene alkylation followed by ethyl benzene dehydrogenation
in an integrated facility to produce styrene.
The proposed regulations will cover certain vents from benzene alkyla-
tion, ethyl benzene dehydrogenation, and ethyl benzene hydroperoxi.dation
processes.
SLIDE 3
In 1978, styrene production was slightly over 3,000,000 Mg/yr. In
1983, the projected styrene production will be over 4,000,000 Mg/yr.
SLIDE 4
There are three major uses for styrene, all of which are in the polymer
industry. Polystyrene used for packaging and disposable serviceware accounts
for over 60 percent of the styrene use. Acrylonitrile-butadiene-styrene
plastics and styrene-butadiene rubber make up over 30 percent of the styrene
use.
SLIDE 5
The total EB/S industry benzene emissions are 2,210 Mg/yr, most of
which originates from this model process type. This model styrene plant is
based on production of 300,000 Mg/yr of styrene using benzene alkylation,
followed by ethyl benzene dehydrogenation. The benzene emission rate for
the model plant is 69 kg/yr.
There are four benzene emissions sources from this model plant; these
are the alkylation reaction section, the ethylbenzene purification sections,
the dehydrogenation reaction section, and the styrene purification section.
The alkylation reactor and the catalyst treating section emit benzene at
the rate of 11 kg/hr. The ethylbenzene purification section is composed
primarily of atmospheric and pressure distillation columns. In the dehydro-
genation reaction section, the emission vent from the hydrogenation separa-
tion section is, in most cases, vented to the process superheater because
of its high heating value. The emission rate of one kg/hr represents the
controlled emission rate. The styrene purification section is composed
primarily of vacuum distillation columns and emits 12 kg benzene/hr.
SLIDE 6
The other process type analyzed for regulation under this standard is
the ethylbenzene hydroperoxidation process. Only one plant uses this
process to produce styrene in an air oxidation process along with propylene
oxide.
There are two emission points in this process—the ethylbenzene oxida-
tion reactor and the styrene purification section. The oxidation reactor
vent emits four kg/hr benzene in a high-flow gas stream. Th.is stream is
dilute in benzene with a 20 ppmv concentration. We are still studying
whether this stream should be covered under this regulation; at present,
this vent is not covered.
III-3
-------
FIGURE 3
ETHYLBENZENE/STYRENE PRODUCTION
1S78
1983
CAPACITY
UTILIZATION, %
PRODUCTION,
MG/YR (TONS)
ETHYLBENZENE STYRENE
70
3,319,000
(3,651,000)
78
3,192,000
(3,511,000)
ETHYLBENZENE STYRENE
90
4,248,000
(4,672,800)
100
4,086,000
(4,494,600)
FIGURE 4
MAJOR USES OF STYRENE
USE, I
POLYSTYRENE
• PACKAGING
• DISPOSABLE SERVICEWARE
ACRYLONITRILE-BUTADIENE-STYRENE (ABS) PLASTICS,
• PIPES
• AUTOMOTIVE PARTS
STYRENE-BUTADIENE RLBBERS (SBR).
• PNEUMATIC TIRES
.20
11
III-4
-------
BENZENE
FIGURE 5
MODEL STYHENE PLANT
69 kg/hr BENZENE
45 kji/lir
ETIIYLCNE
ETtlVLBENZILNE
ALKYLATION ETI1YLBENZENE
REACTION SECTION PURIFICATION SECTION
DEIIYOROGENATION REACTION SECTION
STYRENE PURIFICATION SECTION
-------
FIGURES
ETHYLBEIMZENE
HYDROPEROX1DAT10N PROCESS
ETHYLBENZENE
PROPYLENE
PROPYLENE OXIDE
AIR
±
OXIDATION
REACTOR
EPOXIDAT10N
REACTOR
DEHYDRATION
STYRENE
SXYRESE
4 kg/hr
19 kg/hr
III-6
-------
The styrene purification system is very similar to the one in the
dehydrogenation process. This emits 19 kg/hr of benzene.. From these two
EB/S processes, the regulation will cover the atmospheric and pressure
columns, vacuum columns, the alkylation vents, and the hydrogen separation
vent.
SLIDE 7
There are four control techniques to reduce benzene emissions. These
techniques apply to both new and existing sources of benzene emissions.
These are product recovery, combination of product recovery and combustion,
combustion alone, and substitutes for styrene.
Under product recovery, condensation could be used to control streams
with high benzene concentration for over an 80 percent efficiency. Absorp-
tion could be used to control other vents at an efficiency of less than
99 percent. In combination, product recovery could yield an overall effi-
ciency of 85 percent.
Condensation and absorption coupled with a flare could yield a 94 percent
reduction in benzene emissions. This is based on an assigned flare efficiency
of 60 percent.
With combustion alone, routing of waste streams to an existing boiler,
process heater, or incinerator could achieve 99 percent benzene emission
reduction. A flare could also be used to control benzene emissions from 60
to 99 percent. This is presented as a range because there is little conclu-
sive flare data. The flare is assigned a 60 percent efficiency as a con-
servative estimate.
Substitutes for styrene would involve closing all domestic ethylbenzene
and styrene production facilities. Along with substitutes for styrene,
these control techniques can be applied to the EB/S industry as regulatory
options.
SLIDE 8
The 85 percent regulatory option would involve routing the benzene/
toluene column vent and the atmospheric and pressure column vents to conden-
sers. The other vacuum column vents and the reactor vents are routed to a
polyethylbenzene scrubber to achieve around.99 percent reduction. This
would give an overall benzene reduction of 85 percent.
This configuration, along with a 60 percent flare, results in 94 percent
benzene reduction.
SLIDE 9
The 99 percent regulatory option would rnvolve routing the vacuum
column vents, the atmospheric and pressure column vents, the alkylation
reactor vents, and the hydrogen separation vent to an existing boiler.
III-7
-------
FIGURE?
CONTROL TECHNIQUES AND EFF1C1ENCES
TEO-NIGUE EFFICIENCY, %
PRODUCT RECOVERY
t CONDENSATION . 85
• ABSORPTION
COMBINATION PRODUCT RECOVERY AND COMBUSTION
• CONDENSATION AND ABSORPTION COUPLED WITH FLARING 34
COMBUSTION
• ROUTING OF WASTE STREAMS To BOILER OR PROCESS HEATER 99
• INCINERATION 99
• FLARING 60-99
SUBSTITUTES FOR STYRENE ICO
III-8
-------
FIGURE 8
SCHEMATIC OF 85% AND 94% REGULATORY OPTION
FLARE HEADER
CONDENSER
D
t
BENZENE/
TOLUENE
COLUMN
VENT
FLARE
KNOCKOUT
DRUM
ATMOSPHERIC/
PRESSURE
COLUMNS
PACKED
TOWER
OTHER
VACUUM
COLUMN
VENTS
ALKYLATION
REACTOR
VENTS
-------
FIGURE 9
99% REGULATORY OPTION
VACUUM
COLUMN
VENTS
ATMOSPHERIC/
PRESSURE
COLUMN VENT
ALKYLATION
REACTION
AREA VENTS
T
EXISTING
BOILER
V
NATURAL
GAS
OXYGEN
MONITOR
I
HYDROGEN
SEPARATION
VENT
-------
SLIDE 10
Under the proposed EPA Carcinogen Policy, specific steps are taken to
select the best means of controlling a hazardous air pollutant. First,.
based on applicable control techniques, the regulatory options are identi-
fied. Next, the environmental, energy, and economic impacts of each of the
regulatory options are examined. Then, based on these environmental,
energy, and economic impacts, the best available technology CBAT) is
selected. Finally, the maximum lifetime risk and annual deaths attributable
to the emissions after the application of BAT and for the next most stringent
option (the beyond.-BAT option) are considered to determine whether the risk
reduction versus the cost increase of going from BAT to the next most
stringent option is not unreasonable.
SLIDE 11
Nationwide environmental, energy, and economic impacts are the basis
for selecting the best control level for the standard. Based on the pre-
viously discussed controls, four regulatory options were examined for their
impacts: 85 percent, 94 percent, 99 percent, and 100 percent.
Energy use ranges from a cost of 1,800 bbl oil/yr with 85 percent
control to a savings of 120,000 bbl oil/yr with 99 percent control. However,
all represent less than one-tenth percent of the total energy demand of a
plant. The estimated annualized costs are based on 1978 Fourth Quarter
dollars. The annualized costs are actually savings which result from the
recovery of fuel or product. The percent product price is based on the
maximum price increase required to recover costs for one company. Although
this price increase is expected to be experienced only by Sun Oil Company,
there is nothing prohibiting other companies from raising their prices
accordingly. Nationwide emissions for each level of control are 685 Mg/yr
for 85 percent, 350 Mg/yr for 94 percent, and 80 Mg/yr for 99 percent. All
other environmental impacts are negligible.
Based on this assessment, the 99 percent control was selected as the
best available technology (BAT).
SLIDE 12
Lifetime risks and annual deaths were examined to determine the cost
of going from BAT to the next most stringent option, or beyond-BAT, for
total plant emissions. Risks and deaths are based on the total of 2.5
million people residing within 20 kilometers of an existing facility. Risk
represents the probability of someone dying of leukemia who has been exposed
to the maximum annual average benzene concentration for a 70 year lifetime.
For example, the maximum lifetime risk would be the probability of one
death per 5900 people in a 70 year lifetime.
If the best available technology CBAT) is applied to plant-wide emis-
sions, the lifetime risk would be 1.7 x 10~4 to 1.2 x 10~3 and the annual
deaths would be .03 to .19. Beyond-BAT or the 100 percent control option
would eliminate the. possibility of risks and deaths from these emissions.
However, 100 percent control would have severe economic impacts. There-
fore, we determined that the residual risks remaining after the application
of BAT were not unreasonable.
III-ll
-------
FIGURE 10
METHODS FOR REGULATION UNDER
PROPOSED EPA CARCINOGEN POLICY
• IDENTIFY REGULATORY OPTIONS BASED ON CONTROL TECWIQUES,
• EXAMINE ENVIRONMENTAL, ENERGY, AND ECONOMIC IMPACTS OF
REGULATORY OPTIONS,
• SELECT BAT,
• EXAMINE RESIDUAL RISK WITH BAT,
• CONSIDER BEYOND-BAT OPTION,
FIGURE 11
NATIONWIDE ENERGY AND ECONOMIC IMPACTS
OF CONTINUOUS EMISSIONS CONTROL
IMPACT
ENERGY, BBL OIL/YR
(SAVINGS)
CAPITAL COSTS, $
ANNUALIZED COSTS
(SAVINGS), $
PRODUCT PRICE a $463/MG
CLOSURES
TOTAL NATIONWIDE
EMISSIONS, MG/YR
LEVEL OF CONTROL, %
85
1,800
1,400,000
(600,000)
0,15
0
685
94
6,000
3,100,000
(200,000)
0,46
0
350
99
(120,000)
3,400,000
(460,000)
0,27
0
80
100
(*)
*
*
«
17
0
•EXCESSIVE IMPACT
111-12
-------
FIGURE 12
LIFETIME RISK AND ANNUAL DEATHS FOR
DETERMINATION OF BEYOND BAT
FOR TOTAL PLANT EMISSIONS
PLANTWIDE EMISSIONS
BAT
. BEYOND BAT
LIFETIME RISK
LTxlO"4 - L2xlO"3
0
ANNUAL DEATHS
0,03 - 0-19
0
ni-13
-------
SLIDE 13
The control techniques for excess emissions are similar to those for
continuous emissions and all assume timely maintenance and repair. The
techniques used to achieve 60 to 99 percent control are recycle and flare,
which are currently used in some EB/S facilities. Recycling redirects the
stream back to the hydrogen separation compressor inlet, and retains and
compresses the stream until conditions are suitable for ft to enter the
boiler. Flaring involves manifolding various vent streams to a properly
sized flare for thermal destruction. Ninety to.100 percent control is
obtained by recycle, flare, and dual compressor. The boiler differs from
that required for continuous emissions in that ft requires complex control
and safety equipment because of variable stream flow and composition.
100 percent control requires substitutes and closure of all EB/S facilities.
SLIDE 14
We next examined the environmental, energy, and economic impacts for
each regulatory option identified. The nationwide energy and cost impacts
of excess emission control varies with each control technique. However, in
each case, the energy impact is less than one-tenth percent of total energy
demand of .a plant. The installed capital costs are smallest for the recycle/
flare option at $524,000 and range from ten to 30 times greater, respec-
tively, for the recycle/flare/dual compressor (.$5,500,000) and for the
boiler/flare ($15,500,000) options. Excess emissions are 21 Mg/yr for
the recycle and flare option, ten Mg/yr for the recycle/flare/dual compres-
sor option, and one Mg/yr for the boiler/flare option.
Based primarily on the high costs of the recycle/flare/dual compressor
and the boiler/flare options, the recycle/flare option was considered the
best available technology (BAT).
SLIDE 15
The risk reduction was compared to the cost increase of going from BAT
to the next most stringent option, or beyond-BAT, by examining the lifetime
risk and annual deaths for excess emissions. Based on 2.5 million people
residing within 20 km of an existing facility, risk represents the proba-
bility of someone dying from leukemia who has been exposed for a 70 year
lifetime to maximum annual benzene concentrations. With BAT, the lifetime
risk would be 1.7 x 10"' to 1.2 x 10~6 and the annual deaths would be
8.7 x 10~5 to 5.7 x 10~4. Beyond BAT, the lifetime risk would be reduced
to 5.3 x 10~8 to 3.7 x 10"77 and the annual deaths would be 1.7 x 10"7 to
1.4 x 10~4. Although risks and deaths are reduced with the beyond-BAT
option (recycle/flare/dual compressor), the high cost which would result
from this control level would severely impact the EB/S industry. There-
fore, the residual risks remaining after the application of BAT are con-
sidered not unreasonable.
SLIDE 16
After selecting BAT for both continuous and excess emissions, the next
step was to select a format for the standard. Two objectives existed in
111-14
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FIGURE 13
REGULATORY OPTIONS
FOR EXCESS EMISSIONS
LEVEL OF CONTROL, 7*
60 TO 99
90 TO 100
99
100
CONTROL TECHNIQUE
RECYCLE AND FLARE
RECYCLE, FLARE/ AND
DUAL COMPRESSOR
BOILER AND FLARE
SUBSTITUTES AND CLOSURE
FIGURE 14
NATIONWIDE ENERGY AND COST IMPACTS
OF EXCESS EMISSIONS CONTROL
IMPACT
ENERGY, BBL OIL/YR
INSTALLED
CAPITAL COST, $
EXCESS EMISSION
iWYR
CONTROL TECHNIQUE
RECYCLE/FLARE
11,500.
524,000
21
RECYCLE/FLARE/
DUAL COMPRESSOR
11,100
5,500,003
10
BOILER/FLARE
U,1CO
15,500,000
1
111-15
-------
FIGURE 15
LIFETIME RISK AND ANNUAL DEATHS
FOR DETERMINATION OF BEYOND BAT
FOR EXCESS EMISSIONS
EXCESS EMISSIONS
BAT
BEYOND BAT
LIFETIME RISK
L/xKT7 - L2XKT6
SJxlO"8 - 3,7xllT7
ANNUAL DEATHS
8,7xlO"5 - SJxlO"4
1 JxlO'5 - l.MO"4
FIGURE 16
SELECTION OF NUMERICAL
EMISSIONS LIMIT
• /Vcco TEST RESULTS SHOW 9-10 PPM BENZENE,
t EL PASO TEST RESULTS SHOW <2 PPM BENZENE,
• /Voco RESULTS ARE HIGH DUE To CONTAMINATION,
• EMISSIONS LIMIT SET AT 5 PPM.
111-16
-------
selecting.the format: (1) simplify measures and (2) avoid formats which
discouraged fuel or product recovery. With these two objectives in mind,
there were three options considered: a mass standard, a standard based on
percent reduction, and a standard based on concentration levels. Mass
standard was rejected because of complex measurement. Percent reduction
was rejected because it may discourage product recovery. Because a concen-
tration would meet both objectives, it was chosen as the format for the
standard.
It was then necessary to apply the level of control for the standard
(99 percent) to a concentration level. The numerical emissions limit under
99 percent control was determined by running tests on boilers at two
facilities. The El Paso test results show less than two ppm benzene was
achievable. The Amoco test results show nine to ten ppm benzene was achiev-
able. Amoco results are considered high due to contamination. Therefore,
to provide a cushion for variations in design, the emissions limit was set
at five ppm. In addition, another test will be done at the Amoco facility
in January.
SLIDE 17
The recommended standard for continuous emissions is five ppmv, refer-
enced on a dry basis to three percent oxygen to avoid dilution. Method 110
and continuous monitoring is required. (These are discussed on another
slide.)
The recommended standard for excess emissions is based on recycle/
flare configuration. With a smokeless flare, the maximum time for flare
use is two hours during startup, two hours during shutdown, and at all
times during malfunction. The time limit should encourage recycling or
alternate means of control during the remaining hours of startup and shutdown.
SLIDE 18
The recommended monitoring requirements, include continuous benzene
emissions monitoring to be measured with a gas chromatograph and flame
ionization detector (GC/FID). The advantage of this method is that benzene
is measured directly. However, one disadvantage is that the control of all
regulated streams is not ensured. For example,, a major stream could be
vented while other, insignificant streams are sent to the boiler with no
noticeable change in emissions. Secondly, GC/FID is expensive, particularly
in light of the fact that it does not meet all monitoring objectives.
SLIDE 19
Because the recommended monitoring method does not meet all the objec-
tives, alternate methods were considered. Engineering data show that if
the boiler operates correctly, then emission limits will be achieved.
Therefore, an objective of monitoring is to make sure boi'lers are operating
properly and all streams are going to it.
A combination of alternative monitoring recommendations includes the
measurement of firebox temperature and flue gas oxygen levels for checking
111-17
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FIGURE 17
RECOMMENDED STANDARD
• CONTINUOUS EMISSIONS
t 5 PPMV REFERENCED ON A DRY BASIS To 3% OXYGEN,
BASED ON TESTS OF BOILERS AND PROCESS HEATERS
• METHOD 110 AND CONTINUOUS I^NITORING
• EXCESS EMISSIONS
• RECYCLE/FLARE CONFIGURATION FOR EXCESS EMISSIONS
• SMOKELESS FLARES
• FLARE USE
• MAXIMUM OF 2 HOURS DURING STARTUP
• MAXIMUM OF 2 HOURS DURING SHUTDOWN
t ALL TIMES DURING MALFUNCTION
FIGURE 18
MONITORING REQUIREMENTS
CONTINUOUS BENZENE MEASUREMENT WITH GC/FID,
a ADVANTAGE:
BENZENE Is MEASURED DIRECTLY,
• DISADVANTAGES:
CONTROL OF ALL REGULATED STREAMS is NOT ENSURED,
GC/FITJ SYSTEM IS EXPENSIVE,
111-18
-------
FIGURE 19
ALTERNATIVE MONITORING
RECOMMENDATIONS
COMBINATIONS OF MEASUREMENT OF FIREBOX TEMPERATURE, FLUE GAS OXYGEN
LEVELS, AND STREAM. FLOW WITH VISUAL CHECKS OF VALVES,
9 ADVANTAGES:
MEASUREMENT Is CURRENTLY BEING DONE AT PLANTS,
APPROPRIATE BOILER EFFICIENCY Is INDICATED,
ALL REGULATED STREAMS ARE MONITORED,
• DISADVANTAGE:
BENZENE Is NOT MEASURED DIRECTLY,
boiler operation, measuring stream flow, and visual checks of valves for
checking stream routing.
The advantages of these monitoring techniques are that many of the
measurements are currently being done at plants, appropriate boiler effi-
ciency is indicated, and all streams covered by the standard would be moni-
tored. The disadvantage is that benzene exiting the control device is not
measured directly.
111-19
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B. ETHYLBENZENE/STYRENE PRODUCTION INDUSTRY PRESENTATIONS
1. Monsanto Company
Dr. Harry M. Walker
Senior Environmental Specialist
Box 711
Alvin, Texas 77511
Mr. Goodwin , members of the National Air Pollution Control
Techniques Advisory Committee, ladies and gentlemen. I am Dr. Harry M. Walker of
Monsanto. I hold a Ph.D. in organic chemistry. I joined Monsanto in 1949 as a
staff member at its Texas City styrene monomer plant. Since then I have been
associated with this operation in some capacity for nearly 26 of the past 30 years
in research, process technology and for the past eight years in air pollution con-
trol. For the past three years I was co-chairman of the Technical Committee of the
Houston Area Oxidants Study and chairman of its Health Effects Task Force. I am
thoroughly versed in atmospheric chemistry as well as in the science and technology
of air pollution and its control and I am, of course, intimately familiar with the
technology of ethylbenzene and styrene production.
I am here today to present Monsanto's comments on the draft National Emissions
Standard for Hazardous Air Pollutants for Benzene Emissions from Ethylbenzene/
Styrene Plants.
I recognize that the NAPCTAC group concerns itself solely with control technology,
feasibility, economics and related technical matters. Therefore my comments will
address these areas. However, I wish to first touch on the background of this
entire proceeding.
111-20
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-2-
Monsanto has consumed very large quantities of benzene during the past 37 years
at its Texas City styrene plant. During this period I am unaware of any cases of
adverse health effects attributed to benzene among the work force. While I would
hardly present my personal observations as a valid epidemiolbgical study, I do find
-
them reassuring and am confident that the practices followed by Monsanto for thasa
A
do provide adequate protection against benzene.
I was personally well trained to respect benzene while a graduate student at the
University of Minnesota in the mid-40's. After joining Monsanto I was even more
strongly indoctrinated in the safe handling of this material.
My personal experience has therefore been that the facts about benzene have long
been known both to industry and to academia and that, based on these facts, sound
operating practices have long been in place in the styrene industry which have
protected the workers and the public.
Monsanto has previously presented testimony on benzene emission control proposals
i
in connection with maleic anhydride manufacture and with linear alkyl sulfonate
manufacture. It has also contributed to comments on the same subject presented by
the Chemical Manufacturers Association. I will not attempt to repeat any of this
testimony but by attached references am making it also a part of the record of this
hearing.
In substance Monsanto doubts that justification exists for the regulation of benzene
from ethylbenzene/styrene manufacturing as a hazardous air pollutant. Ethylbenzene/
styrene manufacture is perhaps the environmentally cleanest of the billion pound/year
scale organic manufacturing processes.
111-21
-------
-3-
I shall now proceed to examine the proposal in light of the technical considerations
which are appropriate today.
The proposal before us would limit the benzene concentration present in any process
vent or presumably any combustion stack in any ethylbenzene/styrene plant to <5 ppm
by volume. We find such a proposal to be totally inappropriate for regulatory pur-
poses because among other reasons concentration alone without reference to flow does
not measure the extent of the emission.
Thus a fixed roof 500,000 gallon storage tank with vent condenser containing benzene
would show 60,000 ppm benzene at its vent yet have a standing emission loss of less
than 2 T/year. Conversely a medium sized industrial boiler when used as an abatement
device would still emit 21 T/year with a stack gas benzene concentration of only 5 ppm.
We therefore disagree with the basis for the selection of a standard format as dis-
cussed on pages 25, 26, and 27 of the draft document. A straight mass emission
standard is the simplest, most direct, and most meaningful of all. We strongly object
to the effluent concentration standard because it cannot quantify the significance of
the emission. We object to the percent reduction standard because of the continual
ambiguity of the starting basis and its frequent variability. Thus the compliance
status of an abater can shift from compliance to noncompliance with feed concentra-
tion alone when the unit's performance has in fact remained unchanged. We believe that
a mass factor emission limit expressed in pounds per ton of product or feed is the
best approach to this type of regulation.
The 5 ppm limit proposed does not appear to be based upon any demonstrated neces-
sity for such a low limitation. The degree of over-regulation being proposed is
111-22
-------
-4-
delineated in the data presented on page 17 of the document and on Table B-3 of
the Background document. '
Using the1 recently proposed OSHA workplace standard of 1 ppm as a possible basis
for the protection of human health the controlled concentrations of .04, .02 and
'.02 ppm at 160' meters downwind represent over regulation of 25 or 50 fold. How-
ever since 160 meters downwind would still be within the fenceline of most plants
a' value at 2000 meters or about 1 mile downwind would be more appropriate. At
this distance the concentrations (taken from Table 3-3 and converted to ppm) would
be .001, .00086 and .00057 ppm for the three options. Thus over regulation ratios
of 1000, 1162 and 1754 are indicated. While we are aware of arguments that contend
that TLV values are only for healthy adults and that allowances have to be applied
to cover the young-, the old, the sick, the poor and other groups and to allow for
24 hour exposures; we know of no multipliers that would fall within many orders of
magnitude of those which are apparently implicit in the regulation proposed.
We make these comparisons to the proposed OSHA standard only for reference to a level
which appears to have Federal sanction for the protection of health. We note that
this standard has been rejected in Federal court.
*
,To place the 5 ppm value further in perspective we note that the proposed standard
for maleic anhydride plants using benzene as a raw material is 0.30 grams of benzene
vapor emitted per 100 grams of benzene entering the process. This is equivalent to
approximately 94% destruction in the control system and 44 ppm of benzene in the flue
gas from a thermal incinerator. There is no apparent reason to make the standard for
existing styrene plants stricter than the standard for existing maleic anhydride
plants.
"1-23
-------
-5-
Benzene is present in non-catalyst equipped automobile exhaust emissions to the
2
extent of about 75 ppm. This figure drops to 20 ppm for catalytic converter-
3
equipped automobiles with less than 20,000 miles of service. We note that these
levels are far higher than the control levels proposed for EB/styrene plants. In
fact should the entire U. S. vehicle fleet attain the 20 ppm figure, which it
certainly won't, that the annual emissions from this source would be about 40,000
tons/year. Conversely the claimed emissions from the EB/styrene industry which
the document addresses are 2,436 T/yr. or only 6% of the most optimistic automo-
tive total.
Similarly we note that gasoline contains an average of 1.3% benzene. The vapors
5
above 'this gasoline similarly contain an average of 2400 ppm of benzene. These
levels continue to increase as the regulation-induced trend to non-leaded gasoline
progresses. Gasoline tank vapors are increasingly being breathed at close range by
motorists as they fuel their vehicles. This problem has significantly been enhanced
by regulatory action which has banned automatic latches on the pump handles. We
motorists are therefore forced to breathe within arms length of the tank filler the
fumes which seem to aggressively seek us out despite serious efforts to avoid them.
Compared to this hazard any contribution from EB/styrene plants is indeed trivial.
During the past several years I have been closely associated with the Houston Area
Oxidants Study. As a portion of this program HAOS conducted extensive ambient
hydrocarbons analysis including benzene. More than 150 samples taken over three
months at four urban Houston sites yielded an average benzene value of 7.0 ppb.
While these samples were predominantly taken at 6-9 a.m. in one industrial and in
three non- industrial areas; sampling over much longer periods yielded only slightly
111-24
-------
-6-
lower values and site to site variations were small. Thus we can state rather
firmly that the ubiquitous automobile exhaust benzene background in urban areas
such as Houston is about 7 ppb.
To judge possible affects on these background levels we have used the Climatological
Display Model to calculate the impact of possible uncombusted benzene emissions
from our largest plant abatement boiler. From this we conclude that if our
boiler should suddenly cease to destroy benzene and in effect vent the entire stream
it would emit 41 ppm in the stack. However this will only raise the annual back-
ground at the maximum point downwind in Texas City by an insignificant 0.28 ppb.
