Uni«dSt«es	               EP A-600/R-94-00 7
    nmentti Protection
 *•*""	January 1994
 Research and
 Development
 IMPROVED EQUIPMENT CLEANING
 IN COATED AND LAMINATED
 SUBSTRATE MANUFACTURING
 FACILITIES (PHASE I)
Prepared for
Office of Pollution Prevention and Toxics
Prepared by
Air and Energy Engineering Research
Laboratory
Research Triangle Park NC 27711

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                                                  EPA-600/R-94-007
                                                  January 1994
IMPROVED EQUIPMENT CLEANING IN COATED AND LAMINATED
          SUBSTRATE MANUFACTURING FACILITIES
                          (PHASE!)
                             By:

                 Beth W. McMinn and Jill B. Vitas
                  TRC Environmental Corporation
                    100 Europa Drive, Suite 150
                 Chapel Hill, North Carolina 27514
                   EPA Contract No. 68-D9-0173
                   Work Assignment No. 3/309
               EPA Project Officer Michael Kosusko
           Air and Energy Engineering Research Laboratory
            Research Triangle Park, North Carolina 27711
                       .  Prepared for

                U.S. Environmental Protection Agency
                Office of Research and Development
                     Washington, D.C. 20460

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                                      ABSTRACT

      The report gives results of a Phase I study to characterize current equipment cleaning
practices in the coated and laminated substrate manufacturing industry, to identify alternative
cleaning technologies, and to identify demonstrable technologies and estimate their emissions
impacts.    It  presents  information  from  sources  including literature searches,  industry
questionnaires, plant visits, pollution prevention experts, and industry and trade association
personnel.  (NOTE: Phase n activities will be the actual demonstration of selected alternative
technologies, and Phase El will be to transfer related technology by means of conference papers,
journal articles, and newsletters, prepared and presented  at industrial workshops, pollution
prevention conferences, and other events where industrial application of pollution prevention
technologies is discussed.)  Facilities within this industry tend to operate in one of two segments:
(1) large facilities operating coating lines dedicated to one type of product, such as masking tape
or label stock; or (2) batch processors or plants that manufacture comparatively small quantities
of a wide variety of high value-added products.  Both segments of the industry use essentially
the same cleaning methods, even  though  the  segments differ substantially in  the range of
substrates, coatings, and application equipment used at the plants.
CH-93-100                                     U

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                           TABLE OF CONTENTS


 Chapter                                                                Page

 Abstract	 ii
 List of Figures	  vii
 List of Tables	viii
 Executive Summary	,  . ix
 Metric Equivalents	xi

 1    INTRODUCTION AND BACKGROUND	1-1
     1.1   PROJECT BACKGROUND	1-1
     1.2   PROJECT OBJECTIVES	1-4
     1.3   REPORT ORGANIZATION	1-5
     1.4   REFERENCES	1-6

 2    CURRENT MANUFACTURING AND CLEANING PRACTICES	2-1
     2.1   GENERAL	2-1
     2.2   INDUSTRY STRUCTURE	2-1
          2.2.1 Introduction	2-1
          2.22 Industry Market  	2-1
     2.3   RAW MATERIALS AND PRODUCTS	2-3
          2.3.1 Introduction	2-3
          2.3.2 Raw Materials 	2-3
              2.32.1 Substrates	2-3
              2.32.2 Coatings	2-7
          2.3.3 Finished Products and End-Uses	2-9
     2.4   MANUFACTURING PROCESS DESCRIPTION   	2-15
          2.4.1  Introduction	2-15
          2.42  Raw Material Mixing	2-15
          2.4.3  Coating Application	2-16
              2.4.3.1 Delivery of the Coating Supply	2-16
              2.4.3.2 Metering of the Coating Supply 	2-18
              2.4.3.3 Transfer of the Coating to the Substrate	2-25
          2.4.4  Drying/Curing	2-25
          2.4.5  Rolling, Printing, Cutting, and Product Shipment	2-29
     2.5   SPECIFIC PRODUCTION PROCESSES	2-32
          2.5.1  Introduction	2-32
          2.5.2  Paper Tape Manufacturing	2-32
          2.5.3  Film Tape Manufacturing	2-33
          2.5.4  Duct Tape Manufacturing	2-33
          2.5.5  Reinforced Tape Manufacturing	2-35
          2.5.6  Label Stock Manufacturing	2-35
     2.6   CLEANING REQUIREMENTS 	2-36
CH-93-100                                111

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                       TABLE OF CONTENTS (Continued)

 Chapter                                                                 Page
           2.6.1  Introduction	2-36
           2.6.2  Cleaning Frequency and Desired Level of Cleanliness  	2-36
           2.6.3  Construction of Pan to be Cleaned	2-37
           2.6.4  Soil to be Removed	2-38
      2.7   CURRENT CLEANING TECHNIQUES	2-38
           2.7.1  Specific Equipment Cleaning Requirements	2-39
               2.7.1.1  Ovens  	2-39
               2.7.1.2  Reservoirs  	2-39
               2.7.1.3  Troughs	2-39
               2.7.1.4  Pumps, Lines, and Hoses	2-39
               2.7.1.5  Dams	2-40
               2.7.1.6  Miscellaneous	2-40
           2.7.2  Cleaning Techniques	2-40
               2.7.2.1  Run Dry	2-40
               2.7.2.2  Mechanical Scraping	2-40
               2.72.3  Solvent Wiping	2-41
               2.72.4  Immersion  	2-41
               2.72.5  Other	 2-41
     2.8  PROPERTIES OF CURRENT CLEANING SOLVENTS	2-42
          2.8.1 Introduction	2-42
          2.82 Toluene	2-42
          2.8.3 Mineral Spirits	2-43
          2.8.4 Methyl Chloroform	2-44
          2.8.5 Methyl Ethyl Ketone (MEK)	2-45
          2.8.6 Xylene	2-46
          2.8.7 Other 	2-47
     2.9  CHARACTERIZATION OF POLLUTION RESULTING FROM
          CURRENT PRACTICES	2-49
          2.9.1 Air Emissions  		2-49
          2.92 Liquid Waste Streams	2-50
          2.9.3 Solid Wastes		2-51


3    QUESTIONNAIRE RESULTS	3-1
     3.1   GENERAL	3-1
     32   DESCRIPTION OF ORIGINAL QUESTIONNAIRE	3-1
     3.3   DESCRIPTION OF REVISED QUESTIONNAIRE	3-2
     3.4   FINAL QUESTIONNAIRE SUMMARY AND CONCLUSIONS	3-3
          3.4.1 Saturation Processes 	3-17
CH-93-100                                IV

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                      TABLE OF CONTENTS (Continued)

 Chapter                                                                 Page


          3.4.2 Release Backing Processes	3-17
          3.4.3 Adhesive Coating Processes	3-18
          3.4.4 Other Processes	3-18
          3.4.5 General Pollution Prevention Industry Trends	3-19
          3.4.6 Conclusions 	3-20
     3.5   REFERENCES	3-20

 4   POLLUTION PREVENTION ALTERNATIVES	4-1
     4.1   GENERAL	4-1
     4.2   CLEANUP AVOIDANCE	4-1
          4.2.1 Job Scheduling/Production Campaigning	4-1
          4.2.2 Run Dry	4-2
     4.3   BEST PRACTICES	4-2
          4.3.1 Storage of Cleaning Solvents	4-2
          4.3.2 Use and Accessibility of Cleaning Materials 	4-2
          4.3.3 Mechanical Pre-Cleaning	4-3
          4.3.4 Disposal of Spent Cleaning Materials	4-3
          4.3.5 Centralization of Major Cleanup   	4-4
     4.4   RECYCLING OF SOLVENTS AND CLEANING MATERIALS	4-4
          4.4.1 Solvent Recovery	4-4
          4.4.2 Extension of Solvent Ufe/Countercurrcnt Rinsing  	4-5
          4.4.3 Cleaning Rags	4-5
     4.5   ALTERNATIVE CLEANING MATERIALS	4-6
          4.5.1 Mineral Spirits	4-6
          4.5.2 Citrus Based Cleaners and Terpenes	4-6
          4.5.3 Di-Basic Esters (DBEs)	4-6
     4.6   EQUIPMENT MODIFICATIONS	4-7
          4.6.1 Improved Shielding 	4-7
          4.6.2 Surface Coating	4-7
          4.6.3 Surface Wrapping	4-8
          4.6.4 Substrate Edge Guides	4-8
     4.7   ULTRASONIC CLEANING	 4-8
     4.8   WATERBASED ADHESIVES	4-11
     4.9   REFERENCES	4-11

5    SUMMARY AND EVALUATION OF DEMONSTRATION OPPORTUNITIES  . . 5-1
     5.1   GENERAL	5-1
     52   TECHNOLOGY SELECTION CRITERIA	5-1
          5.2.1 Potential Environmental Impact	5-1
CH-93-100

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                      TABLE OF CONTENTS (Continued)

 Chapter                                                            Page
          5.22  Technology Cost  	5-4
          5.2.3  Applicability and Longevity  	5-5
          5.2.4  Availability	5-5
     5.3  SITE SELECTION CRITERIA	5-5
          5.3.1  Industry Segmentation  	5-6
          5.3.2  Resource Availability	5-7
          5.3.3  Tuning	5-7
     5.4  REFERENCES	5-8

 APPENDIX A  COATED AND LAMINATED SUBSTRATE INDUSTRIES WITH
              ANNUAL SALES GREATER THAN $1 MILLION  	A-l

 APPENDIX B  COATED AND LAMINATED SUBSTRATE FACILITIES
              AND ASSOCIATED TRIS EMISSIONS	B-l

 APPENDIX C  TRIP REPORTS	C-l
CH-93-100                              VI

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                                 LIST OF FIGURES


 Number                                                                        Page

 1-1    EPA's Pollution Prevention Research Plan	1-3

 2-1    Adhesive Mixing Process	2-17
 2-2    Metering Roll Control of Coating Thickness	2-19
 2-3    Blade-over-roll Coater	2-21
 2-4    Coating Knives	2-21
 2-5    Metering Rod Coater	2-22
 2-6    Metering Rod	2-22
 2-7    Dip and Squeeze Coater	2-23
 2-8    Air Knife Coater	2-24
 2-9    Direct Gravure Coater, Coating Reservoir Between the Roll and the Blade	2-24
 2-10   A Schematic Diagram of a Direct Roll Coater  	2-26
 2-11   Offset Application Roll	2-26
 2-12   Direct Application Roll	2-27
 2-13   A Schematic Diagram of a Reverse Roll Coater	2-27
 2-14   Floating Knife Coater	2-28
 2-15   Two-Zoned Drying Oven	2-30
 2-16   Coating Line with Exhaust Recirculation	2-31
 2-17   Paper Tape Manufacturing Process Flow Diagram	2-34

 4-1    Ultrasonic Cleaning System  	4-10
CH-93-100                                   VU

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                                  LIST OF TABLES
  Number                                                                       Page

  2-1    1987 Distribution of 2641 Facilities Among 2671 and 2672 Facilities	2-2
  2-2    Raw Materials Consumed in 1987	2-4
  2-3    End-Uses of Adhesive Coated and laminated Films  	2-6
  2-4a   SIC 2671 Product End-uses  	2-10
  2-4b   SIC 2672 Product End-uses  	2-12
  2-5    Physical and Chemical Properties of Toluene	2-43
  2-6    Physical Properties of Varsol  	2-44
  2-7    Physical and Chemical Properties of Methyl Chloroform	2-45
  2-8    Physical and Chemical Properties of Methyl Ethyl Ketone  	2-46
  2-9    Physical and Chemical Properties of Mixed Xylenes	2-47
  2-10   Physical Properties of Perchloroethylene  	2-48
  2-11   Physical Properties of Heptane	2-48
  2-12   Physical Properties of Isopropyl Alcohol	 2-49

  3-1    Questionnaire Respondent Profiles	3-4
  3-2    Process Profile 	3-5
 3-3a   Saturation Process Equipment Cleaning	3-9
 3-3b   Release Process Equipment Cleaning	3-10
 3-3c   Adhesive Process Equipment Cleaning	3-12
 3-3d   Other Process Equipment Cleaning  	3-14
 3-4    General Pollution Prevention Research	3-15

 5-1    Technology Selection Criteria	5-2

 A-l    Coated Paper, Packaging Facilities (SIC 2671) With 1992
       Annual Sales Greater Than $1 Million	A-2
 A-2   Coated and Laminated Paper, NEC Facilities (SIC 2672) With
        1992 Annual Sales Greater Than $1 Million	A-4
B-l    SIC 2671 - Coated Paper, Packaging	 B-2
B-2    SIC 2672 - Coated and Laminated Paper, NEC	B-4
B-3    Miscellaneous Coated and Laminated Substrate
       Manufacturing Facilities	B-7
CH-9J-100                                   Vlll

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                              EXECUTIVE SUMMARY

       As a result of the Pollution Prevention Act of 1990, the Environmental Protection Agency
 (EPA) established the 33/50 Program which calls for voluntary industry emissions reductions of
 17 high-priority toxic chemicals. The goal of this program is to reduce the total amount of these
 chemicals released into the environment and transferred off-site by 33 percent by the end of 1992
 and by 50 percent by the end of 1995.
       In support of the 33/50 Program, EPA's Air and Energy Engineering Research Laboratory
 (AEERL) is investigating ways to reduce air emissions of these 17 chemicals through pollution
 prevention in selected industry segments. Two criteria were used to select industrial categories
 for study: annual toxics emissions and the potential for pollution prevention opportunities. First,
 the Toxic Release Inventory System (TRIS) was reviewed to identify categories with the greatest
 mass emissions of the 33/50 chemicals. Categories with the greatest emissions were then Tanked
 according to the potential for successful pollution prevention projects.
       One of the key industries identified through this process was the coated and laminated
 substrate manufacturing industry. This industry is the number one source of methyl ethyl ketone
 (MEK) and the number three source of the toluene releases in TRIS. Both toluene and MEK are
 33/50 chemicals.  With the assistance of the Pressure Sensitive Tape Council (PSTQ, the Tag
 and  Label Manufacturers  Institute (TLMI),  industry personnel,  and  TRC  Environmental
 Corporation  (TRC), AEERL is conducting  a three-phased  effort to investigate in detail the
pollution prevention options for process equipment cleaning associated with  the coated and
laminated substrate industry.
       Through the  use of an industrial questionnaire and the results of an extensive  literature
search, this industry was characterized, and alternative cleaning technologies were identified. In
addition, seven site visits were conducted to better understand the manufacturing process, current
cleaning technologies, and to identify possible demonstrable technologies that will be the basis
for the demonstration phase (Phase IT) of this project The results of these Phase I activities are
discussed in this document
CH-93-100                                    IX

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        Facilities within the coated and laminated substrate manufacturing industry tend to operate
  in one of two segments. One segment consists of large facilities operating coating lines dedicated
  to one type of product such as masking tape or label stock. The other segment consists of batch
  processors or plants that manufacture comparatively small batches of a wide variety of high
  value-added  products.
        Both  segments of the coated and laminated substrate manufacturing industry  use
  essentially the same cleaning methods, even though the segments differ substantially in the range
  of substrates, coatings, and application equipment used at the plants. The  solvents  required to
  clean equipment in a coated and laminated substrate manufacturing facility are, in large part,
  determined by the resin in the coating formulation.
        AEERL  plans  to conduct demonstrations in facilities that  represent the two industry
  segments.  The  first demonstration facility will  be a facility operating lines dedicated to one
  product type. The focuses at this  facility would  be the implementation and evaluation of a
  cleaning solvent substitute, improved operating  practices, and process modifications such as
 Teflon coated rollers. AEERL has discovered through their contacts with industry personnel that
 some "dedicated line" facilities are pursuing these options while others are not  The focus  at the
 second type of facility, the batch processor, would be geared toward improving the efficiency of
 cleaning operations. AEERL has found that the nature of the batch processing business requires
 a high degree of cleaning between jobs  and mat this cleaning often takes place much more
 frequently than does cleaning at dedicated line facilities. The objective at the batch processing
 would be to calculate the optimum amount of cleaning solution necessary to achieve the required
 degree of cleanliness.  A second objective at this facility would be to identify the optimum
 method of administering the cleaning solution.  The details and the results of both of the facility
 studies would be documented in a final report It is intended that the case  studies described in
 the final report will assist not only the dedicated line facilities and the batch processors, but also
 those facilities that have characteristics of each.  In a subsequent report, AEERL will describe
 demonstration activities and results.
CH-93-100

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                              METRIC EQUIVALENTS

        Certain non-metric units are used in this document for the reader's convenience.  Readers
 more familiar with metric units may use the following equivalents to convert to that system.

          Non-metric                 Multiplied bv                Yields Metric
             atm                         101                         kPa
             gal.                       0.00379                       m3
              Ib                        0.454                        kg
             ton                         907                         kg
             yd2                        0.836                        m2
CH-93-100                                   XI

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                                    CHAPTER 1
                       INTRODUCTION AND BACKGROUND

 1.1   PROJECT BACKGROUND

      As a result of the Pollution Prevention Act of 1990, the Environmental Protection Agency
 (EPA) established the 33/50 Program which calls for voluntary industry reductions in releases
 of the following 17 high-priority toxic chemicals which are listed by mass of emissions.

            Toluene                        Trichloroethylene
            Xylenes                        Methyl Isobutyl Ketone
            1,1,1-Trichloroethane             Tetrachloroethylene
            Dichloromethane                Benzene
            Methyl Ethyl Ketone             Chloroform
            Chromium and Compounds       Nickel and Compounds
            Lead and Compounds            Cyanide and Compounds
            Cadmium and Compounds         Mercury and Compounds
            Carbon Tetrachloride

 The goal of the 33/50 program is to reduce the total amount of these chemicals released into the
 environment and transferred off-site by 33 percent by the end of 1992 and by 50 percent by the
 end of 1995. These reductions will be based upon the Toxic Release Inventory System (TRIS),
 with 1988 as the base year.1
     In support of the 33/50 Program and the Agency's pollution prevention goals, EPA's Air
 and Energy Engineering Research Laboratory (AEERL) is investigating ways to  reduce air
 emissions of these 17 chemicals through pollution prevention.  The Pollution Prevention Act of
 1990 defines pollution prevention as "any practice which reduces the amount of any hazardous
 substance, pollutant, or contaminant entering the waste stream  or otherwise released to the
environment (including fugitive emissions) prior to recycling, treatment, or disposal; and reduces
the hazards to public health and the environment associated with the release of such substances,
pollutants, or contaminants."2 Pollution prevention efforts offer economic and reduced health and
ecological risk benefits  to many sectors of society that are not available through traditional
pollution control methods.
CH-9MOO                                  1-1

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       In 1991, AEERL representatives met with industry, academia, and State environmental
  agency representatives to identify several source categories deserving of pollution prevention
  research.  Two criteria were used to select the industrial categories for study:  annual toxics
  emissions and the potential for pollution prevention opportunities.  First, the TRIS was reviewed
  to identify categories with the greatest mass emissions of the 33/50 chemicals.  Categories with
  the greatest emissions were then ranked according to  the potential for successful pollution
  prevention projects resulting in  significant reductions of 33/50 chemical releases. One of the
  industries identified during the  1991 meeting was  the adhesives-coated and laminated paper
  manufacturing industry [Standard Industrial Classification (SIC) 2672]. This industry was chosen
  because of significant air emissions of 33/50 Program chemicals methyl ethyl ketone (MEK) and
  toluene as reported through the TRIS.
       In October of 1991, a Focus Group Meeting was  held  between AEERL, pollution
  prevention  experts,  and  representatives  of  the   adhesives-coated  and  laminated paper
  manufacturing industry to discuss specific pollution prevention projects that would support the
  33/50 Program.   Meeting participants indicated that emissions  of toluene  and MEK from
 equipment cleaning operations are second only to emissions from  the  coatings and  coating
 application steps, and, therefore, would present a good opportunity for the implementation of
 pollution prevention techniques.  As a result of this meeting and preliminary industry inquiries,
 the scope of the industry investigation was later expanded to include other coating and substrate
 varieties (such as those included in SIC 2671 -Coated and Laminated Packaging Paper and Plastics
 Film)  because the manufacturing  methods  and  cleaning processes  are  similar,  therefore,
 technology transfer is possible over a wider range of industries. Figure 1-1 illustrates how the
 equipment cleaning research project fulfills pan of EPA's  goal to stimulate the development and
 use of products and processes that result in reduced pollution.3
CH-95-100                                    1-2

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9
*
8
                                   INFORMATION NEEDS
       EPA

       ssessment methods
        ;ts.
,._„_.—jstrtutes
Trends in product-use patterns
       Voduct i
       Jew.prpduc
       'roducfsuf
  INDUSTRY
Product substitutes
New products
Product applicability
  OTHER AGENCIES

New products
Product assessment methods
 CONSUMERS

New products
Product substitutes
                     ±
         RESEARCH GOALS
          1) Stimulate the development and
             use of products that result In
             reduced pollution
          2) Stimulate development and
             Implementation of technologies
             and processes...	
           3) Expand reusability. recydablllty, and demand...

           4) Identify and promote non-technological
            approaches...

           5) Conduct technology transfer and technical
            assistance...

           6} Identify and address future
            environmental problems...
                                              OBJECTIVES

                                          PRODUCT RESEARCH PROGRAM
                                          Establish standard methods
                                          Evaluate products
                                          Facilitate product development
                                          Demonstrate production and use

                                          PROCESS RESEARCH PROGRAM

                                          Establish standard methods
                                          Conduct pollution prevention opportunity assessments
                                           Identify, demonstrate, and
                                            evaluate process techniques
                                           Identify opportunities for
                                            technology transfer
                                                     RESEARCH

                                                        TOPIC

                                                         AREA

                                                   Identify improved equipment
                                                   cleaning methods
                                                          SPECIFIC RESEARCH PROJECT


                                                                Improved Equipment Cleaning In Coated and

                                                            Laminated Substrate Manufacturing Facilities (Phase I)

                                                             1) Characterize Industry

                                                             2) Identify current cleaning technologies

                                                             3) Identify alternative cleaning technologies

                                                             4) Compile technical guidance on use of water-based coating systems
                                   Figure 1-1.  EPA's Pollution Prevention Research Plan.

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  1.2   PROJECT OBJECTIVES

       This report presents the results of a Phase I study to characterize current equipment
  cleaning practices in the coated and laminated substrate manufacturing industry, to identify
  alternative cleaning technologies, and to identify demonstrable technologies and estimate their
  emissions  impacts.  In order to  successfully  accomplish these objectives, information was
  collected from several sources including literature searches, industry questionnaires, plant visits,
  pollution prevention experts, and industry and trade association personnel
       Literature searches of the EPA on-line databases, local  university library databases, and
  Dialog* were conducted.  The Pollution Prevention Information Clearinghouse (PPIQ and the
  Pollution Prevention Information Exchange System (PIES) were accessed on a biweekly basis.
  The  E-Mail capabilities of PEES were also  used to communicate with other PIES users with
  knowledge of the coated and laminated substrate manufacturing industry.
       The second source of project background information was data retrieved through industry
  questionnaires. Two separate questionnaires  were distributed, under a previous EPA contract, to
  14 adhesive-coated and laminated paper  manufacturers,  primarily pressure  sensitive  tape
 manufacturers and tag and label manufacturers.  A separate questionnaire was prepared for
 manufacturers operating under either SIC 2672 or SIC 2641  (Paper Coating  and Glazing)
 depending on their SIC.  Neither questionnaire was sent to more than 8 manufacturers.  The
 results of the questionnaires were clarified through follow-up  contacts with the recipients and
 through  revised questionnaires. Over 30 additional facilities (i.e., not recipients of the original
 questionnaires) were contacted for further information on equipment cleaning practices.  The
 second group of facilities contacted were representative of the expanded scope of the research
 project, and consisted of facilities involved in the coating and laminating of flexible substrates
 (SIC  2671)  as well as those included in SIC  2672.
      In  addition to conducting literature searches and distributing two industry questionnaires,
 contacts  were made with industry and pollution prevention experts with the Massachusetts Office
 of Technology Assistance (OTA), the North  Carolina Office of Waste Reduction (OWR), the
 Pressure  Sensitive Tape Council (PSTQ, the Tag and Label Manufacturers  Institute (TLMI), and
equipment manufacturing firms.

CH-93-100                                    1-4

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      The final source of project and industry information was compiled during a total of seven
 site visits.  Two of these site visits were conducted under a previous EPA effort The trip reports
 and associated data for these facilities were combined with the information resulting from the
 additional  five trips.  Together, these information gathering efforts provided the background
 needed to  accurately  describe the coated and laminated substrate  manufacturing industry, to
 evaluate the range of equipment cleaning methods used in the industry, to identify demonstrable
 technologies, and to form the foundation for future Phase n and lit efforts of this project
      Phase n activities will begin upon the completion of Phase I.  Phase n of the project will
 be the actual demonstration of selected alternative technologies.  This phase will quantify air
 emissions and other media  wastes, record production parameters, and make other observations
 and measurements  necessary to assess the impacts  of the alternative technology.   The
 demonstration project will include a training component focused on the production personnel at
 the demonstration site to teach any skills or modified techniques that are required to properly
 implement the alternative technology. Phase n will also involve summarizing the results of the
 demonstration.
      The final phase of the project (Phase HI)  is to  conduct technology transfer.  Focused
 documents such as  conference papers, journal  articles, and newsletters will be prepared and
 presented at industrial workshops, pollution prevention conferences, and other events where
 industrial application of pollution prevention technologies is discussed.  Trade associations and
 contacts made during Phases I and n will be targeted audiences and vehicles used for technology
 transfer.  PPIC, the National Roundtable of State Pollution Prevention Programs, and other groups
 focused on pollution prevention will also be used

 13  REPORT ORGANIZATION

     This report is  divided into five chapters and three appendices.  Chapter 2 identifies and
describes current manufacturing and cleaning practices. It includes an overview of the industry's
use of raw materials, coating application equipment, current cleaning techniques, current cleaning
solvents, and resulting waste streams.
     Chapter 3 describes the evolution of the industry questionnaires and the methodology by
which the recipients were selected. Chapter 3 also presents a summary of efforts to compile and

CB-W-100                                    1-5

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  tabulate the questionnaires' results. This chapter identifies current industry trends in coating
  formulations,  current trends in equipment cleaning  methodologies and  technologies,  and
  opportunities for pollution prevention research as indicated by the questionnaire respondents.
            Chapter 4 discusses some of the pollution prevention alternatives to currently used
  equipment cleaning techniques and materials.  This chapter also briefly identifies some of the
  opportunities for retrofitting current processing equipment to allow for the use of waterbased
  coatings.
       The last chapter (Chapter 5) presents a summary and evaluation of pollution prevention
  demonstration opportunities.  Appendix  A lists  coated and laminated substrate facilities with
  annual sales greater than one million dollars. Appendix B lists SIC 2671 and 2672 facilities and
  their associated emissions as they appear  in the TRIS. Appendix C contains copies of the seven
  trip reports conducted under this and the  previous EPA-led effort to  investigate and identify the
  improved  equipment cleaning methods for the coated and laminated substrate manufacturing
 industry.

 1.4  REFERENCES
 1.    U.S. Environmental Protection Agency. Pollution  Prevention Fact Sheet:  EPA's 33150
      Program. Office of Pollution Prevention, Washington, DC.  August 1991.
 2.    Pollution Prevention Act of 1990, 42 U.S.C. §13101, et seq.
 3.    U.S.  Environmental Protection Agency. Pollution Prevention  Research Plan:  Report to
      Congress, EPA-600/9-90-015. Office of Research and Development,  Washington, DC.
      March 1990.
CH-93-100                                    1-6

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                                    CHAPTER 2
            CURRENT MANUFACTURING AND CLEANING PRACTICES

 2.1   GENERAL

      This chapter provides an overview of the coated and laminated substrate manufacturing
 industries.  The chapter is divided into eight sections: (1) Industry Structure, (2) Raw Materials
 and Products, (3) Manufacturing Process Description,  (4) Specific Production Processes, (5)
 Cleaning Requirements, (6) Current Cleaning Techniques, (7) Properties of Current Cleaning
 Solvents, and (8) Pollution Characterization. The industry structure section addresses the current
 market, materials used in the manufacturing process, products manufactured, and product end-
 uses. The manufacturing process section describes the various elements of the manufacturing
 process with emphasis on equipment and procedure. Current cleaning techniques and cleaning
 materials are discussed in relation to the manufacturing processes. The last section characterizes
 the  air  emissions  and  liquid and solid waste  streams  that result  from current industry
 manufacturing practices.

 2.2   INDUSTRY STRUCTURE

 2.2.1 Introduction

      This section  gives an overview  of the coated  and laminated substrate manufacturing
 industry, including geographic distributions, production trends, industry issues, and the major
 subdivisions within the industry. Much data are based on SICs 2671 and 2672.

 122 Industry Market

      The coated and laminated substrate  industry, as defined by SIC 2671 and 2672, consists
of firms that manufacture coated or flexible materials made of combinations of paper, plastic
films, metal foils, and similar materials for packaging (SIC 2671) and other purposes, including
pressure sensitive tapes (SIC 2672).  Some facilities continue to report SIC 2641, Paper Coating
CH-93-100
                                         2-1

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  and Glazing, as their primary SIC even though SIC 2641 was discontinued in 1972. (During the
  information gathering phases of this  project, several of these facilities were  identified and
  contacted  through  a questionnaire.)   In  1972,  SIC  2641 was  split  into 2671 and 2672.1-2
  (Facilities  operating under these SICs were contacted through separate questionnaires.) Because
  the  current SICs are 2671 and 2672,  this discussion will focus on these  two classifications.
  However,  Table 2-1 summarizes the  effect of the  SIC revisions on  the industry and the
  corresponding employment data.
       According to the 1987 Census of Manufactures, SIC 2671 employed 15,000 people in 21
  states, and SIC 2672 employed nearly 31,000  people in 23 states.   The leading states in
  employment of 2671 personnel, accounting for 42 percent of the industry's employment, were
  Wisconsin, Indiana, Pennsylvania, and Illinois.  Similarly, Massachusetts, Ohio, Illinois,  and
  Pennsylvania accounted for 38 percent of SIC 2672's employment. Over 93 percent of SIC 2671
  and  55 percent of SIC 2672 plants are  small facilities employing less than 20 people.2  These
  smaller facilities often provide a highly  customized product line marketed within a small
  geographic region.   Some of  the larger  companies, however, own  multiple manufacturing
 facilities and distribute products nationwide.
                 TABLE 2-1.  1987 DISTRIBUTION OF SIC 2641
                               FACILITIES AMONG SIC 2671 AND SIC
                               2672 FACILITIES
 Industry
                      No. of      Cost of
 No. of     No. of    Employees   Materials
Facilities  Companies  (thousands)   (million $)
 Value of      New
Shipments   Expenditures
(million $)    (million $)
 Old Industry SIC 2641,      532       439
 Paper Coating and
 Glazing
  New Industry SIC 2671,    120        89
  Paper Coated and
  Laminated, Packaging
  New Industry SIC 2672,    412       362
  Paper Coated and
  Laminated, NJE.C.
                         455      4,476.5      8307.7       329.6
                         15.0      1,442.0      2,416.0        1283
                         30.9      3,034.5      5,891.7       2013
Source: Reference 2
NEC - Not Elsewhere Classified
CH-9MOO
                    2-2

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 2.3   RAW MATERIALS AND PRODUCTS

 2 J.I Introduction

      The products manufactured by the coated and laminated substrate industry are used in a
 variety of applications. Generally, these produces can be categorized as being either tapes, labels,
 or miscellaneous products. Each of these product types is composed of some combination of
 backings and coatings which can be described in terms of its construction or function.  The
 product backings often designate construction.  In the case of pressure-sensitive adhesive (PSA)
 products, which constitute a  large portion of the industry,  the adhesive may be the defining
 component  The other method of subdivision is functional use. End-use product categories
 include hospital and first aid products, office and graphic arts products, packaging and surface
 protection products, building industry materials, electrical products, and automotive industry
 products. This section includes information relating to raw materials, finished products, and
 product end-uses.

 232 Raw Materials

      The raw materials used in the coated and laminated substrate manufacturing process consist
 of substrates, adhesives and other coatings, and cleaning materials.   Commonly used raw
 materials in both SIC 2671 and SIC 2672 facilities are listed in Table 2-2.

 232.1  Substrates
      A substrate (backing) is the material to which an adhesive is applied to make the desired
product  Substrates are supplied to the manufacturer in large, continuous rolls called webs.
 Substrates provide strength, protection, and/or a colored surface for the adhesive.  Substrate
categories include paper, film, fabric, foil, and foam.  Paper and film are the two most frequently
used backing materials.2*3
      Paper is the most common and one of the least expensive web materials available, however,
at least one facility considers raw paper its most expensive production raw material, ranging in
cost from $0.50 to $0.75 per pound, depending on the paper grade and specification.3'4  Paper
CH-93-100                                    2-3

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                   TABLE 2-2.  RAW MATERIALS CONSUMED IN 1987
                                   Material
                                   Quantity
   INDUSTRY 2671, PAPER COATED AND LAMINATED, PACKAGING
                  Primary Materials, parts, containers, and supplies
   Paper
   Glues and adhesives
   Plastics resins consumed in the form of granules, pellets,
   powders, liquids, etc.
   Plastics, products consumed in the form of sheets, rods, tubes,
   and other shapes
   Printing ink (complete formulations)
   Petroleum wax
   Paperboard containers, boxes, and corrugated paperboard
   Aluminum foil:
    Plain
    Converted
  INDUSTRY 2672, PAPER COATED AND LAMINATED, NJE.C.
                 Primary Materials, parts, containers, and supplies
  Paper
  Glues and adhesives
  Plastics resins consumed in the form of granules, pellets,
   powders, liquids, etc.
  Plastics, products consumed in the form of sheets, rods, tubes, and other shapes
  Printing ink (complete formulations)
  Petroleum wax
  Paperboard containers, boxes, and corrugated paperboard
  Aluminum foil:
   Plain
   Converted
                                     926 million Ib
                                           NA
                                   520.9 million Ib

                                           NA

                                           NA
                                    30.1 million Ib
                                           NA

                                    25.9 million Ib
                                           NA
                                          NA
                                          NA
                                          NA

                                          NA
                                          NA
                                          NA
                                          NA

                                          NA
                                          NA
 Source: Reference 2
 NA = Not Available
 NJLC. = Not Elsewhere Classified
CH-93-100
2-4

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 substrates may be either coated with a saturant (i.e., saturated) or uncoated (i.e., unsaturated).
 Saturated paper backings include flatback paper (which is smooth) and creped paper (which has
 small "folds" giving it high stretching properties).   Unsaturated kraft  papers'have also been
 developed within the last twenty years.  This substrate variety is common in the United States,
 and is used extensively in Japan. Additional paper substrates are classified as specialty papers
 and include rope fiber paper which has a high tensile strength and nylon paper tape which has
 increased temperature resistance in electrical applications.3
      One common use of paper substrates is the manufacture of masking tapes. Masking tapes
 were first used in the automotive industry for painting applications in which the tape, or maskant,
 had to be resistant to elevated  temperatures  for long periods  of time.  New applications for
 masking tapes quickly developed, to include general-purpose masking tapes which serve a variety
 of household needs.3
      Polymeric film substrates include cellophane, acetates, polyester, vinyl, polypropylene, and
 polyethylene.  These polymeric films have  many  properties  (e.g., impermeability, thinness,
 smooth surface, good dielectric properties, and chemical inertness) which make  them desirable
 in a variety of applications including packaging, and electrical and pipe wrapping. The cost of
 film substrates is currently declining, consequently films are competing more in traditional paper
 markets.3
      Cellophane tape, the oldest transparent film tape, is used widely in office and  general-
 purpose household applications. Because cellophane is  hygroscopic and becomes brittle when
 dry and soft when humid, it is being replaced by other films  (such  as acetates) in certain
 applications despite the higher cost of the replacement films.3
      End-uses of some of the common film tapes are presented in Table 2-3.  Polyester films
 are used in  electrical applications requiring high  tensile  strength and  high  tear resistance.
 Polyethylene films are often used in high volume applications, because of the film's low cost
Tetrafluoroethylene (TFE) film,  one of the  most expensive of the film  substrates, imparts high
dimensional stability, resistance to elevated temperatures (482°F/250°C), chemical inertness, and
a low coefficient of friction.3
      A third substrate category used in coating and laminating applications is foil.  Foils are
typically aluminum, lead, or copper, with aluminum  used most frequently.  Aluminum backings
create a moisture seal and are often used in electrical applications, in heating and air conditioning

CH-9MOO                                     2-5

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      TABLE 2-3. END-USES OF ADHESIVE COATED AND LAMINATED FILMS
             Tape Type
                     End-Use
   Plasticized vinyl film
   Rigid vinyl film


   Polyester film


   Polypropylene film

   Colored vinyl film


  Polyethylene  film
  Tetrafluoroethylene (TFE) film
  Polyimide film
 Electrical insulation applications
 Protection of electroplating racks
 Maskant of metal surfaces to be plated
 Can sealer
 Protection of metal window frames
 Corrosion resistance for underground pipes
 Printable label tapes
 Packaging
 General purpose

 Packaging
 Electrical applications

 Packaging

 Identification
 Floor markings

 Medical tapes
 Electrical insulating
 Duct insulating
 Carpeting
 Corrosion protection for underground gas and oil lines

 Coil winding
 Transformers
 Cables
 Relays
 Condensers
 Resisters
Dry film lubricants

Electrical applications
Flat cable construction
Masking in soldering operations
Source: Reference 3, 5
CH-93-100
       2-6

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 insulation ducts as a reflective heat shield, in high temperature masking operations (e.g., printed
 circuit board manufacture), in repairing sheet metal, and in blocking radiation on X-ray plates.
 Aluminum laminated to cloth or foam provides vibrational and acoustical damping. Lead foils
 are used for their resistance to the chemicals in plating operations, in acoustical  damping
 applications, and in radiation shielding.
      Foam substrates include polyethylene, vinyl, urethane, and polychloroprene. The structure
 of a foam backing imparts many unique characteristics including the ability to conform to uneven
 surfaces and to distribute force loads to prevent stress concentration and ultimate product failure.
 Law density foam substrates are used for sealing and gasketing, while foam/foil and foam/film
 laminates are used for thermal and  acoustical insulations.   Two-sided  adhesive-coated foam
 products are used to mount a wide variety of objects including vehicle reflectors and balancing
 weights, bathroom fixtures to walls, medallions to wine and liquor bottles,  and electrocardiogram
 terminals to patients.3  Fabric tapes  offer a backing with both high  tensile strength  and high
 flexibility. Low tear strength may also be incorporated with no loss of tensile strength. Medical
 tapes and duct tapes are made with fabric backings.

