SEPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-85-022a
April 1987
Air
Polymeric Coating
of Supporting
Substrates —
Background
Information for
Proposed Standards
Draft
EIS
-------
EPA-450/3-85-022a
Polymeric Coating of
Supporting Substrates —
Background Information
for Proposed Standards
Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
April 1987
-------
This report has been reviewed by the Emission Standards and Engineering Division of the
Office of Air Quality Planning and Standards, EPA, and approved for publication. Mention of
trade names or commercial products is not intended to constitute endorsement or
recommendation for use. Copies of this report are available through the Library Services
Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park NC 27711, or
from National Technical Information Services, 5285 Port Royal Road, Springfield VA 22161.
-------
ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Draft
Environmental Impact Statement
for the Polymeric Coating of Supporting Substrates
Prepared by:
Jack *R. Fanner ' \ " ^ ((Jate)/
Director, Emission Standards and Engineering Division
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27/11
1. The proposed standards of performance would limit emissions of volatile
organic compounds (VOC's) from new, modified, and reconstructed
facilities that perform polymeric coating of supporting substrates.
Section 111 of the Clean Air Act (42 U.S.C. 7411), as amended, directs
the Administrator to establish standards of performance for any
category of new stationary source of air pollution that "... causes
or contributes significantly to air pollution which may reasonably be
anticipated to endanger public health or welfare."
2. Copies of this document have been sent to the following Federal
Departments: Labor, Health and Human Services, Defense, Agriculture,
Commerce, Interior, and Energy; the Council on Environmental Quality;
State and Territorial Air Pollution Program Administrators; EPA
Regional Administrators; Association of Local Air Pollution Control
Officials; Office of Management and Budget; and other interested
parties.
3. The comment period for review of this document is 75 days from the date
of publication of the proposed standard in the Federal Register.
Mr. C. Douglas Bell may be contacted at (919) 54l-bb/8 regarding the
date of the comment period.
4. For additional Information contact:
Mr. James C. Berry
Chemicals and Petroleum Branch (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27/11
Telephone: (919) 541-5671
5. Copies of this document may be obtained from:
U. S. EPA Library (MD-35)
Research Triangle Park, N.C. 27711
Telephone: (919) 541-2777
National Technical Information Service
5285 Port Royal Road
Springfield, Va. 22161
111
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TABLE OF CONTENTS
Page
List of Figures vii
List of Tables viii
CHAPTER 1 SUMMARY 1-1
1.1 Regulatory Alternatives 1-1
1.2 Environmental Impact 1-3
1.3 Economic Impacts 1-5
CHAPTER 2 INTRODUCTION 2-1
2.1 Background and Authority for Standards 2-1
2.2 Selection of Categories of Stationary Sources 2-4
2.3 Procedure for Development of Standards of
Performance 2-6
2.4 Consideration of Costs 2-8
2.5 Consideration of Environmental Impacts 2-9
2.6 Impact on Existing Sources 2-10
2.7 Revision of Standards of Performance 2-11
CHAPTER 3 PROCESSES AND POLLUTANT EMISSIONS.
3-1
3.1 Industry Description 3-2
3.2 Raw Materials 3-7
3.3 Processes and Their Emissions 3-9
3.4 Baseline Emission Level
3-19
3.5 References for Chapter 3 3-22
CHAPTER 4 EMISSION CONTROL TECHNIQUES 4-1
4.1 Introduction 4_1
4.2 VOC Emission Capture Systems 4-1
4.3 VOC Emission Control Systems 4-10
IV
-------
TABLE OF CONTENTS (continued)
Page
4.4 VOC Emission Control Systems for Coating Mix
Preparation Equipment and Solvent Storage
Tanks 4-32
4.5 Low-Solvent Coatings 4-36
4.6 References for Chapter 4 4-37
CHAPTER 5 MODIFICATION AND RECONSTRUCTION 5-1
5.1 Provisions for Modification and Reconstruction 5-1
5.2 Applicability to Polymeric Coating of Supporting
Substrates 5-3
5.3 References for Chapter 5 5-7
CHAPTER 6 MODEL PLANTS AND REGULATORY ALTERNATIVES 6-1
6.1 Model Plants 6-1
6.2 Regulatory Alternatives 6-12
6.3 References for Chapter 6 6-18
CHAPTER 7 ENVIRONMENTAL AND ENERGY IMPACTS 7-1
7.1 Air Pollution Impacts 7-1
7.2 Water Pollution Impacts 7-5
7.3 Solid Waste Impacts 7-7
7.4 Energy Impacts 7-8
7.5 Nationwide Fifth-Year Impacts 7-9
7.6 Other Environmental Impacts 7-9
7.7 Other Environmental Concerns 7-9
7.8 References for Chapter 7 7-38
CHAPTER 8 COSTS 8-1
8.1 Cost Analysis of Regulatory Alternatives 8-1
-------
TABLE OF CONTENTS (continued)
Page
8.2 Other Cost Considerations 8-6
8.3 References for Chapter 8 8-28
CHAPTER 9 ECONOMIC ANALYSIS 9-1
9.1 Industry Profile 9-1
9.2 Economic Impact Analysis 9-32
9.3 Socioeconomic and Inflationary Impacts 9-43
9.4 References for Chapter 9 9-51
APPENDIX A EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT A-l
APPENDIX B INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS B-l
APPENDIX C EMISSION SOURCE TEST DATA C-l
C.I EPA-Sponsored Test at Polymeric Coating Plant C-l
C.2 EPA-Sponsored Tests for Related Industries C-6
C.3 Plant-Wide Solvent Recovery Efficiencies at
Polymeric Coating Plants C-10
APPENDIX D EMISSION MEASUREMENT AND MONITORING D-l
D.I Emission Measurement Test Program and Methods D-l
D.2 Performance Test Methods D-8
D.3 Monitoring Systems and Devices D-20
D.4 Test Method List and References D-26
vi
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LIST OF FIGURES
Page
Figure 3-1 Solvent-Borne Polymeric Coating Operation and,
VOC Emission Locations 3-10
Figure 3-2 Three Typical Coating Application Equipment
Configurations 3-13
Figure 4-1 Application/Flashoff Area Hood Designs 4-11
Figure 4-2 Flow Diagram of a Two-Unit, Fixed-Bed Adsorber 4-14
Figure 4-3 Fluidized-Bed Carbon Adsorber 4-19
Figure 4-4 Schematic of Condensation System Using Nitrogen 4-24
Figure 4-5 Diagram of Conservation Vent 4-33
Figure C-l Solvent/Process Flow Diagram—Plant B C-13
Figure C-2 Solvent Block Flow Diagram—Plant B C-14
Figure C-3 Process Schematic and Sample Locations—Plant C C-15
Figure C-4 Solvent Recovery Efficiency Data—Plant A C-16
Figure C-5 Solvent Recovery Efficiency Data—Plant B C-17
Figure C-6 Solvent Recovery Efficiency Data—Plant C C-18
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Table 1-1
LIST OF TABLES
Environmental and Economic Impacts of Various
Regulatory Alternatives Compared to Alternative I
1-4
Table 1-2
Table 3-1
Table 3-2
Table 3-3
Table 3-4
Table 3-5
Table 3-6
Table 4-1
Table 4-2
Table 4-3
Table 4-4
Table 4-5
Table 4-6
Table 4-7
Table 6-1
Matrix of Environmental and Economic Impacts of
Regulatory Alternatives for Coating Operations
Major End Uses of Coated Substrates
Distribution of Plants that Apply Polymer Coatings
to Substrates by Number of Coating Lines
Number of Plants that Apply Coatings to Supporting
Substrates by State
Solvent and Solids Content of Polymeric
Coati ngs
Coating Applicator Parameters
State Regulations for VOC Emissions From Polymeric
Coat i ng Sources
Coefficients of Entry for Selected Hood
Openings
Range of Capture Velocities
VOC Emission Control Devices Used by Polymeric
Coat i ng PI ants
Process Parameters for Polymeric Coating Plants
Controlled by Fixed-Bed Carbon Adsorbers
Process Parameters of Plant B Fluidized-Bed
Carbon Adsorber System
Range of Process Parameters for Polymeric Coating
Plants Using Inert Air Condensation Systems
Typical Process Parameters for Polymeric Coating
Plants Using Incinerators
Model Sol vent Storage Tank Parameters
1-6
3-3
3-5
3-6
3-8
3-15
3-20
4-5
4-6
4-12
4-16
4-22
4-26
4-29
6-3
vm
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LIST OF TABLES (continued)
Page
Table 6-2 Model Coating Mix Preparation Equipment
Parameters 6-4
Table 6-3a Model Coating Operation Parameters for Carbon
Adsorber or Incinerator Control Options
(Metric Units) 6-6
Table 6-3b Model Coating Operation Parameters for Carbon
Adsorber or Incinerator Control Options
(English Units) 6-7
Table 6-4a Model Coating Operation Parameters for
Condensation Control Option (Metric Units) 6-8
Table 6-4b Model Coating Operation Parameters for
Condensation Control Option (English Units) 6-9
Table 6-5 Model Coating Operation Parameters for
Substrate Type and Consumption 6-10
Table 6-6 Regulatory Alternatives for Solvent Storage
Tanks 6-13
Table 6-7 Regulatory Alternatives for Coating Mix
Preparation Equipment 6-15
Table 6-8 Regulatory Alternatives for Coating Operations 6-16
Table 7-1 Annual Air Pollution Impacts of the Regulatory
Alternatives and VOC Emission Reduction Beyond
Baseline for Model Solvent Storage Tanks 7-10
Table 7-2 Annual Air Pollution Impacts of the Regulatory
Alternatives and VOC Emission Reduction Beyond
Baseline for Model Coating Mix Preparation
Equipment 7-12
Table 7-3 Annual Air Pollution Impacts of the Regulatory
Alternatives and VOC Emission Reduction Beyond
Baseline for Model Coating Operations 7-13
Table 7-4 Annual Secondary Air Pollution Impacts for
Particulate Matter Emissions From Electrical
Energy Generation for the Control Equipment 7-15
IX
-------
LIST OF TABLES (continued)
Table 7-5 Annual Secondary Air Pollution Impacts for
Sulfur Oxide Emissions From Electrical
Energy Generation for the Control Equipment 7-17
Table 7-6 Annual Secondary Air Pollution Impacts for
Nitrogen Oxide Emissions From Electrical
Energy Generation for the Control Equipment 7-19
Table 7-7 Annual Secondary Air Pollution Impacts From
the Combustion of Natural Gas for the Control
Equipment 7-21
Table 7-8 Annual Secondary Air Pollution Impacts for
Particulate Matter Emissions From Steam
Generation for the Control Equipment 7-22
Table 7-9 Annual Secondary Air Pollution Impacts for
Sulfur Oxide Emissions From Steam
Generation for the Control Equipment 7-23
Table 7-10 Annual Secondary Air Pollution Impacts for
Nitrogen Oxide Emissions From Steam
Generation for the Control Equipment 7-24
Table 7-11 Annual Secondary Air Pollution Impacts for
Carbon Monoxide Emissions From Steam Generation
for the Control Equipment 7-25
Table 7-12 Annual Wastewater Discharges and Wastewater
VOC Emissions From the Fixed-Bed Carbon Adsorber
Control of Model Mix Preparation Equipment 7-26
Table 7-13 Annual Wastewater Discharges From the
Fixed-Bed Carbon Adsorber Control of Model
Coating Operations 7-27
Table 7-14 Annual Wastewater VOC Emissions From the
Fixed-Bed Carbon Adsorber Control of Model
Coating Operations 7-28
Table 7-15 Annual Solid Waste Impacts of the Regulatory
Alternatives on the Model Coating Mix Preparation
Equipment and Coating Operations 7-29
Table 7-16 Annual Electrical Energy Requirements for the
Control Equipment of Model Coating Mix
Preparation Equipment and Coating Operations 7-30
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LIST OF TABLES (continued)
Page
Table 7-17 Annual Natural Gas Requirements for the
Incinerator Control of Model Coating
Operations 7-32
Table 7-18 Annual Steam Requirements for the Control
Equipment for Model Coating Mix Preparation
Equipment and Model Coating Operations 7-33
Table 7-19 Total Annual Energy Demand of Control
Equipment for the Model Coating Mix
Preparation Equipment and Coating Operations 7-34
Table 7-20 Fifth-Year Impacts of Various Regulatory
Alternatives for Coating Lines 7-36
Table 7-21 Fifth-Year Impacts of Various Regulatory
Alternatives over Baseline for Coating Lines 7-37
Table 8-1 Basis for Estimating Annualized Costs—New
Facilities 8-8
Table 8-2 Capital and Annualized Costs for Solvent
Storage Tanks 8-9
Table 8-3 Capital and Annualized Costs for Coating
Mix Preparation Equipment 8-10
Table 8-4 Capital and Annualized Costs for Coating
Operations 8-11
Table 8-5 Capital and Annualized Costs of Conservation
Vents for Solvent Storage Tanks 8-12
Table 8-6 Capital and Annualized Costs of Pressure
Relief Valves for Solvent Storage Tanks 8-13
Table 8-7 Capital and Annualized Costs for Common
Carbon Adsorber for Control of Solvent
Storage Tanks 8-14
Table 8-8 Capital and Annualized Costs of Conservation
Vents for Coating Mix Preparation Equipment 8-15
Table 8-9 Capital and Annualized Costs for Common
Carbon Adsorber for Control of Coating Mix
Preparation Equipment 8-16
xi
-------
LIST OF TABLES (continued)
Page
Table 8-10 Capital and Annualized Costs for Carbon
Adsorber Control of Model Operations-
Regulatory Alternative 1 8-17
Table 8-11 Capital and Annualized Costs for Carbon
Adsorber Control of Model Operations-
Regulatory Alternative II 8-18
Table 8-12 Capital and Annualized Costs for Carbon
Adsorber Control of Model Operations—
Regulatory Alternative III 8-19
Table 8-13 Capital and Annualized Costs for
Condensation System Control of Model
Operations—Regulatory Alternative 1 8-20
Table 8-14 Capital and Annualized Costs for
Condensation System Control of Model
Operations—Regulatory Alternative II 8-21
Table 8-15 Capital and Annualized Costs for
Condensation System Control of Model
Operations—Regulatory Alternative III 8-22
Table 8-16 Capital and Annualized Costs for Incinerator
Control of Model Operations—Regulatory
Alternative IV 8-23
Table 8-17 Average and Incremental Cost Effectiveness
of Regulatory Alternatives for Storage Tanks 8-24
Table 8-18 Average and Incremental Cost Effectiveness
of Regulatory Alternatives for Coating Mix
Preparation Equipment 8-25
Table 8-19 Average and Incremental Cost Effectiveness
of Regulatory Alternatives for Model Operations
(Using Carbon Adsorber) 8-26
Table 8-20 Average and Incremental Cost Effectiveness
of Regulatory Alternatives for Model Operations
(Using Condensation System) 8-27
Table 9-1 Wholesale Value of Shipments by SIC Group,
1973-1982 9-3
xii
-------
LIST OF TABLES (continued)
Page
Table 9-2 Polymeric Coating of Supporting Substrates:
Adjusted Value of Shipments, 1982 '.. 9-5
Table 9-3 Polymeric Coating of Supporting Substrates:
Wholesale Value of Shipments for Industry
Segments, 1973-1982 9-6
Table 9-4 Polymeric Coating of Supporting Substrates:
Percentages of Total Output by Industry
Segment, 1973-1982 9-7
Table 9-5 Average Prices for Selected Products 9-9
Table 9-6 Polymeric Coating of Supporting Substrates:
Industry Segment Employment, 1973-1982 9-12
Table 9-7 Plants Applying Polymeric Coatings to
Supporting Substrates: Location, SIC Code,
Type of Coater, and Business Size 9-13
Table 9-8 Polymeric Coating of Supporting Substrates:
Concentration Ratios for Industry Segments,
1977 9-22
Table 9-9 Correlation Between Polymeric Coating Industry
Output and Indexes of Motor Vehicle and Total
U.S. Industrial Production 9-24
Table 9-10 Value of Imports for Polymeric Coated Products,
1978-1982 9-27
Table 9-11 Value of Exports for Polymeric Coated Products,
1978-1982 9-28
Table 9-12 Projected Annual Growth Rates for Sales of
Selected Final Products Manufactured From
Polymeric Coated Substrates 9-30
Table 9-13 Data Used To Derive Industry Forecast Equation 9-31
Table 9-14 Projected Value of Annual Output for the
Polymeric Coating Industry, 1984-1990 9-33
Table 9-15 Percent Cost Increases for Model Plants 9-38
Table 9-16 Annual Revenue Estimates for Model Lines
Producing Typical Products 9-40
• • *
xm
-------
LIST OF TABLES (continued)
Page
Table 9-17 Percent Price Increases for Typical Products 9-41
Table 9-18 Total Value of New Solvent-Based Capacity
Required, 1986-1990 9-44
Table 9-19 Summary of Fifth-Year Annualized Costs Under
Most Costly Regulatory Alternatives 9-48
Table A-l Evolution of the Background Information Document A-2
Table B-l Cross-Indexed Reference System to Highlight
Environmental Impact Portions of the Document B-2
Table C-l Process Parameters Monitored During
Plant B Source Testing C-19
Table C-2 Process Parameters for Fluidized-Bed
Carbon Adsorption System—Plant B C-21
Table C-3 Valid Data—Carbon Adsorber Control
Efficiency for Single Fabric Coating
Line—Test Data for Plant B C-22
Table C-4 Valid Data—Mix Tank Emissions Estimated From
EPA Method 24 Data for Plant B C-23
Table C-5 Invalid Test Data—Capture, Control, and Total
VOC Reduction Efficiency for Single Fabric
Coating Line at Plant B C-24
Table C-6 Invalid Plant Data—Total VOC Reduction
Efficiency for Single Fabric Coating Line
at Plant B C-27
Table C-7 Invalid Test Data—Summary of Test Results
at Plant C C-28
Table C-8 Valid Data—Summary of Coating Line Operations
at PSTL Facility C-29
Table C-9 Valid Data—Press Operations During Tests at
Meredith/Burda C-30
Table C-10 Valid Data—Summary of Demonstrated VOC
Emission Control Efficiencies at
Meredith/Burda, Percent C-31
xiv
-------
LIST OF TABLES (continued)
Page
Table C-ll Valid Data--Summary of Capture Efficiency
Data—General Tire and Rubber Company -... C-32
Table C-12 Valid Data—Summary of Carbon Adsorption
Efficiency Data—General Tire and Rubber
Company C-33
Table C-13 Summary of Solvent Recovery Measurement
Procedures C-34
xv
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1. SUMMARY
1.1 REGULATORY ALTERNATIVES
This background information document (BID) supports proposal of the
new source performance standards for limiting emissions of volatile organic
compounds (VOC's) from facilities performing polymeric coating of
supporting substrates. The development of standards of performance for
new, modified, or reconstructed stationary sources of air pollution were
dictated by Section 111 of the Clean Air Act (42 USC 7411). The sources of
the VOC emissions are the solvent storage tanks, coating mix preparation
equipment, and coating operation. The regulatory alternatives considered
are presented in Chapter 6.
Four regulatory alternatives were selected for control of VOC
emissions from solvent storage tanks. Alternative I represents
uncontrolled storage tanks and is equivalent to no Federal regulatory
action. This alternative is considered to be the baseline condition from
which the impacts of the other alternatives are calculated. The remaining
alternatives would require Federal regulatory action and would place
limitations on the allowable levels of VOC emissions.
Alternative II represents the estimated control level achievable by
venting each storage tank to the atmosphere through conservation vents set
at 17.2 kilopascals (kPa) (2.5 pounds per square inch, gauge [psig]).
Alternative II is equivalent to an overall control level of approximately
70 percent of the total emissions from the solvent storage tanks.
Alternative III represents the approximate level of emission reduction
achievable by control of emissions using pressure relief valves set at
103 kPa (15 psig) installed on solvent storage tanks. Alternative III is
equivalent to an overall control level of approximately 90 percent.
1-1
-------
Alternative IV, representing a 95 percent control level, is achievable by
venting all solvent storage tank emissions to a control device that is
95 percent efficient.
Three regulatory alternatives were selected for control of VOC
emissions from coating preparation equipment. Alternative I, the baseline
alternative, represents no control of emissions from these sources and is
equivalent to no Federal regulatory action. Alternative II represents the
estimated control level achievable by placing fastened, gasketed covers on
the individual pieces of equipment in the coating mix preparation room and
venting the emissions from each of these to the atmosphere through
conservation vents. Alternative II represents an overall control level of
40 percent of the total emissions from these sources. The additional
reduction in emissions represented by Alternative III, 95 percent overall
control, is achievable by venting the emissions from the individual pieces
of coating mix preparation equipment to a control device that is 95 percent
efficient.
Four regulatory alternatives were selected for control of VOC
emissions from the coating operation, which includes the application/
flashoff area and drying oven. The first alternative would require no
additional Federal regulatory action. It represents an overall VOC control
level of 81 percent of the emissions from the coating operation and
corresponds to the Control Techniques Guidelines (CT6) requirement of
0.35 kilogram (kg) of VOC per liter (s,) (2.9 pound [Ib] VOC per gallon
[gal]) of coating for existing polymeric coating facilities. The control
level of Alternative I could be achieved by capturing all drying oven
emissions and by venting all of these emissions to a control device that
achieves 90 percent control efficiency.
Alternative II is based on an overall 90 percent reduction of VOC
emissions. This control level can be achieved by installation of a
partial enclosure around the application/flashoff area and by venting
these emissions and the oven emissions through a control device that
achieves 95 percent control efficiency. Alternatives III and IV are
based on installation of a total enclosure around the application/
flashoff area and control of these emissions and the oven emissions by
95 and 98 percent efficient control devices, respectively. This
1-2
-------
configuration results in a 93 percent control level for Alternative III and
a 96 percent control level for Alternative IV.
1.2 ENVIRONMENTAL IMPACT
The primary environmental pollutant from the polymeric coating
facility is the VOC emitted from the solvent storage tanks, coating mix
preparation equipment, and coating operation. Emissions of VOC can result
in air pollution because they are precursors 1n the formation of ozone and
oxygenated organic aerosols (photochemical smog).
An overview of the potential environmental impacts with respect to
baseline that could result from the implementation of the regulatory
alternatives is presented in Table 1-1. Detailed analyses of the
environmental and energy impacts associated with each alternative are
discussed in Chapter 7.
Nationwide VOC emissions from new, modified, or reconstructed
polymeric coating lines (coating operations and associated coating
preparation equipment and solvent storage tanks) were estimated for the
years 1985 to 1990. It is projected that 26 new polymeric coating lines
will be constructed by 1990. Of these lines, 18 will be subject to the
control requirements. In 1990, nationwide VOC emissions from new solvent
storage tanks would result in 2 megagrams (Mg) (2.2 tons) under Alternative
I, while emissions under the most stringent level of control, Alternative
III, would be reduced to 0.1 Mg (0.11 tons). The VOC emissions from the
coating mix preparation equipment would range from 254 Mg (280 tons) under
Alternative I to 13 Mg (14 tons) under Regulatory Alternative III. The VOC
emissions from the coating operation would range from a high of 1,285 Mg
(1,416 tons) under Alternative I to a low of 128 Mg (172 tons) under
Alternative IV.
The regulatory alternatives are likely to result in negligible to
moderate adverse impacts on water quality and solid waste generation.
The operation of fixed-bed carbon adsorbers produces wastewater containing
dissolved organics. There are no wastewater discharges from fluidized-bed
carbon adsorbers, incinerators, or condensation systems. At most lines
in this industry, the wastewater currently is discharged to publicly
owned treatment works. Nationwide in 1990, the total quantity of
1-3
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TABLE 1-1. ENVIRONMENTAL AND ECONOMIC IMPACTS OF VARIOUS REGULATORY ALTERNATIVES
COMPARED TO ALTERNATIVE I (BASELINE) IN THE FIFTH YEAR (1990)
Wastewater
Emission reduction increase
Reg. Alt.
Storage tanks
1 1
1 1 1
IV
Coating mix preparation
equipment
1 1
II 1
Coating operation
II
1 1 1
IV
Mg/yr
1.40
1.80
1.90
102
241
964
1,060
1,156
tons/yr
1.54
1.98
2.09
112
266
1,062
1,168
1,275
mj/yr
0
0
0
0
967
3,628
4,515
(7,715)
10J gal/yr
0
0
0
0
255
958
1,193
(2,038)
Solid
waste increase
kg/yr
0
0
0
0
141
850
943
(733)
Ib/yr
0
0
0
0
311
1,874
2,080
(1,615)
a
Energy Cost increase
increase Annual -
TJ/yr 109 Btu/yr Capital, $ ized, $
0 0 17,360 2,900
00 0 (768)
0 0 238,000 47,490
0.0 0.0 42,240 (34,420)
2.7 2.6 412,340 35,190
15.4 14.6 1,394,700 332,700
12.8 12.2 2,535,400 326,160
120.3 114.1 1,115, 00 1,777,740
aFirst quarter 1984 dollars.
-------
wastewater produced under Alternative III would be approximately
12,230 cubic meters (m3) (3.2 million gal) for the coating operation and
967 m3 (0.26 million gal) for the coating mix preparation equipment. The
operation of fixed-bed and fluidized-bed carbon adsorbers generates some
solid waste in the form of waste carbon. Alternative III for the coating
mix preparation equipment would result in 141 kg (311 Ib) of solid waste,
assuming that 75 percent of the spent carbon is recycled. The total
quantities of solid waste from the coating operation in the fifth year
would range from 733 kg (1,615 Ib) under Alternative I to 1,676 kg
(3,695 Ib) under Alternative III.
The VOC emission control equipment used at polymeric coating
facilities utilizes energy in the forms of electricity, natural gas, and
fuel oil. The amount of energy required increases with increasing levels
of VOC control. In 1990, new polymeric coating operations would require
approximately 27 terajoules (TJ) (26 billion British thermal units [Btu])
of energy under Alternative I if carbon adsorbers only are installed to
recover solvent emissions. Alternative IV (incinerator) would require the
largest amount of energy, 148 TJ (140 billion Btu). The energy impacts
from control of the coating mix preparation equipment and the solvent
storage tanks are negligible.
The noise attributable to air pollution control equipment at polymeric
coating facilities results largely from motors and fans. Negligible
increases in noise levels occur as a result of increasingly stricter
regulatory alternatives. A matrix of the environmental and economic
impacts for the regulatory alternatives is presented in Table 1-2.
1.3 ECONOMIC IMPACTS
The economic impacts of each regulatory alternative are presented
in Table 1-1. Cumulative capital control costs over the first 5 years
would range from zero (Alternative I) to $238,000 (Alternative IV) for
control of solvent storage tanks, from zero (Alternative I) to $412,340
(Alternative III) for control of coating mix preparation equipment, and
from $4,624,600 (Alternative I) to $7,160,000 (Alternative III) for
control of the coating operation. Fifth-year annualized costs for
emission control would range from a net credit (Alternative III) to
1-5
-------
TABLE 1-2. MATRIX OF ENVIRONMENTAL ANP ECONOMIC
IMPACTS OF REGULATORY ALTERNATIVES FOR COATING OPERATIONS3
Regulatory
action
Alternative I
81 percent control
Alternative II
90 percent control
Alternative III
93 percent control
Alternative IV
96 percent control
Delayed standard
Air Water
impact impact b
(**) (*)
+1
-i-l
+2
+3
-1
0
0
0
Solid
waste
impactD
(*)
-1
+1
0
Energy Noise Economic
impact^ impact impact0
(***) (-) (*)
0 0
0
0
-3 0
0 0
+1
+2
+1
+2
+1
+2
-3
0
aThe environmental and economic impacts of the control of emissions
from solvent storage tanks and coating mix preparation equipment are
negligible in comparison to control of emissions from the coating
operation.
The impacts listed are for alternatives using carbon adsorber control
systems. For condensation system, the impact in all cases is zero.
cFor alternatives where either a carbon adsorber or a condensation system
can be used, the top impact number refers to carbon adsorber control, and
the bottom number refers to condensation system control.
KEY
+ Beneficial impact 0—No impact
- Adverse impact I—Negligible impact
* Short-term impact 2—Small impact
** Long-term impact 3—Moderate impact
*** Irreversible impact 4— Large impact
1-6
-------
$47,490 (Alternative IV) for the solvent storage tanks, from a net credit
(Alternative II) to $35,190 (Alternative III) for coating mix preparation
equipment, and from $349,620 (Alternative I) to $1,777,740
(Alternative IV).
The economic analyses indicate that the percent price increases
estimated for the typical products of model plants are generally less than
one-half of 1 percent for all combinations of regulatory alternatives. The
regulatory alternatives would have little or no impact on the industry's
growth rate and structure. Detailed analyses of the costs and the economic
impacts are presented in Chapters 8 and 9.
1-7
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2. INTRODUCTION
2.1 BACKGROUND AND AUTHORITY FOR STANDARDS
Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail. Various levels of control based on different techno-
logies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for a
standard. The alternatives are investigated in terms of their impacts on
the economics and well-being of the industry, the impacts on the national
economy, and the impacts on the environment. This chapter summarizes the
types of information obtained by EPA through these studies in the
development of the proposed standards.
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended,
hereafter referred to as the Act. Section 111 directs the Administrator to
establish standards of performance for any category of new stationary
source of air pollution which "... causes, or contributes significantly
to, air pollution which may reasonably be anticipated to endanger public
health or welfare."
The Act requires that standards of performance for stationary
sources reflect "... the degree of emission limitation and the percentage
reduction achievable through application of the best technological
system of continuous emission reduction which (taking into consideration
the cost of achieving such emission reduction and any nonair quality health
and environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated-1' The standards apply only
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to stationary sources, the construction or modification of which commences
after the standards are proposed in the Federal Register.
The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
Examples of the effects of the 1977 amendments are:
1. The EPA is required to review the standards of performance every 4
years and, if appropriate, revise them.
2. The EPA is authorized to promulgate a standard based on design,
equipment, work practice, or operational procedures when a standard based
on emission levels is not feasible.
3. The term "standards of performance" is redefined, and a new term
"technological system of continuous emission reduction" is defined. The
new definitions clarify that the control system must be continuous and may
include a low- or non-polluting process or operation.
4. The time between the proposal and promulgation of a standard under
Section 111 of the ,.ct may be extended to 90 days.
Standards of performance, by themselves, do not guarantee protection
of health or welfare oecause they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking
into consideration the cost of achieving such emission reduction and any
nonair quality health and environmental impacts and energy requirements.
Congress had several reasons for including these requirements.
First, standards having a degree of uniformity are needed to avoid
situations where some States may attract industries by relaxing standards
relative to other States. Second, stringent standards enhance the
potential for long-term growth. Tnird, stringent standards may help
achieve long-term cost savings by avoiding the need for more expensive
retrofitting when pollution ceilings may be reduced in the future.
Fourth, certain types of standards for coal-burning sources can adversely
affect the coal market by driving up the price of low-sulfur coal or by
effectively excluding certain coals from the reserve base due to their
high untreated pollution potentials. Congress does not intend that new
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source performance standards contribute to these problems. Fifth, the
standard-setting process should create incentives for improving technology.
Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources. States are free under Section 116 of the Act to establish
even more stringent emission limits than those established under
Section 111 or than those necessary to attain or maintain the National
Ambient Air Quality Standards (NAAQS) under Section 110. Thus, new sources
may in some cases be subject to State limitations that are more stringent
than standards of performance under Section 111, and prospective owners and
operators of new sources should be aware of this possibility in planning
for such facilities.
A similar situation may arise when a major emitting facility is to be
constructed in a geographic area that falls under the prevention of
significant deterioration of air quality provisions of Part C of the Act.
These provisions require, among other things, that major emitting
facilities to be constructed in such areas are to be subject to best
available control technology. The term "best available control technology"
(BACT), as defined in the Act, means
... an emission limitation based on the maximum degree of
reduction of each pollutant subject to regulation under this
Act emitted from or which results from any major emitting
facility, which the permitting authority, on a case-by-case
basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable
for such facility through application of production processes
and available methods, systems, and techniques, including
fuel cleaning or treatment or innovative fuel combustion
techniques for control of each such pollutant. In no event
shall application of "best available control technology"
result in emissions of any pollutants which will exceed the
emissions allowed by any applicable standard established
pursuant to Sections 111 or 112 of this Act.
(Section 169(3))
Although standards of performance are normally structured in terms
of numerical emission limits where feasible, alternative approaches are
sometimes necessary. In some cases, physical measurement of emissions
from a new source may be impractical or exorbitantly expensive.
Section lll(h) provides that the Administrator may promulgate a design
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or equipment standard in those cases where it is not feasible to prescribe
or enforce a standard of performance. For example, emissions of hydro-
carbons from storage vessels for petroleum liquids are greatest during tank
filling. The nature of the emissions (i.e., high concentrations for short
periods during filling and low concentrations for longer periods during
storage) and the configuration of storage tanks make direct emission
measurement impractical. Therefore, a more practical approach to standards
of performance for storage vessels has been equipment specification.
In addition, under Section lll(j) the Administrator may, with the
consent of the Governor of the State in which a source is to be located,
grant a waiver of compliance to permit the source to use an innovative
technological system or systems of continuous emission reduction. In order
to grant the waiver, the Administrator must find that: (1) the proposed
system has not been adequately demonstrated; (2) the proposed system will
operate effectively and there is a substantial likelihood that the system
will achieve greater emission reductions than the otherwise applicable
standards require or at least an equivalent reduction at lower economic,
energy, or nonair quality environmental cost; (3) the proposed system will
not cause or contribute to an unreasonable risk to public health, welfare,
or safety; and (4) the waiver when combined with other similar waivers
will not exceed the number necessary to achieve conditions (2) and
(3) above. A waiver may have conditions attached to ensure the source will
not prevent attainment of any NAAQS. Any such condition will be treated as
a performance standard. Finally, waivers have definite end dates and may
be terminated earlier if the conditions are not met or if the system fails
to perform as expected. In such a case, the source may be given up to
3 years to meet the standards, and a mandatory compliance schedule will be
imposed.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Administrator to list categories of
stationary sources. The Administrator "... shall include a category of
sources in such list if in his judgment it causes, or contributes
significantly to, air pollution which may reasonably be anticipated to
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endanger public health or welfare." Proposal and promulgation of standards
of performance are to follow.
Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of an approach for assigning
priorities to various source categories. The approach specifies areas of
interest by considering the broad strategy of the Agency for implementing
the Clean Air Act. Often, these areas are pollutants that are emitted by
stationary sources rather than the stationary sources themselves. Source
categories that emit these pollutants were evaluated and ranked considering
such factors as: (1) the level of emission control (if any) already
required by State regulations, (2) estimated levels of control that might
be required from standards of performance for the source category,
(3) projections of growth and replacement of existing facilities for the
source category, and (4) the estimated incremental amount of air pollution
that could be prevented in a preselected future year by standards of
performance for the source category. Sources for which new source
performance standards were promulgated or under development during 1977, or
earlier, were selected using these criteria.
The Act amendments of August 1977 establish specific criteria to be
used in determining priorities for all source categories not yet listed by
EPA. These are: (1) the quantity of air pollutant emissions which each
such category will emit or will be designed to emit, (2) the extent to
which each such pollutant may reasonably be anticipated to endanger public
health or welfare, and (3) the mobility and competitive nature of each such
category of sources and the consequent need for nationally applicable new
source standards of performance. The Administrator is to promulgate
standards for these categories according to the schedule referred to
earlier.
In some cases, it may not be immediately feasible to develop
standards for a source category with a high priority. This might happen
if a program of research is needed to develop control techniques or if
techniques for sampling and measuring emissions require refinement. In
the developing of standards, differences in the time required to complete
the necessary investigation for different source categories must also be
considered. For example, substantially more time may be necessary if
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numerous pollutants must be Investigated from a single source category.
Further, even late in the development process, the schedule for completion
of a standard may change. For example, inability to obtain emission data
from well-controlled sources in time to pursue the development process in a
systematic fashion may force a change in scheduling. Nevertheless,
priority ranking is, and will continue to be, used to establish the order
in which projects are initiated and resources assigned.
After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be
determined. A source category may have several facilities that cause air
pollution, and emissions from these facilities may vary according to
magnitude and control cost. Economic studies of the source category and of
applicable control technology may show that air pollution control is better
served by applying standards to the more severe pollution sources. For
this reason, and because there is no adequately demonstrated system for
controlling emissions from certain facilities, standards often do not apply
to all facilities at a source. For the same reasons, the standards may not
apply to all air pollutants emitted. Thus, although a source category may
be selected to be covered by standards of performance, not all pollutants
or facilities within that source category may be covered by the
standards.
2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of performance must: (1) realistically reflect best
demonstrated control practice; (2) adequately consider the cost, the nonair
quality health and environmental impacts, and the energy requirements of
such control; (3) be applicable to existing sources that are modified or
reconstructed as well as to new installations; and (4) meet these
conditions for all variations of operating conditions being considered
anywhere in the country.
The objective of a program for development of standards is to
identify the best technological system of continuous emission reduction
that has been adequately demonstrated. The standard-setting process
involves three principal phases of activity (1) information gathering,
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(2) analysis of the information, and (3) development of the standard of
performance.
During the information gathering phase, industries are questioned
through telephone surveys, letters of inquiry, and plant visits by EPA
representatives. Information is also gathered from other sources,
including a literature search. Based on the information acquired about the
industry, EPA selects certain plants at which emission tests are conducted
to provide reliable data that characterize the pollutant emissions from
well-controlled existing facilities.
In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies. Hypothetical
"model plants" are defined to provide a common basis for analysis. The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives." These regulatory
alternatives are essentially different levels of emission control.
The EPA conducts studies to determine the cost, economic, environ-
mental, and energy impacts of each regulatory alternative. From several
alternatives, EPA selects the single most plausible regulatory alternative
as the basis for standards of performance for the source category under
study.
In the third phase of a project, the selected regulatory alternative
is translated into performance standards, which, in turn, are written in
the form of a Federal regulation. The Federal regulation, when applied to
newly constructed plants, will limit emissions to the levels indicated in
the selected regulatory alternative.
As early as is practical in each standard-setting project, EPA
representatives discuss the possibilities of a standard and the form it
might take with members of the National Air Pollution Control Techniques
Advisory Committee. Industry representatives and other interested parties
also participate in these meetings.
The information acquired in the project is summarized in the back-
ground information document (BID). The BID, the proposed standard, and a
preamble explaining the standard are widely circulated to the industry
being considered for control, environmental groups, other government
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agencies, and offices within EPA. Through this extensive review process,
the points of view of expert reviewers are taken into consideration as
changes are made to the documentation.
A "proposal package" 1s assembled and sent through the offices of EPA
assistant administrators for concurrence before the proposed standard is
officially endorsed by the EPA Administrator. After being approved by the
EPA Administrator, the preamble and the proposed regulation are published
in the Federal Register.
The public is invited to participate in the standard-setting process
as part of the Federal Register announcement of the proposed regulation.
The EPA invites written comments on the proposal and also holds a public
hearing to discuss the proposed standard with interested parties. All
public comments are summarized and incorporated into a second volume of the
BID. All information reviewed and generated in studies in support of the
standard of performance is available to the public in a "docket" on file in
Washington, D.C. Comments from the public are evaluated, and the standard
of performance may be revised in response to the comments.
The significant comments and the EPA's position on the issues raised
are included in the preamble of a promulgation package, which also contains
the draft of the final regulation. The regulation is then subjected to
another round of review and refinement until it is approved by the EPA
Administrator. After the Administrator signs the regulation, it is
published as a "final rule" in the Federal Register.
2.4 CONSIDERATION OF COSTS
Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111 of
the Act. The assessment is required to contain an analysis of: (1) the
costs of compliance with the regulation, including the extent to which
the cost of compliance varies depending on the effective date of the
regulation and the development of less expensive or more efficient
methods of compliance; (2) the potential inflationary and recessionary
effects of the regulation; (3) the effects the regulation might have on
small business with respect to competition; (4) the effects of the
regulation on consumer costs; and (5) the effects of the regulation on
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energy use. Section 317 requires that the economic Impact assessment be as
extensive as practicable.
The economic impact of a proposed standard upon an industry is usually
addressed both in absolute terms and by comparison with the control costs
that would be incurred as a result of compliance with typical, existing
State control regulations. An incremental approach is taken because both
new and existing plants would be required to comply with State regulations
in the absence of a Federal standard of performance. This approach
requires a detailed analysis of the economic impact of the cost
differential that would exist between a proposed standard of performance
and the typical State standard.
Air pollutant emissions may cause water pollution problems, and
captured potential air pollutants may pose a solid waste disposal
problem. The total environmental impact of an emission source must,
therefore, be analyzed and the costs determined whenever possible.
A thorough study of the profitability and price-setting mechanisms of
the Industry is essential to the analysis so that an accurate estimate of
potential adverse economic impacts can be made for proposed standards. It
is also essential to know the capital requirements for pollution control
systems already placed on plants so that the additional capital
requirements necessitated by these Federal standards can be placed in
proper perspective. Finally, it is necessary to assess the availability of
capital to provide the additional control equipment needed to meet the
standards of performance.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy Act (NEPA) of
1969 requires Federal agencies to prepare detailed environmental impact
statements on proposals for legislation and other major Federal actions
significantly affecting the quality of the human environment. The
objective of NEPA is to build into the decision-making process of Federal
agencies a careful consideration of all environmental aspects of proposed
actions.
In a number of legal challenges to standards of performance for
various Industries, the United States Court of Appeals for the District
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of Columbia Circuit has held that environmental impact statements need not
be prepared by the Agency for proposed actions under Section 111 of the
Clean Air Act. Essentially, the Court of Appeals has determined that the
best system of emission reduction requires the Adirnistrator to take into
account counterproductive environmental effects of proposed standards, as
well as economic costs to the industry. On this basis, therefore, the
Courts established a narrow exemption from NEPA for EPA determinations
under Section 111.
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to Section 7(c)(l), "No action taken under the Clean Air Act
shall be deemed a major Federal action significantly affecting the quality
of the human environment within the meaning of the National Environmental
Policy Act of 1969." (15 U.S.C. 793(c)(l))
Nevertheless, the Agency has concluded that the preparation of
environmental impact statements could have beneficial effects on certain
regulatory actions. Consequently, although not legally required to do so
by Section 102(2)(C) of NEPA, EPA has adopted a policy requiring that
environmental impact statements be prepared for various regulatory actions,
including standards of performance developed under Section 111 of the
Act. This voluntary preparation of environmental impact statements,
however, in no way legally subjects the Agency to NEPA requirements.
To implement this policy, a separate section is included in this
document which is devoted solely to an analysis of the potential environ-
mental impacts associated with the proposed standards. Both adverse and
beneficial impacts in such areas as air and water pollution, increased
solid waste disposal, and increased energy consumption are discussed.
2.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as ". . . any stationary
source, the construction or modification of which is commenced ..."
after the proposed standards are published. An existing source is
redefined as a new source if "modified" or "reconstructed" as defined in
amendments to the General Provisions (40 CFR Part 60, Subpart A), which
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were promulgated in the Federal Register on December 16, 1975
(40 FR 58416).
Promulgation of standards of performance requires States to establish
standards of performance for existing sources in the same industry under
Section lll(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality criteria
have not been issued under Section 108 or which has not been listed as a
hazardous pollutant under Section 112). If a State does not act, EPA must
establish such standards. General procedures for control of existing
sources under Section lll(d) were promulgated on November 17, 1975, as
Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7 REVISION OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
Section 111 of the Act provides that the Administrator ". . . shall, at
least every four years, review and, if appropriate, revise ..." the
standards. Revisions are made to ensure that the standards continue to
reflect the best systems that become available in the future. Such
revisions will not be retroactive but will apply to stationary sources
constructed or modified after the proposal of the revised standards.
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3. PROCESSES AND POLLUTANT EMISSIONS
Polymeric coating of supporting substrates is a subcategory of web
coating. Web coating is defined as coating of fabric, paper, plastic film,
metallic foil, metal coil, or other products that are flexible enough to be
unrolled from a large roll, coated by blade, roll coating, or rotogravure
as a continuous sheet and, after cure, rerolled. Several web coating
categories are already subject to, or are being investigated for,
regulation by new source performance standards. These are: publication
rotogravure; rotogravure printing and top coating of flexible, polyvinyl
chloride (PVC), and urethane surfaces; coating of magnetic tape; coating of
pressure sensitive tapes and labels; and printing and application of
adhesives and coatings on paper, film, and foil in converting operations.
Polymeric coating of supporting substrates is intended to include all
other web coating operations excluding paper coating operations or those
operations that print an image on the surface of the substrate. Any
coating applied on the same printing press that applies the Image would
also be excluded. While polymeric coating encompasses a wide range of
substrates, coatings, and products, all of the operations are similar with
respect to the line configuration of unwind, coating application, flashoff
area, drying or curing oven, and rewind.
This chapter describes various processes used for polymeric coating of
supporting substrates and their resulting volatile organic compound (VOC)
emissions. The last section of this chapter discusses the selection of the
baseline emission level, which is used in later chapters to determine
incremental environmental and economic impacts of the regulatory
alternatives.
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3.1 INDUSTRY DESCRIPTION
A more detailed generalized flow of the coating process consists of
the following steps: (1) the receipt of raw materials such 'as substrates,
solvents, polymer resins, and additives; (2) the preparation of the
coating; (3) the application of the coating to the substrate; (4) the
drying/curing of the coating; and (5) any subsequent processes performed on
the coated substrate, such as slitting. The principle step in the
manufacturing process is the application of coatings to a substrate.
There are two general categories of coated products. In the first
category, the coated substrate takes on a combination of properties from
both the coating and the substrate. Coatings generally impart elasticity
to the substrate and also provide resistance to one or more of the
following: abrasion, water, chemicals, heat, fire, and oil. Examples of
coatings are natural and synthetic rubbers, urethanes, polyvinyl chloride
(commonly known as PVC or vinyl), acrylics, silicone, and nitrocellulose.
Substrates provide tensile strength, elongation control, and tear
strength. Substrates include woven, knit, and nonwoven textiles; leather;
yarn; and cord. The most prevalent substrate is woven fabric. The second
general category consists of those substrates that are coated with epoxy or
phenolic resins. Typical substrates are fiberglass and manmade fabrics.
Once coated, these products are not immediately cured but, first, are laid
in a mold and then cured under pressure to form a composite structure. In
both categories coated substrates are intermediate products that are used
in the fabrication of a variety of major end products, some of which are
listed in Table 3-1. However, these coatings and substrates do not
categorize the polymeric coating industry exclusively. It is the coating
process rather than the coating or substrate type that distinguishes
polymeric coating from other similar industries.
There are at least 128 domestic plants owned by 108 companies that
perform polymeric coating. The distribution of plants by number of coating
lines and by State is presented in Tables 3-2 and 3-3, respectively.
Over half of the 71 plants that supplied information (Table 3-2) have 1 to
4 coating lines, and only about 7 percent of the plants have 10 or more
lines. The largest number of coating lines found in a plant is 18.
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TABLE 3-1. MAJOR END USES OF COATED SUBSTRATES
1 2
End use
Coating
Substrate3
Aerospace composite
aircraft fabric
structures
Architectural structures
Awnings
Book covers
Conveyor, light duty,
and industrial V-belts
Diaphragms and gaskets
Drapery linings
Fencing
Flexible hoses
Hot-air balloons
Inflatables
Lightweight liners
Mattress fabric
Silicone, epoxies,
phenolics, vinyl
Silicone
Vinyl
Nitrocellulose,
urethanes
Synthetic rubber,
natural rubber
Synthetic rubber,
natural rubber
Acrylics
Synthetic
natural
Synthetic
natural
Urethanes
Synthetic
natural
Synthetic
natural
rubber,
rubber
rubber,
rubber
rubber,
rubber
rubber,
rubber
Synthetic rubber,
natural rubber
Fiberglass,
polyester, nylon,
polyaramids
carbon fiber
Fiberglass
Polyester, cotton,
canvas
Nylon, cotton,
polyester
Polyester and
cotton cord
Polyester and
cotton
Polyester, polyester-
cotton blend
Nylon
Polyester, cotton
Polyester, nylon
Glass or polyester
woven
Cotton, polyester,
and nylon cord
and yarn
Polyester drill
(continued)
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TABLE 3-1. (continued)
End use
Coating
Substratea
Military fabric
Offset printing blankets
Pond liners
Protective clothing
Rainwear
Recreational clothing
and equipment
Sails
Shoe fabric
Soft-sided luggage
Tarpaulins
Tents
Truck and storage
tank covers
Upholstery
Silicone, epoxies,
phenolics, vinyl
Synthetic rubber,
natural rubber
Synthetic rubber
Synthetic rubber,
natural rubber,
urethanes
Urethanes, synthetic
rubber, vinyl,
acrylics
Urethanes
Adhesives, urethanes
Urethanes, vinyl
Urethanes, vinyl
Synthetic rubber,
urethane, vinyl
Urethanes
Synthetic rubber,
natural rubber,
vinyl
Urethanes, vinyl
Fiberglass, poly-
aramid, polyester,
nylon
Polyester, cotton
and rayon blend
Nylon or polyester
scrim
Cotton, rayon,
nylon, polyester
Nylon, cotton
Nylon, polyester
Nylon, polyester
Cotton drill, high
density nonwoven
textiles
Rayon drill, nylon,
polyester
Nylon, polyester
Rayon, nylon,
polyester
Nylon, polyester
Cotton, rayon, nylon,
polyester
aSubstrates are listed by material or physical form.
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TABLE 3-2. DISTRIBUTION OF PLANTS THAT APPLY POLYMERIC
COATINGS TO SUPPORTING SUBSTRATES BY NUMBER OF COATING LINES
No. of
coating I1nesa
1
2-4
5-10
>10
TOTAL
No. of
plants
19
30
17
5
7T
Percent-
age of
plants
27
42
24
7
100
aCoating line is defined to include the coating
application/flashoff area and the drying oven.
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TABLE 3-3. NUMBER OF PLANTS THAT APPLY POLYMERIC
COATINGS TO SUPPORTING SUBSTRATES BY STATE
State No. of plants
Alabama 1
Arkansas 2
California 7
Colorado 1
Connecticut 7
Florida 1
Georgia 6
Illinois 3
Indiana 2
Kansas 1
Maryland 1
Massachusetts 18
Michigan 2
Minnesota 1
Mississippi 1
Missouri 2
New Hampshire 2
New Jersey 9
New York 10
North Carolina 6
Ohio 13
Pennsylvania 2
Rhode Island 7
South Carolina 8
Tennessee 5
Texas 3
Vermont 1
Virginia 3
Wisconsin 3
TOTAL 128
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This source category is not restricted to any one region of the country by
raw material or market requirements, but most plants are located in the
more heavily populated and industrialized areas.
Polymeric coating plants may be classified into two broad categories,
commission and captive (or noncommission) coaters. The commission coater
has many customers and produces coated substrates according to each
customer's specifications. The captive coater produces coated substrate as
an intermediate product in a manufacturing process.
3.2 RAW MATERIALS
The raw materials used to produce polymeric coatings include
plasticizers, solvents, polymer resins, pigments, curing agents, and
fillers such as carbon black or Teflon®. Plasticizers are added to the
coating to increase its pliability. Frequently used plasticizers include
fatty acids, alcohols, and dialkyl phthalates.
Solvents are added to the coating to disperse the solids and to adjust
the viscosity of the coating. Factors affecting solvent selection are
dispersability, toxicity, availability, cost, desired rate of evaporation,
ease of use after solvent recovery, and effect on solvent recovery
equipment. Table 3-4 presents the solvent and solids content of the
various polymeric coatings. The major organic solvents used in the
coatings are toluene, dimethyl formamide (DMF), acetone, methyl ethyl
ketone (MEK), isopropyl alcohol, xylene, and ethyl acetate. Toluene is one
of the lowest cost organic solvents and therefore is the most commonly
used.
The trend over the past 15 years is to use less solvent because of
the increasing cost, environmental regulations, and awareness of the
hazards of emissions both to workers and to the environment.8 More than
30 percent of the plants identified in this source category currently
use low-solvent coatings such as waterborne or higher solids.2 Waterborne
coatings may be defined as containing more than 5 percent water (by
weight) in the liquid fraction.9 Higher solids coating is a term often
applied to any coating which contains considerably higher solids than
conventional coatings used in the past.1 Plastisol coatings and rubber
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TABLE 3-4. SOLVENT AND SOLIDS CONTENT OF POLYMERIC COATINGS7
Typical percentage, by weight
Polymer type
Rubber
Urethanes
Acrylics4
Vinylb
Vinyl Plastisol
Organise!
Epoxies
Si li cone
Nitrocellulose
% solvent
50-70
50-60
50
60-80
5
15
30-40
50-60
70
% solids
30-50
40-50
50
20-40
95
85
60-70
40-50
30
aOrganic solvents are generally not used in the formulation of acrylic
coatings. Therefore, the solvent content for acrylic coatings represents
.nonorganic solvent use (i.e., water).
Solvent borne vinyl coating.
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coatings used 1n calendering and extrusion processes are 95 to 100 percent
, . . 11-15
solids.
3.3 PROCESSES AND THEIR EMISSIONS
The process of applying a polymeric coating to a supporting substrate
consists of: mixing the coating ingredients (including the solvents),
conditioning the substrate, applying the coating to the substrate, and
evaporating the solvent in a drying oven. Sometimes, subsequent curing or
vulcanizing is necessary. The steps in this process are typical of any
polymeric coating plant applying liquid coatings. Figure 3-1 presents a
schematic of a solvent borne polymeric coating operation. The emissions of
concern are VOC's that result primarily from the vaporization of solvents
during coating and drying of the substrate and, in lesser amounts, during
solvent storage, coating preparation, and cleaning of the equipment. Small
amounts of VOC emissions also may occur as by-products of reactions that
take place when coatings are mixed or as the coatings are cured.
3.3.1 Solvent Storage
Each polymeric coating plant may have up to five solvent storage
tanks. Generally, the capacity of the tanks ranges from 19 cubic meters
(m) (5,000 gallons [gal]) to 38 m3 (10,000 gal). However, tanks as small
as 3.8 m3 (1,000 gal) and as large as 76 m3 (20,000 gal) in capacity are
used. The tanks are built with open vents or with conservation vents. The
majority of plants have solvent storage tanks that are located below
ground. » However, industry contacts have indicated that solvent storage
tanks at new plants would be built above ground because of concerns about
potential ground water contamination.17
3.3.2 Preparation of Coating
For the purposes of this document, coating mix preparation equipment
includes all the mills, mixers, mixing and holding tanks, and pumps
required to produce a polymeric coating (either in dry or liquid form) that
is ready to be applied to the substrate. The number of steps involved in
preparing the coating depends on the form (chunks, blocks, chips, pellets,
or fine powder) in which the polymer is received and fed to the process.
3-9
-------
u>
I—'
o
SOLVENT
STORAGE
CONDITIONED
SUBSTRATE
COATING
PREPARATION
EQUIPMENT
CLEAN UP
SOLVENT
COATING
APPLICATION/
FLASHOFF
AREA
*
I
DRYING
OVEN
TT
t_
CURING
OVEN
(OPTIONAL)
COATLu
SUBSTRATE
VOC emissions are denoted by an '*'
Figure 3-1. Solvent borne polymeric coating operation and VOC emission locations.
-------
The polymers that are supplied in large chunks or blocks require the
most elaborate coating preparation procedure. This procedure for preparing
coating is typical of rubber coatings. The polymer, along with pigments,
fillers, and sometimes oils, is fed to a Banbury mixer that blends the
mixture by a set of rotors. The mixture is discharged as a semi-moHen
slab, which is cooled and then is usually sent to a two-roll mill in which
curing agents and other additives are blended. At some plants, the polymer
is fed directly to the roll mill if the chunks are small enough. The roll
mill is a set of two rollers that squeezes layers of polymer together.
Mixing occurs as strips of polymer are peeled off and refed to the rolls.
From the two-roll mill, the polymer is either sent to a calendering or an
extrusion process, both of which use solventless coatings, or to a shredder
that cuts the polymer into small rectangular cubes or pellets. The cubes
or pellets are fed to a mixing vessel, sometimes called a churn or kettle,
to be dissolved or suspended in solvents or plasticizers.
Some manufacturers supply the polymer in chip or pellet form that
precludes the Banbury mixing and roll milling steps. Additives and
solvents are added directly to the polymer into a mixing vessel. The
homogeneity of a coating solution is critical; therefore, the coating is
filtered through a series of wire screens prior to application.
Another procedure for preparing coatings is typical of PVC
plastisols. The polymer is a fine powder, which is suspended in
plasticizers with emulsifying agents. Occasionally a small amount
(5 percent or less) of organic solvent is added for viscosity control.11 A
typical coating preparation equipment configuration for plastisol coatings
1 fl
is a mixer, vacuum pump, vacuum hood, and filter.
Urethane coatings are generally purchased premixed and require little
or no mixing at the plant site. Acrylic and vinyl coatings are also
sometimes purchased premixed.19 Therefore, few, if any, pieces of coating
preparation equipment are required for these operations.
3.3.3 Substrate Preparation
Prior to the application of the coating, substrates are typically
cut into production size rolls and inspected for any defects. If there
are any major defects, the substrate is discarded. Minor defects are
3-11
-------
cut out of the substrate. ° Substrates may also be washed and shrunk or
2 1
stretched. Sometimes, to reduce the moisture content, the substrate is
passed through a series of steam-heated rollers just prior to coating.22
Fabric widths used in coating operations range from 48 to 72 inches.
Although use of the 72-inch width is increasing, the 60-inch width is
currently most commonly used. Wider fabrics maximize production rates,
which result in a less expensive intermediate product.4'5*23
3.3.4 Coating Application
The three primary types of equipment used for applying liquid coating
(including plastisols) to the substrate are: knife-over-roll, dip, and
reverse-roll coaters. Figure 3-2 presents typical configurations for these
coaters. This equipment is applicable for organic solvent borne and
waterborne coatings.