This calculation sharply refutes the necessity of a standard as low as 5 ppm in the
stack.
Monsanto's EB/SM plant represents about 17% of the industry. Presumably 17% of
these emissions or 414 Tons are attributed by EPA to this plant. This contrasts
with actual benzene emissions recently re-audited for the plant at only 16.5 T/year —
a figure which includes storage emissions. From Monsanto's experience therefore we
would suggest that the 2436 T/yr. (2210 Mg/yr) figure of the report represents a
significant overestimation of the total benzene emission from one of the inherently
cleanest of the major chemical production processes.
Monsanto finds no justification for any level of new benzene controls, certainly not
those demanded by subject document. We feel that we perhaps have the cleanest plant
in the industry. From the information on page 35 the Administrator apparently assumed
that our plant could meet all option levels as it now stands. However this is not so.
The 5 ppm level probably cannot be met in a combustion stack on a routine basis. In
this respect we find the data presented contending this to be most unconvincing.
111-25
-------
-7-
Many styrene plants use steam boilers and steam superheaters to serve the joint
function of hydrocarbons destruction and fuel value recovery. Recent tests at our
plant involving the destruction of waste hydrocarbons from another process suggest
that destruction efficiencies may be considerably reduced in boilers and heaters
containing heat transfer surface within the fire-box itself. The quenching action
of rapid heat removal seems to stop oxidation short of complete destruction. Certainly
no standard such as the one proposed should be promulgated prior to definitive testing
of this phenomenon in appropriate units.
We are also aware that the destruction level achieved for traces of hydrocarbons in
vapor streams is very significantly dependent upon the degree of mixing in the fire-box
and whether the material actually passes through the flame or not. The oxygen content
and the BTU value of the streams burned are also variables of major importance to the
level of destruction.
I wish to stress that the use of boilers and superheaters to destroy pollutant hydro-
carbons is .both cost and energy efficient. However their operation will be controlled
to maximize their effectiveness in their ordinary process function. They cannot be
run for maximum benzene destruction efficiency hence cannot normally be expected to
reach their best potential performance in this service. No Standard should be pro-
posed that does not properly allow for these operating restraints.
We note that one steam superheater at the El Paso plant in one test achieved a stack
benzene level below 5 ppm. Of course a styrene plant steam superheater transfers
heat into the process at process temperatures in excess of 1500°F —certainly one of
the highest levels in industry. Thus its fire-box temperature is extremely high —in
excess of 2200°F and is also large in volume. This combination of high temperature
111-26
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-8-
and long residence time means that such units can be very effective hydrocarbons
incinerators. However we doubt that proposing an emission standard based on
averaging this result with that from a lesser unit is statistically sound.
As a practical matter some producers may have to retrofit their benzene-containing
streams into existing boilers where furnace temperatures and residence times are
low and quench rates are high. Such units are unlikely to meet 5 ppm in the stack.
We presently lack sufficient data to yet establish definitive levels but concentra-
tions more than an order of magnitude greater are possible. Clearly a ppm approach
to control is fraught with technical uncertainty.
While we reiterate our firm conviction that, no special standard is justified for
EB/styrene plants we must observe that a mass factor standard, of 0.1 # per 100 Ibs.
of feed, is much more practical.
I am concerned that our plant could not meet a 5 ppm standard in combustion units
where benzene is abated. One major point is simply that the standard addresses
performance essentially 100% of the time. If the capability under the best condi-
tions is barely at the standard level then the standard will not be met at all times.
This performance deficiency between peak' and average is always present and must be
given proper weight in establishing any level of BACT.
Monsanto believes that where combustion processes are employed to control benzene
that control levels should be set well within the capability of the procedures. We
do not believe continuous monitoring is necessary to determine compliance because if
111-27
-------
-9-
certain parameters such as excess air or key process temperatures are in the correct
range the destruction level is determined by the physical hardware in place and is
unlikely to deviate significantly.
We find the cost of in-plant continuous chromatographic analyzers to be $50,000
each plus $5000 per point monitored. In addition they have very high maintenance
expense. These considerable costs are unnecessary. We recommend that compliance
be determined only in the simplest possible manner to reasonably guarantee abatement.
This would be operator log certification of stream flows to the combustor devices
plus log records of flows, temperatures, etc. from conventional process instruments.
We also find that the provision designed to limit flaring to two hours during
startup and shut down is impossible to meet in our dehydrogenation unit where a
36-hour warmup period is normally required. However we see no problem —little
benzene would flow to the flare under warmup conditions and our flare is a good
one which we believe is efficient in benzene destruction. We feel that the difference
in benzene emissions between the flare and the superheaters for the few hours per year
the flare is used is insignificant. We need no regulatory incentive to burn the off-
gas in the superheaters —we estimate our economic loss to be $100,000 per day when
this stream is flared. Obviously we avoid this loss whenever possible.
One other point we must make —we monitor all hydrocarbon containing streams origi-
nating in vacuum systems and going to combustion processes for oxygen content.
When the explosive range is approached we take appropriate action. In some cases
this means venting the dangerous stream before an explosion can occur. Such streams
111-28
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-10-
cannot be flared in this situation without extreme hazard. Thus a regulation
requiring flaring during all types of upsets is not practical since it would pre-
sent an unacceptable safety hazard to persons and equipment.
While Monsanto controls its major vents rigorously by combustion processes we have
several minor "no flow" vents which go directly to the atmosphere. These would all
exhibit analytical levels of benzene well above 5 ppm. However they do not have
any positive flow or perhaps only a few cubic inches per hour. They contribute
negligible amounts of benzene to the atmosphere. Our recent audit of emissions from
the entire plant indicated less than % Ib/hour total from this group of vents.
Never-the-less, if the proposed regulations were to be implemented we estimate
that we would be faced with an expenditure of $500,000 to $1,000,000 to manifold up
these insignificant vents and somehow render them incapable of yielding analyses
>5 ppm. We believe that the reasonable approach here is simply to set a threshold
of insignificance. All of these vents easily comply with the TAGS control level
of 100 Ibs. per day of non-methane hydrocarbons and are in fact below the TAGS and
EPA/PSD level of insignificance of 25 T/yr. For benzene alone an appropriate
threshold might be 15 Ibs/day or 5 T/yr. Better a mass factor limit for the entire
plant avoids this problem completely.
As a practical matter measurement of rate accurately at 100 Ibs/day is quite
difficult. At 15 Ibs/day it becomes essentially a research project. As a practical
matter verification of these rates should only be required initially and after
major process changes deemed likely to significantly increase flow.
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-11-
We control a number of "small flow" vents by means of polyethylbenzene scrubbers —
a technique which we regard as particularly excellent for the purpose. However
the measured concentration of benzene out of one of the larger of these is 350 ppm.
at a flow rate of 0.6 cfm. The annual emission of benzene through this scrubber
is only 26 Ibs. We believe that a requirement to incinerate such a stream would
be completely unnecessary and represent the ultimate in over-regulation.
Evidence that these minor small flow and no flow type vents present no hazard is
obtained from the extensive fence-line sampling for benzene which has been carried
out around our plant. More than 100 1-hour samples taken on a number of different
sampling days over several years have shown a maximum level of 114 ppb and an average
level of only 25 ppb. These results show that our performance exceeds the target
levels for Options B and C given on page 16 —even before our last major abatement
project.
In summary —Monsanto has accumulated convincing evidence that EB/styrene plants
such as ours at Texas City contribute insignificantly to human benzene exposure as
compared to typical urban backgrounbs of 7 ppb. We see no justification for further
control of these plants under NESHAPS.
We do not object to burning our major vent streams which we already do, but strongly
object to any attempt to demand destruction to just a few ppm which we do not believe
to be routinely possible in process boilers and heaters.
We similarly object to requirements to burn no-flow and small flow vents and other
insignificant sources which would be extremely costly with no benefit accruing.
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-12-
We are seriously concerned over requirements for highly expensive continuous
monitoring systems when simple records retention procedures can easily provide
adequate documentation that the streams in question have been burned.
We object to time limitations on flaring during start-up and shut down as being
completely unnecessary and completely unrealistic as proposed.
We also believe that it will be totally impossible to comply with an absolute
demand that all start-up, shut down and upset emissions be flared.
Finally, benzene emissions cannot be regulated by ppm alone. A mass factor rate
limit approach is the only reasonable one.
We believe that today essentially all styrene producers burn their major vent streams
to recover increasingly costly energy. This accomplishes without regulation the
apparent major objective of the proposal under discussion.
It is Monsanto's recommendation that the proposal to control benzene emissions from
EB/styrene plants under NESHAPS be dropped as totally unnecessary.
I thank you for your attention.
H. M. Walker
Air Control Coordinator
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BIBLIOGRAPHY
1. Pierle, M. A., Presentation, to National Air Pollution Techniques Advisory
Committee, 8/22/78.
2. Stern, A. C., ed. Air Pollution Control, Vol III, p.62 (1968).
3. Nebel, G. J., "Benzene in Auto Exhaust" JAPCA 30, 391 (1979).
4. Turner, F. C., J. R. Felton and J. R. Kittrell, Arthur D. Little, Inc.
Report Contract 68-02-2859, EPA-450/2-78-021.
5. Computation by C. W. Smalling, 12/79.
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2. Oxirane Corporation
Sylvester W. Fretwell
Manager of Environmental Affairs
Oxirane Corporation
4550 Post Oak Place Drive
Houston, Texas 77027
BENZENE STANDARD STATEMENT
Oxirane Corporation is the management company for a family of
domestic petrochemical companies. Included in that family is an
ethylbenzene/styrene manufacturing facility, Oxirane Chemical Company
(Channelview). This plant is unique in the domestic styrene field
in that the styrene is produced as a co-product with propylene oxide
via an oxidation process called ethylbenzene hydroperoxidation. The
draft regulation proposes to cover benzene emissions from this plant
and this process as well as benzene emissions from the conventional
ethylbenzene dehydrogenation process. Oxirane's position is that the
proposed standard does not adequately address the differences between the
conventional process and our hydroperoxidation process.
The proposed rule is based specifically on the dehydrogenation
process, but the assumption is made that emissions from that process
are also representative of emissions from the hydroperoxidation process.
We will illustrate in our statement that this assumption is false, both
for process emissions and for "excess" emissions; and we will further
illustrate that Oxirane would be singled out to be unfairly penalized by
imposition of emission standards based on a different process. In
addition, we will illustrate that the potential cost impact given in
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the background document is grossly understated, since the cost to Oxirane
alone to retrofit the proposed control measures would exceed the cost
estimate for the entire industry. We will illustrate that the benefit
to be gained from such a costly retrofit is negligible.
We will also illustrate that the proposed gas chromatograph
stack gas monitoring requirement is not reasonable when applied to our
boilers or process heaters, and that the surrogate proposal to control
oxygen in the flue gas at 2% is contrary to the industrial trend for
energy conservation.
I. PROCESS VENTS
The proposed standard (p. 47) covers process vent streams from:
(1) alkylation reactor section, (2) atmospheric/pressure
columns, (3) hydrogen separation system, and (4) vacuum
producing devices. These emission points are specific to
plants producing ethyl benzene by benzene alkylation and
styrene by ethyl benzene dehydrogenation. There is some
ambiguity regarding what emissions from the hydroperoxidation
process are covered.. The preamble, p. 3, lists the ethylbenzene
hydroperoxidation reactor as one of the process vent streams
covered by the proposed standard. Another listing, p. 12,
identifies hydroperoxidation vacuum column vents (as distinct
from other vacuum column vents) as one of the process vent
streams covered by the proposed standards.
We feel that this ambiguity reflects an effort to force-fit
the emissions and emission control strategy for the hydroperoxidation
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process into a mold they do not fit. The original Ethyl benzene
and Styrene Product Report, published by Hydroscience in May
1978 under EPA Contract No. 68-02-2577, addressed only the
dehydrogenation process. Potential control strategies were
discussed in that report. These control strategies have been
carried over into the proposed standard, but they have been
extended to also cover the hydroperoxidation process. The
rationale used (p. 11) is: "Although differences exist between
EB/S plants, there are no significant variations in the
industry..." There are, in fact, major differences between
the conventional dehydrogenation process and Oxirane's
hydroperoxidation process, differences which lead to differences
in emissions. The most significant differences are as follows.
A. The hydroperoxidation process is a co-product process.
Propylene oxide is co-produced with styrene monomer.
Any benzene emissions result not only from styrene
production but also from the simultaneous and inseparable
production of propylene oxide.. The conventional model
> plant produces 300,000 Mg/yr styrene. A similar-sized
hydroperoxidation plant would produce 300,000 Mg/yr
styrene and 120,000 Mg/yr propylene oxide. It is
unreasonable to expect that benzene emissions from a plant
producing 420,000 Mg/yr of two products would be the
same as benzene emissions from a plant producing 300,000
Mg/yr of one product.
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B. The chemistry, reactions, 'and chemicals, are different.
1. One of the large potential sources of benzene
emissions in the conventional dehydrogenation process -
in fact, the largest single source for the model plant-
is the hydrogen off-gas stream from the reactor.
There is no similar stream in the hydroperoxidation
process.
2. The key reaction in the hydroperoxidation process is
an air oxidation reaction of ethyl benzene. There is
no similar reaction in the dehydrogenation process.
The air oxidation reaction exhausts a large stream of
inert gas to the atmosphere, an exhaust which is
not present in the dehydrogenation process. This
vent stream cannot be treated by the proposed
control measure, incineration in a boiler or process
heater, because of the large volume of the inert gas.
Telephone conversations with EPA personnel have
revealed that EPA is considering separate rulemaking
to cover this one vent. They have indicated that
the control mode being considered, if any additional
control is required, is a thermal incinerator on the
exhaust stream from our present scrubbing system. We
have estimated, on a rough basis, that thermal incineration
for this one vent stream would cost $1-1,500,000
capital and would require burning 150,000 Bbl/yr oil
at a cost of $5,300,000/yr. This compares to the
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EPA's estimate for the total industry of $3,300,000
capital and a net annualized operating cost credit
of $460,000/yr for Control Option C. In addition,
burning this quantity of oil would generate over
300 T/Y combustion-related pollutants, almost 5 pounds
of pollutants for every pound of benzene destroyed.
3. Ethyl benzene hydroperoxide from the oxidation reaction
• is reacted with propylene in an epoxidation reaction
to form propylene oxide and methyl benzyl alcohol.
This reaction and these chemicals have no parallel in
the dehydrogenation process.
The high pressure propylene and propylene oxide related
chemicals control the design of vent collection and
incineration systems for the entire plant. For example,
the EB/S model plant would have a 3" diameter continuous
flare (Continue Option B) and a 10" diameter emergency
flare (Control Option 1). The Oxirane Chemical
Company (Channelview) plant has a 14" diameter continuous
flare and a 66" diameter emergency flare. The
benzene-related vents are very small factors in the
overall vent systems. We have determined that the
benzene concentration in the gases vented to the
continuous flare is about 400 ppm (v).
It would be a costly and unnecessary expense to provide
a separate vent/incineration system for only the
benzene related vent streams.
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4. The styrene distillation is different. Styrene in the
hydroperoxidation process is formed by dehydration of
methylbenzyl alcohol. The impurities which must be
removed by distillation are ethyl benzene and low vapor
pressure chemicals methyl benzyl alcohol and acetophenone.
Benzene is a very minor, ppm level, component of the
crude styrene; and benzene from this source to the vent
system is negligible.
*
The primary byproducts in the ethyl benzene dehydrogenation
reaction are relatively high vapor pressure benzene
and toluene. These chemicals and unreacted ethyl benzene
are separated from styrene in the styrene distillation
and benzene is the major component in the vented gases.
II. EXCESS EMISSIONS
The proposed standard calls for "excess" emissions resulting
from startup, shutdown, and malfunction to be combusted in
smokeless flares, with excess emissions from startup and shut-
down to last for no longer than two hours per incident. We find,
in Appendix G of the Background Information Document, that this
rationale is based entirely on the vent stream from the dehydrogenation
reactor. As stated earlier, the hydroperoxidation process
has neither this reaction nor this vent stream. The rationale,
and therefore the proposed standard, are not applicable to the
hydroperoxidation process.
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The proposed standard poses two major problems, both specifically
related to the hydroperoxidation process.
1. Because we are dealing with a very large emergency flare, it
is not economically feasible to make the flare smokeless.
We would have to spend millions of dollars for standby boiler
capacity for smoke control during rare emergency venting
conditions.
2. The size and complexity of bur plant are such that 'startup
and shutdown take much longer than two hours. "Excess"
emissions during startup and shutdown are preferentially
routed to the continuous smokeless flare, but necessarily
for longer t.han two hours. This two hour limit is a
needless restriction which we would.find impossible to meet.
III. FLARE EFFICIENCY
EPA estimates flares have a combustion efficiency of 60 to 99%.
(One study quoted in AP-40 showed a carbon combustion efficiency
for vent gases of 99.9%.) EPA combines an 85% efficiency of
' condensation/absorption with 60% efficiency for flares to get a
total [0.85+(0.15)(0.6)] (100)=94% efficiency for Control Option B.
Suppose the flare efficiency is 90%. The total would then be 98.5%.
To equal the 99% control level of the proposed Option C, a flare
would only have to be 93% efficient {[0.85+(0.15)(0.93)] (100)=99J.
We have estimated that it would cost Oxirane $800,000
in capital expenditures to retrofit Control Option C (not
including the oxidation reactor vent covered earlier) for all
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process vents which could potentially contain benzene. We submit
that there is no evidence to suggest that this retrofit would
result in better control of benzene emissions than we now achieve
with our present control system.
One of EPA's arguments against use of a flare on process vents
is that the combustion performance of the flare cannot be
measured. Accordingly, EPA would have difficulty in assuring
compliance with a standard which is based on volumetric concentration
of benzene in the vented gas. We consider that this position is
unreasonable in that it would require Oxirane to scrap a carefully
engineered and well functioning flare system and replace it with
another system which might not give any better benzene emissions
control.
IV. MONITORING BY GC
We have three combustion devices which would fit the EPA criteria
and be considered adequate, with retrofit, to combust the process
vents. The stack gases.from the. most likely of these devices is such
that, if the total benzene we see in our vent to the flare went
to it and received zero .combustion, the benzene concentration in
•'the flue gas would be 2 ppm(_v)? With..only nominal combustion, the
i
proposed GC monitoring device, would never detect any
benzene. Furthermore, the hot, dirty, and wet atmosphere in
which the GC would have to work would make it a very unreliable
piece of equipment. We consider this proposed monitoring system
totally inappropriate.
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Further, we consider that under our regulatory scheme, it is
sufficient for EPA to require installation of a system adequate
to control benzene emissions, and then to require that the system
be periodically certified as functioning for the intended purpose.
Compliance monitoring is unnecessary.
One alternate method being considered for assuring complete
combustion of benzene is requiring 2% oxygen, minimum,in the flue
gas of boilers or heaters used to combust benzene vents.' This
requirement is contrary both to technological development in
burner design and to industrial trend in energy conservation.
Burners designed for complete combustion with less than 1% excess
oxygen are not uncommon.
V. RECOMMENDATION
In the background document, EPA has listed all of the existing
ethylbenzene/styrene plants in the United States. This is a small
group of 17 plants operated by 14 companies. EPA has predicted
that no new sources will be constructed during the proposed 5-year
life of this regulation. Therefore, the proposed regulation will
apply only to those sources which have already been defined; and
it will apply as a retrofit requirement rather than as a requirement
which can be incorporated into new plant designs. EPA has estimated
the costs and the benefits of applying this retrofit to each of
the existing 17 sources. We have demonstrated that the cost to
Oxirane would be much greater than that estimated by EPA. We
feel certain that the benefit in reduced benzene emissions would be
much smaller than that estimated by EPA. The same may be true for
other facilities. Therefore, we recommend that this draft
-------
regulation not be proposed in its present form. We recommend,
instead, that the potential benefits of the proposed control
systems be carefully defined for each existing facility. If there
still appears to be justification for requiring improved control, .
the modifications necessary and the costs of the proposed control
systems or acceptable alternates should be carefully estimated for
each existing facility. Then, a regulation can be proposed which
would have the desired effect and which would be supported by
accurate cost information.
EPA should be prepared to abandon this effort if the real-life
analysis shows negligible benefit; or, alternatively, EPA should
be prepared to accept site-specific control plans in order to
achieve the most cost effective improvements.
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3. Dow Chemical U.S.A.
Mr. Paul Sienknecht
Dow Chemical U.S.A.
172 Buildinq
Midland, Michigan 48640
Mr. Chairman, my name is Paul Sienknecht and I represent Dow Chemical
U.S.A. Also with me is Gerald Powell, Manager of Dow's Styrene Technology
Center. As Dow Chemical Company is a major producer of ethyl benzene and
styrene, I wish to summarize our concerns related to the draft standards for
ethyl benzene and styrene plants which are being proposed under Section 112 of
the Clean Air Act. Our comments today will be somewhat general. They are
not as detailed as we would like them to be due to the very short period of
time we have had to study the documents and to prepare an appropriately
detailed response and/or alternate proposals. We do intend to develop and
present more detailed written comments and recommendations in the near future
either directly to the Agency or through the Chemical Manufacturers Association,
Today, I will only highlight our major concerns regarding (1) the justification
of promulgating the proposed standards from legal and health effects viewpoints,
(2) technical aspects of the standards as proposed, and (3) the procedural or
timing aspects of the promulgation effort.
LEGAL AND HEALTH EFFECTS JUSTIFICATION
On June 8, 1977, the Environmental Protection Agency (EPA) published a
notice in the Federal Register listing benzene as an addition to the list of
hazardous air pollutants under Section 112 of the Clean Air Act.
It should be noted that the addition of benzene to the list of hazardous
air pollutants did not and has not appeared in Title 40 of the Code of Federal
Regulations.
The Dow Chemical Company has serious reservations concerning the legality
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of the proposed national emission standard for benzene from ethylbenzene/styrene
plants. Our reservations will be fully discussed during the formal comment
period after the proposed rule is published. At this point, however, we will
list some of our major concerns with the proposed rule.
First, there is a challenge, based on the background documents, as
to whether benzene is properly listed as a hazardous air pollutant under
Section 112 of the Clean Air Act.
Second, the Administrator did not comply with Secion 112(b)(l)(B)
of the Act in that the proposed regulation establishing emission standards
for benzene together with a notice of public hearing was not published
within 180 days after the inclusion of benzene on the list of hazardous
air pollutants. Although the Administrator noted in the June 8, 1977
notice of listing that the 180-day schedule for proposal of emission
regulations "may not be feasible", it is our position that a delay in excess
of 2-1/2 years is both unreasonable and contrary to statute. Certainly
such a long delay raises the question of whether the Agency itself believes
that deaths are being caused by exposure to low levels of benzene.
Third,, based on EPA's background documents and supportive data, the
proposed regulation unnecessarily regulates a particular source of benzene -
that is, ethylbenzene/styrene plants, and regulates that source to an improper
extent. EPA's background document indicates that the current level of controls
at existing ethylbenzene/styrene facilities averages 70% emission control.
Additionally, a review of the numbers and methods used by EPA to determine the
lifetime risk of benzene emissions from ethylbenzene/styrene plants reveals
that the supposed risk from that source is less than miniscule.
Subpart (c) of the section entitled "Emissions standard and compliance
provisions" requires that "The owner or operator of each source shall maintain
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and operate the source, including associated air pollution control equipment,
in a manner consistent with good air pollution control practice for minimizing
benzene emissions " Nowhere is there a standard, or a definition, of "good
air pollution control practice", much less "good air pollution control practice
for minimizing benzene emissions". Beside being ambiguous, the supposed
standard is in fact no standard at all and therefore totally unauthorized
by Section 112 of the Clean Air Act.
In reporting a malfunction in conjunction with excess emissions, it is
proposed that an owner or operator submit--?
Documentation that air pollution control equipment, process
equipment, or processes were at all times maintained and
operated, to the maximum extent practicable, in a manner
consistent with good practice for minimizing emissions
and were designed in accordance with good engineering practices.
Such a reporting requirement is not authorized under any provision of
the Clean Air Act, including Sections 112, 114, and 301Ca). Also, the
language "consistent with good practice for minimizing emissions" and
"designed in accordance with good engineering practices" does not constitute
a legal or an ascertainable standard and is impermissibly vague.
We also have serious reservations on the proposed monitoring requirements,
and the fact that the proposed rule seems to do violence to the fundamental
health based feature of Section 112 by changing that health based provision
to a technology based one. These and other questions and comments will be
expanded upon and presented during the formal comment period after publication
of the proposed rule.
In reference to health effects, we would like to examine the alleged
risks to the public from exposure to benzene. In the Draft NESHAP document,
it is stated that as a result of emission reductions, estimates of excess
leukemia deaths resulting from exposure to benzene emissions from controlled
ethylbenzene/styrene plants would be reduced from a range of 0.09 to 0.63 to
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a range of 0.03 to 0.19 deaths per year. ,These estimates are extrapolations
of exposures at high concentrations in industrial situations existing in
industry years ago to very low levels of concentration to which the
general public may be presently exposed. Furthermore, they were developed
using linear extrapolations without consideration of the dose response
effect. This interpretation of cancer causation is not universally agreed
upon by the scientific community. The treatment of data in this manner by
EPA has been criticized by the Chemical Manufacturers Association in comments
delivered to the Agency on July 3, 1979 relating to Proposed Benzene Water
Quality Criteria.* We do not plan to enter into a detailed discussion of
risk assessment here. We will comment to the Agency on the health risks
of benzene as the NESHAP proceeds through the rule-making process.
What we do wish to point out to this committee is that the deaths reputed
to be caused by exposure to benzene emissions are hypothetical estimates, and
there is no indication that we are here discussing real deaths. If we did
not believe this, we would be alarmed and would have severely reduced benzene
emissions from our production facilities even in the absence of regulation.
Because we believe that exposure of the public to very low concentrations of
benzene does not constitute a health risk, we recommend to this committee and
to EPA that benzene emissions from ethylbenzene/styrene plants not be regulated
under Section 112 of the Clean Air Act.
TECHNICAL ASPECTS OF THE STANDARDS
Notwithstanding our reservations over the health and legal questions
already discussed, we do have some problems with the technical provisions of
the standards as proposed. I will briefly cover our concerns regarding the
five ppmv concentration limitation, excess emission requirements, monitoring
and reporting requirements, cost and capital estimates, determination of
violations, and definitional problems.
*See Section III.D.I.
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(1) The five ppmv Concentration Limitation
The standard of five ppmv is questionable. The standard is based on data
representing only 10% of the operating plants and even this data is questionable.
The lower limit used is based on a unit receiving low benzene "concentrations
and having two combustion zones. Such equipment is not usual in the industry.
Tests should be made and standards based on more normal situations and
conditions.
No real allowance is made for any plant problems or upsets. Also it
should be recognized that the standard is proposing that equipment designed
for another purpose be.used for benzene destruction but the freedom to operate
that equipment to maximize benzene destruction is minimal or non-existant.
(2) Excess Emission Requirements
The definition of and compliance provisions relative to excess emissions
are at best confusing and appear to be inconsistant. In part (a) of the
paragraph on Emission Standard and Compliance Provisions, it is stated that
"This emission limitation (Sppm) does not apply during start-up, shut-down, or
malfunction". Yet in part (b), it states that each owner or operator shall
combust all excess emissions due to start-up, shut-down, and malfunction.