 2 JJ J Coatings
      The various coatings applied, along with the type of substrate, define the end-use of a
 coated and laminated product Coatings typically consist of solvents, resins,  and additives, with
 the composition varying depending on the desired characteristics.   The fluid portion of the
 coating is  referred to as the vehicle.  Vehicles maintain a  coating in liquid form for easy
 application.  Once a coating is deposited on a substrate, the vehicle solvents should evaporate
 completely.  Vehicles transfer the solid portion of the coating to the  substrate  surface in a
 uniform layer and typically play  no role in film  formation.   Some  commonly used coatings
 include saturants, release coats, tie coats, and adhesives.  Not all coated and  laminated products
 incorporate all of these coatings. For example, saturants are used primarily with paper substrates,
 while tie coats are used mainly with film products.  A brief discussion of each type of coating
follows.
      Saturants are mixtures applied to raw paper to improve the paper's internal strength  and
resistance to various environments.  The backing  of paper tape,  for example, may contain as
much as 50 percent saturant by weight6  The two types of saturants used are solvent-based  and
CH-93-100                                    2-7

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  waterbased.  Saturants are used to reduce the amount of loose fibers extending from the surface
  of a paper web.  They also impart strength to the web once dried. Solvent-based saturants orient
  all the fibers uniformly and provide better water resistance than the waterbased coating; however,
  they do not strengthen the web as  much as waterbased saturants. Natural rubber and  styrene-
  butadiene rubber (SBR) are the preferred polymers for solvent-based saturants.  Other  saturant
  raw materials include polyurethanes, toluene, polyether blends, and hydrocarbon resins. Although
  pollution problems and high costs of solvents make waterbased saturants more attractive,  solvents
  arc necessary for the manufacture of electrical paper tapes because of the high performance
  characteristics currently offered only by solvent-based saturants.3
       Waterbased saturants or latexes are used more often than solvent-based saturants  for tape
  backing. Waterbased latexes are easier to use than solvent-based saturants, which must be broken
  down and compounded to dissolve the rubber. Several synthetic latexes used in the waterbased
  saturants are SBR, acrylics, and carboxylated SBR.  Acrylics provide excellent saturation, have
  a light color, and are heat and light stable. Other waterbased coatings are available but not used
  as frequently as the ones previously mentioned.
      Release coatings are applied to the substrate backing on the side opposite of the adhesive.
 The release coat allows rolled adhesive products to be unwound, prevents tearing, and provides
 resistance to fluids.6 A release coat or "backsizing" contains release  material, liquid resins, and
 solvents such as silicone solution, isopropyl alcohol, and toluene.3'7 The release coat should
 provide an adequate and consistent release, the release agent should not transfer to the adhesive
 surface, and aging should not effect the ability to unwind the tape.  Polymer coatings, waxes,
 silicones, and chained polymers are used in release coatings. Polymers are used to prevent the
 adhesive from penetrating into  the backing.  Waxes are added to polymer coatings to improve
 the slip, blocking resistance, and release of the coating.
      Tie coats or primers are coatings applied between natural rubber  adhesives and  film
 substrates to improve the bond between the  adhesive and the film.   Primers may be a  mixture
 of creep rubber, diphenylmethane diisocyanate, and toluene or blends of SBR, with and  without
 resins.3'5
     Adhesive is applied to the saturated/backsized substrate. The adhesive product may contain
petroleum resins, solvents, natural and synthetic rubber, antioxidant,  and filler.6  Adhesives are
required to have three main properties: peel adhesion, cohesive holding power, and surface tack.

Cfl-95-100                                    2-8

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 Natural rubber has a low tack and adhesion to surfaces.  Therefore, tackifying resins must be
 added to natural rubber-based adhesives.  Wood rosin and its derivatives, terpene resins, and
 petroleum-based resins arc the main resins used with natural rubber.  Other adhesive products
 include block copolymers; thermoplastic rubbers including polyethylene or polybutylene; butyl
 rubber, a  copolymer of  isobutylene  with a minor amount  of isoprcne; polyisobutylene, a
 homopolymer, acrylic polymers; vinyl ether polymers; and, silicon adhesive which is both a gum
 and a resin.  Facilities have a wide  variety of choices for raw material inputs for adhesive
 mixing.

 2.33 Finished Products and End-Uses

      A summary of coated and laminated substrate product end-uses is included in Tables 2-4a
 and 2~4b.  In 1987, the value of all product shipments for  SIC 2671 was $2.4 billion and  the
 value of all product shipments for SIC 2672 was $5.9 billion.2  Wartf s Business Directory lists
 43 SIC 2671 facilities and 81 SIC 2672 facilities with 1992 sales greater than one million dollars.
 These lists are provided in Appendix A, Table A-l (SIC 2671) and Table A-2 (SIC 2672).8
      There are several  types of products manufactured by coated and laminated substrate
 manufacturers.  Two of the largest product categories are  tapes and labels.  Classes of tape,
 identified by construction, include woven and nonwoven fabric tape, paper tape, film tape, foil
 tape, and foam tapes. Some of the web materials mentioned previously are used in combination
 with glass,  rayon, nylon, polyester, or acetate fibers to produce reinforced substrates. Films such
 as polyethylene, polyester, or polypropylene are often combined with these fibers to produce
 tapes used in heavy-duty packing and bundling applications.  The type and number of reinforcing
 strands per area, the thickness of the coating applied, and the type of film used differentiate the
 grades and  types of film tape.3*5  Two-faced tapes are substrates with an adhesive coating applied
on both sides of the substrate (usually foam or film).  Two-faced tapes have both heavy-duty uses
 (e.g., carpet tapes and securing plates  to a printing cylinder) and light-duty uses (e.g., business
forms and nametags).
CH-93-100                                    2-9

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              TABLE 2-4a. SIC 2671 PRODUCT END-USES
1987 Product Shipments
1987
Product
Code
2671- -

26711-
26711 11
26711 15
2671100
26712-
26712 11
26712 12
2671200
26713-

26713 13
26713 14
26713 18
26713 21
2671300
26714-
26714 11
Product
No. of
Companies
with Ship-
ments of
$100,000 or
More
Quantity
Value
(millions)
PAPER COATING AND LAMINATING,
PACKAGING
Total
Single-web paper (coated rolls and
waxed) for packaging uses
Plastics-coated 	 	 	
Other

sheets, including
. . . 1,000's tons
	 do
Single-web paper, coated rolls and sheets, including
waxed, for packaging uses, n.sJc.
Single-web film (coated rolls and sheets, including
coextruded) for packaging uses
Single-web film, coated 	 	 ' nno's tm*
Coextruded film
	 do
Single-web film, coated rolls and sheets, including
coextruded, for packaging uses, n.sJc.
Paper/paper mnltiweb laminations for packaging
uses
Polyethylene laminations:
Coated , , , , . , ..,..,,,,
Uncoated 	
Other laminations:
Coated 	
Uncoated 	 	 	
Paper/paper multiweb laminations, for
o&k.

. . . 1,000's tons
	 do
. . . 1,000's tons
	 do
packaging uses,
Multiweb laminated rolls and sheets, except
paper/paper and foil, for packaging uses
Film/paper multiweb laminations ... 	 l -OOO's tons


(NA)
(NA)
26
34
(NA)
(NA)
54
20
(NA)
(NA)

12
6
9
10
(NA)
(NA)
15
(X)
(X)
912
156.1
(X)
(X)
197.4
110.7
(X)
(X)

(S)
44.8
7.5
62.4
(X)
(X)
31.0
2,460.1
474.4
168.5
285.1
20.7
879.1
483.4
343.1
52^
249.1

105.8
46.4
10.8
51.6
34.6
857.6
953
                                 (Continued)
CH-93-100
2-10

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               TABLE 2-4a. SIC 2671 PRODUCT END-USES (continued)
1987 Product Shipments
1987
Product
Code
26714 12
26714 13
26714 14
26714 15
26714 16
2671400
26710-
2671000
2671002
No. of
Companies
with Ship-
ments of
$100,000 or
Product More
Him/film multiweb laminations:
Polypropylene/polypropylene 	 1,000's ions
Cellophane/polypropylene 	 do
Cellophane/polyethylene 	 do
Metalized film/film laminations 	 do
Other film/film laminations 	 do
Multiweb laminated rolls and sheets except paper/paper
and foil, for packaging uses, ius.k.
Paper coating and laminating, packaging, n^k.
Paper coating and laminating, packaging, n.sJc.
typically for establishments with IS employees or more
(see note)
Paper coating and laminating^ packaging, n.sJc~,
typically for establishments with less than IS
employees (see note)
20
7
9
19
27
(NA)
(NA)
(NA)
(NA)
Quantity
42.4
(S)
5.5
14.6
99.9
(X)
(X)
(X)
(X)
Value
(million $)
205.9
9.6
14.9
723
364.1
95.4
(NA)
(NA)
(NA)
Source: Reference 2
do-Ditto
nsJc. - not specified by kind
NA - Not Available
X - Not Applicable
S - Withheld because estimate did not meet publication standards
CH-93-100
2-11

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                 TABLE 2-4b. SIC 2672 PRODUCT END-USES

1987
Product
Code
2672--

26721-
26721 13
26721 53
2672100
26722-
2672200
26723-
2672300
26724-
2672445
2672451
2672453
2672455
2672456
2672459
2672400
26720-
2672000


i
1
Product
PAPER COATING AND LAMINATING,
N.E.C.
Total
Printing paper coated at establishments other
than where paper was produced
Coated, one side
(for labels and similar uses) .... 1,000's tons
Coated, two sides (for printing of magazines.
directories, catalogs, and similar uses) .... do
Printing paper coated at establishments other
than where paper was produced, ius.k.
Gummed products:
Gummed products
Pressure-sensitive products:
Pressure-sensitive products
Other coated and processed papers, except
for packaging uses
Processed paper
(embossed, leatherette, etc.) 	 1,000's tons
Oiled and similarly treated paper 	 do
Waxed and wax-laminated paper for
nonpackaging uses, including household . . do
Carbonless paper 	 do
Plastics-coated paper 	 do
Other coated and processed paper, including
soap-impregnated paper but excluding
sensitized paper 	 do
Other coated and processed papers, except for
packaging uses, n-sJc.
Paper coating and laminating, n.e.c, nsJL
Paper coating and laminating, n.e.c., n.s.k.,
typically for establishments with 15 employees
or more
(Continued)

NO. or
Companies
with Ship-
ments of
(100,000 or
More

(NA)
(NA)
38
19
(NA)

25

123
(NA)
7
5
11
4
7
34
(NA)
(NA)
(NA)

1987 Product
Quantity

(X)
(X)
(S)
(S)
(X)

(X)

(X)
(X)
532
10.0
(S)
(S)
Wx
(X)
(X)
(X)

: Shipments
Value
(million $)

5,497.7
464.5
301.7
156.8
5.9

218.4

3,100.0
1,200.0
64.2
10.4
104.0
953.5

68.0
514.7
339.5

CH-93-IOO
2-12

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               TABLE 2-4b. SIC 2672 PRODUCT END-USES (continued)
1987
Product
Code
2672002
\
Product
Paper coating and laminating, n.e.c., n.sJc,
typically for establishments with less than 15
employees

No. of
Companies
with Ship-
ments of
$100,000 or
More
(NA)
1987 Product
Quantity
(X)
Shipments
Value
(million $)
1752
 Source: Reference 2
 do- Ditto
 n.s Jc. • not specified by kind
 n.e.c. - not elsewhere classified
 NA - Not Available
 X - Not Applicable
 S - Withheld because estimate did not meet publication standards
CH-93-100
2-13

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       Tape end-use categories include the following.-3"5-7'9"11

       Medical and first aid tapes were the first application of pressure-sensitive products. These
       products  are used by doctor's offices, and at home for first aid purposes, foot care, and
       athletic protection wraps.

       Office and graphic an tapes were first produced as clear cellophane film tapes, but now
       include many other substrate varieties.

       Packing and surface protection film tapes are the most frequently used tapes for packaging.
       Saturated paper tape is still  dominant in  surface protection tape applications and sheet
       products.

       Building industry products include tapes used for paint masking, temporary attachment of
       wood products, weather sealing a building, bridging narrow cracks to overpaint, electrical
       wrapping, coverings for doors and walls, floor tile installation, and glass treatments.

       Electrical tapes include two classes:  tapes intended for original equipment manufacturers
       (OEM) and tape for electrical insulation during installation. Current OEM tape may have
       cloth, film, paper, aluminum foil, nonwoven fabrics, or laminated  substrates depending
       upon the desired qualities in the backing.  Electrical installation tapes often have either a
       plasticized vinyl or polyethylene film backing.

       Automotive industry products are used in the electrical system of automobiles.  These
       products are similar to the OEM tapes discussed above.  Other automotive tape  products
       include tape strips used to mount interior moldings and trim.

       Shoe industry tapes are used to cover the backseam to reduce pressure spots. Fabric, paper,
       and  film tapes may be used in this application.  Tapes are  also  used in binding and
      reinforcing areas in the construction of shoes.

      Appliance industry products include decorative strips, nameplates,  foam gasketing, and
      foam pads for sound insulation for attachment to appliances.

      Splicing tapes are used to splice various webs during manufacturing operations.  Paper
      tapes, two-faced tapes,  and film tapes are used for this purpose.

      Corrosion protective tapes help to prevent the breakdown of materials covered by the tape.
      Consumption of polyethylene film tapes for corrosion protection is very large.
      Label manufacturing is  similar to pressure sensitive tape manufacturing,  with priority

properties being backing, printability, flatness, ease of die cutting, and release paper components.

A label manufacturer may sell his product either in rolls or sheets as a final product, or as a raw

product for a printing and die cutting operation.3'4

CH-93-100                                    2-14

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      Other adhesive coated and laminated product lines include adhesive-coated floor tiles, wall
 coverings, automotive and furniture woodgrain films, and decorative sheets.

 2.4   MANUFACTURING PROCESS DESCRIPTION

 2.4.1  Introduction

      Coated and laminated substrate facilities use numerous methods to process the wide variety
 of products that they manufacture.  Manufacturing variables include the design and capabilities
 of the coating equipment, the type of substrate, the type  and viscosity of the coatings being
 applied, and the drying or curing method. The manufacturing process generally consists of the
 following four steps:
 •     raw material mixing
 •     coating application
 •     drying/curing
      rolling, printing, cutting, and product shipment

 2.42 Raw Material Mixing4*7"9*10

      Many coating and laminating facilities formulate their coatings  on-site in  a central mix
 room. The complexity of the mixing process depends on the size of the facility and the number
 of products manufactured. Generally speaking, large facilities operating dedicated lines formulate
 all of their  own coatings from raw materials.  Smaller coating and laminating  facilities may
 purchase premixed coatings which they either use as-shipped or modify to satisfy customer needs.
 Modification typically consists of adding small amounts of performance enhancing chemicals.
      Saturants, release coatings, tie coatings, and some adhesives are typically manufactured in
 mix tanks using high- or variable-speed dispersers.  Facilities that purchase pre-mixed coatings
 and add performance enhancing chemicals often blend these chemicals directly into the coating
drum.   Facilities equipped with stainless steel mixing tanks and dispersers are capable of
preparing  coatings of any chemical composition [i.e., 100 percent solids, waterbased, solvent-
 based, ultra-violet (UV)  curable].
CH-93-100                                   2-15

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       Adhesive preparation often follows a slightly different process. The thicker adhesive stock
  is prepared by blending natural and synthetic rubbers, hydrocarbon resins, oils, and fillers in a
  banbury, a specialized disperser similar to a bread mixer.  The banbury output is then directed
  to mills where a sheet of adhesive stock is extruded, cut, and palletized for further processing.
  The palletized sheets are sent to a mixing area, where they are loaded into large (e.g., 10,000
  gallons) mix tanks.  Solvent (often toluene) which dissolves the stock, additional resins, rubber
  (self polymerizing), and oils are pumped into the mix tank to complete the adhesive formulation.
  Figure 2-1 illustrates the adhesive mixing process.
       Once the coatings are formulated, they are either pumped to storage tanks or transferred
  via tote vessels or dedicated piping to specific process lines for immediate use.

  2.43 Coating Application

       The application of a coating to a flexible web involves four major functions: (1) transport
 of the web, (2) delivery of the coating supply, (3) metering of the coating, and (4) transfer of the
 coating from the supply vessel to the substrate. For purposes of this report it is not important
 to understand web transport, other than to note that the mechanisms used to tension and advance
 the web can become contaminated with coatings and require cleaning. These mechanisms include
 items such as rollers, gear boxes,  belts, and equipment housings.  The  mechanisms used to
 supply, meter, and apply coating are also subject to contamination, and thus require cleaning; but
 more  importantly,  their design influences  the degree to  which coatings  are spilled during
 application.  The following sections describe the other three coating application functions, along
 with some common coating equipment configurations.

2.43.1 Delivery of the Coating Supply
      After mixing, coatings are stored in permanently installed tanks, movable tote vessels, or
drums, depending on  the size and production methods of the coating operation. In order to coat
a substrate web, the coating must be transferred from such storage locations to a reservoir, from
which it can be made  available to the coating apparatus. Depending on the size of the operation
and production methods, this is accomplished through permanently installed piping and manifold
systems, or portable lines that are attached to mobile storage vessels.  Various types of pumps
CH-93-100                                   2-16

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                 STOCK PREPARATION
                      * Banbury mix rubber/fillers
                      * Mil! banbury stock
                      * Palletize stock, send  to  mixing
                 MIXING
                      * Solvent
                      * Rubber stock
                      * Resins
                      * Oiis
               T
BULK STORAGE
    * To  coating  lines
                    T
      TOTE TANKS/DRUMS
         *  Small volume  coatina
                     Figure 2-1. Adhesive Mixing Process.
CH-93-100
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  are used to maintain a flow of coating materials through these distribution networks.  Most
  coating operations periodically flush these pumps and transport lines with solvent to prevent a
  buildup of coating material on the interior surfaces.  Some facilities pack their lines with solvent
  during production shut-down periods to avoid the curing of coatings in the line.
       The delivery system brings coating material into close proximity with the web and coating
  head, depositing the liquid at a steady rate into a reservoir. In some cases, this flow is subjected
  to continuous monitoring and adjustment, particularly on short runs.  But in longer production
  runs, once the flow is adjusted to the proper rate, the coating supply is left alone, and process
  control is exercised with the metering mechanism.
       The reservoir, the dams around it, and the spill pans beneath it are all regularly subjected
  to contamination, and require cleaning on a regular basis.  The reservoir itself must be cleaned
  prior to the  start of any new  job, and  the other surfaces  are cleaned frequently to avoid
  contamination of the incoming coating.

 2.432 Metering of the Coating Supply
      The coating that is applied to the web must be sufficient to completely wet its surface, but
 not exceed the design thickness for the application.  To some degree, applied coating thickness
 is  controlled through adjustment of the supply system and the coating's viscosity.  Fine
 adjustments are accomplished by a metering device.  Metering can occur before or after the
 coating is applied to the web. The most common metering mechanisms are (1) a metering roller,
 (2) a doctor blade, (3) a metering rod, and (4) nip rollers.
      A metering roller controls the amount of coating that reaches the web in roll coating
 applications.  Metering rollers are very smooth and spin counter to the direction of the application
 roller. They are set at a predetermined distance from the application roller, so that as the coating
 laden roller rotates towards the surface  of the web, the metering roller restricts the amount of
 coating that can pass through the preset gap.  Coating typically collects at the outer edges of this
 gap, so many coating heads incorporate a solvent drip that solubilizes mis buildup, allowing it
 to wash away. A coating apparatus employing a metering  roll to control coating thickness is
depicted in Figure 2-2.
     Doctor blades or floating knives are used to remove excess coating either from the surface
of the transfer mechanism, or after the coating has been transferred to the web. Doctor blades
CH-93-100                                    2-18

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                                         METERING ROLL
                DAMS
      APPLICATOR ROLL
                       BACKING ROLL
CH-93-100
Figure 2-2. Metering Roll Control of Coating Thickness.






                       2-19

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  have very clean, straight edges, and are finely adjustable to provide a level scraping effect over
  the surface of the coating. Doctor blades are most effective in providing metering of an already
  well controlled coating layer.  If a doctor blade is set to remove too much coating, either from
  an application roller or from the surface of a web, it will begin to foul and actually pull too much
  coating away, resulting in adhesive voids on the web. Figure 2-3 shows a doctor blade-over-roll
  coater.  Figure 2-4 shows various types of knives used to achieve different coating effects.
       Metering rods, like doctor blades, can control coating thickness before or after transfer to
  the web. A metering rod is a thin rod wrapped in wire.  It is brought into tangential contact with
  the coating laden surface and coating passes through the grooves in the wire wraps.   The
  diameter of the  wire wrapping determines the amount of coating that is allowed to pass.  The
  viscosity of the  coating must be controlled to allow the coating to level after it has passed the
  metering rod.  Figure  2-5 shows a typical metering rod set up  to control the thickness of a
  coating applied  by a direct roll coater.  Figure 2-6 depicts the flow of coating through the
 grooves in a metering rod's  wire wrapping.
      Nip rollers are used to squeeze a saturated web to remove excess coating. Nip rollers are
 adjacent rollers  that rotate counter to one another, allowing the  web to travel between them.
 They are usually covered with a flexible surface material, primarily rubber, so that they may be
 set in contact with one another, but flex enough to accommodate passage of the web. Figure 2-7
 shows a dip and squeeze  coater using chilled iron rollers as nip rollers.
      Additional metering mechanisms include air knives, which are high speed curtains of air
 that literally blow  excess coating back as an application roller rotates towards the web, and
 mechanisms uniquely associated with a single coating application, such as the engravings in a
 gravure cylinder.  Gravure coaters are similar to roll coaters in that they transfer coating to the
 surface of a web through the rotational motion of a cylinder.   The major difference is that
 gravure cylinders are engraved while the  surface of standard coating rollers is mirror smooth.
 Gravure coating is a common way of selectively coating the surface of a web. Figure 2-8 shows
 a typical air knife coater.  The  arrows indicate that the applicator roll can be either a reverse or
 direct rolL Figure 2-9 depicts  a simple gravure  coating system.  Regardless of the mechanism
 used, the metering device  must be kept as clean as possible  to allow it to effectively perform its
 task.


CH-93-100                                    2-20

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                           Figure 2-3. Blade-over-roll Coaler.
                      A      B     C     D      E
1
DIP
J
E(
:TION
c
)F V
2
/EE
(?
1
f
            Figure 2-4. Coating Knives (A = beveled; B,C = rounded edge;
                     D = hook; E = bull nose; F = spanishing knife)
Oi-93-100
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                           APPLICATOR ROLL
                                                       WIRE WOUND ROD
                              Figure 2-5. Metering Rod Coater.
                                                COATING
                                                     WIRE
                                                    ROD
                               Figure 2-6. Metering Rod.
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                                                                      OVEN
                                     CHILLED IRON
                                        ROLLS
                          Figure 2-7.  Dip and Squeeze Coater."
CH-93-100
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               NOZZLE
BACKING
 ROLL
  DIRECT OR
REVERSE ROLL
 APPLICATOR
               BLOW OFF
                 HOOD
    COATING
      PAN
                           Figure 2-8. Air Knife Coater."
                   GRAVURE ROLL
 Figure 2-9. Direct Gravure Coater, Coating Reservoir Between the Roll and the Blade.
CH-W-100
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2.43.3 Transfer of the Coating to the Substrate
      Transfer of a coating from a reservoir to a web is most commonly accomplished with a roll
coating mechanism. Roll coaters are a series of one or more cylinders that remove coating from
the reservoir and then contact the web transferring a portion of the coating to the web surface.
If the same cylinder that contacts the coating in the reservoir also contacts the web, such as the
coater shown in Figure 2-10, the roll coater is known as a direct roll coater.  If the supply roller
transfers the coating to a counter-rotating cylinder before it reaches the web, the device is called
an offset roll coater. Offset roll coaters are capable of greater control of the coating deposit, but
require more exacting process control and have more surfaces that require cleaning. Figure 2-11
shows an offset roll coater.
      In addition to describing the transfer  of coating from the reservoir to the web (i.e., with a
single roller), the term direct roll coater is also  used to indicate that the web and the coating
cylinder surface are moving in the same direction at their tangential point of contact. Figure 2-12
shows the relative direction of motion of the web and application roller in a direct roll coater.
If these two surfaces are moving counter to one another at this point, then the system is described
as a reverse roll coater, shown in Figure 2-13.   Reverse roll coaters are capable of effecting a
smoother and more uniform coated surface.
      In some coating applications, there is less  need for precision and coatings can be poured
directly onto  the web and metered using a metering roller, doctor blade, or metering rod. These
applications generally incorporate a less viscous  coating, and are intended for low performance
environments, such as disposable labeling or general purpose masking tape.  In such cases, the
transfer mechanism is the pouring device, such as an  aperture in the reservoir, or a weir (dam)
that the coating pours over as the reservoir is fed.  In  such applications it is essential to control
the flow of coating to the reservoir to ensure that the pouring mechanism does not deliver too
much coating to the surface of the web.  Figure 2-14 shows a floating knife coater, which meters
the coating from a reservoir directly on the web.

2.4.4  Drying/Curing

      Ovens serve two primary functions: to dry the coating by evaporating the solvent or to cure
a polymer coating.  Important characteristics of an oven are the source of heat, the operating
                                         2-25

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                                                 RUBBER ROLL
                     APPUCATION
                        ROLL
                Figure 2-10. A Schematic Diagram of a Direct Roll Coater.
                    APPLICATION
                       ROLL
                                                    SUBSTRATE
                                                 RUBBER TRANSFER ROLL
                          Figure 2-11. Offset Application Roll.
CH-9MOO
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                          SUBSTRATE
                                                     RUBBER ROLL
                                                     FOUNTAIN  ROLL
                           Figure 2-12.  Direct Application Roll.
                        SUBSTRATE
                                                   RUBBER ROLL
                                                     APPLICATION
                                                       ROLL
              Figure 2-13. A Schematic Diagram of a Reverse Roll Coater.
CH-93-100
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                           Figure 2-14.  Floating Knife Coater.
 temperature,  the  residence  time (a function of web speed), the  allowable  hydrocarbon
 concentration, and the oven circulation (a function of air velocity).
      Ovens are of two types: direct and indirect An indirect-fired oven involves heat exchange.
 An incoming air stream exchanges heat with steam or combustion products, but does not mix
 with  them.   This  heat transfer is  often accomplished using shell-and-tube  or plate  type heat
 exchangers.3'11 Direct heating routes the hot products of combustion (blended with ambient air
 to achieve the desired temperature) directly into the drying zone.  The fuels for a direct-fired
 oven  are usually either natural gas or liquefied petroleum gas (e.g., propane).  Direct-fired ovens
 are used most frequently because of their higher thermal efficiency. Indirect-heated ovens lose
 efficiency in the production of steam and in the heat transfer process.3'11
      Oven drying involves raising a coating's temperature above the boiling point of the vehicle
 solvent and keeping the temperature elevated long enough for entrapped solvents to migrate to
 the surface  and evaporate.   The time required to drive off vehicle  solvents at the boiling
temperature is known as the drying residence time.  During the drying process, heat is transferred
to the coating and backing.  Approximately 80 to  95 percent of the vehicle  solvent evaporates
CH-93-100
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 and is removed with the oven exhaust in most coating processes.11  The remaining trapped
 solvents generally migrate to the edge of the adhesive once it is used in its functional application.
 (This process is known as out-gassing, and is frequently a cause of adhesive failures.)  Another
 important factor to consider with temperature is the temperature profile.   If the initial drying
 proceeds too quickly, voids may develop in the coating.  Conversely, if drying occurs slowly at
 low temperatures, longer ovens may be necessary to achieve  sufficient residence time.
      Multi-zone ovens almost always overcome these difficulties.  A typical two-zoned oven is
 illustrated in Figure 2-15.  Zoned ovens are physically divided into several sections, each with
 its own exhaust and  supply of hot air.  The  temperature in the first zone is typically low,  but
 gradually increases in later zones.  This structure allows for uniform drying.  Large drying/curing
 ovens may have as  many as six zones ranging in temperature from 110°F (43°C) to 400°F
 (204°C).  Facilities may also employ recirculating ovens to provide better drying efficiency.
 Recirculation of the exhaust gas is an energy saving practice, but care must be taken to ensure
 that sufficient makeup air is circulated to prevent solvent saturation inside the oven. Figure 2-16
 illustrates oven exhaust recirculation.4'5'7'9"11

 2.4.5  Rolling, Printing, Cutting, and Product Shipment

      Many coating operations also offer value-added converting services to their customers.
 Such services include custom slitting and roll  winding, printing, die-cutting, and sheeting.  A roll
 of coated product may weigh up to  5,000 Ibs and be 30 inches wide when it comes off the
 production line. Such products are generally slit to a customer specified width, and automatically
 rolled  onto standard cores for customer use in automatic dispensers.  Many facilities have the
 ability to slit and wind product on-site, however, some facilities send finished rolls to contract
 converters to be sized.
     In addition to slitting and winding of stock products, coaters often customize label  and
 packaging products by printing a logo and die-cutting to size. Printing is typically done using
 flexographic or screen printing.  The  industry trend is towards the use of waterborne  and
radiation  curable inks for these processes.   Die cutting is typically  done with hydraulic-ram
presses and steel-rule dies.  The product is generally cut to the liner with the waste removed and
 the web rolled and packaged for shipping.
 CH-93-100                                     2-29

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8
                                           HEATED AIR
                   HEATED AIR
                  FROM BURNER
                  4-ROLL
                  REVERSE
                    ROLL
                  COATER
BURNER"""" l 	 1
ZONE 1
EXHAUST
I
n
**•

— II II
TJ U



ZONE 2
EXHAUST
1
n


II 11
U <_r
                                                                                     HOT AIR NOZZLES
TENSION
 ROLLS
                UNWIND
                                                                                                        WIND
                                              Figure 2-15.  Two-Zoned Drying Oven."

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Q
*
§
EXHAUST
                                                    RECIRCULAT10N
                      COATING KNIFE —7
                                                FUEL
                                           (NAT. GAS, FUEL
                                            OIL. PROPANE)
                                                                                                                   FRESH AIR
                                      Figure 2-16.  Coating Line with Exhaust Recirculation."

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       When  coating and  all custom conversion is finished, the product rolls  are ready for
  shipment  Finished products are wound on cardboard cores with plastic caps inserted into the
  ends of the roll to prevent damage to the edges of the product  The rolls are then placed in
  containers (e.g., cardboard boxes) for shipment Large rolls which have not been cut and sized
  are shipped in open rolls with wood-end caps, and metal straps around the rolls for support

  2.5   SPECIFIC PRODUCTION PROCESSES

  2.5.1 Introduction

       The  following section provides process descriptions specific  to certain  manufactured
 products.  The actual process descriptions include some of the fundamental processes described
 in Section  2.4.   The production processes described in this section will deal specifically with
 paper tape, film  tape, duct tape, reinforced tape, and labels.
       Paper Tape Manufacturing
      The manufacture of paper tape involves three basic coating steps:  saturation, release
 coating, and adhesive coating.   Coloring and priming may be used in specific applications.  In
 some cases, facilities may purchase saturated paper webs, thus eliminating the saturation step.
 Facilities choosing to saturate their own webs most frequently use the dip and squeeze method.
 The paper web is placed on an unwinder and is threaded through the coating line.  The web
 passes through the saturant trough, is  squeezed to remove any excess saturam, and is then sent
 to a drying oven.
      Once the paper is saturated,  and colored and/or primed, the release coat is applied  to the
 non-bonding surface of the substrate (i.e., the side mat will not receive  the adhesive coating).
 Application rollers (direct or gravure) are normally used to apply the release coat to the top side
 of the substrate. Additional rollers maintain the tension of the paper to ensure an even coating.
A doctor blade or knife  may be used to remove any excess coating which is fed back  to the
coating bath for reuse.  The release coating bath is often fed from a small line tank which, in
turn, is fed from a larger tank in a mixing area.  Once release-coated, the  tape will pass through
CH-9MOO                                    2-32

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 a drying oven.  The saturated and release-coated paper is then either wound and physically
 moved to the next coating step (i.e., adhesive coating) or it continues processing on the same
 coating line.
      The adhesive coating is applied to the bottom or non-release coated side of the paper. A
 doctor blade may also be used to remove excess adhesive and return it to the adhesive bath.  The
 adhesive is fed by a line tank or directly from a large mixing tank.  The adhesive coated paper
 passes through another set of dryers. The product is then wound, followed by slitting, packaging,
 and shipping.  Figure 2-17 is a paper tape manufacturing process flow diagram.

 2.53  Film Tape Manufacturing

      The coating of film substrates is nearly identical to paper coating, with a primer, or tie-coat,
 replacing the saturant coating step prior to the adhesive coating. The film web, which may be
 polypropylene, vinyl, polyvinyl chloride (PVQ, polyester, acetate, or cellophane, is coated with
 the primer, which is a thin layer of a high tack polymer material, to improve the bond between
 the adhesive and the film.

 2.5.4  Duct Tape Manufacturing

      Duct tape is manufactured in a two stage process. First,  a laminated web of cloth and film
 is prepared  Duct tape adhesive, in solid form, is calendared to the cloth side of this laminated
 web. In the calendaring process, the web  and adhesive are laminated  together by a nip roller
 which contacts the adhesive leaving a very smooth surface. The difference between calendaring
 and roll coating is that the calendared adhesive is removed cleanly from the roll, while liquid
 adhesive applied by roll coating actually splits, with some adhesive remaining on the roller. The
 three layer product is then given a release coating on the film side, slit to width, and wound in
rolls of varying length.
CH-93-100                                    2-33

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   INTERMEDIATE
   COATING
     * Tie coat
     * Color coat
PAPER FROM VENDOR
  ' Latex saturate
  * Poiyurethane
   saturate
                               COATING

                                  * Apply release coat
                                  * Apply adhesive
COATINGS

  * Adhesive from
    mixing/bulk storage
  * Release coat
                               SLITTING
                                  * Tube (core) making
                                  * Slitting (automatic & duplex)
                                  * Bulk pack at slitter or load on
                                   peg carts for packing
                               PACKING
                                 * Bulk pack in boxes
                                 * Individual roll wrap (film wrap)
                                 "Box
                              SHIPPING
             Figure 2-17.  Paper Tape Manufacturing Process Flow Diagram.
CH-93-100
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 2.5.5  Reinforced Tape Manufacturing

      Reinforced tapes arc manufactured in the same  manner as film tapes except with an
 additional step of  joining  reinforcing  fibers  to  the  film backing.   The  reinforced tape
 manufacturing process consists of tie, release, and adhesive coatings, and possibly a laminating
 step. Reinforced tapes consist of a film backing substrate (e.g., polyester, acetate) that has been
 joined with reinforcing fibers, such as fiberglass. The fiber reinforcers provide superior strength
 compared to paper or film tape.
      The film and reinforcing fibers are threaded through the coating line.  The fibers are tie-
 coated/laminated to the film. The film substrate has the release coat applied on the opposite side
 of the tie-coat  Several rollers are used to maintain the tension of the substrate during this
 process.  A doctor blade may be used to return any excess release coating to the coating bath.
 The substrate is then passed through a set of dryers  and rewound. The release-coated substrate
 is then threaded through the adhesive coating system.  The adhesive coat is applied over the
 reinforcing threads.  Any excess adhesive may be returned to the coating bath by a doctor blade.
 The product is then passed through another set of dryers.  The finished product is then wound,
 followed by slitting, packaging, and shipping.

 2.5.6 Label Stock Manufacturing

      Label stock manufacturing is  also similar to paper tape manufacturing. The  two rolls of
 paper that are typically used in the label making process include  a release liner (the label
 backing) and the face stock (the label itself).  A release liner is formed by  applying a release
 coating to the saturated paper.  This release coating is often a mixture of silicone and solvents.
 The substrate coated with the release coating is men dried in an oven and rewound. The release-
 lined substrate is placed on a coater-laminator machine. The silicone-coated surface is coated
 with an adhesive then dried in a oven. As the coated paper comes from the oven, it is laminated
 by  pressure rollers with the  label  face  stock creating a three-layer lamination (face stock,
 adhesive, and release liner). Once laminated, the coated paper is slit  Slitting machines cut the
paper into particular sizes as a finished product or for further processing.  If the slit laminate is

CH-93-100                                    2-35

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  to be printed, it is sent to a printing press where it may be die-cut, perforated, and/or printed.
  The labels are then rolled or fan-folded into sheets and boxed for storage and shipping.

  2.6   CLEANING REQUIREMENTS

  2.6.1 Introduction

       The equipment used in the manufacture of adhesive paper products is cleaned to prevent
  coating contamination, ensure product performance, maintain equipment operations, and reduce
  waste buildup. Cleaning materials attack and break the bond between the adhesive and the metal
  (or other surface) being cleaned. The total quantity of cleaning material used depends on several
  variables including cleaning frequency; desired level of cleanliness; size, shape, and composition
  of part to be cleaned; and soil to be removed.