Knife-over-roll is the most common type of coating application
method. The coating is either pumped or manually poured onto the
substrate just in front of a knife that is perpendicular to the
substrate. The coating thickness depends on the clearance between the edge
of the knife and the substrate. The equipment can apply a variety of
coatings at a wide range of coating thicknesses from 50 ym (2 mils) up to
2,500 urn (100 mils).25
Dip coating is another common coating application method used when
saturation of the substrate is desired. All cord- and yarn-coating lines
and some rubber- and epoxy-coating lines employ dip coaters. The
substrate passes from a roller (or series of spools) through a coating
reservoir (called a dip tank or dip vat) and emerges through a pair of
rollers or wiper blades that removes excess coating. The amount of coating
remaining on the substrate is controlled by the pressure of the rollers or
wiper blades on the substrate.
The third coating application method is the reverse-roll coater. This
method is used when thin coating layers must be applied with a high degree
of precision.*1 »5'26 There are many configurations of reverse-roll
coaters. In a three-roll reverse-roll coater, the substrate is drawn
around the bottom of the three rolls while coating is applied to the top
roll. Coating thickness is controlled by the gap between rolls and the
3-12
-------
TO DRV ING OVEN
co
i—>
CO
COATED
SUBSTRATE
WIPER ,
BLADES
DIP COATER
COATING
COATED SUBSTRATE TO DRYER
_ SUBSTRATE TO BE COATED
HARD RUBBER OR STEEL ROLLER
KNIFE-OVER-ROLL COATER
ROLL OF
UNCOATED
SUBSTRATE
COATED SUBSTRATE
TO DRYER
SUBSTRATE TO
BE COATED
KNIFE
COATING
REVERSE-ROLL COATER
Figure 3-2. Three typical coating application equipment configurations.
-------
line speed. The reverse-roll coating method is commonly used by urethane
coaters. According to one industry contact, rubber coatings typically are
not applied by this method because the coating tends to dry on the
-ii 28
rollers.
While the three liquid coating application methods vary in the
physical setup, the overall coating line configuration of unwind, coating
application, flashoff area, drying oven, and rewind is similar for all
three. Their main function of applying coatings to the substrate is the
same. Similar VOC fugitive emission capture devices around the coating
application/flashoff area and similar control devices to control the VOC
emissions, could be applied to coating lines using any of the coating
application methods.
Table 3-5 presents the coating type, line speed, and dry coating
thickness of the coating applicators used to apply liquid coatings. Line
speeds of 5 to 32 meters (5 to 35 yards) per minute are typical for all
types of applicators; however, 46 meters (50 yards) per minute can be
achieved with some coating compounds. » Although three different coaters
are used to apply a wide variety of liquid coatings, there is not a wide
variation in coating line speeds, amount of coating applied, or dry coating
thickness as can be seen by Table 3-5.
The types of coating processes that apply 95 to 100 percent solid
coatings include calendering, extrusion, and lamination. Calendering is a
process in which the coating is formed into a self-supporting sheet by
squeezing it between successive pairs of heated rolls, each pair rotating
faster than the previous pair. The sheet is subsequently pressed against
the supporting substrate to form the coated product. Extrusion is the
process of forcing a heated thermoplastic resin through a slit or die to
form a sheet. In the coating process, the sheet, while still in a semi-
molten state, is pressed into the substrate. Lamination is a process of
using heat, adhesives, and pressure to bond a substrate and plastic'film.
The line utilization rate is the amount of time the coating equipment
is in operation during a working day and is directly related to the
length of substrate rolls, the time required to change rolls, any downtime
due to process upsets, and product changes. The line utilization rate
3-14
-------
TABLE 3-5. COATING APPLICATOR PARAMETERS'
Coater
Coating type
Line
speed, Dry coating
meters/min thickness,
(yards/min) urn (mils)
Knife-over-roll Rubber (natural & synthetic)
Urethane
Vinyl
Silicone
Acrylic
Dip
Reverse roll
Rubber (natural & synthetic)
Epoxy
Phenolic
Silicone
Vinyl
Urethane
6.1-23
(6.7-25)
1.5-40
(1.7-43)
13.7-64
(15-70)
75-500
(3-20)
25-2,000
(1-80)
25-1,250
(1-50)
3-15
-------
for captive coating lines tends to range between 80 and 90 percent of a
given shift. * Commission coaters generally have more product changes to
implement, and the time required to implement product changes may result in
lower utilization rates. Commission coaters may orly use their coating
equipment 45 to 50 percent of a given shift.3'5
3.3.5 Drying
Liquid coatings must be solidified by evaporating the solvent, or in
the case of plastisols, causing the plasticizers to diffuse into the PVC
resin. This is accomplished by passing the coated substrate through a
drying oven. The typical distance between the coating application point
and the.oven entrance varies from about 15 cm (6 in) for knife coaters up
to 1 m (3.3 ft) for dip or roll coaters. Drying ovens may be vertical or
horizontal and range from 4 to 8 feet in width and 20 to 100 feet in height
or length. They may be steam heated or direct fired but usually involve
some kind of forced air convection system utilizing impingement nozzles.
The air turbulence dries the coating surface and prevents dead spots in the
oven where the temperature or solvent vapor concentration might build up to
a dangerous level.
Most ovens are single zoned; however, the temperature usually
increases between the oven entrance and exit. Multizoned ovens are used
where discretely different temperatures or residence times at particular
temperatures are necessary for drying and in-line curing. Multizoned ovens
are also used when more than one coating application station exists in the
coating line.
A key design and operating parameter is the percentage of the lower
explosive limit (LEL) of the solvents that must be maintained inside the
oven for safe operation. Insurance companies require that solvent borne
coating lines maintain the solvent concentration in the oven at 25 percent
or less of the LEL if the solvent concentration in the drying oven is not
continuously monitored. Historically, most polymeric coaters have
operated their ovens at less than 25 percent of the LEL and at relatively
M- 30
high airflow rates ranging from 3,000 to 15,000 scfm. » The high
airflows allowed for future increases in production or higher solvent load
to the oven. Recently, advances in oven design and monitoring
instrumentation, spurred by rapidly rising fuel cost, have enabled
3-16
-------
manufacturers to increase solvent concentrations up to 50 percent of the
2 9
LEL while allowing for varying solvent loads.
Some rubber coated substrates require subsequent curing or
vulcanizing. One procedure is to drape the coated substrate on tiers in a
festoon oven that is heated up to 140°C (280°F) for 1 to 12 hours. Another
procedure is to wind the coated substrate within a special nonadhering
paper and cure as a roll in a large autoclave.
Some polymeric coaters that apply higher solids coatings are using
ultraviolet or electron beam curing. 2 In ultraviolet curing, ultraviolet
light reacts with photosensitizers in the coating to initiate cross!inking
to form a solid. The electron beam process uses high energy electrons to
effect the cure of the coating. For both curing methods, there is a
substantial decrease in energy usage compared with thermal curing.
3.3.6 VOC Emissions
3.3,6.1 Sources of Emissions and Factors Affecting Emissions. The
VOC emissions from polymeric coating of supporting substrates are primarily
solvents and trace amounts of plasticizers and reaction by-products (cure-
volatiles). Solvents are used in coatings and during cleanup of the coater
and ancillary equipment. The VOC emissions are released from several
points in the coating operation, and these sources are identified in
Figure 3-1.
The VOC emissions from outdoor solvent storage tanks occur as working
losses during filling and breathing losses due to diurnal temperature
changes. The rate of these emissions depends on the tank size, solvent
vapor pressure, solvent throughput, magnitude of temperature changes, and
presence of conservation vents or relief valves.
In the coating preparation area, VOC's are emitted from the individual
mixers and holding tanks during: (a) the filling of mixers, (b) transfer
of the coating, (c) intermittent activities such as changing the filters in
the holding tanks, and (d) mixing if the equipment is not equipped with
tightly fitting covers. The emissions may be intermittent or continuous,
depending on whether the method of coating preparation is batch or
continuous.
3-17
-------
Emissions from the coating application area result from the
evaporative loss of solvent around the coating application area during
transfer and application of coating and from the exposed substrate as it
travels from the coater to the drying oven entrance (flashoff). The
magnitude of these losses is a function of the amount of solvent in the
coating as well as line width and speed, coating thickness, volatility of
the solvent(s), temperature, distance between coater and oven, and air
turbulence in the coating area.
In the drying oven, the rate of evaporation of solvent is affected by
the temperature, airflow rate and direction, and the line speed. The
airflow rate is always adjusted to keep the VOC concentration below the
LEL. All but a very small fraction of the solvent from the coating
evaporates in the oven, and there are virtually no solvent emissions from
subsequent production steps. Some plasticizers and reaction by-products
may be emitted if the coating is subsequently cured or vulcanized. These
emissions are usually negligible compared to the total emissions from the
operation.
Information obtained in the development of new source performance
standards for the manufacturing of magnetic tapes was utilized to determine
the apportionment of emissions between the coating preparation equipment
and the coating line. 5 Because both polymeric coating and magnetic tape
manufacturing are web coating processes using similar types of solvents, it
has been assumed that the ratio of emissions from the coating preparation
equipment and the coating line is the same for both types of coating
processes. In the magnetic tape manufacturing process, it was estimated
that of the total emissions, approximately 10 percent are emitted from the
coating mix preparation equipment and 90 percent from the coating
operation. This ratio of emissions from these two areas has been assumed
to be applicable for facilities performing polymeric coating of
substrates. This estimate was confirmed by a coating mix preparation
equipment vendor.36 This number is generally accepted as a rule-of-thumb
among the polymeric coaters surveyed in this investigation.
Information on 18 facilities shows that the amount of solvent used
for cleaning of coating equipment in 1979 varied from 0 to 14 percent of
3-18
-------
the total solvent used at the plants; the average was 3.5 percent. Much
of this solvent stays In the liquid phase and can be reused or is stored or
disposed in accordance with solid waste and water quality regulations.
3.3.6.2 Emission Estimates. Potential uncontrolled emissions from
polymeric coating operations were estimated from data on the total amount
of solvent used by polymeric coating plants. Information on solvent usage
was obtained from 32 plants using solvent borne coatings. These data were
reduced to determine the average solvent usage per coating line per
shift. This number was scaled to estimate the annual solvent usage for an
individual plant and on a nationwide basis for this source category. The
estimated average uncontrolled VOC emissions from a polymeric coating line
using solvent borne coatings and operating 2 shifts per day would be 155 Mg
(170 tons) per year. Potential uncontrolled VOC emissions from coating
lines are estimated to range from 0 to 3,000 Mg (0 to 3,300 tons) per
plant. Potential nationwide uncontrolled VOC emissions were estimated to
range from 29,000 to 35,000 Mg (32,000 to 39,000 tons).37
3.4 BASELINE EMISSION LEVEL
The baseline emission level represents the level of control that is
required under existing State and local regulations. The baseline is used
to evaluate the impacts of the regulatory alternatives to be selected for
analysis.
3.4.1 Existing Emission Limits
Table 3-6 summarizes the State and local regulations for VOC emissions
applicable to plants with facilities that apply polymeric coatings to
supporting substrates. Of the 30 States that have plants with polymeric
coating facilities, 22 States (with 112 facilities) limit VOC emissions to
0.35 kilogram per liter (kg/a) (2.9 Ib/gal) of coating applied, excluding
water. This emission limit is recommended by the control techniques
guideline (CTG) document.38 Three of the 30 States having polymeric
coating plants have no VOC emission limits that apply to this source
category. The remaining five States require intermediate levels of VOC
control.
3-19
-------
TABLE 3-6.
STATE REGULATIONS FOR VOC EMISSIONS FROM
POLYMERIC COATING SOURCES
State
Al abana
Alaska
Arizona
Arkansas
California0
Colorado
Connecticut
Deleware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowaf
Kansas
Kentucky
Louisiana
Maine
Maryl and
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
No. of
plants
per State
1
--
--
2
7
1
7
--
--
1
7
—
--
3
2
—
1
1
--
--
1
19
2
1
1
2
—
—
—
3
7
--
10
6
—
13
Regulation3
1
b
b
2.3,4
—
1
1
1
d
1
1
b
b
e
1
—
b
5
1
b
1
1
1
b
b
1
b
b
b
1
1
b
1
1
b
1
9
Air pollution regulation reference
(Environment Reporter)
Ch. 6.1.1.6 and Ch. 6.1.1.7. March 23, 1982.
November 1, 1982.
February 2, 1982.
Sec. 5.5. September 26, 1980.
November 11, 1982. Reg. 7 IX.
Sec. 19-508-20(0) and Sec. 19-508-20(0). January 2, 1975.
Regulation XXIV. Section 9. October 8, 1982.
Sec. 8-2:707(F). February 26, 1981.
17-2.650(1). December 30, 1982.
391-3-1-0. 02(w) and 391-3-1-0. 02(x). August 27, 1982.
May 13, 1976.
October 1, 1979.
Rule 205(f).
Article 8. Rule 2, November 8, 1982.
November 17, 1982.
May 1. 1982.
401 KAR 59:210, 401 KAR 61:120, 401 KAR 59:214 and
401 KAR 61:124. January 14. 1983.
Sec. 22.9.2. January 27, 1983.
December 22. 1982.
Sec. 10.18.21.07. December 27, 1982.
Sec. 7.18(14). Sec. 7.18(15), Sec. 7.18(16), and
Sec. 7.18(17). December 31, 1982.
Part 6, Table 63 and R 336.1620. December 31. 1982.
November 8, 1982.
December 8, 1982.
Ch. 2 and Ch. 5. November 11, 1982.
June 1, 1981.
August 6, 1982.
July 1981.
Part 1204.05 and Part 1204.06. July 20, 1982.
7:27-16.5. March 1, 1982.
November 24, 1980.
Parts 228.3, 228.7, and 228.8. May 10, 1981.
Regulation 0.0920, 0.0921, and 0.0935. December 1. 1982.
July 1, 1982.
3745-21-09(F), (6). (H). December 3. 1982.
Regulation 3.7.3(A)(1). April 9, 1982.
(continued)
3-20
-------
TABLE 3-6. (continued)
State
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
No. of
plants
per State
--
2
7
8
—
5
3
--
1
3
--
--
3
Regulation3
2.3,4
2,3.4
1
1
b
1
1
1
1
1
2.3,4
b
1
b
Air pollution regulation reference
(Environment Reporter)
340-22-170. January 22. 1982.
Sec. 129.52. January 7, 1983.
APC Regulation 19. April 5. 1982.
Standard No. 5, Sec. II(C), and (G). December 16, 1982.
March 18, 1982.
Ch. 1200-3-18-0.06, 0.14 and 0.20. February 1, 1982.
Regulation V. February 16, 1982.
Part IV. July 29, 1982.
Subch. 1, 5-253. November 3, 1981.
Rule Ex-5, 4.55. March 1, 1983.
Ch. 173-490 and WAC 173-490-207. December 31, 1981.
April 8, 1982.
NR 154.13(E), (F), and (K). December 1, 1982.
August 26, 1981.
aFollowing regulations are applicable for fabric coating facilities:
Regulation 1: 0.35 kg/S, (2.9 Ib/gal) of coating, minus water, delivered to coating applicator.
Regulation 2: 0.52 kg/1 (4.3 Ib/gal) of coating, minus water, delivered to a coating applicator that applies a clear
coating.
Regulation 3: 0.42 kg/1 (3.5 Ib/gal) of coating, minus water, delivered to a coating applicator that utilizes air or
forced air dryers and that applies extreme performance coatings.
Regulation 4: 0.36 kg/2, (3.0 Ib/gal) of coating, minus water, delivered to a coating applicator for all other coatings.
Regulation 5: No more than 15 percent by weight of VOC's net input into an affected facility.
''National aoblent air quality standards only.
cPend1ng.
No discharge to atmosphere of more than 15 Ib of photochemically reactive solvents in one day or 3 Ib in 1 hour unless
uncontrolled organic emissions are reduced by 85 percent. No discharge to atmosphere of more than 40 Ib of nonphoto-
chenlcally reactive solvents in 1 day or 8 Ib in 1 hour unless uncontrolled organic emissions are reduced by 85 percent.
No discharge to atmosphere of >8 Ib per hour of organic material frora any emission source, except if controlled: (1) By
flame, thermal, or catalytic incineration to reduce emissions to <10 ppm equivalent methane or convert 85 percent of
hydrocarbons to CO and HO). (2) By vapor recovery to control 85 percent of total uncontrolled organic material, (3) 8y
any other air pollution control equipment capable of 85 percent reduction of uncontrolled organic material.
Emissions from painting and surface coating operations--0.01 grain of particulate per standard cubic foot of exhaust gas.
9(a) No discharge to atmosphere from any coating line or operation using: Alkyd Primer, 4.8 Ib/gal; vinyls, 6.0 Ib/gal; ML
lacquers, 6.4 Ib/gal; Acrylics, 6.0 Ib/gal; Epoxies 4.8 Ib/gal; maintenance finishes, 4.8 Ib/gal; custom product finishes;
6.5 Ib/gal; (b) An owner or operator may develop a plant-wide emission plan instead of for each coating line; (c) No
discharge of more than 3,000 Ib of organics in one day or more than 450 Ib in 1 hour; (d) 90 percent reduction by
incineration; (e) 85 percent reduction by adsorption or any process of equivalent reliability and effectiveness.
3-21
-------
Twenty States do not have existing polymeric coating plants. Of these
States, three have applicable VOC emission limits of 0.35 kg/a (2.9 Ib/gal)
of coating applied, excluding water. Two of these three have exemptions
for sources using or emitting less than a specified amount of coating or
VOC's. Thirteen of the 20 States that do not have existing polymeric
coating plants have no VOC emission limits that apply to this source
category. The remaining four States require intermediate levels of VOC
control.
3.4.2 Determination of Baseline Emission Levels
The baseline emission level for the coating operation is considered to
be an allowable VOC emission limit of 0.35 kg/a (2.9 Ib/gal) of coating for
a typical formulation. This is the average of the State regulations when
each emission limit was weighted by the number of existing polymeric
coating plants in that State.
To comply with the State regulations, polymeric coating plants may
either install an abatement device, use low-VOC-content coatings, or
both. Typically, when a control device is used, only emissions from the
drying oven are controlled. Some emissions from the application/flashoff
area may be entrained by the oven draft and, thus, will be controlled.
Emissions from the coating preparation equipment and solvent storage tanks
are not ducted to the control device. Therefore, the baseline emission
levels for solvent storage tanks and coating preparation equipment are
considered to be the uncontrolled emission levels. For coating operations
(application/flashoff area and drying oven), the baseline emission level is
considered to be the level attained by controlling drying oven emissions.
3.5 REFERENCES FOR CHAPTER 3
1. Kirk-Othmer Encyclopedia of Chemical Technology. Volume 6. John
Wiley and Sons. Third Edition. 1978. pp. 377-386.
2. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. July 9, 1984. Information summarizing the
name and locations of each plant, type of coating used, number of
coating lines, major end products, and whether or not the plant is a
commission coater.
3. Reference 2, p. 9.
3-22
-------
4. Letter from Hindie, M., The Kenyon Piece Dyeworks, Inc., to Grumpier,
0., EPAiCPB. March 23, 1984. Information provided about 1983 monthly
solvent recovery efficiency data and factors affecting commission
coaters.
5. Telecon. Maurer, E., MRI, with Swain, R., Lembo Corporation.
March 7, 1984. Information on coating equipment design and operation.
6. Telecon. Maurer, E., MRI, with Leach, A., Indev Machinery Division.
March 7, 1984. Information on coating equipment design and operation.
7. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 26, 1984. Summary of information on
polymeric coatings used in the coating of supporting substrates.
8. Telecon. Thorneloe, S., MRI, with Walsh, W., Research and Graduate
Studies, North Carolina State University. March 12, 1984. Information
regarding trends in solvent usage in polymeric coating operations.
9. U. S. Environmental Protection Agency. Glossary for Air Pollution
Control of Industrial Coating Operations. Second Edition.
EPA-450/3-83-013R. December 1983. p. 23.
10. Reference 9, p. 9.
11. Reference 9, p. 22.
12. Telecon. Maurer, E., MRI, with Hartenstein, R., Custom Coated
Products, Division of Hartco. November 29, 1983. Information
regarding the conversion by this plant to 100 percent solid PVC
coatings.
13. Telecon. Maurer, E., MRI, with Mr. Venkataraman, Seaman Corp.,
Shelterite Division. January 3, 1984. Information on a solventless
"hot melt" (calendering) process.
14. Telecon. Maurer, E., MRI, with Schoen, W., Armstrong Cork Company.
December 19, 1983. Information on a solventless rubber coating
operation.
15. Telecon. Maurer, E., MRI, with Gilbert, R., and D. Phillips, Reef
Industries, Inc. January 19, 1984. Information on an extrusion
operation.
16. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 22, 1984. Summary of
nonconfidential information regarding solvent storage tanks at
polymeric coating plants.
3-23
-------
17. Telecon. Friedman, E., MRI, with Coffey, F., Southern Tank and Pump
Company. August 23, 1984. Information on solvent storage tanks.
18. Telecon. Friedman, E., MRI, with Mueller, J., Day Mixing Company.
June 5, 1984. Information regarding plastisol coatings.
19. Telecon. Maxwell, C., MRI, with Raffi, C., Raffi and Swanson, Inc.
July 15, 1983. Information regarding retail customized coatings.
20. Memorandum from Newton, D., MRI, to Grumpier, D., EPAiCPB. July 22,
1983. p. 3. Report on site visit to Aldan Rubber Company,
Philadelphia, Pennsylvania.
21. Memorandum from Maxwell, C., MRI, to Grumpier, D., EPA:CPB. June 24,
1983. p. 2. Report on site visit to Reeves Brothers, Inc., Buena
Vista, Virginia.
22. Memorandum from Thorneloe, S., MRI, to Grumpier, D., EPA:CPB.
March 2, 1984. p. 6. Report of site visit to Utex Industries, Inc.,
Weimer, Texas.
23. Holden, V., Manufacturing Methods Give Coated and Laminated Fabrics
Their Character. Industrial Fabric Products Review. September 1983.
pp. 60-62.
24. Grant, R. Coating: Science, Engineering, or Art? Journal of Coated
Fabrics. 11:80. October 1981.
25. Grant, R. Coating and Laminating Industrial Fabrics. Journal of
Coated Fabrics. 12:196-212. April 1983.
26. Grant, R. Coating and Laminating Applied to New Product Development.
Journal of Coated Fabrics. 10:232-253. January 1981.
27. U. S. Environmental Protection Agency. Control of Volatile Organic
Emissions From Existing Stationary Sources—Volume II: Surface
Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty
Trucks. EPA-450/2-77-008. May 1977.
28. Telecon. Maurer, E., MRI, with Salos, E., Archer Rubber Company.
March 15, 1984. Information on rubber-coating operations.
29. Reference 23, p. 79.
30. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. May 9, 1984. Process parameters for plants
using control devices while applying polymeric coatings to supporting
substrates.
3-24
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31. Reference 20, p. 6.
32. Kardashian, R. Electron Processing for the 1980's. Journal of Coated
Fabrics. 11:131-136. January 1983.
33. Reference 26, pp. 90-93.
34. U. S. Environmental Protection Agency. Flexible Vinyl Coating and
Printing Operations—Background Information for Proposed Standards.
EPA-450/3-81-016a. January 1983. pp. 3-12 - 3-13.
35. Memorandum from Beall, C., MRI, to Project File. June 22, 1984.
Distribution of emissions between coating mix preparation and the
coating line.
36. Telecon. Friedman, E., MRI, with Mueller, J., Day Mixing Company.
June 5, 1984. Information on coating preparation equipment.
37. Memo from Maurer, E., MRI, to Elastomeric Coating of Fabric Project
File. April 12, 1984. Estimated solvent consumption at facilities
performing elastomeric coating of fabrics.
38. U. S. Environmental Protection Agency. Control of Volatile Organic
Emissions From Existing Stationary Sources—Volume I: Control methods
for Surface-Coating Operations. EPA-450/2-76-028. November 1976.
39. Memorandum from Maurer, E., MRI, to Polymeric Coating of Supporting
Substrates Project File. April 19, 1984. Baseline emissions level.
3-25
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4. EMISSION CONTROL TECHNIQUES
4.1 INTRODUCTION
The VOC emissions from polymeric coating of supporting substrates
result primarily from evaporative losses of solvent from solvent storage
tanks, coating mix preparation equipment, the application/flashoff area,
and the drying oven. A small amount of solvent may be retained in the
final product. As stated in Chapter 3, some of the VOC's emitted may be
reaction by-products rather than evaporative losses. However, the control
techniques for these emissions are no different from those used to control
evaporative emissions. There are two approaches to controlling emissions
from polymeric coating operations. One is by the use of an emission
capture system and control device collectively referred to as a control
system. The other is by use of low-solvent coatings.
This chapter describes the technology available for capture and
control of emissions from all of the sources mentioned above and the
expected levels of control achievable. The use of low-solvent coatings is
also discussed.
4.2 VOC EMISSION CAPTURE SYSTEMS
A capture system combines one or more capture devices to collect VOC
emissions and deliver them to a control device. Capture efficiency is
defined as the fraction of all organic vapors generated by a process that
are directed to a control device. For the purposes of this discussion, the
capture of emissions is divided into two major categories: (1) capture
from solvent storage tanks, coating mix preparation equipment, and drying
oven; and (2) capture from the coating application/flashoff area.
The first category is composed of equipment that is inherently
capable of good capture. The second category is more dependent on the
4-1
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design parameters of the capture device or system and even the operation of
the plant production process. Each category will be discussed in detail
below.
4.2.1 Emission Capture Systems for Solvent Storage Tanks, Coating Mix
Preparation Equipment, and Drying Ovens
Emissions from storage tanks can be captured by two methods. One
method is to use a pressure relief valve to prevent vapors from escaping
the tank during filling and diurnal breathing. The other method would be
to vent vapors through ductwork to a control device. While no polymeric
coating plant has been identified that is employing these technologies,
both are common in the organic chemicals and magnetic tape manufacturing
industries.
The VOC emissions from coating mix preparation equipment may be
captured by tightly covering and venting the coating mix preparation
equipment (i.e., mixers and holding tanks) to a control device, usually
with a minimum airflow rate. The solvent laden air discharged from the
coating preparation equipment can be used as part of the oven make-up air,
or it can be vented directly to the control device.
At least eight polymeric coating plants use covered coating mix
preparation equipment. Three plants duct coating mix preparation equipment
emissions to a control device.1'2 At one plant, all coating mix prepara-
tion equipment is covered. When the covers are opened, dampers in the
ductwork also are opened, and the draft created by the control device
blower is sufficient to pull in all emissions. The emissions are vented to
a carbon adsorber.
Local ventilation, partial enclosures, and total enclosures (discussed
in the next section) might also be used to capture emissions from coating
mix preparation equipment, but these methods would appear to be no more
(and probably less) effective than sealed covers. These other devices or
systems would require more air to be evacuated from the mixing area;
consequently, the control equipment that serves them would also have to be
larger and more expensive than if sealed covers were used.
Proper design, operation, and maintenance virtually guarantees a high
capture efficiency of drying ovens. Well-designed and -operated ovens are
maintained at slightly negative pressure to prevent leakage and reduce
4-2
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loss of oven gases containing VOC emissions through substrate inlet and
outlet openings. Large pressure differentials are avoided to prevent
unnecessary dilution of oven exhaust. The solvent laden air in the oven
exhaust is drawn into the oven ductwork and may be recirculated in the oven
before it is directed to a control device. This recirculation allows
faster air velocities and, therefore, better drying conditions and more
efficient use of energy needed to heat the air.
4.2.2 Emission Capture Systems for the Application/Flashoff Area
The coating application/flashoff area requires more complex systems to
capture VOC emissions. The types of capture systems employed at polymeric
coating plants and at plants in other web coating industries include local
ventilation, partial enclosures, and total enclosures.
Current practice in this industry is to vent all or part of the
emissions from the application/flashoff area directly to the atmosphere
rather than to a control device primarily because State and local
regulations may not require the capture and control of VOC emissions from
these sources. In cases where the plant does not have a control device,
ventilation systems are used to maintain a safe working environment. It
would be technically feasible to duct emissions to a control device rather
than to the atmosphere.
4.2.2.1 Local Ventilation Systems. Local ventilation systems are the
capture systems most widely used at polymeric coating plants. They usually
consist of one or more hoods such as floor sweeps, slotted ducts, and even
certain kinds of partial enclosures. Capture efficiencies of these
ventilation systems vary widely with respect to air pollution control.
An efficient local ventilation capture system should maximize the
collection of VOC emissions, minimize the collection of dilution air, and
maintain an adequate ventilation rate in the work place. The factors
important in designing an efficient capture system include:
1. Degree of turbulence;
2. Capture velocity; and
3. Selectivity of collection.
Although these factors are interdependent, each will be discussed
separately.
4-3
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Turbulence in the air around a VOC emission source is a serious
impediment to effective collection. Turbulence dilutes the solvent laden
air stream and contributes to the transport of VOC's away from the capture
device. The increased amount of dilution air increases the size and
resultant cost of control equipment. Sources of turbulence that should be
recognized and minimized include:
1. Thermal air currents;
2. Machinery motion;
3. Material motion;
4. Operator movements;
5. Room air currents; and
6. Spot cooling and heating of equipment.
Turbulence around hoods and exhaust vents should also be minimized.
The coefficient of entry (Ce) is a measure of the degree of turbulence
caused by the shape of the opening. A perfect hood with no turbulence
losses would have a coefficient of entry equal to 1. Table 4-1 gives
coefficients of entry for selected hood openings. Flanged or bell-mouthed
hood openings reduce the pressure drop at the entrance which reduces
turbulence, and, thereby, improves capture.
The velocity necessary to collect contaminated air and draw it into a
capture device is called the capture velocity. At capture velocity, the
inflow of air to the capture device is sufficient to overcome the effects
of turbulence and, thereby, minimize the escape of contaminated air. Local
ventilation systems require higher capture velocities than total or partial
enclosures and result in larger quantities of air being ducted to the
control device. Empirical testing of operating systems has been used to
develop the guidelines for capture velocity presented in Table 4-2.
Selectivity describes the ability of the capture system to collect
pollutants at their highest concentration by minimizing the inflow of clean
air. A highly selective system will achieve a high capture efficiency
using low airflow rates. Low airflow rates and the increased VOC concen-
tration in the air stream result in control systems that are relatively
economical to operate.
4-4
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TABLE 4-1. COEFFICIENTS OF ENTRY FOR SELECTED HOOD OPENINGS3
Hood type
Description
c/
Plain opening
0.72
Flanged opening 0.82
sz.
Bell mount inlet 0.98
4-5
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TABLE 4-2. RANGE OF CAPTURE VELOCITIES3
Capture velocity,
Condition of dispersion of contaminant m/s (fpm)
Released with little velocity into quiet air 0.25-0.51 (50-100)
Released at low velocity into moderately still 0.51-1.02 (100-200)
air
Active generation into zone of rapid air motion 1.02-2.54 (200-500)
Released at high initial velocity into zone of 2.54-10.2 (500-2,000)
very rapid air motion
4-6
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The best method of improving selectivity is to minimize the distance
between the emission source and the capture device. Selectivity also can
be enhanced by the use of flanges or bell-shaped openings on hoods and
exhaust points. These features cause the airflow to be pulled more
directly from the source of emissions. Less dilution air is pulled from
behind and the sides of the hood.
At polymeric coating plants, air intake ducts are located as close to
the emission source as 0.15 meter (m) (0.5 foot [ft]). There are some
plants, however, in which overhead hoods are suspended 0.3 to 1.5 m (1 to
5 ft) above the emission source, and floor sweeps are placed underneath the
source. Some plants rely on air intake created by the drying oven to
provide the local ventilation for the coating application/flashoff area
(and sometimes the entire coating room).
4.2.2.2 Partial Enclosures. A partial enclosure is any rigid or
semirigid structure that partially surrounds or encloses a source. It is
open on at least one side to provide unobstructed access to the coating
application/flashoff area. An example would be a tunnel that is attached
to the oven and extends beyond the application/flashoff area but is open on
that end. Another example is demonstrated at a polymeric coating plant
where a 10-foot-high curtain of silicone-coated fiberglass surrounds the
dip tank. Because the top of the enclosure is bounded by the base of a
vertical drying tower (vertical oven), the flashoff area is within the
enclosure. Canopy hoods are positioned above the dip tank, and solvent
laden air drawn into the hoods is exhausted to the atmosphere. However,
the remaining VOC emissions contained by the enclosure are drawn into the
drying tower and from there to the control device.7 At a plant in a
similar web coating industry, flexible vinyl strips are hung around the
coating application/flashoff area to form a curtain.
The objective for partially enclosing the application/flashoff area
is to eliminate cross-drafts and turbulence that impede the effectiveness
of local hoods and floor sweeps. As with local ventilation systems,
there is a wide range in capture efficiencies of the partial enclosures.
In general, partial enclosures achieve equal or better capture effic-
ciencies at lower airflow rates than local ventilation systems alone.
4-7
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The emissions may be vented through the drying oven and then to the control
device or directly to the control device.6
4.2.2.3 Total Enclosures. The most effective emission capture system
is a total enclosure that surrounds the emission source. The only openings
are those that allow air into the enclosure to prevent a buildup of organic
vapors to hazardous exposure or explosive concentrations. A negative-
pressure differential is maintained with the outside of the enclosure to
ensure that no air can escape through the limited openings.
A ventilation system can be designed so that the room containing the
source(s) of emissions functions as a total enclosure. By closing all
doors and windows, the room may be evacuated either by the draft from the
oven("s) or by hoods and exhaust ducts. The room ventilation exhaust can be
directed to the control device, it can be used as make-up air to the oven
which is served by a control device, or it can be split between the two
routes. One polymeric coating plant is known to use room ventilation to
capture emissions from the application/flashoff area. At this plant, the
coating operation is contained in a room that is kept at negative
pressure. There is an indraft of about 0.25 to 0.51 meters per second
(m/s) (50 to 100 feet per minute [fpm]) at the room openings. The capture
of emissions from the coating application/flashoff area is augmented by the
use of floor sweeps with inlet velocities of 1.52 m/s (300 fpm), which are
located along the coating operation. Ventilation ducts are located
directly under the flashoff area to capture emissions. The captured
emissions are vented to the oven to serve as make-up air and then to a
control device.
A total enclosure also may be designed as a small room surrounding the
emission source or as a "glove box" shaped to conform roughly to the shape
of the equipment. This design may preclude total emission capture at all
times, however, because of turbulence or back drafts caused by the opening
of enclosure doors during operation. If the pressure differential inside
and outside the enclosure is adequate, fugitive losses would be minimal.
The VOC emissions that are contained by the enclosure are ducted to
the oven to serve as make-up air or directly to the control device.
When the captured emissions are used as oven make-up air, the total
4-8
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airflow to the control device is lower than that for systems that duct air
from the application/flashoff area to the control device through
independent ductwork. In some cases, the draft from the oven opening at
the substrate entrance is sufficient to draw the captured emissions into
the oven without the use of additional hoods and ducts.9 Using ventilation
air as oven make-up air increases the VOC concentration in the solvent
laden air that is ducted to the control device; thus, the potential size of
the control device required to treat the solvent laden air may be
smaller. One polymeric coating plant uses a total enclosure designed as a
small room that captures emissions from the coating application/flashoff
9
area.
The efficient operation of a small room or "glove box" total enclosure
depends upon the enclosure doors being closed. The most common substrate,
fabric, is relatively nonhomogeneous (compared to paper or film), and
polymeric coating plant personnel claim that the coating process may
require the constant attention of an operator. Insecure seams and fabric
imperfections may result in tension tears. The lack of uniform substrate
thickness may require continuous tension adjustments. For these reasons,
it may be necessary for workers to have immediate access to the enclosed
area in the event of a web break or other problem. Estimates of the number
of times during a shift that a worker would need access to the coating
application/flashoff area ranged from 8 to 150. A representative of one
plant stated that an operator would have to be stationed at the
application/flashoff area for the duration of each production run.10
A room ventilation type of total enclosure could be used to allow
frequent or continuous worker access, and fresh air could be supplied
directly to operators stationed within the enclosure. Although such a
system was not observed in use at a polymeric coating plant, it would
reduce the airflow rate to the control device in comparison to typical room
ventilation systems that do not have a fresh air supply and would provide
for worker safety. Fresh air supply systems are currently used at plants
in at least two spray coating industries and could be adapted to polymeric
coating plants.
4-9
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Although not specifically demonstrated in this industry, a total
enclosure could be equipped with local hoods and evacuated at a rate that
maintains a safe concentration for the worker without requiring a fresh air
supply system. The amount of air necessary to achieve this condition would
be a function of the proximity of the hood to the source of emissions. A
few potentially effective hood designs and locations have been observed in
this and similar industries. Two general designs are illustrated in
Figure 4-1.
4.3 VOC EMISSION CONTROL SYSTEMS
The emission control devices used by polymeric coating plants are
listed in Table 4-3. The technologies used to control VOC emissions are
carbon adsorption, condensation, and incineration. The theory, design
characteristics, and principles of operation of these control devices are
discussed in the following sections with emphasis on factors affecting
their application in polymeric coating plants. Emissions from the coating
line are commonly controlled using these devices. Three plants control
emissions from the coating mix preparation equipment by ducting them to a
carbon adsorber used to control coating operation emissions.2 It would
also be possible to duct emissions from a solvent storage tank to one of
these control devices, although no tanks at polymeric coating plants are
known to be controlled by this method at the present time.
4.3.1 Carbon Adsorption
Carbon adsorption has been used for the last 50 years by many
industries to recover a wide variety of solvents from solvent laden air
streams. Carbon adsorbers reduce VOC emissions by adsorption of organic
compounds onto the surface of activated carbon. The high surface-to-volume
ratio of activated carbon and its preferential affinity for organics make
it an effective adsorbent of VOC's. The organic compounds are
subsequently desorbed from the activated carbon and recovered. The two
types of carbon adsorbers are fixed-bed and fluidized-bed.
4.3.1.1 Fixed-Bed Carbon Adsorbers. For most of the 50 years that
carbon has been used as a commercial adsorbant, it has been available
4-10
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PLENUM
KNIFE BLADE
(COATING
APPLICATOR)
FAN
VOC EMISSIONS
TO OVEN-*
OR CONTROL
DEVICE
DIP TANK
VOC EMISSIONS
Mgure 4-1. Application/flashoff area hood designs.
4-11
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TABLE 4-3. VOC EMISSION CONTROL DEVICES USED BY
POLYMERIC COATING PLANTS
No. of Percentage
Control device control devices of plants
Carbon adsorber
Fixed-bed 9
Fluidized-bed _1
10 25
Condensation system
Inert atmosphere 2
Air atmosphere _1
3 8
Incinerator
Catalytic 9
Thermal 16
Type not specified _1
26 67
Total 39 100
4-12
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only in a fixed-bed process. The typical depth of the carbon bed is 20 to
25 centimeters (cm) (8 to 10 inches [in.]), and the bed is supported within
a vertical or horizontal cylindrical metal vessel. The solvent laden air
is fed into the bed, and the organics are adsorbed as the air passes
through the bed. Most fixed-bed adsorbers have multiple beds in separate
cylinders to allow simultaneous adsorption and desorption and, thus,
continuous operation. Figure 4-2 is a schematic of a two-unit fixed-bed
adsorber.11* When the VOC concentration in the air discharged from a bed
starts to increase, or at a preset time interval, the inlet solvent laden
air is routed to a different carbon bed, and the nearly saturated bed is
regenerated. Regeneration is usually accomplished using low pressure
steam. The steam heats the bed to desorb the solvents and acts as a
nonflammable carrier gas. Typical steam requirements range from 4 to
9 kilograms (kg) of steam per kg of recovered solvent (4 to 9 pounds [Ib]
of steam per Ib of recovered solvent).12*15 After regeneration, the carbon
bed is dried and cooled to improve the ability of the carbon to adsorb
organic compounds. The mixture of steam and organic vapors exhausts from
the adsorber and is condensed in a heat exchanger; the condensate is routed
to a decanter (see Figure 4-1) or to a holding tank if the condensate is
water-miscible. In the decanter, the solvent floats on the solvent-
insoluble water layer. Both water and organics are drawn off to separate
storage or further treatment. Distillation is necessary in the case of a
water-miscible condensate.
The interdependent parameters considered in the design of a fixed-bed
carbon adsorption system are:
1. Type of solvent(s);
2. Drying oven exhaust outlet temperature;
3. Control device solvent laden air inlet temperature;
4. Solvent laden air inlet concentration;
5. Solvent laden air inlet flow rate;
6. Type and amount of carbon;
7. Superficial bed velocity;
8. Bed pressure drop;
9. Cycle time;
4-13
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SOLVENT-LADEN AIR
UNIT 1 ON
ADSORBING CYCLE
M
-P>
CARBON
-M-
STEAM
CONDENSER
UNIT 2 ON
REGENERATING CYCLE
OPEN
CLOSED
DECANTER
TOP-PHASE LIQUID
BOTTOM-PHASE LIQUID
SOLVENT-FREt AIR
Figure 4-2. Flow diagram of a two-unit, fixed-bed abdsorber.14
-------
10. Degree of regeneration of the carbon bed; and
11. Pressure and temperature of steam.
The first five parameters are characteristics of the production process.
The next three are design parameters for the adsorber. The remaining
parameters are operating variables that may affect the performance of the
adsorber. Table 4-4 presents process parameters representative of
polymeric coating plants controlled by carbon adsorbers.
Major problems encountered in the operation of fixed-bed carbon
adsorbers in polymeric coating plants are: fouling of beds, corrosion, and
excessive heat buildup or bed fires. Carbon beds can be fouled by dust or
other particulate matter, high boiling compounds, high molecular weight
compounds, and compounds that polymerize or oxidize on the carbon
particles.1 Fouled carbon cannot be regenerated at normal steam
temperature and pressure. Fouling reduces adsorption efficiency and
requires early replacement of the carbon. Spent carbon is sent back to the
supplier for reactivation. The customer usually receives a credit for it
against new carbon. Filtration equipment may prevent fouling if there is
dust or other particulate matter in the drying oven exhaust.
Corrosion can be a problem in fixed-bed carbon adsorbers used to
recover solvents that are converted to acidic compounds in the wet steam.
The carbon acts as a catalyst in some of these reactions. This problem can
be overcome by the use of corrosion resistant materials such as stainless
steel, more frequent carbon regeneration to remove the degrading organics,
or by switching to a less corrosive solvent.
Heat buildup is perhaps the most common problem of carbon bed
operation. Adsorption is an exothermic phenomenon; typical heat generation
is 465 to 700 kilojoules (kj) per kg (200 to 300 British thermal units
[Btu] per Ib) of solvent adsorbed. At high solvent concentrations, more
heat of sorption may be generated than can be dissipated by the carrier
gas. In this situation, the overheated carbon bed results in poor
adsorption and possibly bed fires.16 The addition or replacement of carbon
to the bed also increases the tendency for the bed to overheat due to the
increase in adsorptive sites per unit of new carbon.17
Ketones are frequently associated with carbon bed fires. In addition
to a high heat of sorption, ketones react in the presence of low
4-15
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TABLE 4-4. PROCESS PARAMETERS FOR POLYMERIC COATING
PLANTS CONTROLLED BY FIXED-BED CARBO>' ADSORBERS
Parameters Typical range
Solvent laden air
Flow rate 1.4 to 3.3 m3/s (3,000 to 7,000 scfm)
Inlet concentration <2Q% LEL
Inlet temperature 35° ± 6°C (95° ± 10°F)
Oven temperature 93° ± 28°C (200° ± 50°F)
?m /s = cubic meters per second at standard conditions.
scfm = standard cubic feet per minute where standard conditions are
20°C (68°F) and 101.3 kPa (29.92 in. Hg).
4-16
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concentrations of water to form acids and acid anhydrides. This exothermic
reaction is catalyzed by the carbon. These properties of ketones can
lead to excessive heat buildup or bed fires.
Excessive heat buildup can be avoided by cooling the bed between
regeneration and adsorption cycles adequately and by maintaining the
inlet gas temperature at or below 38°C (100°F) and the organic concen-
tration at or below 25 percent of the LEL. A recommended practice for
operations using ketones is to keep the relative humidity at 40 percent
or higher, which creates competition between water and the organic vapor
for adsorptive sites. The energy required to evaporate the water
helps to dissipate the heat of sorption from the organic. Some carbon
beds may contain cooling coils to remove heat continually from the
carrier gas.
Many polymeric coating plants use a single solvent in coatings, and
the recovered solvent requires only decantation. A further treatment
step, distillation, is required when multiple solvents or water-miscible
solvents are used. Typical distillation systems consist of a decanter
and one or more distillation columns. Caustic drying systems are used
for the removal of small amounts of residual water from the solvent.
The complexity and the recovery efficiency of the separation equipment
will vary with the amount of water and number of solvents in the recovered
condensate and the desired purity of the recovered solvent. One plant
that is using multiple solvents sends the recovered solvent to a solvent
1 ft
broker who uses the solvent as a diluent. A plant that uses large
amounts of solvent might find it economical to separate and purify the
solvents in-house.
Volatile organic compound removal efficiencies of 95 to 97 percent
are achievable with modern designs of fixed-bed adsorbers.19' ° There
are nine fixed-bed carbon adsorbers in operation at polymeric coating
plants. Most of these units were built during the last 5 to 7 years.11
One of these units has been tested by the EPA and is described below to
illustrate the emission control efficiency achieved and the applicability
of carbon adsorption to polymeric coating plants.
Plant A installed a carbon adsorber in 1977 to control toluene
emissions from three coating lines. The solvent recovery system at
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Plant A consists of three carbon beds and a decanter for solvent separa-
tion. The design flow rate for the carbon adsorption unit is 4.7 cubic
meters per second (m3/s) (9,900 actual cubic feet per minute [acfm]) with
an inlet concentration of about 2,000 parts per million by volume (ppmv).
The average operating cycle of the carbon adsorber is 3.6 hours. Outlet
solvent concentrations ranged from 6 to 390 ppmv, depending on the degree
of saturation of the carbon bed. When the performance test was conducted,
average VOC removal efficiency was found to be in excess of 97 percent for
5-year-old carbon.19
4.3.1.2 Fluidized-Bed Carbon Adsorbers. In fluidized-bed systems,
adsorption and desorption both are carried out continuously in the same
vessel. Figure 4-3 presents a flow diagram of a fluidized-bed carbon
2 1
adsorber. The system consists of a multistage, countercurrent,
fluidized-bed adsorption section; a pressure-sealing section; and a
desorption section. Nitrogen gas is used as a carrier to remove the
solvent vapors from the desorption section. The pressure-sealing section
prevents air from entering the mixture of solvent and nitrogen vapors. The
regenerated carbon is carried by air from the bottom to the top of the
column via an external duct.
The solvent laden air is introduced into the bottom of the adsorption
section of the column and passes upward countercurrent to the flow of
carbon particles. Adsorption occurs on each tray as the carbon is
fluidized by the solvent laden air. The carbon flows down the column by a
system of overflow weirs. Below the last tray, the carbon falls to the
desorption section where indirect heating desorbs the organic compounds
from the carbon; hot nitrogen gas passes through the bed countercurrent to
the flow of carbon flow and removes organic compounds. The desorption
temperature is normally around 121°C (250°F) but can be raised to 260°C
(500°F) to remove buildup of high-boiling materials. The desorption
section is maintained continuously at the temperature required to
volatilize the adsorbed compounds. The solvent and nitrogen mixture is
directed to a condenser where the solvent can be recovered for reuse. The
nitrogen is sent through the "secondary adsorber" (top layer of carbon in
the desorption section), which removes residual solvent from the nitrogen,
and is then recycled.
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CLEAN AIR
ADSORPTION
SECTION
PRESSURE-SEALING
SECTION
DESORPTION
SECTION
(SHELL-AND-
TUBE HEAT
EXCHANGER)
SOLVENT-LADEN
AIR IN
MIXTURE OF SOLVENT
AND NITROGEN VAPORS
NITROGEN
RECYCLE
BLOWER
AIR LIFT AIR LIFT NOZZLE
BLOWER FOR CARBON RECYCLE
-£- CARBON FLOW
Figure 4-3. Fluidized-bed carbon adsorber.
4-19
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The mlcrospherical particles of carbon used in a fluidized-bed are
formed by spray-drying molten petroleum pitch. The carbon particles are
easily fluidized and have strong attrition resistance.27 The adsorptive
properties of the carbon particles are similar to those of other activated
carbons.
The interdependent parameters considered in design of a fluidized-bed
carbon adsorber are:
1. Type of solvent(s);
2. Drying oven exhaust outlet temperature;
3. Control device solvent laden air inlet temperature;
4. Solvent laden air inlet concentration;
5. Solvent laden airflow rate;
6. Superficial bed velocity;
7. Bed pressure drop;
8. Rate of carbon flow; and
9. Degree of regeneration of the carbon (bed).
The first five parameters are characteristics of the production process.
The next two parameters are characteristics of the design of the adsorber.
The eighth parameter, rate of carbon flow, is set by the operator to
achieve desired control efficiency. The remaining parameter is an
operating variable that may affect the performance of the adsorber.
Just as with the gas entering the fixed-bed, the dryer exhaust gas
(solvent laden air) must be cooled before it reaches the fluidized-bed
adsorber in order to optimize the carbon's absorptivity. The pressure drop
per stage normally ranges from 1 to 2 kilopascals (kPa) (4 to 8 in. water
column [in. w.c.]), with six to eight stages required, depending on the
application. The pressure drop across the entire bed is 6 to 16 kPa (24 to
64 in. w.c.). The gas velocity through the adsorption section may be as
high as 1 m/s (200 fpm), which is two to four times that in fixed-bed
adsorbers.
The primary problem that may occur with the operation of fluidized-bed
adsorbers is fouling of the carbon. The same factors that affect fouling
of carbon in fixed-bed adsorbers also affect the carbon used in fluidized-
bed adsorbers. Corrosion is generally not a problem in fluidized-bed
adsorbers because stripping is accomplished by nitrogen rather than by
4-20
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steam and the water content of the recovered solvent is low (typically
5 percent or less by weight). The only water present In the recovered
solvent 1s that which was absorbed from the solvent laden air. Thus,
generally, the carbon adsorber need not be constructed of expensive
corrosion-resistant materials. Bed fires are also not a problem in
fluid1zed-bed adsorbers because the relatively high superficial velocities
eliminate the possibility of hot spot formation.
One polymeric coating plant is currently using a fluidized-bed carbon
adsorber. This unit is described below to illustrate the application to
polymeric coating plants.
Plant B installed a fluidized-bed carbon adsorber in August 1983 to
replace a fixed-bed carbon adsorber that was subject to frequent carbon bed
fires. The plant uses MEK exclusively. Table 4-5 lists process parameters
for the flu1dized-bed carbon adsorber at Plant B. This unit was tested by
EPA and was found to achieve 99 percent solvent recovery efficiency.
The fluidized-bed carbon adsorber is sized for an inlet airflow of
5.66 m3/s (12,000 acfm). Influent VOC levels to the control device range
from 1,000 to 2,600 ppmv, and effluent levels range from 5 to 60 ppmv
(averaging 15 to 20 ppmv).
The fluidized-bed carbon adsorber has been said to control emissions
of water soluble solvents because steam is not the regenerating fluid.
However, according to an EPA study, the recovered solvent still may contain
enough water (10-12 percent) to require further treatment.21ff25 This has
been the case at Plant B where humidity has proven to be a problem. The
carbon captures a substantial amount of water, which contains about 27
percent MEK after condensation. This water/MEK solution is distilled to
recover the solvent.
4.3.2 Condensation
Condensation is a method of recovering VOC emissions by cooling the
solvent laden air to the dew point of the solvent (or solvent mixture)
and collecting the solvent droplets. The temperature reduction necessary
to condense the solvent vapor depends on the vapor pressure and concen-
2 fi
tratlons of the solvents in the gas stream. Two types of commercially
available condensation systems have been used to recover VOC emissions
4-21
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TABLE 4-5. PROCESS PARAMETERS OF PLANT r, FLUIDIZED-BED
CARBON ADSORBER SYSTEM
Solvent laden air
Inlet temperature, °C (°F) 57 to 66
(135 to 150)
Relative humidity, %, range 30 to 100
average 65 to 75
Inlet concentration, ppmv, design 2,600
actual 1,000 to 2,600
Outlet concentration, ppmv, range 5 to 60
average 15 to 20
Total carbon charge, kg (Ib) 4,040
(8,900)
No. of trays 8
Carbon flow rate, kg/h (Ib/h) 750 to 1,280
(1,650 to 2,815)
Pressure drop per tray 0.5 in. w.c.
Regeneration temperature, °C (°F) 222 to 223
(431 to 434)
N2 flow rate, m3/s (acfm) 0.10 to 0.12
(220 to 260)
4-22
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from drying ovens at polymeric coating plants. These systems differ in the
design and operation of the drying oven (i.e., use of inert gas or air in
the oven) and in the method of cooling the solvent laden air (i.e.,
liquified inert gas or refrigeration).
4.3.2.1 Condensation System Using Inert Gas (Nitrogen) Atmosphere.
Figure 4-4 presents a flow diagram of a condensation system using a
2 7
nitrogen-blanketed drying oven and a nitrogen-cooled heat exchanger. The
inerting curtains shown in Figure 4-4 are streams of solvent-free nitrogen
gas that prevent both airflow into the oven and VOC flow from the oven.
Fume collection hoods also may be located near the ovens and curtains to
capture any gases escaping these areas.
Nitrogen is used in the drying oven to permit operation with high
solvent vapor concentrations without the danger of explosion. The nitrogen
recycled through the oven is monitored and operated to maintain solvent
vapor concentrations of 10 to 30 percent, by volume.27 The use of high
solvent vapor concentrations and minimum gas flow rates allows economical
solvent recovery.
Solvents are recovered by sending a bleed stream of approximately 1
percent of the recycle flow through a shell-and-tube condenser.28 The
liquid nitrogen is on the tube side, and the solvent-laden nitrogen passes
over the outside of the tube surfaces. Vapors condense and drain into a
collection tank. The nitrogen that vaporizes in the heat exchanger is
recycled to the oven and inerting curtains. To avoid solvent condensation
in the oven and to maintain the product cure rate and the recycle and
virgin nitrogen feed rates, the temperature in the oven must be maintained
so that the solvent vapor concentration is above the dew point.
The nitrogen-blanketed system is water-free; hence, the cost of a
distillation system may be avoided, especially if the coating uses a single
solvent.30 Also, corrosion is not a problem. Therefore, special materials
of construction are not required when using a nitrogen condensation system
even when recovering ketones.
The interdependent parameters considered in the operation and design
of an inert condensation system are:
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DRY NITROGEN GAS
WEB
HEAT EXCHANGER
WITH LIQUID N2
COOLANT
LIQUID
N2
SUPPLY
RECYCLED GASES
WEB
VOC EMISSIONS
/
DRYING OVEN WITH INERT ATMOSPHERE
" "voc "EMISSIONS
INERTING CURTAIN
INERTING CURTAIN
Figure 4-4. Schematic of condensation'system using nitrogen.27
-------
1. Type of solvent(s);
2. Temperature of the solvent laden nitrogen bleed stream;
3. Solvent laden nitrogen flow rate; and
4. Concentration of VOC's in nitrogen.
The first two parameters are characteristics of the production process.
The remaining parameters are design characteristics of the condensation
system. Table 4-6 presents typical process parameters for polymeric
coating plants controlled by these systems.
The major problem associated with the use of this system is the need
to purge the unit of the inert atmosphere each time there is a production
change or problem requiring workers to enter the oven. According to one
plant, the normal production operation involves interruptions due to fabric
and product changes, process corrections, and routine mechanical problems
such as damaged rolls and contamination of coating. System purges reduce
the VOC recovery efficiency.
An additional operating problem anticipated with this condensation
system design is the possibility of air leaking into the oven, which would
create explosive conditions. However, these ovens have well-designed
safety systems.
A possible limitation to use of this system is the difficulty in
operating a total enclosure around the coating application/flashoff area.
A purge of the inert atmosphere would be required every time workers need
access to the enclosure. Each time the system is purged, VOC recovery
efficiency decreases, and nitrogen requirements increase.
The only practical way to determine the overall efficiency of this
system is by measuring the solvent used at the coater and the solvent
recovered. Because there are no exhaust stacks, the nitrogen and any
uncondensed organic vapor are recirculated. Fugitive emissions might occur
at the ends of the oven if there is an inadvertent pressure increase in the
oven that overcomes the action of the inert gas curtains.32
Presently, two polymeric coating plants use this type of condensation
system to recover solvents. Plant C installed a condensation system in
1982 to recover VOC emissions from the oven for a single solvent. The
solvent laden air is fed through a closed-loop system at a rate of 0.2 m3/s
(450 acfm) and a temperature of 107°C (225°F). The company estimates
4-25
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TABLE 4-6. RANGE OF PROCESS PARAMETERS FOR POLYMERIC COATING
PLANTS USING INERT AIR CONDENSATION SYSTEMS
Parameter
Range
Gas flow rate, m /s (scfm)
Oven temperature, °C (°F)
Inlet temperature, °C (°F)
Inlet concentration, %
0.21 to 8.50 (450 to 18,000)
per coating line
66 to 121 (150 to 250)
66 to 107 (150 to 225)
10 to 30 by volume
4-26
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that 99 percent of the solvent that enters the condenser is recovered and
returned to solvent storage.
The other plant is using a unit developed by equipment suppliers and
plant personnel that is atypical of condensation systems using a nitrogen
atmosphere and is not representative of control technology applicable to
the polymeric coating industry. This plant is able to augment the cooling
function of the nitrogen with well water, which significantly reduces
operating costs. Most plants do not have this advantage. Plant personnel
estimate that the unit operates at 75 to 95 percent efficiency. Purging
losses cause the variation in efficiency.