How can we have excess emissions (which are defined as meaning any release of
benzene from process vent streams to the atmosphere in excess of the 5 ppmv
standard) from operational situations for which the standard is not applicable?
The standard indicates that venting to a flare during start-up, shut-down
or malfunction is acceptable. Malfunction is defined as any sudden and
unavoidable failure of process or control equipment. There certainly are times
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when a process is upset for reasons other than total or sudden failure
of process or control equipment and which also are not the result of careless
operation or poor design. Such types of operational problems may result in
excess emissions, but no provision is made to allow flaring as an acceptable
way to avoid a violation for such problems.
The two hours allowed for flaring during start-up and shut-down periods
are too short. Some of the process equipment has design limitations with
respect to rate of temperature change which will not permit a two hour
shut-down or start-up period. Six hours would be a more appropriate minimum.
The Excess Emission Report requirements are either not clearly written
or are excessive. The flaring requirements during start-up, shut-down and
malfunctions are imposed to destroy what otherwise would be excess emissions
in the absence of such a flare. Why then, is it necessary to report situations
that are occuring according to the established rules? Such excessive reporting
is burdensome both to the industry and to the Agency.
Several questions which have not been addressed in the development of
the standards include: (a) Is the discharge of a safety relief valve classified
as a malfunction? (b) With respect to flares, what constitutes a visible
emission? and (c) Are calculations acceptable as the means to determine the
emission rate to and from a flare during a malfunction?
(3) Monitoring and Reporting Requirements
The use of gas chromatography with flame ionization detection is a
viable method for analysis of vent streams containing benzene if no reasonable
alternative exists. The monitoring options outlined in the proposal present
a very viable alternative to the use of gas chromatography. The instrumentation
is much simpler"and much more reliable. Option 3, for example, requires a
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temperature measurement instead of the gas chromatograph. The oxygen
analyzer is required in either case and is much less complex than the
chromatograph.
One should also note that there are instrument system failures which
can cause chromatographs to read low. For example, a leak in the sample
line will dilute the sample. In contrast, temperature measurements result
in continuous up-scale values and failures cause them to read out-of-range
giving a positive indication of failure.
To evaluate the alternatives fully, the actual parameters for benzene
destruction relating to temperature, time, and oxygen availability need
to be better understood.
In the proposal discussion regarding costs, two chromatographs are
mentioned but the reason for the two is not clear. If the purpose is to
have redund.ant instrumentation to reduce down time, it should be realized
that the sample system is subject to more failures than the analyzer. Even
with two gas chromatographs, on-line operation exceeding 95% would be
difficult over the long term. The alternate monitoring methods referred to
would have much more reliable operation.
In the section on Emission Test and Procedures, a sample flow rate
proportional to the vent flow rate is required. If this were to be applied
to the continuous monitoring situation, the sample taking would be complicated
resulting in reduced reliability and increased maintenance.
The proposed record keeping and reporting requirements are unduly
burdensome and excessive and add another significant cost and dilution of
efforts for more constructive purposes.
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The proposed compliance time is unrealistically short. The time to
engineer, purchase and construct the control devices will certainly exceed
90 days — therefore automatically requiring a request for a waiver from
the Administrator, resulting in more paperwork and more dilution of
productive work.
(4) Cost and Capital Estimates
The costs of retrofitting existing facilities with the proposed control
and monitoring devices are significantly understated. Actual installation
costs may be as much as two to three times higher than those shown in the
Background Information Document (BID). In addition, the amount of associated
piping would be greater than shown due to the fact that the existing production
plants do not conform to the Model Plant which is assumed to be representative
of the Styrene Plants. Actual plants may require two flare systems to meet
safety and loss prevention requirements due to the problem of handling hydrogen
containing vent gas streams in combination with other process vent streams.
\
Also, one flare system cannot be sized to properly and efficiently handle the
wide range of flow rates which could occur if it is to handle both normal
and abnormal situations.
Operating costs are likewise understated. Actual energy consumption and
the back-up capital required is understated. In the case of steam required
for .smokeless flare operation, this large amount of steam must always be
ready when needed and represents a significant back-up capital commitment.
(5) Determination of Violations
A serious defect of this proposed regulation is the fact that mulfunction
excess emissions are not clearly defined as to what the Agency will accept
or reject as being unpreventable. While the Agency will determine this from
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the facts, too much is left to Agency discretion and there is no guidance
for the operator or owner to fashion his conduct to avoid a problem. This
is a very important area as the proposed standard does little to recognize
the normal variations that plants experience while functioning properly. The
standard should include some criteria for decisions relating to violations.
(6) Definitional Problems
In the definition of "Process Vent Stream", the term "having the potential
of being released to the atmosphere" is used. Obviously this language is
ambiguous and should be deleted.
In the paragraph on reporting requirements of continuous monitoring data,
the term "—but not limited to—" is used. This phrase should be deleted as
it leaves the monitoring and reporting requirements unfairly open-ended.
In the paragraph describing the Administrators determination of the
cause of excess emissions, the term "sound engineering practices" should be
changed to "accepted engineering practices".
PROCEDURAL ASPECTS AND TIMING OF THE PROPOSAL
I have referred earlier to the lack of time given to properly prepare
for this presentation. Let me elaborate on this. The draft proposed
regulation and Background Information Document (BID) were received barely one
month before today's meeting. Documents such as this require careful review
by a number of different specialists in different locations. One month is
allowed to make an initial review to see who needs to be involved, to make
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and distribute copies to those that need them, for the specialists to
locate and gather the additional background documents which are referred to
but not included in the package, to study and evaluate all the information,
and then to develop and assemble meaningful comments and recommendations.
One month for all of this is entirely too short a period of time.
These difficulties could be at least partially relieved by making the
BIDs available earlier. The NAPCTAC meeting is scheduled too early within
the rule-making procedure.
The timing of this ethylbenzene/styrene regulatory effort is unfortunate
in that a number of related issues are currently involved in unsettled
controversy and litigation. This results in industry and the public working
in a mass of confusion. Examples include:
1. The issue of whether control of benzene emissions at low levels
from stationary sources is needed has been questioned but not
formally challenged. Such a challenge and discussion of the issue
will occur very soon when the formal public comment period is
opened on the proposed standards for the control of benzene
emissions from the maleic anhydride industry.
2. The United States Supreme Court has not yet acted on the litigation
before it involving the Occupational Safety and Health Administration
Permanent Standard for Occupational Exposure to Benzene of 1 part per
million airborne exposure.
3. The Agency is clearly following at least some of the foundations that
were laid down in its recently proposed air carcinogen policy. This
policy which has created considerable controversy is still in the
public comment period.
111-52
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In terms of priority and need for regulation, if indeed the
Agency believes that low level benzene emissions are a threat to the public
health, it is difficult to understand their rationale in choosing not to
attempt to quickly regulate the 80% of total nationwide benzene emissions
which they claim come from mobile sources but instead to concentrate their
efforts on a fraction of the remaining 20% which is alleged to come from
ethylbenzene/styrene plants. It would seem that emissions from filling
station operations would also be much more significant,
In the preamble to the proposed rule, it is stated that the Administrator
considered the alternative of taking no action, relying instead on the OSHA
standard for benzene emissions and hydrocarbon control under State Implementation
Plans (SIPs). This was rejected on the basis that work place standards would
not be expected to result in the control of benzene emissions from process
vents within an ethylbenzene/styrene plant. This rationale is difficult to
understand. Achieving lower work place exposures can only be achieved by
reducing the amount of benzene emitted and to believe that process vents can
be ignored in accomplishing this is unrealistic.
In summary, we question the need or wisdom of promulgating additional
benzene control regulations until the above mentioned basic issues are resolved.
We do not advocate delay for the sake of delay or the taking of undue risks by
delaying regulation. But when we examine the health and risk data presented
in the ethylbenzene/styrene documents, we see that.the numbers are extremely
low and scientifically questionable, and that the levels of exposure are so low
that there is no known additional risk to life and health by waiting until these
major issues are settled. For these reasons we recommend that further promulgation
of the NESHAP for benzene emissions from ethylbenzene/styrene plants be halted.
111-53
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4. Cosden Oil and Chemical Company
Mr. Theodore M. Nairn, Jr.
Cosden Oil and Chemical Company
P.O. Box 1311
Big Spring, Texas 79720
My name if Ted Nairn. I am Coordinator of Air and Water Conservation
for Cosden Oil and Chemical Company.
Cosden appreciates this opportunity to comment on the draft preamble, re-
gulations and background information document for hazardous air pollutant
standards for benzene emisisons from ethylbenzene/styrene production.
Cosden Oil and Chemical Company operates the Cos-Mar Plant at Carville,
Louisiana which is jointly owned by Cosden and the Borg-Warner Corporation.
Cosden wishes to make some preliminary comments today and to respectively
request additional time to submit final comments. Additional time is
desired for two reasons. The first reason is, Cosden's Staff has not
had time to complete our review of the 270 page background information
document. Secondly, tests were conducted on process vent emissions in
our Cos-Mar Plant under an EPA contract. We have had an opportunity to
review and comment on the draft report of these test results. In our
comments, we have raised some serious questions as to the accuracy of
the data obtained from the tests. EPA is now working on the questions raised
about draft test report. We anticipate the need for an additional four
weeks to complete final comments after our questions have been answered
concerning the draft test report.
Our comments concerning the draft proposals are as follows:
111-54
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1) We agree that reasonable controls should be employed to control
benzene emissions. The combustion of the hydrogen-rich gas from styrene
dehydrogenation reaction sections *s?e a reasonable control measure.
2) We do not believe that it is reasonable to retrofit existing
plants to burn the vacuum column vent emissions. This control may be
justified for new or modified plants. We wish to correct the statement
on page 4-9 of the draft background information decument. The Cos-Mar
plant does not burn vacuum column vent emissiosn in a boiler as indicated
on lines 5 and 6.
3) We believe that EPA should develop actual flare efficiency data
for flares before decisions are made based on assumed efficiencies.
Additional flare technology should be examined such as efficiency of
liquid recovery before flares and vapor recovery before flares.
4) The two hour time proposed for flaring of emissions from start-up
and shutdown is not adequate. Normally, flaring time is not of long
duration. However, plant experience indicates that some flaring during
an eight hour period, both for start-up and shutdown may be necessary
in order to protect plant personnel and equipment. This time require-
ment may vary with size and design of plant.
5) We are concerned that mobile sources represent 80 percent of the
nations's total benzene emissions and that ethylbenzene/styrene plants
represent only a small part of the remaining 20 percent. The same degree
of efficiency is not being effected on mobile sources as proposed for the
ethylbenzene/styrene plants.
111-55
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C. DISCUSSION
Following the contractor presentation which reviewed the proposed
standard for hazardous air pollutants (NESHAP) for EB/S plants, Don Goodwin
opened the floor to questions and comments from the NAPCTAC members. EPA
staff and contractor personnel were available to respond to questions and
discuss issues of concern to the NAPCTAC members.
Opening questions from NAPCTAC members centered on assumptions and
methodology undertaken in the development of the dispersion modeling.
Attention was focused mainly on derivations of population exposure and, as
a function of this, maximum lifetime risk to the most exposed population
and incidence of deaths. Population exposure, EPA personnel explained, is
based on a 1970 census count to determine the number of people residing
within 20 kilometers of an EB/S plant. Exposure was estimated through the
use of the Industrial Source Complex (ISC) model. Emission rates of an
uncontrolled model plant were scaled up or down depending on styrene produc-
tion of each actual plant. Adjustments were made for emission controls and
the data was then plugged into the model. Benzene concentration, it was
explained, was predicted at each ring distance downwind of the plant out to
a maximum radius of 20 km from the plant. Population exposure was then
determined. Risk to the most exposed population after application of best
available technology (BAT) was then calculated using maximum annual benzene
concentrations. Incidence of death after application of BAT was calculated
using annual average benzene concentrations.
A discussion ensued concerning justification of the standard as it
applies to the EB/S industry. One committee member requested risk and
death estimates under existing controls. It was pointed out by David Patrick
(SDB) that risk and death assessment for existing controls is not an issue.
Benzene has been designated as a hazardous air pollutant and the proposed
Carcinogen Policy mandates the control of all significant benzene sources.
EB/S benzene emissions rank as the second largest source of benzene emissions
in the chemical manufacturing industry and, as such, it has been selected
for regulation. Beyond this, it requires that EPA indentify BAT for a
particular source (considering environmental, energy, and. economic impacts).
Only after BAT is 'identified does the proposed Carcinogen Policy specify
that residual health impacts be evaluated. The next most stringent option
(beyond BAT) is examined to assess the cost increase versus the risk reduc-
tion of going from BAT to beyond BAT. From this analysis., the ultimate
level of control is selected.
111-56
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Committee members, questioned the Agency's decision to choose the BAT
option instead of going beyond BAT for continuous emissions. Don Goodwin
responded that, unlike the case of maleic anhydride, in which a 97 and 99
percent option existed, the options for the EB/S industry consist of a
choice between 99 and TOO percent control. The latter option (beyond BAT)
would force closure of the entire EB/S industry with a resultant severely-
negative economic impact to the industry itself, the many end-markets, and
the consumer sector. Moreover, there are few, if any, safe substitutes for
all styrene uses and it is doubtful that enough styrene could be imported.
For these reasons, the Agency's decision to choose the BAT option (99 per-
cent control) is evident.
Both committee members and industry representatives questioned the
estimated combustion efficiency of a typ-ical EB/S boiler. The questions
arose due to disagreement of opinion concerning residence time of the off-
gas in the boiler firebox. EPA personnel pointed out that, unlike in the
case of an incinerator, offgas residence time in a boiler is not necessar-
ily a prime indicator of combustion efficiency. In a typical EB/S boiler,
the offgas is mixed with the fuel before combustion and passes directly
through the burner ports. This design helps facilitate more complete
combustion by providing optimum flame turbulence, an increased travel in
the flame zone, and, as a result, a longer residence time. Flame tempera-
ture is, in most cases, in excess of 3000 F, which is more than adequate to
ensure complete combustion of the benzene.
After the discussion by NAPCTAC members, industry representatives
presented their testimony and discussion continued on issues of concern to
the EB/S industry.
Dr. Harry Walker of Monsanto asserted that a concentration standard
does not really limit the extent of benzene emissions without including
some reference to flow rate. He argued that a mass emissions standard
would be much more meaningful, i.e., it would better indicate a plant's
total contribution of benzene to the atmosphere (relative to its production
level or amount of feedstock). He thinks that the vents in the Monsanto
EB/S plant which have little or no flow should be exempt even though the
benzene concentration levels exceed the limits of the standard. He claimed
that benzene emissions from these small vents contribute only about five
percent of all benzene emissions from that plant.
David Mascone, lead engineer for EPA, commented that a mass emission
standard was considered, but due to variations in processes and production
rates (both among plants and even within a given plant), the complexity of
the standard and.the difficulty of administration would outweigh the bene-
fits of this approach. He added that some vents having little or no flow
would in fact be exempt from the standard. Possible misinterpretation in
this-area stems from the fact that differences in design features and
certain equipment appearing in one plant and.not in another preclude the
use of precise definitions of equipment covered i;n the regulation. Also,
due to the lack of specific information on the origin of some streams, it
has been necessary to broaden the scope of the language in the rule.
Resolution of these issues will come about as details of individual plants
and processes become available from industry.
111-57
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Sylvester W. Fretwell of Oxirane Corporation voiced a similar complaint
concerning applicability of the standard to a small vent servicing the
scrubbing system in the styrene production unit. He claimed that Oxirane
would have to spend in excess of $5 million to combust just that one stream.
David Mascone replied that due to Oxirane1s unique design and the
presence of a coproduct, special provisions in the standard may be necessary
for that plant. He said he will review any data provided by Oxirane on the
oxidation reaction vent and a decision will be made at a later date on
whether or not this vent should be covered. He added that all vents are
analyzed and emissions quantified whether they are included under the
standard or not. Again, he stressed that further information is necessary
to draft more precise language so that certain vents are included and some
are not.
The next issue involved terms of the proposed standard as it applies
to excess emissions. The concensus of industry spokesmen was that the
proposed time limit for flaring during.periods of startup and shutdown was
too short. One representative alleged that his plant requires six to eight
hours to flare waste streams generated during these periods. David Mascone
responded that a six-to-eight-hour flaring time might be reduced if the
plant utilized a recycle procedure, flaring only as long as is necessary,
thereafter routing the stream to the boiler or superheater as soon as is
feasible. He said that the Agency is willing to discuss specific problems
that a plant may have in meeting a particular requirement of the standard.
A question was then raised concerning flare combustion efficiency. As
is stated in the background information documents, the Agency has assumed a
60 percent benzene destruction efficiency for existing flares in the EB/S
industry. A committee member cited a German study in which flare efficiency
was calculated to be as high as 99 percent. David Mascone responded that
the discrepancy in assignment of overall efficiency was due to a number of
engineering considerations concerning the differences between flares cur-
rently in use in the EB/S industry and those in the German study. Factors
such as flow rate, composition of streams, steam injection, and general
burner tip design in the EB/S industry differ from those in the German
study. The lead engineer mentioned that data from other tests suggest that
flares similar to those in industrial use may have combustion efficiencies
as low as 60 percent. The Agency therefore has chosen the more conserva-
tive estimate until more definitive data are available.
Paul Sienknecht of Dow questioned the validity of the emission test
data at both the El Paso and Amoco facilities. Benzene concentrations in
the stacks of the El Paso facility were significantly below the five ppmv
standard. Moreover, burner configuration is considered atypical of other
boilers in the industry and may not provide an appropriate data base for
the proposed standard. The Amoco test developed contamination problems in
test equipment because some benzene was retained on the walls of the glass
vessels used in sampling. Stack benzene concentrations at the time of
testing were greater than ten ppmv. A second test is scheduled in January
at Amoco. Because the boiler at this facility is typical of those found
throughout the EB/S industry, the results of this test should better
reflect the emissions reduction capability of most plants in the EB/S
industry.
111-58
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D. CORRESPONDENCE
1. Letter from Chemical Manufacturers Association to EPA
MANUFACTURING CHEMISTS ASSOCIATION
1825 CONNECTICUT AVENUE. N.W.. WASHINGTON. D.C. 20009
G-V-?°*?>°- TELEPHONE-<=0
TcLEX
TECHNICAL DIRECTOR 6LEX
July 3, 1979
Hand Delivered ': •.-.... . ..".'•' . . ." ''•'
Mr. Kenneth M.•Mackenthun, Director
Criteria and Standards Division (WH-585)
Office of Water Planning and Standards
U. S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Re: Proposed Benzene Water* Quality Criteria,
44 Fed. Reg. 15935-15936, March 15, 1979
Dear Mr. Mackenthun: .
The Chemical Manufacturers Association (CMA) (formerly
known as the Manufacturing Chemists Association) submitted
detailed comments on June 12, 1979, with respect to draft
water quality'criteria documents for 27 toxic pollutants
developed pursuant to Section 304(a) of the Clean Water Act.
CMA's June 13, 1979, comments, provided a detailed evaluation
of the Agency's guidelines and .methodology used to develop
.the proposed water quality criteria, and the various support
documents. In addition, CMA analyzed the acquatic and
human health effects on which the Agency apparently based
its proposed water quality criteria. An analysis of the
draft benzene water quality criteria and support document
was included in Appendix C.
CMA believes that the Agency should temporarily refrain
from developing and/or issuing final water quality criteria
for benzene for the following reasons. The proposed benzene
water quality criteria is essentially derived from the
Occupational Safety and Health Administration (OSHA)
Permanent Standard for Occupational Exposure to Benzene —
1 part per million airborne exposure. That standard is
presently under review in the United States Supreme Court and
will be decided in the 1979 October Term. For that reason,
EPA should follow the lead of the Consumer Product Safety
Commission which has postponed adoption of a consumer product
safety rule concerning benzene until April, 1980.
111-59
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The proposed water quality criteria for benzene are
based on SPA's Carcinogen Assessment Group's (GAG) Final
Report on Population Risk to Ambient Benzene Exposures,
September 12, 1978. The CAG report uses three epidemiological
studies which are in the public record of the OSHA Benzene
Permanent Standard proceeding. These studies were by
Infante, et al., Aksoy, et al. and Ott, et al. In each
case, we believe that the CAG has improperly adjusted or
has misread the data and has arrived at erroneously low
criteria levels. CMA submits that CAG and EPA have made
at least the following errors in applying the Infante,
Askoy, and Ott data. ... . :• .
1. EPA asserts (44 Fed. Reg.. 15935) that these
studies "rule out exposure to solvents other than
benzene." That is not the case. The Infante study*
covered two Pliofilm plants. Whi^e plant B may be
considered to have used only benzene as a solvent, workers
in plant A were exposed to a variety of chemicals.
2. The Infante study showed seven leukemia
deaths in the cohort. CAG has added two more on the
authority of Dr. Sakol who claimed that two death
certificates were improperly filled out and the two
workers "were probably in Infante's cohort." (Final
Report, p. 10). By adding these two deaths, CAG has
contrived to increase relative risk from 5.60 to 7.20,
an increase of 35%.
3. CAG acknowledges that Infante gives
"essentially no estimate of worker exposure" and that
at one of the plants "air monitoring information ..... •
is almost non-existent." (Final Report, p. 9). That is
not correct. The OSHA public record shows that exposure
levels reached levels of 120, 500 and even 1000 ppm.
Despite this information on the OSHA record, CAG has
produced a time-weighted average by assuming that
exposures were "generally close to the occupational
standard."
V CAG regards the Infante study "as the least
flawed of those utilized." Final Report, p. 9.
111-60
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4. CAG also misreads Aksoy and relies on
exposure levels of.15-30 ppm out of working hours and
150-210 ppm during working hours. In fact, Dr. Aksoy •
testified at the OSHA hearings that exposures varied
during working hours and reached levels of 650 ppm..
(OSHA Hearing, Exhibit 60, pp. 4-5; Tr. 157-185). ;
5. In using the Qtt study, CAG claims that .
three deaths from leukemia were found. In fact, there
were two deaths from leukemia. The third employee had
contracted leukemia but actually died of .broncho-pneumonia.
The inclusion of the third death distorts the .relative
risk.
For the foregoing reasons, CMA submits that the
CAG Final Report is considerably flawed and should not
be used to establish water quality criteria for benzene.
Should the Agency require additional information
or want to discuss any of these issues, you may contact
David W. Carroll, Assistant General Counsel, at
328-4274, or-John C. Van Horn, Manager, Special Projects,
at 328-4248.
Sincerely,
Geraldine V. Cox
cc: Thomas C. Jorling (WH-556)
S. T. Davis (WH-551)
Joan Z. Bernstein (A-130)
Jeffrey G. Miller (EN-335)
Richard G. Stoll, Jr. (A-131)
Stephen J. Gage (RD-672)
111-61
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IV. NEW SOURCE PERFORMANCE STANDARDS
FOR VOLATILE ORGANIC COMPOUND EMISSIONS
FROM PRESSURE-SENSITIVE TAPE AND
LABEL SURFACE COATING OPERATIONS
A.I INDUSTRY DESCRIPTION AND REGULATORY ALTERNATIVES
Mr. Thomas P. Nelson
Radian Corporation
3024 Pickett Road
Durham, North Carolina 27707
The pressure sensitive tape and label (PSTL) surface coating industry
is classified under SIC 2641, paper coating and glazing. The PSTL
industry is a large and growing industry. In 1978 the estimated annual
industry sales were nearly $1.7 million (Table A). Pressure sensitive
tapes represent the largest dollar volume item, while the label and
specialty products sector are the fastest growing. The annual PSTL
industry growth rate is estimated at ten percent per year. The new
source performance standard (NSPS) will cover surface coating operations
associated with tape, label and specialty product manufacturing.
TABLE A:
Pressure Sensitive Tapes & Labels (SIC Code-2641)
Pressure Sensitive Tapes
Pressure Sensitive Labels
Specialty Products
TOTAL
1978 Sales
($x1Q6)
900
485
300
1,685
IV-1
Annual
Growth Rate
9%
12%
13%
10%
-------
Currently there are over 100 companies involved in the surface
coating of pressure sensitive adhesive products. These companies
represent approximately 300 actual coating lines. The estimated
uncontrolled VOC emission rate from all 300 coating facilities is
600,000 metric tons per year. Of these emissions only 20 percent
are currently controlled.
In order to understand the manufacture of a tape, label or specialty
product, the industry profile (Figure A) should be .examined from
the suppliers of raw materials through the final product consumers.
The primary raw materials used in this industry are adhesives, re-
leases, solvents and web materials. An adhesive in the sticky
material on a tape or label. A release is the coating on the back-
side of a tape or label. The release coating allows the tape or label
to be wound on itself but not stick to itself. The web is the material,
such as paper, polypropylene, PVC, or other plastics, on which the
adhesive or release is coated. The adhesives and releases are formu-
lated with solvents and other minor ingredients to form the actual
coating. Formulation may be done by the base stock manufacturers
in-house or by firms solely involved in formulation. Web materials
are primarily purchased as uncoated continuous rolls, however, some
manufacturers may purchase a silicone release precoated material.
The base stock manufacturers coat adhesives and releases or adhesives
only. Their base stock product is an adhesive-coated continuous
web which is then converted through air cutting or slitting operations
to the final tape or label product. The NSPS for the PSTL industry
covers only the roll coating operations associated with the application
of adhesives and releases. In Figure A the groups associated with
roll coating operations are the base stock manufacturers and the
release coaters.
Pressure sensitive tape and label surface coating operations
are located in many states across the United States (Figure B). Three
areas of particularly high densities of coating operations are the
urban northeast, the Chicago area and the Los Angeles area. These
IV-2
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FIGURE A: Hierarchy of
the Pressure Sensitive Tapes & Labels Industry
Manufacturers of
Adhesive & Release
Raw Materials
Manufacturers of
Web Materials
Adhesive &
Release Formulators
Tapes & Labels Base Stock
FIGURE Bl Geographical Locations
of Pressure Sensitive Tapes & Labels
Coating Operations in the United States.
IV-3
-------
areas are already heavily industrialized and have recognized polluted
environments. The largest tape manufacturing companies are 3M, Permacel
(Johnson and Johnson), Nashua Corporation, Mystic Tape (Borden Chemical),
and Tuck Industries. The largest label and label stock manufacturers
are Avery/Fasson, Morgan Adhesives, Dennison, S.D. Warren (Scott Paper
Co.), and Fitchberg Coated Products.
In the PSTL industry the affected facility is defined as a single
coating line (Figure C). The coating line consists of a coating applicator
and a drying oven along with added web handling equipment. The primary
pollutant in this industry is volatile organic compounds (VOC) resulting
from the application of solvent-based coating to the continuous web and
from the vaporization of the solvents in the drying oven. Typical
solvents used in the PSTL industry are toluene, mixed naphthas, hexane,
heptane, ethyl acetate, and some methyl ethyl ketone (MEK).
The VOC emissions are emitted as either fugitive solvent emissions
around the coating applicator and the exposed web from the applicator to
the oven, or as captured solvent emissions in the drying ovens. Based on
estimates given in industry, the amount of solvent released in the oven
is 80 to 99 percent of the solvent that is applied to the web by the
applicator. The fugitive solvent emissions around the applicator and
exposed web account for one to eighteen percent of the applied solvent.
Also from zero to seven percent of the solvent may be retained in the
coated product.
Two types of add-on VOC controls were examined in the Background
Information Document (BID) study: carbon adsorption and incineration.
