xvEPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 2771 1
EPA-450/2-78-045a
October 1979
Air
Organic Solvent
Cleaners -
Background
Information for
Proposed Standards
Draft
EIS
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EPA-450/2-78-045a
Organic Solvent Cleaners -
Background Information
for Proposed Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle, Park, North Carolina 27711
October 1979
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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, N.C. 27711,
or from National Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161.
Publication No. EPA-450/2-78-045a
11
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Background Information
and Draft
Environmental Impact Statement
for Organic Solvent Cleaners
Type of Action: Administrative
Prepared by:
7/3/7?
Don R. Goodwin ' (Date)
Director, Emission Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, N. C. 27711
Approved by:
/
David G. Hawkins (Date)
Assistant Administrator for Air, Noise and Radiation
Environmental Protection Agency
Washington, D. C. 20460
Draft Statement Submitted to EPA's
Office of Federal Activities for Review on January 1980
(Date)
This document may be reviewed at:
Central Docket Section
Room 2903B, Waterside Mall
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460
Additional copies may be obtained at:
Environmental Protection Agency Library (MD-35)
Research Triangle Park, N. C. 27711
National Technical Information Service
5285 Port Royal Road
Springfield, Virginia 22161
m
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TABLE OF CONTENTS
Page
LIST OF FIGURES vii
LIST OF TABLES viii
CHAPTER 1. SUMMARY 1-1
1.1 PROPOSED STANDARDS 1-1
1.2 ENVIRONMENTAL IMPACT ]-2
1.3 ECONOMIC IMPACT 1-4
CHAPTER 2. INTRODUCTION 2-1
2.1 AUTHORITY FOR THE STANDARDS 2-1
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES. . .2-6
2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF
PERFORMANCE 2-8
2.4 CONSIDERATION OF COSTS 2-11
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS 2-12
2.6 IMPACT ON EXISTING SOURCES 2-14
2.7 REVISION OF STANDARDS OF PERFORMANCE 2-15
CHAPTER 3. THE ORGANIC SOLVENT CLEANING INDUSTRY 3-1
3.1 GENERAL 3-1
3.2 LEVEL OF EMISSIONS FOR COLD CLEANERS 3-4
3.3 LEVEL OF EMISSIONS FOR OPEN TOP VAPOR DEGREASERS .3-5
3.4 LEVEL OF EMISSIONS FOR CONVEYORIZED DEGREASERS . .3-7
3.5 REFERENCES - 3-9
CHAPTER 4. EMISSION CONTROL TECHNIQUES 4-1
4.1 GENERAL 4-1
4.2 PERFORMANCE OF EMISSION CONTROL TECHNIQUES . . . .4-10
4.3 REFERENCES 4-16
±\
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TABLE OF CONTENTS (continued)
Page
Chapter 5. MODIFICATION AND RECONSTRUCTION OF
ORGANIC SOLVENT CLEANERS 5-1
5.1 BACKGROUND 5-1
5.2 POTENTIAL MODIFICATIONS 5-2
5.3 RECONSTRUCTION 5-5
5.4 REFERENCES 5-7
CHAPTER 6. SELECTED EMISSION CONTROL SYSTEMS 6-1
6.1 COLD CLEANERS 6-1
6.2 OPEN TOP VAPOR DEGREASERS 6-6
6.3 CONVEYORIZED DEGREASERS 6-11
6.4 WASTE SOLVENT DISPOSAL OPERATIONS 6-15
6-5 REFERENCES 6-17
CHAPTER 7. ENVIRONMENTAL IMPACT 7-1
7.1 AIR POLLUTION IMPACT 7-1
7.2 WATER POLLUTION IMPACT 7-3
7.3 SOLID WASTE IMPACT 7-8
7.4 ENERGY IMPACT 7-10
7.5 OTHER ENVIRONMENTAL IMPACTS 7-14
7.6 OTHER ENVIRONMENTAL CONCERNS 7-15
7.7 REFERENCES 7-18
CHAPTER 8. ECONOMIC IMPACT 8-1
8.1 INDUSTRY ECONOMIC PROFILE 8-1
8.2 COST ANALYSIS OF ALTERNATIVE EMISSION CONTROL SYSTEMS 8-38
8.3 OTHER COST CONSIDERATIONS 8-61
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TABLE OF CONTENTS (continued)
Page
8.4 ECONOMIC IMPACT OF ALTERNATIVE EMISSION
CONTROL SYSTEMS 8-63
8.5 POTENTIAL SOCIO-ECONOMIC AND INFLATIONARY IMPACTS. . . '8-93
8.6 REFERENCES 8-96
Chapter 9. RATIONALE FOR THE PROPOSED STANDARDS 9-1
9.1 SELECTION OF SOURCE FOR CONTROL 9-1
9.2 SELECTION OF POLLUTANTS AND AFFECTED FACILITIES. ... 9-2
9.3 SELECTION OF THE BASIS OF THE PROPOSED STANDARDS ... 9-8
9.4 SELECTION OF THE FORMAT OF THE PROPOSED STANDARD ... 9-16
9-5 SELECTION OF EMISSION LIMITS 9-16
9.6 MODIFICATION/RECONSTRUCTION CONSIDERATIONS 9-18
9.7 SELECTION OF PERFORMANCE TEST METHODS 9-21
APPENDIX A. EVOLUTION OF THE PROPOSED STANDARDS A-l
APPENDIX B. INDEX TO ENVIRONMENTAL IMPACT
CONSIDERATIONS B-l
APPENDIX C. EMISSION SOURCE TEST DATA C-l
APPENDIX D. EMISSION MEASUREMENT AND CONTINUOUS
MONITORING D-l
APPENDIX E. ENFORCEMENT ASPECTS E-l
APPENDIX F. ECONOMICS
F.I MANUFACTURING DECREASING...SIC CODES 25, 33-39. . F-l
F.2 MAINTENANCE DECREASING OF RAILROAD STOCK F-14
F.3 MAINTENANCE DECREASING OF AIRCRAFT F-15
F.4 AUTO REPAIR DECREASING F-17
F.5 ESTIMATED COSTS OF DECREASING OPERATIONS F-19
F.6 REFERENCES FOR APPENDIX F F-32
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LIST OF FIGURES
Page
Figure 5-1 METHOD OF DETERMINING WHETHER CHANGES TO AN
EXISTING FACILITY CONSTITUTES A MODIFICATION
OR RECONSTRUCTION UNDER 40CFR 60.14 AND 60.15 . .5-3
Figure 8-1 COST EFFECTIVENESS OF CONTROL OPTIONS FOR
OPEN TOP VAPOR DEGREASERS 8-56
Figure 8-2 COST EFFECTIVENESS OF CONTROL OPTIONS FOR
CONVEYORIZED VAPOR DEGREASERS 8-58
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LIST OF TABLES
Page
Table 1-1 MATRIX OF ENVIRONMENTAL AND ECONOMIC IMPACTS
OF ALTERNATIVE STANDARDS _
Table 3-1 NATIONAL DECREASING SOLVENT CONSUMPTION . ... 3-3
Table 4-1 CONTROL TECHNOLOGY EVALUATION SUMMARY . . . . . 4-2
Table 6-1 DESCRIPTION AND OPERATING CONDITIONS FOR
REPRESENTATIVE COLD CLEANER .......... 6-5
Table 6-2 PERCENTAGE REDUCTION IN VAPORIZATION LOSSES . . 6-10
Table 6-3 OPERATING CONDITIONS FOR REPRESENTATIVE OTVD . . 6-10
Table 6-4 REDUCTIONS IN VAPORIZATION LOSSES ....... 6-11
Table 6-5 REDUCTION IN TOTAL SOLVENT EMISSION EFFECTED BY
CARBON ADSORBERS ................ 6-15
Table 7-1 CONSUMPTION AND UNCONTROLLED EMISSIONS OF
SOLVENTS IN METAL-CLEANING OPERATIONS IN 1974. . 7-2
Table 7-2 UNCONTROLLED EMISSIONS FROM DEGREASERS IN 1985 . 7-3
Table 7-3 APPLICABLE CONTROL EQUIPMENT AND ITS
EFFECTIVENESS .................. 7-4
Table 7-4 PROJECTED ANNUAL EMISSIONS FROM NEW
DEGREASERS, 1979-1985 ............. 7-5
Table 7-5 PROPERTIES RELATED TO ENERGY CONSERVATION . . . 7-13
Table 8-1 PRODUCERS OF HALOGENATED SOLVENTS ....... 8-5
Table 8-2 INDUSTRIES USING DEGREASERS BY SIC CODE - 1976 .8-7
Table 8-3 ESTIMATED NUMBERS OF DEGREASERS BY SIC CODE -
1976 ...................... 8-11
Table 8-4 DECREASING COST SHARES BY DECREASING PROCESS
FOR SIC CODE INEUSTRIES ............ 8-17
viii
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LIST OF TABLES
Table 8-5 ESTIMATED NUMBERS OF DEGREASERS FOR 1976
BY GEOGRAPHIC LOCATION 8-20
Table 8-6 PROJECTED NUMBERS OF DEGREASERS FOR 1980
AND 1985 BY SIC CODE 8-23
Table 8-7 AVERAGE PLANT SIZE BY 3-DIGIT
INDUSTRIES: 1963-1972 8-29
Table 8-8 SUMMARY OF TRENDS IN AVERAGE PLANT SIZE,
1963-1972 8-32
Table 8-9 SOLVENT USE IN ROOM TEMPERATURE CLEANING
IN THE METALWORKING INDUSTRY 8-37
Table 8-10 COST PARAMETERS FOR MODEL COLD CLEANERS . . . 8-42
Table 8-11 COSTS OF CONTROLS FOR MODEL COLD CLEANERS . . 8-44
Table 8-12 ENGINEERING PARAMETERS FOR MODEL OPEN
"TOP VAPOR DEGREASERS (OTVD) 8-46
Table 8-13 COSTS OF ALTERNATIVE CONTROLS FOR OPEN
TOP VAPOR DEGREASERS 8-48
Table 8-14 EMISSION CONTROL ESTIMATES FOR CVD 8-51
Table 8-15 ENGINEERING PARAMETERS FOR MODEL
CONVEYORIZED VAPOR DEGREASERS (CVD) 8-52
Table 8-16 COSTS OF ALTERNATIVE CONTROLS FOR
CONVEYORIZED VAPOR DEGREASERS 8-54
Table 8-17 ANNUALIZED COSTS OF CONTROLS FOR TYPICAL
DEGREASERS, 1976 PRICES 8-73
Table 8-18 OUTPUT EFFECTS, SCENARIOS 1-3 8-74
Table 8-19 ADDITIONAL EMPLOYMENT REQUIREMENTS,
SCENARIOS 1-3 8-77
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LIST OF TABLES
Table 8-20A TOTAL COMPLIANCE COSTS: SCENARIOS
1 AND 4 8-79
Table 8-20B TOTAL COMPLIANCE COSTS: SCENARIOS
2 AND 5 8-80
Table 8-20C TOTAL COMPLIANCE COSTS: SCENARIOS
3 AND.6 8-81
Table 8-21 DIRECT PRICE EFFECTS, SCENARIOS 1-3 8-83
Table 8-22 EFFECTS OF CONTROL OPTIONS OF PROFIT
RATES, CAPITAL AVAILABILITY AND INVESTMENT . .8-85
Table 8-23 POST STANDARD USE OF DECREASING
EQUIPMENT: BY INDUSTRY 8-88
Table 8-24 TOTAL UTILIZATION OF DECREASING EQUIPMENT
IN SIC's 25, 33-39, 401, 458 AND 473 .... 8-89
Table 8-25 - SUMMARY OF ECONOMIC IMPACTS 8-91
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1. SUMMARY
1.1 PROPOSED STANDARDS
Standards of performance for new and modified organic solvent cleaners
(degreasers) are being proposed under the authority of section 111 of the
Clean Air Act. The emissions from these sources which would be controlled
include volatile organic compounds as well as perchloroethylene,
trichloroethylene, methylene chloride, trichlorotrifluoroethane, and
1,1,1-trichloroethane. Prior to proposal of these standards, the Administrator
determined that emissions from organic solvent cleaners contribute to the
endangerment of public health or welfare. In accordance with section 117 of
the Act, proposal of the standards was preceded by consultation with
appropriate advisory committees, independent experts, industry representatives,
and Federal departments and agencies.
The proposed standards would reduce emissions of these five halogenated
compounds and volatile organic compounds from cold cleaning degreasers, open
top vapor degreasers, and conveyorized degreasers. The owner or operator
of the affected faclity would be required to follow proper operating procedures
and equipment specifications by degreaser type and size. The discussion that
follows summarizes the proposed control equipment and operating requirements
for each affected facility.
The control equipment for cold cleaners includes a cover, drainage racks
or baskets, specified freeboard ratio, visible fill line, and a permanent
label with operating requirements. Also, if a sprayer is used, a solid spray
is required. In an electric agitation pump is used, rolling motions are
required.
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The operating requirements proposed for cold cleaners include closing
of cover when degreaser is not in use, spraying parts inside of tank, time
limit on drainage of parts, restriction of air agitation and waste solvent
disposal requirements.
The control equipment for open top vapor degreasers includes a cover,
safety switches and labels. All vapor degreasers must have a freeboard ratio
equal to or greater than 0.75. Degreasers with a vapor-air interface area
greater than one square meter are required to have either a refrigerated
freeboard device or a lip exhaust connected to a carbon adsorber. However,
for small degreasers with a vapor-air interface area of less than one square
meter, these two devices are optional.
The operating requirements for open top vapor degreasers include air of
the requirements for cold cleaners as well as specified work load moving
rates, racking of parts, restricted work loads, vapor level restrictions, a
properly operating water separator, and repairing of leaks.
The control equipment proposed for conveyorized degreasers includes
refrigerated freeboard devices, carbon adsorption systems, drying tunnel and
safety switches. The operating requirements for conveyorized degreasers
include most of the requirements for open top vapor degreasers.
1.2 ENVIRONMENTAL IMPACT
The beneficial and adverse environmental impacts associated with the
various control system alternatives that were considered are presented in
this section. The impacts are discussed in detail in Chapter 7, Environmental
Impact, and Chapter 8, Economic Impact. A matrix summarizing these impacts
is included in Table 1-1. A cross reference between the EPA guidelines for
the preparation of Environmental Impact Statements and this document is
included in Appendix B.
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Table 1-1. Matrix of Environmental and Economic
Impacts of Alternative Standards
Administrative
Action
Proposed
Standards
Delayed
Standards
No
Standards
Air
Impact
+3
-3
-3
Water
Impact
-1
+1
+1
Solid
Waste
Impact
0
0
0
Energy
Impact
+1
0
0
Noise
Impact
0
0
0
Radiation
Impact
0
0
0
Economic
Impact
+3
-3
-3
Inflation
Impact
0
0
0
U>
+ Beneficial Impact
- Adverse Impact
0 No impact
1 Negligible Impact
2 Small Impact
3 Moderate Impact
4 Large Impact
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The beneficial impacts on air quality are moderate for the proposed
standards. There would be small adverse water quality impact from the
wastewater from carbon adsorption control systems. A small beneficial
energy impact would be associated with the proposed standards. There are no
known noise or radiation impacts associated with the proposed standards.
1.3 ECONOMIC IMPACT
The costs associated with the proposed standards for new and modified
organic solvent cleaners have been judged not to be of such
magnitude to require an analysis of the inflationary impact. Many
facilities would realize a net cost reduction due to implementation of
the proposed standards.
Implementation of proper operating procedures and control devices
would reduce solvent loss and minimize solvent expenditures. Control of
open top and conveyorized vapor degreasers as well as manufacturing and
maintenance cold cleaners would have a positive economic impact.
The cost of control for each affected equipment type on a per kilogram basis
is given in section 8.2.
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2. INTRODUCTION
Standards of performance are proposed following a detailed investi-
gation of air pollution control methods available to the affected
industry and the impact of their costs on the industry. This document
summarizes the information obtained from such a study. Its purpose is to
explain in detail the background and basis of the proposed standards and
to facilitate analysis of the proposed standards by interested persons,
including those who may not be familiar with the many technical aspects of
the industry. To obtain additional copies of this document or the
Federal Register notice of proposed standards, write to EPA Library (MD-35),
Research Triangle Park, North Carolina 27711. Specify Organic Solvent
Cleaners-Background Information: Proposed Standards, document number
EPA-450/2-78-045 when ordering.
2.1 AUTHORITY FOR THE 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 and welfare."
The Act requires that standards of performance for stationary
sources reflect, "... the degree of emission limitation achievable
through the application of the best technological system of continuous
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emission reduction . . . the Administrator determines has been adequately
demonstrated." In addition, for stationary sources whose emissions
result from fossil fuel combustion, the standard must also include a per-
centage reduction in emissions. The Act also provides that the cost of
achieving the necessary emission reduction, the nonair quality health and
environmental impacts and the energy requirements all be taken into account
in establishing standards of performance. The standards apply only to
stationary sources, the construction or modification of which commences
after regulations are proposed by publication in the Federal Register.
The 1977 amendments to the Act altered or added numerous provisions ,
which apply to the process of establishing standards of performance.
1. EPA is required to list the categories of major stationary
sources which have not already been listed and regulated under standards of
performance. Regulations must be promulgated for these new categories on
the following schedule:
25 percent of the listed categories by August 7, 1980
75 percent of the listed categories by August 7, 1981
100 percent of the listed categories by August 7, 1982.
A governor of a State may apply to the Administrator to add a' category
which is not on the list or to revise a standard of performance.
2. EPA is required to review the standards of performance every
four years, and if appropriate, revise them.
3. EPA is authorized to promulgate a design, equipment, work practice,
or operational standard when an emission standard is not feasible.
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4. 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-polluting or non-polluting process or operation.
5. The time between the proposal and promulgation of a standard
under section 111 of the Act is extended to ten months.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking
into consideration the cost of achieving such emission reduction, any
nonair quality health and environmental impact and energy requirements.
Congress had several reasons for including these requirements. First,
standards with a degree of uniformity are needed to avoid situations where
some States may attract industries by relaxing standards relative to
other States. Second, stringent standards enhance the potential for
long-term growth. Third, stringent standards may help achieve long-term
cost savings by avoiding the need for more expensive retrofitting when
pollution ceilings may be reduced in the future. Fourth, certain types
of standards for coal burning sources can adversely affect the coal market
by driving up the price of low-sulfur coal or effectively excluding certain
coals from the reserve base because their untreated pollution potentials
are high. Congress does not intend for new source performance standards to
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contribute to these problems. Fifth, the standard-setting process should
create incentives for improved 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 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 limitations 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 which 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 produc-
tion processes and available methods, systems, and techniques, including
fuel cleaning or treatment or innovative fuel combustion techniques for
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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 section 111 or 112 of this Act."
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 or equipment
standard in those cases where it is not feasible to prescribe or enforce
a standard of performance. For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, 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 per-
formance for storage vessels has been equipment specification.
In addition, section lll(j) authorizes the Administrator to grant
waivers of compliance to permit a source to use innovative continuous
emission control technology. In order to grant the waiver, the Administrator
must find: (1) a substantial likelihood that the technology will produce
greater emission reductions than the standards require, or an equivalent
reduction at lower economic energy or environmental cost; (2) the proposed
system has not been adequately demonstrated; (3) the technology will not
cause or contribute to an unreasonable risk to the public health, welfare
or safety; (4) the governor of the State where the source is located
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consents; and that, (5) the waiver will not prevent the attainment or
maintenance of any ambient standard. A waiver may have conditions attached
to assure the source will not prevent attainment of any NAAQS. Any such
condition will have the force of 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 three years to meet the standards, with a
mandatory progress schedule.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Administrator to list categories of
stationary sources which have not been listed before. The Administrator,
"... shall include a category of sources in such list if in his judgement
it causes, or contributes significantly to, air pollution which may
reasonably be anticipated to endanger public health or welfare."
Proposal and promulgation of standards of performance are to follow while
adhering to the schedule referred to earlier.
Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of a system 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 actually pollutants which
are emitted by stationary sources. Source categories which emit these
pollutants were then evaluated and ranked by a process involving 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
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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 are under development during 1977 or earlier, were
selected on 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 anti-
cipated 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.
In some cases, it may not be feasible to immediately develop a
standard for a source category with a high priority. This might happen
when a program of research is needed to develop control techniques or because
techniques for sampling and measuring emissions may 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 numerous
pollutants must be investigated from a single source category. Further,
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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, determining the types of
facilities within the source category to which the standard will apply
must be decided. A source category may have several facilities that
cause air pollution and emissions from some of these facilities may be
insignificant or very expensive to control. 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 may be 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 a standard 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 demon-
strated control practice; (2) adequately consider the cost, and the nonair
quality health and environmental impacts and energy requirements of such
control; (3) be applicable to existing sources that are modified or
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reconstructed as well as 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 which has
been adequately demonstrated. The legislative history of section 111 and
various court decisions make clear that the Administrator's judgement of
what is adequately demonstrated is not limited to systems that are in
actual routine use. The search may include a technical assessment of
control systems which have been adequately demonstrated but for which there
is limited operational experience. In most cases, determination of the
"... degree of emission reduction achievable . . ."is based on results
of tests of emissions from well controlled existing sources. At times, this
has required the investigation and measurement of emissions from control
systems found in other industrialized countries that have developed more
effective systems of control than those available in the United States.
Since the best demonstrated systems of emission reduction may not be in
widespread use, the data base upon which standards are developed may be
somewhat limited. Test data on existing well-controlled sources are
obvious starting points in developing emission limits for new sources.
However, since the control of existing sources generally represent retrofit
technology or was originally designed to meet an existing State or local
regulation, new sources may be able to meet more stringent emission
standards. Accordingly, other information must be considered before a
judgement can be made as to the level at which the emission standard
should be set.
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A process for the development of a standard has evolved which takes
into account the following considerations.
1. Emissions from existing well-controlled sources as measured.
2. Data on emissions from such sources are assessed with considera-
tion of such factors as: (a) how representative the tested source is in
regard to feedstock, operation, size, age, etc.; (b) age and maintenance
of control equipment tested; (c) design uncertainties of control equip-
ment being considered; and (d) the degree of uncertainty that new sources
will be able to achieve similar levels of control.
3. Information from pilot and prototype installations, guarantees ,
by vendors of control equipment, unconstructed but contracted projects,
foreign technology, and published literature are also considered during
the standard development process. This is especially important for sources
where "emerging" technology appears to be a significant alternative.
4. Where possible, standards are developed which permit the use of
more than one control technique or licensed process.
5. Where possible, standards are developed to encourage or permit
the use of process modifications or new processes as a method of control
rather than "add-on" systems of air pollution control.
6. In appropriate cases, standards are developed to permit the use
of systems capable of controlling more than one pollutant. As an example,
a scrubber can remove both gaseous and particulate emissions, but an
electrostatic precipitator is specific to particulate matter.
m
7. Where appropriate, standards for visible emissions are developed
in conjunction with concentration/mass emission standards. The opacity
2-10
-------
standard is established at a level that will require proper operation
and maintenance of the emission control system installed to meet the
concentration/mass standard on a day-to-day basis. In some cases,
however, it is not possible to develop concentration/mass standards, such
as with fugitive sources of emissions. In these cases, only opacity
standards may be developed to limit emissions.
2.4 CONSIDERATION OF COSTS
Section 317 of the Act requires, among other things, 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 and standard including
the extent to which the cost of compliance varies depending on the
effective date of the standard or regulation and the development of less
expensive or more efficient methods of compliance;
(2) the potential inflationary recessionary effects of the standard
or regulation;
(3) the effects on competition of the standard or regulation with
respect to small business;
(4) the*effects of the standard or regulation on consumer cost; and,
(5) the effects of the standard or regulation on energy use.
Section 317 requires that the economic impact assessment be as
extensive as practicable, taking into account the time and resources
available to EPA.
2-11
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The economic impact of a proposed standard upon an indust-ry 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
since 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 impact upon the industry
resulting from the cost differential that exists between a standard of
performance and the typical State standard.
The costs for control of air pollutants are not the only costs
considered. Total environmental costs for control of water pollutants
as well as air pollutants are analyzed wherever 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. It is also essential
to know the capital requirements placed on plants in the absence of
Federal standards of performance so that the additional capital requirements
necessitated by these standards can be placed in the proper perspective.
Finally, it is necessary to recognize any constraints on capital availability
within an industry, as this factor also influences the ability of new
plants to generate the capital required for installation of 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
2-12
-------
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 performances for
various industries, the Federal Courts of Appeals have held that environ-
mental impact statements need not be prepared by the Agency for proposed
actions under section 111 of the Clean Air Act. Essentially, the Federal
Courts of Appeals have determined that "... the best system of emission
reduction, . . . require(s) the Administrator to take into account
counter-productive environmental effects of a proposed standard, as well
as economic costs to the industry. . ." On this basis, therefore, the
Courts "... established a narrow exemption from NEPA for EPA determina-
tion 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."
The Agency has concluded, however, that the preparation of environ-
mental impact statements could have beneficial effects on certain regulatory
actions. Consequently, while not legally required to do so by section
102(2)(C) of'NEPA, environmental impact statements are prepared for various
2-13
-------
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 identified and
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 becomes a new
source if the source is significantly modified or' reconstructed. Both modifi-
cation and reconstruction are defined in amendments to the general provisions of
Subpart A of 40 CRF Part 60. which were promulgated in the Federal Register
on December 16, 1975 (40 FR 58416). Any physical or operational change
to an existing facility which results in an increase in the emission
rate of any pollutant for which a standard applies is considered a modifi-
cation. Reconstruction, on the other hand, means the replacement of
components of an existing facility to the extent that the fixed capital
cost exceeds 50 percent of the cost of constructing a comparable entirely
new source and that it be technically and economically feasible to meet
the applicable standards. In such cases, reconstruction is equivalent to
a new construction.
2-14
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Promulgation of a standard 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 provisions outlining
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 assure 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.
2-15
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3. THE ORGANIC SOLVENT CLEANING INDUSTRY
Extensive information concerning this industry is found in the EPA
publication Control Techniques Guideline Document (CTG), Control of
Volatile Organic Emissions from Solvent Metal Cleaning, (EPA-450/2-77-022).
The CTG is an integral part of the support package for this New Source
Performance Standard. Information presented in this chapter supplements the
CTG and contains additional data gathered since it was issued. The base
year for data in the CTG and for this supplement is 1974.
3.1 GENERAL
Solvent cleaners can be divided into three major categories: cold
cleaners, open top vapor degreasers, and conveyorized degreasers. Con-
veyorized degreasers use either vapor degreasing or cold cleaning.
Although 1974 was used as a base year for these proposed standards, there
have been changes within the organic solvent cleaning industry since then.
Such changes include: the growing use of plastic autoparts or chrome-
plated metal parts rather than painted metal parts; the hesitation to
use or to expand organic solvent cleaning operations as a result of un-
certainties with regard to regulations and the suspected carcinogenicity
of some solvents; and the increased incidence of solvent substitution,
particularly the practice of substituting 1,1,1-trichloroethane for
234
trichloroethylene. ' ' From projections of industry growth (see Chapter
8.1), it is estimated that in 1985 there will be 1,780,919 cold cleaners,
45,605 open top vapor degreasers, and 6,506 conveyorized degreasers (Table 8-6)
3-1
-------
The consumption of solvents for degreasing in 1974 on a national
basis is reported in Table 3-1. The estimated solvent consumption for
degreasing in 1974 was 726 thousand metric tons (800 thousand short
tons). This amount includes both halogenated and petroleum solvents
(aliphatic and aromatic). Solvent use was 58, 28, and 14 percent for cold
cleaning, vapor degreasing, and conveyorized (cold and vapor) degreasing,
respectively.
Another estimate of total national degreasing solvent consumption for
1974 was 1.1 million metric tons (1.2 million short tons). There was
agreement with the CT6 estimate for halogenated solvent consumption.
Petroleum solvent consumption was estimated at 720,000 metric tons
(790,000 short tons) compared with the less than 300,000 metric tons
(330,000 short tons) estimated in the CTG. Petroleum solvent consumption
includes solvents used in the maintenance cold cleaners found in small
shops, and for wiping and spraying oversized items (where solvent is brought
to the item to be cleaned). In the larger estimate of total solvent con-
sumption, approximately 73 percent was for cold cleaning, 18 percent for
open top vapor degreasing, and 9 percent for conveyorized degreasing. * ' *
The data presented in the CTG are used for estimates made in this
Background Information Document. In both estimates of solvent consumption
for degreasing operations, more than half the total quantity of solvent
was used in cold cleaners.
3-2
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Table 3-1
National Degreasing Solvent Consumption (1974)
3
Solvent Consumption (10 metric tons)
Solvent Type Cold cleaning Vapor degreasing All degreasing
Halogenated:
Trichloroethylene 25 128 153
1,1,1-trichloroethane 82 80 162
Perchloroethylene 13 41 54
Methylene Chloride 23 7 30
Trichlorotrifluoroethane 10 20 30
153" 276 429
Aliphatics 222 222
Aromatics:
Benzene 7
Toluene 14
Xylene 12
Cyclohexane 1
Heavy Aromatics 12
46 0 46
Oxygenated:
Ketones:
Acetone 10
Methyl Ethyl Ketone 8
Alcohols:
Butyl
Ethers
Total Solvents:
Range of Accuracy:
5
6
29
450*
(+125)
0
**
276
(±25)
29
726
(+145)
Includes 25,000 metric tons from non-boiling conveyorized degreasers
jtt-jL"
Includes 75,000 metric tons from conveyorized vapor degreasers.
3-3
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3.2 LEVEL OF EMISSIONS FOR COLD CLEANERS
The CTG estimate of 1974 emissions of organic solvents from non-
conveyorized cold cleaners is 380,000 metric tons (419,000 short
tons). Cold cleaning accounts for almost all of the aliphatic, aro-
matic, and oxygenated degreasing solvents emitted nationally and for
about one-third of the halogenated degreasing solvents emitted.1 The CTG
estimated that the average cold cleaning unit generally emits about 0.3
metric ton (0.33 short ton) per year of organics. About one-half to three-
fourths of those emissions result from evaporation of the waste
solvent at a disposal site.I
On the basis of estimates of both solvent consumption and number
of cold cleaners, it was estimated in the CTG that in 1974 there was
a total of 1.22 x 106 cold cleaners in use, of which 880,000 were
maintenance cold cleaners and 340,000 were manufacturing cold
cleaners.l The average manufacturing cold cleaner emits twice the
amount of solvent as the average maintenance cold cleaner. The sol-
vent emissions from maintenance and manufacturing cold cleaners were
estimated in the CTG to be 0.25 and 0.50 metric ton (0.28 and 0.55 short ton)
per unit per year respectively (Appendix B.2.2 in reference 1). This
is equivalent to annual emissions of 220,000 and 170,000 metric tons
(242,000 and 187,000 short tons) from maintenance and manufacturing
cold cleaners, respectively. By this estimate, the national 1974
solvent emissions from cold cleaners amounted to 390,000 metric tons
(429,000 short tons). On the other hand, emission tests performed on
3-4
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agitated cold cleaners indicated that about 0.06 kilogram (0.125
pound) of solvent is lost per hour.lO'H A maintenance cleaner,
operating an average of 2 hours per day for 260 days per year, would
emit 0.30 metric ton (0.33 short ton) of solvent per year. Assuming
that a manufacturing cold cleaner operates one full 8-hour shift per
day, its annual emission would be 0.811 metric ton (0.89 short ton)
of solvent. On the basis of these assumptions as well as the estimated
number of each type of cold cleaner in 1974, bath evaporation
would have resulted in the emission, in 1974, of about 26,000 and
40,000 metric tons (29,000 and 44,000 short tons) of solvents from
maintenance and manufacturing cold cleaners, respectively. Addition-
al emissions would have resulted from solvent carry-out and improper
disposal of waste solvent. Bath evaporation accounts for 20 percent
of solvent emissions from cold cleaners;1 therefore, by this esti-
mation, 330,000 metric tons (364,000 short tons) of solvent were
emitted from cold cleaners in the United States in 1974.
3.3 LEVEL OF EMISSIONS FOR OPEN TOP VAPOR DEGREASERS
Five solvents are generally used in open top vapor degreasers
(OTVD). These are: trichloroethylene, 1,1,1-trichloroethane, per-
chloroethylene, methylene chloride, and trichlorotrifluoroethane.
National open top vapor degreaser emissions for these solvents was
estimated to be 200,000 metric tons (220,000 short tons) in 1974.
For OTVD, the major types of emissions include diffusion and convection,
3-5
-------
solvent carryout, and waste solvent disposal. Unlike cold cleaners, most
emissions occur due to diffusion and convection. This is because warm
solvent vapors mix with air at the top of the vapor zone. This mixing
increases with drafts and with disturbances from parts being moved into
and out of the vapor zone. The solvent vapors thus diffuse into the room
air and into the atmosphere.
Carryout losses are the liquid and vaporous solvent entrained on
clean parts as they are taken out of the degreaser. There are five
factors which directly effect the rate of carryout emission. They are:
Porosity or absorbency of work loads,
Size of work loads in relation to the degreaser's vapor area,
Extent to which parts are allowed to drain after cleaning,
Hoist or conveyor speeds, and
Cleaning time in the vapor zone.
These factors are discussed further in Chapter 4.1.2 and the CTG.
Although the waste solvent evaporation from vapor degreaser sludge is
usually less than the diffusion and carryout losses, it still contributes
12
about 5 to 20 percent of the degreaser's total solvent emissions. The
volume of waste solvent in sludge from vapor degreasers is much less than
that from cold cleaners for equivalent work loads. The reasons are two-
fold. First, the solvent in the vapor degreaser sump can be allowed to
become much more contaminated than the solvent used in a cold cleaner
because the contaminants, with high boiling points, stay in the sump
rather than vaporize into the cleaning zone. Second, since vapor degreasing
solvents are halogenated, they are generally more expensive and are
distilled and recycled to a greater extent than are cold cleaning solvents.
3-6
-------
It is estimated that there will be 45,605 OTVD in operation in the
United States in 1985 (see Table 8-6). Of these, approximately 19 percent
will be regulated by this NSPS. Using vaporization, carryout, and waste
solvent disposal emission factors for average OTVD, there would be an
emission savings of 41,315 metric tons per year by 1985. This is based
on data in section 8.2 which estimates uncontrolled emissions to be 11.3
metric tons per degreaser per year and controlled emissions to be 6.5
metric tons per degreaser per year.
3.4 LEVELS OF EMISSIONS FOR CONVEYORIZED DEGREASERS
According to the CTG approximately 85 percent of conveyorized degreasers
(CD) are vapor degreasers, leaving 15 percent as conveyorized non-boiling
degreasers. It is estimated that conveyorized vapor degreasers (CVD)
emit 25 metric tons of solvent per year per degreaser, whereas conveyorized
cold cleaners (CCC) emit about 50 metric tons per year per degreaser.
National emissions from all conveyorized degreasers was estimated to be
75,000 metric tons for CVD and 25,000 metric tons for CCC in 1974 .
For an equivalent work load, solvent emissions are much less for
conveyorized degreasers than for open top vapor degreasers. This is because
of the small entrances and exits used with conveyorized degreasers.
As with an OTVD, solvent emissions for conveyorized degreasers
are due to diffusion and convection, solvent carryout, and waste solvent
disposal. Of these, 4carryout of vapor or liquid solvent contribute to
the highest percentage of emissions. The factors that affect carryout
are the drainage of cleaned parts and drying time. A drying tunnel,
3-7
-------
rotating basket, or equivalent method is essential for a CD since there is
little an operator can do to reduce carryout from a poorly designed
system.
Diffusion and convection can be reduced by minimizing the entrance
13
and exit areas and by regulating the spray system. Although these
solvent bath emissions are not as great as carryout emissions, they are
greater than waste solvent emissions. Methods of emission control for CD
can be found in Chapter 4.2 and the CTG.
Evaporation due to waste solvent disposal is the smallest percentage
emission from conveyorized degreasers. Waste solvent emissions from CD
are generally less than 20 percent of the total CD emissions. This is
because most conveyorized degreasers distill their own solvent. An
external still is attached to the CD so that the solvent can be constantly
pumped out, distilled, and returned to the sump. Wastes disposed
from conveyorized degreasers usually include sump and still bottoms only.
' 3-8
-------
3.5 REFERENCES
1. U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Solvent Metal Cleaning, OAQPS Guidelines,
No. 1.2-079, EPA-450/2-77-022. U.S. E.P.A., Office of Air
Quality Planning and Standards, Research Triangle Park, North
Carolina, November 1977.
2. U.S. International Trade Commission. Synthetic Organic
Chemicals, United States Production and Sales, 1976, USITC
Publication 833, U.S. Government Printing Office, Washington,
D.C. 1977, 357 pp.
3. U.S. International Trade Commission. Preliminary Report on U.S.
Production of Selected Synthetic Organic Chemicals (Including
Synthetic Plastics and Resins Materials) Preliminary Totals,
1977. Series C/P-78-1, USITC, Washington, D.C. 20436, March 16,
1978.
4. Information provided by Gray-Mills Co., Chicago, Illinois, in a
telephone conversation between Ed Roels and Gerald R. Goldgraben
of The MITRE Corporation, Metrek Division, on March 17, 1978.
5. Information provided by E.I. DuPont de Nemours & Co., Wilmington,
Delaware, in a telephone conversation between Charles L. Gray,
Jr. and Gerald R. Goldgraben of The MITRE Corporation, Metrek
Division, on March 6, 1978.
6. E.I. DuPont De Nemours & Company, Petrochemicals Department,
FREON Products Division. Non-aerosol Propellant Uses of Fully
Halogenated Hydrocarbons. Written statements and supplemental
information provided to EPA in response to requests for informa-
tion (42FR47863 and 43FR1986), Wilmington, Delaware, March 15,
1978.
7. Surprenant, K.S. and D.W. Richards. Study to Support New Source
Performance Standards for Solvent Metal Cleaning Operations.
Prepared by the Dow Chemical Company for the U.S.E.P.A., OAQPS,
Contract No. 68-02-1329, Task Order 9, 2 Vols. April 1976.
8. Lapp, Thomas W., Betty L. Herndon, Charles E. Mumma, and Arthur
D. Tippit. An Assessment of the Need for Limitations on Tri-
chloroethylene, Methyl Chloroform, and Perchloroethylene. Draft
Final Report (3 volumes) prepared by Midwest Research Institute
for EPA, Office of Toxic Substances, EPA Contract 68-01-4121,
September 15, 1977.
3-9
-------
9. Data provided by Detrex Chemical Industries, Inc., Detroit,
Michigan in correspondence from T.J. Kearny to J.C. Bollinger,
of the EPA, dated February 16, 1976.
10. Information provided by the Kleer-Flo Company, Eden Prairie,
Minnesota, in a presentation to the National Air Pollution Con-
trol Techniques Advisory Committee in San Francisco, California
on November 3, 1976.
11. Data provided by the Twin City Testing and Engineering
Laboratory, Inc., St. Paul, Minnesota in a laboratory test
report to the Kleer-Flo Company, Eden Prairie, Minnesota on
August 30, 1976.
12. "Trip Report - Meeting of ASTM Committee D-26 on Halogenated
Organic Solvents, Gatlinburg, Tenn.," EPA Memorandum from
J. L. Shumaker to D. R. Patrick, June 30, 1977.
13. A.S.T.M. , D-26., "Handbook of Vapor Degreasing," A.S.T.M. Special
Technical Publication 310A, Philadelphia, PA, April 1976.
3-10
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4. EMISSION CONTROL TECHNIQUES
This chapter describes the devices which may be used to control
emissions from the three types of organic solvent cleaners. A complete
discussion of emission control techniques is found in the CTG. Infor-
mation presented in this chapter supplements the CTG and provides
additional data gathered subsequent to its issuance. Control efficiencies
are discussed in terms of percent emission reduction. In addition,
operating procedures which affect solvent emissions are discussed.
These procedures may be effective by themselves or in combination
with control devices. Factors which affect the efficiency of these
control measures are identified and discussed.
4.1 GENERAL
Levels of solvent emissions from cold cleaners, vapor degreasers,
and conveyorized (cold or vapor) cleaners are discussed in Chapter 3.
The four general sources of emissions which are common to all
organic solvent cleaning equipment are: solvent bath evaporation,
solvent carryout (drag out), ventilation exhaust, and waste solvent
disposal.
A. summary of emission control devices and procedures which may be
used on each type of degreaser to control emissions from each source
is presented in Table 4-1. The efficiencies of the control
4-1
-------
Table 4-1. CONTROL TECHNOLOGY EVALUATION SUMMARY
,Type of Degreaser
A. Cold Cleaner
1. Immersion or Dip
2. Conveyorized
3. General
B. Open Top Vapor
Degreaser
Type of Emission
Bath evaporation
Solvent carry-out
Ventilation
Waste solvent disposal
Solvent carry-out
Ventilation
Waste solvent disposal
Bath evaporation
Control Techniques
Options
Cover
None, procedure
only
e Drain racks or
baskets
Adsorber (carbon)
followed by recovery
Incinerator
Distillation
e Solvent recovery
service
Landfill
Incineration
None, procedure only
Drainage area
within tank
Adsorber (carbon)
followed by re-
covery
e Incineration
None, procedures
only
Distillation
Solvent recovery
service
Landfill
Incineration
e None, procedure
only
Cover
Enclosed design
(door opens only
when part enters
or leaves )
High freeboard
None, procedure only
Procedures
Closing cover except during
loading and unloading
Air agitation not
recommended
Drainage time: 15 sec.
minimum or until dripping
ceases
{ Routine maintenance
Proper timing of regeneration cycles
Maintaining proper air
velocity in system
Use of appropriate still
Maintaining proper air
velocity in system
Proper solvent handling
Drainage time: 15 sec.
minimum or until dripping
ceases
{ Routine maintenance
Proper timing of regeneration
cycles
Maintaining proper air
velocity in system
Maintaining ventilation
rate at minimum level
to prevent unnecessary
evaporation
Locating ventilation ductwork
* above the cover
Use of appropriate still
Maintaining proper air
velocity In system
Proper solvent handling
Keeping cover closed except
when degreaser Is in use
Use of freeboard ratio of
0.75 with all solvents
Minimizing drafts
Efficiency of Control
for the Particular
Type of Emission
92X2
50X3
60-90X*
NA
>85* (vol.)
NA I
NA j
NA
60-90Z
NA
NA
>85X (vol.)
NA
NA
NA
30-50**
NA
_
20-30Z8
Reference
2
3
4
4
5
*
1,4
4
4
5
1,4
4,5,6
4>
to
-------
Table 4-1 (Continued). CONTROL TECHNOLOGY EVALUATION SUMMARY
Type of Degreaser
B. Open Top Vapor
Degreaser
(Continued)
Type of Emission
Bath evaporation
(Continued)
Carry-out
Bath evaporation and
carry-out
Waste solvent disposal
'
Control Techniques
Options
Condenser flow
switch and thermo-
stat
Vapor level control
thermostat
Sump thermostat
Solvent level
control
Spray safety
switch
Water separator
None, procedures
only
Drain racks
None, procedures
only
Carbon adsorber
Condensing coils 1
Refrigerated free- L
board devices 1
Still
Acceptable dis-
posal technique;
(special incin-
erators, landfills)
None, procedures
only
Procedure
Turning off heat and closing
cover when condenser coolant
is not circulating or is
too warm
Avoiding excessive (shock)
work loads that cause a
vapor level drop in excess
of 4 inches
Periodic draining of used
solvent, cleaning of
degreaser, and solvent
renewal
Maintaining sufficient
solvent level in sump
Spraying only below the
vapor level
Routine maintenance
program
Repairing leaks; inspection
and maintenance of system
Minimizing drafts
Racking parts and tipping
out pools of solvent before
removal
Moving parts through
degreaser at less than
3.5 m/min
Degreasing work load
in vapor zone at least
30 sec. or until condensa-
tion ceases
Drying for about 15
sec.
Keeping porous and
absorbent materials
from entering vapor
zone
Monitoring temperature and
flow of water following
design specifications
Direct on-line dis-
tillation or contract
reclamation service
Minimizing transfer
and storage losses
Maintenance program
Repairing leaks
Efficiency of Control
for the Particular
Type of Emission
NA
NA
50-65%
30-403:''
(cold traps)
Can recycle BO-
SS* of the
solvent
NA
i
Reference
1,5,6,7
1,7
1,7
1,7
1,6
6
1,6,7
1,5,6,7
1,4,6
1
1,4
1,4
1,4
1,6
5,6
-------
Table 4-1 (Continued). CONTROL TECHNOLOGY EVALUATION SUMMARY
Type of Degreaser
C. Conveyorlzed
Degreaser
Type of Emission
Bath evaporation
Carry-out
Ventilation
Waste solvent disposal
Control Techniques
Options
Condensing colls
and chillers
Entrance and exit
area covers
Water separator
Safety switches
(same as vapor
degreasers)
None, procedures
only
Drain rack
Drying tunnel
None, procedures
only
Carbon adsorption
Still (direct on-
line or reclamation
service
Procedures
Proper adjustment
of primary cooling
colls
Closing cover when degreaser
la not In use
Routine maintenance
Efficiency of Control
for the Particular
Type of Emission
NA
NA
NA
Reference
1
1.5
1
| 1
(" Avoiding overloading
Proper adjustment
of the heat rate
. Proper spray adjustment
Repairing leaks; system
Inspection and main-
tenance
Providing for drainage NA
Providing for proper NA
drying
Conveyer speed leas than
3.5-m/mln
I* Proper operation &
maintenance
Proper disposal of
20-60Xb
60-801°
>85X
still bottoms
1
1,5,6
4
4
1.4
NOTES: JThla assumes 75:25 Idle-to-operating time ratio and a carry-out equal to twice the
diffusion rate with a 0.5 freeboard ratio and an air velocity between 0 and 30 m/min
(0-100 ft/min).
Efficiency of a carbon adsorber used in the exhaust system of a crossrod vapor degreaser.
Efficiency of a carbon adsorber used in the exhaust of a monorail vapor degreaser.
NA - Data unavailable.
-------
techniques are also listed. Some common factors which can influence
the effectiveness of a control technique are:
Solvent volume, type, volatility, temperature
and concentration,
Degreasing method, and
Size of workload and duration of use.
4.1.1 Controls to Minimize Solvent Bath Evaporation
The principal devices for controlling solvent bath emissions are:
Improved covers,
High freeboards,
Efficient condensing coils,
Refrigerated freeboard devices
Safety switches, and
Water separators.
4.1.1.1 Improved Covers
A cover is one of the more effective control devices for an open
top degreaser. The covers that are usually provided with open top
degreasers often do not completely seal the opening or are too heavy for
routine use. A sturdy, well designed cover which makes a good seal
with the sides of the degreaser and which is easy to operate, pro-
vides the best deterrent to evaporation of the solvent from the bath.
The different types of covers for degreasers are the hinged steel
top, the plastic or canvas roll top, and the horizontal guillotine.
While many open top degreasers (cold or vapor) are equipped with a
cover, it can be an effective control only if it is used. A
4-5
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power-assisted cover may be advantageous depending on the size of the
cover and the frequency of cover use.
Many conveyorized degreasers are covered. Improved covers at the work
inlet and exit to the unit can be a factor in reducing emissions.
4.1.1.2 High Freeboards
The purpose of the freeboard is to reduce drafts at the solvent
vapor/air interface for vapor degreasers, and at the solvent liquid/air
interface for cold cleaners. The freeboard is the distance from this
interface to the top of the degreasing tank. Freeboard height is expressed
in terms of the freeboard ratio, that is, the ratio of freeboard height to
degreaser width (not length).
Locating degreasers away from drafts will improve freeboard effectiveness,
Care should be taken to prevent unnecessary drafts from heating, ventilation
and air conditioning (HVAC) systems, and the opening and closing of doors.
Baffles can be erected to further reduce drafts.