4.3.2.2 Condensation System Using An Air Atmosphere. One company
markets a condensation system in which solvent laden air is drawn from a
tightly sealed drying oven through a counterflow heat exchanger.35 In the
heat exchanger, the solvent laden air is cooled to reduce the moisture
content and heat load on the refrigerated condenser. The solvent and water
formed by the refrigerated condenser are stored for further processing.
The cooled solvent-free air is then blown through the heat exchanger for
preheating before being returned to the oven. Drying ovens used with this
system must have a minimum of air leakage and be equipped with solvent
vapor concentration monitoring devices. Typically, these ovens are
designed to operate at 40 to 50 percent of the LEL or at solvent
concentrations of less than 0.5 percent, by volume.36
Recycling the solvent laden air through the ovens keeps the relative
humidity in the oven exhaust quite low; consequently, the condensate
contains small amounts of water. Solvent purification can be accomplished
by caustic drying or by distillation, depending on the solvent purity
specifications and whether a mixture of solvents is used.11
The interrelated factors important in the design and operation of a
condensation system using a counterflow heat exchanger are:
1. Type of sol vent(s);
2. Solvent laden airflow rate;
3. Temperature of the solvent laden air at the heat exchanger inlet;
4. Solvent laden air concentration in the oven exhaust;
4-27
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5. Temperature of the refrigerated air entering the heat exchanger
and the efficiency of the heat exchanger; and
6. Operating temperature of the refrigeration coil.
The first four parameters are characteristics of th2 coating process. The
remaining parameters are operating variables that may affect the
performance of the condenser.
Solvent laden air streams that have high water vapor concentrations
tend to cause the refrigeration coils of the condensation system to
freeze. To prevent the freezing, the refrigeration coils must be monitored
periodically to ensure satisfactory operation. Corrosion problems are not
expected for this system if the water content of the recovered solvent is
less than 5 percent. Consequently, even recovery of ketones or solvent
mixtures containing ketones does not require the use of stainless steel or
other special construction materials if the device is properly operated.
One polymeric coating plant has recently installed an air atmosphere
condensation system. However, this system has not been in operation long
enough to determine actual performance under normal operating
conditions. The company manufacturing the system claims that the solvent
recovery efficiency should exceed 90 percent.
4.3.3 Incineration
Incineration is the oxidation of organic compounds by the exposure of
the VOC's to high temperatures in the presence of oxygen and sometimes a
catalyst. Carbon dioxide and water are the oxidation products.
Incinerators are used to control VOC emissions from several polymeric
coating plants (see Table 4-3). These control devices have been selected
in similar industries when solvent recovery is not economically feasible or
practical such as at small plants or at plants using a variety of solvent
mixtures. Incinerators used to control VOC emissions from polymeric
coating plants may be of thermal or catalytic design and may use primary or
secondary heat recovery to reduce energy consumption. Table 4-7 presents
typical process parameters for polymeric coating plants using
11
incinerators.
4.3.3.1 Thermal Incinerators. Thermal incinerators are usually
refractory-lined oxidation chambers with a burner located at one end.
4-28
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TABLE 4-7. TYPICAL PROCESS PARAMETERS FOR POLYMERIC COATING
PLANTS USING INCINERATORS
Parameter
Typical values
Gas flow rate, m /s (scfm)
Oven temperature, °C (°F)
Inlet temperature, °C (°F)
Inlet concentration, %
2.36 to 4.72 (5,000 to 10,000)
121 ± 28 (250 ± 50)
93 ± 28 (200 ± 50)
18 LEL
4-29
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In these units, part of the solvent laden air is passed through the
burner along with an auxiliary fuel. The gases exiting the burner that
are blended with the by-passed solvent laden air raise the temperature
of the mixture to the point when oxidation of the organics takes place.
With most solvents, complete oxidation is obtained in less than
0.75 seconds at temperatures of 870°C (1600°F).38'39
The interrelated factors important in incinerator design and
operation include:
1. Type and concentration of VOC's;
2. Solvent laden airflow rate;
3. Solvent laden air temperature at incinerator inlet;
4. Burner type;
5. Efficiency of flame contact (mixing);
6. Residence time;
7. Auxiliary fuel firing rate;
8. Amount of excess air;
9. Firebox temperature; and
10. Preheat temperature.
The first three parameters are characteristics of the production process.
The next three parameters are characteristics of the design of the
incinerator. The auxiliary fuel firing rate is determined by the type
and concentration of VOC's, the solvent laden airflow rate, firebox
temperature, and the preheat temperature. The last four parameters are
operating variables that may affect the performance of the incinerator.
Well-designed and well-operated incinerators in similar industries have
•a o -a q
achieved VOC destruction efficiencies of 98 percent or better. '
Presently, there are 16 polymeric coating plants using thermal
incinerators. Plant D uses a thermal incinerator to control VOC emissions
from the oven of a single fabric coating line using primarily acetone in
the coating. The solvent laden air from the oven has a flow rate of
1.9 m3/min (4,000 scfm) and a temperature of 135°C (275°F).
The plant uses two heat exchangers along with the incinerator to
recover some of the heat generated in the incinerator. In the first
heat exchanger, the exhaust from the incinerator is used to raise the
temperature of the oven exhaust from 135°C (275°F) to 317°C (603°F)
4-30 .
-------
before it enters the incinerator. In the second heat exchanger, the
exhaust from the first heat exchanger is used to heat fresh air, which is
used as oven makeup air. The exhaust from the second heat exchanger is
then vented to the atmosphere through a stack. Plant personnel indicate
4 0
that the efficiency of the incinerator is about 97 percent.
4.3.3.2 Catalytic Incinerators. Catalytic incinerators use a
catalyst to promote the combustion of VOC's. The solvent laden air is
preheated by a burner or heat exchanger and then brought into contact with
the catalyst bed where oxidation occurs. Common catalysts used are
platinum or other noble metals on supporting alumina pellets or ceramic
honeycomb. Catalytic incinerators can achieve destruction efficiencies
similar to those of thermal incinerators while operating at lower tempera-
tures, i.e., 315° to 430°C (600° to 800°F). Thus, catalytic incinerators
can operate with significantly lower energy costs than can thermal
incinerators that do not practice significant heat recovery.1* Construc-
tion material may also be less expensive because of the lower operating
temperatures.
Factors important in the design and operation of catalytic
incinerators include the factors affecting thermal incinerators as well as
the operating temperature range of the catalyst. The operating temperature
range for the catalyst sets the upper VOC concentration that can be
incinerated. For most catalysts on alumina, catalyst activity is severely
reduced by exposure to temperatures greater than 700°C (ISOOT).1*2
Consequently, the heating value of the inlet stream must be limited.
Typically, inlet VOC concentrations must be less than 25 percent of the
LEL.
A catalytic incinerator used at a polymeric coating plant is described
below to illustrate the applicability of this control system.
At Plant E, the VOC emissions from each of two ovens are controlled by
one of two catalytic incinerators.1* A similar company-designed
incinerator controls emissions from a smaller oven. The gas stream is
preheated before it crosses the catalyst, and the catalytic reaction raises
the temperature of the gas to 310°C (610°F). After moving through a heat
exchanger, the gas stream is divided. A portion of the gas stream,
retaining 50 percent of the heat, is vented to the atmosphere. The
4-31
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remaining heat laden air either is returned to the incinerator or cooled to
oven temperatures by mixing with fresh air and returned to the oven.
In 1976, one of the larger catalytic units was tested with a flame
ionization detector total carbon analyzer. The test revealed that a
95.7 percent reduction in hydrocarbons was being achieved in the
incinerator. The company estimates that it is currently capturing and
controlling 90 percent of the VOC emissions from the oven. The catalyst
ii 3
is thermally cleaned every 2 months and replaced every 3 years.
4.3.3.3 Heat Recovery. Heat recovery offers a means of reducing
the energy consumption of the incinerator or another process in the
plant. Primary heat recovery refers to the transfer of heat from the
hot incinerator effluent to a relatively cool inlet VOC stream. Secondary
heat recovery refers to exchange of heat from the incinerator to any
other process.
Overall heat recoveries of 70 to 80 percent can be achieved by
plants installing new lines in similar industries using primary and
secondary heat recovery. Actual overall energy savings obtained will
vary with the VOC concentration in the oven exhaust, the incinerator
operating temperature, and the capability of the plant to utilize secondary
heat recovery.
4.4 VOC EMISSION CONTROL SYSTEMS FOR COATING MIX PREPARATION EQUIPMENT
AND SOLVENT STORAGE TANKS
4.4.1 Conservation Vents and Pressure Relief Valves
Conservation vents have been used to minimize tank losses from
plants (including polymeric coating plants) 1n a variety of industries.
The conservation vents are permanently attached to the outside of sealed,
vapor-tight vessels; these vents open when either positive or negative
pressure within a vessel exceeds predetermined values. The pressure or
vacuum settings are achieved by weights inside the vent. Conservation
vents reduce VOC emissions that would occur because of cyclic changes in
the temperature of the liquid inside a vessel. These losses are called
breathing losses.
Figure 4-5 presents a diagram of a conservation vent. The vessel
pressure is applied to the underside of the pressure pallet and the top
4-32
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CO
CO
GUIDE POLE,
PRESSURE
PALLET ASSEMBLY,
PRESSURE
SEAT RING
STEM GUIDE
?X. 400D
GUIDE POLE, PRESSURE
PALLET WEIGHT
VACUUM COVER
FLANGE
PALLET ASSEMBLY, VACUUM
SEAT RING
GUIDE POLE, VACUUM
SCREEN
Figure 4-5. Diagram of conservation vent.45
-------
side of the vacuum pallet. As long as the vessel pressure remains within
the valve pressure and vacuum settings, the pallet remains in contact with
the seat rings, and no venting or breathing takes place. The pressure
pallet lifts from its seat ring when the vessel pressure reaches the valve
pressure setting and allows the excess pressure to vent to the
atmosphere. As the vessel pressure drops below the valve setting, the
pressure pallet returns to the closed position. For a negative pressure
(vacuum), the vacuum pallet lifts from its seat ring when the vessel vacuum
reaches the valve vacuum setting, allowing air to flow into the vessel to
relieve'the excess vacuum condition. The vacuum pallet returns to its
normal position as the vessel vacuum drops below the valve vacuum
setting. Conservation vents will not prevent the tank from venting when
it is filled (working losses) because the internal pressure will exceed the
set pressure on the valve.
The amount of VOC emission reduction achieved by conservation vents
depends on the solvent vapor pressure, the diurnal temperature change, the
tank size, and the vent pressure and vacuum settings. Breathing and
working losses from solvent storage tanks can be estimated using emission
equations.**7 Assuming yearly average diurnal temperature changes of 11°C
(20°F), the true vapor pressure of toluene (the most common solvent used in
the industry) (5.3 kPa [0.77 psia]), and a turnover rate of 5 volumes per
year, these equations yield estimates for breathing losses of 55 to
70 percent of the total annual emissions from solvent storage tanks.
According to one equipment vendor, as much as 50 percent of the total VOC
emissions from the tank can be reduced with the use of properly installed
and maintained conservation venting equipment to control breathing
losses.1*8 Conservation vents set at 0.215 kPa (0.5 ounce) vacuum and
17.2 kPa (2.5 psig) pressure control all of the breathing losses and a
small amount of the working losses for toluene for an average overall
efficiency of 70 percent/9
A pressure relief valve operates in a manner similar to that of a
conservation vent. These valves operate at higher pressures achieved by
internal springs, not weights, and usually do not have any vacuum settings.
The pressure relief valves control all of the breathing losses and much
of the working losses. Based on the vapor pressure of toluene and a
4-34
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pressure setting of 103 kPa (15 psig), a control efficiency of 90 percent
k 9
was calculated for pressure relief valves.
4.4.2 Internal Floating Roof Solvent Storage Tanks
Emissions from solvent storage tanks have been reduced in other
industries by the use of internal floating roof tanks. An internal
floating roof tank has a permanently affixed external roof and an internal
roof that rises and falls with the liquid level.50 Tanks of this design
reduce the area of exposed liquid surface in the tank which, in turn,
decreases evaporative losses.51 However, this control technique is
inappropriate for the small (<75 m3 [20,000 gal]) solvent storage tanks
in use at polymeric coating plants. Therefore, internal floating roof
tanks are not considered a control option for tanks at polymeric coating
plants.
4.4.3 Disposable-Canister Unit Carbon Adsorption
This system can theoretically be used to control emissions from
individual solvent storage tanks and coating preparation equipment that
have low flow rates and solvent concentrations. This system is designed
for air streams having flows generally less than 0.05 m3/s (100 acfm)
and low organic loading. No polymeric coating plant is known to use
this system; however, it has been used to control solvent storage tank
and reactor vessel emissions at plants in other industries.52
In this carbon adsorption system, a prefabricated canister containing
activated carbon is connected to the emission source vent. The principle
of operation is the same as that of a fixed-bed carbon adsorber except
that there is no regeneration of spent carbon. Rather, the canister and
contents are removed for disposal, and a new canister is installed. The
actual useful life depends on size of the canister and the type and
amount of vapors to which the carbon is exposed.
Bed overheating can be a problem if these systems are used to
recover ketones. The large surface area of the activated carbon allows
ketone molecules to react exothermically, possibly leading to bed fires.
This problem can be circumvented by keeping the carbon damp.53
4-35
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4.5 LOW-SOLVENT COATINGS
The use of low-solvent coatings is an effective technique to reduce
VOC emissions. Some combination of waterborne, higher solids, plastisol,
and calendered or extruded coatings are used as the sole means of reducing
VOC emissions at over 30 percent of the plants that apply polymeric
coatings to supporting substrates. A combination of low-solvent coatings
and control of the drying oven is used by at least 10 percent of the plants
applying polymeric coatings to supporting substrates. The primary factor
that influences the use of low-solvent coatings as an emission control
technique is that many polymeric-coated products cannot be produced
satisfactorily with low-solvent coatings at this time. Therefore, it is
anticipated that solvent borne coatings will continue to be necessary in
some coating applications.
Waterborne coatings allow the mixing of certain materials that would
be incompatible in solvent borne .coatings. Although waterborne coatings
dry more slowly than solvent borne coatings, the longer drying time
required is partially offset by the high solids content of waterborne
en eg
coatings, which is typically 55 to 60 percent by volume. ~ A disad-
vantage of existing waterborne coatings is that, for some products, these
coatings may not be able to achieve the desired final product
characteristics.
The advantages of higher solids coatings compared to solvent borne
coatings include reduced solvent usage, reduced energy costs for the heat
to dry the coating, and faster line speeds. Some manufacturers use
ultraviolet or electron beam curing with higher solids coatings, which
reduces energy costs and allows for a more physically compact coating
operation. A disadvantage of higher solids coatings is short pot life;
they must be applied shortly after preparation.57
Coatings applied by calenders and extruders or in plastisol form
have virtually no VOC emissions. The only emissions are due to a small
percentage of plasticizers that evolve as process heat is applied to the
plastisol/plasticizer. An advantage of calenders and extruders is
faster line speeds, but these processes are limited to application of
4-36
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fairly thick coatings. The use of plastisols is currently limited to PVC
and some urethanes.
4.6 REFERENCES FOR CHAPTER 4
1. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 24, 1984. Summary of confidential
and nonconfidential information on the use of covered coating
preparation equipment and the use of room ventilation for the capture
of VOC emissions.
2. Memorandum from Mclaughlin, N., EPAiEMB, to McCarley, J. E. Jr.,
EPA:EMB. May 10, 1984. Status report and recommended testing options
for Elastomeric Coating NSPS (83/13).
3. Industrial Ventilation. A Manual of Recommended Practice (14th
Edition). American Conference of Governmental Industrial
Hygienists. Committee on Industrial Ventilation. Lansing,
Michigan, pp. 4-4 - 4-5.
4. Reference 3, p. 4-1.
5. Reference 3, p. 4-12.
6. Memorandum and attachments from Glanville, J., MRI, to Magnetic Tape
Project File. April 5, 1984. Summary of emission capture systems
used at magnetic tape coating facilities (located in ESED confidential
files).
7. Memorandum from Thorneloe, S., MRI, to Grumpier, D., EPArCPB.
July 6, 1984. Report of site visit to ODC, Incorporated, Norcross,
Georgia.
8. Memorandum from Newton, D., MRI, to Crumpler, D., EPArCPB. July 25,
1983. Report of site visit to Burlington Industrial Fabric,
Kernersville, North Carolina.
9. Memorandum from Thorneloe, S., MRI, to Crumpler, D., EPArCPB.
March 2, 1984. Report of site visit to Utex Industries, Inc., Weimar,
Texas.
10. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 22, 1984. Summary of confidential
and nonconfidential information on the need of a worker to access the
coating application/flashoff area and drying oven.
11. Memorandum from Thorneloe, S., MRI, to Elastomeric Coating of Fabrics
Project File. May 9, 1984. Typical process parameters of polymeric
coating plants using VOC control devices.
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12. Meyer, W. Solvent Broke. Vulcan-Cincinnati, Inc. Cincinnati,
Ohio. (Presented at TAPPI Test/PAP Synth. Conf. Boston. October 7-9,
1974.) pp. 109-115.
13. Daniel son, John A. Air Pollution Engineering Manual. Prepared for
U. S. Environmental Protection Agency, Research Triangle Park, North
Carolina. Publication No. AP-40. May 1973. pp. 189-202.
14. Stunkard, C. B. Solvent Recovery From Low Concentration Emissions.
Calgon Carbon Corporation. Undated.
15. Radian Corporation. Full-Scale Adsorption Applications Study: Draft
Plant Test Report—Plant 3. Prepared for U. S. Environmental
Protection Agency. Cincinnati, Ohio. EPA Contract No. 68-03-3038.
August 19, 1982. p. 29.
16. U. S. Environmental Protection Agency. Control of Volatile Organic
Emissions From Existing Stationary Sources—Volume I: Control Methods
for Surface-Coating Operations. EPA-450/2-76-028. Research Triangle
Park, North Carolina. November 1976. pp. 33-34.
17. Memorandum from Newton, D., MRI, to Crumpler, D., EPArCPB. July 22,
1983. Report of site visit to Aldan Rubber Company, Philadelphia,
Pennsylvania.
18. Telecon. Banker, L., MRI, with Hindie, M., Kenyon Piece Dyeworks,
Inc. December 19, 1984. Information on treatment of recovered
solvent blend.
19. Memorandum from Thorneloe, S., MRI, to Crumpler, D., EPA:CPB.
March 28, 1984. Report of site visit to Dayco Corp., Three Rivers,
Michigan.
20. Crane, G. B. Carbon Adsorption for VOC Control. U. S. Environmental
Protection Agency. Chemicals and Petroleum Branch, Research Triangle
Park, North Carolina, p. 1. January 1982.
21. Golba, N., and J. Mason. Solvent Recovery Using Fluidized-Bed Carbon
Adsorption. Union Carbide Corporation, Tonawanda, New York.
(Presented at the Water-Borne and Higher Solids Coating Symposium. New
Orleans. February 17-19, 1982.) 18 p.
22. Basdekis, H. (IT Enviroscience). Emission Control Options for the
Synthetic Organic Chemicals Manufacturing Industry. Control Device
Evaluation, Carbon Adsorption. Prepared for U. S. Environmental
Protection Agency. Research Triangle Park, North Carolina.
February 1980. pp. 11-25 - 11-26.
23. Radian Corp. Polymeric Coating of Supporting Substrates: Emission
Test Report for Utex Industries, Inc. Revised draft. Prepared for
U. S. Environmental Protection Agency. Research Triangle Park, North
Carolina. November 21, 1984. p. 5-24.
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24. Telecon. Thome loe, S., MR I, with Pfeiffer, R., Union Carbide Corp.
August 22, 1983. Information on cost of fluidized-bed carbon
adsorbers.
25. Parmele, C., H. Basdekis, and M. Clark. Evaluation of the Union
Carbide PURASIV HR® Vapor Recovery System. U. S. Environmental
Protection Agency. Cincinnati, Ohio. July 1983. p. 2.
26. Reference 16, p. 56.
27. Rothchild, R. Curing Coatings With an Inert Gas Solvent System.
Journal of Coatings Technology. 53(675):53-56. April 1981.
28. Nikityn, J. Inert Atmosphere Solvent Recovery—Reprinted from the
Journal of Industrial Fabrics. Volume I, Number 4. Spring 1983.
29. Erikson, D. (IT Enviroscience). Emission Control Options for the
Synthetic Organic Chemicals Manufacturing Industry—Control Device
Evaluation, Condensation. Prepared for U. S. Environmental
Protection Agency. Research Triangle Park, North Carolina.
July 1980. p. II-l.
30. Telecon. Thorneloe, S., MRI, with Rieman, D., Airco Industrial
Gases. May 18, 1983. Information on Airco condensation system for
solvent recovery.
31. Letter from Hindie, M., The Kenyon Piece Dyeworks, Inc., to Crumpler,
D., EPAiCPB. March 23, 1984. Recovery efficiency data for
condensation system.
32. Telecon. Beall, C., MRI, with Rieman, D., Airco Industrial Gases.
February 15, 1984. Information on Airco condensation system.
33. Letter and attachments from Koch, D., Kellwood Company, to Farmer, J.,
EPArESED. February 21, 1984. Response to Section 114 letter on the
elastomeric coating of fabrics.
34. Memorandum from Maxwell, C., MRI, to Grumpier, D., EPArCPB. July 21,
1983. Report of site visit to the Kenyon Piece Dyeworks, Inc.,
Kenyon, Rhode Island.
35. United Air Specialists, Inc. Kon-den-Solver® for Solvent Vapor
Recovery. Undated.
36. Telecon. Thorneloe, S., MRI, with Memering, L., United Air
Specialists. May 4, 1983. Information on the Kon-den-Solver® system
for VOC recovery.
37. Telecon. Meyer, J., MRI, with Harper, S., Verbatim Corp. March 3,
1983. Information on VOC control system at Verbatim, Sunnyvale,
California, plant.
4-39
-------
38. Memorandum from Mascone, D., EPAtCPB, to Farmer, J., EPArESED.
July 22, 1980. Thermal incinerator performance for NSPS, Addendum.
39. Memorandum from Mascone, D., EPA:CPB, to Farmer, J., EPA:ESED.
June 11, 1980. Thermal incinerator performance for NSPS.
40. Memorandum from Powers, S., MRI, to Grumpier, D., EPA:CPB. May 10,
1985. Report of site visit to the Narmco Materials facility in
Anaheim, California.
41. Reference 16, p. 51.
42. Reference 16, p. 54.
43. Memorandum from Maurer, E., MRI, to Grumpier, D., EPArCPB.
February 24, 1984. Report of site visit to the Gates Rubber Company,
Denver, Colorado.
44. U. S. Environmental Protection Agency. Pressure-Sensitive Tape and
Label Surface Coating Industry—Background Information for Proposed
Standards. EPA-450/3-80-003a. Research Triangle Park, North
Carolina. September 1980. p. 4-18.
45. Varec Division, Emerson Electric Company. Gas Control Equipment
Catalog S-5. Undated.
46. Telecon. Glanville, J., MRI, with Harper, S., Verbatim Corp.
February 2, 1984. Information on storage tank ventilation.
47. U. S. Environmental Protection Agency. VOC Emissions From Volatile
Organic Liquid Storage Tanks—Background Information for Proposed
Standards. EPA 450/3-81-003a. Research Triangle Park, North
Carolina. July 1984. pp. 3-26 - 3-27.
48. Varec Division, Emerson Electric Company. Pollution and Gas Control
Equipment. Bulletin CP-6003-B. Undated.
49. Memo from Glanville, J., MRI, to Polymeric Coating of Supporting
Substrates Project File. December 31, 1985. Calculation of
conservation vent and pressure relief valve control efficiency.
50. Reference 47, p. 3-6.
51. Reference 47, p. 4-9.
52. Letter and attachments from Wetzel, J., Calgon Carbon Corp., to Beall,
C., MRI. February 13, 1984. Information on Calgon1s VentSorb® unit.
53. Telecon. Beall, C., MRI, with Byron, B., Tigg Corp. February 8,
1984. Information on disposable-canister carbon adsorption system.
4-40
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54. Telecon. Friedman, E., MRI, with Silver, R., Aurora Bleachery, Inc.
June 6, 1984. Information on waterborne coatings.
55. Telecon. Friedman, E., MRI, with Cough!in, T., Nylco Corp. June 6,
1984. Information on waterborne coatings.
56. Telecon. Friedman, E., MRI, with Lania, R., Chase and Sons. June 6,
1984. Information on waterborne coatings.
57. Telecon. Maurer, E., MRI, with Swain, R., Lembo Corp. March 7,
1984. Information on coating equipment.
4-41
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5. MODIFICATION AND RECONSTRUCTION
Standards of performance apply to plants for which construction,
modification, or reconstruction commenced (as defined under 40 CFR 60.2)
after the date of proposal of the standards. Such plants are termed
"affected facilities." Standards of performance are not applicable to
"existing facilities" (i.e., facilities for which construction, modifi-
cation, or reconstruction commenced on or before the date of proposal of
the standards). An existing facility may become an affected facility and,
therefore, be subject to the standards of performance if the facility
undergoes modification or reconstruction. The enforcement division of the
appropriate EPA regional office will make the final determination as to
whether an existing facility is modified or reconstructed and, as a result,
subject to the standards of performance as an affected facility.
Modification and reconstruction are defined under 40 CFR 60.14 and
60.15, respectively. These General Provisions are summarized in Section
5.1. Section 5.2 discusses the applicability of these provisions to
facilities performing polymeric coating of supporting substrates.
5.1 PROVISIONS FOR MODIFICATION AND RECONSTRUCTION
5.1.1 Modification
With certain exceptions, any physical or operational change to an
existing facility that would increase the emission rate to the atmosphere
from that facility of any pollutant covered by the standard would be
considered a modification within the meaning of Section 111 of the Clean
Air Act. The key to determining if a change is considered a modification
is whether actual emissions to the atmosphere from the facility have
increased on a mass per time basis (kg/h [lb/h]) as a result of the
change. Changes in emission rate may be determined by the use of emission
5-1
-------
factors, by material balances, by continuous monitoring data, or by manual
emission tests in cases where the use of emission factors does not clearly
demonstrate that emissions do or do not increase. Under the current
regulations, an emission increase from one facility may not be offset with
a similar emission decrease at another facility to avoid becoming subject
to new source performance standards (NSPS). If an existing facility is
determined to be modified, it becomes an affected facility, subject to the
standards of performance for the pollutant or pollutants that have
increased due to modification. All emissions, not just the incremental
increase -in emissions, of the pollutants that have increased from the
facility must be in compliance with the applicable standards. A
modification to one existing facility at a plant will not cause other
existing facilities at the same plant to become subject to the standards.
Under the regulations, certain physical or operational changes are not
considered to be modifications even though emissions may increase as a
result of the change (see 40 CFR 60.14(e)). The exceptions as allowed
under 40 CFR 60.14(e) are as follows:
1. Routine maintenance, repair, and replacement (e.g., lubrication of
mechanical equipment; replacement of pumps, motors, and piping; cleaning
of equipment);
2. An increase in the production rate without a capital expenditure
(as defined in 40 CFR 60.2);
3. An increase in the hours of operation;
4. Use of an alternative fuel or raw material if, prior to proposal
of the standard, the existing facility was designed to accommodate that
alternate fuel or raw material;
5. The addition or use of any system or device whose primary function
is to reduce air pollutants, except when an emission control system is
replaced by a system determined by EPA to be less environmentally
beneficial; and
6. Relocation or change in ownership of the existing facility.
An owner or operator of an existing facility who is planning a
physical or operational change that may increase the emission rate of a
5-2
-------
pollutant to which a standard applies shall notify the appropriate EPA
regional office 60 days prior to the change, as specified in
40 CFR 60.7(a)(4).
5.1.2 Reconstruction
An existing facility may become subject to NSPS if it is recon-
structed. Reconstruction is defined as the replacement of the components
of an existing facility to the extent that (1) the fixed capital cost of
the new components exceeds 50 percent of the fixed capital cost required to
construct a comparable new facility and (2) it is technically and
economically feasible for the facility to meet the applicable standards.
Because EPA considers reconstructed facilities to constitute new
construction rather than modification, reconstruction determinations are
made irrespective of changes in emission rates.
The purpose of the reconstruction provisions is to discourage the
perpetuation of an existing facility for the sole purpose of circumventing
a standard that is applicable to new facilities. Without such a provision,
all but vestigial components (such as frames, housing, and support
structures) of the existing facility could be replaced without causing the
facility to be considered a "new" facility subject to NSPS. If the
facility is determined to be reconstructed, it must comply with all of the
provisions of the standards of performance applicable to that facility. If
an owner or operator of an existing facility is planning to replace
components and the fixed capital cost of the new components exceeds
50 percent of the fixed capital cost of a comparable new facility, the
owner or operator must notify the appropriate EPA regional office 60 days
before the construction of the replacement commences, as required under
40 CFR 60.15(d).
5.2 APPLICABILITY TO POLYMERIC COATING OF SUPPORTING SUBSTRATES
5.2.1 Examples of Modification
5.2.1.1 Solvent Storage Tanks. Few, if any, changes in the physical
configuration of storage tanks that would increase emissions are
anticipated. Because replacement of frames, housings, and supporting
structures would not increase emissions from a storage tank, such replace-
ment would not constitute a modification. An increase in the capacity of
5-3
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a storage tank, while an unlikely occurrence, could cause emissions to
increase and, therefore, could constitute a modification.
5.2.1.2 Coating Mix Preparation Equipment. No changes in the
physical configuration of coating mix preparation equipment that would
increase emissions are expected. Industry practice is to replace
individual items of equipment if a major process change requires different
processing equipment. Except for replacement to accommodate process
changes, mixers, mills, and tanks are used indefinitely and repaired as
. , 1-3
needed.
Operational changes that might increase VOC emissions would be a
change in the length of time required to prepare coating or a change in raw
materials. A change in processing time would not constitute a modi-
fication, however, because it would be an increase in hours of operation,
which is exempted under 40 CFR 60.14(e) from modification determinations.
Also under 40 CFR 60.14(e), existing facilities that change to an alternate
raw material are exempted from modification determinations if the facility
was designed to accommodate the raw material prior to proposal of this
standard. The same coating mix preparation equipment is used to prepare
the known range of coatings used in this industry. ~ Thus, modifications
of coating mix preparation equipment are not expected.
5.2.1.3 Coating Operation. Potential modifications of polymeric
coating operations and processes include changes to increase production and
changes in the method of applying the polymeric coating to the substrate.
Changes in the application method may affect the VOC emission rate of the
coating operation. Production increases can also increase the VOC emission
rate from a coating line.
The productivity of a polymeric coating operation is determined by the
substrate width, the line speed, the hours of operation, and the efficiency
of scheduling. Most of the equipment modifications that might be made to
increase productivity involve totally new sources or investments so large
as to qualify as reconstruction. Specific examples of production equipment
changes are discussed below, with emphasis on the few cases where the
modification providions might apply. However, in general, no changes are
expected that would cause the operation to be subject to the modification
provisions.
>
5-4
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5.2.1.3.1 Changes in substrate width. Changes in the width of the
substrate would increase both production and emissions. The maximum
substrate width that any given coating operation can accommodate is an
integral part of the basic design of the system. Substrate width cannot be
increased significantly beyond this maximum without installing essentially
all new equipment. It is, therefore, unlikely that such a modification
would be made.
5.2.1.3.2 Changes in line speed. An increase in maximum operating
speed is the most likely change that could constitute a modification. The
maximum operating speed for a given facility depends on both the basic
design of the coating operation and on the specifications for each
product. The factors that might constitute an operating speed limitation
include:
1. A limitation on the available power and/or speed of the motors
that drive the substrate;
2. Drying limitations based either on the amount of heat available or
on residence time in the oven;
3. A limitation on air circulation in the drying oven that causes the
lower explosive limit (LEL) to be exceeded; and
4. A limitation on the maximum speed at which a smooth coating can be
achieved with a given coating head or at which the line can be operated
without shutdowns.
Any equipment changes made to obtain an increased production rate
(such as larger/faster drive motors, higher capacity boilers for the ovens,
higher capacity oven air circulating blowers, or LEL sensors with
alarm/shutdown capacity) would require capital expenditure and result in
increased emissions and could cause the facility to come under the
modification provisions. Depending on the cost of the changes, they might,
however, cause a considered facility to come under the reconstruction
provisions.
5.2.1.3.3 Raw material changes. Many changes in coating
specifications (such as percentage of VOC's or coating thickness) could
also result in increased VOC emissions. Such changes would only be
considered modifications if the coating operation equipment had to be
altered to accommodate use of that coating. However, coating reformulation
5-5
-------
tends to be directed toward reducing VOC content. It is unlikely that any
equipment modifications resulting from reformulation would increase VOC
emissions.
5.2.1.3.4 Changes in the hours available for operation and/or
scheduling efficiency. A typical polymeric coating operation operates
approximately 80 hours per week. Significant increases in production
and emissions could result from extending the working hours, but an
increase in the hours of operation is specifically exempted from
modification considerations by 40 CFR 60.14(e).
Even during the hours of operation, a coating operation may be shut
down to change products. Each time a change is made in the type of
substrate to be coated on a given operation or the type of coating to be
applied, time must be allowed to clean the equipment and to reset the
controls to the new product specifications. Thus, careful scheduling can
increase production, which will result in increased VOC emissions. The
careful scheduling of production would not be considered a modification if
that production rate increase can be accomplished without a capital
expenditure.
5.2.2 Examples of Reconstruction
Reconstruction, as defined under 40 CFR 60.15, might occur if the
components of a polymeric coating plant (i.e., storage tanks, coating mix
preparation equipment, coating operation, and other miscellaneous sources)
are replaced and if the fixed capital costs of the replacement components
exceed 50 percent of the fixed capital costs of a comparable new facility.
There appear to be no circumstances which would cause the relatively
small storage tanks (less than 40 m3 [10,000 gal]) used by polymeric
coaters to fall under the reconstruction provision.H Because associated
support structures (frames, housing, etc.) are not part of a tank, replace-
ment of such structures would not constitute reconstruction.
Repair of coating mix preparation equipment may occasionally incur
sufficient expense to qualify as reconstruction if the repairs are
extensive. Replacement of single components in a coating operation (i.e.,
a change in coating application method or drying oven) occurs rarely, but
replacement of the oven in particular may incur sufficient expense to
5-6
-------
require EPA's determination as to whether it would be considered a
reconstruction of a coating operation.
Some of the coating application equipment changes discussed in
Section 5.2.1.3 are likely to incur sufficient cost to qualify as recon-
structions. Any change of equipment to increase substrate width
significantly would probably require such extensive equipment replacement
that it would be considered a reconstruction. It is doubtful that any such
change would occur since the plant probably could install a new coating
operation for approximately the same expenditure. Similarly, equipment
changes to increase operating speed could be costly enough to require a
reconstruction determination. This would be most likely in cases where
oven capacity limits line speed. Reconstruction of polymeric coating
facilities is expected to occur only in isolated cases, if at all.
5.3 REFERENCES FOR CHAPTER 5
1. Telecon. Friedman, E., MRI, with Melton, D., Moorehouse Industries,
Inc. June 13, 1984. Information on mix room equipment.
2. Telecon. Maurer, E., MRI, with Herman, K., Sherman Machinery, Inc.
March 8, 1984. Information on mix room equipment.
3. Telecon. Friedman, E., and Banker, L., MRI, with Mueller, J., Day
Mixing Company. June 5, 1984. Information on mix room equipment.
4. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. May 9, 1984. Typical process parameters for
elastomeric coating of fabric facilities using VOC control devices.
5-7
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6. MODEL PLANTS AND REGULATORY ALTERNATIVES
This chapter describes model plants that are representative of new
plants that apply polymeric coating to supporting substrates. A model
plant is defined to include a model coating operation and associated model
solvent storage tanks and model coating mix preparation equipment. Also,
presented in this chapter are the regulatory alternatives that represent
the various levels of VOC emission control that could be achieved by the
use of available control devices. The model plants and regulatory
alternatives are used in subsequent chapters as the basis for estimating
the environmental, economic, and energy impacts associated with the control
of VOC emissions.
6.1 MODEL PLANTS
As discussed in Chapters 3 and 4, the polymeric coating process
encompasses a wide range of coatings, substrates, end products, production
processes, and VOC control options. The model plants presented here are
parametric descriptions of polymeric coating lines and represent typical
plants in the industry. ~ The model plants are based on specific
information from polymeric coating plants, general information from various
industry contacts, and published literature.
The model plants reflect polymeric coating lines that are expected to
be built in the future, whether they are captive or commission coaters.
The model plants represent the fact that expansion is expected to occur on
the basis of a single coating operation with the possibility of expansion
of support areas (solvent storage tanks and coating mix preparation
equipment).
Annual solvent consumption rates were selected as the basis for
determining the model plant size categories because these data are more
6-1
-------
readily available than either data pertaining to the total amount of
substrate coated per year or the amount of coating applied per unit
area. Because of the variety of end products and their inherent
production process differences, solvent consumption is a more meaningful
common denominator than annual production rates based on line speed and
coating thickness.
Solvent consumption may vary on a single line because of several
factors. In general, production variables such as substrate width, coating
thickness, line speed, and utilization rate affect the rate of coating
consumption which necessarily affects solvent consumption. The hours of
actual line operation are another important variable.
6.1.1 Solvent Storage Tanks
The solvent storage tanks for the model plant are those tanks required
to store and supply solvents to the model coating mix preparation
equipment. While most polymeric coating plants presently use underground
solvent storage tanks, it is expected that new tanks will be above ground,
fixed roof tanks. Above ground tanks are easier to install and maintain
and, most importantly, reduce concerns regarding groundwater
contamination.
The number and capacity of the model storage tanks are given in
Table 6-1. The number and capacity are based on the calculated annual
solvent consumption of the model plants and an inventory turnover rate of
f> 8
five times per year.
6.1.2 Coating Mix Preparation Equipment
The coating mix preparation equipment for the model plant will contain
the equipment (mixers and holding tanks) required to supply coating to the
model coating operation. The model coating mix preparation equipment
parameters are given in Table 6-2. The capacity and number of pieces of
coating mix preparation equipment required to process the coatings are
based on discussions with vendors and are representative of equipment
configurations likely to be installed in the future. Because urethane
coatings are purchased premixed, coating mix preparation equipment is not
required and model coating mix preparation equipment parameters are not
if
included for a urethane coating operation.
6-2
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TABLE 6-1. MODEL SOLVENT STORAGE TANK PARAMETERS
Model tank configuration
Parameter
Solvent usage, m /yr (gal/yr)
No. of tanks
Capacity of each tank, m (gal)
No. of turnovers per year
Total emissions, Mg/yr (ton/yr)a
A
113.6
(30,000)
2
11.4
(3,000)
5
0.06
(0.07)
B
189.3
(50,000)
2
18.9
(5,000)
5
0.11
(0.12)
C
378.5
(100,000)
2
37.9
(10,000)
5
0.27
(0.30)
aBased on calculated emission rate of toluene using volatile organic
liquid storage tanks equations for above ground fixed roof tanks.
6-3
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TABLE 6-2. MODEL COATING MIX PREPARATION EQUIPMENT PARAMETERS
cr>
Parametera
Coating prepared, m3/d
(gal/d)
Solvent used, m3/d (gal/d)
Equipment, No. of:
100-gallon mixers
200-gallon mixers
330-gallon mixers
55-gallon holding tanks
Equipment ventilation rate,
m3/min (scfm)D
Uncontrolled emissions,
Mg/yr (tons/yr)c
1 . Rubber-coated
industrial fabric
A
0.68
(180)
0.45
(120)
1
1
0
4
6
(200)
9.5
(10.5)
B
1.01
(290)
0.72
(190)
0
2
0
6
4
(150)
15
(17)
C
2.20
(580)
1.44
(380)
0
4
0
11
9
(300)
31
(34)
3. Rubber-
coated cord
A
0.53
(140)
0.45
(120)
2
0
0
3
6
(200)
9.5
(10.5)
B
0.83
(220)
0.72
(190)
1
1
0
4
4
(150)
15
(17)
4. Epoxy-coated
fiberqlass
B
1.97
(520)
0.80
(210)
0
1
2
10
4
(150)
15
(17)
C
3.90
(1,030)
1.55
(410)
1
1
3
19
9
(300)
31
(34)
jjBased on solvent consumption.
"Based on solvent concentration of 4,000 ppm in the exhaust.
to those of coating line.
cBased on 10 percent of total VOC emissions.
Hours of operation assumed to be equal
-------
Rubber compounding equipment such as roll mills or Banbury mixers
are not included in the model coating mix preparation equipment parameters
for the operations using rubber coating. If a new rubber coating operation
is added to an existing plant, rubber compounding could be handled by
the existing equipment. In the case of a new plant consisting of a
single coating operation, it would be less costly to purchase compounded
rubber than to install rubber compounding equipment.
6.1.3 Coating Operation
The coating operation of the model plant is defined as the coating
application/flashoff area and associated drying oven required to manufacture
polymeric coated substrates. In some instances, the coating operation
may include more than one coating application/flashoff area and associated
drying oven operated in a continuous series for the purpose of applying
multiple coats on the substrate. However, for the purposes of impact
analysis, a single application/flashoff area and drying oven is being
evaluated because it represents the most typical case.
Parameters for four model coating operations are summarized in
Tables 6-3, 6-4, and 6-5. The parameters were chosen to accomodate a
range of market conditions, such as import competition and changes in
consumer demand, and differences in end-product values. The parameters
also address the variations in coating formulation, substrate types,
process equipment, and VOC capture and control devices used.
6.1.3.1 Coating Formulation. Rubber, urethane, and epoxy coatings
are widely used polymeric coatings, and model coating operation parameters
have been developed for processes using these typical coating formulations.
Acrylic coatings, which are typically waterborne, and both PVC coatings
and rubber coatings containing 100 percent solids emit few or no VOC's.
Therefore, the coating processes associated with these coating formulations
are not included in the model coating operation parameters. Solvent
borne silicone and nitrocellulose coatings are not widely used and are
expected to be represented by the model coating operation parameters for
rubber-coated industrial fabric. Phenolic coatings are represented by
the model coating operation for epoxy-coated fiberglass.
6.1.3.2 Substrate Types. Table 6-5 summarizes the substrate types
and annual substrate consumption for typical products produced on each
model coating operation.
6-5
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TABLE 6-3a,
I
CT>
MODEL COATING LINE PARAMETERS FOR CARBON ADSORBER OR INCINERATOR CONTROL OPTIONS
(Metric Units)
Parameter
Production
Total volume of coating used, n /yr
Amount of solvent used, n /yr (Mg/yr)
End product(s)
Operating Parameters
Period of operation, h/yr
Utilization rate. X
Actual operation, h/yr
No. of operators
Process Parameters
Coating composition
Solids
% by volune
Solvent(s)
% by volume
Coating equlpnent
Coating applicator
Drying oven
Coating application
Oven temperature, °C
Oven ventilation rate, n3/m1nc
Solvent concentration In exhaust.
X LEI
Control device
Carbon adsorber Inlet tenperature, °C
Incinerator heat exchanger Inlet
temperature, °C
Inlet solvent concentration, ppnV
Uncontrolled VOC enlsslons
from coating operation. Mg/yr
A
169
110
(95)
Rubber-coated
Industrial fabric
B C
274 548
178 356
(154) (308)
* Diaphragms, printing blankets »
2.0008
4-
1,000
^
«•
«•
4.000b 4.000
50
2,000 2,000
3
Rubber *
35
Toluene
65
Knife-over-roll, dip tank
93
116
25
«•
4-
3.250
85.5
Single- zone
93 93
102 188
23 25
35
93
2.990 3.230
139 277
Urethane -coated
fabric
B C
306 613
168 333
(154) (308)
» Luggage, tents •>
4.000 4.000
50 50
2.000 2,000
4 4
*• Urethane »
* 45 '
DMF. Toluene
35,20
Knife-over-roll
reverse-rol 1
Double- zone
177 177
104 209
25 25
35 35
177 177
3,250 3.250
154 308
Rubber-coated
cord
A.
129
no
(95)
«•
2,000
50
1.000
2
«•
B
209
178
(154)
V-belts
4.000
50
2,000
2
Rubber •>
15
Toluene
85
40-cord dip tank
232
116
25
35
232
3,250
85.5
Triple- zone
232
102
23
35
232
2,990
139
Epoxy-coated
fiberglass
B
488
199
(154)
«• Aircraft/military
products
4,000 4
50
2,000 2
4
* Epoxy
60
Acetone
40
Dip tank
Single-zone
121
102
18
35
121
4,680 6
139
C
975
390
(308)
•ft
.000
50
.000
4
•ft
121
148
25
35
121
,500
277
aPeriod of operation 8 h/d, 5 d/wk, 50 wk/yr.
bPer1od of operation 16 h/d. 5 d/wk. 50 wk/yr.
"•Standard conditions are 20°C and 1 atmosphere pressure.
dBased on 90 percent of total VOC emissions except for the urethane coating operations which are based on 100 percent of total VOC emissions because urethane coatings are
purchased prenlxed and, therefore, have no coating nix preparation equipment emissions.
-------
TABLE 6-3b,
MODEL COATING LINE PARAMETERS FOR CARBON ADSORBER OR INCINERATOR CONTROL OPTIONS
(English Units)
CTl
Parameter
Production
Total volume of coating used, gal/yr
Amount of solvent used, gal/yr
(tons/yr)
End product (s)
Operating Parameters
Period of operation, h/yr
Utilization rate, X
Actual operation, h/yr
No. of operators
Process Parameters
Coating composition
Solids
% by volume
Solvent(s)
% by volume
Coating equipment
Coating applicator
Drying oven
Coating application
Oven temperature, °F
Oven ventilation rate, scfrac
Solvent concentration in exhaust,
% LEL
Control device
Carbon adsorber inlet temperature, °F
Incinerator heat exchanger inlet
temperature, "F
Inlet solvent concentration, ppraV
Uncontrolled VOC emissions
from coating operation, tons/yr
Rubber- coated
industrial fabric
ABC
44,690 72.350 144.700
29.050 47.030 94,050
(105) (170) (340)
«• Diaphragms, printing blankets *
2,000a 4,000b 4,000
* 50
1,000 2,000 2,000
3
» Rubber +
* 35 •»
* Toluene *
» 65 *
«• Knife-over-roll, dip tank *
«• Single-zone *
200
4,100 3.600 6.640
25 23 25
95
200
3,250 2,990 3,230
94.5 153 306
Urethane-coated
fabric
B
80,900 161
44,500 88
(170)
* Luggage, tents
4,000 4
50
2,000 2
4
* Urethane
45
«• DMF, Toluene
35,20
C
,900
,050
(340)
•••
.000
50
,000
4
-ft
-ft
-ft
-ft
«• Knife-over-roll ••
reverse-rol 1
* Double-zone
350
3,690 7
25
95
350
3,250 3
170
-ft
350
,380
25
95
350
.250
340
Rubber-coated
cord
A
34,180
29,050
(105)
4>
2,000
50
1,000
2
4-
«•
«•
«-
B
55,330
47,030
(170)
V-belts ••
4,000
50
2.000
2
Rubber •»
15
Toluene *
85
«• 40-cord dip tank +
*
450
4,100
25
95
450
3,250
94.5
Triple-zone •»
450
3,600
23
95
450
2,990
153
Epoxy-coated
fiberglass
B
128,000 257
52.520 103
(170)
* Aircraft/military
products
4,000 4
50
2,000 2
4
» Epoxy
60
* Acetone
40
* Dip tank
* Single-zone
250
3,600 5
18
95
250
4.680 6
153
C
.600
.030
(340)
•»
.000
so
.000
4
-ft
-*
-ft
-ft
-ft
-ft
250
,220
25
95
250
,500
306
aPeriod of operation 8 h/d, 5 d/wk, 50 wk/yr.
bPeriod of operation 16 h/d, 5 d/wk. 50 wk/yr.
"•Standard conditions are 68°F and 1 atmosphere pressure.
''Based on 90 percent of total VOC emissions except for the urethane coating operations which are based on 100 percent of total VOC emissions because urethane coatings are
purchased premixed and, therefore, have no coating mix preparation equipment emissions.
-------
TABLE 6-4a.
CT>
I
CO
MODEL COATING LINE PARAMETERS FOR CONDENSATION CONTROL OPTION
(Metric Units)
Rubber- coated
Industrial fabric
Parameter
Production
Total volume of coating used, n/yr
Amount of solvent used, m3/yr (Mg/yr)
End product(s)
Operating Parameters
Period of operation, h/yr
Utilization rate. X
Actual operation, h/yr
No. of operators
Process Parameters
Coating composition
Solids
X by volume
Solvent(s)
X by volute
Coating equipment
Coating applicator
Drying oven
Coating application
Oven temperature, °C
Oven ventilation rate, m/m1nc
Solvent concentration in exhaust,
X LEL
Control device
Inlet temperature, °C
Inlet solvent concentration, ppnV
Uncontrolled VOC emissions
from coating operation, Mg/yrd
A
169
110
(95)
«• Diaphragms,
2,000a
*•
1.000
*•
*
«•
*•
4*
B C
274 548
178 356
(154) (308)
printing blankets •
4.000b 4,000
50
2.000 2.000
3 *
Rubber •»
35
Toluene *
65
*• Knife-over-roll, dip tank •»
* Single-zone •*
*
102
28
«•
3.640
85.5
93
102 118
23 40
82
2.990 5.200
139 277
Ur ethane-coated
fabric
B
306
168
(154)
* Luggage, tent
4.000 4
SO
2.000 2
4
* Urethane
45
» CMF, Toluene
35.20
C
613
333
(308)
•*
.000
so
.000
4
+
•*>
•*
-I-
* Knife-over-roll »
reverse-rol 1
* Double-zone
177
102
26
166
3.380 5
154
-*>
177
131
40
166
,200
308
Rubber-coated
cord
• A
129
110
(95)
V-belts
2,000 4
50
1.000 2
2
» Rubber
15
* Toluene
85
B
209
178
(154)
*
,000
50
.000
2
•*
•*
•*.
•»•
» 40-cord dip tank •»
* Triple-zone
232
102
28
221
3.640 2
85.5
•»
232
102
23
221
,990
139
E poxy-coated
fiberglass
B
488
199
(154)
* Alrcraft/nllltary
products
4,000
50
2,000
4
* Epoxy
» 60
* Acetone
* 40
* Dip tank
* Single-zone
121
102
18
110
4,680
139
C
975
390
(308)
•*
4.000
SO
2.000
4
•+
4
4
4
•+
•#
121
102
36
110
9.360
277
"Period of operation 8 h/d, 5 d/wk, 50 wk/yr.
Period of operation 16 h/d, 5 d/wk, SO wk/yr.
Standard conditions are 20'C and 1 atmosphere pressure.
Based on 90 percent of total VOC eaissions except for the urethane coating operations which are based on 100 percent of total VOC emissions because urethane coatings are
purchased premlxed and, therefore, have no coating mix preparation equipment emissions.
-------
TABLE 6-4b.
MODEL COATING LINE PARAMETERS FOR CONDENSATION CONTROL OPTION
(English Units)
CT»
I
ID
Parameter
Production
Total volume of coating used, gal/yr
Amount of solvent used, gal/yr
(tons/yr)
End product (s)
Operating Parameters
Period of operation, h/yr
Utilization rate. X
Actual operation, h/yr
No. of operators
Process Parameters
Coating composition
Solids
% by volume
Solvent(s)
X by volume
Coating equipment
Coating applicator
Drying oven
Coating application
Oven temperature, °F
Oven ventilation rate, scfra
Solvent concentration in exhaust.
X LEL
Control device
Inlet temperature, °F
Inlet solvent concentration, ppmV
Uncontrolled VOC emissions
from coating operation, tons/yr
^Period of operation 8 h/d, 5 d/wk,
Period of operation 16 h/d. 5 d/wk.
^Standard conditions are 68°F and 1
A
44.690
29.050
(105)
Rubber-coated
industrial fabric
B C
72,350 144.700
47.030 94.050
(170) (340)
» Diaphragms, printing blankets +
3
2,000
4-
1.000
4-
4-
4-
t-
4-
h
4,000 4.000
50
2,000 2,000
3 •»
Rubber •>
35
Toluene +
65
«• Knife-over-roll , dip tank -»
4-
4»
3,600
28
*
3,640
94.5
50 wk/yr.
50 wk/yr.
atmosphere pressure.
Single-zone *
200 *
3,600 4,160
23 40
180 +
2,990 5,200
153 306
Based on 90 percent of total VOC emissions except for the urethane coating operations
purchased premixed and, therefore.
have no coating mix
preparation equipment emissions
Ur ethane-coated
fabric
B
80,900 161
44.500 88
(170)
«- Luggage, tents
4.000 4
50
2.000 2
4
* Urethane
45
«• DMF, Toluene
35,20
C
.900
.050
(340)
•»
.000
50
,000
4
-»
*
-»
+
* Knife-over-roll •»
re verse- roll
* Double- zone
350
3,600 4
26
330
3.380 5
170
which are based on 100
•»
350
.620
40
330
,200
340
percent
Rubber -coated
A
34,180
29.050
(105)
4-
2,000
50
1.000
2
4-
4-
4-
4-
cord
B
55.330
47,030
(170)
V-belts - *
4.000
50
2.000
2
Rubber •» »
15 •» «•
Toluene -» *
85 - *
*• 40-cord dip tank + *
4-
450
3,600
28
430
3,640
94.5
Triple-zone * *
450
3.600
23
430
2.990
153
of total VOC emissions because
Epoxy-coated
fiberglass
B
128.000 257
52,520 103
(170)
Aircraft/military
products
4.000 4
50
2.000 2
4
Epoxy
60
Acetone
40
Dip tank
Single-zone
250
3.600 3
18
230
4,680 9
153
C
,600
.030
(340)
-*•
.000
50
,000
4
•*
-»
f
*
-»
->
250
,600
36
230
.360
306
urethane coatings are
-------
TABLE 6-5. MODEL COATING OPERATION PARAMETERS FOR SUBSTRATE TYPE AND CONSUMPTION
Parameter
Product 1
Substrate
Type
Width, Inches
Coated substrate, yd /yr
Product 2
Substrate
cn Type
^ Width, Inches
O
2
Coated substrate, yd /yr
Rubber-coated Urethane-coated
industrial fabric fabric
A B C B C
* Diaphragms * * Luggage *
*• Nylon fabric * * 8-ounce polyester •»
"48 * 60 60
580.970 940.550 1,881,100 4.700.290 9.406,390
«• Printing blankets + * Tents *
* Cotton fabric -» * Hylon fabric *
72 60 60
137,508 222.616 445.230 13.091,481 26.199.144
Rubber-coated Epoxy-coated
cord fiberglass
A B B C
* V-belts * * Aircraft/ •»
military products
* Nylon cord •> * Fiberglass *
* Cord •» 72 72
193 313 1.512.112 3.024,224
tons/yr tons/yr
N/Ab * * N/A
.Plant size based on solvent consumption.
Not applicable.
-------
6.1.3.3 Process Equipment. The primary types of equipment used for
applying the coating to the substrate are knife-over-roll, dip tank, and
reverse-roll coaters.3 All three types of coating application methods are
included in the model coating operation parameters, where applicable, for
subsequent evaluation of the economic impact of various regulatory
alternatives.
The drying ovens and drying temperatures are representative of those
used by polymeric coating plants to dry/cure each of the coating types.
The ventilation rates for the drying ovens were calculated based on oven
operation at a percentage of the lower explosive limit (LEL) of the
1 2
solvents. The LEL values are assumed to be representative of those that
will be used in the industry.
6.1.3.4 VOC Capture and Control Devices. The VOC capture devices
used on the coating application/flashoff area of the model coating
operations are total enclosures and partial enclosures. The calculation of
the ventilation rates required is based on specific suction velocity and
design of the vents located at either side of the substrate in the
application/flashoff area. The exhaust air from the total and partial
1 2
enclosures is directed into the oven and through the VOC control device.
The VOC control devices used at polymeric coating plants are carbon
adsorbers, incinerators, and condensation systems. Model coating
operation parameters have been developed for fixed-bed carbon adsorbers and
thermal incinerators because these are the most commonly used control
devices. Separate model coating operation parameters are also provided for
a condensation system using an air atmosphere. Effective control of
fugitive VOC emissions from the application/flashoff area has not been
demonstrated when a condensation system using an inert atmosphere in the
oven is used. Therefore, model coating operations parameters were not
developed for this control device.
For model coating operations controlled by carbon adsorbers or
incinerators, the drying oven exhaust rate was calculated for each
solvent mixture and usage rate assuming operation of the oven at a
concentration of 25 percent of the LEL of the solvents. The ovens can
be designed to operate safely at this level, and ovens are operated at
this level in other similar surface coating operations. While perhaps
6-11
-------
more cost effective, a higher VOC concentration was not chosen due to the
increased potential for premature breakthrough and carbon bed fires.
Furthermore, carbon adsorption can achieve 95 percent or greater removal
efficiencies cost effectively when the VOC concentration in the exhaust
stream is 25 percent of the LEL.
For model coating operations controlled by air atmosphere condensation
systems, the drying oven exhaust rate was calculated for each solvent
mixture and usage rate assuming operation of the oven at 40 percent of the
LEL. This solvent concentration was based on discussions with an equipment
vendor on condensation system design considerations and is necessary to
operate the unit cost effectively.
In order to capture most of the emissions from the enclosure, a
minimum face velocity of 0.6 m/s (100 ft/min) must be maintained at all
openings according to standard industrial ventilation practices. This
results in a minimum oven ventilation rate of 102 m/min (3,600 scfm), which
is the sum of the exhaust from the capture device and the infiltration from
the two openings in the oven for substrate entrance and exit. Therefore,
some model coating operation parameters include solvent concentrations in
the oven exhaust of less than 25 and 40 percent for carbon adsorber or
incinerator and condensation system control, respectively.