The performance of these add-on controls were estimated in conjunction
with a fugitive capture system. The fugitive capture system, such as
hooding or total enclosure, is an important factor in maintaining a high
level of overall VOC control. Total enclosure of the coater and
exposed web area is highly recommended but is not currently demonstrated
IV-4
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FIGURE C: Typical Controlled
Tape or Label Solvent Coating Facility
Emissions
to the
Atmosphere
^ Add-OnVOC J \
1
Captured
Fugitive
VOC
Emissions
Hood
(or enclosure)
Adhesive or ^
Release Coater ^
c
^
w Control Device "1 \
/ j
4
v
Oven
Emissions
1 I
j (
n r
Drying/Curing Oven
Unwind
Wind
-------
in the PSTL industry. Other similar type surface coating operations do
use total enclosures for enhancing overall VOC capture.
The test data used to support the NSPS came from two primary sources
(Table B). One source was data on the efficiency of current add-on VOC
control devices. This efficiency is based on the reduction of VOC
across the add-on device and was not an overall VOC control number. For
devices found in the PSTL industry the addon VOC control efficiencies
ranged from 96 to 99 percent for well-controlled facilities. The second
source of test data was overall solvent balance data from carbon-
adsorption-con trolled facilities. A carbon-adsorption-controlled facility
provides a unique opportunity to measure the recovered solvent and
compare that value to the amount of solvent applied in the wet coating.
For well-controlled facilities the overall VOC reductions ranged from 90
to 93 percent.
Besides using add-on VOC controls, solvent emissions can be reduced
(or eliminated) from a facility if the operator uses low-solvent or high-
solids coatings. Both adhesives and releases have low solvent coating
alternatives (Table C). For adhesives, there are hot melt and water-
borne coatings. In 1978 it was estimated that 15 percent of all pressure
sensitive adhesives used were either hot melt or waterborne. However,
it is predicted that there will be a dramatic increase in the use of low
solvent coatings. For example in 1985 eighty percent of all adhesives
are expected to be low solvent coatings. A similar situation is expected
for low solvent silicone releases such as the 100 percent solid and
waterborne formulations. Currently, less than 25 percent of the industry
uses low solvent releases. By 1985,two-thirds of all silicone releases
will be low solvent types.
Although the low solvent systems are attractive from an environ-
mental standpoint, a regulation for this industry can not be written
based on low solvent technology only. There are still several coatings
which due to their inherent characteristics must be coated a solvent-
based system. It is predicted that in 1985 sol vent-based coating will
still be required for certain applications.
IV-6
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TABLE B: Conclusions from Test
Data of Controlled Pressure Sensitive
Tape and Label Coating Lines
• Carbon Adsorption and Incineration Control
Device Efficiencies range from 96 to 99 per-
cent on well-controlled facilities.
• Solvent Material Balances on Carbon Ad-
sorption Controlled Facilities showed overall
VOC control of 90 to 93 percent.
TABLE Cl Low Solvent Coatings
Percent of Total Industry Production
Estimated Predicted
1978 1985
•
o
Adhesive
Hot Melt
Water-Borne
Release
100% Solids
Water-Borne
5
10
3
20
30
50
33
38
IV-7
-------
To assess the environmental, energy and economic impacts of a
NSPS, twelve model plants were developed. These model plants re-
present typical facilities used in the industry today. The analysis
examined three different line widths, three different line speeds,
and two different solvents (Table D). Cases were examined for both
adhesive and release formulations. The parameters used to assess the
industry impacts were felt to give a representative picture of current,
typical surface coating operations.
Along with the model plants, three regulatory alternatives were
examined (Table E). Alternative I represents the case where no NSPS
is developed and new sources are regulated by current state regulations.
As a conservative estimate it was assumed that all states would follow
the State Implementation Plan (SIP) Control Technique Guidelines (CTG).
In this situation the estimated overall VOC reduction required for a
coating facility would be approximately 80 percent. This is based on an
assumption of 90 percent VOC capture and 90 percent reduction of the
captured VOC. Regulatory Alternative II assumes the development of
a NSPS which would require 95 percent reduction of captured VOC
rather than the 90 percent for the SIP. Therefore, the overall VOC
reduction would be near 85 percent. Finally, Alternative III considers
the use of a fugitive VOC capture system to increase the overall VOC
capture of the process. In this case the NSPS would represent 90
percent overal1 VOC control.
Combining the twelve model plants and three regulatory alternatives,
thirty-six model control cases were examined. The examination in-
cluded a look at the effects of increased regulatory control on environ-
mental, energy and economic impacts. The environmental impact analysis
showed that in 1985 an estimated 27,400 megagrams of VOC would be
emitted if no NSPS were developed (Table F). If an Alternative II
NSPS were developed there would be a 9.5 percent reduction in the
estimated VOC emissions without NSPS. If the stringent Alternative
III NSPS is used, the decrease in baseline emissions is 15.7 percent.
The analysis of added solid waste and wastewater by more regulation
showed minor impacts.
IV-8
-------
TABLE D: Model Plant Parameters
Line Widths . (A) 0.61 meter (24")
(B)0.9 meter (36")
(C) 1.5 meter (60")
Line Speeds (A) 0.13 m/sec (25 f pm)
(B) 0.3 m/sec (53 f pm)
(C) 1.2 m/sec (230 fpm)
Solvents (A) Toluene
(B) Naphtha
i
Coatings (A) Pressure sensitive
adhesive
(B)Silicone Release
TABLE El Regulatory Alternatives
Estimated % Overall
Description VOC Control
Regulatory
Alternative I No NSPS with state regula- 80
tions for new sources
Regulatory
Alternative II Best control of oven 85
emissions only
Regulatory
Alternative 111 Best control of oven and 90
fugitive solvent emissions
TABLE Fl Environmental Impacts (1985)
Reduction
MG/Year from Baseline
• VOC Emissions
Potential
Regulatory Alternative 1 (baseline)
Regulatory Alternative II
Regulatory Alternative III
137,000
27,400
24,800
23,100
—
—
9.5%
15.7%
Wastewater and Solid Waste Impacts
are Minor
IV-9
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A similar impact analysis was done for the energy consumption.
Added energy consumption results from added fan capacity on the control
units and added fuel oil use for carbon adsorber boilers or for in-
cineration units. The results for the most stringent case showed
an added energy impact of three percent overall the baseline (no NSPS)
value (Table G).
A cost analysis was performed for all thirty-six model control
cases (Table H). The costs include capital and operating costs for
both the coating line and for the add-on VOC control equipment. The
results of the study showed that add-on VOC controls represent 8 to
32 percent of the total installed capital costs. The capital costs
for hoods or enclosures are less than one percent of the total capital
investment. For the annualized costs, the raw materials have the
greatest effect on the product price. The add-on VOC control equip-
ment operating., costs are six to eight percent of the total annual
operating costs for a well-controlled facility.
The cost for the VOC controlled coating facilities were compared
to the costs for low-solvent-type systems such as hot melt adhesive
and 100 percent solid silicone releases. Then cost comparisons were
based on a discounted cash flow analysis for typical plant financial
structures. The results of the economic impact analysis showed
that hot melt adhesives and 100 percent solid silicone releases are
the most profitable alternatives (Table I). However, as previously
mentioned low-solvent, high-solids technology can not be used in
all cases. Therefore, the economic analysis was constrained to
eliminate the hot melt and 100 percent solids alternatives. In this
situation, systems which had to use add-on VOC controls showed a
decrease in internal rate of return of 1.29 to 4.60 percent for full
cost absorption. This is in comparison to the Alternative I (no NSPS)
situation. If the costs of the add-on VOC controls could be passed
on through to the consumer, the product price showed a 0.40 to 1.67
percent increase for the cases analyzed.
Based on the results of the environmental, energy and economic
analyses, it was determined that the Alternative III control level
IV-10
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TABLE G: Energy Impacts (1985)
Increase
10 Kwhr from Baseline
• Electrical Consumption
Regulatory Alternative I (baseline) 6.9 —
Regulatory Alternative II 7.0 1.4%
Regulatory Alternative III 7.1 2.9%
a Increase
10 Liter* from Baseline
o Fuel Usage
Regulatory Alternative I (baseline) 30 —
Regulatory Alternative II 30 0%
Regulatory Alternative III 31 3.3%
•Fuel Oil Equivalent
TABLE H: Model Plant Cost Analysis
• Add-On VOC Controls Represent 8 to 32
Recent of Total Installed Capital Costs
• Capital Costs for Hoods or Enclosures
are Minor
• Raw Materials have the Greatest Effect
on Product Price
• Control Equipment Operating Costs •:••
are 6 to 8 Percent of Total Annual
Operating Costs
TABLE il Economic Impacts
• Hot Melt Adhesives and 100 Percent Solid
Silicone Releases are the Most Profitabie
Alternatives
• Add-ON VOC Controls
Decrease in Rate of Return Ranged from
. 1.29 to 4.60 Percent
Increase in Product Price Ranged from
0.40 to 1.67 Percent
o The Economic Analysis Indicates
Minor Impact
IV-11
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would provide the best VOC reduction at minimum industry impact.
The overall VOC reduction levels were also supported by the test
data presented earlier. Therefore, the recommended new source
performance standard for VOC control in the PSTL surface coating
industry is 0.20 kilogram VOC per kilogram of coated solids, or
a maximum of 90 percent overall VOC control (Table J). The first
part of the regulation, 0.20 kilogram VOC per kilogram solids, will
allow the use of low-solvent coatings with no add-on VOC controls.
The second part, a maximum of 90 percent overall VOC control, will
allow coaters to use high-solvent formulations without the burden
of an extremely high (greater than 90 percent) required overall
VOC reduction. There is also a provision in the NSPS which allows
operators a reduced overall VOC control level if they can show a
greater than three percent solvent retained in the coated product.
This is based on weighted-average data over a typical month of
coatings.
Finally, there are the performance testing, monitoring and
reporting requirements (Table K). The performance tests for low-
solvent coatings, carbon adsorption, and incineration are different.
For low-solvent coatings, the regulation requires the operators
to estimate the weighted-average VOC content of coatings used over
a typical month operation. EPA reference test method 24 will be
used to measure solvent in the coating. To determine compliance
the value is then compared to the 0.20 kilogram VOC per kilogram
solid number. Carbon adsorption- and incineration-controlled
facilities are also required to estimate the weighted-average
solvent content in the coatings used over a typical month of -
operation. This value is used to estimate the overall VOC reduction
required by the system. If the average value is less than 2.0
kilogram VOC per kilogram coating solids, the operator calculates
the VOC reduction required to meet the 0.20 kilogram limit. If the
average is greater than 2.0, the operator will be required to meet
the 90 percent overall VOC reduction maximum. Compliance for a
IV-12
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TABLE Jl Recommended Standard for
VOC Control in the Pressure Sensitive
Tape & Label Surface Coating Industry
• 0.20 Kilogram volatile organic compounds
(VOC) per kilogram of coated solids, or
• Maximum of 90 percent overall VOC control
TABLE K:
Performance Testing, Monitoring and Reporting
• Performance Testing
Low-Solvent Coatings • Measurement of Solvent in Coating
Carbon Adsorption • 30 Day Liquid Material Balance
Incineration • Three 1-Hour Gas-Phase Tests
• Monitoring
Low Solvent Coatings • Solvent-in-Coating Determination
Carbon Adsorption • Recovered Solvent
• Solvent-in-coating Determination
Incineration • Temperature
• Hood or Enclosure Performance
9 Reporting
Notification of Construction and Startup
Performance Test Results
Quarterly Report on System Performance
IV-13
-------
carbon adsorption system is based on a 30-day liquid material balance.
For incineration, compliance is based on three - one hour tests.
The gas-phase VOC analyses will use EPA reference test method 25.
The monitoring requirements for the three control system
alternatives are also different. For low solvent coatings, the
operator keeps a log of all coatings used. The measured solvent
content in these coatings is then used to calculate a monthly average
content for each reporting month. Each monthly value must be at or
below the 0.20 kilogram VOC per kilogram solid limit. For carbon
adsorption controlled facilities, the operator will monitor the solvent
used and the solvent captured to calculate a monthly overall VOC
reduction. For incineration systems, the operator will monitor the
incinerator temperature and the performance of any fugitive VOC
capture system. These values must indicate that the total control
system is operating as it did during its completed performance test.
The reporting requirements include an initial report informing
the EPA offices of the construction of a new source or the major
modification or reconstruction of an existing source. The second
report is the results of the performance tests. The final reporting
requirement is a quarterly report discussing any violation to the
NSPS.
IV-14
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A.2 CONTROL EFFICIENCY DATA
Mr. James C. Berry
Chief, Chemical Application Section
U.S. Environmental Protection Agency
Figure 1 is a schematic diagram of Adhesives Research's carbon adsorber
system. This plant provides the basis for the Pressure Sensitive Tapes and
Labels draft NSPS. The plant recovered 93% of all the solvent that entered
the process by passing essentially all building exhaust through the adsorber.
Figure 2 shows a carbon adsorption system at Shuford Mills, Inc. The
carbon adsorption system collects 89% of all solvent which enters the pro-
cess. Emissions from the applicator are collected in a hood over the
applicator and vented to the outside air. EPA measured solvent concentra-
tions in the hood exhaust and using this data calculated that if the hood
exhaust were ducted to the carbon adsorber, the overall solvent recovery
would be 91%. This plant provides strong support for the draft NSPS.
Figure 3 shows a diagram of a carbon adsorber at Meredith Burda, a
publication rotogravure plant. This plant uses a semi-enclosure of the
applicator and dryer to. exhaust almost all solvent emissions to the carbon
adsorber. The system recovers 95% of all solvent which enters the process.
While this is not a pressure sensitive tape or label line, this is similar
in that it is a web coating process and we believe this example supports
our case.
Figure 4 represents the carbon adsorber system at the Texas color
-rotogravure,pi ant. The carbon system collects 81% of solvent used in the
process. The applicator emissions are collected in a hood and are vented
to the atmosphere. EPA measured these emissions and calculated that if
they were ducted to a carbon adsorber, the overall solvent collection
efficiency of the plant would be 91%.
Figure 5 summarizes this data. We have four web coating processes
which are capable of recovering 90% of the solvent used in the system. We
believe these well controlled plants support the draft NSPS which requires
a maximum of 90% control.
IV-15
-------
WEB PROCESS
CARBON
..'-...
- -' • •...••• . : • . •• •
1
* 1
APPLICATOR DRYER
. c
v^
MUOVJHDC
'
D • . ,
RECEIVER
^ E
E_
A
ADHESIVES RESEARCH -— = 93%
Figure 1
Figure 2.
A
APPLICATOR DRYER i
CARBON
ADSORBER
RECEIVER
SHUFORD MILLS.
D
-£ =91.5
WHERE
= 89% D' = f(B •" E)
Figure 2
IV-16
-------
WEB PROCESS
APPLICATOR DRYER
MEREDITH BURDA
Figure 3
CARBON
ADSORBER
.RECEIVER
D
-£•=98%
D
WEB PROCESS
APPLICATOR DRYER
TEXAS COLOR
D
CARBON
ADSORBER
RECEIVER
D'
= 91 %
WHERE
— = 81% D' = f (B * E)
r\
Figure 4
IV-17
-------
WEB PROCESS
CONTROL EFFICIENCIES
Plant
Meredith-Burda
(GA)
Texas Color
(GA)
Adhesives Research
(PST&L)
Shuford Mills
(PST&L)
Capture
System
Large Efficient
Enclosure
Applicator-Hood
Dryer-Enclosed
Building Vent
Applicator-Hood
Dryer-Enclosed
Overall
Control
Material
Balance
95
X
93
K
Overall
Control
Calculated
91
92
Figure 5
IV-18
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B. Pressure-Sensitive Tape and Label
Industry Presentations
1. VARA INTERNATIONAL, INC.
Tom Vara, President
Vara International, Inc.
1201 19th Place
Vero Beach, Florida 32960
(Mr. Vara did not have a written presentation, but spoke extemporane-
ously. His talk is summarized below.)
Mr. Vara's main point was that ketones can be recovered successfully
on carbon adsorption if stainless steel equipment is used. He also said
that the energy value of the solvent recovered is usually at least twice
the energy required to operate the adsorber. Mr. Vara said carbon adsor-
bers installed at IBM in Kentucky have performed successfully.
2. REGENERATOR CORPORATION
William J. Darm, President
Regenerator Corporation
315 E. Franklin
Newberg, Oregon 97132
(Mr. Darm did not submit a paper. His remarks are summarized below.)
Mr. Darm described regenerative condensing as a means of solvent
recovery. He claimed such systems can cool air streams and condense
organic vapors at low cost. Mr. Darm expects 100% solvent removal using
less than 80 horsepower in one system. His main concern was that our regu-
lation would be written in such a way as to preclude use of regenerative
condensation as a control device.
IV-19
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3. Anchor Continental, Incorporated
Mr. Alonzo R. Moore
Anchor Continental, Incorporated
P. 0. Drawer G
Columbia, South Carolina 29250
Mr. Chairman:
My name is Alonzo R. Moore and I represent Anchor Continental, Inc., a manufacturer
of pressure sensitive tapes, located in Columbia, South Carolina.
Let me preface my remarks by saying the performance standards developed are well
thought out and would deliver to all of us an environment few have enjoyed in the
past.
The ideal existence would be to have all the goods and services most of us view
as necessities, coupled with a perfect environment.
Perhaps, working together, we can achieve this ideal.
I want briefly to address the proposed Regulatory Alternative I and II.
We strongly urge that New Source Performance Standards be no more stringent than
Alternative I, which is expected to be similar to State Implementation Plans. We
believe existing SIP regulations have not had sufficient time fully to affect
emissions. We believe actual emission reductions will be far greater as time
passes. Incentives already exist to encourage conversion to low solvent coatings,
water based coatings, and 1007. solid hot melts as well as the use of add-on
control equipment. These new techniques are being adapted successfully on many
products. At the present time, however, all products cannot be made successfully
with the new low solvent methods. Too rapid conversion, accompanied by too little
know-how may result in low yield production and inferior quality products — an
unhappy condition that no one wants to see come to pass.
IV-20
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ANCHOR CONTINENTAL, INC.
, 0. Drawer G • Columbia, S. C. 29250
Central Docket Section (A-130) - Nov. 10, 1979 - Page 2
There also seems to be some question among qualified professionals about what
ambient air level of VOC is reasonable and safe. Is the ambient air standard
already unnecessarily low?
Regulatory Alternative I would yield approximately 807« total industry reduction
of VOC emissions by 1985, while the more stringent Regulatory Alternative III
would achieve an 837» reduction. We believe the additional 37, reduction would
reach the point of diminishing return in the monitoring, cost, and attention by
both regulatory agencies and industry. Certainly, achieving the additional 370
reduction would add much more than 37,, to the cost of complying with the regulation.
The personnel attention and expense required for further reduction of VOC
emissions—below the level of South Carolina's SIP—would pose a serious threat
to research on new products, development of cost saving improvements of existing
products and continued production of quality products.
The overall result of requiring unrealistic attention to the marginal environmental
benefits could cost us dearly in economic competition with foreign manufacturers
in both national and world markets. If we were competing only among other United
States producers, the economic impact would be less drastic. This is even more
vital today when the value of the United States dollar is falling and our balance
of trade is unfavourable.
If the present SIP is unworkable, a less desirable alternative would be that the
required control level be no more stringent than Regulatory Alternative II, which
sets approximately an 857» VOC reduction from new or modified coating lines.
IV-21
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ANCHOR CONTINENTAL, INC.
P. 0. Drawer G • Columbia, S. C. 29250
Central Docket Section (A-13Q) - Nov. 10, 1979 - Page 3
We believe it is important to protect our environment. We live here, too. We
also believe United States' industry needs to be innovative and progressive and
needs to be able to compete worldwide. We believe that regulatory agencies and
industry, working together, can do all of these things.
Thank you for allowing us to comment.
Alonzo^R. Moore,
Technical Service Engineer
IV-22
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4. NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT. INC.
Russell 0. Blosser
Assistant Technical Director
National Council of the Paper Industry
for Air and Stream Improvement, Inc.
260 Madison Avenue
New York, N. Y. 10016
(Mr. Blosser did not submit a paper. His talk is summarized below.)
Mr. Blosser's main points were:
a. The PSTL industry has a hybrid nature. A wide variety of coatings
are used and printing is sometimes done. He recommends that this
regulation be put on "hold" until the rotogravure and other coating
regulations are proposed, so that all can be examined as a group.
Many of these other standards may impact the PSTL industry.
b. He said our test Method 25 measures ethane, although EPA has said
ethane is nonreactive.
c. The modification issue needs close examination. It is hard to opti-
mize line speed or burner design. When those shortcomings are correc-
ted, this should not trigger NSPS.
d. In regard to an economic study, the nature of our growth estimate may
be off.
e. EPA's energy estimate may be off. More heat may be needed to dry some
low solvent coatings.
f. It is not uncommon to recycle air in the oven back to the burners.
When you recirculate air in this way you burn part of the VOC so you
won't get 90% recovery with a carbon adsorber.
IV-23
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5. 3M COMPANY
David Benforado
3M Company
P.O. Box 33331
St. Paul, Minnesota 55133
(Mr. Benforado did not submit a paper. His talk is summarized below.)
Mr. Benforado's main points were:
a. The BID does a good job of characterizing the industry.
b. Chapters 7 and 8 of the BID did not get much industry review before
the NAPCTAC meeting.
c. Why was a low plant size exemption dropped?
d. A precoat is often used before the adhesive is applied. High solids
materials cannot be used for this precoat; it will be necessary to
use afterburners for control. The precoat section should be included
with the adhesive application as one affected facility.
e. Industry will move to high solids coatings by 1990 even if no regula-
tions are adopted, so why pass a regulation?
f. Control to stringent levels may discourage development of new products.
g. Volatile organic compounds are precursors and not pollutants in
themselves.
h. The energy impact probably won't be positive as we have shown in the
BID.
i. The economic section is based on 40% LEL (lower explosive limit) gas
concentration in the oven exhaust. This level of solvent concentra-
tion is not possible to maintain if products made on the line are
changed often. The tendency will be for lower LEL levels to be
achieved. This will mean lower heat recovery benefits.
j. The economic section doesn't show marginal costs for marginal impacts.
For example, going from regulatory alternative II to regulatory alter-
native III will reduce emissions an additional 1,100 metric tons/year
by 1982. What is the incremental cost of this reduction?
k. The TGNMO Method 25 is tedious, time consuming, costly, error prone,
and requires highly skilled personnel to operate. The Los Angeles
TGNMO method did not give good reproducibility in round robin tests.
Mr. Benforado recommends that a flame ionization detector (FID) be used.
The FID measurements could be compared to TGNMO measurements by adding
a CO measurement to the FID measurement. This will take care of FID
error caused by oxygenated solvents.
IV-24
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6. AMERICAN INSTITUTE OF METALIZERS. COATERS, AND LAMINATORS
Richard Vieth
Morton Chemical
2 North Riverside Plaza
Chicago, Illinois 60606
As President of the Association of Industrial Metallizers,
Coaters and Laminators, I speak for a trade association composed
of approximately 50 flexible film converters, most of whom are
coaters of pressure sensitive adhesives.
Our association has just learned of the new proposed regula-
tion covering Standards of Performance for New Stationary Sources
for Pressure Sensitive Tape and Label Manufacturing Facilities.
We would also appreciate the opportunity to submit our asso-
ciation's comments and critique prior to the issuance of any final
regulation on this matter. Please address all data or communica-
tions as follows:
Association of Industrial Metallizers, Coaters
and Laminators
\ 61 Blue Ridge Road,
"^ Wilton, Connecticut 06897
Attn: Mr. William Troph
Executive Secretary
As Director of Development for Morton Chemical Company, I
would also like to offer several comments:
1. We object strongly to the proposal to reduce allowable emis-
sions on new sources or major modified sources to 0.2 kilograms
VOC per 1.0 kilograms of applied coating solids, (i.e. 16.67%).
The newly established CTG's for paper coating allow 2.9 pounds
of solids (per gallons of applied coating) or approximately
33.0% solvent.
As a result of these CTG's, and the resulting SIP's incorporat-
ing these, we and other adhesive and coating suppliers have
spent substantial time and money in developing low solvent ad-
hesive and coating technology. The first results of this
TV ?^ ^ North Riverside Plaza. Chicago. Illinois 60606
" (312)621-5200
Division of MortonNorwkh
-------
Don R. Goodwin, Director
-2-
December 17, 1979
research and development effort are now reaching initial sampl-
ing stages, and we expect an increased flow of this type of
product to the market place.
In all of these systems, application equipment modification
is generally required to allow usage of the revised system.
These new systems and equipment modiciations will generally
result in substantial reductions of both oven and f-ugitive
emissions.
If the new proposed regulation is enacted, it will largely
tend to negate the adoption of this technology, or penalize
the converters adopting it. The reasons for this would be:
a.) This technology could be used only on currently installed
production lines.
b.) If a line of products using this technology was success-
ful requiring a new production line, or a major modifica-
tion to a current line, it would require either a change
in technology to a lower solvent containing material, or
adoption of add-on control equipment at a major cost
penalty.
This seems to me to penalize or discriminate against the
successful and vigilant operator to the advantage of the less
successful.
2. During the NAPTAC committee meeting several references were
given to an increase in water-based pressure sensitive usage
to 50% of the total usage by 1985. Indeed, a great deal of
research and development effort has been expended in attempt-
ing to accomplish the change from solvent-based to water-based
pressure sensitives, but, at this point in time, no water-based
systems have been developed that are suitable for any of the
high performance areas of pressure sensitive application. This
suggests a substantially slowerrate of change-over than that
projected in the Radian studies and in your preamble document.
Thank you for the opportunity to state my position at the commit-
tee meeting. We look forward to receiving the draft documents for
our memberships study and comment.
Sincerely yours,
MORTON CHEMICAL
RDV:mas
cc: W. Troph - AIMCAL
E. Monigan - Dunmore
Richard D. Vieth
Manager, Adhesives & Coatings
Development £
AIMCAL President
IV-26
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D. DISCUSSION
NAPCTAC members commented on several areas of the draft standard.
These comments are described below.
Comment: Morton Sterling asked if the pressure sensitive tapes and
labels (PSTL) standard is similar to the auto coating standard.
Response: James Berry, EPA, said that the standards are different in
that the PSTL industry makes a wider variety of products, so that low
solvent coatings may not be available for all uses.
Comment: Janet Chalupnik asked whether the industry would go to hot
melt and other low solvent coatings even if NSPS is not adopted.
Response: Tom Nelson, Radian Corporation, said that State Implementation
Plans (.SIP) and industry economics would encourage industry this way.,
but an NSPS will further encourage this trend.
Comment: Janet Chalupnik questioned spending effort to regulate small
sources of volatile organic compounds (VOC) until state auto inspection
and maintenance programs are in place. Mrs. Chalupnik asked if an NSPS
is needed since the reduction in emissions of an NSPS compared to
reduction by the SIP is small.
Response: James Berry, EPA, said the SIP regulations might allow
variances for some sources. An NSPS will provide consistent nationwide
regulation.
Comment: Claibourne Smith asked if the standard is based on a water-
borne coating or a hot melt.
Response: James Berry, EPA, replied that the draft standard is based on
90% control which can be met by incineration or carbon adsorption.
However the draft standard will encourage industry to go to higher
solids coating.
Comment: Claibourne Smith said he is not sure that water-borne coatings
will meet the recommended 0.20 Kg solvent/Kg solids. He said he is
concerned that the standard will prevent the use of these products.