4.1.1.3 Condensing Coils
The function of a condensing coil is to limit the upper level of the
vapor zone. A condenser, consisting of a coil of pipe through which
cooling water flows, establishes a vapor level height. Hot solvent
vapors and water vapor that are in the vapor zone condense on reaching the
cool air. The condensate is collected and channeled to a separator to remove
any condensed water and is then returned to the degreaser tank.
4-6
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The factors which affect the efficiency of condensing coils are
the heat input rate, the flow rate and temperature of the water, and
the surface area of the coil. An efficient condenser will optimize
the water flow and surface area for a specific solvent.
A degreaser operator must know the conditions necessary for the
condenser to control the vapor level effectively. Degreasers should
be equipped with devices to monitor and to adjust both the tempera-
ture and flow of the coolant.
4.1.1.4 Safety Switches
Safety switches are used on vapor degreasers to prevent emissions
in case the degreaser malfunctions or the operator makes an error.
The five main types of safety switches are:
Vapor level control thermostat
Condenser water flow switch and thermostat
Sump thermostat
Solvent level control
Spray safety switch
The first four types of switches turn off the sump heat whereas the
fifth turns off the spray. A description of these switches is found
in the Control Techniques Guidelines document, section 3.1.1.5.1
There are a number of operating procedures which will control
emissions and will obviate the conditions that activate the safety
switches. These procedures are:
4-7
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Shutting off of the sump heat if the condenser coolant is not
circulating or if it is too warm.
Periodic draining of the used solvent, cleaning of the
degreaser, and replenishment of the solvent.
Maintaining solvent level in the sump.
Spraying only below the vapor level.
Repair of leaks.
The safety switches are used in emergencies. They do not replace
proper degreaser maintenance and operation.
4.1.1.5 Water Separators
The purpose of a water separator is to remove the water which
condenses with the solvent vapor so that pure solvent can be returned
to the degreaser. Water contamination of a solvent can result in
depletion of water-soluble stabilizers which can lead to breakdown of
the solvent. The absence of a water separator or its failure
increases evaporative emissions. Water returning to the surface of a
boiling solvent sump can combine with the solvent to form an azeo-
trope which has a lower vapor density and is more volatile than the
6
pure solvent.
Routine maintenance is necessary for efficient operation of a
water separator and to prevent emissions which would result from its
failure.
4.1.2 Controls to Minimize Carryout (Drag Out)
Solvent carryout emissions are controlled primarily by using a
drain rack or basket and by following good operating practices. The
factors which influence the effectiveness of drain racks or baskets
4-8
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include drainage time, the size and shape of parts, and the drying
method. The size of the work load relative to the degreaser's vapor
area also affects drain rack effectiveness in controlling emissions.
Operating practices which limit carryout emissions are:
Racking parts and tipping out pools of solvent before removal
of the parts from the degreaser,
Moving parts through the degreaser at speeds less than 3.3
m/min (10.8 ft/min),
Drying parts in the freeboard area for about 15 seconds,
Keeping the work load in the vapor zone of vapor degreasers at
least 30 seconds or until condensation ceases.
Compressed air is sometimes used to dry cold cleaned parts. This
practice increases emissions and should not be used. In addition,
compressed air contains oil which would deposit on the parts being
cleaned, thus defeating the purpose of degreasing. Instead, parts
should be dried on drain racks.
4.1.3 Controls to Minimize Ventilation Emissions
Ventilation emissions can be controlled by use of a carbon ad-
sorber and by proper operating practices. Carbon adsorbers are
effective when used with properly designed ventilation systems. Such
a system provides a flow input to the adsorber which allows the ad-
sorber to operate efficiently. Ventilation systems include lip
exhausts, spray booth exhausts, and overhead ventilators. Adsorbed
solvent can be recovered through desorption techniques and can then
be recycled to the degreaser. A carbon adsorber is estimated to be
4-9
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cost effective if at least three drums (55 gallons each) of solvent
per week can be recovered."
Poor operating practices lessen the efficiency of carbon adsorp-
tion systems. Examples of poor operating practices and conditions
include inoperative dampers, the use of carbon that does not meet
specifications, inappropriate timing of the desorption cycles, and
excessive inlet flow rates. The carbon bed must be desorbed before
the adsorption capacity of the bed is exceeded (breakthrough).
Breakthrough occurs at a point well before saturation when the mass
transfer zone reaches the end of the bed. If breakthrough occurs,
solvent-laden air will be emitted. If desorption is performed too
often, an energy penalty will be incurred.
The major factor affecting emissions from a carbon adsorber is
the exhaust rate. The exhaust rate must be optimized to minimize
degreaser emissions and to maximize adsorber collection efficiency.
Too great an exhaust rate will increase emissions from an open top
degreaser because the air/vapor interface is disturbed.
Additional information regarding ventilation emission control and
other emission control alternatives may be found in the Control
Techniques Guidelines Document.
4.2 PERFORMANCE OF EMISSION CONTROL TECHNIQUES
This section discusses the performance of the emission control
techniques delineated in Section 4.1 The supporting data for
determining the emission control capability of each control technique
4-10
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are presented. The performance data, where available, are expressed
in terms of percent emission control and are shown in Table 4-1 in
the "Efficiency" column.
4.2.1 Peformance of Solvent Bath Evaporation Controls
4.2.1.1 Improved Covers
Covers on open top degreasers reduce total emissions greatly
depending on the frequency of use of the cover.1>4 Tests on cold
cleaners have demonstrated that the efficiency of a cover in control-
ling bath evaporation losses can exceed 90 percent.^ Emission
reduction varies with solvent volatility, draft velocity, freeboard
ratio, operating temperature, and degree of agitation.^
A closed cover is effective in reducing bath evaporation emissions
from a degreaser. It is recommended that open top degreasers be covered
whenever they are not used as well as between the loading and unloading of
4 6
parts. ' In addition, degreasers which are used intermittently should be
covered during periods of disuse longer than half an hour.
4.2.1.2 High Freeboards
EPA conducted tests to determine the effectiveness of freeboards
on open top degreasers. The solvent used was 1,1,1-trichloroethane,
and the degreaser was operated under moderate draft conditions. In
the idling mode, control efficiencies were 27 and 55 percent when the
freeboard ratio was increased from 0.50 to 0.75 and from 0.50 to
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1.00, respectively. Control efficiencies of approximately 20 to 40
percent, respectively, were achieved during operation. The
effectiveness of the freeboard to control emissions is reduced during
normal operations because of carry-out emissions. Other tests using
the same solvent demonstrated that air flow rate and inlet water
temperature to the top of the condenser determine the effectiveness
of the freeboard.9.
At a condenser temperature of 16°C (60°F), control efficiency
for an open top vapor degreaser using trichlorotrifluoroethane solvent
was 36 percent when the freeboard ratio was increased from
0.46 to 0.75.10
The effectiveness of freeboard height in controlling emissions
from open top vapor degreasers varies with factors such as mode of
operation, solvent used, work load area of the degreaser, condenser water
temperature, and exhaust air flow rate. According to EPA's cold cleaner
test reports, freeboard height has a significant effect on emissions when
high volatility solvents such as halogenated organic compounds are used;
however, freeboard height appears to have little effect on cold cleaner
2 3
emissions when low volatility solvents such as mineral spirit are used. '
The American Society for Testing and Materials (A.S.T.M.) proposed standards
for solvent metal cleaning operations recommends an effective freeboard
ratio of 0.75 for open top vapor degreasers using halogenated solvents.
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4.2.1.3 Condensing Coil
Tests conducted on an open top vapor degreaser, using 1,1,1-trichloroethane,
9
indicated that low water inlet temperatures reduce vapor loss. Freeboard
ratio and lip exhaust air flow influence the effectiveness of condensing
9
coils. At a given freeboard ratio, the effectiveness of this temperature
difference in controlling emissions increases with decreasing air flow
9
rates. A decrease in the freeboard ratio lessens the effectiveness of
9
lowering the condenser inlet water temperatures.
4.2.1.4 Refrigerated Freeboard Devices
The control efficiency of refrigerated freeboard devices is between
4 11
35 and 60 percent when used with open top or conveyorized vapor degreasers. '
These efficiencies depend on the type of secondary chiller (i.e., warm
chiller (above 0°C) or cold chiller (below 0°C)), as well as operating
conditions. The available test data documenting these efficiencies are
presented in the CTG.
4.2.1.5 Safety Switches
At present, there are no adequate data to quantify the control
efficiency of the vapor level control thermostat, condenser water flow
switch and thermostat, sump thermostat, solvent level control switch, and
spray safety switch. These switches are activated only as a result of
improper degreaser operation. The inclusion of these devices in degreasers
is recommended for safety considerations as well as for minimizing solvent
4 6
emissions in the event of equipment failure or operator error. '
4-13
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4.2.1.6 Water Separator
The emission control efficiency of a water separator is not known
because very limited information is available. The need for a
properly designed water separator is discussed in section 4.1.1.5.
It is recommended that water separators be used with conveyorized
1 6 T2
degreasers and open top vapor degreasers. ' '
4.2.2 Performance of Controls to Minimize Solvent Carryout
The control efficiency of each of the techniques for minimizing
solvent carryout, discussed in section 4.1.2, have not been deter-
mined. However, despite the lack of data regarding carryout, the
techniques described are recognized by the industry as significantly
reducing the solvent losses from this emission source.1»4,5,6,13,14
The reason for this is that the techniques minimize the amount of
solvent carried out of the degreaser by the parts being cleaned and
its subsequent evaporation into the air.
4.2.3 Performance of Controls to Minimize Ventilation Emissions
Carbon adsorption systems, when used in conjunction with well
designed ventilation systems, can achieve high levels of emission
control. Theoretically, a carbon adsorber can capture more than 99
percent of the organic material input. Because a ventilation system
does not capture all of the solvent vapors and direct them to the adsorber,
the actual tested reduction in emissions resulting from the use of
carbon adsorption is 40 to 65 percent. Poor operating and maintenance
practices can further decrease the control efficiency of a carbon adsorber.
However, manufacturers of carbon adsorption systems estimate up to 85
percent solvent reduction through the use of carbon adsorption systems.
4-14
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These systems are satisfactory for the recovery of trichloroethylene, per-
chloroethylene, and fluorocarbon solvents. 1,1,1-Trichloroethane contains
water soluble stabilizers. These stabilizers would normally be removed from
the solvent in the steam condensate following carbon desorption. However,
with a special stabilizer added to the adsorbent, 1,1,1-trichloroethane can
also be recovered satisfactorily. Methylene chloride emissions are also
not usually controlled by carbon adsorption, due to a corrosion problem
associated with steam stripping. The solvent dissolves large quantities of
air which can lead to corrosion of the adsorber unit during the steam stripping
process. Control efficiency data for carbon adsorbers are presented in the
CTG.
4.2.4 Performance of Controls to Minimize Waste Solvent Emissions
Proper operating techniques, disposal methods, and reclamation equip-
ment substantially reduce waste solvent emissions. Care in transferring,
handling, and storing waste solvents sharply reduces the evaporative
emissions from spills and from open storage containers. There are no data
to express quantitatively the effectiveness of these operating techniques. Many
of the emissions resulting from indiscriminate dumping of waste solvents on
the ground or down the drain and from disposal of waste solvent can be
reclaimed through distillation.16'17
As much as 95 percent of the halogenated solvents may be recovered
from used solvents depending on the type of solvent and the distillation
equipment used. ' Waste solvent from cold cleaners can be handled by
commercial reclamation services. One such company reported that it recycles
19
about 75 percent of the solvent that it delivers for use in cold cleaners.
4-15
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4.3 REFERENCES
1. U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards. Control of Organic Emissions from
Solvent Metal Cleaning, OAQPS Guideline No. 1.2-079,
EPA-450/2-77-022. Research Triangle Park, North Carolina,
November 1977.
2. Pelletier, W. and P.R. Westlin. Evaporation Emissions Study
on Cold Cleaners. United States Environmental Protection
Agency. Research Triangle Park, N.C. May 1977.
3. Westlin, P.R. and J.W. Brown. Solvent Drainage and Evapora-
tion from Cold Cleaner Usage. United States Environmental
Protection Agency. Research Triangle Park, N.C. January
1978.
4. Surprenant, K.S. and D.W. Richards. Study to Support New
Source Performance Standards for Solvent Metal Cleaning Oper-
ations. Prepared by the Dow Chemical Company for the U.S.
EPA, Office of Air Quality Planning and Standards, under
Contract No. 68-02-1329, Task Order 9, 2 Volumes, April 1976.
5. American Society for Testing and Materials (ASTM), Committee
D-26. Recommended Practice for New Source Performance
Standards to Control Solvent Metal Cleaning Emissions.
6. American Society for Testing and Materials (ASTM), Committee
D-26. Handbook of Vapor Degreasing. STP 310A, ASTM,
Philadelphia, Pa. 1976.
7. Baron-Blakeslee .Inc., Chicago, Illinois. Operating Procedure
Manual.
8. Data provided by Baron-Blakeslee, Inc., Chicago, Illinois, in
a conversation between Joseph Pokorny and Gerald R.
Goldgraben, of The MITRE Corporation, Metrek Division, at a
meeting on March 8, 1978.
9. Confidential data provided by Allied Chemical, Buffalo
Research Laboratory, Buffalo, New York, to Gerald R.
Goldgraben and Dr. Paul Clifford, of The MITRE Corporation,
Metrek Division, on February 14, 1978.
10. Data provided by E.I. Dupont de Nemours & Company, Wilmington
Delaware, in a telephone conversation between Charles Gray,
Jr. and Chih-chia V. Fong of The MITRE Corporation, Metrek
Division, on June 12, 1978.
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11. Arthur D. Little, Inc. Preliminary Economic Impact Assessment of
Possible Regulatory Action to Control Atmospheric Emissions of
Selected Halocarbons. Prepared for the U. S. EPA, Office of Air
Quality Planning and Standards, EPA Contract No. 68-02-1349, Task 8,
September 1975.
12. American Society for Testing and Materials (ASTM), Committee D-26.
Cold Cleaning With Halogenated Solvents. STP 403, Philadelphia, PA.,
1966.
13. Detrex Chemical Industries, Inc., Detroit, Michigan. General
Instructions Manual for Detrex Solvent Degreasing Equipment.
14. Baron-Blakeslee, Inc., Chicago, Illinois. Operating Instructions.
15. Data provided by VIC Manufacturing Company, Minneapolis, Minnesota,
in a letter to EPA, July 8, 1977.
16. Data provided by Dow Chemical Company, Midland, Michigan, in
a telephone conversation between K.S. Suprenant and J. L. Shumaker
of EPA/OAQPS, on January 11, 1977.
17. Data provided by Graymills Co., Chicago, Illinois, in a telephone
conversation between F. X. Bar and J. L. Shumaker of EPA/OAQPS on
January 13, 1977.
18. Detrex Chemical Industries, Detroit, Michigan, literature sheet No.
IL 7505.5.
19. Data provided by Safety Kleen Co., Elgin, Illinois, in a letter to
EPA, August 5, 1975.
4-17
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5. MODIFICATION AND RECONSTRUCTION OF
ORGANIC SOLVENT CLEANERS
5.1 BACKGROUND
Upon promulgation, New Source Performance Standards (NSPS) apply
to all affected facilities which are constructed, modified, or recon-
structed after the date of proposal of the standards. The sources
regulated by the proposed standard are organic solvent cleaners (degreasers).
The affected facility is the degreaser equipment and its
ancillary components. Provisions applying to modification and recon-
struction were published in the Federal Register on December 16, 1975
(40 CFR 58419).
Modification is defined as "any physical change in, or change in
the method of operation of, an existing facility which increases the
amount of any air pollutant (to which a standard applies) emitted
into the atmosphere by that facility or which results in the emission
of any air pollutant (to which a standard applies) into the atmos-
phere not previously emitted."! Reconstruction occurs when
components of an existing facility are replaced to such an extent
that:
(1) The fixed capital cost of the new components exceeds 50
percent of the fixed capital cost that would be required to
construct a comparable entirely new facility, and
(2) It is technologically and economically feasible to meet the
2
applicable standards.
5-1
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There are certain circumstances under which an increase in emis-
sions is not considered to be a modification. If a capital expendi-
ture that is less than the most recent annual asset guideline repair
allowance published by the Internal Revenue Service (Publication 534)
is made to increase capacity at an existing facility which results in
an increase in emissions to the atmosphere of a regulated pollutant,
a modification is not considered to have occurred.
An increase in working hours (i.e., from one- to two-shift opera-
tion) or an extension from 8 to 10 hours per shift would also
increase solvent emissions per day. This situation is also not a
modification under the definitions set forth under 40 CFR 60.14(e)(3).
A step-by-step approach to determining whether a physical or
operational change constitutes a modification or reconstruction under
the regulations is depicted in Figure 5-1.
5.2 POTENTIAL MODIFICATIONS
Some of the possible changes do not qualify by definition as
modifications under 40 CFR 60.14. They are, however, potential causes
of increased solvent emissions and are therefore discussed in this section.
5.2.1 Routine Maintenance, Repair, and Replacement
Maintenance, repair, and component replacement which are consid-
ered routine for a source category are not considered modifications
under section 60.14(e)(l). An increase in emissions is not expected
to occur as a result of normal maintenance, repair, or replacement of
degreaser components.
5-2
-------
Ln
r ARE ROUTINE ~*
MAINTENANCE.
REPAIR OH REPLACEMENT
v MHWIIIy '
CALCULATE
D
CALCULATE TOTAL
EXPENDITURE f OR
THE CHANGE.
C
ESTIMATE
INCREASE IN
PRODUCTION HATE
ADDING
x^0^uVloX
DECONTROL SYSTEM WHICll^
^O.MUIIM
r ACIIIIV It NOT tuUCI TO THE
Figure 5-1.
Method of Determining Whether Changes to an Existing
Facility Constitutes a Modification or Reconstruction
under 40 CFR 60.14 and 60.15
-------
Routine maintenance would involve cleaning out a degreaser,
water jacket, condenser coils and heater element (in the case of
vapor degreasers), a still, valves and transfer lines, and lubrica-
ting pumps and motors. Maintaining these components would lessen
emissions, assuming proper operational procedures are followed.
Repairing leaks would also lessen emissions.
Several degreaser components can be expected to require replace-
ment as a matter of routine. These components may include the
heating coil or elements, the condenser coil, a valve, pump, or
motor. Replacement with equivalent components should not affect
emissions and would be considered exempt under section 60.14(e)(l).
Similarly, the routine replacement of solvent and activated carbon
(for an existing carbon adsorber) would not be considered a modifica-
tion if the replacement materials were identical in type and
quantity.
5.2.2 Alternative Solvents
The use of an alternative fuel or raw material would not be
considered a modification if the existing facility was designed to
accommodate the alternative. In the case of a degreaser originally
designed to use alternative solvents, the substitution of the alternative
solvent(s) would be considered exempt under section 60.14(e)(4).
5.2.3 The Addition of a System Which Controls Air Pollutants
The addition or use of any system or device whose primary function
is to reduce air pollutants, except the replacement of such a system or
device by a less efficient one, is not by itself considered a modification
under section 60.14. For example, the addition of a carbon adsorption
5-4
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system to an existing degreaser for the purpose of reclaiming valuable
solvent that would otherwise be emitted to the atmosphere would not be
considered a modification under section 60.14(e)(5).
5.2.4 Increase in Production Rate Without a Capital Expenditure
An increase in production rate of an existing facility is not in and
of itself a modification under section 60.14 if the increase can be
accomplished without incurring a capital expenditure.
Degreasers are generally rated for maximum recommended work throughput.
It is possible for a degreaser user to increase the amount of work being
degreased by using the unit more of the time. This increase in the work
rate would not be considered a modification under section 60.14(e)(2). If
the need for increased capacity requires a capital expenditure to modify
the degreaser, then that degreaser would be considered a modification under
this section.
5.2.5 Equipment Relocation
Relocation of a degreaser within the same plant does not constitute
a modification.
5.2.6 Removal or Disabling of a Control Device
The removal of a cover or the disabling of the closure mechanism
on an existing facility constitutes a modification. Further, the intentional
disabling of any emission control component of an existing degreaser system
which would cause an increase of emissions is a modification. An existing
facility which is modified becomes an affected facility under the NSFS.
5.3 RECONSTRUCTION
5.3.1 Replacements Deemed to be Reconstruction
Degreasers are expected to last up to 30 years with vapor degreasers
requiring replacement at 20 to 30 years and large conveyorized degreasers
5-5
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at 30 years. Major reconstruction is not generally undertaken except for
4
large, complex, custom-designed, conveyorized systems. The examples which
follow illustrate conditions under which an affected facility may be
considered to be reconstruction according to section 60.15.
When a refrigerated freeboard device is replaced at a cost in excess
of 50 percent of the cost of a new facility, the degreaser would, unless
exempted elsewhere, be considered a reconstructed facility under
Section 60.15 (a) and (b). The rebodying of a degreaser, although rarely done,
could cost more than 50 percent of the capital cost of a new degreaser; the
affected facility must then comply with the standard. The replacement of a
gas-fired or steam heater in a degreaser by an electric heating system may
cost in excess of 50 percent of a new degreaser, especially if extensive
electrical service installation is required; this would constitute reconstruction
under section 60.15.
5.3.2 Technical Infeasibility Precluding Compliance
The following example illustrates a reconstruction for which it
would be technologically infeasible to meet the applicable standard.
A large degreaser may be rebuilt at a substantial cost and may
be located along an assembly line with limited space. It may not be
possible to provide control equipment as specified in the NSPS
because of lack of space. Steam may also be needed for use with a
carbon adsorber at a location which does not have facilities for
providing steam, and the plant cannot be modified to provide it.
Under these conditions, reconstruction may be considered not to have
occurred because it is technologically infeasible to meet the
applicable NSPS.
5-6
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5.4 REFERENCES
1. U.S. Environmental Protection Agency. Code of Federal
Regulations (CFR), Title 40, Protection of Environment, Section
60.14, Modification. Office of the Federal Register.
Washington, D.C., July 1, 1977. p. 16-18.
2. U.S. Environmental Protection Agency. Code of Federal Regula-
tions (CFR), Title 40, Protection of Environment, Section 60.15,
Reconstruction. Office of the Federal Register. Washington,
D.C. July 1, 1977. p. 18.
3. Data provided by Baron-Blakeslee, Inc., Chicago, Illinois, in
a conversation between Richard Kullerstrand and Gerald R. Gold-
graben of The MITRE Corporation, Metrek Division, on March 8,
1978.
4. Data provided by Detrex Chemical Industries, Inc., Detroit,
Michigan, in a telephone conversation between L. Schlossberg and
Gerald R. Goldgraben of The MITRE Corporation, Metrek Division,
on May 18, 1978.
5-7
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6. SELECTED EMISSION CONTROL SYSTEMS
This section delineates emission control equipment and required
operating practices that constitute emission control systems for degreasers.
The organic solvent cleaning industry utilizes a range of equipment types,
sizes, and operating techniques. Therefore, no one emission control technology
and no single set of operating practices apply to the entire industry.
A set of equipment types and sizes representative of those currently in
use is set forth. Each of these will be described. Emission controls and
operating practices will be defined for each.
6.1 COLD CLEANERS
6.1.1 Emission Control Options for Cold Cleaners
All cold cleaners (CC) should be equipped with covers which can be
readily closed. Fusible links may be used to actuate closing in the event
of fire. All CC should be equipped with an interior or exterior drain
rack. For the latter, drained solvent should be routed back to the tank.
The exterior drain rack need not be covered. If a parts basket is used,
interior hooks which suspend the basket above the solvent level will serve
as a replacement for the interior drain rack. All CC should have a
freeboard ratio of at least 0.7 if the solvent volatility is greater than
or equal to 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38°C. For solvents
with a volatility of less than 4.3 kPa measured at 38°C, a freeboard
ratio of 0.5 will suffice.
6-1
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All CC should be equipped with a visible internal fill line above
which they should not be filled. Finally, a conspicuous label should be
permanently affixed near to all CC on which the recommended operating
practices are clearly stated.
If a CC is equipped with a cleaning wand, the pump should not
deliver the solvent at greater than ten psi measured at the pump
outlet. Solvent should be delivered in a solid stream and not as a
droplet spray. -If a CC is equipped with an electric pump for solvent
agitation, the pump should only be large enough to produce a rolling
motion of the solvent. In no case should the pump be so powerful as
to produce observable splashing of the solvent against tank walls or
parts being cleaned when the solvent level is at the fill line.
6.1.2 Operating Practices for Cold Cleaners
Solvent is lost to the environment from cold cleaning operations
by four main routes: spillage during solvent transfer, vaporization
of solvent from the open tank, carryout of solvent on cleaned parts,
and losses from improper waste solvent disposal. The operating prac-
tices defined in this section will reduce solvent loss from the first
three of these sources. Methods of reducing losses from waste solvent
disposal include solvent recovery, incineration, and proper landfilling.
6-2
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Cold cleaners should be covered when not in use and also when
parts are being cleaned by solvent agitation. If the CC is equipped
with an air agitator, the air flow should not be so large as to pro-
duce visible entrainment of droplets above the solvent surface when
the tank is filled to the normal level. Spraying should always be
performed within the tank and not in the exterior solvent drain tray.
Cold cleaners when uncovered should not be exposed to steady drafts
greater than 40 m/min (131 ft/min) above the tank lip. Drafts may be con-
trolled by enclosures or screens. After the cleaned parts are removed from the
solvent and spraying has been completed, the parts should be allowed
to drain until dripping has stopped. It has been demonstrated that the
amount of solvent drained in the initial 15 seconds ranged from 75 to 97
percent of the total solvent drained in 30 seconds. If the parts have cavities
or blind holes, the parts should be agitated or rotated during the drain
period.
Dirty solvent should be kept in covered containers. Dripping drain
taps and cracked cover gaskets should be replaced or repaired, and
tank leaks should be repaired immediately. Solvent spilled during
transfer should be wiped up promptly, and the wipe rags should be
stored in a closed container.
6.1.3 Expected Reductions in Emissions from Cold Cleaners
The magnitude of the losses from a CC depends on the solvent
and the workload. For volatile solvents and a heavy workload which
6-3
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requires that the cover be off much of the time, vaporization losses
will exceed carryout losses. For less volatile solvents and a light
workload, the reverse may be true. The expected reductions will
therefore be derived for the representative CC that is described
in Table 6-1. For this CC, the uncontrolled solvent losses from
vaporization and carryout are 430 and 74 kg/year respectively. If a
30-second solvent drain time is allowed before parts removal and if
the CC is covered for all but the two hours per day during which it is in use,
then the controlled emissions by vaporization and carryout are 64
and 36 kg/year. The control efficiency of a cover is 84 percent in
reducing vaporization losses and that of a properly operated drain
rack is 50 percent in reducing carryout. The combined efficiency of
both controls in reducing emissions from bath evaporation and solvent
carry-out is 79 percent.
Good operating practices are essential in reducing solvent losses
from CC since almost all cold cleaners are operated manually. There-
fore, if covers are not replaced on cold cleaners when they are not in
use and/or if parts are removed from the drain racks too soon, the 79
percent reduction in emission will not be obtained. If a CC equipped
with a solvent agitator is left open during agitation, increased sol-
vent vaporization losses will decrease the efficiency of a cover from
84 percent to 49 percent. Care should be exercised during solvent
transfer operations in order to reduce solvent loss through spillage.
If the solvent is changed six times yearly in the representative CC,
6-4
-------
Table 6-1. DESCRIPTION AND OPERATING CONDITIONS FOR REPRESENTATIVE
COLD CLEANER
Area
Solvent
Airflow
Freeboard ratio
Operating time
Loads/day
Evaporation*
Carryout^
(30-sec drain)
Carryout*
(5-sec drain)
Cover efficiency2
(when cover is in
place)
0.42
39°C (102°F) flash point mineral
spirits
12 m/min (39 ft/min)
0.6
2 hrs/day, 5 days/week
20
118 g/hr-m2
7 g/load
14.2 g/load
90%
Calculated from Tables 2 and 4 in Reference 1.
6-5
-------
a 10 percent uncontrolled loss during each transfer will double the
solvent emissions. Evaporative losses are proportional to draft velocity.
Location of the CC in a 64 m/min (210 ft/min) draft would increase solvent
3
emissions by 152 percent over a draft velocity of 23 m/min (92 ft/min).
6.2 OPEN TOP VAPOR DEGREASERS
Open top vapor degreasers (OTVD) are manufactured in a much
greater range of sizes than are cold cleaners. Production OTVD are
available in sizes ranging from 0.2 to 4.5 square meters (2 to 48
square feet), and much larger custom-built models are also in use.4
Different sets of control technology options are applicable to models
of substantially different sizes. In addition, the relative effi-
ciency of the control technology options will depend on the fraction
of time that the OTVD is uncovered and processing work.
6.2.1 Control Equipment Options for Open Top Vapor Degreasers
The major sources of solvent emissions from OTVD are diffusion
of solvent vapor and carryout of solvent on the parts which have been
cleaned. In this respect, OTVD are similar to cold cleaners. For the
OTVD, carryout can only be minimized by proper operating procedures, since
there is no technology to control this loss. However, there are a
number of existing control technologies which will reduce vaporization
losses.
It has been estimated that the typical OTVD is heated but not in
use about 75 percent of the operating day.^ An effective cover will
6-6
-------
reduce vaporization by 90 percent during these periods. For a small
OTVD, manually operated covers are generally used Covers on larger OTVD
can be powered or equipped with spring assists< Many OTVD are being manu-
factured with a roll-up cover as standard or optional equipment A few
large OTVD, manufactured for pipe degreasing, are equipped with sliding
guillotine covers
Increasing the freeboard ratio decreases vaporization losses from
uncovered OTVD, particularly if drafts of more than 30 m/min (98
ft/min) are present. Refrigerated freeboard devices which provide an
additional layer of cool air above the vapor-air interface are also
effective in reducing vaporization losses.
For a production OTVD which operates at a high workload, the most
effective emission control is a lip exhaust connected to a carbon
adsorber. The cover should be located below the lip exhaust. A lip
exhaust should not be used by itself since the increased disturbance
of the air-vapor interface can double the solvent vaporization
rate.5
Vaporization losses during transfer of hot or warm contaminated
solvent from the OTVD sump should be controlled by using threaded or
other leak-proof couplers. The contaminated solvent should be trans-
ferred to a vented tank which can be sealed after transfer is com-
plete. Sump and still bottoms should be kept in sealed containers. A
visible label on which required operating practices are clearly stated
should be clearly visible to all OTVD operators
6-7
-------
6.2.2 Operating Practices for Open Top Vapor Degreasers
Operating practices for an OTVD are of two types: those designed
to minimize vaporization or disturbance of the air-vapor interface and
those which will minimize solvent carryout.
The first group includes a number of different operating prac-
tices. The OTVD should always be covered when parts are not being
degreased. The OTVD should not be exposed to steady drafts greater
than 40 m/min (131 ft/min) over the lip. If the OTVD is equipped with
a lip exhaust, the exhaust should be turned off when the degreaser is -
covered. Work being degreased should not occupy greater than 50
percent of the area of the air-vapor interface. The OTVD should not
normally be overloaded so as to cause the air-vapor interface to drop
more than 10 cm (4 inches) when the work is lowered into it. However,
in certain specific solvent vapor degreasing operations, where, of
necessity, very large masses must be degreased at one time (e.g.,
large castings and fabricated assemblies), the air-vapor interface may
unavoidably drop more than 4 inches. In such situations, the manu-
facturer of the equipment and the user of the equipment should attempt
to reduce this problem as much as possible through equipment
design, rate of work introduction and withdrawal, and other oper-
ating practice modifications. If a powered hoist is used, vertical
speeds should not exceed 3.3 m/min (10.8 ft/min) when lowering and
raising the parts being degreased. Spraying operations should be done
within the vapor layer, and work should not be lifted from the vapor
6-8
-------
until condensation has stopped. When starting up a cold OTVD, the
condenser water should be turned on before the sump heater. This
process should be reversed on shutdown, and condenser water flow
should be maintained until the vapor layer collapses.
The second group of operating practices minimizes solvent carryout.
If parts are sprayed or rinsed in a warm sump prior to the final vapor
degreasing, the work should not be removed from the vapor until visible
condensation or dripping has stopped. Parts having recesses or blind-
holes should be rotated or agitated prior to being removed from the
vapor layer. Porous or absorbent materials should not be degreased.
Water should not be visible in the solvent stream from the water
separator. Visible leaks, cracked gaskets, and malfunctioning pumps,
water separators, and steam traps should be repaired immediately.
6.2.3 Reduction in Emissions from Open Top Vapor Degreasers
The set of emission control technologies that is appropriate for
each particular OTVD depends on the size and workload of that OTVD.
Covers will be more effective in reducing emissions from degreasers
which are hot but idle most of the time than from those which have a
heavy workload requiring them to be uncovered much of the time. Lip
exhausts connected to carbon adsorbers are generally the most effective
controls.
The efficiency of each of the various control technology options
in reducing vaporization losses has been estimated although precise
experimental data are lacking. The probable effectiveness of controls
in reducing vapdrization losses of trichloroethylene from any size
OTVD is tabulated in Table 6-2.
6-9
-------
TABLE 6-2. PERCENTAGE REDUCTION IN VAPORIZATION LOSSES
Control Technology
Reduction (%)
Freeboard ratio (FR) increased to
0.75 from 0.5 (50 ft/min draft)
Refrigerated freeboard device
Lip exhaust and carbon adsorber
Cover (when in place)
275
406
657
903
Since no single set of emission controls can be specified for all
OTVD, a representative set of degreasers and operating scenarios has
been selected (see Table 6-3).
TABLE 6-3. OPERATING CONDITIONS FOR REPRESENTATIVE OTVD
Size of OTVD
Fraction of time idle
Shifts in use per day
Vapor-air interface
m )
Small
0.75
1
0.8
Medium
0.50
2
1.67
Large
0.25
3
5.0
In order to estimate the effectiveness of various control tech-
nology options for OTVD, calculations were based on theXrepresentative
units described in Table 6-3 and on the following assumptions: vapor-
2 2
ization is taken as 1.82 kg/m -hr (0.373 Ib/ft -hr) when the OTVD is
hot and uncovered^ and carryout is assumed to be 1.5 kg/m^-hr (0.3
2 8
Ib/ft -hr) when the degreaser is hot and active . The uncontrolled
6-10
-------
losses are based on an uncovered OTVD with FR = 0.5. The controlled
losses assume use of a cover when work is not being processed as well
as the designated emission control equipment. The estimated reduc-
tions in emissions due to vaporization losses are presented in Table 6-4.
TABLE 6-4. REDUCTIONS IN VAPORIZATION LOSSES
Control technology
Reduction due to
control (%)
Reduction due to
cover (%)
Total emission
reduction (%)
OTVD size
Small
FR = 0.75
6.2
61.0
67.2
Medium
Refrigerated
freeboard
device
14.9
34.8
49.7
Large
Lip exhaust
and adsorber
15.2
32.2
47.4
As with cold cleaners, these reductions in vaporization losses
require the continual implementation of the recommended operating prac-
tices. As far as possible, OTVD should not be exposed to drafts since
doubling the airflow (from 15.3 m/min) more than doubles vaporization
losses.^
6.3 CONVEYORIZED DEGREASERS
There are two types of conveyorized degreasers (CD): conveyor-
ized vapor degreasers (CVD) and conveyorized cold cleaners (CCC). The
6-11
-------
latter use halogenated solvent for cleaning printed circuit boards.
Both types of CD are used almost exclusively for production work. The
CD are often enclosed and are thereby more protected from drafts than OTVD.
6.3.1 Control Equipment Options for Conveyorized Degreasers
There are two major emission control technologies for CVD:
carbon adsorption and refrigerated freeboard devices. With adsorption,
an exhaust fan draws the solvent-air mixture from the CVD and passes
it through a bed of activated carbon. At intervals, the bed is de-
sorbed, usually with steam; the solvent-water mixture is then passed
through a separator, and the recovered solvent is returned to the CVD.
The refrigerated freeboard device on a CVD functions in the same way
as one on an OTVD. An inversion layer is created which decreases the
migration of solvent vapor through the cold air layer.
Carryout losses from a CVD may be reduced by using a drying
or a downdraft tunnel, depending on the type of degreaser , coupled
to a carbon adsorber. Circuit board CCC also normally convey the flat
boards on mesh belts. Solvent carryout can be reduced with soft rollers
which physically wipe the solvent from the board.
The loss of vapor by convection or diffusion from the entry and
exit ports of a monorail CVD can be reduced by decreasing the port
area. Silhouette cutouts or hanging plastic or rubber flaps are
effective. Mesh belt circuit-board cleaners normally have small port
areas so cutouts are not very effective, particularly if cold solvent
is used. Downtime covers will minimize vaporization losses during cooling;
they will also reduce cold solvent vaporization losses from CCC and from
idle CVD.
6-12
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6.3.2 Operating Practices For Conveyorized Degreasers
Conveyorized degreaser work speeds are usually fixed. Cross-rod
CVD are often equipped with baskets which rotate, thereby decreasing solvent
carryout in blind holes and cavities, and with sprays that are fixed below
the vapor zone.
There are several operating practices that would significantly reduce
solvent emissions from CD. Belt or rod speeds should be kept at or below
3.3 m/min (10.8 ft/min) for all degreasers by proper gearing of electric
motor drives. Spraying should take place within the vapor layer. If
silhouette cutouts are used on monorail degreasers, they should be changed
for each new run of parts whenever possible in order to maintain silhouette
clearance at 10 percent or less of the entrance or exit opening. Condenser
water should be turned on before the sump heater at startup, and water flow
should be maintained after shutdown until the vapor layer has col-
lapsed. Downtime port covers should be positioned immediately after
sump heat has been shut off.
Solvent concentrations in the carbon adsorber exhaust should be
monitored continuously by automatic equipment to check for malfunc-
tions or solvent breakthrough in the adsorber bed. The carbon
adsorber should not be bypassed during desorption. Leaks should be
repaired immediately. Sump drainage and transfer of hot or warm
solvent should be carried out using threaded or other positive
couplings. Both clean and contaminated solvent should be stored in
closed containers.
6-13
-------
6.3.3 Reduction in Emissions from Conveyorized Degreasers
Investigations of the use of carbon adsorbers on conveyorized degreasers
show an effective 95 percent recovery of solvent from the air by the
adsorber bed. " Vaporization losses from CVD are generally less
than those from OTVD by a factor of three.^ In addition, the inlet
air will dry parts and reduce carryout if an adsorber is used. There
are no data to indicate the relative reductions in vaporization and
carryout emissions, but two major manufacturers of carbon adsorbers
will guarantee 50 percent reduction in total solvent usage.^ Sol-
vent recovery has been estimated at 85 percent for monorail CVD and 60
percent for crossrod CVD. ^ A 60 percent reduction was achieved for
a circuit-board cleaner.^ The estimated reductions in total sol-
vent emissions that can be effected by a properly installed carbon
adsorber are given in Table 6-5.
No reliable data are available on emission reductions from a free-
board chiller on a CVD. One test showed a 65 percent emission reduc-
tion, but these data are suspect since the CVD exhaust was turned on
when the refrigerated freeboard device was off.** It is known that
increasing exhaust velocities significantly increases vaporization
losses.5»9 Because a refrigerated freeboard device used on a CVD
is not exposed to drafts, they are usually more efficient than an OTVD of
the same area. One manufacturer estimates that a refrigerated freeboard
device installed on a crossrod CVD will reduce total emissions by 40
percent.^"
6-14
-------
TABLE 6-5. REDUCTION IN TOTAL SOLVENT EMISSION EFFECTED
BY CARBON ADSORBERS
Degreaser Type
Crossrod
Monorail conveyer
Monorail and drying tunnel
Circuit board cleaner
Reduction^)
12
50
6012
60*0
The use of downtime covers will reduce emissions by 3 to 6 per-
cent on a CVD that is operated for one shift per day. The savings are
negligible for a CVD that is operated for three shifts daily. Silhou-
ette ports which decrease open area by 50 percent can reduce vaporiza-
tion losses by approximately 10 percent if no other control technology
is used. Emission reduction is negligible if only a carbon adsorber
is used and amounts to about 5 percent if only a refrigerated free-
board device is used.
6.4 WASTE SOLVENT DISPOSAL OPERATIONS
Disposal of waste solvent from all organic, solvent cleaning operations
(new and old) would be regulated by the Resource Conservation and Recovery
Act (RCRA). Any additional LUqulrtJffiUnis iiu^OtJtid bj Llilo NSPS would not eauoc
aTl intt-fanmtn'\ Inrrrner ru I IK iiiii iFTir N nl n no limit iHnpngnl
6.4.1 Regulation by the Resource Conservation and Recovery Act
These regulations define halogenated and non-halogenated solvents and
solvent recovery still bottoms as hazardous wastes. Under RCRA, waste
solvent, sump, and still bottoms may be disposed of by distillation, incineration,
6-15
-------
landfilling, or storage in surface Impoundments or basins. Distillation
is the preferred method for the control of waste solvent because it recycles
the waste solvent thereby conserving energv_y ^ppi-fyHmat-plv one-half of
all open top vapor degreasers, and almost all of conveyorized degreasers use
distillation as a method for recovering spent solvent
6.4.2 Regulation by the Proposed Stan
These proposed standards, in addition to RCRA, would prevent the
discharge of waste solvent into surface impoundments and basins, and require
that waste solvent be deposited in closed containers prior to burial. These
additional requirements are necessary to ensure that the waste solvents do
not evaporate into the air during their disposal.
6-16
-------
6.5 REFERENCES
1. Westlin, P.R., and J.W. Brown. Solvent Drainage and Evaporation
From Cold Cleaner Usage. United States Environmental Protection
Agency. Research Triangle Park, N.C. January 1978. Table 1.
2. Pelletier, W., and P.R. Westlin. Evaporative Emissions Study on
Cold Cleaners. United States Environmental Protection Agency.
Research Triangle Park, N.C. May 1977. p.6.
3. Reference 2, Table 2 and 3.
4. Equipment catalogs from Baron-Blakeslee, Chicago, 111. and Detrex
Corp., Detroit, Mich.
5. Richards, D.W., and K.S. Suprenant. Study to Support New Source
Performance Standards For Solvent Metal Cleaning Operations -
Appendix Reports. Dow Chemical Co. Midland, Mich. Contract
No. 68-02-1329. June 30, 1976. Appendix 12.
6. Reference 5. Appendix C3. Table 7.
7. Reference 5. Appendix CIO.
8. Data provided by E.I. Dupont de Nemours and Co., Wilmington,
Delaware in correspondence from Charles L. Gray, Jr. to Jeffrey
Shumaker, of the EPA, dated June 30, 1977.
9. Confidential information provided by Allied Chemical Co., Buffalo
Research Laboratory, Buffalo, N.Y., to Gerald R. Goldgraben and
Paul C. Clifford of The MITRE Corporation, Metrek Division, on
February 14, 1978.
10. Reference 5. Appendix Cll.
11. Reference 5. Appendix E4.
12. Reference 5. Appendices E5 and E8.
13. Reference 5. Appendix E7.
14. Data provided by Detrex Corporation, Detroit, Michigan, in a
telephone conversation between Richard Clement and James Bick
of The MITRE Corporation, Metrek Division, on June 14, 1978.
15. Reference 5. Appendix C7.
6-17
-------
16. Data provided by Autosonics Corporation, Norristown, Pennsylva-
nia, in a telephone conversation between Burton Rand and James
Bick of The MITRE Corporation, Metrek Division, on July, 1978.
6-18
-------
7. ENVIRONMENTAL IMPACT
Volatile organic compound (VOC) emissions from organic solvent
cleaners represent about 2 5 percent of total nationwide VOC
it
emissions and 4.1 percent of such emissions from stationary sources .
Degreasing operations rank as the fifth largest stationary source category of
VOC emissions.
7.1 AIR POLLUTION IMPACT
Degreasing operations consumed approximately 726,000 metric tons (798,600
short tons) of solvents during 1974. Of this quantity, nearly 706,000 metric
tons (775,500 short tons) were released to the environment, primarily as air
emissions (Table 7-1).
If use of degreasing processes increase as expected, total uncontrolled
emissions from all degreasing operations would exceed 1.5 million metric tons
(1.65 million short tons) by 1985 (Table 7-2). Significant reductions in
solvent emissions are achievable through the application of emission control
equipment and good operating procedures (Table 7-3). Estimated controlled
emissions from new source operations (units that come on-line during the
period 1980-85) wili total 120,000 metric tons (134,200 short tons), as
compared to uncontrolled emissions of 332,000 metric tons (366,300 short
tons) for the same period. This would represent a 64 percent reduction in
new source solvent air emissions (Table 7-4).
Improper maintenance or operation of control equipment, such as saturated
*For-1974, estimated total VOC emissions were 28 x 10 metric tons (30.8
x 10 short tons), of which 17 x 10 metric tons (18.7 x 10 short tons)
were from stationary sources.
7-1
-------
Table 7-1. CONSUMPTION AND UNCONTROLLED EMISSIONS OF SOLVENTS IN METAL-CLEANING OPERATIONS IN 1974
(thousand metric tons)
to
Solvent
«
Halogenated *~^
Trlchloroethylene
1,1, 1-Trlchloroethane
Perchloraethylene
Methylene Chloride
Trlchlorotrifluoroethane
Aliphatic
Aromatic
Oxygenated
TOTAL
Consumption >c
CC
/v*
23
76
13
22
9
207
46
29
425
ccc
1
2
6
1
1
15
25
OTVD
t*l
90
57
29
5
20
201
CVD
ir
38
23
12
2
75
TOTAL
153
162
54
30
30
222
46
29
726
i j
Uncontrolled Emissions
CC
22
73
12
21
8
197
44
28
405
CND
2
6
1
1
15
25
OTVD
90
57
29
5
20
201
CVD
38
23
12
2
75
TOTAL
152
159
53
29
29
212
44
28
706
Types of solvent metal-cleaning operations are cold cleaning (CC), conveyorized nonboiling degreaslng (CND), open top vapor degreaslng
(OTVD) and conveyorized vapor degreaslng (CVD).
Data from Reference 1.
'"Assumes that solvent usage In conveyorized degreaslng Is proportional to that In nonconveyorlzed operations.
uncontrolled emissions from cold cleaning operations are 20,000 metric tons less than solvent consumption; proper disposal of waste
solvent accounts for the difference (Reference 1).
-------
Table 7-2 Uncontrolled Emissions from Degreasers in 1985
Degreasers
Type
CC
OTVD
CD
Total
Number of
Units
1,780,919
45,605
6,506
1,833,030
Emission factors
Metric Tons/Unit-Yr.
0.487
11.306
28 .950
Emissions
Metric Tons
867,308
515,610
188,349
1,571,267
Does not include emissions due to waste- solvent disposal
Emission factors for average degreasing units (Section 8.2).
adsorbent from carbon adsorption systems, maladjusted refrigeration units or
excessive ventilation, can lead to increased emissions from individual units.
This can be prevented through adequate maintenance programs and proper operator
training.
7.2. WATER POLLUTION IMPACT
Waste solvent disposal is the primary source of water pollutants from
degreasing operations. Other main sources include water discharge from
separators on vapor degreasers and distallation units and steam condensate
from regeneration (solvent desorption) of carbon adsorption units.
7.2.1 Waste Solvent Disposal
During 1974, degreasing operations produced approximately 282,000
metric tons (310,200 short tons) of waste solvents (Table 7-3). The disposal
methods often provided inadequate destruction and/or containment of the
solvents.
7-3
-------
TABLE 7-3. APPLICABLE CONTROL EQUIPMENT AND ITS EFFECTIVENESS
Type of Degreaser
Cold Cleaner
Open Top Vapor
Degreaser
Conveyorlced
Degreaaer
All Types
Cold
Vapor
Emissions
Type
Bath evaporation
Solvent carry-out
Waste solvent
dlapoaal
Ventilation
exhaust
Bath evaporation
Solvent carry-out
Hut* solvent
disposal
Ventilation
exhaust
Bath evaporation
Solvent carry-ou
Hast* solvent
disposal
Ventilation
exhaust
Bath evaporation
Ventilation
exhaust
Quantity,
X
20''1
..!