6.2 REGULATORY ALTERNATIVES
Separate regulatory alternatives have been developed for solvent
storage tanks, coating mix preparation equipment, and coating operations.
The regulatory alternatives considered for solvent storage tanks, coating
mix preparation equipment, and coating operations represent the various
emission control levels that are achievable based on available emission
control equipment. The control levels assigned to the regulatory alter-
natives are calculated using estimated uncontrolled emission rates and
estimated efficiencies of various capture and control device options.
6.2.1 Solvent Storage Tanks
The regulatory alternatives for solvent storage tanks are presented in
Table 6-6. The four alternatives for the tanks are:
6-12
-------
TABLE 6-6. REGULATORY ALTERNATIVES FOR SOLVENT STORAGE TANKS
Reg. Alt. Control device
I None
II Conservation vents, set at 17.2 kPa
(2.5 psig)
III Pressure relief valves, set at 103.4 kPa
(15 psig)
IV Carbon adsorber or condensation system
Percent
VOC
control
0
70a
90a
95
Approximate control level based on ratio of calculated breathing losses
to calculated total emissions from tanks.
6-13
-------
1. Alternative I. Baseline. (No control). This case represents
uncontrolled solvent storage tanks. Most States do not require any control
of emissions from this source.
2. Alternative II. (70 percent control). This case represents the
approximate level of emission reduction achievable by control of breathing
losses by the use of conservation vents set at 17.2 kPa (2.5 psig)
installed on solvent storage tanks.
3. Alternative III. (90 percent control). This case represents the
approximate level of emission reduction achievable by control of breathing
losses by the use of pressure relief valves set at 103 kPa (15 psig)
installed on storage tanks.
4. Alternative IV. (95 percent control). This control level can be
achieved by venting all storage tank emissions to a control device that is
95 percent efficient.
6.2.2. Coating Mix Preparation Equipment
The regulatory alternatives for coating mix preparation equipment are
presented in Table 6-7. The three alternatives are:
1. Alternative I. Baseline. (No control). This case represents
uncontrolled coating mix preparation equipment. The States do not require
any control of emissions from this source.
2. Alternative II. (40 percent control). This case represents the
approximate level of emission reduction achievable by control of breathing
losses by installation of fastened, gasketed covers with conservation vents
on each piece of coating mix preparation equipment.
3. Alternative III. (95 percent control). This case represents the
emission reduction achievable by covering the coating mix preparation
equipment and ducting the vapors to a control device that is 95 percent
efficient.
6.2.3. Coating Operation
The regulatory alternatives for the coating operation with the
associated emission capture and control device configurations are presented
in Table 6-8. The three alternatives are:
1. Alternative I. Baseline. (81 percent control). This case
corresponds to the Control Techniques Guideline (CTG) recommended emission
limit of 0.35 kg VOC/liter (2.9 Ib VOC/gallon) of coating, minus water
6-14
-------
TABLE 6-7. REGULATORY ALTERNATIVES FOR COATING MIX PREPARATION EQUIPMENT
Reg. Alt. Control device
I None
II Fastened, gasketed covers with
conservation vents
III Carbon adsorber or condensation system
Percent
VOC
control
0
40a
95
Approximate control level based on ratio of calculated breathing losses
to calculated total emissions from tanks.
6-15
-------
TABLE 6-8. REGULATORY ALTERNATIVES FOR COATING OPERATIONS
Reg.
Alt.
I
II
III
IV
Recommended
Emission capture
AppHcatlon/flashoff
Suction Into oven
Partial enclosure
Total enclosure
Total enclosure
abatement
Ovena
Negative
pressure
Negative
pressure
Negative
pressure
Negative
pressure
technology
Emission control
Carbon adsorber
or condensation
system
Carbon adsorber
or condensation
system
Carbon adsorber
or condensation
system
Incinerator
Emission
capture
efficiency,
percent
90
95
98
98
Control
device
efficiency,
percent
90b
95C
95C
98C
Overall
VOC
control,
percent
81
90
93
96
all the alternatives, the use of well-designed oven with no losses to room is assumed.
"Recommended efficiency of carbon adsorber in the CTG.
cBased on actual emission measurements.
-------
for existing polymeric coating plants and is based on application of
reasonably available control technology (RACT) to polymeric coating
operations. The 81 percent control level of Alternative I assumes that
plants are capturing and venting 90 percent of the emissions from the
coating operation to a control device that achieves 90 percent VOC control
2. Alternative II. (90 percent control). The 90 percent control
level of Alternative II can be achieved by capturing approximately
95 percent of all VOC emissions from the coating operation and by venting
these emissions through a control device that achieves 95 percent control
efficiency. The required 95 percent capture efficiency can be achieved by
use of a partial enclosure to collect a portion of the emissions from the
coating application/flashoff area in addition to capturing 100 percent of
the drying oven emissions.
3. Alternative III. (93 percent control). This case is based on
capture of at least 98 percent of the emissions from the coating operation
and control of these emissions by a 95 percent efficient control device.
This results in an overall 95 percent control level. The required
98 percent capture efficiency can be achieved by use of a total enclosure
to collect emissions from the application/flashoff area in addition to
capturing 100 percent of the drying oven emissions.
4. Alternative IV. (96 percent control). This case is based on
capture of at least 98 percent of emissions from the coating operation and
control by a 98 percent efficient control device. Capture of coating
operation emissions can be achieved by use of a total enclosure around the
application/flashoff area and by capturing 100 percent of the drying oven
emissions.
6.2.4. Low-Solvent Coatings
An optional technique for achieving emission reductions equivalent
to or greater than those associated with the regulatory alternatives is
the use of low-solvent coatings (waterborne or higher solids). Reformula-
tion to low-solvent-coatings is not a universally applicable solution
because adequate substitutes for traditional solvent borne coatings are
not yet available for many products. Because it is not a universally
6-17
-------
available alternative, the use of low-solvent coatings was not considered
as a regulatory alternative.
Due to the wide range of products produced by polymeric coaters,
there is a significant range of coating formulations in use. No single
formulation can represent all of the coatings in use. Because of the
lack of a single baseline coating for polymeric coating plants, the use
of low-solvent coatings could not be considered an option to achieving
the emission reductions required by Regulatory Alternatives II through
IV. For example, a polymeric coating plant that is currently using a
coating containing 0.56 kg VOC/2, (4.70 Ib VOC/gal) of coating applied
would have to switch to a coating containing 0.10 kg VOC/i (0.83 Ib
VOC/gal) of coating (12 percent solvent) to achieve an emission reduction
equivalent to Regulatory Alternative III (93 percent control). A plant
that is currently using a lower solvent coating (0.32 kg VOC/8, [2.64 Ib
VOC/gal] of coating) would have to switch to a coating containing 0.04 kg
VOC/2, (0.30 Ib VOC/gal) of coating (4 percent solvent) to obtain the
same emission reduction. In other words, the second plant, which is
already using a low-solvent coating, would have to switch to a far lower
solvent content coating than the first plant. Because of this differential
impact, the use of low-solvent coatings was not considered as an option
to the regulatory alternatives.
6.3 REFERENCES FOR CHAPTER 6
1. Memorandum from Thorneloe, S., MRI, to Elastomeric Coating of Fabric
Project File. May 9, 1984. Typical process parameters for
elastomeric coating of fabrics; facilities using VOC control devices.
2. Memorandum from Maurer, E., MRI, to Elastomeric Coating of Fabrics
Project File. April 12, 1984. Estimated solvent consumption at
facilities performing elastomeric coating of fabrics.
3. Memorandum from Maurer, E., MRI, to Elastomeric Coating of Fabric
Project File. April 23, 1984. Coating operation equipment design and
operating parameters.
4. Memorandum from Friedman, E., MRI, to Polymeric Coating of Supporting
Substrates Project File. July 27, 1984. Information on mix room
equipment.
5. Memorandum from Hester, C., MRI, to Crumpler, D., EPA. February 17,
1984. Preliminary Section 9.1—Industry characterization.
6-18
-------
6. Memorandum from Maurer, E., MRI, to Elastomeric Coating of Fabric
Project File. April 12, 1984. Estimated solvent consumption at
facilities performing elastomeric coating of fabrics.
7. Telecon. Friedman, E., MRI, with Coffey, F., Southern Tank and Pump
Company. August 23, 1984. Information on solvent storage tanks.
8. VOC Emissions From Volatile Organic Liquid Storage Tanks—Background
Information for Proposed Standards. Draft. U. S. Environmental
Protection Agency. Research Triangle Park, North Carolina. Report
No. EPA-450/3-81-003a. July 1984. pp. 3-25 to 3-26.
9. Telecon. Friedman, E., MRI, with Herman, K., Sherman Machinery.
August 29, 1984. Information on coating preparation equipment.
10. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Webs Project File. October 26, 1984. Summary of information on
polymeric coatings used in the coating of supporting substrates.
11. Memorandum from Friedman, E., MRI, to Polymeric Coating of Supporting
Substrates Project File. September 18, 1984. Product specific raw
material costs for model coating lines.
12. Memorandum from Banker, L., MRI, to Polymeric Coating of Supporting
Substrates Project File. November 20, 1984. Calculation of drying
oven ventilation rates for model coating lines.
13. Flexible Vinyl Coating and Printing Operations—Background Information
for Proposed Standards. Draft. U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina. Report
No. EPA/450/3-81-016a. January 1983. p. 6-6.
14. Telecon. Thorneloe, S., MRI, with Memering, L., United Air
Specialists, Inc. May 4, 1984. Information on the Kon-den-Solver®
condensation system.
6-19
-------
7. ENVIRONMENTAL AND ENERGY IMPACTS
This chapter presents an analysis of the environmental and energy
Impacts of the regulatory alternatives for model solvent storage tanks,
coating mix preparation equipment, and coating operations. The
incremental increase or decrease 1n air pollution, water pollution, solid
waste generation, and energy consumption for the regulatory alternatives
compared to baseline are discussed.
Separate regulatory alternatives have been developed for solvent
storage tanks, coating mix preparation equipment, and coating
operations. The regulatory alternatives used 1n the impact analyses for
model solvent storage tanks and coating mix preparation equipment are
summarized in Tables 6-6 and 6-7, respectively. The regulatory
alternatives used 1n the impact analyses for model polymeric coating
operations are summarized in Table 6-8.
7.1 AIR POLLUTION IMPACTS
Volatile organic compounds (VOC's) are emitted from several points
in the polymeric coating of supporting substrates. The largest single
source of VOC emissions is the drying oven used to evaporate the solvent
and cure the coating. Fugitive VOC emissions are emitted from around
the coating application/flashoff area. Volatile organic compound emissions
also occur during coating preparation activities, solvent storage, and
cleanup of the coater and ancillary equipment. Some solvent (0 to
20 percent of solvent applied, below 5 percent on an average) may be
retained in the product depending on the product type and specification.
In an uncontrolled line, the entire amount of solvent used is vented to
the atmosphere. The VOC emissions can be controlled by use of add-on control
equipment such as carbon adsorbers, incinerators, and condensers. Carbon
7-1
-------
adsorber and condenser control systems recover solvent for reuse in
coating mix formulations.
7.1.1 Primary Air Pollution Impacts
The annual VOC emission levels associated with the application of
each regulatory alternative for model solvent storage tanks and coating
mix preparation equipment are presented in Tables 7-1 and 7-2,
respectively. The annual VOC emission levels associated with the
application of each regulatory alternative for model coating operations
are presented in Table 7-3. The annual emissions were calculated using
the model solvent storage tanks, coating mix preparation equipment, and
coating operation parameters given in Chapter 6. The range in annual
uncontrolled emissions are as follows:
1. Model solvent storage tanks—0.06 to 0.27 Megagrams (Mg) (0.07 to
0.30 tons);
2. Model coating mix preparation equipment--9.5 to 30.8 Mg (10.5 to
34 tons); and
3. Model coating operation—85.7 to 308.4 Mg (94.5 to 340 tons).
The range in annual VOC emissions ere as follows for Regulatory Alter-
natives II, III, and IV for model solvent storage tanks, II and III for
coating mix preparation equipment, and II, III, and IV for model coating
operations:
1. Model solvent storage tanks—0.002 to 0.08 Mg (0.002 to 0.09
tons);
2. Model coating mix preparation equipment--0.5 to 19 Mg (0.5 to 20
tons); and
3. Model coating operation—3.4 to 31 Mg (3.8 to 34 tons).
The annual VOC emission incremental reduction beyond baseline for model
solvent storage tanks, coating mix preparation equipment, and coating
operations are given in Tables 7-1, 7-2, and 7-3, respectively.
The primary impact of a VOC emission reduction in this industry is a
potential decline in ambient VOC levels and, thus, a reduction in subsequent
ozone and photochemical smog formation. For plants in rural areas or areas
of low ambient nitrogen oxide and ozone concentrations, the primary
environmental impact is the prevention of transport of VOC's in the
atmosphere to locations where ozone and photochemical smog are problems.
7-2
-------
7.1.2 Secondary Air Pollution Impacts
Secondary emissions of air pollutants result from generation of the
energy required to operate the control devices. Electrical energy is
needed primarily to operate the motors and fans used to capture and convey
gases to different sections of the control system. Generation of the
electric power required to operate carbon adsorbers, incinerators, and
condensers will result in particulate matter (PM), sulfur oxide (SOX),
nitrogen oxide (NOX), and carbon monoxide (CO) emissions. The combustion
of natural gas in incinerators will result in PM, NOX, and CO emissions.
The combustion of fuel oil in the boiler used to produce steam for the
fixed-bed carbon adsorption system will also result in PM, SOX, NOX, and
CO emissions.
Secondary emissions were calculated assuming that electric power to
the control device was supplied by a coal -fired power plant. The thermal
efficiency of the electric generator was assumed to be 33 percent. Also
for this analysis it was assumed that for all types of power plants and
all ages of plants, the estimated emissions per British thermal unit (Btu)
of heat input in 1990 are approximately equal to the current new source
performance standards (NSPS) for coal -fired power plants. Therefore, the
2
secondary emissions were calculated using the NSPS values. The
applicable standards limit PM emissions to 15 kg/TJ* (0.03 lb/10 Btu) of
x
heat input, SO emissions to 520 kg/TJ (1.20 lb/106 Btu) of heat input,
and NOX emissions to 260 kg/TJ (0.60 lb/106 Btu) of heat input.3 There
are no annual secondary pollutant emissions associated with Regulatory
Alternatives I, II, and III for model solvent storage tanks and I and II
for coating mix preparation equipment. The annual secondary pollutant
emission levels associated with application of Regulatory Alternative IV
for the model solvent storage tanks is negligible. The annual secondary
pollutant emission levels associated with the application of Regulatory
Alternative III for model coating mix preparation equipment and the annual
secondary pollutant levels associated with each of the regulatory
alternatives for the model coating operations are presented in Tables 7-4,
*TJ = Terajoules = 1012 joules.
7-3
-------
7-5, and 7-6. Annual secondary emissions of PM for model coating
operations range from 2.7 to 56 kilograms (kg) (5.9 to 124 pounds [lb]).
The annual secondary SOX emissions for model coating operations range from
107 to 2,260 kg (236 to 4,980 lb). The annual secondary NOX emissions for
model coating operations range from 54 to 1,130 kg (118 to 2,490 lb).
The combustion of natural gas as supplemental fuel in incinerator
control devices results in secondary air pollutants. Assuming the
incinerator generates pollutants at a rate comparable to that of an
industrial process boiler, the secondary emissions were calculated using
emission rates of 5 kg/TJ (0.011 lb/10 Btu) of heat input for particulates,
8 kg/TJ (0.019 lb/106 Btu) for CO, and 84 kg/TJ (0.194 lb/106 Btu) for
4.
NOX. The annual secondary emissions for Regulatory Alternative IV for
each model coating operation are presented in Table 7-7.
The major secondary air pollution impacts for fixed-bed carbon
adsorption systems are the emissions from the boiler used to produce
steam. The steam is used to strip the carbon bed of adsorbed VOC's at a
ratio of 4 kilograms of steam per kilogram (4 Ib steam/lb) of recovered
solvent. Assuming that the boiler uses fuel oil containing 1.5 percent sulfur
by weight and that the thermal efficiency of the boiler is 80 percent,
estimates can be made of the levels of secondary emissions. For particu-
lates, the emission rate is 50 kg/TJ (0.12 lb/106 Btu) of heat input;
for SOX, it is 690 kg/TJ (1.6 lb/106 Btu); for NOX, it is 170 kg/TJ
(0.4 lb/106 Btu); and for CO, it is 14.5 kg/TJ (0.034 lb/106 Btu).5 The
secondary emissions for those regulatory alternatives that require the
generation of steam are presented in Tables 7-8 through 7-11. Annual
emissions of PM for model coating operations range from 51 to 275 kg
(111 to 606 Ib). Annual emissions of SOX for model coating operations
range from 661 to 3,598 kg (1,458 to 7,930 Ib). Annual emissions of NOX
for model coating operations range from 169 to 917 kg (371 to 2,020 lb).
Annual emissions of CO for model coating operations range from 14 to
76 kg (31 to 168 lb).
The magnitude of the secondary pollutants generated by the operation
of the control system is much smaller than the magnitude of solvent
emissions being recovered. For the worst case, the largest amount of
secondary emissions result from the application of Regulatory
7-4
-------
Alternative III for the control (by a carbon adsorber) of a urethane
coating line (line designation C). Emissions of VOC are reduced from 308
to 22 Mg (340 to 24 tons) annually while 4.3 Mg (4.7 tons) of secondary
pollutants are emitted annually.
7.2 WATER POLLUTION IMPACTS
There are no wastewater effluents from an uncontrolled polymeric
coating line or from the use of incinerators and condensation systems
using a nitrogen atmosphere. There are some wastewater effluents from the
use of fixed- and fluidized-bed carbon adsorbers and condensation systems
using an air atmosphere. The amount of this wastewater discharge depends
on the amount of water vapor in the solvent laden air, solubility of
solvent in water, and whether or not the mixture is distilled. For this
analysis, this amount is assumed to be negligible for fluidized-bed carbon
adsorber and condensation systems using an air atmosphere.
Wastewater problems do arise from the use of fixed-bed carbon
adsorbers. In a fixed-bed carbon adsorption system, water is used to
produce steam, which is then used to strip adsorbed solvent from the
carbon beds. Upon completion of the stripping operation, the solvent-
steam vapors are condensed and fed to a decanter where the water insoluble
organic layer separates from the water and water soluble organic layer.
Water soluble organics can be separated by distillation, but trace amounts
of organics could remain in the aqueous discharge. The wastewater
discharged after the solvent has been decanted poses a potential adverse
environmental impact resulting from possible organic contamination of the
water. Even if the solvent is considered immiscible in water, trace
concentrations of solvent may become fixed in the water during the
operation of the condensation stage.
7.2.1 Coating Operation Wastewater Emissions
The annual wastewater discharges associated with each model coating
operation and regulatory alternative (for model coating mix preparation
equipment and coating operations) requiring fixed-bed carbon adsorber
control are presented in Tables 7-12 and 7-13. There are no annual
wastewater discharges associated with regulatory alternatives for model
solvent storage tanks. As shown, annual wastewater discharges range from
7-5
-------
36 to 117 cubic meters (m3) (9,600 to 31,000 gallons [gal]) for model
coating mix preparation equipment and 278 to 1,170 m3 (73,500 to 310,000
gal) for model coating operations.
The annual wastewater VOC emissions associated with each regulatory
alternative are based on the solvent concentration of the wastewater
discharge. The VOC concentration of the wastewater effluent is dependent
on the requirements of solvent purification for each model coating
operation line. Model coating operations 1 and 3 use a single solvent
(toluene) that has a 0.05 percent miscibility in water. Therefore, the
solvent does not require purification after decantation for reuse in the
coating formulation. The solvent concentration in the wastewater
discharge for model coating operations 1 and 3 is, therefore, based on the
solubility of toluene in water, which is 500 ppm.7 Recovered solvent from
model coating operation 2 requires a distillation system because more than
one solvent is used. A distillation system will provide a solvent purity
of 98 percent with 100 ppm in the water effluent. Recovered solvent from
model coating operation 4 also requires a distillation system because
acetone is used, which is completely miscible in water. A distillation
system will provide a solvent purity of 99.9 percent with 10 ppm in the
water effluent.
The annual wastewater VOC emissions associated with each regulatory
alternative for model coating mix preparation equipment and coating
operations are presented in Tables 7-12 and 7-14, respectively. For model
coating operations 1 and 3, which do not require solvent purification
after decantation, the maximum organic load is 8.2 percent of the total
air emissions shown in Table 7-3. For model coating operation 2, based on
a solvent concentration of 100 ppm in the wastewater discharge, the
maximum organic load is 1.7 percent of the total air emissions shown in
Table 7-3. For model coating operation 4, based on a solvent
concentration of 10 ppm in the wastewater discharge, the maximum organic
load is 0.2 percent of the total air emissions shown in Table 7-3.
The potential impacts of the organics are further lessened because of
the availability of an ample number of water pollution control tech-
nologies. These treatment technologies include recycling the condensate
into the steam-generating stream, which could allow a 95 percent or
7-6
-------
greater reduction of solvent discharge.9 The effects of recycling on
boiler life are undetermined. Other control options are aqueous-phase
carbon adsorption, activated sludge treatment, and oxidation of the
organics.
A National Pollutant Discharge Elimination System (NPDES) permit is
required for polymeric coating wastewaters that are discharged directly to
a receiving stream. The NPDES permit authority establishes the
requirements for each direct discharge. Wastewater from polymeric coating
processes that is discharged to a publicly owned treatment works (POTW)
must meet the requirements in 40 CFR Part 403, General Pretreatment
Regulations, as well as any requirements established by the local POTW.
7.3 SOLID WASTE IMPACTS
7.3.1 Line Impacts
The only solid waste impacts from the add-on control systems result
from the use of carbon adsorption units. The activated carbon in these
units gradually degrades during normal operation. The efficiency of the
carbon eventually drops to a level such that replacement is necessary,
thereby creating a solid waste load. The average carbon life was
estimated to be 5 years. The amount of waste generated annually for
various size lines for each of the regulatory alternatives is presented in
Table 7-15. Annual solid waste disposal impacts range from 36 to 284 kg
(80 to 626 Ib) for model coating operations. Three alternatives are
available for handling the waste carbon material: (1) landfilling the
carbon, (2) reactivating the carbon and reusing it in the adsorber, and
(3) using the carbon as fuel. Landfilling is simple and efficient because
the technology for the operation is considered common practice. No
environmental problems would occur if the landfill site has been properly
constructed. If the site is not secured by a lining of some type (either
natural or artificial), possible soil leaching could occur. The leachate
may contain traces of organics which have been left on the carbon as
residues. Transmission of this leachate into ground and surface waters
would represent a potential environmental impact.
The second and most common alternative for handling the waste carbon
material does not create any significant amount of solid waste. Most of
7-7
-------
the carbon is reactivated and reused in the carbon adsorber. Disposal of
waste carbon represents only 5 to 10 percent of the carbon used. Disposal
of this waste by landfilling poses minimal environmental problems provided
the landfill site is properly constructed.
The third method involves selling the waste carbon as a fuel. The
physical and chemical structure of the carbon in combination with the
hydrocarbon residues make the waste a fuel product similar to other solid
fuels such as coal. Potential users of this fuel include industrial and
small utility boilers. Because activated carbon generally contains very
little sulfur, furnace SOX emissions resulting from combustion would be
negligible.. Particulates and NOX emissions from the burning of activated
carbon would be comparable to those of coal-fired operations. However,
the use of this disposal method would be limited because of the small
quantities of carbon generated by lines in this industry.
7.4 ENERGY IMPACTS
The air emission control equipment for polymeric coating utilizes two
forms of energy: electrical energy and fossil fuel energy. Electrical
energy is used in the carbon adsorber, incinerator, and condensation
control systems. The electrical energy is required to operate fans,
cooling tower pumps and fans, boiler support systems, and all control
system instrumentation. Fuel oil is used in steam generation for fixed-
bed carbon adsorption units, and natural gas is used for supplemental fuel
in incineration units. Electrical energy and steam are also required for
the distillation systems used to separate and purify recovered solvents
from typical sized lines.
7.4.1 Electricity and Fossil Fuel Impacts.
The annual electricity consumption calculated for each model operation
and regulatory alternative is presented in Table 7-16. Table 7-17 shows
the annual natural gas demand for incinerators associated with Regulatory
Alternative IV. Incinerators may use primary or secondary heat recovery
to reduce energy consumption. A heat recovery factor of 35 percent was
used in the energy analysis. Table 7-18 shows the annual steam demand for
each model plant and regulatory alternative. The total annual energy
demand for each regulatory alternative is presented in Table 7-19.
7-8
-------
Comparison of the total energy demand of each regulatory alternative
shows that energy consumption does not increase significantly with
increased VOC control, except for regulatory alternatives requiring
incinerators.
7.5 NATIONWIDE FIFTH-YEAR IMPACTS
Table 7-20 presents the fifth-year impacts at various regulatory
alternatives. These impacts are based on the projection of 18 new coating
lines being built by 1990. Table 7-21 presents the fifth-year impacts at
various regulatory alternatives beyond baseline.
7.6 OTHER ENVIRONMENTAL IMPACTS
The impact of increased noise levels is not a significant problem
with the emission control systems used at polymeric coating plants. No
noticeable increases in noise levels occur as a result of increasingly
stricter regulatory alternatives. Fans and motors present in the majority
of the systems are responsible for the bulk of the noise in the control
operations.
7.7 OTHER ENVIRONMENTAL CONCERNS
7.7.1 Irreversible and Irretrievable Commitment of Resources
As discussed in Section 7.4, the regulatory alternatives will result
in an increase in the irreversible and irretrievable commitment of energy
resources. However, this increased energy demand for pollution control by
carbon adsorption systems, condensers, and incinerators is insignificant
compared to the total line energy demand.
7.7.2 Environmental Impact of Delayed Standard
Because the water pollution and energy impacts are small, there is no
significant benefit to be achieved from delaying the proposed standards.
Furthermore, there does not appear to be any emerging emission control
technology that achieves greater emission reduction or that achieves an
emission reduction equal to that of the regulatory alternatives at a lower
cost than those represented by the control devices considered here.
Consequently, there are no benefits or advantages to delaying the proposed
standards.
7-9
-------
TABLE 7-1. ANNUAL AIR POLLUTION IMPACTS OF THE REGULATORY ALTERNATIVES AND VOC
EMISSION REDUCTION BEYOND BASELINE FOR MODEL SOLVENT STORAGE TANKS
Rubber-coated
industrial fabric
i
f— '
o
Emissions
Reg. Alt. I, Unc.
Mg
tons
Reg. Alt. II, Unc. x 0.3
Mg
tons
Reg. Alt III, Unc. x 0.1
Mg
tons
Reg. Alt. IV, Unc. x 0.05
Mg
tons
A
0.06
0.07
0.02
0.02
0.01
0.01
0.00
0.00
B
0.11
0.12
0.03
0.04
0.01
0.01
0.01
0.01
C
0.27
0.30
0.08
0.09
0.03
0.03
0.01
0.02
Urethane-
coated
fabric
B
a
a
a
a
a
a
a
a
C
a
a
a
a
a
a
a
a
Rubber-
coated cord
A
0.06
0.07
0.02
0.02
0.01
0.01
0.00
0.00
B
0.11
0.12
0.03
0.04
0.01
0.01
0.01
0.01
Epoxy-coated
fiberglass
B
0.11
0.12
0.03
0.04
0.01
0.01
0.01
0.01
C
0.27
0.30
0.08
0.09
0.03
0.03
0.01
0.02
Emission
tion vs.
Reg. Alt. I6
Reg. Alt. II
Mg
tons
0.04 0.08 0.19 a a 0.04 0.08 0.08 0.19
0.05 0.08 0.21 a a 0.05 0.08 0.08 0.21
(continued)
-------
TABLE 7-1. (continued)
Urethane-
Rubber-coated
industrial fabric
Reg. Alt. Ill
Mg
tons
Reg. Alt. IV
Mg
tons
0
0
0
0
A
.06
.06
.06
.07
B
0.10
0.11
0.10
0.11
C
0.24
0.27
0.26
0.29
coated
fabric
B
a
a
a
a
C
a
a
a
a
Rubber-
coated cord
A
0.06
0.06
0.06
0.07
0
0
0
0
B
.10
.11
.10
.11
Epoxy-coated
fiberglass
B
0.10
0.11
0.10
0.11
C
0.24
0.27
0.26
0.29
Not applicable.
}Reg. Alt. I is baseline,
-------
TABLE 7-2. ANNUAL AIR POLLUTION IMPACTS OF THE REGULATORY ALTERNATIVES AND VOC
EMISSION REDUCTION BEYOND BASELINE FOR MODEL COATING MIX PREPARATION EQUIPMENT
Rubber-coated
industrial fabric
Emissions
Reg. Alt. I, Unc.
Mg
tons
Reg. Alt. II, Unc. x 0.6
Mg
tons
Reg. Alt III, Unc. x 0.05
Mg
tons
Emission reduction vs.
Reg. Alt. Ib
Reg. Alt. II
Mg
tons
Reg. Alt. Ill
Mg
tons
A
9.5
10.5
5.7
6.3
0.5
0.5
3.8
4.2
9.0
10.0
B
15.4
17.0
9.3
10.2
0.8
0.9
6.2
6.8
14.6
16.2
C
30.8
34.0
18.5
20.4
1.5
1.7
12.3
13.6
29.3
32.3
Urethane-
coated
fabric
B
a
a
a
a
a
a
a
a
a
a
C
a
a
a
a
a
a
a
a
a
a
Rubber-
coated cord
A
9.5
10.5
5.7
6.3
0.5
0.5
3.8
4.2
9.0
10.0
B
15.4
17.0
9.3
10.2
0.8
0.9
6.2
6.8
14.6
16.2
Epoxy-coated
fiberglass
B
15.4
17.0
9.3
10.2
0.8
0.9
6.."
6.8
14.6
16.2
C
30.8
34.0
18.5
20.4
1.5
1.7
12.3
13.6
29.3
32.3
IjNot applicable.
DReg. Alt. I is baseline.
-------
TABLE 7-3. ANNUAL AIR POLLUTION IMPACTS OF THE REGULATORY ALTERNATIVES AND VOC
EMISSION REDUCTION BEYOND BASELINE FOR MODEL COATING OPERATIONS
CO
Rubber-coated
industrial fabric
Emissions
Uncontrolled
Mg
tons
Reg. Alt. I, Unc. x 0.19
Mg
tons
Reg. Alt II, Unc. x 0.1
Mg
tons
Reg. Alt. Ill, Unc. x 0.07
Mg
tons
Reg. Alt. IV, Unc. x 0.04
Mg
tons
A
85.7
94.5
16.3
18.0
8.6
9.5
6.0
6.6
3.4
3.8
B
138.8
153.0
26.4
29.1
13.9
15.3
9.7
10.7
5.6
6.1
C
277.5
306.0
52.7
58.1
27.8
30.6
19.4
21.4
11.1
12.2
Urethane-
coated
fabric
B
154.2
170.0
29.3
32.3
15.4
17.0
10.8
11.9
6.2
6.8
C
308.4
340.0
58.6
64.6
30.8
34.0
21.6
23.8
12.3
13.6
Rubber-
coated cord
A
85.7
94.5
16.3
18.0
8.6
9.5
6.0
6.6
3.4
3.8
138
153
26
29
13
15
9
10
5
6
B
.8
.0
.4
.1
.9
.3
.7
.7
.6
.1
Epoxy-coated
fiberglass
B
138.
153.
138.
153.
13.
15.
9.
10.
5.
6.
8
0
8a
Oa
9
3
7
7
6
1
C
277.5
306.0
277. 5a
306. Oa
27.8
30.6
19.4
21.4
11.1
12.2
(continued)
-------
TABLE 7-3. (continued)
Rubber-coated
industrial fabric
A
B
C
Urethane-
coated
fabric
B
C
Rubber-
coated cord
A
B
Epoxy-coated
fiberglass
B
C
Emission reduction vs.
Reg. Alt. ID
Reg. Alt. II
Mg
tons
Reg. Alt. Ill
Mg
tons
Reg. Alt. IV
Mg
tons
7
8
10
11
12
14
.7
.5
.3
.3
.9
.2
12.5
13.8
16.7
18.4
20.8
23.0
25.0
27.5
33.3
36.7
41.6
45.9
13.9
15.3
18.5
20.4
23.1
25.5
27.8
30.6
37.0
40.8
46.3
51.0
7.7
8.5
10.3
11.3
12.9
14.2
12
13
16
18
20
23
.5
.8
.7
.4
.8
.0
124.9
137.7
129.1
142.3
133.2
146.9
249.7
275.4
258.1
284.6
266.4
293.8
^Emissions are same as uncontrolled.
DReg. Alt. I is baseline.
-------
TABLE 7-4. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR PARTICULATE MATTER
EMISSIONS FROM ELECTRICAL ENERGY GENERATION FOR THE CONTROL EQUIPMENT
01
Rubber-coated
industrial fabric
Emissions
Reg. Alt. III-CAa
(Mix equipment)
kg
Ib
Coating operation
Reg. Alt. I-CA
kg
Ib
Reg. Alt. I-Cond.a
kg
Ib
Reg. Alt. I I-CA
kg
Ib
Reg. Alt. II-Cond.
kg
Ib
A
0.2
0.4
2.9
6.5
28
62
2.9
6.5
28
62
B
0.2
0.3
5.2
11.5
56
124
5.2
11.5
56
124
C
0.3
0.7
9.6
21.1
56
124
9.6
21.1
56
124
Urethane-
coated
fabric
B
b
b
6.5
14.4
56
124
6.5
14.4
56
124
C
b
b
13.0
28.7
56
124
13.0
28.7
56
124
Rubber-
coated cord
A
0.2
0.4
4.1
9.0
28
62
4.1
9.0
28
62
B
0.2
0.3
7.1
15.7
56
124
7.1
15.7
56
124
Epoxy-coated
fiberglass
B
0.2
0.3
b
b
b
b
5.6
12.3
56
124
C
0.3
0.7
b
b
b
b
8.1
17.8
56
124
(continued)
-------
TABLE 7-4. (continued)
a,
Rubber-coated
industrial fabric
Reg. Alt. III-CA
kg
Ib
Reg. Alt. III-Cond.
kg
Ib
Reg. Alt. IV-Inc.a
kg
Ib
A
2.9
6.5
28
62
2.7
5.9
B
5.2
11.5
56
124
4.7
10.4
C
9.6
21.1
56
124
8.7
19.1
Urethane-
coated
fabric
B
6.5
14.4
56
124
5.9
13.1
C
13.0
28.7
56
124
11.8
26.1
Rubber-
coated cord
A
4.1
9.0
28
62
3.7
8.2
B
7.1
15.7
56
124
6.5
14.3
Epoxy-coated
fiberglass
B
5.6
12.3
56
124
5.1
11.2
C
8.1
17.8
56
124
7.3
16.2
CA = carbon adsorber; Cond. = condensation-air refrigeration system; Inc. = incinerator.
Not applicable.
-------
TABLE 7-5. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR SULFUR OXIDE EMISSIONS FROM
ELECTRICAL ENERGY GENERATION FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
Emissions
Reg. Alt. III-CAa
(Mix equipment)
kg
Ib
Coating operation
Reg. Alt. I-CA
kg
Ib
Reg. Alt. I-Cond.a
kg
Ib
Reg. Alt. I I-CA
kg
Ib
Reg. Alt. II-Cond.
kg
Ib
A
8.1
17.8
117
258
1,127
2,484
117
258
1,127
2,484
B
6.1
13.5
208
458
2,254
4,967
208
458
2,254
4,967
C
12.5
27.6
383
844
2,254
4,967
383
844
2,254
4,967
Urethane-
coated
fabric
B
b
b
261
575
2,254
4,967
261
575
2,254
4,967
C
b
b
521
1,149
2,254
4,967
521
1,149
2,254
4,967
Rubber-
coated cord
A
8.1
17.8
163
360
1,127
2,484
163
360
1,127
2,484
B
6.1
13.5
285
629
2,254
4,967
285
629
2,254
4,967
Epoxy-coated
fiberglass
B
6.1
13.5
b
b
b
b
223
491
2,254
4,967
C
12.5
27.6
b
b
b
b
323
713
2,254
4,967
(continued)
-------
TABLE 7-5. (continued)
CD
Rubber-coated
industrial fabric
Reg. Alt. III-CA
kg
Ib
Reg. Alt. III-Cond.
kg
Ib
Reg. Alt. IV-Inc.a
kg
Ib
A
117
258
1,127
2,484
107
236
B
208
458
2,254
4,967
188
415
C
383
844
2,254
4,967
346
764
Urethane-
coated
fabric
B
261
575
2,254
4,967
238
524
C
521
1,149
2,254
4,967
474
1,044
Rubber-
coated
A
163
360
1,127
2,484
148
327
cord
B
285
629
2,254
4,967
259
571
Epoxy-coated
fiberglass
B
223
491
2,254
4,967
203
447
C
323
713
2,254
4,967
294
647
.CA = carbon adsorber; Cond. = condensation-air refrigeration system; Inc. = incinerator.
Not applicable.
-------
TABLE 7-6. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR NITROGEN OXIDE EMISSIONS FROM
ELECTRICAL ENERGY GENERATION FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
A
B
C
Urethane-
coated
fabric
B
C
Rubber-
coated cord
A
B
Epoxy-coated
fiberglass
B
C
Emissions
Reg. Alt
. III-CAa
(Mix equipment)
kg
Ib
Coating
Reg. Alt
kg
Ib
Reg. Alt
kg
Ib
Reg. Alt
kg
Ib
Reg. Alt
kg
Ib
operation
. I-CA
. I-Cond.a
. I I-CA
. II-Cond.
4.0
8.9
59
129
563
1,242
59
129
563
1,242
3.1
6.7
104
229
1,127
2,484
104
229
1,127
2,484
6.3
13.8
191
422
1,127
2,484
191
422
1,127
2,484
b
b
130
287
1,127
2,484
130
287
1,127
2,484
b
b
261
575
1,127
2,484
261
575
1,127
2,484
4.0
8.9
82
180
563
1,242
82
180
563
1,242
3.1
6.7
143
315
1,127
2,484
143
315
1,127
2,484
3.1
6.7
b
b
b
b
111
245
1,127
2,484
6.3
13.8
b
b
b
b
162
356
1,127
2,484
(continued)
-------
TABLE 7-6. (continued)
ro
o
Rubber-coated
Industrial fabric
Reg. Alt. III-CA
kg
Ib
Reg. Alt. III-Cond.
kg
Ib
Reg. Alt. IV-Inc.a
kg
Ib
A
59
129
563
1,242
54
118
B
104
229
1,127
2,484
94
207
C
191
422
1,127
2,484
173
382
Ure thane-
coated
fabric
B
130
287
1,127
2,484
119
262
C
261
575
1,127
2,484
237
522
Rubber-
coated cord
A
82
180
563
1,242
74
164
B
143
315
1,127
2,484
130
285
Epoxy-coated
fiberglass
B
111
245
1,127
2,484
101
224
C
162
356
1,127
2,484
147
324
rCA = carbon adsorber; Cond. = condensation-air refrigeration system; Inc. = incinerator.
Not applicable.
-------
^
IN3
TABLE 7-7. ANNUAL SECONDARY AIR POLLUTION IMPACTS FROM THE
COMBUSTION OF NATURAL GAS FOR THE CONTROL EQUIPMENT
Rubber-coated
industrial fabric
Emissions
Reg. Alt. IV-Inc.a
Part icu late matter
kg
Ib
Carbon monoxide
kg
Ib
Nitrogen oxide
kg
Ib
A
20
44
34
75
350
772
B
35
77
60
132
615
1,356
C
65
143
110
243
1,135
2,502
Urethane-
coated
fabric
B
32
71
55
120
562
1,238
C
64
142
109
241
1,124
2,477
Rubber-
coated cord
A
16
36
28
61
286
631
B
29
63
49
108
503
1,108
Epoxy-coated
fiberglass
B
34
75
58
127
593
1,307
C
49
108
84
184
860
1,895
alnc. - incinerator.
-------
TABLE 7-8. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR PARTICULATE
MATTER EMISSIONS FROM STEAM GENERATION FOR THE CONTROL EQUIPMENT
I
ro
ro
Rubber-coated
industrial fabric
Emissions
Reg. Alt. III-CAa
(mix equipment)
kg
Ib
Coating operation
Reg. Alt. I-CA
kg
Ib
Reg. Alt. I I-CA
kg
Ib
Reg. Alt. II I-CA
kg
Ib
A
7
15
51
111
56
124
58
128
B
11
24
82
181
91
201
94
207
C
21
47
164
361
182
401
188
415
Urethane-
coated
fabric
B
b
b
127
280
137
302
123
270
C
b
b
255
562
275
606
245
541
Rubber-
coated cord
A
7
15
51
111
56
124
58
128
B
11
24
82
181
91
201
94
207
Epoxy-coated
fiberglass
B
11
24
b
b
136
•19
116
257
C
21
47
b
b
271
598
233
513
j*CA = carbon adsorber,
DNot applicable.
-------
TABLE 7-9. ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR SULFUR OXIDE EMISSIONS
FROM STEAM GENERATION FOR THE CONTROL EQUIPMENT
-vl
I
ro
CO
Rubber-coated
industrial fabric
Emissions
Reg. Alt. III-CAa
(mix equipment)
kg
Ib
Coating operation
Reg. Alt. I-CA
kg
Ib
Reg. Alt. I I-CA
kg
Ib
Reg. Alt. III-CA
kg
Ib
A
86
190
661
1,458
736
1,622
760
1,676
B
140
308
1,072
2,363
1,191
2,625
1,230
2,711
C
280
617
2,145
4,728
2,382
5,251
2,461
5,425
Urethane-
coated
fabric
B
b
b
1,663
3,665
1,794
3,955
1,605
3,539
C
b
b
3,334
7,347
3,598
7,930
3,211
7,077
Rubber-
coated cord
A
86
190
661
1,458
736
1,622
760
1,676
B
140
308
1,072
2,363
1,191
2,625
1,230
2,711
Epoxy-coated
fiberglass
B
140
308
b
b
1,775
3,913
1,523
3,356
C
280
617
b
b
3,551
7,826
3,046
6,713
!*CA = carbon adsorber.
bNot applicable.
-------
TABLE 7-10.
ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR NITROGEN OXIDE EMISSIONS
FROM STEAM GENERATION FOR THE CONTROL EQUIPMENT
—1
I
ro
Rubber-coated
industrial fabric
A
B
C
Urethane-
coated
fabric
B
C
Rubber-
coated cord
A
B
Epoxy-coated
fiberglass
B
C
Emissions
Reg. Alt
. III-CAa
(mix equipment)
kg
Ib
Coating
Reg. AH
kg
Ib
Reg. Alt
kg
Ib
Reg. Alt
kg
Ib
operation
. I-CA
. I I-CA
. I I I-CA
22
48
169
371
188
413
194
427
36
79
273
602
303
669
313
691
71
157
547
1,205
607
1,338
627
1,382
b
b
424
934
457
1,008
409
902
b
b
849
1,872
917
2,020
818
1,803
22
48
169
371
188
413
194
427
36
79
273
602
303
669
313
691
36
79
b
b
452
997
388
855
71
157
b
b
905
1,994
776
1,710
?CA = carbon adsorber.
DNot applicable.
-------
TABLE 7-11,
ANNUAL SECONDARY AIR POLLUTION IMPACTS FOR CARBON MONOXIDE EMISSIONS
FROM STEAM GENERATION FOR THE CONTROL EQUIPMENT
INi
O1
Rubber-coated
industrial fabric
A
B
C
Urethane-
coated
fabric
B
C
Rubber-
coated cord
A
B
Epoxy-
coated
fiberglass
B C
Emissions
Reg. Alt
. III-CAa
(mix equipment)
kg
Ib
Coating
Reg. Alt
kg
Ib
Reg. Alt
kg
Ib
Reg. Alt
kg
Ib
operation
. I-CA
. I I-CA
. I I I-CA
2
4
14
31
16
34
16
36
3
7
23
50
25
56
26
58
6
13
46
100
51
111
52
115
b
b
35
78
38
84
34
75
b
b
71
156
76
168
68
150
2
4
14
31
16
34
16
36
3
7
23
50
25
56
26
58
3
7
b
b
38
83
32
71
6
13
b
b
75
166
65
143
j*CA = carbon adsorber.
bNot applicable.
-------
TABLE 7-12. ANNUAL WASTEWATER DISCHARGES AND WASTEWATER VOC EMISSIONS
FROM THE FIXED-BED CARBON ADSORBER CONTROL
OF MODEL COATING MIX PREPARATION EQUIPMENT8
Regulator Alternative III
Wastewater Wastewater VOC
discharge emissions
Model coating line m 10 gal kg Ib
1.
2.
3.
4.
Rubber-coated Industrial fabric
Line designation:
A
B
C
Urethane-coated fabric
Line designation:
B
C
Rubber-coated cord
Line designation:
A
B
Epoxy-coated fiberglass
Line designation:
B
C
36
59
117
a
a
36
59
59
117
9.6
15.5
31.0
a
a
9.6
15.5
15.5
31.0
16
25
51
a
a
16
25
0.4
0.9
35
56
112
a
a
35
56
1.0
2.0
aNot applicable.
7-26
-------
TABLE 7-13. ANNUAL WASTEWATER DISCHARGES FROM THE FIXED-BED CARBON ADSORBER
CONTROL OF MODEL COATING OPERATIONS8
^j
ro
Wastewater discharges
Regulatory
Alternative I
Model coating line
1.
2.
3.
4.
Rubber-coated industrial fabric
Line designation:
A
B
C
Urethane-coated fabric
Line designation:
B
C
Rubber-coated cord
Line designation:
A
B
Epoxy-coated fiberglass
Line designation:
B
C
m3
278
450
900
499
999
278
450
a
a
103 gal
73.5
119
238
132
264
73.5
119
a
a
Regulatory
Alternative II
m3
309
499
999
556
1,110
309
499
499
999
103 gal
81.6
132
264
147
294
81.6
132
132
264
Regulatory
Alternative III
m3
326
530
1,060
586
1,170
326
530
530
1,060
103 gal
86.2
140
279
155
310
86.2
140
140
279
lNot applicable.
-------
TABLE 7-14. ANNUAL WASTEWATER VOC EMISSIONS FROM THE FIXED-BED CARBON ADSORBER
CONTROL OF MODEL COATING OPERATIONS8
-J
t
ro
oo
Wastewater VOC emissions
Model coating line
1.
2.
3.
4,
Rubber-coated industrial fabric
Line designation:
A
B
C
Urethane-coated fabric
Line designation:
B
C
Rubber-coated cord
Line designation:
A
B
Epoxy-coated fiberglass
Line designation:
B
C
Regulatory
Alternative I
kg
120
194
389
46
91
120
194
a
a
Ib
265
428
857
101
201
265
428
a
a
Regulatory
Alternative II
kg
133
216
431
51
102
234
216
4.0
7.7
Ib
294
475
950
112
224
294
475
8.7
17
Regulatory
Alternative III
kg
141
229
454
54
107
141
229
4.k
8.2
Ib
310
504
1,000
118
236
310
504
9.2
18
Not applicable.
-------
TABLE 7-15. ANNUAL SOLID WASTE IMPACTS OF THE REGULATORY ALTERNATIVES ON THEa
MODEL COATING MIX PREPARATION EQUIPMENT AND COATING OPERATIONS
-J
ro
Model coating line
1.
2.
3.
4.
Rubber-coated
industrial fabric
Line designation:
A
B
C
Urethane-coated fabric
Line designation:
B
C
Rubber-coated cord
Line designation:
A
B
Epoxy-coated fiberglass
Line designation:
B
C
•
kg
5
5
9
d
d
5
5
14
28
Regulatory alternatives
-CA*- I-CA
Ib
12
10
20
d
d
12
10
31
61
kg
49
39
80
36
74
49
39
d
d
Ib
108
87
176
80
163
108
87
d
d
I I-CA
kg
52
42
84
39
77
52
42
134
269
Ib
115
93
185
85
171
115
93
297
593
1 1 I-CA
kg
55
44
88
40
112
55
44
116
284
Ib
121
97
195
89
248
121
97
256
626
aThe solid waste impacts are based on an expected carbon life of 5 years and the assumption that
75 percent of the waste carbon is recycled.
bThis regulatory alternative applies to model coating preparation equipment.
^CA = carbon adsorber.
dNot applicable.
-------
TABLE 7-16. ANNUAL ELECTRICAL ENERGY REQUIREMENTS FOR THE CONTROL EQUIPMENT
OF MODEL COATING MIX PREPARATION EQUIPMENT AND COATING OPERATIONS
I
CO
o
Rubber-coated
industrial fabric
Energy requirement
Reg. Alt. III-CAa
(Mix equipment)
GJ
Million Btu
Coating operation
Reg. Alt. I-CA
GJ
Million Btu
Reg. Alt. I-Cond.a
GJ
Million Btu
Reg. Alt. II-CA
GJ
Million Btu
Reg. Alt. II-Cond.
GJ
Million Btu
A
5.1
4.9
75
71
721
683
75
71
721
683
B
3.9
3.7
133
126
1,441
1,366
133
126
1,441
1,366
C
8.0
7.6
244
232
1,441
1,366
244
232
1,441
1,366
Urethane-
coated
fabric
B
b
b
167
158
1,441
1,366
167
158
1,441
1,366
C
b
b
333
316
1,441
1,366
333
316
1,441
1,366
Rubber-
coated cord
A
5.1
4.9
104
99
721
683
104
99
721
683
B
3.9
3.7
183
173
1,441
1,366
183
173
1,441
1,366
Epoxy-coated
fiberglass
B
3.9
3.7
b
b
b
b
'42
135
1,441
1,366
C
8.0
7.6
b
b
b
b
207
196
1,441
1,366
(continued)
-------
TABLE 7-16. (continued)
Rubber-coated
industrial fabric
Reg. Alt. III-CA
GJ
Million Btu
Reg. Alt. III-Cond.
GJ
Million Btu
Reg. Alt. IV-Inc.a
GJ
Million Btu
JJCA = carbon adsorber; Cond.
DNot applicable.
A
75
71
721
683
69
65
B
133
126
1,441 1
1,366 1
120
114
= condensation-ai
C
244
232
,441
,366
222
210
Urethane-
coated
fabric
B
167
158
1,441
1,366
152
144
r refrigeration
C
333
316
1,441
1,366
303
287
system;
Rubber-
coated cord
A
104
99
721
683
95
90
Inc. = i
B
183
173
1,441
1,366
166
157
ncinerator.
Epoxy-coated
fiberglass
B
142
135
1,441
1,366
129
123
C
207
196
1,441
1,366
188
178
-------
TABLE 7-17. ANNUAL NATURAL GAS REQUIREMENTS FOR THE INCINERATOR
CONTROL OF MODEL COATING OPERATIONS
Model coating line
ReguVtory Alternative IV
GJ
10 Btu
1. Rubber-coated industrial fabric
Line designation:
A
B
C
4,200
7,380
13,620
3,980
7,000
12,910
2. Urethane-coated fabric
Line designation:
B
C
3. Rubber-coated cord
Line designation:
A
B
4. Epoxy-coated fiberglass
Line designation:
B
C
6,740
13,484
3,440
6,030
7,120
10,320
6,390
12,780
3,260
5,720
6,750
9,780
7-32
-------
TABLE 7-18. ANNUAL STEAM REQUIREMENTS FOR THE CONTROL EQUIPMENT FOR
MODEL COATING MIX PREPARATION EQUIPMENT AND MODEL COATING OPERATIONS
I
CO
GO
Rubber-coated
industrial fabric
Steam requirement
Reg. Alt. III-CA3
(Mix equipment)
GJ
Million Btu
Coating operation
Reg. Alt. I-CA
GJ
Million Btu
Reg. Alt. I I-CA
GJ
Million Btu
Reg. AH. II I-CA
GJ
Million Btu
A
100
95
768
728
855
810
883
837
B
162
154
1,244
1,180
1,383
1,311
1,429
1,354
C
325
308
2,491
2,361
2,767
2,622
2,858
2,709
Urethane-
coated
fabric
B
b
b
1,931
1,830
2,084
1,975
1,864
1,767
C
b
b
3,871
3,669
4,178
3,960
3,729
3,534
Rubber-
coated cord
A
100
95
768
728
855
810
883
837
B
162
154
1,244
1,180
1,383
1,311
1,429
1,354
Epoxy- coated
fiberglass
B
162
154
b
b
2,062
1,954
1,768
1,676
C
325
308
b
b
4,123
3,908
3,536
3,352
CA = carbon adsorber.
Not applicable.
-------
TABLE 7-19. TOTAL ANNUAL ENERGY DEMAND OF CONTROL EQUIPMENT FOR THE MODEL
COATING MIX PREPARATION EQUIPMENT AND COATING OPERATIONS
I
CO
Rubber-coated
industrial fabric
A
B
C
Urethane-
coated
fabric
B
C
Rubber-
coated cord
A
B
Epoxy-coated
fiberglass
B
C
Energy requirement
Reg. Alt. III-CAa
(Mix equipment)
GJ
Million
Btu
105
100
166
158
333
316
b
b
b
b
105
100
166
158
166
158
333
316
Coating operation
Reg. Alt.
GJ
Million
Reg. Alt.
GJ
Million
Reg. Alt.
GJ
Million
Reg. Alt.
GJ
Million
I-CA
Btu
I-Cond.a
Btu
I I-CA
Btu
II-Cond.
Btu
843
799
721
683
930
882
721
683
1,377
1,305
1,441
1,366
1,516
1,437
1,441
1,366
2,735
2,592
1,441
1,366
3,011
2,854
1,441
1,366
2,097
1,988
1,441
1,366
2,250
2,133
1,441
1,366
4
3
1
1
4
4
1
1
,204
,985
,441
,366
,511
,276
,441
,366
872
827
721
683
959
909
721
683
1,427
1,353
1,441
1,366
1,566
1,484
1,441
1,366
b
b
b
b
2,204
2,UD
1,441
1,366
b
b
b
b
4,330
4,104
1,441
1,366
(continued)
-------
TABLE 7-19. (continued)
I
CO
en
Rubber-coated
industrial fabric
Reg. Alt.
GJ
Million
Reg. Alt.
GJ
Million
Reg. Alt.
GJ
Million
III-CA
Btu
III-Cond.
Btu
IV-Inc.a
Btu
A
959
909
721
683
4,269
4,047
B
1,562
1,480
1,441
1,366
7,502
7,110
C
3,103
2,941
1,441
1,366
13,843
13,121
Urethane-
coated
fabric
B
2,031
1,925
1,441
1,366
6,894
6,534
4
3
1
1
13
13
C
,062
,850
,441
,366
,787
,068
Rubber-
coated cord
A
988
936
721
683
3,531
3,347
B
1,612
1,528
1,441
1,366
6,196
5,872
Epoxy-coated
fiberglass
B
1,910
1,811
1,441
1,366
7,246
6,868
C
3,743
3,547
1,441
1,366
10,503
9,955
j*CA = carbon adsorber; Cond. = condensation-air refrigeration system; Inc. = incinerator.
DNot applicable.
-------
TABLE 7-20. FIFTH-YEAR IMPACTS OF VARIOUS REGULATORY ALTERNATIVES
FOR COATING LINESa
Emissions
VOC
Reg. Alt.
Storage tanks
I
II
III
IV
Mg
2.0
0.6
0.2
0.1
tons
2.2
0.66
0.22
0.11
Wastewater
m3
0
0
0
0
103 gal
0
0
0
0
Solid waste
kg
0
0
0
0
Ib
0
0
0
0
Energy
TJ
0
0
0
0
10y Btu
0
0
0
0
Coating mix
preparation
equipment
u>
en
I
II
III
Coating operation
I
II
III
IV
254
152
13
1,285
321
225
128
280
168
14
1,416
354
248
142
0
0
967
7,715
11,343
12,230
0
0
0
255
2,038
2,996
3,231
0
0
0
141
733
1,583
1,676
0
0
0
311
1,615
3,489
3,695
0
0
0
2.7
27.1
42.5
39.9
147.4
0
0
2.6
25.7
40.3
37.9
139.8
Coating line includes the storage tanks, coating mix preparation equipment, and coating operation.
-------
TABLE 7-21.
FIFTH-YEAR IMPACTS OF VARIOUS REGULATORY ALTERNATIVES
OVER BASELINE FOR COATING LINES
Emissions
VOC
Reg. Alt.
Storage tanks
II
III
IV
Mg
-1.40
-1.80
-1.90
tons
-1.54
-1.98
-2.09
Wastewater
m3
0
0
0
103 gal
0
0
0
Solid waste
kg
0
0
0
Ib
0
0
0
Energy
TJ
0
0
0
109 Btu
0
0
0
I
CO
Coating mix
preparation
equipment
II
III
-102
-241
-112
-266
0
967
0
255
0
141
0
311
0.0
2.7
0.0
2.6
Coating operation
II -964 -1,062
III -1,060 -1,168
IV -1,156 -1,275
3,628
4,515
-7,715
958
1,193
-2,038
850
943
-733
1,874
2,080
-1,615
15.4
12.8
120.3
14.6
12.2
114.1
-------
7.8 REFERENCES FOR CHAPTER 7
1. The Final Set of Analysis of Alternative New Source Performance
Standards for New Coal-Fired Power Plants. June 1979. ICF Inc.,
Washington, D.C. p. C-III-3C.
2. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 22, 1984. Calculation of
environmental and energy impacts.
3. Environmental Protection Agency General Regulations on Standards of
Performance for New Stationary Sources. Code of Federal Regulations.
Title 40, Chapter I, Subchapter C, Part 60, Subpart Da. July 1,
1979. Environmental Reporter. January 22, 1982.
pp. 121:1518.11-121:1526.
4. Compilation of Air Pollution Emission Factors. 3rd Edition. U. S.
Environmental Protection Agency. Research Triangle Park, North
Carolina. Publication No. 999-AP-42. April 1981. pp. 1.4-1 - 1.4-3.