Response: Jack Farmer, EPA, said that many water-borne coatings will
meet the recommended limit even though the solvent content of individual
products vary widely. Jim Berry, EPA, said that even if a product
contained more than the standard, only the increment over 0.2 Kg/Kg need
be controlled.
Comment: William Reiter said that the draft Background Information
Document for the standard stated that there are problems with carbon
adsorption. He felt we do not discuss thoroughly enough how to overcome
these problems.
IV-27
-------
Response: Jim Berry, EPA, said we have looked at similar coating facil-
ities, all using carbon adsorption. Some of these ran successfully,
while did not. There are enough successful facilities to demonstrate
that carbon adsorption is feasible.
Comment: William Reiter wanted to know what kind of parameter could be
measured to monitor hood efficiency.
Response: Don Goodwin, EPA, said duct flow, electric fan current, or
anything to show that the hood is operating the same as during the
compliance test.
Comment: Neil Kaye said that the draft regulation requires reports as
required in paragraph 60.7 (c). He said he could find no such paragraph.
Response: Jack Farmer, EPA, said paragraph 60.7 is in the general
provisions.
Comment: Eric Lemke said there would be enforcement problems with a
thirty day material balance for carbon adsorption. If a control agency
goes to court with a thirty day average, the court will not see how the
company could know if it was out of compliance during the first part of
the thirty day period. Mr. Lemke said he just didn't think the thirty
day average would hold up in court. He suggested the use of a break-
through meter to show that breakthrough had not occurred as a monitoring
tool.
Response: James Berry, EPA, said it would be hard to get accurate
measurements in less than a thirty day period. He said we would study
the use of a breakthrough meter to see if it could be used as a moni-
toring tool.
Comment: Eric Lemke was concerned that photochemical reactivity is not
considered in our solvent regulations. He said we may reduce solvent
volume emitted by one third and increase reactivity by ten times.
Response: Jim Berry, EPA, said EPA is writing regulations to be consis-
tent with the 1977 EPA policy statement on reactivity. This policy
considers essentially all organic solvents to be reactive.
Comment: Bob Dunlap said Appendix C of the draft Background Information
Document CBID) doesn't present our data base in a very strong light.
Response: James Berry, EPA, said we recognized this and had improved
the presentation for this meeting and would make improvements in future
editions of the BID.
Comment: Claibourne Smith said EPA should consider the comments on test
methods 24 and 25 submitted by the auto industry when they reviewed the
automobile coating standard. Are these comments relevant to the PSTL
industry?
IV-28
-------
Response: George Walsh, EPA, said method 24 had been modified as
Candidate 2 to measure weight of solvent rather than weight of carbon.
Mr. Walsh said method 24 is now acceptable to industry.
Mr. Walsh said that the main industry complaint against method 25
is that it is cumbersome.
Comment: In response to Tom Vara's talk on carbon adsorption, Neil Kaye
asked if Mr. Vara's equipment could meet the draft standard.
Response: Tom Vara, Vara International, said his carbon adsorbers could
meet the recommended standard.
Comment: William Darm, Regenerator Corporation, was concerned that the
condensation equipment made by his company could not be used to meet the
standard, since the BID talks only about afterburners and carbon adsorbers.
Response: James Berry, EPA, said that our recommendation would not
preclude condensation as a control device.
Comment: A. R. Moore of Anchor Continental, Inc. gave a talk in which
he recommended that the NSPS level of control be lowered from 90% to
81%. Morton Sterling asked what technologies are available to meet 81%
control that would not be available at 90%.
Response: Mr. Moore said that the effort required by staff for testing
and monitoring to get the small increment of control between 81 and 90%
is not worth the trouble.
Comment: In response to a talk by Russ Blosser, Robert Dunlap asked why
Mr. Blosser's talk had not stressed technology more.
Response: Russ Blosser, National Council for Air and Stream Improvement,
said his organization had not had the draft standard and BID long enough
to evaluate the technology adequately.
Comment: Robert Dunlap asked Mr. Blosser if long term data existed on
carbon adsorption.
Response: Mr. Blosser said he believed EPA had developed most of the
data that exists.
Comment: Russ Blosser said that provisions should be made for down time
on a tape line. He pointed out that the flue gas desulfurization
standard deals with down time in a specific way.
Response: Jack Farmer, EPA, replied that the flue gas standard was an
entirely different kind of standard.
Comment: Art Boozer, Avery Label Company, made a comment from the
audience. If oven air is recirculated through the burners, cart of the
VOC will be burned. Since this VOC will be destroyed, a carbon adsorber
IV-29
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attached to the line will not be able to capture 90% of solvent used on
the line. Mr. Boozer said this recycle is needed for energy savings.
Response: Mr. Eric Lemke said this might suggest the use of a break-
through device on the carbon adsorber to determine compliance. James
Berry, EPA, said one possible solution would be to run the ovens without
recycle for the compliance test. When the carbon adsorber is proven to
comply, recycle of oven gas can be started.
Comment: In response to a speech by Dave Benforado, Morton Sterling
asked if we needed an NSPS for this industry since SIPs would control
the industry to a large degree.
Response: Dave Benforado answered that the industry would move toward
low solvent coatings even if no NSPS were adopted.
Comment: Claibourne Smith asked Mr. Benforado if water-borne coatings
were available which could meet the draft standard.
Response: Dave Benforado replied that water-borne coatings will meet
the standard for many types of tapes and labels.
Comment: Robert Dunlap asked Mr. Benforado about precoat materials.
Response,: Mr. Benforado said precoat or backsize is not the same as
silicone release. He said the economic analysis in the BID do not apply
to backsize. Mr. Benforado recommended that the precoat and adhesive
coater be bubbled together for the standard.
Comment: An unidentified member of the audience said that he did not
think the current draft regulation allowed bubbling of precoat and
adhesive operations.
Response: James Berry, EPA, said EPA would examine this issue and
determine how it should be handled.
IV-30
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!_. Letter from Union Carbide to EPA
UNION CARBIDE CORPORATION
x IIMIORK
CARBIDE
CHEMICALS AND PLASTICS
RIVER ROAD, BOUND BROOK, N. J. 08805 • TELEPHONE (201) 356-8000.
December 14, 1979
Mr. D. R. Goodwin
Director, Emission Standards and
Engineering Division
U.S.E.P.A.
Office of Air Quality Planning
and Standards
Research Triangle Park, North Carolina
Dear Mr. Goodwin:
27711
Unfortunately I am unable to attend the National Air Pollution
Control Techniques Advisory Committee meeting this month. However, I would
like to input some further information for incorporation in the final draft of the
B.I.D. for the manufacture of pressure sensitive tapes and labels.
In 1979 there have been dramatic price increases in petroleum
derived materials. These price escalations have resulted in a large increase
in the raw material cost, to the coater, of solvent based raw materials. In order
to have a realistic comparison between systems, the total cost to apply 1 pound of
dry adhesive the table below is useful.
Table 1
Adhesive Raw Material and Formulating Costs
Emulsion
Natural Rubber
Tackifier
Solvent
(3:Hexane:2 Toluene)
Emulsion Adhesive
Period Cost
Total Cost for
1 Ib. of Adhesive
RMC
($/Lb.)
0.60
0.60
0.11
0.85
Cost
Formulation ($)
Solvent Rubber
Cost
Formulation
.85 Ibs. 0.51
.15 " 0.09
2.00 " 0.22
1.00 Ibs.
0.85
$0.85
IV-31
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Mr. D. R. Goodwin 2 December 14, 1979
In this table I have compared the RMC and period production
costs of a solvent based rubber PSA versus an emulsion adhesive. This assumes
the coater is custom formulating and has period costs of about 10£/pound for
chopping rubber and its dissolution and tackification. If the coater were to
purchase a formulated adhesive, the period cost from this table would now become
the adhesive formulators period cost and his gross margin, possibly an extra 15£/
pound. Consequently from these calculations, and industry information on their
adhesive costs at the coating head, the total cost of the emulsion adhesive per
pound of dry applied adhesive is approximately 85 ^/applied pound, while for the
solvent rubber system it is between 92£ and $1. 10/applied adhesive pound. This
calculation assumes no formulation period costs for the emulsion system. This
is in general correct although for specific applications a limited amount of
formulation is sometimes carried out. The formulation of the emulsion systems
usually consists of a short blending process, in contrast to the lengthy and
tedious dissolution of rubber in solvents.
The inclusion of this information in the B.I.D. will seriously
change some of the calculations, rankings and conclusions in the Gost Analyses
and Economic Impact Analyses in Chapter 8. In particular the Tables 8-22 (Raw
Material Costs contribution); 8-27, 28, 29 (Variable Operating Costs contributions!
will need to be modified to reflect today's costs as outlined above. Further in the
Net Present Value calculations the Variable Costs (V) will be dominated by the raw
material costs. The inclusion of the data presented above would have a drastic
effect on Tables 30 through 41 and the NPV ranking of the coating systems therein.
In a UCC internal assessment of the relative value of water based
adhesives in the pressure sensitive adhesive industry there has been use made of
the NPV calculation. In the B.I.D. calculation there appears to be no inclusion of
raw material and labor escalation rates. These I believe to be most important, not
necessarily for their absolute value, but because of the projected differential
between the 100% petrochemically based solvent rubber PSAs, and their 50-60%
organic based emulsion counterparts. Internally we are escalating solvent-based
adhesives at 11%, and water based materials at 9%. This is a conservative
estimate of what could be a far larger differential.
Finally, I was most surprised that no extra operating/labor costs
are anticipated in Table 8-22 for the systems with the carbon adsorption and
inceneration control devices. I assume that this assumption has been justified
from industry and manufacturer data.
I hope these comments are of use in the preparation of the final draft
of the B.I.D. I will be pleased to discuss this information further with you at
your convenience.
Sincerely yours ,
A. DT Hamer
ADHtlms
IV-32
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2. Letter from Allied Chemical to EPA
Allied.
Chemical
Corporate Headquarters
P.O. Box1057R
Morristown. New Jersey 07960
December 27, 1979
Mr. J. Farmer
Emission Standards & Engineering Div. (MD-13)
Office of Air Quality Planning & Standards
U.S. EPA
Research Triangle Park
North Carolina 27711
Re: EPA Proposals
Pressure Sensitive Tape &
Label Surface Coating Industry
Rotogravure Printing Industry
Dear Mr. Farmer:
I had the opportunity of reviewing very briefly both of these rather
weighty documents. Both address the subject of disposing of organic
solvent vapor wastes by basically two methods:
1. Adsorption (Fixed Bed - Fluidized Bed)
2. Incineration
Interestingly enough, no mention is made anywhere in these documents on
the hazards inherent in either of these two techniques.
In the fixed bed adsorption process there have been cases of fires in
the activated carbon adsorption beds. The incidence of occurrence
is dependent on several things; (a) the chemical properties of the solvent,
particularly with respect to the ease with which it can be oxidized;
(b) air velocity through the bed; and (c) design of the vessel containing
the adsorping material. A discussion of some of the parameters dealing
with a specific case of acetone was published in British Chemical Engineering,
Jan. 1968, Vol. 13, No. 1, pages 85-88 (D. A. Boiston). At the moment,
I have no knowledge of fire, explosion or other safety problems for
fluidized bed units other than the more obvious ones which might occur
during a desorption process of the bed. I also would like to point out
that the A.I.Ch.E. Loss Prevention Symposium in Atlanta, Georgia (1978)
had a series of 3 papers which were published as Vol. 12, Loss Prevention
(papers attached).* One of these papers is from Scotts Graphics, Inc.
where they discuss their experiences.
*The technical articles that accompanied this letter have been placed in the
pressure-sensitive tapes and labels docket, number 8-79-38.
IV-33
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- 2 -
Incinerators can also be a cause of problems. In this case, we would be
taking the solvent laden air and passing it through a flame supplied by
some fuel, (natural gas, propane, fuel oil, etc.). It would be expected
that this unit would be equipped with the usual quota of combustion safe-
guard controls (shutting down on flame failure, etc.). The NFPA codes
on combustion safeguards would be applicable or could easily be adopted
to an incinerator. Several other questions need to be considered:
1. What happens when the incinerator goes down on flame failure? Where
is the solvent laden air to be disposed off?
2. What happens if an excessive concentration of flammable solvent vapors
get into the incinerator (e.g., @ concentrations at or above the lower
flammable limit). What are the provisions for prevention of a flashback
ignited from the incinerator? Can flame arresters or water seals be
used? I would like to observe that the design and particularly,
the maintenance of flame arrestors is far from an easy task. The
A.I.Ch.E. Loss Prevention Manual, Vol. 12 has a paper on that flame
arrester design. Water seals design and operation needs careful
thought, even to the selection of the proper pressure rating for
pipes and vessels. The 1980 A.I.Ch.E. Loss Prevention sumposium
will be held in Philadelphia and will have a session on Incinerators.
It is my view that the use of incinerators and absorbers, if recommended
by the E.P.A., need to include considerable amounts of advice concerning
the factors that go into the safe design and operation of such a unit,
particularly incinerators. If this is not done, I can foresee a situation
where some concern whose management is not familiar with a problem can
install a unit without proper safeguards which can be the source of a
serious explosion. In a pioneering technology situation an unsafe
condition could occur which had not been considered by the design engineers.
The entire design problem requires integrating the emission control device
(incinerator or absorber) design with the solvent emitting operation.
We have seen one case where a small change by the operations people
in one part of the process led to an unsafe condition at the incinerator.
I trust that the above comments will be helpful.
Very truly yours,
• f.
R. F. Schwab, Manager
Process Safety & Loss Prevention
RFS:dr
Enc.
cc: W. Reiter
IV-34
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V. NEW SOURCE PERFORMANCE STANDARDS
FOR VOLATILE ORGANIC CHEMICAL EMISSIONS FROM PUBLICATION
ROTOGRAVURE PRINTING INDUSTRY
A. EPA PRESENTATION
Mr. Richard Burt
Radian Corporation
3024 Pickett Road
Durham, North Carolina 27707
A profile of the industry is shown in Figure A. The publication roto-
gravure printing industry is a highly specialized segment of the graphic arts
industry. It is concerned with the high-volume printing of high-quality,
smooth paper products such as magazines. In addition, lower quality products
such as catalogs, newspaper supplements and inserts, as well as, advertising
products are printed. The total product values from the industry in 1976 was
about $2.1 billion. The projected annual real growth rate through 1985 is
about 7%. The industry is fairly concentrated with only 17 parent companies,
owning fewer than 30 plants throughout 15 States. Most of these plants are
located on the East Coast and Midwest parts of the country.
An estimate of VOC emissions from this industry is shown in Figure B. In
1977 the total potential emissions were about 137,000 MG. About 60% of these
were recovered. The source of these emissions are the solvent components in
the inks, varnishes, extenders, and solvent used. The typical solvent used is
a mixture of toluene, xylene, and naphtha.
Figure C shows the points where fugitive emissions can escape from a
printing unit. A typical printing press consists of several printing units.
The gravure printing method usually involves only four colors of inks, yellow,
red, blue, and black. Each printing unit handles only one color of ink. The
paper web is fed from a continuous roll of paper, and is guided between the
revolving gravure printing cylinder and a rubber roller of the first unit.
After the impression is made, the paper web travels up through an enclosed
dryer, where jets of heated air evaporate the volatile solvent. The web exits
the top of the dryer and is guided along rollers to the next unit.
In a well controlled plant, the solvent laden air in the dryer exhaust is
directed to a carbon adsorption system. Fugitive vapors result from solvent
evaporation in the ink fountain; the exposed part of the gravure cylinder, the
paper path from the cylinder to the dryer inlet, and from the paper after
exiting the dryer. On newer presses, these fugitive losses are minimized by
enclosing the ink fountain, extending the bottom of the dryer closer to the
printing cylinder, and providing only small slit openings for the web entrance
and exits. At their newest presses, most of these fugitive vapors are captured
and directed along with the dryer exhaust to a carbon adsorption system.
A schematic of the fugitive emissions capture system installed at the
newest Meredith/Burda facilities is shown in Figure D. A cabin enclosure is
V-l
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installed over the top portion of the printing press, shown here consisting of
four printing units. The fume pick-up nozzles, located on the bottom of the
cabin, draw in solvent laden air from around the printing units. The captured
fugitive solvent vapors are then directed alonq with the dryer exhaust from
each printing unit, and sent to a carbon adsorption system. In addition,
several floor sweeps, installed around the press, are also vented to the
adsorber system. The integration of a cabin enclosure and floor sweep vents,
with the dryer exhaust collection represents the Best emissions capture system
in this industry.
A flow diagram showing emission points of a printing facility is presented
in Figure E. Liquid solvent in inks, varnishes, and extenders are metered into
the press, as well as, liquid solvent added for printing and cleaninq. Some of
the solvent leaves the press as fugitive vapor emissions. The printed product
retains about 3% of the total solvent used at the press. Recovered used dirty
solvent from cleaning operations, and any waste inks are processed for solvent
recovery. The recovered solvent from the captured vapors are recycled for use
as dilution solvent. The excess recovered solvent can be sold as a by product.
The value of the recovered solvent produces a profit.
Emission control tests were conducted at two plants. Figure F shows a
schematic of the control systems used at each facility. The new presses at
Meredith/Burda represent the BEST controlled facilities in this industry. A
solvent volume balance around the presses, based on direct liquid meter readings,
was used to determine the overall control efficiency. The dryer exhaust as
well as most of the fugitive emissions were collected for a total capture
efficiency of almost 97%, and an overall control efficiency of about 95%.
Because the Meredith/Burda facilities had several unique features, a
second plant was tested. The Texas Color Printers plant represents typical
WELL controlled facilities. A solvent volume balance was conducted during
this test also. Only the dryer emissions were captured, representing almost
86% of the total solvent used at the press. The resulting overall control
efficiency was about 83%. Most of the fugitive emissions were collected by
floor sweeps; however, the solvent vapors are vented directly to the atmosphere.
A summary of results by five different data sources for tests conducted
at these two plants, is shown in Figure G. The EPA tests at Meredith/Burda,
covered over 51 hours, resulting in an overall efficiency of over 94%, with an
adsorber efficiency of 98%. The Grayure Research Institute conducted parallel
tests, for a total of 78 hours. Their results showed an overall efficiency of
93%, with an adsorber efficiency of 99%. The ink and varnish analyses used by
both the EPA and the Gravure Research Institute were obtained from the ink
manufacturer. In addition, the Meredith/Burda plant sent data which showed an
average overall efficiency for two months of 95%.
One EPA test at the Texas Color Printers plant, covered 27 hours resulting
in an overall efficiency of over 84%, with an adsorber efficiency of 96%. A
second EPA test covered 82 hours. The resulting overall efficiency was over
83%. The Gravure Research Institute also conducted parallel tests on same
data resulting in overall efficiency of 98%. In addition, the Texas color plant
V-2
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sent data covering a five month period, showing an average overall efficiency
of 81%.
The adsorber efficiencies were obtained by gas phase analyses in all
tests. The overall efficiencies were based on solvent volume balances derived
from direct liquid meter readings. These readings were not corrected for any
possible temperature variations Because no temperature indicators or recorders
were installed at any of the meters.
The recommend standards are based on the test results from the BEST con-
trolled facilities, as shown in Figure H. The two Meredith/Burda test results
from the Figure G average about 95% overall efficiency. It is realized that
the Meredith/Burda facilities are rather unique by using expensive European
style inks, pure toluene as solvent, and a cabin enclosure above the presses.
However, plants using conventional inks can be designed to give comparable
recovery efficiency.
To show this, we calculated the potential overall recovery efficiency for
the Texas Color Printers plant. The floor sweeps around these facilities are
vented directly to the atmosphere as shown in Figure F. However, directing the
floor sweeps vents into the adsorber system could raise the overall efficiency
to about 91%. This calculation was based on gas phase analyses of the floor
sweep vents, and assuming the adsorber outlet concentration would remain the
same at the higher air flow rate.
Six model plants were developed as shown in Figure I. Two plant sizes
were considered: a small plant consisting of two eight-unit presses, and a
large plant consisting of four eight-unit presses. Three regulatory alter-
natives were applied to each plant. A 75% control level represents capturing
the dryer exhaust from older presses - baseline case. This corresponds to the
control techniques guideline (CTG) recommendation for existing facilities,
which the States, are expected to use in developing their State Implementation
Plans (SIP). The 80% control level represents capturing the dryer exhaust from
new presses. This corresponds to a typical, WELL controlled facility. The 90%
control level represents capturing the dryer exhausts from new presses, as well
as, most of the fugitive emissions. This corresponds to the BEST controlled
facility as demonstrated at the Meredith/Burda plant. Fixed bed carbon adsorp-
tion systems, with a 95% recovery efficiency, were used for all six models.
Environmental, energy, and economic analyses were conducted for all six model
plants to determine the impacts of controlling VOC emissions from this industry.
Results of the projected 1985 environmental impacts are shown in Figure J.
The potential VOC emissions are projected to be about 236,000 MG/year. If all
new facilities were controlled at 80% level, with existing facilities controlled
at the 75% level, the emissions would be reduced about 7% from baseline control.
Similiarly if new facilities were controlled at the 90% level, the emissions
would be reduced about 20% from baseline control.
Resulting secondary emissions from steam and electrical power generation
are considered to have minor impacts.
Resulting waste-water impacts of the condensate from steam regeneration of
the carbon adsorbers, are considered to be minor.
V-3
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Results of the projected 1985 direct energy impacts are shown in Figure
K. The industries gross energy consumption for steam and electrical power
generation would increase by about 3% from baseline, if all new facilities
were controlled at the 80% level. If all new facilities were controlled at
the 90% level, the energy consumption would increase by about 7%.
However, Figure L shows that there would be national net energy savings
when the fuel energy value of the recovered solvent is considered. There were
net energy savings for all model plant cases studied.
The results of the economic analysis are shown in Figure M. Controlling
all new presses at the 80% level would increase the capital cost of emission
control by about 6% over baseline control. Control at the 90% level would
increase the capital costs by about 36%. However these costs are more than
offset by the value of the recovered solvent, resulting in annual savings for
all three control levels.
These savings make the installation of emission control solvent recovery
systems profitable, even at the highest, 90%, control level. This economic
analysis was based on a combination of both small and large model plants,
totaling 75 new presses by 1985.
The recommended standard, based on the presented analyses, is shown in
Figure N. The emissions of volatile organic compounds (VOC) from new, modified,
and reconstructed facilities would be limited to 10% of the total solvent
volume used at the press. Emissions will be determined by a solvent volume
balance derived from direct liquid meter readings.
Affected facilities would be exempt from the standard if they use water-
borne inks, where the organic solvent comprises not more than 10% of the total
water and organic solvent volume as applied at the gravure cylinder.
These recommend standards are based on the cumulative test results of the
EPA and Meredith/Burda tests at the Meredith/Burda plant, and the calculated
potential efficiency of Texas Color plant.
The performance testing, monitoring, and reporting requirements are
presented in Figure 0. The performance test will be based on a 30 successive
calendar day, liquid material balance. The monitoring requirements will
consists of daily ink and solvent meter readings. Temperature corrections of
the meter readings will not be required. The meters must be recalibrated at
least semi-annually. The inks, extenders and varnishes must be analyzed for
volatile organic content. The reporting requirements will include notification
of construction and start-up, as well as, performance test results. Only
quarterly reports will be required as long as the standards are met. However,
additional monthly reports will be required for any month for which emissions
exceed the standard.
V-4
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INDUSTRY PROFILE
(SIC 27541 & 27543)
o Affected Facilities — Web (Roll) Fed Presses
© $2.1 Billion Product Value (1976)
£ 7% Annual Real Growth Rate Projected
through 1985
a 27 Plants in 15 States — 17 Parent
Companies
Figure A.
VOC EMISSIONS (1977)
• 137,000 MG Potential Emissions
• 60% Recovered
o VOC Emissions from Solvent Components
in Inks, Varnishes, Extenders and Solvent
Used at Presses
3
Figure B.
V-5
-------
PAPER
WEB
STEAM
HEATING
COIL
DOCTOR o o
BLADE
WEB
ROLLER
DRYER
"" EXHAUST
(SOLVENT
LADEN AIR)
WARM AIR NOZZLE
DRYER
DRYER INLET AIR FLOW
FUGITIVE SOLVENT VAPOR
FUGITIVE SOLVENT VAPOR
EMISSIONS AROUND A
GRAVURE PUBLICATION
PRINTING UNIT Figure C. 4
-------
SLA* TO
ADSORBER-
SYSTEM
CABIN ENCLOSURE
UPTAKE DRYER
OUTLETS (TYPICAL)
PRESS UNIT
•SLA • SOLVENT LADEN AIR
PUBLICATION ROTOGRAVURE PRINTING PRESS
FUGITIVE EMISSIONS CAPTURE SYSTEM
Figure P. 5
SOLVENT— VOC FLOW DIAGRAM
SOLVENT IN
INKS, VARNISHES,
& EXTENDERS
SOLVENT
ADDED FOR
PRINTING/CLEANING
TOTAL SOLVENT
USED AT PRESS
RECYCLE
FUGITIVE
VOC EMISSIONS
PRODUCT
RETAINED
SOLVENT
USED DIRTY
SOLVENT
WASTE INKS
RECOVERED
SOLVENT FROM
CAPTURED VOC
RECLAIMED
•RECLAIMED
SALES
Figure
V-7
-------
SCHEMATIC OF CONTROL
SYSTEMS AT TESTED PLANTS
Meredith/Burda
PRESS
CARBON
ADSORBER
(98%)
Texas Color
PRESS
DRYER EXHAUST
CARBON
ADSORBER
(97%)
FUGITIVE EMISSIONS
OVERALL
95%
CONTROL
OVERALL
83%
CONTROL
figure F.
SUMMARY OF RECOVERY
EFFICIENCIES
Data Sources
EPA
EPA
GRAVURE RESEARCH
INSTITUTE
MEREDITH/BURDA
TEXAS COLOR
PRINTERS
Meredith/
Burda
Overall
94.4%
—
93.0%
95.7%
—
Adsorber
98%
—
99%
—
—
Texas
Color
Printers
Overall
84.9%
83.1%
81.5%
—
81.0%
Adsorber
96%
—
98%
—
—
Fiqure 6.
V-B
8
-------
REGULATION DATA BASE
Overall
Data Sources Efficiencies
EPA TEST 94.4%
MEREDITH/BURDA TESTS 95.7%
CALCULATED POTENTIAL 91.0%
TEXAS COLOR TEST
Figure h.
MODEL PLANTS/
REGULATORY ALTERNATIVES
PlantSizes
• Small 2/8 Unit Presses
• Large 4/8 Unit Presses
Regulatory Alternatives
o 75% Dryer Exhaust/Older Presses
(Baseline)
• 80% Dryer Exhaust/New Presses
o 90% Dryer/New Presses/Fugitive
10
Fixed Bed Carbon Adsorption
Figure I.
• V-9
-------
t"vr-.*i.'*»;-c~
r-j*—',!?*;•?"• '
=*?»>*-_ 'if.- _
ENVIRONMENTRAL IMPACTS (1985)
VOC EMISSIONS
Reduction
from
MG/Year Baseline
Potential
75% Baseline
80%
90%
236,000
59,000
55,000
47,000
7%
20%
WASTEWATER AND SOLID WASTE IMPACTS ARE
MINOR
Figure J-
DIRECT ENERGY IMPACT
(1985)
Control
Levels
75% Baseline
80%
90%
Industry Increase
Gross Energy From
Consumption, GJ Baseline
2.6 X 106
2.7 X 106
2.8 X 106
BASIS: Steam + Electrical Power
Figure K.