5S1
45"
31..5
47«'5
221
78"
IS1
85b
85b
Control Equipment
Type
Cover
Drain racks or baskets
Holding, tank
Still
Suitable disposal
Incinerator
Carbon adsorber
Cover
Enclosed design
Ugh freeboard
Condensing colls
Refrigerated freeboard
device
Condenser flow (witch
t thenostat
Vapor level control
thermostat
Sump thenoatat
Solvent level control
Spray safety switch
Hater separator
Lip exhaust with
carbon adsorber
Drain rack*
Automatic hoist with
timed pause
Still (built-in or
external)
Incinerator
Carbon adsorber
Entrance exit area
covers
Hater separator
Drain racks
Drying tunnel
Still (built-in or
external)
Carbon adsorber
Condensing colls 4
refrigerated
freeboard device
Safety switches
Carbon adsorber
Demonstrated
Efficiency,
Z
,2c.2
503
1
>85 vol. X
60-90*
90C'2
27..4
A
30-40
70*
80-85*
A
50-65*
60*
50-70
Emissions, 10 3 Metric Tons
Uncontrolled
81
101
223
182
62
95
44
157
IS
21
64
Controlled
d
51
<33
18-73
d
45
37-43
19
7-9
55-79
8
19-32
*Kelative quantities of emissions during degrsaslng operation*.
Vapors from both bath evaporation and solvent carry-out.
with cover in place.
Depends on percentage of time cover Is closed.
"By Increasing freeboard ratio from 0.5 to 0.75.
-------
Table 7-4 PROJECTED ANNUAL EMISSIONS FROM NEW DEGREASERS, 1979-1985
a,d
Year
1979
1980
1981
1982
1983
1984
1985
Ikirnnfrtfl ]rri f^f
CC
26
27
27
28
29
31
32
Be
OTVD
19
20
18
19
20
20
21
units
CD
6
7
6
6
7
7
7
TOTAL*
52
54
SI
54
56
58
60
is ions. 10 metric ton*
New unit
CC
26
53
80
109
138
169
201
: cumulative from 1979b
OTVD
19
39
57
76
95
116
137
CD
6
13
19
26
32
39
46
TOTAL
52
105
157
210
266
324
384
Controlled emissions. 10 metric tons
New units
CC
5
6
6
6
6
6
7
OTVD
11
12
10
11
11
12
12
CD
3
3
2
3
3
3
3
TOTAL6
19
20
IB
19
20
21
22
Nev unlti
CC
5
11
17
22
28
35
41
: cumulative fro* 1979
OTVD
11
23
33
44
55
67
79
CD
3
5
8
10
13
16
19
TOTAL
19
39
57
76
97
117
139
Differ ence,b>C
(10 metric tons)
33
67
99
134
169
207
245
in
"Based on projected numbers of new units (Table 8-6) and emission factors for average degreaslng units (Section 8.2):
Cold cleaner: 487 kilograms/year uncontrolled, 100 kilograms/year controlled
Open top vapor degreaser: 11,306 kilograms/year uncontrolled, 6538 kilograms/year controlled
Conveyorlzed degreaser: 28,950 kilogram/year uncontrolled, 11,580 kilograms/yenr controlled
Totals aay differ due to rounding.
Difference between controlled and uncontrolled emissions from new degreasers placed In service from 1979 on.
dOo«s not include emissions due to waste solvent disposal.
-------
Contamination of natural water systems by waste solvents can occur
through direct sewer disposal or as leachate from landfills. JThe proposed
"
_______^^~~
regulations on solid waste disposal practices from organic solvent cleaning
facilities are designed to prevent such contamination.
7.2.2 Water Separator Effluent
Small amounts of contaminated water are collected by water separators on
vapor degreasers and distillation units. The water is introduced in the
process on the parts that are degreased. Generally, effluent from water
separators amounts to less than 3.8-7.6 liters (1-2 gallons) per degreaser
per day.
The amount of solvent in the discharge depends upon the type of solvent
used. The maximum quantity of solvent per liter of water discharge would
amount to zero grams of 1,1,1-trichloroethane and trichlorotrifluoroethane,
.20 grams of perchloroethylene, 1 gram of trichloroethylene and 20 grams of
methylene chloride. These small quantities would have an insignficant effect on
wastewater quality.
De-icing of refrigerated control equipment operated below 0°C (32°F),
steam stripping of still bottoms on distillation units and other emission
control procedures will increase the volume of wastewater discharge. Accurate
data on the quantity of discharge from these procedures are not available.
7.2.3 Steam Condensate from Carbon Adsorber Regeneration
7.2.3.1 Solvents in Steam Condensate
The carbon adsorber regeneration process involves passing steam through
the carbon bed. Solvents, which were adsorbed by the carbon, are then desorbed
by the steam. The adsorbed solvents, except for trichlorotrifluoroethane,
are somewhat soluble in water and, therefore, small quantities of solvent
remain in the steam condensate portion of the wastewater discharge.
7-6
-------
Trichlorotrifluoroethane, perchloroethylene and trichloroethylene along
with associated stabilizers , are amenable to control by carbon adsorption.
Due to problems with water-soluble stabilizers, 1,1,1-trichloroethane emissions
are not usually controlled by carbon adsorption. Methylene chloride emissions
are also not usually controlled by carbon adsorption, due to a corrosion
problem associated with steam stripping. The solvent dissolves large quantities
of air which can lead to corrosion of the adsorber unit during the steam
o
stripping process.
A large carbon adsorption system for perchloroethylene may use 1890
kilograms (4200 pounds) of steam (about 1900 liters or 500 gallons of water)
9
for each adsorption cycle . The steam is condensed with the solvent, then
separated by gravity. Small amounts of solvents and stabilizers remain in
the water fraction and are eventually discharged to the wastewater stream.
The concentration of solvents and stabilizers in the steam condensate depends
on their solubility in water.
7.2.3.1 Solvents in Steam Condensate
Solvent discharge in steam condensate is based on information from
carbon adsorber manufacturers and activated carbon producers. According to
these industry estimates, around 250 degreasing units were equipped with
carbon adsorption systems in 1978. Assuming that 20 percent of new source
degreasing units will be equipped with carbon adsorption systems (Table 8-6),
it has been estimated that approximately 1962 carbon adsorption systems would
come on-line during the period 1980-85. Based on these data, the amount of
solvent discharge in steam condensate for the period 1980 to 1985 would be
186 metric tons (204 short tons).
^Stabilizers, also referred to as inhibitors or additives, are organic compounds
that are added in small quantities to chlorinated solvents to inhibit decompo-
sition. The quantity of stabilizers released to the water separator dis-
charge is negligible.
7-7
-------
7.2.3.2 Stabilizers in Steam Condensate
Stabilizers are present in steam condensate, from carbon adsorbers, at
concentrations that depend on their solubility in water. Compounds which are
1.4
used as stabilizers for the various chlorinated solvents are known ' ,
however, their exact formulations are trade secrets of the manufacturers. It
is, therefore, difficult to estimate the potential discharge of stabilizers
dissolved in the steam condensate from regeneration.
The CTG estimates that the maximum potential discharge would result from
a solvent combination that contained 5 percent stabilizer that was 40 percent
water soluble . If this condition, along with equal evaporation rates for
solvent and stabilizer and maximum adsorption of the chlorinated solvents
(see Section 7.2.3.1), are assumed, then 114,100 metric tons (125,500 short
tons) of chlorinated solvents (Table 7-1, and 7-3) and 5710 metric tons (6280
short tons) of stabilizers would be adsorbed. The probable maximum discharge
(based on Section 7.2.3.1 assumptions) would be 3.7 metric tons (4.1 short
tons).
7.3 SOLID WASTE IMPACT
The principal types of solid waste generated from organic solvent
cleaners include spent carbon from carbon adsorbtion units and waste
solvent, sump, and still bottoms. It is believed that there would be an
insignificant increase in the amount of spent carbon disposed due to this
standard of performance. There would not be a incremental increase in the
amount of waste solvent disposed, since hazardous waste disposal regulations
as required by the Resource Conservation and Recovery Act would control all
degreasing operations.
*l,l,l-trichloroethane requires 5 percent stabilizer, the other solvents
require a lower percentage.
7-8
-------
7.3.1 Disposal of Spent Carbon
Spent carbon from adsorption systems is easily reactivated and has an
estimated life of up to 30 years. Replacement of the carbon, though, is
recommended every 10 to 15 years. Assuming that the 1962 new source degreasing
operations equipped with carbon adsorption systems contain an average of 635
kilograms (1397 pounds) of carbon which is replaced every ten years, then
disposal of spent carbon from adsorbers on new source degreasing operations
would amount to 296 metric tons (326 short tons) in 1990 and 267 metric tons
(294 short tons) in 1996.
7.3.2 Disposal of Waste Solvent
The waste solvent disposal provisions in this standard of performance
would limit the methods of solvent disposal which would be allowed under the
Resource Conservation and Recovery Act (RCRA). Organic solvent cleaners
which generate less than 100 kg of waste solvent per month would
be allowed by RCRA to dispose of their waste in any state approved landfill
without using any method of containment. Disposal of solvents by application
In landfills could result in the release of volatile organic emissions to the
atmosphere by evaporation. Burial of these wastes in closed containers
would control these releases.
RCRA also allows for the disposal of hazardous wastes in surface impoundments
and basins. High volatility solvents used in degreasing could be emitted as
air pollutants If waste solvent was controlled in this manner. Therefore,
this standard of performance does not allow for the disposal of waste solvent,
«
sump, and still bottoms in surface Impoundments and basins.
Incineration can. be used as a disposal method for waste solvents.
However, only 25 to SO domestic incinerators have the gas cleaning equipment
7-9
-------
necessary for handling chlorinated solvents. This equipment is designed to
remove halogenated compounds (primarily hydrochloric acid), particulates and
other pollutants.
Based on a survey of 20,000 plants in the metal working industry, it was
estimated that 524 metric tons (576 short tons) of waste solvents were
disposed of through incineration during 1974 . This amount is only about
0.02 percent of total solvent emissions for that year (Table 7-1). Emissions
from the incinerators used for waste solvent disposal may have a regional
environmental impact, depending upon their locations.
The best option for controlling waste solvent from organic solvent
cleaning facilities is by reclamation, using either distillation or an equivalent
method. Where practical, disposal of waste solvent, sump, and still bottoms
should be avoided, and alternatives such as recovery and reuse should be
employed.
7.4 ENERGY IMPACT
The principal energy consuming emissions control devices for degreasing
units are refrigerated freeboard equipment, both portable add-on and built in
types. Incinerators are intensive energy consumers, but are used to control
only 0.02 percent of total solvent emissions. .Lip exhausts also consume large
quantities of energy.
Energy consuming emission control devices for degreasing and solvent
disposal operations would include (1) refrigerated freeboard devices,
(2) carbon adsorption systems, (3) distillation equipment, and (4) incinerators.
*This is based on the disposal of 364,800 liters (96,000 gallons) of waste
solvent with an average density of 1.4 kilogram/liter (12 pounds/gallon).
7-10
-------
Operation of this equipment in 1985 would require approximately 0.27 million
kWh per day (equivalent to about 440 barrels of oil per day). However, the
proposed standards would result in the capture of degreaser emissions
equivalent to about 6500 barrels of oil per day. Therefore, these new
source performance standards in 1985 would result in a net conservation of
energy equivalent to about 6000 barrels of oil per day.
7.4.1 Energy Consuming Equipment
Refrigerated freeboard devices create a cold air blanket over the vapors in an
open top vapor degreaser. The refrigeration units use 1/2 uo 3 horsepower
motors which consume 0.38 to 2.25 kWh (1274 to 7641 BTUs/hr), to drive the
11 12
compressors. ' Energy consumption for an open top vapor degreaser could
increase by an estimated 5 percent with the addition of a typical refrigerated
freeboard unit
Portable refrigeration units have cooling capacities of 24,000 to 360,000
BTUs per hour and provide a 10°C (50°F) water supply (based on 35°C (95°F)
ambient air temperature). These units, which consume 4.8 to 63 kWh (16,195
12
to 212,562 BTUs/hr), include circulating pumps that provide coolant to the
degreaser's condenser coils.
Carbon adsorption systems require a supply of steam for regeneration and
electricity for pumping the cooling water and powering the blower motor.
Standard commercially available carbon adsorption systems use blower motors
13
of 3 to 20 horsepower. Design specifications require 1.5 to 6 kilograms of
steam per kilogram of solvent capacity of the carbon bed for steam stripping
7-11
-------
regeneration of the carbon (Table 7-5).4»9'12'13'14 Energy requirements for
*
carbon regeneration would then range from 3300 to 13,200 BTUs per kilogram
**
of solvent.
At present, steam desorption is usually based on a time cycle rather
than on the amount of solvent in the carbon bed. Therefore, the quantity
of steam used per desorption cycle would be the same regardless of the degree
of carbon saturation.
Solvent recovery stills use energy to provide heat for vaporization and
cooling for vapor condensation. Heat requirements are met with electricity
or steam and condenser cooling can be achieved with pump water or a
refrigeration unit. Solvent distillation requires at least 0.1 kWh per
kilogram of recovered solvent. ' ' ' Various solvent properties determine
the energy required for distillation (Table 7-5).
Incinerators must achieve temperatures of 320 to 490°C (600 to 900°F)
for catalytic oxidation of solvent laden gases and temperatures of 760 to
870°C (1400 to 1600°F) for direct thermal combustion. Large quantities of
energy are needed to achieve these temperatures. Because of this, incinera-
tion is presently used for only a small fraction of total waste solvent
disposal. It has been estimated that the energy required for catalytic
oxidation of all waste solvent from domestic cold cleaners would equal
1.4 x 1018 BTUs for 19744.
*0ne kilogram of steam equals 220 BTUs.
**Lip exhaust energy requirements are included with the calculations for
carbon adsorption systems.
7-12
-------
TABLE 7-5. PROPERTIES RELATED TO ENERGY CONSERVATION4
Solvent
Trichlorotrifluoroethane
(CFC-113)
1,1, 1-Tr ichlor oethane
Perchloroethylene
Trichloroethylene
Methylene Chloride
High Flash Naphthab
(variable composition)
Stoddard Solvent
(variable composition)
Isopropyl Alcohol
Water c
(Water & Detergents)
Boiling Point,
°F
117.6
165
250
188.4
103.6
240-320
310-388
180
212
°C
47.6
74.1
121.1
86.9
39.8
116-160
154-198
82.3
100
Specific Heat of
Liquid
litu/lb°F, cal/-QC
0.218
- 0.258
0.205
0.225
0.276
0.45
0.52
0.615
1.00
Heat of
Vaporization
Btu/lb
63
104
90
103
142
132
118
285
970
cal/g
35
58
50
57
77
73
66
159
539
Heat Required £o Vaporize
Liquid from
75°F (24°C)
Btu/gal.
950
1400
1710
1570
1660
1390
1660
2290
9240
cal/g
63
93
114
105
111
91
111
170
615
I
!-
CO
Reference '18.
Composition varies as it is a mixture that meets a specified boiling range and a limit on unsaturation.
Specific heats and latent heats of vaporization are those for typical compounds at the mid-
point of the boiling range.
For cleaning purposes, organic surfactants are present in the water at concentration of 1 to 3 weight percent,
but they do not significantly alter the physical properties of water that affect distillation and reclamation.
-------
7.4.2 Waste Heat Recovery
Substantial energy savings may be attained when heat recovery systems
are used on incinerators. The use of heat recovery systems on incinerators
could reduce overall energy usage for catalytic combustion by 40 to 80 percent.
7.4.3 Fuel Switching
Steam is used to regenerate solvent from carbon adsorbers and for distallation.
It may also be used as a heat input for vapor degreasing. The steam used in
these applications would come from an existing (or newly installed) fossil
fuel-fired boiler. The type of fuel (coal, oil or natural gas) used would
depend upon the size and type of boiler and the facility in which it is used.
7.4.4 Energy Conservation
It was estimated that with the implementation of this NSPS, use of
solvents recovered from carbon adsorption systems would conserve over 6500
barrels of oil per day in the solvent production process during 1985. This
energy conservation figure is based on solvent consumption data from the
CTG and an estimated average energy requirement of 1.25 barrels of oil per
barrel of solvent produced.
7.5 OTHER ENVIRONMENTAL IMPACTS
7.5.1 Noise
Blower noise from carbon adsorbers may constitute an adverse environ-
mental impact. This effect, however, would be localized to the general area
in the plant near the adsorber.
Noise level measurements have not been made due to the fact that they
appear to be insignificant when compared with the normal noise level in
machine shops and other manufacturing areas where carbon adsorbers are located.
7-14
-------
While noise does not seem to present a serious environmental
problem, it should be considered when the in-plant location of a carbon
adsorber is selected. The addition of noise suppression equipment to carbon
adsorbers could minimize this problem.
7.5.2 Activated Carbon Requirements for Adsorption Systems
Carbon adsorption systems can use large quantities of activated carbon.
An average size adsorber requires 635 kilograms (1390 pounds) of activated
carbon and a large adsorber may use up to ten times the amount.
Installation of average size adsorption systems on 1962 new source
degreasing operations (see Section 7.2.3.1) would require a total of 1238
metric tons (1362 short tons) of activated carbon for the period 1980-85.
This quantity represents less than 1.6 percent of the total domestic activated
carbon consumption of 89,000 metric tons (97,900 short tons) for 1977.
7.6 OTHER ENVIRONMENTAL CONCERNS
7.6.1 Environmental Impact of Delayed New Source Performance Standard
or no Standard
In response to the National Ambient Air Quality Standard (NAAQS) for
photochemical oxidants, state and local governments developed implementation
plans and codes to control these pollutants. Restrictions were placed on
the quantities of photochemically reactive solvents that could be emitted
from various sources in areas were the primary air quality standards could be
attained only with the application of emission controls. This includes most
4
industrial regions . Therefore, VOC emissions from many existing degreasing
operations are currently regulated.
7-15
-------
If this standard of performance is not promulgated or its implementation
delayed, new source degreasing units would have to comply with existing state
regulations. Existing degreasing operations will not be affected by this
standard of performance, unless a unit undergoes significant modifications.
The effect of a delayed standard would be the difference between
uncontrolled and controlled solvent emissions from new source degreasing
operations during the period of the delay. The estimated annual difference
in solvent emissions would be 33,000 metric tons (36,300 short tons) for
1980, increasing up to 211,000 metric tons (232,100 short tons) by 1985
(Table 7-4). If the standard of performance was not promulgated, this differ-
ence would total 718,000 metric tons (789,800 short tons) for the period
1980-85.
7.6.2 Summary of Environmental Impact of Proposed Standards
The proposed standards would reduce the emissions of volatile organic
compounds and trichloroethylene, perchloroethylene, methylene chloride,
1,1.3-trichloroethane. and trichlorotrifluoroethane from all organic solvent
cleaners( With implementation of the new source performance standardsf
controlled emissions from these facilities would be 120,000 megagrams
(about 134^000 tons) in 1985, which constitute a reduction of 64 percent>
The only potentially adverse impact on water quality of the proposed
regulation would derive from the solvent dissolved in the steam condensate
from regeneration of carbon adsorbers. Only 74 grams (0.16 pounds) of
solvent per day is expected to be lost in the waste stream from a typical
carbon adsorber; the environmental impact of this small quantity is
insignificant.
7-16
-------
Promulgation of these proposed standards would also result in a solid
waste impact for the disposal of the spent carbon from the carbon adsorbers.
Disposal of spent carbon from affected facilities would amount to 243
megagrams (268 tons) nationwide in 1989 and would increase to 271 megagrams
(299 tons) in 1995. Thus, the solid waste impact would also be minimal.
7_17
-------
7.7 REFERENCES
1. U. S. Environmental Protection Agency, Office of Air and Waste
Management, Office of Air Quality Planning and Standards. Control of
Volatile Organic Emissions from Solvent Metal Cleaning. OAQPS Guidelines
#1.2-079, EPA-450/2-77-022. Research Triangle Park, North Carolina.
November 1977.
2. Pelletier, W., and P. R.-Westlin. Evaporation Emissions Study on
Cold Cleaners. United States Environmental Protection Agency.
Research Triangle Park, N.C. May 1977.
3. Westlin, P.R., and J.W. Brown. Solvent Drainage and Evaporation
from Cold Cleaner Usage. United States Environmental Protection Agency.
Research Triangle Park, N.C. January 1978.
4. Surprenant, K.S., and D.W. Richards. Study to Support New Source
Performance Standards for Solvent Metal Cleaning Operations.
x
Final Report. The Dow Chemical Company, Midland, Michigan.
April 30, 1976, Volumes I and II.
5. Data provided by E. I. Dupont de Nemours & Company, Inc.,
Wilmington, Delaware, in correspondence from Charles L. Gray, Jr., to
Jeffrey Shumaker of the U. S. EPA on June 30, 1977.
6. American Society for Testing and Materials (A.S.T.M.), Committee
D16. Handbook of Vapor Degreasing STP 310A. A.S.T.M., Philadelphia,
Pennsylvania, 1976.
7. Perry, R. H., and C. H. Chilton. Chemical Engineer's Handbook.
5th Edition. New York, McGraw Hill, 1973.
8. Information provided by Mr. James Goodrich of Detrex Corp., in a
telephone conversation on June 5, 1979, with George Viconovic of
GCA/Technology Division.
7-18
-------
9. Baron-Blakeslee, Inc. Carbon Adsorption Systems for Recovery of
Solvent Vapors. CAV, CAR #2141.8. Chicago, Illinois.
10. Shumaker, Jeffrey, Chemical and Petroleum Branch. Memo to James
Berlow, Inorganic Chemicals and Services Branch, U. S. Environmental
Protection Agency, August 18, 1978.
11. Detrex Chemical Industries, Inc. Data sheets. Detroit, Michigan.
12. Baron-Blakeslee, Inc. Specification sheets. Chicago, Illinois.
13. Detrex Chemical Industries, Inc., Detrex Econo-0-Solo Solvent
Vapor Emission Control and Recovery Systems, Literature EQ 80.5.
Detroit, Michigan.
14. Information provded by Baron-Blakeslee, Inc., Chicago.
Illinois, in a telephone conversation between Joseph Pokorny and Judith
G. Gordon of The MITRE Corporation, Metrek Division, on March 31, 1978.
15. Data provided by E. I. DuPont de Nemours & Company, Inc., Wilmington,
Delaware, to the Environmental Protection Agency on Nonaerosol Propellant
Uses of Fully Halogenated Hydrocarbons, in March 1978.
16. Data provided by Detrex Chemical Industries, Inc., Detroit, Michigan,
in telephone conversation between L. Schlossberg and Gerald R. Goldgraben
of The MITRE Corporation, Metrek Division, on April 20, 1978.
7-19
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8. ECONOMIC IMPACT
8.1 INDUSTRY ECONOMIC PROFILE
8.1.1 Introduction
Organic solvent cleaners are used in the production installation,
and maintenance of virtually all metal based commodities.
Typically it represents only a small part of a given firm's opera-
tions, measured in terms of its share of total costs of production
(see Table 8-4). Any changes in organic solvent cleaning costs are
therefore likely to have only a small impact on the behavior of firms
and industries. Nevertheless, individually small effects may be
significant when aggregated and it is important to identify and
quantify them in order to assess the impact of a New Source Performance
Standard (NSPS) for organic solvent cleaners.
The impact of New Source Performance Standards is not just limited
to firms utilizing organic solvent cleaners. Changes in firms'
decisions on rates of replacement of existing degreasing equipment and
rates of acquisition of additional machinery are likely to result from
NSPS regulations. Further, selections of types of solvent and volume of
solvents used in degreasing processes will change as a result of new
environmental regulations. As a consequence, producers of degreasing
equipment and producers of solvents will be affected by this NSPS.
The regulations will also impinge upon market conditions facing
a third group, the household sector. Changes in firms' costs of
8-1
-------
production may well be passed on to consumers, in part or in full, in
the form of higher or lower prices. Where organic solvent degreasing
firms make fipal goods or services, as is the case with auto repairs,
the price impact will be direct. When firms make intermediate goods
such as sheet metal the impact will be indirect, affecting final com-
modity costs of production and prices via the prices of inputs.
Two of the above groups are directly involved with organic
degreasing: (1) producers of organic degreasing equipment and solvents
and (2) firms utilizing organic solvent cleaners> Therefore,
the industry profile focuses upon these two sectors.
8.1.2 Industry Characteristics
8.1.2.1 Suppliers
Degreasing Equipment Manufacturers. Degreasing equipment used
in the U.S.A. ranges from old drums filled with kerosene to large
conveyorized degreasers costing up to $250,000. Three types
of degreasers have been identified: cold cleaners, open top vapor
degreasers and conveyorized degreasers. Conveyorized degreasers are
divided into two sub-categories: (1) boiling conveyorized degreasers
and (2) non-boiling conveyorized degreasers. Cold cleaners, using
non-boiling solvent are produced by the following companies: Safety-
Kleen, Kleer-flo, Graymills, D. C. Cooper, Build-All, Kamas, and R&D Manufac-
turing. Together they produce an estimated 118,700 cold cleaners annually.
8-2
-------
Two types of broad marketing strategy have been adopted by cold cleaner
producers. Safety Kleen Corporation rents its units to clients and performs
all maintenance work itself, providing and recycling solvent used in them.
In 1978, it had 185,000 units in operation (mainly in automotive repair
shops and automobile dealerships). Other companies simply sell their
product to individual customers, who are then responsible for maintenance
and the changing and disposal of solvent.
Most vapor degreasers, both open top and conveyorized, are produced
by Detrex Chemical Industries and Baron-Blakeslee Incorporated. These
two corporations both estimate that they have a joint market share of
1 2
80-90%. ' Other manufacturers include Phillips Manufacturing, Lenape,
AutoSonics Incorporated, Delta Incorporated, Crest Ultrasonics, and
Branson Cleaning Equipment. Industry estimates place annual sales of
open top vapor degreasers and conveyorized degreasers at 3,700 and 300,
*
respectively.
Other companies produce ancillary emissions control equipment, such
as carbon adsorbers, refrigerated freeboard chillers, and water
barriers. VIC Manufacturing estimates that it has sold approximately
1,000 carbon adsorbers "over the past few years." Detrex expects
sales of such ancillary equipment to increase in the future because
of current and prospective OSHA and EPA regulations. The company is
*See Appendix F for discussion of these estimates
8-3
-------
now developing a line of accessories including spring loaded covers,
carbon adsorbers and refrigerated chillers.*
Solvent Manufacturers. The organic solvents used in
degreasing may be divided into two broad categories: (1) halogenated
solvents, used in vapor degreasers and (2) non-halogenated solvents,
including petroleum solvents, alcohols and ketones, used in cold cleaning.
Major producers of halogenated solvents are identified, by type of solvent,
in Table 8-1. They include Dow, Dupont, Ethyl, PPG Industries, Diamond
Shamrock, Vulcan, Hooker and Stauffer. Producers of petroleum solvents,
4
ketones and acetones include Exxon Chemical, Shell Chemical & Union Carbide.
The market for organic solvents is discussed in some detail in
section 8.1.3. However, it is worth noting here that total sales of
solvents used in degreasing accounted for less than one percent of
the almost twenty-eight billion dollars worth of synthetic organic
chemicals produced in 1976 and only an estimated 3,000 jobs were
associated with the production of such solvents.* Any NSPS
related to organic solvent cleaning is therefore likely to have only a
small impact on the synthetic organic chemicals industry.
Surprenant et alj provided estimates of sales of solvents in
1976; data on value of output of synthetic organic chemicals and
employment were taken from The Annual Survey of Manufacturers,
1976.5.
8-4
-------
Table 8-1. Producers of Halogenated Solvents.
Type of Solvent
Producers
Trichloroethylene
Perchloroethylene
1,1,1-Trichloroethane
Methylene Chloride
Trichlorotrifluoroethane
PPG Industries, Dow, Diamond Shamrock, Hooker,
Ethyl
Dow, PPG Industries, Vulcan Materials,
Diamond Shamrock, DuPont, Stauffer, Ethyl,
Hooker
Dow, PPG Industries, Vulcan Materials, Ethyl
Dow, Vulcan, Diamond Shamrock, Stauffer,
Allied Chemical, DuPont
DuPont) Allied Chemical
Source: Reference 4.
8-5
-------
8.1.2.2 Users of Degreasers
a) User Industries
Organic solvent cleaners are used in a number of manufacturing
sectors and several service sectors (maintenance and repair activi-
ties) within the economy. Manufacturing industries which use
degreasers are included within the following two-digit SIC code
sectors: 25 (Metal Furniture), 33 (Primary Metals), 34 (Fabricated
Products), 35 (Non-Electric Machinery), 36 (Electric Equipment), 37
(Transportation Equipment), 38 (Instruments and Clocks) and 39
(Miscellaneous Industry). As detailed in Appendix F, the study
conducted by Eureka Laboratories in California (Leung et. al.,°) is
used to identify the specific three-digit SIC manufacturing indus-
tries in which organic solvent degreasing occurs. These sectors are
identified in Table 8-2. The service sectors which do organic solvent
cleaning are: 401 (Railroads-maintenance), 458 (Air Transport-
maintenance) and 753 (Auto Repair).
For each user industry, Table 8-2 presents estimates of the value
of output, number of employees, and capital stock for 1976, together
with an estimate of the return on capital. Note that there is con-
siderable variation among industries on the basis of any one of those
factors. The smallest three-digit industries which use degreasing
are Miscellaneous Furniture and Fixtures (259), with output of $1,044
million and employment of 26,100 for 1976, and Miscellaneous Primary
Metal Products (339), with output of $1,236 million and employment of
24,600 in 1976. Miscellaneous Furniture and Fixtures (259) also had
.8-6
-------
Table 8-2 Industries Using Degreasers by SIC Code - 1976
SIC Industry
25 Metal Furniture
254 Partitions and Fixtures
259 Misc. Furniture and; Fixtures
33 Primary Metals
332 Iron and Steel Foundries
335 Nonferrous Rolling and Drawing
336 Nonferrous Foundries
339 Misc. Primary Metal Products
34 Fabricated Products
342 Cutlery, Hand Tools, and Hardware
343 Plumbing and Heating (except Electric)
344 Fabricated Structural Metal Products
345 Screw Machine Products, Bolts, etc.
346 Metal Gorgings and Stampings
347 Metal Services
348 Ordinance and Accessories
349 Misc. Fabricated Metal Products
35 Non-Electric Machinery
351 Engines and Turbines
352 Farm and Garden Machinery
353 Construction and Related Machinery
354 Metalworking Machinery
355 Special Industrial Machinery
356 General Industrial Machinery
357 Office and Computing Machines
358 Refrigeration and Service Machinery
359 Misc. Machinery, except Electrical
1976 Value
of Output
($106)
1,952
1,044
9,787
18,753
3,389
1,236
7,392
2,608
21,584
4,396
15,250
2,877
2,804
12,612
9,009
10,534
19,741
11,278
9,454
14,196
13,723
10,660
6.930
Number of
Employees
UO3)
50.9
26.1
216.4
171.3
84.7
24.6
158.4
50.6
401.4
99.6
265.4
89.8
74.7
259.2
124.6
146.0
311.5
289.5
196.2
280.7
229.4
172.9
209.0
Capital
Stock
($io6)
435.9
165.5
5,014.9
7,049.0
1,131.1
559.4
2,226.0
658.3
5,125.3
1,747.0
5,655.5
995.7
731.7
3,742.6
3,305.4
2,185.8
5,750.2
4,382.8
2,686.7
4,845.0
3,340.1
2,548.9
2 r 698. 3
Profit
Rate
(%)
3.35
3.35
3.64
3.64
3.64
3.64
8.84
8.84
8.84
8.84
8.84
8.84
8.84
8.84
8.41
8.41
8.41
8.41
8.41
8.41
8.41
8.41
8 41
00
-------
Table 8-2 (continued)
SIC Industry
36 Electric Equipment
361 Electric Distributing Equipment
362 Electrical Industrial Apparatus
364 Electric Lighting and Wiring Equipment
366 Communication Equipment
367 Electronic Components and Accessories
369 Misc. Electrical Equip, and Supplies
37 Transportation Equipment
371 Motor Vehicles and Equipment
372 Aircraft and Parts
376 Guided Missiles, Space Vehicles, Parts
379 Misc. Transportation Equipment
38 Instruments and Clocks
381 Engineering and Scientific Instruments
382 Measuring and Controlling Devices
39 Miscellaneous Industry
401 Railroads - Maintenance
458 Air Transport - Maintenance
753 Auto Repair
1976 Value
of Output
($io6)
4,688
8,453
7,342
19,138
12,433
6,829
95,381
23,463
7,142
3,117
1,847
6,180
16,286
18,536
3,701
13,269
Number of
Employees
(103)
104.1
194.7
159.2
421.5
323.0
129.6
797.1
408.0
141.7
49.7
43.5
168.9
410.0
496.5
N.A.
1763.0
Capital
Stock
($io6)
i
1,274.3
2,746.0
2,105.0
4,806.6
5,227.6
1,884.2
17,496.3
5,777.8
1,778.6
396.1
406.0
1,574.3
3,805.3
26,925.0
N.A.
10,316.0
Profit
Rate
(%)
!
4c* f\
.50
4.50
4C f\
.50
4c f\
.50
Ac f\
.50
4.50
3.62
3.62
3.62
3.62
10.13
10.13
6.44
1.20
N.A.
3.04
00
00
Source: Reference 5, 56 and 57.
-------
the smallest capital stock by far ($165.5 million), and no manufac-
turing industry earned a lower rate of profit (3.35 percent). At the
other end of the spectrum, the Motor Vehicle and Equipment sector
(371) produced $95,381 million of output in 1976. The value of out-
put in sector 371 was more than four times the value of output in the
next largest industry, 372-Aircraft and Parts ($23,463); the number
of employees in sector 371 (797,100) was almost twice as large as the
number in the next largest manufacturing employer, 366-Communication
Equipment (421,500).
Industry 371 also had the largest manufacturing capital stock
($17,496.3 million). Note that capital stock figures vary substan-
tially even when the value of output is considered. While industry
366 (Communication Equipment) produced output worth $19,138 million
in 1976, with a capital stock of $4,806.6 million, Industry 335 (Non-
ferrous Rolling and Drawing) produced output worth $18,763 million,
but with capital stock worth $7,049 million. Rates of profit vary
considerablly, also. The service industries earned the lowest
returns: 1.2 percent in railroads and 3.04 percent in auto repair.
The highest return, 10*13 percent, was earned in Industry 38 (Instru-
ments and Clocks); the'lowest manufacturing return, 3.35 percent, is
earned in Industry 25 (Metal Furniture).
As noted, the industries which use organic solvent cleaners vary
substantially. Two additional points must be made about this
variation. First, differences occur not only between two-digit
i
industries, but also between three-digit industries within any
8-9
-------
given two-digit sector. Disaggregation to the three-digit level
therefore adds substantial accuracy to the analysis. Second, varia-
tions in ouput, employment and capital stock are highlighted largely
in order to produce a more complete picture of the industries which
do degreasing. There is no simple, direct connection between the
magnitude of any of these variables and the amount of degreasing done
in any particular industry. The number of degreasers of different
types which are located in that sector is a better indication of the
importance of organic solvent cleaning in the industry.
b) Estimated Numbers of Degreasers by SIC Code Industry
Table 8-3 presents estimated numbers of degreasers for 1976 by
three-digit SIC Code industry. Cold cleaners, open top vapor
degreasers, and conveyorized degreasers are treated separately. The
estimated numbers of each type of degreaser per million dollars of
industry output are included as well. Note that in addition to the
degreasers allocated to specific manufacturing and service industries
for the production of output, there are 345,773 cold cleaners in what
is called "general industry usage." These degreasers are used
throughout industry for internal maintenance, and cannot be allocated
to specific three-digit sectors. (For information regarding estima-
tion procedures, see Appendix F.)
An estimated 1,268,000 cold cleaners were in use in 1976. Of
these, 416,879 were used in producing manufactured products, 505,348
8-10
-------
Table 8-3. Estimated Numbers of Degreasers by SIC Code, 1976.
oo
SIC
25
254
259
33
332
335
336
339
34
342
343
344
345
346
347
348
349
35
351
352
353
354
355
356
357
358
359
Value of
1976 output
Industry (flu6)
Metal Furniture
Partitions and Fixtures
Misc. Furniture and Fixtures
Primary Metals
Iron and Steel Foundries
Honferrous Rolling and Drawing
Nonferrous Foundries
Misc. PriMry Metal Products
Fabricated Products
Cutlery, Hand Tools, and Hardware
PliMblng and Heating (except Electric)
Fabricated Structural Metal Products
Screw Machine Products, Bolts, etc.
Metal Gorging; and Stampings
Metal Services
Ordnance and Accessories
Misc. Fabricated Metal Products
Non-Electric Machinery
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Metalworklng Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Misc. Machinery, except Electrical
1,952
1,044
9,787
18.753
3,389
1,236
7.392
2,608
21,584
4.396
15.250
2,877
2,804
12,612
9,009
10,534
19.741
11.278
9.454
14.196
13.723
10.660
6,930
Estimated no. of degreasers,
1976
Cold
Cleaners
6.156
3.265
1.992
2,246
4,058
9,715
11,891
2,772
25,131
5.409
5,892
19,157
132
16.024
792
8.238
11.089
38.152
10.467
30,734
4.589
6.085
79.547
Open top
vapor
351
109
137
277
105
1.254
1.152
205
771
160
205
1.124
5
864
33
304
451
569
41
1.876
220
169
1,085
Convey-
orized
117
36
34
70
25
313
280
49
187
39
50
273
1
209
6
65
96
122
9
402
47
35
232
Estimated no. of degreasers per
$ million of output
Cold
cleaners
3.153
3.127
0.204
0.120
1.197
7.863
1.608
1.063
1.164
1.230
0.386
6.658
0.047
L270
0.088
0.782
0.562
3.383
1.107
2.165
0.334
0.571
11.478
Open top
vapor
0.180
0.104
0.014
0.015
0.031
1.015
0.156
0.079
0.036
0.036
0.013
0.391
0.002
0.069
0.004
0.029
0.023
0.050
0.004
0.132
0.016
0.016
0.157
Convey-
orized
0.060
0.034
0.003
0.004
0.007
0.253
0.038
0.019
0.009
0.009
0.003
0.095
0.000
0.017
0.001
0.006
0.005
0.011
0.001
0.028
0.003
0.003
0.033
-------
Table 8-3 (continued)
oo
SIC
36
361
362
364
366
367
369
37
371
372
376
379
38
381
382
39
401
458
753
Industry
Electric Equipment
Electric Distributing Equipment
Electrical Industrial Apparatus
Electric Lighting and Hiring Equip.
Communication Equipment
Electronic Components and Accessories
Misc. Electrical Equip, and Supplies
Transportation Equipment
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles. Space Vehicles. Parts
Misc. Transportation Equipment
Instruments and Clocks
Engineering and Scientific Instruments
Measuring and Controlling Devices
Miscellaneous Industry
Total Manufacturing
Railroads - Maintenance
Air Transport - Maintenance
Auto Repair
Total Services
General Industry Usage
TOTAL
Value of
Estimated no. of degreasers,
1976
1976 output Cold
($10*) Cleaners
4.688
8.453
7.342
19.138
12.433
6.829
95,381
23.463
7.142
3.117
1.847
6,180
16.286
423,508
18.536
3.701
13.269
-
-
-
3.945
4.138
10.93S
11.339
10.196
4.989
10.944
11.967
716
4,358
6.086
17,797
15,936
416.879
1,161
36.160
468.027
505.348
345,773
1.268.000
Open top
vapor
871
279
2,465
2.539
1.362
71
630
2,779
178
0
550
3.194
614
26.999
61
3,279
0
3.340
0
30,339
Convey-
orized
115
36
324
333
178
10
89
393
25
0
32
187
73
4.492
0
0
0
0
0
4,492
Estimated no. of degreasers per
$ million of output
Cold
cleaners
0.842
0.490
1.489
0.592
0.820
0.731
0.115
0.510
0.100
1.398
3.295
2.880
0.978
0.984
0.063
9.770
35.272
-
-
-
Open top
vapor
0.186
0.033
0.336
0.133
0.110
0.010
0.007
0.118
0.025
0
0.298
0.517
0.038
0.064
0.003
0.886
0
-
-
-
tonvey-
orized
0.025
0.004
0.044
0.017
0.014
0.001
0.001
0.017
0.004
0
0.017
0.030
0.004
0.011
0
0
0
-
-
-
Source; Appendix F, and Reference 5.
-------
were located in service industries, and 345,773 were in general
industry usage. Among service industries, the auto repair sector
(753) had by far the largest number of cold cleaners (468,027 of
505,348, or 93 percent). This corresponds to over thirty-five cold
cleaners per million dollars of auto repair activity, the largest
number per million dollars of output in any sector, manufacturing or
service.
In 1976, four manufacturing industries were using more than
20,000 cold cleaners: 359-Miscellaneous Machinery, except Electrical
(79,547); 354-Metalworking Machinery (38,152); 357-Office and Compu-
ting Machines (30,734); and 344-Fabricated Structural Metal Products
(25,131). Twelve manufacturing industries used between ten and
twenty thousand cold cleaners, while seventeen used from one to ten
thousand cold cleaners. The remaining three industries used less
than one thousand units each.
On a per million dollars of output basis, the greatest concen-
tration of manufacturing cold cleaners was in the same industry which
had the largest number of cold cleaners, 359-Miscellaneous Machinery,
except Electrical (11.5 per million dollars). Two other manufac-
turing industries had more than five cold cleaners per million
dollars of output: Industry 339-Miscellaneous Primary Metal Products
(7.9) and Industry 347-Metal Services (6.7). Note that Industry 339
had only an intermediate absolute number of cold cleaners (9,715),
but a high number per million dollars of output (7.9). Both Industry
254-Partitions and Fixtures and Industry 259-Miscellaneous Furniture
8-13
-------
and Fixtures had 3.2 cold cleaners per million dollars of output.
Industries 381-Engineering and Scientific Instruments and 382-
Measuring and Controlling Devices had 3.3 and 2.9 cold cleaners per
million dollars of output, respectively. Industry 354-Metalworking
Machinery is the only other sector with more than three cold cleaners
per million dollars of production. Nine industries had between one
and two cold cleaners per million dollars of output, while the
remaining eighteen had less than one.
In 1976, there were 30,399 open top vapor degreasers in opera-
tion. Of these, 26,999 or 89 percent were in manufacturing.
Virtually all of the eleven percent in services were used in air
transport maintenance. Only four industries had more than two thou-
sand open top vapor degreasers: 382-Measuring and Controlling
Devices (3,194); 372-Aircraft and Parts (2,779); 366-Communication
Equipment (2,539); and 364-Electric Lighting and Wiring Equipment
(2,465). Note that these industries had moderate numbers of cold
cleaners, indicating that a large number of one type of degreaser
does not necessarily mean either a large or a small number of another
type. Six industries had between one and two thousand open top vapor
degreasers, while eight had between five hundred and one thousand,
nine had between two hundred and five hundred, and nine had less than
200. The remaining four manufacturing industries had less than one
hundred open top vapor degreasers.
8-14
-------
Only four manufacturing industries had more than three-tenths of
an open top vapor degreaser per million dollars of output: 339-
Miscellaneous Primary Metal Products (1.02); 382-Measuring and Con-
trolling Devices (0.52); 347-Metal Services (0.39); and 364-Electric
Lighting and Wiring Equipment (0.34). With the exception of Industry
364, these industries also had among the highest numbers of cold
cleaners per million dollars of production. Ten industries had
between one-tenth and three-tenths of an open top vapor degreaser per
million dollars of output while twenty-two had less than one-tenth.
In 1976, there were 4,492 closed conveyorized degreasers in use,
all of which were located in manufacturing industries. Five indus-
tries had more than three hundred such degreasers: 356-General
Industrial Machinery (402); 372-Aircraft and Parts (393); 366-
Communication Equipment (333); 364-Electric Lighting and Wiring
Equipment (324); and 339-Miscellaneous Primary Metal Products (131).
These industries also had reasonably large numbers of open top vapor
degreasers. Ten industries had between one hundred and three hundred
conveyorized degreasers while twenty-one industries had less than
100. Note that Industries 348 and 351 have very small numbers of all
types of degreasers, while Industries 356 and 372 have reasonably
large numbers of all types.
Conveyorized degreasers per million dollars of output range from
zero to 0.253 (339-Miscellaneous Primary Metal Products). Aside from
Industry 339, all estimates are less than one-tenth of a degreaser.
8-15
-------
Industries 254-Partitions and Fixtures (0.060) and 347-Metal Services
(0.095) had the next highest estimates. Fourteen industries had
between .01 and .05 conveyorized degreasers per million dollars of
output while nineteen industries had less than .01.
c) Estimated Costs of Degreasing Operations
The most significant indicator of the importance of degreasing
activities within any particular industry is the share of total
industry costs (measured by value of industry shipments) accounted
for by organic solvent cleaners t Total industry degreasing costs and
cost shares by type of degreasing activity are presented in Table
8-4. These costs were estimated by combining cost data for typical
uncontrolled degreasing operations in each industry (presented in
Appendix F) with the data on numbers of degreasers in each industry
presented in Table 8-3. According to RTI's estimates, American
industry spent approximately $1,948,700,000. on organic solvent
degreasing in 1976. This represents less than four-tenths of one
percent of the total value of industry output. Cold cleaning
accounted for about $1,377,000,000., or a little more than 70
percent of total industrial degreasing costs. Open top vapor
degreasing accounted for another 21 percent, and conveyorized
degreasing the remaining 9 percent of total degreasing costs. In the
thirty-nine industries identified as major users of degreasing equip-
ment, total degreasing costs exceeded one percent of value of ship-
ments in only ten industries and two percent in only three.
8-16
-------
Table 8-4. Degreasing Cost Shares by Degreasing Process for SIC Code Industries
00
cold Cleaning Costs
254
259
332
335
336
339
342
343
344
345
346
347
348
349
351
352
353
354
355
366
357
350
359
3C1
362
364
366
367
369
371
3/2
376
3/9
301
302
390
401
450
753
SIC code (Short Title)
Partitions and Fixtures
Hlsc. Furniture and Fixtures
Iron and Steel Foundries
(Ion ferrous Rolling and Drawing
Monferrous Foundries
Hlsc. Primary Metal Products
Cutlery, Hand Tools, and Hardware
Plunblng and Heating (except Electric)
Fabricated Structural Hetal Products
Screw Machine Products, Bolts, etc.
Hetal Gorging* and Stampings
Metal Services
Ordnance and Accessories
Misc. Fabricated Hetal Products
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Hetalworking Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Hlsc. Machinery, except Electrical
Electric Distributing Equipment
Electrical Industrial Apparatus
Electric lighting and Hiring Equip.