5. Reference 4. pp. 1.3-1 - 1.3-5.
6. Telecon, Thorneloe, S., MRI, with Schweitzer, P., Chempro. August 29
and 30, 1984. Information on solvent purification requirements for
model coating lines.
7. Perry, R. and C. Chilton. Chemical Engineers' Handbook. Fifth
Edition. McGraw-Hill Book Company. 1973. p. 3-43.
8. Memorandum from Thorneloe, S., MRI, to Polymeric Coating of Supporting
Substrates Project File. October 24, 1984. Wastewater discharge and
waterborne VOC emission calculations.
9. IT Enviroscience. Assessment of the Impact of Untreated Steam
Condensate From Planned Vapor-Phase Carbon Adsorption Systems in
Selected Industries. Prepared for U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina. Undated.
7-38
-------
8. COSTS
This chapter presents the process and control costs for each of the
model plants for new, modified, or reconstructed facilities. Emphasis is
placed on the incremental control cost impacts of implementing the various
regulatory alternatives presented in Chapter 6. Model plant design and
operating parameters are also presented in Chapter 6. The costs presented
in the following sections provide input for the economic impact analysis
described in Chapter 9.
Capital and annualized costs are presented for an uncontrolled plant
and for the pollution control devices for the various regulatory
alternatives. All costs are reported in first quarter 1984 dollars.
8.1 COST ANALYSIS OF REGULATORY ALTERNATIVES
Regulatory alternatives were developed to represent various
emission control levels that are achievable based on available emission
control equipment. Model plants and lines were developed to evaluate
the economic and environmental impacts to implement the regulatory
alternatives. A model polymeric coating plant includes a single coating
operation and associated solvent storage tanks and coating mix
preparation equipment. A model coating operation is defined as the
coating application/flashoff area and associated drying oven required to
manufacture polymeric coated substrates. Four model coating operations
were selected to characterize the manufacturing operations that are
expected to be constructed, modified, or reconstructed in the near
future. The solvent storage tanks for the model plants are those tanks
required to store and supply solvents to the model coating mix
preparation equipment. The coating mix preparation equipment for the
model plant includes the preparation equipment (mixers and holding
tanks) required to supply mixed coatings to the model coating operation.
8-1
-------
The following sections of this chapter present the capital and
annualized costs to construct, install, and operate model coating
operations, storage tanks, and mix preparation equipment. Also, the
installed capital cost, operating cost, annualized cost, and cost
effectiveness to implement the emission control systems on which the
regulatory alternatives are based are analyzed for each model plant. A
discussion about the costs of modified or reconstructed facilities is also
presented.
8.1.1 Capital and Annualized Costs of Model Plants
Table 8-1 presents the factors that are used to calculate the
annualized costs. Tables 8-2 through 8-4 present the estimated capital
and annualized costs for the uncontrolled model solvent storage tanks,
coating mix preparation equipment, and coating operations. The installed
capital costs presented in these tables are based on conversations with
equipment vendors and include the cost of solvent storage tanks; mixers
and holding tanks; and coating application equipment, associated drying
oven, substrate unwinders and rewinders, and other ancillary equipment,
i _it
respectively for the three model facilities. Building and land costs
were also included in the capital cost estimates for the model coating mix
preparation equipment and coating operation.
The annualized costs for solvent storage tanks include maintenance
and inspection costs, taxes, insurance, administration, and the annual
capital charge. The annual capital charge is the cost associated with
recovering the initial capital investment over the depreciable life of the
equipment and is calculated by multiplying the total installed capital
cost by the capital recovery factor. The capital recovery factor is based
on the depreciable life of the equipment and a 10 percent interest rate.
The annualized costs for the coating mix preparation equipment and
the coating operation are the sum of the annual operating and maintenance
costs, plus the annual capital charge. The operating costs include
operating labor, supervision, raw materials, utilities, and overhead. The
land cost is not included in the capital recovery charge; it is multiplied
by the interest rate to obtain the annual interest charge on the money
invested in the land.
8-2
-------
Tables 8-5 through 8-8 present the total installed capital and
annualized costs for the control devices associated with Regulatory
Alternatives II and III (Regulatory Alternative I is uncontrolled) for
model solvent storage tanks and coating mix preparation equipment. The
capital cost of the conservation vents for the solvent storage tanks and
coating mix preparation equipment (Regulatory Alternative II) are based on
vendor quotes.5 The capital costs of the pressure relief valves (RA III)
for the storage tanks are based on an engineering study performed to
determine the capital and annualized costs of these valves. The capital
cost of the carbon adsorber presented in Table 8-9 is the incremental cost
that would be incurred because of the addition of solvents from coating
mix preparation equipment control to the solvent emissions to be
controlled from the coating operation. The ductwork costs are calculated
based on information from the Richardson Engineering Manual. "Saved"
solvent credit (Tables 8-5, 8-6, and 8-8) is based on the current market
price of the solvents that are prevented from being emitted to the
atmosphere by use of conservation vents and pressure relief valves.
Similarly, the recovered solvent credit (Tables 8-7 and 8-9 through 8-15)
is based on the current market price of the solvents that are recovered by
the control device.
The capital and annualized costs for carbon adsorber control that
achieves the levels of Regulatory Alteratives I through III for model
coating operations are presented in Tables 8-10 through 8-12. The capital
costs of the control device are based on information from model plant
parameters and the Economic Analysis Branch (EAB) Control Cost manual.8
The control device capital costs include costs for control device itself,
as well as auxiliary equipment and indirect installation charges.
Distillation system costs are included for model operations using solvent
blend and water-soluble solvent (acetone). The annualized costs include
the annual operating, maintenance, and capital recovery charges and are
based on factors from the EAB Control Cost manual (Table 8-1). Again, the
recovered solvent credit is the value of the solvents recovered by the
control device.
The capital and annualized costs for condensation system control
that achieves the levels of Regulatory Alternatives I through III for
8-3
-------
model coating operations are presented in Tables 8-13 through 8-15. The
capital cost of the control device is based on information provided by the
equipment vendor for one particular case; then, a logarithmic relationship
known as the six-tenths-factor rule is used to estimate the equipment
costs given various model coating operation parameters. • The
annualized costs are based on information from the equipment vendor and
EAB Control Cost manual (Table 8-1). One advantage of using a
condensation system is that a major portion of oven exhaust can be
recirculated back to the oven after being cleaned of the solvents. This
recirculated air is heated in a heat exchanger with the hot oven exhaust
directed to the condensation system. Since this recirculated air is at a
higher temperature than ambient air, reduction in heating requirements of
the oven make-up air results, thereby reducing the energy costs.
The capital and annualized costs for incinerator control to achieve
the level of Regulatory Alternative IV are presented 1n Table 8-16. The
capital costs of the control device are based on Information from model
plant parameters and EAB Control Cost manual. The capital costs include
costs for incinerator, heat exchanger, fan or blower, damper controls, and
instrumentation. Incinerator costs are based on design factors including
operating temperature of 815°C (1500°F), residence time of 0.5 seconds,
and 35 percent heat recovery.
8.1.2 Cost Effectiveness
The cost-effectiveness value is the annual cost to control 1 Mg (ton)
of VOC pollutant. The average cost-effectiveness value is the annualized
cost per Mg (ton) of pollutant required to implement a control system
achieving greater VOC reduction than that which is most commonly being
used at present (baseline). The average cost effectiveness of an
alternative was determined by dividing the incremental annualized control
system cost by the incremental annual VOC reduction. The Incremental
annual cost is the difference in the net annualized cost of the
alternative compared to baseline. The incremental VOC reduction is the
difference in the VOC reduction of the alternative compared to baseline.
The incremental cost effectiveness 15 a measure of the additional
annual cost required to achieve the next higher level of emission
8-4
-------
reduction. The incremental cost effectiveness was calculated by dividing
the incremental increase in the annual control device cost by the
incremental emission reduction.
The average and incremental cost-effectiveness values for the various
regulatory alternatives for model solvent storage tanks and mix
preparation equipment are presented in Tables 8-17 and 8-18,
respectively. The average and incremental cost-effectiveness values for
various regulatory alternatives for model coating operations using carbon
adsorber control for Alternatives I through III and incinerator control
for Alternative IV are presented in Table 8-19, and using condensation
system control for Alternatives I through III and incinerator control for
Alternative IV are presented in Table 8-20.
As shown in Table 8-17, the incremental cost effectiveness ranges
from $800/Mg ($730/ton) for conservation vent controlling emissions from a
storage tank to $380,270/Mg ($344,900/ton) for a common carbon adsorber
controlling emissions from storage tanks and model coating operations.
Table 8-18 shows that the incremental cost effectiveness ranges from
$-412/Mg ($-375/ton) for conservation vent controlling emissions from
coating mix preparation equipment to $l,127/Mg ($l,023/ton) for a common
adsorber controlling emissions from coating mix preparation equipment and
model coating operations.
The incremental cost effectiveness for the model coating operations
(Table 8-19) ranges from $-794/Mg ($-720/ton) for a carbon adsorber
controlling emissions from a coating operation to $27,862/Mg ($25,271/ton)
for an incinerator controlling emissions from a coating operation. The
incremental cost effectiveness ranges from $-932/Mg ($-846/ton) for
condensation system control to $37,886/Mg ($34,363/ton) for an incinerator
controlling emissions from a coating operation (Table 8-20).
8.1.3 Modified/Reconstructed Facilities
Under the provisions of 40 CFR 60.14 and 60.15, an "existing
facility" may become subject to standards of performance if it is deemed
modified or reconstructed. In such situations, control devices may have
to be installed for compliance with new source performance standards
(NSPS).
8-5
-------
The cost for installing a control system on an existing facility may
be greater than the cost of installing the control system on a new
facility. Because retrofit costs are highly site-specific, they are
difficult to estimate. The availability of space and the configuration of
existing equipment in the plant are the major limiting site-specific
factors.
8.2 OTHER COST CONSIDERATIONS
In addition to costs associated with the Clean Air Act, the polymeric
coating plants may also incur costs as a result of other Federal rules or
regulations. These impacts are discussed in this section.
8.2.1 Costs Associated with Increased Water Pollution and Solid Waste
Disposal
Wastewater disposal problems arise from the use of carbon adsorption
solvent recovery systems. Dissolved solvents in the condensate from the
carbon adsorber represent the primary potential water pollutant. Because
of the distillation involved in the solvent recovery system (for model
operations using solvent blend and water-soluble acetone), the aqueous
bottoms contain from 70 to 5,500 ppm solvent, with a typical value of less
1 2
than 500 ppm. This wastewater is usually disposed of in a municipal
sewer system following treatment in a stripper column in the distillation
system. The actual amount of any surcharges would be determined by local
regulations. In any event, it is unlikely that such charges would be
significant.
Solid waste consists of the spent carbon used in carbon adsorption
systems. The carbon from fixed-bed and fluidized-bed carbon adsorbers is
usually sold back to processors, reactivated, and then sold again to the
original purchaser or to other carbon adsorber operators; therefore, there
are no solid waste disposal costs associated with these systems.
8.2.2 Resource Conservation and Recovery Act
The liquid solvent wastes generated by the air pollution control
devices associated with the polymeric coating plants are classified as
hazardous or toxic under the provisions of the Resource Conservation and
8-6
-------
Recovery Act (RCRA). However, there are no liquid solvent wastes
generated because all of the solvents that are recovered are reused.
8.2.3 Resource Requirements Imposed on State, Regional, and Local
Agencies
The owner or operator of a polymeric coating plant is responsible for
making application to the State for a permit to construct and subsequently
to operate a new installation. The review of these applications and any
later enforcement action would be handled by local, State, or regional
regulatory agencies. It is expected that these plants will be distributed
throughout the United States instead of clustered in one State and that
they will be added primarily in States already having polymeric coating
plants. Therefore, the promulgation of standards for polymeric coating
plants should not impose major resource requirements on the regulatory
agencies. Any costs incurred are not expected to limit the financial
ability of these plants to comply with the proposed NSPS.
8-7
-------
TABLE 8-1. BASIS FOR ESTIMATING ANNUALIZED COSTS-
NEW FACILITIES
(First Quarter 1984 Dollars)
Cost element
Cost factor
Direct operating costs
1. Utilities
A. Electricity
B. Steam
C. Cooling water
D. Natural gas
2. Operating labor
A. Direct labor
B. Supervision
3. Maintenance
A. Labor (hourly rate of 1056 premium over
operating labor)
B. Material parts
4. Replacement material
A. Activated carbon
Indirect operating costs
5. Overhead
6. Capital charges
A. Administrative
B. Property tax
C. Insurance
D. Capital recovery factor3
$0.056/kWh
$7.96/10, Ib
$0.13/10 gal
$3.13/Mcf
$7.60/h
15% of 2A
$8.36/h
100% of 3A
$1.35/lb
80% of 2A+2B+3A
2% of capital cost
1% of capital cost
1% of capital cost
0.16275
lBased on 10 percent interest rate and an equipment life of 10 years.
8-8
-------
TABLE 8-2. CAPITAL AND ANNUALIZED COSTS FOR SOLVENT STORAGE TANKS1'8'16
(First Quarter 1984 Dollars)
Cost
I.
1.
II.
1.
III.
1.
2.
CO
1
UD
3.
IV.
item
Capital costs
Total installed costs: a
Direct operating costs
Inspection and maintenance:
Indirect operating costs
Taxes, insurance, administration:
(0.04)(I)
Capital recovery charges:
(0.11746)(I)C
Total indirect costs: (1 + 2)
Total annualized costs (II + III)
Rubber- coated
industrial fabric
ABC
9,400 11.000 12,700
560 660 760
380 440 510
1,100 1,290 1,490
1,480 1.730 2,000
2,040 2,390 2,760
Urethane-coated Rubber-coated Epoxy-coated
fabric cord fiberglass
B C A B B
b b 9,400 11.000 11,000
b b 560 660 660
b t 380 440 440
b b 1,100 1,290 1,290
b b 1,480 1,730 1,730
t b 2,040 2,390 2,390
C
12,700
760
510
1,490
2,000
2.760
aBased on vendor quote.
''Not applicable—coatings are bought premixed; no solvent storage tanks used.
cBas«J on 10 percent interest rate and an equipment life of 20 years.
-------
TABLE 8-3. CAPITAL AND ANNUALIZED COSTS FOR COATING MIX PREPARATION EQUIPMENT
(First Quarter 1984 Dollars)
2^17
Rubber- coated
Industrial fabric
Cost 1ten
I.
1.
2.
3.
4.
5.
6.
II.
1.
» 2.
H- »
0
3:
4.
III.
1.
2.
3.
IV.
Capital costs
Coating preparation equipment:9
Purchased equipment cost: (1.18)(1)
Equipment Installed cost: (1.102)(2)
Building: (0.29)(2)
Land: (0.06)(2)
Total Installed costs: (3+4+5)
Direct operating costs
Labor:
-Operator
-Supervisory
Maintenance:
-Labor
-Parts
Utilities:
-Electricity3
Total direct costs: {1 t 2 r 3)
Indirect operating costs
Overhead :
Capital charges :c
Total indirect costs: (1 + 2)
Total annualized costs (II + III)
A
19.200
22.660
24.970
6.570
1.360
32,900
7.600
1.140
8.360
8.360
670
26.130
13,680
5,100
18.780
44.910
B
24,300
28,670
31,590
8,310
1,720
41,620
15,200
2.280
16.720
16.720
1.670
52.590
27,360
6.460
33,820
86,410
C
48.550
57.290
63.130
16.610
3,440
83.180
15,200
2,280
16.720
16.720
3.340
54.260
27,360
12,900
40,260
94.520
Urethane- coated
fabric
B
b
b
b
b
b
t
b
.b
t
b
b
b
b
b
b
b
C
t
b
b
b
b
b
b
b
b
b
t
t
t
t
t
b
Rubber- coated
cord
A
14,150
16.700
18,400
4,850
1.000
24.250
7.600
1,140
8,360
8,360
500
25,960
13,680
3,760
17,440
43,400
B
19.200
22.660
24,970
6.570
1,360
32,900
15.200
2.280
16.720
16.720
1,340
52,260
27.360
5,100
32,460
84.720
Epoxy-coated
fiberglass
B
48,500
57,230
63,070
16.600
3,430
83.100
15.200
2.280
16.720
16,720
5.850
56.770
27,360
12.890
40.250
97.020
C
97.950
115.580
127.370
33,520
6.930
167,820
15,200
2,280
16,720
16,720
10.530
61,450
27.360
26.030
53,390
114,840
aBased on industry and vendor data.
Not applicable—coatings are bought preraixed; no coating preparation tanks used.
"•Administration, taxes, and capital recovery costs, equal to 15.746 percent of total installed equipment costs (excluding land costs).
total direct land costs by a 10 percent interest rate to estimate the annual interest charge on money invested in the land.
Land costs are included by multiplying
-------
00
I
TABLE 8-4. CAPITAL AND ANNUALIZED COSTS FOR COATING OPERATIONS '
(First Quarter 1984 Dollars)
18
Rubber- coated
industrial fabric
Cost
I.
1.
2.
3.
4.
5.
6.
II.
1.
2.
3.
4.
5.
III.
1.
2.
3.
IV.
item
Capital costs
Coating operation:6
Purchased equipment cost: (l.I8)(I)
Equipment installed cost: (1.102)(2)
Building: (0.29)(2)
Land: (0. 06}(2)
Total installed costs: (3 + 4 * 5)
Direct operating costs
Labor:
-Operator
-Supervisory
Raw materials:3
-Substrate
-Coatings
Maintenance:
-Labor
-Parts
Utilities:
-Electricity3
-Natural gas
Total direct costs: (1 + 2 + 3 + 4)
Indirect operating costs
Overhead:6
Capital charges :c
Total indirect costs: (1 + 2)
Total annualized costs (II + III)
A
389,000
459,000
506,000
133,100
27,500
666,600
45,600
6,840
295.640
268,140
16,720
16,720
210
2,100
651.970
55,330
103,380
158,710
810,680
B
389,000
459.000
506,000
133,100
27,500
666,600
91,200
13,680
478,620
434,100
33,440
33,440
420
3,400
1.088,300
110,660
103,380
214,040
1,302,340
C
389,000
459,000
506,000
133,100
27,500
666,600
91,200
13,680
957,250
868.200
33.440
33,440
420
6,800
2,004,430
110,660
103,380
214,040
2,218.470
Urethane- coated
fabric
B
501 .000
591,000
651,000
171,400
35,500
857.900
121.600
18,240
4,764,400
566,300
33.440
33,440
1.920
6,640
5,545,980
138,620
133,050
271,670
5.817.650
C
501,000
591,000
651,000
171,400
35,500
857,900
121,600
18,240
9,534,600
1,133,300
33,440
33,440
1,920
13,280
10,889,820
138,620
133,050
271.670
11,161,490
Rubber-coated
cord
A
615,000
726,000
800,000
210,500
43.600
1,054.100
30,400
4.560
579,400
51,950
16,720
16.720
1.380
5,970
707,100
41.340
163,470
204,810
911,910
B
615,000
726,000
800.000
210,500
43,600
1,054,100
60,800
9,120
937,840
84,100
33,440
33.440
2,760
9,700
1,171,200
82,690
163,470
246.160
1,417,360
Epoxy-coated
f iberqlass
B
397,000
468,000
516,000
135,700
28.100
679.800
121,600
18,240
2,268,200
1.932.000
33.440
33,440
1,090
3,640
4,411,650
138,620
105,430
244,050
4,655,700
C
397.000
468,000
516.000
135.700
28.100
679,800
121,600
18,240
4,536.300
3,864,000
33.440
33,440
1,090
7,280
8,615,390
138,620
105,430
244,050
8.859,440
aBased on industry and vendor data.
''SO percent of the sum of operating, supervisory, and maintenance labor.
"-Administration, taxes, and capital recovery costs, equal to 15.746 percent of total installed equipment costs (excluding land costs).
total direct land costs by a 10 percent interest rate to estimate the annual interest charge on money invested in the land.
Land costs are included by multiplying
-------
TABLE 8-5. CAPITAL AND ANNUALIZED COSTS OF CONSERVATION VENTS FOR SOLVENT STORAGE TANKS »
(First Quarter 1984 Dollars)
Cost Hen
I. Capital
1. Control
costs
device:*
2. Purchased equipment cost:c
Rubber-coated Urethane- coated Rubber-coated Epoxy-coated
Industrial fabric fabric cord fiberglass
A BC B CA BBC
700 700 700 b b 700 700 700 700
830 830 830 b t 830 830 830 830
(1.18)(No. 1 above)
3. Total Installed cost:d
(1.50)(No. 2 above)
1,240
1,240
1.240
1,240
1,240
fCosts are for two conservation vents for two storage tanks at a price of J350/vent.
bNot applicable.
clncludes costs for Instruments and controls, taxes, and freight.
"Includes Installation direct and indirect costs.
e!6.275 percent capital recovery factor based on 10-year life and 10 percent Interest, plus 4 percent for taxes. Insurance, and administration.
1,240
1,240
co
t— »
r\s
II.
1.
2.
III.
1.
IV.
V.
VI.
Direct operating costs
Labor and maintenance:
Utilities:
Indirect operating costs
Capital recovery charges:
(20.275 percent of total
Installed cost)6
Total annuallzed costs (II + III)
"Saved" solvent credit
Net annuallzed costs (IV - V)
0
0
250
250
17
233
0
0
250
250
29
221
0
0
250
250
72
178
b
b
b
b
b
b
b
t
b
b
b
b
0
0
250
250
17
233
0
0
250
250
29
221
0
0
250
250
39
211
0
0
250
250
97
153
-------
TABLE 8-6. CAPITAL AND ANNUALIZED COSTS OF PRESSURE RELIEF VALVES FOR SOLVENT STORAGE TANKS
(First Quarter 1984 Dollars)
Cost Hen
Rubber-coated
industrial fabric
Urethane-coated
fabric
Rub her-coated
cord
Epoxy-coated
fiberglass
B
I. Capital costs
1. Control device:
2. Purchased equipment cost:
(1.18) (Ho. 1 above)
3. Total installed cost:
(1.50)(No. 2 above)
aNot applicable.
b16.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 4 percent for taxes, insurance, and administration.
CO
1— •
CO
II.
1.
2.
III.
1.
IV.
V.
VI.
Direct operating costs
Labor and maintenance: 0
Utilities: 0
Indirect operating costs
Capital recovery charges: 0
(20. 275 percent of total
installed cost)b
Total annualized costs (II + III) 0
"Saved" solvent credit 22
Net annualized costs (IV - V) -22
0 0 a
Q Q a
0 0 a
0 0 a
37 92 a
-37 -92 a
a 0 000
a 0 000
a 0 000
a 0 000
a 22 37 50 124
a -22 -37 -50 -124
-------
TABLE 8-7. CAPITAL AND ANNUALIZED COSTS FOR COMMON CARBON ADSORBER
FOR CONTROL OF SOLVENT STORAGE TANKS •
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost
I.
1.
2.
3.
4.
5.
II.
1.
00 2-
I 3.
^
4.
item
Capital costs
Control device:8
Purchased equipment cost:
(1.18) (No. 1 above)
Equipment installed cost:
(1.61) (No. 2 above)
Ductwork Installed cost:
Total installed cost: (3 + 4)
Direct operating costs
Labor and maintenance:
Carbon replacement cost at 5-year life:
Utilities:
-Electricity
-Steam
-Cooling water
Total direct costs: (1 + 2 + 3)
A
--
—
17.000
17,000
0
0
0
0
0
0
B
__
—
—
17.000
17,000
0
0
0
0
0
0
C
__
--
--
17.000
17.000
0
0
0
0
0
0
Urethane- coated
fabric
B
b
b
b
b
b
b
b
b
b
b
b
C
b
b
b
b
b
b
b
b
b
t
b
Rubber- coated
cord
A
--
--
17,000
17,000
0
0
0
0
0
0
B
__
--
--
17,000
17,000
0
0
0
0
0
0
E poxy-coated
fiberglass
B
—
—
17.000
17,000
0
0
0
0
0
0
C
--
--
--
17,000
17.000
0
0
0
0
0
0
III. Indirect operating costs
1. Capital recovery charges:
(20.275 percent of total
installed cost)c
3,450
3,450
3,450
3,450
3,450
aNo incremental cost in the carbon adsorber cost.
bNot applicable.
C16.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 4 percent for taxes. Insurance, and administration.
3,450
3,450
IV. Total annual! zed costs (II + III)
V. Recovered solvent credit
VI. Net annuali zed costs (IV - V)
3,450
23
3,427
3.450
39
3,411
3,450
97
3,353
b
b
b
b
b
b
3,450
23
3,427
3.450
39
3,411
3.450
53
3,397
3,450
131
3,319
-------
TABLE 8-8. CAPITAL AND ANNUALIZED COSTS OF CONSERVATION VENTS
FOR COATING MIX PREPARATION EQUIPMENT
(First Quarter 1984 Dollars)
Rubber- coated
Industrial fabric
Cost item
I.
1.
2.
3.
4.
5.
II.
1.
co 2-
«-• in.
CJl
1.
IV.
V.
VI.
Capital costs
Control device:3
Purchased equipnent cost:0
(1.18) (No. 1 above)
Equipment installed cost:
(1.50) (No. 2 above)
Ductwork installed cost:
Total installed cost (3 + 4):
Direct operating costs
Labor and maintenance:
Utilities:
Indirect operating costs
Capital recovery charges:
(20.275 percent of total
installed cost)6
Total annuali zed costs (II + III)
"Saved" solvent credit
Net annualized costs (IV - V)f
A
700
630
1.240
680
1.920
0
0
390
390
1.430
-1,040
B
700
830
1.240
680
1.920
0
0
390
390
2,310
-1.920
C
1.400
1.660
2.480
1.360
3.840
0
0
780
780
4.620
-3,840
Urethane-coated
fabric
B
b
b
b
b
b
b
b
b
b
b
t
C
b
k
b
b
b
b
b
b
b
b
b
Rubber-coated
cord
A
700
830
1.240
680
1,920
0
0
390
390
1.430
-1,040
B
700
830
1,240
680
1.920
0
0
390
390
2,310
-1,920
Epoxy-coated
fiberglass
B
1.050
1.240
1.860
1.020
2.880
0
0
580
580
3,130
-2.550
C
2,450
2,890
4,340
2.380
6.720
0
0
1.360
1,360
6.260
-4,900
aBased on price of the conservation vents of $350/vent.
bNot applicable.
clncludes costs for instruments and controls, taxes, and freight.
''includes installation direct and indirect costs.
e!6.275 percent capital recovery factor based on a 10-year life and 10 percent interest, plus 4 percent for taxes, insurance, and administration.
fNegative value indicates e credit.
-------
cn
TABLE 8-9. CAPITAL AND ANNUALIZED COSTS FOR COMMON CARBON ADSORBER FOR
CONTROL OF COATING MIX PREPARATION EQUIPMENT '
(First Quarter 1984 Dollars)
Rubber- coated
industrial fabric
Cost item
I.
1.
2.
3.
4.
5.
11.
1.
2.
3.
4.
III.
1.
IV.
V.
VI.
Capital costs
Control device:8
Purchased equipment cost:c
(1.18) (No. 1 above)
Equipment installed cost:*'
(1.61) (No. 2 above)
Ductwork installed cost:
Total installed cost: (3 + 4)
Direct operating costs
Operating and maintenance labor
plus materials: (6 percent of
total installed cost)
Carbon replacement cost at 5-year life:
Utilities:
-Electricity
-Steam
-Cooling water
Total direct costs: (1 + 2 + 3)
Indirect operating costs
Capital recovery charges:
(22 percent of total
installed cost)6
Total annual! zed costs (II + III)
Recovered solvent credit
Net annuali zed costs (IV - V)f
A
4.300
5,100
8,200
18,250
26.450
1.585
65
80
635
75
2.440
5,820
8,260
3,390
4.870
B
3,400
4,000
6,500
18,250
24.750
1,485
55
60
1,030
120
2,750
5,445
8,195
5.490
2.705
C
3,700
4,400
7,000
22,680
29.680
1,780
110
125
2,060
240
4,315
6.530
10,845
10,980
-135
Urethane-coated
fabric
B
b
b
b
b
b
b
b.
b
b
b
b
b
b
b
b
C
b
b
b
t
b
b
b
t
b
t
b
t
b
b
b
Rubber-coated
cord
A
4,300
5,100
8,200
18.250
26,450
1.585
65
80
635
75
2,440
5.820
8,260
3,390
4,870
B
3.400
4,000
6.500
18,250
24.750
1,485
55
60
1,030
120
2,750
5,445
8.195
5.490
2.705
Epoxy-coated
fiberglass
B
5,600
6,600
10,600
20,460
31,060
1.865
165
60
1.030
120
3,240
6.830
10,070
7,430
2,640
C
6,900
8.100
13,100
29.930
43.030
2,580
330
125
2,060
240
5,335
9,465
14.800
14,860
0
alncremental cost due to coating preparation equipment control.
bNot applicable.
Clnc1udes costs for instruments and controls, taxes, and freight.
''Includes installation direct and indirect costs.
e!6.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
Negative value indicates a credit.
-------
TABLE 8-10. CAPITAL AND ANNUALIZED COSTS FOR CARBON
OF MODEL OPERATIONS—REGULATORY ALTERNATIVE i
(First Quarter 1984 Dollars)
ADSORBER CONTROL
6—819,20
Rubber-coated
industrial fabric
Cost item
I.
1.
2.
3.
4.
5.
6.
II.
1.
00 2.
' 3.
1^
4.
III.
Capital costs
Control device:3
Purchased equipment cost:c
(1.18) (No. 1 above)
Equipment installed cost:"
(1.61)(No. 2 above)
Ductwork installed cost:
Distillation system installed cost:6
Total installed cost: (3 » 4 + 5)
Direct operating costs
Operating and maintenance labor
plus materials: (6 percent of
total installed cost)
Carbon replacement cost at 5-year life:
Utilities:
-Electricity
-Steam
-Cooling water
Total direct costs: (1 + 2 + 3}
Indirect operating costs
A
115,900
136,800
220,300
65,400
--f
285,700
17,140
1,050
1.170
4,870
600
24,830
B
106,800
126.000
202.800
58.100
—
260.900
15.660
850
2,060
7,890
950
27.410
C
138,900
163.900
263.900
87.900
--
351.800
21,110
1.700
3,800
15.790
1,900
44,300
Urethane- coated
fabric
B
107,900
127.300
205,000
65,400
79,000
349,400
20,970
870
2.590
12.240
1.340
38,010
C
140,000
165,300
266,100
103,000
119,000
488,100
29,290
1,740
5,180
24,540
2,670
63,420
Rubber-coated
cord
A
115,900
136,800
220,300
80,400
--
300,700
18,040
1,050
1,620
4,870
600
26,180
B
106,800
126,000
202,800
72,900
—
275,700
16,540
850
2,840
7,890
950
29,070
Epoxy- coated
fiberglass
B
b
b
b
b
t
b
b
b
t
b
b
b
C
b
b
b
b
b
t
b
t
b
b
b
b
62,850
57,410
77.390
76,870
107,370
66,150
60,660
87.680
26,010
61.670
84.820
42,130
42,690
121,690
84,290
37,400
114,880
122.150
-7.270
170,790
244,390
-73,600
92.330
26,010
66,320
89,730
42,130
47,600
b
b
b
b
b
b
1. Capital recovery charges:
(22 percent of total
installed cost)9
IV. Total annualized costs (II + III)
V. Recovered solvent credit
VI. Net annualized costs (IV - V)h
;^=^:===^z=^=:^===^=^
Includes costs for carbon adsorber, carbon, fans and blowers, controls, condenser, decanter, heat exchanger, etc. A 20 percent allowance was added to the major equipment
purchase cost to compensate for unspecified items.
''Not applicable--no control device needed for Alternative I level for these model lines.
"•Includes costs for instruments and controls, taxes, and freight.
^Includes Installation direct and indirect costs.
eflased on vendor quote.
^Distillation system not needed for these model lines; therefore, no costs.
916.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
Negative value indicates a credit.
-------
00
I
h->
CO
TABLE 8-11. CAPITAL AND ANNUALIZED COSTS FOR CARBON ADSORBER.CONTROL
OF MODEL OPERATIONS—REGULATORY ALTERNATIVE II ' »
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost iten
I.
1.
2.
3.
4.
5.
6.
7.
11.
1.
2.
3.
4.
III.
1.
IV.
V.
VI.
Capital costs
Control device:3
Purchased equipment cost:b
(1.18) (No. 1 above)
Equipnent Installed cost:0
(1.61) (No. 2 above)
Partial enclosure installed cost:d
Ductwork installed cost:
Distillation system installed cost:6
Total installed cost: (3+4+5+6)
Direct operating costs
Operating and maintenance labor plus
materials: (6 percent of total
Installed cost)
Carbon replacement cost at 5-year life:
Utilities:
-Electricity
-Steam
-Cooling water
Total direct costs: (1+2+3)
Indirect operating costs
Capital recovery charges:
(22 percent of total
installed cost)9
Total annual 1 zed costs (II + III)
Recovered solvent credit
Net annual i zed costs (IV - V)h
A
118.700
140,100
225,500
5,700
65,400
__f
296,600
17.800
1,110
1,170
5.420
650
26,150
65.250
91.400
28,930
62.470
B
109,100
128,700
207,200
5.700
58,100
—
271,000
16.260
900
2,060
8,770
1.050
29,040
59,620
88.660
46,820
41,840
C
141.200
166.600
268,200
5,700
87,900
--
361,800
21,710
1.800
3,800
17.540
2.100
46,950
79,600
126.550
93.640
32,910
Urethane- coated
fabric
B
110,200
130,000
209.400
5.700
65.400
79,000
359,500
21.570
920
2.590
13.210
1.490
39,780
79.080
118.860
135,780
-16,920
C
142,300
168,000
270.400
5,700
103,000
119.000
498.100
29,890
1,830
5,180
26,490
2,870
66.260
109.600
175,860
271.480
-95,620
Rubber-coated
cord
A
118,700
140.100
225,500
5,700
80.400
--
311,600
18.700
1.110
1,620
5,420
650
27,500
68,550
96.050
28,930
67,120
B
109.100
128.700
207.200
5.700
72,900
--
285,800
17,150
900
2,840
8,770
1.050
30,710
62,870
93,580
46,820
46,760
Epoxy- coated
fiberglass
B
165.300
195.100
314,000
5,700
65,400
118,000
503,100
30,190
2,880
2,210
13,070
1,520
49.870
110,690
160,560
63,340
97,220
C
225,000
265,500
427.400
5,700
80,400
179,000
692,500
41,550
5,760
3,210
26,140
3,040
79,700
152,360
232,060
126,680
105,380
Includes costs for carbon adsorber, carbon, fans and blowers, controls, condenser, decanter, heat exchanger, etc. A 20 percent allowance was added to the major equipment
purchase cost to compensate for unspecified items.
Includes costs for Instruments and controls, taxes, and freight.
clncludes installation direct and indirect costs.
Installed cost of a capture device obtained from the NSPS development of magnetic tape coating, a similar surface coating operation.
eBased on vendor quote.
'Distillation system not needed for these model lines; therefore, no costs.
916.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
Negative value Indicates a credit.
-------
CO
I
TABLE 8-12. CAPITAL AND ANNUALIZED COSTS FOR CARBON ADSORBER. CONTROL
OF MODEL OPERATIONS—REGULATORY ALTERNATIVE III • »
(First Quarter 1984 Dollars)
Rubber-coated
Industrial fabric
Cost itera
I.
1.
2.
3.
4.
5.
6.
7.
II.
1.
2.
3.
4.
III.
1.
IV.
V.
VI.
Capital costs
Control device:3
Purchased equipment cost:
(1.18) (No. 1 above)
Equipment installed cost:c
(1.61)(No. 2 above)
Total enclosure installed cost:''
Ductwork installed cost:
Distillation system installed cost:6
Total installed cost: (3 + 4 + 5*6)
Direct operating costs
Operating and maintenance labor
plus materials: (6 percent of
total installed cost)
Carbon replacement cost at 5-year life:
Utilities:
-Electricity
-Stean
-Cooling water
Total direct costs: (1 + 2 + 3)
Indirect operating costs
Capital recovery charges:
(22 percent of total
installed cost)9
Total annuali zed costs (II + III)
Recovered solvent credit
Net annualized costs (IV - V)h
A
120,500
142,200
229,000
15,000
65,400
__f
309,400
18,560
1,140
1,170
5,600
700
27.170
68,060
95,230
29,880
65,350
B
110,800
130,700
210,500
15,000
58,100
~
283,600
17,020
930
2,060
9,060
1.100
30,170
62,390
92,560
48,380
44,180
C
142.900
168,600
271.500
15,000
87,900
--
374.400
22.460
1,850
3.800
18,120
2.200
48,430
82.370
130,800
96,760
34,040
Urethane-coated
fabric
B
111,400
131.400
211,500
15,000
65,400
79,000
370,900
22.260
950
2,590
11,820
1.340
38.960
81.610
120,570
140.280
-19,710
C
143,700
169.600
273,000
15,000
103.000
119,000
510,000
30,600
1,890
5,180
23,640
2,680
63.990
112.210
176,200
280,550
-104,350
Rubber- coated
cord
A
120,500
142,200
229,000
15,000
80,400
--
324.400
19,460
1.140
1.620
5.600
700
28,520
71,360
99,880
29,880
70.000
B
110,800
130,700
210,500
15,000
72,900
--
298,400
17,900
930
2.840
9.060
1,100
31.830
65,640
97,470
48,380
49,090
Epoxy-coated
fiberglass
B
167,600
197,800
318,400
15,000
65,400
118,000
516,800
31,010
2,970
2,210
11,210
1.340
48.740
113.700
162.440
65,450
96,990
C
229,600
270,900
436.200
15.000
80,400
179.000
710,600
42,630
5,940
3,210
22.420
2,680
76,880
156,320
233,200
130,900
102,300
Includes costs for carbon adsorber, carbon, fans and blowers, controls, condenser, decanter, heat exchanger, etc. A 20 percent allowance was added to the major equipment
purchase cost to compensate for unspecified items.
''includes costs for instruments and controls, taxes, and freight.
""Includes installation direct and indirect costs.
''installed cost of a capture device obtained from the NSPS development of magnetic tape coating, a similar surface coating operation.
eBased on vendor quote.
^Distillation system not needed for these node) lines; therefore, no costs.
^16.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
^Negative value Indicates a credit.
-------
TABLE 8-13. CAPITAL AND ANNUALIZED COSTS FOR CONDENSAJUWL SYSTEM
CONTROL OF MODEL OPERATIONS—REGULATORY ALTERNATIVE I » • » »
(First Quarter 1984 Dollars)
Rubber- coated
Industrial fabric
Cost Hen
00
i
rsi
I.
1.
2.
3.
4.
5.
6.
II.
1.
2.
3.
4.
Capital costs
Control device:3
Installation cost:8 (0.5)(1)
Equipment Installed cost:3 (1 + 2)
Ductwork Installed cost:
Distillation system Installed
cost:8
Total Installed cost: (3 + 4 + 5)
Direct operating costs
Operating and naintenance labor
plus materials:8
Utilities:
-Electricity8
Heat savings:8
Total direct costs: (1+2+3)
A
100,300
50.150
150,450
17,310
_.c
167,760
2,230
11,200
-1,000
12,430
B
88.500
44,250
132,750
13.960
—
146,710
4,470
22,400
-2,000
24,870
C
134.200
67.100
201.300
24.650
--
225.950
4,470
22,400
-2,000
24,870
Ure thane- coated
fabric
B
84,400
42.200
126.600
17,310
79.000
222,910
4,470
22.400
-2.000
24.870
C
127.900
63.950
191.850
24.650
119.000
335,500
4,470
22,400
-2,000
24.870
Rubber-coated
cord
A
100,300
50.150
150.450
21,120
--
171,570
2.230
11,200
-1.000
12,430
B
88,500
44,250
132,750
17.310
--
150,060
4.470
22,400
-2,000
24,870
Epoxy-coated
fiberglass
B
b
b
b
b
b
t
t
b
b
b
C
b
b
b
b
b
b
fa
b
b
b
III. Indirect operating costs
1. Capital recovery charges:
(-22 percent of total installed
cost)d
36,910
32.280
49,710
49.040
73.810
37,750
33.010
IV. Total annualized costs (II + III)
V. Recovered solvent credit
VI. Net annualized costs (IV - V)e
49,340
26,010
23,330
57,150
42,130
15.020
74.580
84,290
-9,710
73,910
122,180
-48,270
98,680
244,360
-145,680
50,180
26,010
24.170
57,880
42,130
15,750
b
b
t
b
b
b
8Based on vendor quote.
°Hot applicable—no control device needed
Distillation system not needed for these
d!6.275 percent capital recovery based on
eNegat1ve value indicates a credit.
at Alternative I for these model lines.
model lines; therefore, no costs.
10-year life and 10 percent interest, plus
5.725 percent for taxes, insurance, administration, and overhead.
-------
oo
ro
TABLE 8-14. CAPITAL AND ANNUALIZED COSTS FOR CONDENSATION^SYSTEM
CONTROL OF MODEL OPERATIONS—REGULATORY ALTERNATIVE II * ' » •
(First Quarter 1984 Dollars)
Rubber- coated
industrial fabric
Cost item
I.
1.
2.
3.
4.
5.
6.
7.
II.
1.
2.
3.
4.
III.
1.
IV.
V.
VI.
Capital costs
Control device:3
Installation cost:3 (0.5){1)
Equlpnent Installed cost:3 (1+2)
Partial enclosure installed cost:
Ductwork installed cost:
Distillation system installed
cost:3
Total Installed cost: (3 + 4 r 5 + 6)
Direct operating costs
Operating and maintenance labor
plus materials:3
utilities:
-Electricity3
Heat savings:3
Total direct costs: (1 + 2 + 3)
Indirect operating costs
Capital recovery charges:
(22 percent of total installed
cost)d
Total annualized costs (II + III)
Recovered solvent credit
Net annualized costs (IV - V)e
A
100.300
50,150
150,450
5.700
17.310
--c
173.460
2,230
11.200
-1.000
12.430
38,160
50,590
28,930
21.660
B
88.500
44.250
132,750
5,700
13,960
—
152,410
4,470
22,400
-2,000
24,870
33,530
58,400
46,820
11,580
C
134.200
67.100
201.300
5.700
24.650
--
231,650
4,470
22,400
-2.000
24,870
50.960
75.830
93,640
-17,810
Urethane- coated
fabric
B
84.400
42.200
126.600
5.700
17.310
79.000
228.610
4.470
22.400
-2.000
24 ,870
50,290
75,160
135,750
-60,590
C
127,900
63.950
191,850
5.700
24.650
119.000
341.200
4,470
22,400
-2,000
24,870
75,060
99,930
271,500
-171.570
Rubber- coated
cord
A
100.300
50.150
150,450
5.700
21.120
--
177.270
2.230
11.200
-1,000
12,430
39,000
51,430
28,930
22,500
B
88,500
44,250
132,750
5.700
17.310
--
155.760
4.470
22,400
-2,000
24,870
34,270
59,140
46.820
12,320
Epoxy- coated
fiberglass
B
76.200
38.100
114.300
5.700
13.960
118.000
251.960
4.470
22.400
-2.000
24.870
55,430
80,300
63,340
16,960
C
115.500
57,750
173.250
5,700
21.120
179.000
379.070
4,470
22,400
-2,000
24.870
83.390
108.260
126.680
-18,420
3Based on vendor quote.
''installed cost of a capture device obtained from the NSPS development of magnetic tape coating, a
Distillation system not needed for these model lines; therefore, no costs.
^16.275 percent capital recovery factor based on 10-year life and 10 percent interest, pluse 5.725
Negative value indicates a credit.
similar surface coating operation.
percent for taxes, insurance, administration, and overhead.
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00
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ro
ro
TABLE 8-15. CAPITAL AND ANNUALIZED COSTS FOR CONDENSATION .SYSTEM
CONTROL OF MODEL OPERATIONS—REGULATORY ALTERNATIVE III • • • '
(First Quarter 1984 Dollars)
Rubber-coated
Industrial fabric
Cost Hen
I.
1.
2.
3.
4.
5.
6.
7.
II.
1.
2.
3.
4.
Ill
1.
IV.
V.
VI.
Capital costs
Control device:3
Installation cost:3 (O.S)(l)
Equipment Installed cost:8 (1 + 2)
Total enclosure installed cost:b
Ductwork Installed cost:
Distillation system installed
cost:3
Total installed cost: (3+4+5+6)
Direct operating costs
Operating and maintenance labor
plus materials:3
Utilities:
-Electricity3
Heat savings:3
Total direct costs: (1 + 2 + 3)
. Indirect operating costs
Capital recovery charges:
(22 percent of total installed
cost)d
Total annualized costs (II + HI)
Recovered solvent credit
Net annualized costs (IV - V)e
A
100,300
50,150
150,450
15,000
17,310
__c
182,760
2,230
11.200
-1,000
12.430
40,210
52,640
30.530
22,110
B
88.500
44.250
132.750
15.000
13.960
—
161.710
4,470
22.400
-2.000
24.870
35.580
60.450
49.440
11.010
C
134.200
67,100
201,300
15,000
24,650
_-
240.950
4.470
22.400
-2.000
24.870
53.010
77.880
98,840
-20.960
Urethane-coated
fabric
B
84.400
42.200
126.600
15.000
17.310
79.000
237.910
4,470
22,400
-2.000
24.870
52.340
77,210
143,300
-66,090
C
127,900
63,950
191,850
15.000
24.650
119,000
350,500
4,470
22.400
-2.000
24.870
77,110
101,980
286.600
-184,620
Rubber-coated
cord
• A
100,300
50,150
150.450
15.000
21,120
--
186,570
2,230
11,200
-2,000
12.430
41,050
53.480
30.530
22.950
B
88,500
44.250
132.750
15.000
17.310
--
165.060
4.470
22,400
-2,000
24,870
36,310
61.180
49,440
11,740
Epoxy- coated
fiberglass
B
76,200
38.100
114,300
15,000
13,960
118,000
261,260
4,470
22.400
-2.000
24.870
57.480
82,350
66.880
15.470
C
115.500
57,750
173.250
15,000
21,120
179.000
388.370
4.470
22,400
-2.000
24.870
85.440
110,310
133.720
-23,410
3Based on vendor quote.
"Installed cost of a capture device obtained from the HSPS development of magnetic tape coating, a similar surface coating operation.
cDistillation system not needed for these model lines; therefore, no costs.
°16.275 percent capital recovery based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
Negative value indicates a credit.
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TABLE 8-16. CAPITAL AND ANNUALIZED COSTS FOR INCINERATOR,CONTROL
OF MODEL OPERATIONS—REGULATORY ALTERNATIVE IV >»
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost item
CO
i
ro
OJ
I.
1.
2.
3.
4.
5.
6.
7.
II.
1.
Capital costs
Control device:
Purchased equipment cost:3
(1.18) (No. 1 above)
Equipment installed cost:
(1.61) (No. 2 above)
Total enclosure installed cost:c
Ductwork installed cost:
Stack installed cost:
Total installed cost: (3+4+5
Direct operating costs
Operating and maintenance labor
plus materials: (6 percent of
A
115,500
136,300
219,400
15.000
65.400
5,200
+ 6) 305.000
18.300
B
113,600
134,000
215,700
15,000
58,100
5,200
294,000
17.640
C
124,400
146,800
236,300
15,000
87,900
5,200
344,400
20,660
Urethane-coated
fabric
B
114.100
134.600
216.700
15,000
65.400
5,200
302.300
18,140
C
128,000
151,000
243,100
15,000
103,000
5,200
366.300
21,980
Rubber-coated
cord
A
115.500
136.300
219.400
15,000
80.400
5.200
320,000
19.200
B
113,600
134,000
215,700
15,000
72,900
5,200
308.800
18,530
Epoxy-coated
fiberglass
B
113.600
134,000
215,700
15,000
65.400
5,200
301,300
18,080
C
119,700
141.200
227,300
15,000
80.400
5,200
327.900
19.670
total installed cost)
2. Utilities:
-Electricity 1,070 1,870 3.450 2.360 4,710 1,470 2.580 2,010 2,920
-Natural gas 13.800 24.250 44,750 22,150 44,300 11.290 19,810 23,380 33,890
3. Total direct costs: (1 + 2) 33,170 43.760 68.860 42,650 70,990 31,960 40,920 43.470 56.480
III. Indirect operating costs
1. Capital recovery charges: 67.100 64,680 75,770 66,510 80,590 70,400 67,940 66.290 72.140
(22 percent of total
installed cost)d
IV. Total annualized costs (II + 111) 100,270 108,440 144.630 109.160 151,580 102,360 108,860 109.760 128.620
Includes costs for instruments and controls, taxes, and freight.
''includes installation direct and indirect costs.
""Installed cost of a capture device obtained from the NSPS development of magnetic tape coating, a similar surface coating operation.
d!6.275 percent capital recovery factor based on 10-year life and 10 percent interest, plus 5.725 percent for taxes, insurance, administration, and overhead.
-------
co
TABLE 8-17. AVERAGE AND INCREMENTAL COST EFFECTIVENESS OF
REGULATORY ALTERNATIVES FOR STORAGE TANKS, $/Mg ($/ton)
(First Quarter 1984 Dollars)
Rubber- coated
Industrial fabric
Cost item
A
B
C
Urethane-coated
fabric
B
C
Rubber-coated
cord
A
B
E poxy-coated
fiberglass
B
C
Average
1.
2.
3.
Alternative II vs. Ia
Alternative III vs. Ic
Alternative IV vs. ld
5,140
(4,660)
-400
(-370)
53.980
(48.960)
3,050
(2,760)
-370
(-340)
34,190
(31,000)
940
(850)
-380
(-340)
12.750
(11.560)
b
b
b
b
b
b
b
b
b
b
b
b
5.140
(4.660)
-400
(-370)
53.980
(48.960)
3.050
(2,760)
-370
(-340)
34.190
(31.000)
2,910
(2.640)
-500
(-460)
34.050
(30.880)
800
(730)
-510
(-460)
12.620
(11.450)
Incremental
1.
2.
3.
Alternative II vs. Ia
Alternative III vs. IIe
Alternative IV vs. IIIf
5.140
(4.660)
-28,120
(-25,500)
380.270
(344.900)
3,050
(2,760)
-9,480
(-8.600)
377.070
(342.000)
940
(850)
-4.960
(-4.500)
189.900
(172.250)
b
b
b
b
b
t
b
b
b
b
b
b
5.140
(4.660)
-28.120
(-25.500)
380.270
(344.900)
3.050
(2.760)
-9.480
(-8.600)
377,070
(342.000)
2.910
(2.640)
-9,590
(-8.700)
375.970
(341.000)
800
(730)
-5.090
(-4.620)
189,800
(172.150)
aCost effectiveness • Table 8-5 item VI T Table 7-1 VOC emission reduction beyond baseline for Regulatory Alternative II.
"Not applicable.
<-Cost effectiveness = Table 8-6 Item VI f Table 7-1 VOC emission reduction beyond baseline for Regulatory Alternative III.
dCost effectiveness = Table 8-7 item VI -r Table 7-1 VOC emission reduction beyond baseline for Regulatory Alternative IV.
6Cost effectiveness = (Table 8-6 Item VI - Table 8-5 Item VI) f (Table 7-1 VOC enission at Regulatory Alternative II - Table 7-1 VOC emission at Regulatory
Alternative III).
fCost effectiveness = (Table 8-7 1ten VI - Table 8-6 Item VI) f (Table 7-1 VOC emission at Regulatory Alternative III - Table 7-1 VOC emission at Regulatory
Alternative IV).
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00
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en
TABLE 8-18. AVERAGE AND INCREMENTAL COST EFFECTIVENESS OF
REGULATORY ALTERNATIVES FOR COATING MIX PREPARATION EQUIPMENT, $/Mg ($/ton)
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost Item
A
B
C
Urethane- coated
fabric
B
C
Rubber- coated
cord
A
B
Epoxy-coated
fiberglass
B
C
Average
1.
2.
Alternative II vs. Ia
Alternative III vs. Ic
-273
(-248)
537
(488)
-310
(-282)
185
(169)
-310
(-282)
-4
(-4)
b
b
b
b
b
b
b
b
-273
(-248)
537
(488)
-310
(-282)
185
(168)
-412
(-375)
180
(163)
-396
(-360)
-2
(-2)
Incremental
1.
2.
Alternative II vs. Ia
Alternative III vs. Hd
-273
(-248)
1.137
(1.023)
-310
(-282)
545
(495)
-310
(-282)
218
(198)
b
b
b
b
b
b
b
b
-273
(-248)
1.137
(1.023)
-310
(-282)
545
(495)
-412
(-375)
611
(555)
-396
(-360)
285
(259)
*Cost effectiveness » Table 8-8 item VI + Table 7-2 VOC emission reduction beyond baseline for Regulatory Alternative II.
bNot applicable.
'Cost effectiveness • Table 8-9 Item VI + Table 7-2 VOC emission reduction beyond baseline for Regulatory Alternative III.
''Cost effectiveness > (Table 8-9 item VI - Table 8-8 item VI) + (Table 7-2 VOC emission at Regulatory Alternative II - Table 7-2 VOC emission at Regulatory
Alternative III).
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CO
I
rv>
CTi
TABLE 8-19. AVERAGE AND INCREMENTAL COST EFFECTIVENESS OF REGULATORY ATERNATIVES
FOR MODEL COATING OPERATIONS (Using Carbon Adsorber or Incinerator), $/Mg ($/ton)
(First Quarter 1984 Dollars)
Rubber- coated
industrial fabric
Cost 1ten
Average
1. Alternative II vs. Ia
2. Alternative III vs. Ib
3. Alternative IV vs. Ic
Increnental
1. Alternative II vs. Ia
2. Alternative III vs. IId
3. Alternative IV vs. Ill6
A
103
(93)
357
(324)
2.997
(2,718)
103
(93)
1.138
(1,032)
13,746
(12,468)
B
-68
(-62)
89
(80)
3.152
(2.859)
-68
(-62)
558
(507)
15.404
(13,972)
C
-180
(-163)
-101
(-91)
2.576
(2.336)
-180
(-163)
137
(124)
13.252
(12.020)
lire thane- coated
fabric
B
-696
(-631)
-673
(-610)
5,034
(4.566)
-696
(-631)
-60S
(-549)
27.862
(25.271)
C
-794
(-720)
-831
(-754)
4,868
(4,415)
-794
(-720)
-944
(-856)
27,664
(25,091)
Rubber-coated
cord
"A
103
(93)
356
(323)
2,798
(2.538)
103
(93)
1,134
(1,029)
12,742
(11.557)
B
-67
(-61)
89
(81)
2,937
(2,663)
-67
(-61)
558
(507)
14,326
(12,993)
Epoxy- coated
fiberglass
B
778
(706)
751
(682)
824
(747)
778
(706)
-55
(-50)
3,061
(2.776)
C
442
(383)
396
(359)
483
(438)
442
(383)
-368
(-334)
3.153
(2.860)
"Cost effectiveness <= (Table 8-11 item VI
bCost effectiveness = (Table 8-12 Hen VI
'tost effectiveness = (Table 8-16 iten IV
dCost effectiveness = (Table 8-12 iten VI
eCost effectiveness = (Table 8-16 item IV
Table 8-10 item VI)
Table 8-10 item VI)
Table 8-10 item VI)
Table 8-11 item VI)
Table 8-12 item VI)
+ Table 7-3 VOC emission reduction beyond baseline for Regulatory Alternative II.
+ Table 7-3 VOC emission reduction beyond baseline for Regulatory Alternative III.
+ Table 7-3 VOC emission reduction beyond baseline for Regulatory Alternative IV.
+ (Table 7-3 VOC emissions at Regulatory Alternative II - VOC emissions at Regulatory Alternative III).
+ (Table 7-3 VOC emissions at Regulatory Alternative III - VOC emissions at Regulatory Alternative IV).
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oo
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ro
TABLE 8-20. AVERAGE AND INCREMENTAL COST EFFECTIVENESS OF REGULATORY ALTERNATIVES
FOR MODEL COATING OPERATINGS (Using Condensation System), $/Mg ($/ton)
(First Quarter 1984 Dollars)
Rubber-coated
industrial fabric
Cost item
Average
1. Alternative II vs.
2. Alternative III vs
3. Alternative IV vs.
Incremental
1. Alternative II vs.
2. Alternative III vs
3. Alternative IV vs.
^ost effectiveness =
''Cost effectiveness =
cCost effectiveness =
dCost effectiveness =
eCost effectiveness =
Ia
. Ib
Ic
Ia
. II"
III6
(Table 8-14 item VI -
(Table 8-15 item VI -
(Table 8-16 item IV -
(Table 8-15 item VI -
(Table 8-16 item IV -
A
-213
(-194)
-118
(-107)
5,974
-213
(-194)
177
(161)
30,770
(27.914)
Table 8-13
Table 8-13
Table 8-13
Table 8-14
Table 8-15
B
-274
(-249)
-240
(-218)
4,478
-274
(-249)
-137
(-124)
23,352
(21,180)
item VI) - Table
item VI) - Table
item VI) - Table
item VI) - (Table
item VI) - (Table
C
-324
(-294)
-338
(-307)
3,707
-324
(-294)
-377
(-342)
19,844
(17,999)
7-3 VOC emission
7-3 VOC emission
7-3 VOC emission
Ure thane-coated
fabric
B
-887
(-805)
-963
(-874)
6,807
-887
(-805)
-1,189
(-1.078)
37,886
(34,363)
reduction beyond
reduction beyond
reduction beyonc
7-3 VOC emissions at Regulatory
7-3 VOC emissions at Regulatory
C
-932
(-846)
-1,052
(-954)
6,426
-932
(-846)
-1.411
(-1,279)
36,333
(32,961)
baseline
baseline
baseline
Rubber- coated
cord
A
-214
(-194)
-118
(-107)
6,071
-214
(-194)
177
(161)
31,263
(28,361)
for Regulatory
for Regulatory
for Regulatory
B
-274
(249)
-240
(-218)
5.463
-274
(-249)
-139
(-126)
23,278
(21,113)
Alternative II.