 2.6.2  Cleaning Frequency and Desired Level of Cleanliness

      Facilities typically clean on an "as-needed" basis, rather than on a set schedule. As-needed
 often means upon product changeover or during  equipment  shutdowns.  However, as-needed
 cleaning is also performed when substrate webs break, spilling wet coating material on equipment
 surfaces, when coatings splash from troughs, and when excess coating seeps from behind dams
 and splash guards.
      The frequency of cleaning during product changeovers varies depending on the type of
 facility.  As discussed previously, the industry may be divided into two groups:  "dedicated line"
 facilities and "batch processing"  operations. Dedicated line facilities operate lines dedicated to
 one type of product (e.g., grades  of masking tape or label stock), while  batch processors
 manufacture a wide range of products using a number of different substrates and coatings. Batch
 processors include facilities that manufacture and market a line of products, and those which
 provide contract coating services. The latter are known as toll coaters.  Dedicated line facilities
 may run their lines up to 24 hours per day,  7 days per week, and 52 weeks per year. Production
runs are typically scheduled with compatible batches in  sequence.  When a product change is
 about to occur, the production operator will add only enough coating to the application troughs
CH-93-100                                   2-36

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 to coat the length of substrate remaining on the substrate web. This allows the substrate web and
 the coating to be exhausted at approximately the same time. As the first web finishes, the second
 web is threaded and the new coating formulation is added to the application trough. A similar
 technique is used just prior to a shutdown, with the equipment allowed to "run dry."
      If such "on-the-fly" changeovers are not possible, excess coating is  drained  from the
 application pans and coating lines back into storage drums and is retained for future use, and the
 equipment is  cleaned prior to start-up  of the next job. Although some product contamination
 occurs with either process changeover  scenario, the substrate coated with the mixed coatings is
 the last portion of the first roll or the first part of the succeeding web. In either case, this portion
 of the web, the "makeready" substrate,  can be discarded if it is not suitable for use. Makeready
 is generated regardless of substrate and coating.  Product changeovers in a dedicated line facility
 generally occur no more often than one time per day. In many cases, major product changeovers
 occur once per week  (following a designated shutdown period during which  coating line
 equipment undergoes thorough cleaning and preventive maintenance.)
      In contrast, batch processors generally do not clean equipment on any  specific  schedule.
 Due to the relatively short production runs and  the custom nature of the specialty products that
 these facilities manufacture the desired level of cleanliness between jobs is critical. Therefore,
 at the end of each job, all application equipment is thoroughly cleaned in the manner described
 for dedicated lines. Batch processors are likely to use the solvents toluene and MEK because a
 high level of cleaning is required. Alternative cleaners, such as mineral spirits (which may be
 used by  dedicated line facilities for some cleaning applications), are often described by batch
processors as  achieving "inadequate" cleaning results.  Product changeovers in batch facilities
may occur as frequently as every one to two hours.  Seldom do batch processors run a job longer
than one eight-hour shift

2.6.3  Construction of Part to be Cleaned

     The effort required to achieve the desired level of cleanliness is often dependent on the
construction of the part to be cleaned. While many small parts (e.g., portions of pipe, or valves)
can be removed from the equipment line for thorough cleaning, other pieces of equipment (e.g.,
ovens and coating application rollers, coating application pans) must be cleaned in place.  When

CH-93-100                            '        2-37

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  components of these larger pieces of equipment arc removed from the coating line, they are
  typically cleaned in centralized cleaning areas in parts washers specifically designed to handle
  them.  Another cleaning apparatus used in some centralized cleaning rooms is  an ultrasonic
  cleaner.
       Another illustration of the effect that equipment design can have on cleaning is the material
  used to construct the application cylinder.  Some application rollers are made of rubber rather
  than carbon steel. Cleaning rubber rollers with a solvent such  as toluene or MEK accelerates
  deterioration of the roller. Therefore, equipment of this nature is often cleaned with a caustic-
  based cleaning solution.

  2.6.4  Soil to be Removed

      The soil to be removed from the equipment or part also influences the cleaning method.
 The solvents required to clean equipment in coating and laminating facilities are, in large part,
 determined by the resin in the coating formulations.   For example, adhesives often stick to
 application rollers, equipment housings, or transfer pipes. Typically, facilities using solvent-based
 coatings use the primary vehicle solvent in the coating formulation for cleaning purposes.  For
 instance, if an adhesive is formulated with butyl acetate, butyl acetate would be used to clean the
 adhesive coating line. If the formulation solvent is not used for cleaning, then another solvent
 with strong cutting power is used.  Toluene and MEK are solvents frequently used because of
 their strong cutting power.
      Waterbased coatings are often easier to clean, as the  incorporated resin will dissolve in
 water.  Cleanup  of waterbased materials often involves an equipment wipe with  a wet rag.
 Sometimes the cleanup solution will  consist of water mixed with an alcohol, like isopropyl
 alcohol (IPA).   The  addition  of an alcohol results in added "cutting" power for waterbased
 coatings.

2.7  CURRENT CLEANING TECHNIQUES

     This section discusses some of the common cleaning needs and methods of specific pieces
of equipment such as  ovens, reservoirs, troughs, hoses  and dams.
CH-93-100                                    2-38

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 2.7.1  Specific Equipment Cleaning Requirements

 2.7.1.1 Ovens
      Because ovens are enclosed systems, full cleaning is done during equipment shutdowns,
 although exterior surfaces may be cleaned during or between production runs.  Oven cleaning is
 necessary because the ovens are used to volatilize the coating solvent and dry the substrate to a
 specific weight Consequently, some of the solvent and coating mix and become trapped either
 as gel or cured adhesive in the oven screens and hoods. If the ovens are not routinely cleaned,
 the oven screens will become clogged, thereby decreasing the efficiency of drying or curing.

 2.7JJ2 Reservoirs
      Reservoirs are bins located under the application rollers, that are used to supply the coatings
 for application purposes.  Slashes and breaks in the substrate web result in contamination of the
 reservoirs and the  area around the reservoir.  Because these bins act as a catch basin for excess
 coating, they often become encrusted and require cleaning.

 2.7JJ Troughs
      Troughs are  bins which catch any overflow from the reservoirs.  Some facilities use the
 troughs as a holding basin for cleaning solvents. These facilities like the easy access to solvents
 which encourages  workers to clean the immediate area more thoroughly when splashes occur.
 Moreover, when a coating overflow from the reservoir occurs, the solvent in the trough aided in
 cleanup.

2.7 J.4 Pumps, Lines, and Hoses
      Pumps, lines,  and  hoses transfer coatings from  mixing tanks, holding tanks,  and other
temporary storage  areas  to process lines.  Coatings that stick to the exterior surfaces of these
pieces of equipment are removed with mechanical scraping and solvent-soaked rags.  One facility
using waterbased adhesives uses plastic vinyl chloride (PVC) pipes to transfer the coating from
the mixing tanks to the production lines. When these pipes become clogged, they are replaced
rather man cleaned.  The facility has not replaced their pipes in approximately three years.


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 2.7.1.5 Dams
       Both overflow containers around reservoirs and flat metal sheets on the end of rollers are
 considered dams, which prevent coatings from splashing over the side of the machinery.  Hie
 dams are cleaned during shutdown with rags soaked with the cleaning solvent

 2.7.1.6 Miscellaneous
       Miscellaneous cleaning includes the cleaning of product and raw material storage tanks,
 process lines, and floors. Generally, storage tanks and process lines in dedicated line facilities
 are limited to one type of material and, therefore, do not require cleaning.  When the lines are
 not in use, some facilities fill (pack) them with solvent to prevent coating in the lines and tanks
 from solidifying. Floors are often mopped using equipment cleaning solvent Other facilities use
 scrap cardboard or off-specification substrate sheets to protect the floor and reduce the amount
 of mopping.  As the floor coverings are torn and become unprotective, they are disposed of as
 either solid or hazardous waste and are replaced.

 2.7.2  Cleaning Techniques

 2.72.1 Run Dry
      Running a line dry is an operating technique, occurring at the end of a production run, that
 involves adding only enough coating to the application troughs to coat the length of substrate
 remaining on the web.7 This process technique reduces coating waste and thus, coating cleanup.
 Running dry reduces the requirement to remove gross amounts of coating from reservoirs prior
 to cleaning, results in less adhesive remaining on the coating apparatus, and reduces the amount
 of cleaning solvent required.

2.73.3.     Mechanical Scraping
     Mechanical scraping involves the use of a putty knife or other straight-edged instruments
to physically remove the coating by scraping it from the part surface.  Mechanical scraping is
of greatest benefit when performed before the coating has  time to settle and harden.   Many
facilities follow  mechanical  scraping with a solvent wipe.  Care must be taken when scraping
equipment to avoid damaging surfaces that meter or apply coatings.
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 2.7.2 J Solvent Wiping
      Solvent wiping is the most commonly used cleaning technique within the coated and
 laminated substrate industry.  It is primarily used in conjunction with mechanical scraping to
 remove coating residue. A rag is moistened with a cleaning solvent and used to wipe the coating
 from the part  Facilities often maintain safety cans of solvent with both rags and a scraper next
 to the machinery for immediate access by the operators to wipe away the coating when a splash
 occurs. Solvent wiping is a major source of fugitive emissions.

 2.73.4 Immersion
      Immersion  involves the "bathing" of products in a  solution to  remove coating residue.
 Immersion techniques are most commonly used in centralized parts cleaning areas. A number
 of different cleaning materials are used in immersion  parts washers including toluene, MEK,
 mineral spirits, aqueous cleaners, and custom blends.  Some facilities scrape parts  prior  to
 immersion in the baths. This technique removes as much coating as possible before bathing in
 the solvent bath,  helping to increase the useful life of the solvent in the bath by reducing the
 amount of coating contamination. Some facilities use the spent solvent from the immersion bath
 as makeup solvent for their coating process.  This practice is especially prevalent when the
 primary vehicle solvent is used as the immersion bath.

 2.725 Other
      Other cleaning techniques identified were the use of high pressure water sprayers and
 coating machinery surfaces with disposable wraps or impregnated metal powders.  One facility
 uses high  pressure water washes for yearly cleaning of the floors, storage tanks, and equipment
 parts.  A  solution of high pressure water (12,000 psi), heptane, isopropyl  alcohol, and salts is
 used to clean dry adhesives from these areas. This process results in a hazardous waste stream
 with a low Btu value, and consequently a high disposal cost Due to the high cost of this service
 ($800 a day) and the costly disposal of the water as hazardous waste, this  process is due to  be
 discontinued. One facility coated the machinery with non-useable paper or aluminum foil which
reduced the need for chemicals for cleanup and cleanup time, but  increased the cost of solid
hazardous waste disposal.7  Other facilities use porous, flame-coated metal powders, which are


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 then impregnated with release chemicals, to prevent adhesive from adhering to machine surfaces.
 This technique is discussed in Chapter 4.

 2.8   PROPERTIES OF CURRENT CLEANING SOLVENTS

 2.8.1 Introduction

       Some cleaning materials are used more frequently than others. This section describes the
 properties of some of the currently used cleaning solvents.  The  materials discussed include
 toluene, mineral spirits, methyl chloroform, MEK, and xylene.

 2.82  Toluene

      Toluene is a man-made aromatic hydrocarbon produced from  petroleum. Toluene is used
 as a raw material in several  types of coatings including paints,  inks, Pharmaceuticals, and
 adhesives. The chemical formula for toluene is C^tl5CR3.  Toluene  is not corrosive and will not
 react with either bases or dilute acids. It has been estimated that 86 percent of all toluene used
 is released to the biosphere where its life span ranges from 4 days, at high-altitudes during the
 summer, to several months, in low-altitudes during winter months.12 Table 2-5 lists the physical
 and chemical properties of toluene. Toluene is a chemical included in EPA's 33/50 Program.
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       TABLE 2-5.  PHYSICAL AND CHEMICAL PROPERTIES OF TOLUENE
  Property                                                      Value
  Chemical name                                                Toluene
  Synonyms                                   Methylbenzene; toluol; phenylmethane; methacide;
                                                            methylbenzol
  Molecular formula                                             CgHjCH^
  CAS Registry                                                 108-88-3
  Molecular weight                                               92.14
  Melting point                                       -95 to -94.5°C (-139 to -138.1*F)
  Boiling point (760 mm Hg)                                  110.63'C (231.13°F)
  Density, g/cnr
  at25eC(77°F)                                                 0.8623
  at20°C(68<'F)                                                 0.8667
  Physical state (ambient conditions)                                  Liquid
  Color                                                         Clear
  Odor                                                      Benzene-like
  Solubility:
  Water at 20" C (68*F)                              Very slightly soluble (0.05 g/100 mL)

  Vapor pressure at 20*C (68"F)                              219 mm Hg (2.92 kPa)
Source:  Reference 12
2.83 Mineral Spirits

      Most coated and laminated substrate manufacturers that use mineral spirits for cleaning use
Varsol. Varsol is a branded petroleum solvent blend manufactured by Exxon Company, USA.
It is a clear liquid with a mild mineral spirits odor.  Varsol 18, one of the varieties of Varsol,
contains approximately 92 percent saturated hydrocarbons («.#., hexane and heptane), and toluene,
xylene, ethylbenzene,  and an aromatic mixture for  a combined concentration of 7.1 percent
Table 2-6 summarizes the physical properties of Varsol.13
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                  TABLE 2-6.  PHYSICAL PROPERTIES OF VARSOL
                        Property
                           Value
   Chemical name
   Molecular Weight
   PH
   Melting Point
   Boiling Range (760 mm Hg)
   Specific Gravity (15.6eC/15.6"C)
   Physical State
    Color
    Odor
   Solubility:
    Water at 25° C (77° F)
   Vapor Pressure at 25° C (77°F)
  Percent Volatile by Volume at 1 atm
    and25"C(77°F)
  Evaporation Rate @ 1 atm. and 25° C (77° F)
    (n-butyl Acetate = 1)
                    Petroleum solvent blend
                            145
                      Essentially neutral
                       <-18«C (0*F)
                    153-202° C (308-396° F)
                           0.78
                           Liquid
                           Clear
                       Mineral Spirits

                   Negligible: less than 0.1%
                    <10 mm Hg (< 1.3 IcPa)
                           100

                           0.1
 Source: Reference 13
 2.8.4  Methyl Chloroform

      Methyl chloroform or 1,1,1-trichloroethane (TCA) is a man-made chlorinated solvent which
 is predominantly used in cold cleaning operations and vapor degreasing. Methyl chloroform's
 use in adhesives accounts for 10 percent of its total use.14 Methyl chloroform in the atmosphere
 has a  half-life of approximately 6 months to 25  years.14  Though not all methyl chloroform
 travels to the stratosphere, that which does contributes to the depletion of the stratospheric ozone
 layer.  It is responsible  for approximately 16 percent of the ozone-destroying chlorine in the
 stratosphere from anthropogenic sources.  Table 2-7 provides physical and chemical properties
 of methyl chloroform.14  Methyl chloroform is a 33/50 Program chemical.
      Consumption and  production of methyl chloroform  will  decline as  a result  of the
implementation of the 1987 Montreal Protocol on Substances that Deplete the Ozone Layer and
Title VI  of the 1990  Clean Air Act Amendments  (CAAA).15  Under both of these provisions,
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  Property
 TABLE 2-7. PHYSICAL AND CHEMICAL PROPERTIES OF
	METHYL CHLOROFORM

                                                   Value
  Chemical name

  Synonyms
                                              Methyl Chloroform

                                     1,1,1-trichloroethane; ethylidine chloride;
                                     methyltrichloromethane; trielene; algylen;
                              trichloromethylmethane; chloroethane; inhibisol; trichloran;
                               gemalgene; TCA; TCEA; aerothene; a- Trichloroethane;
                                       1,1,1-TCE; 1,1,1-Tri; trichloroethane
  Molecular formula

  CAS Registry

  Molecular weight
  Melting point
  Boiling point (760 mm Hg)

  Density, g/cm3
   at250C(?rF)
   at20°C(68*F)

  Physical state (ambient conditions)
  Color

  Solubility-
   Water at 20° C(68*F)
  Vapor pressure at 20* C (68°F)
                                                  71-55-6

                                                   133.42
                                              -30.4" C (-12.TF)
                                              74.1eC (165.4°F)
                                                   1.136
                                                   1.324

                                                   Liquid
                                                   Gear
                                        Insoluble (0.095 g in 100 g water)
                                    0.034 g (water in 100 g methyl chloroform

                                           99.8 mm Hg (133 kPa)
 Source:  Reference 14
methyl chloroform is classified as a controlled substance scheduled for phase-out within the next

ten years (i.e., 2005  under the 1990 Revision of the Montreal Protocol and 2002 under the 1990

CAAA).16*17  However,  the U.S. has  pledged  to  stop  methyl  chloroform production by

December 31,1995.  In addition, in November 1992,87 nations agreed to accelerate the Montreal

Protocol schedule and phase out methyl chloroform by the beginning of 1996.18


2.8.5 Methyl Ethyl Ketone (MEK)


      MEK or 2-butanone is a colorless organic  liquid with  an acetone-like odor and a low

boiling point  MEK, which is highly reactive, has exceptional solvency and a short atmospheric

lifetime (approximately eleven hours.)19 Table 2-8 provides physical and chemical properties of

•MEK. MEK is another 33/50 Program chemical.
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   Property
TABLE 2-8. PHYSICAL AND CHEMICAL PROPERTIES OF
             METHYL ETHYL KETONE
                                                 Value
   Chemical name
   Synonyms
   Molecular formula
   CAS registry number
   Molecular weight
   Melting point
   Boiling point
   Density at 20° C, g/cm3
   Physical State (ambient conditions)
    Color
    Odor
   Solubility:
    Water at 90" C (1948F)
  Vapor pressure at 20°C (68°F)
                                           Methyl Ethyl Ketone
                             2-butanone, ethyl methyl ketone, MEK, methyl acetone
                                                 C4H,O
                                                78-93-3
                                                 72.1
                                            -86.3'C (123.3'F)
                                            79.6°C (175.3eF)
                                                 0.8045
                                                 Liquid
                                                 Clear
                                                 Sweet
                                                190 g/L

                                          77.5 mm Hg (10.3 kPa)
 Source: Reference 19
 2.8.6  Xylene

      Xylene is an aromatic hydrocarbon that occurs naturally in petroleum and coal tar. Xylene
 is a colorless liquid with a sweet odor and is volatile, flammable, and explosive in air. Xylene
 is not soluble in water, but is soluble in alcohol and many organic liquids.  There are three
 xylene isomers ortho-xylene (o-xylene), meta-xylene (m-xylene), and para-xylene (p-xylene).
 Mixed isomers are a mixture of two or more xylene isomers and a small amount of ethylbenzene.
 Xylenes  can be transformed by photo-oxidation in the troposphere, and can participate in the
 formation of ground-level ozone.20 Table 2-9 lists some physical and chemical properties for
 mixed xylene.  Xylene is also a 33/50 Program chemical.
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   TABLE 2-9. PHYSICAL AND CHEMICAL PROPERTIES OF MIXED XYLENES
  Property                                                  Value
  Chemical name                                         Xylene isomers
  Synonyms                                            dimethylbenzene
                                                            xylol
                                                        methyl toluene
  Molecular formula                                        C6H4(CR3)2
  CAS Registry                                            1330-20-7
  Molecular weight                                           106.16
  Melting point                                             No data
  Boiling point (760 mm Hg)                              137° to 144° C
  Density, g/cm3                                              0.860
   at 20°C (68°F)
  Physical state                                              Liquid
   Color                                                    Clear
   Odor                                                 Benzene-like
  Solubility:                                             0.013 g/100 1
  Water at 25° C (77°F)
                                            Miscible with absolute alcohol, ether, and
                                                      other organic liquids
  Vapor pressure at 20°C (68°F)                        6.15 mm Hg (0.82  kPa)
Source: Referenced
2.8.7  Other

     Three other products currently  used  in equipment cleaning operations at coated  and
laminated substrate facilities are perchloroethylene, heptane, and isopropyl alcohol.  In some
facilities perchloroethylene and heptane are used in adhesive cleaning and isopropyl alcohol (IPA)
is used to clean the press plates. Approximately seven percent of total perchloroethylene output
is dedicated to metal cleaning and degreasing.21*22 Table 2-10 lists several physical and chemical
properties of perchloroethylene.
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        TABLE 2-10.  PHYSICAL PROPERTIES OF PERCHLOROETHYLENE
                  Property                                   Value
  Chemical name                                        Perchloroethylene
  Molecular formula                                           ^C^
  Molecular weight                                            165.83
  Melting point                                          -22.4° C (8.32°F)
  Boiling point                                          121.2° C (250.2°F)
  Physical state (ambient conditions)                             Liquid
    Color                                                     Clear
  Vapor pressure at 20°C (68°F)                         14 mm Hg (1.87 kPa)
  Specific gravity at 20° C (68°F)                                1.623
 Source:  Reference 21
      Heptane is a hydrocarbon solvent made from petroleum products. Table 2-11 provides
 several physical and chemical properties of research grade heptane.

 ^	TABLE 2-11. PHYSICAL PROPERTIES OF HEPTANE	
                  Property                                   Value
  Freezing point                                             -131.10°F
  Boiling point                                              209.17°F
  Specific gravity                                          0.6882 @ 60°F
  Vapor Pressure                                         1.62 psia @ 100°F
Source: Reference 22
     Isopropyl alcohol may be used to clean small amounts of adhesive from application,
metering, and tensioning rollers.  Isopropyl alcohol is a colorless, flammable, mobile liquid.
Table 2-12 list several physical and chemical properties of isopropyl alcohol.
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 	TABLE 2-12. PHYSICAL PROPERTIES OF ISOPROPYL ALCOHOL
                  Property                                   Value
  Chemical name                                         Isopropyl alcohol
  Molecular weight                                            60.09
  Melting point                                          -89.5° C (129.1°F)
  Boiling point (760 mm Hg)                              82.5°C (180.5°F)
  Specific gravity at 20° C (68°F)                                0.7855
  Physical state                                               Liquid
   Color                                                     Clear
 Source: Reference 21,23
 2.9   CHARACTERIZATION  OF  POLLUTION  RESULTING  FROM  CURRENT
      PRACTICES
 2.9.1 Air Emissions

     In 1990, the total of all MEK releases to the air by facilities operating under SIC 2671 was
 1.1 million pounds.24  Toluene air releases totalled 8 million pounds.24  SIC 2672 facilities
 emitted nearly 15 million pounds of MEK and 18 million pounds of toluene.24  Facilities
 contributing to these releases are listed in Appendix B, Table B-l  and Table B-2.  Most coated
 and laminated substrate manufacturing facilities calculate these emissions based on raw material
 consumption. Therefore, total emissions reflect solvent losses occurring during  raw material
 mixing, coating processing (including fugitive releases), equipment cleaning, and material storage.
     Some industry representatives estimate that ten percent of total solvent releases are due to
 equipment cleaning.  This percentage represents the greatest source of fugitive emissions from
 coated and laminated substrate manufacturing.  These emissions are difficult to control with add-
 on devices, so some facilities are attempting to find alternative cleaning products and methods.
Depending upon the cleaning chemicals used (e.g., toluene, methyl chloroform, mineral spirits),
VOCs or toxic pollutants may be emitted.
     The primary impacts of VOC reductions are dependent on the facility location.  In heavily
industrialized  areas, the reduction of VOC emissions may produce a corresponding reduction in
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  ambient hydrocarbon levels, and thus a reduction in ozone formation. In rural areas, lower VOC
  emissions will result in lower overall ambient hydrocarbon levels, helping to reduce the transport
  of ozone precursors to urban areas.  Many air toxics are also VOCs. Therefore, the reduction
  of the toxics will result in benefits similar to those achieved with VOC reduction. In addition,
  the reduction of air toxics will lead to reduced environmental impacts on other media.  For
  example,  improperly handled chlorinated materials (e.g., methyl chloroform) often  result in
  contaminated soil and groundwater. Reducing the quantities of these materials used for cleaning
  will reduce contaminated aquifers, drinking water wells, and soils.
       Emissions from the application of solvent-based coatings are often directed to a control
  device (e.g.  carbon absorption, catalytic or thermal incinerators).  While such control devices
 reduce VOC emissions, the use of incineration will actually increase ambient  levels of carbon
 monoxides (CO) and nitrogen oxides (NOX) in the area.

 2.92  Liquid Waste Streams

      Spent cleaning solvents are the largest liquid waste produced by coated and laminated
 substrate manufacturers.  Many of these solvents are recoverable through distillation and can be
 incorporated in a coating, however they may also be sent off-site for disposal  A second liquid
 waste  stream consists of excess or off-specification coating.
      Another source of liquid wastes may be the control equipment  Facilities  using carbon
 adsorption systems (usually associated with controls on  dryers or ovens) have the potential to
 discharge contaminated water from the steam used to desorb the carbon beds.  Facilities typically
 have three  options for disposing of this waste: (1) use the water for boiler feed; (2) use the water
 for cooling tower purposes; or (3) discharge the water into a wastewater treatment facility or
 local sewer for further treatment.
     Facilities are responsible for the environmental impacts their water may have on a sewer
 or water system.  A facility must always consider the  effects of a new liquid waste stream on
plant wastewater treatment  (WWT)  operations or  on the Publicly Owned Treatment Works
 (POTW).  Some cleaners may reduce toxicity, hazardous waste, and air emissions, but create
excursions  in effluent limitations.

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 2.93  Solid Wastes

      Solid wastes from the manufacturing operations may be classified into three areas: cleaning
 waste, waste substrate, and solidified coating waste. Solid waste from cleaning includes items
 such as rags, floor coverings, machinery coverings, and coating filters.  The disposal of waste
 substrate (from the edge of paper rolls, at the beginning and ending of a run, and from cutting
 and packaging operations) is dependent  on local/state regulations.  The characteristics of the
 solvent on the paper affect its classification as solid waste.
      In addition, solid waste may be created by emissions control equipment. Activated carbon
 from carbon adsorption systems must be replaced periodically, presenting a solid waste disposal
 problem.  The remains from incineration or catalytic  oxidation must be disposed of as solid
 waste.  The carbon may be able to be re-used for fuel or recycling for other uses. Waste from
 incineration or oxidation may also have alternative uses.

 2.10  REFERENCES

 1.    Standard Industrial Classification Manual,  Office of Management  and Budget  1987.
 2.    U.S. Department of Commerce. 1987 Census of Manufactures, Industry Series: Convened
      Paper and Paperboard Products, Except Containers and Boxes, MC87-1-26C. Bureau of
      the Census. Washington, D.C  1990.
 3.    Satas, Donatas, ed, Handbook of Pressure-Sensitive Adhesive Technology. Van Nostrand
      Reinhold Company.  New York, NY.  1982.
 4.    Nashua trip report; see Appendix C
 5.    3M trip report; see Appendix C.
 6.    "Shurtape®, What is pressure-sensitive tape?" Shuford Mills, Inc., Hickory, NC. Provided
      in Memorandum from WJL Little, Jr. to Radian Corporation, Research Triangle Park, NC.
      June 12, 1992.
7.    Anchor trip report; see Appendix C
8.    Gale Research, Inc.  Warfs Business Directory of US. Private and Public Companies,
      Volumes. Detroit, MI.  1992.
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  9.    Rexham trip report; see Appendix C.

  10.   Tesa Tuck trip report; see Appendix C

  11.   Goodwin, D.R. Pressure Sensitive Tape and Label Surface Coating Industry - Background
       Information for Proposed Standards: Draft EIS.   EPA-450/3-80-003a.  (NTIS PB81-
       105942).  Office of Air Quality Planning and Standards.  Research Triangle Park, NC.
       September 1980.

  12.   U.S. Environmental Protection Agency.  Locating and Estimating Air Emissions from
       Sources of Toluene. EPA-454/R-93-047.  Office of Air Quality Planning and Standards.
       Research Triangle Park, NC.  September 1993.

  13.    Varsol 18. Material Safety Data Sheet (MSDS). Exxon Company, USA.

  14.    U.S. Environmental Protection Agency.  Locating and Estimating Air Emissions from
       Sources of Methyl Chloroform. EPA-454/R-93-045. Office of Air Quality Planning and
       Standards. Research Triangle Park, NC.  September 1993.

  15.    U.S. Environmental Protection Agency. 40 CFR 82, "Protection of Stratospheric Ozone,"
      Federal Register, December 30,1991.

  16.   United Nations  Environment Programme.   Handbook for the Montreal Protocol on
      Substances that Deplete the Ozone Layer.  Ozone Secretariat Narobi, Kenya. May 1991.

 17.   Public Law 101-549.  The Clean Air Act Amendments of 1990, Title VI - Stratospheric
      Ozone Protection.  November 15,1990.

 18.   "Cross Media: Ozone Talks,"  Environmental Policy Alert.  December 9, 1992.

 19.   U.S.  Environmental Protection Agency.   Locating and Estimating Air Emissions from
      Sources of Methyl Ethyl Ketone. EPA-454/R-93-046. Office of Air Quality Planning and
      Standards.  Research Triangle Park, NC  September 1993.

 20.   U.S. Environmental Protection Agency.   Locating and Estimating Air Emissions from
      Sources ofXylene. EPA-454/R-93-048. Office of Air Quality Planning and Standards.
      Research Triangle Park, NC  September 1993.

 21.   Most, CC  Locating and Estimating Air Emissions from Sources ofPerchloroethylene and
      Trichloroethylene.  EPA-450/2-89-013  (NTIS  PB89-235501).   Office of Air Quality
      Planning and Standards.  Research Triangle Park, NC  August 1989.

22.   Mellan, Ibert. Industrial Solvents Handbook: Second Edition.  Noyes Data Corporation.
      Park Ridge, NJ.  1977.
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 22.   Mellan, Ibeit Industrial Solvents Handbook:  Second Edition.  Noyes Data Corporation.
      Park Ridge, NJ. 1977.

 23.   Lowenheim, Frederick A., and Moran, Marguerite K. Industrial Chemicals; 4th edition.
      John Wiley & Sons.  New Yoric, NY.  1975.

 24.   Toxic Chemical Release  Inventory Database.  U.S.  Department of Health and Human
      Services, National Institutes of Health, National Library of Medicine.  Bethesda, MD.
      Toxicology Information Program Online Services TOXNET* Files. 1990.
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                                     CHAPTERS
                            QUESTIONNAIRE RESULTS
 3.1   GENERAL
      A questionnaire is frequently used to obtain industrial process information that cannot be
 gathered through literature searches. With the exception of actual facility visits, questionnaire
 distribution is often  the  best method for  gathering  specific  facility data.   Questionnaire
 distribution may either be via paper or disk mail-outs.  Limited information gathering may also
 be conducted by telephone contacts.  It is important to conduct a preliminary  phone or mail
 questionnaire prior to facility site visits to help identify willing  participants, to obtain general
 knowledge of facility products and processes, and to inform industrial personnel of EPA's project
 objectives. As discussed in Chapter 1, the responses to several targeted questionnaires provided
 much  of the background for the Improved Equipment Cleaning for Coated and Laminated
 Substrate Manufacturing Facilities research project  Preliminary questionnaire development
 began under a previous EPA effort. Initially, the questionnaire was to be conducted by phone.
 However, because of the quantity of information required, two separate mail-out questionnaires
 were developed. The poor response rate led to the development of revised questionnaires which
 were mailed  and then followed by phone contacts.  This chapter summarizes questionnaire
 development  and industry  responses.   The  last section in this  chapter identifies pollution
 prevention trends within the industry, as identified through responses to questionnaire efforts.

 33,  DESCRIPTION OF ORIGINAL QUESTIONNAIRE

     The initial project plan, under a previous EPA effort, included the development of a brief
 telephone questionnaire to be used to prepare a cursory industry characterization and to select
potential  demonstration  sites for Phase  n  activities.  Because  of the number of industry
 unknowns, including the variety of industrial processes, products, cleaning technologies, and
associated emissions, a more thorough written questionnaire was  developed.  This questionnaire
requested information on product type and manufacturing capacity, processes and coatings,
equipment cleaning  techniques, solvent consumption and  recycling, and pollution prevention

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  research efforts.  Prior to the distribution of this questionnaire, it was reviewed by several
  industry and trade association personnel including representatives of Anchor Continental and
  Shuford Mills.
       The original 14 recipients of the two written questionnaires, were identified through a
  search of the TRIS database and through leads obtained from members of the October 1991
  Industry Focus Group.1 Separate questionnaires were prepared for manufacturers operating under
  SIC 2672 and SIC 2641.  Prior to distribution of the questionnaire by  mail,  each anticipated
  recipient was contacted by phone to assess willingness to cooperate in the questionnaire effort
  Of the approximately fourteen questionnaires mailed, only four industries responded. Many of
  the non-respondents indicated that confidentiality was a concern.  They believed that answering
  the questions would lead to the disclosure of confidential business information (CBI).
       Facilities  not  responding to the initial  questionnaire received follow-up phone calls.
  Although some of these calls were met with persistent industry reluctance to participate, some
 calls did result in the retrieval of valuable information.  Several facilities did agree to host site
 visits and to consider continued participation as a demonstration site.

 3 J  DESCRIPTION OF REVISED QUESTIONNAIRE

      In an effort to receive input from a wider and more representative industry cross-section,
 a revised questionnaire was developed.  The revised questionnaire tables were adapted from the
 initial questionnaire  to include clarification of processes, products, and associated cleaning
 methods. The final questionnaire consisted of ten tables addressing the cleaning issues for each
 of four primary coating operations.  Two tables (i.e., one for process characteristics and a second
 for equipment cleaning techniques) were developed for each of the four coating processes (i.e.,
 adhesive, saturant, release, and other).  Two additional tables summarized facility location,
 product line,  and general pollution prevention research activity information.
      An extensive list of facilities and potential questionnaire respondents operating within the
 SICs 2641, 2671,  and 2672 was compiled.  Facility names, addresses, phone  numbers, and
contacts  were extracted from Ward's Business Directory, Dun &. Bradstreet Million Dollar
Directory, Air Tones  &  VOCs, and North Carolina Manufacturing Firms Directory.2'3'4'5
Facilities that agreed to review the  questionnaire were sent a copy either by mail or by fax to
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 ensure that the contact would have sufficient time to become acquainted with the questions asked
 and gather any  specific data.  A phone appointment to review and complete the tables was
 established with the facility contact  Several additional questions not amenable to the table
 format were also asked during the phone interview.
      Approximately 51 facilities were contacted by phone to assess their interest in participating
 in the questionnaire effort or in hosting a site visit  These contacts included the 14 facilities that
 had already received the  initial questionnaire.  Over half of the facilities contacted were small,
 label printing  operations claiming a variety of SICs. None of these small facilities were willing
 to complete the  questionnaire or host a site visit  Within the timeframe allowed for this task,
 nine companies completed the questionnaire for ten facilities. (One company responded for two
 of its facilities.)