V-10
3%
7%
12
-------
NET ENERGY IMPACT (1985)
Control
Levels
75% Baseline
80%
90%
National Net
Energy Savings
GJ
5.6 X 106
5.8 X 106
6.0 X 106
Savings
Over
Baseline
3%
7%
BASIS: Steam + Electrical Power
+ Recovered Solvent
Figure L.
13
COSTS OF VOC CONTROL
(1985)
Installed Increase Annual
Control Capital Cost From Savings
Levels ($ millions) Baseline($ millions)
75% Baseline 46.2
80% 48.9
90% 62.7
6%
36%
4.2
4.6
2.9
BASIS: 75 New Presses
No Modified or Reconstructed Presses
14
Figure M.
v-n
-------
RECOMMENDED STANDARDS
FOR ROTOGRAVURE
INDUSTRY
o 10% VOC Emission Limit
(90% Overall Recovery)
• Water-Borne Inks-Exempt if Volatile Portion
Contains Less Than 10% VOC At Press
15
Figure N>
PERFORMANCE TESTING,
MONITORING, & REPORTING
• Performance Testing - 30 Day Liquid Material Balance
• Monitoring . - Daily Ink/Solvent Meter Readings
- Semi-Annual Calibrations
-Ink Analyses
• Reporting -Notification of Construction and
Startup
- Performance Test Results
-Quarterly-Meet Standards
— Monthly-Excess Emissions
16
Figure O.
V-12
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B. PRINTING INDUSTRY PRESENTATIONS
1. Sravure Research Institute, Inc.
Mr. Harvey George
Gravure Research Institute, Inc.
22 Manhassett Avenue
Port Washington, New York 11050
We appreciate this opportunity to comment on the draft of the New Source
Performance Standards for Volatile Organic Chemical Emissions from the Publication
Rotogravure Printing Industry.
We are members of the GRI/GTA Gravure Industry Emission Control Sub-
committee. Gravure Research Institute is the cooperative research organization of
the gravure industry and Gravure Technical Association is our industry trade associ-
ation concerned with industry standardization, trade relations, education, etc. Between
Gravure Research Institute and Gravure Technical Association we represent all the
publication gravure printers in the United States. Our Committee has extensive
experience in gravure printing technology, the manufacture and use of gravure inks
and in environmental control as related to gravure printing. Our Committee has spent
many hours in meetings and conferences with the United States Environmental
Protection Agency in commenting on and assisting in the development of the CTG
document, Control of Volatile Organic Emissions from Existing Stationary Sources —
Volume VIII: Graphic Arts — Rotogravure and Flexography, which sets forth
Reasonably Available Control Technology (RACT) for publication rotogravure and
on the Lowest Achievable Emission Rate (LAER) guidance document for the graphic
arts and on the New Source Performance Standards (NSPS) for publication roto-
gravure now under discussion.
The NSPS as presently proposed is neither realistic nor justified in our view
and will have a serious effect on the future operations of publication gravure printers,
most of whom have already demonstrated their desire and willingness to reduce air
pollution from their operations, both from the standpoint of public interest and in
the interest of production efficiency. More than three quarters of the publication
gravure printing plants that are operating today already have solvent recovery systems
in operatfon and the remainder will soon control their emissions as a result of the
RACT regulations to be implemented by the states and local agencies in the coming
year. The proposed NSPS will have an insignificant effect on the achievement of
national ambient air quality goals over what has already been accomplished by the
industry voluntarily and by the further steps necessary to comply with already promul-
gated RACT, BACT, emission offsets required in clean air areas, and LAER regulations.
In view of the high cost of gravure solvents these solvent recovery systems will be
operated at the highest practical efficiencies for each particular installation, not just
at the RACT level of 75% overall emission reduction. Thus, the assertion that emissions
would be reduced by 20% by 1985 over that if no NSPS were adopted, is incorrect.
V-13
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Mr. Don R. Goodwin
U.S. Environmental Protection Agency — 2 —
=S Before commenting in detail on the draft NSPS and the Background Information
Document (BID) which accompanies it, we would like to state that the BID is a compre-
hensive document and you will note that our industry has contributed extensively in
providing information necessary to the preparation of this document. We will not
comment in detail on the BID at this time. While the BID has essentially the required
information to develop a realistic NSPS, this information has not been used properly
to that end. Instead, much of the pertinent test data and other required information
appears to be disregarded and an incorrect conclusion drawn from the unsupported
experience of one atypical publication gravure printer.
The draft of the NSPS of November 2,1979 would limit the emission of volatile
organic compounds from a publication rotogravure press to 10 percent of the solvent
used for that press, unless it is demonstrated that the retained solvent in the printed
product is of necessity greater than 3 percent. If this exception can be demonstrated,
the proposed emissions limit would be 10 percent of the total solvent used plus the
amount of solvent retained in the product in excess of 3 percent of the total solvent.
Total solvent includes all solvent added to the ink used at the press, all solvent used as a
cleaning agent around the press and all solvent added by the ink manufacturer to the
ink used at the press. An emission limit of 10 percent is not achievable on a consistent
long term basis under practical operating conditions for new or modified publication
gravure sources in the carefully considered judgment and experience of our Committee.
The reasoning by which this proposed 90 percent emission control standard was
arrived is given in the associated BID. This document states explicitly on page 2.3 that
'They (i.e., the standards of performance) are designed to reflect the degree of emission
limitation achievable through application of the best adequately demonstrated
technological system of continuous emission reduction. This should take into consider-
ation the cost of achieving such emission reduction, any non-air quality health and
environmental impact and energy requirements."
The proposed 90 percent emission reduction does not meet these requirements
even if only the results of the two extensive tests conducted by EPA at Meredith/
Burda and Texas Color Printers, and the three materials balance surveys by EPA at
Meredith/Burda, Texas Color Printers and World Color Press are considered. The pro-
cedure for development of standards of performance is outlined in Section 2.3 of the
BID. According to this section the "Standards of performance must:
1. Realistically reflect the best demonstrated control practice;
2. Adequately consider the cost and non-air quality health and environmental
impacts and energy requirements of such control;
3. Be applicable to existing sources that are modified or reconstructed as well as
new installations; and
4. Meet these conditions for all variations of operating conditions being considered
anywhere in the country/'
This is amplified starting with the last paragraph on page 2-7.
"A process for the development of a standard has evolved which takes into account
the following considerations.
V-14
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Mr. Don R. Goodwin
U.S. Environmental Protection Agency
1. Emissions from existing well-controlled sources as measured.
2. Data on emissions from such sources are assessed with consideration of such
factors as: (a) how representative the tested source is in regard to feedstock,
operation, size, age, etc.; (b) age and maintenance of the control equipment
tested; (c) design uncertainties of control equipment being considered; and
(d) the degree of uncertainty that new sources will be able to achieve similar
levels of control.
The proposed 90 percent standard was arrived at by considering only the figures
from part of the Meredith/Burda plant which includes only two production presses and
no proof press as in the model plants of the BID, neglecting the data from Texas Color
Printers and World Color Press, which according to the document, operate modern,
efficient solvent recovery systems for pollution control and have proof presses.
We will show that some errors can be introduced by the fact that only a part of a
plant was measured at Meredith/Burda. Meredith/Burda also has a product mix which
is not typical of the American gravure industry as a whole. Most important, the type of
solvent used at Meredith/Burda — pure toluene — is less volatile and thus easier to control
than the solvent mixtures used by 25 out of 27 gravure publication plants in this country.
Adoption of an ink and solvent system such as that used by Meredith/Burda to
comply with a 90 percent standard would result in higher ink costs than can be justified
for many products, possible supply difficulties, possible conflicts with present and future
OSHA regulations which consider toluene in the pressroom air more toxic than the
conventional solvent mixes and finally no benefits as far as the reduction of photo-
chemical oxidants in urban atmospheres are concerned.
The document purports to show the desirability of a 90 percent emission control
level as compared with levels at 75 percent and 80 percent In view of the higher in-
cremental costs of increasingly high emission control levels,«*w*jw«**««M«b^fa*e»»4««l
4aMLA£ASHMEeABfcdMafcaafaa0MTCto»Mlp A level of 75 percent was recently adopted by the
EPA in the "Guidance to State and Local Agencies in Preparing Regulations to Control
Volatile Organic Compounds from Ten Stationary Source Categories". These guidelines
apply to existing plants. A control level of 80 percent is also analyzed in the BID. EPA
tests and surveys for plants operating modern solvent recovery systems and having
product mixes and ink/solvent systems typical for the American publication rotogravure
industry clearly indicate a control level of 82 percent. This figure is based on materials
balances covering a total plant performance at Texas Color Printers and World Color Press
of about 82 percent as shown in Appendix C of the background document, assuming that
the sweeps as well as the dryer exhausts will be led to the solvent recovery for the control
of unintentional fugitive emissions giving an overall emission control of 87 percent and
after making a 5 percent provision for control equipment maintenance and aging of the
carbon beds. This 5 percent adjustment is especially critical in plants printing current news
features with tight deadlines and for the variations in workload and solvent recovery
system efficiency that occur in the typical publication gravure plant.
V-15
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Mr. Don R. Goodwin ,-.L
U. S.~ Environmental Protection Agency — 4 —
The Meredith/Burda plant in Lynchburg, Virginia operates 6 production presses,
two of which are located in a new pressroom and are controlled by an independent
new solvent recovery. Two open entrance ways, each 12 x 14 ft in area, connect the
new pressroom to the older pressrooms. In view of the extremely high rates of air change
in gravure pressrooms, 5 minutes typical, the possibility exists that solvent laden air could
have been drawn between pressrooms leading to possible increased apparent overall
efficiencies. Because of interconnections between tanks servicing new and old pressrooms,
the ink and solvent meter readings could not be verified by tank level readings, as was
for instance, done at Texas Color Printers. In addition, the ink and solvent meters were
not calibrated as was suggested by our Committee and as required in the proposed stand-
ard . «M4MMiHMMMa*Mw^i«Wtt*ttdft*M*i0Heea^^
«a**MW*4«fifcilMb£&^iifeor the materials balance data furnished by the printer.
The slow and intermittent operations of proof presses with their open fountains and
constant need for clean-up cause dilution of the air stream going to the recovery and
thus promote inefficiency. -Proof presses are an essential part of publication gravure
operations as is indicated in the model plants of the BID, all of which include a proof
press.
The product mix at Meredith/Burda is not representative of that of the American
rotogravure industry as a whole. The plant specializes in long run products of high print
quality. Press runs of 10 to 14 million copies are typical. These long runs promote
consistent press operations and steady rates of air flow of high solvent concentrations to
the recovery. This in turn promotes high recovery efficiency in terms of emissions control
and steam consumption. The product mix contains little or no publications containing
current news features, i.e., the products can be run well before issue date. This promotes
steady use of the solvent recovery at optimum loads and facilitates scheduling of
maintenance. These standards cannot be applied to plants printing current news related
items with tight deadlines or plants requiring frequent press stops due to makeready,
engravers corrections, web breaks, etc.*
before job or edition changes
rVVhen a press is down, all
parts of the press have to be readily accessible to the pressmen for re-webbing and
clean-up. An upper press enclosure which has to be purged of solvent vapors before
the pressmen can gain access to the upper press is likely to prove impractical in plants
printing shorter runs or on poorer paper grades.
The use of pure toluene at Meredith/Burda promotes high capture and recovery
efficiencies. 4laiMtt*WB*<»d»*»«aa.ailamMala»<»*^^
I JoijijJ binrii>jiEd purn ttrtritrrnrniriT^njtTtrrrt. The other 25 plants use a binder
derived from tall oil, a by-product of the southern forest products industry and a solvent
mix consisting roughly of 18—35 percent toluene and 65— 82 percent aliphatic hydro-
carbons. *i«8«*wiw^9aW»*««'Www*«wfc*»*«"**wwT*B*^^
However, the widespread use of pure toluene to achieve a 90 percent emission
reduction in new plants is undesirable for the following reasons: *B*BWW is used to
raise the octane rating of non-leaded motor
release of pure toluene from tall oil derived rosin binders is slower than that of the mixed
solvent leading to drying and color register problems on poorer paper grades. Printing
requires the continuous presence of press operators on the press. The ambient press-
room air must therefore meet at lease current and anticipated OSHA air quality limits.
V-16
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Mr. Don R. Goodwin
U. S. Environmental Protection Agency — 5 —
JGftl«aB»w*BWWty«weH*w*«wrtwtam the aliphatic hydrocarbons with current
8-hour OSHA mandated exposure limits of 200 ppm for toluene and 500 ppm for
aliphatics. OSHA is presently considering lowering the exposure limit for toluene to
100 ppm with a 50 ppm action level. Using a formula published by OSHA for mixed
vapors and assuming that the vapor in the pressroom air is 25 percent toluene, the
permissible limit for the conventional mixed solvent is 344 ppm with a 200 ppm limit
for toluene, and 227 ppm with a 10Qppm limit for toluene. The requirement to meet
current or anticipated OSHA standards by a safe margin is critical to any decision as to
plant expansion or new plant construction. XhaaMmponmirtRC0n«RMMlMaMMi«Mi
Solvent recovery systems are heavy users of energy in the form of steam and
electric power. After the solvent laden air has deposited its solvent on the adsorbing
carbon, the solvent fs stripped from the carbon beds by steam. Most of the steam is
used in heating the large adsorber vessels and carbon beds and to carry the liberated
solvent fumes to the condenser: Electric power is used to drive the solvent laden air
through ducts, filters and the carbon beds. The efficiency of steam and electric power
use have to be considered in three aspects:
1. Energy economy per se
2. Energy as a factor in operating costs
3. The secondary pollution associated with the generation of steam and electric
power.
The background information document purports to demonstrate the desirability
of a 90 percent emission reduction over reductions of 75 percent and 80 percent. In
Table 7-3 and the subsequent analysis of economics and secondary pollution the assump-
tion is made that the steam to solvent ratio remains fixed at 4 Ibs. of steam per Ib. of
solvent at 75 percent, 80 percent and 90 percent overall recovery efficiency. This
assumption violates the rule that the energy input increases almost asymptotically as
permissible emissions are reduced to very small values. At a 96 percent assumed carbon
bed efficiency for a mixed solvent and a bed that has been used for a reasonable time,
and 3 percent solvent retention in the product, all but 3 percent of the solvent used on
the production presses, proof presses and in clean-up of ink soiled press parts would
have to be captured to achieve 90 percent overall recovery efficiency. This implies that
the recovery has to be operated at full or reduced capacity at all times when there is
any activity in the pressroom and when even minor amounts of solvent can be liberated.
The time periods involved can be from 20 percent to 35 percent of the scheduled running
times. The few percent of solvent recovered during these time periods do not justify the
amounts of electric power and steam used to purify air of very low solvent vapor content.
As far as the enforcement aspects are concerned, we agree with the materials
balance concept. There are certain difficulties with the periodic calibration of ink meters.
We advocate the optional use of ink delivery tank truck meters and plant tank level
readings. In our opinion, the purely volumetric condensate meters often used to measure
the recovery solvent do not require periodic calibration.
V-17
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Mr. Don R. Goodwin
U.S. Environmental Protection Agency — 6 —
In conclusion, the proposed reduction requirement of 90 percent of solvent
emission is not adequately demonstrated and is based on data of questionable accuracy
from part of a plant without a proof press that is not typical of the American publi-
cation gravure industry in product mix and ink solvent. Widespread adoption of this
solvent by other plants is either not possible at all or could result in serious cost and
supply problems, conflicts with OSHA regulations and would likely have no beneficial
effect on air quality. We feel that a NSPS is not necessary and will contribute little to
the improvement of national ambient air quality over what is already being accomplish-
ed with existing regulations. Nevertheless, if a NSPS is to be promulgated, the tests and
survey records, as a whole, when adjusted for improvements that can be made in new
plants, indicate a reduction of 82 percent. We recommend as a realistic and feasible
NSPS for publication rotogravure that emissions be limited to 18 percent of total solvent
used at the press unless it is demonstrated that more than 3 percent of the total solvent
is by necessity retained in the printed product Adoption of the 90 percent reduction
and the risk that new plants cannot meet this level and still stay within OSHA regu-
lations and reasonable energy economy, will greatly hamper the modernization of old
plants or new plant construction. This would have a detrimental effect on the growth
of the publication rotogravure industry, the economic well being of its many employees
and related industries. It would also discourage investment in new plants and equipment
and promote the use of obsolescent equipment which was not designed for optimum
energy economy and state of the art pollution control.
Thank you for this opportunity to comment on the draft standard. Our Committee
will be pleased to work further with you on the development of a realistic and achiev-
able NSPS. If we can answer any questions we will be pleased to do so/
;
Yours sincerely, , /
-./. .. /
«.
-^Harvey F/George «-
Chairman
GRI/GTA Gravure Industry
Emission Control Subcommittee
HFG:tm
V-18
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2. Regenerative Environmental Equipment Co., Inc.
Mr. Rodney L. Pennington
Regenerative Environmental Equipment Co., Inc.
Box 600, 520 Speedwell Avenue
Morris Plains, New Jersey 07950
The presentation of Mr. R.L. Pennington was based on the following paper,
which he sent to Don Goodwin on November 29, 1979.
Gentlemen:
In reviewing the draft regulations for the publication rotogravure
printing Industry we find that although some oxidation equipment has been
mentioned as an alternate solution, the real potential in cost effec-
tiveness needs additional clarification.
Highly efficient thermal oxidation equipment with 85-95% primary heat reco-
very is being installed on printing processes with very cost effective
control. The high thermal energy recovery of RE-THERM Units allows systems
to operate at a "NIL" fuel usage plus providing all of the necessary pre-
heated drying air to the presses. The utilization of the clean exhaust
from the RE-THERM Unit for direct feedback or steam generation for heating
the presses as well as for building space heating can be substantial. This
should be considered even though the dryers operate at a low temperature.
REECO RE-THERM System operating on the model small plant parameters at an
overall average pollution control efficiency of 75% for a publication
rotogravure process. You will note that the overall cost effectiveness in
this application is very attractive and will improve on larger plant opera-
tions in that the cost of equipment per CFM decreases with increase in
size. In addition to the cost effectivenes, the RE-THERM System can be
installed with very little or no loss production time. Auxiliary support
facilities such as added steam capacity and cooling water are not required
with the RE-THERM Unit. Also, the initial capital cost of the RE-THERM
System will generally run 25-35% less than the costs the EPA shows for a
comparable solvent recovery system.
We trust that the above point, that volatile organic compound control can
be achieved while still reducing the overall plant energy consumption and
providing very cost effective control will be clarified in your final
report to the industry.
Respectfully yours,
Rocrney L.; Pennington
Sales Manager
R LP '. jd Energy and the Environment
Attachment V-19
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REGENERATIVE ENVIRONMENTAL EQUIPMENT CO., INC.
US ENVIRONMENTAL PROTECTION AGENCY
Mr. Donald Goodwin
November 29, 1979
Page 1 of 5
PLANT DESCRIPTION
The plant is comprised of two (2) eight-unit presses with a scheduled
operation of 7,296 HRS/YR and a 65% utilization or 4,740 HRS/YR actual
operation.
PROCESS EXHAUST FLOW: 50,283 SCFM (53,300 ACFM @ 105°F)
AVERAGE SOLVENT LOADING: 1,487 LBS/HR (3,525 TONS/YR)
FUEL COST: Natural Gas - $3.00/MM BTU
Steam - $4.10/1000 #
ENGINEERING ANALYSIS
The typical approach for this application would be to connect all of the
exhaust stacks from the press above the roof to a common header and direct
the exhaust flow into a single 50,000 SCFM RE-THERM Unit. The clean
discharge from the RE-THERM Unit would be directed through a waste heat
boiler which would have the potential of generating 165 boil horsepower at
15 PSI of steam to be utilized in heating the press as well as providing
building and/or other process heating requirements. In this application,
only the heating requirements for the press line are considered in the
financial analysis.
FINANCIAL ANALYSIS
The objectives of the financial analysis are to determine the extent to
which a requirement for control equipment impacts the "typical" firms pro-
fitability and working capital requirements and to estimate the cost per
pound of pollutant reduced, that is, to measure the cost effectiveness of
the control equipment to society. Plant operators are interested in the
former two (2) while pollution control authorities are interested in the
latter.
V-20
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REGENERATIVE ENVIRONMENTAL EQUIPMENT CO., INC.
US ENVIRONMENTAL PROTECTION AGENCY November 29, 1979
Mr. Donald Goodwin Page 2 of 5
The financial analysis will be based on the following investment, operating
and financial inputs:
Investment Inputs -
50,000 SCFM RE-THERM $635,000
Ducting & System Installation $160,000
Waste Heat Boiler $ 50,000
Total Installed Costs $845,000
Operating Inputs -
Annual RE-THERM Fuel Costs $ 2,000
Annual RE-THERM Electrical Costs $ 12,000
Annual Press Fuel Savings ($ 73,800)
Annual Fuel Costs % Escalation 12%
Annual Maintenance & Labor Costs $ 3,500
Annual Maintenance & Labor Costs % Escalation 8%
Financial Inputs -
Years Analyzed 10 Years
Depreciation Period 10 Years
Depreciation Method Straight Line
Local Property Taxes (LPT) & Insurance 2%
Combined Federal & State Income Tax 50%
Investment & Energy Tax Credit 20%
Interest Rate (Based on tax free bonds) 10%
The impact on company profitability is determined by estimating the total
and average capital and operational costs for the RE-THERM System over its
ten (10) year life. Capital for the system is derived from the tax credit
and through an add-on loan as follows:
Investment $845,000
Less Tax Credit $169,000
Amount to be Financed $676,000
Period Financed 10 Years
V-21
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REGENERATIVE ENVIRONMENTAL EQUIPMENT CO., INC.
US ENVIRONMENTAL PROTECTION AGENCY
Mr. Donald Goodwin
November 29, 1979
Page 3 of 5
The interest expense and repayment schedule for this type loan is as
follows:
Year
0
1
2
3
4
5
6
7
8
9
10
@ Repaid
0
$67,600
$67,600
$67,600
$67,600
$67,600
$67,600
$67,600
$67,600
$67,600
$67,600
Principal
$676,000
$608,400
$540,800
$473,200
$405,600
$338,000
$270,400
$202,800
$135,200
$ 67,600
0
Interest
$67,600
$60,840
$54,080
$47,320
$40,560
$33,800
$27,040
$20,280
$13,520
$ 6,760
0
Total costs comprised of fuel, maintenance, local property tax and
insurance, interest expense and depreciation can be calculated for each
year of the ten (10) year life. This has been done and is detailed on the
attached "Financial Analysis Work Sheet". Samples for years one (1) and
eight (8) are shown below:
Fuel (savings)
Maintenance
LPT & Insurance
Interest Expense
Depreciation
Total Costs
Year One (1)
($ 59,000)
$ 3,500
$ 16,900
$ 67,600
$ 84.500
$112,700
Year Eight (8)
($132,199)
$ 5,998
$ 16,900
$ 20,280
$ 84.500
$ 4,521
The ten (10) year total costs is $343,514 resulting in an average annual
cost of $34,351. That is, were the company unable to secure an increase in
price for its product, it would incur a loss of approximately $34,000 each
year. Using the average solvent usage rate of 1,487 #/Hour and 4,740 hours
of operation per year we find that:
# Solvent Controlled/Year =
Average Yearly $/# Cost =
5,287,500 #
(6/10 of !?/#)
$12.99/TON
V-22
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REGENERATIVE ENVIRONMENTAL EQUIPMENT CO., INC.
US ENVIRONMENTAL PROTECTION AGENCY
Mr. Donald Goodwin
November 29, 1979
Page 4 of 5
Impact on working capital, that is, the amount of money that need be
borrowed to finance both equipment acquisition and operation is determined
by changes to cash flow as opposed to profits. Changes to cash flow are as
follows:
Total Costs (-)
Loan Repayment (-)
Tax Credit (+)
Depreciation (+)
Tax Saving (+)
Net Cash Flow
Year One (1)
-$112,700
-$ 67,600
+$169,000
+$ 84,500
+$ 56,350
+$242,250
Year Eight (8)
-$ 4,521
-$ 67,600
0
+$ 84,500
+$ 2,260
+$ 14,640
Again, specifics for each of the ten (10) years are tabulated on the
attached "Financial Work Sheet". Total net cash flow is a positive
$252,636 and the average annual net cash flow is a positive $25,263.
According to the EPA's model plant annual operating income and profit, the
average pretax profits are 8% of sales for the publication rotogravure
printing for firms in the $36,000,000 sales per year. On this basis, we
find that:
Pretax Profits
Less Average Annual PC Costs
Adjusted Pretax Profits
% Reduction in Annual Pretax Profits
The financial analysis is summarized as follows:
PROFITABILITY
Average Annual Capital & Operating Cost
10 Year Total Capital & Operating Cost
% Reduction in Annual Pretax Profits
WORKING-CAPITAL
Average Annual Net Cash Flow (positive)
10 Year Total Net Cash flow (positive)
POLLUTION CONTROL COST EFFECTIVENESS
Dollars Per Pound
Dollars Per Ton
36 MM/YR
$2,834,300
$ 34,351
$2,799,949
1.2%
V-23
$ 34,351
$ 343,514
1.2%
$ 25,263
$ 252,636
S0.006/J?
$12.99/TON
-------
US ENVIRONMENTAL PROTECTION AGENCY
Mr. Donald Goodwin
November 29, 1979
Page 5 of 5
$ COST/(SAVINGS):
FUEL
MAINTENANCE
LPT & INSURANCE
INTEREST
DEPRECIATION
1
( 59,800]
3,500
16,900
67,600
84,500
2
( 66,976)
3,780
16,900
60,840
84,500
3
75,013
4,082
16,900
54,080
84,500
4
84,015
4,409
16,900
47,320
84,500
5
94,096
4,762
16,900
40,560
84,500
6
105,388
5,143
16,900
33,800
84,500
7
118,035
5,554
16,900
27,040
84,500
8
132,199
5,998
16,900
20,280
84,500
9
148,063
6,478
16,900
13,520
84,500
10
165,830
6,997
16,900
6,760
84,500
TOTAL COSTS
112,700 99,044 84,549 69,114 52,626 34,955 15,959 4,521 -26,665 -50,673
ro
$ CASH FLCVJ:
TOTAL COST
LOAN REPAY
TAX CREDIT
DEPRECIATION
TAX SAVINGS
1
-112,700
- 67,600
+169,000
+ 84,500
+ 56,350
2
- 99,044
- 67,600
+169,000
+ 84,500
+ 49,522
3
- 84,549
- 67,600
+169,000
+ 84,500
+ 42,274
4
- 69,114
- 67,600
+169,000
+ 84,500
+ 34,557
5
- 62,626
- 67,600
+169,600
+ 84,500
+ 26,313
6
- 34,955
- 67,600
+169,600
+ 84,500
+17,477
7
- 15,959
- 67,600
+169,600
+ 84,500
+ 7,979
8
- 4,521
- 67,600
+169,600
+ 84,500
+ 2,260
9
+ 26,665
- 67,660
+169,600
+ 84,500
- 13,332
10
+ 50,673
- 67,660
+169,600
+ 84,500
- 25,336
NET CASH FLOW
+242,250 - 32,622 - 25,374 - 17,657 - 9,413 - 577 + 8,921 + 14,640 + 30,232 + 42,236
CUMMULATIVE
CASH FLOW
+242,250 +209,628 +184,254 +166,597 +157,184 +156,607 +165,528 +180,168 +210,400 +252,636
-------
C. DISCUSSION
Questions were asked by the committee members and a discussion of each
topic by the presenter, EPA staff members, and committee members followed.