Alternative III.
Alternative IV.
Alternative II - VOC emissions at Regulatory
Epoxy-coated
fiberglass
B
135
(123)
120
(109)
824
135
(123)
-357
(-324)
22,600
(20,498)
Alternative
Alternative III - VOC emissions at Regulatory Alternative
C
-74
(-67)
-91
(-82)
483
-74
(-67)
-598
(-542)
18,216
(16.525)
III).
IV).
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8.3 REFERENCES FOR CHAPTER 8
1. Telecon. Friedman, E., MRI, with Coffey, F., Southern Tank and Pump
Company. August 23, 1984. Information on solvent storage tanks.
2. Telecon. Friedman, E., MRI, with Herman, K., Sherman Machinery.
August 29, 1984. Information on mix preparation equipment.
3. Telecon. Friedman, E., MRI, with Swain, R., Lembo Corporation.
August 20 and 27, 1984. Information on coating line costs.
4. Telecon. Friedman, E., MRI, with Litzler, W., C. A. Litzler Company,
Inc. August 27, 1984. Information on coating line costs.
5. Telecon. Thorneloe, S., MRI, with W. Sandra, W. F. Crist Company.
August 16, 1983. Information on conservation vents.
6. Richardson Engineering Services, Inc. Process Plant Construction
Estimating Standards. 1983-1984 Edition. Volumes 1 and 3.
7. Telecon. Friedman, E., MRI, with Ledbetter, B., Union Chemicals
Division. August 27, 1984. Information on solvent prices.
8. Neveril, R. B., GARD, Inc. Capital and Operating Costs of Selected
Air Pollution Control Systems. U. S. Environmental Protection
Agency. Research Triangle Park, N.C. EPA Publication No.
EPA-450/5-80-002. December 1978. p. 5-45.
9. Letter from Memering, L., United Air Specialists, Inc., to Thorneloe,
S., MRI. November 7, 1983. Information on Kon-den-Solver® solvent
vapor recovery systems.
10. Peters, M. S., and K. D. Timmerhaus. Plant Design and Economics for
Chemical Engineers. New York, McGraw-Hill Book Company. 1980.
p. 166.
11. Reference 8, p. 5-37.
12. Memorandum from Glanville, J., MRI, to Magnetic Tape Project File.
June 22, 1984. Wastewater discharge calculations and summary.
13. Reference 8, p. 3-12.
14. U.S. Department of Labor. Bureau of Labor Statistics. Employment
and Earnings.
15. U.S. Department of Labor. Bureau of Labor Statistics. Producer
Prices and Price Indexes Data.
8-28
-------
16. U. S. Environmental Protection Agency. VOC Emissions From Volatile
Organic Liquid Storage Tanks—Background Information for Proposed
Standards. EPA-450/3-81-003a. Research Triangle Park, North
Carolina. July 1984. p. 8-19.
17. Reference 10, pp. 172, 174.
18. Memorandum from Friedman, E., MRI, to Polymeric Coating of Supporting
Substrates Project File. September 18, 1984. Product-specific raw
material costs for model coating lines.
19. U. S. Environmental Protection Agency. Organic Chemical
Manufacturing. Volume 5: Adsorption, Condensation, and Absorption
Devices. EPA-450/3-80-027. Research Triangle Park, North Carolina.
December 1980. pp. IV-2, IV-6.
20. Telecon. Thorneloe, S., MRI, with Schweitzer, P., Chempro. August
29 and 30, 1984. Information on distillation system.
8-29
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9. ECONOMIC ANALYSIS
9.1 INDUSTRY PROFILE
9.1.1 Introduction and Summary
Nationwide, there are over 100 manufacturing firms whose activities
include polymeric coating of supporting substrates. The firms in
the polymeric coating industry are located throughout the country;
however, they tend to be concentrated in the Northeast. The majority
of coating operations involve the production of industrial or inter-
mediate products as opposed to final or consumer products. About half
of the firms are "commission" coaters who sell coated products to
manufacturers of final products, while the other half consists of
"captive" coaters who either manufacture final products themselves, or
are owned by firms that do so.
The firms may be grouped into eight four-digit SIC industry cate-
gories. Two of these categories account for about 50 percent of the
total value of polymeric coated substrates. These are SIC 2295 (Coated
Fabrics, Not Rubberized), and SIC 2296 (Tire Cord and Fabric).
There are many final or consumer products which incorporate poly-
meric coated substrates — one firm, for example, has estimated that its
output is eventually used in the production of over 1,500 final products,
By far, however, the most important use of polymeric coated products is
in the manufacture of motor vehicles. Currently, more than half of the
output of polymeric coated products is consumed in this use.
In 1982, the total value of output produced by the polymeric
coating industry was about $5.8 billion. The industry is expected to
grow at an annual rate of 2.8 percent over the period from 1982 to 1990.
9.1.1.1 Industry Segments. As noted above, the firms that may be
affected by the NSPS can be grouped into eight four-digit SIC cate-
gories. These categories are:
9-1
-------
o 2241 - Narrow Fabric Mills;
o 2295 - Coated Fabrics, Not Rubberized;
o 2296 - Tire Cord and Fabric;
o 2394 - Canvas and Related Products;
o 2641 - Paper Coating and Glazing;
o 3041 - Rubber and Plastics Hose and Belting;
o 3069 - Fabricated Rubber Products, Not Elsewhere Classified; and
o 3293 - Gaskets, Packing, and Sealing Devices.
Two of these groups SIC 2241 (Narrow Fabric Mills) and SIC 2641 (Paper
Coating and Glazing) are only remotely affected by the NSPS since the
overwhelming majority of products attributed to these groups do not
require polymeric coating. Accordingly, these two SIC groups are given
only limited attention in this section. The value of annual shipments
for each of the remaining six SIC groups is presented in Table 9-1.
All values are in current dollars (i.e., unadjusted for inflation).
SIC 2295 (Coated Fabrics, Not Rubberized) includes pyroxylin
(nitrocellulose) coated fabrics, vinyl coated fabrics, and others such
as polyurethane coated fabrics.1 Most firms included in this group
are considered part of the coating industry.
Included in SIC 2296 (Tire Cord and Fabric) are all firms that
manufacture tire cord and fabric regardless of whether these products
are consumed internally or sold to tire manufacturers.2 Most firms
in this industry group are considered part of the coating industry.
The group SIC 2394 (Canvas and Related Products) includes all
manufacturers of canvas and canvas products such as awnings, tents,
air-supported structures, tarpaulins, and other covers.3 Most firms
in this SIC group are considered part of-the coating industry.
Census Bureau data for SIC 3041 (Rubber and Plastics Hose and
Belting) indicate that most of this group's output can be attributed to
the polymeric coating industry.4 Most of the products of SIC 3041
are manufactured by coating textile substrates; a small portion is
manufactured using wire as the supporting substrate. About 85 percent
of the total value of the output of this SIC group is attributable to
coated products that could be affected by the NSPS.
9-2
-------
TABLE 9-1. WHOLESALE VALUE OF SHIPMENTS BY SIC GROUP, 1973-1982
($ Current X10 6)
SIC group
Year
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
22953
975.9
1,056.4
986.1
1,182.5
1,059.0
949.1
998.3
951.7
1,044.7
1,217.7
2296&
717.5
805.0
748.9
835.7
1,013.2
1,090.1
1,129.2
1,009.2
1,060.1
981.5
2394C
321.8
293.2
284.3
301.7
486.8
578.6
542.3
517.2
658.1
741.3
304ld
1,052.0
1,249.9
1,235.4
1,411.9
1,765.7
2,007.8
2,177.7
1,941.5
2,147.2
1,958.0
30692
3,265.3
3,490.2
3,409.1
3,888.1
4,565.0
4,930.3
5,433.6
5,385.4
6,280.6
6,193.6
3293f
723.0
834.7
842.2
1,019.3
1,267.1
1,481.0
1,675.4
1,610.4
1,781.2
1,650.0
Reference 1, p. 3.
Reference 2, p. 3.
Reference 3, p. 3.
^Reference 4, p. 3.
^Reference 5, p. 3.
'Reference 6, p. 3.
9-3
-------
Most of the products covered by SIC group 3069 (Fabricated Rubber
Products, Not Elsewhere Classified) are rubber goods sold for a wide
variety of products such as foam rubber, mats, surgical gloves, and
shoe parts. Analysis of Census Bureau data indicates that roughly
15 percent of the total value of output of SIC 3069 can be considered
part of the polymeric coating industry. Some of the products affected
are: industrial products such as fuel cells and single ply membrane
rubber roofing; rubber coated fabrics such as protective clothing,
footware fabrics, and inflatable fabrics; and other rubber goods such
as boats, pontoons, life rafts, and hot air balloons.5
Another group only partially affected by the NSPS is SIC 3293
(Gaskets, Packing, and Sealing Devices). This group includes production
of a variety of metallic and nonmetallic gaskets, and sealing devices
including those composed of asbestos, paper, felt, cork, and various
types of metals.6 Polymeric coated rings and seals account for about
15 percent of the total value of this group's output.
9.1.1.2 Industry Output. The data presented above can be used
to estimate the polymeric coating industry's total value of output
for 1982. Such an estimate can be obtained by adjusting the total
output values presented in Table 9-1 (for the six four-digit SIC groups)
by the estimated percentage of each SIC group affected by the NSPS.
The results obtained using this adjustment procedure are presented in
Table 9-2; they show that in 1982, the polymeric coating industry pro-
duced $5.8 billion worth of output. This represents about 0.2 percent of
the 1982 GNP figure of $3,057.5 billion.7
9.1.2 Production, Prices, and Employment
9.1.2.1 Historical Production. The most consistent source of
historical output data for this industry is the Census of Manufactures.
As noted previously, Table 9-1 presents the level of shipments for each
of the major SIC groups in which polymeric coating is known to be
performed. In Table 9-3, these data are adjusted by the percentages
discussed above to obtain shipment estimates for only those products
that could be affected by the NSPS. The estimates are expressed in
1982 dollars to facilitate observation of production trends in the
industry segments. Table 9-4 expresses the output of each segment as a
percentage of the annual totals.
9-4
-------
TABLE 9-2. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
ADJUSTED VALUE OF SHIPMENTS, 1982
($ 1982 X106)
SIC
group
2295
2296
2394
3041
3069
3293
TOTAL
1982 value
of shipments3
1,217.7
981.5
741.3
1,958.0
6,193.6
1,650.0
Percentage
X affectedb
100
100
100
85
15
15
Adjusted
value of
shipments
1,217.7
981.5
741.3
1,664.3
929.0
247.5
5,781.3
aTable 9-1 data.
^These percentages are rough approximations of the portion
of total four-digit SIC output that could be considered part
of the source category affected by this NSPS. The percent-
ages are estimates based upon inspection of Census of Man-
ufacturing product and product class data for the appro-
priate SIC groups. See Section 9.1.1.1.
9-5
-------
TABLE 9-3. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
WHOLESALE VALUE OF SHIPMENTS FOR INDUSTRY SEGMENTS, 1973-19823
($ 1982 X106)
SIC Se9ment Industry
Year 2295b 2296C 2394d 3041e 3069f 32939 total
1973 1,610.5 1,542.5 531.0 1,922.1 1,052.8 233.1 6,892.0
1974 1,551.6 1,428.0 430.6 1,884.6 928.7 222.1 6,445.6
1975 1,460.9 1,204.6 421.2 1,689.1 822.5 203.2 5,801.5
1976 1,630.1 1,268.2 415.9 1,821.3 885.1 232.0 6,252.6
1977 1,404.9 1,460.6 645.8 2,163.5 987.1 274.0 6,935.9
1978 1,213.4 1,506.7 739.7 2,358.8 1,022.2 307.0 7,147.8
1979 1,209.0 1,404.1 656.7 2,301.7 1,013.5 312.5 6,897.5
1980 1,059.6 1,121.5 575.8 1,834.0 897.7 268.4 5,757.0
1981 1,068.8 1,090.7 673.3 1,895.7 978.5 277.5 5,984.5
1982 1,217.7 981.5 741.3 1.664.3 929.0 247.5 5,781.3
aTable 9-1 data converted to 1982 dollars through use of the Producer Price
Index for Rubber and Plastic Products (for SIC's 2296, 3041, 3069, and 3293)
or the Producer Price Index for Textile Products (for SIC's 2295 and 2394).
^Coated Fabrics, Not Rubberized, 100 percent included.
cTire Cord and Fabric, 100 percent included.
dCanvas and Related Products, 100 percent included.
eRubber and Plastics Hose and Belting, 85 percent included.
f Fabricated Rubber Products, Not Elsewhere Classified, 15 percent included.
SGaskets, Packing, and Sealing Devices, 15 percent included.
9-6
-------
TABLE 9-4. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
PERCENTAGES OF TOTAL OUTPUT BY INDUSTRY SEGMENT, 1973-1982
Year
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
2295a
23.4
24.1
25.2
26. -1
20.3
17.0
17.5
18.4
17.9
21.1
2296b
22.4
22.2
20.8
20.3
21.1
21.1
20.4
19.5
18.2
17.0
SIC
2394C
7.7
6.7
7.3
6.7
9.3
10.3
9.5
10.0
11.3
12.8
segment
3041d
27.9
29.2
29.1
29.1
31.2
33.0
33.4
31.9
31.7
28.8
3069e
15.3
14.4
14.2
14.2
14.2
14.3
14.7
15.6
16.4
16.1
3293f
3.4
3.4
3.5
3.7
4.0
4.3
4.5
4.7
4.6
4.3
- Industry
total9
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
aCoated Fabrics, Not Rubberized.
^Ti re Cord and Fabric.
cCanvas and Related Products.
dRubber and Plastics Hose and Belting.
^Fabricated Rubber Products, Not Elsewhere Classified.
'Gaskets, Packing and Sealing Devices.
9Columns may not sum exactly to 100 because of rounding.
9-7
-------
Tables 9-3 and 9-4 show that the Rubber and Plastics Hose and
Belting (SIC 3041) segment of the industry accounts for the largest
portion of the total value of industry output. Significant shares are
also accounted for by Coated Fabrics, Not Rubberized (SIC 2295), Tire
Cord and Fabric (SIC 2296), Fabricated Rubber Products, Not Elsewhere
Classified (SIC 3069) and Canvas and Related Products (SIC 2394). A
small portion is due to Gaskets, Packing, and Sealing Devices (SIC 3293).
As Table 9-3 shows, total industry output during the early 1980's
was below the levels of the late 1970's. The reduced output of the
early 1980's is probably attributable to the recession experienced
during those years. This is especially true in light of the fact that
many of the products affected by this NSPS are sold as industrial
products.
Output in the Tire Cord and Fabric (SIC 2296) segment of the
industry has declined both in absolute value as well as in relation to
the whole industry. Table 9-3 shows that shipments for this industry
segment declined by more than one-third over the period 1973-1982.
During the same period, the percentage of total industry output accounted
for by Tire Cord and Fabric declined from 22.4 percent in 1973 to 17.0
percent in 1982 (see Table 9-4). Most of this decline can be attributed
to improved tire life.
Output for the industry segment Coated Fabrics, Not Rubberized
(SIC 2295) also declined over the period 1973-1982. This decrease,
however, was less severe than that of SIC 2296, and is largely attrib-
utable to decreased automobile sales.
9.1.2.2 Prices. Most of the products of the polymeric coating
industry are intermediate products, which are consumed internally by the
same firm, or sold to other firms. Consequently, the market for these
products is often poorly defined, and price information is not widely
available. However, the quantity and value data reported in the Census
of Manufactures can be used to approximate average per-unit prices.
Table 9-5 presents prices derived from the Census data noted above.
Included are average prices for products such as vinyl and urethane
coated fabrics, tire cord and fabric, and various rubber and plastics
hoses and belts.
9-8
-------
TABLE 9-5.
AVERAGE PRICES FOR SELECTED PRODUCTS
($ 1982)
SIC code
22951a
2295111
22952
2295213
2295215
2295217
2295222
2295224
2295226
2295232
2295234
2295236
22953
2295315
2295322
2295338
2295348
2296000b
3041 1C
3041103
3041105
3041113
3041116
30412
3041231
3041241
3041251
30414
3041451
30415
3041561
3041563
30416
3041642
3041644
Product
Pyroxylin coated fabrics
- Light cotton fabric
Vinyl coated fabrics
- 10 oz or less, woven fabric
- 10 oz or less, knitted fabric
- 10 oz or less, nonwoven fabric
- 10 to 16 oz, woven fabric
- 10 to 16 oz, knitted fabric
- 10 to 16 oz, nonwoven fabric
- More than 16 oz, woven fabric
- More than 16 oz, knitted fabric
- More than 16 oz, nonwoven fabric
Other coated fabrics
- Polyurethane coated fabrics
All other coated fabrics
- 10 oz or less, woven fabric
- 10 to 16 oz, all fabrics
- More than 16 oz, all fabrics
Ti re cord and fabric
Rubber and plastics flat belts
- Lightweight conveyor
- Heavy duty conveyor
- Transmission, flat
- Other rubber and plastic belts
Rubber and plastics belts, not flat
- Industrial
- Agricultural
- Fractional horsepower
Rubber hose, nonhydraul ic, not garden
- Textile based
Rubber and plastics garden hose
- Plastic garden hose
- Rubber garden hose
All other rubber and plastic hose
- Single jacket woven textile
- Double jacket woven textile
Price, $
1.11/linear yd
1.63/1 inear yd
1.91/linear yd
1.67/linear yd
2. 74/1 inear yd
2.70/linear yd
3. 28/1 inear yd
3. 10/1 inear yd
4.04/1 inear yd
3. 90/1 inear yd
3.12/linear yd
1.57/linear yd
2.95/linear yd
2. 77/1 inear yd
1.99/lb
2.05/lb
1.63/lb
4.29/lb
1.72/lb
6.39 ea
5.98 ea
1.89 ea
0.40/lb
0.17/lb
0.26/lb
0.96/lb
1.28/lb
(Continued)
9-9
-------
TABLE 9-5. (continued)
SIC code Product Price, $
3069Cd Industrial Rubber Products
3069C14 - Single ply membrane roofing 0.42/ft2
Reference 1, pp. 4-5.
^Reference 2, p. 4.
cReference 4, p. 4.
^Reference 5, pp. 4-5.
9-10
-------
9.1.2.3 Employment. Census Bureau data were used to estimate
employment in the various industry segments for the years 1973-1982.
The annual employment for each segment was obtained by applying the
appropriate industry affected percentage noted in Table 9-2 to the Census
estimate of employment at the four-digit SIC level. The calculated
employment estimates are presented in Table 9-6. Total industry employ-
ment during 1982 is estimated to have been 71,300 persons. While this
figure represents less than 0.08 percent of total nonagricultural employ-
ment for 1982, it should be noted that it includes all persons employed
by coating firms, including those who manufacture final products at
captive coaters.
9.1.3 Market Structure
9.1.3.1 Polymeric Coating Companies. Table 9-7 lists 108 companies
operating 128 plants that perform polymeric coating of supporting sub-
strates. Listed for each plant are the location, SIC code, whether the
coating operation is commission or captive, the major end products
produced, and whether the firm is a "small business" according to cri-
teria set forth by the U.S. Small Business Administration. An inspection
of the types of products manufactured by the plants provides some idea of
the diverse nature of this industry.
The plants are concentrated in the Northeastern part of the United
States. Massachusetts, New York, New Jersey, and Ohio account for over
one third of the plants currently in operation. Information regarding
the degree of integration and levels of industrial concentration exhibited
by the companies in this industry is provided in the following sections.
9.1.3.2 Integration. Among the firms belonging to this industry
there is evidence of horizontal and vertical integration as well as
diversification. A horizontally-integrated firm owns and operates
multiple coating facilities in various locations. A vertically-integrated
firm, on the other hand, is involved in related activities other than the
coating operation itself, such as manufacturing the substrate and coat-
ings, or further processing coated materials into final products such as
conveyor belts or tires. Diversification means that the company manufac-
tures other products or provides services unrelated to its coating
activities.
9-11
-------
TABLE 9-6. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
INDUSTRY SEGMENT EMPLOYMENT, 1973-1982
(thousands)
SIC segment
Year
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
2295^
18.5
18.6
15.9
17.1
13.6
12.3
12.9
11.8
11.4
11.7
2296b
10.3
11.4
10.0
10.1
9.6
9.6
9.7
8.9
8.6
6.5
2394C
14
11
10
10
13
15
12
11
12
14
.0
.2
.4
.3
.9
.4
.0
.1
.5
.5
3041d
25
26
23
25
29
32
32
27
22
21
.6
.5
.1
.4
.2
.5
.9
.5
.9
.0
30696
16
15
13
14
14
14
15
14
14
13
.4
.8
.5
.0
.8
.9
.9
.2
.4
.1
3293f
4
4
3
4
5
5
5
4
4
4
.2
.2
.8
.1
.0
.1
.4
.7
.5
.5
Industry
total
89.0
87.7
76.7
81.0
86.1
89.8
88.8
78.2
74.3
71.3
Reference
bReference
Reference
•^Reference
Reference
"^Reference
1, p. 3.
2, p. 3.
3, p. 3.
4, p. 3.
5, p. 3.
6, p. 3.
9-12
-------
TABLE 9-7 PLANTS APPLYING POLYMERIC COATINGS TO SUPPORTING SUBSTRATES
LOCATION, SIC CODE, TYPE OF COATER, AND BUSINESS SIZE a
Plant/location
Albany International
Buffalo, N.Y.
Aldan Rubber Co.
Philadelphia, Pa.
Alpha Associates, Inc.
Woodbridge, N.J.
The Amerbelle Corp.
Rockville, Conn.
American Waterproofing
New Haven, Mo.
Archer Rubber Co.
Mil ford, Mass.
Armstrong Rubber Co.
New Haven, Conn.
Athol Manufacturing Corp.
Butner, N.C.
Aurora Bleaching, Inc.
Aurora, 11 1 .
Bibb Company
Macon, Ga.
Bond Cote of Virginia, Inc.
Pul aski , Va.
Bridgestone
Lavergne, Tenn.
A.S. Browne Manufacturing Co.
Tilton, N.H.
Buffalo Weaving and Belting
Buffalo, N.Y.
Burlington Industries, Inc.
Kernersvil le, N.C.
CEBI Norton
Watertown, Mass.
Chase & Sons, Inc.
Randolph, Mass.
CHEMFAB
N. Bennington, Vt.
Chemprene
Beacon, N.Y.
SIC Code
3041
2295, 2394,
3069
2295
2295, 2394
2295
3069
2296
2295
2295
3041
2295
2296
3041
3041, 3069
2296, 3041,
3069
2295
3069
3041
3041, 3069
Corn-
mi ssion
coater
Yes/No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
c
c
Yes
No
No
No
No
c
Yes
No
No
Small
business13
Major end products Yes/No
Conveyor belts
Coated fabric used to
fabricate products
(e.g. , tents, tarpau-
lins, rainwear)
Coated fabric
Coated fabric used to
make products (e.g.,
sails and tents)
Coated fabric
Coated fabric used to
fabricate products
(e.g. , diaphragms ,
hospital sheeting)
Tire fabric
Upholstery for auto-
mobiles, school buses
Coated fabric
Coated yarn for V-belts,
coated fabric for con-
veyor belts
Coated fabric
Industrial belts
Belting, sheeting,
matting
Coated fabric for tire
cord, V-belts, snow
fences, diaphragms
Coated fabric
Coated fabric for
cable and wire industry
Coated fabric for
belting
Coated fabric for dia-
phragms, belting, tar-
paulins, machine covers
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
No
No
Yes
Yes
No
No
Yes
Yes
No
9-13
(Continued)
-------
TABLE 9-7. (continued)
Plant/location
SIC Code
Com-
mission
coater
Yes/No
Major end products
Small
business0
Yes/No
Chrysler Plastic Products 2295, 3069 No
Corp., Sandusky, Ohio
Cleveland Plastics 2295 No
Cleveland, Tenn.
Coast Craft Rubber Co. 3069 No
Torrance, Calif.
Collins & Aitoman Corp. 2295 No
Roxboro, N.C.
Columbus Coated Fabrics 2295 c
Columbus, Ohio
Compo Industries 2295 c
Lowell, Mass.
Coo ley, Inc. 2295, 3069 Yes
Pawtucket, R.I.
Cooper Tire and Rubber Co. 2296 No
Findley, Ohio
Texarkana, Ark.
Custom Coated Products 2295 Yes
Cincinnati, Ohio
Oayco Corp. 3069 No
Three Rivers, Mich.
Waynesville, N.C.
Oelatex Processing Corp. 2295
Clifton, N.J.
Coated fabric for auto- No
mobile roofing, door
panels, seating
Coated fabric for pro- Yes
ducts (e.g., handbags)
Diaphragms Yes
Upholstery, geotextiles No
Coated fabric
Footwear fabric
Coated fabric for pro-
ducts (e.g., wind-
screen, netting)
Tire Belts
Sporting goods, auto-
motive parts
Printing blankets
Yes Coated fabric
Dunlop Tire and Rubber Co. 2296 No Tire fabric
Buffalo, N.Y.
Huntsville, Ala.
Utica, N.Y. Tire cord
No
No
Yes
No
Yes
No
Yes
No
Ouracote, Inc. 2295
Ravenna, Ohio
Ourkee-Atwood Co. 3069
New Hope, Minn.
E.I. OuPont de Nemours
and Co., Inc.
Fairfield, Conn.
Eagle Dyeing and Finishing Co. 3069
Mount Holly, N.J.
El 1 Sandman Co.
Worcester, Mass.
2295
Yes
No
No
Coated fabric for
marine, automotive.
and communication
industries
Coated fabric for
appliances, automo-
tive, construction
Industries
Furniture, upholstery
Coated fabric
Yes
No
No
Yes
(Continued)
9-14
-------
TABLE 9-7. (continued)
Plant/location
Elizabeth Webbing Co., Inc.
Central Falls, R.I.
Emerson Textiles
Chelsea, Mass.
Engineered Yarns, Inc.
Coventry, R.I.
Essex Group, Inc.
Fort Wayne, tnd.
Ex-Cell-0 Fabric Finishers
Inc., Coshocton, Ohio
Exxon Chemical Americas
Summervil le, S.C.
Fabrite Laminating Corp.
Woodridge, N.J.
Facemate Corp.
Chicopee Falls, Ohio
Ferro Corp.
Culver City, Calif.
Norwalk, Conn.
Firestone Industrial Products
Noblesville, Ind.
Flextrim Products
South El Monte, Calif.
Foss Manufacturing Co., Inc.
SIC Code
2295
3069
2295
3069
2394
2295
2295
c
2295, 3069
3041, 3069
2295
2295, 3293
Com-
mission Smal 1
coater business0
Yes/No Major end products Yes/No
c Fabric coated for
mildew and water
repell ancy
c Footwear fabric
c Coated fabric
c Coated electrical wire
Yes Canvas products
Yes Coated fabric, geotex-
tiles
Yes Coated fabric
c c
Yes Coated fabric for auto-
motive, military indus-
tries
No Hoses, seatbelts, roof-
ing
Yes Coated fabric
Yes Carpet, gaskets, geo-
Yes
Yes
Yes
No
Yes
No
Yes
Yes
c
No
c
Yes
Haverhill, Mass.
GSC Rubber Coating
Oalton, Ga.
Gates Rubber Co.
Siloam Springs, Ark.
Denver, Colo.
Elizabethtown, N.J.
H.A. Gelman, Co.
Brooklyn, N.Y.
textiles, footwear fab-
ric, wallcoverings
3041 No Belts and hoses
2295, 3069 c Fabric for automotive,
apparel, bedding, fur-
niture and footwear
industries
Yes
No
Gem Urethane Corp .
Amsterdam, N.Y.
General Fabric Fusing
Cincinnati , Ohio
General Tire and Rubber Co
Toledo, Ohio
Columbus, Miss.
Jeanette, Pa.
Barnesville, Ga.
2295
2295
2295
2296
Yes Artificial leather for
footwear, luggage
c Coated fabric
Vinyl coated fabric
Tire cord
Yes
Yes
No
(Continued)
9-15
-------
TABLE 9-7. (continued)
Plant/location
Globe Albany
SIC Code
3041
Com-
mission
coater
Yes/No
Yes
Major end products
Belting
Small
business'5
Yes/No
No
Buffalo, N.Y.
B.F. Goodrich, Co.
Akron, Ohio
Elgin, S.C.
Greenville, S.C.
Oneida, Tenn.
M.R. Grace and Co.
Adams, Mass.
Morristown, Tenn.
Gram'teville Co.
Graniteville, S.C.
Guilford Mills, Inc.
Greensboro, N.C.
Haartz Auto Fabrics, Inc.
Action, Mass.
Haartz Mason, Inc.
Watertown, Mass.
Hadbar
Monrovia, Calif.
Hexcel
Livermore, Calif.
Hoi listen Mills, Inc.
Kingsport, Tenn.
Lincoln, R.I.
Hub Fabric Leather
Everett, Mass.
Jewell Sheen Coating, Inc.
Long Island City, N.Y.
Joanna Western Mills Co.
Chicago, 111.
Johns Manville Corp.
Manville, N.J.
Kenyon Piece Oyeworks Co.
Kenyon, R.I.
Kleen-Tex Industries, Inc.
LaGrange, Calif.
2295, 3069 No
3041
3069
2295
3069
3069
2295
2295
2295
2295
2295
3293
2295
2295
No
2295, 2394, No
3069
2295, 2394 Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Belting, hoses, mis- No
sile and marine pro-
ducts, and tank lining
V-belts
Rubber hose
Hoses, belting
Printing blankets No
Awnings, tents, outdoor No
furniture
Automotive fabric, No
tents, upholstery wall-
coverings
Automotive fabric Yes
Convertible top fabric Yes
Automotive fabric, fab- Yes
ric for military, min-
ing, aircraft missiles
Fabric for aircraft and No
missiles
Fabric for graphic arts No
and book covers
Coated flocked fabric Yes
Sporting goods, lap- Yes
idary supplies, fabric
for Instruction
Bookcovers, window No
shades
Packings, seals, gasket No
fabric
Coated fabrics for pro- No
ducts (e.g., rainwear,
tents, luggage, hot air
balloon cloth, heat seals)
Coated fabric for pro-
ducts (e.g., awnings,
upholstery, cushions
for pole vault and
high Jump, seat covers)
Yes
(Continued)
9-16
-------
TABLE 9-7. (continued)
Plant/location
Lewcott Chemicals and
Plastics Co.
Mlllford, Mass.
Lloyd Manufacturing Co., Inc.
Warren, R.I.
Ludlow Composites
Fremont, Ohio
Marathon Rubber Products
Wausau, Mis.
McCord Gasket Co.
Wyandotte, Mich.
Michel in Corp.
Greenville, S.C.
Mil liken and Co.
La Grange, Ga.
Murray Rubber .Co.
Houston, Tex.
National Cdating Corp.
Rochland, Mass.
Neese Coated Fabrics
St. Louis, Mo.
Nylco Corp .
Nashua, N.H.
OOC, Inc.
Norcross, Ga.
Orchard Manufacturing Co.
Lincoln, R.I.
Otto Fabrics , Inc.
Wichita, Kans.
Pacific Combining Corp.
Los Angeles, Cal if .
Packaging Systems Corp.
Orangeburg, N.Y.
Plymouth Rubber Co.
Boston, Mass.
Polyclad Laminates
Millburg, Mass.
Franklin, N.J.
Putman-Herzl Finishing
Co., Inc.
Putnam, Conn.
SIC Code
2295
2295, 3069
2295
3069
3293
2296
2295
3293
2295
2295, 3069
2295
2295
3069
2295
2295
2295
3069
2295
2295
Com-
mission
coater
Yes/No
Yes
Yes
Yes
Yes
'
NO
No
c
No
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Major end products
Military products
Backing for napping
machines, cloth for
textile industry
Coated fabric
Rainwear
Gaskets
Cord coating
Coated fabric
Seals and Gaskets
Textiles cloth for
laminates
Coated fabrics for tar-
paul ins, convertible
tops and shoe fabric
Waterproofed fabric
Architectural coverings
for tennis courts, green-
houses
Rubber-coated fiberglass
Awnings, belts, roofing
Coated fabric
Coated fabric
Rainwear, gas mask
fabric
Coated fabric used to
produce a laminate for
printed circuits
Coated fabric for pro-
ducts (e.g., backpacks,
ski wear, snowmobiles)
(Conti
Small
business0
Yes/No
Yes
Yes
No
Yes
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
nued)
9-17
-------
TABLE 9-7. (continued)
Plant/location
RCA Rubber Co.
Akron, Ohio
RM Industrial Products, Inc.
North Charleston, S.C.
Rainfair
Racine, Wis.
Reef Industries, Inc.
Houston, Tex.
Reeves Brothers, Inc.
Rutherfordton, N.C.
Soartanburg, S.C.
Buene Vista, Va.
Rose 4 Sons
Hialeah, Fla.
Scapa Dryers , Inc.
Waycross, Ga.
Seaman Corp.
MUlersburg, Ohio
Stacy Fabrics Corp.
Wood Ridge, N.J.
Stanbee Co. , Inc.
Carlstadt, N.J.
Standard Coated Products
Havre de Grace, Md.
Star Tex Industries
Newburg Port, Mass.
Stedfast Rubber Co.
North Eastern, Mass.
J.P. Stevens and Co., Inc.
Walterboro, S.C.
Easthampton, Mass.
Stuart, Va.
Trostel Leather Products
Elkhorn, Wis.
Uni royal , Inc.
Middlebury, Conn.
Utex Industries
Weimar, Tex.
SIC Code
3069
2295, 3069
3069
3069
2295, 3069
2295
3069
2295
2295
3069
2295
2295
2295
2295, 3069
3069
2295
3069
2295
3069
2295
3293
Com-
mission
coater
Yes/No
c
c
No
No
Yes
c
c
Yes
Yes
No
c
c
Yes
No
No
No
No
Small
business15
Major end products Yes/No
Rubber-coated fiber
Coated fabric
Protective clothing,
rainwear
Lightweight liners for
outdoor storage covers
Coated fabric
Upholstery
Printing blankets,
inflatibles, diaphragms,
gaskets
Coated fabric
Coated fabric
Coated fabric
Coated fabric
Shoe products (e.g. ,
box heels, liners)
Coated fabric and
paper for aircraft
Coated fabric for
• shoes, handbags, sport-
ing goods
footwear fabric
Coated fabric for insect
Coated fabric
Backing to carpet for
automotive industry
Impregnating leather for
industrial packings and
seals
Coated fabric for up-
holstery, automobiles,
and furniture
Seals and gaskets
Yes
No
Yes
Yes
No
c
Yes
Yes
Yes
Yes
No
c
Yes
No
No
No
No
(Continued)
9-18
-------
TABLE 9-7. (continued)
Plant/location
Victor Products
SIC Code
3293
Com-
mission
coater
Yes/No
No
Major end products
Gaskets
Small
business*5
Yes/No
Yes
Chicago, 111.
Viking Technical Rubber Co.
West Haven, Conn.
3069
Yes Coated fabric for pro-
ducts (e.g., tarpau-
lins, marine vests)
Yes
aCompiled from State and industry contacts, plant visits, trade associations, 1983
NEDS listing by SIC codes, and the 1983 Industrial Fabric Reviewer/Buyer's Guide.
"According to employment-size criteria established by the U.S. Small Business
Administration. For the SIC groups affected by this standard, S8A defines a small
business as one that employs fewer than 1,000 persons, for SIC's 2295 and 2296, and
fewer than 500 persons, for all other affected SIC groups.
"•Information not available.
9-19
-------
Concerning horizontal integration, there are several firms with
coating operations in more than one location. Industrywide, however,
only about 10 percent of all plants currently operating are owned by
horizontally-integrated firms. Horizontally-integrated firms do not tend
to fall exclusively within any of the SIC segments previously discussed.
With regard to vertical integration, the distinction between captive
(vertically integrated) and commission (nonintegrated) coating firms is
pertinent. Most coating firms are vertically integrated backward to some
degree, manufacturing some raw materials used in the coating process such
as the coating itself, or certain substrates. However, the distinction
between a captive and commission coater is made according to the level of
forward integration displayed by the firm. Commission coaters generally
do not produce a final product but instead sell coated substrates to
other firms that use them to produce a variety of products. Captive
coaters typically either produce some final product themselves, such as a
printing blanket or industrial belt, or are owned by another firm that
consumes the majority of the coated output, such as tire cords and
fabric. In general, the vertically integrated captive coaters are those
that belong to SIC 2296 (Tire Cord and Fabric) or SIC 3041 (Rubber and
Plastics Hose and Belting) or to a lesser degree, SIC 2295 (Coated
Fabrics, Not Rubberized).
Diversification is typically observed in the larger firms in this
industry. Generally, these are firms whose principal products are tires
and rubber, but may also produce plastics, synthetic organic chemicals,
and agricultural chemicals.
9.1.3.3 Concentration. The extent to which industry output tends
to be concentrated at a specific number of manufacturers is a general
indicator of the presence of entry barriers and thus the degree of
competition existing in an industry. Lower levels of concentration are
usually indicative of relatively easy entry of new firms and thus higher
degrees of competition, while high concentration levels generally indi-
cate the existence of entry barriers and thus the absence of a highly
competitive environment. Levels of concentration are reported by the
Census Bureau in the form of concentration ratios, which indicate the
percentages of total industry output produced by the largest 4, 8, and 20
companies. 8
9-20
-------
Table 9-8 presents concentration ratios for the six four-digit SIC
industries analyzed in this study, and for the products of the polymeric
coating industry. The highest degree of competition is exhibited among
the producers of coated fabrics, particularly those who coat with ure-
thane, rubber, and vinyl (SIC 2295 and SIC 3069D). The producers of
canvas products and gaskets, packing and sealing devices also exhibit
high levels of competition, as indicated by low concentration ratios.
Production is highly concentrated in the industry segments performing
rubber coating. In particular, the segments involving the production of
tire cord and fabric (SIC 2296) and various flat belts and V-belts (SIC
30411 and SIC 30412) show high concentration ratios, as does the coating
of fabrics with pyroxylin (nitrocellulose). Accordingly, lower levels of
competitive pressure are experienced by firms manufacturing these prod-
ucts. The industry segments with higher degrees of concentration are
composed largely of captive coaters exhibiting greater forward integra-
tion. These segments generally include the manufacturers of rubber-coated
products such as tire cords and fabrics and various belts and hoses.
9.1.4 Demand and Supply Issues
9.1.4.1 Determinants of Demand. The majority of products produced
by the polymeric coating industry are used primarily as inputs in the
manufacture of final or consumer products. Therefore, the demand for the
output of the industry is a "derived demand" in that it results directly
from consumer demand for the various final products incorporating poly-
meric coated substrates.
The single most important factor shaping demand for the industry is
the consumer demand for new automobiles and trucks. In automobiles, the
coated fabric products of SIC 2295 are used in headliners, seat coverings,
dashboard panels, door inserts, hardtop coverings, carpet backings, and
convertible tops. The bulk of all tire cord and fabric produced by SIC
2296 is used to manufacture tires sold as replacement tires or as original
equipment with new automobiles, as are significant portions of the hoses
and belts produced by SIC 3041. Even the output of SIC 3069 (Fabricated
Rubber Products, Not Elsewhere Classified) and SIC 3293 (Gaskets, Packing,
and Sealing Devices) are consumed by the automobile industry in the form
of rubber motor mounts, exhaust system supports, tubing, washers, weather
strip, gaskets, and oil seals.
9-21
-------
TABLE 9-8. POLYMERIC COATING OF SUPPORTING SUBSTRATES:
CONCENTRATION RATIOS FOR INDUSTRY SEGMENTS, 1977a
ro
Percent of output accounted for by the:
SIC
Code
2295
22951
22952
22953
2296
2394
3041
30411
30412
30413
3069
3069D
3293
Industry/Segment/Product
Coated Fabrics, Not Rubberized
- Pyroxylin coated fabrics
- Vinyl coated fabrics
- Other coated fabrics
Tire Cord and Fabrics
Canvas and Related Products
Rubber, Plastic-Hose and Belts
- Flat belting
- Other belts and belting
- Rubber hose (hydraulic)
Fabricated Rubber Products, N.E.C.
- Rubber coated fabrics
Gaskets, Packing, and Sealing Devices
4 largest
companies
37
86
53
33
78
17
51
63
93
53
15
33
24
8 largest
companies
52
97
68
48
-
26
68
77
99
84
23
53
36
20 largest
companies
69
100
86
74
100
40
83
97
100
100
36
78
55
Reference 8, pp. 147, 156, 189, 198.
-------
The link between motor vehicle output and demand for the output of
the affected industry may be seen by examining output levels for both
industries. Table 9-9 lists the value of output estimated for the poly-
meric coating industry (see Table 9-3) along with indexes of output for
both the motor vehicle industry and total U.S. industrial production, for
the years 1973 through 1982. Correlation coefficients have been calcu-
lated to estimate the strength of the relationship between two pairs of
output data: (1) polymeric coating industry output and motor vehicle
output; and (2) polymeric coating industry output and total U.S. indus-
trial production. The correlation coefficients show that industry demand
is highly correlated with motor vehicle production, while there is very
little correlation with total industrial production. It may therefore be
concluded that the demand for polymeric coated substrates is probably a
result of the demand for new motor vehicles.
9.1.4.2 Demand Elasticity. Quantitative estimates of demand
elasticities are not available for the products whose manufacture may be
affected by the NSPS. Because most of the products affected are inter-
mediate or industrial products, estimates of demand elasticity are
usually generated from confidential producer-sponsored research. Further-
more, the number of products involved, variations in product quality, and
the high degree of captive consumption limit the availability of price
and production data that could be used to estimate quantitative demand
elasticities for this analysis.
On the basis of a qualitative assessment, however, it would appear
that the elasticities of demand for the majority of products covered by
the NSPS are probably low. There are three basic reasons for this
conclusion: (1) there are not many substitutes for the affected products;
(2) the affected products account for only a small portion of final
product price; and (3) many of the final products incorporating polymeric
coated substrates are necessities for which demand is relatively inelas-
tic. Consequently because demand elasticities are low, small changes in
the prices of the products affected by this NSPS will not prompt signifi-
cant changes in the quantities demanded.
9.1.4.3 Determinants of Supply. The output of an industry is
determined by the prices commanded by its products as well as by the
9-23
-------
TABLE 9-9. CORRELATION BETWEEN POLYMERIC COATING INDUSTRY OUTPUT AND
INDEXES OF MOTOR VEHICLE AND TOTAL U.S. INDUSTRIAL PRODUCTION
Year
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
Correlation
coating i
Estimated
polymeric coating
industry output9
($ 1982 X10'6)
6,892.0
6,445.6
5,801.5
6,252.6
6,935.9
7,147.8
6,897.5
5,757.0
5,984.5
5,781.3
coefficient with polymeric
ndustry output
Motor vehicles
production
and parts'3
(1967 = 100)
148.8
128.2
111.1
142.0
161.1
169.9
159.9
119.0
122.3
109.8
0.955
Total industrial
production0
(1967 = 100)
129.8
129.3
117.8
130.5
138.2
146.1
152.5
147.0
151.0
138.6
0.192
9-3.
Reference 7, p. 212.
cReference 7, p. 211.
9-24
-------
availabilities and prices of labor, capital, and raw materials. To some
extent, the importance of these factors in the decision to produce
depends upon whether the producer is a captive or commission coater. In
general, the captive coaters are those who coat with rubber and are part
of SIC 2296 (Tire Cord and Fabric) or SIC 3041 (Rubber and Plastics Hose
and Belting). SIC group 2295 (Coated Fabrics, Not Rubberized) is evenly
split between captive and commission coaters.
Commission coaters may be more sensitive to fluctuations in inter-
mediate product prices because they eventually sell the coated product
rather than process it further into consumer products. Commission
coaters generally operate on a job basis, negotiating price before the
decision to produce.
Captive coaters, on the other hand, do not sell the basic coated
product but process it further into some higher value product such as a
tire, belt, hose, or motor vehicle interior. Because a sale is not made
at the end of the coating process, no explicit product price is estab-
lished at that point.
Several conditions characterize the availability of factors of
production in this industry. First, firms tend to value the ability to
manufacture their own raw materials. This is true for both captive and
commission coaters, with firms in both groups manufacturing both the
substrates and the polymers used in the coating. Among the benefits of
this backward integration are increased control over quality, reduced
risk of raw material shortages, and increased flexibility to experiment
with new coating formulations and substrate types.9
Another important supply factor is the flexibility of the capital
equipment used in various coatings processes. For example, coating
equipment used in coating fabrics may be used in the manufacture of other
products without extensive modification. Among the other products that
may be manufactured are coated papers, films, and pressure-sensitive
adhesive tapes.10 Flexibility such as this has the effect of reducing
barriers to entry, and thereby increasing the degree of competitiveness
in the industry.
9-25
-------
9.1.5 Foreign Trade
9.1.5.1 Imports. Presented in Table 9-10 are import data covering
the period 1978-1982 for the three largest SIC segments of the polymeric
coating industry: SIC 2295 (Coated Fabrics, Not Rubberized); SIC 2296
(Tire Cord and Fabric); and part of SIC 3041 (Rubber and Plastics Hose
and Belting). In all segments, imports are small ranging from less than
0.1 to 2.5 percent of the value of domestic production.
With regard to SIC 2295, 1982 imports are valued at $22.8 million,
or about 1.9 percent of domestic production of comparable products for
the same year (see Table 9-3). The decline in imports from the preceding
years is most.likely a reflection of the recession rather than the onset
of a long-term decline. There is some evidence of variations in import
penetration for specific products; in particular, the ratio of imports to
domestic production for urethane-coated fabrics is probably higher than
that for other types of coated fabric.16
With regard to SIC 2296 (Tire Cord and Fabric), 1982 imports are
valued at $1.5 million. While this level represents a significant increase
over the levels for the preceding 4 years it represents less than 0.2
percent of 1982 domestic production.
Imports of belting and belts for 1982 are valued at $25.2 million,
or less than 3 percent of domestic production. Because statistics for
imported rubber hoses are not made available, it is assumed that such
quantities are not significant relative to domestic production. Conse-
quently, it appears that with the possible exception of urethane-coated
fabrics, import penetration is not likely to significantly affect the
ability of domestic producers to pass-through control related price
increases.
9.1.5.2 Exports. Table 9-11 presents the annual value of exports
for various polymeric-coated products, for the period 1978-1982. The
data cover SIC 2295 (Coated Fabrics), SIC 2296 (Tire Cord and Fabric),
SIC 2394 (Canvas Products), as well as parts of SIC 3041 (Rubber and
Plastics Hose and Belting) and SIC 3069 (Fabricated Rubber Products, Not
Elsewhere Classified). Comparison of this export data to the import data
discussed above shows that the U.S. is a net exporter of the subject
products.
9-26
-------
TABLE 9-10. VALUE OF IMPORTS FOR POLYMERIC COATED PRODUCTS, 1978-1982
Value of imports, $
S
1C Code
2295
2296
30412A
Product
Coated
19789
fabri
csf
Tire cord and fabrics9
Belting
and
beltsQ
28
0
26
.2
.2
.0
1979b
27.3
0.3
30.0
1980C
27
0
25
.0
.2
.2
1982 X106
1981d
27.2
0.5
21.7
19826
22.8
1.5
25.2
Reference 11.
bReference 12.
cReference 13.
Reference 14.
Reference 15.
fAdjusted to 1982 dollars by the Producer Price Index for textile products.
9Adjusted to 1982 dollars by the Producer Price Index for rubber products.
9-27
-------
TABLE 9-11. VALUE OF EXPORTS FOR POLYMERIC COATED PRODUCTS, 1978-1982
Value of exports, $
SIC Code
2295
2296
2394
30412A25
30412A45
30412A95
3069DO
Product
Coated fabrics^
Tire cord and fabric^
Canvas products^
Conveyor beltsQ
Motor vehicle belts9
Machinery belts9
Rubber coated fabrics9
1978a
96.5
75.1
7.8
18.0
22.7
24.7
53.3
1979b
117.9
93.6
16.0
24.6
22.1
27.8
51.3
198QC
104.9
163.4
7.5
18.8
19.5
42.0
75.3
1982 X106
1981d
102.1
111.4
15.0
17.1
19.8
24.1
70.6
19826
77.7
80.3
9.7
15.7
19.8
20.9
63.1
Reference 17.
Reference 18.
Reference 19.
^Reference 20.
Reference 21.
fAdjusted to 1982 dollars by the Producer Price Index for textile products.
9Adjusted to 1982 dollars by the Producer Price Index for rubber products.
9-28
-------
Exports of SIC 2295 exceeded 6 percent of total domestic production
for 1982, while exports of SIC 2296 were more than 7 percent of total
domestic production for the same year (see Table 9-3 for data on total
domestic production). A high ratio of exports to domestic production is
also observed for SIC 2394. Exports are an insignificant portion of the
total output of all other products identified.
9.1.6 Industry Growth
Table 9-12 presents projected annual growth rates for selected final
products manufactured from polymeric coated substrates. The rates range
from a low of 3.0 percent for the printing and recreational equipment
markets to a high of 12.1 percent for aircraft manufacturing. As
noted earlier, the demand for the products of the polymeric coating
industry is essentially derived from the consumer demand for the final
products that incorporate polymeric coated substrates as inputs. It is
difficult, however, to translate growth in final product demand into
estimates of demand increases for the products of the polymeric coating
industry. Complicating factors include: (1) style and technological
changes that could alter the amounts of coated materials consumed in each
product class; (2) the need to estimate the precise distribution of
coated material consumption among all final product classes; and (3) the
large number of final products for which growth rates would be required.
Nonetheless, an estimate of the growth rate of sales for the entire
polymeric coating industry can still be made by recognizing that the
demand for the industry's output is derived mainly from the demand for
motor vehicles. As discussed in Section 9.1.4.1, annual output levels
for the motor vehicles and polymeric coating industries are highly
correlated. This correlation, together with projected domestic produc-
tion of motor vehicles may be used to estimate future industry growth.
Table 9-13 lists output levels for both the motor vehicle and
polymeric coating industries for 1973-1982. By applying linear regression
to these output levels, output in the polymeric coating industry may be
expressed as a function of motor vehicle production. The parameters of
the function are specified by the equation:
$ PCSS (millions) = 3,188.43 + 20.93 $ MV (billions),
9-29
-------
TABLE 9-12. PROJECTED ANNUAL GROWTH RATES
FOR SALES OF SELECTED FINAL PRODUCTS
MANUFACTURED FROM POLYMERIC COATED SUBSTRATES3
Product/Market
Automobiles
Aircraft
Conveyor belts
Flexible hoses
Printing
Protective clothing
Recreational equipment
V-Belts
Growth rate, percent
4.8
12.1
3.4
3.9
3.0
5.0
3.0
3.3
Period
1980-1990
1982-1987
1983-1988
1982-1987
1983-1985
1981-1990
1982-1987
1983-1988
Reference 22.
9-30
-------
TABLE 9-13. DATA USED TO DERIVE INDUSTRY FORECAST EQUATION
Year
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
Value of
motor vehicle
output3
($ current X 10 9)
—
74.61
68.67
70.21
96.10
118.01
132.21
132.70
114.85
137.42
__
Producer
price
indexb
118.0
119.2
129.2
144.6
153.8
163.7
176.0
190.5
208.8
237.6
251.3
Value of
motor vehicle
output
($ 1982 X 10 9)
—
157.29
133.57
122.02
157.02
181.16
188.77
175.05
138.23
145.71
130. 82d
Value of
polymeric coating
industry
outputc
($ 1982 x 106)
--
6,892.0
6,445.6
5,801.5
6,252.6
6,935.9
7,147.8
6,897.5
5,757.0
5,984.5
5,781.3
Reference 23.
^Producer Price Index for
cTable 9-3.
d!982 value derived using
motor vehicles and equipment; Reference 24.
motor vehicle production index from Table 9-9.
9-31
-------
where:
$ PCSS = value of polymeric coating industry output, and
$ MV = value of motor vehicle industry output.
The coefficient of determination, or R 2, is 0.77, indicating that about
77 percent of the variation in polymeric coating output can be explained
by variations in the production of motor vehicles.
Estimates of future output levels for the polymeric coating industry
can be made using the above equation and forecasts of motor vehicle
production. The estimates obtained are presented in Table 9-14 and show
that the estimated value of output for 1990 is $7.2 billion (in 1982
dollars). This level represents an annual growth rate for the entire
industry of 2.8 percent per year over the period from 1982 to 1990.
9.2 ECONOMIC IMPACT ANALYSIS
9.2.1 Introduction and Summary
The following sections present an evaluation of the economic impacts
associated with the costs estimated to result from compliance with this
NSPS. Economic impacts are discussed in terms of percentage cost and
price changes along with qualitative evaluations of the implications of
the estimated changes. The socioeconomic impacts of the proposed NSPS
including inflationary, employment, and small business impacts are
described in Section 9.3. As noted in that section, the fifth-year
annualized costs of compliance with the most costly regulatory alterna-
tives are $1.9 million. Such costs are well below the $100 million level
that Executive Order 12291 specifies as one indicator of a major regula-
tory action.
With regard to price and cost increases, all regulatory alternatives
other than Regulatory Alternative IV, which requires the incineration of
captured VOC's, entail relatively small price and cost increases. For
reasons outlined in the following sections, it is not expected that such
cost and price increases will significantly affect either the demand for
polymeric coated substrates, the production rates of firms that manufac-
ture such products, or employment levels at such firms.
9-32
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TABLE 9-14. PROJECTED VALUE OF ANNUAL OUTPUT
FOR THE POLYMERIC COATING INDUSTRY, 1984-1990
Projected value of motor vehicle output
Year
1984
1985
1986
1987
1988
1989
1990
($ 1972 X10-V
84.85
84.28
82.11
90.70
95.66
94.79
90.72
($ 1982 X109)b
180.70
179.49
174.87
193.16
203.72
201.87
193.20
Projected value of
polymeric coating
industry output0
($ 1982 X109)
6.97
6.94
6.85
7.23
7.45
7.41
7.23
Reference 25.
I \\- 1 V* I \.r I ^sl, l~ \S •
bAdjusted through price index of Table 9-13.
cEstimated through equation $ PCSS (millions) = 3,188.43 + 20.93 $ MV (billions).
9-33
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9.2.2 Method
The method used to estimate potential economic impacts is based upon
an analysis of both cost and price changes that could be prompted by the
promulgation of this NSPS. The cost changes of concern are the incre-
mental net annualized costs incurred by the firms that would operate new
polymeric coating facilities. Price impacts refer to the extent to which
coating line product prices are expected to change if all NSPS-related
control costs, or in some cases cost savings, are passed to consumers.
Percentage cost changes are presented to provide an indicator of the
relative magnitude of NSPS costs for model plants of various types and
sizes under different levels of control. Price increases are estimated
in order to provide an evaluation of the extent to which typical coating
line product prices would be affected by the standard. Percentage cost
increases are estimated by dividing incremental net annualized control
costs by baseline annualized costs, while percentage price increases are
approximated by dividing incremental net annualized control costs by the
value of specific coating line products.
9.2.2.1 Cost Issues. The costs of concern in this analysis are the
incremental costs associated with operating coating facilities under
various NSPS control alternatives. Consequently, NSPS costs are measured
as increments above the baseline control level, or that level of control
required under State Implementation Plans. Baseline net annualized costs
are calculated by combining uncontrolled annualized costs with the costs
to control to the baseline level or Regulatory Alternative I. Thus, to
derive baseline net annualized costs for coating lines using carbon
adsorbers, the uncontrolled total annualized costs of Table 8-4 are added
to the Regulatory Alternative I net annualized costs presented in Table 8-9,
For purposes of this analysis it is assumed that all model facilities
will use carbon adsorber control systems rather than condensation systems,
because the use of the former is most typical of the coating industry.
Also the analysis is based upon the consideration of complete sets of
facilities, that is, coating operations together with compatible coating
preparation equipment and storage tanks. Finally, because each of the
affected facilities can be controlled to one of several levels not all
potential combinations of facilities and control levels are examined in
9-34
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this analysis. For example, because coating operations could be con-
trolled to one of four regulatory alternatives, while both coating
preparation equipment and storage tanks could be controlled to one of
three alternatives, 36 combinations of facility and control level
would be possible. Therefore, in order to limit the number of situations
examined, only those combinations that require each facility to be
controlled above the baseline level (i.e. Regulatory Alternative I) are
considered. Limiting the analysis in this way reduces the combinations
of facility and control alternatives to the 12 noted in Section 9.2.3.
9.2.2.2 Price Impacts. In order to obtain an indication of the
extent to which coating line product prices could be affected by the NSPS
control costs, typical products of the model lines have been identified.
The products of concern are in all cases intermediate products in that
they require further processing before being used in their intended
applications. Consequently, the prices for the products described below
are approximations of the value of the coated product at the end of the
coating stage of manufacturing.
The selection of typical products of the model lines is based upon
four general criteria. First, the product selected should be manufactured
through the application of a polymeric coating that is consistent with
the model line parameters described in Chapter 6. Second, the market
value of the product should adequately represent the value of all possible
products that could be produced at the model line. Third, reliable
price/value data should be available for the selected products. Fourth,
the selected products should be expected to exhibit some growth in output
over the next 5 years. Based upon these criteria, five products have
been selected as being representative of the four model lines previously
noted.
The model coating line "rubber-coated industrial fabric" is assumed
to have two typical products, offset printing blankets and diaphragms.
Printing blankets are used to transfer inked images from inking rollers
to paper and in some cases metal. The resiliency of rubber printing
blankets allows the use of a wide variety of paper thickness and texture.