 3.4   FINAL  QUESTIONNAIRE SUMMARY AND CONCLUSIONS

      The final  questionnaire was developed to show  the  relationship between products,
 manufacturing processes,  waste generation,  and cleaning  technologies.    Responses  are
 summarized according to the four primary coating application processes:  saturation, release
 coating, adhesive application, and other processes. The results are discussed in the remainder
 of this chapter and summarized in Tables 3-1 through 3-4.  These tables use the same format as
 those used to collect the data.
      Table 3-1 provides  an overview of the nine companies (and ten plants) that responded to
 the questionnaire. Facility size is represented by either number of employees or by square yards
 of product manufactured.  A uniform parameter to characterize size was not possible as many
 of the facilities considered either number of employees or production volume confidential.
      Table 3-2 identifies the manufacturing processes of each of the questionnaire respondents.
Table 3-2 is organized by process (i.e., saturation, release coating, adhesive application, and other
processes) and by facility.  Line numbers  are indicated under the company name.  A facility
operating three lines using exactly the same process and equipment will have the number three.
If the facility  operates three lines with slightly different parameters, the line numbers will be
listed individually (i.e., 1, 2, 3).  The Table 3-2 headings include coating technology, coating
method, resin  type, percent resin, carrier type, solvent percent solvent, solvent quantity,  and

CH-9MOO                                   3-3

-------
               TABLE 3-1. QUESTIONNAIRE RESPONDENT PROFILES
Company
Plant A
PlantB
Plant C
Plant D
Plant E
Plant F
Plant G
Plant H
Plant I
Plant J
Product
Consumer and Painting Tapes
Printing and Drafting Films
Drafting and Reproduction Films
Pressure Sensitive Labels
Pressure Sensitive Labels, Paper,
and Film
Pressure, Sensitive Tape;
Industrial Duct and Masking Tapes
Pressure Sensitive Tape for
Industrial Applications
Pressure Sensitive Films and
Screen Inks
Pressure Sensitive Tape
Pressure Sensitive Labels
SIC
2672
2672
2671
2671,
3080, 3081
2672
2672
2672
2672
2672
Size
12-100 million yd2
10 million yd2
10 million yd2
380 Employees
900 Employees
100 Employees
75 Employees
50 Employees
$10 million in sales
500 Employees
200 to 300 million yd2
 percent  solvent recycled  The coating  technology  category refers  to  the general coating
 formulation (e.g.,  waterbased, solvent-based, two-part reactive, hot melt, or other).   Coating
 method refers to either the method of coating application or the type of application roller. Resin
 type refers to the type of resin used in the coating formulation, while percent resin indicates the
 percent solids in the coating formulation. The carrier is the liquid portion of the coating that
 transfers the solid resin to the substrate.  The quantity of solvent present in the coating
 formulation is represented by the percent solvent category, while the solvent quantity category
 indicates the volume of solvent used in the formulation during a specified time frame.  The last
 category indicates the quantity of formulation solvent that is recycled on-site.  Table 3-3 shows
 cleaning operations subdivided  by the four process categories.   Each sub-table describes the
 cleaning method, frequency, solvent, and waste streams generated/employed by the individual
 companies.  This table is further subdivided according to equipment  component  Table 3-4
 summarizes the pollution prevention efforts undertaken by each of the questionnaire respondents.
 It was difficult to  obtain every category of data from every respondent because of varying
policies.
CH-93-100
3-4

-------
TABLE 3-2. PROCESS PROFILE
Process/
Company
Capacity
Coating
Technology
Coating
Method
Resin Type
Percent
Resin
Saturation
Plant A
Plant C
Plant I
1
2





Solvent
Water
2 part
corrosion
inhibitor
Solvent

Water
Water
Metering bar
Dip/squeeze

Knife/blade
Dip/squeeze
Protein latex
Methyl-
styrene and
oil

Styrene-
butadiene
Styrene-
butadiene
5-20
20-100



Carrier
Type

Solvent
or
Water
Solvent

Water
Water
Solvent

IPA
MEK
Heptane

None
None
Percent
Solvent

3-5




Solvent
Quantity






Percent
Solvent
Recycled


0

100
100
Release
Plant A
1
2
3
4
70 million yd2





Water
Solvent,
2-part
Solvent,
2-part
Solvent,
2-part,
water

Metering bar
Metering bar
Metering bar
Metering bar


Vinyl
corrosion
inhibitor
Vinyl
corrosion
inhibitor
Vinyl
corrosion
inhibitor












Toluene,
Heptane
MEK,
IPA





0-97




600 gal/wk




0
          (Continued)

-------
TABLE 3-2. PROCESS PROFILE (Continued)
Process/
Company
Plant D
2
1
Plant F
3 lines

Plant I
1
2
3
Plant!
Adhesive
Plant A
2 lines
Plant B
Plant D
2 lines
(1 can
convert
toH2O
2 lines
1 line
1 line
Capacity









200 to 300
million yd2
Coating
Technology

Silicone
Water
Solvent or
water


Water
Water
Water
Solvent,
2-part
Coating
Method



Knife/blade


Knife/blade
Applicator roll
Knife
Gravure
Resin Type



Nitrile
butadiene and
silicone

Vinyl acetate
Latex
Latex
Silicone

12 million yd2








Water
Solvent

Solvent


Water
Water
Hot melt
Metering bar
Extrusion die

Metering bar


Reverse roll
Reverse roll
Metering bar
Latex
Acrylics

Starch base


Acrylics
Starch base
Plastic resin
Percent
Resin









2-100
Carrier
Type






Water
Water
Water
Solvent

30-60
25-30




100
100
100
Water
Solvent







Solvent






None
None
None
Toluene,
Xylene,
Heptane
Percent
Solvent









50-98


Toluene
MEK

Toluene


Water
Water




50-75





Solvent
Quantity









4200gal/yr
Percent
Solvent
Recycled



90-96


N/A
N/A
N/A
0-90


15,000
gal/yr

2-3 thous
gal/yr






0

50





                (Continued)

-------
TABLE 3-2. PROCESS PROFILE (Continued)
Process/
Company
Plant D (con't)
1 line

1 line
Plant E
8 lines
1 line
4 lines

Plant G
1
2
3
4
Capacity




136 million
yd2


49.8 million
yd2




Coating
Technology

Wax coaler

Hot melt

Solvent
Water
Solvent or
water

Solvent or
water
Solvent or
water
Hot melt
Solvent or
water
Coating
Method





Knife, rev. roll,
gravure
3 reverse roll
Knife, rev. roll,
gravure

Knife/blade
Reverse roll
Hot melt
Knife/blade
Resin Type

Wax
petroleum


Acrylic
rubber,
styrene-
butadiene,
nitrile-
butadiene


Acrylic,
methane and
others
Acrylic,
methane and
others
Nitrile-
butadiene
Acrylic,
methane and
others
Percent
Resin





35-60
avg. »
40


15-65
15-65
100
15-65
Carrier
Type





Solvent
Water
Solvent
or water

Solvent,
water or
mixed
Solvent,
water or
mixed

Solvent,
water or
mixed
Solvent





Toluene,
elhylacetate,
hepane,
hexane, IPA,
xylene

Toluene,
MEK
Acetone,
ethylacetate,
Heptane,
hexane
N/A
Ethanol
Percent
Solvent





40-65
avg. = 60


35-85
35-85

35-85
Solvent
Quantity





5,417
gal/mo

825 gal/mo




Percent
Solvent
Recycled





20 reuse
or recycle


0
0

0
               (Continued)

-------
                                   TABLE 3-2. PROCESS PROFILE (Continued)
Process/
Company
Plant H
Plant I
4 lines
Plant J
2 lines
Capacity
5001bs/hr

200 to 300
million yd2
Coating
Technology
Solvent

Solvent or
water
Surface Web Coating
Plant B
Plant C


Solvent
Solvent
Coating
Method
Knife
Reverse roll
Reverse roll,
gravure,
metering bar

Metering bar
Metering bar
Resin Type
Acrylic
Nat synthetic
rubber
Styrene-
butadiene
Nitrile-
butadiene
acrylic

Acrylics,
cellulose,
esters
Acrylics,
cellulose,
esters
Percent
Resin
25-45

30-60

15-30
20-35
Carrier
Type
Solvent

Solvent
or water

Solvent
Solvent
Solvent
Ethylacelate
toluene
Toluene
Toluene,
Heptane
Percent
Solvent
55-75
40, 55-57
40-70
Solvent
Quantity


1320 gal/yr
Percent
Solvent
Recycled
0

0-90

Toluene,
MEK,
Alcohol
Toluene,
MEK,
Alcohol




0
90
X>

-------
        TABLE 3-3a. SATURATION PROCESS EQUIPMENT CLEANING
Company/Product
Rollers
Troughs
Dams
Floors
Mixing
Vessels
Method
Rant A
Plant C
Plant I
Scrub brush,
wipe, spray
Wipe
Wipe
Scrub brush,
wipe, spray
Dip
Wipe
Frequency
Plant A
Plant C
Plant I
Product
change
Daily and
product
change
I/week
Product
change
Daily and
product
change
I/week
Scrub brush,
wipe, spray

Wipe
Scrub brush,
wipe, spray

Wipe
Scrub brush,
wipe, spray
Bath
Wipe

Product
change
Daily and
product
change
I/week
Product
change
Daily and
product
change
I/week
Product
change
Daily and
product
change
I/week
Solvent
Plant A
Plant C
Plant I
Water
Heptane,
5 gal/event
Toluene
Water
Heptane,
5 gal/event
Toluene
Water
Heptane,
5 gal/event
Toluene
Water
Heptane,
S gal/event
Toluene
Water
Heptane,
5 gal/event
Toluene
Waste Type
Plant A
Plant I
Water
SOgal/wk
water
Rags
Water
SOgal/wk
water
Rags
Water
SOgal/wk
water
Rags
Water
SOgal/wk
water
Rags
Water
SOgal/wk
water
Rags
CH-93-100
                               3-9

-------
          TABLE 3-3b. RELEASE PROCESS EQUIPMENT CLEANING
I
Company/
Product
Rollers
Troughs
Dams
Floors
Mixing
Vessels
Method
Plant A
Plant D
Silicone
Waterbased
emulsion
Plant F
Plant J
Plant I
Putty knife,
scrub brush,
wipe, spray
Solvent run
through
process
Wipe
Wipe, scrub
brush, putty
knife
Wq>e,dip,
bath, scrub
brush
Wipe
Putty knife,
scrub brush,
wipe, spray
Solvent run
through
process
Wipe
Wq«, scrub
brush, putty
knife
Wipe, dip,
bam, scrub
brush
Wipe
Putty knife,
scrub brush,
wipe, spray
Solvent run
through
process
Wipe
Wipe, scrub
brush, putty
knife
Wipe, dip,
bath, scrub
brush
Wipe
Putty knife,
scrub brush,
wipe, spray
Solvent run
through
process
Wipe
Wipe
Wipe, dip,
bath, scrub
brush
Wipe
Putty knife,
scrub brush,
wipe, spray
Solvent run
through
process
Wipe
Run Dry
Wipe, dip,
bath, scrub
brush
Wipe
Frequency
Plant A
Plant D
Silicone and
Waterbased
emulsion
Plant F
Plant I
Plant J
Product
change
Product
change and
weekly
Product Change
Product
change
Product
change and
upset
conditions
Product
change
Product
change and
weekly
Product Change
Product
change
Product
change and
upset
conditions
Product
change
Product
change and
weekly
Product Change
Product
change
Product
change and
upset
conditions
Product
change
Weekly
Daily
Product
change
Product
change and
upset
conditions
Product
change
Product
change and
weekly
When empty
or product
change
Product
change
Product
change and
upset
conditions
                               (Continued)
CH-93-100
3-10

-------
     TABLE 3-3b. RELEASE PROCESS EQUIPMENT CLEANING (Continued)
Company/
Product
Rollers
Troughs
Dams
Floors
Mixing
Vessek
Solvent
Plant A
Plant D
Silicone and
Waterbased
Emulsion
Plant F
Plant I
Plant J
Toluene
Citrus based
mineral spirits
(Previously
TCA)
MEK
Toluene
Toluene and
TCA
Toluene
Citrus based
mineral spirits
(Previously
TCA)
MEK
Toluene
Toluene and
TCA
Toluene
Citrus based
mineral spirits
(Previously
TCA)
MEK
Toluene
Toluene and
TCA
Toluene
Citrus based
mineral spirits
(Previously
TCA)
MEK
Toluene
Toluene and
TCA
Toluene
Citrus based
mineral spirits
(Previously
TCA)
MEK
Toluene
Toluene and
TCA
Waste Type
Plant A
Plant D
Silicone
Waterbased
emulsion
Plant F
Plant I
Solvent,
600/gaVwk
Water.
3SOgal/wk
Spent cleaner
Rags
Rags
Rags

Spent cleaner
Rags
Rags


Spent cleaner
Rags
Rags


Spent cleaner
Rags
Rags


Spent cleaner
Rags
Rags

CH-93-100
                               3-11

-------
             TABLE 3-3c. ADHESIVE PROCESS EQUIPMENT CLEANING
1
Company/Product
Rollers
Troughs
Dams
Floors
Miring Vessels
Method
Plant A
PlantB
Plant D
Plant E
Plant G
Plant H
Plant I
Plant J
Putty knife
Wipe
WqK/scrape
Wipe
Wipe, dip, and
bath
Wipe
Run dry/putty
knife/wipe
Wipe, dip,
bath, scrub brush,
spray
Putty knife
Dip
Wipe/scrape
Wipe
Dip, bath, and
putty knife

Run dry/putty
knife/wipe
Wipe, dip,
bath, scrub
brush, spray


Wipe/scrape
Soak
Wipe, bath, and
putty knife
Wipe
Run dry/putty
knife/wipe
Wipe, dip,
bath, scrub brush,
spray
Scraper

Wipe/scrape
Blades are
soaked

Wipe
Run dry/putty
knife/wipe
Wq», dip,
bath, scrub
brush, spray
Putty knife
Dip
Wipe/scrape


Spray
Run dry/putty
knife/wipe
Wipe, dip, bath,
scrub brush,
spray
Frequency
Plant A
PlantB
Plant E
Plant G
Plant H
;
3
Plant I
| Plant J
Product change
Daily
1-2/day
Product change
1/mo
I/day
1/wk
Product change
Product change,
upset conditions,
continual
Product change
and every 1-2
weeks
Daily
1-2/day
Product change

Product change
Product change,
upset
conditions,
continual


1-2/day
Product change
I/day
3/day
9/day
Product change
Product change,
upset conditions,
continual



Daily
2/yr
2/yr
2/yr


Product change
Daily


1/yr
1/wk
I/day


Solvent
Plant A
Plant B
Water
Toluene,
15,000 gal/yr
Water
Toluene,
15,000 gal/yr
Water
Toluene,
15,000 gal/yr
Water
Toluene,
15,000 gal/yr
Water
Toluene,
15.000 gal/yr
                                  (Continued)
CH-93-100
3-12

-------
       TABLE 3-3c. ADHESIVE PROCESS EQUIPMENT CLEANING (Continued)
Company/Product
Plant C
Acrylics,
plastic resin
Starch
Solvent
Hot melt
Plant E
Plant G
Plant H
Plant I
Plant!
Rollers
Mono
methyl butyl
ether
Hot water
Toluene
Citrus based
cleaner
(90%VOC
content)
Toluene,
MEK,
Ethylacetate
MEK,
xykne
PM Acetate™
(25%),
Cvclohexane
(25%),
API 100
Aromatic™
(50%)
Toluene
Toluene,
TCA
Troughs
Mono
methyl butyl
ether
Hot water
Toluene
Citrus based
cleaner
(90% VOC
content)
Toluene,
MEK,
Ethylacetate
MEK,
xylene
PM Acetate™
(25%),
Cyclohexane
(25%),
API 100
Aromatic™
(50%)
Toluene
Toluene,
TCA
Dams
Mono
methyl butyl
ether
Hot water
Toluene
Citrus based
cleaner
(90% VOC
content)
Toluene,
MEK,
Ethylacetate
MEK,
xykne
PM Acetate™
(25%),
Cyclohexane
(25%),
API 100
Aromatic™
(50%)
Toluene
Toluene,
TCA
Floors
Mono
methyl butyl
ether
Hot water
Toluene
Citrus based
cleaner
(90% VOC
content)
Toluene,
MEK.
Ethylacetate
MEK,
xylene
PM Acetate™
(25%),
Cyclohexane
(25%),
API 100
Aromatic™
(50%)
Toluene
Toluene,
TCA
Mixing Vessels
Mono
methyl butyl
ether
Hot water
Toluene
Citrus based
cleaner
(90% VOC
content)
Toluene,
MEK,
Ethylacetate
MEK,
xylene
PM Acetate™
(25%).
Cyclohexane
(25%).
APIIOO^
Aromatic™
(50%)
Toluene
Toluene.
TCA
Waste Type
Plant A
Plant B
Plant D
Plant E
Plant G
350 gal
water/wk
Rags
Rags
Rags
Fugitives,
rags.
cardboard tray
liners
350 gal
water/wk
Rags
Rags
Rags
Fugitives,
rags,
cardboard tray
liners
350 gal
water/wk
Rags
Rags
Rags
Fugitives,
rags,
cardboard tray
liners
350 gal
water/wk
Rags
Rags
Rags
Fugitives,
rags.
cardboard tray
liners
350 gal
water/wk
Rags
Rags
Rags
Fugitives,
rags.
cardboard tray
liners
                                 (Continued)
CH-9MOO
                                  3-13

-------
        TABLE 3-3c. ADHESIVE PROCESS EQUIPMENT CLEANING (Continued)
Company/Product
Plant H
1 &2
3
Plant I
Plant J
Rollers

lOOgal/yr
1540 gal/yr
Wastepaper
and salvage
ends
toluene wash,
150 gal/mo
TCA,
200 gal/mo
Troughs

lOOgal/yr
1540 gal/yr
Wastepaper
and salvage
ends
toluene wash,
150 gal/mo
TCA,
200 gal/mo
Dams

100 gal/yr
1540gal/yr
Wastepaper
and salvage
ends
toluene wash,
150 gal/mo
TCA,
200 gal/mo
Floors

lOOgal/yr
1540 gal/yr
Wastepaper
and salvage
ends
toluene wash,
ISOgalAno
TCA,
200 gal/mo
Mixing Vessels

lOOgal/yr
1540 gal/yr
Wastepaper
and salvage
ends
toluene wash,
150 gal/mo
TCA,
200 gal/mo
             TABLE 3-3
-------
TABLE 3-4. GENERAL POLLUTION PREVENTION RESEARCH
Company
Plant A
PlantB
Plant C
Plant D
Plant E
Plant F
Plant G
WB'
Y/N
Y
N
N
Y
Y
Y
Y
Years WB§
in Use
27yrs


58yrs
15-20 yrs
5yrs
10 yrs
Level of
Research
Minimal
Minimal
Moderate
Extensive
Extensive
Moderate
to
Extensive
Minimal
Limitations
High cost
Poor curing lusters
Product specifications
Product specifications
High cost,
Waterbased coatings unable to
provide required tack
Tack
Waterbased coatings unable to
provide required tack
Waterbased cleaners do not
remove adhesives adequately
from rollers
Waterbased coatings unable to
provide required tack
Low
Solvent
Research
Moderate
Minimal
None
Moderate

Moderate
to
Extensive
Minimal
General Pollution Prevention Efforts
Description
Higher solids adhesives; Investigated
distillation
Scheduling product runs
Reuse cleaning solvent

Trying mineral spirit/
terpene mix
Run jobs together;
Dilute toluene drip bottle with nontoxic
solvent;
Distillation of waste solvent
Scans technical literature
Designing process line to accept UV
curing equipment in the future;
Operator training;
Run similar adhesive jobs together
Plant H
Waterbascd
PSAs
UV-Curable
Coatings
Y
N
lyr

High
Moderate
Poor physical properties
High cost.
Poor physical properties




Research Impacts
on Cleaning
•



On-silc water
treatment
Non VOC products
are not effective




                     (Continued)

-------
                         TABLE 3-4. GENERAL POLLUTION PREVENTION RESEARCH (continued)
Company
Plant I
Plant J
WB«
Y/N
Y
Y
Yean WB*
in Use
20f yrs
10f yra
Level of
Research
Extensive
Extensive
Limitations
High cost
Slower line speeds
Stow line speeds
Slow drying time
Low
Solvent
Research
Minimal
None
General Pollution Prevention Efforts
Description
Backsizing line(s) use cellophane-like
plastic as roller covers
Replacement of all solvent-based
products by 1994
Research Impacts
on Cleaning
Mineral spirits don't
clean effectively;
Solvent recycling.
Investigating non-
VOC cleaning
products
 *WB - Waterbased coatings (saturants, release coats, and/or adhesives)
O\

-------
 3.4.1 Saturation Processes

      Only three companies manufacture products requiring saturation process lines.  Plant A
 process lines may operate with solvent, water, or two-component reactives. Plant C operates with
 solvent-based materials.  Plant I uses waterbased saturants exclusively.  Coating methods used
 on the saturation process lines  include  blade, dip and squeeze, and metering rod.  Latex and
 styrene-based resins are formulated with isopropyl alcohol (IPA), MEK, and heptane solvent
 carriers.
      Cleaning of saturation process lines is primarily accomplished by wiping the equipment
 components with solvent-soaked rags, as indicated in Table 3-3a.  While Plant A uses waterbased
 cleaners, Plant C and Plant I use heptane and toluene, respectively. The three companies clean
 on a variety of schedules including after product changes, daily, or weekly.  Rags and spent
 cleaning solutions are the primary waste generated from equipment cleaning.

 3.4.2 Release Backing Processes

      Due to confidentiality concerns of some respondents, the information presented in Tables
 3-2 and 3-3b is not complete. Five of the nine responding companies operate 13 release backing
 process lines.   As the tables indicate, waterbased formulations are used extensively in  release
 backings. Plant F's process lines may be run either with water- or solvent-based release coatings.
 Plant I uses waterbased emulsions exclusively. Plant A and Plant J use a mixture of solvent and
 two-part reactive coatings.  Vinyl- and silicone-based resins are common in release backing
 formulations.  Plant F and Plant J recycle at least 90 percent of the solvent
      As indicated in Table 3-3b, equipment  cleaning methods employed for release backing
process lines include preliminary residue scraping followed by wiping the equipment components
 with solvent-soaked rags. Almost exclusively, the respondents clean only after product changes
or on a weekly basis. Toluene is by far the most common cleaning solvent, followed by MEK
and 1,1,1-trichloroethane (TCA).  One  company uses citrus based materials to clean silicone
release backing lines. Rags and  spent solvent are the primary wastes generated from the cleaning
of equipment
CH-93-100                                   3-17

-------
  3.4.3 Adhesive Coating Processes

       As indicated in Table 3-2,  33 adhesive coating lines are operated by the companies
  receiving questionnaires.  Only one facility does not contain an adhesive application station.
  Facility adhesive-coating capacities range from 12 million to 300 million square yards per year.
  A diverse mixture of coating application methods and equipment was represented, including
  reverse roll, gravure, knife-over-roll, metering rod, hot melt, and extrusion die. While most of
  the facilities operate lines  dedicated to the coating  of either solvent-based or waterbased
  adhesives, two companies (i.e., Plant G and Plant J) are able to use either solvent- or waterbased
  adhesives on the same coating line.
       A variety of coating formulation resins (e.g., acrylic, natural and synthetic rubber, nitrile,
  styrene butadiene, urethane, and starch)  were identified by industry respondents.  Although
  several resin types were reported, this variety does not appear to impact the coating method or
  technology employed for the process.
       Commonly used solvents include toluene, ethyl acetate, MEK, heptane, and hexane, with
 toluene being the most commonly used vehicle solvent in  adhesive  formulations among
 questionnaire respondents. Cleaning with  water is possible on water- and starch-based adhesive
 lines.   Solvent vehicles used did not depend on the types of resins in the formulations.  The
 solvent content in the adhesives formulations ranged from 35 to 85 percent
      Although the questionnaire recipients employ a variety of processes, the reported cleaning
 of all  adhesive-coating process equipment is similar, as indicated in Table 3-3c.   Again, the
 preferred cleaning method is wiping the equipment with solvent-soaked rags.  A putty knife or
 scraper is often used on difficult-to-clean areas to loosen dried coating materials.  No trends in
 cleaning frequency were  identified among the companies  or equipment components.  Daily
 cleaning or cleaning after a product change are common.  The primary wastes generated during
 cleaning are solvent soaked rags and waste solvent

3.4.4 Other Processes

     As  shown in Tables 3-2 and 3-3d, the  only other coating  process  identified by  the
questionnaire respondents is surface web  coating (Le., printing  and drafting and reproduction

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 films) at Plant B and Plant C.  Acrylic, cellulose- or ester-based resin formulations formulated
 with toluene, MEK, and alcohol are applied by metering rods.  Plant C recycles approximately
 90 percent of their solvent  Equipment cleaning techniques used by Plant B and Plant C on then-
 web coating lines do not differ from those described earlier.

 3.4.5 General Pollution  Prevention Industry Trends

      Some of  the  equipment cleaning  pollution prevention techniques  identified by the
 questionnaire  recipients include job scheduling, operator awareness  training,  and equipment
 retrofits to accommodate both water or UV-curable coatings as indicated in Table 3-4. Several
 companies have taken steps to reduce the amount of solvent used to clean equipment by
 consecutively  scheduling production runs using adhesives or coatings with similar formulations.
 While many companies dedicate equipment lines to specific products, the majority of companies
 do not dedicate products to certain process lines.  Water- and solvent-based formulations are
 frequently dedicated to particular process lines. Very few companies coat both water and solvent
 formulations on the  same  process lines.   Product specifications generally mandate whether
 waterbased formulations are applicable to a particular job. Certain coating properties are possible
 with waterbased coatings, while others are not
      Other solvent reduction techniques include dilution  of solvents with non-toxic cleaning
 compounds, and use of roller covers, such as cellophane-like materials or teflon coatings which
 prevent the coating from  adhering to the roller.
     Although there is much emphasis on reducing cleaning  solvent consumption and waste
 generation, most facilities still give then- operators free access to cleaning solvents. Safety cans,
filled with solvent, are often located near the application equipment Large solvent storage drums
 (i.e., 55 gallons) are located in a central storage area with  no monitoring or access restrictions.
Additionally, few companies take  advantage of waste solvent recycling.
     Two waste reduction methods identified through industry questionnaires, that do not directly
involve equipment cleaning involve equipment retrofit  opportunities.   One company  is
investigating reducing solvent consumption by designing new process lines  and retrofitting
current lines to accept UV  curing equipment retrofits.  Another potential retrofit of equipment
involves waterbased materials.  The general level of waterbased coatings research conducted by

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  facilities  in the questionnaire is "moderate."   Many of the  companies conduct research  or
  adhesive  formulation in on-site  research and development laboratories.  Other facilities have
  reported that they would consider using waterbased formulations if a coating supplier would
  produce a "reliable" material.  Plants A, E, I, and J have all used waterbased coatings in some
  coating applications (e.g., saturants and release coats) for at least twenty years. These companies
  cite the reduced ability to meet customer product specifications, lack of adhesiveness and luster,
  and high cost as the primary drawbacks of waterbased coatings.  Some of the same complaints
  were noted for waterbased cleaners. According to questionnaire respondents, low-VOC or non-
  VOC cleaning products do not effectively clean the equipment

  3.4.6 Conclusions

       In conclusion, equipment cleaning techniques for solvent-based coating formulations do not
  seem to be dependent upon the type of process or product. Rather, the same cleaning materials
  and methods appear to be used across the wide range of products and processes reported by the
 questionnaire recipients. One universal waste reduction method would be limiting operator access
 to solvent storage areas, however, increased recycling and recovery efforts will also provide
 reduced solvent waste generation benefits.  Non-stick roller covers, protective wrappings on other
 equipment components, and regulated solvent spray or drip systems may also offer effective
 alternatives to current cleaning techniques.

 3.5   REFERENCES
 1.    U.S. Environmental  Protection Agency, Office of Toxic Substances,  Toxic Release
      Inventory System, July 1992.
 2.    Gale Research, Inc.  Ward's Business Directory of US. Private and Public Companies,
      Volume5.  Detroit, MI.  1992.
 3.    Dun &  BradstreeL   Million Dollar Directory:  America's Leading  Public & Private
      Companies.  Parsippany, NJ.  1992.
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  4.    "Pressure Sensitive Tape and Label Industry," Air Toxics & VOCs, Chapter IV. McDvaine
       Co.  1991.


  5.    North Carolina Manufacturing Firms:  1989-90 Directory. Prepared by North Carolina
       Department of Commerce. Raleigh, NC  1989.
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                                    CHAPTER 4
                    POLLUTION PREVENTION ALTERNATIVES

 4.1    GENERAL

       This chapter provides an overview of the pollution prevention alternatives for the coated
 and laminated substrate manufacturing industry. The chapter is divided into eight sections: (1)
 General, (2) Cleanup Avoidance, (3)  Best Practices, (4) Recycling of Solvents and  Cleaning
 Materials,  (5) Alternative Cleaning Materials, (6) Equipment Modifications, (7) Alternative
 Cleaning Technologies, and (8) Waterbased Adhesives. The cleanup avoidance section addresses
 job scheduling, and running the equipment dry. The best practices section discusses the impacts
 of best operating practices on the reduction of emissions associated with equipment  cleaning.
 The recycling section focuses on the benefits associated with recycling.  The alternative cleaning
 materials section addresses the use of mineral spirits, citrus based cleaners, and di-basic esters
 in equipment cleaning. The equipment modifications section discusses changes that can be made
 to existing equipment to reduce waste generation.  Alterative cleaning technologies focuses on
 the use of ultrasonic cleaning and its impact on equipment cleaning. The final section  discusses
 the impact of converting from solvent-based adhesives to waterbased  adhesives on equipment
 cleaning.
       CLEANUP AVOIDANCE
42.1  Job Scheduling/Production Campaigning

       Efficient production scheduling can be a very effective way to reduce the need for
equipment cleaning in any industry.  In job scheduling, similar products are run together.  For
the coated and laminated substrate industry, products with similar coatings would be run in
sequence. Proper scheduling will reduce the need to clean reservoirs, application rollers, and
other pieces of equipment that require large amounts of cleaning solvent. Job scheduling requires
prior planning with production needs balanced against reduced cleaning.1


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        Job  scheduling can  cause  some cross-contamination between batches  of adhesives.
  However, this problem is often solved with the use of makeready substrate.  Makercady substrate
  involves the disposal of the cross-contaminated end of one run and the beginning of the
  subsequent run of substrate.

  4.22  Run Dry

        Running the  coating line dry is an  operating technique, occurring  at the end of a
  production run, that involves adding only enough coating to the application trough to coat the
  length of the remaining web.   This allows the substrate web  and the coating  to end at
  approximately the same time. In some facilities, the excess coating, following a run dry step,
  is drained from the troughs and coating lines and put back into storage drums for future use.
  Both of these methods require considerable operator planning and attention.2

 4.3    BEST PRACTICES

 4 J.I Storage of Cleaning Solvents

        Many facilities store  cleaning solvents close to the production areas to  provide easy
 worker access. Most facilities have small containers (e.g., 3 to 5 gallon safety cans) at or near
 the production machinery, larger containers in the production area for exchange of solvents, and
 a storage area for delivery and pickup of the solvent barrels or tanks.  Occupational Safety and
 Health  Act (OSHA)  regulations provide guidance on storage and movement of drums and
 containers within a facility. Restricting operator access to these solvents is discussed in the next
 section.
      Use and Accessibility of Cleaning Materials
       Coated and  laminated substrate facilities typically do not restrict operator access to
cleaning solvents. Consequently, in many cases, operators dispense more cleaning material than
actually needed to achieve the desired level of cleaning.

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       Additionally, if an operator has a choice of cleaning materials, the material with the
 greatest solvency and cutting  power (and consequently the highest VOC content) is often
 selected.  Although the management may provide and encourage the use of alternative cleaners,
 this use may not be enforced.

 4.3.3  Mechanical Pre-Cleaning

       Dry cleaning techniques can be used to remove coating material that has adhered to the
 sides of mix tanks, coating application heads, application rollers, troughs, dams, and equipment
 housings. These techniques typically consist of using fiber or metal brushes, squeegees, or putty
 knife-type scrapers to mechanically remove excess coating prior to wet cleaning processes.
       An alternative to full solvent wiping may consist of an initial dry scraping, followed by
 a solvent wipe, followed by a second mechanical scraping step.  In this case, most of the coating
 is removed prior to any wet cleaning. The solvent-wipe step serves only to loosen and break the
 bond between the coating and the equipment, not to completely dissolve and remove the coating.
 Actual coating removal is achieved by the second dry step.

 43.4  Disposal of Spent Cleaning Materials

       Waste cleaning materials include spent rags, cleaning solvents, and wash water. Solvent-
 soaked rags are typically considered solid hazardous waste and  must be shipped off-site for
disposal. One facility reported  being able to incinerate rags and filters used with Varsol  in their
boiler.  Depending upon State  regulations, this may be  an option available to many facilities.
One facility distilled TCA for use in the mixing area for solvent-based adhesives. Spent mineral
spirits were recycled by  another facility to  be used as a paint thinner for facility painting
applications. Additionally, washwater and the high pressure water used to clean large pieces of
equipment were determined to be hazardous waste at facilities using solvents to clean spills.
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  4.3.5  Centralization of Major Cleanup

        Several facilities have centralized cleaning areas for parts which can be removed from the
  machinery and cleaned.  The creation of a centralized area may allow a facility to control air
  emissions from the cleaning process by using a ventilation system to collect the solvent-saturated
  air.  The centralized cleaning area also reduces the possibility of a large spill of solvent occurring
  on the process line.
        Exterior sections of large vats may be cleaned by hand while the interior may have a mop
  bath cleaning.  Roller and other similar sized pans may be scrapped, bathed,  and hung to dry.
  Smaller parts may simply be bathed or dipped. Facilities may also have stages of cleaning. The
  parts may be dipped in a less concentrated bath or dirty cleaner as an initial first step.  Then, the
  part may move to a intermediate bath where it is bathed and wiped by hand. The third bath area
  may apply a clean solvent for a final cleaning and then drying.

 4.4    RECYCLING OF SOLVENTS AND CLEANING MATERIALS

 4.4.1  Solvent Recovery

        Some facilities recover solvent using a batch distillation  unit  A batch distillation system
 consists of four components: a spent solvent collection tank, a heated boiling chamber, a
 condenser,  and a clean solvent collection tank.  Once  an operator  has cleaned a  piece of
 equipment,  the spent solvent is  stored in a small  container which is  later sent to the solvent
 distillation system to be reclaimed.
       As the spent solvent is added to the collection tank, a filter removes the large particles.
 When the tank is full, the solvent is transferred by a pumping system to the heat chamber.  As
 the solvent is heated to a specific vaporization temperature, the low boiling point constituents are
 vaporized and collected in a condenser.  The unusable residue that collects at the bottom of the
 heat chamber is referred to as still bottoms. These still bottoms are considered hazardous waste
 and are disposed of off-site.
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       The vapors in the condenser are quickly cooled to promote optimum condensation.  The
 condensate is now nearly 100 percent solvent that is drained off and collected in containers to
 be reused.3

 4.4.2  Extension of Solvent Life/Countercurrent Rinsing

       One source identifies the need to blend additives  and/or  stabilizers into the recovered
 solvents to increase their useful life.  Some cleaning solvents (e.g., TCA and MEK), however,
 are not  considered  well suited to on site  re-stabilization as the process may be too time-
 consuming, labor intensive, and expensive for many facilities to pursue.4
       Countercurrent rinsing is another method for extending the life of cleaning solvents.
 Countercurrent  rinsing uses spent cleaning solvent  to complete  an  initial cleaning of  the
 equipment This step is  then followed by rinsing the surface with clean solvent (either recycled
 or virgin) to remove the remaining soils.5

 4.43  Cleaning Rags

       Frequently, the recycling of cleaning rags is dependent upon the chemical used.  Rags
 contaminated with solvents such as TCA, toluene, MEK, or heptane are treated as hazardous
 wastes and require proper disposal Most facilities visited allow operators to decide when a rag's
 useful life has been reached  Those  facilities using non-halogenated cleaners may be able to
 clean rags either in-house or at a commercial cleaning operation.  However, recycling cleaning
 rags may introduce lint and dirt into the coatings which can cause a quality problem, and the cost
 of cleaning the solvent-coated rags may be prohibitive.
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  4.5    ALTERNATIVE CLEANING MATERIALS

  4.5.1  Mineral Spirits

        Mineral spirits is a volatile, colorless petroleum  solvent with a petroleum odor.  A
  commonly used  mineral  spirit  derivative  is  Varsol, a branded petroleum solvent blend
  manufactured by Exxon.  A list of physical and chemical properties for Varsol is provided in
  Section 2.8.3 of this document
        In limited cases, Varsol has been found to be an effective cleaning solvent replacement
  for toluene and MEK.  Although Varsol does tend to leave a residue  on the equipment being
  cleaned, which can become a quality issue (e.g., leaving a film or leaving a tacky surface), some
  facilities indicated that the amount of residue left on the rollers was minimal and would either
  dry or be removed by the makeready substrate as it passed over the rollers.6

 4.5.2  Citrus Based Cleaners and Terpenes

        In recent years, the use of citrus based and terpene  cleaners has received some attention
 from the coated and laminated substrate manufacturing industry.   Citrus based and  terpene
 cleaners are solutions of such chemicals as d-limonene and methylpyrrolidone.  These cleaners
 are not regulated under Title HI of the dean Air Act Amendments  as hazardous air pollutants.
 In most cases, these cleaners are also exempt from Title I regulations for VOCs.7
       Some facilities have tried citrus based cleaners as  replacements for toluene and MEK.
 However, these facilities commented that the citrus based cleaners were expensive,  did not clean
 well, and produced a strong, undesirable odor. Another drawback is that the spent citrus cleaner
 may still be considered hazardous waste due to the coatings  that are being removed and therefore
 must be disposed of properly.

 4.53  Di-Basic Esters (DBEs)

       Di-basic esters are chemical combinations of the refined methyl esters of adipic, glutaric,
and succinic acids.   A typical mixture of DBE consists of 17 percent dimethyl succinate, 17
CH-93-100                                    4-6

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 percent dimethyl adipate, and 66 percent dimethyl glutaratc.8  DBE is a combustible mixture
 which may contribute to smog.  When heated it decomposes and emits an irritating odor and
 fumes.8  Because DBE is not an air toxic or a VOC and is less toxic than many currently used
 cleaning materials, it may be an effective alternative cleaner. It is reported to be effective in
 cleaning equipment used to coat products with polyurethane adhesives, however its use as a
 cleaner within the coated and laminated substrate industry is not documented.4

 4.6    EQUIPMENT MODIFICATIONS

 4.6.1  Improved Shielding

       Many facilities have modified process equipment to reduce the possibility of splashes and
 spills.  These modifications include the addition of edge guards and shields over application
 areas. By reducing the amount of coating splashed on the outside of equipment or spilled on the
 floor surrounding the equipment, the frequency of cleaning is reduced. However, the addition
 of guards and shields can limit operator access to certain areas of the equipment, making repairs
 more difficult

 4.6.2 Surface Coating

       Many facilities coat rollers with a nonstick materials such as teflon, silicone, or plasma-
 coatings.  These nonstick coatings allow the adhesive-coated substrate to pass over the roller
 without sticking or leaving adhesive on the roller, thus reducing the required cleaning frequency.
       One difficulty associated with coated rollers is durability. When the coating is nicked or
 scraped, it loses its effectiveness.  This is particularly a problem with silicone-coated rollers.
 Ceramic/plasma-coated rollers also have drawbacks: static buildup on these rollers can ignite if
 sparked and the entire line can catch fire. One solution is to avoid placing the plasma coated
rollers in series, which will prevent static buildup.9
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  4.63  Surface Wrapping

        Another technique used to avoid cleaning is the application of a surface wrapping to the
  outside of the equipment  One facility covers the coating line equipment with foil This facility
  reduced its equipment cleaning by removing the wrapping, disposing of it, and reapplying a new
  wrap.   Other facilities apply this same  principle  to the floors  surrounding the coating line
  equipment   Floors may  be covered with  off-specification substrate material which would
  otherwise be waste or with absorbent felt mats (which must be  purchased, but require fewer
  changeovers than off-specification substrates).  In any of these cases, it is important to evaluate
  the quantity of solid waste (equipment wraps or covers) generated in relation to reduced cleaning
  emissions.
        Another surface wrapping technique is the application of tetrafluoroethylene (TFE) film
  tape to rollers to prevent the coatings from sticking to the rollers. However, TFE film tape is
  one of the most expensive film tapes and its  use could be cost prohibitive.

 4.6.4   Substrate Edge Guides

        The  installation of pneumatic or electronic substrate edge guides can  also assist in
 reducing material waste and cleanup.  The guides are often placed at several locations on a
 coating line to regulate the movement of the web and to prevent the web from sliding back and
 forth along the rollers.  In keeping the web straight, the  guides also ensure that the coating is
 applied to the web without running past the edges and onto the  floor or equipment

 4.7    ULTRASONIC CLEANING

       Ultrasonic cleaning is a technology currently used to clean metal parts. It was developed
 as a possible replacement for solvent cleaning.10 Ultrasonic cleaning involves the use of sound
 waves in an aqueous solution to create tiny bubbles which implode and "scrub" the part clean.
 This method of cleaning is used in a variety of industries required to clean metal parts, including
 limited  applications  within the coated and laminated substrate industry.  The benefits of an
ultrasonic cleaning system include rapid cleaning, low  operating cost,  and  high levels of
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 cleanliness. From an environmental perspective, the use of aqueous ultrasonic cleaning solutions
 reduces the VOC emissions associated with equipment cleaning and reduces the hazardous waste
 generated by the facility.11
        Ultrasonic energy uses sound waves above the range of human hearing (generally above
 18,000 kilohertz).   The ultrasonic waves are produced by a  generator which creates  high
 frequency electrical  current and a transducer which  transforms  the  electrical current into
 mechanical waves. The vibrations are transmitted to the cleaning liquid, which then contacts the
 surfaces to be cleaned.12
        Once the waves have reached a significant  amplitude, cavitation occurs.  Cavitation is
 defined as the formation and collapse of vapor cavities in a flowing liquid.13 The result is the
 production of thousands of extremely small, high-intensity shock waves that penetrate and "clean"
 the duty part A benefit of ultrasonic cleaning is that the size of the bubbles allows cleaning the
 most intricate part without having to disassemble it12
        Several properties of the cleaning fluid can influence the effectiveness of ultrasonic
 cleaning, temperature, dissolved gas in the liquid, surface tension, viscosity, ultrasonic power,
 ultrasonic frequency, and part exposure.  Temperature has the most significant effect on
 ultrasonic cleaning.  As temperature increases for most cleaning fluids,  the cavitation intensity
 increases, providing better cleaning. However, if the liquid reaches its boiling point, cavitation
 will not occur.  Dissolved gas in the cleaning fluid decreases the cavitation intensity because the
 gas pocket provides a cushion  that will not allow the full cavitation intensity to reach the part
 to be cleaned.  Cleaning fluids with high surface tension will create higher cavitation intensity
 due to the greater energy that is released when the bubbles implode.  The higher the viscosity
 of the cleaning fluid the more energy required to cavitate.  The ultrasonic power that is used to
 generate the sound waves can become too strong and damage the parts to be cleaned. Identifying
 the sufficient amount of power is very important  Maintaining the proper ultrasonic frequency
 is also important  As the frequency  is increased, more power is needed to produce the same
 cavitation intensity.   The final variable  in the cleaning process  is pan exposure: it is very
 important for parts to be placed correctly in the bath to prevent air pockets from forming and
reducing the efficiency of the cleaning.12
       An ultrasonic cleaning system is shown in Figure 4-1. The system contains three basic
 elements: a generator, a transducer, and a tank filled with the cleaning solution. The generator
 CH-93-100                                     4-9

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9
?
8
                                                                Transducers     Cleaning solution
               Generators
                    \
                                                                                   I
Tank
                                      Figure 4-1. Ultrasonic Cleaning System.