ConiiHinlcation Equipment
Electronic Components and Accessories
Hlsc. Electrical Equip, and Supplies
Motor Vehicles and Equipment
Alrcidfl and Parts
Gulilud Missiles. Space Vehicles, Parts
Misc. Transportation Equipment
Engineering and Scientific Instruments
MKdsurlng and Controlling Devices
Miscellaneous Industry
Railroads - Maintenance
Air Transport - Halntenance
Auto Repair
Value of
Shipments
1952.3
1044.1
9787.0
18753.3
3389.4
1235.6
7392. 5
2608.0
21583.9
4396.0
15249.7
2877.1
2804.3
12612.1
9009.1
10533.7
19740.8
11278.2
9453.5
14196.5
13722. 8
10660.2
6930.5
4688.0
8452.9
7342.0
19138.0
12432.7
6829.1
95381.4
23463.0
7141.6
3116.8
1846.8
6180.2
2691.3
18536.0
3701.0
13269.0
Million $
19.41)4
9.051
7.335
8.095
12.957
37.238
37.968
8.333
81.827
17.325
21.512
53.295
0.384
51.918
3.113
29.986
40.076
136.008
34.185
106.278
14.822
19.429
268.471
12.352
12.675
32.925
38.564
26.6/3
17.047
45.647
45.870
1.992
12.124
19.147
52.288
40.060
4.710
138.782
1796.287
t of value
of shipments
.998
.867
.075
.043
.382
3.014
.514
.320
.379
.394
.141
1.852
.014
.412
.035
.285
.203
1.207
.362
.749
.108
.182
3.874
.263
.150
.448
.202
.215
.250
.048
.196
.028
.389
1.037
.846
1.518
.025
.749
13.537
Open lop vapor Uegreaslng cosl|
Hi II Ion J
4.0122
1.5337
2.3017
4.5891
1.6102
21.6365
17.6659
3.0285
ll.%/5
2.4506
3.4249
15.8506
0.0725
13.3704
0.5791
5.0695
7.4857
9.3646
0.6377
30.2599
3.3977
2.5916
17.2309
13.1939
4.1697
36.4549
40.5199
18.5069
1.1364
11.5088
47.9409
2.5102
0.0000
8.3567
46.5366
8.2565
1.093
56.625
0.0
S of value
of shipments
.246
.147
.024
.024
.048
1.751
.23')
.116
.055
.056
.022
.551
.003
.106
.006
.040
.038
.083
.007
.213
.025
.024
.249
.281
.049
.497
.212
.149
.017
.012
.204
.035
.000
.452
.753
.307
.006
.305
.000
Conveyorlzed Decreasing Cost
HI 11 ion $
3.786
1.134
1.195
2.438
0.830
11.188
9.292
1.590
6.253
1.296
1.751
8.612
0.032
6.975
0.217
2.2/3
3.348
4.232
0.3U1
13.768
1.567
1.162
7.868
3.700
1.176
10.517
11.328
5.497
0.341
3.302
14.048
0.789
0.000
1.056
6.015
2.239
0.0
0.0
0.0
I of value
of shipments
.194
.109
.012
.013
.024
.905
.126
.061
.029
.029
.Oil
.299
.001
.055
.002
.022
.017
.031)
.003
.097
.011
.011
.114
.808
.014
.143
.059
.044
.005
.003
.060
.011
.QUO
.057
.097
.UUJ
.0(11)
.01)0
.000
Total Ocyreasliiu. Costs
Million I
20.001
11.718
10.831
15.1?2
15.397
70.062
C4.92d
12.951
100.047
21.080
26.6IIR
77.757
0.489
72.2A4
3.909
37.329
50.909
149.684
35.124
150.306
19.707
23.103
293.570
29.334
18.020
79.897
90.412
50.676
18.525
60.458
107. Ud/
5.291
12.124
28.559
104.840
51.355
5.803
105.407
1796. 20/
I or value
of shipments
1.438
1.122
.111
.0(11
.454
5.670
.878
.497
.464
.100
.l/'j
2. 703
.017
.573
.043
.W4
.258
1.327
.3/2
1.05'J
.144
.217
4.236
.626
.213
I.08U
.472
.408
.?/!
.063
.498
.0/4
. WJ
1.546
1.696
I.90B
.031
.054
13.538
Source: Tables 8-2 and 8-6.
-------
The manufacturing indue try r.cet significantly involved in
Liiic solvent dcgrcasing is SIC 339, Miscell^eo-vs Primary Metal
Froducts. This classification includes netal h°at treating and the
manufacture of products such as r.ailc and spikes vbich must be clean
when shipped. Degreasing represents :nore than 5.6 percent of the
industry's value of shipments, cr atout 70 sillier dollars. More
than lialf of this amount is attributed to cold cleaning, but
significant open top and conveycrized degreasing activity takes plac*1
as well. SIC 359, Miscellaneous Ncn-Electrical Machinery, had
degreasing costs of 293 million dollars in 1976, accounting for 4.2
percent of industry value of output. Almost all of this amount was
for cold cleaning, the process requiring the least expensive control
equipment. In SIC 347, metal services, degreasing represented more
than 2.7 percent of total costs, of which two thirds consisted of
expenditures on cold cleaning. In addition, three transport and
service industries, 753-auto repairs, 458-air transport maintenance
and 401-railroad maintenance accounted for 1,997 million dollars of
degreasing activity in 1976. About 90 percent of this total, an
estimated 1,796 million dollars, was spent on degreasing in auto and
truck maintenance and repair. This amount is more than- 13.5 percent
of the industry's total receipts. This estimate is based on the
assumption that a quarter of one mechanic's time is spent running
each degreaser. Degreasing may not ordinarily require this much
labor. Consequently, the estimate should be regarded as a maximum
figure.
8-18
-------
It is important to note that degreasing activities represent a
significant part of total operations in some industries where profit
rates are low. This is most apparent in the case of SIC 753 (auto
repair). As noted above, degreasing costs represent an estimated
13.5% of total costs in that industry while the rate of profit is
only 3.04%. A similarly situated industry is SIC 339 (Miscellaneous
Primary Metal Products) where degreasing activities represent 5.7% of
total costs and the rate of profit is 3.64%. Of the remaining indus-
tries in which degreasing costs represent more than 1% of total
costs, only two (SIC's 254 and 259) have profit rates which are lower
than 4% (3.5% in both cases). This suggests that typical firms in
those industries may have some difficulty in financing the capital
investments made necessary by the controls. However, for the
remaining industries that should not be the case. In this context,
it is worth noting that in the industry experiencing the lowest
profit rate (1.2%) in 1976 (401-railroad maintenance), estimated
degreasing costs represent less than 0.031% of total costs. Thus, it
seems unlikely that the capital cost of NSPS control equipment would
be burdensome for that industry.
d) Estimate Numbers of Degreasers by Geographic Location
Table 8-5 presents estimated numbers of degreasers for 1976 by
geographic location. Cold cleaners, open top vapor degreasers and
conveyorized degreasers are considered separately. Estimated manu-
facturing totals and overall totals are both given. Tables Fl-3,
8-19
-------
Table 8-5 Estimated Numbers of Degreasers for 1976 by Geographic Location
Degreaser Type
Manufacturing
Cold Cleaners
Open Top Vapor
Degreasers
Closed Con-
.veyorized
Degreasers
TOTAL
Cold Cleaners
Open Top Vapor
Degreasers
Closed Con-
veyorized
Degreasers
North
East
34,629
2,658
413
76,156
2,778
413
Mid
Atlantic
79,851
5,516
890
197,503
5,744
890
East
North-
Central
147,308
8,148
1,477
335,413
8,646
1,477
West
North-
Central
J
30,152
1,758
293
111,066
2,241
293
South
Atlantic
28,942
1,860
308
152,824
2,310
308
East
South-
Central
17,592
1,058
190
74,939
1,315
190
West
South-
Central
22,974
1,444
249
122,985
1,973
249
Mountain
7,454
548
77
45,967
863
77
Pacific
50,167
4,047
602
149,987
4,446
602
TOTAL
419,069
27,037
4,499
1,268,001
30,377
4,499
CO
Source: Appendix F
-------
Fl-4 and Fl-5 in Appendix F show the estimated numbers of cold
cleaners, open top vapor degreasers, and conveyorized degreasers,
respectively, by location and three-digit industry. The geographic
distribution of degreasers within each industry is based on the
geographic shares of the national value of shipments for that
industry for 1972. (For more information on the estimation proce-
dure, see Appendix F.)
The highest concentration of degreasers used in manufacturing
was in the East North Central section of the United States. This
area had 147,308 cold cleaners, 8,148 open top vapor degreasers and
1,477 conveyorized degreasers in manufacturing, representing 35, 30
and 33 percent, respectively, of the total numbers of manufacturing
degreasers. Comparable numbers for the Middle Atlantic states are
79,851 cold cleaners (19 percent), 5,516 open top vapor degreasers
(20 percent), and 890 conveyorized degreasers (20 percent). The
Mountain states had the fewest manufacturing degreasers, with 7,454
cold cleaners (2 percent), 548 open top vapor systems (2 percent),
and 77 conveyorized degreasers (2 percent).
Total numbers of degreasers (including service and general usage
degreasers, as well as manufacturing degreasers) were distributed
similarly, but more evenly. In particular, the inclusion of service
and general usage degreasers reduces the concentration of cold
cleaners and open top vapor systems in the East North Central and
Middle Atlantic states. These two areas accounted for 54 percent of
all manufacturing c'old cleaners and 51 percent of all manufacturing
8-21
-------
open top vapor degreasers. Comparable percentages for total
degreasers are 42 percent and 47 percent. The shares of cold
cleaners and open top vapor degreasers found in the southern and the
western parts of the U.S. increase when service and general usage
categories are included.
e) Projections of Organic Solvent Degreasers for 1980 and 1985
Projected numbers of degreasers for 1980 and 1985 are based on
projected values of shipments for the appropriate three-digit indus-
tries. These projected values are developed using the Bureau of
Labor Statistics' projected growth rates for 1976 to 1980 and for
1980 to 1985.7»8 The number of each type of degreaser in each
industry is assumed to increase by the same proportion as output in
that industry. Note that this amounts to an assumption of fixed
proportions in production in each of the three-digit industries, or,
alternatively expressed, to an assumption of fixed input-output
coefficients. These fixed coefficients are used to generate projec-
tions of both output and numbers of degreasers. These projections are
virtually unaffected by the introduction of New Source Performance
Standards and therefore represent both the pre-standard and post-
standard estimates of degreaser utilitzation in 1980 and 1985.*
Table 8.6 presents projected values of shipments and projected
numbers of degreasers for 1980 and 1985 by three-digit SIC
See section 8.4.4 for discussion of the impact of NSPS's on the
numbers of each type of degreaser required by each industry.
8-22
-------
Table 8-6. PROJECTED NUMBERS OF DEGREASERS FOR 1980 AND 1985 BY SIC CODE.
f
M
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-
Source: Appendix F; References 5 and 7.
-------
code industry. The total number of cold cleaners (CC) will increase by 16.6
percent from 1976 to 1980 and by 20.5 percent from 1980 to 1985. Manufacturing
CC will increase by 21.4 percent and 19.5 percent for the two periods, while
service CC will increase in number by 12.5 percent and 22.3 percent. General
usage CC will increase by 16.6 percent and 19.2 percent for the two
periods. Thus, for CC, the largest proportional increase is in manufacturing
for 1976 to 1980 and in service uses for 1980 to 1985.
For open top vapor degreasers (OTVD) the largest percentage increase
for each period is in service industries: 34.6 percent and 35.3 percent for
1976 to 1980 and 1980 to 1985, respectively. Analagous estimates for
manufacturing are 20.2 percent and 21.8 percent. Note, however, that because
most of the OTVD are located in manufacturing (manufacturing accounted for
89.1 of all OTVD in 1976), the total numbers of OTVD will increase only by
21.8 percent and 23.4 percent for the two periods. One interesting and
important point is that OTVD are concentrated in industries whose projected
growth rates are higher than for those in which CC are concentrated. Conse-
quently, the percentage increase for OTVD is higher than for CC in each
period. The rate of increase in conveyorized vapor degreasers is 19.1
percent for 1976 to 1980 and 21.6 percent for 1980 to 1985 and lies between
the growth rates for CC and OTVD.
Within manufacturing industries, diverse growth rates yield diverse
rates of increase in degreaser usage. The highest growth
8-24
-------
rates often occur in industries using small numbers of degreasers;
for example, industries 351-Engines and Turbines and 376-Guided
Missiles. Only one industry, 356-General Industrial Machinery, com-
bines a larger number of degreasers with an unusually high growth
rate. (Degreaser use in that industry rises by 80% over the period
1976 to 1985). Consequently, the rate of growth in degreasing acti-
vities will not differ significantly from the rate of growth of
general economic activity.
Increased numbers of degreasers means increased solvent use,
given a constant rate of solvent loss per degreaser. Under this
assumption, which implies that firms do not implement NSPS controls
to a greater extent than they already have, the percent increases in
solvent use for 1976-1980 by SIC code industry are the industry
growth rates for those periods presented in Table 8-6. Demand for
solvents over the next ten years is therefore likely to be most
buoyant in industries such as 356-General Industrial Machinery,
357-Office and Computing Machines, 361-Electrical Distributing
Equipment and 351-Engines and Turbines where projected growth rates
are high. It will be weak in industries such as 332-Iron and Steel
Foundries and 348-Ordinance and Accessories where projected growth
rates are low.
f) Qualifications
The projections of demand for degreasers presented above rest on
two assumptions. The first is that degreaser usage by three-digit SIC code
industries has been correctly identified; the second is the assumption of
8-25
-------
fixed input-output coefficients for degreasers. Both are questionable, but
no less so than alternative assumptions.
Issue may be taken with the validity of the Dow national survey
(Surprenant et al.^) though it covered 2,578 firms. The survey
dealt only with organic solvent degreasing in metal working industries.
Yet from the Eureka survey (Leung et al.^), it is clear that other
sectors such as railroad and aircraft maintenance use vapor degrea-
sers in addition to cold cleaners. Further, the survey only deals
with cold cleaning systems in two-digit industries, not with total
r
numbers of cold cleaners. The Eureka Laboratories survey is more
detailed in the sense that it examines organic solvent degreasing at
the three-digit code level, but less so in that it covers only eight
two-digit SIC industries, omitting SIC Code Industry 39-Miscellaneous
Industry. This two-digit industry was ignored because Eureka1s
provisional survey failed to indicate any usage of organic solvent
degreasing equipment by firms in that industry. Yet Dow's survey
shows that at least a small amount of organic solvent cleaning does
take place in SIC 39. Further, Eureka's study covered only
California, which may be an atypical state vis-a-vis organic solvent
degreasing because of its relatively long history of state air
pollution controls under which, for example, trichlorethylene was
proscribed a decade ago.*
Rule 66 provisions, in operation in California since the mid-
19601 s were only adopted in 1974 by other states.
8-26
-------
An additional problem is that Eureka's survey presented evidence
only on solvent usage by each three-digit industry, not on numbers of
different types of degreasers. Thus, variations in the percentage of
emissions attributable to cold cleaners, open top vapor degreasers
and conveyorized vapor degreasers across three-digit industries
within given two-digit classes could not be identified. Conse-
quently, appropriate adjustments could not be made for such varia-
tions in emissions in the estimation of the different types of
degreaser used at the three-digit level. Despite the above qualifi-
cations, it should be noted that the data on location of organic solvent
degreasers in the U.S. presented in the Dow and Eureka surveys
are the most comprehensive sets currently available.
The fixed coefficient assumption used in the baseline projec-
tions of net investment in organic solvent degreasing must also be
examined. In many plants, degreasing equipment is significantly
underutilized. This situation is not uncommon. Therefore,
increases (decreases) in average plant size over time, measured by
changes in real output, would imply increased (decreased) utilization
of organic solvent degreasers and a consequent fall (rise) in degreaser
input-output coefficients. Failure to take account of such changes
would lead to errors in the projections presented above.
To test for "the possibility of a persistent bias in the projec-
tions because of the fixed input-output coefficient assumption,
At a Westinghouse plant in Raleigh, North Carolina, the open top
vapor degreaser was used for less than 30% of one shift per day.
8-27
-------
historical trends in average plant size for metal working industries
(SIC codes 25 and 33-39) were examined for the three periods 1963-67,
1967-72 and 1963-1972 using data from the Census of Manufactures.*
Values of shipments for 1963 and 1967 were adjusted using the Whole-
sale Price Index by Commodities^ published by the Bureau of the
Census. The results are presented in Tables 8-7 and 8-8. From the
summary Table 8-8, it can be seen that between 1963 and 1967 average
plant sizes rose in 51 of 55 industries; however, between 1967 and
1972,. this number fell to 29 of 56. Over the entire period,
1963-1972, plant size rose in 44 out of 55 industries. There is also
considerable variation between industries and within industries
between time periods. For example, in industry 386-Photographic
Equipment and Supplies, average plant size rose by 470% over the
period 1963-72; in another, 376-Guided Missiles, Space Vehicles and
Parts, it fell to 51.8% of its original level over the same time
period. Clearly, average plant output may rise or fall over time.
In 25 of the 56 industries, the direction of change in average plant
size shifted between 1963-67 and 1967-72, in some cases dramati-
cally. For example, in industry 348-Ordnance and Accessories output
per plant virtually doubled between 1963 and 1967, but fell to almost
its original level in 1972.
The historical evidence on average plant size suggests that all
things are possible. Consequently, the assumption of no change is as
satisfactory as any other. Hence the fixed input-output coefficients
8-28
-------
Table 8-7. Average Plant Size by SIC 3-Digit Industries: 1963-1972.
SIC ,
Code
251/2/3
254
259
331
332
333
334
335
336
339
341
342
343
344
345
346
347
348
349
351
352
353
354
355
Manufacturers of:
Metal Furniture
Metal Partitions
Fixtures, Drapery, Hardware
Basic Steel Products
Iron A Steel Foundries
Primary Nonferrous Metals
Secondary Nonferrous Metals
Nonferrous Rolling A Drawing
Nonferrous Foundries
Misc. Primary Metal Products
Metal Containers
Cutlery A Handtools
Plumbing A Heating
Fabricated Structural Metal Products
Screw, Bolts
Metal Forging
Misc. Metal Services
Ordnance A Accessories (Guns A
Munitions)
Misc. Fabrication Metal Products
Engines A Turbine
Farm A Garden Machinery
Construction A Related Machinery
Metal work ing Machinery
Special Industry Machinery
Average Plant Size by Value
1972 Prices - Dollars
1963
936.8
418.3
343.5
34,366.5
2.866.8
35.172.8
3.081.2
14.623.3
878.8
510.8
7,752.3
1,831.0
1,972.5
937.7
999.0
2,597.1
265.3
8,532.1
1,312.8
16,197.6
1.608.9
2,601.7
670.3
1,283.9
1967
1,255.9
571.5
510.7
33,164.2
3,759.7
29,413.8
4,860.3
14,714.9
1.307.1
744.9
8.990.4
2,365.9
2,180.7
1.271.3
1,298.0
3,046.1
332.9
16.354.2
1,683.8
20,317.6
3,133.3
4,023.0
938.2
1,777.4
of Shipment
x 103)
1972
1,616.2
759.7
737.2
29,521.1
4,083.5
34,103.4
5,504.5
14,259.6
1,262.2
731.9
8,991.1
2,675.6
2.822.7
1,369.9
1,245.6
3,123.2
364.7
8,847.6
1,493.1
21,768.4
3,371.8
4,405.8
752.9
1,684.5
Direction of Change in Average
Plant Size
1963-67 1967-72 1963-72
4 + 4
444
444
-
4-44
- 4 -
+ + 4
+
4 - 4
4-4
444
444
444
444
+ - 4
44-4
444
4-4
4-4
+ 44
4 4 4
4 4 4
+ - +
+ - 4
00
ro
vo
-------
Table 8-7 (continued)
SIC
Code
356
357
358
359
361
362
363
364
365
366
367
369
371
372
373
374
375
376
379
381
382
383
384
385
Manufacturers of;
General Industrial Machinery
Office A Computing Machines
Refrigeration A Service Machinery
Misc. Machinery except Electrical
Electrical Distributing Equipment
Electrical Industrial Apparatus
Household Appliances
Electric Lighting A Miring Equipment
Radio A TV Receiving Equipment
Communication Equipment
Electronic Components A Accessories
Misc. Electrical Equipment A Supplies
Motor Vehicles A Equipment
Aircraft A Parts
Ship A Boat Building A Repairs
Railroad Equipment
Motorcycles, Bicycles A Parts
Guided Missiles. Space Vehicles. Parts
Misc. Transportation Equipment
Engineering A Scientific Instruments
Measuring A Controlling Devices
Optical Instruments A Lenses
Medical Instruments A Supplies
Ophthalmic Goods
Average Plant Size by Value
(1972 Prices - Dollars
196:
1.617.8
*
2.502.4
215.4
4.088.7
3.292.5
7.640.9
1.913.1
6.140.5
9,439.3
2.216.2
2.846.2
14,939.7
11.842.6
1,210.1
15,559.1
2,548.3
113.697.5
1.542.0
1.192.5
2.319.7
1,538.8
1,000.9
1,522.6
1967
2,170.9
11,375.1
3,381.5
289.7
5,402.7
4,430.4
10.548.1
2,599.1
7.864.9
10,026.0
3,853.2
2.989.5
17,146.3
19.267.6
1,746.8
19,509.0
3,743.4
81,173.5
1,703.4
1,742.9
2,926.9
1.897.0
1,233.5
1,089.6
of Shipment
x 103)
1972
2.183.2
8,648.1
4.924.3
268.9
4,573.2
3,577.7
10,760.2
2,978.8
5,333.1
6.915.5
3.078.4
2,612.0
18.850.3
14.479.8
1,939.6
15.007.4
2,970.7
58,908.6
1.461.0
1.402.4
2.478.2
1,089.9
1,573.0
1.138.9
Direction of Change In Average
Plant Size
1963-67 196/-72 19bJ-7z
+ + *
* . *
+ i +
+ - +
+ - *
+ - *
* *
* + *
+
+
+ - »
+
* * +
* +
+ * *
*
+
.
*
* - +
+
+
+ + +
-
Co
Co
o
Incomplete data for SIC 357.
-------
Table 8-7 (concluded)
sic"
Code
386
387
391
393
394
395
396
399
Manufacturers of:
Photographic Equiment A Supplies
Matches, Clocks A Watchcases
Jewelry, Silverware A Plated Mare
Musical Instruments
Toys 4 Sporting Goods
Pens, Pencils, Office A Art Supplies
Costume Jewelry A Notions
Miscellaneous Manufactures
Average Plant Size by Value
(1972 Prices - Dollars
1963
1,906.5
3,166.8
590.7
1,329.1
918.6
796.5
533.0
440.5
1967
7,756.6
4,240.8
725.3
1,563.7
1.120.0
932.2
712.2
515.2
of Shipment
x 103)
1972
8,969.5
4.639.6
789.4
1.795.1
1,488.9
959.3
842.6
511.2
Direction of Change In Average
Plant Size
1963-67 1967-72 1963-72
*
+ + +
+
* +
+ + +
+ + +
* - «
+ - -f
00
-------
Table 8-8. Summary of Trends in Average Plant Size, 1963-1972*
Time Period
1963-1967
1967-1972
1963-1972
# of industries
where plant size
increased
51
29
44 :
# of industries
where plant size
decreased
4
27
11
*Based on data presented in Table 8.1.6.1.
8-32
-------
used in the baseline projections of demand- for organic solvent degreasers
are not unreasonable even if they are not perfect.
8.1.3 Market Conditions
8.1.3.1 Demand for Solvents
The demand for organic solvents is not limited to metal cleaning
operations. Other industrial applications for the solvents used in cold
cleaning include: surface coatings and resins, octane additives, organic
chemical synthesis, plastics production, and textile/pharmaceutical
processing.
With the exception of trichloroethylene, the solvents utilized in
vapor degreasing also have additional applications. Perchloroethylene
is used in dry cleaning (63%), trichlorotrifluoroethane production
(11%), exports (7%) and miscellaneous products (3%). Organic solvent
cleaning holds only a small percentage of the market for this compound
(16%). Uses of trichlorotrifluoroethane besides cleaning (72%) include:
chemical processing (5.2%) carrier medium (4.1%), drying (5.6%), cutting
fluid (2.4%), dry cleaning (3.4%), miscellaneous (0.6%) and government
(6.7%). Methylene chloride also has a variety of uses - plastics, paint
remover and aerosol propellant production (40%), exports (19%), aerosol
vapor pressure depressant (17%), plastics processing (6%), and "other"
(19%) . In the past, the degreasing industry had consumed only a small
part of the total methylene chloride output; presently, the use of this
compound has increased as a substitute for trichloroethylene. Approxi-
mately 75% of 1,1,1-trichloroethane is used in metal cleaning, while the
remaining 25% is divided between the following uses; aerosol propellants,
vinyl chloride production, and other miscellaneous categories.
8-33
-------
Several other factors influence the demand for solvents In degreasing
operations (see Table 8-9 for solvent prices and consumption data). The
degreasing industry, in general, can be classified as an industrial
services industry. As such, the future expanded use of solvent degreasing
systems (and the growth of the degreasing industry) is directly related
to the growth and expansion of the semi-finished and finished productions
manufacturers.
Environmental and health regulations issued by the EPA, OSHA and
state governments can have an impact on the demand for degreasing solvents.
Regulations can alter demand by placing limitations or an outright ban
on the use of certain solvents. Federal or state emission control
requirements could lead to the closing of marginally economic degreasing
operations, thus, reducing total solvent consumption. These regulations
could also reduce solvent demand by allowing companies to use recovered
solvent from carbon adsorbers, instead of consuming newly produced
solvents.
An additional factor that may have an influence on the demand for
degreasers is the availability and cost competitiveness of substitute
technologies such as alkaline washing. However, according to industry
1 2
sources, ' the opportunities available for the substitution of organic
solvent cleaning operations with alkaline washing systems are very
limited. Thus a significant variation in the cost competitiveness of
alkaline washing processes may have little Impact on the demand for
solvents used in the degreasing industry.
The price of substitute solvents is another factor that affects the
total demand for degreasing solvents. This demand determinant is covered
in Section 8.1.3.3.
8-34
-------
8.1.3.2 Substitution of Solvents
Trichloroethylene and 1,1,1-trichloroethane are close technological
substitutes. Both have relatively low boiling points (80°C and 74°C, respectively)
14
and may be used in ordinary industrial operations. While they are not
*
perfect substitutes , it can be expected that an increase in the user
cost for one, would lead to an increase in demand for the other. This
was the case following the classfication of trichloroethylene as a
nonexempt chemical under L.A. Rule 66. Since this ruling in 1966, many
industrial operations have replaced trichloroethylene with 1,1,1-trichloro-
ethane. This trend could be slowed or even reversed if regulatory
restrictions were placed on the use of 1,1,1-trichloroethane.
In recent years, there has been an increase in the use of methylene
chloride in solvent degreasing operations. One reason for this change
in solvent consumption patterns is that methylene chloride can be substituted
for trichloroethylene and 1,1,1-trichloroethane in some industrial
degreasing processes. It is, however, relatively expensive to use due
to a rapid diffusion rate and the fact that a change to methylene
chloride requires extensive modifications in the degreasing systems,
which were designed for use with other solvents.
Perchloroethylene, which is an imperfect substitute for the other
solvents, is used when a high boiling point (121°C) is required for
greater cleaning efficiency or when water is present on the cleaning
surface. It is less desirable to use this solvent for ordinary industrial
degreasing operations due to increased energy costs and parts handling
problems associated with higher operating temperatures. Although
*l,l,l-trichloroethane has problems reacting with zinc and aluminum and
cannot be applied when there is excess water on the cleaning surfaces.
8-35
-------
perchloroethylene is used in 15 percent of all vapor degreasing operations,
it is a. suspected carcinogen. This problem could have a major impact on
future industrial uses of perchloroethylene.
Trichlorotrifluoroethane (the most common freon-based degreasing
solvent) is particularly suited for cleaning small, delicate parts which
cannot tolerate high temperatures. Due to its rapid diffusion rate and
relatively high price (Table 8-9), the solvent is usually used only
when a task requires its special degreasing properties.
8.1.3.3 Solvent Prices
As a group, the halogenated solvents are more expensive to use than
petroleum solvents, alcohols and toluene. These latter solvent groups
are unsuited for vapor degreasing processes due to their low flash point
temperatures. However, their lower prices make them preferred to halo-
genated solvents in cold cleaning operations. Even though acetone and
ketones are more expensive than petroleum solvents, they are sometimes
used in cold cleaners to attain higher cleaning efficiences.
Fluorocarbons (freon-based solvents) have a much higher unit price
compared to other solvents. Due to this price disadvantage, it is
uneconomic to use these solvents in ordinary degreasing processes.
8-36
-------
Table 8-9. Solvent Use in Room Temperature Cleaning in the Metalworking Industry
Solvent
trichloroethylene
1,1, 1-trichloroethane
perchloroethylene
methylene chloride
fluorocarbons
petroleum solvents
acetone
methyl ethyl ketone
toluene
alcohols
safety blends
# of plants
using, 1974
2,295
2,106
702
324
1,026
6,344
1,215
648
837
945
2,079
103 Kg/yr,
1974
19,530
30,596
4,316
3,114
8,845
33,267
3,592
3,090
5,408
2,766
7,248
price/Kg
$, 1974
0.57
0.55
0.55
0.57
1.83
0.22-
0.33
0.51
0.57
0.26
0.37-
0.53
NA
price/Kg
$, 1978
0.46
0.53
0.37
0.46
1.23
0.15
0.40
0.46
0.22
0.18-
0.37
NA
Estimated
value in cold
degr easing
$ x 10 , 1974
11,195
16,863
2,379
1,785
16,185
9,100
2,003
1,771
1,431
1,220
NA
00
to
-J
Source: Reference 3
-------
8.2 COST ANALYSIS OF ALTERNATIVE EMISSION CONTROL SYSTEMS
8.2.1 New Facilities
8.2.1.1 Introduction
The purpose of this section is to develop estimates of capital
and annualized costs of alternative control systems for reduction of
volatile organic compound (VOC) emissions from new solvent cleaning
facilities. The cost to achieve various levels of control will be presented
for model affected facilities representative of the three types of degreasers
under investigation. For the solvent cleaning industry, requirements for
compliance with state regulations for control of VOC emissions were assumed
to be negligible. However, states currently are in the process of drafting
regulations which will require some controls on degreasers. With regard to
OSHA standards, there does not appear to be any significant equipment require-
ments for compliance. The total cost requirements presented will be the
incremental control costs over state and OSHA regulatory requirements.
Throughout this chapter the terms capital and annualized costs
are used; therefore, a brief explanation of each is in order. The
capital cost includes all the costs necessary to design, purchase,
and install the particular system (e.g., refrigerated freeboard
device) or equipment addition (e.g., degreaser cover). The capital
cost includes the purchased cost of the major control device, such as
the refrigerated freeboard device coils and compressor; any
8-38
-------
auxiliaries, such as a fan or steam boiler for a carbon adsorber; any
installation involving foundations, building space requirements, and
electrical wiring; and cost of engineering services, contingencies,
start-up, sales tax, and freight costs. The sources of the control
cost information are provided wherever appropriate. All costs are in
terms of second quarter 1978 dollars.
The annualized costs of a control system are what it costs the
individual plant to own and operate that control system on a yearly
basis. The annualized costs include direct operating costs such as
energy, other utilities, maintenance, operating labor, and capital
related charges such as capital recovery, property taxes, and insur-
ance. Whereas actual costs experienced by individual plants in the
operation of degreasers can vary, the following values were selected
as typical and should provide a reasonable estimate of the annualized
costs of the control systems:
(a) Electricity costs at 4.3 cents per kilowatt-hour *^
(b) Steam cost at $7.26 per 1000 kilogram of steam18
(c) Building space cost at $35 per square
(d) Cooling water costs at 7 cents per 1000
(e) Mineral spirits recovery credit at 21 cents per
kilogram"
(f) Trichloroethylene recovery credit at 45 cents per
(g) Maintenance cost at 4 per cent of capital
(h) Taxes, insurance, and administrative costs at 4 per cent of
capital
8-39
-------
Capital recovery charges are based on annualization of the control
system over its economic life and a ten per cent interest rate. The
economic lives of the control systems presented in this chapter are
assumed to be 15 years.
An important element in the determination of the annualized
costs are the annual operating hours and credits for recovered
solvent. For this analysis, 2080 operating hours were assumed per
annum, based on an 8-hour shift and 260 operating days. The amount
of the recovered solvent credit depends upon the operating hours,
solvent type, and operating mode. More information will be presented
on the operating mode in the discussion of model plant parameters for
the various types of degreasers. The value of solvent assumed to be
recovered is based on the use of two types of solvents for the three
types of degreasers discussed further in this chapter. Prices used
in determining credits for mineral spirits and trichloroethylene are
presented above.
8.2.1.2 Alternative Controls
There are two types of controls that can be used in minimizing
organic solvent cleaning emissions housekeeping or operating
practices that entail minimal cost and methods or procedures that
incur direct costs. Housekeeping practices include the operation of
safety covers installed on tanks, preventing spillage of solvents on
the work area floor, and storing waste solvent in closed containers.
No incremental costs for housekeeping controls are presented in this
8-40
-------
chapter. A reasonable judgment is that such costs are negligible,
particularly considering that they are offset by savings in recovered
additional solvent from improved housekeeping.
The scope of this chapter will encompass only specific equipment
features and control devices that can be designed or added on to new
degreasing equipment. There are four major demonstrated emission
control technologies, these being:
(a) Covers for cold cleaners and open top vapor degreasers
(OTVD),
(b) Increased freeboard ratio for OTVD,
(c) Refrigerated freeboard devices for OTVD and conveyorized
degreasers (CD), and
(d) Carbon adsorbers for OTVD and CD.
In addition, drainage racks are effective for reducing emissions from
carry-out losses in cold cleaning operations. Also, drying tunnels
can be effective in reducing emissions during the operation of mono-
rail conveyorized vapor degreasers. Drainage racks and drying tun-
nels will be included in the cost analysis.
8.2.2 Cold Cleaners
8.2.2.1 Model Plant Parameters
The model parameters that were used in developing control costs
for cold cleaners are shown in Table 8-10. These parameters are
based on industry contacts and EPA studies of the solvent degreasing
industry. The most- common type of cleaning is performed with
8-41
-------
Table 8-10. COST PARAMETERS FOR MODEL COLD CLEANERS
Working Area, m^
Solvent Used
Uncontrolled Emission Rate
a) Vaporization, kg/yr
b) Carry-out losses, kg/yr
Controlled Emission Rate
a) Vaporization, kg/yr
b) Carry-out losses, kg/yr
Solvent Recovered by Control
a) Cover, kg/yr
b) Drainage Rack, kg/yr
Typical Size
0.40
Mineral Spirits
(38.9°C)
413
74
63
37
350
37
Large Size
1.2
Mineral
Spirits
1239
74
189
37
1017
37
8-42
-------
mineral spirits. The uncontrolled emission rates in Table 8-10 repre-
sent a typical mode of operation, based on the following:
(a) Twenty loads processed per day for a period of 2 hours per
day (uncovered).
(b) The degreaser remains uncovered during the remaining
operating day, nights and weekends.
The uncontrolled emission rates are based on a vaporization rate of
0.118 kg/hr-m , as determined by EPA emission studies,2^ an{j 14.2
grams per load for emission carry-out loss.
The controlled emission rates represent the following:
(a) Utilizing the cover when the degreaser is not in use with a
control efficiency of 90 per cent for 8240 hours per year.
(b) Utilizing the drainage rack with a 30-second drain time for
520 hours per year with a control efficiency of 50 per
cent, the latter based on emission testing studies per-
formed by EPA.24'25
8.2.2.2 Costs
A summary of capital and annualized control costs is presented
in Table 8-11. The control system consisted of a spring-loaded,
counterweighted cover to reduce vaporization losses and a drainage
rack to reduce carry-out losses. The capital costs are based on
information received from a major manufacturer of cold cleaners.2"
A review of the table shows that credits for recovered solvents as a
result of the controls are significantly greater than the annualized
costs associated with the ownership and operation of the control
8-43
-------
Table 8-11. COSTS OF CONTROLS FOR MODEL COLD CLEANERS
Base Capital Without Controls ($)
Installed Capital ($)
a) Cover
b) Drainage Rack
Total Annual ized Costs
a) Direct operating costs
b) Capital charges, taxes,
insurance, administrative
c) Solvent credit
Controlled emissions (kg/yr)
Cost (Credit), $ per kg controlled
Typical Size
(0.4 m2)
400
51
25
26
(70)
-0-
8.75
(79.00)
376
(0.187)
Large Size
(1.2 m2)
800
104
78
26
(220)
-0-
17.84
(237.00)
1128
(0.194)
8-44
-------
system. The result is a net credit of approximately $0.19 per kilo-
gram solvent recovered for the typical cold cleaner and approxi-
mately $0.20 per kilogram for the large-sized degreaser.
8.2.3 Open Top Vapor Degreasers
8.2.3.1 Model Plant Parameters
The model plant parameters that are used in developing control costs
for open top vapor degreasers (OTVD) are presented in Table 8-12. These
parameters are based on industry contact wand EPA studies on OTVD.
Trichoroethylene is a common solvent used for vapor degreasing. The cost
analysis is based on the use of this solvent. The uncontrolled emission
rates in Table 8-12 represent a typical mode of operation, based on the
following:
(a) During the 8-hour working day, the degreaser is hot and is
assumed to be uncovered and working for six of these hours
(75 per cent of the working day).
(b) The degreaser is idle for the remaining two hours (25 per
cent of the working day) and remains uncovered.
(c) The vaporization rate is 1.82 kilogram/hr-m2 for a hot
degreaser with a freeboard ratio of O.5.27
(d) The carryout loss is 1.47 kilogram/hr-m2.2^
(e) No emissions are assumed to occur during non-working hours
as the degreaser solvent is not boiling and is contained
or covered*
8-45
-------
Table 8-12. ENGINEERING PARAMETERS FOR MODEL
OPEN TOP VAPOR DEGREASERs (OTVD)
00
Working area (m2)
Solvent
Uncontrolled emissions
. (kg/yr)
vaporization
carryout
Emission Reduction
(kg/yr)
By cover
By second system
Spiall OTVD
0.93 (10 ft2)
Trichloroethylene
3,521
2,133
Cover + Cover +
Freeboard Ref.
Free.
Device
581 316
733 2,058
TOTAL 1,314 2,374
Typical OTVD
1.86 (20 ft2)
Trichloroethylene
7,041
4,265
Cover + Cover + Cover +
Freeboard Ref. Carbon
Free. Adsorber
Device
1,162 632 1,493
1,466 4,116 4,570
2,628 4,748 6,063
Large OTVD
5.58 (60 ft2)
Trichloroethylene
21,124
12,796
Cover + Cover + Cover +
Freeboard Ref. Carbon
Free. Adsorber
Device
3,486 1,896 4,480
4,398 12,347 13,700
7,884 14,243 18,180
-------
The emission reductions shown in Table 8-12 are based on the
following assumptions:
(a) Utilizing a cover with a control efficiency of 90 percent
during idle time (2 hours per shift).
(b) Reduction of 27 percent in vaporization losses for the
increased freeboard (ratio of 0.75)
(c) Reduction of 60 percent29»30 ^n vapOrization losses and
20 percental in carryout losses associated with the use
of a refrigerated freeboard device.
(d) Reduction of 70 percent-^ in vaporization losses and 30
percent £n carryout losses associated with the use of a
carbon adsorber.
The most common OTVD sold is a degreaser with a working area of
approximately 2 square meters (20 square feet). This size of de-
greaser is presented as the typical cleaner in Table 8-13. The two
other model cleaners are presented to indicate the spectrum in terms
of working area size.
Another feature of OTVD is that the number of shifts and de-
gree of utilities will vary throughout the solvent cleaning industry.
Two or three shifts per day can be used; idle time can vary from a
likely estimate of 25 percent to perhaps 75 percent. The combination
of one shift and an idle time of 25 per cent was chosen for what is
believed as a typical operating mode in the solvent cleaning industry.
8-47
-------
Table 8-13. COSTS OF ALTERNATIVE CONTROLS FOR OPEN TOP VAPOR DEGREASERS
Small Degreaser
Typical Degreaser
Large Degreaser
Working Area, tn2
Base Capital^1), $
(w/o controls)
Installed Control
Capital ($)
00
oo Total Annualized Costs ($/yr)
(a)Utilities ($/yr)
(b)Maintenance($/yr)
(c)Capital Recovery ($/yr)
(d)Taxes, Insurance, Adm.
(e)Solvent Credit ($/yr)
Controlled emissions, kg/yr
Cost (Credit), $ per kg
0.93 (10
4,365
Cover +
Freeboard
1,606
(278)
0
38
211
64
(591)
1,314
(0.21)
ft2)
Cover +
Ref.
Free.
Device
5,110
80
67
204
672
204
(1,068)
2,374
0.03
1
Cover +
Freeboard
2,362
(721)
0
56
311
95
(1,183)
2,628
(0.28)
.86 (20 ft2)
5,520
Cover +
Ref.
Free.
Device
6,460
(671)
100
258
850
258
(2,137)
4,748
(0.14)
Cover +
Carbon
Adsorber
17,475
1,180
212
699
2,298
699
(2,728)
6,063
0.19
5
Cover +
Freeboard
4,482
(2,661)
0
102
603
183
(3,548)
7,884
(0.34)
.58 (60 ft2)
10,650
Cover +
Ref.
Free.
Device
11,330
(3,749)
200
453
1,490
453
(6,409)
14,243
(0.26)
Cover +
Carbon
Adsorber
26,190
(1,883)
758
1,048
3,444
1,048
(8,181)
18,180
(0.10)
-------
8.2.3.2 Costs
A summary of the capital and annualized control costs for OTVD
is presented in Table 8-13. The basis for determining the costs for
increased freeboard height, covers, and refrigerated freeboard de-
vices is the working area of the degreaser. For carbon adsorbers,
design considerations are based on the amount of solvent emissions
generated at an exhaust rate of 15 cubic meters per minute per square meter
2 34
(50 cfm per ft ) of degreaser area. Sources of cost information were manu-
35 36
facturers of degreaser covers, freeboards, and refrigerated freeboard
37
devices. Carbon adsorber costs were obtained from manufactur-
er.^° The capital costs for the controls include freight, instal-
lation, and sales taxes. It was assumed that a 15 percent charge
added to the list price of control equipment would cover freight,
sales taxes, and insurance. This assumption is based on contacts
with industry vendors.
Capital costs for basic degreasing equipment (without controls)
are also shown in Table 8-13. These are list prices based on heavy
duty, single sump degreasers.39 OTVD are sold in a variety of
models. For single sump models, their price range from $1200 for a
very small degreaser (approximately 0.5 square meter) to $5300 for an
approximate 4 square meter (large) degreaser. Two sump models are
approximately twice as expensive, and three sump models are about
three times as expensive as single sump units. OTVD equipped with
ultrasonic cleaners are considerably more expensive; a very small two
sump model of approximately 0.6 square meter may cost nearly $11,000.
8-49
-------
The annual capital cost recovery for carbon adsorbers shown in
Table 8-13 includes an estimate for building space requirements. For
example, building space is $2000 for the carbon adsorber on the typi-
cal degreaser; $4600 for the large degreaser. The basis for these
costs is $35 per square foot cited earlier. Manufacturers of carbon
adsorbers provided estimates of building space requirements.
In reviewing Table 8-13 for the annualized costs, one can ob-
serve that the cost of control systems generally are more than offset
by the recovered solvent credits. The exceptions are the refriger-
ated freeboard device on the small degreaser and the carbon adsorber
on the typical degreaser. (The annualized cost of a carbon adsorber
before solvent credit would be approximately the same for the small
degreaser as for the typical degreaser, but solvent credits would
only be half as much as for the typical degreaser.) The results of
controlling emissions using a freeboard and cover are a net credit of
$0.21 per kg of solvent recovered for small degreaser to a credit of
$0.34 per kg of solvent recovered for the large model. The results
for using the refrigerated freeboard device are a cost of $0.03 per
kg solvent recovered for the typical model and a credit of $0.26 per
kg solvent recovered for the large unit. The carbon adsorber and
cover result in a cost of $0.19 per kg for the typical unit and a net
credit of $0.10 per kg for the large unit. These results are derived
from an analysis which also includes the solvent savings due to cne
cover.
8-50
-------
8.2.4. Conveyorized Vapor Degreasers (CVD)
8.2.4.1 Model Plant Parameters
The model plant parameters that were used in developed control
costs for conveyorized degreasers are presented in Table 8-15 for
monorail and crossrod designs. These parameter selections are based
on industry contacts and EPA studies of the industry, in the same
manner as cold cleaners and open top vapor degreasers. The emission
rates in Table 8-15 represent typical values. The working area is
used to determine costs for refrigerated freeboard devices. The
assumption used to estimate refrigerated freeboard device costs is
that the cost of the device for a CVD is equal to that for an OTVD of
twice the area.^0 The recovered solvent values and the cost of
solvent are used to estimate solvent credits which will reduce the
annualized control costs of the control devices. The emission con-
trol estimates on which the analysis is based are given in Table
8-14. The CVD is assumed to run one shift, 260 days/year.
Table 8-14. EMISSION CONTROL ESTIMATES FOR CVD
Solvent concentations41
Crossrod
Monorail
Monorail and drying tunnel
Reduction in solvent loss (adsorber)
Monorail4^
Monorail and drying tunnel*"
Reduction in loss (refrigerated
freeboard device)43 ^ 40%
Kilograms steam/kilogram solvent . 3
3 2 45 !
Ventilation rate (m /rain per m ) j 20
750 ppm
900 ppm
1,125 ppm
50%
60%
75%
8-51
-------
Table 8-15. ENGINEERING PARAMETERS FOR MODEL
CONVEYORIZED VAPOR DEGREASERS (CVD)
Working Area (m2)
Sdlvent
Uncontrolled emissions
(kg/yr)
Emission reduction
(kg/yr)
in
Crossrod +
ref. free.
device
4.65(50 ft2)
Trichloroethylene
28,850
11,540
Crossrod +
adsorber
4.65(50 ft2)
Trichloroethylene
29,120
14,560
Monorail +
adsorber
4.65(50 ft2)
Trichloroethylene
28,950
17,370
Monorail, adsorber,
drying tunnel
4.65(50ft2)
Trichloroethylene
38,950
21,710
-------
8.2.4.2 Control Costs
Costs for control of emissions from conveyorized degreasers have
been developed for the following control devices:
Carbon adsorbers
Refrigerated freeboard devices.
Table 8-16 presents the costs for the model conveyorized de-
greasers. Costs are presented in terms of installed capital costs,
annualized costs, and the cost per kilogram of solvent control-
led. Costs are presented for a crossrod with a refrigerated free-
board device, a crossrod and a monorail with carbon adsorbers and a
monorail with a drying tunnel and an adsorber.
Installation of an adsorber saves from $0.12 to $0.19 while
installation of a refrigerated freeboard device saves even more per
kilogram controlled. A drying tunnel also reduces solvent losses if
the work being degreased is so physically configured as to cause
excessive carryout loses.
All savings are computed on the basis that desorption steam is
available and that excessively long runs of exhaust ducts and in-
sulated steam pipes are not required.
»
8.2.5 Cost Effectiveness
8.2.5.1 Open Top Vapor Degreasers
The purpose of this section is to provide a graphical analysis
of the cost-effectiveness of alternative control options to various
types of open top vapor degreasers. This analysis will attempt to
8-53
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Table 8-16. COSTS OF ALTERNATIVE CONTROLS FOR CONVEYORIZED VAPOR DEGREASERS
00.
Crossrod
and Refrigerated
Freeboard Device
Base Capital Cost ($)
Control Cost ($)
Total Annual ized
Cost ($/yr)
(a) Utilities
(b) Maintenance
(c) Capital Recovery
( d ) Taxe s , Ins ur anc e
(e) Solvent Credit
Emission Reduction
(kg/yr)
Cost/credit ($/kg)
38,000
11,490
(2,428)
334
460
1,511
460
(5,193)
11,540
(0.21)
Crossrod
and Adsorber
38,000
19,860
(1,679)
673
794
2,612
794
(6,552)
14,560
(0.12)
Monorail
and Adsorber
47,000
19,860
(2,880)
737
794
2,612
794
(7,817)
17,370
(0.17)
Monorail, Adsorber,
Drying Tunnel
47,000
23,420
(4,126)
833
794
3,080
937
(9,770)
21,710
(0.19)
-------
relate the annualized cost per kilogram of solvent removal with
degreaser size for each control option.
Figure 8-1 is a presentation of the typical relationship for
control of solvent emissions from open top vapor degreasers.