A summary of the questions and topics discussed are given below:
NAPCTAC COMMITTEE:
1. Why are meter recalibrations required? Radian responded that the meter
manufacturers recommended semi-annual calibrations.
2. Is this printing process continuous? Radian ansv/ered that the printing
operations have numerous web breaks and other reasons for interruptions and
shutdowns; however, the plants do attempt to operate on a 24-hour basis.
3. Will uncontrolled presses, mentioned on page 6 of the Preamble, be
subject to the NSPS? EPA answered that existing facilities are regulated
by the state implementation plans (SIP). Only new, modified, and reconstructed
presses would be affected by the NSPS.
4. Is the 60% recovery, shown on slide 3, for 1977? What is present overall
industry recovery? Radian answered that all the data shown on slide 3 was
for the year 1977. Radian does not have sufficient data on the present
industry recovery operations. An industry representative commented that at
least three-fourths of the plants now have solvent recovery systems installed--
V-25
-------
by next year all plants will have the systems. The industry representative
mentioned that solvent recovery systems are not justified economic invest-
ments when considering the dollar savings and availability of solvent. The
industry is installing the solvent recovery systems for three reasons:
a) Public Interest
To comply with :
Because of increasing solvent costs
b) To comply with state and local regulations
0
The Gravure Research Institute (GRI) representative mentioned that
they have no quarrel with installing solvent recovery systems, but with
the recommended overall recovery efficiencies. The industry doesn't
feel it can operate at the higher recovery efficiencies.
5. Why is the recommended standard based on 3 percent solvent retention
by the product? Radian answered that a range of 2.5 percent to 7 percent
product retentions were mentioned in seven references obtained during
the study. A letter from the Meredith/Burda plant stated 3 percent
product retention, with an overall solvent recovery of 95 percent.
Therefore, the 90 percent reduction standard would already allow for
products which retain more solvent. Radian and the EPA did not know of
any reliable method to determine the solvent retained by the product.
However, any method proposed by the industry would be considered.
6. One member read the following list of questions and comments, which
he will submit in a letter to the EPA:
a) Is there a method for determining the amount of solvent retained
by the product? His references showed a range of 2 percent to
6 percent solvent retained.
b) How is the solvent lost from the press during cleaning to be
accounted for?
c) Why doesn't the standard include stack analysis?
d) Why is a capture hood required? It represents new and
underdeveloped technology. The containment cabin would be
expensive, require excess floor space, and cause an employee
safety problem.
e) The incremental costs between 90 percent and 75 percent recovery,
shown in Table 8-9 of the BID, seem low. Their estimate would
be more like $2.0 million.
f) The necessity for meters at each station would be a cost burden,
and require extra personnel time, resulting in loss of
productivity.
g) It was not clear how waste inks were to be handles in the
material balance.
Radian responded to only two of the comments: waste inks will be
included in future revisions to the draft regulation, and daily meter
readings are already taken by the industry for their own process monitoring
and customer billing purposes.
V-26
-------
7. The economic analysis presented on slide 14 is not complete enough.
An incremental cost effectiveness analysis must be done in the BID. It
appears that the economic analysis had been "hit and miss". Need to
combine the environmental, energy, and economic analyses together.
8. How was projected growth determined? Radian answered that the
7 percent real growth projection was based on industry data, with
limitations on availability of new presses, solvent, paper, etc.
9. What is the reason for the swings in the overall efficiencies, for
the World Color plant, shown in Figure C-l of appendix C? Both EPA and
Radian responded that world color captured only the dryer exhausts, and
the swings resulted from fugitive emission losses during normal
operations, as well as during the shutdown periods. The magnitudes of
the swings would not be expected to be as great for a capture system
as installed at the Meredith/Burda facilities. The EPA said the world
color data was presented to show the necessity for a long term, 30-day
test period.
The Gravure Research Institute commented that the data represented
the "Real World". The Meredith/Burda facilities are unique—they are
isolated, and could run more continuously, with less shutdowns, than
more typical plants in the industry. The Texas Color and World Color
plants could not be controlled like the Meredith/Burda facilities. It
would be a "quantive leap" to expect the Texas Color plant to capture
the fugitive emissions so its overall efficiency would increase from
81 percent to 91 percent.
INDUSTRY REPRESENTATIVES:
1. Would any press renovations fall under the NSPS? The EPA answered
that if emissions were reduced, it would not be considered a modification.
Existing plants won't be considered as modifications for just routine
repairs.
2. The industry objected to the wording regarding 75 percent controlled
for economic reasons, shown on page 3-20 of the BID. The EPA responded
by asking what control level would be more correct—80 percent or 85 percent?
The industry commented that the sentence had a mistaken premise, and
that plants are subject to other than economic reasons.
The meeting then continued with a presentation by Harvey George of
the Gravure Research Institute (GRI). His presentation will be submitted
in writing to the EPA. A summary of his presentation is itemized as
follows:
1. Recommended standard not justified; NSPS not necessary—would have
serious impact on the industry, and hamper growth.
2. Over three-fourths of plants now have solvent recovery systems.
V-27
-------
3. Baseline level should be higher than 75 percent, since existing solvent
recovery systems will be operated to achieve maximum efficiency.
4. 10 percent emission limit not achievable by typical plants—recommended
NSPS based on atypical (unique) Meredith/Burda plant.
5. Recommended NSPS does not meet requirements of Chapter 2 of the BID.
6. An 85 percent control level case should have been included in the
environmental, energy, and economic analyses.
7. Typical well controlled plant, like Texas Color, can only achieve
82 percent reduction.
8. Meredith/Burda test results were not accurate:
a) Solvent laden air drawn-in from other presses.
b) Meters not calibrated.
c) Proof presses not included.
d) Toluene not as volatile as typical solvents used.
e) Long, uninterrupted runs are not typical to other plants.
9. A cabin enclosure is impractical for typical plants.
10. Energy usage ratio held constant, as shown in Table 7-3 of the BID—
this is an incorrect assumption, as energy usage increases asymptotically
with increased solvent recovery.
11. Calibrated meters not a good enough monitoring system.
12. If NSPS promulgated, should be 82 percent reduction, or 18 percent
emission limit.
The following questions and comments concerning the GRI's views were
discussed:
1. Why is Texas Color efficiency only 82 percent? Why is the capture
efficiency so low? GRI answered that the dryer represents about 82 percent
of solvent used. If fugitive added in, efficiency goes up to about
87 percent. However, over a long time, only 82 percent recovery is indicated
because of numerous web breaks, downtimes, maintenance, etc.
2. Why can't fugitive emissions be captured more efficiently? GRI said
that cabin enclosures are impractical for typical presses. Operators
must go above presses after web breaks, and for maintenance more often than
at Meredith/Burda. Adsorber efficiencies decrease with lower solvent laden
air concentrations.
V-28
-------
3. An industry representative mentioned that the Meredith/Burda test
report showed that the cabin enclosure vapor concentration was over
200 PPM at 25-30 minutes after press shutdown.
The meeting closed after a presentation by Rod Pennington of
REECO Company. His presentation concerned incineration systems, as
summarized below:
1. The large amounts of supplemental fuel as mentioned in Chapter 4
of the BID, are not required for efficient incineration systems.
2. Incineration systems can be economical.
3. REECO has installed incineration systems for Rotogravure presses,
but not for the publication sector.
V-29
-------
D. CORRESPONDENCE
r from Dayton Press, Inc. to EPA
2219 MCCALL STREET
DAYTON. OHIO 45401 - P.O. BOX 700
(513) 268-6551
A CHARTER COMPANY
December 3 , 1979
Mr. Don R. Goodwin, Director
Emission Standards & Engineering Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, N. C. 27711
Dear Mr. Goodwin:
In response to your announcements of October 12 , 1979 and
November 7, 1979 and the formal notice in the Federal Register at
44 Fr 65670, this is to submit our formal comments to the National
Air Pollution Control Techniques Advisory Committee on the draft of
New Source Performance Standards for Volatile Chemical Emissions
from the Publication Rotogravure Printing Industry dated November 2,
1979.
We appreciate the opportunity to submit our comments on the recom-
mended New Source Performance Standard (NSPS) because of the
significant growth and technological advancements presently tran-
spiring in rotogravure printing and their prominent role in the publi-
cation segment of the graphic arts in particular.
The NSPS for Volatile Organic Chemical Emissions from the Publication
Rotogravure Printing Industry as presented in the Background Information
Document (BID) dated November 2, 1979, is predominently based on
tests and other data developed by the United States Environmental
Protection Agency (EPA) in respect to a recent - 1977 - plant addition
at Meredith-Burda, Inc., in Lynchburg, Virginia.
In reality the Meredith-Burda operations at Lynchburg only embrace a
very small portion of the publication rotogravure market and for that
reason that plant and in particular the 1977 plant expansion of reference
is not representative of publication rotogravure printing. This fact is
attested by an article beginning on page 28 of the October 1978 issue of
V-30
-------
Mr. DonR. Goodwin -2- Decembers, 1979
Graphic Arts Monthly; on page 32 it specifically states, "While
Meredith/Burda is not primarily a magazine printer, concentrating
mostly on commercial work, catalog and supplement type printing, it
is available to produce overflow work as necessary for Better Homes
and Gardens which the Des Moines plant" - Meredith Corporation -
"cannot accommodate".
Moreover, the print orders produced at Meredith-Burda differ sub-
stantially from those plants that are more or less confined to printing
of subscription and newsstand magazines. For example: a news
article on page 44 of the April 1977 issue of Graphic Arts Monthly in-
cluded the following paragraph on page 46:
"Print orders on the M/B presses are not uncommon at 10-14 million,
and it is not unusual to have a supplement or supermarket flyer with
print orders well above that. A major customer, Avon Products, pro-
duces a 72-page catalog every four weeks calling for a 10 million run.
Zayre Stores run 25 national campaigns a year for newspaper inserts with
print orders of 13 million, 12 to 28 pages each. K-Mart is another
high-volume customer."
In contrast, the print orders being processed by magazine publication
printers are in the range of one half down to an order of magnitude
lower than those printed at Meredith-Burda in Lynchburg; hence press
make ready, cylinder changes and the like are more frequent, incur
more press down time, reduce the effective average solvent laden air
concentration and thereby decrease solvent recovery efficiency.
A further difference which the product mix produced at Meredith-Burda
can have on the eventual efficiency attainable by carbon adsorbtion and
recovery is clearly evident in the EPA test report * (Reference #9 in
Section 3.0 of the BID draft) which shows that over a period of three,
8-9 hour test runs on consecutive days one of two presses that was
printing a "furniture advertising booklet" was in operation, thereby en-
hancing the solvent exhaust concentration, 85.8 percent of the available
time; simultaneously the second press which was running a "color feature
section of a magazine" run considerably less, which on average amounted
to 63.7% of the cumulative test time. This clearly shows how the type of
product being produced by rotogravure printing can influence source
operations and adversely impact abatement efficiency.
We further submit that the press configuration at the Meredith-Burda plant
addition on which the draft NSPS is based is not typical of publication
rotogravure printing operations. It is our contention that this plant ex-
tension which has two 8-unit presses, two meters wide, is not truly re-
presentative of publications printing. For example, it excludes proof press
* Graphic Arts, Emission Test Report Meredith-Burda Lynchburg, Virginia.
EMB Report 79-GRA-l, Environmental Protection Agency. Research Triangle
Park, NC 27711. March, 1979.
V ~ «j I
-------
Mr. Don R. Goodwin -3- Decembers, 1979
operations which inherently operate at much lower speeds, typically
150 to 400 feet per minute, and considerably more intermittently than
production presses. The plant of reference also excludes presses
having more than 8 printing units which result in a proportional increase
in dryer ventilation air but which are prone to produce a disproportionately
lower amount of solvent vapor. Even further, there is no variation in the
width and speed of the presses which is becoming increasingly more
common in publication rotogravure plants. 9feere<6mv?H»ltMMe«ib«teBMahater-
While not reflected in the Background Information Document, the EPA
Test report, mentioned above, footnoted at the bottom of page 2, clearly
shows that more than a casual amount of solvent vapors infiltrate into
the pressroom. In Section II, Summary and Discussion of Results, Item
(11) on page 9 states in part that " the outlet contains toluene,
benzene and another unidentified material at about a 1:1:1 ratio." Further
in the concluding general discussion on page 10 the report states that
"Ethanol, used to a limited extent in cylinder making, was detected in an
inlet sample analyzed by GC/MS after the field trip." These discrepancies,
unidentified material and ethanol, are reconcilable on the basis of their air
borne entry from other parts of the connected printing facilities not included
in the material balance and consequent efficiency calculations for the partial
plant of reference. Such being the case it is likely that the negative pressure
in the pressroom would also draw in low levels of other solvent vapors in-
cluding toluene which combined with the ethanol, that was identified, could
readily account for all or even more than the amount of solvent vapors ex-
hausted from the solvent recovery system. The resultant efficiency differential
of several percentage points or more is not particularly consequential at the
Meredith-Burda plant addition; however, this discrepancy results in an infla-
tion of new source control efficiency requirements which would readily fore-
stall the possibility of achieving compliance with the NSPS elsewhere in the
publication rotogravure printing industry.
Several other aspects of the Meredith-Burda system which served as the
reference model in the development of the subject draft NSPS are felt to be
contrary to the intent and purpose of Section 111 of the Clean Air Act. The
emission test report, referred to earlier and identified in the footnote on page
2, shows that the supply of ventilation air in the pressroom work area is com-
paratively low, being less than 50 percent of that ordinarily employed for
publication rotogravure printing operations. Such restriction of course is all
important in the overall equation for maximizing the vapor capture efficiency
as is evidenced by the vapor concentrations eminating from the fume control
cabin in the course of press operations. It is noted, however, that the
toluene and benzene concentrations delivered from the fume cabin remain
precariously high in the course of intermittent press stoppages. For example,
as much as 25 to 30 minutes after temporary shut-down of one or both presses
toluene concentrations as high as 214 ppm and benzene concentrations as high
V-32
-------
Mr. Don R. Goodwin -4- Decembers, 1979
as 14.4 ppm continue to persist in these areas - cabin enclosures -
which are supposed to be available for work occupancy. Time increments
and solvent concentrations of this magnitude, irrespective of their
chemical species, represent a serious and untenable compromise in
maximizing abatement efficiency. It is therefore apparent that the Back-
ground Information Document has failed to consider adequately the
interrelationships between ambient and workplace control considerations.
For the various reasons herein cited it is our contention that the standards
of performance contained in the NSPS draft do not conform with the require-
ments set forth at paragraph 2.3 on page 2-7 of the Background Information
Document. Furthermore, we respectfully submit that the overall limit of
10 percent emissions as specified in the NSPS draft as a practical matter
is unreasonable and unattainable. In light of these observations and the
comments of others knowledgeable in the graphic arts it is imperative that
the overall limit of emissions (and control requirements) be based on test
results which are more nearly representative of publication gravure printing
industry, and thus be increased in conformity with the test results derived
by the U.S. EPA at Texas Color Printers in Dallas, Texas.
We trust that these comments will be meaningful to you and wish to express
our pleasure in having the opportunity to comment on the draft of the New
Source Performance Standard for Publication Rotogravure Printing. Should
you have any questions concerning these comments, please feel free to
contact the undersigned. I would appreciate being included on the mailing
of any further drafts and in particular I would appreciate copy of the final
document when it is issued.
Sincerely,
Robert D. Fremgen, Manager
Chemical & Environmental Engineering
RDFibcn
Attachments
V-33
-------
Another Surge of Growth
for Meredith/Burcta
Ground breaking for $15 million plant expansion shows that American
marketing and European technology make productive partners
THE MEREDITH CORPORATION,
Des Moines, la., has been a highly re-
spected printer and publisher since the
turn of the century. Equally well known
in Europe as a high-quality printer with
publishing interests in West Germany is
Burda GmbH, of Offenburg. When
these two large corporations got to-
gether late in the '60s it was agreed that
Burda had much to offer in the way of
gravwre technology, while Meredith, in
a partnership, could provide solid
American management, salesmanship,
and marketing. Thus was born the con-
cept that led to the establishment of a
new U.S. gravure printer—Meredith/
Burda, Lynchburg, Va.
Groundbreaking for the plant was
held in August of 1970, and in little more
than a year (October 1971), Meredith/
Burda was printing sections of Better
Homes and Gardens and contracting for
catalog and other promotional work on
its first two eight-unit presses. Within a
year, plans were afoot for a building ex-
tension and the purchase of two more
presses to handle the burgeoning print-
ing demands of such customers as Avon
Products, Zayre Corp., K-Mart, Buick
and Pontiac Div. of General Motors
Corporation, Pennsylvania House and
several New York department stores.
This doubling of capacity still did not
satisfy the flood of orders for high-
quality gravure; so this month, once
again, the red soil of Lynchburg is being
bulldozed to make way for yet another
$15 million addition to the plant facilities
of the New South's most aggressive gra-
vure printer.
Timely "marriage"
This sensational growth over a period
when the country's economy has been
in a state of flux and the printing busi-
ness itself left a lot to be desired has
been no accident of fate. The entire proj-
ect of developing a new concept in gra-
vure printing was carefully researched
and thought out before these two pres-
tigious companies decided to join
forces. "It was a marriage right for its
time," said M/B's energetic president
Walter A. Voss as he observed the start
of construction for the second expan-
sion of the plant in its short six years of
existence.
"At Meredith we always felt we had a
firm grasp on marketing and sales
techniques. In our joint venture with
Burda we were preparing for the un-
stoppable demise of the letterpress
process which we have seen go down-
hill steadily for many years.
"The question in our minds was how
do we get into gravure? As we saw our
options, we could have purchased an
existing U.S. gravure plant or train our
own people in the art of gravure
by B.D. Chapman
technology. Both were unworkable. We
did not think that U.S. gravure
techniques were as good as Europe's. It
developed that Burda's knowhow was
just what we needed."
In 1969 the new company was formed
on a 50-50 partnership basis. Meredith
took on the responsibility of manage-
ment and marketing, Burda became re-
sponsible for technology, making all the
major equipment decisions. In Voss'
words, "Each carried its own respon-
sibilities very well."
Voss feels that in their joint enterprise
they have helped reintroduce gravure to
the American market. "We raised our
quality sights and as the new breed of
gravure printer we started producing
products tailor-made for our equip-
ment."
In January of 1974, Gerd Spraul. vet-
Bird's-eye view of MeredithlBurda complex on outskirts of Lynchburg, Va. New addition will
be constructed in open area, left and rear in photo. Access to plant is convenient for trucks via
main highway at top of picture or via Norfolk A Western K.K. in foreground. Spur line runs
into plant. Customers in Atlanta, Detroit, or New York an reached easily overnight.
44 Graphic Arts Monthly / April 1977
V-34
-------
Console panel of a Meredith/Burda press,
above, puts all controls at pressman'} fingertips.
Phone on panel enables operator to be in direct
contact with quality control, ink and paper rooms.
Gravure cylinder, above right, being lowered into
position by means of overhead crane. Catalogs
and weekly supplements may require as many as 30
to 40 cylinder changes in the course of the pressrun.
To maintain constant register, presses are equipped
with control units as seen in photo below right.
Press signatures are pulled at regular intervals
to be checked at the control desk.
eran employee of Burda GmbH and
one-time manager of the firm's Dorm-
stadt plant, was brought over from Ger-
many and installed as vice-president for
manufacturing. Moving into a relatively
new plant where efficiency was the
watch-word, Spraul has fit in well with
other company officers who were on the
scene ahead of him. In charge of finance
was Herb Murphy, who, like Voss,
came from the parent company,
Meredith, in Des Moines.
Harry Brady, vice-president in
charge of sales, whose responsibilities
also encompass sales of commercial
printing for the Meredith Group, joined
M/B in January 1971. Before establish-
ing his home in Lynchburg, Brady was
associated with Western Publishing in
Racine and for many years before that
was on the sales force of R.R. Donnelley
and Sons Co.
Moving around his vast sales territory
(Meredith/Burda does no local selling in
Virginia), which ranges from New York
to Detroit to Atlanta, Brady frequently
takes to his own private plane to cover
the roughly 400-mile radius within
which his largest customers are located.
Training division
Supervising industrial and labor rela-
tions. Jim Fulton, vice-president/
employee relations, rounds out the key
executive team. With previous experi-
ence in the electronics industry, Fulton
joined Meredith/Burda in June 1971.
Working closely with the Virginia In-
dustrial Development Commission and
local colleges. M/B has established a full
training division for new employees.
Of the original candidates recruited in
1970. 14 of them and their families were
sent to Offenburg, Germany, to receive
training at the Burda plant. They stayed
18 months and received double
academic credits during that time in
their apprenticeship. As a result, they
received their journeymen certification
in the summer of 1972.
Again, in conjunction with the Vir-
ginia Department of Labor and the Vet-
eran's Administration, eight appren-
ticeship programs were established. Six
of the programs are in the printing
trades, and two are in maintenance
areas.
To determine a fair level of employee
compensation, a local survey was con-
V-35
April 1977 / Graphic Arts Monthly 45
-------
Meredith/Burda
continued
This is the German Albert gravure press that is presently operating alongside an Italian
Cerutti. M/B intends to install two new presses in the planned 88,000-sq.-ft. plant extension.
ducted to establish an hourly rate struc-
ture to be competitive in the area, but
also to allow for a future productivity
bonus. Additional work benefits were
similarly established.
The company's payroll, which now
totals close to $6 million annually, will
be increased by about $2 million when
the additional complement of 160 more
workers are hired and trained.
At present the plant has 220,000
square feet of floor space constructed in
the center of 50 acres of well-landscaped
Virginia countryside. The addition will
provide another 88.000 square feet and
will represent a total investment of $40
million that Meredith/Burda. Inc. has
thus far spent in developing what are
considered the most modern printing
facilities in the country.
Besides manufacturing and storage
areas, the plant houses administrative.
sales, and business offices: food ser-
vice: medical dispensary: maintenance
shops: and personnel and employment
offices. Insulated curtain walls of the
structural steel frame building are de-
signed for relocation as the plant is ex-
panded. In the forthcoming construc-
tion there will be no interruption to
printing production since the design is
such as to permit business-as-usual
during the building expansion.
Present systems for ventilation, fire
protection and waste disposal are de-
signed to handle the needs of today as
well as the future expanded size. The
facility is equipped with a solvent re-
covery system which extracts gases
evaporated as ink dries during the print-
ing process and recovers them for reuse.
An ink plant owned by Siegwerk.
Inc.. is adjacent to the M/B printing
facilities. Inks are pumped into the
pressroom through underground piping.
Safety valves are prominently located in
both the pressrooms and the ink plant
for use in case of emergencies.
Siegwerk will expand its pumping
equipment and storage facilities to sup-
ply the two new multiunit Cerutti
presses which will be installed in M/B's
new wing, the first of which is expected
to be in production by June 1978. with
the second following in a few months.
The new space will also be used to
relocate and expand the bindery and
provide more storage for roll stock and
material in process. Their present bind-
ery is limited to a pair of Sheridans.
Lynchburg was far from being a de-
pressed area when Meredith/Burda was
casting about for a plant site. The area
offered a good labor force, good
schools, a cooperative local govern-
ment plus good rail facilities, with a spur
of the Norfolk and Western running into
the plant compound. Ordinarily, good
weather the year around keeps the
highways open for commercial haulers
to make overnight deliveries to key city
customers.
Print orders on the M/B presses are
not uncommon at 10-14 million, and it is
not unusual to have a supplement or
supermarket flyer with print orders well
above that. A major customer, Avon
Products, produces a 72-page catalog
every four weeks calling for a 10 million
run. Zayre Stores run 25 national cam-
paigns a year for newspaper inserts with
print orders of 13 million. 12 to 28 pages
each. K-Mart is another high-volume
customer.
In addition, there are numerous long-
run magazine signatures to produce,
catalogs and weekly supplements.
Many of these require as many as 10
price changes, calling for 30 to 40 cylin-
der changes. Some 475 employees are
required to produce this volume, and
the annual M/B payroll has gone from
$600.000 in 1972 to $6 million this year.
Sales volume in this period has risen
from $1.473,000 to over $25 million in
1976.
Experimental three-day week
Starting in January, the company
started experimenting with a three-day,
12-hour work week in the pressroom
only. This calls for two shifts. Monday
through Wednesday and two more
Thursday through Saturday on a rota-
tion basis. If Sunday overtime is re-
quired it is shared by all four shifts. The
shifts are on a 7am to 7pm schedule.
With bilingual German-English
employees, many steps have been taken
by the employee relations division to
develop a highly motivated and en-
thusiastic group. Recreation activities
are planned, social functions, English
lessons and cultural appreciation oppor-
tunities are provided for the German
families which were brought over.
"Speak up" and employee meetings are
a regular feature, and there is an open-
door policy in practice at all times. Firm
discipline and good conduct are musts.
and this policy has paid off in good at-
tendance and low turnover.
All in all. Meredith/Burda has become
a well-established part of the Lynchburg
community and continues to move in a
steady growth pattern that justifies the
years of planning and development. #
46 Graphic Arts Monthly / April 1977
V-36
-------
Printers and publishers alike are
scrambling to convert to gravure.
After years of long delay, the
industry is finding new ways of
overcoming its stigma and
realizing its potential
by Roger Ynostroza
GRAVURE IS HOT, and nowhere is the
temperature higher than in magazine
printing. In fact, right now the publica-
tion printing field is crackling with activ-
ity:
—numerous installations of new
equipment;
—announced plans for expansion of
existing gravure facilities:
—total conversion to gravure by
popular magazines, or the appearance in
them of gravure-printed sections:
—the introduction of new titles spe-
cifically to be printed by gravure:
—the appearance of new names and
faces in the gravure printing field:
—the rush to improve the process.
28 Graphic Arts Monthly / October 1978
V-37
-------
Ten-unit, 91 "-wide Matter gravure press—representing an investment of more than $4
million—is one of two used jointly to print over 18 million copies monthly of the Reader's
Digest. The printers, Dayton Press, Dayton, O., and Arcata Graphics, Buffalo, N.Y., had
no previous experience in gravure, but both are now adding more gravure equipment.
and to adapt it to still more applications;
and
—the gathering momentum of the
process itself in the eyes of printers,
publishers, suppliers, and equipment
manufacturers.
In this article, we will cover each of
the above points, often using broad
strokes because of the amount of mate-
rial available. But the examples to be
given were carefully selected to show
how printers and publishers more and
more are utilizing gravure in the produc-
tion of magazines.
Three suppliers
In the U.S., the majority of gravure
presses for printing magazines is offered
by three companies: Motter Printing
Press Co.. York. Pa.; Officine Mec-
caniche Giovanni Cerutti S.p.A.,
Casale Monferrato. Italy (distributed by
North America Cerutti, Pittsburgh,
Pa.); and Albert-Frankenthal AG.
Frankenthal. West Germany (marketed
in North America by HCM Corpora-
tion. New York).
Certainly there are other gravure
press manufacturers which have
equipment in the U.S. For example,
BobstChamplain, Inc., Roseland, N.J.,
makes presses for the paperboard pack-
aging field, plus a line of press controls
for web offset or gravure.
Of the three manufacturers listed
above, Motter, which in 1978 is cele-
brating its 25th year in business, has far
and away more gravure publication
presses installed, operating, and on
order in North America than any other
manufacturer.