-------
 produces the  high frequency electrical current  The transducer converts the current into
 mechanical vibrations. Some cleaning systems also include rinsing and drying stations.10 The
 capital costs of such a system range from $10,000 to $150,000, depending mainly on tank size.11
       The application  of ultrasonic cleaning to  equipment associated with the coated and
 laminated substrate manufacturing industry requires carefully selecting the cleaning solution.
 Typical cleaning solutions used in the metal parts cleaning systems have limited applicability to
 the removal of adhesives from the rollers, carriages,  application heads,  and other pieces  of
 coating equipment One facility tested over 200 different cleaning solutions before finding a
 cleaner capable of removing the wide variety of coatings.

 4.8    WATERBASED ADHESIVES

       The substitution of waterbased adhesives for solvent-based adhesives has been a subject
 of interest with the coated and laminated substrate industry due to the reduction in VOC
 emissions associated with the adhesive. Simplified equipment cleaning is another benefit of
 waterbased adhesives.  While still wet, waterbased adhesives can be cleaned with warm water
 or a soap solution. However, if the adhesive is allowed to dry, the equipment cleaning methods
 would be the same as those for a solvent-based adhesive.14

 4.9    REFERENCES
1.     Fromm, Carl H. and  Budaraju,  Srinivas,  "Reducing Equipment-Cleaning Wastes,"
       Chemical Engineering, Volume 95, Number 10, July 18, 1988.
2.     Rexham trip report See Appendix C.
3.     Davis, Darryl. Pollution Prevention Strategies in the Fiberglass Boat Building and Open
       Mold Plastics Industries, East Carolina University, 1987.
4.     Source Reduction Research  Partnership,  Metropolitan  Water  District  of Southern
       California,  Environmental  Defense  Fund.   Source  Reduction  and  Recycling of
       Halogenated Solvents in the Adhesives Industry.  1990.
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  5.     McMinn, B.W. and Marsosudiro, PJ.  Control of VOC Emissions from Ink and Paint
        Manufacturing Processes, EPA-450/3-92-013 (NTIS PB92-190230). Office of Air Quality
        Planning and Standards, Research Triangle Park, NC. April 1992.

  6.     TesaTuck trip report, See Appendix C.

  7.     Product information from Inland Technology Incorporated, Tacoma, WA.  Solvent
        Alternatives. Undated.

  8.     Sax, N. Irving and Richard J. Lewis, Dangerous Properties of Industrial Materials, Vol.
        II, New York, 1989.

  9.     3M Company trip report, See Appendix C.

  10.    "Ultrasonic Cleaning: Tiny Bubbles Do the Work", Modern Metals, Volume 44, Number
        9,   October  1988.

  11.    Barnett, K.W. and Most, CE.   Ultrasonic  Cleaning of Rotogravure Cylinders. EPA-
        450/3-89-024 (NTIS  PB89-216360).  Office of Air Quality Planning and  Standards,
        Research Triangle Park, NC. June 1989.

  12.    Fuchs, F. John, "Ultrasonic Cleaning", Metal Finishing, Volume 82, Number 1, January
        1984.

  13.    Perry, Robert H., Chilton, Cecil H., Perry's Chemical Engineers Handbook, Sixth Edition,
        McGraw-Hill Book Company, New York, NY, 1984.

 14.     Bond, Karen.  "Rubber-to-Metal Waterborne Eliminates Emissions and Odors," Adhesives
       Age, Volume  32, Number 2, February  1990.
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                                    CHAPTERS
     SUMMARY AND EVALUATION OF DEMONSTRATION OPPORTUNITIES

 5.1   GENERAL

      The objective of Phase I of the Improved Equipment Cleaning in the Coated and Laminated
 Substrate Manufacturing Industry project is to identify both potentially demonstrable pollution
 prevention technologies and criteria characteristic of a facility in which  the technologies could
 be applied. This section outlines characteristics of such potential demonstration technologies and
 sites.  The information that is presented is based on data collected through several  sources
 including literature searches, industry questionnaires, plant visits, pollution prevention  experts,
 and industry and trade association personnel.

 5.2   TECHNOLOGY SELECTION CRITERIA

      The selection and overall effectiveness of a demonstrable pollution prevention technique
 depends  on several  factors including  potential environmental impact, cost,  applicability,
 availability, and longevity.  This section  applies these  criteria to  several of  the pollution
 prevention alternatives discussed in Chapter 4.  Table 5-1 presents a summary of the potential
 demonstration technologies.

 5.2.1  Potential Environmental Impact

     "Pollution prevention is any practice which reduces die amount of any hazardous substance,
pollutant, or contaminant entering the waste stream or otherwise released to the environment
 (including fugitive emissions) prior to recycling, treatment, or disposal; and reduces the hazards
to public health and the environment associated with the release of such substances,  pollutants,
or contaminants."1 Pollution prevention includes equipment or technology modifications, process
or procedure modifications, reformulation or redesign of products, raw material substitution, and
improvements in housekeeping, maintenance,  training or inventory control. However, when
considering implementing any of these technologies, it is necessary to evaluate the potential
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TABLE 5-1. TECHNOLOGY SELECTION CRITERIA
Pollution Prevention
Alternatives
Impacted Media
Air
Water
Land
Technology Cost
Capital
Annual Operating
Applicability and Longevity
Segment
Longevity
Availability
Cleanup Avoidance
Job Scheduling/Production
Campaigning
Run Dry
+
+
+
+
•f
+
None
None
Facility Dependent
Facility Dependent
Dedicated Line
All
Immediate and Indefinite
Immediate and Indefinite
Yes
Yes
Best Practices
Solvent Storage Techniques
Cleaning Materials
Accessibility
Mechanical Pre-Cleaning
Cleanup Centralization
+
•f
+
+

+
+
+

+
-
+
Minimal
Minimal
Minimal
High
Minimal
Minimal
Minimal
High
All
All
All
All
Immediate and Indefinite
Immediate and Indefinite
Immediate and Indefinite
Immediate and Indefinite
Yes
Yes
Yes
Facility
Dependent
Recycling
Solvent Recovery
Countercurrent Rinsing
+
+
+
+
+,-
+
High
High
Moderate
Moderate
Large Mfgs
Centralized
Cleaning
Immediate and Indefinite
Immediate and Indefinite
Facility
Dependent
Facility
Dependent
Alternative Cleaning Materials
Mineral Spirits
Citrus Based Cleaners
Dibasic Esters
+
+
+
+
-
-
+
+
+
Minimal
Minimal
Minimal
Minimal
Minimal
Minimal
Facility Dependent
Facility Dependent
Facility Dependent
Facility Dependent (upon
Product Testing)
Facility Dependent (upon
Product Testing)
Facility Dependent (upon
Product Testing)
Facility
Dependent
Facility
Dependent
Facility
Dependent
                  (Continued)

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TABLE 5-1. TECHNOLOGY SELECTION CRITERIA (Continued)
Pollution Prevention
Alternatives
Impacted Media
Air
Water
Land
Technology Cost
Capital
Annual Operating
Applicability and Longevity
Segment
Longevity
Availability
Equipment Modifications
Improved Shielding
Surface Coating
Surface Wrapping
+
+
+
+
+
+
+
-
-
Moderate
Moderate
Moderate
None
Minimal
Minimal
Facility Dependent
Facility Dependent
Facility Dependent
Immediate and Indefinite
Immediate and Indefinite
Immediate and Indefinite
Facility
Dependent
Facility
Dependent
Facility
Dependent
Alternative Technologies
Ultrasonic Cleaning
+
+
+
High
Moderate
Centralized
Cleaning
Immediate and Indefinite
Facility
Dependent

-------
  environmental impacts (i.e., possible effects) on  all media (i.e., air, water, and land).   For
  example, one must evaluate the relative environmental benefits (or disadvantages) achieved by
  reducing air emissions from equipment cleaning by moving from aromatic or ketone cleaners to
  aqueous cleaners, which will result in additional  pollutant loading to the facility wastewater
  stream.
       One way to assess potential environmental impacts is through the development of a life
  cycle analysis (LCA) which looks at the product/production process from the extraction of the
  raw materials to the product's ultimate recycle or reuse. In this sense, an LCA is a "cradle-to-
  cradle" approach, rather than the Resource Conservation and Recovery Act's (RCRA's) "cradle-
  to-grave" approach.  LCAs involve project definition, data gathering, model development, result
  analysis and reporting, and result interpretation. Although an LCA for the pollution prevention
  technologies discussed in Chapter 4 is  beyond the scope  of this project,  some  general
  observations can be made.  The impacted media are presented in Table 5-1.

 B.22 Technology Cost

      The cost of  implementing  a pollution prevention technology  includes total capital
 investment and total annual operating costs.  Total capital investment includes costs required to
 purchase equipment, costs of labor and materials for installing that equipment, costs for site
 preparation  and buildings, and other costs referred  to as indirect installation costs  (e.g.,
 engineering and construction and field expenses).  If the technology is an adjustment to a current
 installation, then the costs are referred to as retrofit costs.
      Total annual costs include raw material expenses, operating labor, maintenance, utilities,
 replacement parts, waste treatment and disposal, capital recovery, and overhead.2 For the purpose
 of this report, the cost section of Table 5-1 is divided into capital and annual costs. Specific cost
 categories are listed in the appropriate cost columns.
CH-93-100                                     5-4

-------
 5.2.3  Applicability and Longevity

      Applicability refers to the range/segments of the coated and laminated substrate industry
 to which the technology applies. For example, the technology may be applicable to masking tape
 plants but not to label facilities, or the technology may be applicable to large facilities, but not
 to small, toll coating plants.  Longevity refers to the length of time required to achieve initial
 results and the length of time during which the technology will be applicable.  For example, a
 facility may implement  a technology which will achieve results within one year and will be
 appropriate for  four years  based on the  current manufacturing equipment and methodologies
 practiced at the plant   Table  5-1 identifies the industry segment (i.e., dedicated line or toll
 coating facility) for which the technology is  most applicable.  Table 5-1  also indicates the
 anticipated useful life of the technology.

 5.2.4  Availability

      Technology availability includes the ability of facilities to purchase, or otherwise acquire
 and implement,  the desired technology within a reasonable period of time (e.g., one year). One
 commonly used example of availability is that of add-on control devices such as incinerators.
 Some industry segments  that have recently been required to install incinerators are facing a six-
 month waiting time from placement of order to receipt of equipment This backlog is based on
 the ability of the equipment manufacturing firms to make and ship a desired product

53  SITE SELECTION  CRITERIA

     Selection criteria exist for potential demonstration sites as well as for pollution prevention
technologies. Facility selection criteria include industry segmentation (i.e., size of facility and
product and process  diversity), available resources, location, and timing.   This section will
identify the characteristics of facilities likely to participate as demonstration  host sites.
CH-93-100                                    5-5

-------
  5 J.I  Industry Segmentation

       As discussed in Chapter 2, industry segmentation is determined by facility size and product
  diversity. Generally, facilities within the coated and laminated substrate manufacturing industry
  operate in one of two different segments. The first segment consists of large facilities operating
  coating lines dedicated to one type of product, such as masking tape or label stock.  For example,
  one coating line at one facility produces 16 grades of filament tape. The differences between the
  grades are based on  the type of film (e.g., polyester or polypropylene), the type and number of
  nylon or rayon strands per square inch, and the  thickness of the coating applied.  The second
  industry segment consists of the batch-processor,  or those plants that manufacture comparatively
  small batches of a wide variety of products (usually with a high value-added component). This
  category includes plants that make and market their own line of products, and batch-processors
  that offer contract coating services. For example, one coating line at a batch facility may process
 short-run, wide-width products including dry photo masking agents and reproduction materials.
 Batch facilities are often small, employing less than 50 people.
      Both segments  of the coated and laminated substrate manufacturing industry use essentially
 the same  cleaning methods even though  the segments  differ substantially in  the range  of
 substrates, coatings, and application equipment used at the plants. As a review of the information
 presented in Chapter 2, the primary differences between the cleaning conducted at a dedicated
 line facility and a batch plant are frequency and degree of cleaning.  Dedicated line facilities may
 run their lines 24 hours per day, 7 days per week, and 52 weeks per year. Lines are typically
 shut down one  shift  per week for preventative maintenance and cleaning.  In contrast,  batch
 processors generally do not clean equipment on any specific schedule. Due to the relatively short
 production runs and the custom nature of the specialty products that these facilities manufacture,
 cleaning between each job or product changeover is critical
     For the reasons presented above, demonstrations should be conducted at one facility
 operating in each of the two industry segments.  The focus at the dedicated line facility  might
 include the implementation and evaluation of  a cleaning solvent substitute, improved operating
practices, and process modifications. The focus  at the batch coating facility would  be geared
toward improving the efficiency of cleaning  operations by reducing  the amount of cleaning
solution  necessary to achieve the  required  degree of cleanliness.   A  second objective at this

CH-93-100                                     5-6

-------
 facility would be  to  identify better methods of  administering the cleaning solution.   A
 demonstration within each of the industry segments will assist not only dedicated line facilities
 and batch processors, but also those facilities that have characteristics of each:

 5.3.2  Resource Availability

      In order to conduct a successful demonstration, the host facilities must be willing to commit
 company resources (e.g., time, labor, capital, and equipment) to the project  A demonstration
 team will spend approximately one week at the host site facility. Demonstration preparation will
 be approximately two days, the actual demonstration  will be completed within the remaining
 three days and training, and follow-up will require approximately one day during a separate trip.
 The demonstration and training segments are expected to occur during first shift operations, while
 preparation may include activities  during all normal operating hours  (e.g.,  three shifts,  if
 applicable). Additionally, the host facilities will be expected to spend time coordinating with the
 demonstration team.
      The host facilities will be expected to provide the technical oversight necessary to prepare
 for, conduct, and follow-up  on  the  demonstration.   The labor component  will consist  of
 production operator cooperation and oversight during on-site operations, as well as a technical
 coordinator for both on-site and off-site operations. Another critical labor component will consist
 of management commitment to the success of the demonstration. It is also assumed  that the host
 facilities will purchase and install any necessary equipment to complete the demonstration.
      Another resource component necessary to ensure success of the demonstration will be the
 willingness of the host facility to work with the federal, State, and regional branches of EPA and
 industrial trade associations to disseminate the demonstration results. Result dissemination will
include facility publicity and access  to costing figures,  raw material  (e.g., cleaning  solvent
purchase records), equipment specifications, and production and maintenance records.

533 Timing

      The preparation and demonstration phases of this project will be conducted  during June,
July, and August of 1993.
OB-9MOO                                    5-7

-------
  5.4   REFERENCES
  1.    Pollution Prevention Act of 1990, 42 U.S.C. §13101, et seq.

  2.    Vatavuk, W.M.  OAQPS Control Cost Manual, Fourth Edition, EPA-450/3-90-006 (NTIS
       PB90-169954). Office of Air Quality Planning and Standards, Research Triangle Park, NC.
       January 1990.
CH-93-100                                 5-8

-------
                          APPENDIX A

  COATED AND LAMINATED SUBSTRATE INDUSTRIES WITH ANNUAL SALES
                   GREATER THAN $1 MILLION
CH-93-100                         A-l

-------
      TABLE A-l. COATED PAPER, PACKAGING FACILITIES (SIC 2671) WITH
     	1992 ANNUAL SALES GREATER THAN $1 MILLION	
                                                                                    Saks in
                   Name                                 Address                   $ Millions
   Bemis Company Inc.
   Consolidated Papers Inc.
   Instrument Systems Corp.
   Printpack Inc.
   DataCard Corp.
   Arrow Industries Inc.
   Minnesota Mining and Manufacturing Co.,
     Medical Imaging Systems
   Cellu-Craft Inc.
   MUprint Inc.
   Shields Bag and Printing Co.
   Star Tex Corp.
   Consolidated Papers Inc., Stevens Point Div.
   Central Products Co.
   Packaging Industries Inc.
  Papercon Inc.
  Daubert Industries Inc.
  Bonar Plastics Ltd, Bonar Packaging Inc.
  PlaconCorp.
  Ideal Tape Company Inc.
  Barrows Paper Corp. Packaging Div.
  Superpac Inc.
  Adcbem Corp.
  Worthcn Industries Inc.
  Jefferson Smurfit Corp., laminating and
   Coating Co.
  Western Summit Manufacturing Corp.
  dear Lam Packaging Inc.
          Bihrite Inc^  Tape Products Div.
 625 Marquette Ave, Minneapolis MN 55402       1,128
 PO Box 8050, Wisconsin Rapids WI 54495         949
 100 Jericho Quadrangle, Jericho NY 11753         459
 PO Box 43687, Atlanta GA 30378               302*
 PO Box 9355, Minneapolis MN 55440             300
 PO Box 810489, Dallas TX 75381                185
 8124 Pacific Ave, White City OR 97503            120

 1403 4th Ave, New Hyde Park NY 11040           65
 9045 N Deerwood Dr, Milwaukee WI 53223         65
 PO Box 9848, Yakima WA 98909                  60
 PO Box 1089, Lakevflle MN 55044                 42
 PO Box 227, Stevens Point WI  54481              40*
 531 N Stiles St. Linden NJ 07036                  36
 2450 Alvarado St, San Leandro CA 94577           36
 2700 Apple Valley NE, Atlanta GA 30319           35
 1 Westbrook Corporate, Westchester JL 60154        32
 PO Box 818, Tyler TX 75710                     30
 PO Box 8246, Madison WI 53708                  30
 1400 Middlesex St, Lowell MA 01851              30
 1722 53rd St, Fort Madison IA 52627               30
 PO Box 189, Southampton PA 18966               25
 625 Main St,Westbury NY 11590                  25
 3 E Spit Brook Rd, Nashua NH 03060              24
 1228 E Tower Rd, Schaumburg IL 60173            24

9120 Juniper St, Los Angeles CA 90002             20
 1950 Pratt Blvd. Elk Grove Village IL 60007        19*
 105 Whittendale Dr. Moorestown NJ 08057         18*
                                          (continued)
CH-93-100
    A-2

-------
    TABLE A-l. COATED PAPER, PACKAGING FACILITIES (SIC 2671) WITH
                  1992 ANNUAL SALES GREATER THAN $1 MILLION (continued)
                                                                                  Sales in
                 Name                                 Address                   $ Millions
  Minnesota Mining and Manufacturing Co.,
    Packaging Systems Div.
  Release Technologies Inc.
  Flex Products Inc.
  Kleartone Inc.
  Noipak Corp.
  Tapecon Inc.
  Pioneer Paper Corp.
  Peacock Papers Inc.
  Tolas Health Care Packaging Corp.
  Zom Packaging Inc.
  Lustreprint Corp.
  SuBastion Industries Inc., Prescotech
  Foxon Packaging Corp.
  Arcon Coating Mills Inc.
  Hobar Company Inc.
  Creative Environments Inc.
PO Box 5517, Greenville SC 29606

1400 Harvester Rd, West Chicago IL 60185
2793 Northpoint Pkwy, Santa Rosa CA 95407
695 Summa Ave, Westbury NY 11590
70 Blanchard St, Newark NJ 07105
10 Latta Rd, Rochester NY 14612
50 Triangle Blvd. Carlstadt NJ 07072
273 Summer St, Boston MA 02210
114 Pheasant Run, Newtown PA 18940
1315 Hwy 34, Farmingdale NJ OT727
622 Northumberland, Buffalo NY 14215
PO Box 4362, Evansvilk IN 47711
235 W Park St, Providence RI 02901
PO Box 486, Oceanside NY 11572
PO Box 2363, South San Francisco CA 94080
33 W 54th  St, New York NY 10019
17*

16*
11*
 11
 10
  9
  9
  9
  6
  6
  6
 4*
  3
 3*
  3
 1*
* Indicates an estimated financial figure.
Source: Gale Research, Inc.  Ward's Business Directory of US. Private and Public Companies, Volume 5. Detroit,
ML 1992.
CH-93-100
                                            A-3

-------
      TABLE A-2.  COATED AND LAMINATED PAPER, NEC FACILITIES (SIC
                    2672) WITH 1992 ANNUAL SALES GREATER THAN $1
                    MILLION
               Name
                    Address
 Saks in
$ Millions
   Minnesota Mining and
     Manufacturing Co.
   Boise Cascade Corp., White Paper
     Div.
   Appleton Papers Inc.
   Nashua Corp.
   PLC Enterprises Inc.
   Mosinee Paper Corp.
   International Paper Co., Bleached
     Board Div.
   Anchor Continental Inc.
   Simpson Plainwell Paper Co.
   Avery Dennison Corp., Fasson RoD
    Div.
  American Tape Co.
  Shofbrd Mills Inc., Tape Div.
  James River Corporation of Virginia,
    Riegd Packaging Div.
  Tesa Tuck Inc.
  James River Corporation of Virginia,
    Otis Div.
  Fbrtifiber Corp.
  Fitchburg Coated Products Inc.
  Minnesota Mining and
    Manufacturing Co., Tape
    Manufacturing Div.
  Manco Inc.
  Wheeler Group Inc.
  Avery International Corp., Fasson
   Specialty Div.
  Bomarko Inc.
 3M Or, St Paul MN 55144

 PO Box 50, Boise ID 83728

 PO Box 359, Appleton WI 54912
 PO Box 2002, Nashua NH 03061
 300 Plaza Dr, Vestal NY 13850
 1244 Kronenwetter Dr, Mosinee WI 54455
 PO Box 7069, Pine Bluff AR 71611

 PO Drawer G, Columbia SC 29250
 200 Allegan St, Plainwell MI 49080
 7670 Auburn Rd, Painesvflk OH 44077

 317 Kendall Ave, Marysville MI 48040
 PO Drawer 1530. Hickory NC 28603
 Frenchtown Rd, Milford NJ 08848

 1 Le Fevre Ln, New RocheDe NY  10801
 PO Box 10, Jay ME 04239

 4489 Bandini Blvd. Los Angeles CA 90023
 PO Box 1106, Scranton PA 18510
 Hwy 71 S, Nevada MO 64772

 830 Canterbury Rd, Westlake OH 44145
PO Box 2945, Hartford CT 06104
9292 9th St, Rancho Cucamonga CA 91730

PO Box K, Plymouth IN 46563
13,021

2,610*

  775
  590
  260
  210
  160*

  110
  100*
  99*

   92
  91*
   90

   74
   73

   70
   70
  63*

   60
  53*
   50

   49
                                         (continued)
CH-93-100
          A-4

-------
    TABLE A-2.  COATED AND LAMINATED PAPER, NEC FACILITIES (SIC
                   2672) WITH 1992 ANNUAL SALES GREATER THAN $1
                   MILLION (continued)
                                                                                  Saks in
              Name                                  Address                      $ Millions
  MPI Label Systems
  Hazen Paper Co.
  James River Corporation of Virginia,
    Wyomissing Div.
  Kanzalri Specialty Papers Inc.
  Holland Manufacturing
  Phomat Reprographics Lac.
  James River Corporation of Virginia,
    Premold Div.
  Devon Tape Corp.
  Custom Tapes Inc.
  Tape Inc.
  Drug Package Inc.
  CrowellCorp.
  ADM Corp.
  TimeMed Labeling Systems Inc.
  Riverside Paper Corp.
  DRG Medical Packaging Inc.
  Temple-Inland Inc., Rexford Paper
   Company Div.
  Data Documents Inc., Label Div.
  Label Art Inc.
  M and C Specialties Co.
  Tidi Products Inc.
  Sun Process Converting Inc.
  Topflight Corp.
  Hamilton Hybar Inc.
  ExceUo Specialty Co.
PO Box 70, Sebring OH 44672
PO Box 189, Holyoke MA 01041
PO Box 742, Reading PA 19603

PO Box 2002, Ware MA 01082
IS Main St, Succasunna NJ 07876
29350 Stephenson Hwy, Madison Heights MI 48071
Box 6001, West Springfield MA 01090

1511 TonneUe Ave, North Bergen NJ 07047
7125 W Gunnison St, Harwood Heights IL 60656
PO Box 11067, Green Bay WI 54307
901 N Service Rd, O'Fallon MO 63366
PO Box 3227, Newport DE 19804
100 Lincoln Blvd. Middlesex NJ 08846
144 Tower Dr. Burr Ridge IL 6*0521
PO Box 179, Appleton WI 54911
4101 Lien Rd, Madison WI 53704
PO Box 411, Milwaukee WI 53201

3403 Dan Morton Dr, Dallas TX 75236
1 Riverside Way, Wilton NH 03086
90 James Way, Southampton PA 18966
PO Box 2150, Rialto CA 92376
505 Bonnie Ln. Elk Grove Village IL 60007
160 E 9th St, York PA 17405
4123 Carolina Ave, Richmond VA 23222
4495 Cranwood Pkwy, Cleveland OH 44128
 48
 46
 42

 40
 39
 35
 34

 28
 28
 27
26*
 25
 24
 21
 20
20*
 20

19*
 18
 18
 17
 15
15*
14*
 13
                                         (continued)
CH-93-100
          A-5

-------
     TABLE A-2.  COATED AND LAMINATED PAPER, NEC FACILITIES (SIC
                    2672) WITH 1992 ANNUAL SALES GREATER THAN $1
                    MILLION (continued)
                                                                                    Saks in
               Name                                  Address                      $ Millions
   American Cyanamid Co., Engineered
     Materials Dept
   Shamrock Scientific Systems Inc.
   Highland Supply Corp.
   Salem Label Company Inc.
   Betham Corp.
   Best Label Company Inc.
   Permalite Repromedia Corp.
   Paper Coating Co.
   Handy Wacks Corp.
  Fibre Leather Manufacturing Corp.
  Laminated Papers Inc.
  Fast Coast Finishing Co.
  International Tape Products Co.
  Graphic Arts Finishers
  Litton Industrial Automation
    Systems Inc., Identification
    Products
  East-West Label Company Inc.
  Universal Label Printers Inc.
  Avon Tape Inc.
  Salinas Valley Wax Paper Company
    Inc.
  Alfax Paper and Engineering Co.
  Dielectric Polymers Inc.
  Dora-Process Co.
  Keystone Packaging  Service
  Qoikstik Label Manufacturing Co.
  Blue Ribbon Label Corp.
 21444 Golden Triangle, Saugus CA 91350

 34 Davis Dr, Bellwood IL 60104
 1111 6th Si, Highland IL 60104
 PO Box 39, Salem OH 44460
 87 Lincoln Blvd. Middlesex NJ 08846
 13260 Moore St, Cerritos CA 90701
 230 E Alondra Blvd. Gardena CA 90248
 3536 E Medford St, Los Angeles CA 90063
 PO Box 26, Sparta MI 49345
 686 Belleville Ave, New Bedford MA 02745
 54 Winter St, Holyoke MA 01040
 Box 39. Fairview NJ 07022
 5 Lawrence St, Bloomfield NT 07003
 32 Cambridge St, Charlestown MA 02129
 6750 S Belt Circle Dr, Bedford Park IL 60638

 1000 E Hector St, Consbohocken PA 19428
 12521 McCann Dr, Santa Fe Springs CA 90670
PO Box 1423, Brockton MA 02403
PO Box 68, Salinas CA 93902

35 Washington St, Westborough MA 01581
218 Race St, Holyoke MA 01040
4000 Wiimetka Ave N, Minneapolis MN 55427
555 Warren St. Phillipsburg NJ 08865
210 Broadway. Everett MA 02149
241 Hudson St. Hackensack NJ 07601	
        (continued)
13*

13*
 12
 12
 12
 12
 10
 8*
  8
  7
 6*
 6*
  6
  5
  5

  5
  5
  5
  5

  5
  5
  4
  4
  4
  4
CH-9MOO
          A-6

-------
    TABLE A-2. COATED AND LAMINATED PAPER, NEC FAOLITDZS (SIC
                 2672) WITH 1992 ANNUAL SALES GREATER THAN $1
                 MILLION (continued)
                                                                              Sales in
             Name                                Address                    $ Millions
  Penmar Industries Inc.              1 Bates Ct, Norwalk CT 06854                          4
  Alcop Adhesive Label Co.          826 Perkins Ln, Beveriy NJ 08010                       3
  Mask-Off Company Inc.            PO Box 1 148, Monrovia CA 91017                      3
  Markel Finishing Corp.             400 Bostwick Ave, Bridgeport CT 06605                  3*
  Hurst Label Co.                  PO Box 6903, Burbank CA 91510                       3
  Thomas Tape Co.                 PO Box 207, Springfield OH 45501                      3
  JL Darling Corp.                  2212 Port Tacoma Rd, Tacoma WA 98421                 2
  Dermi-Klene Company Inc.          1901 S Bon View Ave, Ontario CA 91761                 I
  KeDer Ticket Co.                  554 36th St, Union City NJ 07087                     <1*
* Indi«tci *n ««*"«•«»< fi"»""«| figure.
Source: Gale Research, Inc.  Ward" s Business Directory cfU£. Private and Public Companies, Volume 5. Detroit,
ML 1992.
CH-93-100                                    A-7

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                          APPENDIX B

         COATED AND LAMINATED SUBSTRATE FACILmES AND
                   ASSOCIATED TRIS EMISSIONS
CH-9J-100                          B-l

-------
w
TABLE B-l.
FacUity
3M
3M, BRISTOL PLANT
3M CENTER
ADHESIVES RESEARCH INC.
ALUSUISSE FLEXIBLE PACKAGING INC.
AMERICAN NATIONAL CAN CO.
AMERICAN NATIONAL CAN CO.
AMERICAN NATIONAL CAN CO.
AMERICAN NATIONAL CAN CO.
AMERICAN NATIONAL CAN CO.
AMERICAN NATIONAL CAN CO.
AMERICAN NATIONAL CAN CO.
AMERICAN NATIONAL CAN CO.
AMERICAN NATIONAL CAN CO.
AMERICAN TAPE CO.
AMERY TECHNICAL PRODUCTS INC.
ARLON INC., FLEXIBLE TECHNOLOGIES DIV.
AVERY LABEL BASE MATERIALS
BOMARKO INC.
CELLU-CRAFT MIDWEST INC.
CELLU-CRAFT PRODUCTS CO.
CELLU-CRAFT SOUTH
CONSOLIDATED ALUMINUM CORP.
DELUXE PACKAGES
DENNISON MFG. CO.
DIXICO INC.
DIXICO INC.
DRG MEDICAL PACKAGING INC.
FASSON MERCHANT PRODUCTS DIV.
SIC 2671 - COATED PAPER,
PACKAGING

Total
Air Release MEK Release
Parent Company Name in Ibs/yr in Ibs/yr
3M
3M
3M
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
AVERY INTERNATIONAL
NA
NA
NA
NA
NA
NA
AVERY DENNISON
NA
NA
NA
AVERY DENNISON
75,875
2,280,115
84,267
92,455
91,540
384,278
321,837
299,606
142,185
118,251
86,049
20,134
9,270
1,680
3,258,683
14,390
69,000
182,380
205,000
11,179
41,857
16,488
456,249
23,084
478,317
304,995
62,126
51,250
105,832
5,200
26,250

6,100
66,476
73,402
128,574
207,355
91,450
45,455
28,261


1,680

14,390
69,000



15,436

120,612

8,819





Toluene Release
in Ibs/yr
43,600
1,900,250

37,600
1,608
292,828
186,795
68,783
53,373
72,7%
23,754
20,134
9,270

3,258,683



55,000


16,488
85,652

469,493
300.984
60.608
51,250
105,832
                                                                          (Continued)

-------
                          TABLE B-l. SIC 2671 - COATED PAPER, PACKAGING (Continued)
w


Facility
HARGRO FLEXIBLE PACKAGING
HARGRO FLEXIBLE PACKAGING CORP.
HARGRO INDUSTRIAL PKG.
INTERNATIONAL PAPER CO.
JATTE PACKAGING INC.
JAMES RIVER CORP.
JAMES RIVER CORP.
JAMES RIVER II INC.
JAMES RIVER II INC., COATED PRODUCTS DIV.
J.S.C.-SMURFIT LAMINATIONS
KLEARTONE INC.
LABELON CORP.
LEPAGE'S INC.
LITHOGRAPHIC INDUSTRIES INC.
LITHOTYPE CO.
MANVILLE FOREST PRODUCTS PLANT 20
PACQUET ONEIDA INC.
PILLSBURY GREEN GIANT FILM CONVERTING
RITRAMA DURAMARK
R. J. REYNOLDS TOBACCO CO. WHTTAKER
PARK 641
STRAUBEL PAPER CO.
TENNESSEE PRESS INC.
WESTVACO ENVELOPE DIV.
ZIMMER PAPER PRODUCTS INC.



Parent Company Name
NA
NA
NA
INTERNATIONAL PAPER
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
MANVILLE CORP.
NA
NA
NA
NA

NA
NA
NA
NA
GRAND TOTAL
Total
Air Release
in Ibs/yr
214,680
74,797
18,524
70,500
91,100
178,000
152,000
9,178
54,070
11,800
1,663
138,770
44,215
6,613
15,800
66,780
3,152
52,851
164,000
9,978

11,327
48,000
32,800
32,535
10,791,505

MEK Release
in Ibs/yr

1,909
11,410

65,400






66,060

6,613

17,240

27,107

9,465


11,000


1,124,664

Toluene Release
in Ibs/yr
198,000

7,114
13,000

42,000
152,000

26.300


5330
42,324


49,540

25,744
164,000
513


14,000
5,400
32,535
7,892,581
    Source: TRIS 1990
    NA - Not Available/Applicable

-------
           TABLE B-2. SIC 2672 - COATED AND LAMINATED PAPER, NEC
FACILITY
PARENT COMPANY NAME
   TOTAL
AIR RELEASE
 IN LBS/YR
MEK RELEASE
  IN LBS/YR
                                                                                                         TOLUENE
                                                                                                         RELEASE
                                                                                                         IN LBS/YR
     3M
     3M CENTER
     3M, CV & AP CONSUMER PRODUCTS PLANT
     3M TAPE MFG. DIV.
     ACME STEEL CO., PITTSBURG WEST PLANT
     ADCHEM CORP.
     ADCHEM INDUSTRIES INC.
     ANCHOR CONTINENTAL INC.
     APPLETON PAPERS INC.
     APPLETON PAPERS INC. HARRISBURG PLANT
     ARLON INC.
*    AVERY DENNISON BUILDING 3
     AVERY DENNISON BUILDING 7
     AVERY DENNISON FASSON FILMS DIV.
     AVERY DENNISON FASSON ROLL DIV.
     AVERY DENNISON M A PF DIV.
     AVERY DENNISON SPECIALTY TAPE DIV.
     AVERY LABEL BASE MATERIALS
     CAMVAC INTERNATIONAL INC.
     CENTRAL PRODUCTS CO.
     COMPAC  INDUSTRIES INC.
     CORONET PAPER CORP.
     DAUBERT COATED PRODUCTS INC.
     DECORA MFG., DECORA DIV.
     EASTERN FINE PAPER INC.
     ESSELTE  DYMO HIGHLAND PLANT
     FASSON MERCHANT PRODUCTS DIV.
                        3M
                        3M
                        3M
                        3M
                        ACME STEEL CO.
                        ADCHEM CORP.
                        ADCHEM INDUSTRIES INC.
                        LINCOLN GROUP
                        APPLETON PAPERS INC.
                        WIGGINS TEAPE APPLETON
                        BAIRNCO CORP.
                        AVERY DENNISON
                        AVERY DENNISON
                        AVERY DENNISON
                        AVERY DENNISON
                        AVERY DENNISON
                         AVERY DENNISON
                         AVERY INTERNATIONAL
                         BOWATER INDUSTRIES PLC.
                         ALCO STANDARD CORP.
                         COMPAC CORP.
                         NA
                         DAUBERT INDUSTRIES INC.
                         UTDLITECH INC.
                         SHELBURNE HOLDING CORP.
                         ESSELTE PENDAFLEX CORP.
                         AVERY DENNISON
                                 419,050
                                  84,267
                               20,106,008
                                2,554,780
                                     25
                                  27,150
                                   9,900
                                3,374,938
                                  45,889
                                     724
                                  44,250
                                  831,874
                                  756,300
                                   15,595
                                  690,200
                                 1,901.670
                                   9,180
                                  182,380
                                   30,406
                                       2
                                   8,364
                                   3,450
                                  334,300
                                   43,005
                                   23,158
                                  125,110
                                  105,832
                      33,000
                   11,747,612
                      70,000

                       5,600
                       1,850
                      12,161
                      71,400
                      69,000
                        495

                    1,863,000
                       3,080

                      18,422
                      12,300
                      25,339
                       2,166
                      40,175
                       9,589
                      22,250
                      16,000
                    7,469,813
                     676,000

                      18,200
                       6,050
                    3359,653
                       11,426
                      678,000
                      337,800
                       14,250
                      650,000
                       11,800
                       6,400

                       11.984

                       8364
                       3,450
                      322,000
                       15,114
                       19,935

                     122344 (a)
                                      (Continued)

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                        TABLE B-2.  SIC 2672 - COATED AND LAMINATED PAPER, NEC (Continued)
                   FACILITY
                                         PARENT COMPANY NAME
                                 TOTAL
                              AIR RELEASE
                                IN LBS/YR
         MEK RELEASE
           IN LBS/YR
TOLUENE
RELEASE
IN LBS/YR
W
u\
GRAPHIC CONTROLS CORP.
GRAPHICS TECHNOLOGY INTERNATIONAL
INC.
HOOD COATINGS INC
INTERNATIONAL PAPER CO.. MOSS POINT
MILL
IVEX COATED PRODUCTS CORP.