Curves are shown for carbon adsorbers, refrigerated freeboard
devices, and extended freeboards. In addition, all OTVD are equipped
with covers. The size range shown in Figure 8-1 represents the
approximate range of most degreasers (0.5 square meters to 25 square
meters) based on EPA data, contractor studies, and contacts with
degreaser manufacturers. The costs/kg of the control devices shown
represent the capability of the control device for reducing emissions
from a well maintained degreaser assuming all good housekeeping
practices are followed. Although detailed costs are presented for
three model degreasers in Section 8.2.3 several more estimates were
derived in order to define the curves with reasonable precision.
An important concept of degreaser emission controls is the fact
that credits for recovered solvent frequently offset the annualized
costs of installing, operating, and maintaining a control device. In
reviewing Figure 8-1, one can observe the extent to which solvent
credits can more than offset the annualized costs of the control de-
vice. This is graphically illustrated by the horizontal breakeven
line. This line indicates that application of carbon adsorbers will
result in an out-of-the-pocket expense to the operator of a degreaser
which is less than approximately 3.4 square meters in working area.
8-55
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oo
Oi
0.2
0.1
-0.1
-0.2
Cost/kg
-0.3
-0.4
\
Breakeven
OTVD and Carbon Adsorber
OTVD and Freeboard Chiller
OTVD and Raised Freeboard
0.5
10
Area(ftz)
100
1000
FIGURE 8-1
COST EFFECTIVENESS OF CONTROL OPTIONS
FOR OPEN TOP VAPOR DEGREASERS
-------
Similarly, refrigerated freeboard devices will have the same result
for degreasers smaller than approximately one square meter.
Freeboard ratios of 0.75 seem to always be a worthwhile investment
provided that the raised freeboard can be installed without having to
lower the degreaser by digging a pit.
8.2.5.2 Conveyorized Vapor Degreasers
This section provides a graphical analysis of the cost-effec-
tiveness for alternative control options on conveyorized degreasers.
This analysis will relate the annualized cost per kilogram of
solvent control to degreaser size for each control option.
Figure 8-2 shows a relationship of cost versus size for carbon
adsorbers and refrigerated freeboard devices on monorail degreasers.
The assumptions regarding the size range and control efficiencies are
similar to those outlined for open top degreasers. The size range of
most monorail degreasers is 2.3 to 25 square meters. As shown in
Figure 8-2, the application of carbon adsorption results in an out-
of-the-pocket expense for crossrod degreasers smaller than approxi-
mately 3 square meters in working area. Carbon adsorbers are quite
cost effective for monorail degreasers, particularly larger ones if
*
steam boilers do not have to be installed.
8.2.6 Modified and Reconstructed Facilities
Each modified and reconstructed facility will be a special case,
therefore no specific cost estimates can be given. In the case of a
raised freeboard for an OTVD, the cost analysis was based on the use
8-57
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00
I/I
CD
0.2
0.1
0.
-0.1
-0.2
Cost/kg
-0.3
-0.4
1.0
\
Breakeven
10 0
Area (ro')
Crossrod, Adsorber
Monorail, Adsorber
Monorail, Adsorber, Drying Tunnel
CVD and Chiller
I I I I I
100.0
FIGURE 8-2
COST EFFECTIVENESS OF CONTROL OPTIONS FOR
CONVEYORIZED VAPOR DEGREASERS
-------
of a catwalk to allow workers to see into the degreaser. However, if
the ceiling height is too low to permit raising the freeboard, a pit
may have to be excavated and the OTVD lowered. Excavation costs will
depend on building construction, access to the OTVD, size of the
OTVD, ventilation requirements for the pit, and the need to install
pit drainage. These costs are not quantifiable but they will be at
least comparable with the cost of the OTVD and may be considerably
larger.
Similar remarks can be made concerning carbon adsorbers.
Current technology requires the use of steam for desorption. If a
boiler does not exist at the plant, acquisition costs may be consid-
erable. In addition, since desorption is intermittent, the boiler
will be hot but idling much of the time depending on the degreaser
load and adsorber size. This means the cost of steam will increase
considerably over the estimate in Section 8.2.1.1. If building space
is not available near the degreaser, the adsorber may have to be
raised on a platform if ceiling height permits. The cost of a raised
iron grating platform with attendant catwalks and ladders will depend
on the adsorber size but in any case will be well over $1000. If the
adsorber has to be located away from the degreaser and/or boiler, the
cost of ducting and insulated steam pipes will be a major factor.
In summary, if installation of emission controls on degreasers
requires substantial changes or additions to normal installation
practices, it may be expected that the added costs may be 100 percent
8-59
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larger than the costs of controlling new sources. Information re-
ceived from degreaser manufacturers indicates that major modification
of an existing degreaser is a rare occurrence. The one exception is
the installation of a refrigerated freeboard device on an OTVD. This
practice is becoming more prevalent, and the costs are only slightly
higher than factory installation on a new degreaser.
8-60
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8.3 OTHER COST CONSIDERATIONS
Currently, no regulations exist concerning the discharge of
condensate saturated with solvent from a carbon adsorber. In the
event that such regulations are promulgated and that they affect
condensate discharge from adsorbers, an additional control may be
required to remove the solvent from the condensed steam before it is
discharged. It may be possible to recycle the condensate through the
boiler. No data exist on the effect of solvent in boiler feedwater
on boiler performance, corrosion, or two-phase flow in the boiler
tubes. Safety must be considered since most halogenated solvents
present a fire hazard. Their presence in a boiler may not be permis-
sible due to OSHA or other regulations.
If discharge of steam condensate containing solvent is
prohibited at some time in the future, contract hauling may be used
for disposal of the steam condensate. Based on a contract hauling
cost of $0.30 per gallon, the cost of hauling the steam condensate
from one desorption cycle for an average-sized carbon adsorber will
be about $22.50.
Regulations pertaining to effluents from carbon adsorbers are not
likely to be promulgated in the future. Therefore, an economic
impact analysis of such regulations has not been done.
8-61
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There is not expected to be an incremental increase in the amount
of waste solvent disposed due to the implementation of this standard of
performance. Methods requiring proper transportation and disposal of
hazardous wastes are presently regulated by the Department of Transportation
(DOT) and the Resource Conservation and Recovery Act (RCRA). The limitations
imposed by this standard of performance would not increase the amount of
waste disposed. The additional limitations would require generators
of less than 100 kg of waste solvent per month to containerize their
waste prior to landfilling. Since DOT already has containerization require-
ments for transporting hazardous waste, and since RCRA requires landfilling,
the additional costs of this standard would be zero.
8-62
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8.4 ECONOMIC IMPACT OF ALTERNATIVE EMISSION CONTROL SYSTEMS
8.4.1. Introduction
In this section the economic impacts of three regulatory control
options for organic solvent degreasers are analyzed under two sets of market
conditions. The alternative control options are as follows:
Option 1
(a) Cold Cleaners (CC). Cold cleaners are required to have an
easily closeable cover and an external drain in which drying parts
may be w
Open Top Vapor Degreasers (OTVD) . OTVD are required to have
an easily closeable cover and a freeboard ratio of 0.75.
(c) Conveyorized Vapor Degreasers (CVD) . CVD are required to
have a carbon adsorber to control emissions from vaporization and
carry out .
Option 2
CC and CVD are subject to the controls described in Option 1.
OTVD must be fitted with a cover and a refrigerated freeboard chiller
to control" emissions from vaporization.
Option 3
CC and CVD are subject to the controls described in Option 1.
OTVD must be fitted with a cover and carbon adsorber.
The above regulatory options reflect the range of controls considered
by EPA for cold cleaners .and open top vapor degreasers. Though two types of
control, chillers and carbon adsorbers, are possible control options for
conveyorized vapor degreasers, because of resource constraints only carbon
adsorbers are considered here. The costs associated with carbon adsorbers
are greater than those associated with chillers and consequently any
economic impacts resulting from controls requiring chillers will be less
adverse than the impacts of controls requiring carbon adsorbers for CVD.
8-63
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It should also be noted that the control option recommended as the New
Source Performance Standard in chapter nine is a .combination of options 1
and 2. All OTVD with a surface area greater than one meter square must be
fitted with a refrigerated freeboard chiller or a carbon adsorber. For the
smaller OTVD only a cover and increased freeboard ratio are
necessary. As the distribution of OTVD by size is unknown, it was not possible
to evaluate the selected option. It is, however, possible to say that its
impact will lie between those estimated for options 1 and 2.
The economic impacts of each regulatory control option are investigated
in the context of the following price setting models; (1) full-cost pricing
and (2) full-cost absorption. The full-cost pricing model assumes that all
cost changes are passed forward to consumers by affected firms in such a way
as to maintain existing profit margins and that, because market prices are
determined by marginal costs, in each industry all firms will adjust their
prices in a similar way. The full-cost absorption model assumes that
affected firms absorb all costs, holding prices constant and allowing profit
margins to vary. The full-cost pricing model allows for maximum possible
price changes and related economic impacts while the full-cost absorption
model implies that minimum price changes and economic impacts occur.
Johnston^^ and Bain^^ hav« provided evidence that the market conditions for
full-cost pricing exist in many manufacturing industries.* However, in some
(though not all) of the affected industries market structures are not
compatible with those assumptions. Consequently, it is useful to examine
the impacts of the control options under both sets of market conditions as,
*The necessary market condition for full-cost pricing is that
industries should experience constant costs, i.e., unit costs of production
should be constant over all probable output levels.
»
8-64
-------
taken togther, they provide a measure of the widest possible range of
economic effects that could be associated with each control option.
Combining the three regulatory control options with the two price
setting models yields the following six scenarios:
Scenario 1; Option 1 + full-cost pricing
Scenajrio 2; Option 2 + full-cost pricing
Scenario 3; Option 3 + full-cost pricing
Scenario 4; Option 1 + full-cost absorption
Scenario 5; Option 2 + full-cost absorption
Scenario 6: Option 3 + full-cost absorption
The impact analysis for each of the above scenarios focuses on the
thirty-five 3-digit SIC code manufacturing industries and the 2-digit SIC
code manufacturing industries identified as degreaser users in section 8.1.
It also includes the three transport and service industries (SIC's 401, 458,
and 753) involved in organic solvent degreasing.
8.4.2 Economic Impact Methodology
8.4.2.1 Estimation Procedures
The economic impact analysis is designed to provide information on the
effect of each of the three regulatory control options on five major
categories of economic variables:
1 Output and employment.
2. Production cost and price changes within affected industries.
3. Indirect effects on the general level of prices in the economy.
4. Capital financing.
5. Demand for solvent and for degreasing equipment.
All of these categories will be discussed in the context of scenarios
1-3. Under scenarios 4-6 there are, by assumption, no price changes and
therefore no direct employment and output changes in industries using
degreasers. Under these conditions NSPS's will affect only profitability
levels, solvent use, and capital expenditures on degreasing equipment. In
8-65
-------
scenarios 4-6 the impact analysis is therefore restricted to those three
variables.
The impact analysis for each control option is couched within the
framework of a "Leontief" fixed coefficient production function* for each
affected industry whose parameters are based on 1976 production^ data.
Such production functions imply that given percentage increases in output
can only be achieved if the use of all inputs is increased in the same
proportions as output. It is assumed that the number of degreasers needed
per unit of output is unaffected by the regulatory control options.
However, the control options imply that more equipment and energy, and less
solvent will be used with new and retrofitted degreasers. Consequently,
unit production costs and capital, energy and solvent inputs change as a
result of each control. Given full-cost pricing behavior, price changes
will result from production cost changes, generating changes in the demand
for affected products and consequent adjustments to industry output levels.
The output changes are estimated by the procedures described below and used
to calculate the total impacts of the control options on employment, capital
requirements and the use of degreasers. No such price and output changes
occur under full-cost absorption.
1. Output and Employment Effects* None of the options under
consideration has a direct impact on the manpower required in typical
degreasing operations.^ Thus, any impact on employment levels in a solvent
degreasing industry can only occur indirectly in response to a change
*For a detailed discussion of Leontief production functions see
Intrilligator.49
^"Standard operator training and solvent reporting requirements would
not impose a measurable burden on workers.
8-66
-------
in the demand for the industry's product caused by a price change, itself a
consequence of the control options. It is therefore necessary to calculate
output effects prior to estimating employment impacts. Any control
option-related cost change will, under full-cost pricing, generate an
equivalent price change. The price change moves consumers along their
demand curves for the affected product, altering the quantity purchased and,
consequently, the level of industry output. The change in output is
estimated using the following formula:
Industry
Output
Change
Estimated
percent change
_ in price
Elasticity of
demand for
_industry product_
Pre-standard
industry
_output level_
In order to calculate actual output changes, estimates of percent
changes in industry prices were based on percent cost changes obtained from
the cost data presented in section 8.2. The price elasticities of demand in
manufacturing and service industries used in this study were based on
estimates presented by Kohn.^0 Pre-control industry output levels were
obtained from the Annual Survey of Manufactures.^
The changes in manpower requirements associated with estimated output
changes were calculated on the basis of a fixed input-output relationship.
The fixed input-output coefficient assumption implies that in each industry
the man-hours required to produce one unit of output remain constant over
all output levels. Consequently, employment impacts in each industry may be
calculated by multiplying the manpower required per unit of output, the
labor input-output coefficient, by the estimated change in total output.
The required industry labor input-output coefficients were obtained by
dividing 1976 total industry employment^ levels by 1976 total values of
industry outputs.
8-67
-------
2. Production Cost and Price Changes within Affected Industries. In
scenarios 1-3 direct price impacts were determined on a SIC-by-SIC basis by
assuming that the affected industries would pass on price increases in
proportion to the control-related cost increases. The industry-by-industry
production cost increases faced by affected firms associated with each
control option were estimated in the following way. Total production costs
were assumed to be equal to total values of shipments, all profits being
regarded as normal profits.* For each industry, the proportional change in
production costs caused by the control option is thus the absolute change in
production costs associated with the control option divided by the initial
level of value of shipments. Changes in production costs were calculated by
SIC code industry for each option on the basis of data presented in section
8.2 and information supplied by industry sources (see section 8.4.3). These
estimates were used to compute the percentage cost and price changes caused
by the control options associated with scenarios 1, 2, and 3. As was noted
above, in scenarios 4, 5, and 6 firms are assumed to hold prices constant,
fully absorbing all cost changes.
3. Indirect Price Effects* The indirect price impacts associated with
scenarios 1, 2, and 3 were calculated through the use of the 1967
input-output model.53 Price changes for the 39 SIC's were adjusted to
correspond to the industry groupings in .the 1967 input-output table. The
price changes were then fed into the input-output price model, which
transformed them into indirect changes for 477 categories of personal
consumption expenditure (PCE) items. These price changes were then used to
*Normal profit is defined as a cost of production in economic theory as
it represents the payments which must be provided to the owners of the firm
for the services they supply.
8-68
-------
calculate a weighted average consumer price index (CPI) price change. It
should be noted that, though the structure of American industry has changed
since 1967, the 1967 input-output model on which the estimates of induced
price effects are based is the most up-to-date model currently available for
this purpose.^
4. Capital Financing. Generally a firm affected by the control
regulations will seek to finance the increased capital expenditures
associated with those controls from internal sources of funds because
internal funds are cheaper than external funds. External funds, obtained
from banks or the sale of bonds and stocks, involve transaction costs, risk
premiums and underwriting costs not incurred when equipment purchases are
funded out of profits. Consequently, to the extent that firms are forced
to seek external funds for control-related equipment, so the financing costs
they face will be increased. One measure of the financial burden facing
firms is therefore the ratio of control-related capital requirements to
normal profits. As this ratio increases firms are likely to have more
difficulty in using internal funds to finance control equipment and
therefore are likely to experience higher control related cost changes.
Increased capital requirements may also disrupt existing investment
programs. An indicator of the extent to which this may happen is the ratio
of control-related capital requirements to current investment levels.
Again, as the value of this ratio increases so does the burden of the
controls on the existing investment plans of affected firms.
Empirical measures of the above ratios may be obtained as follows. For
each industry the control costs associated with each degreaser are
8-69
-------
multiplied by the numbers of each type of degreaser in use in the industry
and summed. The resulting industry aggregate control costs are first
divided by total industry profits and then by total industry investment to
obtain the two ratios. The ratios of control equipment expenditures to
industry profits and investment costs thus obtained indicate the impact of
the control options on typical plants which have to acquire new degreasers
for replacement or expansion purposes.
5. The Demand for Decreasing Equipment and Solvent. The firms likely
to be most affected by regulatory controls are producers of degreasing
equipment and solvent. Each of the control options requires firms to
increase their capital expenditures on each new degreaser but leaves
unaffected the number of degreasers required per unit of industry output.
On the other hand, as industry outputs change, the absolute numbers of
degreasers used by firms will change. The impact of different control
scenarios on the number of degreasers used by firms is based upon the data
presented in Table 8-3 which presents estimates of the numbers of each type
of degreaser used per million dollars of output for each industry, i.e., the
degreaser input-output coefficients. The change in total numbers of each
type of degreasing unit by industry was calculated by multiplying degreaser
input-output coefficients by estimated changes in Industry outputs.
Difficulties associated with estimating the average level of emissions
reductions per degreaser achieved under each of the control options make it
impossible to provide meaningful quantitative estimates of reductions in
solvent emissions and solvent use. Consequently, a qualitative discussion
of the impact of the control options is provided in section 8.4.A.
8-70
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8.A.2.2 Limitations of the Analysis
Two key assumptions are adopted in the estimation of the econonic
impacts associated with each control option, ^irst, in each industry firrcs
are assumed to follow a common pricing policy, changing prices in proportion
to cost changes under full-cost pricing and holding prices constant in the
face of full-cost absorption. The adoption of the above assumption limits
the analysis in the following way: only the maximum (full-cost pricing) and
minimum (full-cost absorption) possible economic impacts are estimated,
providing a measure of the range within which the economic impacts are
likely to fall. It was not possible to investigate in detail pricing
behavior in each of the 39 industries to obtain a greater degree of
precision in the estimation of control-related economic effects. Second,
all firms in all industries are assumed to utilize identical degreasing
operations. In fact, a wide variety of degreasing operations are utilized
by firms within a given industry as well as across industries^ though it
was not possible to identify such variations on the basis of available data.
Consequently, to the extent that average types of degreasing operations in
each industry differ from the model degreasing operations utilized in this
study so the estimated industry economic impacts will be imprecise.
In conclusion, it should also be noted that the data used to estimate
numbers of degreasers in each industry is not entirely reliable, though it
is the best data available. (See section 8.1.2 (f) and Appendix F).
Consequently, economic impacts are overestimated (underestimated) in
industries where numbers of degreasers are overestimated (underestimated).
8-71
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8.4.3 Costs of Regulatory Control Options
Total annualized costs of controls for each type of degreaser were
developed in section 8.2. These estimates, properly deflated to 1976 prices
for consistency, form the bases for the calculation of total industry
control costs associated with each of the three regulatory control options
and are presented in Table 8-17 on a before- and after-tax basis.*
8.4.4 Economic Impacts
8.4.4.1 Output and Employment Effects.
Only in the case of the full-cost pricing scenarios (scenarios 1-3)
will any output effects occur. Under the full-cost absorption scenarios
(scenarios 4-6) there are no price changes and therefore no changes in
demand, output and employment. Estimates of the output and employment
effects associated with scenarios 1-3 are presented in Table 8-18 together
with the price elasticities of demand and percentage price changes on which
they are based. Four major output implications can be identified.
1. Under each of the three control options, given full-cost pricing be-
havior by firms, the aggregate output of the economy will increase.
2. Under control options 1 and 2 output levels in each of the thirty-
nine affected industries will rise.
3. Under control option 3 output will fall in eleven of the affected
industries and increase in the remaining twenty-eight sectors.
4. The impacts upon industry output levels are relatively small (less
than 0.163 percent of pre-regulation production levels for each
industry under all scenarios).
The increases in industry and local output levels under scenarios 1 and
2 are caused by the cost reductions that result from the implementation of
*Assuning equity funding of control equipment and straight line
depreciation over the life of the equipment for tax purposes, after tax
annualized cost = (1-t) X (Before tax annualized costs), where t measures
the combined state and federal tax rate on corporate income.
8-72
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Table 8-17. Annualized Costs of Controls for Typical Degreasers, 1976 Prices*
Annualized Costs (Dollars)
Before Tax
Control
Options
Option 1
Option 2
Option 3
Type of
Degreaser
CC
OTVD
CVD
CC
OTVD
CVD
CC
OTVD
CVD
Capital
Costs
10
350
3230
10
1000
3230
10
2870
3230
Operating
Costs
-110
-890
-4830
-110
-1380
-4830
-110
-1490
-4830
Total
Costs
-100
-540
-1600
-100
-380
-1600
-100
1380
-1600
Capital
Costs
10
160
1520
10
470
1520
10
1350
1520
After Tax
Operating
Costs
-50
-380
-2270
-50
-650
-2270
-50
-700
-2270
Total
Costs
-40
-220
-750
-40
-180
-750
-40
650
-750
*Source: Section 8.2.
8-73
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Table 8-18. Output Effects, Scenarios 1-3.
00
I
SIC
39
254
259
332
335
336
339
342
343
344
345
346
347
348
349
351
352
353
354
355
356
357
358
359
361
362
364
366
367
369
371
372
376
379
381
382
401
458
753
Industry Short Title
Miscellaneous Industry
Partitions and Fixtures
Misc. Furniture and Fixtures
Iron and Steel Foundries
Nonferrous Rolling and Drawing
Nonferrous Foundries
Hisc. Primary Metal Products
Cutlery. Hand Tools, and Hardware
Plumbing and Heating (except Electric)
Fabricated Structural Metal Products
Screw Machine Products, Bolts, etc.
Metal Gorgings and Stampings
Metal Services
Ordnance and Accessories
Misc. Fabricated Metal Products
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Metal working Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Misc. Machinery, except Electrical
Electric Distributing Equipment
Electrical Industrial Apparatus
Electric Lighting and Hiring Equip.
Communication Equipment
Electronic Components and Accessories
Misc. Electrical Equip, and Supplies
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles, Space Vehicles, Parts
Misc. Transportation Equipment
Engineering and Scientific Instruments
Measuring and Controlling Devices
Railroads - Maintenance
Air Transport - Maintenance
Auto Repair
1976 Output
In Nil lions Elasticity
of Dollars of Demand
16266.0 - .000
1952.3 .000
1040.1 .000
9787.0 .000
10755.5 .500
3569.4 .500
1215.6 .000
7392. 5 .000
2606.0 .000
21563.9 .000
4396.0 .000
15249.7 .000
2677.1
2604.3
12612.1
9009.1
10535.7
19760.6
11278.2
9453.5
14196.5
13722.6
10660.2
6950.5
4666.0
6452.9
7342.0
19156.0
12435.0
6629.0
95581.0
23463.0
7142.0
3117.0
1647.0
6160.0
18536.0
3701.0
13269.0
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
0.400
459014.4
Percent
Change
In Price
0,006
0.023
0.020
0.002
0.001
0.007
0.060
0.014
-0.008
-0.007
0.007
0.002
0.047
0.000
0.009
-0.001
0.005
-0.004
-0.018
-0.005
-0.015
-0.002
-0.003
0.060
-0.010
-0.003
0.018
0.007
0.006
0.004
-0.001
0.006
0.001
0.006
-0.024
0.028
-0.000
0.067
-0.164
Scenario
Percent
Change
in Output
0.006
0.023
0.020
0.002
0.001
0.003
0.060
0.014
0.006
0.007
0.007
0.002
0.047
0.000
0.009
0,001
0.005
0.004
0.016
0.005
0.015
0.002
0.003
0.060
0.010
0.003
0.016
0.007
0.008
0.004
0.001
0,006
0.001
0.006
0.024
0.028
0.000
0.067
0.065
T
Absolute
Change 1n
Output in
Millions
of Dollars
0.943
0.458
0.205
0.151
0.112
0.116
0.990
1.041
0.215
1.493
0.319
0.360
1.366
0.008
1.109
0.049
0.504
0.696
1.998
0.502
2.162
0.301
0.349
4.125
0.461
0.267
1.349
1.392
0.937
0.256
0.727
1.525
0.095
0.202
0.440
1.742
0.069
2.473
8.676
40.247
Percent
Change
In Price
0.006
-0.022
-0.019
0.001
0.001
-0.007
-0.073
-0.013
0.008
0.007
0.007
0.002
0.045
0.000
0.006
0.001
0.005
0.003
-0.017
0.005
-0.014
0.002
0.003
-o.obe
0.009
0.003
-0.016
-0.006
0.007
-0.004
-0.001
-0.006
-0.001
-0.006
-0.022
0.025
-0.000
-0.061
0.164
Scenario
Percent
Change
In Output
0.006
0.022
0.019
0.001
0.001
0.003
0.073
0.013
0.008
0.007
0.007
0.002
0.045
0.000
0.008
0.001
0.005
0.003
0.017
0.005
0.014
0.002
0.003
0.058
0.009
0.003
0.016
0.006
0.007
0.004
0.001
0.006
0.001
0.006
0.022
0.025
0.000
0.061
0.065
~Z ~~
Absolute
Change In
Output In
Millions
of Dollars
0.902
0.435
0.196
0.142
0.103
0.113
0.906
0.964
0.201
1.441
0.306
0.347
1.291
0.008
1.052
0.047
0,464
0.666
1.960
0.499
2.057
0.267
0.336
4.053
0.423
0.266
1.165
1.223
0,647
0.251
0.665
1.340
0.083
0.202
0.403
1.529
0.065
2.255
8.676
36.241
Percent
Change
In Price
-0.002
-0.007
-0.010
0.000
0.000
0.004
0.011
0.000
0.001
-0.004
-0,004
0.001
-0.013
-0.000
0.003
0.000
-0.002
-0,001
-0.013
-0.005
0.004
-0.001
-0.002
-0.046
0.006
0.000
0.012
0.005
0.002
0.003
-0.000
0.004
0.001
-0.006
0.003
0.018
-0.000
0.012
-0.164
-0.006
Percent
Change
in Output
0.002
0.007
0.010
0.000
0.000
0.002
0.011
0.000
o.ooi
0.004
0.004
0.001
0.013
0.000
0.003
0.000
.0,002
0.001
0.013
0.005
0.004
0.001
0.002
0.046
0.006
0.000
-0.012
0.005
0.002
0.003
0.000
0.004
-0.001
0.006
-0.003
-0.018
0.000
-0.012
0.065
0.003
Absolute
Change in
Output in
Millions
of Dollars
O.J93
O.H<4
0.107
0.029
0.012
0.069
0.132
0.011
0.032
0.803
0.176
0.177
0.360
0.004
0.337
0.020
0.233
0.292
1.489
0.465
0.504
0.105
0.198
3.154
0.298
O.OJ7
0.856
-0.879
-0,281
0.19)
0.164
-0.96J
-0.061
0.202
-0.052
-1.116
0.01«
-0.460
8.678
13.277
Source: References5 and 50.
-------
the control technologies. The cost reductions themselves may be explained
by the fact that the value of the solvent savings firms can achieve by
utilizing the control equipment associated with options 1 and 2 exceed the
annualized capital costs of the machinery.
Under control option 3 the costs associated with cold cleaning and
conveyorized degreasing fall but annualized costs associated with open top
vapor degreasing rise. In eleven industries where relatively large amounts
of degreasing are carried out with OTVD's* the cost increases associated
with the OTVD controls outweigh the cost decreases associated with CC and
CVD controls. The result is a net increase in production costs and prices,
and a decline in industry outputs. In the remaining twenty-eight industries
the cost increases associated with OTVD's were more than offset by the cost
decreases associated with CC's and CVD's, resulting in net cost reductions,
price decreases and output increases in those industries. Under option 3
the net impact upon aggregate output is positive as the total fall in output
in the eleven cost-increasing industries is smaller than the total increase
in output in the remaining twenty-eight cost-decreasing industries.
The percent output changes are small for all industries under all
scenarios because the percent changes in production costs and prices
resulting from the control options are small. This is a consequence of the
fact that solvent metal degreasing is only a tiny part of the total
production process in most industries (see section 8.1.2).
Output effects are largest under scenario 1, become smaller under
scenario 2 and are smallest under scenario 3 because the size of cost and
*These eleven-industries, by 3-digit SIC code, are 335, 339, 361, 364,
366, 367, 372, 376, 381, 382, 458.
8-75
-------
price reductions fall (and under option 3 become cost and price increases in
eleven industries) as the control equipment requirements for OTVD's are
expanded from an increased freeboard ratio to a freeboard chiller and,
finally, a carbon adsorber. Though the percent changes in output levels are
small under all control options, the aggregate absolute changes are quite
large: $40.25 millions under scenario 1, $38.24 millions under scenario 2,
and $13.28 millions under scenario 3. In the cases of scenarios 1 and 2
moderate output increases (over SI million) occurred in SIC code industries
342 (cutlery and hand tools), 344 (fabricated metal products), 347 (metal
services), 354 (metal working machinery), 356 (general industrial machin-
ery) , 364 (electrical lighting and wiring equipment), 366 (communications
equipment), 458 (air transport and maintenance) and 753 (auto repairs).
Under scenario 3 moderate output increases occurred only in SIC's 354, 359,
t
and 753. Three industries using relatively large numbers of OTVD's which
experienced moderate output increases under sceanrios 1 and 2, experienced
ouput decreases under scenario 3. These were SIC's 364, 366, and 458.
None of the control options considered here increase the amount of man-
power required to operate degreaslng equipment. Consequently the only
employment Impacts that occur are those caused by control Induced output
changes. Such output changes are zero under scenarios 4-6 and therefore the
associated employment Impacts are also zero. Under scenarios 1-3 price and
output changes occur as a result of the full-cost pricing behavior attribu-
ted to firms. Utilizing the labor Input-output coefficients presented in
column 4 of Table 8-19, changes in manpower requirements were estimated for
each industry under each scenario. Under scenarios 1 and 2, for all indus-
tries other than SIC 753 (where 99 jobs are created) the employment impacts,
8-76
-------
Table 8-19. Additional Employment Requirements, Scenarios 1-3..
oo
SIC
Col. 1
Industry Short Title
Col. 2
Pre-Stindard
Output 1n
Millions of
Dollars
Col. 3
Pn-St*ndard
Employment
In Han Years
Col. 4
Labor-Capital
Ratio
[Col. 2/Col. 3]
scenario l
Col. 5 Col. 6
Change Change In
In Output Employment
In Millions In Han Years
of Dollars [Col. 4 x Col. S]
Scenario 2
col. l
Change
In Output
In H11 lions
of Dollars
col. 8
Change In
Employment
In Han Years
[Col. 4 x Col. 7]
Scenario 3
Cpl. 9
Change
In Output
In Millions
of Dollars
Col. 10
Change in
Employment
1n Han Years
[Col. 4 x Col. 9]
39
254
259
332
335
336
339
342
343
344
345
346
347
348
349
351
352
353
354
355
356
357
358
359
361
362
364
366
367
369
371
372
376
379
381
382
401
458
753
Miscellaneous Industry
Partitions and Fixtures
Misc. Furniture and Fixtures
Iron and Steel Foundries
Nonferrous Rolling and Drawing
Nonferrous Foundries
Misc. Primary Metal Products
Cutlery, Hand Tools, and Hardware
Plumbing and Heating (except Electric)
Fabricated Structural Metal Products
Screw Machine Products, Bolts, etc.
Metal Gorgings and Stampings
Metal Services
Ordnance and Accessories
Misc. Fabricated Metal Products
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Metal work ing Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Misc. Machinery, except Electrical
Electric Distributing Equipment
Electrical Industrial Apparatus
Electric Lighting and Wiring Equip.
Communication Equipment
Electronic Components and Accessories
Misc. Electrical Equip, and Supplies
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles, Space Vehicles, Parts
Misc. Transportation Equipment
Engineering and Scientific Instruments
Measuring and Controlling Devices
Railroads - Maintenance
Air Transport - Maintenance
Auto Repair
16286.0
1952.1
1044.1
9767. 0
1675}.!
1169.4
1215.6
7192.5
2606.0
21581.9
4196.0
15249.7
2677.1
2604.3
12612.1
9009.1
10511.7
19740.6
11276.2
9451.5
14196.5
11722.6
10660.2
6910.5
4686.0
6452.9
7142.0
19116.0
12411.0
6629.0
95161.0
21461.0
7142.0
1117.0
1847,0
6160.0
16516.0
1701.0
11269.0
459014.4
410000
50900
26100
216(00
171100
64700
24600
IS6400
50600
01400
99600
265400
69600
74700.
259200
124600
14600
111500
289500
196200
260700
229400
J72900
20900
104100
194700
159TOO
421500
121000
129600
297100
08000
141700
49700
11500
166900
96500
51100
761000
7775500
25.2
26.1
25.0
22.1
9.1
25.0
19.9
21.4
19.4
18.6
22.7
17.4
31.2
26.6
20.6
13.8
1.4
15.8
25.7
20.8
19.8
16.7
16.2
3.0
22.1
23.0
21.8
22.0
26.0
19.0
3.1
17.4
19.8
15.9
23.6
27.3
26.8
13.8
57.5
0.941
0.458
0.205
0.151
0,112
0.116
0.990
1.041
0.215
1.495
0.119
0.160
1.166
0.008
1.109
'0.049
0.504
0.696
1.996
0.502
2.162
0.101
0.149
4.125
0.461
0,267
1.149
1.192
0.917
0.256
a. 727
1.525
0.095
0.202
0.440
1.742
0.069
2.471
8.678
40.247
24
12
S
3
1
1
20
22
4
26
7
6
41
0
21
I
1
11
51
10
41
S
6
12
11
7 '
29
11
24
5
2
27
2
3
10
46
2
14
499
1075
0.902
0.415
0.196
0.142
0.101
0.111
0.906
0.964
0.201
1.441
o.loe
0.147
1.291
0.008
1.052
0.047
0.484
0.666
1.960-
0.499
2.057
0.287
0.118
4.053
0.42!
0.268
1.165
1.221
0.847
0.251
0.6BS
1.140
0.061
0.202
0.401
1.529
0.065
2.255
8.676
16.241
21
11
S
1
i
1
16
21
4
27
7
6
40
0
22
1
I
11
SO
10
41
5
S
12
9
6
26
27
22
5
2
21
2
1
9
42
2
11
499
1015
0.39}
0.144
0.107
0.029
0.012
0.069
-0,112
0,01 1
0.0)2
0.601
0,176
0,177
0.160
0.004
0.117
0.020
0.211
0.292
1.169
0.465
0.504
0.105
0.196
1.154
0.298
0.037
-0.856
-0.879
-0.261
0.191
0.164
-0.961
-0.064
0.202
-0.052
-1.116
0.014
-0.460
8.678
11.277
10
4
1
1
0
2
-1
0
IS
4
1
11
0
7
0
0
5
38
10
10
i
3
10
-7
1
-19
-19
-7
-------
though positive, are extremely small. The aggregate effect is more sub-
stantial. Under scenario 1 (control option 1) a total of 1,075 jobs are
created and under scenario 2 (control option 2) that total is 1,035. If
control option 3 were to be introduced the number of new jobs would fall to
534, with some industries experiencing small decreases in employment. Only
in one industry (SIC 381) would more than 25 jobs be lost.
It should be emphasized that, as noted in section 8.4.2, the output and
employment impacts based on a full-cost pricing model are maximum estimates
4
and probably overstate the effects of the control options. On the other
hand it is unlikely that the full-cost absorption scenarios which imply zero
output and employment effects in all industries are more realistic. As
pointed out above, empirical evidence and economic theory suggest that firms
do adjust prices in some way in response to cost changes.
8.4.4.2 Production Cost and Price Changes in Affected Industries.
The after tax costs of complying with scenarios 1 and 4 (control option
1), scenarios 2 and 5 (control option 2) and scenarios 3 and 6 (control
option 3) are presented in Tables 8-20A, B, and C respectively. In each
scenario for each industry the installed capital cost of control equipment
and its associated annual capital charge are positive. Annual operating
costs are negative, i.e., annual reductions in firms expenditures on sol-
vents resulting from the controls more than offset Increases in expenditures
on energy and other variable inputs used in degreasing. Under scenarios 1,
2, 4, and 5 (control options 1 and 2) annual operating costs in all indus-
tries fall by a larger amount than annual capital charges rise. Changes in
annualized total costs are consequently negative. Under scenarios 3 and 6
(control option 3) in industries where OTVD's are used relatively inten-
sively compared to CC's and CVD's annual operating costs fall by a smaller
8-78
-------
Table 8-20A. Total Compliance Costs: Scenarios 1 and 4.
oo.
I
SIC
39
254
259
332
335
336
339
342
343
344
345
346
347
348
349
351
352
353
354
355
356
357
358
359
361
362
364
366
367
369
371
372
376
379
381
382
401
458
753
Installed
Capital
Cost
Industry Short Title ($ millions)
Miscellaneous Industry
Partitions and Fixtures
Hisc. Furniture and Fixtures
Iron and Steel Foundries
Nonferrous Rolling and Drawing
Nonferrous Foundries
Hisc. Primary Metal Products
Cutlery, Hand Tools, and Hardware
Plumbing and Heating (except Electric)
Fabricated Structural Metal Products
Screw Machine Products, Bolts, etc.
MetiO Gorging* and Stampings
Metal Services
Ordnance and Accessories
Misc. Fabricated Metal Products
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Metal working Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Misc. 'Machinery, except Electrical
Electric Distributing Equipment
Electrical Industrial Apparatus
Electric Lighting and Wiring Equip.
Communication Equipment
Electronic Components and Accessories
Misc. Electrical Equip, and Supplies
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles, Space Vehicles, Parts
Misc. Transportation Equipment
Engineering and Scientific Instruments
Measuring and Controlling Devices
Railroads - Maintenance
Air Transport - Maintenance
Auto Repair
1
1
0
0
0
0
3
3
0
2
0
0
I
0
2
0
0
1
2
0
5
0
0
a
i
0
4
tl
2
0
I
5
0
0
0
4
0
1
13
62
.465
.294
.039
.409
.785
.J79
.511
.257
.593
.675
.562
.690
.396
.015
.642
.092
.9«3
.364
.428
.400
.245
.643
.560
.822
.620
.596
.567
.701
.616
,27,>
.448
.338
.339
.126
.834
.346
.061
.598
.577
.685
Annual
Capital
Charge
($ millions)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
1
0
0
0
0
0
0
0
1
0
0
0
0
(I
0
2
17
.310
.274
.093
.087
.166
.080
.742
.689
.125
.566
.119
.146
.718
.003
.559
.019
.200
.288
.513
.085
.109
.136
.118
.020
.343
.126
.966
.994
.558
.058
.306
.129
.072
.027
.176
.919
.017
.761
.871
.486
Operating
Costs
($ millions)
1
0
-0
0
0
-0
-1
-1
-0
-2
0
0
-2
-0
-1
-0
0
0
-2
0
-3
0
-0
5
0
-0
-2
-2
-1
-0
-1
2
-0
-0
-0
2
0
-3
-24
-70
.253
.732
.298
.238
.390
.313
.732
.730
.340
.058
.438
.506
.084
.011
.668
.069
.704
.984
.512
.587
.291
.437
.468
.145
.823
.413
.315
.387
.495
.314
.033
.654
.167
.229
.616
.661
.086
.234
.567
.978
Total
Annual ized
Cost
($ millions)
-0
0
-0
0
0
0
0
1
0
1
-0
0
1
-0
1
0
-0
0
1
0
-2
0
-0
-4
-0
-0
-1
1
-0
-0
-0
I
-0
0
-0
-1
-0
-2
-21
.. -5i
.943
.458
.205
.151
.224
.232
.990
.041
.215
.493
.319
.360
.366
.008
.109
.049
.504
.696
.998
.502
.182
.301
.34S
.125
.461
.287
.349
.392
.937
.256
.727
.525
.095
.202
.440
.742
.069
.473
.695
.49?
Total Annual ized
Cost as a Percent
of Projected 1978
Output
(Percent)
-0.
0.
0.
-0.
0.
0.
0.
-0.
o.
-0.
-0.
-o.
0.
o.
0.
0.
-0.
o.
0.
0.
-0.
0.
0.
-0.
0.
0.
-0.
-o.
-o.
-0.
-0.
-0.
o.
0.
0.
0.
0.
-o.
o.
-o.
006
023
020
002
001
007
080
014
008
007
007
002
047
000
009
001
005
004
018
005
015
002
003
060
010
003
016
007
008
004
001
006
001
006
024
028
000
067
164
012
Source: Reference 5; Table 8-17.
-------
Table 8-20B. Total Compliance Costs: Scenarios 2 and 5.
oo
i
oo
o
SIC
39
254
259
332
335
336
339
342
343
344
345
346
347
348
349
351
352
353
354
355
356
357
358
359
361
362
364
366
367
369
371
372
376
379
381
382
401
458
753
Installed
Capital
Cost
Industry Short Title {$ millions)
Miscellaneous Industry
Partitions and Fixtures
Misc. Furniture and Fixtures
Iron and Steel Foundries
Nonferrous Rolling and Drawing
Nonferrous Foundries
Misc. Primary Metal Products
Cutlery, Hand Tools, and Hardware
Plumbing and Heating (except Electric)
Fabricated Structural Metal Products
Screw Machine Products, Bolts, etc.
Metal Gorgings and Stampings
Metal Services
Ordnance and Accessories
Misc. Fabricated Metal Products
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Metalworking Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Misc. Machinery, except Electrical
Electric Distributing Equipment
Electrical Industrial Apparatus
Electric Lighting and Wiring Equip.
Communication Equipment
Electronic Components and Accessories
Misc. Electrical Equip, and Supplies
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles, Space Vehicles, Parts
Misc. Transportation Equipment
Engineering and Scientific Instruments
Measuring and Controlling Devices
Railroads - Maintenance
Air Transport - Maintenance
Auto Repair
2
1
0
0
1
0
s
4
0
3
0
0
S
0
3
0
1
2
3
0
7
0
0
6
2
0
a
a
4
0
2
9
0
0
1
8
0
6
13
126
.353
.801
.596
.607
.165
.531
.323
.922
.669
.790
.793
.987
.020
.022
.691
.140
.363
.016
.250
.460
.957
.961
.604
.390
.679
.999
.130
.371
.60S
.375
.359
.355
.596
.126
.630
.962
.169
.337
.577
.540
Annual
Capital
Charge
($ millions)
0
0
0
0
0
0
1
1
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
1
0
0
1
1
0
0
0
1
0
0
0
1
0
1
2
26
.496
.381
.126
.126
.251
.112 «
.126 '
.041
.186
.801
.168
.209
.062
.005
.623
.030
.292
.426
.687
.097
.663
.203
.170
.351
.609
.211
,719
.770
.974
.079
.499
.978
.126
.027
.345
.695
.036
.763
.871
.760
Operating
Costs
($ millions)
-1.399
-0.816
-0.324
-0.270
-0.456
-0.338
-2.032
-2.005
-0.389
-2.243
0.476
0.5S5
-2.353
-0.012
-1.875
0.077
-0.777
-1.092
-2.648
-0.596
-3.740
-0.490
-O.SOB
-5.404
-1.032
0.479
-2.904
-2.994
1,820
-0.331
-1.184
-3.318
-0.209
-0.229
-0.746
-3.424
0.100
-4.016
-24.567
78.233
Total
Annuallzed-
Cost
($ millions)
-0.902
0.
0,
435
198
0.142
-0.
0.
0.
-0.
-0.
-1.
-0.
-0,
-I.
-0.
1.
0.
-0.
0.
-1.
-0.
-2.
0.
-0.
4.
0.
0.
1.
-1.
"0.
0.
-0.
1.
-0.
-0.
-0,
-1.
-o.
-2,
-21.
-SI.
205
225
906
964
201
441
308
347
291
008
052
047
484
666
960
499
057
287
338
053
423
268
185
223
847
251
685
340
063
202
403
529
06S
2«>5
695
473
Total Annuallzed
Cost as a Percent
of Projected 1978
Output
(Percent)
-0.006
-0.022
0.019
-0.001
-0.001
-0.007
-0.073
-0.013
-0.008
-0.007
-O.OOT
0.002
0.045
O.Oi'O
0.008
-0.001
-O.OOb
-0.003
-0.017
0.005
-0.014
0.002
0.003
0.096
-0.009
0.003
-0.016
-0.006
-0.007
-0.004
-0.001
0.006
0.001
-0.006
0.022
0.025
-0.000
-0.061
-0.16*
0.011
Source: Reference 5; Table 8-17.
-------
Table 8-20C. Total Compliance Costs: Scenarios 3 and 6.
oo
i
00
SIC
39
254
259
332
335
336
339
342
343
344
345
346
347
348
349
351
352
353
354
355
356
357
358
359
361
362
364
366
367
369
371
372
376
379
381
382
401
458
753
Industry Short Title
Miscellaneous Industry
Partitions and Fixtures
Misc. Furniture and Fixtures
Iron' and Steel Foundries
Nonferrous Rolling and Drawing
Nonferrous Foundries
Misc. Primary Metal Products
Cutlery, Hand Tools, and Hardware
Plumbing and Heating (except Electric)
Fabricated Structural Metal Products
Screw Machine Products, Bolts, etc.
Metal Gorgings and Stampings
Metal Services
Ordnance and Accessories
Misc. Fabricated Metal Products
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Metalworklng Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Misc. Machinery, except Electrical
Electric Distributing Equipment
Electrical Industrial Apparatus
Electric Lighting and Wiring Equip.
Communication Equipment
Electronic Components and Accessories
Misc. Electrical Equip, and Supplies
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles, Space Vehicles, Parts
Misc. Transportation Equipment
Engineering and Scientific Instruments
Measuring and Controlling Devices
Railroads - Maintenance
Air Transport - Maintenance
Auto Repair
Installed
Capital
Cost
($ millions)
4. 918
3.266
1.052
1.179
2.342
0.970
10.562
9.715
1.745
7.010
1.462
1.643
9.716
0.043
7.500
0.277
2.653
3.900
5.627
0.631
15.794
1.660
1.510
10.923
6.517
2.165
18.427
18.977
10.295
0.671
4.991
20.964
1.340
0.126
1.927
22.105
0.424
22.015
11.577
253. 280
Annual
Capital
Charge
($ millions)
1.040
0.691
0.222
0.249
0.495
0.205
2.234
2.059
0.369
1.483
0.309
0.390
2.055
0.009
1.566
0.059
0.561
0.625
1.190
0.131
1.140
0.396
0.119
2.110
1.378
0.458
1.897
4.011
2.177
0.142
1.055
4.411
0.283
0.027
0.810
4.717
0.090
4.660
2.H7I
51.562
Operating
Costs
(J millions)
1.431
0.835
0.330
0.278
0.471
0.344
2.102
2.069
0.401
2.285
0.485
-0.567
-2.415
-0.013
1.923
-0.076
-0.794
-1.117
-2.679
-0.599
3.644
0.502
-0.518
-5.464
-1,080
-0.495
-3.041
-1.114
-1.896
0.314
1.219
-1.472
-0.219
-0.229
-0.778
-1.601
-0.104
-4.200
-24.567
-79.914
Total
Annualized
Cost
($ millions)
0.393
0.14U
0.107
0.029
0.024
0.116
0,112
0.01 1
0.012
0.803
-0. 176
-0.177
0.160
0.004
0.337
0.020
0.233
-0.292
1.489
-0.465
0.504
0.105
0.198
1. 154
0.296
0.037
0.856
0.879
0.281
0.191
0.164
0.961
0.064
-0.202
0.052
l.llt
0.014
0.460
-21.695
-26.1b2
Total Annualized
Cost as a Percent
of Projected 1978
Output
(Percent)
-0.002
-0.007
-0.010
0 .000
0.000
0. 004
On t i
V I 1
0 o An
V . V V V
0 001
V . V V 1
-0 . 004
0.004
-0.001
-0 0 1 X
V U 1 J
0 .000
-0.001
0 .000
-0 OOP
V . V V c
-O.GO 1
V . V V i
-0 Oil
V . V i J
-0.005
0.0 04
0 .U U i
0.002
0 . C UO
0 . 006
0. 000
0.012
0 OOK
V . U V J
A A A 3
V . V V £
-0 00 \
V . V U J
-0 .000
OOA/I
. V V M
0.001
V . V V t
0 . 006
0.001
00 I M
. V 1 o
-0.000
0.012
-0. 164
-0TOo«.