In all. Motter reports it has more than
100 gravure presses installed through-
out the U.S. The figure is purposely
vague because, for example, a company
may add units to an existing press or
have the manufacturer rebuild an older
press. Besides this, the number here
does not include the installation of press
folders, which represent a sizable capi-
tal investment and can be just as impor-
tant to a plant's productivity and capa-
bility as the press itself.
Approximately 14 presses have been
installed in just the past two years or so,
and Motter enjoys about a two-year
backlog right now. equivalent to about a
dozen presses. „
V - Jo
By comparison, there are six Cerutti
presses and nine Albert gravure presses
presently printing publications here. Of
course, all these figures are subject to
change; in fact, all the manufacturers
plan to announce new sales and installa-
tions of presses shortly.
There's no question but that much of
the recent flurry of excitement and in-
terest in publication gravure involves
Motter presses. By sheer numbers in
length of run, the list of Motter press
users is a who's who of printing and
publishing giants.
Gravure conversion
By now, everyone is aware that a
number of well-known publications
have been converting in whole or in part
to gravure in the past year or two. In
terms of circulation. Reader's Digest is
among the largest, with a monthly print
order of more than 18 million. The Di-
gest is printed in two locations. Arcata
Graphics, in Buffalo, N.Y., and Dayton
Press, in Dayton, Ohio.
The plants have similar equipment,
10-unit, 91 "-wide Motter presses de-
signed to produce up to 192 pages with
October 1978 / Graphic Arts Monthly 29
-------
Gravure
continued
each revolution at speeds up to 2100 feet
per minute. The presses cost about $4
million each. Besides the presses, the
total $16 million investment by the pub-
lisher included a 26-pocket, fully com-
puterized Harris adhesive binder; five-
unit, webfed Motter proof press; and a
complete line of gravure cylinder-
making equipment, made by K. Walter.
Munich, Germany, and installed at
S&M Rotogravure Service in Mil-
waukee.
The first Digest form printed by gra-
vure appeared in the June 1977 issue;
from that 12-page form, the gravure-
printed section has expanded to include
national advertising and accompanying
editorial pages, approximately 160
pages per issue now. Other parts of the
magazine, including one section that
averages 84 pages printed on rough-
finished uncoated stock, are printed by
web offset.
No prior experience
What is remarkable about the
Reader's Digest conversion is that
neither of the printers—Arcata or
Dayton—had any previous production
experience in gravure. How the com-
panies trained their personnel in gearing
up for gravure was described in GAM
(April 1978, pp. 70-74). An article by
Richard G. Dutton, production director
of the Reader's Digest Association,
explained the publisher's reasons for
selecting gravure as the main process of
production. "Why Reader's Digest Is
Going Gravure" appeared in GAM in
April 1976 (pp. 47-49).
By its prestige, National Geographic
gave gravure a touch of class when, in
1977, it converted its 10.5 million
monthly print order to the process. To
accomplish this, W.F. Hall Printing
Company, one of the largest diversified
printers in the country, with capability
in letterpress, gravure. offset, and
flexography, established a new plant in
the south. Hall of Mississippi, in
Corinth, Miss., was equipped with
web-offset presses and two 12-unit.
70"-wide Motters.
The latter are linked to two Harris
gatherer/binder/trimmer lines said to be
the world's longest such equipment line.
The magazines are printed two-up and
remain that way throughout most of the
production process until, near the end of
the binding line, a splitter separates the
books.
About 90% of the National Geo-
graphic is printed by gravure. with the
remainder, consisting of regional adver-
tising, printed by web offset. The
January 1977 issue was the first to be
printed by gravure in the Corinth plant.
Presses added
A short time later. Hall was awarded
the contract for printing alternate edi-
tions of the Avon Products' Call Back
booklet, a publication with an average
print order of approximately 15 million.
The booklet has a trim size of 7'/8x5V4",
averages about 80 pages, and is printed
jointly by Hall and Meredith/Burda in
Lynchburg, Va. For this. Hall added
two Motter presses to the Corinth plant,
where it now also prints Showcase for
Avon on the second pair of presses.
Showcase is an 8V£xl1" version of the
smaller booklet and has a monthly run of
about half a million copies.
Even more recently. Hall's Corinth
plant has installed an Albert press—10
units, 86" wide, with two folders—for
•The Big Printer
R.R. DONNELLEY & SONS COM-
PANY, the largest commercial
printer in the United States, uses
gravure, offset, and letterpress to
print books, magazines, catalogs
and tabloids, directories, and
other work. The company prints
magazines by gravure in two of its
plants—Mattoon, III., and Gallatin,
Tenn.—and. when necessary, in its
catalog-printing facilities in
Chicago and Warsaw, Ind.
Mattoon utilizes three older gra-
vure presses, plus some letter-
press equipment. Gallatin is exclu-
sively gravure; it is a relatively new
plant, opened in May 1975 with two
presses: five are now in place, with
more on order for delivery within
the next 18 months.
Gallatin was in the news this
summer when Donnelley an-
nounced it would print on existing
equipment there the renewed Life
magazine for Time Inc., on a
monthly basis. The magazine's
first issue, October, began appear-
ing on newsstands the last week in
September; it contains three 40-
page gravure forms and a gravure
cover, plus a 16-page offset form
added late to accommodate adver-
tising overflew. Trim size of the
saddle-stitchaa magazine is
lOVaxISVa". on 50-ib. paper with
60-lb. cover; the initial advertising
printing catalog work for Speigel.
The press was just getting into opera-
tion at the end of August and should be
in full production now. Overall, there
are now 720 employees in the plant.
World Color
World Color Press is yet another big
user of Mottor gravure presses. This
company, based in Effingham. 111., has a
gravure plant located in nearby Salem.
Salem Gravure has been equipped with
three Motters in the past two years (the
latest started up in July), all of them
eight-unit. 48-page machines that have
34Vi" cutoffs and accept a maximum
web width of 72".
World Color was the subject of a fea-
ture article in GAM in June 1978 (pp.
56-60) and is recognized as the country's
largest magazine printer. The Salem
facility prints gravure sections in sev-
eral large-circulation women's
circulation base is 700,000 copies,
but the total print order for the first
issue was more than 1.5 million.
Donnelley is very active in gra-
vure. The Gallatin facility has a
94"-wide press for printing part of
TV Guide; more recently, two
70"-wide, 10-unit Albert presses
with variable-cutoff, cassette-type
folders were added, one running
since November, the second since
February. Too, there is a 94"-wide,
four-unit Albert proof press with
sheeter.
At Mattoon, one multiunit gra-
vure press has been split into two
separate presses, with a new folder
added. And at Donnelley's Warsaw
plant, new press additions, these
for printing catalogs, include a
70"-wide, 10-unit Albert, which
started up in early September, and
a similar press due to be opera-
tional in early 1979.
For the future, as proof of Don-
nelley's bullish attitude about gra-
vure, three 94"-wide, 10-unit Mot-
ter presses have been ordered for
Gallatin. to be running in the first
quarter of 1980. Thus, the Gallatin
plant will have gone from a two-
press startup facility in 1975 to an
eight-press plant in five years.
Besides this. Donnelley will
begin testing a variable-type folder
for Motter next spring.
30 Graphic Arts Monthly / October 1978
V-39
-------
Gravure
continued
magazines, including Woman's Day.
Ciood Housekeeping, Cosmopolitan,
and Seventeen, plus major catalog
work. Undergoing installation now in
the Salem plant is a unique pair of 10-
unit. narrow-width gravure presses due
for startup early next year. (Narrow-
width gravure presses will be covered in
a separate section later in this article.)
Just since the first of this year, three
other national monthly women's
magazines have added gravure sections.
Dayton Press, the printer, produced the
first form in late January on its eight-
unit. 91 "-wide, 96-page Motter presses.
The magazines, in order of phasing in to
gravure, are McCall's, Redbook, and
Ladies Home Journal.
McCall's now uses a 32- or 48-page
gravure form (depending on whether the
form is run two-up or three-up) contain-
ing primarily advertising, with some
editorial pages. Total McCall's run is
more than 7 million copies.
Redbook runs about 32 pages of gra-
vure, involving mostly editorial copy
along with some ads, and a total circula-
tion of more than 5. million. And Ladies
Home Journal uses an average of 32
pages of gravure for a total run of more
than 6 million copies.
Not replacement
The remaining sections of the three
magazines are still being printed by let-
terpress (except for certain regional in-
serts that may be printed by web offset),
yet it cannot be truthfully said that gra-
vure replaced letterpress for the forms it
now prints.
"Gravure really is taking care of an
expansion of the magazines themselves
rather than serving as any replacement
or substitution for letterpress." one
Dayton spokesman said. "Page counts
are up for women's magazines today, so
gravure actually relieves scheduling
pressures in production."
How did Dayton come to install gra-
vure for work other than Reader's Di-
gest "J "Several forces came into play
involving the printer, the publishers, the
advertisers, and the advertising agen-
cies." he said. "Certainly there was
some demand for gravure on the part of
advertisers, and now others are taking
advantage of gravure capacity in the
magazines. Similar forces having to do
with improved quality and economics
were involved."
Dayton is also using the added gra-
vure capacity to produce 96-page forms
of special-interest, quarterly newsstand
publications, printed in runs well in ex-
cess of a million copies, that previously
32 Graphic Arts Monthly / October 1978
Head pressman of multimillion-dollar gravure press at Meredith/Burda coaxes high-
quality color from a dazzle of blinking lights, dials, gauges, and push buttons.
had been printed by web offset. It also
plans to add other work to the gravure
press schedule, probably involving
large, long-run consumer magazines.
Other recent Motter installations in-
clude a press and added units at Texas
Color Printers, a division of Providence
Gravure. in Dallas, and press rebuilding
at Diversified Printing Company,
Atglen, Pa. for printing Parade.
Cerutti installations
In late summer, there were six Cerutti
presses installed in U.S. plants printing
magazines by gravure .Four of these are
located at Meredith/Burda. in Lynch-
burg, Va.. and two are in place at
Meredith Printing Company, Des
Moines, Iowa.
In Des Moines. the presses, installed
in February and in April of this year, are
being used to print more than half of
Better Homes and Gardens, a monthly
publication with a circulation over eight-
million: the 48-page main editorial sec-
tion of House Beautiful, another
monthly with a total circulation of less
than a million (more on this in a separate
section later): and parts of another six-
million-copy magazine.
The two variable-cutoff presses in
Des Moines cost more than 54 million
each, are approximately two meters
wide, have eight printing units each, and
are rated at 40.000 rph. The presses
were selected to be interchangeable and
compatible with the press equipment in
Lynchburg so that work from both
plants could be mixed, or so similar
work could be produced by either plant.
The presses in Des Moines can be
dressed to print -18 or 56 pages—four
around the cylinder and either six or
seven pages across, as necessary.
Meredith has several -sets of cylinders to
accommodate the magazine sizes.
Better Hornet iind Gardens has
swung over to gravure so far that a
front-cover advertisement in the June
edition of Standard Rate & Data Ser-
vice's consumer — .j-azme directory de-
clared that BH^Cf. effective with the
October !978 issue, "is a rotogravure
publication with limited letterpress
availabilities." Aii national four-color.
V-40
black and one color (no matched col-
ors), and black-and-white ads in the
magazine will run gravure. Letterpress
will be available for covers, national
split runs, national mail-order section,
and any ad requiring a matched color;
web offset will be used for regionals and
certain national split runs.
Meanwhile, Meredith/Burda in
Lynchburg has been adding presses. An
article in GAM in April 1977 (pp. 44-46)
entitled "Another Surge of Growth for
Meredith/Burda" described a $15 mil-
lion plant expansion. Two eight-unit
Ceruttis, both two meters wide, were
installed for the original startup in 1971.
Added to these in 1974 were two Albert
presses, also eight-unit, two-meter-
wide machines. And two additional
Ceruttis have been installed; the first
became operational in June, the second
only last month. All the presses are
compatible, and as mentioned earlier,
the presses in Des Moines and in
Lynchburg are similarly compatible.
While Meredith/Burda is not primar-
ily a magazine printer, concentrating
mostly on commercial work, catalog,
and supplement-type printing, it is
available to produce overflow work as
necessary for Better Homes and Gar-
dens which the Des Moines plant cannot
accommodate. Meredith/Burda. in
agreement with W.F. Hall's plant in
Mississippi, produces alternate editions
of Avon's multimillion-copy catalog.
In addition, several Cerutti proof
presses are installed in American
plants—an older one in Lynchburg, a
new one at W.F. Hall, and older ones at
Kable Company and Southam-Murray.
Add to this several folders—a high-
speed variable folder at Texas Color
Printers for producing TV Guide, and a
high-speed folder and some printing
units attached to an existing press at the
Montreal Standard.
While the number of Cerutti press in-
stallations may seem to be compara-
tively modest, a spokesman said the
press manufacturer has a "sizable
amount" of orders and is quite optimis-
tic about future sales and installations in
the U.S. It is said that equipment is get-
ting better acceptance in the U.S.
-------
Gravure
continued
Cerutti expects to make a major U.S.
installation announcement this month.
Also, for a number of other reasons.
Cerutti's future in the U.S. market
seems to be quite bright, particularly if
the narrow-width gravure concept
catches on. Cerutti has approximately
42 presses operating in the U.S. and
Canada in the packaging field. In that
field, the standard press width is about
44", a few inches larger than the stan-
dard web-offset publication press size of
38".
So, obviously, Cerutti has a solid
background in building presses in the
so-called narrow widths, and if and
when the industry begins to demand a
narrow-width gravure press for printing
publications, Cerutti will be in good po-
sition to provide this.
"Actually, all we need to do is build
and add a medium-speed folder—either
a 3:2 or 5:4 model—to the end of our
packaging press, and we think we have a
good proposition for narrow-width gra-
vure for publications," a U.S. represen-
tative for Cerutti said. Of course, there
would need to be some modifications
made, but such a press reportedly could
run at about 1500 fpm. "The new folder
would need to run at about 30.000 rev-
olutions per hour—not a difficult task.
since we have made folders for the
larger presses that run at speeds up to
40,000 rph," he said.
Albert-Frankenthal
In total, there are nine Albert gravure
presses installed in the U.S. today, plus
a number of variable-cutoff folders at-
tached to presses manufactured by
other companies.
Besides this, a 10-unit Albert is slated
for installation early next year and
major announcements have been prom-
ised shortly regarding other sales.
The count includes an older press—
eight units. 40" wide—printing general
work and newspaper inserts at
Springfield Gravure in Ohio, but all the
other presses are fairly new. As men-
tioned above. Meredith/Burda in
Lynchburg purchased two eight-unit
Alberts in 1974.
To complete a summer of gravure ac-
tivity, Hall of Mississippi, as mentioned
earlier, completed the installation and
startup of its 10-unit. 86"-wide, dual-
folder Albert press in Corinth.
Folder installations include four at
Diversified Printing, put in this spring
and summer on Hoe and Motter press-
es, for printing Parade, and a
variable-cutoff folder for a Motter press
at Southam-Murray in Toronto.
Total conversion
The National Enquirer is about to join
those publications chat have converted
totally to gravure. The multimillion-
copy national weekly newspaper, based
in Lantana. Fla., is presently being
printed on newsprint by rotary letter-
press in its captive plant in Pompano.
However, by March 1979, production
of the publication will switch to gravure,
but the Pompano plant will not be in-
volved. Instead, 10-year contracts have
been signed to provide for production at
two new sites—Texas Color Printers
and Arcata Graphics, in Buffalo. Texas
Color will use existing gravure equip-
ment, which it acquired in 1975, to print
approximately 3 million copies of the
Enquirer.
Arcata's investment for the $100 mil-
lion contract it signed is significant.
amounting to some SI! million for yet
another expansion close on the heels of
the Reader's Digest project. Two
seven-unit Motter presses are presently
being installed. They accept a maximum
web width of 75". are equipped with
two reels, and have 39" cutoffs; so, with
both webs, they are capable of produc-
ing as many as 96 pages. 24 of which can
be in four colors. The contract calls for
Arcata to print about 5 million copies of
the newspaper each week during the
first year, to be increased to 6 million or
more as the Enquirer adds circulation.
The expansion at Arcata calls for the
addition of 100 new. employees and the
purchase, for nearly half a million dol-
lars, of a K-201 Hclioklischograph for
engraving the cylinders. The K-201.
first to be installed in North America.
has six scanning heuds and uses a
diamond stvlus to etch the copper. The
National Enquirer will furnish bromide
copies to Arcata. where they will be
scanned and processed through the
computer, and ihe cylinders will be en-
graved. Contrast this with the Reader's
Divest arrangement in which Arcata is
" V-41
furnished press-ready cylinders from
S&M Rotogravure.
In describing the Enquirer project.
one Arcata official said his company
was very pleased with the Digest start-
up, so it intends to follow the same gen-
eral format. That original project was
based on a thorough engineering and
manufacturing PERT chart network for
planning the implementation of gravure.
He said the key to success was com-
plete cooperation and communication
with employees and emphasis on per-
sonnel training. You must budget for
training, he said, and you must make
your employees aware of this manage-
ment dedication to training.
The contracts with Arcata and Texas
Color supersede the Enquirer's original
plans to build a $ 15 million gravure facil-
ity in Lake Worth, Fla., for the printing
of the newspaper. Environmental pro-
tection regulation entanglements de-
layed the plan for so long, the Enquirer
said, that alternate arrangements had to
be made to meet the timetable for con-
version.
Publisher's decision
Hearst Corporation publishes 17
monthly titles plus about 10 quarterly
publications. Recently, the company
added gravure-printed sections to three
of its national monthly magazines:
—Cosmopolitan, which has a 3 mil-
lion circulation mainly based on news-
stand sales, is printed on 40-lb. paper,
and has a total page count of as much as
350 pages or so. now contains a 48-page
gravure section printed by the Salem
Gravure division of World Color Press.
—Good Housekeeping, which has a
5.7 million print order, is also printed by
Salem Gravure, with about 350 pages in
each issue, 144 pages of which are
printed by gravure and the remainder by
letterpress. Its circulation is about two-
thirds subscription and one-third news-
stand. It is printed on 34-lb. paper.
—House Beautiful, whose print order
ranges from 800,000 copies up to a mil-
lion, on 40-lb. stock, has a 48-page main
editorial section printed by gravure by
Meredith, in Des Moines, with the re-
mainder by web offset. Two-thirds of iis
circulation is accounted for by subscrip-
tion and one-third by newsstand -.ales.
Ray Eickemeyer. vice-president and
director of manufacturing al Hearst.
said the decision to use gravure for part
of House Beautiful is significant be-
cause of the comparatively small print
order of a million copies or less which is
involved. Not too long ago. it was gen-
erally felt that two to three million
October 1978 .' Graphic Arts Monthly 37
-------
Gravure
continued
copies constituted the minimum print
order for gravure—the changeover
point at which the acknowledged long-
run advantages of gravure made
economic sense when compared with
other processes.
Since its August 1978 issue, House
Beautiful's main editorial section has
been printed by gravure. "We selected
gravure to improve the quality of the
magazine (compared with letterpress) at
an economic rate," Eickemeyer said,
adding that sufficient web offset capac-
ity at Des Moines was not available at
the time. He said gravure production
costs are presently less than letterpress
costs for the section. Positives are made
by an outside service house, and cylin-
ders by Meredith/Burda, in Lynchburg.
Printing is done in Des Moines.
Eickemeyer also said Hearst expects
to use very little letterpress in the next
two years or so and that most of this
work will be converted to gravure or to
web offset. He attributes much of the
trend toward gravure today to advertis-
ing agencies, saying they are the ones
who actually specify the process to be
used and supply the artwork.
Narrow-width gravure
In addition to being known as the
long-run process, gravure traditionally
has meant presses of considerable size
and investment. Webs and cylinders
with widths of 70", 90", or more are
common for publication presses, and
price tags of $4 million are becoming the
rule.
Today, there's a lot of talk about the
so-called narrow-width gravure
press—approximately 38" in width,
sometimes called the one-meter-wide
press. But so far. there's been more in-
terest than action in actually using the
press. . . with one exception:
World Color Press has purchased two
10-unit Motters that are 38" wide and
have fixed cutoffs of 22%", a standard
web-offset press size. Presently being
installed in the Salem Gravure plant, the
presses are expected to be ready for
production late this year or early in
1979.
World Color says the unique equip-
ment gives it the opportunity to offer
"gimmicks" in the publications it pro-
duces. Such items include inserts, dou-
ble gatefolds, popouts. tearouts. etc. In
addition, the extra unit can be used for
the coating or laminating of. say.
magazine covers.
The presses, each costing about S2
million, can almost be considered pro-
totypes, since they are the first 38"
— Circle Ni>. 139 on Ri-aJcr St-rv/ir Curd
presses Motter has built for gravure.
Motter admits it has no orders for addi-
tional 38" presses at the present time, so
the industry evidently is waiting for the
outcome of World Color's venture into
narrow-width gravure.
As stated earlier. Cerutti reports it is
ready to meet any demand for smaller
equipment (see GAM. August 1976. pp.
40-42, "Hybrid Itaiia Press Aims at
Shorter Runs, Faster Changeover").
and Albert, which has had a 40"-wide
press operating at Springfield Gravure
for about seven years, also is eyeing the
demand.
New names and faces
Printing companies that previously
were strictly web offset are joining the
ranks of gravure printers. For example.
encouraged by the success of the
Meredith/Burda joint venture combin-
ing European technology with Ameri-
can marketing skill. W.A. Krueger Co.
announced in June it had signed a letter
of intent with Switzerland's largest
printing/publishing firm. Ringier & Co.
A.G., to jointly build and operate a
major rotogravure printing facility in the
U.S.
The new plant, which will cost an es-
timated $20 million to build and is
scheduled to begin operations in 1981,
will be operated as a separate entity-
under the name Krueger-Ringier Co..
and be devoted to printing high-volume.
high-quality publications and catalogs.
Results of a site-selection study were
due in September, but a final go/no-go
decision is set to be made in early 1979.
No construction firm has been con-
tracted yet, but architects have already
started preliminary layout plans. A
Krueger task force is studying which
publications might be printed in the new
plant.
As more testimony to the self-
confidence of American printers,
Krueger is going into the venture with
no previous gravure production experi-
ence. Its five plants—in Scottsdale.
Ariz.; Brookfield and New Berlin, Wis.:
Senatobia. Miss.: and Jonesboro.
Ark.—are strictly web offset, operating
a total of more than 20 such web press-
es, with several more on order.
Krueger is ranked among the 10
largest American printers, with an-
nualized revenue of more than S100 mil-
lion. Its weekly magazines include Bus-
iness Week, .Vfu-.yiivi-A'. Journal of the
American Medical -A vsoeiation. and
Advertising Ave. It a: so produces more
than 100 monthly punncations and a full
line of hard-cover books.
V-42
Using gravure and offset, Ringier
prints newspapers, magazines (40% of
those produced in Switzerland), books.
and mail-order catalogs, has sales ex-
ceeding SI 50 million per year, and oper-
ates two major plants, one near Lucerne
and one in Zurich, employing 2700 per-
sons. Ringier was in the news recently
as the printer selected to conduct pro-
duction testing of the MDC wraparound
gravure plate system offered by Max
Daetwyler Corporation in Germany and
first shown at DRUPA '77. It is said the
system features the changing of com-
plete sets of plates and individual plates.
Production testing involves perform-
ance, handling, and safety.
As a preliminary move, Krueger an-
nounced in trade press advertisements
that it plans to offer gravure color sep-
arations made by Ringier to U.S. ad
agencies and publishers. This is "to ac-
quaint the American market with the
kind of quality and efficiency that will
soon be available from Krueger-Ringier
in the U.S."
Start from scratch
Word leaked out this summer that
Brown Printing Co., Inc., Waseca,
Minn., purchased a 10-unit, 72"-wide
Albert gravure press, due for installa-
tion early in 1979. Full disclosure is to
take place shortly, but preliminary in-
formation is that one catalog account is
set for the press, with magazine produc-
tion a future possibility.
Until this announcement. Brown was
a 1500-employee. web-offset publica-
tion and catalog printer, with 10 ATFs,
one Baker-Perkins common-impres-
sion-cylinder press, and a 12-unit Harris
M-IOOOA, along with six sheetfed offset
presses for printing covers, in its main
plant. Last June, Brown opened an
eastern plant, in East Greenville, Pa..
across the state line from Youngstown.
Ohio, and equipped it with a pair of
four-unit M-lOOOAs.
Brown's present product mix is about
70% publications and 30% catalog/
commercial work. It does work for 57
publishers, producing 131 titles, includ-
ing Fortune and Dun's Review. Most of
the magazines it produces are month-
lies, including many special-interest
publications in the medical, electronics.
and construction fields.
Brown is leaping into gravure with
both feet. Total investment amounts to
more than S10 million and involves
complete preparatory and press
facilities and a new building. The Albert
press will have sophisticated register
controls and solvent recovery equip-
-------
ment. In the prep area, a K-201 Helio-
klischograph, etching tanks, and copper
and chrome cylinder plating facilities
are to be installed.
Why is Brown going to gravure?
Board Chairman Wayne Brown said the
company saw some work going to gra-
vure and that the market was enlarging
for the process. He foresaw a bigger
demand for gravure and believed certain
work his company was producing would
eventually go to gravure.
"Generally speaking, we're getting
into gravure for many of the same
reasons that we went into web offset in
1959 from letterpress and sheetfed print-
ing," Brown said. With no previous ex-
perience in gravure. Brown expects to
retrain some web-offset employees and
hire new people for the process.
A plant closes
While the gravure tempo continued to
quicken this past season, the summer
also brought tragic news to the industry:
the giant Philadelphia plant of Triangle
Publications, Inc., ceased production
July 26. Some 1100 employees were af-
fected.
The reason? Irreconcilable differ-
ences between management and labor.
Using a dozen gravure presses, some
of which date back to the 1940s, the
plant produced part of the total TV
Guide press run, plus Seventeen
magazine and a variety of commercial
jobs and newspaper inserts.
At press time, Triangle was "waiting
for the dust to settle" before deciding
the ultimate fate of the plant. Mean-
while, its share of TV Guide production
was distributed among the other three
gravure printers involved—Donnelley
in Gallatin, Arcata in San Jose, and
Texas Color in Dallas. Seventeen was
sent to Salem Gravure.
Momentum
Despite an occasional step backward,
the gravure industry as a whole is active
and busy. The process has caught on in
publishing circles, and the momentum is
beginning to build.
There are numerous press installa-
tions, magazine conversions, work in
new technology, and a search to apply
gravure to other uses.
One of the obstacles gravure finally
seems to be overcoming today is the
stigma of too many promises given by
those within the field and outside it.
They trumpeted gravure's grand en-
trance so often that the audience got
tired and irritated and almost walked
out before the show began. #
V-43
-------
U.S. Environmental Protection Agency
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U.S. Environmental Protection Agency
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
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U.S. Environmental Protection Agency
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NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
RECORD OF ATTENDANCE
DECEMBER 12 and 13, 1979
NAME
(Please Print)
COMPANY
BUSINESS ADDRESS
TELEPHONE
(Area Code)
PRIMARY INTEREST
DATE
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NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
MINUTES OF MEETING
December 12 and 13, 1979
Prepared by:
$-•
Robert R. Kolbinsky
Office of the Director
Emission Standards and Engineering Division
I certify that, to the best of my knowledge, the foregoing
minutes and attachments are complete and accurate.
'<-•/
Don R. GoodwinL Chairman
National Air Pollution Control
Techniques Advisory Committee
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