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
                                     vi

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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
                               vit

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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
                                 ix

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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
                                 x

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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.
                                      1-1

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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.






                                      1-2

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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






                                    2-1

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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
                                     2-3

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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
                                     2-4

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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





                                    2-5

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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
                                    2-6

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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,
                                    2-7

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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
                                     2-8

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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.






                                    2-9

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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

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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

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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

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     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

-------
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

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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

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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

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 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

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                                                                   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

-------
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

-------
    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

-------
    •  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

-------
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

-------
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

-------
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
                                  4-11

-------
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.
                                    4-12

-------
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

-------
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

-------
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

-------
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.


                                4-16

-------
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

-------
                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

-------
     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

-------
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

-------
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

-------
                 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

-------
      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

-------
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

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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

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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

-------
 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

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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

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            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

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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

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                         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

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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

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              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

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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

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                             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

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                                                  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

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                             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

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                                              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

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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
S!C l-4u»t«7
n HKt4l r«r«ltHr«
2*W rirtftloilS 4*4~FlitiirM
2S1 Kite. fvraUur* J«4 Filter*.
11 rrlnnY Mtttlt
111 Iron 41 1 "^ti'tf rouodrlgi
in Ntir-rrMS ."oil 1*1 MM Orwliit:
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11* fll.t. >rt«*rr lltt*l PrwJwl*
M F4!>rlc«t«4 frofectt
MJ" Tit Ttr/r ~H4«* b4npr4l In£ustrl4l Mtcklftcry
!•.' OffK* «»4 CooiMtlitf HocklMt
.1,1 4«lrid 'lltslui. S|>4<* >4*>U>«1, fortt
1/9 MUc. Ir4«t|ioi t4tlo> (ojvlpMut
14 Initrvwnti 4n4 Clorti
111 F**[nf>rr*i"«ii4 ic 14*11 Me iMtnBWtS
1-V N(«ti.rln4J 414 Control 11*1 0**lcc(
1* NliC»ll4IMtt.J-. iMhittQ
Iot4l H4«vf4Ctlirll>f
401 *4llro44t - H4l*U*4«ct
4SO Air Ir4*iOort - ItalntoMK*
75) Auto *«|>4lr
b***r4l l*4wttr/ MM*O
TOTA1
*4l»« of s»lp«»*t (fig*. TB7tI

I.H2
1.044

9,7*k7
10.74)
1.1M


7.M2
2,*ao
II. (M
4.M*
IS.2SO
2.077
2.0U4
12.412
*.oo*
10.414
H.74I
11.270
1.444
14.13*
11.722
10.440
*.*»
4.*MO
(.44)
7.142
K.IM
12.411
t.02*

n.Mi
21.4*1
7,142
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I.M7
t.ito
lt.*M
421,40*
U.SM
),70l
D.2M
•
441.014

2.111
1.240

lU(Ot4
20.700
I.M)
1.421

• .«•)
2.7)4
24.14)
4.0M
17.0)1
1.102

I4J471
IO.M2
12, HO
24.170
D.Sul
10.47*
U.tOl
I*.2S*
12.712
• .M)
4.404
10.742
*.*&•
21.440
14.112
I.M*

100.04)
27.02*
*.!!•
),*00
2.412
• .071
20.242
4*0.171
20.222
4.IM
I4.7G4
-
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2.6419
I.4M

11.001
24.0*4
4.0(7
1.47*

l.OU
1.210
W.1IO
4.HJO
1*.*00
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1.144
U.OS*
14.401
I4.H12
21.417
14.47*
12.004
24.44*
2).»7*
U.07I
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7.)))
' I2.M7
11.124
24.71$
19.472
IO.V7)

10*. 71 7
M.4M
11.41*
4.M1
2.7**
1.14*
21.4*2
402.MI
22,000
t./M
17,004
-
F •
lo.' •> Mi no4«or»
1»7T 	 HUT UK"

4. IS*
1.2*4

I.M2
2.24*
4.040
•.714

II, Ml
t.772
2*. Ill
4.401
4.W2
11.147
112
IC.024
7*2
*.2H
11.001
U.I42
10.4*7
10.7)4
4, SOI
t.OOS
71,447
I.MS
4.IM
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1.2k*. 000

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2.040
2.471
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11.1*1

D.444
2,907
2*. 2*7
( 141
(.400
21. «J)
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1.N2
11.402
44,471
U.SM
40.20*
t.loi
7.2S*
10). 104
4.*))
4.2*4
11. 142
• 12. 7W
12.19)
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11.7*4
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4.M4
7.144
21.241

40*. 124
1.2*7
40.012
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401,2*2
-•«*».„.
1.470.110

0.470
4.49*

2. 21*
).U02
4.0M
12.417

I4.0K
1.420
14.291
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7.117
24.40*
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21.420
1.274
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li.424
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11. Ml
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1.171
110.140
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12.244
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1.144
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i.TM.mf
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2.77*
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0
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417
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141
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114
1.444

1.122
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102
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1.2*0
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1*4
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1.440
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240
7
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14*
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lil
so

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IM
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168
12
72?
82
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147
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ss
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4»S
279


100
478
4U
0
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Q
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ill f.rw,th"»y:.<
1*7" - 1 **(»o 1 »f - i

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2.


j
j.

.'
j.

1.
5.
4.
5.
4.
J.O
1.0

1 .H
1.0
2. J
I.I

, .
i!i
i.*

? . t
1. 1
1.6
i, 1
^ r
J, i
4.0
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2.6 ; <<
7.1) t.i
7.4 5.0
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i.2 >.*
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1.0 4.4
S.o i.t
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1.2 l.l
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6-1 4.<>
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6.9 j'a

»•» 1. \
? ? t i
* - * i . /
la e .
'•• 6.1
<•* 1.9
I.M 3 S7
-
        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

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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

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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

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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

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                                 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

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     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

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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

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     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

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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

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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

-------
                     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

-------
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

-------
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

-------
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

-------
     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

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 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

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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

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 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

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     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

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 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

-------
                                        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:  References—5 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

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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

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                                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

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                                   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

-------
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

-------
                                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

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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 same—none.  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

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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

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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

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 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

-------
                        -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

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     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

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     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

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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

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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

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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
                                    9-9

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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






                                    9-10

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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.
                                    9-11

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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
                                     9-12

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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
                                     9-13

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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.
                                       9-14

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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.
                                       9-15

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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





                                   9-16

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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
                                   9-17

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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
                                  9-18

-------
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
                                9-19

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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).
                                 9-20

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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).
                                   9-21

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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

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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

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                       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)

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                                                   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

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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

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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

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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

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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

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                  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




option—which is a combination design, equipment, work practice, and




operational standard—offers 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

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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

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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

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                  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

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     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

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                                   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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