Source: Reference 5; Table 8-17.
-------
amount than the increase in annual capital charges associated with the con-
trol equipment. Consequently, for those 11 industries total annualized
costs rise, though by less than two'hundredths of a percentage point of the
value of total output in each case. (See Table 8-20.C.)
The percentage changes in costs presented in Table 8-20 equal percent-
age changes in prices under scenarios 1-3. The relevant price changes are
presented in Table 8-21. Prices are assumed to be unaffected by cost
changes under the full-cost absorption scenarios.
8.4.4.3 Induced Price Effects.
Using the 1967 input-output model for the U.S. economy the impact upon
the general level of prices in the U.S. economy (measured by the implied
change in the consumer price index) under scenarios 1 and 2 was estimated to
be a 0.015 percent decrease in the CPI. Under scenario 3 the fall in the
CPI was estimated to be 0.015 percent. There are no inflationary impacts
under scenarios 4-6.
8.4.4.4 Capital Financing.
Each control option requires a substantial increase in the capital
costs of degreasing units. However, funding of the necessary capital ex-
penditures does not appear to pose a serious problem for affected firms for
two reasons: (1) the relatively small role of degreasing in firms' pro-
duction processes and (2) the solvent savings achieved by firms using the
controls which substantially offset the associated capital costs (see Table
8-17). The size of the impacts of each control option on the capital finan-
cing position of firms affected by the controls is evaluated below for both
the full-cost pricing and full-cost absorption scenarios. It should be
8-82
-------
Table 8-21. Direct Price Effects, Scenarios 1-3.
oo
I
cc
SIC Industry Short Title
39 Miscellaneous Industry
254 Partitions and Fixtures
259 M1sc. Furniture and Fixtures
332 Iron and Steel Foundries
335 Nonferrous Rolling and Drawing
336 Nonferrous Foundries
339 Misc. Primary Metal Products
342 Cutlery, Hand Tools, and Hardware
343 Plumbing and Heating (except Electric)
344 Fabricated Structural Metal Products
345 Screw Machine Products, Bolts, etc.
346 Metal Gorgings and Stampings
347 Metal Services
348 Ordnance and Accessories
349 Misc. Fabricated Metal Products
351 Engines and Turbines
352 Farm and Garden Machinery
353 Construction and Related Machinery
354 Metal work ing Machinery
355 Special Industrial Machinery
356 General Industrial Machinery
357 Office and Computing Machines
358 Refrigeration and Service Machinery
359 M1sc. Machinery, except Electrical
361 Electric Distributing Equipment
362 Electrical Industrial Apparatus
364 Electric Lighting and Wiring Equip.
366 Communication Equipment
367 Electronic Components and Accessories
369 Misc. Electrical Equip, and Supplies
371 Motor Vehicles and Equipment
372 Aircraft and Parts
376 Guided Missiles, Space Vehicles. Parts
379 Misc. Transportation Equipment
381 Engineering and Scientific Instruments
382 Measuring and Controlling Devices
401 Railroads - Maintenance
458 Air Transport - Maintenance
753 Auto Repair
Scenario 1:
Percent Change
in Price
-0,0058
-0.0235
-0.0|9b
-O.OOlb
-0.0012
-0.0069
-o.oaoi
-0.0141
-0.0082
U.0069
-0.0073
-0.0024
-0.0475
-0.000)
-o.ooae
-0.0005
-0.0046
-0.0035
-O.OJ77
-0.0053
-0.0154
-0.0022
-0.0033
-0.0595
0.0101
-0.0034
-0.0184
-0.0073
0.0075
-0.0037
-0.0008
-0.006S
0.0013
-0.0065
-0.0238
-0.0262
-0.0004
-0.0668
-O.lfcJS
Scenario 2:
Percent Change
in Price
O.OOS5
-0.0223
0.0189
0.0015
0.0011
0.0066
0.0734
0.0130
0.0077
0.0067
0.0070
-0.0023
0.0449
-0.0003
-0.0063
-O.OOOS
-0,0046
-0.0034
-0.0174
-0.0053
-0.014S
-0.0021
-0.0032
-0.0585
-0.0090
-0.0032
-0.0161
-0.0064
0.0068
-0.0037
-0.0007
-0,0057
-0.0012
0.0065
0.0218
0.0247
-0.0003
-0.0609
-0.1635
Scenario 3:
Percent Change
in Price
-0.0024
-0.0074
-0.0103
-0.0003
0.0001
-0.0041
0.0107
0.0001
0.0012
-0.0037
-0.0040
-0.0012
0.0125
-0.0001
0.0027
-0.0002
-0.0022
-0.0015
-0.0132
-0.0049
-0.0035
-0.0006
-0.0019
-0.04S5
0.0064
-0.0004
0.0117
0.0046
0.0023
-0.0026
-0.0002
0.0041
0.0009
-0.0065
0.0028
0.0161
-0.0001
0.0124
-0.1635
Source: Table 8-20.
-------
noted that the impact of the control options on rates of return on invest-
ment for firms adopting the control technology are not examined as it was
not possible to identify typical model industrial plants for all of the
affected SIC code 3-digit industries. Data on financing is presented in
Table 8-22.
(a) Full-Cost Pricing Scenarios (1-3). If full-cost pricing is assumed
then product prices will be adjusted in a way which leaves profit rates
constant for firms affected by the regulatory controls. Thus, in the
analysis of scenarios 1-3 the ratio of total annualized costs to normal
profits is of little interest as it indicates the magnitude by which profits
change only if, when costs of production change, product prices are held
constant. However, the ratio of installed capital cost to normal profit is
a matter of concern. As was noted above, the cheapest funds available to a
firm for financing new pollution control equipment are internal funds, i.e.,
its profits. Thus, the ratio of the installed capital cost of new pollution
control equipment to normal profits is an indicator of both the likely cost
to the firm of financing new equipment and the difficulty it will face in
acquiring funds for the investment. As the ratio increases the firm becomes
more likely to seek funds from external sources which are more costly and
more difficult to tap.
Under scenarios 1 and 2 the ratio of the installed capital cost of
pollution controls to normal profits is relatively small. In no case are
the additional capital costs more than 6.2 percent of normal profit. Thus
affected firms in all industries could be regarded as having little
difficulty in funding the purchase of the pollution control equipment
recommended under control options 1 and 2. If carbon adsorbers were to be
8-84
-------
Table 8-22. Effects of Control Options of Profit Rates,
Capital Availability and Investment
Scenarios i and fl
scenarios Z and
SIC Industry Short Title
19* Miscellaneous Industry
254 Partitions and Fixtures
259 Misc. Furniture and Futures
332 Iron and Steel Foundries
33S Nonferrous Rolling and Drawing
336 Nonferrous Foundries
339 Misc. Primary Metal Products
342 Cutlery, Hand Tools, and Hardware
343 Plumbing and Heating (except Electric)
344 Fabricated Structural Metal Products
34S Screw Machine Products. Bolts, etc.
346 Metal Gorging: and Stampings
347 Metal Services
348 Ordnance and Accessories
349 Misc. Fabricated Metal Products
351 Engines and Turbines
352 Farm and Garden Machinery
3S3 Construction and Related Machinery
3S4 Metalworklng Machinery
355 Special Industrial Machinery
3S6 General Industrial Machinery
357 Office and Computing Machines
358 Refrigeration and Service Machinery
359 Misc. Machinery, except Electrical
361 Electric Distributing Equipment
362 Electrical Industrial Apparatus
364 Electric lighting and Wiring Equip.
366 Communication Equipment
367 Electronic Components and Accessories
369 Misc. Electrical Equip, and Supplies
3/1 Motor Vehicles and Equipment
372 Aircraft and Parts
376 Guided Missiles, Space Vehicles, Parts
379 Misc. Transportation Equipment
381 Engineering and Scientific Instruments
382 Measuring and Controlling Devices
401 Railroads - Maintenance
45B Air Transport - Maintenance
753 Auto Repair
Profit
After
Tax as a
Percent
of Sales
».««
1.1S
1.15
1.64
3.6*
1.64,
6.84
8.84
a.eu
.a*
a. 84
a.84
t.a«
a. a*
a. a*
a.ai
a.ai
a. at
a. 41
a. «i
a. !
8.41.
B,»l
a, 6|
.so
«.*»
4.50
4.50
4,50
«.«
J.«
I. 61
1.6Z
1.62
10.11
10.11
1.20
1.62
1.0*
Normal
Investment
Expenditures
($ millions)
560.60
la.oo
21. TO
641.20
ma. 60
U4.40
sa.so
241.00
60,00
617.90
122.00
10.00
108.90
62.20
408.50
297 .60
2a7.50
an .00
162.90
214 .90
468.90
400.10
tai.2o
102.10
85.10
289.10
162. 10
512. BO
650.50
221.70
54.60
411.10
125.90
47 .90
1,40
160 . 10
724.70
559,60
824.10
Ratlu of
Total
Annual lied
Cost to
Normal
Profit
-0.00090
0,00701
-0. 00486
-0.00042
-0.00011
-O.OOIH8
-0.00906
-0,00159
-0.0009)
U.00076
-0.00082
-0.00027
-0.00517
-0.00001
-V. 00100
-0,00006
-0.00057
-0.00042
0.00211
-0.0006)
a. ooi8l
-0.00026
-0.000)9
-0.00708
-0.00226
-0.00075
0,00408
-0.00162
-0,00168
-0,00081
-0,00021
-0.00180
-0.000)7
-0,00179
0.002)5
0.00276
-0,000)1
0.01 646
O.OS176
Ratio of
Installed
Capital
Cost to
Normal
Profit
0.00140
0.01979
0.01254
O.OOMS
0.0011S
0.00)08
0.0)214
0.0049g
0.00257
0.00140
0.00145
O.OOOSI
0.011)5
0.00006
0.002)7
0.00012
0.00106
0.00082
0.002S6
0.00050
0.004)9
0.00056
0.00062
0.00827
0.00768
0.00157
0. 01)82
0.00546
0,00471
0.00088
0.00042
0.00628
0.001 )|
0.001 12
0.00446
0.00694
0,000)6
0.02685
0.0)166
Kalio 01
Installed
Capital
Cost to
Projected
Norm*)
Investment
0.00261
0.0X105
0.02022
0.00064
0.00179
0.00)12
0.06001
0. 01140
0.00961
0.00419
0.00461
0.00161
0.0)118
0.00024
0.00647
0.000)1
0.00)28
0.00lb4
0.00669
0.00186
0.01119
0.001)4
0.00)06
0.0159ft
0.01699
0.00206
0.0281 7
0.00917
0.00405
0.00122
0.02652
0.01216
0.00269
0.00264
0.01679
0.027|«
0.00011
O.C064)
O.OI64/
Ratio Of
Total
Annual Ized
Cost to
Normal
Profit
-0.00066
-0.00665
-0.00565
-0.00040
-0.000)0
-0.0018)
-0.00610
-0.00146
-O.U0067
-0.00076
-0.00079
0.00026
-0.00506
0.0000)
-0.00094
-0.00006
-0.00055
-0.00040
-0.00207
0.0006)
0.00172
0.00025
0.001)16
0.00695
0.00200
-0.00070
C. 00)54
0.00142
0.00151
0.00062
0.00020
0.00158
0.000)2
0.00179
0.00216
0.00244
0.00029
0.0166)
0.05)78
Ratio of
Installed
Capital
Cost to
Normal
Profit
0.00224
0.02754
0.01705
0.00170
0.00174
0.004)1
0.04674
0.0075)
0.00)66
0.00199
0.00204
0.0007)
0.01974
0,00009
0.00)49
0.00016
0.00156
0.00121
0.00)41
0.00056
0.00666
0.0006)
0.00090
0.01096
0.01)65
0.0026)
0.02461
0.00972
0.00821
0.00122
0.00066
O.OIIOI
0.00211
0.00112
0.00871
0. 01112
0.00076
0.06221
0.0)166
Ha tip 01
Installed
Capital
Cost to
Projected
Normal
Investment
0.00420
0.0474)
0.02748
0.00094
0.00270
0.0046a
0.09100
0.02026
0.01472
0.00594
0.00650
0.00229
0.04610
0.00016
0.00952
0.0004T
0.00481
0.0024)
0.00896
0.00214
0.01697
0.00200
0.0011)9
0.02115
0.0)175
0.00)46
0.05015
0.016)2
0.00708
0.00167
0.04)20
0.02170
0.0047U
0.00264
0.0)670
0.05598
0.0002)
0.01690
0.01647
Ratio of
Total
Annul II zed
Cost to
Normal
Profit
-0.000)8
-0.00221
-0.00107
-0.00008
0.0000)
-0.00112
0.00121
0.00002
-0.00014
-0.00042
0.00045
-0.0001 )
-0.00142
0.00001
0.000)0
-0.00001
-0.00026
-0.00016
0.00157
-0.00059
-0.00042
-0.00004
0.00022
-0.0054)
o.ooim
-0.00010
0.00254
0.00102
0.00050
-0.00061
-0,00005
0.001 1)
0.00025
-0.00179
0.00026
0.00176
-0.0000k
0.00)4)
0.05)76
Ratio ol
Installed
Capllal
Cost to
Normal
Prof't
0.00469
O.C4V96
0,0)007
0.001)1
0.00^4)
0.00 /66
0.09*70
0.01 490
0.007S7
0.00367
0.03176
0.001 17
0.0)020
0.00017
0.0067)
0.003)7
O.OOt'99
0.002)5
O.OCS9)
0.00079
0.01 (2)
0.0016}
0.00166
0.01674
0.01089
O.OOS69
O.OV.7;
0.02<'0«
0.01* 40
0, 00<* 1 6
0.001 «5
0.02W66
0.00', lei
0.001 t f
o.otviv
0.01'jD J
o.ooi ti
0. 1 6UU7
0.01'bt,
haiio or
Installed
Capital
Cost to
Projected
Normal
Investment
0.00877
0.06599
0.04A46
O.OOI6J
0.005)4
O.OOH48
0.16055
0.04006
0.02690
0.01094
0.01 196
0.00429
0.06922
0.00069
0.016)6
0.0009)
0.0092)
0.00469
0.01551
0: 0029«
O.OJJ68
O.OOJ9I
0,00624
0,0)616
0.07610
0.00749
0. 1 1 )66
0.0)701
0.0156)
0.00)00
0.09|uO
0. Oufl6 )
0.01 064
0.0026«
O.OBduS
0. 1 )9)j
0.00059
0.019 jg
O.OI&U7
CO
oo
Source: References 5, 57 and 58; Table 8-20.
Note: Normal profit calculated for each industry by multiplying value of output by normal.
-------
required on OTVD's, as is assumed in scenario 3, the picture becomes
relatively less favorable for a number of industries, particularly SIC's
339, 364, and 358, where installed capital costs of pollution controls are
respectively 9.7 percent, 5.6 percent and 16.4 percent of normal profits.
The ratio of installed capital cost to normal investment provides an
additional measure of the ease or difficulty with which an affected firm
will be able to fund purchases of the pollution control equipment. Further,
it indicates the degree of dislocation to which the firm's investment
strategy will be subjected by its need to meet the control requirements.
Again, under options 1 and 2, for all industries this ratio is relatively
small, rising above 5 percent in only two industries (SIC's 339 and 382).
In no industry does the installed capital costs of pollution controls rise
above 10 percent of normal investment levels. Under option 3 the picture
changes slightly. The ratio exceeds 10 percent in 3 industries (SIC's 339,
364 and 382) and lies in the range of 5 to 10 percent for five others (SIC's
254, 347, 361, 371 and 381). This suggests that firms in some industries
would have some difficulty in funding the purchase of carbon adsorbers for
open top vapor degreasers.
b) Full-Cost Absorption Scenarios (4-6). In scenarios 4-6 it is
assumed that firms absorb any cost changes instead of passing those changes
on to consumers in the form of higher or lower prices. Thus-firms are
assumed to retain cost savings or absorb cost increases in the form of
higher or lower profits. The extent to which profit levels would rise or
fall under scenarios 4-6 is indicated by the ratio of total annualized cost
changes to normal profits. In all industries, for all scenarios, that ratio
is very small. Only for two industries (SIC's 458 and 753) does the ratio
8-86
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of the change in annualized costs to normal profits rise above 1 percent in
any scenario. Under scenario 3 the largest value of the ratio for an
industry experiencing cost increases is 0.343 percent.
The low values of the ratios of annualized cost changes to normal
profits indicate that profit levels in solvent metal degreasing industries
will change very little if firms follow cost absorption policies. Conse-
quently the discussion of capital funding under scenarios 1-3 presented
above may be applied to scenarios 4-6.
8.4.4.5. Demand for Degreasing Equipment and Solvent.
a) Decreasing Equipment. Tables 8-23 and 8-24 present the total
changes in numbers of degreasing units generated by scenarios 1-3. The net
impact on numbers of degreasers is very small both for each type of
degreaser in each industry and in total. In fact, only in one industry, SIC
753, did the use of a type of degreaser (cold cleaners) measurably rise.
Under all scenarios changes in numbers of open top vapor degreasers and
conveyorized degreasers are negligible. For cold cleaners, the largest
increase occurs in SIC code industry 73 and represents only 0.05 percent of
pre-standard usage.
Table 8-24 clearly indicates that the net increase in the desired stock
of degreasing units resulting from any control regulation will be negli-
gible. On the other hand, it is possible that some increase in replacement
investment could occur as promulgation of the regulatory controls may bring
the existence of the cost savings to be achieved through the use of control-
led equipment to the attention of degreaser users. Thus it is possible that
producers of degreasers will be faced with an increase in demand for their
8-87
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Table 8-23. Post Standard Use of Degreasing Equipment: By Industry.
00
oo
oo
SIC
39
204
259
332
335
336
339
342
343
344
34S
346
347
348
349
351
3S2
353
354
35S
356
357
358
359
361
362
364
366
367
369
371
372
376
379
381
382
401
458
753
Industry Short Title
Miscellaneous Industry
Partitions and Fixtures
Misc. Furniture and Fixtures
Iron and Steel Foundries
Nonferrous Rolling and Drawing
Nonferrous Foundries
Misc. Primary Hetal Products
Cutlery, Hand Tools, and Hardware
Plumbing and Heating (except Electric)
Fabricated Structural Metal Products
Screw Machine Products. Bolts, etc.
Hetal Gorgtngs and Stampings
Hetal Services
Ordnance and Accessories
Hisc. Fabricated Hetal Products
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Hetalworking Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Hisc. Machinery, except Electrical
Electric Distributing Equipment
Electrical Industrial Apparatus
Electric Lighting and Hiring Equip.
Conmini cation Equipment
Electronic Components and Accessories
Hisc. Electrical Equip, and Supplies
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles/ Space Vehicles. Parts
Hisc. Transportation Equipment
Engineering and Scientific Instruments
Measuring and Controlling Devices
Railroads » Maintenance
Air Transport - Maintenance
Auto Repair
Pre-Standard Numbers
Open Top
Cold Vapor
Cleaners Degreasers
15916
61*6
1265
1992
2246
4056
971*
11691
2772
25111
S409
*692
191*7
112
16024
792
8218
U089
1MS2
104*7
10714
4569
606*
79*47
19*5
atlH
1091!,
11119
1019*
969
10944
11967
l\o
41*6
oOCto
17797
llbl
16160
468027
614
151
109
117
277
tos
125*
1152
20S
771
160
205
1124
5
6*
11
104
4*1
569
41
1676
220
169
1085
S7I
279
246*
2519
1162
71
610
2779
17»
0
5*0
1194
el
3279
0
of Degreasers
Convey or i zed
Vapor
Degreasers
71
til
1»
14
10
2*
111
tai»
49
107
19
SO
<71
1
209
6
i
90
I2i
«
402
«7
15
212
lib
16
1*4
111
1/6
lu
«9
191
-------
Table P-24. Total Utilization of Degreasing Equipment in
SIC's 25, 33-39, 401, 458 and 473
Numbers of
Cold Cleaners
Numbers of
Open Top
Vapor Degreasers
Nunbers of
Conveyorized
Vapor Degreasers
Pre-Standaud
Level
922,227
30339
4492
Scenario 1
(NSPS 1)
922,655
30346
4493
Scenario 2
(NSPS 2)
922,649
30346
4493
Scenario 3
(NSPS 3)
922,571
30338
4492
Source: Table 8-23.
8-89
-------
products as firms seek to replace old machinery with the new and more effi-
cient equipment. It should be noted that an increase in replacement invest-
ment would occur even if controls were not introduced as the proposed tech-
nologies reduce firm operating costs. Nevertheless, the standards should
stimulate the rate of replacement investment by providing solvent metal
degreasers with improved information on their degreasing operations. In
many plants degreasing costs form such a small fraction of total costs that
they are likely to be ignored in firm decision making unless companies are
forcibly required to examine them. Such an examination will be required of
degreasing firms under any of the proposed regulatory controls.
b) Solvent Use* Average solvent savings per degreaser resulting from
the implementation of the control options could not be estimated because of
the unavailability of adequate data on the extent to which such controls are
already in use. Nevertheless, it is likely that solvent use will fall below
what it would otherwise have been as firms replace worn out uncontrolled
degreasers with new controlled degreasers. To the extent that this happens,
solvent producers will be faced with a decline in demand for their product.
It is not clear, however, that this decline in demand for solvent by
degreaser users would lead to lay offs and plant shutdowns. As was noted in
section 8.1.1, the level of solvent use will tend to increase over time as
the economy expands. Thus, the increase in solvent demand attributable to
economic growth may offset the decline in solvent demand caused by the use
of controlled degreasers with lower emmission rates.
8.4.5 Summary and Comparison of Economic Impacts.
Table 8-25 presents the estimated ranges of possible output, employment
and price impacts associated with each of the three control options. The
minimum (zero) impacts are those implied by the full-cost absorption model.
8-90
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Table 8-25 Summary of Economic Impacts
Option 1 Option 2 Option 3
Output Impacts
($106) 40.3 38.2 13.3
Employment Impacts
(jobs per year) 1075 1035 534
Inflationary Inputs
(percent change in
the CPI) -0.015 -0.015 -0.013
Sources: Tables 8-18 and 8-19.
8-91
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The maximum impacts are those implied by the full-cost pricing model. For
each control option the minimum impacts are the samenone. Maximum
possible impacts for employment and output are smallest under option 1, next
smallest under option 2 and largest under option 3. The maximum inflationary
impacts are identical under options 1 and 2 (0.015 percent) and fractionally
smaller under option 3 (+0.013 percent). Any price, employment and output
impacts associated with the implementation of the regulations are likely to
be favorable (i.e., increases in output and employment and a decrease in the
rate of inflation) because the proposed controls will result in cost savings
for affected firms.
It must be emphasized that it was not possible to determine where,
within the estimated impact ranges, the actual impacts would lie. Data on
the extent to which controls are already being utilized by firms, the impact
of the controls on retrofits and replacement rates, and market structures in
each of the 39 affected industries would be required to increase the
precision of the analysis. Such information was not available in 'the
context of this study.
8-92
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8.5 POTENTIAL SOCIO-ECONOMIC AND INFLATIONARY IMPACTS
The proposed new performance standard, whose economic impacts lie
between those estimated for control options 1 and 2 in section 8.4, will
have negligible impacts on the following key variables: compliance
costs, total additional costs of production of major industry products
and services, net national energy consumption, and use of key metals and
chemicals.
8.5.1 Annualized Costs of Compliance
Annualized costs of compliance are zero or negative for all of the
control options considered in the economic impact analysis. The maximum
possible annualized cost reductions for options 1, 2, and 3 are $53.5
million, $51.5 million and $26.4 million, respectively. Cost reductions
are likely to occur because solvent savings from the use of the degreasing
controls are greater than the costs of the required capital equipment.
8.5.2 Total Costs of Production for Major Industries
Under control options 1 and 2 all industries will experience some
cost savings. In none of the 11 industries experiencing costs increases
under control option 3 is the estimated annualized cost increase greater
than 0.2 percent, well below the criterion for regulatory action of 5%
of the selling price of the industry products.
8.5.3 Net National Energy Consumption
There will be a small increase in energy consumption resulting from
the implementation of each control option as the operation of carbon
adsorbers requires electricity and steam and refrigerated freeboard
chillers use electricity. Energy impacts for the base year (1976) were
calculated by multiplying numbers of each type of degreaser in use by
unit control energy requirements. This procedure provides a maximum
8-93
-------
estimate of the increase in net energy usage. For control options 1, 2,
and 3 the annual net increase in energy use was estimated to be 0.613
trillion BTU's, 0.845 trillion BTU's and 1.55 trillion BTU's, respectively.
These estimates amount to 296, 408, and 748 barrels of oil per day
equivalent, respectively. Assuming an increase in the use of all
degreasers of 50 percent between 1976 and 1985 (estimated on the basis
of the projections presented in Table 8-6), by 1985 the maximum net energy
impact of control options 1, 2, and 3 would be 444, 612, and 1122
barrels of oil equivalent per day. These impacts are well below the
criterion of 25,000 barrels of oil per day and may be regarded as negli-
gible.
8.5.3.1 Energy Conservation
As noted in Section 7.4.4, the quantity of oil conserved through
the use of solvents recovered from carbon adsorption units will be over
6500 barrel per day by 1985. This would represent a reduction of less
than 0.003% in total daily domestic petroleum consumption. The energy
cost coavings would be over $104,000 per day, based on an average OPEC
price for oil of $16.00 per barrel during 1979.
8.5.4 Impact on the Demand for Metals, Plastics, and Chemicals
The proposed controls impact broadly upon all metal-using manufactur-
ing industries and are likely to have a negligible or a small positive
effect on output levels. However, as no manufacturing industry is
likely to experience an increase in output of more than 0.1 percent, it is
believed that the demand for steel in all forms, aluminum, copper, manganese,
magnesium, and zinc will not increase by more than that amount and will
*The following conversion factor is used:
5.675 x 106 BTU's = 1 barrel of oil.
8-94
-------
not fall. The demand for plastics, synthetic rubber, urea, ammonia, and
pulp will be similarly unaffected. As total solvent production consti-
tutes less than 1 percent of the value of output of synthetic organic
chemicals the controls are unlikely to reduce the demand for, and output
of, ethylene and ethylene glycol by more than that amount. All of these
impacts are well below the criterion for regulatory action of 3 percent.
8.5.5 Reliability of the Impact Estimates
The results of the economic impact analysis are reliable in the
following sense. The range of maximum and minimum economic impacts was
calculated. In all cases the maximum advance economic impacts are well
within the limits established by the criteria for regulatory analysis
and it is most probable that the actually economic impacts resulting
from the proposed controls will be much smaller.
8-95
-------
8.6 REFERENCES
1. Information provided by R. Clement of Detrex Chemicals by telephone to
V. H. Smith, RTI, June 6, 1976.
2. Information provided by J. Picorny of Baron Blakeslee by telephone to
V. H. Smith, RTI, June 1, 1976.
3. Surprenant, K. S. and Richards, D. W. of Dow Chemical Company, Study to
Support New Source Performance Standards for Solvent Metal Cleaning
Operations, Volumes 1 and 2, prepared for Emission Standards and
Engineering Division (ESED) of EPA, under Contract No. 68-02-1329, June
1976.
4. U.S. International Trade Commission, Synthetic Organic Chemicals, 1976.
5. U.S. Bureau of the Census, Annual Survey of Manufactures, 1976, U.S.
Government Printing Office, Washington, D.C., 1978.
6. Leung, S., Johnson, R., Liu, Cheung S., Palo, G., Peter, K., and Tanton,
T., Alternatives to Organic Solvent Decreasing, Eureka Laboratories,
Inc., 401 N. 16th Street, Sacramento, California.
7. U.S. Department of Labor, Bureau of Labor Statistics, Methods and Data
Sources, BLS Revised 1980 and 19J5 Projections, Bureau of Labor
Statistics, April 1977.
8. Kutscher, Ronald F., Revised BLS Projections to 1980 and 1985: An
Overview, Monthly Labor Review, March 1976.
9. U.S. Bureau of the Census, Census of Manufactures^ 1972, U.S. Government
Printing Office, Washington, D.C., 1975.
10. U.S. Department of Labor, Bureau of Labor Statistics, Producers^ Prices
and_Price_Indices, 1978.
11. Information provided by T. Gunnan of Shell Chemical Corporation by
telephone to V. H. Smith, RTI, June 7, 1978.
12. Information provided by D. Hall of Diamond Shamrock corporation by
telephone to V. R. Smith, RTI, August 24, 1978.
13. Information provided by the office of C. Gray of DuPont Chemical
Corporation by telephone to V. H. Smith, RTI, September 8, 1978.
14. Chemical Marketing Reporter, TrichlorethyJLene Unit Built by Dow at
Plaquemine, La, December 12, 1977.
15. Chemical Week, New Source of Ozone Depletion?, January 18. 1978.
16. Chemical Marketing Reporter, Perc Study Enters Final Stages, July 25,
1977.
8-96
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17. Typical Electric Bills, 1976. Federal Power Commission
18. Control of Volatile Organic Emissions From Vegetable Oil
Manufacture. PEDCo, Environmental. EPA Contract 68-02-2842.
July, 1978.
19. MITRE Corp. Estimate.
20. EPA Estimate.
21. Chemical Marketing Reporter. Schnell Publishing Co., May, 1978.
22. Ibid.
23. Westlin, P.R., and J.W. Brown. Solvent Drainage and Evaporation
from Cold Cleaner Usage. United States Environmental Protection
Agency. Research Triangle Park, N.C. January, 1978. Table 1.
24. Ibid. Table 4.
25. Ibid. Tables 2 and 4.
26. Bunyard, F.T. Memo to EPA files, U.S. Environmental Protection
Agency, April 13, 1978.
27. Reference 3. April, 1976. Vol. 2. Appendix C-12.
28. Data provided by E.I. Dupont de Nemours and Co., Wilmington,
Delaware, in correspondence from Charles L. Gray, Jr. to Jeffery.
Shumaker, of the EPA, dated June 30, 1977.
29. Catalog. Baron-Blakeslee Corporation, Chicago, Illinois, March,
1978.
30. Catalog. Detrex Industries. Detroit, Micigan, 1978.
31. Rand, B.R. Autosonics Corp. Personal Communication to James H.
Bick, MITRE Corporation, July 7, 1978.
32. Pokorny, Joseph. Baron-Blakeslee Co. Personal communication to
James H. Bick, MITRE Corporation, June 5, 1978.
33. Ibid.
34. Ref. 27. Vol 1.
&
35. Bunyard, F.T.' Memo to EPA Files. U.S. Environmental Protection
Agency. March 16, 1977.
8-97
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36. Bunyard, F.T. Memo to EPA Files. U.S. Environmental Protection
Agency. March 21, 1977.
37. Ref. 29 and 30.
!
38. Ibid.
39. Ref. 29.
40. Ref. 31.
41. Clement, Richard. DETREX Corp. Telephone conversation with
James H. Bick, MITRE Corporation, June 14, 1978.
42. Ref. 27. Appendix E 7.
43. Ref. 31.
44. Ref. 29.
45. Ref. 41.
46. Johnston, T., Statistical Cost Analysis, New York: McGraw-Hill
Book Company, Inc., 1960.
47. Bain, T.S., Barriers to Lew Competition, Cambridge,
Massachusetts: Harvard University Press, 1956. Chapters 5-9.
48. Deleted. (See Reference 5.)
49. Intrilligator, M. D., Mathematical Optimization and Economic
Theory, Englewood Cliffs, New Jersey: P'rentice-Hall, Inc., 1971,
pp. 227-238.
50. Kohn, R. E., "Price Elasticities of Demand and Air Pollution Con-
trol," Review of Economics and Statistics, Vol. 64, November
1972, pp. 392-400.
51. Annual Survey of Manufactures, 1976, Op. Cit.
52. U.S. Department of Labor, Bureau of Labor Statistics: Employment
and Earnings, 1977.
53. Bingham, T. H., and B. S. Lee, An Analysis of the Materials and
Natural Resource Requirements and Residuals Generation of
Personal Consumption Expenditure Items, Research Triangle Park,
N.C.: Research Triangle Institute, February 1976.
8-98
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-istics, Office of EC- >mic Growth, Methods
BLS Revised 1980 and 1 '.^5 Projections, April
!:.. ..emot'ti, V., : r hone conversation with . H. Smith, RTI,
ugust ?7, ly/t.
;' . .S. Internal !. .cMiue Service, Corporatii Income Tax Returns,
'^75 Preliminary.
. ,3so<..-. -ion ^ ' rican Railroads and Ye^-book of Railroad Facts
and FL-
epartraent . reasury. InL.-rnal Re ue Service Business
Income Tax R^t,.. , 1976 Edition.
-------
9. RATIONALE FOR THE PROPOSED STANDARDS
9.1 SELECTION OF SOURCE FOR CONTROL
Organic solvent cleaners (degreasers) have been identified as
significant sources of air pollutant emissions which cause or contribute
to the endangerment of the public health or welfare. Degreasing is not
an industry but is an integral part of many manufacturing, repair, and
maintenance operations. Volatile organic compounds, as well as 1,1,1-
trichloroethane, trichlorotrifluoroethane, methylene chloride, trichloro-
ethylene, and perchloroethylene constitute the emissions from organic
solvent cleaners. There were an estimated 725,000 megagrams (800,000
tons) of organic solvents emitted from organic solvent cleaning operations
in 1975. This represents about A percent of total national volatile
organic emissions from stationary sources, making organic solvent
cleaners the fifth largest stationary source category for organic emissions.
There are over 1,500,000 organic solvent cleaners currently in operation.
If the current growth rate of 4.1 percent per year continues as expected,
over 300,000 new organic solvent cleaners would be subject to these
standards of performance by 1985.
Degreasing emissions include losses due to evaporation from the
solvent bath, convection, carryout, leaks, and waste solvent disposal.
Thus, the emissions from a degreaser are fugitive in nature. Many of
the degreasers currently in use are operated without proper control of
emissions to the atmosphere. Emissions from degreasers may be controlled
by the use of various equipment options (including a cover, extended
freeboard, refrigerated freeboard device and carbon adsorber) and specific
work practices (involving parts handling, proper use and maintenance of
equipment, preventing drafts and controlling the rate of the degreasing
operation).
9-1
-------
Based on the large number of sources and their wide geographic
distribution across the United States, the current sales and projected
growth rate in the "industry" and the possible reduction in adverse
environmental and health impacts which can be achieved, organic solvent
cleaners have been selected for control through the development of
standards of performance.
9.2 SELECTION OF POLLUTANTS AND AFFECTED FACILITIES
9.2.1 Selection of Pollutants.
Among the solvents used in degreasing operations, approximately
40 percent are non-halogenated hydrocarbons and 60 percent are
halogenated hydrocarbons. Most of these solvents are also reactive
volatile organic compounds (VOC), defined by this proposal as organic
compounds which participate in atmospheric photochemical reactions
or which may be measured by the applicable reference method specified
under any subpart of 40 CFR Part 60. The proposed standards of
performance apply to reactive VOC (ozone precursors) used as cleaning
solvents and to five halogenated compounds for which there is a
reasonable anticipation of public health endangerment.
9.2.1.1 Reactive Volatile Organic Compounds (VOC). The proposed
standards require control of any VOC demonstrated to be precursors to
the formation of ozone and other photochemical oxidants in the atmosphere.
The Administrator has previously determined through the promulgation of
a National Ambient Air Quality Standard (44 FR 8202, February 8, 1979)
that ozone air pollution endangers public health and welfare.
9-2
-------
While not all compounds are equally reactive, analysis of available
data indicates that very few VOC are of such low photochemical reactivity
that they can be ignored in oxidant control programs. EPA's "Recommended
Policy on Control of Volatile Organic Compounds" (42 FR 35314, July 8, 1977)
affirmed that many compounds which produced negligible oxidant concentrations
during initial smog chamber tests were found to contribute appreciably
to ozone levels when exposed to multiday irradiations in urban atmospheres.
In those geographical areas where industrial and automotive emissions
are subjected to long hours of sunlight, or where air stagnation occurs
frequently, such low reactivity compounds may become a significant
source of photochemical oxidant.
The photochemically reactive compounds, as a class, have been
interpreted to constitute a "criteria pollutant" under Section 108 of
the Clean Air Act, since the primary attainment strategy for the ozone
ambient standard is to reduce air emissions of ozone precursors. Standards
of performance may be developed for new sources of this pollutant class
under section lll(b) of the Act. For some reactive VOC, however, health
concerns other than contribution to ozone formation may be foremost.
Where this is the case, regulation as a criteria pollutant may not be
appropriate. The Clean Air Act provides for the designation of such
substances for new source regulation under section lll(d) if the substances
themselves have not been listed previously either under section 108 or
section 112 (National Emission Standards for Hazardous Air Pollutants).
9-3
-------
This designation invokes a provision of this section which requires the
development of plans by individual States to control existing sources as
well. The reactive halogenated compounds, perchloroethylene and trichloro-
ethylene, are designated in this proposed rulemaking for the reasons
discussed below.
Trichloroethylene and, to a lesser extent, perchloroethylene react
to form ozone and therefore would be subject to new source performance
standards for reactive VOC. In addition, there is evidence that both of
these chemicals may present carcinogenic risks to human health. Though
the data are not yet conclusive, both have been found to induce a high
incidence of hepatocellular carcinomas (liver tumors) in mice and have
received positive results in bacterial mutagenicity assays (a screening
technique for potential carcinogens). Based on the weight of evidence,
EPA's Carcinogen Assessment Group has concluded, in preliminary assessments,
that there is substantial evidence that both perchloroethylene and
trichloroethylene are human carcinogens. If further review and analysis
affirm these conclusions, both chemicals would become candidates for
section 112 regulation as "high probability" carcinogens under EPA's
proposed airborne carcinogen policy. In the interim, owever, the
Administrator has determined that, despite the present uncertainties in
the health data, there is sufficient evidence at this time to consider
both perchloroethylene and trichloroethylene as air pollutants which may
reasonably endanger public health and that it is appropriate to proceed
with the designated pollutant regulatory path. In the event that EPA
subsequently lists either substance as a hazardous air pollutant under
section 112, the reduction in health risk obtained by the regulations
proposed today will be a major factor in the determination of the need
for further control in this industry.
9-4
-------
9.2.1.2 Negligibly Reactive Halogenated Compounds. In addition to
reactive halogenated compounds, the proposed new source regulations
would apply to three additional halogenated solvents: 1,1,1-trichloro-
ethane, methylene chloride, and trichlorotrifluoroethane. Since these
chemicals are acknowledged by EPA to be neglibibly reactive, they are
not ozone precursors and must be designated under section lll(d) of the
Act. As described above, the designation for the purpose of obtaining
coverage under new source standards also requires the development under
section lll(d) of standards for existing sources.
Both methylene chloride and 1,1,1-trichloroethane have scored
positive as well as negative results in short-term mutagenicity and cell
transformation tests. The weight of evidence has led the EPA Carcinogen
Assessment Group to conclude in preliminary assessments that both
chemicals exhibit suggestive evidence of human carcinogenicity. Under
EPA's proposed airborne carcinogen policy, this finding would establish
1,1,1-trichloroethane and methylene chloride as candidates for regulation
under section 111 as air pollutants "reasonably anticipated to endanger
public health welfare." In addition, trichlorotrifluoroethane and
1,1,1-trichloroethane have been implicated in the depletion of the
stratospheric ozone layer, a region of the upper atmosphere which shields
the earth from harmful wavelengths of ultraviolet radiation that increase
skin cancer risks in humans.
The judgments of whether and to what extent 1,1,1-trichloroethane
and methylene chloride are human carcinogens, and 1,1,1-trichloroethane
and trichlorotrifluoroethane deplete the ozone layer, are issues of
considerable debate. While the scientific literature has been previously
9-5
-------
reviewed and summarized in -the docket prepared for this rulemaking, more
detailed health assessments are currently in preparation by EPA's Office
of Research and Development. These assessments will be completed and
submitted for external review, including review by the Science Advisory
Board, prior to the promulgation of the regulations and the proposal of
EPA guidance to States in developing existing source control measures.
The extent to which the preliminary findings are affirmed by the review
process may affect the final rulemaking for new as well as existing
sources.
While the measure of concern is less for these latter three solvents
than for perchloroethylene and trichloroethylene, the Administrator has
chosen to proceed with the designation of 1,1,1-trichloroethane, methylene
chloride, and trichlorotrifluoroethane at this time because emissions
from these sources and the associated health risks can be reduced at a
very low cost. This decision reflects EPA's concern that continued
growth in uncontrolled emissions of 1,1,1-trichloroethane, methylene
chloride, and trichlorotrifluoroethane from solvent cleaners may endanger
public health, and is reinforced by projections that, were these chemicals
exempted from regulation, the resulting substitution of exempt for non-
exempt solvents could result in large increases in the emissions of
these pollutants.
The designation of 1,1,1-trichloroethane, methylene chloride, and
trichlorotrifluoroethane incorporates these chemicals under today's
proposed new source standards and invokes section lll(d) which requires
States to develop controls for existing sources. As described in detail
below, the new source standards do not place unreasonable economic costs
9-6
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on the industry. While the impact of similar controls on existing
sources could be more significant due to the technological problems
associated with retrofit, this factor would be an important consideration
in determining the appropriate control level for existing sources. In
view of the substantial reduction in emissions which can be achieved at
low cost, the Administrator is persuaded that the present approach
represents a prudent policy to protect public health.
Summaries of the health basis for designating perchloroethylene,
trichloroethylene, 1,1,1-trichloroethane, methylene chloride, and
trichlorotrifluoroethane are available in the public rulemaking docket
described at the beginning of this notice.
9.2.2 Selection of Affected Facilities.
Organic solvent cleaning is not a specific industry but is an
integral part of many manufacturing, repair, and maintenance operations.
Practically every business that works metal or has maintenance or repair
operations does some type of degreasing. Degreasing operations are
often concentrated in urban areas where there are a large number of
manufacturing facilities.
The solvents used in degreasing operations include halogenated
hydrocarbons, petroleum distillates, ketones, ethers, and alcohols.
These solvents are emitted as fugitive emissions from each of the three
types of degreasers which would be regulated: (1) a cold cleaner, in
which the article to be cleaned is immersed, sprayed or otherwise washed
in a solvent at or about room temperature; (2) an open top vapor degreaser,
in which the article is suspended in solvent vapor over a pool of boiling
9-7
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solvent and the solvent vapors condense on the article and dissolve or
wash soil and grease from it; and (3) a conveyorized degreaser, in which
articles are conveyed on a chain, belt or other conveying system either
through a spray or pool of cold solvent, or through the vapor of a
boiling solvent. In order to achieve significant reduction in volatile
organic compound emissions from degreasing operations, all types of new,
modified, or reconstructed degreasers would be subject to control.
The mode of disposal of waste solvent can also contribute significantly
to solvent emissions. Disposal is not usually handled by the owners of
organic solvent cleaners, but by operators of landfills, incinerators,
or solvent reclaiming facilities. If waste solvent disposal in 1985
were to follow the pattern of waste solvent disposal in 1974, about 43
percent of the waste solvent from new sources would be reclaimed or
disposed of properly and the remaining 57 percent could be a source of
air or water emissions. For this recovery, disposal of waste solvent,
sump, and still bottoms has also been selected for development of
standards of performance.
9.3 SELECTION OF THE BASIS OF THE PROPOSED STANDARDS
Emissions of volatile organic compounds from degreasers can be
reduced significantly by the use of various pollution control devices,
singly or in combination, as appropriate for each method of degreasing.
These controls include: cover, drain rack, raised freeboard, refrigerated
freeboard device, carbon adsorber, downtime port covers, silhouette cutouts
or hanging flaps, and drying tunnel. Degreaser emissions can be reduced
further through the implementation of prescribed work practices. These
9-8
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work practices include: closing the cover when work is not being lowered
into or removed from the degreaser, storing solvent in covered containers,
not exposing open degreasers to steady drafts with velocities exceeding
40 m/min (131 ft/min). and not overloading the degreaser_
The best system of emission control for each type of degreaser was
selected on the basis of tests of the effectiveness of various controls
operating under different conditions and using different solvents, as well
as a cost analysis of each. These are described below.
Because of the diversity of the organic solvent cleaning industry,
selection of the best emission control systems in this section are based
on a specific set of scenarios. In certain instances, a different system
from that selected here might be preferable because of economic and
environmental considerations. For example, if sheet metal were being
cleaned in a conveyorized vapor degreaser (CVD), the carryout would be small
because the surface and the orientation of the work would enhance drainage.
On the other hand, if finned condensing tubes were being cleaned, the
carryout could be very large and a drying tunnel would be needed.
The cost/kg for degreaser emission controls is the net cost (or
savings) divided by the kilograms of solvent controlled. The net cost
(or savings) is the cost of the control minus the value of the solvent
2 2
controlled. On a 1.86 m (20 ft ) open top vapor degreaser (OTVD), a
refrigerated freeboard device saves twice the solvent as compared to a raised
freeboard. The savings/kg are $0.14 for the refrigerated freeboard device
and $0.28 for the raised freeboard. The magnitude of the savings/kg or
the cost/kg depend on the workload and on the degreaser size. For large
2
(5.6 m ) OTVD used three shifts per day and active (uncovered) 75 percent of
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the time, the savings for a cover are $0.36/kg. Savings for a refrigerated
freeboard device on the same OTVD are $0.39/kg.
From the above, it is evident that the definition as well as the
selection of the best emission control system depends on degreaser type,
size, and workload. Selection cannot be made solely on economic grounds
since the control system with the largest saving/kg is usually the cheapest
and usually produces the smallest reduction in the magnitude of solvent
emissions. For these reasons, selection of the emission control systems
is based primarily on absolute reduction in solvent emissions and
secondarily on economic considerations (savings/kg).
Finally, selection of the control system is based on the assump-
tion that the correct work practices outlined in Chapter 6 are fol-
lowed. Control system economics cannot be defined if incorrect work
practices are common. No costs are ascribed to work practices.
9.3.1 Selected Emission Control Systems for Cold Cleaners
The emission control system selected for cold cleaners (CC) would consist
of both control equipment and a series 01 work practices. These controls
used in combination would reduce solvent emissions from cold cleaners by about
80 percent. The equipment requirements would include a cover, a drain rack,
and a visible fill line. The cover would be designed to be readily opened
and closed at any time. External drain racks would lead the drainage back
to the tank. If the CC is equipped with a parts basket, internal hooks to
permit suspension of the basket above the solvent could be substituted for
the drain rack. One of the work practices would require that the solvent level
not exceed the visible internal maximum fill line. The proposed standards would
require that the freeboard ratio for CC would be at least 0.7 if the solvent
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volatility is greater than 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38°C (100°F)
For solvents with a volatility of less than or equal to 4.3 kPa measured at
38°C (100°F), the proposed standards would require a freeboard ratio of 0.5.
The economic analysis for this emission control system for cold cleaners
was based on a typical unit. The uncontrolled cold cleaner was assumed to
be uncovered all the time, whereas the controlled unit had a cover that was
used all but 2 hours per working day (20 loads cleaned per day). Based on
these assumptions, the cover would reduce emissions by 349 kilograms (769 pounds)
per year at a savings of $69.80. The drain rack would reduce emissions by
36 kilograms (79 pounds) per year with a savings of $7.92.
9.3 2 Selected Emission Contol Systems for Remote Reservoir Cold Cleaners
The emission control system selected for remote reservoir cold cleaners
(RRCC) is less stringent than that proposed for conventional cold cleaners.