The printing blankets examined in the price increase estimates of Section
9.2.3.2 are specified as being based upon a 72-inch wide cotton substrate,
9-35
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and are estimated to have a value of $16.57 per square yard when the
coating process is completed. 26
Diaphragms are constructed of rubber-coated nylon, and are used in a
variety of industrial applications including valves and seals. Diaphragm
valves are used to control the flow of slurries and corrosive fluids and
for vacuum. Diaphragms are also used as seals in packless valves. The
diaphragm material examined in the price analysis is based upon 48-inch
wide nylon, and has an intermediate value of $7.52 per square yard.27
The products of urethane coating lines can vary in terms of coating
thickness, substrate weight, and width. The product thought to be
typical of the."urethane-coated fabric" model line is a 60-inch wide,
1.7-oz nylon coated fabric. A common use for such a product is in the
construction of tents, but can also be used in other recreational equip-
ment including footware and luggage. The product described above is
estimated to have an intermediate value of $1.02 per square yard.28
V-belts are estimated to be typical of the "rubber-coated cord"
model line. Such belts are used in a variety of power and motion trans-
mission applications and are generally consumed by the automobile and
industrial equipment industries. The rubber-coated polyester cord used
to construct V-belts of various dimensions is estimated to have a value
of about $2.60 per pound. 29
The product selected as being typical of the model coating line
"epoxy-coated fiberglass" is aircraft parts. Such parts are used in
various applications by the military and aircraft construction industry,
including interior moldings and panels, roof linings, and aircraft
exteriors. The advantages of epoxy-coated fiberglass in these applica-
tions include its low weight and durability. It is estimated that the
epoxy-coated product used to fabricate aircraft products has a value of
about $3.75 per square yard. 30
In order to evaluate the extent to which various regulatory alter-
natives could increase the prices of the coating line products noted
above, the net annualized costs of such alternatives are expressed as
percentages of the total revenue generated by production of each product
at individual coating lines. These percentages are described in Section
9.2.3.2 along with some evaluation of the ability of individual firms to
9-36
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pass through control-related price increases. The probability that price
increases will be passed to the purchasers of the intermediate products
described above is based upon a qualitative evaluation of the degree of
competition among firms producing the affected products, the level of
price increases needed, and the elasticity of demand for the affected
products.
9.2.3 Analysis
9.2.3.1 Percent Cost Changes. As described in the previous section,
the effects of the cost to meet various regulatory alternatives are
described in terms of increased or decreased annual!zed costs as well as
increased or decreased product prices. With regard to costs, percentage
changes for each of the model lines are presented in Table 9-15. The
changes summarized in that table are generated by finding the incremental
net annual!zed control costs associated with meeting the appropriate
regulatory alternatives, and expressing those costs as a percent of the
baseline (i.e., Regulatory Alternative I) annualized costs for the same
facilities. The following example shows how the 0.50 percent cost
increase associated with the control of rubber-coated industrial fabric
model coating line B, and the compatible mix preparation equipment
and storage tank, to Regulatory Alternative III was estimated.
Net annual i zed incremental control costs to meet Regulatory Alterna-
tive III for the three facilities are determined by finding the difference
between the net annualized cost to control the coating operation to
Regulatory Alternative III (Table 8-11) and the cost to control the same
line to the baseline level (Table 8-9). In this example, the incremental
net annualized costs are $1,060. Because there are no costs to control
coating preparation equipment and storage tanks to the Regulatory Alterna-
tive I baseline, the appropriate increments for these facilities are
found in Tables 8-8 and 8-6, respectively. The appropriate increments in
this example are $2,705 for coating preparation equipment and $3,418 for
storage tanks. Thus the total net annualized incremental cost to control
all three facilities to Regulatory Alternative III is $7,183.
With regard to baseline (Regulatory Alternative I) net annual i zed
costs, such costs are determined for the three facilities by adding the
uncontrolled annualized costs for the three facilities (Tables 8-2, 8-3,
9-37
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TABLE 9-15. PERCENT COST INCREASES FOR MODEL PLANTS3
Rubber-
Regulatory alternative Rubber-coated Urethane-coated coated Epoxy-coated
CoatingCoatingStorage industrial fabric fabric cord fiberglass
Operation Preparation Tank A B C B C ' A B B C
II II II 0.00 -0.18 -0.34 -0.17 -0.20 0.00 -0.16 2.00 1.12
II II III 0.35 0.05 -0.21 -0.17 -0.20 0.31 0.04 2.06 1.16
II III II 0.64 0.15 -0.19 -0.17 -0.20 0.58 0.14 2.10 1.18
II III III 0.99 0.37 -0.05 -0.17 -0.20 0.89 0.34 2.17 1.21
III II II 0.27 -0.04 -0.35 -0.22 -0.29 0.25 -0.04 2.07 1.11
10
8 III II III 0.62 0.18 -0.21 -0.22 -0.29 0.56 0.16 2.13 1.15
III III II 0.92 0.28 -0.19 -0.22 -0.29 0.82 0.26 2.18 1.17
III III III 1.26 0.50 -0.06 -0.22 -0.29 1.13 0.46 2.24 1.20
IV II II 4.11 4.47 4.40 2.00 2.03 3.44 3.84 2.26 1.38
IV II III 4.46 4.69 4.54 2.00 2.03 3.75 4.04 2.33 1.42
IV III II 4.75 4.79 4.56 2.00 2.03 4.02 4.14 2.37 1.43
IV m III 5.10 5.01 4.69 2.00 2.03 4.33 4.34 2.44 1.47
aAssumes use of carbon adsorber for Regulatory Alternatives II and III, and incinerator for
Regulatory Alternative IV.
-------
and 8-4) to the Regulatory Alternative I costs for coating operations
(Table 8-9). As noted previously, the baseline costs for coating prep-
aration equipment and storage tanks are zero, consequently the total net
annualized baseline costs for all three facilities are obtained through
the addition of the uncontrolled net annualized costs for the coating
operation ($1,302,340), coating preparation equipment ($86,410), and
storage tank ($2,390), to the Regulatory Alternative I cost for the
coating operation ($42,690), or a total of $1,433,830. Finally, the
percentage increase in annualized cost attributable to Regulatory
Alternative III is 0.50 percent (i.e. ($7,183/$1,433,830) x 100).
The percentage cost changes summarized in Table 9-15 are generally
less than 1 percent with the exception of Regulatory Alternative IV for
coating operations, and epoxy-coated fiberglass facilities under all
regulatory alternatives. Regulatory Alternative IV increases are excep-
tionally high because this most stringent control option requires that
all VOC emissions be incinerated, rather than captured and reused, thus
eliminating product recovery credits. Epoxy-coated fiberglass facilities
show relatively high cost increases because such coating operations do
not require control equipment to meet Regulatory Alternative I emission
limits. Consequently, the incremental costs of meeting more stringent
emission levels are relatively high for these types of facilities.
9.2.3.2 Price Changes. As noted in Section 9.2.2.2, coating
operation product price impacts are estimated by selecting a number of
products that are typical of the output of the model plants described in
previous sections. These products are summarized in Table 9-16, along
with estimates of annual quantities capable of being produced at the
appropriate model plants, estimates of product value at the end of the
coating process and annual revenue estimates based upon the price and
quantity levels noted. Specific product price increases are estimated
through the expression of incremental net annualized costs as a percent
of the revenues noted under various combinations of regulatory alterna-
tives. These percentages are presented in Table 9-17.
The percent price increases estimated for the typical products of
the rubber-coated industrial products model plant are generally less than
one-half of 1 percent for all combinations of regulatory alternatives
9-39
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10
I
TABLE 9-16. ANNUAL REVENUE ESTIMATES
FOR MODEL LINES PRODUCING TYPICAL PRODUCTS
(First Quarter 1984 Dollars)
Model coating line/product
Annual Intermediate
quantity product value
Line/ produced or price3
size (yd2/yr) ($/yd2)
Rubber-coated industrial fabric
- Printing blankets'3
(72-inch wide cotton)
- Diaphragmsc
(48-inch wide nylon)
Urethane-coated fabric
- Tent material0
(60-inch wide,
1.7 oz nylon)
Rubber-coated cordb
- V-belts
(polyester cord)
Epoxy-coated fiberglass^
- Aircraft parts
(72-inch wide,
20 oz fiberglass
fabric)
1A
IB
1C
1A
IB
1C
2B
2C
3A
3B
4B
4C
137,508
222,616
445,230
580,970
940,550
1,881,100
13,091,480
26,199,140
193.1 tons/yr
312.6 tons/yr
1,512,112
3,024,224
16.57
16.57
16.57
7.52
7.52
7.52
1.02
1.02
2.60/lb
2.60/lb
3.75
3.75
Annual
revenue per
coating line
($/yr)
2,278,510
3,688,750
7,377,460
4,368,900
7,072,940
14,145,870
13,353,310
26,723,120
1,004,120
1,625,520
5,670,420
11,340,840
aThe product prices implied by the values reported here are based upon the re-
view of confidential data supplied by manufacturers. However, where such values/
prices can be compared to the product prices implied by the Census of Manu-
factures data summarized in Table 9-5 (i.e. rubber belts and cords, and urethane-
coated tent fabric) the product prices reported by both sources are reasonably
consistent.
Reference 26.
Reference 27.
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TABLE 9-17. PERCENT PRICE INCREASES FOR TYPICAL PRODUCTS*
Regul atory
alternative
CQC
II
II
II
II
III
III
III
III
IV
IV
IV
IV
Cpd
II
II
III
III
II
II
III
III
II
II
III
III
ST&
II
III
II
III
II
III
II
III
II
III
II
III
Printing blankets
A
0.00
0.14
0.26
0.40
0.11
0.25
0.37
0.51
1.66
1.80
1.92
2.06
B
-0.07
0.02
0.06
0.14
-0.02
0.07
0.11
0.19
1.74
1.82
1.86
1.95
C
-0.11
-0.07
-0.06
-0.02
-0.11
-0.07
-0.06
-0.02
1.40
1.45
1.45
1.50
Diaphragms
A
0.00
0.07
0.14
0.21
0.06
0.13
0.19
0.27
0.87
0.94
1.00
1.07
B
-0.04
0.01
0.03
0.07
-0.01
0.04
0.06
0.10
0.91
0.95
0.97
1.02
C
-0.06
-0.03
-0.03
-0.01
-0.06
-0.04
-0.03
-0.01
0.73
0.75
0.76
0.78
Tents
B
-0.07
-0.07
-0.07
-0.07
-0.10
-0.10
-0.10
-0.10
0.87
0.87
0.87
0.87
C
-0.08
-0.08
-0.08
-0.08
-0.12
-0.12
-0.12
-0.12
0.84
0.84
0.84
0.84
V-belts Aircraft parts
A
0.00
0.32
0.59
0.91
0.25
0.57
0.84
1.16
3.51
3.83
4.10
4.42
B
-0.16
0.04
0.13
0.33
-0.04
0.16
0.25
0.44
3.67
3.86
3.95
4.15
B
1.67
1.73
1.77
1.82
1.73
1.79
1.83
1.88
1.89
1.95
1.99
2.04
C
0.89
0.92
0.93
0.96
0.88
0.91
0.92
0.95
1.09
1.12
1.14
1.16
a$ee Table 9-16 for specifications of products.
bAssumed use of carbon adsorber for Regulatory Alternatives II and III, and incerator for Regulatory Alterna-
tive IV.
CCO = Coating operation.
^CP = Coating preparation.
eST = Storage tank.
-------
with the exception of those that require the incineration of captured
VOC's (i.e. Regulatory Alternative IV for coating lines). Price increases
of this level are not considered to be significant, especially in light
of the fact that there are no comparable substitutes for the printing
blanket and diaphragm products, and that the prices for these products
represent only a very small portion of the costs of the final products
(i.e., printing and industrial process equipment) of which they are a
part. Because these two conditions are indicative of inelastic demand,
it is concluded that the price increases estimated will be paid by
the consumers of the rubber-coated industrial products noted.
With regard to the tent material manufactured by the urethane-coated
fabric model line, the cost decreases provided by the capture and recovery
of solvents would allow price decreases for products produced from these
lines. Therefore, it is not expected that any adverse demand-related
consequences could result from the promulgation of control alternatives
other than Regulatory Alternative IV.
If Regulatory Alternative IV is proposed for urethane coating lines,
the incineration of VOC's could cause price increases of about 2-1/2
percent. The ability to pass through price increases of this level would
be questionable, because the threat of foreign imports is most significant
for urethane-coated fabrics.31
Price increases for the V-belt products manufactured at new rubber-
coated cord lines are generally less than 1 percent for regulatory
alternatives that capture and recover solvents. In these cases it is
expected that price increases could be passed to the manufacturers and
owners of motor vehicles who are the largest consumers of V-belt products.
This conclusion is based upon the belief that demand elasticity for
V-belts is very low because the products are necessities, with no substi-
tutes, and such belts represent a very small portion of the total cost of
the vehicles in which they are used.
Price increases for aircraft parts manufactured at epoxy-coated
fiberglass lines are estimated to range from about 1 to 2 percent. Even
though these percentages are generally higher than those estimated for
the other affected products, the consuming industries that purchase these
products can be expected to ultimately pay the required price increases.
9-42
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The consuming industries in this case are the manufacturers of civilian
and military aircraft that are eventually purchased by the Department of
Defense, airlines and other private companies, and foreign governments.
Low demand elasticities are most likely because the affected products
have no substitutes that offer comparable combinations of weight and
strength, and because the cost of the affected products are very small
compared to the total cost of the aircraft in which they are used.
9.3 SOCIOECONOMIC AND INFLATIONARY IMPACTS
The analysis presented in Section 9.2 describes the effects that
this NSPS could have upon prices and production costs of polymeric coated
substrates. In this section the potential for more general economic
impacts is discussed. Included among the issues addressed here are those
required to be considered by Executive Order 12291 including inflation
and employment impacts. Also addressed is the potential for small
business impacts as required by the Regulatory Flexibility Act. These
issues are considered after a review of the method by which the industry
growth estimates of Section 9.1.6 are expressed in terms of new plant
construction.
9.3.1 New Plant Construction
In order to project the total annualized costs of this NSPS during
the fifth year after its proposal, an estimate of the number of new
coating facilities that will be constructed over that period is needed.
The basis for the projection of new facilities described below is the
total industry annual growth estimates presented in Table 9-14.
The first step requires the estimation of the total value of output
required of new solvent-based coating operations over the five-years
including 1986 and 1990. The data summarized in Table 9-18 show that an
estimate of $79 million (1982 dollars) in new output is obtained by
observing the total output levels presented in Table 9-14, finding
increments over full capacity output needed for each year, and modifying
the annual increments by a factor to account for the general decline in
solvent-based output. The full capacity levels noted in Table 9-18 are
based upon the assumption that industrywide full capacity is defined by
the highest annual output level observed during recent years. Table 9-3
9-43
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TABLE 9-18. TOTAL VALUE OF NEW SOLVENT-BASED CAPACITY REQUIRED 1986-1990
10
i
Total industry
sales capacity3
Year ($1982 x 109)
1986
1987
1988
1989
1990
6.85
7.23
7.45
7.41
7.23
Current full
capacity'3
($1982 x 109)
7.15
7.15
7.23
7.45
7.45
Needed new
capacity0
($1982 x 10 9]
0.00
0.08
0.22
0.00
0.00
Solvent New solvent-
use based capacity
1 factord ($1982 x 10 9)
0.320
0.288
0.256
0.224
0.192
5-year total =
0.000
0.023
0.056
0.000
0.000
0.079
3Table 9-14.
bYearly values equal highest capacity observed during previous years.
cPositive difference between the total industry sales capacity and current full
capacity.
Derivation explained in Section 9.3.1.
eNeeded new capacity times solvent use factor.
-------
shows that before 1987 the highest industry output level was $7.15
billion, produced during 1978. This amount is assumed to represent full
capacity until 1987 when the $7.23 billion estimated to be produced
during that year becomes the new full capacity level.
The annual increments to capacity are modified by the solvent use
factors noted to represent the reduced popularity of solvent-based
coating methods due to solvent costs and environmental and health and
safety concerns. The factors used have been obtained through the linear
extrapolation of data indicating that in 1976 about 64 percent of all
coated substrate products were produced through the use of solvents,
while in 1981 this percentage declined to 48 percent.32 Because it is
expected that this trend will continue into the late 1980's the total
value of output from new solvent-based capacity is estimated to be $79
million (1982 dollars). Finally, in order to allow comparison with the
value of output from the model plants, this total is expressed in terms
of first quarter 1984 dollars, through the use of the Producer Price
Index for Industrial Commodities. Because this index stood at 272.8 in
1982, and 285.5 for for the first quarter of 1984, the total value of
output from new solvent-based capacity is $83 million in first quarter
1984 dollars.33, 34
The second step in the new plant projection method requires the
estimation of the total value attributed to production from model plants.
Because the industrywide total value amounts previously described include
some value-added due to processing of coated products beyond the coating
operation itself, some adjustment to the product values implied by the
baseline model plant cost data of Chapter 8 is required, in order to put
the plant output data on a comparable basis. For example, that portion
of the total industry output projection that accounts for the production
of V-belts, reports the value of the coating operation product (rubber-
coated polyester cord) after it has been further processed into the
V-belt product. Consequently, dividing the coating operation cost (or
rubber-coated polyester cord product value) into the value of future
demand for V-belt type products would tend to overstate the number of new
lines needed to satisfy future demand. In order to adjust for this
discrepancy, coating line product values, as estimated by the baseline
costs of Chapter 8, are increased to account for additional processing
9-45
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that coated products typically receive before their sale. Such increases
have been made through the consideration of data reported in the 1982
Census of Manufacturers which indicates that for rubber fabric and rubber
cord coating operations, the value of shipments by these companies
typically exceed the cost of materials purchased by a 2 to 1 ratio. 35 36
Furthermore, for all other fabric coating companies, including urethane
fabric and epoxy fiberglass coating operations, the same ratio is 1.6 to
1. 37 Thus in order to quantify the value of shipments associated with
the output of the model coating operations, the total raw material costs
of the model lines presented in Table 8-4, are increased according to the
appropriate ratios. The resulting values are then directly comparable to
the new capacity dollar values presented in Table 9-18.
The final step in the new plant projection method entails the
expression of the increased capacity requirements in terms of the number
of new coating facilities. This is accomplished through the division of
increased capacity requirements in terms of value of output ($83 million)
by the total value of annual production from all model plants ($55
million). Therefore, assuming that new production would be distributed
evenly among the model plants, approximately two of each of the nine
model coating operations, coating preparation and storage tank facilities
described in Chapter 6, would be needed to satisfy increases in demand
over the next 5 years. Finally, because most coating line and related
equipment is easily repaired and tends to have a long life expectancy,
new plant construction related to the replacement of aged facilities is
not considered by the method described above.
9.3.2 Executive Order 12291
As defined by Executive Order 12291,38 "major rules" are those
that are projected to have any of the following impacts:
o An annual effect on the economy of $100 million or more;
o A major increase in costs or prices for consumers, individual indus-
tries, federal, State, or local government agencies or geographic
regions; or
9-46
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o Significant adverse effects on competition, employment, investment,
productivity, innovation, or on the ability of United States-based
enterprises to compete with foreign-based enterprises in domestic or
export markets.
9.3.2.1 Fifth-Year Annualized Costs. The estimation of fifth-year
annual ized costs, under the most costly regulatory alternatives, is
presented in Table 9-19. The table shows that the highest cost regulatory
alternatives would entail increased annualized costs of about $1.9
million, after all affected facilities are constructed. This amount is
derived by taking the incremental net annualized costs required to meet
the most costly alternatives and multiplying by the number of new facil-
ities expected. It should be noted that this worst-case estimate of
fifth-year annualized costs is well below the $100 million threshold
specified by the Executive Order. If coating lines are controlled to
Regulatory Alternative III, rather than IV as assumed above, fifth-year
costs are reduced to about $413 thousand.
9.3.2.2 Inflationary Impacts. It is expected that the promulgation
of this NSPS would have no effect upon the rate of inflation in the U.S.
economy. Even at the industry level, price increases prompted by the
fifth-year costs noted above would be imperceptable because the total
annual value of the industry's output is expected to exceed $7 billion
during future years.
9.3.2.3 Employment Impacts. The costs of compliance with this
NSPS are not expected to have a measurable effect upon the level of
employment in the polymeric coating industry. Employment impacts are
unlikely because it is not expected that new plant construction will be
adversely affected, nor will new plants operate at reduced rates which
could warrant lower levels of employment.
9.3.2.4 Balance of Trade Impacts. For most of the products affected
by this NSPS, the level of foreign trade is relatively low (see Section
9.1.5). This fact together with the very small cost/price increases
previously noted, indicates that significant effects upon the U.S.
balance trade are unlikely. For the urethane-coated products, where
imports could increase even in the absence of this standard, domestic
9-47
-------
10
I
-p*
00
TABLE 9-19. SUMMARY OF FIFTH-YEAR ANNUALIZED COSTS
UNDER MOST COSTLY REGULATORY ALTERNATIVES3
(First Quarter 1984 Dollars X103)
Product type/
line size
Rubber-coated
industrial fabric
A
B
C
Urethane-coated
fabric
B
C
Rubber-coated
cord
A
B
Epoxy-coated
fiberglass
B
C
Net
cost
annual ized
per facility
Coating Coating Storage
operation preparation tank
38.60
65.75
107.23
116.43
225.18
36.04
61.26
109.76
128.62
4.87 3.43
2.71 3.42
-0.13 3.38
- _
4.87 3.43
2.71 3.42
2.64 3.41
0.06 3.35
Number
Coating
operation
2
2
2
2
2
2
2
2
2
of new facil
Coating
preparation
2
2
2
-
2
2
2
2
itiesb
Storage
tank
2
2
2
-
2
2
2
2
Total
Total net
annual ized cost
93.80
143.76
220.96
232.86
450.36
88.68
134.78
231.62
263.82
= 1,860.64
aCoating operations controlled to Regulatory Alternative IV, other facilities controlled to
Regulatory Alternative III.
bNumber of new facilities needed to satisfy demand over next five years as described in
Section 9.3.1.
-------
product prices should not be increased by this NSPS. Consequently, the
standard will not prompt an increase in such imports.
9.3.2.5 Impacts Upon Investment. Productivity, and Innovation. It
is expected that the relatively low costs of compliance with this NSPS
will not affect investment, productivity, or innovation in the solvent-
based portion of the polymeric coating industry. Although there has been
a noted trend away from the use of solvents in the industry, this trend
is not expected to be compounded by the costs described above. This is
apparently so because while the use of solvents by the industry declined
about 25 percent from 1976 to 1981 (see Section 9.3.1) the cost of those
solvents increased approximately 300 percent. Consequently, it appears
that the use of solvents may be relatively insensitive to small changes
in solvent prices, or the costs of using such solvents in coating pro-
cesses. This is especially true of the minor cost changes previously
noted. Instead, it may be more likely that if the general trend away
from solvent use continues it may be a result of a combination of factors
including: technical improvements in alternative coating methods,
concern for worker health and safety, and uncertainty regarding the
continuous availability of solvent supplies.
9.3.3 Small Business Impacts and the Regulatory Flexibility Act.
The Regulatory Flexibility Act stipulates that if a proposed rule is
likely to have a significant economic impact on a substantial number of
small entities, the proposing agency must, among other things, prepare an
Initial Regulatory Flexibility Analysis. In response to this requirement,
EPA has developed guidelines defining what is meant by a "significant
economic impact" and a "substantial number."39 A significant impact
is said to exist whenever any of the following criteria are satisfied:
(1) annual compliance costs increase total production costs for small
entities by more than 5 percent; (2) compliance costs as a percent of
sales for small entities are at least 10 percentage points higher than
compliance costs as a percent of sales for large entities; (3) capital
costs of compliance represent a significant portion of capital available
to small entities, considering internal cash flow plus external financing
capabilities; or (4) the requirements of the regulation are likely to
result in closures of small entities. A substantial number is defined as
9-49
-------
being achieved if more than 20 percent of the affected small entities are
subject to significant economic impact.
A given polymeric coating company will only be affected by this NSPS
if it either constructs new facilities, or modifies or reconstructs
existing facilities. As discussed in Section 9.3.1, it is anticipated
that over the period 1986-1990, a total of 18 polymeric coating plants
will become subject to the NSPS. The projected distribution by plant
size and type are noted in Table 9-19.
In this analysis, the question of what constitutes a small business
was resolved using business size criteria developed by the U.S. Small
Business Administration. According to these criteria, a firm in SIC
group 2295 is classified as small if it has fewer than 1,000 employees.
The cutoff for SIC groups 3041 and 3069 is 500 employees."0 Given
these employment sizes, it is conceivable that even the large plants
could be owned by small firms. In the extreme case, then, as many as 18
small businesses could be affected by the NSPS.
As the analysis in Section 9.2 indicates, however, the economic
impacts on the plants are likely to be insignificant in nearly all cases.
The only exception is in the case of Regulatory Alternative IV, where the
percentage increase in production cost due to compliance can exceed 5
percent in two cases. In all other situations, cost increases are well
below 5 percent.
9-50
-------
9.4 REFERENCES FOR CHAPTER 9
1. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Coated Fabrics, Not Rubberized. MC82-I-22F-5(P).
May 1984.
2. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Tire Cord and Fabric. MC82-I-22F-6(P). July 1984.
3. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Canvas and Related Products. MC82-I-23E-4(p). April
1984.
4. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Rubber and Plastics Hose and Belting. MC82-I-30A-4(P)
June 1984.
5. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Fabricated Rubber Products, N.E.C. MC82-I-30A-5(P).
February 1984.
6. U.S. Bureau of the Census. 1982 Census of Manufactures -- Prelim-
inary Report: Gaskets, Packing and Sealing Devices. MC82-I-32E-3(P)
April 1984.
7. Economic Report of the President. Washington, D.C., U.S. Government
Printing Office. February 1983. p. 163.
8. U.S. Bureau of the Census. 1977 Census of Manufactures -- Concentra-
tion Ratios in Manufacturing. MC77-SR-9. May 1981.
9. Frost and Sullivan, Inc. Flexible Coated and Laminated Materials
and Products Market in the United States. New York. Spring 1982.
p. 18.
10. Reference 9, pp. 16-17-
11. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1978. 1979.
Table 1.
12. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1979. 1980.
Table 1.
13. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1980. 1981.
Table 1.
14. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1981. 1982.
Table 1.
9-51
-------
15. U.S. Bureau of the Census. U.S. Imports/Consumption and General,
SIC-Based Products by World Areas. FT210/Annual 1982. 1983.
Table 1.
16. Reference 9, p. 23.
17. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1978. 1979.
Table 1.
18. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1979. 1980.
Table 1.
19. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1980. 1981.
Table 1'.
20. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1981. 1982.
Table 1.
21. U.S. Bureau of the Census. U.S. Exports/Domestic Merchandise,
SIC-Based Products by World Areas. FT610/Annual 1982. 1983.
Table 1.
22. Predicasts. Forecast Abstracts 1983. pp. 80, 140, 251, 357, 358,
539, 552, 579.
23. Wharton Econometric Forecasting Associates. Industry Planning
Service - Historical Review. May 1982. p. A-76.
24. Reference 7. p. 231.
25. Wharton Econometric Forecasting Associates. Industry Planning
Service - Ten-Year Outlook. Volume 3. Number 5. May 1984. p.
D-24.
26. Letter from Friedman, E.M., MRI, to Costello, T.V., JACA Corp.
October 2, 1984.
27. Letter from Banker, L.C., MRI, to Costello, T.V., JACA Corp.
February 13, 1985.
28. Reference 27.
29. Reference 26.
30. Reference 26.
31. Reference 9, p. 23.
32. Reference 9, p. 22.
9-52
-------
33. U.S. Bureau of Labor Statistics. Monthly Labor Review. December
1983. p. 90.
34. U.S. Bureau of Labor Statistics. Monthly Labor Review. October
1984. p. 80.
35. Reference 5, p. 3.
36. Reference 4, p. 3.
37. Reference 1, p. 3.
38. The President. Executive Order 12291 - Federal Regulation. Federal
Register. February 19, 1981. p. 13193.
39. Memo from Administrator, EPA, to Associate Administrators, Assistant
Administrators, Regional Administrators, and Office Directors.
February 9, 1982. EPA Implementation of the Regulatory Flexibility
Act.
40. U.S. Small Business Administration. Small Business Size Standards.
Federal Register. February 9, 1984. pp. 5023-5048.
9-53
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APPENDIX A
EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
The purpose of this study was to develop a basis for new source
performance standards (NSPS) for industries that perform polymeric
coating of supporting substrates. To accomplish the objectives of this
program, technical data were acquired on: (1) solvent storage tanks,
coating preparation equipment, and coating operations; (2) the release
and controllability of organic emissions into the atmosphere by these
sources; and (3) the types and costs of demonstrated emission control
technologies. The bulk of the information was gathered from the following
sources:
• Technical literature
• State, regional, and local air pollution control agencies
• Plant visits
• Industry representatives
• Engineering consultants and equipment vendors
• Emission source testing data
Significant events relating to the evolution of the BID are itemized in
Table A-l.
A-l
-------
TABLE A-l. EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
Date
Company, consultant,
or agency/location
Nature of action
06/16/83
06/21/83
06/22/83
06/29/83
09/15/83
10/24/83
10/25/83
10/26/83
11/02/83
11/03/83
01/27/84
Reeves Brothers, Inc.
Buena Vista, Va.
The Kenyon Piece Dyeworks, Inc.
Kenyon, R.I.
Aldan Rubber Company
Philadelphia, Pa.
Burlington Industrial Fabrics
Kernersville, N.C.
U. S. EPA
Research Triangle Park, N.C.
The Gates Rubber Company
Denver, Colo.
Murray Rubber Company
Houston, Tex.
Utex Industries, Inc.
Weimar, Tex.
Victor Products Division
Dana Corporation
Chicago, 111.
Dayco Corp.
Three Rivers, Mich.
The Bibb Company
Macon, Ga.
Chemprene, Inc.
Bacon, N.Y.
W. R. Grace and Company
Lexington, Mass.
Plant visit
Plant visit
Plant visit
Plant visit
Memo authorizing
Phase II—"Draft
Development of New
Source Performance
Standards for
Elastomeric Coating of
Fabrics"
Plant visit
Plant visit
Plant visit
Plant visit
Plant visit
Section 114
information request
(continued)
A-2
-------
TABLE A-l. (continued)
Date
Company, consultant,
or agency/location
Nature of action
02/03/84
04/03/84
07/10-19/84
08/17/84
09/09/84
09/123/84
09/20/84
09/28/84
10/26/84
Hexcel Corp.
Dublin, Calif.
Kellwood Company
New Haven, Mo.
Nylco Corp.
Nashau, N.H.
ODC, Inc.
Norcross, Ga.
Ferro Corp.
Cleveland, Ohio
The Amerbelle Corp.
Rockville, Conn.
ODC, Inc.
Norcross, Ga.
Plant B
U. S. EPA
Research Triangle Park, N.C,
The Bibb Company
Macon, Ga.
Plant C
Mailed to industry members,
selected equipment vendors,
and consultants
Mailed to industry members,
selected equipment vendors,
and consultants
Mailed to industry members,
selected equipment vendors,
consultants
Section 114
information request
Plant visit
Emission test
Change of scope and
name of project to
"Polymeric Coating of
Supporting Substrates"
Revised Section 114
information request
Emission test
Advance Notice of
Proposed Rule
Request for comment on
draft BID Chapters 3,
4, 5, and 6
Request for comment on
draft BID Chapter 8 and
(continued)
A-3
-------
TABLE A-l. (continued)
Date
Company, consultant,
or agency/location
Nature of action
01/12/85
01/15/85
01/16/85
01/17/85
05/31/85
08/08/85
09/18/85
10/29/85
U.S. Polymeric
Santa Ana, California
Narmco Materials
Anaheim, California
Fiberite Corp.
Orange, California
Hexcel Corp.
San Francisco, California
Mailed to members of the
Working Group
Mailed to members of the
Steering Committee
U.S. EPA and industry
representatives
Mailed to members of
Red Border review
Plant visit
Plant visit
Plant visit
Plant visit
Working Group mail out
Steering Committee
mail out
NAPCTAC Meeting
Red Border review
A-4
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APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
This appendix consists of a reference system which is cross-indexed
with the October 21, 1974, Federal Register (39 FR 37419) containing the
Agency guidelines concerning the preparation of environmental impact
statements. This index can be used to identify sections of the document
which contain data and information germane to any portion of the Federal
Register guidelines.
B-l
-------
TABLE B-l. CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the Background
Information Document
1. BACKGROUND AND SUMMARY OF
REGULATORY ALTERNATIVES
Summary of regulatory alternatives
Statutory .basis for proposing
standards
Relationship to other regulatory
agency actions
Industry affected by the
regulatory alternatives
Specific processes affected by
the regulatory alternatives
2. REGULATORY ALTERNATIVES
Control techniques
The regulatory alternatives from
which standards will be chosen
for proposal are summarized in
Chapter 1, Section 1.1.
The statutory basis for proposing
standards is summarized in
Chapter 2, Section 2.1.
The relationships between EPA
and other regulatory agency
actions are discussed in
Chapters 3, 7, and 8.
A discussion of the industry
affected by the regulatory
alternatives is presented in
Chapter 3, Section 3.1. Further
details covering the business and
economic nature of the industry
are presented in Chapter 9,
Section 9.1.
The specific processes and
facilities affected by the
regulatory alternatives are
summarized in Chapter 1,
Section 1.1. A detailed
technical discussion of the
processes affected by the
regulatory alternatives is
presented in Chapter 3,
Sections 3.2 and 3.3.
The alternative control
techniques are discussed in
Chapter 4.
(continued)
B-2
-------
TABLE B-l. (continued)
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the Background
Information Document
Regulatory alternatives
3.
ENVIRONMENTAL IMPACT OF THE
REGULATORY ALTERNATIVES
Primary impacts directly
attributable to the regulatory
alternatives
Secondary or induced impacts
4. OTHER CONSIDERATIONS
The various regulatory alterna-
tives are defined in Chapter 6,
Section 6.2. A summary of the
major alternatives considered
is included in Chapter 1,
Section 1.1.
The primary impacts on mass
emissions and ambient air quality
due to the alternative control
systems are discussed in
Chapter 7, Sections 7.1, 7.2,
7.3, 7.4, and 7.5. A matrix
summarizing the environmental
impacts is included in
Chapter 1.
Secondary impacts for the various
regulatory alternatives are
discussed in Chapter 7,
Sections 7.1, 7.2, 7.3, 7.4, and
7.5.
A summary of the potential
adverse environmental impacts
associated with the regulatory
alternatives is included in
Chapter 1, Section 1.2, and
Chapter 7. Potential socio-
economic and inflationary impacts
are discussed in Chapter 9,
Sections 9.2 and 9.3.
B-3
-------
APPENDIX C
EMISSION SOURCE TEST DATA
The emission source test data presented here were obtained from EPA-
sponsored testing at a polymeric coating plant and related web coating
facilities and from industry records of solvent recovery efficiencies.
C.I EPA-SPONSORED TESTS AT POLYMERIC COATING PLANTS
C.I.I. Plant B
Tests were conducted at Plant B to determine (1) the total volatile
organic compound (VOC) reduction efficiency of a single polymeric coating
operation and (2) the control efficiency of a fixed-bed carbon adsorber
system.
Plant B manufactures gaskets, diaphragms, and seals used by the oil
industry. Rubber-coated cord and fabric are produced as the first step in
the manufacturing process. During the test series, a single solvent,
methyl ethyl ketone (MEK), was used for the preparation of rubber coatings
and equipment clean-up. The coating used was a formulation of 82 percent
MEK and 18 percent synthetic rubber, by weight. Figure C-l is a schematic
of solvent/process flow at Plant B.
A continuous web of fabric is fed from a roll into the dip vat
located 2 to 3 feet prior to entering the vertical tower drying oven. The
coated fabric enters the drying oven through an opening above the dip vat
and travels between air plenums. Make-up air for the oven is furnished
from louvered openings in the oven air-recirculation loop, web entrance
and exit slots, and any leaks through the door seals in the oven. These
doors are frequently opened to observe and adjust the coated fabric.*
*A telephone survey of the industry showed that the opening of oven doors
during operation is highly unusual.
C-l
-------
The dip vat is surrounded by a total enclosure that has viewing
windows on three of the four sides. The enclosure is maintained under
negative pressure with respect to the coating room by virtue of the draft
created by the drying oven. Air enters the enclosure through the web
entrance slot and presumably through any leaks in the doors.
The drying oven is maintained under negative pressure relative to the
dip vat enclosure; hence, room air drawn into the enclosure is in turn
drawn into the drying oven. Solvent vapors from the fabric coater drying
oven, the cord coater drying oven, the enclosure, and the scrap solids
bake oven are ducted to a carbon adsorption system.
Figure C-2 shows the locations of continuous or discrete-stream VOC
concentration/content and flow rate measurements made during the test
program. Table C-l lists process parameters monitored during source
testing.
C.I.1.1 Valid Test Data.
C.I.1.1.1 Carbon adsorber efficiency. Process parameters for the
fixed-bed carbon adsorption system are presented in Table C-2. This
system features continuous regeneration using high-temperature nitrogen.
The carbon adsorber produces a recovered solvent/water stream that is
continually delivered to a recovery tank. Based on plant process
instrumentation, the carbon adsorber typically operates at 98-percent
efficiency, which decreases with increasing carbon service life. Expected
useful carbon life is 6 to 9 months.
During the 4-day test period, the carbon adsorber inlet VOC
concentration was monitored by a method similar to EPA Method 25A. The
analysis was performed by a Byron Model 401 THC analyzer. Gas flow rate
to the carbon adsorber was measured according to EPA Method 2. The
exhaust air from the carbon adsorber was monitored for VOC concentration
by a method and procedure similar to that used for the carbon adsorber
inlet. It was not possible to perform a velocity traverse on the carbon
adsorber outlet due to the configuration of the exhaust stack. However,
the outlet flow was estimated by adding the lift airflow rate (based on
design data) to the measured inlet flow.
C-2
-------
1. Two methods were used to estimate the amount of solvent applied
to the web. However, both the methods have some inherent problems such
that accurate and reliable measurement was not possible. The first
technique of using dipstick measurements in the dip tanks does not
permit accounting for the coating which is being applied to the web
simultaneously as the dip tank is being filled. Thus, this procedure
underestimates the amount of solvent applied. The second technique
compares the amount of liquid solvent introduced to the mix equipment at
the beginning of every batch (perhaps 1 to 2 days before the coating is
used in the process) with unused coatings introduced to the bake oven
after every batch is completed and assumes that the difference is the
solvent applied to the web. This methodology assumes no losses take
place during mixing, transfer, and holding which we know to be
unrealistic. Thus, this method is also suspect.
2. The reported capture efficiency is dependent on a valid
correlation between gaseous and liquid material balance. The EPA's
attempt to perform such a balance under ideal conditions in laboratory
experiments showed results that varied by as much as ±10 percent. One
would expect much greater error than 10 percent under field measurement
conditions.
3. The solvent inleakage at the floor level is not accounted for,
and, as a result, it is reasonable to expect that the recovery efficiency
would be biased high.
4. The recovered solvent was stored in a large (7,000 gallon) tank
where the inherent error in measurement was equal to the change in
liquid level that was being measured. Another complicating aspect of
measuring the recovered solvent is that the liquid in the solvent recovery
tank was assumed to be MEK with a small amount of dissolved water. A
potentially major flaw in this assumption is that the liquid in the tank
(as recovered from the adsorber) in reality contains two immiscible
liquid phases: a solvent layer containing 12 percent water and a water
layer containing 27 percent MEK (assuming the phases are at equilibrium,
i.e., saturation). The test procedure did not account for any phase
distribution. The magnitude of this error is not known, but it is known
that the water-solvent phase is large enough to justify intermittent
(about once a month) use of distillation column to recover solvent.
C-4
-------
For convenience, Table C-5 presents test results for capture,
control, and total control efficiencies. However, the information in this
table should not be used.
C.I.1.2.2 Plant data. Liquid solvent flows of applied and recovered
captured solvent are routinely measured and recorded by plant personnel
and were used to estimate total VOC reduction (recovery) efficiency.
Table C-6 presents total VOC reduction efficiency for a single fabric
coating line using plant data. Total VOC reduction efficiency data for
the entire test period as determined by the two methods differed
considerably—83 percent for the test data compared to 60 percent for the
plant data. Larger variations (26 to 176 percent) in batch-to-batch
efficiency values were evident in the plant data than from EPA test data
(49 to 100 percent). Measurement error was inherent in the plant data
efficiency values with the major source of error attributed to the
quantity of recovered solvent and the amount of solvent applied at the
coating applicator because the fugitive emissions from mixing, transfer
and storage of coatings were not accounted for.
C.I.2 Plant C
The EPA conducted tests at Plant C to measure VOC emissions from two
mix tanks. Figure C-3 shows the general process schematic for Plant C and
for the N-line coating room. The figure also identifies the slurry and
gas sampling location for the tests.
At this plant, all coatings are formulated at the plant site. This
is done in batch mix tanks located in an area designated as the mix
tower. In the mix tower, the typical coating mix operation consists of
charging a steam-jacketed mix tank with a solvent, a solid polymer resin,
a pigment, and various additives. The mix tank is then closed, and the
polymer slurry is mixed with a shear mixer for 2 to 3 hours. Solvent that
vaporizes from the mixture is vented from the mix tank to the atmosphere
through an exhaust stack. At the end of the mix period, the slurry is
discharged to a holding tank. Solvent is used to wash the mix tank and
this increases the quantity of solvent in the slurry.
In the holding tank, the polymer slurry is pumped to a dip tank
where it is applied to a cotton or polyester web. The level of slurry
in the dip tank remains at a constant level while the level in the hold
C-5
-------
tank goes down as the coating is applied. In both the hold and dip tanks,
additional solvent may be added by the operators to maintain proper
coating viscosity. From the N-line dip tank, the polymer-coated web
travels through a heated, nitrogen-atmosphere dryer. From here, the dried
coated fabric is rolled to await processing into a final product.
Emissions from the mix tanks were calculated from stack gas analysis
results and from liquid material balance. The results of the liquid
material balance show a gain of solvent with time instead of the expected
loss of solvent with time due to evaporation, thus invalidating these
results. Because the measured VOC emissions vary drastically for the two
methods, the validity of all of the collected data is questionable.
Therefore, no data were approved for use in setting a standard for
polymeric coating. The collected test data are presented in Table C-7.
However, the information in this table should not be used.
C.2 ERA-SPONSORED TESTS FOR RELATED INDUSTRIES
The emission source test data presented here were obtained from EPA-
sponsored testing at three plants in related web-coating industries.
C.2.1 Pressure-Sensitive Tape and Label Plant
The EPA conducted tests at plants in the pressure-sensitive tape and
label (PSTL) industry. This is an industry with coating and control
processes very similar to those used in the polymeric coating of
supporting substrates. In both types of plants, a solvent-borne coating
is applied to a continuous supporting web. Fixed-bed carbon adsorbers are
control devices used in both types of plants and similarly designed total
enclosures around the coating application/flashoff area are used to
capture fugitive VOC emissions. The following paragraphs describe
relevant test data from the PSTL industry.
One PSTL facility was examined over a 4-week period (January 15,
1979, to February 9, 1979). The facility consists of four adhesive
coating lines controlled by a single carbon adsorption system. There
are three lines that are each 28-inches wide, and one line that is
56-inches wide. The plant operation is characterized by many short runs
at slow line speeds. Table C-8 summarizes the operations of each line
and the total system. This facility is an example of a hard to control
C-6
-------
facility because slow coating lines are the most difficult-to-control
(e.g., they have the greatest potential for fugitive VOC emissions).
The makeup air for the ovens is pulled directly from the work area.
The building that houses the four coaters is tight enough to allow a
slight negative pressure in the work area as compared to the outside of
the building. Also, there is a slight negative pressure in the coater
ovens with respect to the room air. With a fully enclosed, tight system,
the overall result is that all makeup air flows into the building, through
the oven, and out to the carbon adsorption system. Therefore, essentially
100 percent of all solvent emissions are captured. The facility also uses
hoods over the coater areas to capture fugitive solvent emissions near the
coating applicator. Ductwork directs hood gases into the drying oven.
During the 4-week test period, the controlled facility used 28.7 m
(7,589 gallons) of solvents in its adhesive formulations and recovered
26.7 m (7,065 gallons) from the carbon adsorption system. This
represents an overall VOC control of 93.1 percent. The system performed
140 separate runs and used the following solvents: toluene, acetone,
hexane, ethyl acetate, MEK, rubber solvent, heptane, recovered solvents,
xylene, ethyl alcohol, and isopropanol.
C.2.2 Publication Rotogravure Printing
Plants in the publication rotogravure industry are similar to
polymeric coating plants in that solvent-borne coatings are applied to a
continuous web of supporting material. The percent of VOC contained in
typical coatings used at plants in this industry are within the range of
coating formulations used at polymeric coating facilities. Fixed-bed
carbon adsorbers are control devices used in both types of plants.
The EPA conducted tests on the two newest presses (presses 505 and
506) at the Meredith/Burda, Incorporated, plant during the week of
December 11 to 16, 1978. This plant uses toluene as the printing solvent.
A cabin-like structure encloses the top one-third of each printing
press; thus, a partial enclosure system captures fugitive VOC emissions
from the application/flashoff area. The captured solvent laden air is
directed along with the dryer exhaust to the carbon adsorption system.
C-7
-------
Table C-9 summarizes the process operation data. During the tests,
VOC measurements were made at both the inlet and outlet of the carbon
adsorbers. In this industry, bulk inks (coatings) are purchased from an
outside manufacturer and then diluted with additional solvent prior to
application. Mixed (diluted) ink samples were obtained from each of the
eight feed tanks on each press for determination of the toluene content.
The solvent content of the bulk (undiluted) inks was obtained from the ink
manufacturer.
This plant was revisited during January 22 to 24, 1980, for
supplemental measurements. The supplemental measurements showed that some
air containing 60 to 70 ppmv toluene vapors is drawn into the newest
pressroom from other pressrooms and plant areas. This infiltration of
toluene vapors could have inflated the overall solvent recovery results by
about 3 percent. This estimate is based on the assumption that the
infiltrated toluene vapors were generated from other printing
facilities. In addition, the temperature correction factor was estimated
to be 2 percent.
Table C-10 summarizes the overall coating line efficiency and the
carbon adsorber efficiencies. The overall efficiencies were determined
from liquid meter readings and were adjusted by 5 percent to account for
VOC infiltration and temperature correction for solvent volume. The short
term test data (8.5 to 9 h) show carbon adsorber efficiency of 97 to
99 percent and an overall recovery efficiency of 90 to 97 percent. The
51.5- and 78-hour material balance show an overall recovery efficiency of
89 and 88 percent, respectively. The carbon adsorber efficiency during
the 78-hour material balance was 99 percent. The long-term monthly data
obtained from the plant indicate overall plant-wide recovery efficiency of
84 to 91 percent.
C.2.3 Flexible Vinyl Coating and Printing Operations (FVCP)
Plants in the FVCP industry are similar to polymeric coating plants
in that solvent-borne coatings are applied to a continuous web of
supporting material. The percent of VOC contained in typical coatings
used in this industry are within the range of coating formulations used in
polymeric coating facilities. Fixed-bed carbon adsorbers are control
devices used in both the industries.
C-8
-------
The EPA conducted tests at the General Tire and Rubber Company plant
in Reading, Massachusetts, during March 18-26, 1981. The plant produces
vinyl coated fabric. The print line tested is housed in a separate room
in the plant. The line contains six print stations and an inline
embosser.
The print line VOC emissions are captured by a hooding system that
directs the captured emissions into the individual print head ovens. The
capture emissions from the ovens are controlled by a carbon adsorption
system.
The print room's ventilation system consists of a wall exhaust fan, a
room air supply fan, a carbon adsorption inlet fan, an embosser exhaust
fan, and several open doorways. During the tests, all the doorways were
closed and the room air supply fan was off. The use of the wall exhaust
fan was limited and the print line was always down during operation of
this fan.
The VOC emission capture system is considered a partial enclosure
because some air from the enclosed room is used as the process air for
embosser and is eventually exhausted to the atmosphere.
The test program consisted of two phases: Phase 1, determination of
capture efficiency and Phase 2, determination of carbon adsorption control
device efficiency. The tests required only gaseous VOC measurements.
During Phase 1, emissions were measured continuously at three sites:
carbon adsorber inlet, wall fan exhaust, and embosser exhaust. Periodic
VOC measurements at the embosser air intake were also taken. During Phase
2, VOC measurements were made at both the inlet and outlet to the carbon
adsorber. Ambient VOC concentration measurements around the embosser
inlet were continued to obtain further data on capture efficiency.
A summary of the capture efficiency results obtained during the
tests is shown in Table C-ll. The capture efficiency ranged from 90 to
94 percent and averaged 92 percent. A summary of the carbon adsorption
control device efficiency data is presented in Table C-12. Carbon
adsorption control device efficiencies ranged from 98.5 to 99.6 percent
and averaged 99 percent. However, the carbon adsorption system was not
operating at design conditions during the tests. The system, which had
C-9
-------
been on-stream for only a week prior to the test, operated only 8 hours a
day. At the end of each day, the beds were regenerated twice to minimize
the possibility of bed fires during the next day's startup. Therefore,
these carbon adsorption efficiencies may be somewhat higher than would be
expected under design conditions.
C.3 PLANT-WIDE SOLVENT RECOVERY EFFICIENCIES AT POLYMERIC COATING PLANTS
The EPA implemented plant-wide solvent recovery recordkeeping
programs at three polymeric coating plants. The plant-wide solvent
recovery efficiency accounts for all the VOC emissions sources in the
plant, which-includes coating lines, material handling, clean-up, and all
other VOC generating sources. The programs were designed to provide daily
to weekly determinations of solvent recovery efficiency for a period of at
least 6 months. In all three cases, the implemented recordkeeping
programs were modifications of already-existing plant recordkeeping
programs; all measurements and recordkeeping were performed by plant
personnel.
In general, the recordkeeping procedures estimate the total amount of
solvent used in the plant and the total amount of solvent recovered. The
measurement procedures vary among the three plants and are based upon
meter readings, coating formulation data, and storage tank level
measurements. Measurement procedures used by the three plants are
summarized in Table C-13.
A fixed-bed steam-regenerated carbon adsorption system controls the
VOC emissions from rubber-coating operations at Plant A. Solvent recovery
efficiency for the period is shown in Figure C-4. As shown, the weighted
average efficiency for the period is 49.5 percent. The weekly efficiency
values have a mean of 49.2 percent and a standard deviation of 19.8 percent.
Two significant observations are apparent from the data presented in
Figure C-4. First, weekly recovery efficiency values are highly variable,
with the individual values range from 3 to 79 percent. Second, an
increasing recovery efficiency trend appears to coincide with the instal-
lation of new carbon and a new inlet gas cooling coil in the solvent
C-10
-------
recovery system. These modifications to the system are expected to
improve the control device efficiency.
A fluidized-bed, nitrogen-regenerated, carbon adsorber installed in
1983 controls the VOC emissions from the polymeric coating operations at
Plant B. Measured solvent recovery performance is shown in Figure C-5.
As shown, the weighted average solvent recovery efficiency for the period
is 61.4 percent. Weighted average efficiency refers to the total
performance of the system for the entire test period. This value is
calculated based upon the amounts of used solvent and recovered solvent
summed over the entire period. This value is most indicative of long-term
performance.
The mean efficiency for the Plant B data is 63.3 percent with a
standard deviation of 20.5 percent. The mean efficiency is calculated as
the arithmetic average of the weekly efficiency values. The mean
efficiency gives equal weight to each weekly value, regardless of the
magnitude of solvent usage and recovery amounts. The standard deviation
indicates the degree of variability of the weekly values.
The high degree of variability indicated by the time plot and the
standard deviation is due to both measurement and process variability.
Measurement variability results primarily from uncertainties in deter-
minations of solvent quantities in storage tanks. Process variability is
due to the differences in coating conditions for various batch runs as
well as to nonroutine upsets in process operation. The variability would
be expected to decrease over longer monitoring periods.
At Plant C, xylene is transported as a concentrated vapor to a
condensation system. Figure C-6 illustrates plant-wide solvent recovery
efficiency data for the coating line controlled by the condensation
unit. As shown, the weekly efficiency data are less variable than the
data for Plants A and B. For the period, the weighted average efficiency
is 41.0 percent. The mean of the weekly value is 42.5 percent with a
standard deviation of 9.2 percent.
The results presented for Plants A and B included modifications to
the data collected and reported by plant personnel. Modifications to
the reported Plant B data were limited to corrections of arithmetic
errors and errors associated with transcription of data. Plant A data
C-ll
-------
included arithmetic interpretation errors that resulted from failure to
account for distilled solvent. In the Plant A operation, solvent is
distilled (recovered) from unused coating slurry and returned to the
solvent recovery storage tank. In the reported data sheets, however, the
solvent recovery system is not credited with this input. The results
presented include the credit. Because of these problems, the validity of
the data set is unknown.
There is no indication that the plant-wide solvent recovery data
relate to the level of control within a subset of the plant such as the
coating operation because the plant-wide data include cleanup solvent and
wastes. In addition, Plants A and C are not equipped with the level of
control prescribed for the coating operation Regulatory Alternatives III
and IV. Although Plant B was equipped with the controls specified in
Regulatory Alternative III for the coating operation, there were
significant errors in the measurement techniques as discussed in Sections
C.I.1.2.1 and C.I.1.2.2.
C-12
-------
f lUCRHIU
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SPIGOT DISCHARGES
O
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MEK SHI
(m
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(•"SF)
RECOVERED
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OVEN AREA AND
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ES
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SOLVENT RETAINED
IN PRODUCT
-------
O
I—"
tn
Xylene
Addition
1
Xylene
Addition
MIX
TANK
// 9
V
To el-Line
TOPCOAT
MIX/ HOI.I)
TANK
1
Mlx
TANK
// 8
,.To Other Topcoat
Operat ions
MIX TUWhK
Slurry Sample
Gas Sample
Xylene Additions
Xylene Additions
HOLD
TANK
N-LINE
N-LINE
PAD COAT
Xylene
Addition
Xylene
Addition T
TOPCOAT
MIX /HOLD
TANK
J
—
*
N-I.INE
TflPrruT
N-I.INE COATING KUOM
Figure O3. Process schematic and sample locations—Plant C.
-------
E
F
C
N
C
Y
nW6T AVG = 49-
"MEAN = 49'2*
o « 19.3*
SLA Cooler
Coil Replaced
WEEK
Figure C-4. Solvent recovery efficiency data—Plant A.
C-16
-------
E
F
C
E
H
C
Y
t
• m
30
20
10
0
1
nWGT AVG = 6L4%
nMEAN = 63'3%
a = 20.5%
J • I i
5
15
WEEK
Figure C-5. Solvent recovery efficiency data—Plant B.
C-17
-------
E
F
C
I
N
C
v
109
99
88
70
S0
50
40
30
20
10
9
1
nWGT AVG = 41'
"MEAN = 42-5%
o • 9.2*
1 1 1
4
8 9
WEEK
Figure C-6. Solvent recovery efficiency data—Plant C.
C-18
-------
TABLE C-l. PROCESS PARAMETERS MONITORED DURING PLANT B SOURCE TESTING
Solvent storage
• Recovered and virgin solvent storage tank inventories were monitored
through depth gauging of tank levels. Readings were typically taken
before and after each coating job. The virgin solvent tanks were
not monitored for increase in inventory because there were no
deliveries of make-up shipments.
Solvent transport
• All solvent flows from/to the storage tanks and between mixing
vessels were monitored using plant instrumentation.
• Solvent amounts withdrawn from spigots were monitored.
Coating preparation
• Preparation of coatings were observed.
• Solvent flow to the master mixer and each barrel mixer and the
preparation of specialty coatings in small drum mixers was con-
tinuously monitored.
• An on-hand solvent inventory was taken before start-up, during the
lunch break, between coating jobs, and at the end of the day.
• The amount of coating in the barrel mixers and in the small drum
mixers that were in use was monitored hourly.
Coating transport
• The amount of coating transferred from a mixer to a dip vat was
continuously monitored. (No coating was transferred from a mixer to
the denim or cord coater during the test program).
Coating application and drying
• Operation of the fabric coating line was continuously monitored.
• Operating parameters monitored include:
-- Coating process startups, operating periods, upsets, and
shutdown; and
— Coating conditions, e.g., fabric type, fabric width (coated and
uncoated), and web speed.
~~~(continued)
C-19
-------
TABLE C-l. (continued)
Residual coating disposal
• The amount of residual coating remaining in the dip vat, barrel
mixer, and plastic feed stock was determined at the end of each
coating job.
• The status and operating conditions of the bake oven and the booster
blower were continuously monitored.
• The amount of scrap solids discharged from the bake oven was
monitored.
Solvent capture
• Openings and closings of the dip vat enclosure and drying tower door
were continuously monitored.
• Velocity measurements were taken of the airflow into the dip vat
enclosure and drying tower.
Ventilation
• The operating status of the by-pass blower and the mix ceiling
fans was monitored.
• All entrances, doorways, and windows to the coating/mixing room were
monitored to note if they were open or closed.
Solvent recovery
• Solvent recovery rates were periodically monitored by depth gauging
of tank levels.
• Operating parameters monitored include:
— SLA flow rate, temperature, and moisture content;
— Carbon adsorber inlet and outlet VOC concentrations;
— Carbon adsorber operating status (on or off);
— Relative carbon recirculation rate;
— Regeneration temperature; and
— Nitrogen flow rate.
C-20
-------
TABLE C-2. PROCESS PARAMETERS FOR FLUIDIZED-BED
CARBON ADSORPTION SYSTEM—PLANT B
SLA inlet temperature to water cooler
°C
SLA inlet temperature to carbon adsorber
°C
SLA relative humidity, %
Maximum range
Typical range
SLA inlet concentration, ppm
Design
SLA outlet concentration, ppm
Range
Average
Total carbon charge
kg
(Ib)
No. of trays
Carbon flow rate
kg/h
Pressure drop per tray
kPa
(in. w.c.)