KANZAKI SPECIALTY PAPERS
LAMOTITE
LITHO COLOR PRINTING CORP.
LITTLE FALLS COLOR PRINT
LUDLOW CORP.
LUDLOW TECHNICAL PAPERS
MANVILLE SALES CORP.
MASK-OFF CO. INC.
MEYERCORD INTERNATIONAL INC.
MOORE BUSINESS FORMS & SYSTEMS DIV.
MORGAN ADHESIVES CO. (MACTAC)
NASHUA CORP. CPD
NASHUA CORP. LABEL DIV.
NORESIN INC.
NORESIN INC.
NORTHERN ENGRAVING CORP.
ORCHARD DECORATIVE PRODUCTS
OREGON OVERLAY DIV.
PEARL BOOKBINDING CO. INC.
GRAPHIC CONTROLS CORP.
SPECIALTY COATINGS GROUP,
INC.
NA
INTERNATIONAL PAPER

IVEX CONVERTED PRODUCTS
CORP.
KANZAKI USA INC.
REXHAM
NFC PARTNERS
SULLIVAN PAPER CO.
TYCO LABORATORIES INC.
TYCO LABORATORIES INC.
MANVILLE CORP.
NA
MEYERCORD CO.
MOORE BUSINESS FORMS INC.
BEMIS CO. INC.
NASHUA CORP.
NASHUA CORP.
NA
NA
NA
BORDEN INC.
SIMPSON INVESTMENT CO.
NA
 186,590
 450.000

  51,621
 339,303

 339,710

   9,000
1,159,704
 177,409
  24.196
 236,015
   2,350
   7,698
  24,095
   2,700
 422.695
 766,525
 301,426
1,162.500
 145,329
  41,105
  50,531
   6,373
1.119,270
    500
                                                                                               18,200
                                                                                               44.963
                                                                                              150,144
                                                                                                3,750
                                                                                                5,123
                                                                                                             151,535
                                                                                                             450,000

                                                                                                              51,621
     305,000
      51,693
      27,265
      24,196
     236,015
      4,170
      6,255
      8,450
      2,700

     759,302
     292,404
     717,000
                                                                                                              50,531
                                                                                                               5,373
                                                         (Continued)

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                          TABLE B-2. SIC 2672 - COATED AND LAMINATED PAPER, NEC (Continued)
w
FACILITY
PERMALITE REPROMEDIA CORP.
PRECISION COATINOS INC.
REICHHOLD CHEMICALS INC.
REYNOLDS METALS CO., PLANT #1
ROCK-TENN PAPERBOARD PRODUCTS
SANCAP LINER TECHNOLOGY INC.
SIMPSON PAPER CO.
STRAUBEL PAPER CO,
SULLIVAN PAPER CO.
THILMANY
W. H. BRADY COATED PRODUCTS DIV.

PARENT COMPANY NAME
NA
NA
REICHHOLD, INC.
REYNOLDS METALS CO.
ROCK TENN CO.
NA
SIMPSON INVESTMENT CO.
NA
NA
INTERNATIONAL PAPER CO.
W. H. BRADY CO.
GRAND TOTAL
TOTAL
AIR RELEASE
IN LBS/YR
113,310
776,200
489.972
39,520
160,920
64,000
25,400
11,327
45,229
1,069,100
423,050
41,972,480
MEK RELEASE
IN LBS/YR

150,000

24,950






53,350
14,435,669
TOLUENE
RELEASE
IN LBS/YR
98,307
290,000

14,570




45,229
370,000
302.300
18,044,749
      Source: TRIS 1990
      NA -  Not Available (Applicable)
      NEC - Not Elsewhere Classified
      (a) Emissions are summed from SICs 2671 and 2672

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        TABLE B-3.  MISCELLANEOUS COATED AND LAMINATED SUBSTRATE MANUFACTURING FACILITIES
      FACILITY
  PARENT COMPANY
       NAME
TOTAL AIR RELEASE
    IN LBS/YR
MEK RELEASE
  IN LBS/YR
TOLUENE RELEASE
    IN LBS/YR
      SHUFORD MILLS, HICKORY, NC
      FLEXCON, SPENCER, MA
      COATING SCIENCES, INC.,
      BLOOMFffiLD, CT
      THE OCTOBER COMPANY,
      EASTHAMPTON, MA
      TESATUCK, MIDDLETOWN, NY
      REXHAM, MATTHEWS, NC
SHUFORD MILLS, INC.
FLEXCON
COATING SCIENCES, INC.

THE OCTOBER COMPANY

TESATUCK, INC.
REXHAM INDUSTRIAL
       1,931^24
        194,492
         33,985

         18,945

        228,750
        614,515
      32,319
       3,342
     300,970
      1,931324
       132,473
        20,052

        18,945

       228,750
       299,968
     Source: 1990 TRIS
W

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                                 APPENDIX C
                               TRIP REPORTS
                     Site                    Page
                     Anchor                 C-2
                     3M                    C-21
                     TesaTuck                C-30
                     Nashua                 C-36
                     Rexham                 C-48
                     Shuford                 C-55
                     Flexcon                 C-64
CH-93-100                                C-l

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Environmental Solutions through Technology
                                                               TRC Environmental Corporation
                                                               100 Europe Drive, Suite 150
                                                               Chapel Hill, NC 27514
                                                               tr (91 9) 968-9900  Fax (91 9) 968-7557
   Date:         January 8, 1993

   Subject:      Site Visit - Anchor Continental Incorporated
                Pressure Sensitive Tape Manufacturer
                EPA Contract 68-D9-0173, Work Assignment Number 3/309
                TRC Reference No. 1637309
 From:
 To:
                Geary D. McMinn and David D. Ocamb
                TRC Environmental Corporation

                Mike Kosusko
                Organics Control Branch
                Air and Energy Engineering Research Laboratory (MD-61)
                U.S. Environmental Protection Agency
                Research Triangle Park, NC 27711
I.
         Purose
         As part of the overall effort by the U.S. Environmental Protection Agency (EPA) to identify
  areas for preventing the creation of pollution associated with manufacturing entities, EPA is currently
  reviewing the pollution prevention opportunities associated with equipment cleaning in the adhesives-
  coated and laminated paper industry. TRC Environmental Corporation (TRC) is supporting EPA in
  this effort by developing prevention strategies for laminated paper equipment cleaning under Work
  Assignment Number 3/309, EPA Contract Number 68-D9-0173.

        Anchor Continental Incorporated (Anchor), a pressure sensitive tape manufacturing facility,
  was selected for a site visit to collect information on the pollution prevention opportunities available
  for this industry segment The focus of pollution prevention efforts in this industry is on emissions
  of volatile organic compounds (VOCs) and air toxics. The purpose of  the visit to Anchor was to
  gather information on their pressure sensitive tape manufacturing processes and to identify, with input
  from the plant experts, any opportunities for preventing VOC emissions resulting from the cleaning
  of equipment  Specific objectives of the trip were to collect information necessary  to characterize
  the plant production processes, equipment cleaning requirements and practices, and cleaning solvent
  recovery and disposal methods; and to witness first-hand any pollution prevention opportunities for
 pressure sensitive tape equipment cleaning operations.

        This trip report includes four sections.   Section n identifies the location of the Anchor
 facility.  Section HI presents the individuals who participated in the site visit  Section IV includes
 the  technical information compiled during the site visit In addition, the attached Appendix presents
 facility plot plans for the various Anchor production processes.
Offices io California, Colorado, Connecticut, Illinois, Louisiana, Massachusetts, New Jersey, New York, North Carolina, Pennsylvania, Texas,
Washington, Washington, D.C., and Puerto Rico                                                   A TRC Company
...... ™ — «,™.,,^..
                                               C9
                                               •*•

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 n.    Place and Date

       Anchor Continental Incorporated
       2000 South Beltline Boulevard
       Columbia, SC 29250
       (803) 376-5468

       December 18, 1992

 IIL    Attendees

       Anchor Continental Incorporated

       Rick G. Carnell, Environmental Affairs Manager

       TRC Environmental Corporation

       David D. Ocamb, Senior Environmental Engineer
       Geary D. McMinn, Environmental Scientist

 IV.    Discussion

       The discussion began with the purpose of the visit, addressing EPA's goals for pollution
 prevention analysis for pressure sensitive tape  manufacturing, and future preventive activities.
 During this meeting the following major areas were considered:

 •      The general plant description
 •      Manufacturing and site activities  at the Columbia plant including adhesives mixing, paper
       tape manufacturing, reinforced tape manufacturing, cloth tape manufacturing,  and stencil
       products manufacturing
 •      Equipment cleaning practices
 •      General emissions information
 •      Pollution prevention opportunities specific to the Anchor facility
 •      Prevention opportunities that may be applied to the overall industry (e.g., reformulation of
       adhesives and changes in cleaning)

The meeting was followed by a tour of the production operations. Each specific topic addressed in
the meeting is discussed in detail below.

A.     Anchor History and General Plant Description

       Anchor Continental began manufacturing pressure sensitive tapes approximately sixty years
ago.  Anchor currently operates two plants, one in Covington, Ohio, and the headquarters plant in
Columbia, South Carolina. The Columbia facility operates  5 days per week, 24 hours per day, and
produces four types of pressure sensitive products:

                                           C-3

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  •      Paper Tapes
        Duct (Cloth) Tapes
        Reinforced (Film) Tapes
        Stencil Products

        Although specific product characteristics (e.g., adhesive strength or color) vary according to
  customer specifications, there are general product characteristics for each of the different product
  groups.

        Anchor manufactures several types of saturated paper tapes including masking tapes and some
  packaging tapes.  The VOC content of the coatings in these tapes (i.e., saturant, release coat, and
  adhesive), and the resulting VOC emission rate, varies viscosity and with the desired performance
  characteristics.  For instance, a product, such as  automotive tape, which must withstand elevated
  temperatures for an extended period of time tends to be manufactured with natural rubber. When
  dissolved in a solvent such as toluene, natural rubber results in a high viscosity (high solids, low
  solvent) material  Other materials (e.g., synthetic rubbers) result in low solids formulations and yield
  high VOC coating contents and high VOC emission rates.

        Duct or cloth tapes are laminates of cloth  and a polyethylene film.  While the 100 percent
 solids adhesive on such tapes contains no solvents, the release coat does contain a solvent  Solvent
 vapors from the release coat station and oven are destroyed in a catalytic oxidation unit Duct tape,
 as its name applies, is used in ducting  insulation and carpet pad splicing.

        Reinforced (film) tapes are manufactured in the same manner as paper tape except that the
 saturated paper substrate of the paper tape is replaced with a polyester film.  The film contains glass
 fiber strands which provide superior strength. Film tapes have become popular in packaging and box
 sealing, electrical, and pipe wrapping applications.

        Stencil products are manufactured using a calendered, solvent-based adhesive coating process.
 An adhesive-coated film and a rubber sheet are  laminated and wound into  a roll.  The stencil
 products are used in a variety of etching (e.g., glass) and sand blast (e.g., monument) applications.
 The solvent vapors resulting from the drying of the adhesive coat are  destroyed by catalytic
 oxidation.

       Figure A in the Appendix shows the layout of the Anchor - Columbia facility.  The tape and
 stencil products are manufactured on a  total of five process lines in either the production building,
 the rubber division building, or  the latex saturator building.   Adhesives and release coats are
 formulated in the mixing area.  The mixed adhesives and release coats are transferred to the area
 storage  vessels for use in the various tape production processes. In addition, a centralized equipment
cleaning room is located at the south end of the production building. The majority of the movable
equipment used throughout the production facility  (e.g., rollers, dip trays, and knives) is directed to
this central room for dedicated cleaning.
                                            C-4

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       As shown on the plot plan in the Appendix Figure B, the main production building contains
 three of the five facility process lines as well as other specialized processes.  Line 1 is a low VOC
 line regulated by New Source Performance Standards (NSPS). Line 2 is grandfathered from NSPS
 regulations, has fewer restrictions on the VOC content in the processing materials, and, therefore,
 can run tapes that produce higher emissions. Line 3 runs only reinforced and paper tape.  The main
 production building also houses an intermediate coating line which  saturates  raw paper with
 polyurethane to provide the paper with greater tensile strength.

       The remaining two tape process lines are located in the rubber division as shown in Appendix
 Figure C.  Duct (cloth) tape and stencil products are manufactured on dedicated process lines.  The
 rubber division contains two small scale banburys (rubber mixing units)  which are used to mix the
 rubber substrate and mill/extrude the rubber sheeting and adhesive  stocks.

       Appendix Figure D shows the layout of the saturator building. This building contains a hot-
 melt line and an intermediate coating line used to manufacture latex-saturated tape backing for paper
 tapes. In  the latex-saturation process, raw paper is saturated with latex to provide  greater tensile
 strength.  The saturating process involves passing the paper through a latex saturant bath and then
 drying the saturated paper in drying ovens. The saturated paper is then directed to other tape process
 lines for production of the desired tape product The hot-melt uses a solventless thermoplastic
 adhesive to produce specialty tapes.

 B.     Adhesive Mixing

       Adhesive mixing is a basic  manufacturing requirement for the solvent-based adhesives used
 in the tape products produced by Anchor. Anchor mixes adhesives  to meet tight tolerances dictated
 by customer specifications. Figure 1 is a flow diagram representing the Anchor process for adhesive
 mixing. As shown, adhesive mixing begins with stock preparation. Stock is prepared by blending
 natural and synthetic rubbers, hydrocarbon resins, oils, and fillers in a banbury.  The banbury output
 is then directed to mills where a sheet of adhesive stock is extruded, cut, and then palletized for
 further processing.

       The pallet sheets are then sent to the mixing department where they are loaded into mixers
 approximately 10,000 gallons in size. Toluene is added to dissolve the stock.  Heptane is also used
 with toluene for manufacturing certain stencil adhesives. The solvent is pumped into the mixers with
 additional resins, rubber (self polymerizing), and oils to complete the adhesive formulation. Table 1
presents a breakdown of me adhesive ingredients employed by Anchor.  The actual mix ratios are
considered confidential.

       Once an adhesive is formulated, the finished  material  is pumped to storage tanks in the
appropriate manufacturing building or transferred via tote vessels to specific process lines for future
use.   In order to ensure the proper adhesive quality, Anchor  uses in-line filtration.  Filter bags
separate remaining suspended solids (the natural and synthetic rubber) from the coating mixture. The
filter bags are changed once per shift for each coating line.
                                            C-5

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                 STOCK  PREPARATION  -
                     *  Banbury mix rubber/fillers
                     *  Mill bcnbury stock
                     *  Palletize stock,  send  to  mixing
                                  T
                MIXING
                     * Solvent
                     * Rubber stock
                     * Resins
                     * Oils
              T
BULK  STORAGE
   *  To coatina lines
TOTE TANKS/DRUMS
    *  Small  volume coatina
                    Figure 1.  Adhesives Mixing Flow Diagram.

                                    C-6

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                  TABLE 1. ANCHOR ADHESIVES RAW MATERIALS
               Chemical Name                             Chemical Name
  Styrene/butadiene copolymer                  Petroleum hydrocarbon resin
  Zinc dibutyl dithiocarbonate                   Heptane
  Tetrakis (methylene(3,5-Di-tert-butyl-4-         Styrene-isoprene-styrcne block copolymer
  hydroxyhydrocinnamate))
  Polyterpene resin                            Aliphatic hydrocarbon resin
  Zinc oxide                                  Zinc isopropyl xanthate
  Mineral oil                                  Natural rubber
  Polyalphamethyl styrene                      Sodium aluminum silicate
  Diphenylmethane diisocyanate                 Toluene
  Ground limestone                            Hydrated amorphous silica
  Ground silica                                Zinc dibutyl dithiocarbonate
 C.    Paper Tape Manufacturing

       A process flow diagram for paper tape manufacturing is presented  in  Figure 2.   To
 manufacture paper tape,  the raw  paper is  bought from  a vendor either  as latex saturate or
 polyurethane saturate.  The compositions of the purchased saturates are presented in Table 2.  If a
 desired color and/or bond (tie) is required, the paper is processed in an intermediate coating area
 before applying a release and adhesive coat  A tie coat improves the bond of the adhesive to  the
 paper.

       After color and/or tie coats are applied, the release coat is applied to the non-bonding surface
 of the product The composition of the release coat is presented in Table 3. The release coat is
 applied by passing the paper through a roller system containing a release coat  The release coat is
 transferred from the roller to the top side of the paper.  The roller system maintains the tension of
 the paper to ensure even coating application.  A doctor blade, a long knife-like piece of metal,
 removes any excess coating from the paper.  The removed coating returns to the coating bath for
 reuse.  The release coat is pumped from the release coat storage tanks on the process line which are
 fed from the larger storage tanks located in the mixing area.  The tape passes through multi-stage
 natural gas-fired dryers to dry the release coat

       Adhesive,  pumped  from bulk storage  tanks located in the mixing area, is applied after the
release agent  After exiting the release coat dryers, the paper passes through rollers to maintain the
tension for applying the adhesive.  A large  roller dipping into a "bath" of adhesive comes into
contact with the clean,  non-release coat, side of the papercoated paper. A doctor blade is used to
remove excess adhesive from the paper after contacting the roller.  The adhesive-coated paper then
                                           C-7

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INTERMEDIATE  COATING
  *  lie  coat
  *  Color coat
•PAPER FROM VENDOR
   * Latex saturate
   * Polyurethane
     saturate
COATINGS
   * Adhesive from
     mixing/bulk storage
   * Release  coat
                  COATING
                      * Apply release  coct
                      * Apply adhesive
                                         T
                  SLITTING
                      * lube  (core) making
                      * Slitting  (automatic  
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 	TABLE 2. ANCHOR PURCHASED SATURANTS COMPOSITION	

            Saturant Type                             Chemical Name

  Latex Saturant                      Carfooxy-modified butadiene/styrcne polymer emulsion

  Polyurethane Saturant                Toluene diisocyanate
                                     Toluene
                                     Hydrocarbon resin

                                     Polyether blend
 	TABLE 3.  ANCHOR RELEASE COAT RAW MATERIALS

               Chemical Name                             Chemical Name

  Acrylic ester copolymer                     Isopropyl alcohol

  Silicone catalyst                            Silicone solution

  Polyamide resin                            Toluene
proceeds through another set of dryers.   The paper tape is then ready  for Quality  Assurance
Inspection, slitting, roll-up, and packaging for distribution.

D.     Reinforced Tape Manufacturing

       Other types of tapes have the same basic process flow as paper tapes but are manufactured
using slightly different raw materials and substrates. The general process flow diagram for reinforced
tape manufacturing is presented in Figure 3. In general, reinforced tapes have a polyester backing
instead of saturated paper backing.  Fiberglass strands are incorporated to give superior strength
compared to paper tape. These strengtheners are tie-coated or laminated, to the polyester film. The
release coat is applied on the opposite side of the tie-coat with the adhesive being placed over the
reinforcing threads. The remaining processing activities for reinforced tape include drying, Quality
Assurance Inspection, slitting, roll-up, and packaging for distribution.

E.    Duct (Cloth") Tape Manufacturing

      Figure 4 presents  the process flow diagram for duct tape manufacturing.   Duct tape
manufacturing is similar to paper tape manufacturing except that the adhesive is calendered in a solid
form to join together to the laminate, the polyethylene film and the cloth substrate. The result is a
cloth and film web which then has the release coat applied on  the film side. No solvent is present
                                          C-9

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FIBERGLASS STRANDS
POLYESTER FILM
COATINGS
   * Adhesive from
     mixing/storage
   * Release coat mix
                                          T
                   COATING
                       *  lie—coat application to film
                       *  Apply  reinforcing threads  onto  tie—coat
                       *  Apply  release coat  opposite side
                       *  Apply  adhesive over reinforcing  threads
                   SLfTflNG
                      * Tube (core)  making
                      * Slitting (automatic 
-------
CLOTH
POLYETHYLENE FILM
                                         T
                  CALENDER/COATING
                      *  Apply  100% .solids  adhesive  to
                        cloth/film  web
                      *  Apply  release  coat to film
                                         T
                  SUTTING
                     * Tube (core)  making
                     * Slitting (automatic &  duplex)
                     * Bulk pack at slitter or  load on  peg
                        carts for packing
ADHESIVE STOCK
   * Banbury mix base
     stock
   * Mill base  stock  &
     resins

                  PACKING
                     *  Bulk  pack (bulk  & sleeves)
                     *  Inalvtducl roll wrap (film wrap)
                     *  Box
                  SHIPPING
            Figure 4.  Duct (Cloth) Tape Manufacturing Process Flow Diagram.

                                         C-ll

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  in the duct tape adhesive which is  100 percent solids. However, toluene is present in the release
  coat Anchor employs a catalytic oxidizer to destroy any toluene or other emissions generated during
  drying.

  F.     Stencil Products Manufacturing

        The process for manufacturing stencil products is different from tape manufacturing.  The
  stencil products process flow diagram is presented on Figure 5.  The process begins by blending
  rubber stock in a banbury and then milling and calendering the  banbury output to create rubber
  sheets. The sheets are placed on a conveyor for cooling. Adhesive is transferred from the mixing
  area by tote vessels.  The adhesive is applied to a release liner. This adhesive-coated release liner
  is then laminated with the rubber sheets, trimmed to proper size, and wound in rolls.  The stencil
  products are then finished in the same way as other Anchor tape products.

  G.     General Equipment Cleaning Practices

        Anchor does not perform equipment cleaning on  any specific schedule.  When a process is
  down, the equipment is  disassembled (that which can  be), moved to the  centralized equipment
  cleaning room attached  to  the main production building,  and given a toluene bath.   Process
  equipment is soaked and cleaned in one of two 100-gallon toluene vats in the cleaning room.  The
 vats  are filled with toluene as needed; the toluene is changed once per week. Toluene is pumped
 off and recycled as part of the overall adhesive mixing process.  Approximately 180 gallons are
 recycled.  Anchor estimates using mass balance that 20 gallons per week of toluene are lost as waste
 and fugitive emissions. Further discussion of the reclamation process can be found in Section H of
 this report

        Stationary equipment (e.g., rollers) that cannot be moved to the centralized cleaning room is
 cleaned in a two-step process.  First, the equipment is  wiped down with  a dry rag.  Next, it is
 cleaned with a toluene-soaked rag. Drip trays are located under the  adhesive coaters on each coating
 line.   In addition to catching excess adhesive, these trays contain toluene which is used for spot
 cleaning.  Scrapers, similar to putty knives, are dipped into toluene in the drip tray or solvent safety
 can and then used to remove dried adhesive from the process equipment rollers.

       The toluene-soaked rags and excess toluene are collected in five-gallon safety cans located
 near the machinery. The safety cans are sealed, grounded containers which hold the toluene and
 toluene rags to prevent spills and reduce emissions.  Once these cans are full, the operator is required
 to take them to  a 55-gallon drum located in the disposal area (located in the mix area). Toluene-
 contaminated rags and toluene  that cannot be reclaimed are sent off-site for disposal. Any other
 spent solvents (e.g., heptane) and waste, solvent-based coatings used in the facility are sent off-site
 for disposal.

       In the past, Anchor attempted to use Varsol, a mineral spirits solvent substitute, for general
equipment  cleaning in an attempt to reduce toluene use and resulting emissions from clean up.
However, Anchor found Varsol to be less effective than toluene for equipment cleaning.  Anchor
                                            C-12

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RELEASE LINER
RUBBER STOCK
  *  Banbury mix
  *  Mill
COATINGS
   *  Adhesive
     (tote  tanks)
                                         T
                  CALENDERING
                      * Create rubber "sheet"
                                         T
                  COATING
                      * Apply adhesive  to  reiecse liner
                                         T
                  LAMINATING
                      * Combine rubber sheet to  cohesive
                        coated  reiecse liner
                      * Trim to desired  width
                  FINISHING
                      * Rnal visual inspection
                      * Unwind  end  cut to length, wind
                        onto ceres and  box
                  SnlPPlNG
             Figure 5.  Stencil Products Manufacturing Process Flow Diagram.

                                         C-13

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  believes that Varsol is inappropriate for the production line because it leaves a film on the adhesive
  and release coat rollers which reduces the uniformity of the applied coats and subsequently prevents
  the adhesive from attaching to the tape.  Varsol is currently used to clean spills and leaks on floors
  and machinery in the packaging department It is also used for daily floor cleaning.  The Varsol-
  soaked cleaning rags (not classified as hazardous waste) are disposed of in the facility (burned in the
  plant boiler) according to Anchor's South Carolina Department of Health and Environmental Control
  (DHEC) permit  The permit prohibits burning toluene-soaked rags.

  H.    General Emissions Information

        Toluene is used as a  solvent in the mixing of the  adhesives and in cleaning the  process
  equipment Toluene is released from the centralized cleaning room as well as from the "on-the-spot"
  cleaning applications within  the facility.  These  releases  are predominantly fugitive emissions.
  Cleaning equipment  involves wiping  the excess  adhesives with a rag,  scraping the equipment
  component if necessary, and then wiping the area with a toluene-soaked rag.

        Anchor employs both  a toluene recycle/reclamation and an off-site disposal program.  The
  containers holding toluene and toluene-soaked rags are a source of fugitive emissions. After cleaning
 parts and removing sludge, the centralized cleaning room, which  houses the two 100-gallon vats,
 recycles approximately 180 gallons per week of toluene. In addition, an average of 148 gallons of
 sludge per month is sent off-site for disposal. Approximately 200 gallons per month of toluene are
 reused while  only 20 gallons per week are non-reusable.  Roughly 88 gallons of toluene per week
 from other sources are reusable. Approximately six drums per year of toluene rags  are sent off-site
 for disposal.

        Spent Varsol is sent off-site  for disposal while rags contaminated with Varsol are burned in
 the boilers.  Approximately 125 gallons of Varsol per week are generated from plant wide sources.
 Varsol  rags are burned at the rate of two drums per week. Varsol is also used to wash filter bags
 which become contaminated with adhesive on the production lines.  Filter bags are incinerated at the
 rate of  one drum per week.

 L     Pollution Prevention Opportunities

       Potential pollution prevention opportunities include: (1) replacement of all toluene cleaning
 with Varsol; (2) identification  of a cleaning solvent substitute to replace toluene; (3) elimination of
 the toluene/adhesive drip trays on the coating lines, and (4) using sealed cleaning  solvent  buckets
 for on-the-spot cleaning.

       The most effective technique for Anchor to reduce emissions would be to eliminate toluene
 as a cleaning solvent  Even though Anchor has previously replaced a large portion of the toluene
with Varsol, complete replacement of toluene by Varsol is unreasonable since Varsol has a limited
application for cleaning in  the pressure sensitive tape industry.  As mentioned earlier, Varsol can
leave a  film on the coating rollers which reduces the effectiveness  of the adhesive application.  As
such, identification of a new cleaning solvent to use in conjunction with Varsol remains the only
viable opportunity for reducing toluene usage and emissions from  equipment cleaning.  To pursue

                                           C-14

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this preventive opportunity, the cleaning solvent suppliers could be surveyed to determine if an
effective toluene replacement exists in the market place today.  One consideration in using a solvent-
substitute is subsequent disposal of the aqueous waste.

       An additional pollution prevention (and emissions reduction) opportunity available at Anchor
would be to replace the toluene/adhesive drip trays and provide the operators with sealed cleaning
solvent buckets for on-the-spot cleaning. Process operators generally use putty-like cleaning knives
to spot clean areas on calenders, mills, and coating rollers.  The operators generally have a drip tray
present where a small volume of toluene is maintained.  The putty knives are dipped into the tray
to moisten the knife prior to the on-the-spot cleaning. By using a small, sealed cleaning bucket in
place of toluene in an open drip tray, the  operators can use toluene  for spot cleaning while
simultaneously reducing fugitive emissions.

       Additional measures such as using a toluene dilution (e.g., 75 percent toluene and 25 percent
water) could have an impact on emissions from the cleaning process. Alternative technologies such
as using a mist sprayer rather than a continual toluene drip may reduce the amount of adhesive lost
in the application process and reduce  the amount of toluene needed for  clean up.   Finally, a
combination of the above techniques  may be applied to reduce the emissions of toluene from the
pressure sensitive tape industry.
                                            C-15

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APPENDIX
  C-16

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                     I---.".."." ^ : 5'='-•' J"*'"'r iV" .- .
                ..	1		     • s : a;* f »v..:: ': ~ ...
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                                                                                         PLANT UYOUT

                                                                                          |i*t  I* y •» I   «r
                                                                                          II-H.      li..l
Figure A.  Site Plan for the Anchor Continental Incorporated
               Columbia, South Carolina Facility

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                                      r
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                                                                                                                          COATING DMSION
                                                                                                                           W.  .inti  1.^
                                            Figure B. Anchor Production Building Plot Plan

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9
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                PL	I—Pv_LjV...I    KJ ... _
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Figure D. Anchor Saturator Building Plot Plan

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TRC
                                                           TRC Environmental Corporation
                                                           100 Europa Drive, Suite 150
                                                           Chapel Hill, NC 27514
Environmental Solutions through Technology                        w (919) 968-9900 Fax (919) 968-7557
  Date:         March 31, 1993

  Subject:      Site Visit - 3M Company
               Pressure Sensitive Tape Manufacturer
               EPA Contract 68-D9-0173, Work Assignment Number 3/309
               TRC Reference Number 1637309

  From:        Beth W. McMinn and Jill B. Vitas
               TRC Environmental Corporation

  To:          Mike Kosusko
               Organics Control Branch
               Air and Energy Engineering Research Laboratory (MD-61)
               U.S. Environmental Protection Agency
               Research Triangle Park, NC 27711

  I.     Purpose

        As part of the overall effort by the U.S. Environmental Protection Agency (EPA) to identify
  areas for preventing the creation of pollution associated with manufacturing entities, EPA is currently
  reviewing the pollution prevention opportunities associated with equipment cleaning in the adhesives-
  coated and laminated paper industry. TRC Environmental Corporation (TRC) is supporting EPA in
  this effort by  developing pollution  prevention  strategies for laminated paper equipment cleaning
  under Work Assignment Number 3/309, EPA Contract Number 68-D9-0173.

        The Minnesota Mining and Manufacturing Company (3M) in Bristol, Pennsylvania, a pressure
  sensitive tape  manufacturing facility,  was selected for a site visit to collect information on  the
  pollution prevention opportunities available for this industry segment The primary focus of pollution
  prevention efforts in this industry is on emissions of volatile organic compounds (VOCs) and air
  toxics.  The purpose of the  visit to 3M was to gather information on their pressure sensitive tape
  manufacturing processes and to identify, with input from the plant experts, any opportunities  for
 preventing pollution resulting from the cleaning of equipment Specific objectives of the trip were
  to collect information necessary to characterize the plant production processes, equipment cleaning
 requirements and practices, and cleaning solvent recovery and disposal methods; and to witness first-
 hand any pollution prevention opportunities for pressure sensitive tape equipment cleaning operations.

        This trip report includes four sections. Section n identifies the location of the 3M facility.
 Section in presents the individuals who participated in the site visit  Section IV  includes  the
 technical information compiled during the site visit
Offices 
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  H.     Place and Date

        3M Company
        Green Lane
        Bristol, PA 19007
        (215) 945-2800

        February 11, 1993

  EL    Attendees

        3M Company

        Belinda M. Wirth, Environmental Engineer
        Bob McKinnell,  RCRA Coordinator

        TRC Environmental Corporation

        Beth W. McMinn, Project Manager
        Jill B. Vitas, Task Leader

 IV.     Discussion

        The discussion began with TRC describing the purpose of the visit, addressing EPA's goals
 for pollution prevention analysis for pressure sensitive tape manufacturing and future preventive
 activities.  During this meeting the following areas were discussed:

       Market Profile
 •     Manufacturing Supplies
 •     Manufacturing Process Profile
 •     Equipment Cleaning Experience
 •     Emissions Reduction and  Control Experience
 •     Pollution Prevention Experience

 The  meeting was followed by a  tour of the production operations.  Each topic addressed in the
 meeting is discussed in detail below.

 A.     3M History and Market Profile

       3M Company has approximately 70 plants in the United States, 14 of which manufacture
pressure sensitive tapes and labels (i.e., operate under Standard Industrial Classification codes 2671
and 2672).  In total, the  company employs nearly 50,000 people in the United States.  3M is the
largest pressure sensitive tape manufacturer with almost 85 percent of the market share and 1991
sales of nearly $13 billion.
                                          C-22

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       The 3M Bristol facility, whose primary Standard Industrial Classification (SIC) code is 2672
 (Coated and Laminated Paper, Not Elsewhere Classified), began operation in 1948 when 3M
 Company purchased the central building and land. Since that time, 3M has expanded, adding both
 buildings and land, to reach its current 70-acre site as shown on Figure 1.  The Bristol plant is now
 operating with both a facility and employee cap.  The facility's primary product has always been
 pressure sensitive tape. The Bristol plant currently operates within 3M's Masking and Packaging
 Division and produces film and filament packaging tapes for both consumer and industrial markets.
 Nearly 90 percent  of the plant's output is sold to industrial  markets.  Additional  plants in this
 division are located in Bedford Park,  Illinois  and Greenville, South Carolina.  Approximately 40
 percent of the tapes produced at the  Bristol  facility contain  solvent-based adhesives,  while the
 remaining  60 percent contain hot melt  adhesives and typically a solvent-based release coat  In
 addition to manufacturing tapes, the Bristol plant makes fire retardant and marine caulks.

 B.    Manufacturing Supplies

       The 3M Bristol plant uses more than 200 raw materials in their manufacturing processes.
 While the majority of these compounds  are used in the caulk formulations, over 120 materials are
 used in primers, release coatings, and  adhesive blends.  The 3M facility uses toluene and mineral
 spirits to clean the equipment and floors.

 C.    Manufacturing Process Profile

       The manufacturing process at the Bristol facility begins with the formulation of the coatings.
 A release coating prevents an adhesive from sticking to  a surface. For tapes, the release coating
 prevents the adhesive-coated surface from sticking to the backside of the tape during manufacturing
 and winding.  3M uses a release coating step in the manufacture of film and filament packaging
 tapes.  These low solids coatings are composed of resins, solvents, and additives.  The release
 coatings are manufactured in fixed or portable agitated mix tanks and transferred via a dedicated
 manifold system to the release coating application head.

       3M also manufacturers primers which bond the  natural rubber based adhesive to the film
 substrate. Raw materials in the primers include rubbers, solvents, and additives. The primers are
 manufactured by the same process as the release coatings.

       The 3M Bristol facility compounds both hot melt and rubber  based  (natural  and synthetic)
 adhesives.  The adhesives are made in  blenders and high-speed shear dispersers, called moguls, and
 then  transferred via dedicated transfer lines to the applicable coating heads.   The adhesive
 manufactured for the filament tape line uses natural or synthetic rubber dissolved in solvent mixtures
 for the specified viscosity.  Adhesive for the film tape line has a synthetic rubber (hot melt) base.

       The 3M Bristol plant operates two coating lines. The 5W line is dedicated to the manufacture
 of filament tape, while the 6W line produces colored film tapes.  The Bristol plant is the only 3M
plant in the United States that makes filament tape, a type of heavy-duty polyester or  polypropylene
packaging tape reinforced with filament strands. The 5W line operates 24 hours a day, 6 days a
 week, and 40 weeks per year with a maximum capacity of 115  yards  per minute and an average

                                           C-23

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        Ib-.

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       U 95r
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                               III
                PLOT PLAN
       Figure 1. 3M Bristol Facility Plot Plan.

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 capacity of 80 square yards per minute.  The line is typically shut down on Fridays for preventive
 maintenance and cleaning.  Sixteen different grades of tape are manufactured on the 5W line.  The
 differences between these grades are based on the type of film (i.e., polyester or polypropylene), the
 type and number of nylon or rayon strands per square inch, and the thickness of the coating applied.
 The highest grade (and profit margin) products are produced in the greatest quantity (e.g., 3.8 million
 square yards per year).

       The general process flow for the 5W line follows. Rolls of polyester or polypropylene film
 are placed on an unwinder.  The film passes through a gravure coater that applies  a solvent-based
 primer which averages 98 percent VOC (5.9 pounds VOC per gallon of coating less water). Solvents
 used in the 5W coating formulations include xylene, toluene, heptane, ethanol, and cyclohexylamine.
 After the film substrate is primed, it passes through a hot air impingement dryer with an airflow of
 6,000 scfm.  The exhaust from this primer oven is released to the atmosphere. The dry, primed film
 is then release coated with a gravure roller (96 percent VOC and 6.9 pounds VOC per gallon of
 coating less water) and moved through a second hot air impingement dryer. The exhaust from the
 release coat oven is also released to the atmosphere. The film then moves to a primary adhesive
 application stage where an adhesive averaging 4.9 pound VOC per gallon (81 to 82 percent VOC)
 is applied.  Following the adhesive coating, the film enters a two-stage oven equipped with inert gas
 solvent recovery. Once dry, the film and nylon or rayon filament strands  are laminated and adhesive
 coated. The second adhesive coating step is followed by a pass  through two stages of a six zone
 oven also equipped with an inert gas solvent recovery system, a third adhesive coating application,
 and a final pass through the remaining four stages of the oven.  Solvent recovery  in the adhesive
 ovens  on the 5W line is estimated to be 83  to 86 percent efficient  The product is then  wound,
 followed by slitting and packaging.

       The 6W  line operates 24 hours a day, 7 days a week, and 45 weeks per year with a line
 capacity of 425 yards per  minute.  The line is typically shut down for  four to  eight hours on
 Tuesdays for preventive maintenance and cleaning. The 6W line is capable of manufacturing 50 to
 60 varieties of film tape products.  Products are distinguished by film type, color, and film thickness.
 Eighty percent of the films run on the 6W line are polypropylene, 18 percent are polyester, 1 percent
 is polyvinyl chloride (PVC), and the remaining  1 percent are made with miscellaneous substrates
 (e.g. kraft paper, cellophane, etc.). The polypropylene and polyester film tapes and kraft paper tapes
 are used in box sealing applications.  Tapes made with cellophane and PVC films  are used for
 specialty applications such as taping clothing bags.  All of the products produced on the 6W line are
 sold to industrial customers.  Two of 3M's other facilities located in Greenville, South Carolina and
 Cynthiana,  Kentucky  make the same  product  for  consumer markets using similar equipment
configurations.