During non-use periods, the solvent is enclosed in a reservoir and not
subject to evaporation loss to the atmosphere. While parts are being cleaned,
solvent is pumped through a sink-like work area which drains back into the
enclosed container. Because the reservoir is remote from the work area, this
type of organic solvent cleaner is not subject to evaporation losses suffered
by conventional cold cleaners. Therefore, the. proposed standards for remote
reservoir cold cleaners would not require closable covers, provided the solvent
used has a volatility of less than or equal to 4.3 kPa (33 mm Hg or 0.6 psi)
measured at 38°C (100°F), but would require covers if the solvent volatility
was greater than 4.3 kPa.
9.3.3 Selected Emission Control Systems for Open Top Vapor Degreasers
The emission control systems which would be required for all new, modified,
or reconstructed open'top vapor degreasers (OTVD) consist of covers, raised
freeboards, refrigerated freeboard devices, and carbon adsorption systems.
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EPA and industry tests have shown that covers are the most effective control
device in reducing solvent emissions during non-operating conditions. Raised
freeboards have also been shown to be effective at reducing these emissions.
By raising the freeboard ratio from 0.5 to 0.75, solvent emissions are generally
reduced 25-30 percent during idling conditions. Emission reductions are less
during actual operating conditions due to the transference of loads through
vapor/air interface. Freeboard ratios larger than 0.75 may yield greater
emission reductions, however, higher freeboards tend to increase the difficulty
of transferring loads into and out of the degreaser. The demonstrated ability
of covers and raised freeboards to reduce solvent emissions, coupled with
the minimal cost of these two control devices have been the primary reasons for
requiring the use of covers during non-operating periods, and freeboard ratios of
at least 0.75, regardless of OTVD size.
Emission tests have also shown that refrigerated freeboard devices
and lip exhausts connected to carbon adsorbers are more effective at reducing
solvent emissions than raised freeboards. During operating conditions,
emission reductions as high as 65 percent have been demonstrated
with the use of carbon adsorbers, while refrigerated freeboard devices
have been demonstrated to reduce solvent emissions by at least 40 percent.
For this reason, all new,.modified, and reconstructed OTVD with vapor/air
interface areas greater than one square meter would be required to use
refrigerated -freeboard devices or have lip exhausts connected to carbon
adsorbers.
A cut-off size of one square meter was determined to be the most
effective for OTVD, taking into consideration the absolute reduction in
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solvent emissions and economic considerations. Although the capital expenditures
for refrigerated freeboard devices are greater than for raised freeboards,
solvent savings would completely offset the added capital expenditures, provided
the degreasers were operated properly. However, for small degreasers (less than
2
1m in open top area), refrigerated freeboard devices would not be a cost-effective
alternative. Taking into consideration the small reduction in solvent emissions
and economic considerations, small degreasers would not be required to have
refrigerated freeboard devices.
EPA realizes that refrigerated freeboard devices with sub-zero (0°C)
refrigerant temperatures are patented. If any degreaser manufacturer is
unable to demonstrate alternative methods of control, or certifies that the
licensing terms for sub-zero refrigerated freeboard devices are unreasonable,
relief under section 308 of the Clean Air Act, as amended can be initiated.
These proposed standards which specify control technologies do not
preclude the use of other secondary control options, provided they are
equally effective in reducing solvent emissions. In fact, EPA expects to
approve other methods of continuous emission reduction when they have been
demonstrated to be as effective in reducing emissions as sub-zero refrigerated
freeboard, devices. Tests are currently being conducted to investigate the
effectiveness of automated covers which close after the workload enters the
degreaser and the use of increased freeboard ratios as high as 1.25.
Any additional information and data submitted to EPA from persons
outside the Agency would be used to evaluate the appropriateness of
secondary emission control options. Expansion or deletion of certain
secondary emission control options would be made prior to promulgation when
additional data and information becomes available. All information obtained
during the course of this investigation and received during the public
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comment period would be placed in the docket for public review and considered
by EPA before taking final action to promulgate standards for new, modified,
or reconstructed degreasers.
9.3.4 Selected Emission Control Systems for Conveyorized^ Degreasers
There are two major types of conveyorized degreasers: conveyorized
cold cleaners (CCC) and conveyorized vapor degreasers (CVD). The emission
control systems selected for conveyorized degreasers consist of both
control equipment and a series of work practices. Using these controls in
combination will reduce solvent emissions from conveyorized degreasers by
60 percent. The two major emission control equipment requirements for
conveyorized vapor degreasers are carbon adsorbers and refrigerated freeboard
devices. Since refrigerated freeboard devices are not effective on conveyorized
cold cleaners, and because uncontrolled emissions from CCC are twice as
great as from CVD, all conveyorized cold cleaners greater than 2 square
2
meters (43 ft ) in air-solvent interface area would be required to use carbon
adsorbers.
For larger crossrod and monorail CVD, carbon adsorbers produce greater
emission reductions at higher savings than do refrigerated freeboard devices.
For owners or operators of small crossrod and monorail degreasers, the capital
costs of a carbon adsorber could be prohibitive. Because of this, a refrigerated
freeboard device may be used instead of a carbon adsorber. As with OTVD, the
type of conveyorized vapor degreaser, the type of work being processed, and
ambient conditions would determine which emission control system should be
. ^
used.
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9.3.5 Selected Emission Control Systems for Waste Solvent
Disposal Operations
Disposal of waste solvent from all organic solvent cleaning operations
(new and old) would be regulated under the Resource Conservation and Recovery
Act (RCRA) which was recently proposed by EPA (43 FR 58946). These regulations
define halogenated and non-halogenated solvents, and solvent recovery still
bottoms as hazardous wastes. Under RCRA, control of these wastes must be
accomplished through the use of specific disposal techniques. Distillation
is the preferred method for the control of waste solvent because it recycles
the waste solvent thereby conserving national energy resources. Approximately
one-half of all open top vapor degreasers, and almost all conveyorized
degreasers use distillation as a method for recovering spent solvent. In
addition, some manufacturers of cold cleaners recycle used solvent for their
customers. However, distillation may not always be a viable alternative. RCRA
also allows waste solvent, sump, and still bottoms to be disposed of by
incineration, landfilling, or storage in surface impoundments or basins.
These proposed standards, in addition to RCRA, would prevent the discharge
of waste solvent into surface impoundments and basins, and require that
waste solvent disposed in landfills be deposited in closed containers prior
to burial. These additional requirements are necessary to ensure that
the waste solvents do not evaporate into the air during their disposal. Since
waste solvent from all degreasing operations is subject to control under
RCRA, any additional requiements imposed by these standards of performance would
not cause an incremental increase in the amount of waste solvent disposed. Air
emissions are also controlled under Department of Transportation regulations
which prescribe methods of containerization and transportation of waste solvent,
and by performance standards for incinceration under RCRA.
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9.4 SELECTION OF FORMAT FOR THE PROPOSED STANDARDS
Under the Clean Air Act, as amended, there are two regulatory
alternatives available for establishing standards of performance for new
stationary sources. Section lll(b) provides for establishing emission
limitations or percentage reductions in emissions. However, when such
standards are not feasible to prescribe or enforce, section lll(h) of
the Clean Air Act provides that EPA may instead promulgate a design,
equipment, work practice, or operational standard, or combination
thereof. In either event, the standards prescribed would require new,
modified, and reconstructed organic solvent cleaners to use the best
demonstrated system of continuous emission reduction considering costs,
nonair quality health and environmental impacts, and energy impacts.
The emissions from organic solvent cleaners are unconfined (fugitive).
Although techniques have been developed to measure the solvent lost from
degreasing equipment (such as mounting entire organic solvent cleaners
on scales), these methods are impractical for enforcement of regulations
due to the length of time needed to accurately determine the solvent
losses and because of the disruption this would cause in degreaser
operations. For this reason, an equipment and work practice standard
has been selected since It is not feasible to enforce emission limitations
or percentage reductions in emissions for organic solvent cleaning
operations.
9.5 SELECTION OF EMISSION LIMITS
Emissions from organic solvent cleaners, excepting those from carbon
adsorption systems, are considered fugitive emissions. For reasons
discussed in section 9.4, no limits are set for these fugitive
emissions. An emission standard has been proposed for carbon adsorption
control devices which requires that the concentration of solvent in the
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exhaust be less than 25 ppm of any regulated halogenated organic compound as
measured by Method 23 for the length of the carbon adsorber cycle or three
hours, whichever is less. If other volatile organic compounds are used, then
the emissions shall not exceed an average of 25 ppm as carbon, measured
by Method 25 for the length of the carbon adsorber cycle or three hours,
whichever is less. The purpose of the proposed standard
is to insure that carbon adsorption beds be regenerated before complete
breakthrough occurs. Breakthrough occurs when a bed reaches capacity.
During normal operation, the concentration of solvent vapor in the exhaust
from an adsorber will be very low (<10 ppm). Upon breakthrough, the con-
centration will increase rapidly until it reaches the solvent concentration
in the inlet stream. The operator of a degreaser with a carbon adsorption
control system can estimate the amount of time which sould be allowed between one
bed regeneration and the next using the bed capacity and the rate at which
solvent is entering the bed. Since, the solvent input rate generally cannot
be determined with accuracy, this method may not be practical. It would be
necessary to regenerate the bed well before it reaches capacity to insure
against operation after breakthrough. Another- method of determining when
to regenerate a carbon adsorber would be to monitor the concentration of
solvent vapor in the bed exhaust. The 25 ppm concentration limit is based
on the availability of continuous monitoring devices which can detect
solvent vapors at this concentration level. Although a lower limit could
have been set based on the demonstrated capability of carbon adsorption
control systems, this would have required the use of sophisticated monitoring
equipment to insure compliance. Also, because a good portion of the emissions
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from a degreaser equipped with a carbon adsorber are fugitive emissions
not ducted to the adsorber, the benefit to be gained by setting an extremely
low limit on carbon adsorber emissions would be minimal.
9.6 MODIFICATION/RECONSTRUCTION CONSIDERATIONS
The proposed standards apply to all organic solvent cleaners which
are constructed or modified on or after the date of proposal Provisions
for modification and reconstruction are discussed in Chapter 5 along with
the various physical and operational changes that are expected to occur
to organic solvent cleaners
9.6.1 Potential Modifications
Six alternatives are considered for potential modifications in
degreasing facilities:
Routine maintenance, repair, and replacement,
Alternative solvents,
Addition of a system which controls air pollutants,
Increase in production rate without a capital expenditure,
Equipment relocation, and
Removal or disabling of a control device.
Routine maintenance, repair, or replacement are not considered
modifications under 40 CFR 60.14(e)(l). These operations will not
result in an increase in emissions assuming that proper operational
procedures are followed during maintenance, repair, or replacement
operations and if replacement materials are identical in type and
quantity to the original.
The use of an alternative solvent is not considered to be a
modification, under 40 CFR 60.14(e)(4), if the existing facility was
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designed to accommodate it and no modification of the degreaser is
required.
The addition of an air pollution control system to a degreaser is
not considered a modification under 40 CFR 60.14(e)(5) because it
reduces air pollutants and is therefore environmentally beneficial.
The substitution of one control device for an existing device
would not be considered a modification if it is determined by the EPA
that the control device being added is more environmentally benefi-
cial. The intent of this type of exemption is to encourage emission
reductions on existing facilities which would otherwise not be regu-
lated under the proposed standard.
An increase in the production rate of an existing degreasing
facility is not considered a modification under 40 CFR 60.14(e)(2).
When a need for capital expenditure is required to increase the
production rate of a degreaser, the degreaser is then modified and
subject to the proposed NSPS.
Equipment relocation within the same plant does not contribute to
an increase of emission level and, therefore, is not considered a
modification.
The removal or disabling of a device, on an existing degreaser,
which controls solvent emissions is a modification. In addition, an
operational change to an existing facility which results in an in-
crease in emissions is a modification under 40 CFR 60.14(a). As an
example, if a hoist speed is modified to process work at a faster
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rate than is currently in practice, then that degreaser is modified.
The intent is to prevent as much as possible an increase in emissions from
existing degreasers which are not regulated under the proposed standard
and which may not be regulated under state or local law.
9.6.2 Reconstruction
Major reconstruction of a degreasing facility is not generally
undertaken except for large, complex, custom-designed, conveyorized
systems.
Four cases are considered for potential reconstruction:
Replacement of a freeboard chiller,
Rebodying of a degreaser,
Replacement of a gas-fired or steam heater in a degreaser by
an electric heating system, and
Rebuilding of a custom-built degreaser.
All these cases could cost more than 50 percent of the capital cost
of a new degreaser; they would therefore constitute reconstruction
under 40 CFR 60.15 and be subject to the proposed standards. How-
ever, for rebuilding of a customized degreaser, it may be technically
infeasible to comply with the proposed standard. Technical infeasi-
bility may result from an uncorrectable condition, e.g., space limi-
tation in the affected facility. Therefore, under such conditions,
the existing facility may not be considered as reconstructed under 40
CFR 60.15(b)(2).
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9.7 SELECTION OF PERFORMANCE TEST METHODS
Reference Methods 23 and 25 are proposed as methods for measuring
organic solvent vapor concentrations in exhaust streams from carbon
adsorption systems. Reference Method 23 is proposed for addition to
Appendix A to CFR Part 60 concurrent with the proposal of the organic solvent
cleaning new source performance standards (NSPS) and Reference Method 25
is proposed with the Automobile and Light Truck Surface Coating NSPS
(44 FR 57792, October 5, 1979).
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APPENDIX A. EVOLUTION OF THE PROPOSED STANDARDS
In 1974 the EPA contracted the Dow Chemical Company in Midland,
Michigan to study solvent metal cleaning as a source of volatile organic
emissions (EPA contract 68-02-1329, Task Order No. 9). In 1977 the
EPA issued a Control Techniques Guideline Document to the
states based on the compiled information. The CTG was a guide to the
States for controlling volatile organic emissions from existing
degreasing operations. The MITRE Corporation began to assist EPA in
developing a New Source Performance Standard for Organic Solvent
Cleaners after it was established that degreasing facilities are a
major source of volatile organic compounds. Information which
describes the type and level of emissions from the various kinds of
degreasers was obtained from both EPA and industry. GCA/Technology
Division began assistance to EPA in developing this standard in
January 1979.
A-l
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A.I Chronology
The chronology which follows includes those events which have occurred
in developing the NSPS for organic solvent cleaners, including the
activities of the Dow Chemical Company in compiling the data for the
support document. Anticipated events which lead up to the proposal of
the standard in the Federal Register are also included.
Date
December 13, 1974
January 9 - February 3, 1975
January 15, 1975
January 16, 1975
January 16, 1975
January 23, 1975
March 4, 1975
March 4, 1975
March 5, 1975
March 5, 1975
March 6, 1975
March 7, 1975
Activity
Visit to VIC Manufacturing in
Minneapolis, Minnesota
Degreasing plant interviews conducted
by National Marketing Surveys.
Interviews were conducted at 2578 plants.
Visit to Graymills Corporation in
Chicago, Illinois
Visit to Baron-Blakeslee in
Chicago, Illinois
Visit to Phillips Manufacturing Company
in Chicago, Illinois
Visit to Kleer-Flo Corporation in
Eden Prairie, Minnesota
Visit to Olson Manufacturing in Holden,
Massachusetts
Visit to J. L. Thompson in Waltham,
Massachusetts
Visit to Anson incorporated in Providence,
Rhode Island
Visit to Guild Metal Products, Inc. in
Providence, Rhode Island
Visit to Pratt Whitney Aircraft in E.
Hartford, Connecticut
Visit to Detrex Chemical Industries,
Inc. in Detroit, Michigan
A-2
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March 11, 1975
March 13, 1975
March 25, 1975
May 19 - August 1975
May 19 - August 15, 1975
May 19 and 27, 1975
May 21, 1975
May 28, 1975
May 29, 1975
June 5, 1975
June 6, 1975
June 10, 1975
June 12, 1975
Visit to Western Electric Company-
Hawthorne Plant in Chicago, Illinois
Visit to Rockford Products Company in
Rockford, Illinois
Visit to Safety Kleen Corporation in
Elgin, Illinois
Emission control testing of a carbon
adsorber on an open top degreaser,
performed at Super Radiator Corporation,
St. Louis Park, Minnesota by Dow
Chemical Company for EPA.
Emission control testing of carbon
adsorption for an open top degreaser at
Vic Manufacturing Company, Minneapolis,
Minnesota by Dow Chemical Company for
EPA. Report completed on February 11,
1976.
Emission control testing of carbon
adsorption for a crossrod degreaser at
J. L. Thompson Co., Waltham,
Massachusetts by Dow Chemical Co. for
EPA.
Visit to General Motors Corporation -
Diesel Equipment Division in Grand
Rapids, Michigan
Visit to Hoyt Manufacturing in
Westport, Massachusetts
Visit to Pratt Whitney Aircraft in E.
Hartford, Connecticut
Visit to Westinghouse Electric Company
in Raleigh, North Carolina
Visit to General Motors Corporation -
Diesel Equipment Division in Grand
Rapids, Michigan
Visit to Western Electric Company in
Chicago, Illinois
Visit to Hamilton Standard - Division of
United Technologies in Windsor Locks,
Connecticut
A-3
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June 12, 1975
June 13, 1975
June 16 - August 1975
June 20 - July 24, 1975
June 24, 1975
June 25 - August 1, 1975
July 1, 1975
July 3, 1975
July 3, 1975
July 9-10, 1975
July 10 - November 1975
July 28 - September 18, 1975
Visit to Pratt Whitney Aircraft in
E. Hartford, Connecticut
Visit to General Time Corporation in
Thomaston, Connecticut
Emission control testing of carbon
adsorption at Western Electric Company,
Chicago, Illinois by Dow Chemical
Company for EPA
Emission control evaluation of (1) a
pneumatic cover and (2) refrigeration,
performed at Pratt Whitney, Hartford,
Connecticut by Dow Chemical Company
for EPA
Visit to Safety Kleen Corporation in
Elgin, Illinois
Emission control efficiency evaluation
of two refrigerated freeboard chillers,
performed at Hamilton Standard, Windsor
Locks, Connecticut by Dow Chemical
Company for EPA
Visit to Horton Company in Jackson,
Michigan
Visit to Autosonics Company in
Norristown, Pennsylvania
Visit to General Electric Corporation in
Philadelphia, Pennsylvania
Emission control evaluation of carbon
adsorption at Hewlett Packard Corporation,
Loveland, Colorado by Dow Chemical
Company for EPA
Emission control testing of a refrigerated
freeboard chiller on a monorail vapor
degreaser performed at Schlage Lock
Company, Rocky Mount, N. C. by EPA.
Emission testing of cold cleaners and
vapor degreasers at Prestolite Corpora-
tion, Bay City, Michigan by Dow
Chemical Company for EPA.
A-4 '
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August 5 - October 4, 1975
August 20, 1975
September 9-11, 1975
October 8, 1975
October 8, 1975
January 14, 1976
February 1976
March 16, 1976
March 16, 1976
June 1976 (some data
originally from 1961)
June 1976
June 30, 1976
November 3, 1976
November 6, 1976
Cost and energy comparative study between
alkaline washing and vapor degreasing,
performed by Dow Chemical Company at CMC,
Grand Rapids, Michigan for EPA.
Visit to VIC Manufacturing in Minneapolis,
Minnesota
Visit to VIC Manufacturing in Minneapolis,
Minnesota
Visit to Baron-Blakeslee, Incorporated in
Chicago, Illinois
Visit to Graymills, Incorporated in
Chicago, Illinois
Meeting with ASTM Committee in Orlando,
Florida
Completion of a test report, "Control
Efficiency of a Refrigerated Freeboard
Chiller on a Monorail Vapor Degreaser,"
by EPA.
Visit to Magnus, Division of Economic
Laboratories in St. Paul, Minnesota
Visit to Kleer-Flo Company in Eden
Prairie, Minnesota
Emission control evaluation of vapor
degreaser covers, performed at Eaton
Corporation, Saginaw, Michigan by Dow
Chemical Company for EPA.
Emission control testing of increased
freeboard on open top degreasers by
Dow Chemical Company
Completion of "Study to Support New
Source Performance Standards for Solvent
Metal Cleaning Operations," by Dow
Chemical Co., Midland, Michigan.
First NAPCTAC meeting, San Francisco,
California.
Visit to Rucker Ultrasonics in Concord,
California
A-5
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January 26-27, 1977
January 27, 1977
January 28, 1977
May 1977
June 22, 1977
July 21, 1977
July 22, 1977
August 1977
November 1977
December 8, 1977
January 1978
January 25, 1978
May 1978
May 26, 1978
June 22, 1978
August 23, 1978
May 1, 1979
Meeting with ASTM Committee in New Orleans,
Louisiana
Visit to Rollins Environmental Services
in Baton Rouge, Louisiana
Visit to March Chemical Company in
Denham Springs, Louisiana
Completion of a test report,
"Evaporative Emissions Study on Cold
Cleaners," by EPA.
Meeting with ASTM Committee in Gatlinburg,
Tennessee
Visit to Detrex Chemical Industries in
Boiling Green, Kentucky
Visit to Autosonics, Inc. in Norristown,
Pennsylvania.
First issue paper was written by J. C.
Shumaker and D. R. Patrick.
Publication of the OAQPS Guidelines
document, "Control of Volatile Organic
Emissions from Solvent Metal Cleaning,"
EPA-450/2-77-022.
Meeting with ASTM, PEDCo Environmental
and EPA-IERL in Cincinnati, Ohio
Completion of a test report, "Solvent
Drainage and Evaporation from Cold
Cleaner Usage," by EPA.
Meeting with ASTM Committee in Fort
Lauderdale, Florida
Publication of EPA document, "Control of
Volatile Organic Compounds.from
Stationary Sources," EPA-450/2-78-022.
Completion of issue paper.
Working Group meeting.
Second NAPCTAC meeting, Alexandria,
Virginia.
Meeting with ASTM, PEDCo Environmental,
and EPA-IERL in Cincinnati, Ohio.
A-6
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June 1, 1979:
June 12-13, 1979:
July 11, 1979:
July 12-15, 1979:
To be scheduled:
January, 1980 (anticipated)
Steering Committee Meeting
Visit to AutoSonics, Inc., in
Norristown, Pennsylvania.
Visit to Allied Chemical Corporation,
Buffalo, New York to discuss emission
test data on open top vapor degreasers,
Visit to AutoSonics, Inc., in
Norristown, PA.
Presentation of final preamble,
regulation, and advance information
memo for Assistant Administrator
concurrence.
Proposal 6f the New Source Performance
Standard for Organic Solvent Cleaners
A-7
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APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
This appendix consists of a reference system, 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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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 Standards
Support and Environmental
Impact Statement
1.
Background and description of the
proposed action.
-Describe the recommended or
proposed action and its purpose.
2.
-The relationship to other actions
and proposals significantly
affected by the proposed action
shall be discussed, including not
only other Agency activities but
also those of other governmental
and private organizations.
Alternatives to the proposed
action.
-Describe and objectively weigh
reasonable alternatives to the
proposed action, to the extent
such alternatives are permitted
by the law. . . For use as a
reference point to which other
actions can be compared, the
analysis of alternatives should
include the alternative of taking
no action, or of postponing action.
In addition, the analysis should
include alternatives having
different environmental impacts,
including proposing standards,
criteria, procedures, or actions
of varying degrees of stringency.
When appropriate, actions with
similar environmental impacts
The proposed standards are summarized
in chapter 1, section 1.1. The
statutory basis for the proposed
standards (section III of the Clean
Air Act, as amended) is discussed in
the Introduction. The purpose of
the proposed standards is discussed
in chapter 9, sections 9.1 and 9.2.
Water effluent limitations for solvent
metal cleaners are discussed in
chapter 7, section 7.2. Discussion of
the economic impacts that the proposed
new source performance standards may
have on these effluent guidelines is
presented in chapter 8.
The alternative control systems,
based upon the best combinations of
control techniques, are presented in
chapter 4. A discussion to the
alternative of taking no actions and
that of postponing the proposed
action is presented in chapter 7,
section 7.6.1. The alternative
systems are discussed throughout
the document in the evaluation of
the environmental and economic
impacts associated with the proposed
standards.
The selection of the best system for
emision reduction, considering costs,
is presented in chapter 9, section 9.3.
R-2
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CROSS INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT (continued)
Agency Guidelines for Preparing
Regulatory Action Environmental Impact
Statements (39 FR 37419)
Location Within the Standards
Support and Environmental
Impact Statement
but based on different technical
approaches should be discussed.
This analysis shall evaluate
alternatives in such a manner that
reviewers can judge their relative
desirability.
-Where the authorizing legislation
limits the Agency from taking cer-
tain factors into account in its
decision making, the comparative
evaluation should discuss all
relevant factors, but clearly
identify those factors which the
authorizing legislation requires
to be the basis of the decision
making.
-In addition, the reasons.why the
proposed action is believed by the
Agency to be the best course of
action shall be explained.
The alternative formats for the
proposed standards are discussed
and the rationale for the selection
of the proposed formats are discussed
in chapter 9, section 9.4.
The factors which the authorizing
legislation requires to be the basis
of the decision making are discussed
in the Introduction.
The rationale for the selection of
solvent metal cleaners for control
under the proposed standards is
discussed in chapter 9, section 9.1.
The Administrator's decision to
control solvent metal cleaners under
Federal standards and the reasons.
for regulating emissions from solvent
metal cleaners under section III of
the Clean Air Act is discussed in
the Introduction.
3.
Environmental impact of the proposed
action.
A. Primary impact
Primary impacts are those that
can be attributed directly to
the action, such as reduced
levels of specific pollutants
brought about by a new standard
and the physical changes that
occur in the various media with
this reduction.
The primary impacts on mass emissions
and ambient air quality due to the
alternative control systems is
discussed in chapter 7. These impacts
are summarized in Table 1-2, Matrix
of,Environmental.and Economic Impact
of the Alternative Standards, chap-
ter 1, section 1.2.
B-3
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CROSS INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT (continued)
Agency Guidelines for Preparing
Regulatory Action Environmental Impact
Statements (39 FR 37419)
Location Within the Standards
Support and Environmental
Impact Statement
B. Secondary impact
Secondary impacts are indirect
or induced impacts. For
example, mandatory reduction
of specific pollutants brought
about by a new standard could
result in the adoption of
control technology that
exacerbates another pollution
problem and would be a secondary
impact.
4. Other considerations.
A. Adverse impacts which cannot be
avoided should the proposal be
implemented. Describe the kinds
and magnitudes of adverse
impacts which cannot be reduced
in severity to an acceptable
level or which can be reduced
to an acceptable level but not
eliminated. These may include
air or water pollution, damage
to ecological systems, reduc-
tion in economic activities,
threats to health, or
undesirable land use patterns.
Remedial, protective, and
mitigative measures which will
be taken as part of the proposed
action shall be identified.
B. Relationship between local
short-term uses of man's
environment and the maintenance
and enhancement of long-term
productivity. Describe the
extent to which the proposed
action involves trade-offs
between short-term losses
or vice-versa and the extent
to which the proposed action
The secondary environmental impacts
attributable to the alternative control
systems are discussed in chapter 7.
Secondary impacts on air quality are
discussed in chapter 7.
The anticipated impacts on energy
requirements due to each alternative
control system is discussed in
chapter 7, section 7.4.
A summary of the potential adverse
environmental and economic impacts
associated with the proposed standards
and the alternatives that were
considered is discussed in chapter 1,
section 1.2 and chapter 7.
The discussion of the use of man's
environment is included in chapter 7,
section 7.1. A discussion of.the
effects of emissions from solvent
metal cleaners is included in
chapter 9, section 9.1.
B-4
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CROSS INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT (continued)
Agency Guidelines for Preparing
Regulatory Action Environmental Impact
Statements (39 FR 37419)
Location Within the Standards
Support and Environmental
Impact Statement
forecloses future options.
Special attention shall be
given to effects which pose
long-term risks to health or
safety. In addition, the
timing of the proposed action
shall be explained and
justified.
C. Irreversible and irretrievable
commitments of resources
which would be involved in
the proposed action should it
be implemented. Describe the
extent to which the proposed
action curtails the diversity
and range of beneficial uses
of the environment. For
example, irreversible damage
can result if a standard is
not sufficiently stringent.
-The analysis should be sufficiently
detailed to reveal the Agency's
comparative evaluation of.the
beneficial and adverse environ-
mental, health, social and
economic effects of the proposed
action and each reasonable
alternative.
Irreversible and irretrievable
commitments of resources are discussed
in chapter 7, section 7.5.1.
A summary of the environmental and
economic impacts associated with the
proposed standards are presented in
chapter 1, section 1.2.
A detailed discussion of the environ-
mental effects of each of the
alternative control systems can be
found in chapter 7. This chapter
includes a discussion on the beneficial
and adverse impacts on air, water,
solid waste,.energy, noise, radiation,
and other environmental considerations.
A detailed analysis of the costs and
economic impacts associated with the
proposed standards can be found in
chapter 8.
B-5
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APPENDIX C
EMISSION SOURCE TEST DATA
EPA has made an effort to gather all data and information currently
available that describes the effectiveness of organic solvent cleaning
emission control systems. These data are obtained within the docket and
are summarized by this Appendix which discusses source test data on
three discrete but related subject areas: first, degreaser controls and
the overall emission reductions they can achieve; second, the effectiveness
of carbon beds in adsorbing organics; and third, solvent concentrations
found in steam condensate from regeneration of carbon beds.
C.I DEGREASER CONTROLS
Emission test data have been developed from EPA source tests, and
from tests conducted by organic solvent producers and degreaser manufacturers.
Tests performed on OTVD and CD controlled with a variety of devices, are
reported on in the appendices of the document, "Study to Support New
Source Performance Standards for Solvent Metal. Cleaning Operations,"
written by D. W. Richards and K. S. Surprenant of the Dow Chemical
Company, dated June, 1976. A table, summarizing the information in
these reports is located in Appendix A (Table A-l) of the guideline
document for solvent metal cleaning (CTG). Data on the effectiveness of
various degreaser controls have also been developed by PEDCo Environmental
under contract to EPA's Industrial Environmental Research Laboratory in
Cincinnati, Ohio; by AutoSonics, Incorporated in Norristown, Pennsylvania;
and by Allied Chemical Corporation in Buffalo, New York. Allied has
C-l
-------
requested that the tests conducted by them be kept confidential, pending
publication of the results by the company. Emission tests conducted by
AutoSonics and PEDCo can be found within the docket.
The emission reductions achieved by the various controls on OTVD ranged
from 65 percent down to an actual increase in emissions of 8 percent (four
of these controls were improperly designed or operated). This wide range
exemplifies the need to consider the many factors affecting degreaser emissions
when determining the effectiveness of controls. The size and design of
degreasers, the application or type of work cleaned, and operating procedures
all have large effects. These factors vary widely among existing degreasers
making it difficult to pinpoint a single emission reduction which is representative
of all like controls used throughout the country. No single test can be
cited to define best available control technology. Rather, conclusions have
been drawn through review of all the available test data with an understanding
of the many factors which affected each test.
The docket also includes two series of tests conducted on cold cleaners
by EPA. One test series investigated the effects of solvent agitation, solvent
volatility, freeboard height and covers on evaporation losses. The second
test series further investigated the effects of freeboard height on emissions,
and quantified the amount of carry-out losses that could be expected from
cold cleaners.
The tests on cold cleaners showed petroleum distillate emissions to
be much less than the halogenated organic compound emissions. Also, emissions
increased as draft velocities over the l^p of the cold cleaners increased.
Overall, the controls which have been tested and would be required by this
NSPS are expected to reduce solvent emissions from cold cleaners by 80 percent.
C-2
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C.2 CARBON BED EFFICIENCIES
This section summarizes data which support the performance specifications
on exit gas streams from carbon adsorbers used to control emissions from
degreasers. The data presented includes information obtained from testing
carbon adsorbers on dry cleaning operations. These data are relevant and
applicable because the compounds and inlet concentrations are similar to those
found with carbon adsorbers on degreasers.
Table C-l summarizes the results of tests on nine carbon adsorbers
controlling a variety of organic compounds. The compounds adsorbed include
trichloroethylene, perchloroethylene, 1,1,1-trichloroethane, and mixtures
of several chlorinated and fluorinated methanes and ethanes. For each test,
the inlet and exit concentrations are given along with the type of equipment
the adsorber is controlling, the sampling technique used to develop the
data, and remarks about the sample periods and adsorber operating conditions.
The organic concentrations in the adsorber exit streams ranged from
1 ppm to 45 ppm with one abnormally high value at 308 ppm, which is believed
to reflect breakthrough of the carbon bed during this particular test. In
general, the exit concentrations remained comparatively constant and at a
low level (below 25 ppm) despite widely fluctuating inlet concentrations
which ranged from 25 ppm. to 6600 ppm.
Several of the tests (Nos. 1, 2, 7, and 8) yielded data on how the
exit concentration varies with time throughout the adsorption/regeneration
cycles. Review of these shows that, in general, the adsorber controls very
well and uniformly with varying inlet concentrations until the bed nears
saturation. At this point in time, known as breakthrough, the exit concentrations
increase dramatically and the control efficiency of the carbon adsorber
C-3
-------
Table C-l
TEST DATA ON COLLECTION EFFICIENCY OF CARBON ADSORPTION
FOR SEVERAL ORGANIC COMPOUNDS
Test
1
2
3
4
5
6.
Compound
Trlchloroethylene
2
Trichloroethylene
i
..
4
Trichloroethylene
4
Trichloroethylene
Trichloroethylene
1,1, 1-Trichloroethane
Inlet
Concentrat ions
120
90
-
115
. 70
425
332
-
-
25
165
37 to 145
(range)
148
4745
Exit
Concentrations
4
12
22
45
8
14
10
5
8
2
10
11
18
307**
Adsorber
Application
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Degreaser
Measurement
Technique
Beckman
Model
6800 THC
Analyzer
Scott
Model 215
THC
Analyzer
Gas-Tech
Halide
Meter
Gas-Tech
Halide
Meter
Gas-Tech
Halide
Meter
Carbon tube
adsorption
extraction;
then, GC
analysis of
extract .
Remarks
The 5 samples are 2 to 3
hour averages over
morning and afternoon
.periods. Results are
supported by simultaneous
GC analysis.
The 4 samples 4 to 6
hour averages oh 4
consecutive mornings and
are supported by
simultaneous GC analysis .
The sample is a 3.5
average .
The sample is a 3 hour
average. Both beds
were regenerated during
this period.
The exit concentration
an 8-hour average. Both
beds were regenerated
during this period.
Samples are 2 to 4 hour
averages taken with and
without parts being
degreased .
(continued)
-------
Table C-l (cont'd)
Inlet
Test Compound Concentrations
7 Perchloroethylene 542
748
617
g
8 Perchloroethylene 5300
6300
,6500
9 Mixed Organics9 200 - 500
500
3200 - 6600
45
*t
Exit
Concentrat ions
31
24
17
31
24
16
<10
< 5
3-6
< 1
Adsorber
Application
Dry Cleaner
Dry Cleaner
Dry Cleaner
Dry Cleaner
Dry Cleaner
Dry Cleaner
Laboratory
tests on
carbon
column.
Measurement
Technique
GC/FID; integrated
bag samples
GC/FID; integrated
bag samples.
Detectable
limit = 5 ppm
= 1 ppm
= 1 ppm
Remarks
Samples are 6 hour
averages which do
not include
desorption cycles.
Samples are 1 to 2
hour averages which
do not include
desorption cycles.
Exit concentrations
are prior to break-
through. Compounds
include: CH?C1~;
CH.C1 & CC1,F,; and
C2C12F4.
*ppm by volume, expressed as the compound being controlled.
**the carbon bed in this test was believed to have reached breakthrough during the sampling;period.
-------
drops to zero. Existence of this breakthrough phenomenon with some adsorbers,
along with data on other adsorbers which maintain continuous flow concentrations
throughout periods which include regeneration cycles, show the importance
of correctly timing the adsorption/regeneration cycles. In conclusion, the
data indicate that when correctly designed and properly operated, carbon adsorbers
can continuously reduce a wide range of inlet concentrations to below 25 ppm.
C.3 SOLVENT CONCENTRATIONS IN STEAM CONDENSATE
This section summarizes the available test data on the amount of residual
solvent present in condensate from steam regenerated carbon beds. All data are
developed from adsorbers controlling emissions of perchloroethylene from dry
cleaning operations, but would be applicable to carbon adsorbers controlling
degreasers.
Table C-2 lists the perchloroethylene concentrations found in sewered
condensate from adsorbers in three different locations. Also shown are remarks
to clarify the data presented. Results show average concentrations of
perchloroethylene in the condensate over complete regeneration cycles range
from 38 to 113 ppm. Instantaneous values ranged from nearly 1000 ppm early
in the desorption cycle, to zero near the end of the cycle.
Two general observations can be made from-reviewing the data. First,
the solvent concentration in the condensate is initially quite high but it
drops off quickly. Second, in all cases the average concentration over the
regeneration cycle was less than handbook values of the solubility of
perchloroethylene in water (approximately 1000 ppm).
C-6
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Table C-2
SOLVENT CONCENTRATIONS IN STEAM CONDENSATE
FROM REGENERATION OF CARBON BEDS
Test
1
2
3
Compound
Perchloroethylene
Perchloroethylene
12
Perchloroethylene
Concentration*
in Condensate
1010
62
6
113
38
66
65
102
100
71
Remarks
Instantaneous samples in
the beginning, middle,
and end of a 5-hour
desorption cycle.
Averages over about 1 hour
desorption cycles.
Averages over about 1/2 to 3/4
hour desorption cycle.
* ppm by volume expressed as perchloroethylene.
C-7
-------
References
1. Scheil, George W., Midwest Research Institute, Air Pollution Emission
Test, "Source Test Trichloroethylene Degreaser Adsorber," Report No.
76-DEG-l, prepared for the U. S. Environmental Protection Agency,
Research Triangle Park, North Carlina, February 11, 1976.
2. Scott Environmental Technology, Inc., Plumsteadville, Pennsylvania,
Chlorinated Hydrocarbon Studies at a Solvent Degreasing Plant, prepared
for the U. S. Environmental Protection Agency, Research Triangle Park,
North Carolina, August 30,-1976.
3. Surprenant, K. S., and D. W. Richards, Dow Chemical Company, Study
to Support New Source Performance Standards for Solvent Metal Cleaning
Operations, prepared for the U. S. Environmental Agency, Research
Triangle Park, North Carolina, June 30, 1976, Appendix C-10
4. Reference 3, Appendix C-ll.
5. Reference 3, Appendix C-9.
6. Reference 3, Appendix C-4.
7. Scott Environmental Technology, Inc., Plumsteadville, Pennsylvania,
Air Pollution Emission Test, "Hershey Dry Cleaners and Laundry,"
Report No. 76-DRY-l, prepared for the U. S. Environmental Protection
Agency, Research Triangle Park, North Carolina, March, 1976.
8. Scheil, George W., Midwest Research Institute, Air Pollution Emission Test,
"Texas Industrial Services, San Antonio, Texas," Report No. 76-DRY-2,
prepared for the U. S. Environmental Protection Agency, Research Triangle
Park, North Carolina, June 25, 1976.
9. Hydroscience, Inc., Knoxville, Tennessee, Internal memorandum from
Charles S. Parmele to Ralph E. White, dated April 12, 1978, subject:
"Backup Data to Support Activated Carbon Removal Efficiencies of 99
percent or Greater."
C-8
-------
10. Reference 1.
11. Reference 2.
12. Scheil, George W., and Thomas Merrifield, Midwest Research Institute,
Air Pollution Emission Test, "Westwood Cleaners, Kalamazoo, Michigan,"
Report No. 76-DRY-3, prepared for the U. S. Environmental Protection
Agency, Research Triangle Park, North Carolina, June 25, 1976.
C-9
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APPENDIX D
EMISSION MEASUREMENT AND CONTINUOUS MONITORING
D.I EMISSION MEASUREMENT METHODS
The primary method used to gather emission data has been the integrated
bag sampling procedure followed by gas chromatographic/flame ionization
detector analysis. Appendix A, 40 CFR Part 60, EPA Method 23: Determination
of Halogenated Organics from Stationary Sources," describes this approach.
For this method, the integrated bag sampling technique was chosen over
charcoal adsorption tubes for two reasons: (1) less uncertainty about sample
recovery efficiency, and (2) only one sample portion of analyze per sample
run.
This method was written because an initial EPA funded study on
halogenated hydrocarbon monitoring revealed areas where improvements in
the bag sampling technique were needed. In particular, leaking bags and
bag containers were cited as probable causes of poor correlation between
integrated and grab samples taken at an emission site. In light of these
findings, more rigorous leak check procedures were incorporated. The
first EPA test with the improved method utilized both integrated bag and
grab sampling techniques as forms of quality control. For the three days
during which tests were made, very good correlation between the two techniques
was obtained.
D-l
-------
D.2 MONITORING SYSTEMS AND DEVICES
There are several types of portable, self-contained instruments currently
available for emission monitoring in organic solvent cleaning facilities.
The principles of operation are catalytic-oxidation, flame ionization, photo-
ionization, and infrared energy absorption. All four types of detection
will respond to practically all types of organic materials, although the
relative responses to the different types will vary.
For halogenated solvent operations where a single compound predominates
the instruments can be calibrated with the compound and the results will be
on that basis. Examples of some manufacturers' reported ranges for
perchloroethylene are: (1) catalytic-oxidation, 27-1300 ppmv; (2) flame
ionization, 2-20,000 ppmv; and (3) infrared, 0.5-200 ppm +, depending on
configuration.
The cost of a monitoring instrument ranges from about $1000 to $5000,
depending on the detection principle, operating features, and required
accessories associated with the different instrument types and vendors.
An EPA contractor examined several less expensive systems at a drycleaning
plant in New York and determined them to be inadequate because of erratic
responses.
D.3 PERFORMANCE TEST METHODS
If it is necessary to conduct an emission test for halogenated compounds
on the adsorber vent, then Method 23: "Determination of Halogenated Organics
from Stationary Sources" is recommended as the performance test method.
D-2
-------
In the final draft of Method 23, further leak checks were added as
precautions against erroneous data. These additions were suggested by
an EPA contractor that was studying the vinyl chloride test method. No
particular problems with the use of Method 23 should occur, provided
that strict adherence is made to the leak check procedures. For non-
halogenated VOC emissions, Method 25: "Determiantion of Total Gaseous
Non-Methane Organic Emissions as Carbon: Manual Sampling and Analysis
Procedures: should be the performance test method.
The costs for conducting either a Method 23 or a Method 25 emission
test in triplicate by a source testing contractor will depend on the
length of the carbon adsorber cycle and the distance to be travelled by
testing personnel. They are estimated at $2000 to $5000 for a single
unit installation. Testing costs per unit would be lower if several
units at a single site were tested.
D-3
-------
APPENDIX E. ENFORCEMENT ASPECTS
The selected format for the proposed New Source Performance
Standard is a design/equipment/work practice/operational standard.
The basis for this selection is described in Chapter 9.4. Three
options were considered in determining the enforcement require-
ments for the proposed standard:
A combination of design and equipment specifications by de-
greaser type and size; periodic inspections of work line and
operational practices; prominent display of specified oper-
ational procedures; solvent consumption record-keeping; and
maintenance and training requirements for degreaser users.
A combination of controls applicable to all degreasers re-
gardless of the types and sizes of degreasers; recordkeeping
(e.g., solvent used, reporting all spills and leaks, and ul-
timate disposal); maintenance for all leaks in excess of a
specified amount; daily inspection of all degreasing equipment
by plant personnel; periodic reports to EPA detailing the
above; and routine EPA inspection.
A periodic inspection to check operational practices.
The first option combines design, equipment, work practice, and
operational standards to permit the most efficient emission control
and enforceability. Under this option, a number of measures will
have to be taken by users of degreasers to comply with the proposed
standards; these include:
Purchase of degreasing equipment which meets the design and
equipment standards.
Implementation of proper work practice to minimize emission.
This may include preventative maintenance programs, proper
display of warning signs and work procedure instructions,
E-l
-------
regular inspections, and start-up, shut-down and emergency
procedures.
Record keeping and reporting, certification of training of
degreaser operators, and acquiring equipment operating
manual(s) and making them available to operators.
This option also indirectly provides an incentive to the manufactur-
ers to design to the specified standards. The types of control
equipment specified in the regulations are currently in use and are
commercially available.
The second option would specify design and equipment requirements
for all types of degreasers. Since degreasers are mostly used in
small shops, e.g., garages, the proposed equipment and work practice
standards may represent an unreasonable burden on the users of de-
greasers. Small businesses generally do not have the capability nor
the resources to comply with these requirements. Enforcement of
these practices would require EPA to process detailed routine reports
and to inspect the operations routinely. EPA lacks the resources
necessary to implement this type of enforcement procedure. An unrea-
sonable requirement may lead to litigation which would effectively
postpone implementation of any control measures for degreasers.
The third option does not provide sufficient enforcement to guar-
antee the implementation of a design/equipment/work practice/
operational standard. There is no written certification that the
specified equipment is being used. There is no assurance that the
workers are properly trained or that the equipment is routinely
E-2
-------
maintained. Thus, there would be no assurance of compliance with the
key elements of the standard.
In summary, the second option is excessive because it incorpo-
rates requirements beyond those needed to insure compliance with the
standard while the third option is inadequate because it does not
provide means to insure compliance with the standard. The first
optionwhich is a combination design, equipment, work practice, and
operational standardoffers the best enforcement mechanism to satis-
fy all objectives of the proposed standard. This option therefore
will provide the best emission control and enforceability.
Enforcement of the proposed regulation will be accomplished by
means of EPA on-site inspections of equipment, work practices, and
records; by maintaining certification statements for all affected
facilities; and by maintaining and routinely examining the quarterly
reports that will be submitted in accordance with the regulation.
Reports of inspection should be submitted on special forms suitable
for automatic data processing, and they should be filed with the EPA
Regional Office for the region in which the inspection was made.
Inspection reports should be processed expeditiously; they should be
reviewed regularly in order to concentrate enforcement activities on
facilities with greatest need.
Violations must be adjudicated immediately in order to prevent
the intent of the regulation from being negated. Violations detected
during an inspection must be flagged on the inspection report. In
E-3
-------
the case of each violation that directly affects solvent emissions,
as for example failure to use a prescribed control device, the owner
of the facility must be notified of the violation and the period of
time in which it must be corrected. Action should be taken to halt
the degreasing operation if the violation is not corrected within the
specified time. Violations of record keeping and of other similar
provisions in the regulation that do not affect emissions should be
handled by routine administrative procedures.
E-4
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APPENDIX F. ECONOMICS
F.I MANUFACTURING DECREASING...SIC CODES 25, 33-39
For the purposes of this study it was necessary to estimate the numbers
of cold cleaners, open top vapor degreasers, and closed conveyor degreasers
located in selected 3-digit SIC code manufacturing industries. These estimates
were constructed by adapting, extrapolating and combining the data on
degreasing which exists from previous studies. Although no single work
is sufficient for this purpose, these studies combined provided the infor-
mation necessary for basic estimates of numbers of degreasers.
In a study performed for the Environmental Protection Agency (Richards
and Surprenant, 1976), researchers at the Dow Chemical Company estimated
the number of degreaser systems in 2-digit SIC code manufacturing industries
for 1974. The first step in the estimation procedure was to allocate those
degreasers among the component 3-digit SIC industries. This allocation, which
was based on the Eureka Laboratories estimates of organic solvent emissions in
2
California (Leung et al., 1976) is described below.
The Eureka study determined levels of organic solvent emissions (tons
per day) for various 3-digit SIC code industries' in California in 1976 (X£).
These California figures were converted to national figures (X ) through
the multiplication of each by the ratio of an industry's 1976 nationwide value
of shipments (q ) to its 1976 value of shipments from California (q ). In
each case, the value of shipments used was taken from the Annual Survey
of Manufacturers, 1976. When such figures were unavailable (for California), the
ratio of the number of firms in the U.S. for 1972 to the number of firms in
4
California in 1972, taken from the 1972 Census of Manufacturers, was used to
estimate X . A total emission level was calculated for each 2-digit SIC code
F-l
-------
code industry by summing emissions from the component 3-digit industries. The
share of each 3-digit industry's emissions in the appropriate 2-digit industry
emission total was then calculated. Both total emissions and shares are presented
in Table Fl-1.