Regeneration temperature
°C
N2 tpow rate
m /s
(acfm)
57 to 66
(135 to 150)
32 to 35
(90 to 95)
30 to 100
65 to 75
2,600
5 to 60
15 to 20
4,037
(8,900)
8
748 to 1,277
(1,650 to 2,815)
0.13
(0.5)
222 to 223
(431 to 434)
0.0017 to 0.0020
(3.7 to 4.3)
C-21
-------
TABLE C-3.
VALID DATA—CARBON ADSORBER CONTROL EFFICIENCY FOR SINGLE
FABRIC COATING LINE—TEST DATA FOR PLANT Ba
Date
07/16/84
Daily Total
07/17/84
Daily Total
07/18/84
Daily Total
07/19/84
Daily Total
Batch
No.
219
219
222°
221d
221
223
223
223
225e
225
224
Solvent
in inlet,
kg
155
48
87
290
43
541
584
165
259
287
7U
83
53
261
307
(Ib)
(342)
(105)
(192)
(639)
(95)
(1,193
(1.288)
(364)
(571)
(633)
(1,568)
(183)
(117)
(575)
(875)
Solvent
in exhaust,
kg
0.5
0.3
0.6
0
0.3
10.6
TO
1.5
5.3
0.3
0
0.9
0.3
0.4
O
(Ib)
(1.1)
(0.7)
(1.31
(0.7)
(23.4
(24.1)
(3.3)
(11.7)
(0.7)
(1577)
(2.0)
(0.7)
(0.9)
toy
Control
efficiency,
percent5
99.7
99.5
99.4
99.6
99.3
98.0
98.1
99.1
98.0
99.8
99.0
99.0
99.5
99.8
99.6
TOTAL
1,982 (4,370) 21.1
(46.5)
98.9
aThe test report also lists data generated during shutdowns before and
after coating jobs and during employee breaks as well as the data
generated during batch operations. The efficiencies were calculated
based on data that were generated during batch operations only. Batch-
only data are presented here.
"Control efficiency -
*»™* 1n
6XhaUSt
x 100
Enclosure doors were opened for approximately 84 minutes (70 percent
of the time.)
dUpset. Drying oven doors opened for 35 minutes.
eUpset. Drying oven doors opened for 15 minutes.
C-22
-------
TABLE C-4. VALID DATA—MIX TANK EMISSIONS ESTIMATED FROM EPA METHOD 24 DATA FOR PLANT B
o
ro
CO
Tine (t)
between Total
Initial solvent loss Rate of
Mix Initial solvent Final solvent and final Time Time ^sv^' solvent loss. Rate of solvent
Batch No. tank No. fraction (f.) fraction (f ) readings, h nixing, h uncovered, h° percent percent/h kg/h-mc
221 3 0.7824 0.7809 18.3 4.2 14.1 0.858 0.047 0.20
223 4 0.8419 0.8416 17.7 3.7 14.0 0.262 0.015 0.092
224 1 0.7914 0.7820 18.7 18.7 0.0 5.40 0.288 0.94
225 3 0.7922 0.7800 20.6 20.6 0.0 6.97 0.338 0.91
As none of the nix tanks were fitted with a leak-tight cover, the effectiveness of covering nay be narginal.
Determined based upon estinated initial volume of the mix tank, estimated surface area of the slurry in the tank, initial density and volatile content, t, and
V
loss.
(Ib/h-ft')
(0.041)
(0.019)
(0. 193)
(0. 186}
-------
TABLE C-5.
INVALID TEST DATA-CAPTURE, CONTROL, AND TOTAL VOC REDUCTION EFFICIENCY
FOR SINGLE FABRIC COATING LINE AT PLANT Ba
o
I
ro
Date
07/16/84
Daily Total
07/17/84
Daily Total
07/18/84
Daily Total
07/19/84
Daily Total
Batch
No.
219
219r
222f
2219
221
223
223
223
225h
225
224
Solvent
applied
(mAp) ,
kg (lb)
209
64
66
339
65
496
561
178
281
265
724
128
85
295
508
(461)
(141)
(146)
(748)
(143)
(1.093)
(1,236)
(392)
(620)
(584)
(U596)
(282)
(187)
(650)
(1.119)
Solvent
in SLA
.
-------
TABLE C-5. (continued)
o
I
ro
en
Date
07/16/84
Daily Total
07/17/84
Daily Total
07/18/84
Daily Total
07/19/84
Daily Total
Captured
solvent
, KAPT)' ,1KX
kg (Ib)
145
44
64
253
32
491
523
150
235
265
650
76
48
246
370
(320)
(97)
(141)
(558)
(71)
(1,082
(1,153)
(331)
(518)
(584
(1,433)
(168)
(106)
(542)
(816)
Capture
effi-
ciency
(nCAPT)*C
percent
69
68
99
74.9
50
99
93
84
84
100
90
60
56
83
73
Solvent in
adsorber
exhaust
(mEXH)»
kg (Ib)
0.5
0.3
0.6
1.4
0.3
10.6
10.9
1.5
5.3
0.3
7.1
0.9
0.3
0.4
1.6
(1.1)
(0.7)
(0.7)
(23.4
(24.1)
(3.3)
(11.7)
(0.7
(15.7)
(2.0)
(0.7)
(0.9)
toy
Control
effi-
ciency
(^CTRL)?
percent
99.7
99.5
99.4
99.6
99.3
98.0
98.1
99.1
98.0
99.8
99.0
99.0
99.5
99.8
99.6
Total
effi-
ciency
(nT),*
percent
69.2
67.8
98.0
74.6
49.3
97.0
91.6
83.5
81.9
99.8
88.9
59
56
83
72
TOTAL
1,796
(3,960)
84
21.1
(46.5)
98.9
83.4
(continued)
-------
TABLE C-5. (continued)
aThe test report also lists data generated during shutdowns before and after coating jobs and during
employee breaks as well as the data generated during batch operations. Capture, control, and total
efficiencies were calculated based on data that were generated during batch operations only.
Batch-only data are presented here.
mCAPT = mSLA - mBO ' ml .
nCAPT ~ "WT x 100
mAP
d
nCTRL = mSLA " mEXH x 100
mSLA
e
nT ~ nCAPT x nCTRL
^ f 100
<" ^Enclosure doors were opened for approximately 84 minutes (70 percent of the time.)
jHJpset. Drying oven doors opened for 35 minutes.
"Upset. Drying oven doors opened for 15 minutes.
-------
TABLE C-6.
INVALID PLANT DATA—TOTAL VOC REDUCTION EFFICIENCY FOR SINGLE FABRIC COATING
LINE AT PLANT B
o
Date
07/16/84
Daily Total
07/17/84
Daily Total
07/18/84
Daily Total
07/19/84
Daily Total
TOTAL
T"he superscript
b
"W" " BFD' " mBOF
c
"RC- = V " "BOV
\ =>• * m%
V
Batch No.
(a.m. , p. n
219 (a.n.)
222 (p.m.)
221 (a.m.)
221 (p.m.)
223 (a.m.)
223 (p.m.)
225 (a.m.)
224 (p.m.)
is used to
••
•
Solvent mixed
with batch
.) kg
265
122
387
55
612
667
475
336
811
235
363
597
2,462
db)
(584)
(269)
(853)
(121)
(1.350)
(1.471)
(1.047)
(741)
(1,788)
(518)
(800)
(1.318)
(5.430)
Solvent
not used
kg B
32
60
93
0
35
35
0
33
233
31
36
67
228
Uh Ob)
(71)
(132)
(205)
(0)
1ZZ1
(77)
(0)
(73)
(73)
(68)
(79)
(147)
(502)
Solvent
appl ied
kg ""•
233
_62
294
55
577
632
475
303
778
204
327
531
2,234
Ob)
(514)
(137)
(648)
(121)
(1.272)
(1.393)
(1,047)
(666)
(1.715)
(450)
(721)
(1.171)
(4.927)
Total solvent
recovered
(n_.K
kg
256
U9
375
101
225
326
134
292
426
116
244
360
1,487
K (Ib)
(564)
(262)
(827)
(223)
(496)
(719)
(295)
(643)
(938)
(256)
(538)
(794)
(3.278)
Solvent
recovered from
bake oven
kg (mr-"}'
19
10
30
13
64
76
12
J
20
15
15
30
156
«« (Ib)
(42)
1221
(64)
(29)
(141)
(170)
(26)
(18)
(44)
(33)
1331
(66)
(344)
Recovered
captured Total
solvent efficiency
(n ).C (Tl-.).d
237
109
345
88
162
250
122
285
406
101
229
330
1.331
«L (Ib) percent
(522) 102
(240) 176
(762) 117
(194) 159
(357) 28
(551) 40
(269) 26
(628) 94
(897) 52
(223) 50
(505) 70
(728) 62
(2.938) 60
indicate plant -available data.
-------
TABLE C-7. INVALID TEST DATA—SUMMARY OF TEST RESULTS AT PLANT C
Volatile
weight
Date Time Batch Location fraction
9/12/84 2110 656-1 Mix tank No. 8 0.740428
(0.2957)
? 9/13/84 1007 902 Mix tank No. 8 0.498149
£ (0.0059)
9/13/84 1345 220-3 Mix tank No. 9 0.456089
(0.0031)
Emission
rate from
stack analyses*
BI /s Kg/h
ft /min (Ib/h)
0.1396 10.2
(4.63) (32.8)
0.0028 0.21
(0.093) (0.9)
0.0015 0.093
(0.0420) (0.2)
Emissions
from stack
analyses
m, kg
ft (lb)
0.9 3.9
(8.6) (159)
0.03 0.09
(0.2) (97)
0.006 0.02
(0.042) (26)
Total
emissions
from
material
balance-
kg (lb)B
72
44
12
Calculated from measured stack gas concentrations and average flowrate. Average flowrate was
calculated from stack diameter and average velocity.
"These values represent a net gain.
-------
TABLE C-8. VALID DATA—SUMMARY OF COATING LINE OPERATIONS AT PSTL FACILITY
ro
Line No.
Line width, m
(in.)
No. of runs
Average line speed, m/s
(ft/mi n)
Average weight percent solvent
Total solvent useda
kg
db)
8,
(gal)
1
1.42
(56)
25
0.21
(41)
57.5
12,750
(28,110)
15,630
(4,129)
2
0.71
(28)
68
0.24
(46.5)
62.2
4,915
(10,837)
5,761
(1,522)
3
0.71
(28)
23
0.24
(46.5)
66.0
3,747
(8,262)
4,323
(1,142)
4
0.71
(28)
24
0.22
(42.5)
62.4
2,309
(5,091)
3,017
(797)
Total
140
i_
(44.8)b
60. 3b
23,723
(52,300)
28,731
(7,589)
^Measured during 4-week test period.
"Average of four runs.
-------
TABLE C-9. VALID DATA—PRESS OPERATIONS DURING TESTS AT
MEREDITH/BURDAa
Advertising Product-Press: No. 505
Press width, m (in.)2 (79)
Web width, m (in.) 1.3 (50)
Shutdown, daily fraction (hour)D 0.27 (6.5)
Printing time, %c 86
Press speed, m/s (ft/min) 4.6-5.6 (900-1,100)
Magazine Product-Press: No. 506
Press width, m (in.) 2 (79)
Web width, m (in.) 2 (78 3/8)
Shutdown, daily fraction (hour)D 0.58 (13.8)
Printing time, %c 64
Press speed, m/s (ft/min) 7.6-9.6 (1,500-1,900)
Both Presses: .
Shutdown, daily fraction (hour)0 0.42 (10.1)
Printing time, %c 75
Both up, %c (ppmd) 60 (1,670)
One up/one down, %c (ppmd) 33 (770)
Both down, %c (ppmd) 7 (300)
Total solvent usage, JPt/s (gal/h)e 0.15 (143)
Type of solvent used Toluene
^Average of three test runs.
"Equivalent shutdowns per 24 hour period.
GActual press operating time relative to test time.
dAdsorber inlet solvent vapor concentrations.
elncludes solvent in inks, varnishes, and extenders.
C-30
-------
TABLE C-10. VALID DATA—SUMMARY OF DEMONSTRATED VOC EMISSION CONTROL
EFFICIENCIES AT MEREDITH/BURDA, PERCENT
Meredith/Burda (Phase III)
Data sources Overall3 Adsorber
Short-term (8.5-9 hours) 90-97 97-99
51.5-hour material balance 89
78-hour material balance 88 99
Long-term monthly plant data 84-91
(10 months)
Efficiencies are 5 percent lower than measured apparent efficiencies:
2 percent for a temperature correction factor and 3 percent for
infiltration of solvent vapors.
C-31
-------
TABLE C-ll. VALID DATA—SUMMARY OF CAPTURE EFFICIENCY DATA-
GENERAL TIRE AND RUBBER COMPANY
o
I
CO
ro
VOC emissions, kg
Date
3/18/81
3/19/81
3/20/81
3/23/81
3/25/81
3/26/81
aCaoture e
Production
order No.
T-14582
T-15523
T-15521
T-15516
T-15519
T-15511
T-15508
T-15507
fficiencv. % =
Run time
Start
1401
1420
1256
0909
1351
0942
1126
1439
End
1607
1610
1402
1025
1413
1047
1222
1540
CA intake
Run
length,
minutes
126
110
74
76
32
65
56
61
emissions, kg
Embosser
air
intake
4.8
(10.6)
3.2
(7.1)
2.9
(6.4)
2.3
(5.1)
0.6
(1-3)
2.5
(5.5)
1.7
(3.7)
1.6
(3.5)
(Ib)
Capture
CA efficiency,
Wall fan
Ob
6.9
(15.2)
Ob
Ob
u
ob
ob
u
inlet
66.4
(146.4)
21.6
(47.6)
27,0
(59.5)
22.3
(49.2)
6.0
(13.2)
35.5
(78.3)
21.6
(47.6)
21.5
(47.9)
UOOtt
%a
93
NMC
90
91
91
94
93
93
. tmbosser air intake emission, g + CA inlet emissions, kg
DWall fan not operating properly.
cNot meaningful because of poor air management during this test run.
-------
TABLE C-12. VALID DATA—SUMMARY OF CARBON ADSORPTION EFFICIENCY DATA--
GENERAL TIRE AND RUBBER COMPANY
CO
CO
Date
3/25/81
3/26/81
Production
order No.
T-15511
T-15508
T-15507
Run
Start
0942
1126
1439
time
End
1047
1222
1540
Run
length,
minutes
65
56
61
VOC emissions^
CA inlet
35.5
(78.3)
21.5
(47.4)
21.5
(47.4)
kq (lb)
CA outlet
0.13
(0.29)
0.32
(0.71)
0.22
(0.49)
Carbon
adsorption
efficiency
99.6
98.5
99.0
-------
TABLE C-13. SUMMARY OF SOLVENT RECOVERY MEASUREMENT PROCEDURES*1
Plant Solvent recovered Solvent used
A Differences in recovered Differences in virgin (feed)
solvent inventory solvent inventory
B Differences in recovered Gravimetric and volumetric
solvent inventory readings of metered solvent
charged to the coating process
C Differences in recovered Volumetric readings of metered
solvent inventory solvent charged to the coating
process
aln general, solvent recovery efficiency, percent = x 10°
C-34
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APPENDIX D - EMISSION MEASUREMENT AMD MONITORING
This appendix describes the measurement method experience that was
gained during the emission testing portion of this study, recommended per-
formance test procedures, and potential continuous monitoring procedures.
The purposes of these descriptions are to define the methodologies used to
collect the data, to recommend potential procedures to demonstrate compli-
ance with a new source performance standard, and to discuss alternatives
for monitoring either emissions or process parameters to indicate contin-
ued compliance with that standard.
D.I EMISSION MEASUREMENT TEST PROGRAM AND METHODS
Emission source testing in the polymeric coating industry was
conducted by the Emission Standards and Engineering Division (ESED) of
the Environmental Protection Agency (EPA) as part of the background
support study for the new source performance standard for this industry.
These tests included a complete balance test at one facility, a mix area
test at another facility, and long-term overall solvent recovery testing
at three facilities. The long-term data gathering was performed at
facilities that use carbon adsorption and condensation units for volatile
organic compound (VOC) control.
D.I.I Coating Analysis Testing
Coating samples were received from three polymeric coating manufac-
turers and analyzed using EPA Reference Method 24. All samples were
solvent-based coatings; no low-solvent or waterborne coatings were
available. Preliminary analysis indicates that Method 24 is applicable to
these coatings, although specialized techniques and equipment may be
needed.
D-l
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The results of the Method 24 testing met the previous requirements
of the American Society of Testing and Materials (ASTM) standards on
which Method 24 is based. The analysis results generally compared well
with the manufacturers' formulation data. Therefore, Method 24 should be
applicable to the polymeric coating industry.
D.I.2 Emission Source Testing Programs
One polymeric coating plant was tested for VOC emissions. In
general, the purpose of the testing program was to characterize the VOC
emissions to the atmosphere and the control efficiency of the vapor
capture and processing systems, as well as the overall solvent usage, end
distribution, and material balance throughout the entire coating process.
This field testing was much more comprehensive than the performance test
procedures specified in the applicable regulations for the industry in
order to evaluate various testing approaches and methods and to gather
useful auxiliary information to better understand the process operation.
D.I.3 Stack Emission Testing Conducted
D.I.3.1 Testing Locations. Gas streams that were tested for VOC
concentrations and flow rate included: inlets and outlets of vapor
processing devices; uncontrolled exhaust streams venting directly to the
atmosphere; intermediate process streams such as hood exhausts and bake
oven exhausts venting to other process units. From the concentration and
flow rate results, the VOC mass emissions or mass flow rate in each
stream could be calculated. The gas streams to the carbon adsorption
recovery unit and from the emergency blower exhaust were in vents that
were suitable for conventional EPA stack emission measurement techniques,
and these measurement approaches are described in this section.
If there were emissions that were not collected and vented through
stacks suitable for conventional testing, then ambient VOC survey tech-
niques had to be adopted. (An example would be open doorways, roof
exhausts, and bake oven exhausts.) Where possible, flow rates were
estimated from vendor data. These nonconventional measurement techniques
are described in a later Section, D.I.6.
D.I.3.2 Flow Measurements. During ESED/EPA's field testing
programs, Reference Methods 1 and 2 were used to determine the volumetric
flow rate of the gas streams being sampled. Moisture contents were
D-2
-------
measured by inline psychrometers rather than EPA Method 4. Because all of
the stacks or ducts that were tested had diameters of at least 12 inches,
Methods 1 and 2 were applicable, and alternative flow rate measurement
techniques were not required. The volumetric flow rates were determined
on a wet basis, corresponding to the VOC concentration method used
for that site measured VOC concentrations under actual conditions (wet
basis).
Reference Method 1 was used to select the sampling site along the
duct or stack, and to determine the number of sampling points on the
cross-sectional area inside the duct. Method 2 was used to measure gas
velocity. This method is based on the use of an S-type pi tot tube to
traverse the duct cross-section to calculate an average gas velocity.
To determine the gas stream molecular weight and density, as required
for Method 2, the fixed gases composition and moisture content are
needed. The fixed gas composition (02, C02, CO, N£) was determined
assuming the dry molecular weight of the vent gases was assumed to be
the same as ambient air in lieu of Method 3. This was a valid assumption
in that the measured streams were essentially ambient air, i.e., there
were no combustion sources involved and the hydrocarbon concentrations in
the stream were relatively low. Gas stream moisture content was
measured with a wet bulb/dry bulb technique. The wet bulb/dry bulb
technique may be less precise than Method 4; however, it was acceptable
because the effect of the moisture value on the final results was rela-
tively insignificant (no corrections to dry conditions were needed). The
moisture content is used to adjust the molecular weight in a calculation
step in Method 2, and to adjust the flow rates to a dry basis if needed.
Using the duct area, the gas volumetric flow rate was then calculated.
D.I.3.3 Concentration Measurements. The VOC concentration in each
stack was determined using a semi-continuous (1-minute interval) flame
ionization detector. For the polymeric coating industry, the EPA
recognizes that this technique will give results equivalent to those of
the continuous analyzer method specified in EPA Method 25A. It should be
noted that, at the time of the testing, Methods 25 and 25A had not been
finalized, so preliminary versions were followed. However, the later
D-3
-------
changes to these methods are not expected to be significant and would not
have affected the test results.
The direct extraction flame ionization analyzer (FIA) method was
used at all measurement sites which were analyzed for gaseous VOC
emissions. The direct FIA had the advantage that, with semi-continuous
measurements, minor process variations could be noted. Also, once it was
set up, it was relatively inexpensive to operate for a long period, and
thus, changes in emissions due to process variations could be easily noted.
The other methods can be used at any sampling location, including
sites in explosive atmospheres or remote locations. When the time-
integrated sampling methods are used (such as EPA Method 25, bag sampling
or syringe sampling), the sample is collected for a 45- to 60-minute time
period. Because of its complex analysis procedure, the Method 25 samples
are analyzed later in the laboratory- The integrated bag samples, however,
are analyzed as soon as possible (within 24 hours) on-site by either a FIA
or gas chromatographic (GO method.
The FIA's were usually calibrated with propane, although sometimes
they were also calibrated with the solvent being used in the coating
process. At the polymeric coating facility, the FIA was calibrated with
the solvent being used in the process. This was convenient because the
process used a single solvent.
The results from the different FIA sampling approaches should be
equivalent, provided they are compared for the same time periods. In
previous tests of other coating industries, the Method 25 results differed
somewhat from the results of the FIA. The differences were probably due
to the fact that Method 25 procedure measures all carbon atoms equally,
while the FIA detector has a varying response ratio for different organic
compounds. The difference in results would be most pronounced when a
multi-compound solvent mixture is used.
In situations where more than one solvent is used, a GC technique may
be best. The results from the GC sampling approaches would necessarily be
different from the continuous FIA because of the different sampling time
periods. The results from a GC analysis are reported as concentrations for
each individual compound, and thus cannot be compared directly to the FIA
results. The FIA is calibrated with one compound and the total hydrocarbon
D-4
-------
concentration is reported as one number on the basis of that compound.
Also, the FIA detector has a varying response ratio to different organic
compounds, so again the difference in results between the GC and FIA would
be most pronounced when a multi-component solvent mixture is used.
D.I.3.4 Tank Measurements. The measurement of solvents and coatings
in tanks and/or flow rates through meters was critical to the material
balance test at one plant in the polymeric industry. Also, the long-term,
liquid-solvent material balance testing (discussed in Section D.I.5)
requires measurement using tanks and meters. There is no ASTM or EPA
reference method for tank or meter measurements. In all cases in the
material balance and long-term tests, tank volumes were verified by manu-
facturer's data, and meter readings were verified by calibration data
(where available) supplied by the plant. At the one material balance
test, additional calibration was performed by the testing contractor.
D.I.4 Mix Room Emission Estimates
The mix room emissions from one plant were measured using data
gathered by EPA Method 24. This procedure called for grabbing a sample at
the start of the mix operation and later grabbing a sample at the finish of
the mix operation. The solvent content of both samples was measured and
compared. Assuming the solids content remained the same, the VOC loss can
be directly calculated from this data.
D.I.5 Liquid-Solvent Material Balance Testing Conducted
The EPA conducted long-term, liquid-solvent material balance tests at
three plants in the polymeric coating industries. The EPA worked with the
facilities and reviewed their procedures for data gathering. The recovery
devices include a fixed-bed, steam-regenerated carbon adsorber, a fluid-
ized-bed, hot nitrogen-regenerated carbon adsorber, and a condensation unit,
The solvent used by the plant was compared to the solvent recovered
(usually on a weekly or monthly basis), in order to obtain an overall
control efficiency, combining capture and recovery efficiencies. In
general, the solvent used by the plant was based on solvent purchases and
any in-house sources and the solvent recovered was determined by reading
the level in the solvent recovery tank at the recovery device.
D.I.6 Ambient Surveys and Fugitive Emission Characterization
Ambient measurements were conducted during some test series. Open
doorways were monitored periodically to estimate the mass flux of VOC into
D-5
-------
and out of the coating area. The flow rate through openings was
measured with a hand-held velometer or a hot-wire anemometer
(6 to 9 points were sampled per doorway). Hydrocarbon concentration
was measured with a portable total hydrocarbon analyzer with a
photoionization-type detector (PID).
Ambient VOC concentration levels in the coating area were
measured periodically during the testing period. The surveys were
conducted throughout the room at various heights and distances from
the center.
Surveys were also made of the VOC concentrations and flow rates
into hood intakes above the coater, in order to estimate and
characterize the fugitive VOC1s which were drawn into the hooding
exhaust stack. VOC concentration and flow measurements were made at
representative spots around intake hoods as close to the intake as
the physical equipment setup permitted.
D.I.7 Solvent Sample Analysis
Some plants mix their coatings on-site from raw materials.
Samples of the solvent (or mixture of solvents) can be obtained and
analyzed for speciation by direct injection into a gas chromatograph.
The results from these analyses indicate whether the solvent (or
solvent mixture) being used matches the plant's formulation data.
Samples of recovered solvent from carbon adsorbers were also
obtained and analyzed in order to compare the composition of the
recovered solvent to that of the new solvent. This comparison
identified species which are more likely to be recovered by a
particular recovery system.
D.I.8 Wastewater Sample Analysis
If the solvents being used were miscible in water, then the
recovered solvent/condensate from a steam-regenerated carbon adsorber
is separated in a distillation step. Wastewater would then result
from the distillation column. For immiscible solvents, the condensate
can be decanted and result directly in a wastewater. The wastewater
samples were analyzed for compound speciation and total organic carbon
using standard laboratory water analysis procedures.
The results from this determination were used to characterize the
operation of the carbon adsorber or condensation unit and applied to
the solvent material balance calculations.
0-6
-------
D.I.9 Product Sample Analysis
Product samples were collected and analyzed for residual solvent
content for the material balance test. The results from this determi-
nation were applied to the solvent material balance calculations. The
test procedure was an adaptation of a NIOSH ambient carbon tube measure-
ment technique. The product samples were put in a container with a known
aliquot of carbon disulfide (C$2)- The extract was analyzed for compound
speciation by a gas chromatograph, in the same manner as ambient sample
carbon tubes. This product sampling and analysis was a preliminary test
procedure, as there is no EPA reference method for product sampling. The
results were a range expected for polymeric coatings, but there is no way
to independently verify the results.
D.2 PERFORMANCE TEST METHODS
Many different approaches, test methods, and test procedures can be
used to characterize VOC emissions from industrial surface coating facil-
ities. The particular combination of measurement methods and procedures
to be used depends upon the format of the standard and test procedures
specified in the applicable regulation. General testing approaches are:
1. Analysis of coatings,
2. Direct measurement of emissions to the atmosphere from stacks,
3. Determination of vapor processing device efficiency,
4. Determination of vapor capture system efficiency,
5. Determination of overall control efficiency based on liquid
solvent material balance, and
6. Survey of fugitive emissions.
D.2.1 Performance Testing of Coatings
D.2.1.1 Analysis of Coatings. Recommended Method. EPA Reference
Method 24 is the recommended method for the analysis of coatings. This
method combines several ASTM standard methods to determine the volatile
matter content, water content, density, volume solids, and weight solids
of inks and related surface coatings. These parameter values are combined
to calculate the VOC content of a coating in the units specified in the
applicable regulation.
Reference Method 24A is similar in principle to Method 24, but some of
the analytical steps are slightly different and the results would differ.
D-7
-------
It was developed specifically for publication rotogravure printing inks
and contains specific analytical steps which were already widely used
in that industry. Thus, Reference Method 24A is not recommended for
analysis of coatings for polymeric coatings.
Volatile Matter Content (Wv). The total volatile content of a
coating is determined by using ASTM D 2369-81, "Standard Test Method for
Volatile Content of Coatings." This procedure is applied to both aqueous
and nonaqueous coatings. The result from this procedure is the volatile
content of a coating as a weight fraction.
Water Content (Ww). There are two acceptable procedures for deter-
mining the water content of a coating: (1) ASTM D 3792-80, "Standard Test
Method for Water Content of Water-Reducible Paints by Direct Injection
into a Gas Chromatograph," and (2) ASTM D 4017-81, "Standard Test Method
for Water in Paints and Paint Materials by the Karl Fischer Titration
Method." This procedure is applied only to aqueous coatings. The result
is the water content as a weight fraction.
Organic Content (W0). The volatile organic content of a coating
(as a weight fraction) is not determined directly. Instead, it is
determined indirectly by substraction from the total volatile content and
the water content values.
W0 = Wv - Ww
Solids Content (Ws). The solids content of a coating (as a weight
fraction) is also determined indirectly using the previously determined
values:
Ws = 1 - Wv = 1 - W0 - Ww
Volume Solids (Vs). There is no reliable, accurate analytical
procedure that is generally applicable to determine the volume solids of
a coating. Instead, the solids content (as a volume fraction) is calcu-
lated using the manufacturer's formulation data.
Coating Density (Dr)- The density of coating is determined
using the procedure in ASTM D 1475-60 (Reapproved 1980), "Standard Test
Method for Density of Paint, Varnish, Lacquer, and Related Products."
Cost. The estimated cost of analysis per coating sample is:
D-8
-------
$50 for the total volatile matter content procedure; $100 for the water
content determination; and $25 for the density determination. Because
the testing equipment is standard laboratory apparatus, no additional
purchasing costs are expected.
Adjustments. If nonphotochemically reactive solvents are used in the
coatings, then standard gas chromatographic techniques may be used to
identify and quantify these solvents. The results of Reference Method 24
may be adjusted to subtract these solvents from the measured VOC content.
D.2.1.2 Sampling and Handling of Coatings.. For Method 24 analysi s
of a coating, a sample should be obtained and placed in a 1-liter
container. The head-space in the container should be as small as possible
so that organics in the coating do not evaporate and escape detection.
The coating sample should be taken at a place that is representative of the
coating being applied. Alternatively, the coating may be sampled in the
mixing or storage area while separate records are kept of dilution solvent
being added at the coating heads. Some polymeric coatings have a component
that causes the coating to "set" within a short time period. Samples of
these coatings need to be taken before the "setting agent" has been added.
The coating sample should be protected from direct sunlight, extreme
heat or cold, and agitation. There is no limitation given in Method 24 for
the length of time between sampling and analysis.
D.2.1.3 Weighted Average VOC Content of Coatings. If a plant uses
all low-solvent coatings (as specified in the applicable regulation), then
each coating simply needs to be analyzed following Method 24. However, if
a plant uses a combination of low- and high-sol vent coatings, the weighted
average VOC content of all the coatings used over a specified time period
needs to be determined. Depending on the format of the standard, the
average is weighted by the volume or mass of coating solids.
In addition to the Method 24 or manufacturer's formulation informa-
tion, the amount (as a weight) of each coating used must be determined.
The EPA has no independent test procedure to determine the amount of
coating used, and instead it is recommended that plant inventory and usage
records be relied upon. Most plants already keep detailed records of
amounts of coatings used. Thus, no additional effort or cost is expected
to be required to attain coating usage. If a plant keeps its inventory
records on a volume basis, then the density of the coating needs to be
determined to convert the inventory to a mass basis.
0-9
-------
D.2.2 Stack Emission Testing
D.2.2.1 Testing Locations. Stack emission testing techniques
would be needed to measure the VOC concentration and gas flow rate in
stacks and ducts such as: inlets and outlets of vapor processing devices;
exhaust streams from mixing equipment and/or storage tanks; uncontrolled
exhaust streams venting directly to the atmosphere; intermediate process
streams such as hood exhausts and drying oven exhausts venting to other
process units. The particular streams to be measured depends upon the
applicable regulation.
D.2.2.2 Use of Test Results. The results from the VOC concen-
tration measurement and flow rate measurement can be combined and used in
many ways. If a regulation is on a concentration basis, then only VOC
concentration measurement is needed and the result can be used directly -
If the regulation is on a mass emission basis (i.e., mass emitted per unit
of production; or mass emitted per unit of time), then the concentration
and flow rate results are combined to calculate the mass flow rate. If
the regulation is on an efficiency basis, then mass flow rate is deter-
mined for each of the streams being compared and the efficiency is calcu-
lated straightforwardly.
The performance test procedure in the applicable regulation will
define the test length and the conditions under which testing is accept-
able, as well as the way the reference test method measurements are
combined to attain the final result.
D.2.2.3 Overall Control Efficiency. Performance test methods and
procedures are used to determine the overall control efficiency of the
add-on pollution control system. The add-on control system is composed
of two parts: a vapor capture system, and a vapor processing device
(carbon adsorber, condenser, or incinerator). The control efficiency of
each component is determined separately and the overall control efficiency
is the product of the capture system and processing device efficiencies.
(Note: This measured overall control efficiency will not reflect control
or emission reduction due to process and operational changes.)
D.2.2.4 Processing Device Efficiency. The three types of processing
devices that are expected to be used in the polymeric parts coating industry
are carbon adsorbers, condensers, and incinerators. The test procedure to
determine efficiency is the same for each control technology.
D-10
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To determine the efficiency of the emission processing device, the
VOC mass flow rate in the inlet and outlet gas streams must be determined.
To determine the mass of VOC in a gas stream, both the concentration and
flow rate must be measured. The recommended methods and the reason for
their selection are discussed later in Sections D.2.2.7 and D.2.2.8.
D.2.2.5 Capture System Efficiency. The efficiency of the vapor
capture system can be defined in one of two ways: (1) as the ratio of
the mass of gaseous VOC emissions directed to the vapor processing device
to the total mass of gaseous VOC, or (2) as the ratio of the mass of
gaseous VOC emissions directed to the vapor processing device to the total
mass of solvent applied in the coating process. The definitions are
essentially equivalent; selection of the measurement approach using one of
the two definitions is based upon considerations discussed below.
In order to determine capture efficiency by the first definition
(gas phase), all fugitive VOC emissions from the coating area must be
captured and vented through stacks suitable for testing. Furthermore, the
coating line being tested should be isolated from any fugitive VOC
emissions originating from other sources. All doors and other openings
through which fugitive VOC emissions might escape would be closed.
One way to isolate the coating line from other VOC sources is to
construct a temporary enclosure around the coating line to be tested.
This approach is not recommended because a temporary enclosure would
necessarily alter the ventilation around the coating line, making the
performance test not representative of normal operating conditions.
Instead, if an enclosure is needed, a permanent enclosure is recommended.
The cost of a one-time permanent enclosure would be comparable to that of
constructing and taking down a temporary enclosure each time a performance
test is conducted. However, if a temporary enclosure is used, the
enclosure must be designed to operate with ventilation proportional to the
overall building ventilation. In addition, the flow and YOC concentration
of the ventilation air would need to be measured using methods described in
Sections D.2.2.7 and D.2.2.8 or alternative methods with similar precision
and accuracy. Hence, the temporary enclosure must also be designed for
making these measurements.
Instead of requiring a performance test, a regulation may require a
specific equipment configuration in order to ensure a high capture
efficiency. For example, the applicable regulation may specify a total
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enclosure around the coater or sealed lids and a closed venting system for
coating mix equipment. To ensure that these equipment specifications are
met, visible inspections or Method 21 leak detection surveys can be
conducted. However, ESEU/EPA has no experience using Method 21 for
detecting such leaks in the surface coating industries, and thus cannot
recommend a leak concentration level to be used in evaluating the perform-
ance of various pieces of capture equipment.
In order to determine capture efficiency by the second (gas/liquid-
phase) definition, a generally simple approach is required. The gas-phase
VOC content of the capture streams must be measured, as discussed in
Sections D.2.2.7 and D.2.2.8. This is generally a straightforward
procedure, since the VOC stream is typically of relatively constant flow
rate and confined within a duct of known configuration. Simultaneously,
the liquid-phase solvent application rate must be determined. This
measurement typically involves measurement of the coating application rate
and the VOC content and density of the coating. The coating application
rate can be measured using plant instrumentation or by use of volumetric or
gravimetric techinques. The coating characteristics are determined by EPA
Reference Method 24, as described in Section D.2.1.
D.2.2.6 Stack Emission Testing—Time and Cost. The length of a
performance test is specified in the applicable regulation and is selected
to be representative for the industry and process being tested. The length
of a performance test should be selected to be long enough so as to account
for variability in emissions due to up and down operation times, routine
process problems, and different products. Also, the performance test time
period should correspond to the cycles of the emission control device.
Coating line operations are intermittent; there are often long time
periods between runs for cleanup, setup, and color matching, so the total
length of a performance test could vary from plant to plant. In general,
a performance test would consist of three to six runs, each lasting from
1/2 to 3 hours. It is estimated that for most operations, the field
testing could probably be completed in 2 to 3 days (i.e., two or three
8-hour work shifts) with an extra day for setup, instrument preparation,
and cleanup.
The cost of the testing varies with the length of the test and the
number of vents to be tested: inlet, outlet, intermediate process, and
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fugitive vents. The cost to measure VOC concentration and flow rate is
estimated at $6,000 to $10,000 per vent, excluding travel expenses.
D.2.2.7 Details on Gas Volumetric Flow Measurement Method.
Recommended methods. Reference Methods 1, 1A, 2, 2A, 2C, 2D, 3 and 4 are
recommended as appropriate for determination of the volumetric flow rate of
gas streams.
Large stacks with steady flow. Methods 1 and 2 are used in
stacks with steady flow and with diameters greater than 12 inches.
Reference Method 1 is used to select the sampling site, and Reference
Method 2 measures the volumetric flow rate using a S-type pi tot tube
velocity traverse technique. Methods 3 and 4 provide fixed gases analysis
and moisture content, which are used to determine the gas stream molecular
weight and density in Method 2. The results are in units of standard cubic
meters per hour.
Small ducts. If the duct is small (less than 12 inches diameter)
then alternative flow measurement techniques will be needed using Method
2A, Method 2D, or Methods 2C and 1A. Method 2A uses an in-line turbine
meter to continuously and directly measure the volumetric flow. Method
20 uses rotameters, orifice plates, anemometers, or other volume rate or
pressure drop measuring devices to continuously measure the flow rate.
Methods 1A and 2C (in combination) modify Methods 1 and 2 and use a small
standard pi tot tube traverse technique to measure the flow in small ducts,
and apply when the flow is constant and continuous.
Unsteady flow. If the flow in a large duct (greater than 12 inches
diameter) is not steady or continuous, then Method 2 may be modified to
continuously monitor the changing flow rate in the stack. A continuous
1-point pitot tube measurement is made at a representative location in the
stack. For small ducts with unsteady flow, continuous measurement with
Method 2A or 2D is recommended.
Adjustment for moisture. The results do not need to be adjusted
to dry conditions (using Method 4 for moisture) if the VOC concentrations
are measured in the gas stream under actual conditions; that is, if the
VOC concentrations are reported as parts of VOC per million parts of
actual (wet) volume (ppmv). If the concentrations are measured on a dry
basis (gas chromatographic techniques or Method 25) then the volumetric
flow rate must correspondingly be adjusted to a dry basis.
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D.2.2.8 Details on VOC Concentration Measurement Method (Method 25A).
The recommended VOC measurement method is Reference Method 25A, "Determi-
nation of Total Gaseous Organic Concentration Using A Flame lonization
Analyzer". This method was selected because it measures the expected
solvent emissions accurately, is practical for long-term, intermittent
testing, and provides a continuous record of VOC concentration. A
continuous record is valuable because of coating line and control device
fluctuations. Measurements that are not continuous may not give a repre-
sentative indication of emissions. The coating lines in this industry may
operate intermittently, and the vent concentrations may vary significantly.
Continuous measurements and records are easier to use for intermittent
processes, and the short-term variations in concentration can be noted.
The continuous records are averaged or integrated as necessary to obtain
an average result for the measurement period.
Method 25A applies to the measurement of total gaseous organic
concentration of vapors consisting of alkanes, and/or arenes (aromatic
hydrocarbons), and other organic solvent compounds. The instrument is
calibrated in terms of propane or another appropriate organic compound.
A sample is extracted from the source through a heated sample line and
glass fiber filter and routed to a FIA. (Provisions are included for
eliminating the heated sampling line and glass fiber filter under some
sampling conditions.) Results are reported as concentration equivalents of
the calibration gas organic constitutent or organic carbon.
Instrument calibration is based on a single reference compound. For
the polymeric coating industry, the recommended calibration compound is
propane or butane. (However, if only one compound is used as the sole
solvent at a plant, then that solvent could be used as the calibration
compound.) As d result, the sample concentration measurements are on ti,-
basis of that reference compound and are not necessarily true hydrocarbon
concentrations. The response of an FIA is proportional to carbon content
for similiar compounds. Thus, on a carbon number basis, measured concen-
trations based on the reference compound are close to the true hydrocarbon
concentrations. Also, any minor biases in the FIA concentration results
are less significant if the results will be used in an efficiency
calculation (both inlet and outlet measurements are made and compared) and
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biases in each measurement will tend to cancel out. For calculation
of emissions on a mass basis, results would be nearly equivalent using
either the concentration and molecular weight based on a reference gas
or the true concentration and true average molecular weight of the hydro-
carbons.
The advantage of using a single component calibration is that costly
and time consuming chromatographic techniques are not required to isolate
and quantify the individual compounds present. Also, propane and butane
calibration gases are readily available in the concentration ranges needed
for this industry.
The analysis technique using an FIA measures total hydrocarbons
including methane and ethane, which are considered non-photochemically
reactive, and thus not VOC's. Due to the coating solvent composition,
little methane or ethane is expected in the gas streams so chromatographic
analysis is not needed nor recommended to adjust the hydrocarbon results to
a nonmethane, nonethane basis.
Other Methods. Three other VOC concentration measurement methods
were considered (and rejected) for this application: Method 18, Method
25B, and Method 25.
Method 18. Gas chromatograph analysis on integrated bag samples
following Method 18 was considered because results would be on the basis of
true hydrocarbon concentrations for each compound in the solvent mixture.
However, the BAG/GC sample technique is not a continuous measurement and
would be cumbersome and impractical because of the length of the testing.
Also, it would be costly and time consuming to calibrate for each com-
pound, and there is little advantage or extra accuracy gained from the GC
approach.
Method 25B. Method 25B, "Determination of Total Gaseous Organic
Concentration Using a Nondispersive Infrared Analyzer," is identical to
Method 25A except that a different instrument is used. Method 25B applies
to the measurement of total gaseous organic concentration of vapor
consisting primarily of alkanes. The sample is extracted as described in
Method 25A and is analyzed with a nondispersive infrared analyzer (ND1R).
Method 25B was not selected because NDIR analyzers do not respond as well
as FIA's to all of the solvents used in this industry. Also, NDIR's are
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not sensitive in low concentration ranges (<50 ppmv), and the outlet
concentrations from incinerators and carbon adsorbers are expected to
often be below 50 ppmv.
Method 25. Method 25, "Determination of Total Gaseous Nonmethane
Organics Content" was also considered. A 30- to 60-minute integrated
sample is collected in a sample train, and the train is returned to the
laboratory for analysis. The collected organics are converted in several
analytical steps to methane and the number of carbon atoms (less methane
in the original sample) is measured. Results are reported as organic
carbon equivalent concentration. The Method 25 procedure is not
recommended for this industry because it is awkward to use for long test
periods and it takes Integrated samples instead of continuously sampling
and recording the concentration. Concentration variations would be masked
with Method 25 time-integrated sample. Also, Method 25 is not sensitive in
low concentration ranges (<50 ppmv). However, Method 25 has the advantage
that it counts each carbon atom in each compound and does not have a
varying response ratio for different compounds.
D.2.3 Liquid Solvent Material Balance
If a plant's vapor processing device recovers solvent (such as carbon
adsorption or condenser systems) then a liquid solvent material balance
approach can be used to determine the efficiency of the vapor control
system. This is done by comparing the solvent used versus the solvent
recovered. These values may be obtained from a plant's inventory records.
The EPA has no test procedure to independently verify the plant's accounting
records. However, it is recommended that the plant set up and submit to
the enforcement agency its proposed inventory accounting and record keeping
system prior to any performance testing.
For this performance testing approach, the averaging time (performance
test time period) usually needs to be 1 week to 1 month. This longer
averaging period allows for a representative variety of coatings and
products, as well as reducing the impact of short-term variations due to
process upsets, solvent spills, and variable amounts of solvent in use in
the process.
The volume of solvent recovered may be determined by measuring the
level of solvent in the recovered solvent storage tank. The storage tank
should have an accurate, easily readable level indicator. To improve the
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precision of the volume measurement, it is recommended that the recovered
solvent tank have a relatively small diameter, so that small changes in
volume result in greater changes in tank level. Alternatively, the
solvent recovered may be measured directly by using a liquid volume meter
in the solvent return line. Adjustments to the amount of solvent
recovered may be needed to match the format of the applicable regula-
tion. For example, if the regulation applies to only certain unit
operations in a plant, then the contributions of other VOC sources must be
subtracted from the total amount of solvent recovered. When measuring the
recovered solvent, special techniques may be required if the solvent is
not well mixed and homogeneous. This may require the measurement of
volume of two immiscible liquid phases. These samples of each phase would
need to be taken to determine the solvent content. The concentration of
solvent in each phase and the volumes would then be used to calculate the
total solvent recovered.
The volume of solvent used may be determined from plant inventory and
purchasing records or by measuring the level in the solvent storage
tank. Alternatively, a liquid volume meter can be used to measure the
amount of solvent drawn off from the solvent storage tank. Adjustments to
the amount of solvent used may be needed to match the format of the
applicable regulation. For example, the regulation may apply to only
certain unit operations in a plant, or to only solvent applied at the
coater not to solvent used for cleanup.
0.3 MONITORING SYSTEMS AND DEVICES
The purpose of monitoring is to ensure that the emission control
system is being properly operated and maintained after the performance
test. One can either directly monitor the regulated pollutant, or
instead, monitor an operational parameter of the emission control
system. The aim is to select a relatively inexpensive and simple method
that will indicate that the facility is in continual compliance with the
standard.
The three types of vapor processing devices that are expected to be
used in the polymeric coating industry are carbon absorbers, condensers,
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and incinerators. Possible monitoring approaches and philosophy for each
part of the VOC control system are discussed below.
D.3.1 Monitoring of Vapor Process Devices
D.3.1.1 Monitoring in Units of Efficiency. There are presently no
demonstrated continuous monitoring systems commercially available which
monitor vapor processor operation in the units of efficiency. This
monitoring would require measuring not only inlet and exhaust VOC
concentrations, but also inlet and exhaust volumetric flow rates. An
overall cost for a complete monitoring system is difficult to estimate due
to the number of component combinations possible. The purchase and
installation cost of an entire monitoring system (including VOC
concentratin monitors, flow measurement devices, recording devices, and
automatic data reduction) is estimated to be $25,000. Operating costs are
estimated at $25,000 per year. Thus, monitoring in the units of
efficiency is not recommended due to the potentially high cost and lack of
a demonstrated monitoring system.
D.3.1.2 Monitoring in Units of Mass Emitted. Monitoring in units of
mass of VOC emitted would require concentration and flow measurements only
at the exhaust location, as discussed above. This type of monitoring
system has not been commercially demonstrated. The cost is estimated at
$12,500 for purchase and installation plus $12,500 annually for operation,
maintenance, calibration, and data reduction.
D.3.1.3 Monitoring of Exhaust VOC Concentration. Monitoring
equipment is commercially available to monitor the operational or process
variables associated with vapor control system operation. The variable
which would yield the best indication of system operation is VOC
concentration at the processor outlet. Extremely accurate measurements
would not be required because the purpose of the monitoring is not to
determine the exact outlet emissions but rather to indicate operational
and maintenance practices regarding the vapor processor. Thus, the
accuracy of a FIA (Method 25A) type instrument is not needed, and less
accurate, less costly instruments which use different detection principles
are acceptable. Monitors for this type of continuous VOC measurements,
including a continuous recorder, typically cost about $6,000 to purchase
and install, and $6,000 annually to calibrate, operate, maintain, and
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reduce the data. To achieve representative VOC concentration measurements
at the processor outlet, the concentration monitoring device should be
installed in the exhaust vent at least two equivalent stack diameters from
the exit point, and protected from any interferences due to wind, weather,
or other processes.
In addition to monitoring the exhaust only, the inlet to the vapor
control system can be monitored. This data will provide insight to the
performance of the recovery system and indicate whether increases in
exhaust VOC concentrations are due to process variables or improper
operation of the control device. The increase in cost would be primarily
associated with the capital cost of an additional continuous VOC monitor
(i.e., less than $6,000). The annual operation cost should not be much
greater than the costs for a single analyzer. The EPA does not currently
have any experience with continuous monitoring of VOC exhaust concen-
tration of vapor processing units in the polymeric industry. Therefore,
performance specifications for the sensing instruments cannot be
recommended at this time. Examples of such specifications that were
developed for sulfur dioxide and. nitrogen oxides continuous instrument
systems can be found in Appendix B of 40 CFR 60.
D.3.1.4 Monitoring of Process Parameters. For some vapor processing
systems, there may be another process parameter besides the exhaust VOC
concentration which is an accurate indicator of system operation. Because
control system design is constantly changing and being upgraded in this
industry, all acceptable process parameters for all systems cannot be
specified. Substituting the monitoring of vapor processing systems
process parameters for the monitoring of exhaust VOC concentration is
valid and acceptable if it can be demonstrated that the value of the
process parameter is an indicator of proper operation of the vapor
processing system. However, a disadvantage of parameter monitoring alone
is that the correlation of the parameters with the numerical emission
limit is not exact. Monitoring of any such parameters would have to be
approved by enforcement officials on a case-by-case basis. Parameter
monitoring equipment would typically cost about $2,000 plus $3,000
annually to operate, maintain, periodically calibrate, and reduce the data
into the desired format. Temperature monitoring equipment is somewhat
D-19
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less expensive. The cost of purchasing and installing an accurate
temperature measurement device and recorder is estimated at $1,500.
Operating costs, including maintenance, calibration, and data reduction,
would be about $1,500 annually.
D.3.1.5 Monitoring of Carbon Adsorbers. For carbon absorption vapor
processing devices, the preferred monitoring approach is the use of a
continuous VOC exhaust concentration monitor. However, as discussed
above, no such general monitor has been demonstrated for the many
different organic compounds encountered in this industry. Alternatively,
the carbon bed temperature (after regeneration and completion of any
cooling cycles), and the-amount of steam used to regenerate the bed have
been identified as indicators of produce recovery efficiency. Temperature
monitors and steam flow meters which indicate the quantity of steam used
over a period of time are available.
D.3.1.6 Monitoring of Condensers. For condenser devices, the
temperature of the exhaust stream has been identified as an indicator of
product recovery efficiency, and condenser temperature monitors are
available.
D.3.1.7 Monitoring of Incinerators. For incineration devices, the
exhaust concentration is quite low and is difficult to measure accurately
with the inexpensive VOC monitors. Instead, the firebox temperature has
been identified and demonstrated to be a process parameter which reflects
level of emissions from the device. Thus, temperature monitoring is the
recommended monitoring approach for incineration control devices. Since a
temperature monitor is usually included as a standard feature for
incinerators, it is expected that this monitoring requirement will not
incur additional costs to the plant.
D.3.1.8 Use of Monitoring Data. The use of monitoring data is the
same regardless of whether the VOC outlet concentration or an operational
parameter is selected to be monitored. The monitoring system should be
installed and operating properly before the first performance test.
Continual surveillance is achieved by comparing the monitored value of the
concentration or parameter to the value which occurred during the last
successful performance test, or alternatively, to a preselected value
which is indicative of good operation. It is important to note that a
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high monitoring value does not positively confirm that the facility is out
of compliance; instead, it indicates that the emission control system or
the coating process is operating in a different manner than during the
last successful performance test.
The averaging time for monitoring purposes should be related to the
time period for the performance test.
D.3.2 Monitoring of Vapor Capture Systems
D.3.2.1 Monitoring in Units of Efficiency. Monitoring the vapor
capture system in the units of efficiency would be a difficult and costly
procedure. This monitoring approach would require measuring the VOC
concentration and volumetric flow rate in the inlet to the vapor
processing device and in each fugitive VOC vent and then combining the
results to calculate an efficiency for each time period. Such a
monitoring system has not been commercially demonstrated. The purchase
and installation of an entire monitoring system is estimated at
$12,500 per stack, with an additional $12,500 per stack per year for
operation, maintenance, calibration, and data reduction. Thus, monitoring
in the units of efficiency is not recommended.
D.3.2. Monitoring of Flow Rates. As an alternative to monitoring
efficiency, an operational parameter could be monitored instead. The key
to a good capture system is maintaining proper flow rates in each vent.
Monitoring equipment is commercially available which could monitor these
flow rate parameters. Flow rate monitoring equipment for each vent would
typically cost about $3,000 plus $3,000 annually to operate, maintain,
periodically calibrate, and reduce the data into the desired format. The
monitored flow rate values are then compared to the monitored value during
the last successful performance test.
Proper flow rates and air distribution in a vapor capture system
could also be ensured by an inspection and maintenance program, which
generally would not create any additional cost burden for a plant. In
that case, the additional value of information provided by flow rate
monitors would probably be minimal. Routine visual inspections of the
fan's operation would indicate whether or not capture efficiencies remain
at the performance test level, and no formal monitoring of the air
distribution system would be required.
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If a total enclosure is specified in the applicable regulation to
ensure proper capture, then the proper operation of the total enclosure
can be monitored. Examples of monitoring devices include VOC
concentratioon detectors inside the enclosure, pressure sensors inside the
enclosure, flow rate meters in ducts, and fan amperage meters.
D.3.3 Monitoring of Overall Control System Efficiency on a Liquid Basis
If a plant uses a vapor recovery control device, the efficiency of
the overall plant control (combined vapor capture and vapor recovery
systems) can be monitored using a liquid material balance. (These amounts
may need to be adjusted to match the format of the applicable
regulation.) The amount of solvent used is compared to the amount of
solvent recovered. These values are obtained from a plant's inventory
records. For this monitoring approach, the averaging time or monitoring
period usually needs to be 1 week to 1 month. This longer averaging
period is necessary to coordinate with a plant's inventory accounting
system and to eliminate short-term variations due to process upsets,
solvent spills, and variable amounts of solvent in use in the process.
Because most plants already keep good solvent usage and inventory
records, no additional cost to the plant would be incurred for this
monitoring approach.
D.3.4 Monitoring of Coatings
If a plant elects to use low-solvent content coatings in lieu of
control devices, then the VOC content of the coatings should be
monitored. There is no simplified way to do this. Instead, the
recommended monitoring procedure is the same as the performance test: the
plant must keep records of the VOC content and amount of each coating used
and calculate the weighted average VOC content over the time period
specified in the regulation. As an alternative, the plant could set up a
sampling program so that random samples of coatings would be analyzed
using Reference Method 24.
D.4 TEST METHOD LIST AND REFERENCES
The EPA testing methods that are mentioned in this Appendix are
listed below with their complete title and reference.
D-22
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D.4.1 Reference Methods in Appendix A - 40 CFR 60
Method 1 - Sample and Velocity Traverses for Stationary Sources.
Method 2 - Determination of Stack Gas Velocity and Volumetric
Flow Rate (Type S Pitot Tube).
Method 2A - Direct Measurement of Gas Volume Through Pipes and Small
Ducts.
Method 3 - Gas Analysis for Carbon Dioxide, Excess Air, and Dry
Molecular Weight.
Method 4 - Determination of Moisture in Stack Gases.
Method 18 - Measurement of Gaseous Organic Compound Emissions by Gas
Chromatography.
Method 21 - Determination of Volatile Organic Compound Leaks.
Method 24 - Determination of Volatile Matter Content, Water Content,
Density, Volume Solids, and Weight Solids of Surface
Coatings.
Method 24A - Determination of Volatile Matter Content and Density of
Printing Inks and Related Coatings.
Method 25 - Determination of Total Gaseous Nonmethane Organic
Emissions as Carbon.
Method 25A - Determination of Total Gaseous Organic Concentration
Using a Flame lonization Analyzer.
Method 25B - Determination of Total Gaseous Organic Concentration
Using a Nondispersive Infrared Analyzer.
D.4.2 Proposed Methods for Appendix A - 40 CFR 60
Method 1A - Sample and Velocity Traverses for Stationary Sources With
Small Stacks or Ducts (Proposed on 10/21/83, 48 FR 48955).
Method 2C - Determination of Stack Gas Velocity and Volumetric Flow
Rate From Small Stacks and Ducts (Standard Pilot Tube)
(Proposed on 10/21/83, 48 FR 48956).
Method 20 - Measurement of Gas Volume Flow Rates in Small Pipes and
Ducts (Proposed on 10/21/83, 48 FR 48957).
D.4.3 Other Methods
"General Measurement of Total Gaseous Organic Compound Emissions
Using a Flame lonization Analyzer," in "Measurement of Volatile Organic
Compounds Supplement 1," OAQPS Guideline Series, EPA Report
No. 450/3-82-019, July 1982.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before complcnngi
i. REPORT NO.
EPA-450/3-85-022a
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
.III l_c MI-MU/ OUD I I I UC
Polymeric Coating of Supporting Substrates-Background
Information for Proposed Standards
5. REPORT DATE
April 1987
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3817
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air and Radiation
U. S. Environmental Protection Agency
Research Triangle Park. North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Draft
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of performance for the control of VOC emissions from the polymeric
coating of supporting substrates are being proposed under the authority of
Section 111 of the Clean A1r Act. These standards would apply to all new, modified,
or reconstructed polymeric coating lines using at least 110 cubic meters of solvent
per year 1n the production of polymeric-coated supporting substrates. This document
contains background Information and environmental and economic Impact assessments of
the regulatory alternatives considered in developing the proposed standards.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Pollution Control
Standards of Performance
Volatile Organic Compounds
Web Coating
Polymeric Coating of Supporting Substrates
Air Pollution Control
13B
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
312
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220.1 (R.v. 4-77) PREV.OUS ED.T.ON is OBSOLETE
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