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

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                                 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

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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.

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                      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

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                       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

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                       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

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                         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

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                         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

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                         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

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                         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

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                         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

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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

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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.

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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

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             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

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$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
                                     2-2

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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
                                    2-3

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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
                                     2-4

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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

                                    2-5

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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,
                                     2-6

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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

                                    2-7

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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
                                     2-8

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energy use.  Section 317 requires that the economic Impact assessment be  as
extensive as practicable.
     The economic impact of a proposed standard upon an industry is usually
addressed both in absolute terms and by comparison with the control costs
that would be incurred as a result of compliance with typical, existing
State control regulations.  An incremental approach is taken because both
new and existing plants would be required to comply with State regulations
in the absence of a Federal standard of 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
                                    2-9

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of Columbia Circuit has held that environmental impact statements need not
be prepared by the Agency for proposed actions under Section 111 of the
Clean Air Act.  Essentially, the Court of Appeals has determined that the
best system of emission reduction requires the 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
                                    2-10

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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.
                                   2-11

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                   3.  PROCESSES AND POLLUTANT EMISSIONS

     Polymeric coating of supporting substrates is a subcategory of web
coating.  Web coating is defined as coating of fabric, paper, plastic film,
metallic foil, metal  coil, or other products that are flexible enough to be
unrolled from a large roll, coated by blade, roll coating, or rotogravure
as a continuous sheet and, after cure,  rerolled.   Several  web coating
categories are already subject to, or are being investigated for,
regulation by new source performance standards.  These are:  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.
                                    3-1

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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.
                                     3-2

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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)
                                    3-3

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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.
                                     3-4

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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.
                             3-5

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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
                        3-6

-------
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
                                    3-7

-------
      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.
                                    3-8

-------
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

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                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

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     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

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 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

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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.
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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.
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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.
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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

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     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

                                    4-17

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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.

                                    4-18

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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:
                                   4-23

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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

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     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   .

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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

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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.
                                    4-37

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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.
                                    4-38

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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

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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

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factors, by material balances, by continuous monitoring data, or by manual
emission tests in cases where the use of emission factors does not clearly
demonstrate that emissions do or do not increase.  Under the current
regulations, an emission increase from one facility may not be offset with
a similar emission decrease at another facility to avoid becoming subject
to new source performance standards (NSPS).  If an existing facility is
determined to be modified, it becomes an affected facility, subject to the
standards of performance for the pollutant or pollutants that have
increased due to modification.  All emissions, not just the incremental
increase -in emissions, of the pollutants that have increased from the
facility must be in compliance with the applicable standards.  A
modification to one existing facility at a plant will not cause other
existing facilities at the same plant to become subject to the standards.
     Under the regulations, certain physical or operational changes are not
considered to be modifications even though emissions may increase as a
result of the change  (see 40 CFR 60.14(e)).  The exceptions as allowed
under 40 CFR 60.14(e) are as follows:
     1.  Routine maintenance, repair, and replacement (e.g., lubrication of
mechanical equipment; replacement of pumps, motors, and piping;  cleaning
of equipment);
     2.  An increase  in the production rate without a capital expenditure
(as  defined in 40 CFR 60.2);
     3.  An increase  in the hours of operation;
     4.  Use of an  alternative fuel or raw material if, prior to proposal
of the  standard, the  existing facility was designed to accommodate that
alternate fuel or raw material;
     5.  The addition or use of any system or device whose primary function
is to reduce air pollutants, except when an emission control system is
replaced by a system  determined by 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

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pollutant to which a standard applies shall notify the appropriate  EPA
regional office 60 days prior to the change, as specified in
40 CFR 60.7(a)(4).
5.1.2  Reconstruction
     An existing facility may become subject to NSPS if it is recon-
structed.  Reconstruction is defined as the replacement of the components
of an existing facility to the extent that (1) the fixed capital cost of
the new components exceeds 50 percent of the fixed capital cost required to
construct a comparable new facility and (2) it is technically and
economically feasible for the facility to meet the applicable standards.
Because 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

-------
                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

-------
             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

-------
                         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

-------
                  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.

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     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

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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

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      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

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     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

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 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

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                       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.

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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

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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

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 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

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                   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

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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

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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

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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

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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

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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

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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

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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.

-------
00
I
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.

-------
                             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).

-------
00

ro
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).

-------
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
I
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).

-------
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

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   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

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          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

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          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

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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

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                              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

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                          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

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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

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                           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

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     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.

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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.

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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.

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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

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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.

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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

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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

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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

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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

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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

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       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

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                          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

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                          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

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          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

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                          TABLE B-l.   (continued)
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
                                     Location within the  Background
                                         Information Document
    Regulatory alternatives
3.
ENVIRONMENTAL IMPACT OF THE
REGULATORY ALTERNATIVES

Primary impacts directly
attributable to the regulatory
alternatives
    Secondary or induced  impacts
4.  OTHER CONSIDERATIONS
                                     The various  regulatory alterna-
                                     tives  are  defined  in  Chapter 6,
                                     Section  6.2.   A  summary of the
                                     major  alternatives  considered
                                     is   included  in  Chapter 1,
                                     Section  1.1.
The primary impacts on mass
emissions and ambient air quality
due to the alternative control
systems are discussed in
Chapter 7, Sections 7.1, 7.2,
7.3, 7.4, and 7.5.  A matrix
summarizing the environmental
impacts is included in
Chapter 1.

Secondary impacts for the various
regulatory alternatives are
discussed in Chapter 7,
Sections 7.1, 7.2, 7.3, 7.4, and
7.5.

A summary of the potential
adverse environmental impacts
associated with the regulatory
alternatives is included in
Chapter 1, Section 1.2, and
Chapter 7.  Potential socio-
economic and inflationary impacts
are discussed in Chapter 9,
Sections 9.2 and 9.3.
                                    B-3

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                                APPENDIX C
                         EMISSION  SOURCE  TEST DATA

     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

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     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

-------
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                     Xylene
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                                   MIX
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                                   // 9
                                  V
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                         TANK
                         // 8
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                   Operat ions
                                           MIX TUWhK
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                                                                                 Xylene Additions
                                                                        Xylene Additions
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                                     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

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 t
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30

20

10

  0
           1
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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
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109
 99
 88
 70
 S0
 50
 40
 30
 20
 10
   9
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                                      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

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  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

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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.

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             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.









































































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                   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

-------
     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.
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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:
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$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.
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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.
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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

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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.
                                   D-23

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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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