Since solvent emissions are produced by the degreasing process, it was
assumed that degreasing systems are distributed in the same manner as solvent
emissions. Accordingly, the emission shares calculated above for 3-digit
industries were applied to DOW's 2-digit industry estimates of total degreasing
systems to produce estimated numbers of degreasing systems within 3-digit
SIC code industries. For closed conveyor and open top vapor degreasers this
application was straightforward: a multiplication of the 2-digit SIC totals
by the 3-digit SIC share estimates. For cold cleaners, further explanation
and adjustment are required.
The Dow survey estimated numbers of degreasing systems in manufacturing
operations employing twenty or more workers. This captured most, if not
all of the closed conveyor and open top vapor degreasers, since such systems
are commonly found in large enterprises. But there are many cold cleaning
systems located in plants with twenty or fewer employees for which an accounting
must be made. Accordingly, it was assumed that, for each 3-digit SIC code
industry, a plant with twenty or fewer workers is just as likely to have a
cold cleaner as is a plant with more than twenty workers. The 1972
Census of Manufactures provides data, for each 3-digit SIC industry, on the
number of establishments with more than twenty employees and the number with
twenty or fewer. For each 3-digit industry, the fraction of all plants with
more than twenty workers having degreasers was calculated. This fraction was
then applied to the number of establishments with twenty or fewer workers, in
order to estimate the number of cold cleaning systems in such plants. The numbers
F-2
-------
TABLE Fl-1. ESTIMATED NATIONAL ORGANIC SOLVENT EMISSIONS
BY DIFFERENT MANUFACTURING INDUSTRY
SIC Industry
25 Metal Furniture
254 Partitions and Fixtures
259 Misc. Furniture and Fixtures
33 Primary Metals
332 Iron and Steel Foundries
335 Nonferrous Rolling and Drawing
336 Nonferrous Foundries
339 Misc. Primary Metal Products
34 Fabricated Products
342 Cutlery, Hand Tools, and Hardware
343 Plumbing and Heating (except Electric
344 Fabricated Structural Metal Products
345 Screw Machine Products, Bolts, etc.
346 Metal Gorgings and Stampings
347 Metal Services
348 Ordnance and Accessories
349 Misc. Fabricated Metal Products
35 Non-Electric Machinery
351 Engines and Turbines
352 Farm and Garden Machinery
353 Construction and Related Machinery
354 Metalworking Machinery
355 Special Industrial Machinery
356 General Industrial Machinery
357 Office and Computing Machines
358 Refrigeration and Service Machinery
359 Misc. Machinery, except Electrical
36 Electric Equipment
361 Electric Distributing Equipment
362 Electrical Industrial Apparatus
364 Electric Lighting and Wiring Equip.
366 Communication Equipment
367 Electronic Components and Accessories
369 Misc. Electrical Equip, and Supplies
37 Transportation Equipment
371 Motor Vehicles and Equipment
372 Aircraft and Parts
376 Guided Missiles, Space Vehicles, Parts
379 Misc. Transportation Equipment
38 Instruments and Clocks
381 Engineering and Scientific Instruments
382 Measuring and Controlling Devices
Emissions
(Tons per Day)
4.13
3.26
0.87
12.26
0.93
2.11
0.76
3.46
106.09
26.87
4.74
17.92
4.05
5.33
26.62
0.11
20.45
105.41
0.79
6.26
9.50
13.35
0.90
42.32
4.69
3.92
23.68
40.26
4.87
1.49
13.49
13.12
6.91
0.38
218.58
35.52
172.03
10.98
0.05
1.90
0.28
1.62
Shares
(3-Digit/2-Digit
Total)
0.789
0.211
0.076
0.172
0.062
0.690
0.253
0.045
0.169
0.038
0.050
0.251
0.001
0.193
0.007
0.059
0.090
0.127
0.009
0.401
0.044
0.037
0.225
0.121
0.037
0.335
0.326
0.172
0.009
0.163
0.787
0.050
0.147
0.853
Total
488.63
F-3
-------
of cold cleaners in small plants were added to the numbers of cold cleaners
in large plants to produce a first estimate of cold cleaning systems in
manufacturing.
In fact, all of the aforementioned estimates of numbers of degreasers
are first estimates only. Several expansions and corrections must be made
in order to generate the best possible estimates. First, the estimates
constructed thus far for cold cleaners are for the numbers of cold cleaning
systems, not the component cold cleaners, per se. Consequently, these estimates
are used mainly to describe the distribution of cold cleaners within the affected
industries rather than to measure the total numbers of cold cleaners. Indepen-
dent information from the EPA [U.S. Environmental Protection Agency, Nov.-,
1977] indicates that there were approximately 340,000 cold cleaners being
used in manufacturing processes in 1974. This total is distributed among the
appropriate 3-digit SIC code industries in accordance with the distribution
of cold cleaning systems described above.
Second, a comparison of Dow's estimates for closed conveyor and open top
vapor degreasers with EPA estimates indicates that the Dow research under-
estimates the number of each kind of cleaner. Again, the estimates constructed
above are considered to represent accurately the distributions of such systems,
if not the total numbers. In order to produce better approximations, corrections
factors of 1.373 for open top vapor degreasers and 1.323 for closed conveyor
degreasers are applied to the estimated numbers of degreaser in 3-digit SIC code
industries.
Next, the estimated numbers of degreasers for 1974 are updated to produce
estimates for 1976. The numbers of degreasers are assumed to increase
approximately in the same proportion as productive capacity. Separate expansion
factors are estimated for each 3-digit SIC code industry. Each factor was
F-4
-------
calculated by dividing real investment in plant and equipment in 1975 and
1976 by the value of plant and equipment in 1976, with the requisite infor-
mation coming from the Annual Survey of Manufacturers, 1976.
Lastly, these estimate of numbers of degreasers are compared with
independent information on such numbers in 1976. EPA estimates for the
numbers of degreasers in 1974 are combined with industry estimates for the
numbers of vapor degreasing systems produced and cold between 1974 and 1976,
to generate estimates of the numbers of closed conveyor and open top vapor
degreasing systems in place in 1976. Such figures indicate that there should
be at least 27,000 open top vapor degreasing systems and at least 4200 closed
conveyor systems in manufacturing in 1976. Since our estimate for closed
systems (4492) is only moderately greater than 4200, it is regarded as
acceptable. For open top vapor degreasing systems, the original estimate (25;604)
is too low. Since the distribution of such systems within the 3-digit industries
is considered to be representative, the number of open top vapor degreaers
within each industry is inflated through multiplication by a factor of (27,000/-
25,604) or 1.0545. The resulting estimate of numbers of degreasers of all
kinds are presented in Table EL-2.
For the purposes of our study, it is necessary, also, to allocate these
degreasing systems across geographic regions. Since there is no direct informa-
tion on degreasers by geograhic area, it is assumed that degreasers are
distributed in the same manner as the manufacture of the goods in whose
production they are used. The 1972 Census of Manufacturers provides data on
the regional values of shipments within many of the 3-digit industries considered
here. For those industries, the total number of degreasers of each type is
allocated among regions on the same basis as the value of shipments. In 3-digit
industries for which information on the regional values of shipments is unavail-
able, data on the numbers of plants in the various regions is used. For those
F-5
-------
TABLE Fl-2. ESTIMATED NUMBERS OF DEGREASERS BY MANUFACTURING INDUSTRY FOR 1976
SIC Industry
25 Metal Furniture
254 Partitions and Fixtures
259 Misc. Furniture and Fixtures
33 Primary Metals
332 Iron and Steel Foundries
335 Nonferrous Rolling and Drawing
336 Nonferrous Foundries
339 Misc. Primary Metal Products
34 Fabricated Products
342 Cutlery, Hand Tools, and Hardware
343 Plumbing and Heating (except Electric
344 Fabricated Structural Metal Products
345 Screw Machine Products, Bolts, etc.
346 Metal Gorgings and Stampings
347 Metal Services
348 Ordnance and Accessories
349 Misc. Fabricated Metal Products
35 Non-Electric Machinery
351 Engines and Turbines
352 Farm and Garden Machinery
353 Construction and Related Machinery
354 Metalworking Machinery
355 Special Industrial Machinery
356 General Industrial Machinery
357 Office and Computing Machines
358 Refrigeration and Service Machinery
359 Misc. Machinery, except Electrical
36 Electric Equipment
361 Electric Distributing Equipment
362 Electrical Industrial Apparatus
364 Electric Lighting and Wiring Equip.
366 Communication Equipment
367 Electronic Components and Accessories
369 Misc. Electrical Equip, and Supplies
37 Transportation Equipment
371 Motor Vehicles and Equipment
372 Aircraft and Parts
376 Guided Missiles, Space Vehicles, Parts
379 Misc. Transportation Equipment
38 Instruments and Clocks
381 Engineering and Scientific Instruments
382 Measuring and Controlling Devices
39 Miscellaneous Industry
TOTAL
Cold
Cleaners
9,421
6,156
3,265
18,011
1,992
2,246
4,058
9,715
86,408
11,891
2,772
25,131
5,409
5,892
19,157
132
16,024
189,693
792
8,238
11,089
38,152
10,467
30,734
4,589
6,085
79,547
45,542
3,945
4,138
10,935
11,339
10,196
4,989
27,985
10,944
11,967
716
4,358
23,883
6,086
17,797
15,936
416,879
Open Top
Vapor De-
greasers
460
351
109
1,773
137
277
105
1,254
4,486
1,152
205
771
160
205
1,124
5
864
4,748
33
304
451
569
41
1,876
220
169
1,085
7,587
871
279
2,465
2,539
1,362
71
3,587
630
2,779
178
0
3,744
550
3,194
614
26,999
Closed
Conveyor
Degreasers
153
117
36
442
34
70
25
313
1,088
280
49
187
39
50
273
1
209
1,014
6
65
96
122
9
402
47
35
232
996
115
36
324
333
178
10
507
89
393
25
0
219
32
187
73
4,492
F-6
-------
industries, degreasers are assumed to be distributed in the same manner as
manufacturing establishments. The resulting geographic distribution of cold
cleaners is presented in Table Fl-3.
Analogous estimates for open top and closed conveyor vapor degreasers are
found in Table Fl-4 and Table Fl-5, respectively.
F-7
-------
Table Fl-3. NUMBERS OF COLD CLEANERS BY GEOGRAPHIC LOCATION*.
T
oo
SIC
25
2b4
259
33
-iJl*
335
336
339
34
J4
-------
Table Fl-3 (continued)
SIC
37
Sli
372
376
379
38
381
382
39
401
458
753
Industry
Transportation Equipment
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles, Space Vehicles, Parts
Misc. Transportation Equipment
Instruments and Clocks
Engineering and Scientific Instruments
Measuring and Controlling Devices
Miscellaneous Industry
Total Manufacturing
Railroads - Maintenance*
Air Transport - Maintenance
Auto Repair'
Total Service
General Industrial Usage1
TOTAL
North
East
1,785
109
1,568
30
78
2,963
578
2,385
2,454
34,629
-
1,369
22,979
24,348
17,179
76,156
Mid
Atlantic
2,262
930
981
59
292
5,188
1,308
3,880
5,450
79,851
-
2,915
58,733
61.648
56,004
197,503
East
North-
Central
9.688
6.621
1.568
4
1,495
6,193
1,637
4,556
3,171
147,308
-
5,805
87,471
93,276
94,829
335,413
West
North-
Central
3.020
1,029
1,113
50
828
1,520
310
1,210
813
30.152
-
5,203
48,224
53,427
27,487
111,066
South
Atlantic
2,112
952
814
54
292
993
335
658
1,052
28.942
-
4,368
76,566
80,934
42,948
152,824
East
South-
Central
623
328
132
19
144
405
85
320
765
17,592
-
2.288
33.757
36,045
21.302
74,939
West
South-
Central
1.788
197
1197
15
379
640
213
427
574
22,974
-
5,641
58,637
64,278
35,733
122,985
Mountain
470
22
215
59
174
978
213
765
239
7,454
-
3,404
26,519
29,923
8,590
45.967
Pacific
6,456
755
4,368
370
963
5,047
1,345
3,702
1,418
50,167
5,167
55,141
60,308
39,512
149,987
TOTAL
28,204
10,943
11,956"
660
4,645
23,927
6.024
17,903
15,936
419,069
1,161
36,160
468.027
505.348
343.584
1,268,001
*As a result of rounding, numbers may differ slightly from those In the previous tables.
*The geographic distribution of railroad maintenance Is not available.
§Data for auto repairs is actually for 1975, but represents as close an estimate for 1976 as Is possible.
'Represents degreasers used for general Internal maintenance throughout the economy.
-------
Table Fl-4. NUMBERS OF OPEN TOP VAPOR DEGREASERS BY GEOGRAPHIC LOCATION*.
SIC
25
2i>4
259
33
JJ2
335
336
339
34
342
343
344
345
346
347
348
349
35
3bl
352
353
354
355
356
357
358
359
36
361
362
364
366
367
369
Industry
Metal Furniture
Partitions and Fixtures
Misc. Furniture and Fixtures
Primary Metals
Iron and Steel Foundries
Nonferrous Rolling and Drawing
Nonferrous Foundries
Misc. Primary Metal Products
Fabricated Products
Cutlery, Hand fools, and Hardware
Plumbing and Heating (except Electric)
Fabricated Structural Metal Products
Screw Machine Products, Bolts, etc.
Metal Gorgings and Stampings
Metal Services
Ordnance and Accessories
Misc. Fabricated Metal Products
Non-Electric Machinery
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Metalworklng Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Misc. Machinery, except Electrical
Electric Equipment
Electric distributing Equipment
Electrical Industrial Apparatus
Electric Lighting and Wiring Equip.
Comnunl cation Equipment
Electronic Components and Accessories
Misc. Electrical Equip, and Supplies
North
East
20
14
6
166
3
34
4
125
400
187
7
32
17
9
91
1
56
350
5
1
4
67
6
165
31
3
68
770
91
18
264
239
154
4
Mid
Atlantic
101
83
18
352
19
61
19
253
782
192
35
136
26
27
202
1
163
908
6
12
53
88
7
448
47
38
209
2,052
246
59
695
543
500
9
East
North-
Central
148
109
39
748
78
79
53
538
1.804
518
93
193
88
146
442
1
323
1,852
17
134
221
316
12
752
25
67
308
1,762
206
114
737
465
207
33
West
North-
Central
35
28
7
78
6
12
7
53
229
45
9
59
4
4
53
1
54
429
1
98
46
24
2
120
24
17
97
382
69
13
113
135
42
10
South
Atlantic
49
34
15
73
9
29
2
33
291
46
16
106
4
4
64
0
49
250
2
14
16
31
7
81
14
7
78
750
104
26
195
328
91
6
East
South-
Central
21
16
5
' 110
9
29
6
66
205
36
17
56
5
5
26
0
60
205
0
28
9
8
1
69
20
16
54
368
66
20
187
71
22
2 .
West
South-
Central
24
20
4
72
6
10
3
53
261
13
7
89
2
3
71
1
75
257
0
7
60
7
1
83
4
13
82
419
31
16
69
216
84
3
Mountain
8
7
1
30
1
9
0
20
48
8
0
19
1
0
9
0
11
82
0
3
7
2
0
23
19
0
28
149
3
1
15
74
56
0
Pacific
54
40
14
158
7
18
11
122
472
112
20
79
13
7
167
1
73
434
5
7
33
27
5
135
39
7
176
939
56
11
187
470
211
4
TOTAL
460
351
109
1,787
138
281
105
1,263
4,492
1,157
204
771
160
205
1.125
6
864
4,767
36
304
449
570
41
1,876
223
168
1,100
7,591
872
278
2.462
2,541
1,367
71
-------
Table Fl-4 (continued)
SIC
37
371
372
376
379
38
381
382
39
401
458
Industry
i<
Transportation Equipment
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles, Space Vehicles, Parts
Misc. Transportation Equipment
Instruments and Clocks
Engineering and Scientific Instruments
Measuring and Controlling Devices
Miscellaneous Industry
Total Manufacturing
Railroads - Maintenance*
Air Transport - Maintenance
Total Service
TOTAL
North
East
377
6
364
7
0
480
52
428
95
2,658
-
120
120
2,778
Mid
Atlantic
297
54
228
15
0
814
118
696
210
5,516
-
228
228
5,744
East
North-
Central
746
381
364
1
0
966
148
818
122
8,148
-
498
498
8,646
West
North-
Central
329
59
258
12
0
245
28
217
31
1,758
-
483
483
2,241
South
Atlantic
258
55
189
14
0
148
30
118
41
1,860
-
450
450
2,310
East
South-
Central
55
19
31
5
0
65
8
57
29
1,058
-
257
257
1,315
West
South-
Central
293
11
278
4
0
96
19
77
22
1,444
-
529
529
1,973
Mountain
66
1
50
15
0
156
19
137
9
548
-
315
315
863
Pacific
1,149
43
1,014
92
0
786
122
664
55
4,047
-
399
399
4.446
TOTAL
3.570
629
2,776
165
0
3,756
544
3,212
614
27,037
6.1
3,279
3.340
30,377
*As a result of rounding, numbers may differ slightly from the previous table.
*The geographic distribution of railroad maintenance Is not available.
-------
Table Fl-5. NUMBERS OF CONVEYORIZED VAPOR DEGREASERS BY GEOGRAPHIC LOCATION*.
North
East
Hid
Atlantic
East
North-
Central
West
North-
Central
South
Atlantic
East
South-
Central
West
South-
Central Mountain Pacific
TOTAL
(-
N>
25 Metal Furniture
254 Partitions and F1 xtures
259 M1sc. Furniture and Fixtures
33 Primary Metals
332Iron and SteeT Foundries
335 Nonferrous Rolling and Drawing
336 Nonferrous Foundries
339 Misc. Primary Metal Products
34 Fabricated Products
34~2Cutlery, Hand Tools, and Hardware
343 Plumbing and Heating (except Electric)
344 Fabricated Structural Metal Products
345 Screw Machine Products, Bolts, etc.
346 Metal Gorglngs and Stampings
347 Metal Services
348 Ordnance and Accessories
349 Misc. Fabricated Metal Products
35 Non-Electric Machinery
351Engines and Turbines
352 Farm and Garden Machinery
353 Construction and Related Machinery
354 Metal work Ing Machinery
355 Special Industrial Machinery
356 General Industrial Machinery
357 Office and Computing Machines
358 Refrigeration and Service Machinery
359 Misc. Machinery, except Electrical
36 Electric Equipment
351Electric Distributing Equipment
362 Electrical Industrial Apparatus
364 Electric Lighting and Wiring Equip.
366 Communication Equipment
367 Electronic Components and Accessories
369 Misc. Electrical Equip, and Supplies
7
5
2
41
1
8
1
31
97
45
2
8
4
2
22
0
14
75
1
0
1
14
1
35
7
1
15
101
12
2
35
31
20
1
34
28
6
88
5
15
. 5
63
190
47
8
33
6
7
49
0
40
195
1
3
11
19
2
96
10
8
45
268
32
8
91
71
65
1
49
36
13
186
19
20
13
134
437
126
22
47
21
36
107
0
78
396
3
29
47
68
3
161
5
14
66
232
27
15
97
61
27
5
11
9
2
19
1
3
2
13
55
11
2
14
1
I
13
0
13
91
0
21
10
5
0
26
5
. 3
21
51
9
2
15
18
6
1
16
11
5
17
2
7
0
8
71
11
4
26
1
1
16
0
12
54
0
3
3
7
2
17
3
2
17
99
14
3
26
43
12
1
7
5
2
27
2
7
1
17
48
9
4
13
1
1
6
0
14
44
0
6
2
2
0
15
4
3
12
49
9
3
25
9
3
0
8
7
1
18
1
3
1
13
63
3
2
22
0
1
17
0
18
56
0
1
13
2
0
18
1
3
18
54
4
2
9
28
11
0
2
2
0
7
0
2
0
5
12
2
0
5
0
0
2
0
3
18
0
1
2
0
0
5
4
0
6
19
0
0
2
10
7
0
17
13
4
39
2
4
3
30
115
27
5
19
3
2
41
0
18
93
1
2
7
6
1
29
8
1
38
124
7
1
25
62
28
1
151
116
35
442
33
69
26
314
1088
281
49
187
37
51
273
0
210
1022
6
G6
96
123
9
402
47
35
238
997
114
36
325
333
179
10
-------
Table Fl-5 (continued)
East West East West
North Mid North- North- South South- South-
East Atlantic Central Central Atlantic Central Central Mountain Pacific
TOTAL
37
37T
372
376
379
38
3til
382
39
Transportation Equipment
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles, Space Vehicles, Parts
M1sc. Transportation Equipment
Instruments and Clocks
Engineering and Scientific Instruments
Measuring and Controlling Devices
Miscellaneous Industry
Total Manufacturing
53
1
51
1
0
28
3
25
11
413
42
8
32
2
0
I
48
7
41
25
890
105
54
51
0
0
57
9
48
15
1477
47
8
37
2
0
15
2
13
4
293
37
8
27
2
0
9
2
7
5
308
8
3
4
1
0
3
0
3
4
190
42
2
39
1
0
5
1
4
3
249
9
0
7
2
0
9
1
8
1
77
162
'6
143
13
0
46
7
39
6
602
505
90
391
24
0
220
32
188
74
4499
*As a result of rounding, numbers may differ slightly from those on the previous tables.
M
CO
-------
F.2 MAINTENANCE DECREASING OF RAILROAD STOCK
A study of 4 railroad maintenance depots in California revealed that
each month 505 gallons of chlorinated solvents and 1184 gallons of petroleum
solvents, alcohols and ketones were used in conjunction with vapor degreasers
and cold cleaners to maintain 4432 locomotives (Leung et al., 1978). It is
assumed that the non-chlorinated solvents were used in cold cleaners of average
size and that the chlorinated solvents were used in open top vapor degreasers.
Utilizing the EPA estimates of average annual emissions for maintenance for
cold cleaners (6.5 gallons per unit per month) (EPA, 1977), and industry estimates
of solvent usage in open top degreasers* (50 gallons per unit per month), the
California plants are assumed to operate 190 cold cleaners and 10 vapor degreasers.
In 1976 the total number of locomotives in the U. S. A. was 27,609. Multiplying
the estimated number of degreasers in the 4 California plants by 27,609/4,432
(=6.11) an estimate of total number of degreasers used in railroad maintenance
is obtained (1161 cold cleaners and 61 open top vapor degreasers).
*Telephone conversation with Joseph Pokorny of Baron Blakeslee.
F-14
-------
F.3 MAINTENANCE DECREASING OF AIRCRAFT
The estimates of degreasers used in aircraft maintenance were obtained
in the following manner: A detailed study of degreasing at Mather Air Force
Base, California (Leung et al. 1978) an airport with lighted and paved runways,
the use of 1 open topped vapor degreaser and 8 cold cleaners at the base. All
similar airports were assumed to use the same number of degreasers. Airports
not paved or lighted were assumed to utilize one cold cleaner in maintenance
operations. Data on numbers and types of airports by region was obtained for
1975 from Table 3-S of the FMA Statistical Handbook and are presented in Table
Fl-6. The estimates of degreasing activities are highly speculative as data
on only one airport was available and, farther, it was arbitrarily assumed
that all unpaved and/or unlighted airports only use one cold cleaner for main-
tenance .
F-15
-------
F.3-1. DISTRIBUTION OF AIRPORTS BY REGION
East West East West
New Mid North- North- South South- South-
England Atlantic Central Central Atlantic Central Central Mountain Pacific TOTAL
if of Lighted
and Paved 120 228 498 483 A50 257 529 315 399 3,279
Airports
# of Unlighted
or Unpaved 409 1,091 1,821 1,339 768 232 1,409 884 1,975 9,928
Airports
TOTAL 529 1,319 2,319 1,822 1,218 489 1,938 1,199 2,374 13,207
N
M SOURCE: References 2 and 6.
o\
-------
F...4 AUTO REPAIR DECREASING
The number of repair and maintenance facilities for each of the three
years in Table Fl-7 were taken from Service Job Analysis, Hunter Publishing
Co., Chicago, 111. (1978). Using data on state breakdowns of service stations,
from Chilton's Motor Age Automotive Marketing Guide, Chilton, PA. (1976), regional
shares for car and truck repair and maintenance facilities were derived from
the Service Job Analysis information. Our estimates of degreasers per facility
was reported in Alternatives to Organic Solvent Degreasing, Eureka Laboratories,
Sacramento, Cal. (1978).
F-27
-------
Table F4-1. ESTABLISHMENTS AND DEGREASERS IN AUTOMOTIVE AND TRUCK REPAIR MAINTENANCE
r
H
00
Number of
Establishments
Engaged In
Automobile
and Truck
Repair and
Maintenance
Number of
Degreasers In
Automobile
and Truck
Repair and
Maintenance
1973
1975
1978
1973
1975
1978
Mid
Atlantic
45.430
45,179
43.423
59.059
58.733
56.450
East
North-
Central
67.658
67.285
64.668
87,955
87,471
84,068
West
North-
Central
37,301
37.095
35,652
48.491
48.224
46.348
South
Atlantic
59.206
58.897
56.588
76.968
76.566
73.564
East
South-
Central
26.111
25.967
24.957
33.944
33,757
32.444
West
South-
Central
45.355
45.105
43,351
58.962
58,637
56,356
Mountain
20,512
20.399
19.605
26.666
26.519
25.487
Pacific
42,651
42.416
40,766
55,446
55,141
52,996
New
England TOTAL
17,775
17,676
16,989
23,108
22.979
22.086
362.000
360.000
342.000
470.600
468.000
444.600
-------
F.5 ESTIMATED COSTS OF DECREASING OPERATIONS
In any given year a firm will incur costs as a consequence of its de-
greasing activities. These costs will change as capital equipment require-
ments, manpower, energy use and solvent use change in response to NSPS's.
This appendix presents estimates of the annualized costs of uncontrolled
degreasing operations. The estimates are based on the assumption that no
firm uses any of the controls recommended under the proposed NSPS's. This
is an "unrealistic" assumption because some firms do utilize the operating
procedures and control equipment recommended in the NSPS's. However, it is
a useful assumption in the sense that it identifies the extreme pre-standard
case. Any other assumption about the pre-standard situation would imply
smaller NSPS economic impacts. In addition, given the imprecise nature of
existing information on actual degreasing activities and the extent to which
firms already comply with the proposed NSPS's, any other assumption would be
equally arbitrary.
F.5.1 Cost Estimates
The annualized cost of any degreasing operation has two components:
(1) an annual capital charge and (2) variable costs (including the cost of
labor, energy, solvent and maintenance services). The annual capital charge
is estimated on the basis of the following formula:
1
ACC «= IC( L + AOR + MSR)
Z d+r)
1=1
where ACC = annual capital charge
1C = installed capital cost
L - lifetime of the asset in years
r - rate of Interest
F-19
-------
AOR = administrative overhead rate
MSR = maintenance service rate.
The formula is derived partially from the theory of present values. The
present value of an annual income stream of one dollar over a period of L
L
years is Z(l4r)~*-. Letting the annual capital recovery charge be defined
L
by the mnemonic ACRC, the expression ACRC z(l+r)-i may be defined as
the present value of the stream of annual capital recovery charges. If the
discounted sum of future returns to a given piece of capital equipment are
to be sufficient to cover its costs to the firm, then the present value of
the stream of ACRC's must be equal to the installed cost of capital; i.e.,
L L
1C = ACRC zU+r)'1. Solving for ACRC, we have ACRC = IC/Zl+r)"1. Note
that this formula is appropriate even if the firm finances capital from
internal funds.
In this study all capital equipment is assumed to have a life of 15
years and the market rate of discount is taken to be 10 percent. Conse-
L
quently the value of the capital recovery factor, Z(l+r)~l, is 0.131. The
annual overhead and maintenance service charges are both assumed to be 4
percent of the value of the installed capital costs. Consequently, the
value of the annual capital charge for any degreasing cost is given by the
empirical formula:
ACC - IC(0.131 -I- 0.04 + 0.04) - 1C (0.211).
Annual variable costs consist of payments for solvent, labor and
energy.
F.5.1.1 Solvent Costs. It is assumed that in the base year (1976) the
cost of solvent used in cold cleaning (mineral spirits) is 2\i per kilogram.
The cost of the solvent (trichloroethylene) used in both types vapor de-
greasers is assumed to be 45£ per kilogram.
F-20
-------
p. 5.1.2 Energy Costs. Cold cleaners require a negligible amount of energy
in their operations. However, the same cannot be said for open top and
conveyorized vapor degreasers. In both operations solvent must be heated to
create the vapor layer in which cleaning takes place and further heat must
be applied to work loads to insure that effective vapor cleaning is
achieved. Three types of heat may be utilized to create vapors and heat
materials: (1) electricity, (2) gas and (3) steam. Industry sources
indicate that usually electricity is used in the operation of open top vapor
degreasers and steam in the operation of conveyorized degreasers. 1978
prices for electricity and steam are assumed to be $0.043 per KWH and $7.26
per 1000 kg of steam respectively. The electricity price was deflated by
the BLS wholesale price index for electricity and the steam price by the RLS
wholesale price index for coal to obtain estimates of 1976 prices for
electricity and steam (see Table G2-1). Annual energy costs were calculated
as the sum of payments for electricity and steam.
F.5.1.3 Labor Costs. The operation of degreasers requires labor. However
labor costs will vary across SIC code industries because of wage rate
variations and are thus industry specific. In this study hourly labor costs
are measured by the average gross hourly earnings of production (non-
supervisory) workers in each 3 digit SIC code industry for the base year,
1976. Data on hourly earnings are presented in Table F2-2. Total labor
costs are estimated as number of manhours spent degreasing multiplied by
costs (hourly earnings).
In order to calculate pre-NSPS annual degreasing costs it was nec-
essary to identify representative degreasing operations for each of the
three types of degreasers. Given the lack of survey data on degreasing
operations, a number of degreasing equipment manufacturers were contacted by
F-21
-------
Table F5-1. ENERGY COSTS, 1976 AND 1978
BLS Producer Price Indexes
Year Coal Electricity
Price of
Electricity
$lkWh
Price of
Steam
$11000 kg.
1976
1978
368.7
432.4
207.6
252.8
$ 0.035*
$ 0.043*
$ 6.29*
$ 7.26#
U.S. Department of Labor, Bureau of Labor Statistics, Producer Prices.
and Price Indexes.
^Source: MITRE.
*1976 Price = 1978 Price x 1976 Price Index
1978 Price Index.
F-22
-------
Table F5-2. LABOR COSTS, 1976*.
SIC Code Gross
Hourly Earnings of Production
and Non-Supervisory Workers
254
259
332
335
336
339
342
343
344
345
346
347
348
349
351
352
353
354
355
356
357
358
359
361
362
364
366
367
369
371
372
376
379
381
382
39
401
458
753
GIU
Partitions and Fixtures
Misc. Furniture and Fixtures
Iron and Steel Foundries
Nonferrous Rolling and Drawing
Nonferrous Foundries
Misc. Primary Metal Products
Cutlery, Hand Tools, and Hardware
Plumbing and Heating (except Electric)
Fabricated Structural Metal Products
Screw Machine Products, Bolts, etc.
Metal Gorgings and Stampings
Metal Services
Ordnance and Accessories
Misc. Fabricated Metal Products
Engines and Turbines
Farm and Garden Machinery
Construction and Related Machinery
Metalworking Machinery
Special Industrial Machinery
General Industrial Machinery
Office and Computing Machines
Refrigeration and Service Machinery
Misc. Machinery, except Electrical
Electric Distributing Equipment
Electrical Industrial Apparatus
Electrical Lighting and Wiring Equip.
Communication Equipment
Electronic Components and Accessories
Misc. Electrical Equip, and Supplies
Motor Vehicles and Equipment
Aircraft and Parts
Guided Missiles, Space Vehicles, Parts
Misc. Transportation Equipment
Engineering and Scientific Instruments
Measuring and Controlling Devices
Miscellaneous Industry
Railroads - Maintenance
Air Transport - Maintenance
Auto Repair
.
*Source: Department of Labor BLS; Employment
$4.82
4.41
6.16
6.01
5.22
6.45
5.22
4.86
5'.34
5.24
6.10
4.43
4.68
5.31
6.64
6.08
6.03
5.94
5.36
5.73
5.29
5.22
5.57
5.10
4.97
4.87
5.62
4.11
5.65
7.10
6.45
4.43
4.43
5.13
4.73
4.01
6.88
6.46
6.46
4.87
and Earnings, Vol. 24, 3
March 1977. The figure used for 458 and 753 is the one
presented for the 2 digit industry SIC-45 - General
Transport. Specific earnings rates are not published
by BLS for 458 and 753 because of data problems.
F-23
-------
RTI and asked to describe typical plant degreasing equipment. This infor-
mation was combined with a number of assumptions concerning capacity
utilization rates to identify typical operations. These typical operations
and the associated annualized capital charges, solvent costs, energy costs
and manpower requirements are described in Tables F5-3 toF5-5. Total
v-
annual costs for each type of degreasing activity by SIC code industry are
presented in Table F5-6. They include the annual capital charge, solvent
costs, energy costs and labor costs. The estimates vary across industries
because of the variations in labor costs discussed above.
F-24
-------
Table F5-3. TYPICAL UNCONTROLLED DECREASING OPERATION: COLD CLEANERS.
Cost
Category
*
CAPITAL STOCK
Assumptions
75% of all degreasers have a 15
gallon tank with a solvent-air
interface area of 0.56 m2- The
1978 Installed Capital cost of
this degreaser is assumed to be
$339.00.
25% of all degreasers have a 65
gallon tank with a solvent-air
interface area of 0.56m2
1978 installed capital cost of
this degreaser is assumed to be
$660.00.
Cost Estimates
Annualized Capital Charge of
cold cleaners
= $[(0.75)339.00 + (0.25)660]
x 0.21111
= $88.46.
SOLVENT
ENERGY
All machines are assumed to be
left uncovered at all times.
The vaporization rate of
mineral spirits is assumed to
be 0.188 kg/hr-m2. Annual
solvent loss from vaporization
is thus: [0.75 x 0.56 + 0.25 x
0.58]m2 x [0.188 kg/hr-m2] x 24
hrs x 365 days = 494.94 kg.
Each machine is assumed to
process 20 work loads each day,
5 days a week, 52 weeks a year.
Solvent loss from uncontrolled
carryouts is assumed to be 14.2g
per load. Solvent loss from
carryout is thus: 0.0142 kg x
20 hr x 260 days = 73.840 kg.
Waste solvent discarded by
cold cleaner operators as
unusable is assumed to be 50%
of total solvent use; i.e.,
equal to solvent lost in
carryout and through
vaporization. Total solvent
usage is thus 1137.5kg.
;
Cold cleaners are assumed to
use negligible amounts of
energy.
Annual Solvent Cost
= 1137.5 kg x $0.21 per kg
= $390.8.
F-25
-------
Table F5-3 (Concluded).
Cost
Assumptions
Cost Estimates
LABOR+ Each machine is assumed to be
operated for 2 hours each day,
5 days per week, 52 weeks per
year. Total manpower require-
ments are thus 520 hours.
Annual Labor cost = 52 hrs
x gross hourly earnings of
labor
*Data on typical cold cleaner operations provided to RTI by Larry Shields of
Gray Mills Corporation'in a telephone conversation on June I, 1978.
//Installed capital labor data for 15 gallons or 65 gallons tank degreasers
obtained from Gray Mill 1978 price lists 14K 10 PL-II and 65 PL-15.
tData on solvent usage and labor usage provided by MITRE corporation.
110.211 is the estimated captial recovery, overhead and maintenenace
charge coefficient.
§Data on solvent waste obtained from Appendix D of OAQPS Document, Control of
Volatile Organic Emissions from Solvent Metal Cleaning, Appendix B,
EPA-450/2-77-022.
F-26
-------
Table F5-4.
TYPICAL UNCONTROLLED DECREASING OPERATION:
OPEN TOP VAPOR DEGREASER
Cost
Category
Assumptions
Cost Estimates
(1976)
CAPITAL* .. The typical open top vapor de-
greaser has a vapor interface area
of 1.32 m . The tank holds 115
gallons of solvent. The 1978 in-
stalled capital cost of this de-
greaser was $4766.5. The 1976
cost is assumed to be 20% less,
or $3972.08.
Annualized Captial Charge of
an OTVD in 1976
= $3972.08 x 0.211
= $ 838.11.
SOLVENT t The vaporization rate for solvent
in an OTVD is assumed to be 1.82
kg/hr m . The degreaser is
assumed to be left uncovered 8
hours per day, 5 days per week, 52
weeks per year. Solvent loss from
vaporization is thus 1.82 kg/hr m
x
5262 kg..
2
1.39 m x 8 hrs x 260 days
The machine is assumed to be in
use 6 hours per working day and ~
carryout losses are 1.47 kg/hr m .
Thus annual solvent loss from
carryout is 1?47 kg/hr x (260 x 6
hrs) x 1.39 m = 3187.5 kg.
Annual Total
Wash solvent, discarded as un-
usable, is assumed to be 22.5% of
total solvent use. Thus total
annual solvent use is estimated to
be 10903 kg.
Annual Solvent Cost
= 8449.5 kg x $0.45
= $4906.
ENERGY*+ The degreaser is assumed to be
heated by electricity and its ele-
ment to have a capacity of 24 kW
It is assumed that element is
operating at full capacity 8 hours
per day, 5 days per week, 52 weeks
per year.
Annual Energy Costs
= (24 kW) (260 x 8 hrs) (0.035)
- $1747.20.
F-27
-------
Table F5-4 (Concluded).
Cost Assumptions Cost Estimates
Category (1976)
LABOR+ Each machine is assumed to be Annual Labor Costs
generated for 6 hours per day, 5
days per week, 52 weeks per year. = 1560 hrs x gross hourly
Total manpower requirements are earnings.
thus 1560 hrs. The 1978 in-
stalled capital cost of this de-
greaser is $4766.5. The 1976 cost
is assumed to be 20% less, or
$3972.08.
*Data on typical OTVD capital equipment specifications, prices and price
changes, and energy supplied to RTI by Richard Clements of Detrex, Ltd.
in a telephone conversation on August 15th.
+Data on solvent usage and labor usage estimated by MITRE.
F-28
-------
Table F5-5.
TYPICAL UNCONTROLLED DECREASING OPERATION;
CONVEYORIZED VAPOR DEGREASER (CVD)
Cost
Category
Assumptions
Cost Estimates
(1976)
CAPITALt The typical CVD is assumed to be a
cross rod two dip degreaser with
12 rotating baskets.
The 1978 price of the degreaser is
$33,000 and the price,of fixtures
for each basket $900. The cost of
the total unit is thus $41,600.
The 1978 cost of this equipment is
assumed to be 20% more than its
1976 cost. Thus the 1976 cost of
the machinery is $34,667. Instal-
lation costs are incurred by the
firm as a result of the extra
building space needed for the CVD.
The 1976 cost of space is esti-
mated to be $30/sq. ft.// The
space required by the2CVD is esti-
mated to be 109.3 ft. . Building
costs are therefore $3280. The
total installed capital cost is
thus $37947.
Annual Capital Cost
= $37947 x 0.211
= $8006.8
SOLVENT* Annual solvent vaporization for a
cross rod CVD with a vapor inter-
face area of 40 sq. ft. is esti-
mated to be 23296 kg. Waste
solvent, discarded as unusable, is
assumed to be 15% of total solvent
use. Thus total annual solvent
use is estimated to be 27607 kg.
Annual Solvent Cost
= 27407 kg x $0.54
= $12333.
ENERGY- The typical CVD uses steam as a
heat source at the rate of 340 Ibs
per hour. The machine is assumed
to be utilized 8 hours per day, 5
days per week, 52 weeks per year.
The annual total amount of steam
used is thus 707200 Ibs or
321455'kg.
Annual Total Energy Cost
321455 kg x $6.19
1000 ks
= $1990.
F-29
-------
Table F5-5 (Concluded).
Cost Assumptions Cost Estimates
Category (1976)
LABOR The CVD is assumed to be operated Annual Labor Cost
8 hours per day, 5 days per week,
52 weeks per year. Annual man- = 2080 hrs x gross hourly
power requirements are thus 2080 earnings.
hours.
Data on typical CVD's supplied to RTI by Richard Clements of Detrex in a
telephone conversation on August 15th.
*Solvent-usage calculated on the basis of solvent savings from the
utiliztion of carbon adsorbers estimated by MITRE.
#The 1978 cost of building estimate identified by MITRE to be $35 sq. ft.
was deflated by the Department of Commerce Composite Construction Index
whose value in 1976 was 143.5 and March 1978 was 267.5.
F-30
-------
Table F5-7. Annualized Costs of a Typical Uncontrolled Degreasing Operation
By Type of Degreaser and SIC Code Industry.
SIC Code
n
u>
254 Partitions and Fixtures
259 Misc. Furniture and Fixtures
332 Iron and Steel Foundries
335 flonferrous Rolling and Drawing
336 Nonfcrrous Foundries
339 Misc. Primary Metal Products
312 Cutlery, Hand Tools, and Hardware
343 Plu'nbing and Moatim! (except Electric)
344 Fabricated Structural Metal Products
345 Screw Machine Products, Holts, etc.
346 Metal Gorgings and Stampings
34/ Metal Services
348 Ordnance and Accessories
349 Misc. Fabricated Metal Products
351 Engines and Turbines
352 Farm and Garden Machinery
353 -Construction and Related Machinery
354 Metalworking Machinery
355 Special Industrial Machinery
356 General Industrial Machinery
357 Office and Computing Machines
358 Refrigeration and Service Machinery
359 Misc. Machinery, except Electrical
361 Electric Distributing F.quipment
362 Electrical Industrial Apparatus
364 Electric Lighting and Wiring Equip.
366 Communication Equipment
3f>7 Electronic Components and Accessories
369 Misc. Electrical Equip, and Supplies
371 Motor Vehicles and Equipment
372 Aircraft and Parts
376 Guided Missiles, Space Vehicles, Parts
379 Misc. Transportation Equipment
381 Engineering and Scientific Instruments
382 Measuring and Controlling Devices
39 Miscellaneous Industry
401 Railroads - Maintenance
458 Air Transport - Maintenance
753 Auto Repair
Cold Cleaners
2986
2772
3602
3604
3194
3833
3194
3006
3256
3204
3650
2782
2912
3240
3932
3641
3614
3560
3266
3459
3230
3194
3376
3131
3064
3012
3402
2610
341/
4171
3833
2783
2783
3147
2933
2564
4057
3838
3038
Open Top Vapor
Oegrejsers
14710
14071
16801
16567
15335
17256
15335
14/73
15522
15366
16708
14102
14492
15475
17550
165/6
16598
16458
15553
16130
15444
15334
10881
15118
14945
14789
15959
13588
16006
18268
17254
14102
14102
15194
14570
13447
17924
17269
17?69
Convey or 17 ed
Ponreiise
32355
31502
3514.?
34830
33137
35/46
33 in/
32439
33437
?3229
35073
31544
320G4
333/5
36141
34976
34872
34685
33479,
34248
33333
33224
33916
32938
32667
3245?
34019
30879
34091
3/098
35746
31544
31544
33000
32168
30670
36640
35/67
35767
-------
F.6 References for Appendix F
1. Richards, D. W., and K. S. Surprenant, Study to Support New Source
Performance Standards for Solvent Metal Cleaning Operations, Appendix
Reports. Midland, Michigan: Dow Chemical Co., June 1976.
2. Leung, Steve, Roger Johnson, Chung S..Liu, Gary Palo, Peter Richard and
Thomas Tanton, Alternatives to Organic Solvent Degreasing, Sacramento,
Ca.: Eureka Laboratories, Inc., May 1978.
3. U. S. Department of Commerce, Bureau of the Census, Annual Survey of
Manufactures 1976. Washington, D.C.: U. S. Government Printing Office
Dec. 1977.
4. U. S. Department of Commerce, Bureau of the Census, 1972 Census of
Manufactures, Volume II, Industry Statistics. Washington, D.C.: U.S.
Government Printing Office, 1976.
5. U. S. Environmental Protection Agency, Office of Air and Waste Management,
Control of Volatile Organic Emisions from Solvent Metal Cleaning. Research
Triangle Park, N.C.: U. S. Environmental Protection Agency, Publication
No. EPA-450/2-77-022, Nov. 1977.
6. U. S. Department of Transportation, F.A.A.: F.A.A. Statistical Handbook
of Aviation, 1975.
F-32
-------
TECHNICAL REPORT DATA
(Please read Instructions on the wenc before completing!
1. REPORT NO.
EPA-450/2-78-045a
3. RECIPIENT'S ACCESSION NO.
4. TITLE ANDSUBTITLE
Organic Solvent Cleaners -
Background Information for Proposed Standards
5 REPORT DATE
October 1979
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
GCA/Corporation
GCA/Technology Division
Bedford, Massachusetts 01730
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3057
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
Final
14. SPONSORING AGENCY CODE
EPA 200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of performance are proposed under authority of section 111 of the
Clean Air Act to limit the emissions of volatile organic compounds (VOC) and
trichloroethylene, perchloroethylene, methylene chloride, 1,1,1-trichloroethane,
and trichlorotrifluoroethane from new,modified, and reconstructed facilities
in which solvents are used to clean idegrease) metal, plastic, fiberglass, or
any other type of material. The proposed standards would require new, modified,
and reconstructed solvent cleaning facilities to use the best system of continuous
emission reduction, considering costs, nonair quality health and environmental
impacts, and energy impacts.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
COSATl Held/Group
Air Pollution
Pollution Control
Standards of Performance
Organic Solvent Cleaners
Volatile Organic Compounds
Emission Controls
Air pollution control
Organic chemicals
Solvents
13 B
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report/
llnr1a<;«;i'fi'pH
21. NO. OF PAGES
282
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION I's OBSOLETE
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SUPPLEMENTARY PAGE TO ORGANIC SOLVENT CLEANERS - BACKGROUND INFORMATION
FOR PROPOSED STANDARDS
Errata Sheet
The purpose of this supplementary page is to negate any requirements
the proposed standards would have concerning the disposal of waste solvent.
The disposal of waste solvent from all organic solvent cleaning operations
(new and old) will be regulated under the Resource Conservation and Recovery
Act. However, the section on waste solvent disposal is being reserved in
the organic solvent cleaner NSPS, pending completion of waste disposal
evaluations and resolution of the issues.
RCRA defines halogenated and non-halogenated solvents, and solvent
recovery still bottoms as hazardous wastes. Those persons who generate and
dispose of more than 100 kilograms per month of hazardous wastes are subject
to the provisions of this regulation. Under RCRA, control of these wastes
must be accomplished by distillation, incineration, landfilling, or storage
in surface impoundments or basins. Hence, the proposed standards for organic
solvent cleaners no longer address the disposal of waste solvent, as it is
regulated by RCRA.
To accommodate this change, the following corrections must be incorporated
in the Background Information Document:
1) p. 1-2 Omit waste solvent disposal requirement in last
paragraph of section 1.1, PROPOSED STANDARDS.
2) p. 6-15 Omit last sentence of section 6.4, WASTE SOLVENT
DISPOSAL OPERATIONS.
3) p. 6-16 Omit section 6.4.2, Regulation by the Proposed
Standards.
4) p. 7-6 Omit last sentence of first paragraph, section 7.2.1,
Waste Solvent Disposal.
5) p. 7-0 Omit first two paragraphs of section 7.3.2,
Disposal of Waste Solvent.
6) p. 8-62 Omit last three sentences of section 8.3, OTHER
COST CONSIDERATIONS.
7) p. 9-8 Omit last sentence of section 9.2.2, Selection
of Affected Facilities.
8) p. 9-15 Omit last paragraph of section 9.3.5, Selected
Emission Control Systems for Waste Solvent Disposal
Operations.
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