       Coating stations  on the 6W line consist of two precoaters and one functional adhesive
applicator.  The configuration of this line allows 3M personnel to use any combination of these three
coating stations.  A brief description of the 6W line and its current operating parameters follows (see
Figure 3).  Clear or colored films are loaded onto an unwinder. The film is guided by idling rolls
to Station 1, an enclosed coating operation, where a gravure roller is used to apply primers.  This
coating station operates on  average  one day (i.e., 24 hours) per month.  Waterbased primers are
                                           C-25

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  applied 16 to 20 hours each month while solvent-based coatings account for the remaining 4 to 8
  hours of operation.  The solvent-based (e.g., toluene, xylene, heptane, and isopropanol) coating
  formulations are typically pigmented and are used to change the properties of the film.  From Station
  1, the web moves into an enclosed release coat (low adhesive backsize - LAB) application station
  (Station 2).  This station also uses a gravure roller. Station 2 is used 100 percent of the time that
  the line is operating. Each of these two precoat stations (i.e.,  the primer and the LAB) is followed
  by a single stage oven. The next coating application station applies the functional hot melt adhesive
  using die application.  The coated film is then wound and moved to  the slitting operations.  No
  emissions control device is  used on this line as the hot melt formulation contains no solvents.
  Exhaust from both of the ovens is vented directly to the atmosphere.

  D.     Emission Reduction and Control Experience

        Emission control devices used by the 3M Bristol facility include the following:

  •      Inert gas solvent recovery ovens following adhesive application on the 5W filament tape line
  •      Baghouses in the rubber compounding and milling areas
  •      Baghouses in the converting area for detackifying operations
  •      Condensers on the release and primer blenders

        The solvent (i.e., heptane) that is recovered from the two adhesive solvent recovery ovens is
 recycled back into the adhesive.  3M has also installed (but is not operating) duct work to capture
 the air stream from the open web area (prior to the web entering zones  seven and eight of the inert
 gas solvent recovery oven) on Line 5W to improve the capture efficiency resulting in an overall
 control efficiency of over 90 percent  Plant officials hope to route  the flash-off stream to the
 facility's boiler for heat recovery.  The facility is currently waiting on permission from the State of
 Pennsylvania.

       In addition, 3M Company has plans to transfer the LAB coating of polypropylene that occurs
 at Station 2 on Line 6W to another facility with a sophisticated solvent recovery unit The Bristol
 facility would then receive primed and LAB coated polypropylene films from a sister facility and
 apply only the hot melt adhesive on the 6W line.  The elimination of these steps at the Bristol plant
 would allow the facility to reduce solvent emissions originating at the  6W line.  Emissions at the
 other 3M facility would  not be significantly affected by  the added coating application processes.
 Table  1 shows the Bristol facility's 1991 reportable Toxic Release Inventory (TRI) emissions. Table
 2 shows 1992 VOC emissions broken down by coating line.
E.     Equipment Cleaning Experience

       Because the 3M Bristol facility operates coating lines dedicated to one product category
(individual products may have different coating formulations), extensive cleaning is limited to
production downtime or significant product changeovers.  Normally, downtime, which consists of
scheduled downtime for preventative maintenance (i.e., Tuesdays for 6W and Fridays for 5W),
                                           C-26

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               TABLE 1.  3M BRISTOL FACILITY 1991 TRI EMISSIONS
Chemical
Toluene
Xylene
Ethylbenzene
Cyclohexane
Methyl Ethyl Ketone
Methanol
Zinc Compounds
Quantity (pounds/year)
910,000
12,000
1,200
102,605
1,400
7,600
11 to 499
Source
Stack
Stack
Stack
Stack
Stack
Stack
Fugitive
          TABLE 2. 3M BRISTOL FACILITY 1992 VOC EMISSIONS (TONS)

    Coater           1st Qtr.       2nd Qtr.       3rd Qtr.       4th Qtr.    Total
5W
6W
Total
202.5
79.6
282.1
172.4
97.7
270.1
202.7
96.9
299.6
135.5 713.1
110.6 384.8
246.1 1,097.9
downtime due to lack of line utilization, or quality imposed line shutdowns, is 1 percent of operating
time.  Production is scheduled to run compatible batches in sequence. When a product change is to
occur, the production operator will add only enough coating to the application troughs to coat the
length of film remaining on the substrate web. This allows the substrate web and the coating to end
at approximately the same time.  As the first web finishes, the second web is threaded and new
coating formulations are added to the application troughs.  In some cases, excess coating is drained
from  the application pans and coating lines back into storage drums.  The drummed material is
retained for future use.  Although mere is some product contamination with either scenario, the
substrate coated with the mixed coatings is the  last portion of the first roll or the first part of the
succeeding web. In either case this portion of the web, the makeready substrate, is discarded.
Makeready is generated regardless of substrate  and coating. This method of process changeover,
characteristic of large facilities running dedicated production lines, minimizes coating waste and,
consequently, minimizes required cleanup.  For  example, the  6W  line  often runs pigmented
adhesrves. Production jobs are scheduled to run from white to darker colors.  These changeovers
                                         C-27

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  may  generate several  thousand yards of  makeready  film,  most of  which  (i.e., all  of the
  polypropylene) is sold as scrap.

        More  significant product changeovers require more  cleaning.   In some cases, lines are
  stopped, application rolls are wiped down, and application trays are removed and replaced with clean
  trays.  The removed trays are then cleaned with toluene and made ready for  the next product
  changeover.   In-process cleaning is done as needed when coatings,  especially adhesives, spill or
  splash onto equipment housings.

        Cleaning operations at the Bristol facility may be separated into three primary categories (i.e.,
  in-process equipment cleaning, centralized parts cleaning, and miscellaneous cleaning) using three
  types of cleaning solvents (i.e.,  mineral spirits, toluene, and heptane).  The type and method of
  process equipment cleaning is based on the adhesive or coating formulation rather than on the type
  of film or substrate.  The coating application rollers on both the 5W and the 6W lines are cleaned
  using similar methods. The cleaning frequency, however, is slightly different Adhesive application
  rollers are the  most frequently cleaned piece of equipment, followed by the LAB application rollers.
  All of the coating rollers on the  SW line and the prime coat application roller on the 6W line are
  wiped with a  non-static rag  soaked in toluene  and then cleaned with a caustic solution.  Spot
  equipment cleaning (e.g., sides of dams and troughs and coating application heads) on both lines is
  done with toluene-soaked rags. Larger jobs, including the cleaning of piping,  pumps, ovens, and
  equipment housings,  are done with rags and mineral spirits.  If material has solidified on the
  equipment, toluene may  be used instead of mineral spirits. The hot melt adhesive roller on the 6W
 line is  cleaned using dry methods such as mechanical scraping.

        The Bristol facility operates four centralized parts cleaning areas.  One area is dedicated to
 the cleaning of pressure tanks, mix tanks, and tote tanks. These large pieces of equipment are
 transferred into the cleaning room equipped with exhaust fans  and an air make-up fan. The outside
 of the equipment is manually cleaned with rags, brushes, and mineral spirits, while internal tank
 components are cleaned manually with heptane, mops, and squeegees. The other centralized cleaning
 areas use parts washers  and are used to clean coating application heads, coating  troughs, material
 piping, and miscellaneous equipment parts. The  parts to be cleaned are placed in the solvent bath,
 soaked, and men scrubbed with brushes. Two of these stations use mineral spirits and the third uses
 toluene. All of the solvent employed in parts cleaning operations is used for a period ranging from
 three days to three weeks. Once they are no longer usable, the spent solvents are combined, declared
 waste, and transferred to drums which are sent off-site for fuel blending. (The waste solvent has a
 BTU value of 18,500). Cleaning rags that are no longer usable are also combined and sent off-site
 as hazardous waste.

       Miscellaneous  cleaning includes the cleaning  of product and raw material  storage  tanks,
 process lines, and floors. Routine floor cleaning is performed as needed using mineral spirits.  In
 general, storage tanks and process lines are dedicated and, therefore, do not require cleaning. The
 Bristol facility has been using high pressure water for these difficult and occasional (yearly) cleaning
jobs. A licensed contract facility, OHM, uses a solution of high pressure (12,000 psi) water, heptane,
 isopropyl alcohol, and salts to clean dry adhesives from process equipment, storage tanks, floors, and
                                           C-28

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 other equipment parts.  The wash water is contained and disposed of as hazardous waste (D001,
 Waste Flammable Liquid).  Because this type of service is rather expensive (/.«., approximately $800
 per day) and because it is costly to dispose of the waste (due to the low BTU value), 3M plans to
 discontinue this method of cleaning. No replacement cleanup methods have been identified.

       In 1990, the Bristol plant generated 1,366,000 pounds of solid hazardous waste (e.g., rags and
 adhesive/coating waste) and 847,000 pounds of waste cleaning solvent  Projected 1993 figures are
 23,800 pounds of solid hazardous waste and 26,000 pounds of waste solvent

 F.     Pollution Prevention Experience

       Much  of 3M's  pollution prevention experience  at the Bristol plant consists of avoiding
 cleanup and following  "best management" practices.  The facility uses centralized cleaning areas
 which limits  operator access to cleaning solvents.   In  addition, 3M recovers the solvent that
 volatilizes in the 5W ovens and recycles it back into the adhesive formulation.

       The Bristol facility has attempted to use citrus based  cleaners in slitting and packing
 operations. Although the cleaners performed well and resulted in no quality problems, they were
 cost prohibitive. The Bristol facility has not attempted to use citrus based cleaners on the coating
 lines.

       The Bristol facility has experimented with  silicon-coated, non-stick rollers,  but  due to
 durability problems, these rollers have not been used in the production process.  An alternative for
 silicone, which the Bristol plant does use, is flame-applied plasma coatings which prevent adhesive
 buildup on winding, idling, and tension rollers. Adhesive remaining on these rollers can be easily
 removed by hand. One difficulty that the Bristol facility faces with plasma-coated rollers is that they
 tend to encourage static buildup.  The buildup of static is a concern because if there is a spark the
 entire line could catch on fire.  To avoid this dilemma, 3M configures the equipment so that plasma-
 coated rollers  are not in series. Thick films are more susceptible to static than are thin films.

       The 3M research and development laboratories in St Paul, Minnesota are currently developing
 and evaluating low VOC coatings. The Bristol facility recently replaced the heptane-based precoat
 on  the 6W line with a waterbased acrylate for a short production-scale run.  Although the coating
did meet the production specification, it resulted in several manufacturing difficulties. Foam formed
in the application pan.  Some of the foaming effects which resulted from agitation  caused by the
gravure coater could be eliminated with an alternative application method such as flow bar coating.
Other difficulties include poor stability with heat and over time, increased dry temperatures, and
inefficient material transfer.
                                           C-29

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 TRC
                                                           TRC Environmental Corporation
                                                           100 Europe Drive, Suite 150
                                                           Chapel Hill, NC 27514
Environmental Solutions through Technology                        tf (919) 968-9900  Fax (919) 968-7557
    Date:        April 14, 1993

    Subject:      Site Visit - TesaTuck, Inc.
                 Pressure Sensitive Tape Manufacturer
                 EPA Contract 68-D9-0173, Work Assignment Number 3/309
                 TRC Reference No. 1637309

    From:        Beth W. McMinn and Jill B. Vitas
                 TRC Environmental Corporation

    To:          Mike Kosusko
                 Organics Control Branch
                 Air and Energy Engineering Research Laboratory (MD-61)
                 U.S. Environmental Protection Agency
                 Research Triangle Park, NC 27711

    I.
          As part of the overall effort by the U.S. Environmental Protection Agency (EPA) to
    identify areas for preventing the creation of pollution associated with manufacturing entities, EPA
    is currently reviewing the pollution prevention opportunities associated with equipment cleaning
    in the adhesives-coated and laminated paper industry. TRC Environmental Corporation (TRC)
    is supporting  EPA in this effort by developing prevention strategies for  laminated paper
    equipment cleaning under Work Assignment Number 3/309, EPA Contract Number 68-D9-0173.

          TesaTuck  Incorporated (Til), a pressure sensitive tape manufacturing facility, was
    selected for a site visit to collect information on the pollution prevention opportunities available
    for this industry  segment  The focus of pollution  prevention efforts in  this industry is on
    emissions of volatile organic compounds (VOCs) and air toxics. The purpose of the visit to TO
    was  to gather information  on their pressure sensitive tape manufacturing processes and to
    identify,  with input from the plant experts, any opportunities for preventing VOC emissions
   resulting  from the cleaning of equipment  Specific objectives of the trip were  to  collect
   information  necessary to characterize the plant  production processes,  equipment cleaning
   requirements and practices, and cleaning solvent recovery and disposal methods; and to witness
   first-hand any pollution prevention opportunities for pressure sensitive tape equipment cleaning
   operations.

         This trip report includes four sections.   Section n identifies  the location of the TO
   facility.   Section  HJ presents  the individuals who participated in  the site visit  Section IV
   includes the technical information compiled during the site visit
Offices in California, Colorado, Connecticut, Illinois, Louisiana, Massachusetts, New Jersey, New York, North Carolina, Pennsylvania, Texas,
Washington, Washington, D.C., and Puerto Rico                                                  A TSC Company

Pnnnd on Recyded Paper                               C"30

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       Place and Date

       TesaTuck Incorporated
       Crotty Road
       Middletown, NY  10940
       (914) 692-2826

       February 12, 1993

       Attendees

       TesaTuck. Incorporated

       Mark Harrison, Director of Environmental Affairs
       Stanley Williams, Plant Manager

       TRC Environmental Corporation

       Beth McMinn, Project Manager
       Jill Vitas, Task Leader

IV.    Discussion

       The discussion began with TRC reviewing the purpose of the visit and addressing EPA's
goals for pollution prevention analysis  for pressure sensitive tape  manufacturing and future
preventive activities.  During this meeting the following major areas were considered.

•      Market profile and general plant description
•      Manufacturing supplies
•      Manufacturing process profile
•      Equipment cleaning experience
•      Emission reduction and control experience
•      Pollution prevention opportunities

The meeting was followed by a tour of the production operations. Each specific topic addressed
in the meeting is discussed in detail below.
A.     Market Profile and General Plant Description

       TTI was bought by Tesa Incorporated, a German-owned company, in the 1970's. TTI
owns the Middletown plant, and two others in the United States: one in Carbondale, Illinois and
one in Sparta, Michigan. The Middletown facility was built in 1980 and the equipment that TTI
currently uses was installed in 1986. Approximately 260 employees are located at this facility,


                                        C-31

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 of which 214 are production staff.  The Middletown facility operates 6 days per week (the plant
 is closed every Saturday after 4:00 pm through Sunday), 24 hours per day.

        At  the Middletown facility, TTI manufactures both commercial  and industrial grade
 masking and duct tapes.  Industrial grade masking  tapes (painting tapes) serve the original
 equipment manufacturer (OEM) and  marine markets.  Currently 70 percent of the products
 manufactured at the Middletown facility contain solvent-based coating, with the remaining 30
 percent using waterbased coatings.

        The Middletown facility is located on 37 acres within two connected buildings that total
 approximately 180,000 square feet Masking tape is manufactured on two process lines; one that
 applies the saturant and release coatings and one that applies the adhesive. Adhesives and release
 coatings are  formulated in the mixing  area.   The mixed adhesives and  release coatings are
 transferred to the process lines via dedicated pipe/manifold systems. The duct tape process line
 is located in a separate building, where all mixing,  coating, and packaging are done in one
 continuous process line.
 B.     Manufacturing Supplies

        TTI uses a variety of hydrocarbon resins in their coating formulations.  Toluene is the
 main solvent used in the adhesive formulations, although small amounts of heptane and isopropyl
 alcohol are also used.  For cleaning, TTI uses mineral spirits, which can be incorporated into the
 formulation with no quality problems.
 C.    Manufacturing Process Profile

       Adhesive Mixing

       Adhesive mixing is a basic manufacturing requirement for the solvent-based adhesives
 used in the masking tape products manufactured at TTL  The adhesive provides the bond between
 the tape  and the substrate. Adhesive mixing begins with stock preparation.  Stock is prepared
 by blending natural and synthetic rubbers, hydrocarbon resins, oils, and filters in a compounding
 tank. The output is then directed to a two-roll sheeting mill where a sheet of adhesive stock is
 extruded, cooled, cut, and chopped into pellets for further processing.

       The pellets are then sent via conveyor to the mixing area where they are loaded into large
 mixers. Toluene, heptane, and spent mineral spirits are added to dissolve the stock into a slurry
 with 48 percent by weight solids. The solvent is pumped into the mixers with additional resins,
rubber, and oils to complete the adhesive formulation.

       The finished adhesive formulation is then either pumped into a storage tank for later use
or pumped directly to the coating equipment through a manifold system.


                                          C-32

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       Paper Tape Manufacturing

       A coating block diagram is presented in Figure 1.  To manufacture paper tape, the raw
 paper is bought from a vendor.

       The waterbased saturant  is applied to the raw paper  by a reverse roll coater (i.e.,
 Coater 1).  Once the saturant has been applied, the substrate web passes through a floating air
 oven. A thermal oxidizer is used to destroy any toluene or other emissions generated during the
 drying process.  The web is dried  to a specific weight   The waterbased release coat is then
 applied via a reverse gravure roller (i.e., Coater 2). The web passes through another floating air
 oven  which is also vented to the thermal oxidizer.  At this  point, the web is wound and
 transferred to the adhesive coating line where a solvent-based adhesive is applied by a heated
 reverse roll coater (i.e., Coater 3). The fully coated web then passes through a final oven to dry.

       Once the adhesive has been applied and dried the finished tape is allowed to cool, then
 slit and packaged to be sent to the warehouse for shipping.

       Duct (Cloth) Tape Manufacturing

       Duct tape manufacturing is similar to paper tape manufacturing except that the adhesive
 is calendared in a solid form to the laminated polyethylene film and cloth substrate.  The result
 is a cloth and film web which has the release coat applied on the film side. No solvent is present
 in the duct tape adhesive, which is 100 percent solids. However, toluene is present in the release
 coat TTI employs a thermal oxidizer to destroy the toluene or other emissions generated during
 diving of the release coat

 D.    Equipment Cleaning Experience

       TesaTuck regularly shuts down on Saturday at 4:00 p.m. During the shut down, operators
 thoroughly clean the equipment and floors surrounding the equipment Where it is possible, the
 equipment is wiped down with a rag soaked with mineral spirits. Til uses an aqueous detergent
 and water to clean the saturant head and drip tray.  The gravure cylinders are sent to E7E
 Products in South Carolina to be ultrasonically cleaned every 6 months.

       Mineral spirits has proved to be the best cleaner because of its low cost and ease of use.
 It is kept in small safety containers near the equipment so that the operator can access it easily.
 Spent mineral spirits is introduced back, into the adhesive  formulation. The film that is  left on
 the equipment from the mineral spirits does not cause a quality problem because the first 20 feet
 of the run will  remove it and will be discarded.  This "makeready" substrate would be disposed
 of regardless of the substance used to clean the equipment The spent mineral spirits from the
 duct tape line is  recycled to the masking tape adhesive formulations. TTI uses approximately
 1,000 gallons of mineral spirits per quarter.  Due to the environmental impacts of the toluene,
TTI strictly enforces the use of mineral  spirits instead  of toluene even though the toluene
                                          C-33

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                                cm oz.ee
                                \sa? £
                                 S oLvC^

                                TP STogAftE
9
                                                                                                                       STA.
                                            Figure 1. Tesa Tuck Coating Block Diagram.

-------
 provides better cleaning.  Accumulated spent mineral spirits (that are not used in the adhesive)
 are distilled and used as paint thinner when the operators paint the floors and fences in and
 around the facility.

        The equipment cleaned the most frequently at the facility is the saturator application head,
 which is cleaned continuously with water. The equipment that requires the most cleaning solvent
 (mineral spirits) is the adhesive coating application head and the calendar application head (duct
 tape line).

        The process lines and adhesive mixing tanks are cleaned by flushing with toluene and
 using  the spent cleaning solvent in the next batch.  The  paper tape reverse  gravure  roller is
 continuously and automatically cleaned with a water spray.
            has tried to use citrus based cleaners. Due to the high cost and poor cleaning power,
 they were not considered to be feasible. In addition, spent citrus based cleaners are considered
 to be hazardous waste.

 E.     Emission Reduction and Control Experience

       Currently, TTI has three thermal oxidizers that control VOC emissions from the ovens on
 the three process  lines.  Hoods have been  installed over the open web areas to provide for
 approximately  100 percent capture of the solvent emissions.  Each of these hoods is ducted to
 the incinerators.

       TTI is  gradually reducing toluene usage by replacing it with heptane.  TTI hopes to
 replace 50  percent of the toluene with heptane, since heptane is not a listed hazardous  air
 pollutant and because heptane is less harmful to the environment

 F.     Pollution Prevention Opportunities

       Possible pollution prevention opportunities at TTI include the conversion to waterbased
 adhesive formulations and greater use of coated rollers.

       In the discussion of waterbased adhesive formulations, TTI identified that production
 would decrease due to the length of time needed  to dry the waterbased formulations.  In order
 to maintain production at the current level, additional dryers would be needed.

       The use of coated rollers for the idlers and take-up rollers in the process line has become
industry standard.  These rollers provide the necessary  tension on the web while preventing the
adhesive from  sticking to the roller itself.   TTI purchases  their coated rollers from Plasma
Coating Corporation in Waterbury, Connecticut
                                          C-35

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Environmental Solutions through Technology
                                                               TRC Environmental Corporation
                                                               100 Europe Drive, Suite 150
                                                               Chapel Hill, NC 27514
                                                               » (91 9) 968-9900  Fax (91 9) 968-7557
     DATE:       April 1, 1993

     SUBJECT:    Site Visit - Nashua Corporation - Label Division
                  Label and Label Stock Manufacturer
                  EPA Contract 68-D9-0173, Work Assignment Number 3/309
                  TRC Reference No. 1637309

     FROM:       Geary McMinn and Scott Snow
                  TRC Environmental Corporation

     TO:          Mike Kosusko
                  Organics Control Branch
                  Air and Energy Engineering Research Laboratory (MD-61)
                  U.S. Environmental Protection Agency
                  Research Triangle Park, NC 27711
  I.
           Purpose
           As part of the overall effort by the U.S. Environmental Protection Agency (EPA) to
    identify pollution prevention opportunities associated with  manufacturing entities, EPA is
    currently reviewing  equipment cleaning practices in the adhesives-coated and laminated paper
    industry. TRC Environmental Corporation (TRC) is supporting EPA in this effort by developing
    alternative pollution prevention strategies for adhesive-coated and laminated paper equipment
    cleaning under Work Assignment Number 3/309, EPA Contract Number 68-D9-0173.

          Nashua Corporation, a label and label stock manufacturing facility, was selected for a site
    visit to collect information on the pollution prevention opportunities for emissions of volatile
    organic compounds (VOCs) and air toxics available in this industry segment  The purpose of the
    visit to Nashua was  to gather information on their label stock manufacturing processes and to
    identify  and discuss, with input  from the plant engineers, any opportunities for preventing
    emissions resulting from the cleaning of equipment  Specific  objectives of the trip were to
    collect information necessary to characterize the plant production processes, equipment cleaning
   requirements and practices, use of waterbased adhesive technology, waterbased equipment retrofit
   considerations, and cleaning solvent recovery and disposal methods; and to identify any pollution
   prevention opportunities for label stock equipment cleaning operations.

          This trip report includes four sections.  Section n identifies  the location of the Nashua
   facility.  Section  EQ presents the individuals who participated in  the site  visit  Section IV
   includes the technical information compiled during the site visit
Offices in California, Colorado, Connecticut, Illinois, Louisiana, Massachusetts, New Jersey, New York, North Carolina, Pennsylvania, Texas,
Washington, Washington, D.C., and Puerto Rico                                                   A TRC Company

Pnnleef or Pecyded faster                                C-36

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 H     Place and Date

       Nashua Corporation
       Label Division
       3838 South 108th Street
       Omaha, Nebraska 68144
       (402) 397-3600

       February 12, 1993
       Attendees

       Nashua Corporation - Label Division

       Dan Abraham, Process Engineer

       TRC Environmental Corporation

       W.  Scott Snow, Mechanical Engineer
       Geary D. McMinn, Environmental Scientist
IV.    Discussion

       The discussion began with TRC personnel stating the purpose of the visit, addressing
EPA's goals for the pollution prevention analysis for pressure sensitive  tape  and label
manufacturing, and identifying future preventive activities. During the meeting the following
major topics were discussed:

•      Market profile and general plant description
•      Manufacturing supplies
•      Manufacturing process profile
•      Equipment cleaning practices
•      Emission reduction and control experience
•      Pollution prevention  opportunities
•      Waterbased formulation experience

The meeting was followed by a tour of the site.  Each specific topic addressed in the meeting
is discussed in detail  in this report
                                        C-37

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  A.    Nashua Market Profile and General Plant Description

        Nashua Corporation began operating the Omaha, Nebraska, plant in 1966. The plant was
  originally built in 1959 and operated by the International Paper Company. The facility currently
  employs approximately 100 administrative and management personnel and 200 to 300 hourly
  production personnel.  The unionized Omaha plant operates 24 hours per day, 5 to 7 days per
  week depending upon customer demand.  The Omaha plant produces pressure sensitive labels,
  roll-stock, and custom label products. The Omaha facility, a tape plant in Albany, New York,
  and a coated products facility at the headquarters in Nashua, New Hampshire, all operate within
  Nashua's Coated Product's Group.

        Figure 1 shows the layout of the Nashua - Omaha facility.  There are three coating lines
  in the plant located in the coating room east of the glue filtering room.  All three coating lines
  at the Omaha facility have been grandfathered from environmental regulations.  Line 1 is an
  adhesive coater/laminator and currently coats with both solvent-based and waterbased adhesives.
  During  1991, Line  1 ran  100 percent solvent-based adhesives,  however, it currently runs
  approximately 50 percent solvent-based and 50 percent waterbased products.  Nashua engineers
  expect that  by the end of 1993, Line 1 will  function with 100 percent waterbased products.
 Line 2 is the release coating machine and presently applies both a solvent-based release coating
  and  a  100  percent solid-catalyzed  silicone  release coating.   Line 3 is  another  adhesive
 coater/laminator and currently runs 100 percent waterbased coatings that contain ammonia as a
 pH stabilizer (concentration of less than 1.0 percent in solution). Nashua currently collects and
 recovers  solvent vapors  from the drying ovens of Line 1 with a  carbon adsorption system at
 approximately 80 percent efficiency.

       Raw paper, the material used to manufacture label stock, was identified by Nashua as the
 highest cost item used in the manufacturing process at approximately $0.50 to $0.75 per pound
 depending on grade  and specification. The raw paper which is saturated with release coating is
 called label stock. Adhesive, which provides tack for the labels, is then applied to the label stock
 and a laminated backing is  added.  Adhesive  costs approach $1 per wet pound or $2 per dry
 pound.  Nashua indicated that approximately 0.33  pounds of adhesive is typically applied per
 pound of paper. After lamination, the label  material is ready for either shipment as a final
 product or further processing in the label-converting area.  The majority of business for the
 Omaha plant is label stock manufacturing.

 B.     Manufacturing Supplies

       Nashua considers the chemical composition of their coatings and supplies confidential.
They indicated that their 100 percent  solids release coating contains no VOCs and the solid is
considered the carrier. For the solvent-based  silicone release  coating, silicone is diluted with
tolusol, a heptane/toluene blend, which is considered the carrier.  Their waterbased adhesive
coatings also contain no VOCs and water is the carrier.  Nashua identified that there is no direct
correlation between VOC content of their adhesives and bond strength; however, a small amount
of water or solvent remains in the cured coating to prevent the product from becoming too dry


                                         C-38

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                          N
                          i
                                                    BOILER ROOM
WASTE TANK
                                        SHOP


                         GLUETANKS   |-|J   |\|H  HH'I +_
2
                                     r    •    •  r*^  •
                                      MAINTENANCE '
                                        AND LAB   I  i^i—
                       COATING ROOM
             \
                      SOLVENT ROOMS
    CHEMICAL   CLEANING ACRYLIC TANK
      AND
    OTHER RAW
    MATERIAL
    STORAGE
                           GLUE
                           FILTERING
                                               FINISHING ROOM
                                                           • U
                                                  SLITTING ROOM
17
                                                                      WAREHOUSE
                                                                                PRESSROOM
T OFFICES
                                                                                        o L_ir
                                                                                        DC   "
                                  Figure 1. Nashua Plant Layout

-------
  (thus lowering the tack). Nashua indicated that after drying, a small amount of water is added
  to their waterbased products by a mist system to prevent the loss of tack.

  C.     Manufacturing Process Profile

        General Process Description

        The manufacturing of labels at Nashua - Omaha consists of three basic steps: adhesive
  mixing, label stock manufacturing, and label converting. When the desired end-product does not
  require converting, the last step in this process is omitted. Adhesives are brought into the plant,
  mixed, and stored in process holding tanks.  Figure 2 presents a flow diagram of the label and
  label stock production processes.  Master rolls of raw paper are first coated with a silicone
  release liner and adhesive, and then are laminated with face stock.  After these steps, the label
  stock is cut and sized in the slitting room and is either sent to warehousing and shipping or
  processed in the label converting operations.  The Omaha facility produces between 200,000,000
  to 300,000,000 square yards per year of label stock and release backing. The facility receives
  and exports materials by both rail and track.

        Adhesive Mixing

        The purpose of label adhesives is to provide a bond between the substrate and the label
 stock.  Nashua indicated that they use a variety of adhesives in their manufacturing process.  The
 formulation of their solvent-based adhesives involves combining adhesive stock, natural rubbers,
 acrylic products, and other materials in large  steel mixing tanks.  Solvents used in their solvent-
 based adhesives include toluene and heptane. Waterbased adhesives are mixed in tanks with a
 fiberglass lining which promotes easier stripping and cleaning.  After mixing, the adhesives are
 pumped through stainless steel canister filters to process holding tanks.

        In order to achieve the proper level of initial tack, Nashua strives to manufacture a final
 product that contains less than 3 percent water for waterbased adhesives or less than 1 percent
 solvent for solvent-based adhesives.  Ammonia, which elevates the pH and serves as a stabilizer,
 is also present in small quantities (less than 1 percent) in waterbased adhesives.

       Label Stock Manufacturing

       The first step in label stock manufacturing is to create a coated release liner.  The solids
 silicone or  the silicone-tolusol mixture is applied to master rolls of raw paper on the Line 2
 coating machine.  The coated release liner is then dried in an oven heated by steam coils for
 approximately 5 to 10 seconds.  Any vaporized solvent is vented by the oven exhaust systems
 to the atmosphere. After diving, the coated release liner is wound onto rolls and transported to
either Line 1  or Line 3 for coating/lamination.   Excess silicone can  be  frozen  in air tight
containers for future use.
                                          C-40

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    Raw Paper
    Master Roll
     Silicons
  Coating Process
	Released to Air
     Adhesive
  Coating Process
    	Charcoal Activated
          Carbon Bed
    Lamination
      Process
        i
  Sliting Process
           Raw Paper
           Master Roll
           Finished
           Roll Stock
    Converting
      Process
        i
( Finished Labels  J
        i
   Warehousing
        i
     Shipping
       Figure 2.  Finished Label Production Process.

                         C-41

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        Nashua stated that their process lines run either solvent-based or waterbased adhesives,
 but typically require a downtime of approximately 24 hours to setup the coating heads when
 converting adhesives. Line 1 uses solvent-based adhesives consisting of natural rubber and resins
 dissolved in toluene or waterbased adhesives.  Line 3 uses only waterbased adhesives which are
 purchased ready to use.  Nashua adds some ingredients to improve the initial tack of these
 adhesives.

        The release liner is unwound and the silicone-coated surface is coated with an adhesive
 and cured in an oven.  The  drying ovens  on Line  1  are similar to  Line 2's except that the
 emissions are ducted to a carbon adsorption system. The reclaimed solvent can then be re-used
 in compounding adhesives. Line 3  dryers use direct fired burners and cannot process solvent-
 based adhesive products.  As the coated paper travels out of the oven, it is moisturized by a
 water spray mist and then laminated under pressure rollers with  the label face stock creating a
 three-layer lamination (face stock, adhesive, and release liner).  Wind and unwind rollers are
 wrapped with double-sided tape to help the  product stick to the rollers.

        Once  the product has finished drying and been rewound, it is transferred to the slitting
 room for cutting and sizing. Nashua has several high-speed slitting machines which cut the rolls
 of paper into narrow  widths for use on its own printing presses or for shipment as  finished
 product  Excess edge portions of the paper known as off-cuts are removed by a trim system
 which conveys the cut-offs to a cyclone separator, and ultimately to a dumpster for transport to
 the city landfill. The special cut rolls are moved to the pressroom for custom orders or the finish
 room (if the  product is being sold  to competitors or other processors) for packaging before
 warehousing and shipment as a finished product The warehouse  holds custom orders and stock
 label products awaiting shipment

       Label Converting Operations

       The slit laminate which is to be processed further is moved to the pressroom. In the
 pressroom, the laminate is loaded onto label presses where it may be die cut, perforated, and/or
 printed.  The waste matrix from the die cut is removed, rolled, and sent to the city landfill The
 inks used in the printing presses are waterbased.  A printing plate is required for use with the
press.  Nashua uses a photochemical etching  process to make these plates in the preparation
 department  This process uses  a perchloroethylene/butanol mixture as the etching  solvent
Nashua reclaims this solvent with a distillation unit

       After converting, the printed labels are wound into rolls  or fan-folded into sheets  and
boxed. The finished products  are sent to the warehouse for storage and shipping.
                                          C-42

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 D.    Equipment Cleaning Practices

       The function of an equipment cleaning product in the adhesives-coated and laminated
 paper industry is to break the bond between the adhesive and the metal (or other surface) being
 cleaned. Water solutions alone are normally ineffective for cleaning purposes. Nashua has found
 that products such as mineral spirits, 1,1,1-trichloroethane (TCA), and toluene successfully break
 the  adhesive  bonds.   Nashua has also tested many other materials for equipment cleaning,
 including mineral oils, xylenes, and citrus products.   Table 1 provides a summary chart of
 cleaning products Nashua is currently using and has proposed to use to clean process equipment
 The VOC content of cleaning products is estimated by the manufacturer and Nashua accepts these
 estimates for emissions calculations.

       Nashua is currently trying to replace toluene  in their cleaning operations in order to
 reduce toxic emissions.  Toluene is not recycled by Nashua due to its fire and explosive risk,
 evaporation, and low purchase cost TCA, another effective cleaner, which costs approximately
 $3 to $4 per gallon, is recycled on site using a distillation unit  Approximately 2,268 gallons of
 TCA are recycled a year. Nashua will be replacing TCA due to the phase out requirements of
 the Montreal Protocol.  Nashua has found that citrus based products are costly (up to $10 per
 gallon), do not effectively clean acrylic-based adhesives, and exude a strong, undesirable odor.

       Nashua uses several techniques to satisfy their various cleaning requirements.  Equipment
 is not cleaned on any specific time schedule, however, when tines are down for changeover, the
 rollers, filters, and  other equipment are normally cleaned.  Larger parts (such as  application
 rollers and adhesive filters) are cleaned in the glue rooms (Figure 1).  The cleaning solvents
 Nashua uses are stored in tanks and drums on site.  Dip cans containing cleaning  solvent are
 located in the plant near the machinery which  they service.  Most cleanup involves a wipe down
 using solvent-ladened cleaning rags. Nashua indicated that their operators have full access to the
 cleaning solvent storage areas.

       The fiberglass adhesive mixing tanks are cleaned by cutting the adhesive residue with a
 high-pressure water blaster.  The blaster cuts pieces of the adhesive off the tank wall which are
 then peeled away a section at a time. The adhesive residue is collected at the bottom of the tank
 and  removed for shipment  to the landfilL  The mixing tank cleaning system also uses a pit
 located under the tanks that captures the blaster water and transfers it to a special holding tank
 for delivery to the city water treatment system. During the mixing of adhesives in the fiberglass
 tanks, layers of  different adhesives are deposited on the tank walls.   Within these layers,
 microscopic "bugs" grow.  According to Nashua, the "bugs" present no product  contamination
 and are welcomed at the city landfill due to their ability to breakdown waste material

      Nashua uses  dedicated lines to  transport  the adhesives from the mixing tanks  to the
process holding tanks.   The waterbased adhesive lines are never exposed to air, therefore, the
adhesive does not harden in them as quickly as it does  in the solvent-based lines.   These
waterbased lines normally operate until a significant reduction in flow is identified, at which time
they are replaced rather than cleaned. Polyvinyl chloride (PVC) piping  was chosen for these


                                         C-43

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  TABLE 1.  SUMMARY OF CLEANING PRODUCTS USED AND PROPOSED AT
             NASHUA - OMAHA

                                                     Cleaning Products
 Area Cleaned                                    Used              Proposed

 Water-based adhesive mixing tanks                   W

 Solvent-based adhesive mixing tanks                 Tol                Tol

 Water-based coating lines                          H2O

 Solvent-based coating lines                         Tol

 Rollers (all)                                      Tol, TCA           MS

 Drip on edge of paper                             TCA               MO, MS

 Dryers (Water- and solvent-based lines)               MS

 Filters (stainless steel)                              Tol, TCA           MS

 Floor cleaning in production/mixing  area              MS                H2O

 Press plate etching                                 Perch              O

 Press roller cleaning                               IP A
Description of Terms:
H2O   - Hot water and scrapper
IP A   - Isopropyl Alcohol - (solution is approximately 10 percent IP A)
MO   - Mineral Oil
MS    - Mineral Spirits
O     - Octusol (Dupont replacement for Perch)
Perch  - Perchloroethylene/Butanol mixture
Tol    - Toluene
TCA   - Trichloroethane
W     - High pressure water wash
                                    C-44

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 lines due to removal convenience and low cost Nashua stated that some PVC piping has been
 replaced after approximately three years in operation.

        Nashua indicated that their largest daily cleaning problem is the metallic filters used to
 filter the  adhesive when transferred from the mixing tank to the process holding tanks.  These
 filters are removed from the lines and cleaned in a toluene bath using a scrub brush. The baths
 are changed approximately once every two weeks  and the waste  toluene is sent off site  for
 disposal.  Eventually, Nashua plans to have mineral spirits or another viable product replace  the
 toluene in the cleaning bath.  The product that does the best cleaning job on the filters will also
 be used to clean the application roller. The process holding tanks for the solvent-based adhesives
 are flushed with solvent This remaining solvent and any dissolved adhesive remain in the tank
 and mix with the next batch of adhesive. No product quality problems have been noted with this
 cleaning procedure.

        Nashua uses a putty  knife and a hot water spray to clean splashes and spills on  the
 machinery that  applies waterbased adhesives.  Waste adhesive  which contains less than  20
 percent water is sent to the landfill. Splashes and spills on the solvent-based adhesive machinery
 are cleaned with a putty knife and TCA soaked rags.  A TCA drip is used on the edges of  the
 application roller to prevent adhesive from flowing over the paper edge. In the future, mineral
 spirits or  a viable alternative will be used as an alternative to TCA.

        Mineral spirits are used to mop the floor of the mixing and production areas and are also
 used to clean the solvents trapped in  the dryer oven hoods.  In the pressroom, TCA and toluene
 are used to remove  dried, waterbased inks and adhesive from the presses and tooling. Isopropyl
 alcohol (approximately 600 gallons a year) is also used to remove inks from the rollers.

 E.     Emissions Reduction and Control Experience

       Nashua intends to replace the toluene and TCA used for cleaning processes by the end
 of  1993. Most emissions of toluene are fugitive and Nashua does not control or recycle toluene
 because of the explosive and fire hazards, the high cost of capturing toluene emissions, and the
 relatively  low cost of virgin toluene solvent Approximately 3,000 gallons of toluene are used
 on  an annual basis with 1,800 gallons being sent off site for disposal as hazardous waste.

       Nashua currently reclaims TCA by a distillation system.  Approximately 2,268 gallons
 (2,160 gallons from release coat and 108 gallons from adhesive line cleaning) of a total 2,520
 gallons of TCA are recycled annually with 200 gallons shipped off site as hazardous waste.
Nashua indicated that approximately 10 gallons of TCA are used for cleaning process holding
tanks after every product changeover. Approximately 600 gallons per year of isopropyl alcohol
are used to clean the printing press lines.

       Solid waste  from the Nashua facility includes paper waste from the cutting and slitting
processes, which is compacted and sent to the landfill Hazardous waste shipped off site includes
approximately 3,500 pounds per month of waste  adhesive, silicone,  paper, TCA, oil from


                                         C-45

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  machines, and perchloroethylene  still bottoms (used in etching printing plates).  Rags and
  absorbent socks (called "pigs") contaminated with VOC solvents arc considered hazardous waste
  and disposed of properly, while those containing no VOCs are sent to the landfill.

        Nashua's city sewer discharge limit allows for 100 ppm of total recoverable petroleum
  hydrocarbons in their wastewater discharge.  Nashua conducts tests once per month at the plant
  outfall to assure compliance.  Normally, the concentration ranges from 20 to 30 ppm.  In the
  past, adhesive mixes clogged the discharge  system, however, to avoid this,  the wastewater is
  currently stored in special tanks and shipped by truck to the city treatment facility, where it can
  be treated and sold as fertilizer. By the end of 1993, Nashua predicts that 95 percent of their
  wastewater will be disposed of at the city treatment facility.

        Nashua indicated that they recycle approximately 10 to 15 percent of total raw paper
  input Once the paper has been coated with silicone or adhesive, it cannot be recycled and is
  transported to the landfill.

        Other control experiences  at Nashua  - Omaha  include  floor vents, special  coated
  application and non-application rollers, and plant boilers. For proper ventilation, floor vents are
  used in the adhesive holding area and equipment cleaning area to collect and evacuate indoor air
  to the atmosphere.  Also, Nashua is currently testing different types of coated rollers (e.g., teflon,
 plasma, graphite) for the adhesives application and non-application processes.  These rollers are
 designed to simplify the equipment cleaning process by employing a less sticky surface. Finally,
 the plant boilers are located at the north end of the plant and are the only equipment in the plant
 requiring air emissions permits.

 F.    Pollution Prevention Opportunities

       Potential pollution prevention opportunities include the replacement of all toluene and
 TCA cleaning with a viable non-VOC solution.

       Nashua is currently in the process of converting their adhesive coatings to 100 percent
 waterbased solutions.  Since these products contain water and not solvents as carriers, most of
 the process emissions from the coating lines should be eliminated. However, equipment cleaning
 of these waterbased lines will remain a potential TCA fugitive emissions source. To prepare for
 this changeover, alternative  cleaning solutions have  been,  and are currently being, tested at
 Nashua.  These include products such as mineral spirits, mineral oils, and citrus based products.
 At the time of this site visit, no viable alternative had been found to completely replace the
 toluene and TCA used in equipment cleaning.

       Nashua's emissions reduction programs are extensive.  Any safety cans which contain
 toluene or TCA located next to the production equipment are spring closed. Also, tank cleaning
 baths are  covered and allow enough room for large equipment pieces to avoid overfilling the
tanks.  Nashua encourages its operators to scrape equipment before using chemicals as a final
wipe.  Finally, mats are provided around machinery to capture any spills which may exceed the


                                          C-46

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 capacity of the drip tanks, thus avoiding extensive floor cleanup. An outside service is employed
 to clean these mats.

 G.    Waterbased Formulation Experience
                  <*
       As previously mentioned, Nashua - Omaha  has  extensive experience in waterbased
 adhesives and plans to  phase out all solvent-based coatings by the end of 1993.  The major
 reason for this is  to comply with requirements of the Clean Air Act of 1990. Other reasons
 include fewer permitting/paperwork requirements, less restrictions by New  Source  Review or
 New Source  Performance Standards,  and elimination of  most hazardous waste  regulatory
 requirements.

       Equipment additions were needed to change from solvent-based to waterbased adhesives.
 First, a different configuration of rollers and a different gravure set-up are required on the coating
 machines.  The application roller must be designed to allow a greater thickness of waterbased
 adhesive to remain on the substrate.  Waterbased coatings do not penetrate  most substrates as
 well as solvent-based coatings and therefore must be thicker to penetrate any given substrate.
 Coating speeds must be reduced to accommodate the longer drying times required by waterbased
 adhesives.  All mixing  tanks, holding  tanks, filters, pumps, and piping must  be  retrofitted to
 prevent contamination from previously used solvent-based adhesives. Nashua has also coated the
 waterbased adhesive tanks with fiberglass to allow for cleanup with high-pressure (3,000 to 5,000
 psi) water.  Pumps used to transport waterbased adhesives must have  lower  horsepower and
 compression rates due to the lower viscosity and higher surface tensions of waterbased adhesives.
       Nashua does not anticipate losing much business due to the solvent-to-water adhesive
changeover because they have been able to find or formulate new waterbased adhesives to replace
most of the solvent-based products. However, some products require certain characteristics of
natural rubber that waterbased adhesives have been unable to provide (e.g., extremely cold
bonding, wet bonding, and peel and re-peel ability).

       Economic and environmental incentives are die primary reasons for Nashua's conversion
from solvent-based to waterbased adhesives.   Although waterbased adhesives cost more than
solvent-based  adhesives (more specialized adhesives may double the cost), adhesives costs are
not the driving costs:  raw paper costs drive the end-product cost  Nashua expects the increased
adhesive cost to have some effect on their cost to customers. Although the adhesives changeover
would  result in possibly  changing waste  streams by increasing water  usage  or by adding
waterbased products, the overall effect should be a reduction in total waste. The reduced waste
disposal costs  and permitting costs are two economic benefits. Nashua advised that any facility
wishing to switch to waterbased adhesives must first set goals and  then invest the time and
research to attain them.
                                         C-47

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 TRC
                                                            TRC Environmental Corporation
                                                            100 Europa Drive, Suite 150
                                                            Chapel Hill, NC 27514
Environmental Solutions through Technology                         « (919) 968-9900 Fax (919) 968-7557
   Date:         March 19, 1993

   Subject:      Site Visit - Rexham Industrial
                Coated and Laminated Substrate Manufacturer
                EPA Contract 68-D9-0173, Work Assignment Number 3/309
                TRC Reference No. 1637309

   From:         Beth W.  McMinn and Jill B. Vitas
                TRC Environmental Corporation

   To:           Mike Kosusko
                Organics Control Branch
                Air and Energy Engineering Research Laboratory (MD-61)
                U.S. Environmental Protection Agency
                Research Triangle Park, NC 27711
  I.     Purpose

        As part of the overall effort by the U.S. Environmental Protection Agency (EPA) to identify
  areas for preventing the creation of pollution associated with manufacturing entities, EPA is currently
  reviewing the pollution prevention opportunities associated with equipment cleaning in the adhesives-
  coated and laminated paper industry.  TRC Environmental Corporation (TRC) is supporting EPA in
  this effort by identifying and developing prevention strategies for coated and laminated substrate
  equipment cleaning under Work Assignment Number 3/309, EPA Contract Number 68-D9-0173.

        Rexham Industrial (Rexham),  a coated and laminated substrate manufacturing facility, was
  selected for a site visit to collect information on the pollution prevention opportunities available for
  this industry  segment The focus of pollution prevention efforts in this industry is on emissions of
  volatile organic compounds (VOCs)  and air toxics.  The purpose of the visit to Rexham  was to
  gather information on their coated and laminated substrate manufacturing processes and to identify,
  with input from the plant experts, any opportunities for preventing VOC emissions resulting from
  the cleaning of equipment  Specific objectives of the trip were to collect information necessary to
  characterize the plant production  processes, equipment cleaning requirements and practices, and
  cleaning solvent recovery and disposal methods; and to witness first-hand any pollution prevention
 opportunities  for coated and laminated substrate equipment cleaning operations.

       This trip report includes four sections.  Section n identifies the location of the Rexham
 facility.  Section HI presents the individuals who participated in the site visit  Section IV includes
 die technical information compiled during the site visit
Offices in California, Colorado, Connecticut, Illinois, Louisiana, Massachusetts, New Jersey, New York, North Carolina, Pennsylvania, Texas,
Washington, Washington, D.C., and Puerto Rico                                                  A TRC Company

Printed on Recycled Paper                               C~48

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       Place and Date

       Rexham Industrial
       P.O. Box 368
       Matthews, NC 28106-7003
       (704) 847-9171

       March 5, 1993
 ffl.    Attendees

       Rexham Industrial

       Gordon Miller, Manager of Safety and Environmental Affairs

       U.S. Environmental Protection Aeency

       Michael Kosusko, EPA Work Assignment Manager

       TRC Environmental Corporation

       Beth W. McMinn, Project Manager
       Jill B. Vitas, Task Leader


IV.    Discussion

       The opening conference began with EPA and TRC discussing the purpose of the visit, the
background of the coated and laminated substrate manufacturing project, EPA's goals for pollution
prevention analysis, the handling of confidential business information, and the resulting trip report
The opening meeting then proceeded with a question and answer period during which time EPA and
TRC discussed the following topics:

•      Market profile and general plant description
•      Manufacturing supplies
       Manufacturing process profile
•      Equipment cleaning experience
•      Emission reduction and control experience
•      Pollution prevention opportunities

The meeting was followed by a tour of the production operations.  Each specific topic addressed in
the meeting is discussed in detail below.

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  A.    Rexham Market Profile and General Plant Description

        Rexham is  a wholly  owned  subsidiary of Bowater PLC of England.  They currently
  own/operate 34 facilities in North America. Rexham sees a strong health, safety, and environmental
  compliance record as a competitive advantage.  Their customers seem to be looking for  "green"
  suppliers.

        Rexham is made up of four divisions:  Industrial Films, Printing and Packaging, Plastics, and
  Medicals.  The Matthews  facility is the Industrial Films Division Headquarters.  The facility is
  considered  a  custom converter,  producing  coated and laminated products in four categories:
  electronics/photographies, miscellaneous products, graphic arts,  and medical supplies.  One of
  Rexham's  electronic products is  a dry photo  masking agent  Photographic products consist of
  masking agents and photographic substrates.  Balloon hull material, a seven-ply laminate, is one
  example of products included in  the miscellaneous category.  The graphic arts products  include
  materials for reproductions and proofs. The main products  in the medical supplies category are
  surgical barriers.

        The Matthews facility began operation in 1963.  Since that time it has increased its operating
  schedule to an anticipated 7 days per week, 24 hours per day, 360 days per year in 1993. Rexham
  currently employs 275 people at the Matthews facility, of which 160 are production staff involved
 in the manufacturing of the coated products.  Figure 1  shows the layout of the facility.

 B.     Manufacturing Supplies

        Rexham's primary raw materials consist of coating formulations, solvents, and substrates.
 Rexham can work with many different coating formulations with a variety of resin bases, including
 but not limited to, acrylics, urethanes, and polyesters. The majority of the formulating and cleaning
 solvents used at the facility consists  of methyl ethyl ketone (MEK)  and toluene, with  smaller
 quantities of tetrahydrofuran, some esters, and some alcohols.

       The Rexham facility has the capability of handling a variety of substrates, including films,
 paper, foils, and foam.  Currently, about 90 percent of Rexham's products are manufactured with
 plastic film substrates, 9 percent with paper substrates,  and  the remainder is with foils and foam.

       Rexham  cleans process equipment with  the solvent that is incorporated in the coating
 formulation. For those processes that include mixtures of different solvents, Rexham typically will
 clean with the solvent in the highest concentration in the formulation.

 C.     Manufacturing Process Profile

       Although specific steps  vary by product type, Rexham's general manufacturing process
includes the following steps.   Incoming dry  raw materials are stored in their original shipment
containers (e.g., bags and fiber drums) in Warehouse  1 or 2.  Wet raw materials are stored in
designated drum storage or staging areas located throughout the plant  These materials are moved,
as necessary, to the central mix room where the  required coating formulation materials are blended

                                           C-50

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                                  Legend -
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                                   Evacuation  Procedure:
                           1. Al sound of eviicuitlinn olntin. piocced to the
                             •bosl* nvnllnble antl snle oxit Exll!
                           2. MOVB to ycxii Uopt/Teiirn nssc>nt>ly nroa and be
                              counted Movn nroinuJ ole'ior ot (anility II needed
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                           4 II omei(jcncy Is serious, please move back mid away
                              liom Inclllty nnd iillo* cmeiucncy vehicles by.
                                                                 Figure I.  Rexham facility layout.

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  with variable-speed dispersers in mix tanks or drums.  Due to the large number of products it
  manufactures, Rexham's mixing process can be very simple or very complex, and is modified to
  satisfy customer needs. Approximately 50 percent of the coatings used at the Matthews facility are
  premixed by a supplier, 10 to 15 percent are mixed in-house from raw materials, and the remainder
  are purchased blends that Rexham modifies by adding performance enhancing chemicals. Rexham's
  equipment  is capable of handling coatings  of any chemical composition (i.e.,  100 percent solids,
  waterbased, solvent-based, ultra-violet formulations).

        The mixed coatings are then pumped from 55-gallon drums or mix tanks through a manifold
  system to the coating application system. Substrate webs are also moved to the coating lines.  The
  coating is applied to the substrate web by an application roller. Once the coating has been applied,
  it enters  a  zoned oven which allows for uniform drying.  After the substrate is dried, it passes
  through a nip roller where it is laminated (if needed).  If multiple coatings are necessary the previous
  steps  are repeated.   The  product is then wound,  slit according  to customer requirements (if
  necessary), and then packaged and sent to Warehouse 1 or 2 for shipping.  Rexham operates on a
  "just-in-time" inventory concept, which allows for production of an order within 28 days of receipt

        Rexham operates eight coating lines, each configured to  run a particular type of product
 Table 1 contains a general description of each of the configurations Rexham uses.


 	TABLE 1. REXHAM COATING LINE CONFIGURATIONS	

  Number of Machines     Machine Width        Run Length      Number of Coatings
1
1
2
1
2
pilot coater
narrow
wide
wide
wide
wide

short
short
long
long
long
multiple configurations
1
1
1
2
multiple

D.     Equipment Cleaning Experience

       Rexham does not perform equipment cleaning on any specific schedule. However, due to the
relatively  short production runs and the custom nature of the specialty products that  Rexham
manufactures, cleaning between jobs is critical.  Therefore, at the end of each job, all application
equipment is thoroughly cleaned. Typically the coating line operator requests a drum of either virgin
or reclaimed cleaning solvent (e.g., primarily MEK or toluene - See Section B) from the mix room.
Although Rexham has attempted to use alternative cleaners, such-as mineral spirits, it describes the
cleaning results as "inadequate." The cleaning solvent drum is brought to the coating line equipment
and the operator pumps a small amount into a bucket  The operator wets a rag in the bucket and


                                          C-52

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 then wipes down die equipment The used rag is discarded in a hazardous waste drum which is sent
 off-site for disposal. The spent cleaning solvent is transferred to a "dump" drum which is either sent
 to the on-site still for recycling or sent off-site for disposal as hazardous waste.  The Rexham still
 currently reclaims solvent at the rate of 50 gallons per hour, 24 hours per day, 5 days per week.

       A machine that is anticipated to be idle for several days undergoes a cleaning regime similar
 to the process described for cleaning between jobs. This cleaning job, however, is more thorough,
 involves the disassembling of equipment, the cleaning of pumps, equipment housings, and ovens, and
 requires approximately 30 man-hours (e.g., five people each at six hours) to accomplish.

       Rexham operates a central cleaning  area with a solvent (MEK) bath and two ultrasonic
 cleaning units.   The ultrasonic cleaners are used  to clean the coating cylinders and very dirty
 adhesive reservoir pans and application roller carriages.  Rexham tried many cleaning solutions in
 the ultrasonic cleaner before finding one which would remove all the coatings  from the rollers.

       Where it is possible, the floors around the coating lines are covered with off-specification film
 substrates.  Although this film is normally mopped with cleaning solvent at the end of each shift, it
 does reduce the quantity of solvent that would otherwise be used to clean the  floors.  As the film
 floor coverings are ripped and become unprotective, they are disposed of as solid waste and replaced
 with another layer of off-specification film.

 E.    Emission Reduction and Control Experience

       Rexham is aware of EPA's 33/50 program but has made a corporate decision not to formally
 participate.  However, the company will meet the goals of the program over the next few years.

       Solvents are used in the  mixing of  the coatings  and in cleaning the process  equipment
 Solvent fugitive emissions result from the baths in the central cleaning area as well as  from the "on-
 the-spot" cleaning applications within the facility.

       The oven exhaust from two coating lines is currently ducted to a 4-bed carbon absorber. The
 removal efficiency of the carbon absorber is reported to be greater man 92 percent  Oven exhaust
 from two additional lines is ducted to a REECO™ regenerative thermal oxidizer (RTO),  rated at
 20,000 standard cubic  feet per minute, and achieving a destruction efficiency reported to  be 96
percent This control system achieves the Lowest Achievable Emission Rate (LAER) recognized by
EPA.  The remaining four lines are ducted  to a direct-fire incinerator, considered by EPA to be
Reasonably  Available Control Technology (RACT) for the industry.

       Rexham is planning to install total enclosures on all of their coating  lines to capture  and
control all VOC emissions from the process. Total enclosures  will also reduce operator exposure.
With the enclosure design that Rexham will construct, Rexham  does not anticipate difficulties with
operator access to lines and equipment
                                           C-53

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 F.     Pollution Prevention Opportunities

       Potential pollution prevention opportunities include: (1) reduction in the use of solvent to
 clean the floors, (2) reduction in amount of solvent used to clean the equipment, and (3) running the
 process line dry when possible.

       The most effective preventive technique for Rexham would be to reduce or eliminate the use
 of solvent for floor cleaning.  The operators currently cover the floor with off-specification film
 substrate, which is eventually disposed of as solid waste. Mopping the substrate-covered floors each
 shift with solvent may not be necessary.

       Another opportunity for Rexham would be to optimize the amount of cleaning solvent needed
 to achieve the required cleaning specifications.  Operators  would be restricted to this amount of
 solvent  It is anticipated that the optimum amount of cleaning solvent would be considerably less
 than what is currently being used.

       One additional pollution prevention technique would be to run the line dry. "Running dry"
 a line is an operating technique, occurring at the end of a production run, that involves adding only
 enough coating to the application troughs to coat the length of substrate remaining on the web. This
 allows the  substrate web and the coating to end at approximately the same time.  In some facilities,
 excess coating is drained from the application pans and coating lines back into storage drums.  The
 drummed material is retained for future use. This production technique minimizes coating waste and,
 consequently, minimizes required cleanup. It also requires operator attention and planning.

       Currently, Rexham uses waterbased formulations only at customer request Rexham said that
the industry is headed toward waterbased formulations to reduce emissions, but that phase-in of this
approach will be gradual.
                                           C-54

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RADIAN

MEMORANDUM
                    t
DATE:      September 30,  1992
SUBJECT:   Trip  Report  -  Shuford Mills
FROM:      John  Keith and Trent Zirkle, Radian Corporation
TO:        Improved Equipment Cleaning Project File

I.  PURPOSE
     The  purpose  of the  visit to Shuford Mills was to  learn  about
the methods  of  cleaning  adhesives coating equipment and  the
resulting multi-media  wastes generated from the cleaning.  The
visit was also  intended  to develop a working relationship between
Shuford Mills and the  U.S. Environmental Protection Agency  (EPA),
Air and Energy  Engineering Research laboratory  (AEERL) for
potential demonstration  projects.

II.  PLACE AND  DATE
     Place:  Shuford Mills
             Hickory, North Carolina
     Date:  June  25,  1992


III. ATTENDEES

     Shuford Mills
     William Little
     Andy Stimpson
     Bob Hollieway
     Radian Corporation
     John Keith
     Trent Zirkle
*M298-62/als.021
                               C-55

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 IV.  DISCUSSION

 1.  Project Background

      The U.S. EPA AEERL is conducting research and development
 projects for various industrial processes to identify, develop,
 and demonstrate applicable technologies that reduce waste
 generation (i.e., pollution prevention technologies).   The
 adhesives and coated paper manufacturing industry has  been
 selected for a pollution prevention research project focussed on
 reducing air emissions and multi-media waste generated by
 equipment clean-up.  Three of the 17 targeted chemicals
 identified in the EPA's 33/50 Program; methyl ethyl ketone (MEK),
 toluene, and xylenes, are typically used as solvents during
 equipment clean-up in this industry.  AEERL has contracted Radian
 to conduct the initial phase of the research project to;  identify
 current cleaning methods,  technologies,  and generated  wastes;
 identify current similar research efforts;  and determine
 pollution prevention (alternative)  technologies.   Shuford Mills
 has expressed interest in participating in  this research  project.

 2.   Shuford Mills Background

     The Shuford Mills Tape Division manufactures a variety of
 pressure sensitive tapes.   Pressure sensitive tapes do not
 require  water  or heat to activate the adhesive;  only a light
 rubdown  pressure is required to make the tape stick.   The major
 product  at  Shuford Mills'  Hickory,  North Carolina plant is
 masking  tape.  Approximately 500 to 600  people are employed at
 the Hickory plant.

 3.  Operation

     At  Shuford  Mills'  Hickory  plant,  manufacturing involves
three distinct coating  operations:   saturation,  backsizing or
release  coating,  and adhesive coating.   In  the saturation step,  a
paper backing material  is  saturated with a  water  based liquid
«M298-62/als.021                      C-56

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 latex material.  During backsizing, a water-based coating is
 applied to  one side  of the paper to prevent delamination and
 tearing,  to provide  water resistance, and to aid in unwinding and
 slitting.   In the adhesive step, a solvent based adhesive is
 applied to  the substrate on the opposite side of the backsize.

     The  three coating operations are sequential but not
 continuous.  Each coating step is performed on a separate process
 line.  However, each coating operation consists primarily of the
 same major  processes.  A roll of paper is unwound and the coating
 is applied.  The coated paper then passes through a drying oven
 where most  of the moisture and/or organic vapors are volatilized.
 For solvent based adhesives, the captured vapors are sent to a
 carbon adsorberfor recovery.  The release coating is water based,
 and the water is emitted to the atmosphere during drying.  After
 exiting the dryer, the coated paper is then re-wound onto a roll.

     Shuford Mills has three saturation lines.  As shown in
 Figure 1, raw paper  is unwound and run through a trough of latex-
 based saturant.  The saturated paper exits the trough and passes
 by a doctoring blade.  The doctoring blade controls the thickness
 and quantity of saturant applied to the paper.  The rollers and
 dams (or  ears) are only cleaned during shutdown, about once per
week.  A  toluene-soaked rag is used to wipe the equipment clean.
The toluene is stored in covered, five gallon buckets next to the
rollers.  Toluene left on the rag either evaporates or is
returned  to the bucket where the rag is stored.  Due to coating
material  that accumulates in the toluene cleaning solvent  in the
bucket, the toluene  must be periodically replaced.  The  "spent"
toluene is  recycled  as make-up solvent for the coatings
formulations.

     The  second coating operation, backsizing, is shown  in
Figure 2.   Coating is applied to the paper via a small coated
roller.  The roller  contacts a bath of coating material and
transfers the coating material to the paper as the roller

*M298-62/«ls.021                     C-57

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                 Raw Paper
Saturated Paper
2
00
                                                                                      Drying Oven
                                  Salurant
                                                        Figure 1.  Saturation

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                                                                                                         Saturated and Backslze Paper
Saturated Paper
                                                                               Drying Oven
                                                 Figure 2.  Backsizing

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 rotates.  A doctoring blade controls the thickness of the coating
 material applied.  Any rollers that may come in contact with the
• coated side of the paper are wrapped with a thin cellophane-like
 plastic sheet.  This sheet can be removed and discarded, instead
 of using solvent to clean the roller.

      The coating material on a given backsize line may be changed
 up to ten times per week.  When product quality allows, the
 rollers and troughs are not cleaned every time the coating
 material is changed.  Flow of one coating material to the trough
 is stopped.  Most of the coating material left in the trough is
 applied before flow of the next coating material starts.  This
 results in a brief period when the coating material is "mixed."

      When product quality dictates a more thorough cleaning to
prevent the mixing of coating materials,  a toluene-soaked rag is
used to clean the application roller and trough.   The toluene is
handled in the same way as described for the saturation
processes.

      The third coating operation,  adhesive coating,  is shown in
Figure  3.   Adhesive is applied via a coated roller.   The roller
is coated by contact with adhesive from a holding trough.  The
tip  of  the trough is butted against the roller.   A slow-rotating
metering roller controls the thickness  of the adhesive applied.
As with backsizing,  the adhesive on a given line may be changed
up to ten  times per week.   When product quality  allows, the
equipment  (rollers,  trough,  ears)  are not cleaned every time the
adhesive  is  switched.   As with the backsize,  brief periods of
"mixed"  adhesive will  be applied.

     When product quality dictates that no "mixed" adhesive be
used, flow of  the adhesive to  the  trough is stopped by closing a
valve on the feed pipe  to the  adhesive  header.   Figure 4 shows
the adhesive feed equipment  and the trough.   After the feed pipe
is closed off,  the  valve from  the  header  to the  trough is closed.
The adhesive left in the header is drained into  a bucket and
4M298-62/als.021
                               C-60

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                                                                                                                  Saturated.Backslzed, and
                                                                                                                   Adhesive Coated Paper
                                   Adhesive Header
                                                        Metering Roll
2
     Saturated and Backslze Paper
                                                                                       Drying Oven
                                                    Figure 3. Adhesive Coating

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£
to
                       From Adhesive Storage
                                  Adhesive
             Rotating Pipe Joint
       Drain Pipe
             Residual Adhesive1
             Collection Drum
Drum
                 (Material Recycled as Raw Adhesive)
                           Side View
                              From Adhesive Storage
                                                        Header
                                                   Valves
                                                  ^    Drain Pipe
              I      I


.X.


Trough
Roller
1
Residual Adhesive
 Collection Drum
                                        Front View
                                         Adhesive Header (Not To Scale)
                                                                                          Drum
                                     Figure 4. Blow-Up of Adhesive Header

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recycled.  While the paper is still being run through  the
rollers, a putty knife is used to scrape as much coating
materialas possible from the trough and ears to the point  where
the trough and the roller meet.  This allows the scraped coating
material to be applied to the substrate.  Finally, a toluene-
soaked rag is used to wipe the equipment clean.

4.  Solvent Usage

     Toluene is the only cleaning solvent used at  Shuford  Mills.
All spent toluene from cleaning is recycled as make-up solvent in
product formulations.  No estimate of the amount of toluene used
for cleaning was made.  Shuford Mills is planning  to install a
metering system to track where toluene is used.  The largest
cleaning use of toluene occurs when the substrate  tears during
the adhesive coating process.  When this happens,  coating
materials get on a dry rubber roller.  Approximately 2.5 to 3
gallons of toluene are needed to clean this roller.  No estimate
of how often the substrate tears was available.
*K298-62/als.021
                                C-63

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RADIAN
COMVOKATIOM

 MEMORANDUM

 DATE:     September 30, 1992
 SUBJECT:  Trip Report - FLEXcon Company, Inc.
 FROM:     John Keith, Radian Corporation
 TO:       Improved Equipment Cleaning Project File

 I.  PURPOSE
      The purpose of the visit to the FLEXcon Company, Inc.
 (FLEXcon) was to learn about the methods of cleaning adhesives
 coating equipment and the resulting multi-media wastes generated
 from cleaning.   The visit was also intended to develop a working
 relationship between FLEXcon, U.S. Environmental Protection
 Agency,  Air and Energy Engineering Research laboratory (AEERL),
 and the Massachusetts Office of Technical Assistance (MOTA) for
 potential demonstration projects.

 II.   PLACE AND  DATE
      Place:   FLEXcon Company, Inc.
              Spencer,  Massachusetts
      Date:  May 4,  1992

III.  ATTENDEES
      U.S.  EPA AEERL
      Michael  Kosusko
      Mass  OTA
      Paul Richard,  Jr.
      FLEXcon
      Darwin Irish
      Charles  Schultz
      Radian Corporation
     John Keith
3M298-62/«U.021
                                C-64

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IV.  DISCUSSION

1.  Project Background

     The U.S. EPA AEERL is conducting research and development
projects focussed on various industrial processes to determine,
develop, and demonstrate applicable technologies that reduce
waste generation  (i.e., pollution prevention technologies) with
special interest on air emissions of 17 targeted chemicals.  The
adhesives and coated paper manufacturing industry has been
selected for a pollution prevention research project focussed on
reducing air emissions and multi-media waste generated by
equipment clean-up.  Three of the 17 targeted chemicals; methyl
ethyl ketone (MEK), toluene, and xylenes, are used as solvents
during equipment clean-up.  AEERL has contracted Radian to
conduct the initial phase of the research project to; identify
current cleaning methods, technologies, and generated wastes,
identify current similar research efforts, and determine
pollution prevention (alternative) technologies.

     FLEXcon, through Mass OTA, has expressed interest in
participating in this research project.  MOTA is a State funded
program that offers free technical assistance to industry..
2.  FLEXcon Background

     FLEXcon manufactures adhesive coated products.  The
substrates that the coatings are applied to are  mostly  paper,  but
include some synthetic plastic films.  FLEXcon has  13 production
lines in Spencer, Massachusetts, with additional production
capability in Connecticut and Minnesota, and warehousing
operations in Kansas.  FLEXcon employs approximately 900
employees in Spencer, Massachusetts.
3M298-62/«ls.021
                                C-65

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      Massachusetts industries are subject to compliance with the
 Massachusetts Toxic Use Reduction Act  (TURA).  TURA mandates that
 industries monitor and reduce the generation of multi-media
 wastes prior to any control, capture, or recycling/reuse efforts.
 In response to TURA, FLEXcon has implemented a company wide
 pollution prevention program to reduce the generation of wastes.
 FLEXcon's program is modeled after their quality control program
 and uses employee teams made up of operations staff, management,
 maintenance, engineering,  and research and development staff.
 The teams focus on different production areas to identify,
 monitor,  and reduce multi-media waste generation.

      FLEXcon's efforts to date include; tracking the amounts of
 solvents  used and wastes generated during clean-up, working with
 adhesive  vendors to identify alternative formulations or products
 that have reduced solvent content (e.g., water based adhesives)
 and investigation into a distillation unit to reclaim waste
 solvents  for reuse.

 3.   Operations

      A  generic process schematic of  an adhesives coating line is
 shown on  Figure  1.   The FLEXcon coating lines were the same,
 schematically.   The  substrate  is run past the application roller
 where the coating  is applied.   The coated substrate then moves
 through an oven  with different  temperature zones.   The coating
 dries, and,  in the case of  resin based coating,  cures in the
 oven.  Most  of the solvents in  the adhesive  coating volatilize in
 the oven.  The final coating on  the  product  typically contains
 less  than 0.5 percent  solvent by weight.   The coated product is
pressed onto a silicone  coated backing is rolled and moves to
cutting and sheeting operations.   In cutting and sheeting,  the
large rolls of product  are  rerolled  and cut  into smaller rolls or
cut into sheets and stacked.
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                                C-66

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                                            To Air Emissions

                                            Control Device
                         Adhesive
   Solvent
  Emissions



/    1    \

Substrate
Adhesive
Application


Oven
(drying & curing)


Backing
&
Rolling


Cutting
&
Sheeting
Finished

n
                                  Figure 1. Schematic of Adhesives Coating Operation

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                                                                           Doctor Blade
oo
                                  Flush Bottle
Copllcatlon
  •
 Roll
                                                                                       Drum of Adhesive
                                   Figure 2.  Adhesive Application Equipment Schematic

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      For adhesive  coated  paper production, most  equipment cleanup
 occurs  at the application section of the coating line.   Figure
 2shows  the configuration  of the adhesive application  equipment
 used at FLEXcon.   The  adhesive is pumped from  a  drum  to  a
 reservoir that allows  the adhesive to contact  each  of the two
 rollers.   The reservoir is made up of three pieces; the  trough,
 and  two dams.   The positioning of the reservoir  directly impacts
 the  thickness of the adhesive applied.  The space between the
 metering roll and  application roll and the speed of the  metering
 roll, application  roll, and the substrate also control the
 thickness and quality  of  the coating.  The doctor blade  removes
 excess  adhesive from the  surface of the metering roll before
 emersion into the  reservoir.  The two flush bottles provide a
 continuous drip of toluene which dissolves and flushes away any
 adhesive at the dam a  metering roll interface.   Without  the
 toluene flush adhesive builds up on the ends metering roll.
 Excessive build up of  adhesives can force the  rolls apart which
 impacts the thickness  of  the coating.

     The  wastes generated by cleaning are waste  adhesive and
 toluene and associated emissions from the flush  bottles,  and the
 waste adhesive and MEK and associated emissions  from  cleaning the
 three reservoir components, rolls, doctor blade,  pump, and hoses.
 Additionally,  the  waste collection tray is also  cleaned  during a
 "super" clean-up which occurs less frequently.

     A  clean-up was not conducted during the site visit  so no
 specific  details regarding clean-up can be presented. However,
 the general clean-up method was described after  the tour.

     The  pump  and  hoses are cleaned by flushing  them  with MEK.
The three reservoir components are removed and soaked in a MEK
bath.  The rolls and doctor blade are wiped with rags saturated
with MEK.  Clean-up generates approximately 15 gallons of MEK
waste.  During a super clean-up the waste collection  tray is
wiped down with MEK, and  the doctor blade is removed  and soaked
 in an MEK bath along with the three reservoir  components.
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                                C-69

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                                  TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
  1. REPORT NO.
   EPA-600/R-94-007
                                             3. RECIPIENT'S ACCESSION NO.
  4. TITLE AND SUBTITLE
   Improved Equipment Cleaning in Coated and
    Laminated Substrate Manufacturing Facilities
    (Phase I)
                                             5. REPORT DATE
                                              January 1994
                                             6. PERFORMING ORGANIZATION CODE
  7. AUTHOR(S)
   Beth W.
Me Minn and Jill B.  Vitas
                                                         8. PERFORMING ORGANIZATION REPORT NO.
              CH-93-100
  9. PERFORMING ORGANIZATION NAME AND ADDRESS
   TRC Environmental Corporation
   100 Europa Drive, Suite 150
   Chapel Hill,  North Carolina  27514
                                                         10. PROGRAM ELEMENT NO.
                                             11. CONTRACT/GRANT NO.
                                              68-D9-0173, Task 3/309
  12. SPONSORING AGENCY NAME AND ADDRESS
  EPA, Office of Research and Development
  Air and Energy Engineering Research Laboratory
  Research Triangle Park, NC 27711
                                             13. TYPE OF REPORT AND PERIOD COVERED
                                               Task Final; 11/92 -  6/93
                                             14. SPONSORING AGENCY CODE
                                              EPA/600/13
  is. SUPPLEMENTARY NOTES AEERL project officer is Michael Kosusko,  Mail Drop 61,  919/541-
  2734.
  16. ABSTRACT'
           The report gives results of a Phase I study to characterize current equip-
  ment cleaning practices in the coated and laminated substrate manufacturing indus-
  try, to identify alternative cleaning technologies,  and to identify demonstrable tech-
  nologies and estimate their emissions impacts.  It presents information from  sources
  including literature searches,  industry questionnaires, plant visits, pollution pre-
  vention experts, and industry and trade  association personnel. (NOTE: Phase II  ac-
  tivities will be the actual demonstration of selected alternative technologies,  and
  Phase III will be to transfer related technology by means of conference papers, jour-
  nal articles, and newsletters,  prepared and presented at industrial workshops, pol-
  lution prevention conferences,  and other events where industrial application of pol-
  lution prevention technologies is discussed. Facilities within this industry tend to
  operate in one of two segments: (1) large facilities operating coating lines dedicated
  to one  type of product, such as masking tape or label  stock; or (2) batch processors
  or plants  that manufacture comparatively small quantities of a wide variety of high
  value-added products.   Both segments of the industry use essentially the same clea-
  ning methods, even though the segments differ substantially in the range of sub-
  strates, coatings,  and application equipment used at the plants.
17.
                              KEY WORDS AND DOCUMENT ANALYSIS
                 DESCRIPTORS
                                            b.lDENTIFIERS/OPEN ENDED TERMS
                                                         c.  COSATI Field/Group
 Pollution
 Cleaning
 Coatings
 Laminates
 Manufacturing
 Emission
         Solvents
         Polymers
Pollution Control
Stationary Sources
13 B
13H
11C
11D
05C
14G
11K
07D
18 DISTRIBUTION STATEMENT

 Release to Public
                                19. SECURITY CLASS (This Report 1
                                Unclassified
                                                                     21. NO. OF PAGES
                             195
                                20. SECURITY CLASS (Thispage)
                                Unclassified
                                                         22. PRICE
EPA Form 2220-1 (9-73)
                              C-70

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